ML20214F408
| ML20214F408 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/09/1986 |
| From: | Vogt T COMSTOCK ENGINEERING, INC. |
| To: | Dewald I COMSTOCK ENGINEERING, INC. |
| References | |
| 84-09-12-07, 84-9-12-7, OL-I-ROREM-031, OL-I-ROREM-31, NUDOCS 8705260067 | |
| Download: ML20214F408 (16) | |
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Memorandu37 APR 22 P6 32 off;ce: 3raidwood To:
Irv DeWald UFFIL._, _ a,
,y y cw DOCKET w i ec;v Fr:m: T. D. Voet BRN 'Cb Seete-ber b,1994
Subject:
Weld Filler Metal Withdrawal Date:
Cent =ol No: 84-09-12-07 In response to the NRC statements regarding the Cc= stock smer metal with-drawal program, reference NPO Docket No. 50-456 and No. 50-457, the follow-ing actions have been taken.
A review of the identified iter.s was conducted and the following has been identifie d.
1.
The heat nunbers identified are acceptable heat nu=hers trace-able to valid certificatica papers.
2.
The ec ponents welded utilizing either of these electrodes meets or exceeds the strength rer.:j.re=ar.ts specified by AWS 01.1-75.
3.
'lhe velders Isaking the welds were c.:alified to use either filler metal.
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An obvious procedure violation did occur.
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A noncenfor=ance report should be initiated.
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Based on the above ce=ments nonconfernance report NCR 3275 as been issued to identify the procedure violaticas which did occur and allow ti=e for a proper review and evaluatien of the identified nonconfor=ance condition.
Correction Action Completed: Procedurc 4.3.10 Pav D dated 8-12-84 titled
" Storage," issue and Control of Welding Material has been revised and approved, which reg.: ires a filler metal issue tab to be issued for each type and size of electrode and for each day's welding activity.
Corrective Action to be Taken: Training on the Procedure Raquirements will be given to all affected Personnel detailing the control of heat numbers and docu=entatica practices for the filler metal issue tabs.
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Comstock Engineering, Inc.
Memorandum R. Saklak 7,.
office: Braldweed N. Puckett Date: Auoust 17. i984 Subjec=
mod slips control No: 84-08-15-14 4 2/f?'
L During the period of tiza that I was doing Research on Wald Rod Slips for the sonths of May, June. and July of 1982 it occured to f d,g) me that the problems we were having during the afore mantioned g
period could possibly be generic through other periods, so I g
performed a spot check on the Rod Slips Issued in December 1982, Septazber 1983, January 1984, June and July 1984 and during thi.s g
period the problem did persist, however not as prevelant in the year 1984. In addition during the period prior to May 1982 Heat Numbers for I-6013 electrode were not en.ared on the weld filler material withdrawal form. I also took a sa=pling of heat numbe=s off of these previously issued Rod Slips to see if they could be traced to documentation the Beat lot nu=bers is the Research of
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'neelve separats heat numbers I was successful in all but three heats 40157441 and 40159011 for I-7018 and 35202061 for E-6013.
It would be my suggestion at the very earliest convenient tirm
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that a sers thourough review be perforred en all the Red Slips so as to have an in-house identificatics of any ma-lor problei=s i
we may have.
b-Respectfully, v'-
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Memorandum To:
File (W. O. Puckett)
Office: Braidwood From:
I. F. DeWald
Subject:
Letter Dated August 22, 1984, W.O. Puckett Date:
9-17-84 y
hN Control No. 84-09-17-04 b.
In reference to the subject letter issued by W. D. Puckett expressing his concerns pertaining to the welding area.
A.
The stainless steel welding procedures originally approved by Cor..onwealth Edison Cc pany, and Sargent and Lundy were reviewed and the following has been identified:
ne welder qualification tests were accomplished in the SG position. This only qualifies the welders to weld in the 1G, 3G and 4G positions only.
In view of the afore menttioned the stainless steel procedure 4.3.14 must be requalified to include the 2G position, the welders must be qualified in the 2G position which will qualify them in all positions. Rese areas are presently being corrected. Non-Confor:.ance Report No. 3145 was initiated addressing the above concern.
