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DiabloCanyonProject PACIFIC GAS AND ELECTRIC COMPANY BECHTEL POWER CORPORATION January 19, 1984 Denni s Kirsch - N.R.C.
Diablo Canyon Inspection Team Region V Walnut Creek, CA Attention: Sam Reynolds (N.R.C.)
Per your request, attached is a general description of the Diablo Canyon weld design program. It includes five packages of related documents as attachments.
M. E. Leppke Onsite Project Engineer Disblo Canyon
,I FEB..,
TRANSMITTED VIA FACSIMILE E 7
8708190317 870814 PDR FOIA DEVINEBA-743 PDR P O BOX 3965
- SAN FRANCISCO, CALIFORNIA 94119 e
1 WELD DESIGN PROGRAM i
This report has been prepared to summarize the veld design and installation program at Diablo Canyon.
It has been written with a view towards clarifying how each piece of the program compliments the other.
Problems are identified and corrected by a process of multiple reviews.
It 4
must be recognized that no single element of the program by itself can be considered self sufficient.
The issues which arise must, therefore, be used as feed back in future efforts to train personnel and improve the process.
The Diablo Canyon program is no exception and there is a firm commitment by the Project to improving the communication of weld design and the general understanding of each participant in the program.
The weld symbols used at Diablo Canyon have basically been consistent with standard AWS 2.4 Some configurations are difficult to symbolize and it is understandable that construction personnel might question them.
This is particularly true when modifying an As-built plant such as Diablo Canyon.
In view of this concern, welding symbols were viewed as only a part of the means of conveying weld requirements.
Any discussion of welding at Diablo Canyon must, therefore, recognize weld symbols within the context of other programs.
To date no case has come to our attention in which the weld symbols used have resulted in the installation of unacceptable welds.
The Diablo Canyon Weld Design Program includes several elements:
1.
Regular communication occurs on weld design other than weld symbols provided without comment.
2.
Ambiguous welds were discounted in design calculations.
3.
Weld design provides for substantial reserve margins.
4 Training classes have resulted in a steadily improving clarity.
Early work on the reverification program consisted of reviewing all available As-built information.
Additional inf ormation was obtained by plant walkh u.y where r( d ews indicate insufficient or inaccurate information, Weldint was include" in all reviews.
Major areas address (but not limited t( )
were:
1.
Pipe supports; designers using As-built drawings performed conservative calculations which eliminated any uncertainties in welds I
by taking no credit where doubts exist (i.
e.,
square groove welds, seal welds, ga rtic'a'1, penetration welds on lug attachments)
(Attachment No. 1).
This was done to improve engineering efficiency and allow designers to spend time on more critical elements.
]
Requests were made of the Onsite Engineering Feasibility Group to
)
provide additional information where calculations indicated that 1
these assumptions effect the acceptability of the installation in meeting revised loading (Attachment No. 2).
This information was l
supplied by weld symbols supplemented by sketches of affected areas.
Pipe support welds were found in general to not be highly stressed
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and seldom control acceptance.
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i 2.
Ccaduit supports:
.Designses wsra previdsd with -As-built drcwings
'obtained by field walkdowns.
Welds are simple 3/16" fillet welds q
with designers never taking credit for weld throat produced by the
)
small radii of struts.
These welds are not highly stressed and 1
almost never control acceptance.
3.
HVAC Supports:
Drawings by field walkdowns.
The welding in this y
area is unique to the project in that the fraction shown on partial
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penetration welds was always the effective throat.
This compares to j
the remainder of the project which provided depth of preparation.
i The welds in these supports are generally not highly stressed and seldom control acceptance.
4 Structural Steel:
Designers reviewed As-built drawings and field-conditions.
Structural steel welds are generally very simple and seldom provoked questions as to the desired welds.
Very little verification of welds was required.
5.
Equipment Mounting:
Designers reviewed installation As-builts.
Additional field information was obtained by walkdowns where doubt of i
qualification arose. Few weld issue came from this area.
6.
Rupture Restraint:
A sample of welds were field verified by NDE and checked by calculation for adequacy.
Engineering and Construction has conducted training classes and is committed to future Engineering training classes in order to improve the communication of weld symbol use and weld design (Attachment No. 3).
