ML20214B752

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Intervenor Exhibit I-ROREM-97,consisting of 840512 Memo Discussing Company Welding Program for Facility,Including Rev to Procedure 4.8.3 & Compliance W/Contract Requirements for Possible Spec Changes
ML20214B752
Person / Time
Site: Braidwood  Constellation icon.png
Issue date: 08/25/1986
From: Dewald I
COMSTOCK ENGINEERING, INC.
To: Mennecke C, Quaka T
COMSTOCK ENGINEERING, INC.
References
OL-I-ROREM-097, OL-I-ROREM-97, NUDOCS 8705200401
Download: ML20214B752 (4)


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Comstock Engineering, Incy Memorandum

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From:

I. DeWald

Subject:

Braidwood Welding Program l

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5-12-84 nm Contract Specif1 cations L-2790 SulY AL5U3Af4CE BA10WOCO STATION Control No.

84-05-12-12 Recently, a review of the L. K. Comstock & Co., Inc. welding program at the Braidwood Nuclear Power Plant was conducted to evaluate the existing program to assure compliance to the contract requirements. This review was also to eva-luate the concerns identified by S & L who indicated our QC Inspectors were being over-critical and were marking discontinuities which S & L f elt were acceptable, Several meetings were held between Mr. T. Vogt, Comstock Engineering, Inc.,

Corporate Welding Engineer and Mr. Stu Klevens and both parties were in agreement that Comstock Procedure 4.8.3, Revision E, dated 1/30/84 was open to individual interpretation in regard to overlap, undercut, are strikes, lack of fusion, tack welds, base metal, reduction and spatter.

The procedure, therefore, allowed the Comstock Level II Inspector to make evaluations and interpretations which could be construed as over-inspection.

Based on the above review, the Welding Inspection Procedure 4.8.3 was revised clarifying all areas in which an Inspector could evaluate or interpret to cause an over-inspection of an item.

Also discovered during the review of the Comstock Braidwood Welding Program were various items pertaining to being in compliance to the contract requirements.

Based on the review, the following observations and recommendations are being for-warded for clarification and possible resolution via change to Contract Specifica-tion L-2790:

Background

s Prior to A=endment 30 to S & L Specification L-2790, all welding was to be in accordance with S & L Form 1701. Paragraphs 1.2.2 and 1.2.3 of Form 1701 required all welding procedures and welding performance tests to be conducted in accordance with AWS D1.1-75.

In addition, the following S & L Standards also require welding to be in accordance with AWS D1.1:

STD-EB-115.0 Paragraph 2.7 STD-EB-702BB Paragraph 2.4 Amendment 30 issued to S & L Specification L-2790 7/14/83, added welding in accordance with AWS D1.3.

Although AWS D1.3 was added, Paragraph 401.19.2 does not specifically define the items / components or materials to be welded in accordance with AWS D1.3.

Several questions were raised Ahuc2370 i

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Memo to C. Mennecke/T. Quaka Page 2 Control'No. 84-05-12-12 concerning welding in accordance with Specification L-2790, reference Mr. L. J.

Tapella, (CECO), memo to Mr. F. A. Kosik (S & L) dated March 23, 1934 which addressed Co=monwealth Edison's interpretation of the S & L/AWS Visual Weld Acceptance Criteria.

Mr. F. A. Kosik responded April 4,1984 and concurred with the interpretation as stated in the March 23,1984 memo.

In accordance with S & L Standard Form 1701, Paragraph 1.1.1, states in part, "All welding shall conform to the requirements of this standard unless otherwise indicated in the Project Specification or on the design drawings".

Concern 1:

Several important items have been addressed via letters between Comstock, CECO and S & L concerning welding requirements and procedure requirements, but these Dnportant items have not been incorporated into S,& L Spec,1fication L-2790.

Recommendation:

Request S & L Specification L-2790 be revised to include the following to ' support the criteria specified in Comstock i

Procedure 4.8.3, Rev. F, dated 5/10/84.

Ref erence S & L L-2790 Paragraph 401.18 Welding Procedures may be qualified to either ASME B & PV Code,Section IX, or AWS D1.1 requirements.

Job type materials such as unistrut and cable pan, which are classified as commercially purchased mate-rial may be used to perform qualifications using AWS D1.1 as a guideline.

Qualification established using commercially purchased materials qualifies all types of joints and positions to be used in construction provided the filler metal strength requirements are as specified in the original procedure qualification test.

Commercially purchased materials and structural materials may be grouped together under one (1) Weld Procedure Speci-fication (WPS) provided essential welding parameters i

renain the same.

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Memo to C. Mennecke/T. Quaka Page 3 Control No.

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S & L_ Specification L-2790 A.

' Undercut requirements of AWS DI.1-is waived for Specification L.-2790, and shall conform to the following requirements 4

regardless of the ' direction of primary stress in relation to the weld undercut.

B.

Undercut equal to or-less chan 3/16" in length and not over

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1/16" in depth is acceptable provided spacing between two dis-continuities is not less than 3 inches.

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C.

Undercut over 3/16" in length shall not exceed 1/32" in depth.

D.

Undercut in cable pan and unistrue shall be limited as follows:

Unistrut -.012 inch maximum Cable Pan

.008 inch maximum E.

Undercut defined in C and D shall have no length restrictions.

F.

Arc str3kes exceeding 1/32" in depth on material thickness up to and including 5/8" and ' arc strikes 1/16" in depth on mate-j rial thickness greater than 5/8" shall be:

Ground to sound metal; Repair welded if required in accordance with applicable welding procedure.

G.

Arc strikes on mild steel are acceptable and need not be removed provided:

J They do not exceed the depth requirements stated in F above.

There are no cracks.

No foreign inaterial such as slag, copper or unfused electrode is located in the area of the discon-tinuity.

The length of the are strike does not exceed four (4) inches.

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Arc strikes on all other materials, within the limits specified in paragraph F'shall be ground to a smooth contour and checked 4

visually to ensure soundness.

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The visual weld quality requirements for convexity and unspecified welds in AWS D1.1 ' is waived.

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Memo to C. Mennecke/T. Quaka Page 4 Control No.

84-05-12-12 These recommendations are based on the infor=ation available at the time of the review. If S & L has made exceptions similar to what is described, request these changes be incorporated into the specification.

Concern 2:

Commercially purchased job type materials have been used since the beginning of the job for performing procedure qualification tests.

The thicknesses required by AWS D1.1 to perform the procedure quali-fication test were not used. S & L Specification L-2790 does not clearly define the use of job type materials for procedure qualifi-cation test in accordance with AWS D1.1-75.

NOTE: "Many items have been installed. in accordance with procedures which were qualified using job type material".

The above concerns expressed by the Comstock Engineering, Inc.,

Corporate Welding Engineer are being forwarded to you for review and considera-tion of possible Specification changes.

Very respectfully, D

I. F. DeWald Quality Control Manager IFD/j f cc:

F. Rolan R. Marino T. Paserba Ahus2J73

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