ML20214N983

Testimony of Rl Kurtz Re Intervenor Rorem Subcontention 2.C Concerning Edition of Aws Code Applied to Welding Activities within Lk Comstock Scope of Work.Related Correspondence

ML20214N983
Person / Time
Site:	Braidwood
Issue date:	09/16/1986
From:	Kurtz R COMMONWEALTH EDISON CO., SARGENT & LUNDY, INC.
To:
Shared Package
ML20214N985	List: ML20214N983 ML20214N992 ML20214P003
References
CON-#386-710 OL, NUDOCS 8609170200
Download: ML20214N983 (11)

Text

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USNRC UNITED STATES OF AMERICA }$ gp jg gjj Qg NUCLEAR REGULATORY COMMISSION I

BEFORE THE ATOMIC SAFETY AND LICENSING BOARD OFFIC(i-OCCXL rj c

In the Matter of: )

COMMONWEALTH EDISON COMPANY )

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) Docket Nos. 50-456 (31_

) 50-457 (Braidwood Station, )

Units 1 and 2) )

Rebuttal Testimony of Randall L. Kurtz on Rorem Subcontention 2.C Introduction

01. State your full name, employer and your present position.

A1. My name is Randall L. Kurtz.

I am employed with Sargent & Lundy Engineers as the Assistant Head of the Quality Control Division. My business address is 55 E. Monroe, Chicago, Illinois 60603.

Q2. Please describe your professional and educational qualifications.

A2. I received a Bachelor of Science Degree in Metallurgical Engineering from Purdue University in 1976. From January 1974 to April 1976 I was employed by Bechtel, Inc., as a vendor surveillance inspector.

8609170200 860916 PDR ADOCK 05000456 T PDR DSo3

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In May 1976, I was employed by Sargent & Lundy Engineers as a Quality Control Engineer. My responsibilities in-cluded reviewing the nondestructive testing procedures submitted in response to S&L speci'fications by vendors and contractors for the Byron and Braidwood projects. I was certified by examination in'accordance with S&L pro-cedures as a Level III Inspector in visual examination, source surveillance inspection, ultrasonic testing, magnetic particle testing, radiographic testing and liquid penetrant testing.

In 1977 I was promoted to the position of Quality Control Coordinator. In that position I assisted Senior Coordinators in the administration of the S&L quality control activities on various nuclear projects. This led to my assignment as Lead Project QC Coordinator for two nuclear plants, including Marble Hill, whose design replicates that of the Braidwood plant.

In 1981 I was promoted to Senior Quality Control Coordinator, and I continued to work almost full-time on the Marble Hill project until 1983.

As the Senior Quality Control Coordinator for Marble Hill, I was heavily involved in implementation and interpretation of code requirements, including ASME

f Section III and AWS Dl.l. For example, on the Marble Hill project S&L had responsibility for issuing formal code interpretations. I was a principal author of several of those formal interpretations, and was in-volved in the preparation or review of all of them. I ,

was also certified as a Certified Welding Inspector by the American Welding Society. In addition, I was certi-fied by S&L as a lead auditor in accordance with the requirements of ANSI N45.2.23.

In August 1983 I became the Supervisor of the Project Section in the Quality Control Division. In that position I was responsible for assuring that the Quality Control Division Project Section activities were performed in accordance with client project requirements, S&L pro-cedures and accepted QA/QC standards. The Senior Quality Control Coordinator with responsibilities for Byron and Braidwood reported to me.

Currently I am Assistant Head of the Quality control Division. I manage OCD's activities implementing the commitments of the S&L Quality Assurance Program, management directives and client project requirements.

Additional responsibilities include an assignment on S&L's Structural Weld Committee, the group that formu-lates S&L policy on welding and welding-related issues.

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i I am a principal author of a program for a code inter-pretation system, dealing principally with ASME Section III.and AWS Dl.l. This program provides a computer method for cross-referncing'all. relevant code interpretations.