These classes are applicable to Design Engineers, Field Engineers, Inspectors, and Contractor personnel.
The design information provided by engineering to construction was supplemented by significant amounts of other communication.
Memos, letters and discrepancy reports are transmitted between construction and engineering on a regular basis (Attachment No. 4).
This information is used by both design engineering and construction to revise existing procedures and instructions, where nea +- ry, to standardize and clarify requirements and intent.
This ongoing pron ss serves to insure that the design intent is communicated to construction and that construction practices are communicated to engineering.
Design engineering, has also placed engineers in the field to respo, to any questions which arise (Attachment No. 5).
They are present at all time that construction work is in progress.
This assures that the designeY')s intene tw is provided to construction as well as aiding in the c
resolution ol'InstTilation difficulties.
The. process involved in communicating and implementing the designer's intent has lead to many discusions.
They are all identified and handled in the same general manner.
Identification of most points requiring interpretation occur during pre-field construction reviews, preparation of erection drawings, assembly of work traveler packages, and during construction but prior to QC acceptance. Such items are resolved by:
I 1.
Refering them to the Onsite Tolerance Clarification Group.
j 2.
Refering to Onsite Engineering Group for design change or red lining.
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,aturning to SFHO Engineering for interpretation cnd clarification.
3.
R During QC review or af ter final acceptance the process identified above may be supplemented by:
)
1.
Issue of a discrepancy report with engineering input for disposition.
2.
Issue of a discrepancy report with the PTGC welding engineer input for disposition.
Weld symbols uses which require clarification on a re-occuring bases are refered to engineering for generic clarification.
These are generally provided in formal letters issued by the Project Engineer.
The following secti,on illustrates a number of symbols used which are typical of those requiring clarification.
1.
Typical single flare bevel symbol:
No specified T noted on e
drawing implies T 'by design to be per AWS D1.1 with maximum e
T
=5/16R.
Any greater T required by design will-be stated e
e explicity.
% 2.
Flare Bevel (See comment 1.).
k.
Typical stagger'ed fillet 3
weld.
Arrow side symbol to be same size as noted for other side symbol.
Design intent is that both side symbol to be dimensioned per AWS.
4.
Single bevel groove veld.
Bevel and included angle the same.
Angle to be as per either pre qualified or specially qualified procedure.
j Any deviation outside of code essential variables if so noted to be 1
reviewed by engineer.
No included angle required to be noted unless specific requirement of design engineer.
S.
Typical square' groove butt weld.
Future design use will specify both T
required and root opening if weld has structural value.
This
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7' symbol will be used in the future to denote a " seal weld" if weld is na: structura; nr.c will be noted in the tail as such.
6.
(See comment 5.).
7.
Fillet weld on two sides both fillet weld sizes assumed same.
Field to verify.
Future per AWS both sides to be sized.
8.
Single bevel groove weld with fillet cap.
Interpretation and assumption requires design engineer clarification or construction As-builting.
9.
Fillet weld on two sides.
Intent is for fillet weld on right and left sides of shape.
Future design will arrow both sides requiring weld deposit plus length of required weld.
Also, wrap around requirement will be stated (See Attachment 2-1).
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,10.
Fillet weld for size onsize tublar steel.
Size on si(e, tubladsteel 1
one weld symbol as shown not sufficient.
Requires a filD E wel~d for i
2 sides and a flare groove type weld for other two sides.
11.
Fillet weld on 3 sides (See consent 1.).
12.
Fillet weld on 3. sides.
Symbol accepted as shown.
No need to specify "3 sides."
13.
Site engineer directive DCC 10263 and SFHo DCC 8039 Chron. 037390 (See Attachment No. 4) specified wrapping of corner when possible and in all cases the weld size and length to be noted on As-built drawing.
14.
Fillet veld on 3 sides.
Future only arrow side to be shown and only 3 sides to be welded (See comment 12.).
- 15. For SFHO engineer directive see D/;C 7688 and DCC 7524 for explanation of joint design requirements, measurement and weld symbol.
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' Task:
Allegation or Concern Nos. 103-118, 124
%g ATS No:
RV-83-A-0074 BN No:
84-009'(1/16/84) j l
Characterization:
)
Multiple. allegations associated with failure of the licensee and Pullman Power 1
Products to meet required codes and standards rules for welding pipe. supports and pipe whip restraints.