B.
The welding of A36 to galvanized A446 using E-7018 had been i
resolved by the subject individual prior to the issuance of his letter. This was also addressed to Commonwealth Edison Cempany and Sargent and Lundy in a letter dated 5-12-84 Control No. 84-05-12-12, of which add.ressed, the qualification of weld procedurws to AWS D1.1 and AWS D1.3 as to the use of materials and their thickness used on site. Non-Conformance Report No. 3099 was generated addressing the welding of AS m-A446 (Calvanized Material) to ASTM-A36 using E-7018 electrodes. This NCR was dispositioned as not a non-conforming condition as WPS attachment R in BP 4.3.3 qualify weldments for 3/8" as a W_== up to 11/16 maximum and welding could continue for these required welds. Non-Conformance Report No. 3137 was initiated on 8-23-84 indicating the welding of ASM-A446 to ASTM-A36 requiring 1/8 and 1/4" fillet welds, a WPS had been done and submitted for approval in 4.3.3 REV C which was re.iected by Sargent and Lundy due to the weld type. The original weld samples along with the revised WPS was resub:=.itted to the PTL for requalification and to Sargent and Lundy in BP 4.3.3 REV D with weld type revised to indicate a fillet weld vice a flare level groove weld as was originally sub:nitted.
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-1 rile (W. O. Puckett)
Page 2 of 3 Control No. 84-09-17 Cent.
On August 15, 1984 Control No. 84-05-15-01 a letter was sent to construction recommending stainless steel welding be stopped and the procedure requalified.
Also that the procedure to weld A36 to A446 be requalified.
L.K.C.
Construction responded by stopping the welding in letter C-84-08-50.
The A36 to A446 procedure was requalified and has been submitted for approval.
A review of the welding procedures did show inconsis-tancies of whi'ch were minor in nature and were previously addressed by Sargent and Lundy on the procedure review of 4.3.3 REV C.
The necessary corrections were made and procedure 4.3.3 REV D was submitted for approval of which interin approval has been granted by Cor=enwealth Edison Company for site use.
C.
'Ihe welder qualifications as indicated by Mr. Puckett as being indeter=inant were reviewed and found to be minor in nature.
Items found that are considered _ miner in nature are LOA Brand na:ne of electrode not given.y.
A.
B.
Wrong material spec. listed for base metal (i.e. A-lO6 GR. B Iftted for ASTM-A36 plate).
, pf C.
Wrong specification nu=ber listed (i.e. SFAS.1 for AWS A5.1).
S The above itens are considered ninor in nature and do not g
affect the inteerity of the tasts or the qualifications.
F The necessary corrections are expected to be completed by g*
Never.:er 15, 1984.
A y
During the welder qualification review (5) five velders
[k were found to be qualified by Mr. Puckett between 8-7-84 and] hM 8-14-84 of which Mr. Puckett was not certified as an inspector through this time period, Non-Confermance Report No. 3276 was My initiated on 9-12-84 addressing this problem.
pg'7, D.
Concerns were also addressed by Mr. Puckett pertaining to the Tiller Metal Withdrawal, Non-Conformance Report %
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No. 3275 was initiated addressing this problem. The Weld
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- i Rod Control procedure 4.3.10 has been revised to correct
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N the concerns and Commonwealth Edison Company has granted interim approval.
Mr. Puckett's concerns had been previously addressed by the Resident NPO inspector in docket No. 50-546, 50-547 regarding the proble= with the old filler metal withdrawal tabs.
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File (W. O.
- Puckett, Page 3 of 3 Control No. 84-09-17 Cent.
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E.
A surcary of Mr. Puckett's letters Control No's 64-08-15-14, 2
b 84-on-1514 A and letter dated August 22, 1984 indicates that
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'the information presented by Mr. Puckett does not substantiate (s
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a cor plate breakdown in L.K. Comstock's Welding Program nor L
Comstock't Quafity Control Program, and that a stop ork is not w trante d.
