ML20211J178
| ML20211J178 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 04/17/1984 |
| From: | Parks R GOVERNMENT ACCOUNTABILITY PROJECT |
| To: | |
| Shared Package | |
| ML16341D790 | List:
|
| References | |
| NUDOCS 8606260261 | |
| Download: ML20211J178 (133) | |
Text
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n Exhibit 2 l
1 My name is Richard D. Parks. I am submitting this affadavit to document the discrepant conditions identified, and corresponding violations of the applicable codes as a result of the plant tour conducted on April II,1984 with D. Kirsch and G. Hernandez of Region V, United States Nuclear
- a Regulatory Commission (NRC) at the Diablo Canyon Nuclear Power Plant.
I and three witnesses accompanied the NRC to provide " hands *on" examples of non-compliance with regulations, specifications and codes that form the basic cornerstone of a comprehensive Quality Assurance /Ouality Control program.
Each example identified to the NRC was subsequently " tagged" for identification and a "repart sheet" was filled out by the NRC. The " problem description" is a quote from the report sheet. The examples identified that violated applicable codes are discussed as follows:
ITEM #1, Tag #2: Elevation 116, Unit 1 Reactor Building. Line l
Designation NO.S2-254-10, in the area of Pressurizer and Reactor l
Coolant Pump 1-2.
Problem
Description:
Weld attaching Safety Injection Accumulator line to nozzle of the cold leg line (NO.S2-254-10). On the side facing Reactor Coolant Pump (RCP) is a grinding gouge in the pipe.at the pipe-weld interface approximately 3/8 inches long,1/8 inch at 8606260261 860611 PDR ADOCK 05000275 U
PDR Devine Exhibit 8
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widest point and 1/16 inch deep (dimensions as visually determined by NRC Inspector - no measurements taken"). Additionally, there appears to be a slight amount of undercut at two locations. The undercut is approximately 5/8 inches on the weld side facing the RCP. and approxi-mately 1 inch at 120 from the side away from the RCP,
.:..v Code Violation: American Society of Mechanical Engineers (ASME)
Section III, " Rules for Construction of Nuclear Power Plant Components - 1977 edition, Division I General Requirements, Subsection NB, " Class 1 Components", para NB-4424 " Surfaces of W Ids".
"As-welded surfaces are permitted, and for piping the appropriate stress indices given in Table NB-3683.2-1 shall be applied. However, the
- s urface of welds shall be sufficiently free from coarse ripples, grooves, overlaps, and abrupt ridges and valleys to rneet (a) through 1
(f) below:
(a)...
(b)...
(c) Undercuts shall not exceed 1/32 inch (0.8mm) and shall not encroach on the required section thickness.
(d)...
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(e)...
(f)If the surface of the weld requires grinding to meet the above criteria, care shall be taken to avoid reducing the weld or base metal below the required thickness."
The discrepant condition identified by the witness violates the code requirements with respect to being " free from coarse rippies, grooves, overlaps, and abrupt ridges and valleys to meet (c) and (f)."
ITEM #2. Tag #4: Unit 2 Reactor Building, Elevation 115, Support 97-3R in vicinity of RCP 2-3.
Problem
Description:
"Exr:essive overweld ha: caused excessive shrinkage of SS line. This was supposed to be a full penetration weld with fillet cap and is as specified. The overwelding can damage the pipe because calculations don't account for residual stresses caused by such overwelding."
Code Violation: United States of America Standard (USAS) B31.7-1969
" Code for Pressure Piping - Nuclear Power Piping" (note: this standard now is known as ANSI-B31.7), foreword " FABRIC ATION REQUIREMENTS AND THEIR CORRELATION WITH DESIGN", page XVI paragraph 5.
"Even hanger attachment details are covered. For Class 1 piping, complete penetration welds are required. The designer must consider 1
all stresses in the attachment as well as their effect on the pressure
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retaining part."
The welds in question do not conform to the stated intent of the
" Nuclear Power Piping" code with respect to the residual stresses induced by the overwelding. It is the concern of this particular anon-ymous witness that these residual stresses should have been but were not a factor in the design calculations.
ITEM 43, Tag #5: Unit 2 Reactor' Building, large restraint wall attachment (around surge line), beneath Unit 2 Pressurizer.
Problem
Description:
"Shopwelding is supposed to conform to AWS D1.1 standards. The inner welds are excessively rough and of such a profile that they would not conform to AWS D1.1 The welds are ragged."
Code Violation: American Welding Society (AWS) Structural Welding Code - Steel, paragraph 8.15 " Quality of Welds", subparagraph 8.15.1 "Vis ual Inspe ction". "All welds shall be visually inspected. A weld shall be acceptable by visual inspection if it shows that 8.15.1.1
-The weld has no cracks 8.15.1.2 Thorough fusion exists between adjacent layers of 3
weld metal and between weld metal and., base metal l
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t 8.15.1.3 All craters are filled to the fuit cross section of the weld 8.15.1.4 Weld profiles are in accordance with (para.) 3.6 (w, eld profild "
The weld in question does not conform to the requirements specified in paragraph 3.6 [ weld profile @ or the evident thorough.fesion requirements as stated in 8.15.1.2.
ITEM G4, Tag #6: Unit 2 Auxiliary Building, area GW, elevation 115, i
line No. 2-52-265-8 (Containment Spray Discharge Pipe - 4 lug attachments between S and T line.)
Item De.c ription: " Lug attachments are called out to be 1/2 inch fillet welds on three sides. Actual size is 7/16 inch fillet or less."
Problem
Description:
" Actual size is alleged to be less than or equal to 7/16 inch which is 1/16 inch less than required. The excessive welding used in the design of the lugs attachment welds, when welded to Schedule 10 stainless thin wall pipe, has caused excessive shrinkage.
The excessive shrinkage causes residual stresses in the pipe which has not been accounted for in the design or stress analysis. The position of the clamp is such that there is a torsional force applied to i
6.
- es the lugs, because the clamp cannot contact the wall of the pipe due to the shrinkage. This torsional force is not accounted for in the design and compromises the pipe integrity."
Code Violation: Refer to " Code Violation" discussion in " ITEM #2, Tag #4".
2...
The welds in question do not conform to the stated intent of the I
" Nuclear Power Piping" code with respect to the residual stresses induced by the welding or the torsional force applied to the lugs due to exces sive shrinkage. It is the concern of this particular anonymous I
witness that these stresses should have been but were not a factor in
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the design calculations.
ITEM #5, Tag #7: Unit 2, Auxiliary Building, Area 2H, support 413-131R around CCW line.
Problem Des cription: "Eight lug attachment welds are required to be full penetration welds on three sides. Actual weld is not a full pene-tration weld, but is, instead a fillet weld, contrary to the design."
i Code Violation: American Welding Society (AWS) - A2.4 - 79
" Symbols for Welding and Non-Destructive Testing," paragraph 9.0
" Groove Welds," subparagraph 9.2.2 " Complete Joint Penetration R e quire d. " "When no depth of groove preparation or effective 1
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throat is shown on the welding symbol for single-groove and symmetrical double-groove welds, complete joint penetration is required."
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Symbol provided on "Dstail" for weld (s) in question.
PG and E has stated in their letter, DCL-84-040, "The. weld symbols used at Diablo Canyon are consistent with the standards specified in AWS... " and in an Interoffice Memorandum (file no. 930, 146.20, CA2) dated October 25, 1983 that "all pipe support as-builts issued by General Construction after October 15, 1983 should have di weld symbols in conformance with AWS A2.4."
The welds in question were incorrectly performed because of lack of proper interpretation of the weld symbol utilized on the design drawing.
It is the concern of this particular anonymous witness that this discrepancy provided an example of code compliance violation due to a lack of intimate knowledge with AWS A2.4. These particular welds had been inspected and accepted by Pullman Quality Control and PG and E
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Ouality Control prior to the discrepancy being identified by a Pre-Inspection Engineer.
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1 I have read the above eight page statement. I have baped the information contained therein either on personal knowledge or by reviewing the relevant information with the particular witness involved. This statement is true, correct and complete to the best of my knowledge and belief.
I declare under penalty of perjury that the foregoing is true and correct, and that the sa:ne was executed this 17th day of /drii',1984 at San Inis Obispo, California.
L. h4 RICHARD D. PARKS, clarant STATE OF cal.IFORNIA
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CDLWIi Of SAS 11 TIS OBISPO )
On April 17, 1984, before Ine, the undersigned, a Notary Public in for said State, personally appeared RICHARD D. PARKS, personally known to Ine and proved to Ine on the basis of satisfactory evidence to be the person whose name is subscribed to the within instnznent, and that he executed the same.
WIEESS rry hand and official seal.
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t.!3A P. WENTER W4 0 a, J lio b t',g?,.:- < r ac. cAurcarra Notary Publib in and for d,[,I.Ns)lfjf.
said County and State
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l AFFIDAVIT 1
My name_is Harold Hudson.
I have worked for 5 years at Diablo Canyon, as a Pullman Power Products pipefitter, QA/QC inspector, QA program Internal Auditor and Lead Auditor.
I am I
about to resign my job, in large part~because of my family's fears about the safety of the plant if it begins commercial operation.
I am providing this statement to answer a myth --
that quality assurance at Diablo Canyon was acceptable because y
problems were identified -- through a case study -- pipe smypent rupture restraints.
Problems indeed were identified, which is one of the three steps necessary for a good audit or QA program.
But it is not sufficient.
The problems kept recurring.
That is be-cause the QA program failed in its second and third responsibil-ities -- identifying any similar deficiencies that exist; and identifying and addressing the cause of the problem, to prevent i
recurrence.
Repetitive cases of previously identified violations l
represent a deliberate quality assurance breakdown, not a success.
The history of the pipe rupture restraint program is j
a series of repetitive violations.
l A History of the Pullman Power Products (M.W. Kelloco)
Pice Ruoture Restraint Construction Procram at the Diablo Canyon Nuclear Plant, California.
Prepared by Harold Hudson 5/26/84 Pullman Pcwer Products (M.W. Kellogg Co.) was contract'4d'by the Pacific Gas and Electric Company to install piping, pipe supports I" l/ r 1
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Devine Exhibit 9 l
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end pipe rupture restraints at the Diablo Canyon Nuclear Plant.
Pipe Rupture Restraints are used to insure that if a pipe filled with steam or pressurized water rupture, surrounding equipment would be protected by restraining the pipe at critical points.
If not restrained, the steam or pressurized water flowing from
- a broken pipe would cause the pipe to whip back and forth damaging surrounding equipment.
Pipe Rupture Restraints take on special importance at the Diablo Canyon Plant due to the close proximity of the Hosgri Earthquake Fault and the effect an earthquake would have in piping systems at the plant.
In May 1970, M.W. Kellogg (PPP) would sign PG&E Contract Specification #8711 for erecting Main Systems Piping and furnishing, fabricating, and erecting the balance of power plant piping.
C.S. #8711 covered piping, valves, hangers and pipe supports.
Actual on site construction would begin in 1971.
In 1971 PG&E '
would issue Contract Specification #8833XR to furnish and erect structural steel for Units 1 and 2.
M.W.. Kellogg 's- (PPP) original work 'under this contract was to erect containment structure pipe rupture restraints for Units 1 and 2 and the re-actor coolant loop, cross over pipe restraints for Units 1 and 2.
The C.S.#8833XR construction schedule called for Unit
- 1 Pipe Rupture Restraint erection to start on 7-8-72 and Unit #2 erection to start 3-8-73.
The framing for Pipe Rupture l
Restraints would be subject to a Quality Assurance Program in accordance with section 3 of the contract.
In addition all Pipe Rupture Restraint welding procedures were to be prepared and lkCk
qualifisd in cccordance with the American Walding Society (AWS)
D1.0-69 or D1.1-72 Codes.
PG&E would designata Pipo Rupture 1
Restraints as Design Class I work requiring full Quality Assur-ance compliance.
But it should be noted that neither C.S. #8833XR e,
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or C.S.#8711 made any reference to or made any commitment to comply with.10 CFRCO Appendix B, the Code of F.ederal. Regulations I
concerning Quality Assurance requirements.
,M'*d..Kellogg (Pullman) would' erect Pipe Rupture Restraints with little attention to Quality Assurance.
On 9-19-73, the PG&E Project Superintendent sent to Kellogg a letter concerning Kellogg's Quality Assurance Program.
This Letter stated that past i
audits conducted both by the Atomic Energy Commission and PG&E 1
Quality Assurance Dept. had disclosed nun.erous QA deficiencies.
These deficiencies usually fell into two categories.
- 1. Failure to follow existing Quality Assurance procedures.
- 2. Failure to upgrade Quality Assurance procedures.
PG&E requested Kellogg to place more emphasis on their QA audit program to eliminate most deficiencies before the next AEC and PG&E audits.
On 10-24-73 Kellogg reported the results of their first audit of the Rupture Restraint QA Program.
One of the areas audited was " Adherence to Correct Installation Procedures."
Per the report all aspects of Rupture Restraint installation were checked to insure compliance to a letter (unavailable for review) approved by PG&E's A.G. Walters on 10-19-72.
The audit report stated that "it appears that Spec 8833XR and 8711 as stated in the body of the letter are being complied with completely 3
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statsd in the letter woro condensed into a single procedure to ba u ed a this complex."
The initial Rupture Restraint construction s
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,did no_t have,gn approved Engineering,Specifica, tion.to dir.ect the-work but merely a letter referencing requirements for erection and Quality Assurance.
But PG&E would come to a different conclusion about i
Kellogg's Pipe Rupture Restraint QA program.
- During October and November 1973, PG&E conducted an audit to verify tihat Pipe Hangers and Pipe Rupture Restraints were fabricated, furnished and erected in accordance with Spec 8711, PG&E and Kellogg QA manuals.
It should be noted that PG&E did
~
not audit Restraints against the correct Contract Specification, Spec. 8833XR but against Spec 8711 which covered Pipe Supports and not Pipe Rupture Restraints.
The same mistake was made in the Kellogg audit of 10-24-73.
Why PG&E did not include Spec 8833XR
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which had placed Rupture Restraints under specific QA requirements is unknown.
This would be a reocurringdproblem in the early i
years of construction.
Rupture Restraint and' Pipe Supports
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would often be confused as one and the same.
They wouldgauditE) the same Spec, and share the same construction and QA requirements.
The audit disclosed that Kellogg (Pullman) and PG&E's General Construction Dept. departed significantly from the require-
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ments of the Specification and PG&E's Quality Assurance Manual.
Kellogg's(Pullman) Quality Assurance program'did not comply with Section 4 of Spec 8711 and PG&E's Procedure PRP-4.
It also disclosed that the PG&E Mechanical Department's surveillance j
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progrbmdidnotc,pywithPrcaduroP'RC-7 h Dk As a result, P
's Project Superintendent stop'ed work p
on the installation.of the pipe hangers and rupture restraints and directed that, corrective action be, init_iathd,to resolve,
all. deficiencies and preclude recurrence...
The audit.. reviewed Kellogg's (Pullman) Quality Assurance Manual, with respect to the pipe hangers and restraints, for adequacy and compliance to Spec 8711 and QA Procedure PRP-4.
Section 4 of Spec 8711 se't forth the requirements of the standard
" Supplementary Specifications for Contractor's Quality Assurance Program" included in Procedure PRP-4.
Kellogg's (Pullman) QA Manual copplied with Section 4 of the Specifications but the Manual did not specifically address l
itself to, nor completely apply to the control of pipe hangers and
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l restraints.
Because of this Kellogg (Pullman) had written an 1
" Engineering Specification", ESD223, establishing a QA program applicable to the control of hangers and restraints.
The intent of ESD223 was to set forth procedures and instructions to the field QA inspectors, engineers and foreman implementing the policy stated in the QA Manual.
The audit revealed that ESD223 esta-blished QA policy instead of providing instructions on how to implement the policy. stated in the Manual.
l ESD223 did not meet all the requirements of Section 4 of l
the Spec.
Deficiencies were noted in the areas of document review and control, qualification of special processes,,and personnel, work procurement control, receipt inspection of material identification control and status of material, nonconforming material control, inspection and test records and inspection and test
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plans.
The hanger and restraint QA program was found to be in 5
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KoW@ Eon of ~ Proc ure PRP-4 A coparato QA Manual /QA Progra,m was established for Pips Supports and Rupture Restraints.
This program was based on Contract Spec B711 QA Requirements.
Again C.S.#8833XR was ignored.,.. Rupture Restraint QA requirements were referenced in b
CS #8833Xf, not.C.S. #8711.
No commitment was made to.10CFR50 t
5 45 Appendix B and/or ANSI N47 2 QA Requirements.
ANSI Nes.2 had recently l
come into being to provide QA coverage for areas that' fell outside ASME code QA requirements which Pipe Supports and Rupture Re-straints did.
Alsoi Discrepancy Reports identifying and dis-positioning the discrepant item existing in work co=pleted were to 1
i be initiated, and steps to preclude recurrence implemented.
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.Another item audited was the receipt, storage and installation
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of pipe hangers and rupture restraints.
The audit revealed:
- 1. Kellogg's (Pullman) receipt inspections were only checks i
for road damage and completeness of material only.
6 j
Kellogg did perform surveillance inspections of stored assemblies.
i 2.
PG&E Civil Dept. provided the inspection and documenta-tion to assure that procurement requirements had been i
met.
Several receiving inspection forms which noted contingencies had not been completed.
These items had 1
not been placed on " hold" or withheld'from installation.
l The Resident's Instructions did not require identification and segregation of non-conforming items.
receiving reports for all restrainst could not beAdditionally, i
located.
3 Kellogg (Pullman) had not determined or received a written release from PG&E stating that the procurement requirements had been met.
d 4.
Except for ultrasonic inspection, Kellogg documented i
their inspections on " marked-up" erection drawings.
The method of recording inspections and acceptance criteria were not set forth in an instruction, and the auditor had difficulty determining the inspection status.
The auditor found that not all in-process inspection of workmanship and technique required by the 'AWS Code were being performed.
5.
Some welders were welding materials of greater thickness j
than they were qualified.
6.
Welding was not in complete accordance with the assigned weld procedures.
Several of the non-essential variables had been altered or were not being complied with.
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high strength steel bolts ware not in accordanca with the AISC Code.
The recommended corrective action for these findings was the sameas for Audit Item No. I. stated as above,
- Another item audited was PG&E's Resident Mechanical Engineers surveill'ance system of'the fabricating,' furnishing and ins'talling of pipe 1 hangers' and rupture restraints.
The audit revealed that surveillance of the receipt and installation of pipe hangers and rupture restraints were performed t
by Power Plant Piping Group.
The Resident's written instructions ghg to this gr,oup were set dorth.in MFZL2.
But MF2k2 instructions did
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not specifically address surveillance of pipe hangers and restraints.
Corrective action was to issue written instructions for surveillance of pipe hangers and restrain ts Thus this audit revealed that containment rupture restraint erection was in 4
noncompliance to Spec 8711 and presumably Spec E'833XR, which had 4
similar QA requirements.
t It was during this same time frame that other problems were' identified in the Kellogg's QA Program.
A Kellogg Internal Audit dated 9-6-73 revealed that the N.D..E. Personnel Qualification Program was not included in the engineering specifications, thereby making it part of the Kellogg QA Program and thus requiring PG&E approval of each page and each revision..
As a result of this audit NDE Personnel Qualifications Requirements were incorporated into ESD 235 and ESD 237, making these-j requirements part of the QA Program and subject to PG&E review and approval.
In 1973 the American National Standards Institute (ANSI) would issue ANSI M45.2.6, which defined an acceptable method 7
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for16plomanting10CFRfCAppsndixBrcquirementsfor"Qualifi-cation of Inspection, Examination, and Testing Personnal for i
the Construction Phase of Nuclear Power Plants".
Kellogg's Corporate QA Manual would be revised in 3-19-74 and its Corporate Field Installation Mjnnual would be revised on 4-1-74 to liplement
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..s a.
A 12-12-74 Kellogg Interoffice Corresponden'ce from the Corporate Director of QA, E.F. Gerwin, would only suggest/ recommend to the Diablo Canyon site QA/QC Manager that he implement ANSI N45.2.6 requirements.
A subsequent Interoffice Correspondence from the Rallogg Corporate QA Dept., dated 12-17-74, would direct the site QA/QC Manager to put into effect ANSI N45.2.6 "at your earliest possible convenience".
A Kellogg Corporate Management Audit of the Diablo Canyon job site on April 3,4,"and 5, 1975, revealed nonconform.-
ities in the area of " updating of Certificate of Qualification Records"andrecommendedcompletereviewofpersonnelrecords[by the Field QA/QC Manager.
Field QA/QC Manager J.P. Runyan responded to the Corporate Audit on an I.O.C. dated 5-13-75, stating, " Personnel records review has been performed and updated.
We have also updated our records in an attempt to comply with ANSI N45.2.
6Property "ANSI code" (as page type) with input value "ANSI N45.2.</br></br>6" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.".
Runyan,-on 6-15-75 would revise the ESD 237 Certificate of Qualification card for Quality Assurance Techni-cians and Inspectors to read " qualified in accordance with SN -
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TC-and/or ANSI N45.2.6."
As a result, I believe t at Field QA/QC canager J.P. Runyan deliberiately falsified QA Personnel Certification Records to give the appearance of compliance to 8
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ANSI N45.2.6 requiramants when no such compliance was impicmanted.
Runyan, in his 5-13-75 response to the Corporate Audit stated:
"Itshouldbenotedthatitisvirtuallhimpogsibletocomply
'tohallytoN45.E[6becAuseofexp'eriencerequirements.
We cannot hire personnel that meet the experience requirements for the' salary scale we off'er.
Even if the money was available, it would be difficult to find qualified people.
We are taking the approach of qualification based on performance in a speci'fic,,
job."
This was a nonconformance to ESD235 and ESD 237 QA/QC personnel qualification requirements, both ANSI N45.2.6 d SNT- {oQg TC-IA qualification requirements and the intent of 10CFRp0 App..B.
Criteria II, IX and IVII.
As a result, the Kellogg attempt to upgrade its QA Program was a dismal failure resulting in falsified records.
It should be noted that Kellogg'did not
, evise its QA Manual to reflect the attempted ANSI N45.2.6 com-r pliance and that PG&E did not revise. C.S. #8711 or C.S. #8833XR to direct compliance to ANSI M45.2.6.
'In August 1973, the U.S. Atomic Energy Commission issued Regulatory Guide 1.29, which indicated t' hat " nuclear power plant structures, systems, and components important to safety be designed to withstand the effects of earthquakes 'without loss of capability to perform their safety functions".
It also indicated that pertinent requirements of Appendix B to 10CFR50 (Quality Assurance Criteria for Design, Construction and operation of Nuclear Power Plants) would apply to al activities affecting the safety related functions of the identified structures, systems, and components, including their foundations and supports.
l The discovery of the Hosgri earthquake fault off>the' coast ikCNe 9
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Saismic Dasign classification established by the U.S. AEC in its Regulatory Guide 1.29 and made 10CFR O Appendix B QA Criteria a necessary part of PG&E's design and construction program.
But PG&E did not revise its C.S..#8711 or C.S.
- 8833XR to require,Kellogg's construction program to comply with the QA requirements of 10CFRSO, Appendix B.
