ML20211J481
| ML20211J481 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 07/27/1984 |
| From: | Rich Smith NRC OFFICE OF INSPECTOR & AUDITOR (OIA) |
| To: | |
| Shared Package | |
| ML16341D790 | List:
|
| References | |
| NUDOCS 8606260406 | |
| Download: ML20211J481 (10) | |
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'.S. NUCLEAR RE7ULATGRY COMMISSIO Office cf Inspect::r and Auditor July 27, 1984 Ou. o ir.n.erisuan Report of Interview James P. Knight, Assistant Director for Components and Structures Engineering, Office of Nuclear Reactor Regulation (NRR), upon telephonic interview, con-cerning an allegation that a Governmental decision had been made outside official channels, provided the following supplemental infomation to that provided by Dr. Mark Hartzman on this date:
The allegation number 87 addressed by Dr. Mark Hartzman in SSER 22 was not referred to 01 as recomended by him because it was determined that no suspected wrongdoing was present and, further, that the matter had no effect on health and safety, as finally reviewed. Although Knight made this decision he comunicated it to his supervisor, Richard Vollmer, with the further advice that they (review group) would still keep their " eyes open" for any indication of matters of 01 investigative interest.
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Ibnald M. Smith Investigator, OIA Jtily 26, 1984 O,,,,,,,,,,,
THIS DOCUMENT IS PROPE RTY OF NRC, IF LOANEC TO ANOTHER AGENCY IT ANO ITS CONTENTS ARE NOT TO BE OlSTRIBUTED OUTSIDE THE RECEIVING AGENCY WITHOUT PERMISSION OF THE OFFICE OF INSPECTOst AND AUDITOR.
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HARTZMAN EXHIBIT 2 nos U
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r 10 Moreover, our searching review of the motions reveals no, thing that causes us to question the continuing validity of the conclusions we reached in ALAB-756 and ALAB-763 --
conclusions that followed extensive evidentiary explorations of construction and design quality assurance at Diablo Canycn.
For these reasons, the motion to reopen on the issue of the applicant's design quality assurance program is denied and, with the reservation noted in the footnote below, the motion to reopen on'the issue of the applicant's construction quality assurance program is also denied.21 (Footnote Continued) the number of errors occurring in this type of calculation to be higher than expected (NRC Staff's Answer To Joint t
Intervenors' Motion To Augment Or In the Alternative, To Reopen The Record (March 15, 1984), Knight Affidavit at 14).
A staff imposed license condition required the applicant to redo all computer-based small bore pipe support calculations
-- including additional physical effects not addressed in the original analyses.
Transcript of May 9, 1984 Meeting 1
b~etween NRC staff and applicant at 15-23, 247.
We note that the result of this program, with the reanalysis of all but 15 of 357 supports completed, shows that all of the supports meet design criteria, and no modifications are necessary.
Letter from J. Schuyler to D. Eisenhut (June II, 1984)
(DCL-84-223), attachment at 1-5.
Thus, errors in the small bore pipe support computer calculations, though numerous, l
have had no effect on the design adequacy of the supports.
21 We reserve ruling on one matter raised by the joint i
intervenors' reopening motion on the issue of construction quality assurance until we receive further information from.
the applicant.
In its February 22, 1984 motion at page 12, '
the joint intervenors charge that the applicant improperly used, as studs for the containment liner, A307 hardware bolts with the heads removed.
According to an affidavit i
accompanying the applicant's response, the use of such bolts was permissible.
Pacific Gas And Electric Company's Answer (Footnote Continued)
ATTACHMENT P
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11 As previously indicated, the number qf diverse allegations of purported deficiencies contained in the joint
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in ervenors' notions is very large.
Even discounting the substantial repetition in the tv.o 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 reply, the joint intervenors have attached a May 31, 1954 Pullman Power Products " Interoffice Correspondence" memorandum dealing with this issue.
That memorandum is addressad to "Distributi6n" from *H. Karner" and concerns
. the subject of " Acceptable Stud Materials For Carbon Steel Welding (Ref: DR 5891)."
The memorandum states, inter alia, that " (A-307 bolts with the heads removed are NOT acceptable)," and is signed by Barold W. Karner, QA/DC 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 novants' charge, the applicant's prior response to that charge, and the i
recent Pullman memoran.fum.
22 Not only does some of the same material accompany both motions, there is substantial repetition within the l
supporting materials accompanying each of the joint.