I am a member of Edison Electric Institute's Piping,

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Metallurgy, Welding and Corrosion. Task Force.

This group reviews common industry problems in an attempt to develop generic resolutions. I have presented technical papers on inspection and nondestructive examination to the Energy Division.of the American Society for Quality Control and the American Power Conference.

I have given training courses in visual weld inspection, weld mapping and principles of nondestructive examination and other subjects to various groups including utility and contractor inspectors.

03. What is the purpose of your testimony?

A3. My testimony will explain which edition of the AWS Code applies to welding activities within L.K. Comstock's scope of work at Braidwood Station. In addition, I will respond to a specific technical issue raised by Mr.

Puckett during the hearings in this proceeding.

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' Applicable Welding Code

04. What welding requirements were specified in the contract for the performance of the electrical work at Braidwood

' Station?

A4. As explained in the testimony of Mr. Kenneth Kostal, the initial contract between Commonwealth Edison and E.C.

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Ernst, Inc.,.which incorporated Sargent & Lundy Specifica-tion L-2790, required that welding be performed in accordance with AWS D1.1-1975. The specification also permitted Ernst the option of qualifying its procedures under Section IX of the ASME Code. Mr. Kostal also explains that the contract between Commonwealth Edison and L.K. Comstock, which also incorporated Sargent & Lundy Specification L-2790, similarly required that welding be performed in accordance with AWS Dl.1-1975, except that at Comstock's option, welders could be qualified under ASME Section IX.

05. Did Ernst qualify its procedures under Section IX of the ASME Code?

A5. No. Based on my review of the Ernst welding procedures, which were reviewed by Sargent & Lundy, all welding procedures and welding procedure qualification beginning with the date of the first procedure submitted, were based on AWS Dl.1-1975. This reflects the common under-standing of all parties that AWS Dl.1-1975 was the ap-  :

plicable welding code under the terms of the contract.

Q6. Did Comstock qualify any of its welders under Section IX of the ASME Code?

A6. No. Based on my review of the Comstock procedure for welder qualification, Comstock used AWS Dl.1-1975 as the basis for welder qualification.

07. What codes and standards did comstock apply to its welding activities at Braidwood?

A7. Based on my review of the Comstock welding procedures, which were reviewed by Sargent & Lundy, all welding procedures and welding procedure qualification, be-ginning with the date of the first procedure submitted, were based on AWS Dl.1-1975. Again, this reflects the understanding of all parties that AWS Dl.1-1975 was the applicable welding code under the terms of the contract.

08. Mr. Treece's testimony seems to indicate that there is some question about the scope and continuity of Form 1701 under Specification L-2790. Does this mean that the welding '

performed by Ernst and Comstock at Braidwood was not, for some period, governed by AWS Dl.1-1975?

AB. No. The welding performed by Ernst and Comstock was con-tinuously governed by AWS Dl.1-1975. This is evidenced by the reference to AWS Dl.1-1975 in every issue of every welding procedure submitted by Ernst and Comstock, which I have received.

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09. Is the continued use of the 1975 edition of AWS Dl.1 by Comstock today permitted by the AWS Code and the cognizant Code committee?

A9. Yes, since the 1975 edition of AWS Dl.1 is the code specified in'the Comstock contract documents. The American Welding Society has issued a Formal Interpretation stating that the applicable edition of the code is the one specified

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in the contract documents. (See Board Exhibit 5.) Although the interpretation references only Dl.1-1980 and Dl.1-1984, it is clear that the interpretation has general applicability and is not restricted to these examples.

010. Doesn'.t the formal interpretation indicate a preference in behalf of the Committee for use of the current edition of AWS Dl.l?

A10. No. The Committee recommends'that the engineer allow use of the current edition of the code only in the special case where this is requested by the organization performing the welding under the code. The Committee's endorsement of allowing this flexibility to the contractor does not reflect their preference for any particular edition of the code.