PG&E and Pullman have contended that the Piping construction program which was based on ASME Section III Code requirements meet the intent of 10CFR O, App. B.
But the Pipe Support and Pipe Rupture Restraint construction programs were not based on ASME SEction III, b
and were not required by Contract Spec to meet 10CFR$0, App. B. YO L
i The result.was that pipe support and rupture restraint QA programs were not based on nor did they comply with the QA
(
requirements of 10CFR O, Appendix B.
The seismic analysis and reanalysis to withstand a major earthquake resulted in redesign and additional construction of hangers, supports, and rupture restraints in an ongoing process.
With the confirmation of the Hosgri Fault in 1973/1974, there was an upgrading program instituted to beef up existing hangers and rupture restraints.
This program was called the "Mosgri Rework Program."
The reanalysis and subsequent work granted to Kellogg, including the Hosgri Program was performed by l
Kellogg/ Pullman in 1975, 1976 and 1977.
The erection of Pipe l
l Rupture Restraints expanded to piping systems in all areas of the power plant.
In 1974, PG&E contracted Nuclear Services Corporation to design the additional pipe Rupture Restraints which were gok required to withstand a 7.5 earthquake and contracted
M Bargsn Itt. al Products to fabricata da rastraints.
KGilogg/Pullutn would parform the Graction of these Pipa Rupture Restraints.
..On 1-14-74, Engineering Specification Dieblo (ESD) 243, Pipe Rupture Restraints, was' issued by Kellogg and on 2-1-74 a revision to the ESD was approved and published.
Most of the ESD requirements were copied from PG&E Spec 8833XR and the AWS Code D1.0-69.
The 2-1-74 revision to ESD 243 required all Rupture Restraint welds to be made with weld prodedure Code 7/8, preheat of 50 F minitum with welder verification only, no preheat check by QA other than periodic monitoring during welder audits, and no documentation of preheat or interpass temperature.
Visual inspection of fit up and final inspection with ultrasonic examination of all full penetration welds was required.
For over a year these were the only QA/QC requirements for welding on Rupture Restraints.
A ' problem which arose in these. years was QA/QC directing production work.
he Kellogg (Pullman) QA/QC Manager l'ssued an Interoffice Correspondence on 1-31-74 stating that superinten-dents had complained of QA Inspectors talking to and giving work instructions to foremen and pipefitters.
He stated that jhphL
- from now on, no support or rupture restraint QA Inspector shall discuss any rework, defective support problem or engineering spec. requirements with foremen, general foremen, or pipefitters.
It was necessary on 6-17-74 for the QA/QC Superv,isor to issue an Interoffice Correspondence further clarifying the role of QA.
He stated that GA is not an engineering service 11 kN l
cnd th0n wsnt en to stato whdt functions QA would perform.
t QA/QC was not to diract production work or to provido engineering services at the Diablo Canyon Plant.
It is ques-What functions s
tiened just how much of this type work QA/CC did.
QA/QC would perform would develop as the Rupture Restraint erection program progressed.
On 3-27-74 a Kellogg (Pullman) internal audit of the pipe i4 support documentation of completed supports setatinmenc u>
revealed several deficiencies.
The corrective action for one of i
these deficiencies would later play a role in a rupture restraint documentation problem.
The audit revealed that some process sheets did not have the proper amount of insp ction poi $hNhIf.
The e
i audit's corrective action directed that "any inspection coints-that do not apply to a parM.cular support shall be noted with a "N/A"."
Thus inspectors were given the authority on pipe support process sheets to check N/A "not applicable" for inspection hold poidts that they felt did not apply.
The problem of N/Aing inspection hold po3.nts would arise in rupture restraints in the future.
A problem in the rupture restraint weld documentation program would be revealed in a Kellogg (Pullman) internal audit of pipe rupture restraints on 5-13-74.
The audit revealed inspector's " Daily inspection Log" which showed field welds in rupture restraints.
Their status was in compliance with y.
ESD 24p.
But the actual field weld process sheet used to document the individual weld did not show a date when the welding operation was completed nor whether a final visual inspection was performed.
The audit also revealed that most RR field welds in ~
\\hh 12
tho Unit i Auxiliary, Building showad poor workmenship.
Ths conclusions of the audit waro that "if possible, a' data should b2 i
shown on the process sheet when an operation is completed" and that "f
. -.ield.we.l.ds.on the U. nit i Rup~ture Restraints in -
the Auxiliary Building should be r.einspected, and a modified l
Pro, cess Sheet shoul,d be,made up to show 100% or final inspection of these welds."
No mention was made of the condition of Rhstraintsinotherpartsoftheplant.
It would not be until May 1975 that these conclu'sions concerning weld process sheet documentation would be incorporated into the requirements of ESD 243.
Rupture Restraints erection would continue with only cursory QA/QC participation.
On 12-24-74 Discrepancy Report #2654 was written on RR l (Q3N' 1031-5RT, Unit 1, W area.
" Cracks' were reported in base material 6" long at FW2C and FW2F.
Ultrasonic examination revealed indecttions to be laminar in nature,1" below the flange face.
InsntJtions were ground to remove and new weld pf(k<
Flit-S~T metal was added.
This was the46knel indication that a cracking problem was developing in rupture restraints.
Many more similar -
situations would arise.
In February 1975, PG&E would perform Audit No. 75-2 on Kellogg (Pullman) to verify that piping supports and rupture restraints were installed per PG&E and Kellogg QA Manuals, Specs 8711 and 8833XR and the FSAR.
The audit discovered de-parture from prescribed quality procedures in the areas of drawing control, weld electrode control, ultrasonic aquipment calibration, and PG&E surveillance inspection documentation.
The audit stated, " individually, the departures were not of 13
~
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,-e w-m--se----
-m r
c.
,-----,4----w--
w-q 9--merg e
u 7
--=v--*
w'
I major significanca; howavar, collectively tha dapartures indicato the nocd for a more comprehensive internal audit system."
Since the beginning of construction in 1972, Kellogg (Pullman) had performed only two inte$nal audits on rupture
- a..
.... i :.
1 restraints.
ThiswasinOctober1973andMarg}1974.
Kellogg had been performing internal audits but mainly on the erection of piping with occasional audits on hanger supports.
Because of this PG&E audit, Kellog would begin to audit rupture restraint work more often.
l As a result of a..Kellogg Internal Audit of drawing control for rupture restraints on 3-24-75, which discovered out of revision drawing being used for erection, the QA/QC supervisor issued an Interoffice Correspondence dated 4-3-75 directing all R.R.
drawing tc be audited once a month by QA inspectors; that the Pipe ~ Support Dept. (rupture restraints were included in this department) be added to the Chief Field Engineer's drawing i
distribution list for R.R. revision update; and that out-of-revision drawings discovered be updated by the inspectors responsible.
Thus it became the Inspector's responsibility to control drawing for rupture restraints.
By the spring of 1975, it was becoming apparent to Kellogg (Pullman) QA management that a lack of preheat for welding was i
becoming a problem.
On 4-25-75, the Kellogg (Pullman) QA/QC Manager issued an Interoffice Correspondence to all support inspectors 4tating that the A.W.S. Code required preheat when welding structural members if the material thickness exceeded 3/4".
He stated that weld procedure 206 indicated preheat requirements for different material thicknesses and that these requirements applied to all N@kh 14
walding processa..
Thus in mtny cases two walding proccdures would hcva to ba used to make a wald.
He addsd that the temperature should be maintained during the welding process; and that inspectors should note on the process sheet that preheat was checked and give
- ~
~ihe approximate te'mperature.
v.
~
Revision #5 to ESD 243,' dated 5-6-75, added authoblzation
'to'bse weld code 205 o'r 206 for vertical butt welds, d5 8
angle gusset plates, 30P groove welds with backing, and 450 groove welds with backing.
This revision also clar'ified and' expanded 1
\\
welding inspection and documentation requirements to include seven sequential steps with six QC hold points (production could not proceed until the hold point was signed by QC) as follows:
l
- 1. Verify material, clean and fit up. (H.P.)
- 2. P. reheat tem eraturg (H.P.)
QOd
- 3. Oc;Lm _S&s=
co "( F SkS3 (H.P.)
1
- 4. 10% inspect multiple pass fillets (H.P.)
i
- 5. Weld complete i
- 6. Final visual
( H. P,. )
- 7. N.D.E. completed weld (H.P.)
j With revision #5 to ESD 243, verification of preheats became a QC function instead of a production function.
Process sheets would now be issued detailing the operation sequences for each weld and specifying where QC Inspections were required.
But this revision would not be fully implemented.
Process l
sheets for rupture restraint #148, would have welding performed as late as April 1976 which did not comply with the requirements of revision #5 to ESD 243 l
i Another problem that arose was the fact that the.. process sheets listed field weld numbers but did not indicate the 4~
{(6 96 type of weld being made (fille /, groove, etc).
This would 1
cause problems at a later date when process sheets, field 15 QoQ
dept. would parform a restamping program to make thom match.
Even with revision #5 to ESD 243, preheating of welds remained a problem.
On 9-17 and 19, 1975, PG&E performed a
~ '
quality control audit of the Kellogg (Pullman) company's
-.. ~
welding on pipe rupture restraints.
This audit found that QA personnel allowed welders,to weld without verifying minimum preheat and interpass temperatures.
As a redbit of this audits the Kellogg (Pullman) QA/QC Manager issued an Interoffice Correspondence, date 9-22-75, stating that welders were not preheating and that Inspectors were required to monitor preheat and interpass temperatures.
He pointed out that these temperatures must be maintained during the welding process and when checked, recorded on the process sheet.
Also in response to the PG&E audit, the QA/QC Manager sent a letter to PG&E, dated 10-6-75, stating corrective action had been taken to assure that preheat requirements were being followed and applied in compliance with established procedures.
This letter also stated a meeting had been held with the Superintendent in charge of Rupture Restraints to establish j
production responsibilities with regard to preheating.
An official response to the PG&E audit was made by the Kellogg (Pullman) QA/QC Manager on 10-9-75, when he issued Descrepancy R port #2969 stating that rupture restraints in e
the field had welds completed without proper preheat.
PG&E's official recommended disposition was to " accept as is based on acceptance of ultrasonic testing."
16 J
l
officially.rGcognized by both Kellogg (Pullman) and PC&E,,
with corrective action promised.
Up to this time Kellogg (Pullman I
l e
Field Engineers' had been'providing minimal enbineering services for welding rupture restraints..
These engineers had been pri-marily concerned with.the e;rection of. piping and pipe hanger supports.
Because of the continuing problems with weld cracking in restricted joints, the QA/QC Manag(er on 10-21-75, ist Q.EST%ttJT/
gC. i M
sued an Interoffice Correspondence to QC SupportgInspectors which in effect ordered inspectors to perform engineering duties.
He stated that inspectors should take the following action in an effort to avoid the cracks:
- 1. Suggest to the production personnel that they use more heat, preferably 300' or more.
He notes Eh'at this is not required but is highly recommended.
- 2. Check to assure that the temperature is maintained i
during the complete welding cycle.
- 3. Recommend a welding sequence which will induce less stress.
- 4. After weld is complete let it cool completely before final visual inspection then examine closely for tight cracks.
- 5. Make sure that there are no visible cracks before Q
calling for T. inspection.
Suggesting to production personnel that more heat be applied to, welds and recommending welding sequences should have been a designated engineering function.
It was not, and as a result of this correspondence.'it became the QC inspector's responsibility in direct contradiction to the QA/QC Manager's directions of 1/31/74.
QC Inspectors were now to assume engineering duties.
This corresponde6'ce also would tentatively identify additional reasons for the cracking problem, welds in restricted joints and welding sequences.
ggg 17
-r-,
-_.-.,,,..-,,,,.-.---e.w._.._..,..,
-y-
..m,.,
,,,.,,-,--,-,y.
.Th3 w3ld cl.4 king problsm in Rupture..actraints would continua.
Basido ths wald cracking problem thore would also b3 c prob 1cm in identifying walds aftdr they ware mado.
PG&E during the week of Oct. 27, 1975, conddcted Audit No."hg75-4 b$
to verify compliance to PRP-4, Suppliers'/Co.7. tractors' Quality
" Assurance Program $ and' esc ~2d3.Fdur item $ were' audited with one
^
~
. discrepancy found.
The audit disclosed that the procedures for identifying welds were not being implemented uniformly.
Four rupture restraints were audited for workmanship and on two of them weld identification inconsistencies were noted.
Restraint No. 1047.4R7 had three welds stamped with a welders ID letters, but the process sheets did not reflect the welder's ID letters.
On one of'the above welds the process sheet indicated that the ultrasonic examination had been completed, but the weld had not been stamped with the inspector's CY) stamp per ESD 243.
Restraint No. 1047,14Rt had two welds whichwerenotqgampedwiththewelder'sID.
One weld process
()gyg sheet indicated XT inspection but the weld was not stamped to reflect this.
The corrective action recommand:d by 20aC was for all welders and inspectors to be instructed on the requirements for stamping and inspecting completed welds.
This problem of weld identification and documentation was not an isolated case but effected almost all rupture restraints erected up to this time.
The problem was not just failure of welders to stamp their welds and inspectors to record the informa-
~
tion on the process sheets.
On many of the restraint erections there were joint connections involving as many as 3 to 10 or more welded connections.
All the welded connections in the joint were given a single identification number.
Then later it was decided that each, welded connection had to,be identified, so the process sheets were amended to read FW number A-or however many joints were involved.
But the process sheet did not necessarily reflect the correct welder for each welded joint.
Then to compound the problem, Kellogg would initiate a stamp program as part of their corrective action to the PG&E audit.
Kellogg's (Pullman) response to the audit, dated 12-1-75 was that a field inspector had been assigned to review all O'
_.,,,,-.-,-e..--w-v+=----*-~r--*~*""Y'"
ficld rOccrds ct. Inst complotsd work to ci~5ro corrolation
~
~
betwacn tho two.
Field recorda ussd waro "Dnily Insp2ction Logs" and process sheets. T nese records did not record what type of weld was made (fillet, groove, etc.).
So the field inspector could not accurately' match field records with welds and sub-
. t:
i sequent 1y many welds were, misidentified and misstamped.
i This problem of weld identification would resurface on several l
future occasions and reveal that welds were not correctly identified and stamped.
The problem of properly filling out QA documentation was l
a continuing problem.
The QA/CC Manager issued an Interoffice Correspondence on 4/14/76 giving instructions on how to make changes to QA documents.
" White out" was not to be used to correct entries.
A line through the incorrect entry and a new entry for the correct information was directed.
All changes i
had to be initialed and dated.
t Cn 4/22/76 an Interoffice Correspondence issued to all
~
field inspectors gave instructions concerning the proper filling out of Process sheets.
It stated that process sheets will be i
signed and dated.in each required block.
Lines drawn down the i
column with initial and date at the top and bottom is not accepted.
Any changes including N/A on the process sheet will be initialed. If a weld is cut out you will state the l
1 reason, initial and date.
QA documents would be of little
\\
value if the documents were not filled out properly.or the information provided did not include all data or provide accurate data.
This problem would keep reoccuring.
]
On June 4, 1976, PG&E Engineering Research sent a letter 19
I to PG&E manngsmsnt at Diablo Canyon Plant conccrning an 1
invastigation into th,e cah0h of cracking adjacent 'to beam-to-column flange welds in Unit i pipe rupture restraints A
(D
_..f#315,8).
A f,a1,1ure analysis was performed on a portion of cracked welds and residual stress measurements were made on the beam the welds came from as well as in areas. adjacent i
l to where the racks were found.
The results of these inves-l tigations were:
i
- 1. The fracture is brittle in nature.
- 2. The fracture results from flame cutting of the welding relief hole in the weld.
- 3. There are high, up to yield stress level, residual stresses in the vicinity of the beam 'to-column weld joints.
These stresses are a result of the beam-to-e.
column weld.
- 4. Higher residual stresses, and cracks, appear to be l
associated with wide, greater than 3/4" wide weld passes.
The letter stated that the failures appear to be the result of a number of minor materials property, fabrication details, and construction sequence details that combined to cause these cracks.
The letter then gave recommendations for repair and modification' of welding and manufacturing procedures to to alleviate these problems.
These recommendations were:
- 1. Preheat before all thermal cutting operations according to the welding preheat schedule for the thickness of material being cut.
- 2. Remove, by grinding or other mechanical means, a minimum'of 1/16 inch from all flame cut or are gouged surfaces not to be incorporated in the weld.
- 3. The welding procedure should be modified to limit the weld bead width to 5/8" maximum'F or 2 " and thicker material in beam-to-column joints and other.
restrainted joints, the minimum pneheat temperature should be raised to 3005 F, and a maximum interpass temperature of 8000 F should be imposed.
l 20 g
i
)
- 4. Nfi5ro pas..olo Gha wald joint datnik should be
~~~~ ~ ~~
~
modificd to rGduca the volum2.of w2ld matal depositcd.
~
This can ba cecomplished by using anarrower groova, a double-V wald properation, or both, instand of the 45 single-V weld preparation presently used.
Weld Code 7/8, a primary R.R. welding procedure, did not include in'its weld procedure' Specifications (WPS), joint detaili for'a double V weld.
But Code 7/8 would now be used to make double V groove welds in nonconformance to the WPS.
Revision #7 to ESD 243, dated 6-10-76 was a direct result of the PG&E investigation of a cracking problem on rupture restra 126, Unit i turbine Building.
The revision added t bular data for preheat and interpass hem gerature requirements during welding and thermal cutting.
It added a requirement to clean by 3 tnuDir3
,m.41'n); a minimum of 1/16" from thermal cut surfaces which were 1
not to be incorporated into a weld.
The revision added minimal guidelines to dimension weld access relief holes.
Prior to this time a specific preheat and interpass tempera-ture was not included in ESD 243.
The weld procedure specification was the control document, however, reference to ESD 243 was not included in the weld specification until October 1976.
l There were four weld procedure specifications for rupture restraints with weld Code 7/8, the main procedure.
Weld code 7/8 was originally two separate procedures identified as weld Code 7 and weld Code 8.
Thesa procedures were approved on 11/25/69.
Both codes were for welding carbon steel pipe using E7018 shielded metal arch welding process.
On 1,2-10-73, the codes were combined and added carbon steel plate to the specifications.
Weld code 7/8 was identified for use on 21
rupturo roatrainto groova and fillot walds.
Prahant requircmOnts wara chtngad to 50' F minimum with 175' F minimum for m0torial that had a carbon content in excess of 0.30% and 1" thickness.
Interpass temperature was indicated to be 50 c'F minimum.
A 10-15-76
' revision to wel'd Code 7/8 stated See 'ESD 243 for AWS Welding",
referring to structural steel welding (which rupture restraints This revisio;n also stated that the procedure was qualified was).
to allow welding of unlimited thickness on structural members
~
under AWS requirements.
Weld Code 92/93 was similar to weld code 7/8 in that some of the welding techniques were the same.
Code 92/93 was qualified f'or open butt welding but was used to weld groove welds with a backing strip.
This weld code was used during peak workload periods because there was no require:$ent to re-qualify 1
welding personnel.
A problem would arise with process sheets
\\h referencing Code 7/8 but eet requisition referencing Code 92/93.
Production and QC substituted Code 92/93 for Code 7/8 to expedite the construction process.
Weld Code 205 was developed and approved for flux cerad arc welding of carbon steel to carbon steel for structural steel only.
Weld Code 206 was developed and approved for gas metal arc welding carbon steel to carbon steel for structural steel only.
Kellogg (Pullman) established ESD 219 for " weld procedure monitoring"in 1973.
This procedure was originally established to monitor Class I pipe welding.
Revision 5, dated 6-17-76, added rupture restraint welding as Class I welding and directed that ESD 243 would be the applicable procedure for preheat monitoring 22
fer structural wi ling.
ESD 219 olso 'statt 'that W21darc cnd inspcctors chall monitor tho interpose temparaturo of all C1csa I welds for. compliance with the weld procedure.
Paragraph 3.3 of ESD 219 concerning " Pre-Heat temperature" states "the mlnitum 4
pre-heat temperature on this project is 50' F.
If the air or r.
metal temperature is below 50C F, pre-heating is required.
.. a.
s..
Air temperature shall be monitored by wall thermometers."
Pull-i man Internal Audit report #80, date of 12-24-80, found there were no wall thermometers evident in the powerhouse which could be used to monitor air temperature to determine if pre-heating l
was required.
Corrective action was to order thermometers and,
]
upon receiving them to implement ESD 219.3.3.
i Nine months later on 9-22-81, Internal Audit Report #94 I
would report that wall thermometers were received by Pullman QC, calibrated but never issued to the fiald for implementation of ESD 219.3.3.
It was not until November 1981 that wall thermometers were placed in the power house to monitor air temperature.
It took 8 years for the requirements of ESD 219.2.2 to be im-i plemented.
It took 11 months after the noncompliance was found before corrective action was actually implemented.
In my pro-i l
fessional opinion, this was inadequate. implementation of Quality Assurance requirements.
i 3-23-76 9o 7-2c 'il From 7-;0 70, a total of twenty four discrepancy reports weregeneratedwhichinvolvedcrackinginPipeRuptureRhstraints.
On 7-22-76, ESD 243 was revised to authorize field modification of weld joint detail during weld repairs and/or new weld preps.
J This was done to reduce the volume of weld metal deposited, 1
23 N
t i
1.o. narrowar groovoc, double bavel groovas varsus cinglo b3vol i
grcoves, thereby helping resolve the weld cracking problem.
The continuing problem of weld cracking raised the question I
l of when the final visual exam should take place.
On 9-9-16, an 4
IOC was issued to all rupture restraint inspectors instructing i
them To'sigd process sheet'sthp'#5 I weld complete (not a QC
~
hold point) when welding was complete.
Step #6 - Final Visual, was not 'to be signed until the weld had cooled to ambient I
temperatures and then the inspector was to check and see that the weld area was clean of slag, scale and smoke, and that it i
V hAb was smooth for #T exam.
The inspector was then to complete his final inspection and sign the process sheet.
This would help inspectors to more readily detect cracks in the velds.
i 4.
On 10-7-76, DR#3295 and PG&E DR#M-3192 would report i
1200 welds to " rupture restraint structure members" without the i
application of the required preheat.
The welds involved attachments i
t such as temporary lifting eyes, nuts and bolts, shims, rod eyes l
and hinges.
The weld sizes ranged from single pass 1/8" fillets to i
I 1/2" fillets.
Base material thickness, which governed preheat t
]
requirements, ranged from 3/4" to 6".
There were no process k
)
sheets issued to control the welding or any other QA/QC documentation.
{
DR#3295 required that these welds be examined by magnetic particle testing to determine if they were acceptable.
Three hundred fourteen welds were examined and found acceptable.
Based i
1 on the acceptance of these welds, the remaining welds were accepted as is without being tested.
i 24
_ _ _ _ _, _ _.. _. _. _ _ _. _ _ _. ~. _
Ccmmission Inspsetore involving themasivas spscifically with rupturo restraints.
Then on 8-2-77 an NRC inspector made an inspection j
bY of the Ben 9 rupture restraink:on Unit I piperack.
The inspector found what he believed to be undercut on FW40..The' inspector also found documentation problems.