'Ihe inconsistancies that were addressed were previously identified by other parties prior to Mr. Pucket s letters of concern. The concerns are minor in nature and corrective action has and is being implemented to correct th se concerns.
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I. F. bewald Ouality Control Manager IFD/sm Attachments CC:
D. Sharblin CECO PCD
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h R. Quaka CECC QA J. Giesaker CECO PCD
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L. Tapella CECO PCD 4
F. Rolan L.K.C. Proj. Mgr R. Marino Comstock Eng. Inc.
T. Paserba Comstock Eng. Inc.
T. Trurble Cor. stock Eng. Inc.
T. Vogt Comstock Eng. Inc.
R. Seltrann QC File QC Mgr File
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Q 53004253
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PERSONNAL & CC::FCE:
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Worley Puckett - Ninety (90) Day Evaluation Meeting.
August 2 7, 1984 - Time : 2:20 PM - Place: Irv's Office Present:
I. DeWald L. Seese W. Puckett A) Irv Reviews Company Policy on 90 Day Evaluation.
B). Shows Test Problems c) Worley " Regrettable Situation" "I was prepared for it."
D) Irv presents Exit I4tter on Reportable Items.
Puckett "I don't have time to make a statement today and when he does it will be with the NRC" "I want you to know it was my intent to resign after the review" " I don't want to work for this orgasization."
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"We will see what a Lawyer and the NRC will say."
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W'J Y V
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I. F. DeWald I
Quality control Manager
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L. Seese.
Assistant QC Manager E e.x '. 6'+
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EETING - Augus t 2 7, l'...
D. Sharblin CECO PCO AT;*ENDEES:
D. Sharblin CECO PCD Project Superintendent J. Gieseker CECO PCD I. DeWald COMSEK ENGINEERING, E;C. QC Manager Meeting Agenda: Discussions were held concerning U. O. Puckett and concerns addressed from various persons.
I) 'the decision after discussing his performance was to terminate W. O. Puckett under the 90 day clause the Company has in force.
B) The Welding inconsistancies as expressed in the letter from
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g' W. O. Puckett is felt by. CECO PCD and myself r.inor correctable g,
items and items. presently corrected.
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1 C) Lead Inspection situation of salary will be addressed with R. Marino, first by I. DeWald and second by D. Sharblin CICC PCD.
.D) W. O. Puckett situation to also be addressed to R. Marino for F
ra=ifications prior to dis =issal.
A Submitte d, r
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I. F. DeWald Quality Control Manager IrD/pb B 2sooc43sv Ea t-2. a,
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Memorandum i
To-
- r. M an Office: Braidwood
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i Frc,m:2. DeWald i
gg elding Qualifications & Procedures Date: August 15, 1984 W
84-05'-15-01 g go d i
control No:
i In reference to W. Puckett's obseivation and concerns with our present Welding Proced:1re, there are definite inconsistancies in the stainless Steel Welding Procedure which are:
1.
A) no welders are not qualified in all positions as the SG position was used for the Initial Qualification.
B) na welders have to be qualified in the 2G Rorize.~4 Position to be qualified for all positions.
c) The procedure that was qualified in the SG position do's not qualify a B1-Metalic Weld.
e Ezanple: SA-240 Type 304 Stainless Plate to SA312 Type 304 Stainless Steel Pipe, or SA312 Type 304 Stainless Steel Pipe to any grade Carbon Steel Plate.
2.
A Weld Qualification Procedure has to be done for welding ASTM-A36 to AS':M A446 using E7018 Electrodes.
3.
ne above sentioned Welding Qualificatiens for' the welder and procedure has bs be accomplished in order to bring our procedures EP 4.3.3 and BP 4.3.14 into coupliance with AWS D1.1 Specifications.
4.* **In view of the,above mentioned probler.s I recommend that all Stainless Steel Welding be stopped until such tise as Item #1 has been corrected.
5.
'!he carbon Steel Welding Procedure should' be qualified as soon as possible.
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- r. Polan - Centrol No:
.-05-15 con tinued Page 2 1
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For any further reqcired inferr.ation W. C. Puckett shculd be ccatacted.