Implied Signi'icance to Design, Construction or Operation i
That the failure of the QA/QC system to meet stated codes'and standards rules is a potential safety problem.
Assessment of Safety Significance The alleger indicated violations of the QA/QC program, and " Codes and Standards" rules in the Pullman welding fabrication of pipe supports and pipe f
rupture restraints.
Review of licensee documents indicated that in the case of pipe supports, the licensee committed to requirements for fabrication in their document specification 8711 " Erecting !!ain Systems Piping and Furnishing, Fabricating, and Erecting Balance of Plant Piping (Units 1 and 2)."
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Specification 8711 indicates in Section 2, 1.17 and 1.18 that the codes and 1
standards rules to be followed are ANSI B31.1 and B31.7 for pipe supports.
For " Supplementary Steel" for pipe supports AISC 7th Edition (utilized for design) references AWS DI.1 for welding fabrication qualification, whereas B31.1 and B31.7 invokes qualification to ASME SCIX. A general statement in I
Section 3 (2.0) (" Code Requirements) indicates " design and fabrication" in acco'rdance with " applicable standards of ASTM, ANSI, ASME, MSS, AWS and PFI."
Section 3, paragraph 4.1 requires welder performance qualification testing in accordance with ASME SCIX.
Section 3, paragraph 4.12 (which stat-es the engineer's position) requires that all welding shall be performed in accordance with a procedure specification qualified in accordance with ASME SCIX.
In summary, the qualification for fabrication for pipe supports is in accordance with ASME SCIX.
In the case of pipe rupture restraints, the licensee committed in Section 2 (para) 2.1 of specification 8833XR AISC to welding in accordance with AWS D1.0 or D1.1 and commits materials in Section 2 (para) 2.1 to A36 (Group I) steel with A441 and A572 grades 42 to 50 (Group II) as approved substitutes for fabrication.
]
The alleged violations have been categorized in the following generic areas associated with welding and QA/QC activities.
(NRC staff positions are based on inspections, technical discussions with Pullman and the licensee, and review of applicable quality documents.)
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1.
Allegation 103 - Pullman used ASME SCIX procedures to weld D1.1 f
fabrications:
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A.
Pipe Supports - The alleger interprets. Specification 8711 as.
requiring welding qualification for " Supplementary Steel" designed to AISC to be~ performed in 'accordance with' AWS-D1.1.
The 8711 Specification Section 3 (para)-4.11 and 4.12 require performance and.
procedure qualification in accordance with SCIX. The welding
. qualification methods utilized by Pullman meet both SCIX and D1.1 rules. D1.1 (para) 5.2 permits the ENGINEER to " accept evidence of i
t previous qualification" and it is normal practice to interpret this as permitting ASME SCIX PQR_ qualification in lieu of D1.1 qualification by testing.
Pullman ESD 223 (para) 6.8.2.2_ preheat requirements clarify the basic Pullman WPS docuraents for welding to existing structural steel materials and meets the AWC. Table 4.2 requirements for welding Group I materials. The filler, metals called for in the Pullman WPS documents also meet the matching filler metal rules of AWS Table 4.1.1.
The combination of the preheat and matching filler metal rules would also meet these criteria for AWS D1.1 prequalified status..
The procedures for welding pipe support are adequately qualified.
(Also see Item 13)
B.
Pipe Restraints - Specification 8833XR Section 2 (para) 1.24 states that welding procedures shall be qualified in accordance with AWS D1.0-69 as D1.1-79.
The procedures utilized for welding meet the matching filler metal rules and ESD 243 (para) 9.6 preheat rules for prequalified D1.1 procedures.
The procedures have also been demonstrated by testing through ASME PQR qualification.
Pullman
1 i
PQR-AWS-13 through 20, PQR-AWS-9 through 12,-and PQR 467 further demonstrate the engineering justification for utilization of both
-Group I and Group II welding procedure specification qualification.
]
The procedures.for welding pipe restraints are adequately qualified.
2.