He found on process sheets for FW40 and 41 that the final inspection was dated one day prior to the fit up of the weld joints..He also found another process sheet with the final inspection hold point "N/A" by Kellogg Inspector Mullis, i
j Kellogg (Pullman) issued DR#3449 to report and resolve the i
i findings of the NRC inspector.
The following corrective action j
)
was taken:
i i
- 2. FW 40 and 41 were reinspected and the dates corrected.
A review of rupture restraint process sheets was performed and a random reinspection of a minimum of 20% of all welds i
accepted by Inspector Lindell was performed.
- 3. All process sheets reviewed in #2 above which had "N/A" inserted in inspection points were reinspected and if required, repairs made.
(This action infers that Lindell was more suspected of N/Aing process sheet operations than Mullis who was caught N/Aing by the NRC.)
1
- 4. Errors found in stamping of welds during reinspection were to be restamped to correspond with applicable red requisitions and process sheet documentations.
This would involve 43 welds on Bent 4.
i j
Inspector Lindell had not been employed by Kellogg (Pullman) since 9-3-76 so no action was taken against him.
Inspector Mullis t
]
had no explanation for entering "N/A" in the process sheets.
Mullis was then fired for failure to comply with established procedure.
)
4 j
on 9-12-77, an.IOC was issued by the QA/QC Manager to report on meeting with Pullman Power Products (Kellogg) field inspectors 25
m, - AN.
incpactors did not havo thaThoco m;ctings poir.
at fiold They were to advise weldercuthority to N/A*in pection point s
s s.
,ie'uYiements 'and"6'~pei[or.Y rqilir'and fitters of the q
e ed iNsp'ec' ~i~ons is soo' n as possible after notification t
of. Inspector Mullis, the reasoAlso discussed was the termi nation required to correct the situatin for that termination and the on.
work By this Pullman (Kellogg) sh implemented corrective actioowed the NRC that the company h d comply with procedures.
n for QC inspector's failures to a
cover up bigger problems. Inspector Mullis was a sca to pegoat Inspector Mullis inspection point, but whatcannot be excused for N/Aing a fi nal Inspector Mullis was doing about extenuating circu In the Unit #1 more than just QC inspection wo k E,
W and piperack areas r.
was performing engineering and d, Inspector Mullis of Pullman (Kellogg) QA/QC !!a rafting work with the approval An Interoffice Correspondnagement and Production Managem Manager had directed QC in ent.
ence dated 10-23-75 from the QA/QC of telling production personspectors to assume engineerin g duties make welds and to tell productinel to use more heat than requ red to welds by recommending welding on personnel how to make their less stress in the welds sequences which would induce neering duties.
Inspector Mullis assumed th to earlier QA/QC correspondeThis instruction was in e engi-
~
rect contradiction inspectors were not to giv nce dated 1-31-74 which stated pipefitters, and to corresponde work instructions to foremen and Quality Assurance was not anence dated 6-17-74 which stat d engineering service.
e 26 Why was it i
i I
.o n cocotry for Qv incpsetors to perform engineering dutios?
Thara.waro field Gnginaars on tha jobsita, but their main concern was the erection of piping and hangers.
They gave little if any engineering direction to the erection of rupture restraints.
1
.. r.:.r 1.7. :. - :.r.. ::
Rupture restraints had low engineering priority because Pullman u.
(Kellogg) management had instructed inspectors like Mullis to 1
provide the engineering services needed.
Af ter the NRC incident engineering would take a more active role.
In addition to performing QC and engineering duties, Inspector Mullis did As-Built drawings of the rupture restraints he worked on.
These drawings showed the as-built field conditions of the rupture 4
i.
restraint as well as numbers assigned to each welded connection for documentation identification purposes.
Inspector Mullis drew many of these as-built drawings and they are the basis for the current rupture restraint documentation packages field layout drawings.
Inspector Mullis was fired for NAing an inspection point, l
1 yet QA/QC Management on two occasions stated it was okay for an inspector to do so.
Interoffice Correspondence dated 3-27-74
)
(attachment 3A) stated "any inspection points that do not apply to a particular support shall be noted with a "N/A"."
Interoffice gk Correspondencedated4-22-76(e*'=g"-nt110) l r
stated "any changes 4
i
\\
including N/A on the process sheet will be initialed..."
NAing l
l l
inspection points on process sheets was an accepted practice on i
)
supports which inspector Mullis decided to implement in rupture restraints.
So the first NRC audit of rupture restraints revealed documenta-tion problems and field welding problems but failed to recognize a major breakdown in the QA program, quality control inspectors ph4(.
27
doing enginsering and drafting work.
Inspector Mullis assumed duties and responsibilities outside his assigned QC functions.
Pullman (Kellogg) management knpw k(
0*
and approved of it until Hullis was caught by the NRC.
- ~..
Maybe the reason Inspector Mullis NAed the inspection point was that he was so busy doing engineering and drafting that he didn't have time for quality control.
It should be noted that on 5-17-77 an interoffice correspon-i dence issued by the QA/QC Manager stated that Inspector Mullis i
j "through daily demonstrations meets the requirements of SNT-TC-1 j
IA..., ESD 235, ESD 237 and KFP6 " Evidence of Continuing Satis-factory Performance"."
Two and a half months later he was fired for failure to comply with established procedures.
ESD 243 was revised on 1-19-78 to add the requirements for the Field Engineer to review all drawings and h itiate all Field i
Process sheets.
It added a requirement for QA review of process sheets, prior to issue for work and revised the field process sheet i
to include the weld symbol, thickness of material and QA review entries.
QOb on7-20-78,DR#3683reportedalamflartearwhichopened during repair of a weld in the Unit #1 piperack.
Subsequent l
NDE and metallurgical studies by PG&E revealed a generic problem associated with highly restrained joints.
On 10-3-78, PG&E fg# issued non-conformance report #DCif78-RM-008 which identified that welds for pipe rupture restraints in materials greater than 11f' thick had developed cracks.
on 3-23-79, PG&E issued non-conformance report #DC1-79-R 28.
which idsntificd numsrous walda that davaloped cracks aftsr completion of welding and final examination.
On 5-7-79, NCR#
DC1-79-RM-007 was issued, which identified that further inves-
.tigation.had found rejectable linear, indications in other rupture j
restraint weld joints.
On 6-6-79 PG&E issued NCR #.DC1-79-RM-010, which identified that. nondestructive and des.tructive testing had found the existance of rejectable defects in field welds.
This NCR resulted in an extensive program of investigation, evaluation
{
and repair of rupture restraint welds.
On 6-21-79 PG&E issued NCR # DC2-79-RM-011 which identified welds in Unit #1 with gM(
I l
rejectabledefects,andthatthesameors4Mlarf"nditionsmay i
o 4
exist in Unit II.
The major problems causing rupture restraint weld cracking j
as determined by PG&E and Pullman were:
I
- 1. Joint Desien A. Massive weldments, 5" deep x 4-5/8" wide with 45*
single bevel grooves that would shrink unrestrained i
about h" in a transverse direction, instead were totally restrained by high columns and beams.
All d
\\g,%g e.
ppotentialshrinkageistransformedintoresidual stress and/or cracks.
b.
Highly restrained joints with heavy sections attached j
to relatively thin sections.
Lateral reinforcement stiffers, 2" to 3" gusset plates, were welded exactly l
opposite, both pulling on h" to 3/4" thick webst and i
PG&E Department of Engineering Research would develop i
c.
their investigation around four additional welded i
connection joints classified by degree of restraint.
i j
- 12. Base Material
- a. Almost all cracks originated as lamellar tears in A441 1
and A588 steels used in highly restrained joints.
- b. Some materials had excessive rolled laminations.
i
- c. PG&E supplied base material 'that was inadequately l
i d
identified prior to implementation of QA verification of base material.
i
- d. Low nelting point alloys formed with copper (in A441) and sulfides triggering tears.
i
- 3. Indiscriminate Material Removal L3) bF
- a. Large dtstructive test samples were removed.
- b. Some sections were essentially destroyed chesahd cracks.
c.Noconsiderationwasgiventohowremovalstressesaffge,g
. _7 othar, inta in tho samo otr' uctut
- 4. Inedscunto Prahont end Interonsa Tamoornturo Control i
a.. Material type being welded was not included as an element of planning for rupture restraint work.
As a result, cufficient controls were not established for preheat and interpass temperatures.
i
,., bl. Ambiguous terms Land. phrases,.were. cobied from PG&E
+
specifications, with inadequate implementation of l
j AWS code requirements regarding prehuat and interpass 1
- t-temperatures.
{
A major crack repair program would be initiated in both
'l
~
Units of the power plant in March of 1979.
The Pullman Field QA/QC Manager stated in an IOC dated 8-28-79 that an estimated 1
i 40,000 man hours had been expended to date and that only approx-
)
imately 507. of the work in Unit I was completed.
Rework would
\\
continue in Unit I & II until 1981/1982.
l The rupture restraint crack reeair procram would result in'il d cons R VcTtoIV Pb i
i major changes in the Pullman ine L-udtron program.
In May 1979, Pullhan would issue a special welding procedure to make the I
weld repairs.
Welding technique Specification #AWS1-1 was formulated to clarify the technique for application of weld code 7/8 i
j procedure as applied to AWS welding only.
AWS1-1 and other similar.
SMeboke techniques were based on PG&E recommended procedures *44h their gog.
g analysis of the cracking problems.
The technique gave very
~
detailed parameters for making the crack repair welds.
But l
these techniques were not applied to the general rupture restraint t
construction program.
Weld Code 7/8 would continue to'be the primary welding procedure for general RR construction.
Prior
- C A-to1979rupturerestrainfweldershadbeenqualifiedtothe ACME Section IX code.
As a result of the crack repair' program ye welders would now be required to qualify Zee the AWS Code requirements.
k'N
~
-,-m-v-m---e,ny,.
~-,am..n
,,-m
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,-,w,
, -, n a,..
,,-+
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,,, w,m,-e,-- w m --
.wn,,,-
w--,,
A numbor of (
2ngos waro medo concornir.
the NDE rGquircm:nts
-for ruptura rostraints.
C.S. #8833XR was revised to require M0d that all completed full penetration and partial [enetration welds -
and fillet. weld.h"..and. larger..shall be magnetit particle inspected.
u..
- , * ~. -.
Pullman would' prepare a QA Instruction #143 to implement these re-l quirements which would ev,entually be incorporated into ESD243.
When the instruction was submitted to the PG&E Resident Mechanical I
Engineer for his approval he would amend the instruction to read
{
"all partial penetration welds h" and larger" would requS.re
{
magnetic particle examination.
Pullman would implement the PG&E i
j revised QAI#143 and for the.cnext two years would perform NDE which did not comply with the revised C.S. #8833XR requirements.
In August 1981, PG&E recognized its error and required QAI#143 to
^
be revised to include all partial penetration welds to be t
magnetic particle examined.
A reinspection program was initiated 1
to identify the welds not magnetic particle tested.
PG&E provided to Pullman the NDE procedures to be used I
for magnetic particle testing.
However, Pullman Internal Audit 1
- LXXVII, dated 9-25-80 identified that PG&E had provided con-l flicting procedures for Pullman to use.
PG&E had directed that l
all rupture restraint magnetic particle exams were to be performed
]
to PG&E's DER NDE procedure #3212.
This procedure stated that i
l the preferred examination was the Yoke method per PG&E DER NDE procedure #3204.
But EG&E had provided Pullman with a DER NDE procedure #3205 which was a prod. method.
PG&E had stated one
{
method was to be used but had provided a procedure for a dif-forent method.
As a result of the Internal Audit, PG&E would direct Pullman to use the Prod. method.
j PG&E would direct Pullman to use a PG&E ultrasonic proce-l u
i ;.
= - - -
duro #3523 to cxan. no only full panotration oolda 9/16" cnd greater effective throughout.
This weuld not comply with C.S.
- 8833XR requirements to ultrasonically inspect all connections utilizing full penetrations welds.
This conf 1'ict between C.S.
Aok'#8833XR requireinents and PG&E fT procedure would be identified V
l in Pullman's. Unscheduled Internal Audit #29, dated July 1982, l
but both Pullman and PG&E refused to address the non-conformance to Contract Specification requirements.
Not until 1984 when d
h allegations of non-conformance to contract /T requirements were l
made to the Nuclear Regulatory Commission would PG&E revise C.S. #8833XR.
1 1
e I
[
i j
}
t
.i O
32
_.-_________,_____-__.___m..
In 1982 I identified in Pullman's Internal Audit
- 101 that ESD234 Ultrasonic procedure had not been properly
,, qualified....ESD234...had been used prior to 19.79 t.o examine -
\\
s all full penetration Rupture Restraint welds.
IA4101 iden-l tlfied that ESD234 did not have Procedure Qualification Records documenting a Procedure Qualification Test.C.S.8833XR l
required all procedures (including NDE) to have qualifica-tion records.
This problem may have contributed to the weld cracking problems.
'g
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]
.The Rupture Restraint Teek Repair Program was not the only major problem with Pipe Rupture Restrainta.
There j
would be a significant Quality Assurance breakdown identifi-j ed in the Rupture Restraint Construction Program.
By 1977
{
PG&E was concerned that Pullman was experiencing difficulties in performing work, that was constantly changing per require-i ments at the direction of PG&E, to qualify standards that i
would allow PG&E to enter into the later hearings with the i
NRC with complete confidence that Units I and II would be i
j acceptable for licensing.
PG&E requested Pullman to have an independent audit performed of its QA Program.
Pullman contracted Nuclear Services Corporation of Campbell, Calif.
to perform this audit.
)
From August 22 to September 20, 1977, Nuclear Services corp. audited the Pullman Construction Program at f
the Diablo Canyon job site.
The basic conclusion reached by NSC was that the Pullman QA Program did not meet 10CFR50 4
Appendix Requirements.
NSC summarizes Pullman's problems, as follows:
- 1. Prior to early 1974, there is little evidence i
available to verify the adequacy of the work per-Theavailableevidenceindicate[sthat lk0
- formed.
l only a rudimentary quality control program existed l
and that control over the production organization i
i was minimal.
NSC concluded that there was no con-fidence that welding done prior to early 1974 was performed in accordance with welding specification requirements.
l 33
o i
i l
i
)
2.From early 1974 to late 1974, there is evidence available to verify the adequacy of the work per-1
{
formed.
The available evidence indicat,es that con-q.
trol. was. achieved..of.t.he materials control program j
and the welding. control program.
.3. From late 1974 to the present, an increasing
)
amount of documentation and records has been gen-j erated to verify the adequacy of the work performed.
The available evidence demonstrated that an increas-
.i ingly more stringent quality program has been placed i
i j
into effect and increasing greater control of the work effort has been achieved.
However, the present program and controls st.11 do not meet 10CFR50 Appendix B requirements.
I As a result of the 1977 Nuclear Service Corp. audit, PG&E's QA Department would perform Audit #80422, issued
}
6-13-78.
PGGE's conclusion was that the QA Program implemen-
{
ted by Pullman essentially fulfilled contract requirements
[
and meets requirements of the ASME Boiler and Pressure Vessel
. Code, 1971 edition.
PG&E stated that the 1971 code was l
consistent with the requirements of 10CFR50 Appendix 5. What l
2*
PG4EandPullmanfailedtorecognigewasthatonlyPullman's I
hDk Piping Construction program was baged on the ASME Code QA l
requirements.
The Pipe Support Pi Rupture Restraint j g QA programs were not b ed on a : =T)q code or standard h
}
and there was no commitment to 10CFR50, Appendix B for these programs.
1 One of PG4E's audit findings was that Pullman audits 4
j performed to verify Unit II hardware items in early 1978 did not effectively evaluate the quality of their work.
Pullman had audited 122 hangers, restraints, and snubbers and 77 sometric drawing packages and found no discrepen'cies.
l Yet when PG&E re-audited half of the items inspected by
)
Pullman, several discrepencies were noted.
The result was that PG&E ordered Pullman's corporate staff to perfrom another audit in the summer ofl978.
I b.
Tho PG&E Audit 450422 would goncreto two Non- '
conformance Reports.
NCRfDC-78-RM-004 identified that Pullman's QA Program was not adequately defined.
There were procedures,which implemented QA requiremdnts of the contract but are not identified as part of the program and revisions,are no,t c,ontrolled by the program., PGGE found that it wa,s not clear which manuals,and procedures were applicable to specific activities.
The corrective action was to write a program discription that would clearly identify the documents to be considered part of the total quality assurance program and establish the heirarchy of the documents.
The second part of the NCR addressed Pullman's inadequate corporate and Internal Audit Program.
The scope of both types of audits had not been established, and there was no detailed schedule developed to show that all aspects of the program had been audited.
Audit records indicated that all aspects of the program had not been audited.
No management audits had been performed on pipe supports and i
rupture restraints.
An unofficial, unapproved internal audit schedule existed, but it ha k
and few ESD's appeared m.9.# not been followed consistantly H
6
-schedule.
A second NCR #DC-78-RM-005 was also issued.
P.G.&E's review of prodedures and work in progress indicated that Quality Control inspections igdg eg g e from scheduling and N N production pressures was not assumed by the program as written.
Procedures did not clearly indicate that it was the Pro-ductions Department's responsibility to read and use the pro-cess sheet insuring that steps were performed in the required sequence and that hold points were observed.
Four Minor Variation Reports would be issued to deal with specific discrepancies.
It should be noted that P.d. & E. identified some Pullman inspectors who were not qualified to ANSI N452.6 and recommended that the Pullman inspector certification card should be amended to eliminate the claims that inspectors are qualified to ANSIg45.2.6, 1
or inspectors should be qualified in accordance with its requirements.
ss
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__ _ _ _ ~ _ _ _ _
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InNovembcr1978on/IOCfromPullman'sCorporate
{
Senior QA Engineer to'the Director of QA confirmed P.G.&E.'s
~
audi,t findings concerning Pullman's Corporate audit program.
i The IOC stated that the "Diablo Canyon Project'has been
'auiditk5"e$tenElvh'iy'eniy lii Shrdwar's arehs'."' TN entire i
program has not'been evaluated."' The'IOC would also state,
}
"In the past, Pullman Power Products did not conduct audits br' practices to ASME r 10'CFR 50, Appendix'B."
Also in November 1978 Pullman implemented corrective j
action to NCRfDC-78-RM-004 by issuing a QA Program Description.
Pullman deleted the Pipe Support / Pipe # Rupture Restraint QA i
j Manual from its QA Program.
In its place there would only be j
one QA Manual.
The QA Program Description stated, "The basic
{
document for the QA Program is the Pullman Power Products QA l
Manual.
This manual was written to conform to the requirements of ASME Section III 1971 for piping fabrication and installation.
l Many of the requirements of the pipi g manual such as:
Organization, l
N0b NDE Calibration, Weld Rod Control, Weld heat treatment, Welders j
qualification and audits are applicable to other work.
Not all the requirements of the piping manual are applicable to the full scope of work.
Where these exceptions exist they are indicated by subtier documents such as separate QA plans, ESD's or QA instruction.'!
The QA Program Description listed a number of subtier documents as applicable to Pipe Supports and Pipe Rupture Restraints.
I But nowhere in the QA Program Discription is there a specific list of 1
the piping manual requirements which are applicable to Supports and Restraints.
The Discription states that many of the require-ments of the piping manual are applicable to other work but it j
fails to specify which requirement for which work.,Also there is no committment in the QA Program Description to 10 CFR 50 Appendix B for the other work areas which fall outside the scope of the ASME Section III QA Manual.
The result is that to this day Pipe Rupture j
Restraints still do not have an adequately defined QA Program which is based M 10 CFR 50, Appendix B6A %9Ji 0%g A h/We'U N CO4G AM/WMO gg As a result the P.G.& E. QA Department Audit 480422, l
dated 6/13/78, which found that Pullman's Corporate audit performed in early 1978 "did not effectively evaluate the quality of their i
work", Pullman was required by P.G. 4 E. to send additional staff i
to the site to perform "an overall assessment of the situation" %
W L--....-.--..-----
~ ~ * - - - ~ ~
~ " ~
- __ =
i j
to datormino whethor cdditionni roinopoction ohould bo parform d and j
tho ccopo thorcof.
Pullman'c Corporato Managemont p0rformOd tho site audit froni 7/10 to 7/20/78.
The purp'ose of Audit #7177-3-78 f
astoverifyandfvaluatefieldinitiatedcorrectiveactionthat j
r.,.e.,sult.e. d from the N..ucle.ar. S. er. vice Corporation Audit of Pullman,
{
to, verify th,e adequacy of"th's Quality Assurance Program implemented l
and the quality of hardware insta11ed primarily in Unit 1.
y l
hia1manTAudUt[ 97177-3-78 wouldresub. tin 43AuditAction
~
t j
Requests requiring correc.tive action to improve the adequacy of i
the QA Program.
Criterion I of the audit would verify 24 of the i
j Nuclear Service Corporation Audit findings that had been or would l
require corrective action.
There find l
M 1.DescriptionofindividualN;gogeluded:9... responsibilities i
are inadequate.
{
- 2. Hydrostatic testing interface between P.G.&E. and
)
PPP lacks adequate control.
- 3. Interface between PPP Corporate Organization and Field 4
Organization is not described'with respect'to Field l
fl Purchases and Corporate QA Auditing 9f these suppliers.
l
- 4. Indocttination and training program requirements for j
personnel involved in quality related activities are inadequate.
- 5. QA Document control Procedure does not have provisions for training and familiarity in the implementation of pro-I cedures.
- 6. Activities affecting quality are not, described in pro-l cedures.
1 l
- 7. No control exercised over ESD procedures
- 8. No procedure for control of QA instructions.
- 9. Procedure detailing review of Hangers and Pipe Supports l
1s lacking.
10.No procedure exists prohibiting the changing or alteration 1
of key documents.
l
- 11. No procedure specifying who is responsible for 90 l
Day Welders Log.
t l
- 12. Random sampling of welding in process not documented.
- 13. There is no procedure for preheating of weld joints.
.n
i
+. h.
"T b.. I dentityo{.My tapcandbeat-treate.,
c..,,
u
.,.,.,.,, _,...guages with applicable inspection reports.
- 16. ESD 213 does. not contain provisions for reporting
$k preandp%stcalibrationvalues.
gp. 17.' Hydr %Itatic Test Procedures did not cross reference p
each other.
- 18. No procedure for filing, storing and protection of records.
b gpt 19.Nopr$cedureorchecklisttodefinescopeoffield conducted internal audits.
Criterion II of Audit 7177-3-78 reported a significant problem 1
gg$, in the evaluation of the Piping I o's.
Information referenced on the Field Installation Instruction (Drawings) did not agree with information published on the Process Sheets.
Criterion III of Audit 7177-3-78 reported numerous individual descrepancies of Hanger assemblies but did not report any program deficiencies.
Criterion IV dealt with Rupture Restraints.
Of the 43 Audit Action Request generated by Audit 7177-3-78, 20 were written against Rupture Restraints.
A significant QA Program deficiency was. identified in the Rupture Restraint construction program.
The corporate auditor concluded:
"The rupture restraints documentation package cannot be used for an adequate audit.
It was pointed.out that additional drawings are available.
The only way some of these restraints could have been installed is by the referenced design drawings, however we were in-formed by site personnel that other drawings exist that could effect the final installation.