.Q11. Since 1979, AWS Dl.1 has incorporated by reference the provisions of AWS Dl.3 governing the welding of base metals less than 1/8" thick. Shouldn't these code requirements apply to Comstock's welding of these base metalo?

8 All. No. To further confirm that code interpretation No.

Dl-84-015 applies to the welding work performed by L.K. Comstock at the Braidwood site, Commonwealth Edison Company directed an inquiry to Dr. Moss Davis of the American Welding Society by letter of October 17, 1984. (See Board Exhibit 3. ) The letter posed the following question: "Due to a contract date in 1975 prior to the publication of Dl.3 code, welding of material less than 1/8" is accomplished meeting the requirements of the Dl.1 code. Is it permissible to perform this welding to the Dl.1 coder even though later editions state that it is not intended for materials less than 1/8"?" In the written response, dated November 19, 1984, AWS rephrased the question in the following manner:

"AWS Dl.1-75 has no limitations on the thickness of material to be welded. Is it permissible to perform welding to AWS Dl.1-75 on materials less than 1/8"?"

The letter replied as follows: "Yes. The code specified in the contract document applies unless modified by the engineer. (See Interpretation No. Dl-84-015.)" (See Board Exhibit 4.) Thus it is clear that the use of AWS Dl.1-1975 for welding activities of the electrical contractor is consistent with industry practice and the appropriate codes.

5 Q12. Has the contractor in this case requested permission to use the AWS Dl.3 Code?

A12. No. Comstock has not requested such permission. In fact, Amendment 42 to Specification L-2790 provides permission to the' contractor to use AWS Dl.3. This amendment states in part that, "at the option of the .,

contractor where base metals thinner than 1/8" are to 1

be welded, the requirements of AWS Dl.3 may be applied in. lieu of AWS Dl.1" LKC has not exercised this option.

Exercise of the option would require a rereview of all procedures and a revision of most procedures would be required. This extensive task would not enhance the l

quality of the work.

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Welder Qualification 013. At Tr. 6141 Mr. Puckett asserts that the thickness qualification range stated in Table 5.26.1 of AWS Dl.1 for the specific case of a 6 inch Schedule 80 test pipe applies to groove welds on plate. Do you agree?

A13. No. Table 5.26.1 of AWS Dl.1 does provide a minimum thickness of material which a welder is qualified to weld when his qualification test is performed on 6 inch Schedule 80 pipe. However, this lower limitation is intended to apply only to pipe, not to plate.

Table 5.26.1 provides range of thicknesses which a welder is qualified to weld based on whether his

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s qualification test was performed on plate or pipe.

Mr. Puckett correctly states that a pipe test is more difficult to perform than a plate test. This is re-flected in the Code by the fact that a welder who qualifies on pipe is also qualified to weld plate, while a welder who qualifies on plate is not qualified to weld pipe. A welder who qualifies on plate has no minimum thickness limitation imposed on his qualification, regardless of the thickness of the test plate. For a welder who qualifies on pipe, however, Table 5.26.1 specifies a minimum thickness of pipe which the welder is qualified to weld. Thus it would be inconsistent with the requirements of the Code to extend the minimum thick-ness limitation specified for pipe to the plate qut.lification.

This would impose a more restrictive qualification range for plate applications when a welder qualified using the more difficult pipe test than when ha used the less difficult plate test. The values given in Table 5.26.1 for minimum thickness qualified necessarily relate to pipe applications only and in fact correlate to the '

thickness of the thinnest commercially available pipe.

Q14. Mr. Puckett asserted, at Tr. 6142-6143, that the Ernst welder qualifications were performed using a 6 inch schedule 80 pipe with backing strip. Do you agree?

s A14. No, I have reviewed all revisions to the E.C. Ernst welder qualification procedure '(Procedure 9.2) and all revisions call for welder qualification to be performed on'6 inch schedule 80 pipe without backing strip in the 6G position.

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