He is presently getting the Qualificatien Process set-up for the ASCM A36 A446.
Attachment e-
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Raspectfully, t
I. F.
DeWald Quality Control Manager IFD/pb cca W.C. Puckett RJrsautomnn QC, File QC Mgr. File 4
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L. K. Comstock & Company, Inc.
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Memorandum To.
L.K.C. Suoervision offic.: Braidwc M From:
F. Rolan
Subject:
NCR #3099 Dets: OR/17/S (1:45 p.m.)
Control No.: C84-08-50 You are directed to STOP immediately all welding of ASTM A-36 to ASTM A-446 material using E7018 elec -ode until weld procedure 4.3.3 is qualified in accordance with WS 1.1 1975 Sect. 5, Part.B.
d Also, stop all welding operations on s tain1 ss st el until welde s g\\
are qualified in all positions as indi ated o
.ezo a um of August 15, y
1984 from Irv DeWald (84-05-15-016 F. Rolan
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Project Manager Attachments FR/dp cc:
D. Bryant I. DeWald J. Klena S. Seltmann Araa Managers Area General Foremen file 32 sooo43s4
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Irv. DeWald August 22, 1984
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W. Puckett h -3b Irv:
over the past few weeks I have been performing a preleminary ruviaw of.'4ur Weld.
Procedures. In addition to the ones that I have alr1ady recomumended stop work E en i.e all stainless and A36 to A446 using E-7018. There are at least five t-others that were incorrectly qualified. These being all the procedures involving galvanised ASTM A446. ' Die afore mentioned procedures.wezu qualified -
- using the cryteria of AWS Dl.11975 and it should have never been done. AWS AM. rs Dl.1 cryteria was never intended to be used to Weld materials less than an 1%.
- 5 1/8" thickness our heaviest guage unistrut is 12GA which is.105 all of our procedures that involve A-446 should have been qualified using the cryteria of D.l.3 which has a coupletely different set of test requirements and a completely different set of essential varaibles. In addition to these pro-cedures that I can assure you are not qualified there are so many inconsistancies in the remaining procedures that we are using that I'm sure their qualifii:ation would be considered indeterminate.
I'm aware of the impact it would have but I strongly recomunend that all weldings be stopped and that and all out effort i
be started to do a complete review of our procedures, welders qualification and welders filler material. Withdrawal Forms and once the magnitude of our problems have been determined we can better address our non-compliances and fozzulate a plan that will bring us back under the codes and specifications we should be working too.
Irv I work for Comstock too and I speak from a lot of experience with the Procedures being what they are and the moral of the QC Inspectors being what it is we are dangerously approaching a complete break down in our QC Program.
I think you are aware of this and I'm sure neither of us would want'this to l
happen.
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Comstock Engineering, Inc.
I-Memorandum L Saklak o,9;,,
Braicaoed 7,.
From: W. Puckett
Subject:
Rod slips Date: April 15, 1984 Control No: 84-08-15-14 In regards to Weld Rod withdrawal Forms dated between 5/25/8gp/ y and 7/22/83, the main concern involves three heat numbers 91 #
411P4161 and 40259001 for E-7018 and 2D209808 for E-6013.
N.R.C's concern was that the Weld Pod withdrawal Forms referanced a type of Rod i.e., E-6013 but the heat number listed for the i
material is documented as being E-7018.
I preforzned extensive
'l research on these Rod Slips with the following zusults.
1.
The three heat numbers afore mentioned are good heat nunbers traceable to valid certification papers.
2.
The components on which they were used, the filler
,F strength meets or exceeds the strength requirements.
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3 The welders making the welds were qualified to use either filler.
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4.
We have an obvious procedure violation which could be aleviated in the future by a thorough Indoctornation of the craf t tool room weld rod issue clerk.
- 5. - A non conformance " report should be 1:dtiated listing the heat nu=bers and types invclved and a outline of s
the procedural violatien.
Respectfully, k
G y, c,@ _ _ t-.
W. O. Puckett WOP /pb cc: QC File QC F.gr.
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