These additional drawings are not referenced within the RR package.
It is obvious, and site personnel agree, that this is a
{%pN(
definhteprobleminregardstodrawingreferencing.
QA site personnel also have problems getting documentation.
to properly match final erection due to lack of "as built" drawings.
It was pointed out that there is a lack of proper (g\\
interface between P.G. & E. and site PPfQA."
se,
Critoria V of Audit 7177-3-78 was Hongcr Drawing Control Qolk
- and Af Builting Program, and the audit concluded there is evidence that adequate control is being exercised.
Criterian VI of the audit was a review of Non-Conformance Repor gngoncludedthattherew'asevidencethat p
the recommended. murtien of the DR"S were " generally" followed with the necessary documentation developed to support the nature of Ehe work performed.
~
Criterian VII concerned Management Audits and found that audits were not performed in accordance with the QA Program requirements of every six months.
Audit 7177-3-78 concluded that the area of main concern was associated with Rupture Restraint.
It was recommended that a Field Inspection Program be initiated in the area of Rup ure Restraints for both Unit I and II.
A.A. Eck, who was the Jiead auditor for this audit, concluded that t g g ality Assurance Program as implemented basically meets the ASME Certe; and Pressure Vessel Code Requirements, 1971 edition."
Although significant QA problems were identified in the Rupture Restraint Construction Program, Pullman Management claimed the QA Program as implemented basically meets the ASME code re-quirements.
A possible reason for this could have been the fact that piping, which was based on the ASME code QA requirements, had no significant problems identified.
Yet rupture restraints, which were not based on the ASME code, or 10 CFR 50 Appendix B or ANSI N45.2 QA requirement, had significant QA problems.
It was their absence of committment to the federal code and national standards which resulted in a deficient QA program for Rupture Restraint.
P.G. & E. now was acutely aware that Pullman's pipe rupture restraint program had been out of control.
On 10/26/78, P. G. & E.
issued Nonconformance Report #DCl-78-RM-009.
This NCR was concerned withPullman's documentation for the erection and insp'ction of e
rupture restraints inside Containment I.
The NCR would identify:
"1. Documentation shows work complete, correct and indpected.
Work is not correct.
- 2. There is physical evidence of work but inspection records are incomplete or nonexistent."
But P.G. & E. would find that the problem extended far beyond Containment I and documentation problems.
NCR#DCI-78-RM-009 va
\\
l
~
was cancelled and in its place P.G. & E. issusd NCR4 DCI-79-RM-003 on 1/24/79 for all Unit I Ruptu,re Restraint work, and NCR4 DC2-80-RM-002 on 11/19/80 for all. Unit II Rupture Restraint Work.
Both NCR's
- DCI,7,9-RM- 0,03, and, #DC2-80-RM-002 would identify:. m...
"1.a.
Documentation shows acceptable bolted connections.
However, there are cases of out of tolerance gaps g,--
existing under base plates, nuts not bearing against splice plates properly and nut not engaged per re-quirements.
b.
Documentation.shows acceptable welded connections.
However, there are cases of materials and welds not conforming to the specifications.
3 c.
There are bolts that have " torque seal" which indi-cates tensioning and inspection, however, inspection records do not exist."
PGEE would identify the cause of the Nonconformances to be the fact that " Pullman Power Products Rupture Restraint Program has had in-adequate design change control, inspection performance and control."
Another cause not identified by PG&E was the fact tnat Pullman's Rupture Restraint construction program was not commit g o the QA
' requirements of the ASME, 10CFR50 Appendix B or ANSl !4';.2 codes, the result being a totally inadequate Quality Assurance Program for the erection and inspection of Rupture Restraints.
The corrective action required by PG&E was that " Pullman shail perform a documented inspection of all bolted and welded connections and applicable documentation, required by the Specifica-tion, as set forth in approved contractors ESD8s, in order to:
- 1. Identify connections which do not conform to specifica-tion requirements and pq h
- 2. identify connections which do etet require documentation."
IdentifieddfficientconditionswouldberesolvedpertheNCR's.
It
'should be noted that PG&E did not report these NCR's to he Nuclear RegulatoryCommisionasabjCFR Part 21 Report ble item.
. kON Pullman would issue on 2/16/79, ESD 273 "QA Final Walkdown and Documentation Review-Rupture Restraints" as the procedure to dir-ect the reinspection of. Rupture Restraint work.
The final walkdown M
fle
inapsetion and documantation revicw commenced shortly tharsafter in Unit I and continued into tha summer of 1980.
Unit I Final Walkdown Inspections were performed in non-compliancetoEfD273andotherprocedurerequirements.
Pullman Deficient Condition'N6tice (DCN's) 1476-027 (4'/1/8 0), #476-028 (4/21/80)~and #476r0'29~i5/1/80) identified that Final QA Walkdown Inspections did no't conform to 'QA instructions #13i and' #148, 'which i
statedthatESD268andESD273wouldbeusedgggdentifyand document dificiencies discovered during final erndware walkdown.
The following ESD 273 and E3D 268 procedure requirements were not implemented during the Unit I Final Walkdown inspections.
- 1. QC Inspectors did not initiate Deficient Condition Notices during the walkdown process but merely noted Q44 dfficienciesonaQC/EngineeringWalkdownSheet, (ESD 273).
- 2. A D.C.N. was not initiated for each dificient condition detected.
Deficient conditions were taken from the QC/ Engineering Walkdown sheet and listed on a punch s
l list and then assigned a single DCN number.
Representative Punch li'st DCN#381-215 for construction induced defects, had 98 separate deficient conditions listed.
This did not conform.to ESD 273 procedure requiring a DCN for dpdr eachdificientconditionnoted.
- 3. ESD 273 required that " documentation of all deficient conditions noted shall be in accordance with ESD268".
(joAThefollowingESD268procedureswerenotimplfmented during Final Walkdown Inspections of Unit I Rupture Restraints.
A. Field QC Inspectors did not generate DCN's as required by ESD 268.
Instead QC Inspectors noted deficiencies on QC/Eng. Walkdown Sheets.
B. ESD 268 required that "each DCN shall be assigned a number by the Field QC Inspector concerned."
This was not done.
Engineering reviewed the QC/Eng. Walkdown sheet and then requesggd a DCN number from the QC Inspector ClON Supervisor, not jd1 Field QC Inspector noting the 8eficient condition.
The orginator was squeezed out of the picture.
flo
C. Field QC Inspactors did not " affix a hold tag to all j
discrepant items reported on a DCN".
During the Final Walkdown Inspection Program for Rupture Restraints no 3.c,....... hold. tags were affixed yhen a deficiefst condition was identified and then listed on the QC/Eng. Walkdown sheet.
Deficient (discrepant) conditions were identified on Paper but were not identified in the field by having a m.....
hold tag affixed.
These deviations from ESD 273 and ESD 268 were carried out by Field QC Inspectors and Engineers
... based on verbal instruction from QA/QC and Engineering Man-agement.
Additional noncompliancies to ESD 273 were identified on DCN#476-030 (5/16/80):
- 1. Field QC Inspectors did not reference assembly drawings for their examinations of the U Bolt.
Verbal instructions on QA/QC Management to Field QC instectors was to only assure U Bolts were in place and not perform detailed examinations to the drawings as required by g 2
- 3. Field QC Inspectors did not examine assembly drawings componentdfscriptionsagainstinstalledassembliestoin-sure all components had been installed.
Verbal instructions from QA/QC Management were to only assume that U Bolts were in place and not to perform detailed examinations to the drawings.
ESD 273 would be revised by Pullman implementing the verbal in-i structions used to perform all Unit I Final Inspections after the whole Unit I Walkdown program was completed.
PG&E would approve this revision in late May/early June 1980.
The Unit I Final Walkdown Inspection Program would henge ND identified significant numbers of discrepancies and resulted in major rework.
Pullman DR#4259 is representative of th'e type of discrepancies identified.
DRf4259 identified that connections on Rupture Restraint 126, modified in March 1976, were not to specification.
The following discrepancies were identified:
~
n
~
~
l
- l. A plato added was not documented on a material requisition or marked to identify source.
- 2. FW 32, designed as a full penetration weld on three sides 'of the added plate, was 1/16"-below flush and the weld"h'ad'not been ultrasonically examined and was i
now inaccessable.'
- 3. Original eight-bolt holes in the receiver plate were plug welded without documentation.
The technique used did not comply with AWS DI.0-69 code.
- 4. The four new lower bolts were drilled through FW 32 and its backing strap.
The backing strap was not trimmed to facilitate full seating at the bolt head and the strap had a maximum gap of 1/4".
- 5. Design required eight 5/8" A 325 bolts but eight 3/4" A490 bolts were installed.
Washers were installed under the turned element but not under the bolt head.
Bolts were not documented on a material requisition or marked to identify source.
- 6. The top south bolt had received air arc damage resulting in fusion of the nut and bolt.
- 7. The bottem north bolt did not have full engagement.
- 8. All bolts have been tensioned, evidenced by torque seal, however, process shee,ts were not documented.
- 9. Splice plate had been installed with a 1/16" gap at top and 1/8" gap at the bottom without shims.
e
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- --,+. -.---
ldOb The Unit #I[ Final Walkdown Inspection began *in June 1982.
To expedite the Walkdown process ESD 273 was revised to delete from Dct h5N the Walkdown process all bolted and welded connections installed
-a after 1/24/79.
The basis'for this delection was PG&E's NCR f h' 79-RM-003, dated 1/24/79, which stated under corrective Action to Prevent Recurence that " Pullman Power Products has developed and implemented 'a "pEogra'm w'hicii ass ~ures adeqtiate' control of design
~
~
. changes.
Training and indoctrination programs have been developed and bnplemented which assures adequate performance of inspection
+
~2 personnel."
As Internal Auditor, in a July 7, 1982 Pullman Interoffice.
Correspondence to the QA/QC Manager, I requested a reconsideration of the deletion of Final QC Walkdown Inspection of Bolted and Welded Connections installed after 1/24/79:
"There is documented evidence available which raises questions about the " adequate per-formance of inspection personnel".
Since January 1979, there have been approximately one hundred (100) findings concerning discre'pancies or noncompliance.= to procedures, committed by Field QC Inspectors or committed by others but not 1Elentified and/or corrected by QC Inspectors.
These findings are documented on Pullman Internal Audit Reports and PG&E Minor Variation Reports.
Most of these findings involve Unit #2 work.
The areas of discrepancies or non-compliances identified were Quality Control Inspections, Process Sheet Discrepancies, Discrepancies with Installed Material Removed and To be Reinstalled, Discrepancies with Material Storage and Traceability and Discrepancies with Field Warehouse Requisition and Material.
But Pullman QA/QC Management would not reconsider and Unit gg
- Tinal Walkdowns were not performed on post 1/24/79 rupture restraint work.
The Unit II Final Walkdown Inspections would also result in major rework of rupture restraint.
Subsequently, Pullman Field Engineers wrote several Discrecancy Reports on post 1/24/79 work T
yELTautty
\\kh$4whentheworkwasinad=quotelyreviewedbyEngineering.
Also Deficient Condition Notices would be written identifying documentation problems missed in pre-1979 work.
l 9Y
In 1982 serious prob 1 cms were identified in the calibration process for torque wrenches used in the rupture restraint bolting program.
The problem extended beyond rupture restraints to calibrated equipment used on ANSI B31.7 and ASME code work. PG&E,'s
~
Gener,al Construction'Depa'rtment had been providing' calibration....
services to Pullma'n at the Diablo Canyon' site since at least 1974.
P'G&E calibrhted 'a vafi'ety,of"t'ool's" including:~ ' torque wren'ches, hydrogages, thermometers, heat temperature recorders, hygrometers,
{gfandtrip-volt-chhnmeters.
As a result of Pullman Vendor Audits in PG&E's General Construction I was notified that some tools were being forwarded to PG&E's Nuclear Plant Operations for calibration.
PG&E's NPO calibration service had never been subjected to a QA program audit by Pullman as required.
Pullman, through myself, performed a vendor audit of PG&E's NPO Department in October 1982 and identified the following deficiencies:
i
- 1. There were no documented instructions for the calibration of Pullman torque wrenches and subsequent documentation.
- 2. The traceability of calibration operation for their torque wrenches and subsequent certification could not be assured because:
- a. The identification of the torque wrench on related documentation was not consistent.
- b. The certification documentation was confusing and in-adequate.
- c. Documentation necessary for maintaining traceability and certification proving traceability was not generated.
- 3. The calibration documentation for NPO Standards had deficiencies:
- a. There were no documented calibration frequencies for a standard used in a calibration process.
- b. Calibration information labels attached to NPO equipment did not provide positive identification of the devices for which the information was intended.
As a result of the audits in PG&E's General Construction and Departments, Pullman removed PG&E from its Approved Vendor's..._-
until such a time as corrective action measures and measures to preclude recurrence were completed and approved.
a<
~
- -,.. -, - -. ~
g
,-----m-w
-+e-e---n.,,--,
s
.e s,---,e-4,aype-9 m w-r e
--.I Subsequently PG&E would write a Minor Variation Report #M-4406 against Pullman.
The discrepancy would identify that Pullman had procured calibration services from.PG&E General Construction Depart-ment without written contract or. specification which delineate,d
.......................i..
-,..... u Quality and T,echnical requirements.,This calibration service had b'en g'oing'on as'far back as 1974 without Quality and Technical
~
requirements.
'"~~
~~'A'lso".ip 198f, significant Program' deficiencies w' era
~
identified in the application of Weld Procedure Code 7/8 to Rupture Restraint Welding.
In August, through Pullman Unscheduled Internal Audit #32 I' identified'in'both Units of the plant a large number of
~
~
square groove welds made in one inch thick material using code 7/8.
These type welds were not a prequalified joint detail of the AWS Welding Code.
Weld Code 7/8 did not have Procedure Qualification Records for the Type Weld as required by the AWS when joint details differed from those prescribed by the code.
PG&E and Bechtel res-ponded on 1/24/83 to a Pullman letter concerning this problem by stating that the square groove welds would not be allowed.
In addition, the PG&E and Bechtel letter stated :" Weld procedure specification code 7/8 has been approved for the process and joint
' configuration itemized on the WPS.
There itemized parameters are j
considered prequalified by AWS or are supported by tests and pro-cedure qualitication records.
If Pullman wishes to use WPS Code 7/8 for processes or joint configurations not itemized a new WPS and PQR's are required."
Based on this PG&E and Bechtel letter, my Pullman Unscheduled Internal Audit #35, dated 12/1/82 with a final prepared date of 3/23/83, identified in both units of the plant a number of single
\\kUb
$ /evel groove welds in skewed T joints with special fit up require-ments and fillet welds with special fit up requirements which were not prequalified AWS welds.
The welds were made with Code 7/8 without establishing Procedure Qualification Records.
In addition, eight other types of joint configurations were identified as made with Code 7/8, but which were'not itemized in the code 7/8 WPS.
These welds did not conform to the intent
\\%
l of the PG&E and Bachtel letter and waro nonconformances 'to the Weld Procedure Code.
Other Weld Procedure Code 7/8 deficiencies l
were also identified.
Pullman spent 1983 and 1984 implementing corrective ~ action to these Weld Code 7/8 problems.
But the J
coriective a'Stion'has hot'addres' sed all the problems.
Code 7/8 wa' 'reirised' and new weld procedure #AWS 1-10 generated which j
s addressed ~ joint configurations not listed in Code 7/8.
But the ac-tual welds in the field made in non'conformande to Code 7/8 have not been addressed.
The Pullman Power Products construction program for Pipe Ruptures Restraint has a long and continued list-ing of discrepancies and nonconformances to PG&E specification QOAand10kFR50AppendixB.QualityAssuranceRequirements.Therecan be no assurance that all of the problems have been identified, reported and corrected.
PG&Einf.S. #8833XR defines Quality
~
Assurance as those planned and systematic actions necessary to establish confidence that material (equipment and systems) will.
perform satisfactory to services.
PG&E defines Quality Control as those Quality Assurance actions which provide a means'to con-trol the quality of material supplied (and work performed) to predeterminded requirements.
Pipe rupture restraints have had a continuing history of failure to meet basic codes and quality assurance standards.
Perhaps quality assurance is all irrelevant.
If QA matters, however, there is no basis for confidence that if an earthquake occurs, the piping will be sufficiently res-trained to avoid damaging surrounding equipment.
I have read the above M page affidavit and it is true,.
accurate and complete to the best of my knowledge and belief.
b'b-b k g
Signed (M O O-Date f
Harold Hudson (3
SIAIE OF CALIFORNIA 5da f
CDLNIY OF SAN LUIS OBISPO gi On June 5, 1984, before me, the undersigned, a Notary Public' in and for said j
g" p, 2 g County, personally appeared HAPOLD 0. HUDSON, proved to me on the basis of satisfactor,;
evidence to be the person stose name appears in the above instrument, and acknowledged '
to me that he executed same.
V, n
,4,g HH/nw WIEESS my hand and official seal, y u.4, il L% LM
['
Lisavdenter, Qg Notary Public N
97
,v-
,n
INTERVIEW WITH NRC INVESTIGATORS January 5, 1984 Howard" Johnson's, San Luis Obispo Present:
DENNIS KIRSCH, Chief of the Rea'ctor Safety Branch, Region 5, Division of Reactor Safety and Projects.
GONZALO HERNANDEZ:
Reactor Inspector, Region 5.
TIMOTHY'J. O'NEILL Pullman QC Inspector at Diablo Canyon.
STEVE LOCKERT: Pullman QC Visual Inspector.
JOHN CLEWETT, Government Accountability Project.
KIRSCH:
Steve you talked with Mark Padovan (sp) on the 23rd. Oh by the way, the time is 7:27, the l
date is January 5th, 1983.
I I
84.
KIRSCH:
By golly, you're right. I am running behind, My check book is going to be in terrible shape. You talked with Mark Padovan on the 23rd of December and relayed to him a number of concerns. What I would like to do is go over those concerns first of all, and try to establish basically read them into, I guess, the record, probably be the best thing to do, and establish if you have any additional information other_than just these kinds of i
concerns, additional information that is relevant to each of these as we go through them. Ok, and then we will get to any additional ones after we go through all these. Now these are Marvin's words, based on his phone conversation. His write-up of what he understood from the phone conversation with you. You indicated that in mid-September of 1983, you were reading PG&E and
]
Devine Exhibit 10
{
pago 2 KIRSCH:
Pullman contracts #8711 fe,' Pipe hangers and #8833XR for rupture restraints which define the work Pullman was to do for PG&E. The contrac'ts indicated that Gas-tungston arc (?sp) welding equipment was to have a reostat (sp) control and be of high-frequency so that no base metal and electrode contact was necessary to initiate
- welding. And your concern here was that the contact, of course will cause tungston inclusion (sp) to the base metal.
LOCKERT:
Well my concern is #1 they are not following the procurement document document.
KIRSCH:
Well we'll get to that, but the safety significance i
of this thing is that it would cause a tungsto'n ihclusion into the base metal from some melt of the tungston electrode on the tape machine O'NEILL:
The reason that tungston inclusion is a problem in j
base metal is because its generally a sharp indication thats not, its treated as a slag (SP) inclusion by the x-ray inspection out there, but a tungston inclusion generally is not melted into the base metal, Its a very tungston is a very hard dense material.
KIRSCH:
I understand.
O'NEILL:
. and when it breaks off in a weld, what it creates is a sharp stress rays or point where stresses will concentrate in that weld, and that is the problem with tungston inclusion.
KIRSCH:
We'll get to some more on this. I just.want to complete reading this please.
This type of equipment has not i
been in use at Diablo Canyon for the last five years.
The reastat (sp) control permits the current to turned _
2 i
off and on and~ adjusted without the reastat control l
l
C KIRSCH:
(drawing)? in or begin welding and separating the electrode from the work to stop welding causes defects.
PG&E indicated to you that would change the contracts.
i LOCKERT:
Yea, this was at a later date. In mid-September I sought Pullman's attention.
KIRSCH:
OK, who in Pullman did you call?
LOCKERT:
The QA manager, Harold Carter.
KIRSCH:
Harold Carter, Ok.
LOCKERT:
and I notified him per memo.
KIRSCH:
ok you notified him by Memo. Do you have a copy of that memo?
LOCFERT:
No I don't.
KIRSCH:
for me, ok, well we'll find it.
1 O'NEILL:
You might mention why you don't.
LOCKERT:
Oh, when I got fired I was not allowed to bring any paperwork with me when I lef t that included memos, personal scratch paper, anything like that.
KIRSCH:
That's understandable. That's normal. OK uh I guess what I need to know what kind of tape (sp) welding equipment do they use out there.
LOCKERT:
well they use a resistance type power supply, they plug into what is it called..
O'NEILL:
its a standard grids supply, Manpower supply, and each welder plugs a resistance box into the power supply t get his well in (?). The way the-/ go about tig (sp) weldini
. r..
y
paga 4 O'NEILL:
is they usually take an electrode lead, or stinger for stick welding. they take and they'll have the fitter s clip the tungston lead into the electrode lead when they want to start their arc, as they do it, sometimes
~
you'll have fitter dialing you up to what you want to be welding at but each control box has varied steps that.
increase the. current which is not the best way to be dealing with tig (sp) welding because you don't have the control that you normally get with reastat control.
that's why you want a reastat control (unintelligible)
KIRSCH:
OK, the day the shielding gas is all coming off the bottle (unintelligible)
O'NEILL:
The bottle is right here and the flow meter may be right there at the station or it may be 3 stories up on the next floor.
j KIRSCH:
OK. so you use a resistance type box off the grid.
3 LOCKERT:
right.
O'NEILL:
DC straight polarity KIRSCH:
and this has the switched, well maybe like a reastat is very sloppy, not a good a reastat O'NEILL:
It is a definite step control.
KIRSCH:
step control yea.
LOCKERT:
and only if the fitter is on the box adjusting for the welder. That's the only control he has. If the fitter is not there, the machine turns on to whatEver value its set at and stays at.
~
KIRSCH:
uhuh.
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page 5 O'NEILL:
The way I have seen most of it done out there, the welder will strike an arc, initiating an arc by touching the tungston to the fa,ce metal and it will j
break that loose, he'll start welding and when he gets 1
done, depending on how much he knows about what he's doing-usually I seem em just take a tungston and he'll just pick it right up off the face metal which is really.p6or on stainless steel because you use all your gas shielding into that weld deposit (SP?).
KIRSCH:
Another question -
O'NEILL:
They have documented problems with the starts and stops as far as radiographs o,n stainless steele (unintelligible) that does contain it.
f LOCKER T :
I can read you here on my document the type of defect that occurs at the end of weld cycle. The defects occur at the end of the weld cycle when the welder tries i
to extinguish the arch, by pulling the tungston electrode directly out of the area over the weld pool. The weld pool is kept molten as the arc elongates, but then 4
starts to freeze as the arch and magnetic field collapse oscillating the weld pool and as the weld freezes, this oscillation creates a whole new center of the weld pool
{
and by taking that tungston electrode straight out of the weld pool you do not see that defect all the time, j
but many times you'll see that defect.