' Allegation Nos. 104 and'105 - Pullman welding procedure specification i
~(WPS)-documents fail to indicate the scope of weld joint configurations approved for use and indicated as sketches in the WPS documents.
j The alleger is correct in stating that the Pullman WPS documents do not adequately illustrate all generic joint types which are welded. These WPS documents are qualified in accordance with SCIX which indicates in QW 402.1 that a change in generic joint type is a non-essential variable.
Lack of all generic types of joints utilized is a violation of SCIX rules i
and requires a revision to the WPS but does not require requalification.
Some of the joints not addrersed in the WPS are addressed in Pullman ESD i
-documents (which can be considered as part of the "ASME WPS").
One of the major joint types of concern is the partial penetration welds without
'I the included angle indicated on the drawing or in the joint sketches.
Interviews with Pullman QC personnel indicated that partial penetration included angle practices by the craft personnel have produced angles equal to or greater than 45 which would conform to AWS D1.1 pre qualified rules which were used in design assumptions for effective i
throat. The adequacy of welding techniques for flare level joints is l
I addressed in PG&E mer.o Curtis to Leppke File 925 dated January 6, 1984.
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e) 3.
Allegation No. 106 - Pullman welded materials that were not listed as 1
approved for use in SCIX and/or AWS D1.1 documents and were not properly specified in~the WPS documents.
, The alleger is correct that the codes and standards are not clear or easy
'to interpret concerning some materials of construction and are only broadly covered in WPS documents. The materials in allegation were as follows:
i A.
Pipe Supports (Specification 8711) (B31.1/331.7/ASME)'
1.
SA36 (P1) 2.
A500 (P1 per Code Case N224) 3.
SA515 (P1) 4.
SA516 (P1) 5.
Bolting (A307 and A108 Grades 1010-1020) (P1)
B.
Pipe Rupture Restraints (Specification 8833XR) (AWS) l' A36 (Group I) 2.
A441 (Group II) 3.
A572 Grades 42 to 50 (Group II) 4.
A588 (Group II) 5.
A500 (Group I) 6.
A516 Grade 70 (Group II) l
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4Q ASTM A500 and A501 are. classified in ASME Code Case N224 as ASME P1.
I materials _per SCIX and are classified in AWS D1.1 in Tabla 4.1.1'as Group I materials.which are comparable to Pl.
They have carbon content i
controls that provide better weldability than some other plait. carbon steels classified as P1 materials.
9 ASTM /ASME A/SA 515 is classified as a P1 pressure vessel steel approved' for ASME Code usage, but is not listed in D1.1 because it is normally considered (and used) as a pressure vessel material not a " structural plate" material. The inspector discussed the use of A515 with Dr. Davis, I
AWS D1.1 Committee Secretary, who indicated that in his technical opinion if an inquiry was made to AWS on the inclusion of A515 it would easily receive committee approval. The weldability of A515 and A516 are essentially identical, the only significant difference being the gram ~
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size practice.
Pullman conducted PQR's to verify the engineering justification for utilizing A515 grade 70 for D1.1 fabrication.
The test I
assemblies are single sided 1" thick 45 included angle joints with i
backing welded in the IG, 2G, 3G and 4G positions and reported in Pullman PQR documents PQR-AWS-9 to 12, i
Pullman has clarified in a memo dated November 30, 1982, that A307 (indicated in Code Case N71 (1644-6) as P1) and A108 grades 1010 to 1020 l
meet P1 ASME SCIX requirements and are therefore considered qualified by PQR rules.
I i
Materials A441, A572 grades 40 to 50, and A588 are listed as AWS Group II materials and are considered prequalified for welding to DI.1 rules with
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70KSI filler metals and with preheat indicated in Table 4.2.
The Table 4.2 preheat rules are reiterated in AWS 1-1., AWS 1-3, and ESD243 i
documents.
Item 13 of this writeup also addresses Pullman PQR documentation by testing for welding the Group II materials.
4.
Allegation No. 107 - Pullman used welding technique sheets to clarify.
parameters stated in a Pullman WPS document without clearly identifying the technique sheet on all applicable process sheets for pipe rupture restraints.
i The alleger is correct that is some cases QC failed to clearly identify on the weld process sheets when welding was conducted to the WPS plus the l
welding Technique Sheets.
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.The use of welding technique sheets to clarify WPS documents is a standard industry practice.