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intervenors' notions.'- Additionally, the material +.
purportedly supporting each motion is lumped together in a manner that lacks essential organisation.r Further, some of this material consists of anon p us statements.
See note 18, supra. 3he novants havd also. included.in.their_ filings consieerable material that is irrelevant.and.isunatorial to many of their claims.'
Thus, the unorganised mature of the supporting material, combined with the massive amount of.
Irrelevant matter in movants' filings, has made our task of (Footnote Continued) y
o,.
1 (b) The alleger is correct in stating that the WPS documents do not adequately illustrate all joint types which are welded. WPS 7/8 is qualified in accordance with ASME Section IX req'uirements which indicates in QW 402.1 that a change in joint type is a non-essential variable.
Lack of description of all types of joints utilized is contrary to Section IX rules and requires a revision to the WPS.
However, this is an administrative change only and does not require requalification of the WpS.
(c) In response to the allegation regarding unapproved welded materials, the staff reviewed each type of material identified by the alleger.
Certain of these materials such as A500 and A307 were not listed in the published code but were approved for use by a separate code The staff is satisfied that all the materials of concern in
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case.
this allegation were properly approved for ASME or AWS usage.
2.
Allegations 106, 107 and 108:
The alleger stated that Welding Technique Specification No. AWS 1-1 was' not applied to AWS welding in that, (a) AWS 1-1 was not referenced on every Pipe Rupture Restraint Welding Process Sheet, (b) AWS 1-1 was written and approved by an unqualified individual, and (c) AWS 1-1 specified an unlisted AWS code material.
o Staff Position i
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ATTACHMENT Q
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(a) The alleger is correct that in some cases QC failed to clearly identify on the weld process sheets when welding was to be conducted to the WPS plus the Welding Technique Sheet's.
However, the use of Welding Technique Sheets to amplify and clarify WPS documents is an accepted standard. industry practice. At Diablo Canyon the significant clarification made by the Welding Technique Sheet is the introduction of tighter controls on preheat. Whether this information was directly tied to the WPS through the technique sheet is of little consequence since the same information is clearly stated in other relevant documents (EDS 223 and EDS 243). As the preheat is covered in all cases, the inclusion of the exact document, whether it is the WPS or Welding Technique Sheet identification, is considered to have no engineering or quality related significance.
(b) The alleger expressed concern that a Welding Technique Sheet was prepared by an unqualified individual.
In so doing Pullman utilized a QA/QC person to perform a function out of his area of expertise and permitted this individual to audit his own work.
The staff found that there are no codes and standards requirements that state that a WPS or Welding Technique Sheet must be prepared by a specific individual..The only requirement is that the document adequately address the codes and standards variable rules i.e., essential and non essential variables.
The WPS documents and Welding Technique Sheets met the rules (with the exception of the QW 402.1 non essential variable as previously discussed) and were properly approved by the licensee.
QA/QC personnel normally monitor A.4-103.4
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implementation of programs and procedures, the fact that they may have assisted in writing the implementing procedures does not support the conclusion that QA/QC is auditing its own work.'
(c) The alleger is correct that ASTM A515 steel is not listed in AWS D1.1 as an approved welding material.
The staff found that A515 is not listed in AWS D1.1 Structural Welding Code because A515 is normally considered as a pressure vessel material.
However, A515 was properly qualified and is acceptable material for welding structures in compliance with AWS DI.1 rules.
3.
Allegations 109 and 110:
The alleger states that structural steel pipe supports were not designed, fabricated and erected to the American Welding Society (AWS) code.
He further states that the PG&E Contract Specification 8711 requires pipe supports to comply with the applicable standards of the ASTM, ANSI, ASME, MSS, AWS, and PFI.
Additiontlly, he states there was no change to the PG&E contract specification to allow pipe support to be worked to a standard other the AWS.
Staff Position i
The staff found that the pipe support work was properly done to the ASME code which is permitted by the AWS code.
Supporting details of the staff's findings are as follows:
A.4-103.5 W--
The American Welding Society D1.1 permits the ENGINEER to " accept evidence of previous qualification." It is normal practice to interpret this as permitting ASME Section IX welding qualification in lieu of D1.1 qualification by testing.
In addition, the 8711 Specification Section 3 (para 4.11 and 4.12) require performance and procedure qualification in accordance with Section IX. Based on staff reviews, the welding qualification methods utilized by Pullman meet ASME Section IX requirements.