KIRSCH:
the hole, what are you saying then that it creates porosity (sp)
O'NEILL:
You get a it's called a crater, its due to the i
magnetic effect and it is also due to the fact that the puddle is shrinking there, its hot and starting to solidify, its not as bad a problem on stainless as it is on aluminum but you do get the porocity because they lift the tungston off of there
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page 6 O'NEILL:
have a real long arc that creatca en area where its still being heated, but there is no shielding gas flowing over it, and when you suck nitrogen and oxygen out of the air into staini'ess steele, you create some definite metallurgical problems with it when you weld it 1
B KIRSCH:
Ok uh, Wete you involved in observing tungston
~
tig (sp) welding, or inspecting tig welding?
9 i
,s LOCKERT:
yes.
F KIRSCH:
What you were a visual inspector?
5 LOCKERT:
that's right.
KIRSCH:
What level?
LOCKERT:
level two KIRSCH:
You were level two?
LOCKERT:
right.
KIRSCH:
what-In your opinion what would be the effect of this-now understand on pipe you wouldn't want this I
kind of a stress raiser, but what would be the effect did you see them do this on both pipe and on supports?
a support attachments to the stainless pipe? They don't use tig (SP) welding on carbon steele.
O'NEILL:.
They do depending on the problem I see is they don't know where to use it on different things. They'll use tig (sp) welding out on the wind on -carbon steel on the pipe around i
KIRSCH:
Oh yea?
i l
e b
~ - -
Page 7 O'NEILL:
I have seen them do that with regularity and I as an inspector brough it to the Engineer's attention that it is not a real good thing to be doing, but they don't seem to They have decided that this is how they're going to do it and that's the way they're going to do it.
KIRSCH:
Out on the rack they'll use tig (sp) ?
O'NEILL:
I have seen them use tig (sp) welding out on the pipe rack on windy days, on joints that would make a lot more sense to use shielded metal arc welding under the conditions and joint design.
KIRSCH:
Do you see any problems with using tig (sp) welding out on the rack?
O'NEILL:
As long as they shield the wind, but they don't shield the wind and there is no root pass inspection require-ment, and as a matter of fact, the job I was on.
l KIRSCH:
Where they welding pipe or were they welding structural?
1 O'NEILL:
This they were welding hanger members that were carbon steel.
KIRSCH:
Then they were structural?
i O'NEILL:
uhuh. But I have also seen them use it quite a bit on stainless pipe. In fact one day I walked by and a < elder had his fan blowing right across.
his tig(sp) are to where I could visually see that he was contaminating that weld. I asked him to stop i
l He became very abusive. I just asked him would you please move ycur fan here, and the guy just basically got in my face and said I had no qualifications to be -
telling him how to weld, and I myself have been a i
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Pcg8 8 O'NEILL:
tig (sp) welding for six years now. I have used a certified. I qualified to Military standards which are some of the tightest around for tig (sp) welding and I am about 10 units short for a bachelcr of Science in Welding Engineering. Steve's got one. So.
b Can you tell me where that was at?
KIRSCH:
E!
i O'NEILL:
Cal Poly.
F I mean where you saw that fan blowing across.
KIRSCH:
No no, Oh, The fan was blowing across the guy was welding O'NEILL:
on 3/4" schedule 160 stainless line that a 650 PSI l
Nitrogen line for one of the accumulators in Unit,II containment.
1 LOCKERT:
91 level (sp) (unintelligible) pressurizer right next to the bottom of the stairs i,
O'NEILL:
its the accumulator.
s LOCKERT:
Oh yea the accumulator.
l I might add that I informed the guy's foreman about O'NEILL:
what he was doing, and he just and he just asked me well did the weld look bad? and the weld visibly didn't look bad, but if you were to use some NDE (sp) on it l
its my opinion that it would not turned out good on those passes, but because they were covered up it might i
have not when the final NDE (sp) was performed on it might have turned out good.
That kind of a line is not required to be radiographed I
i KIRSCH:
I think its just a liquid penetrant.
O '!EILL:
Liquid penetrant, yea.
I
Pcgo 9 LOCKERT:
Dennis, in reference to your question where I saw that process being used, it was on pipe welding, stud welding.
KidSCH:
la unit two?
LOCKERT:
In unit two'and uh KIRSCH:
How long ago, when was that?
LOCKERT:
Well I'd say from September-October to December.
KIRSCH:
of 83?
LOCKERT:
What's that?
KIRSCH:
of 837 LOCKERT:
right HERNANDEZ:
You saw that repeatedly?
LOCKERT:
I didn't see gas-tungston arc welding being used every day, but on a week to week basis, I might get some gas-tungston arch welding where they use it to attach studs to the containment lyre (sp) and occasionally they use it for root passes on structural-welding.
O'NEILL:
They use it when they have to make an open root weld LOCKERT:
Is that the 88-89 i
\\
O'NEILL:
That would be the 88-89 procedure for carbon steele hanger members when they can't get l
l KIRSCH:
88-897
i WPS a
in welding procedure specificat o.,
' LOCKERT:
Pullman O'NEILL:
of that line in the Do you remember what port oline for the accumulator?
in accumulatpr; the nitrogen a modification ml KIRSCH:
It was l
something about it.
early October?
aus.
d in what, I remember r.
of that line that occurre LOCKERT:
floor. It wasn't in
[
h yea, it was being done on t e way I calmed d the its position, and I questionefor his isodiagrams (sp)
O'NEILL:
i was making, the guy down is I asked h m I
d weld number he so I could tell what fielhe didn't have it, which is work station,
[
~
and at first he told me s
at the it be therethen they realized that
~
that a requirement and finally he produced Its somewhere it,
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h goods.
don't know they really had to put up t einto the accumulat going right accumulator is.
what number the
~
1 of the stairs.
i you said the bottom i
L
]
h KIRSCH ~:
h L
LOCKERT/
f-right.
the stairs.
t-O'NEILL:
only one near the bottom on There is KIRSCH:
thats true.
O'NEILL:
able to find it I think.
be If I remember right. We'll I
KIRSCH:-
l unit two right?
This is HERNANDEZ:
Right.
LOCKERT:
9 O
_ + -,
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pago 11 O'NEILL:
I have that documented on my daily inspection reports for that day.
LOCKERT:
I was also involved in that and you can find my daily sheet you probably can get some field weld numbers for that.
KIRSCH:
OK.
HERNANDEZ:
What was the date on that.
LOCKERT:
Early October.
HERNANDEZ:
So we can check the daily's for early October and look for your file.
LOCKERT:
Yea.
O'NEILL:
Steve can't They didn't allow him to take his own personal inspection records out.
HERNANDEZ:
Yea, but they should have his.
O'NEILL/
LOCKERT:
Unintelligible O'NEILL:
Another instance I saw gas-tungston arc welding that I realized was not going in the way it should and I addressed this to the QC manager in the meeting we had today.
Due to the lack of training I was not aware of the proper procedure I should have followed when I came across this. Its on Class E piping which requires no QC participation as far as,,the in-process work. It requires heat and TO and weld filler tracibility and thats about it. I as an area surveillance was looking at what was going on here watching them purge and I noticed they weren't purging their lines they were 9
,m-
p293 12 1
O'NEILL:
They were doing this down on a bench also on the floor I reached in under an elbow where I could get my hand l
in to feel the back side of the weld, and the stainless when it is not purged properly gets a sugary coating, and it was pretty apparent that they didn't, they fell through on it, they had a lot of garbage on the inside and'it was sugared quite a bit.
KIRSCH:
OK, what kind of a line was that on ?
O'NEILL:
That was on a 4"< scheduled 10 stainless line in the l
in the 85 foot elevation far north end of the Turbine j
one building.
KIRSCH:
Those are class E lines?
O'NEILL:
Class E and it has something to do with the reverse l
osmosis area.
KIRSCH:
You are aware though that that is not a safety related system, and therefore it is outside of our regulatory bound.
t O'NEILL:
I would just like to point that out as part of the
)
way tig (sp) welding is conducted around there, from 1
what I've seen.
KIRSCH:
OK.
7 2
I CLEWETT:
.If I could make just one comment. I think, I mean I don't know enough about welding to know what's what on this and Ibelieve the both of you that this is not a particular safety related here. I-think one thing that is of potential interest to the NRC is to the extent that these are examples of a certain philosophy towards welding and, you know, that it may be that because of the fact that there are lots of examples it means that
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Paga 13 CLEWETT:
there is 'a more widespread phenomenon thats going on.'
KIRSCH:
I agree, I agree, but my interett was that I wanted to know if it was a safety related line, I wanted to know what line and where.
CLEWETT:
Absolutelf.'
KIRSCH:
Yes the comment is well taken and it was understood (unintelligible).
KIRSCH:
OK. Let's go on.You indicated that Pullman welding procedures 7/8 for rupture restraints was qualified on flat plate in accordance with the Asme (sp) code.
LOCKERT:
That was qualified on pipe.
KIRSCH:
That was what I rememberd. Ok so it qualified on Pipe.
LOCKERT:
Uhum.
~
KIRSCH:
Using the same qualification information obtained by Asme (sp) methods, Pullman qualified the procedure to AWS standards. So in other words they took the Asme (sp) qualification and 4
LOCKERT:
Transferred KIRSCH:
Transferred it over to structural.
LOCKERT:
to AWS.
O'NEILL:
They're applying it on AWS work. They h. ave not qualifid it per AWS Dll standards.
LOCKERT:
the Rupture restraints.
y
-4
p3ga 80 O'NEILL:
They're using it on restraints.
KIRSCH:
Is that AWS work?
I KIRSCH /LOCKERT/
O'NEILL:
Unintelligible.
LOCKERT:
definitely for the rupture restraints.
KIRSCH:
For the rupture restraints only.
O'NEILL:
I believe its D11 79 (unintelligible)
KIRSCH:
You say its not correct to qualify the procedure.
to AWS standards using Asme (sp) methods because joint design is essential as with the AWS standard quali5ication where as joint design is not essential for qualification j
in accordance with Asme (sp).
O'NEILL:
I might add that its not considered an essential i
variable, meaning if you change it you don't have to re-qualify the procedure, but Asme (sp) section i
9/]977 edition says your qualified welding procedures specification will list all qualified joint designs j
and up until when did that GWS come out?
Up until October, they did not follow that requirement of Asme (sp) they would, as in a case in point, procedure 7A is qualified, and it says in the procedure that this procedure shall utilize a backing strip on all welding meaning its not suited for open root welding. They use it with regularity on open root welding where hanger members, this is what we're discussing, where they'll back-grind the back side.
KIRSCH:
and back weld it out
~
l
-y O'NEILL:
Back weld and weld from two sides. Now ASME doesn't prohibit that but they say it has to be noted on your i
WPS. I addressed that verbally to the QA/QC manager and was told that well we have been doing like this for 10 years and we're not going to stop now.
KIRSCH:
Something.c6nfuses me though. Ifr you back-if your using it for AWS welding, whey would you comply with the ASME requirement to note it on the WPS for back gouging?
l O'NEILL:
THE 7/8 Procedure qualification, WPs is qualified ASME section 9 for use on hangers only.
KIRSCH:
OK.
O'NEILL:
They cannot tranfer that qualification to AWS just by saying well we have this qualified procedure, now were going to do it like this.
LOCKERT:
I might add, Tim that the tinsel (sp) and bend tests will qualify forfor either code (?)
KIRSCH:
That's right.
LOCKERT:
But now, when you take your ASME qualified procedure and switch, and move it over to AWS area, the only joint design that is now qualified in the AWS is an original joint design shown on the CQR KIRSCH:
unintilligible.
LOCKERT:
Right, so all of a sudden, joint design becomes an essential variable over here. WPS 7/8 will only weld one joint design in rupture restraint, As far as I know.
~
KIRSCH:
Is that how you remember 7/8?
y,
-y y
7,
Pcg@ 16 I don't remember the correct code.
Me either.
LOCKERT:
Well I can provide you fellow with some documentation here.
KIRSCH:
That would be some help.
LOCKERT:
There is KIRSCH:
What are we reading from here?
LOCKERT:
This is my prepared document. I gave you some specifics over the phone, and this is my written response to you fellows.
KIRSCH:
Now is one of those copies ours?
LOCKERT:
If you'd like it.
KIRSCH:
Oh good.
LOCKERT:
so...
KIRSCH:
That will maybe help preclude me from having to write so much.
O'NEILL:
When you want to use a AWS procedure, the way AWS, are you familiar how the AWS structural code is set up and work with it.
KIRSCH:
Somewhat.
O'NEILL:
Well you have pre-qualified procedures saying that if you use this base metal and this process and this
~
filler metal, you can use one of these job designs _
i
Paga 17 O'NEILL:
that we have already estalished or qualified without going through the expense of quhlifying this procedure.
The 7/8 procedure is a procedure qualification, but it only applies to the materials that they use to qualify that. AWS says that what you have to do in the event that you want to qualify material that is not listed in their code is you have to go through essentially what they have done to' use 7/8 as a AWS procedure.
But then its only qualified for that material they did the procedure qualification on.
KIRSCH:
Ok, so then they're using different materials.
O'NEILL:
They're using it as a pre-qualified AWS procedure.
j I
But the main thing is AWS says you have to write a l WPS welding procedure spec for all your qualified joint designs, and that's one thing they for pre-qualified?
For pre-qualified joints you shall write a WPS welding procedure spec for each qualified joint design that you plan to use in production.
HERNANDEZ:
You do not have to write a PQR?
O'NEILL:
Not. You do have to have a PQR HERNANDEZ:
not for the pre-qualified O'NEILL:
Let me think, there is a form in there If I could look at your HERNANDEZ:
Well your utilizing the pre-qualified joint design O'NEILL:
Right so they would not require
s Page 18 HERNANDEC:
That's the point of using the LOCKERT:
That's why you use the pre-qualified. You can use something else as long as you qualify it.
O'NEILL:
Right.
HERNANDEZ:
Provided you have a welding procedure specification that tells you what your going to do.
LOCKERT:
Right.
O'NEILL:
This is an item I'd like to address later, or now, its dealing with the use of un-qualified base metals out there.
LOCKERT:::
This is one thing in 7/8 that I was researching now. Pages 3,4,5,6 are the PQR. This paperwork was never allowed.
This paperwork, the PQR, I was never allowed to see this as an inspector out there. Pullman denied me access to this record here. I don't know whey, but what I was trying to discover was that what was the original joint design in the ASME qualification and it says here joint dimensions are in accordance with sheet 2 of 10 l
on this procedure qualification ~ record, and they also have another one over here. Sheet 2 of 10 and we have six sheets in this WPS so its very confusing to try to figure out what the original joint design I
was. Here again, sheet 2 of 6 and so they're referring l
us back to here now which one was the original joint design, I don't know, I was never able to determine that so consequently I was never able to determine which joint design was actually qualified in the AWS code area.
t
-o HERNANDEZ:
And again, were talking about the rupture restraints.
Your talking also about some problem with the unqualified l
base materials.
p293 19 O'NEILL:
Yes I'd like.
KIRSCH:
Let's hold on before we get into to that one.
Let's wait, because I'm still confused a little bit.
i LOCKERT:
OK.
KIRSCH:
You're saying that they Pullman uses 7/8 as a qualified AWS procedure for all kinds of joint designs?
O'NEILL:
YES, in the rupture restraints.
I don't inspect rupture. I noticed from reading the rupture restraints specification and talking with Steve when he was involved with rupture restraints. I was looking at some today...
KIRSCH:
This just based on the PQR from the ASME.
O'NEILL/
Yes/ right.
LOCKERT:
KIRSCH:
What I don't know right now, but using some joint design.
O'NEILL:
Yea, you can't determine (unintelligible) what
^
joint design they did use. Codes are set up different ways to address different types of fabrication. You 1
realize AWS you're dealing with structural shapes, basically hot rolled steel or ASME you can be dealing with all kinds of KIRSCH:
But its still legal to use an AWS qualified procedure and take it back, or an ASME qualified procedure and take it back into AWS.
O'NEILL:
You can do that provided you do it in k'ccordance with the materials and things specified in your original qualification.
Pcga 20 LOCKERT:
That's the point I was trying to make. If they They've done that. They've used the ASME qualified for welders a
HERNANDEZ:
Qualified for the procedure or the welders.
LOCKERT:
Well right'now were talking just procedure.
1 HERNANDEZ:
Ok the procedure. to the ASME and they have done AWS welding right? but doesn't the rupture restraints only deal then with a certain type of material, for instance, carbon steel?
LOCKERT:
It has to do with a variety of carbon steel the 844]
and 588, O'NEILL:
516, 515, mostly A-36.
A-36 0k
)
kLt They list them right here.
That's one of the qualified materials.
O'NEILL:
OK, you're talking Tl which is an ASME qualifed material, OK that does not really go right over the AWS.
HERNANDEZ:
What page was that you St e 2 ferring to.
LOCKERT:
This will be attachment looks like 10, it will be page 1 of 3 of Pullmans AWS 11 O'NEILL:
See ASME will let you do that'. If you qualify and you group them into these P numbers, you qualify in this P number, you can use
page 21 KIRSCH:
Anything in that P group.
O'NEILL:
Yea, but they also limit that, they say you have to look at the mettalurgical and chemical and the weldability aspects, ASME pre-supposes that you have a cognisant Engineering staff that really looks at this stuff and reviews it before you put it into the field. And that's one thing that I don't see happening out there by the way they use their materials, and the way they use un-qualified materials l
which I will addresc later when we get through all of this.
KIRSCH:
Are they using 7-8 to weld materials for which it wasn't qualified.
l O'NEILL:
Yes they are on safety related items, containment (unintelligible).
KIRSCH:
Containment spray rings, supports?
O'NEILL:
Supports and containment liner studs that they attach to hold up the spray ring hangers, they are using both cases of materials that they use supposedly i
(Side 2
...on the containment spray ring, the studs to the Tape A) containment liner they use A108 which is not a AWS pre-qualified material and has not been qualified with ASME procedure, its not a P1 material to the 77 edition of the ASME section 9. And they also use ASTMA 307 which is a material that comes in as a bolt They cut the head off the bolt and they put a chisel point on that bolt and they now weld that to the containment line.
HERNANDEZ: (?) I thought A307 was essentially A36 mild steel
with mna in
- there, c A307 co right think specification, spe you limitation may the if you look at on thed weldability carbon ion No se s'
A307 carbon limitatany un-qualifief that material. and sulfur, t,h ation.
takescan get out of.050 on phospho that spe ificit comes no rous c
that on that limitationsthe fact that you upper limit oonly chemical d with only, yothat materia no ve u ha l
a an l
in its lf coup eof complianof what and may ha ce are the e
ve w
w that certificateibility on kno sitea QA program do not no but on ite you a
on have inchemistry trac s
may l is.
vendor l
o that materia,that materia w the is. No in als ?
o tracibility t content liner i
carbon containment the ects what o the welding these t metallurgical aspon the h gh i
are They're studs. Um, theand phosphorous after you ittlness SCH:
liner carbon Containment ffe t of that are if is you get a bret a banding eweld c
te cted et
@EILL:
side, what you gdue to the, you g impact strength o your but and carbon in it get
(;.. _. dy it overall where they all welded C.;
of phosphorous ces the not s ct on ure testsa qualified on, that reduc i n 9, I'me Sharpe (sp) don't bottom line, impa e
have weld, and se t o z
y ow they've doncedures, and theA307. That's the ompletely a c to the I kn weld pro weld them. This is that a
these cedure to any of ven't addressdoing, compiling weld prows, to ASME terial. Ithe process address it i
to ha of to A un-qualified mayet. I'm inI'm getting re memo, to to ady see.
of a Company and the form g[;
cumentation we kin e
do i
sometime th s report?
ow...
ce right n on-conforman a n hole don't yo s to how that w1-ike write also u
educated a what a definite la I'd Why is KIRSCH:
ver beenthere. That ne ve we ha See I've out is O'NEILL:
system to you people works cross get a O
I
Pcga 23 l
O'NEILL:
training out there.
L LOCKERT:
Do you, Inspectors in the field don't field don't write the non-conformance report, usually the inspectors only write deficient condition notice which is usually KIRSCH:
DR?
j LOCKERT:
no DCN they call it...
O'NEILL:
but DCN is Pullman's in-house method of reporting problems. Now you submit that to the QA/QC manager he decides that this report (unintelligble) PG&E if it is, he generates a DR.
LOCKERT:
In fact, they don't even want the inspectors to disposition their own DCN's. The QA/QC manager is the i
one who holds responsibility ultimately for dispositioning 4
l all problems that come into his hands..
KIRSCH:
Containment liner. Which containment liner, unit I Unit II, both?
O'NEILL:
Unit I and Unit II. In fact just to show you, I got LOCKERT:
Gonzalo, I think you were correct in saying that when you order SA 307 as a non-headed anchor bolt, the purchaser must specify ASTM (sp) designation A36.
What Pullman's doing is taking the regular bolt and cutting the head off. You're getting.
f O'NEILL:
That's a warehouse requisition.
containment liner
]
(at same time studs for that particular. The guy hasn'l put the hanger as LOCKERT:)
number on there. Here's a copy.
KIRSCH:
This one isn't the hanger number 532S.
4 (at same time)
\\
Page 24 LOCKERT/
HERNANDEZ:
You're getting this material (unintelligble)
Oh I see so they're not actuall'y ordering that Right. they're ordering bolts and then (unintelligible)
O'NEILL:
That is the detailed drawing. I'm sorry that is the (at same hanger number.Sometimes they do sometimes they don't.
time)
They really don't fill those out properly.
Here is a copy of the PO that comes in on.
KIRSCH:
Can I have this.
O'NEILL:
Yea you can have those.
LOCKERT:
DO you have a copy of those?
O'NEILL:
I can get them. Ive got the number. You can see that that PO is for bolts, and then here's another one where they have A307 weld studs that are purchased as studs for that reason. Here's a copy of what they're suppose to be using there for all your welded studs are suppose to be done to AWS Dll. I talked to a Foley Engineer today, that told me that they were written up on an NCR for welding A108 studs on to something.
Now I don't know what that was, but thats the case from.
As a welding engineer I would not question the pre-qualified welding of A108. Because the studs come in on that specification with a limiting carbon on it. The carbon on that specification is limited to.20 with a tolerance on that, which is within the realm of good weldability. You can generally weld carbon contents up to about.25 and within other limits with ease. Now it doesn't get them away from the fact..that it's not a pre-qualified a material. But the A307 scares me, because they, you know, that's just, that's not a good material to be welding to begin with.
~
pago 25 l
KIRSCH:
What is this from?
i O'NEILL:
That's from this hanger drawing right here that another inspector happened to be involved with. I just got the copy of this to show what there.
KIRSCH But you spy *they have no procedure for welding of studs?
O'NEILL:
Not A307. It's not listed. If you look in your Dll right there, it's not listed as an AWS pre-qualified material. Nor is A108. From a metallurgical stand-point, you'd have a lot less problems welding A108 due to l
the fact that you do have a limitation on carbon in that. Because A307 is made to be a fastener. They give the steel maker, the manufacturer, the leway there to I
1 say here use whatever carbon you need to meet these l
specifications. They're not anticipating being welded.
HERNANDE2:
Going back a little bit, you're talking about the DCN's and the stats for O'NEILL:
Deficient condition notice.
l HERNANDEZ:
Deficient condition.