The significant (WPS) clarification made by the welding technique sheet is the introduction of tighter controls on preheat.
As the preheat requirements are also stated in the ESD 223 and ESD 243 documents, the question of preheat is considered adequately covered. The use of preheat which is a non-mandatory requirement for ASME Code welding is considered good engineering practice.
As the preheat is covered in all cases, the inclusion of the exact document whether it is the VPS or technique sheet identification is considered to have no engineering significance.
The preheat specified in the Technique Sheets Table 4.1.1 meets D1.1 requirements for "prequalified" welding procedures Group I and II materials even though the welding procedures were also qualified "by testing" without preheat.
b 5.
Allegation No. 108 - Pullman utilized an unqualified individual who was not a member of the Pullman Engineering staff to prepare a Welding j
Technique Sheet..Incso 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.
There are no codes and standards rules that state that a WPS or welding technique sheet be written by a welding engineer. The only requirement is that the document adequately address the codes and standards variable rules. The WPS documents and welding technique sheets met the variable rules except as indicated in item 2 of this writeup and were approved by the licensee.
l 6.
Allegation No. 109 - Pullman welders qualified prior to July 10,.1979, for welding on AWS D1.0 were not qualified to this code, but rather were qualified.to ASHE SCIX.
The utilization of welders qualified to SCIX t
resulted in rejectable welds.
The alleger is correct that Pullman utilized SCIX qualifications for 1
i welders welding to AWS rules, l'
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The inspector reviewed approximately 110 records of welder performance i
qualification from the period 1974 to 1983.
The test assemblies l
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l consisted of pipe with GTAW consumable insert roots and SHAW for the 1
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remainder of the joint, and plate test assemblies with backing strips.
The pipe tests were conducted in the 2G and 5G positions and the plate tests were conducted in the 20, 3G and 40 positions.
The majority of the
(-
1.
plate tests were conducted with A515 plate, the remainder with A36 plate.
The plate thickness utilized was 1" thick which meets 3/16" to unlimited thickness qualification requirements for both AWS and ASMI. All of the test assemblies were evaluated by standard guided side bend tests.
(The weldability of A515 was also demonstrated in the performance qualification system by the guided bend tests).
The records reviewed met AWS and ASKE requirements for welding single sided plate welds with backing and doubic sided weld joints.
It is standard practice to consider SCIX qualified welders as qualified to AWS rules if the AWS thickness criteria is properly addressed.
This has been reiterated by an AWS letter reference on this subject and meets specification 8711 and 8833XR requirements. As the test assembly required for qualification for SMAW is the same for both ASME and AWS the contention that ASME identification on the qualification record contributes to field welded defects is considered to have no engineering justification.
)
7.
Allegation No. 110 - Pullman utilized welding procedures which have not been tested for notch toughness in the weld liAZ for weldments made under PG&E 8833XR when Section 3.6 requires such qualification.
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The alleger is correct that the above reference appears to require HAZ notch toughness verification.
Technical discussions with the licensee engineering personnel indicate that the design of the rupture restraints does not require PQR documents
demonstrating HAZ uotch toughness. Notcl. toughness in the weld HAZ is not a codes and standards nor a NRC requirement for rupture restraints.
The licensee position is documented in a Leppke (PG&E) to NRC memo dated January 18, 1984.
J Even though not required by the licensee's engineering staff, Pullman has
- conducted a PQR to demonstrate the weldability of A588 (AWS Group II) and has conducted a materials engineering evaluation to compare the weldability of A588 with other AWS Group II materials utilized for pipe upture testraints.
The relative weldability evaluation based on carbon equivalent calculations indicates that the other Group I and Group II materials utilized have weldability superior to A588.
Pullman relates this weldability determination to the ability of the procedure to produce i
adequate toughness in the weld HAZ. The PQR test assembly welded in the
'3G pcsition demonstrated that the toughness of the HA'; in the as welded condition exceeded that of the unaffected base metal by having an average of 70 ft-lbs at -10F and exceeds the requirements of 8833ER Section 2
)
(para) 3.6.
This data is reported in Pullman memo - Neary (Pullman) to Arnold (PG&E) dated January 11, 1984.
i S.
Allegation No. 111 - Pullman utilized WPS 88/89 which was qualified to ASME SCIX for AWS D1.1 welding when GTAW is not covered in D1.1.