The materials for pipe support welding were: A36, A500, SA515, SA516, and bolting materials A307, and A108 (grades 1010-1020).
The staff found that each of these materials is suitable and allowable for ASME pipe support welding.
The staff reviewed Pullman procedure qualification documentation for engineering justification for welding in accordance with current ASME Section IX and AWS D1.1 rules (through utilization of the ENGINEER'S prerogatives in paragraph 5.2).
This review included the procedure qualifications for "as-welded" fabrications and the following types of welding: ASME P1 to P1 material using shielded metal arc welding (SMAW);
AWS Group I to Group I, using SMAW; AWS Group II to Group I and II, using SMAW; Welding of SA500, A441, A588, using SMAW; welding ASME P1 to AWS Group I using gas tungsten are welding (GTAW), ASME P8 to P8 using SMAW; ASME P8 to P8 using GTAW; tack welding, using SMAW or GTAW.
Various thickness ranges were included.
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i PACIFIC OAS AND E LE C T RIC C O M PANY 77 BEALE STREET. SAN FR ANCISCO. CALIFOR NI A 94104 TELEPHONE (415) 781 4211 OYJ f:
5 P. O. B OX 744 2. S A N FR ANCISCO, CALIFORNI A 94120 TELECOPIER (415) 543 7813 o,
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July 5,1984 Thomas'S. Moore, Esq., Chairman r John H. Buck Dr. W. Reed Johnson Atomic Safety and Licensing Appeal Board U. S. Nuclear Regulatory Commission 4350 East-West Highway East-West Tower, 5th Floor Bethesda, MD 20814 Re: Docket No. 50-275, OL-DPR-76 Docket No. 50-323 Diablo Canyon Units 1 and 2 Response to Footnote 21 of Memorandum and Order Dated June 28,1984 (ALAB-775)
Gentlemen:
In response to footnote 21 of the decision of the Appeal Board dated June 28,1984 (ALAB-775), the Affidavit of H. W. Karner is enclosed.
As can be seen from the Affidavit, the prior responses of applicant to allegations concerning the use of #307 material remain true and correct.
i Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it.in the enclosed addressed envelope.
1 Very truly yours,
' an G. L' ock Enclosure
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ATTACHMENT R l
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD
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In the Matter of
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Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC
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50-323 COMPANY
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(Diablo Canyon Nuclear Power )
Plant, Units 1 and 2)
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AFFIDAVIT OF H. W. KARNER STATE OF CALIFORNIA
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CITY AND COUNTY OF SAN FRANCISCO )
The above, being duly sworn, deposes and says:
My name is Harold W. Karner.
I am employed by Pullman Power Products as Manager, Quality Assurance / Quality Control, at Diablo Canyon Power Plant. On May 31,1984, I issued an interoffice memorandum to all Pullman QA/QC inspectors onsite which stated, inter alia, that "A-307 bolts with the heads removed are NOT acceptable." My intention when issuing the memo was nr+ tc imply that the prior use of A-307 bolts as studs was technically unacceptable, but merely to procedurally stop a practice which had evoked enough controversy that its continuation was not deemed desirable.The memo was written to specifically address DR-5892, which referenced A-490 and A-193-B7 studs, and to provide additional controls on the type of carbon steel stud material which can be welded without extra case-by-case authorization.
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The May 31, 1984 memo does not in any way alter the position taken in PGandE's Response to Joint Intervenors' Motion to Reopen the Record on the Issue of Construction Quality Assurance, Attachment C, page's 12-13.
A-307 Grado B bolts / studs are weldable and have been properly welded and meet all i
specification and code requirements for weldability, chemical compositien, strength, and traceability.
There was no technical reason why I included the statement regarding the use of A-307 Grade B bolts as studs.
I only meant that from that date forward, Pullman welders could no longer make A-307 Grade B studs from A-307 Grade B bolts without prior QA/QC approval.
I have read the preceding two pages and the information outlined therein is true and accurate to the best of ny knowledge.
Dated: July 5,1984 H. W. Karner Subscribed and sworn to o
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before me this 5th day C. T. NEAL MADISON of July,1984 NOTARY PUBUC - CAUFORNIA clTY AND COUNTY OF
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Cyntnia Neal-Madison Notary Public in and for the City and County of San Francsico SEAL' State of California My commission expires December 27, 1985 e
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