O'NEILL:
The way those work is you initiate one of those, you have your lead man approve it and then you have 3
to take it over the field engineers and you have to get their approval and you have to get one of them to sign it and disposition it, if its an in-process type problem, Like say somebody passed a hole (sp). point somewhere. I came on one where they pas,, sed a hole (sp) point for backing off the bolts on the base plate prior 1
to welding. Well you have to get the engineer to i
disposition that, uh, in some cases they refuse to l
sign them. I have had three instances now where they j
Pago 26 O'NEILL:
refused to sign my DCN's. And 'all I can do is note that and send it on through. Sometimes My supervisors will try talk me out of it, and I know its dificient, and I can show them right in our specifications where it is deficient. Don't tell me oh no that's not really a deficient condition because of this or that or whatever. And I have also had the QA/QC Manager just flat out void it out and say this is not a deficient condition. And if you want to check my DCN log book I kept logs of all of voided and non-voided.
LOCKERT:
The big point is is that they're not given the chance to evaluate whether it is a non-conformance or not in many cases there not being evaluated. Not given the chance to be evaluated.
~
1 HERNANDEZ.:
What process does this DCN go through, if it does, if it is approved?
O'NEILL:
If its approved its taken, ok it goes from me to field engineer, who signs it, and then it goes to Well I give my lead signature to field engineer, then it goes to the chief engineer, he reviews their disposition. It goes to a level three, who reviews the NDE(sp) requirements of any re-work or work that's going to be re-inspected, any type NDE(sp) requirements and then it goes to the QA/QC manager for a signature on that part of it. Down at the bottom, you have whats called steps to prevent recurrence so that doesn't happen again. And generally they won't accept a DCN unless you can give them a name to go point a finger at. I have written some on generic problems, like, see thats my only opportunity to inform somebody or my only means of telling them what's wrong.
KIRSCH:
Do you have, maintain a DCN log out there?
0;NEILL:
Yes I do.
. ~ - - - - -
KIRSCH:
If I ware to coms through, or como outato your l
go down to Pullman and request your DCN log copy would you have any what that give you any heartburn?
O'NEILL:
No, its up to date and you.
KIRSCH:
This is DCUrs written by you?
O'NEILL:
Yes.
i HERNANDEZ:
Wouldn't that point a finger to you though?
O'NEILL:
Not at all.
HERNANDEZ:
No?
O'NEILL:
Well, yea, if you guys come in and ask for my DCN log, they're going to know somethings going on for sure.
HERNANDEZ:
Right.
O'NEILL:
Cause I'm kind of regarded as being a shit disturber out there anyway.
HERNANDEZ:
But this DCN log is it a log that's kept either informally or formally....
O'NEILL:
No it's required by you people I believe.
HERNANDEZ:
So we could go there and look at DCN log?
O'NEILL:
You can look at anybody's DCN log out there.
HERNANDEZ:
Is a log then kept a separate log for'each inspector or a log kept.
G m
.,., - ~,
Pag 3 28 I
O'NEILL:
The log I keep is just copies. They keep the original on file in the QA/QC managers office, with the attached steps to prevent recurrence. Before they can close that, deficient condition, which is has to be closed i
before you can finally accept either a hanger or a l
piping, or whatever, They have to document the steps to prevent r' currence and then a QA person has to audit e
that to make sure its all been done, and when they're satisfied, they sign it off on the bottom.
FERNANDEZ:
But I though you said that the DCN was an in-house procedure, that they utilize before you go to an NCR. What you're telling me is essentially a DCN is an NCR.
O'NEILL:
Well it can be, but only if the QA/QC... If the DCN like it use to be that you get a DCN arc strikes on piping. Well that was automatically, anything that had to do with piping or any kind of work that had to be done on piping. That was automatically reported to PG&E. So if you saw that then it became... What happens then is you're assigned a DR number that is written on you DCN and you have to log your DCN number in you log, you log the date that it happened, whether you applied a hold tag or not, The hanger number (
)
number, or whatever, some kind of reference, and then you have a space for a DR number, if it goes to a DR, and then the date that its closed.
HERNANDEZ:
OK, that's what I was referring to, the process before.
You write the DCN originally, and if somebody along the line the QA manager decides yes this is nonconformance of condition, you then write what is cal, led a discrepancy report.
O'NEILL:
He would write that HERNANDEZ:
Who would, write it?
_o
-r.
y y
,w,
l Paga 29 O'NEILL:
His office HERNANDEZ:
Do they ever come back to you?
t O'NEILL:
Yes I would get a copy of that. I, well it would be i
first, When I submit the original copy of the DCN
~
with supporting documentation, it goes with the Engineers signature, my lead signature, it goes down to the QA/QC manager's office they run it
+
I through the mills to get the Chief engineer signature, a copy is made at that time and given to me as a control copy which goes into my log. and, I usually make an information copy of them prior to ever sending them in l
KIRSCH:
Do you keep that in your log?
)
O'NEILL:
I do in some cases, but its stamped for information i
only. I keep that.. there has been cases where I have written DCN's that got lost, conveniently, right before f
a ASME audit that had to do with uncontrolled filler metals and uncontrolled pipe attachment removal on 1
Class C.
i l
KIRSCH:
What I'm looking for would be.. Suppose I wanted to look at DCN's written by a number of inspectors, OK?
And what I was concerned about that these were that-the QA/QC manag2r had decided that it wasn't a DR, non-conforming item i
1 O'NEILL:
Uhum.
}
KIRSCH:
Is it still entered in the DCN log in the QA/QC area.
.O'NEILL:
Yea, he would have the oringal copy, If he just voided that thing and kicked it back to you, then he would noE have a copy of that, but when that happens to me, I keep i
that copy in that my log with his: signature on it voiding it so that I know what happend with it.
N HERNANDEZ:
Is,this a caparate log from tha official log?
LOCKERT:
Yea, there is two logs.
The company has one and the individual has one.
4 HERNANDEZ:
Does this voided DCN does that have a reason why its voided?
O'NEILL:
Usually he'll write so'mething in there as to why he voided it. Sometimes they don't follow much pattern of coherence.
KIRSCH:
Where do you work?
O'NEILL:
I work, right now I work in the (
) shop, and I work for the QA. What I have been doing recently is when QA, You know how the QA system works on Piping match the warehouse requisition with everything you have in the package, weld stores requisitions all of that When QA-is reviewing a package and they can't find the original warehouse requisition, They come to me and give me the approximate date of installation and I go down to the warehouse and I look through their copies and see if I can find a copy of the original. If I can find it, I burn a copy like the one I gave you there, and they use that as the QA package.
KIRSCH:
Our question though, Back to the DCN's, I want to DCN logs are all inspectors required to keep them?
O'NEILL:
Yes.
KIRSCH:
Their own individual logs?
O'NEILL:
Yes.
KIRSCH:
So if I were to go in tomorrow or someday and say I want to see the DCN, I want to look at DCN logs
~
for...
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O'NEILL:
You'd have to come to the individual inspector.
KIRSCH:
For Timothy I would just go to Carter (sp) and say Carter (sp) I want to look at thh DCN logs for inspector O'Neill and for some other QC inspector out there, who are some other ones that I can use that won't point a finger at you?
O'NEILL:
Um, KIRSCH:
Some other QC types, and just say I want to look at these DCN HERNANDEZ:
How may guys are in the (
) shop similar to your position?
O'NEILL:
There is only a couple doing the QA, see I didn't write most of my DCN's as a QA inspector in the warehouse, KIRSCH:
You did them in the field.
O'NEILL:
Field work and I, right off hand, I could give you
~
some names to KIRSCH:
OK, Why don't lay me a few, lay a few on me, so that way I can go s y I wanted to look, I want the DCN logs for these inspectors in 20 minutes, here.
O'NEILL:
Uh, One guy, Don Lee, Um...
You could ask to see Steves, They have to maintain that on File after he's terminated.
HERNANDEZ:
His private-log, as well as the one after they.
O'NEILL:
Yea,yourlogisreallyacontrolledlohthat is turned in. That's why I make the information copies also, Cause When I leave I am going to take my affirmation copies out of that DCN log and turn' in the control copies.-
O
O'NEILL:
Um, I'm trying to think of some inspectors I'm trying to think of people who are reasonably on the ball there and should have.their books in order.
Uh. Gary Sawyer.
KIRSCH:
How do you spell his last name.
O'NEILL:
SAWYER.
i i
LOCKERT:
Gerry Dunn.
l j
KIRSCH:
Gerry Dunn.
OK. so that gives me five, so that won't really point a finger at anybody. That's good, OK.
So that's one of the things we'll do (unintelligible) and we'll make copies I
HERNANDEZ 14aybe we can touch on something we did this aftern'oon.
I Have you ever been instructed-that you can write an j
NCR or discrepancy anytime that you want to?
O'NEILL:
Never.
1 i
HERNANDEZ:
There has never been a meeting held by Carner (sp) j
~
or his group where you have been informed that you have that right.
O'NEILL:
Not at all. That's one thing that we have really, l
myself, my partner, who is the Union Steward, We both address the Carner (sp) on several occasions at the lack of-training out there is responsible for a lot of the problems that he has. In fact now, When people get DR's they have just now started keeping track of who gets j
DR's written against them, and a guy that gets a DR ;
written against him now gets this letter out of Carner(sp) which is very strongly worded and attacEed to that is a notice that if you do it again, you are going to be i.
terminated. In some cases, it may be justifiable, but
~
to the inspector in the field, it looks-like Harold's(sp) l a
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O'NEILL:
mostly going just go after your job and you know, if you screw up, your the one that's going to get... You're responsible as an inspector for guaranteeing that the engineers do their job right, that all the revisions and all the changes that they make to these drawings are right. I've got some horrendous packages that I have kept informa, tion copies of, just to'show you the way that these' packages are butchered up out in.the field while they're being worked. A lot of times, they you come up to these things and there is some much red ink scrawled on this approved for construction drawing that is suppose to denote where everythings been changed that you can't make any sense out of what their doing.
KIRSCH:
So you've never been told that you can identify problems to your management and that your management will resolve your problems?
O'NEILL:
I have been told that.I can identify problems to the management, not through a training session, I have learned that by reading the ESD's(sp) on my own.
KIRSCH:
Weren't you required, weren't you given ESD's(sp) as required reading when first came on the job.
LOCKERT:
That's true.
O'NEILL:
Not all of them. I was required to read the ESD's(sp) that applied to what I would be doing. Piping.
LOCKERT:
The Quality assurance manual does have instructions in their how to do a DR, I believe, I don't if any NCR is addressed. But the fact is that you're not encouraged to write your own DRS. You not encouraged to write your own NCRs. The preferred method is through the DCN which then goes to Harold and then he decides. then he would be the one to decide whether it is a DR or an N.....
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O'NEILL And liko I asy h3'O just now otart0d locking at the 4
incp;ctora to gst thsco writtGn cgoinct him, not co j
much as a means to identify where the problem areas are, but more as an intimidation and harrasement type thing. The game plan out there 'seems to be keep th e j
inspector over-worked. We worked 60-70 hours a week.
Up until recently when we re-negotiated our contract i
and we st,ill aren't being paid this yet, but we were i
l being paid very little compared to the other crafts, and compared to our leve of responsibility, you've got, you know you're signing permanent plant-life documentation out there, and there's the guy sweeping f_
the floor making more money than you are, which is, you know, its kind of hard to swallow. Some cases its i
T j
justified, but...
KIRSCH There's not a lot that-I can do about that.
[
4 O'NEIL:
We already took care of that, somewhat.
You know, I
overworked, you get fatigued. You're always told, 5
j I don't how many weekends now, you're going to work j
4 1
Saturday and Sunday. I told them Well I don't want l
1 j
to work Sunday. Well if you don't you could be subject i
4 t
{
to termination. That's routine out there. The inspector is always under Carners(sp) program is generally not encouraged to find out what specs and codes he's suppose j
to be working to. You've got supervisors that are telling you that if its not addressed in the ESD(sp) which are our specs, that you are not to look any further.
l LOCKERT:
Yea.
i O'NEILL:
You are to just buy it, because if its not addressed
{
in the ESD, Steve addressed Don, That's one certain individual that's more blatant about that than anyone else.
1 i
j KIRSCH:
(
) Unintelligible 1
l l
O'NEILL:
Russ Knowle(sp)
J r
6 LOCKERT:
Yea, he told me specifically that I could not look in the AISC construction manual, the ASTM (sp) standard, or the ASME code. I was not to,look at anything beyond the E3D (sp). I'll see if I can find that for you..
October 17th is a (
) (Unintelligible. )
O'NEILL:
The way the training is. conducted out there, too,.when it is done, there is
(.
) What they do is they hand you a sheet, like say you get burned for a DCN You brought out something that has the wrong pipe gaps on it. You're given a sheet that's basically a copy of the section of the ESD that you violated. You're told to read this sheet, and then sign a sheet that says you've been retrained on this' subject. Which in a lot of cases, people just look over it, sign the sheet, and j
you know, up until now, when this other letter's been coming out, I need,that one copy. I can give you a copy of that letter if you'd like. That's a union. I have to keep that.
HERNANDEZ:
Let me take a look at it, Yea I'll give it back to you.
You don't have formal training classes?
O'NEILL:
We do but they're very sporadic and its only in times like right before the ASME audit, we had a real pump on well if these guys come up to you and ask you any questions, don't really volunteer anything, just answer their questions, Don't try and bullshit em or you know.
KIRSH:
What's this, now I am having a little bit a trouble here. This September 20th, and these are the problems
)
that you noted on September 20th.
LOCKERT:
Well yea, from that' incident on September 20th, I believe that those code references there were violated.
i O'NEILL:
Maybe you ought to re-submit that and read it into the~
record as having supplemented your statement.
LOCKERT:
Into tha tap 2.
O'NEILL:
Yea, you're going to submit this document.
CLEWETT:
I don't think you have read the whole 13 pages.
l LOCKERT:
It would.take too long.
.r ALL SPEAKING Unintelligible:
j O'NEILL:
Particular statement, Problem XYZ or something That might help anyone listening to the tape I
could have a reference here to what those were.
l
)
O'NEILL:
I would like to talk about a design problem'that I just today addressed while I have been.
KIRSCH:
Before we get to that, hold on to that one, Because j
I'm still trying to figure out what all this is saying to me. Deviation September 20, Demoted (sp) deviations from the (
)of contract specification 8711.
What kind of a deviation?
LOCKERT:
Well if you read th incident, you'll find KIRSCH:
What incident, where's it at?
I'm having trouble following what your talking about.
I LOCKERT:
Alright, September 20, these are the code violations 123, and then starting here is the.
1 KIRSCH:
This is the description of the situation that lead to these things.
LOCKERT:
Right.
KIRSCH:
Ah. OK, let me.
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6 O'NEILL:
Is that thg gas-tungston audit?
LOCKERT:
, Yea, that was way back in September.
KIRSCH:
If you wish to save tape, you can tape, you can take it off the tape, Because I'm going to be reading for a minute,,than before I ask any questions, I'll put you back on.the tape.
O'NEILL:
The hardest thing to figure out there, I still have been looking for, but I haven't been able to find out what codes PG&E is really bound to hold out there.
HERNANDEZ:
We have having that similar discussion on that, and basically, what we've been able to find is that their t
committed we're talking Pullman, Piping supports, they're committed AMSE (?) E31-1 (SP) and B31-7,69 1971(sp) which are reference spec A7-ll. Now you've got to remember when this plant started up, started construction that is why we're going back to these early codes.
HERNANDEZ:
Also I think only B31-7 makes a slight reference to
~
pipe supports, for instance. It's not like (unintelligible At that time there was nothing explicitly talked about pipe supports, so what happened is the engineer PG&E essentially (
?) information from other areas as codes came into existence. But they simply had no commitments to any other code and so they essentially generated their own criteria. That's why you have no reference to the AWS pre-qualified joint design or ASME. So essentially what the engineers specified.
O'NEILL:
Does this have to do with their PSAR, a'nd FSAR, were these codes written in? So that's where 8711. What I'm wondering is are they held to the strict letter of these
~
codes.
6 HERNANDEZ:
Liko whnt c d3 cro you talking cbout?
~
O'NEILL Like ASME 9 HERNANDEZ :
Well they whet through the qualifications OK to section 9, ox. but Again, at the time that the plant started up their (
?) like MF )sp) was not in existence in 1971, O'NEILL:
The reason I'm asking is I noticed on all those welding procedures, there is a rev (sp) update in 1977 to bring them into the 77 edition of Section 9.
You know, if you look in the corner of all those weld procedures on revisions tha.t are all revised at least all of them in 1977.
HERNANDEZ:
So maybe thats the latest, the last date that.they' revised that procedure.
O'NEILL:
Section 9 of 1977, that's the procedure, or the edition that's referenced in the 8711 specifications so thats where I'm wondering how it all ties in.
HERNANDEZ:
Well the only thing I can say is that, I'm not sure how that, when they elected to do the procedure qualification to such section 9. Ok, at what point they decided. All I talking about is the pipe supports themselves, the welding criteria that would be specified
(
?).
O'NEILL:
I think B-31-1 and B-31-7 were in reference to section 9 also. I'm not sure of that, but I believe they do.
HERNANDEZ:
That's right.
O'NEILL:
I wanted to look at the pre-qualified material.
6 4
KIRSCH:
Scptembcr 22nd, you docum:nt, cuppocidly, a violation h2ro, failuro to implement the quality issurance programs specified in (
unintelligible) criteria 2 and 10 rather. A welder, what welder?
LOCKERT:
If I had my, daily logs and my papers, I would be able to t' ell you what welder.
KIRSCH:
Are you saying your daily logs, in otherwords If I grab your daily logs, I can go through here.
LOCKERT:
The unfortunate thing is I'm calling these dates from memory, and in the introduction, I'm telling you these dates are not...
KIRSCH Ok. then these dates are not exact.
LOCKERT:
Dates mentioned in this report before December are approximate because I don't have the necessary paperwork to....
t KIRSCH:
OK LOCKERT:
So these dates are-on or about December, or whatever the date is.
September 22.
LOCKERT:
In the event that you could provide that paperwork to me, I could give you the exact dates, exact welder.
KIRSCH:
OK. these would be in what logs, would they be in.
4 LOCKERT:
They would be in my daily inspection logs.
1 O'NEILL:
From that you could trace it to was it.a pipe attachment, j
or was it a hanger weld?
t 1
d b
deg3 ~40 1
LOCKERT:
I can't remember what incident that one is. Oh that was rupture restraints.
t KIRSCH:
I think we better get something down here before we g'et a whole lot farther. I forgot to put down to ask you specifically the question.
Steve, do'you request confidentiality?
I LOCKERT:
Um I don't see any. reason why I should.
O'NEILL:
Let's get some legal advice on this.
LOCKERT:
No don't know what. I understand that these charges have serious consequences, but..
KIRSCH:
No I mean, for you it doesn't have any serious consequences.
LOCKERT:
Well KIRSCH:
But do you wish to have your name kept from PG&E and Pullman's knowledge that we talked to you. I mean we won't go divulging the information, but some of the things that we may do for example, when we go ask for Steve Lockert's' daily inspection log, or his DCN log, is going to point a finger, and somebody will sit back and say Ahah I got it without Us saying something.
LOCKERT:
Well the way I feel about it is that the confidentiality
- to me I mean Pullman, and PG&E, I have already contacted 1
these people about these problems already. So they'know who it was leaking. I don't mind that you tell Pullman or that you tell PG&E, but if you were, if this thing really blows up, and it was to go into the paper and on TV, or where-ever, I don't know what could happen, but I don't want a bunch of these ('
?) coming over to my place and saying
Pago 41 KIRSCH:
I don't think so,*... and break you legs, no I don't think it will go there. We won't mention your name, but there may be some of the documents that you have generated that we will be wanting to look at. and just to go back through here and see what dates, and who, and wheres, and whys and wherefores.-
Yesyouhkvemypermis,sion.
LOCKERT:
KIRSCH:
You Timothy do request confidentiality.
O'NEILL:
definitely.
KIRSCH:
I understand.
O'NEILL:
I believe that if it were ever to come to Harold Ca'rner (sp) 's knowledge that I was here tonight, I would not be working.
KIRCC n That would be the most foolish thing they could possibly do.
LOCKERT:
They've already done it once.
O'NEILL:
There have been other guys that was, I don't know if.you've ever heard from a guy by the name of Roger Fisher, This is kind of rare, because he quit, he was terminated under the threat.
KIRSCH:
This doesn't have anything to do with the allegations let's go off the tape.
p tors he e as nspec o by e name f
Roger Fisher was the guy that knew the codes fairly well and he did kind of have an attitude problem, where people were concerned, but the reason he was terminated when he was terminated was because for much the same
P093 42 O'NEILL:
Reason Steve was terminated, I feel, and this is my own opinion. I was involved with Roger, and I knew i
what Steve went through. Roger was terminated because he made allegations that he was going to contact the NRC on site about intimidation and harrasement in relation to a DCN that he had written, It was not really I
kind of ni't picking on the part of the DCN, but we had a certain craft superindentent who I was very familiar with as was a partner of mine Greg Meager (sp) 4 who everytime you tried to bring, you know, basically it ended up if you shot anything down, this guy was right down on your back telling you, you know, what an asshole you were. He goes to our craft supervision.
or pard me to my supervision with stories about things that I'm not doing at all that they've made up trying to make me look like an idiot out there to get my supervisor to come out there and fire me, basically.
A certain incident.
KIRSCH:
What does Craig Meager (sp) do?
O'NEILL:
He is also a QC inspector out there. A certain incident. well what happened with Roger was one day he was down in the vault, we have these diesel fuel oil vaults out there, and he was writing a DCN on a certain hanger down there. The superindentent by the name of Rich Babino(sp) came down and asked, he yelled down in the hole, Pardon me, Rich Babino(sp) was down in the vault with Roger. He was writing a DCN on a hanger.
I Another inspector Keith Octenberg(sp) looked down in the hole and asked Babino(sp) if Roger Fisher was down there and Babino (sp) replied, and this is from key supporting statements that I'll define in a minute. He replied yea, that long-haired cock-sucker with the earring in his ear yea, he's down here. Something to that effect. This guy ~
was really a hot head. I got into several other altercations with the guy and he basically tried to
..n.-.
j O'NEILL:
Intimidcto ma into buying thic ctuff that wa0 not l
there. Um. So Roger wrote the DCN, the next day was a Saturday, It was a Saturday that that happened. That
)
was a long time ago, It was back in October or so. I j
got it in my records.
)
LOCKERT:
No, because Roger was gone by the time I got into the i
program.
1 O'NEILL:
Yea, He was fired basically for they said excessive f
absentism. Well the company policy is you give the 1
guy a verbal warning, then you give him a written 1
]
warning with 3 days off, and then you terminate him.
i Well Roger wrote on his DCN the harrasement incident i
with Mr. Babino(sp). When the DCN was forwarded to Harold Carner(sp) Carner (sp) voided the DCN. He took a supporting statement from Keith Octenberg (sp) threw i
l it in the garbage and said I don't need this. He took i
the word of Mr. Babino(sp) and exonerated him before even hearing Mr. Fisher's story on the whole thing. And i
- i a welder and fitter that witnessed the whole incident i
when Roger went to get their signature on a supporting i
4 l~
Start of statement were told by.his foreman these two welders j
tape 2 and fitters that if they signed that supporting statement !
t side ]
j they were down the road. Um.
1 HERNANDEZ:
Your talking about'the statement that This Rich Babino(sp)t l
made about this guy that he's down here, or not down here.!
j.
i O'NEILL:
Yea, the long hair you know etc. etc.
i
{
HERNANDEZ:
Why was this written on a DCN. It was added as an l
O'NEILL:,
additional kind of clarification that this' kind of f
stuff was going on. I have in my daily. inspection records i
{
many references to Mr. Babino(sp) and to incidences of
]
intimidation and harrasment made against myself out' there l
when I was a field inspector in his area.-It later turned out that Mr. Babino(sp) was relieved'of his superindendent:
i I
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Pcgo 44 O'NEILL:
responsibility out there and was trasferred to Georgia as a Field engineer because he just didn't fit into the program anywhere. He had a Habit of making friends and infuencing people by walking and telling you Your'e going to start doing this. People don't really like to be told what they're going to do by someone who isn't their immediate supervisor um.
4 KIRSCH:
OK, Let's go on.
You said that you are I'm reading, going through Steve's write up here. Would talk about that design incident that you were going to discuss
(
here just a little bit ago, before I so rudely interrupted?
O'NEILL:
Through the years of studying welding and metallurgy I have come up with in 304 stainless steels, basically an ostenetic(sp) stainless steel of 300 series. Yo6 i
have a real problem in this stainless steel when you weld it If you get the carbon too high. The carbon content in ostenetic (sp) stainless steel, after you weld it is directly related to the corrosion resistance of that steel. A very disturbing thing that I came across and I addressed this just today with this memo right here to Harold and Frank Leoti(sp) the assistant and the QA/QC manager, they have been purchasing all their stainless materials out there, welding, filler metals, and face (sp) piping, plate, etc, all AISI 304 materials essentially to a purchase order specification, and I just have one here for the welding filling, that says all filler metals, and its the same on every PO for a base metal out there, a pipe, or any stainless specifications. The material purchased under this Purchase order shall have a minimum carbon conten$ of.04. Now I have had this confirmed by Metallurgists at Cal Poly, who is a former teacher. What they have there, is they have that ass backwards. It should say a maximum carbon content of.04. Let me explain why.
~ - - -.
.---(-
Pcgo 45 O'NEILL When stainless steel, Ostenetic(sp) stainless steel is welded with a carbon content, well let me just explain, how it all cane about. It's kind of hard to 4
get this across in a non-technical manner, but What 3
were talking about here is a phenomeno called carbide percipitation, that greatly reduces the l
corrosion,rdsistance and thus the design life of the.
stainless in question. The way it works is when you make !
a weld in stainless, you heat the weld metal and an adjacent area next to the weld metal into a temperature range of 800-1500 degrees. Ok, when 304 came out, the 1
i original specification called for a.08 maximum carbon content.
08 is pretty low in comparison with mild steel or normal carbon steel, but to stainless 0.8 is the maximum allowed under the 304 specification. under various all your ASTM specs that reference to 304 J
reference.08 is the maximum. Now that they discovered was that in these areas, where it has been heated j
between 800 and 1500 degrees, the carbon in that l
.0, usually it will run, and I've seen some mill (sp) l test reports out here around.56,.60 what happens l
is that carbon combines with the chromium in the grain boundaries of the metal there and it sucks... the reason stainless is corrosion resistant is because that chromium is left in solution and after its all cooled and everything, it forms a protective oxide i
layer over all exposed surfaces. Once that layer forms its impervious (sp) to further corrosion. Chromium oxide is really hard and sticks to the metal and it doesn't come off easily, in fact, a the mill what they'll do is they'll use a pacification (sp) treatment of nitric acid to build this chromium. oxide layer up on this stainless surface, because, face when your taking stainless is for corrision resistance, you're not worried, really about strength. What happens is the J
l areas heated in that 800-1500 degree range, the carbon-takes that chromium in a ratio of about 6 CR24 C6. So you get about 4 chromium atom to every carbon atom in the
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Ptga. UD O'NEILL:
and it creates a chromium carbide that has the effect of pulling all the chromium =out of the grain boundaries where its needed to supply the.corrision resistance, which gives you a direct avenue for your corrosion to take place. And the way that happens is it gets in your zones, usually in your weld metal and right next to the weld metal it at a specified distance where that heatings take place. And that would depend a lot on your thickness, the process you using. So to combat this problem, the steel manufacturers, and metallurgists and stuff got together and they came out with a L grade stainless. and you've seen 304L. Well that L means that its got.035 maximum carbon my specification, because they've found that at that carbon content, you can weld it with high heat input and it will not cause. There is not enough l
carbon in there to causes carbide precipitation loss l
and corrosion problem.
i HERNANDEZ:
They call it what sens.....
O'NEILL:
Sensitization (sp).
F KIRSCH:
You brought this to their attention today. Have They given you an answer back.
3 4
O'NEILL:
No the last time a brought a memo like that to them, 4
I didn't get an answer back for a month. It was one month. I have a copy of that memo. That concerns the....
KIRSCH:
Do you feel that they are not going to give you an answer on this?
'I
- e O'NEILL:
I'm waiting to see.
I' feel that if I do it will be at least a month from now before I'get it.
4 l
e
~,..
Pago 47 KIRSCH:
While I'm not reluctant to jump hop on the problems, I would, I, We, The agency has always encouraged people to notify their responsible management or the licensee and If they don't get satisfaction from them, then we can do something.
~
O'NEILL:
That's why I have gone thrcugh.
KIRSCH:
Right now, I, all they're going to tell me is Oh yea, we got it, we're still looking at it. We're evaluating it, but there is...
it means nothing.
l O'NEILL:
I realize that. I addressed that to Harold today, and He said well if PG&E's approved it, and that is his out on PG&E. That's PG&E Purchase order specification. What that says to me is PG&E really
~
doesn't understand welding of stainless because if they did, they would ne'ver specify it like that. You've got your steel manufacturers, probably love them because they can unload all their high-carbon stainless that nobody else will buy LOCKERT:
Its cheaper.
O'NEILL:
It's a whole lot cheaper to make high-carbon stainless that 304L. From my research I found out that they discovered the problem... maybe you guys know about this down in San-Onofre in some large diameter heavy wall stainless pipes that was fabricated with a sub-4 arc process in the shop to put the spools together.
- l It was like 2 inch wall thickness and they come,along after five years in service and here they're reading 2 inches, and they get within a certain ar'ea of the weld and now they're reading 1/2 inch on the wall thickness.
Because what happens is it eats that out from the inside.
The only way you can catch that is with an Ultrasonic wall thickness.
HERNANDEZ:
All right, 10 thic tho (
)of tho Otegnat fluorotcd (?cp) water? Rcm;mbsr that 304 matalg j
KIRSCH:
That requires 304L, or....
HERNANDEZ:
Well, the problem has been recognized before, like Bechtel orders all, nothing but 304L.
O'NEILL:
Another person on site told me he was working at another plant that was about half completed and they came in and just tore out all the 304 and replaced it with 304L.
KIRSCH:
Do you have. May I have this copy?
O'NEILL:
That's my only copy. I can make you a copy.
l j
KIRSCH:
Can you (
) me a copy of it?
O'NEILL:
Yea, I can get you copies of all of this. In fact l
I have other copies of my inspection records and things that relate these other incidences that I am just telling you off the top of the head now.
KIRSCH:
If you'd bring me a copy of that, I would appreciate l
it.
O'NEILL:
- Sure, KIRSCH:
Then I can run it by some of our members.
O'NEILL:
That's why I went and checked.
m KIRSCH:
Unintelligible.
..... don't claim to be even remotely familiar with that (
)
O'NEILL:
You know, they obvicusly can't tear out all the 304, but they do have to address (unintelligible
)
capicity. That's what I want to see out of them. Is 4
4
-r r
.,e w e a e
r-
.%e w
Pago 49 O'NEILL:
That they're gonna to address.. I speculated, I imagine ~
they'll just come back with memo saying this is a
- PG&E approved procedure. Our hhnds are out of it, or something to that effect. but I don't know.
I also address there stainless electrode storage out there.
HERNANDEZ:
Is this oor' copy here?
O'NEILL:
I should have made you copies of all of this stuff.
They have.a copy machine down here, I can get you copies of this, or 1f you're gonna be here tomorrow.
KIRSCH:
You mean here in the Hotel?
O'NEILL:
They don't have a copier?
I HERNANDEZ':
Well we're going to be here for a while.
O'NEILL:
If you'll be here, I can give you copies of this tomorrow KIRSCH:
You'll drop it by tomorrow?
O'NEILL:
i Their stainless electrode storage out there I questioned right off the bat. I used to work up at Westinghouse KIRSCH:
Why don't you hit the cool on that, would you?
O'NEILL:
I came out of a job where we were building the Trident missile tubes for the Trident submarines, and the Military has some pretty tight control on processes.
We kept all of our stainless electrodes in heated ovens and controlled them after they went in the oven and went out to the field. Because basically, although no mention is made in ASME section II, or the AWS AS.4-specification, that it doesn't explicitly call out a low hydrogen electrode. The coating ingredients are
i Page 50 3
O'NEILL:
basically identical to the coating ingredients in your E 7018's your 8018's, its a' mineral coating, mostly calcium carbonate, a lot of fluoride in there.
and it is suseptible to moisture pick-up in the research I've done t
Oh definitely.
HERNANDEZ:
Are you talking coated stainless steel electrodes.
O'NEILL Coated stainless steel electrodes.
1 i
HERNANDEZ:
And they have no^ requirements for keeping them a I
minimum of something like 200 degrees or so.
O'NEILL:
NONE, None what-so-ever I should have brought a copy of the other memo that I gave Frank Leoti (sp)
LOCKERT:
I've got a copy.
O'NEILL:
Steve's got it here. This was addressed a month later with another letter from a Pullman welding engineer that was even... that was just rather humerous I thought.
Uh.. They, Technically they're right, There is no mention of it being low hydrogen, but common sense says it is HERNANDEZ:
The code, I thought ASME or somebody did talk about a minimum temperature for coated stainless steel
. electrodes. Like what number are we talking about?
O'NEILL:
Por ASME. That would probably be in a section 3, if its in there at all.
HERNANDEZ:
No but what's the number like E30....
O'NEILL:
E308-15 or -16. See your electrode designations are basically the same. You've got -li, -16 and -18 are low hydrogen. -15 is a low hydrogen line type electrode-v n.~
,n,
-w, n
n,n-
Pcga 51 O'NEILL:
suitable for DC reversed polarity operation only.
Your -16 is a lime titania (sp) They add titanium dioxide to that coating to give you arc stabalization so you can run it on AC or DC reverse polarity and I
then to get you to an 18 coating, which is only for carbon or low alloy steel, they add iron powder to it.to increase the deposition rate and give you a little higher current. So you can get more metal out of that electrode. But your -15 and -16 are definitely low hydrogen type coatings. Now they claim through that letter that porosity is not a problem. You know, the guy sits in there....
i l
HERNANDEZ:
They do tests to determine that?
O'NEILL:
I don't know if_ pullman's documented any tests like
~
that. They referenced some Bechtel reports in this.
KIRSCH:
Becthel did some tests on it.
O'NEILL:
But, you've got to look at where they did the tests.
Did they do that down in Baton Rouge (sp) Louisiana where the humidity is 100%? Did they do it out here?
Did they do it Yuma Arizona, where there is no humidity?
It's relative. The military has realy stringent requirements for water-moisture content in electrodes HERNANDEZ:
They're referencing the Bechtel tests on low hydrogen?
O'NEILL:
They don't really. They just say Bechtel reports. They_
don't tell you what reports. The guy says the code there, I don't even know what code he's talking about.
HERNANDEZ:
In other words they're referring to thd Bechtel tests 7
that were done on low Hydrogen rods (?) for (
)?
O'NEILL:
Stainless coatings, stainless electrodes.
y
Pega 52 HERNANDEZ:
No low hydrogen carbon E7018. I'm sure that's what they're talking about. I don't know if they did stainless also.
O'NEILL:
Yea, well I wrote that letter because for everything I've been taught, that spec contradicts itself in that its saying here's all these storage conditions for low hydrogen electrodes and then it says you need only keep stainless clean and dry. They do store it in a heated cabinet in th'e rod room, but once it goes out to the field. There is no control over heating. It goes out in the rod oven and it doesn't even have a plug on it.
HERNANDEZ:
Well how long does it stay out?
O'NEILL:
Well, say that's where they're control breaks down.
Supposedly there's no requirement for, you know, it can stay out HERNANDEZ:
Well no, but the guy goes, the welder takes the rod and lets say he takes it out at 8 o' clock in the morning does he bring it back at lunch time, which is four hours later?
O'NEILL:
No they're not to held to the four hour requirement.
So they can be bringing them back at the end of the shift, eight hours. They go right back into the rod oven. You know, they may have picked up moisture. They may not. It's a...
There's definitely a control problem on filler rod (?) They don't count... The QA rod room attendant does not_ count the rod stubs coming back in In fact I have a DCN, I believe its number 006 and a supporting statement 007 where they, hEre we're talking about a safety related line, a CCW line for the component cooling water heat exchangers down in 85CCW room Unit I, where they have, they were going to put
~
pipe attachments on this line as doubler plates, and e
'~
Pcga 53 O'NEILL:
this is another point that I've seen out there.
They weld on the CCW system when they put all these new pipe attachments on for the seismic re-evaluation program. They weld on that line with water, and they don't drain the line. So what you're doing. The carbon specification on A-53 pipe which.
KIRSCH:
What's this on?
O'NEILL:
This is the component cooling water system in general.
It's a class C line. The way I see that system. That system is vital to the.
KIRSCH:
I understand the vitality of system. What I'm wanting to know is where on the component cooling wate'r system.
O'NEILL:
If you go down into the 85 foot elevation, they have a lot of the pipes going into the pump, Pipes going into the heat exchangers, all in the heat exchanger room they've put, a lot of times they'll take and put big large doubler plate on there, and then they'll l
attach a big spansion, they'll either put a pipe clamp on or put a snubber on it. The component cooling water i
heat exchanger room would be a good place to look at.
Uh, I believe due to the quench (sp) rate, and I haven't seen mill test reports on the carbon content on those spools, because those spools were fabbed up down in J
our Paramount shop, and I haven't been able to find any tracible records of chemistry on that, but the ASTM spec on that will let carbon go up to.03, or pard me.30 and under normal conditions,.30 is not too bad, but if you put a water quench (sp) behind that, you're going to be putting such a quench rate on the weld, that you're going cause underbead (sp) cracking in that welding, and I believe that we have that out there. I talked with my Roommate whose a PTMT (sp) technician out there. He's told me of cases ~
where he's seen tig welds root passes for these stansion(sp) welds which are.... Tig weld is a real
O'NEILL:
small weld compared to that big 30 inch pipe full of water. That's a hell of a heat (
).
HERNANDEZ:
Are you sure the line is full of water?
O'NEILL:
The line is full of water. They're not pumping the line. The line is not under pressure. Sometimes they are through. I've KIRSCH:
It's full of water. It doesn't make a hell of a lot of difference one way or the other whether it's full of water, or its.
. Your certain?
O'NEILL:
Positively they weld it full of water because it's a chromated (sp) water system, as I understand it you don't have the facilities to drain the system, or they don't want to. For whatever reason, they weld attachments on to this line, as a general rule without draining it, That's my way of thinking.
KIRSCH:
You got that one down? Welding attachments to full water lines with lines full of water.
HERNANDEZ:
Yes, this is a.
. but you know. I wonder'if I can again this same question. Are they full of water?Because there was a problem with the confluent (sp) cooling water, say a year ago. I don't recall exactly when, where they had a leak after they welded, determined they had a problem, and they put up those (
)
plates and all that. If I recall correctly, the line was not full of water.
O'NEILL:
They may have drained that one. The ones I've seen, and been involved with.....
HERNANDEZ:
But you have seen lines that were full of water?
.,-n
Page 55 KIRSCH:
The big lines going into the heat exchanger and into the pumps huh?
O'NEILL:
'Amse big ones those husky 30 inch. They're 30 inch, but their wall thickness is only 3/8 of an inch KIRSCH:
It's a low pressure system.
O'NEILL:
Yea, it's, I've seen them weld directly on those with water in that line. In fact the fire sprinkler lines are another one. A guy comes up to me one day 1
and here they have a pre-heat requirement. And the guy goes to me how are we going to pre-heat this line with water in it. I said I don't know, go ask the piping engineers what they wanted. And then that night I started thinking about, and I thought well There must l
be some code requirement for that pre-heat or they would'nt have put it on there. The procers sheet came back in (
)on the pre-heat and everything, so they went ahead and welded on it. But I asked the piping engineer the next morning when I saw him. What's the deal behind this pre-heat, and he said it was some inter-pretation problem between B31-1 required or 31-7, I'm not sure which one, requires that, and I believe he's talking wall thickness here. On'a wall thickness greater than 1 inch. You have to either pre-heat prior welding, or you post-weld heat treat when you get done. And what they were trying get around was the post-weld heat treat requirement. But they were inter-preting it because they were attachning 1 inch thick lugs A515 lugs onto the pipe that they didn't.
KIRSCH:
get that much heat into them.
O'NEILL:
Well they thought that they had to pre-heat the lug, which may very well be cause another pipine engineer who was a frined of Steve's and mine, Roger Clap (sp)
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Paga 56 l
O'NEILL:
Who just quit out there because of the bullshit he was subjected to, He told me a* lot of times they were getting A515 in there with greater than.30 carbon and he'd address it to his people saying well you know this stuff really should be pre-heated. The carbon content is high enough and the manganese content as well is high enough that it should be pre-heated, and they'd say, well the code does'nt require it so we're not bound to do it. Basically don't do anything the code says you don't have to do. So they came back and they welded those lugs on. They weld lugs on all over the place, pipe attachments, with water behind.
KIRSCH:
You say all over the place.. You mentioned one fire protection line..
O'NEILL:-
OK. I've seen it happen on the fire protection line...
KIRSCH:
Where at?
O'NEILL:
In the turbine building.
i KIRSCH:
Where at in the turbine building?
O'NEILL:
On the north, lets see what would that be, that would the north west corner of the turbine building where the main comes into the building. They welded lugs on those pipes, That I was directly involved with.
KIRSCH:
OK.
O ' NEILI. :
The CCW system, they, I have seen them,,on that with water behind the line in the heat exchanger room. I've
~
seen them weld them on 100 Auxillary where the fan cooler lines go up into the fan coolers and up through-the auxillary buildings _there. In fact all through those vertical pipes going into the fan coolers
Pago 57 O'NEILL:
through auxillary they weld pipe attachments I've been involved with those...
KIRSCH:
CCW system?
O'NEILL:
CCW system. I was also involved in an incident that became,a real harrassment deal on the diesel fuel oil $ransfer lines down in the same vault that we were talking about before, where these guys wanted to weld on a fuel oil line. It was a weld repair to clear a DCN that was written by somebody else for porosity and a lug attachment on this line. Well they supposedly have a line clearance to weld on it, but I i
was down in the vault three days prior to this and they were running the pumps. OK, they..I have been involved.
with this before. So if they had the line clearance...
This is like they got the line clearance on a thursday, a
I was down in the vault Saturday and they were running the pumps, supposedly when they had a line clearance on that line. Well Monday they come in and they want to weld on this line. Well I asked them to see the line clearance. The guy says well... and the way the clearances work, you have a red tag that goes on the valve 1
that shuts it off and the foreman has the stub on that, and I demanded to see the red stub to make sure they have a valid line clearance, so the guy doesn't fire up and blow sulfuric acid or fuel oil, or whatever back in his face.
Um, so what happened was the foreman... I' talked to the welder, and you know, what they had to do was grind out the porosity and they almost got to a low (sp) wall condition and so I said well lets see the line clearance before you start welding on this... Well they didn't have the line clearance, or they got a piece.of paper that says there was a line clearance issued, but it didn't say it was still valid. So I said well I want to see the red tag, and this general foreman and the superindendent became realy abusive and started saying well hell in the oil fields-we weld on our lines full of gasoline, we
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Pago 58 O'NEILL:
weld on lines full of diesel oil, we weld on lines full of natural gas...
KIRSCH:
and they do..
O'NEILL:
I'm fully aware of that. I just said to him, well you know, we're not in the oil fields here and the welder feels its*u'nsafe and I feel that its unsafe, because it was in a trench where if the guy were to blow through that line and if it were to catch fire, he'd never get out of there, he'd be scorched and plus as far as them having a line clearance, it was not clear in my mind that they did because when I'm down there three days-after they're suppose to have a valid clearance, they're running the pumps, that tells me somebody's either ignoring the line clearance or they just never had it to begin with.
KIRSCH:
Or they pulled (unintelligible??)
O'NEILL:
They didn't have anything that indicated that. That was what my major worry was that they didn't have a line clearance and it turned out that they didn't.
HERNANDEZ:
Who were the people that became abusive?
O'NEILL:
A guy by the name of Jay Wright (sp) a foreman out there, General foreman, pardon me. A guy by the name of Roger Martin, he's a superindendent, and we've had several incidences with Roger Martin. He's finally Basically they've gone to my supervision and said hey this guy's an ass hole, everytime he comes up, He rejects are work, puts a hold tag on it or whatever. I don't-do it intentionally, It's just it's so' screwed up that I have no choice, so they've convinced my supervision that I really don't belong out there inspecting craft work. I believe that to be the bottom line
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Page 59 KIRSCH:
You think that's why you were put over in QA, and taken out of the field?
O'NEILL:
Yea, I think that's why I'm not doing direct inspections in the field now. Which I don't mind.
It's... Actually I kind of like it, I don't go home with a headache evenynite f, rom dealing with those people..That's the truth.
KIRSCH:
OK.
O'NEILL:
I realize that we've covered a lot of ground.
KIRSCH:
That's an understatement. I still haven't digested all of this, l
i O'NEILL:
Its tough. Especially from a non-technical point. It's hard to really latch on.
LOCKERT:
An immense transfer of information, you can't really digest it all in a short amount of time.
O'NEILL:
Well we what we were mostly concerned were the events i
leading up to Steve's, you know, Mostly I'm here to substantiate what here's to tell you.
KIRSCH:
Why don't you kill it. I'm just going to read here for a minute and make sure that I understand what is in this, in the letter.
CLEWETT:
I have plenty of tape KIRSCH:
Let it run.... pause....By this report you say you requested, you request
(
) full penetration while attaching a stansion (sp) to a pipe you found that a color plate was on the (
)' and you asked them to remove it and they didn't remove it.
Uh...
Where was this at ?
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Page 60 LOCKERT:
It was in Unit II, probably the 91 level.
KIRSCH:
Is this in your log?
LOCKERT:
Yes, there's a note in there saying Russ Knowle (sp) j prevented me from taking the cover plate off.
KIRCSH:
Can you tell us what stansion (sp) it was.
LOCKERT:
Yea, it would be in my daily log.
KIRSCH:
Daily log. I should be able to pick that up.
LOCKERT:
There will be a little not saying Russ Knowle(sp) prevented me from taking the cover plate off.
LOCKERT:
OK before we go, we probably ought (
)
I'm not saying we should leave right now, but before we come to a conclusion...
CLEWETT:
We not quite half done with available tape. We have as much again, as we talked about already.
LOCKERT:
Tim here is a pretty deep well. When it comes'
~
to welding and we have spent many a night talking about our jobs.
O'NEILL:
The nuts and bolts out there on the. things with the containment liners studs. I have another package here that's... This is a snubber on the feed water line, it's a design class I code clase E line. It's out on the pipe rack. The way I got involved with this was It was was re-issued because they had to swap the snubbers. They took a snubber off of one location where they needed a match set and theytook the snubber 1
that was at this location and moved it over there, and moved that snubber over here. So they had to go back out and re as-built (sp) on the drawing the 2-y-
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4 Page 61 O'NEILL:
pin to pin (sp) dimension of the snubber serial number. Well when the asbuilder (sp). Do you know what an as builder (sp) is? When he walked out there, he looked at it and could see that the welding on the plate was obviously deficient. So it got to me through our department through my lead at the time, and he said go out and write a DCN on this because they didn't asbuild (sp) this DR 4678 right here, which only addresses the over-sized weld. It doesn't address the under-sized welds on this thing. OK. this is also dispositioned by a field engineer who is suppose to use " good engineering judgement" and he just said accept as is, accept as'is, accept as is... well some of these welds have contours on them that are just completely out of acceptance tolerances that we're working to, excessive convexity. It's pretty obvious the guy was welding with it could not handle low hydrogen electrode, Lecause he had just piled it all up on the middle and really didn't fuse it into the sidewalls very well. I've gone around and around with this particular engineer. His name is Carl Galudo (sp) He's pretty good at just saying accept as_is, and this is stronger than the o'rigina. installation and we're going to just buy it like this.
HERNANDEZ:
He's an engineer that;s '.
O'NEILL:
He's a Pullman field engineer. To my knowledge the guy really doesn't have an engineering background.
He's an industrial arts instructor.
HERNANDEZ:
Is this not conforming condition.
O'NEILL:
yea it is. well its deficient. Is the way we described it. Well it would have been written up by NCR and then dispositioned by PG&E.
3 Page 62 O'NEILL:
It's going to be written up on a DR tomorrow, I haven't written it up today. I mean I'm coming with this stuff right here just fresh. This stuff fell in my lap. But the reason I bring this up is I go out to this hanger, and here on the bottom of it, there are anchor bolts that have nuts cut in half. That are torqued on then the nuts are' tack-welded onto the base plate. Well a nut ASTMA 194 and you'll look in here and you'll look in the section 9 and A194 is not a P1 material and they don't really have a qualified procedure to be welding that onto a P1 base plate.
4 HERNANDEZ:
I guess I lost you. Did you say they cut the nuts?
]
O'NEILL:
They cut the nuts in half because what the problem
~
was is they couldn't get full thread engaged with a whole nut, so they decided well we'll cut in half and they still couldn't get full thread engagement so they came up with this thing, Its called a design problem, and this, I think this is pretty much typical of the way the enginee, ring works out there from what I've seen on PG&E's level.
I would like to just read this to you here: Design problem #1-2335-P, its dated August 7, 1978, engineering problem. Attention. J.
Gormley (sp) RE bacher. Attached is as-built plate detail 1
for hanger 1048-8SL drawing 04919818. The studs for this '
hanger were set in the concrete for civil drawing 447242 however, the studs are not long enough in all cases to allow for full thread engagement through the nuts. Two have the nuts have been cut down to 9/16 of an inch in height. Bottom of plate has been welded to existing insert with a 3/16 fillet (sp) ' weld. pield would like disposition as to the accesibility of this installation. Answer required 8/23/78, per RS Reed (sp) on 9/23/78 As of 9-22-78, no response has been received on site. Please expedite.
1.
O'NEILL:
Per J. Gormley (sp) on 10-26-78, this type of question is very troublesome. It appears to me that the GC filed engineer is as qualified,as we are to estimate l
the capacity of the as-built scheme. Perhaps if we knew how much the capacity has been reduced over design we could answer more quickly. As is, this will just stop an' engineer from doing priority, first priority work. Per J.R. Stevenson (sp) on 1-12-79, M.R. Tressler (f' agreed to review with field personnel and re-submit if necessary. Per J.R. Stevenson (sp) on 1-30-79.
j M.R. Tressler (sp) agreed to submit a as-built drawing I
this problem is resolved, And in an asterisk here, l
per R.S. Breed (sp) on 2-14-79, per previous discussion j
betwe'en D.J. Curtis and CBraff (sp) and based on J.E.
Shigley (sp) mechanical engineering design, second edition, section 7-9 "three full threads are all that are required to develop a full bolt strength" the existing nuts tack-welded to the base plate are sufficient. This problem is resolved.
And that's approvec by RDE, which I'm not sure but I imagine that's.
KIRSCH:
You say that's a class E hanger.
O'NEILL:
Class E.
that's correct, but its seismic class I with snubbers. We are bound.... unintelligible, interruptec' 9
KIRSCH:
You say it's located out on the pipe rack.
O'NEILL:
Yea on the pipe rack. It's on the feed water line of as it's just making the bend in the containment and there is another, there's a Y coming off KIRSCH:
Unit I containment?
O'NEILL:
Yea Unit I. The thing about this, I talked to all th e inspectors involved in this and they were pretty much told under the threat of their-job that this has already been accepted by PG&E as is. This inspector that bought
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Page 64 O'NEILL:
The final workmanship, Craig Meager (sp) addressed the problem at the time, because I asked him. I said well what's the story with how'can you buy welding that 1ooks like this, and he said that he was told by our field engineering people that this is already been addressed start of second side tape II O'NEILL:
He said that this has already been addressed. I talked to the PCGC, the general construction inspector that dispositioned the DR 4678. He told me by the way his name is Bill Young. He told me that this was when he first came on site. He wasn't quite sure about it and that he told him that he felt it would come back at them at some time if they didn't fix it up.
Um. but everything was accepted as is by our filed engineering and by PG&E and everybody down the line.
KIRSCH:
How'd you come by that docment?
I 1
O'NEILL:
Like I say they re-issued the drawing because they changed the snubber, and what they did was they had to go back out and re-as-built (sp) the pin to pin (sp) and the snubber change. and when the as-builder (sp) was out there, to check it out, he looked at the base plate. Now he wasn't suppose to look at that base plate, but you know, he did and he realized that number one, this DR4678 in here which is our pre-inspect type DR when we first go out and look at a hanger. If you find existing old work conditions that are deficient you write them up on the DR46-78 which is a generic DR for unit I for old work hangers. Bu,t its since been closed. Normally you'd write it up on that and it would be dispositioned by the field engineer, either bring it up to design specifications, or accept as is and as-built, and whatever, well they didn't as-build (sP5 in the last rev. The existing conditions on this O
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6 O'NEILL:
base plate here per,the DR 4678 they had previously So I was told to go out verify it, and if that was the case to write the DCN for that item right there.
Well when I went out and looked at it, I saw Number one all this welding was under-size. Welding was not up to our acceptance criteria for contour and convexity and things'l'ike that. These nuts were welded on the base plate.
HERNANDEZ:
Tim If I can interrupt you about this welding thing.
You're talking about 1978 work. Did you look at the spec in 1978 as rules required.
O'NEILL:
Well from what I can tell. The section 9-77 is the reference document in 87 11 for welding. So that's what I'm basing this on.
i
~
KIRSCH This is a base plate attachment in containment.
1 O'NEILL:
To the containment wall. It's attached. There is an insert behind it and that's where there... There is also j
a gap behind this base plate that's not at a tolerance j
yet. Its about 3/32+ I couldn't get an 1/8th inch l
well wire. That's how we check gaps behind base plates.
4 But I couldn't get an 1/8 inch back there because of'the way its set in the wall. Not only that, there is a platform support right here that appears to be pulling away from the wall. I brought my supervisor out there, we looked at it today. He didn't feel that it was a problem. but it looks like its pulling itself away from the wall.
But, when I-talked to the inspector 3
that bought the workmanship, he told me that back in I don't know when it was, He said that when he was called to inspect this, He held up fof two days on it because he wanted the welding (back in may in 1983) he would not accept the welding on there, and it became a political deal and he was told you got to accept it as is, and that's basically what happend on it.
n
~
Pnga'66 KIRSCH:
OK. Is that your copy of that document.
O'NEILL:
Yes, this is a for info only copy that I kept for my own records.
KIRSCH:
What is the number of that document?
O'NEILL:
The hanger is number 1048-8SL. Which you'd want to see (interrupted)
KIRSCH:
What is this sheet?
O'NEILL:
That's the sheet that Pullman attaches to the drawing when it goes to our QA departments. See it has got the stamps on it. a QA/QC accepts stamp. and a QA-accept stamp.
That was my big question, was how did I get a hold of this package when its already through the mill in QA accepted. It took me half the day yesterday to get an answer on it. But I finally got with the snubber people and they shed some light on the thing.
They were the ones that provided the copy that had that DP in there, that design problem.
Now they use 5
a quick fix as a design problem (unintelligible).
KIRSCH:
This is the whole package that went with that hanger?
O'NEILL:
That right there is I believe the QA copy of the package.
The one that PG&E should have the original in their vault.
KIRSCH:
Unintelligible.. OK we'll look at that, a
O'NEILL:
If you want, I could get you an info copy or copy this one. I'm thinking if you go out t@ere and ask j
them about all these hangers, and all this stuff that I've been working on. It's not going to be too hard to put together where that info came from.
Pcgo 67 l
KIRSCH:
Well I know that there is any other choice do you?
You raised the issure. I'm obligated to do something with it.
CLEWETT:
In terms of getting the copy. He's coming out here with,some other copies of other things, He can bring....
KIRSCH:
Yea he can give me copies of other things, but I O'NEILL:
Yea, you'd want to see the original anyway. That's what they got to have.
KIRSCH:
You wrote a qualification thing where you talked with them here about with mark. That's all in here in this.
LOCKERT:
Right.
KIRSCH:
So basically all I need to do here is go through l.
and pull everything out of your statement, your 4
{
written statement here and then I have basically j
a summation of your concerns. Is that right Steve?
i 1
LOCKERT:
Yes. If you have any questions while your skimming....
i KIRSCH:
I don't right now, I may, it may ' come to pass that after we get started running through this thing that I'm going to come up and get his logs, daily inspection logs, and his DCN log and I'm going have a lot of questions. Then I'm still going to be needing to get a hold of him. Likewise when I get a held of Tim's DCN logs, I may come up with a lot of questions, and I may need to get a hold of Tim l
But right new I don't know what else I can do other that just try to digest all of this.
l l
I 1
i
POgg 68 CLEWETT:
Oh I understand.
O'NEILL:
It's a lot to latch onto.
KIRSCH:
And it may well come to pass that I'm not even going to be able to get anything, this is so massive...
that I may not even be able to get anything done due to people limitations this time around.
I may have to come back. in a couple weeks or month. But we'll get to it, sooner or later.
O'NEILL:
How do they stand up for their fire-up out there.
Are they going to be given the go-ahead, or I've heard KIRSCH:
That's not up to me.
O'NEILL:
I was just wondering.
KIRSCH:
I don't have the foggiest idea.
O'NEILL:
If they really do have to go back in and do any work on any of this. They will be putting people in a lot 1:. ore risk unless they got beta hazards and things like that floating around after they fired it up.
KIRSCH:
Oh that's understood, but other people have done that sort of thing.
Other utilities have done this same sort of thing. So its not an unknown thing.
O'NEILL:
I imagine it doesn't get that bad at first. couple of years.
KIRSCH:
I guess I have a lot of work to go thro, ugh.I am going to have to go through and digest all of this. You have agreed to sometime in the middle of next week provide me with a copy of that tape, Because what I'm going to,
do is submit a copy of it. There have been so many words that we haven't been able to get it all down in writing
e KIRSCH:
I'm going to have it all transcribed out and.
CLEWETT:
I am going to have to find a second machine and somehow make a copy of that, but I think I'll probably be able to do that by then.
KIRSCH:
Yea, if yoy!ll get that to me by Wednesday, and then I'll make arrangements to get it transcribed.
CLEWETT:
OK should I arrange to have that delivered to the NRC people on site here or should I mail it up to you.
KIRSCH:
No, I'm going to be here through next week.
We'll be checking out I think Friday Morning.
CLEWETT:.
OK, I'll....
KIRSCH:
If you could just bring it by to me hnd I'll make arrangements to get a transcription made of the tapeJ I certainly will appreciate.that.
CLEWETT:
It you do get it transcribed, is there any chance that we could get a copy of that transcript.
KIRSCH:
I would'nt have any problem with that. Now it depends again. You realize that Sometimes these transcriptions don't come out all that clean because the lady doesn't know whose talking or she may make mistakes, as to what was said, and it will be a very rough kind of thing, but All I want to do with that transcription
(
)
CLEWETT:
Sure we don't have a court reporter taking everything dcwn.
l KIRSCH; So it will be something.
i Thank you Steve, I appreaciate it and we will probably j
be getting back in touch with you at least one time j
3
Paga 70 KIRSCH:
or another. for certain I may want somebody, somebody from the agency may be getting,in touch with you to clarify some points or ask questions before our final, we get in touch with you finally.
Thank you very much.
e e
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9
GylRTJO UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
'84 J!f 29 A8 :27 ATOMIC SAFETY AND LICENSING APPEAh BOARD Administrative Judges:
Thomas S. Moore, Chairman June 28, 1984 Dr. John H. Buck (ALAB-775)
Dr. W. Reed Johnson
'l[4
)
In the Matter of
)
)
PACIFIC GAS AND ELECTRIC COMPANY
) Docket Nos. 50-275 OL
)
50-323 OL (Diablo Canyon Nuclear Power
)
Plant, Units 1 and 2)
)
)
Joel R. Reynolds, John R.
Phillips and Eric Havian, Los Angeles, California, and David S. Fleischaker, Oklahoma City, Oklahoma, for the San Luis Obispo Mothers for Peace, et al.,, joint intervenors.
f Rchert Ohlback, Philip A.. Crane, Jr., Richard F. Locke and Dan G. Lubbock, San Francisco, California, and Arthur C. Gehr, Bruce Norton and Thomas A. Scarduzio, Jr., Phoenix, Arizona, for Pacific Gas and Electric Company, applicant.
Joseph Rutberg, Henry J. McGurren and Lawrence J.
Chandler, for the Nuclear Regulatory Commission staff.
MEMORANDUM AND ORDER 1.
On March 20, 1984, we issued ALAB-763 containing our findings of fact and conclusions of law with respect to the adequacy of the applicant's current design quality assurance program and the sufficiency of its design verification efforts to establish the efficacy of the design
,\\
l Devine Exhibit 11
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3 failed to present new evidence of a significant safety issue.6 We now have before us two additional motions of the I
joint intervenors to reopen the record in the Diablo Canyon 4
operating license proceeding.
The first, filed February 14, i
1984, again seeks to reopen on the issue of the adequacy of the applicant's design quality assurance program.7 The second, filed February 22, 1984, seeks to reopen on the issues of the adequacy of the applicant's construction quality assurance program and the applicant's character ~and competence.
Both motions are accompanied by the affidavits 0 ALAB-756, supra, 18 NRC at 1354-55.
4 7 The joint intervenors' motion is phrased in the l
alternative.
They first endeavor to augment the evidentiary
. hearing record of the reopened design quality assurance proceeding with the materials accompanying the motion.
Alternatively, they seek to reopen the record for further hearing.
The joint intervenors attempt to augment the hearing record based on a colloquy between applicant's counsel and us at the end of the evidentiary hearing concerning the formal closing of the record.
See Tr.
D-3246.
They have misapprehended the import of those remarks.
Our comment was intended to accommodate, as a matter of administrative convenience, such matters as a party's belated motion to admit an exhibit that had been marked for identification at trial but, through an oversight, had not been moved into evidence.
We did not (and could not properly) provide for the wholesale augmentation of the evidentiary record now sought by the joint intervenors.
Supplementing the record with,the materials proffered by the jcint intervenors would' require, at a minimum, the consent of all parties.
Accordingly, the motion to augment the record is denied and we shall treat the motion solely as one to reopen the record.
W
O O
5 filed a reply to the applicant's response to the motion concerning design quality assurance,10 and then filed a 11 second supplement to that motion to which both the applicant and the staff responded.12 By order of May 23, 1984, we provided the join't intervenors with an opportunity to reply to the applicant's and the staff's final responses to both motions.13 The order stated that any reply must be accompanied by the affidavits of qualified individuals and clearly establish, for the matters raised by the joint intervenors' filings, why the responses of the applicant and the staff are insufficient.
It also indicated that the joint intervenors must demonstrate the significance to plant safety of their assertions as well as identify each remaining issue of disputed material fact with regard to
~
i 0 See Joint Intervenors' Reply To Answer Of Pacific Gas And Electric Company To Motion To Augment Or, In The Alternative, To Reopen The Record (March 15, 1984).
1 See Joint Intervenors' Supplement To Motion To Augment Or, In The Alternative, To Reopen The Record (April 6, 1984).
12 See Answer Of Pacific Gas And Electric Company To Joint Intervenors' Supplement To Motion To Augment Or, In The Alternative, To Reopen The Record (April 23, 1984); NRC Staff Response To Joint Intervenors' Supplement To., Motion To Augment, Or In The Alternative, To Reopen The Record (April 25, 1984).
13 See Order of May 23, 1984 (unpublished).
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7 l
perfection in plant construction and the facility quality assurance program is not a precondition for a license under either the Atomic Energy Act or the Commission's regulations.
What is required instead is reasonable assurance that the plant, as built, can and will be operated without endangering the public health and safety.
. In order for new evidence to raise a "significant safety issue" for purposes of reopening the record, it must establish either that uncorrected.
. errors endanger safe plant operation, or that there has been a breakdown of the quality assurance program sufficient to raise legitimatedoubtastothep}gnt'scapabilityof being operated safely.
Although the focus of ALAB-756 was a motion to reopen on the issue of construction quality assurance, what we said there is equally applicable to reopening motions directed to the issue of design quality assurance.
Further, the Commission has emphasized in this very proceeding that the proponent of a reopening motion must present "'significant new evidence.
. that materially
'affects the decision,'" not " bare allegations or simple submission of new contentions."17 At a minimum, therefore, the new material in support of a motion to reopen must be set forth with a degree of particularity in excess of the basis and specificity requirements contained in 10 CFR
- 2. 714 (b) for admissible contentions.
Such supporting 16 ALAB-756, supra, 18 NRC at 1344 (citations omitted).
1 CLI-81-5, 13 NRC 361, 362-63 (1981).
d 9
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9 have carefully examined each of the joint intervenors' charges with their supporting materials and'the responses of the applicant and the staff.
Our scrutiny of the motions leads us to conclude that the joint intervenors have failed to present new evidence of any significant safety issue that could have an effect on the outcome of the licensing proceeding.19 Among other things, the movants have not presented evidence that establishes uncorrected design or construction errors that endanger safe plant operation.
Nor have they demonstrated that there has been a breakdown of the applicant's quality assurance program that raises legitimate doubt that the facility can operate safely.20 19 The joint intervenors' reply to the applicant and staff responses filed pursuant to our May 23, 1984 order was accompanied by numerous supporting affidavits.
Despite our instruction that the reply address why the responses of the applicant and staff are insufficient for "each matter raised (or) asserted," the joint intervenors' reply "do [es]
not individually address all of.
. the matters raised."
Reply at 5.
Further, in some instances, the reply raises entirely new issues.
Although joint intervenors indicate that they had insufficient time to comply with our order, no request for an extension of time was filed.
In any event, the joint intervenors concede that "few (of the noted) deficiencies will be demonstrably 'significant' if considered individually."
Reply at 6.
The movants are apparently content, therefore, to rely on the cumulative significance of the numerous purported deficiencies, none of which individually has been shown to be safety significant.
20 For example, a number of the allegations focus on deficiencies in the methodology, practices, and quality assurance associated with the computer design of small bore (less than 2" diameter) pipe supports.
The staff also found (Footnote Continued)
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11 As previously indicated, the number of diverse allegations of purported deficiencias contained in the joint intervenors' motions is very large.
Even discounting the i
substantial repetition in the two motions, the affidavits and other documentary materials proffered as new evidence in support of the movants' charges are extensive.22 When the (Footnote Continued)
In Opposition To Joint Intervenors' Motion To Reopen The' Record On The Issue of Construction Quality Assurance And
)
Licensee Character And Competence, supra note 9, Attachment C at 12-13.
As an exhibit to their June 12, 1984 I
reply, the joint intervenors have-attached a May 31, 1984 Pullman Power Products " Interoffice Correspondence" memorandum dealing with this issue.
That memorandum is addressed to " Distribution" frcm "H. Karner" and concerns the subject of " Acceptable Stud Materials For Carbon Steel Welding (Ref: DR 5891)."
The memorandum states, ir.ter alia,,
that "LA-307 bolts with the heads removed are NOT acceptable)," and is signed by Harold W. Karner, QA/QC Manager.
The applicant shall inform'us by July 6, 1984 why, in the words of the Pullman memorandum, A-307 bolts with the
-heads removed are.not acceptable.
The applicant's i
explanation shall be accompanied by appropriate affidavits of qualified experts and shall address the movants' charge, the applicant's prior response to tha.t charge, and the recent Pullman nemorandum.
22 Not only does some of the same material accompany both motions, there is substantial repetition within the supporting materials accompanying each of the joint.
intervenors' motions.
Additionally, the material
. purportedly _ supporting each motion is' lumped together in a manner that lacks essential organization.
Further, same of this material consists of; anonymous statements.
Sed note 18, supra.
The movants havs also included in their: filings.
considerable material that is irrelevant and immaterial to many of their claims.
Thus, the unorganized nature of the supporting material, combined with the massive. amount of irrelevant matter in movants' filings, has made our task of T
(Footnote Continued)-
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W 13 demonstrate the applicant's deficient character and lack of competence to design, construct, and operate the facility.
To these historical examples, the joint intervenors add a lengthy list of alleged deficiencies in the applicant's
. design and construction quality assurance' programs from their most recent motions to reopen the record.
They argue that these new charges and supporting materials, combined with their previously recited historical evidence, in effect, create a pattern and practice of deficient character and incompetence on the part of the applicant that constitute significant new evidence to support reopening the record on this issue.
The joint intervenors' motion to reopen the record on the issue of the applicant's character and competence is denied.
The movants' historical examples of alleged applicant misconduct are not timely presented.
- Moreover, the movants' new list of purported deficiencies fails to present evidence of a significant safety issue that could have an effect on the outcome of the proceeding.
The past incidents of alleged applicant misconduct relied upon by the joint intervenors occurred too long ago to be properly considered in a motion to reopen the record without a showing why this issue could not have been raised earlier.
No such showing has even been attempted by the movants.
Nor can the tardy presentation of these historical examples be saved by bootstrapping them to a series of more
15 For the foregoing reasons, the joint intervenors' motions to reopen the record, with one reservation,25 are denied.
It is so ORDERED.
FOR THE APPEAL BOARD O..b-3%n.. A C. JQn Shoemaker Secretary to the Appeal Board l
See note 21, supra.
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