The alleger is correct that the GTAW process is not covered in the body of the AWS DI.1 document as it is not applicable to welding in the open
[(
where breezes affect gas shielding. AWS D1.1 (para) 1.3.4 and 5.2 permits qualification of "other processes" and " evidence of previous
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qualification" of joint procedure qualification. The use of single sided open. butt welds.with GTAW ASME SCIX (para) QW322 states:
Root passes with and without back purge are demonstrated in Pullman PQR test numbers ML7-63, ML7-64 and 57233-6-3. The use of a standard practice for welding Class 1 piping is considered satisfactory for supports and restraints. The licensee position on this subject is indicated in a Kerr (PG&E) to NRC memo dated January 16, 1984.
9.
Allegation No. 112 - Pullman welder stencil N was-not qualified to conduct welding because the welders' log records can not prove he conducted welding'during the period August 1972 to December 1972.
The alleger is correct that deficiencies in the adequate maintenance of the welders' logs existed during toe period noted. AWS D1.1 (para) 5.30 states that a welder's qualification is considered to remain indefinitely l
unless the welder is not engaged in a given process for a period exceeding six months.
(The term process applies to the generic types of process e.g., SMAW, GTAW, GMAW, etc.)
ASME SCIX (para)-QW322 states:
The performance qualifications of a welder shall be affected under the I
following conditions:
(a) when he has not welded with a process during a period of three months or more, his qualifications for that process shall be
b 4
expired; except when-he is welding with another process, the.
period may be extended to six months; (b) when he has not welded with any process during a period of three months, all his qualifications shall be expired including
'any which may extend beyond turee months by virtue of (a) above; The method of providing evidence of welding is not stated, and no explicit method is required to meet' codes and standards rules.
There is evidence (e.g., filler metal issue slips, welding process sheets, etc) that welder N met the above codes and standards requirements as determined by methods other than the welder's log, therefore, maintaining his qualification.
- 10.. Allegation No. 113 - The alleger indicated a deficiency in the pipe rupture restaint welding resulted in serious weld cracking problems.
The alleger is correct that the licensee had experienced cracking problems in the welding of pipe restraints. The alleger questioned the licensee's actions.related to this pipe restraint weld cracking problems.
The licensee reported the cracking problem to the NRC in a letter to the Director I&E Region V on May 3,1979, as a reportable 50.55(e).
Region V Inspection Reports 50-275/323/79-07, 79-13, 79-17, 79-22, 79-26, 80-02, and 81-04 (close out) discuss the licensee's response to the cracking problem.
The licensee submitted a final 50.55(e) report to Region V on this subject on December 9, 1980.
e 11.
Allegation Nos. 114 and 115 - The alleger indicated the alleged unacceptability of square groove welds for pipe supports and pipe restraints.
The alleger is correct that the welding of square groove welds without indicating the joint type in the WPS is a violation of a non-essential variable rule of SCIX (QW 402.1), however, this does not require requalification.
Pullman has conducted PQR tests using standard welding parameters for welding P1 (AWS Group II) materials to further verify the engineering justification of square groove welds. The Pullman PQR's covers the welding of 1" thick plate test assemblies (single sided'with backing) with 1-9/16" and 7/8" butt spacing in the 1G, 2G, 3G, and 4G positions for application to AWS 1-1, WPS 7/8, and other applicable ASME and AWS procedural documents. The Pullman documents are identified as PQR-AWS-13 to 20.
The documents meet ASME and AWS requirements.
I The square groove qualification question raised in Unscheduled audit 32 (10/82) AAR5, is discussed in (Design Problem) DP-2-506-C (1/10/83),
(Discrepancy Report) DR4900 and DR4899 (2/17/83), (Design Change)
DC-1-EC-9679R1 (3/28/83), Plant Modification Safety Evaluation Summary
" Change in connection detail" DC-1-EC-9679R1 (4/13/83), (Design Change)
DC-2-GC-12046 (4/26/83), Gisclon (PG&E) Memo 420.5 (5/19/83), and Minor Variation Reports MVR-4414-R2 (5/20/83) and MVR-4413-R1 (5/31/83). The MVR's have not been completed (thru QA) as of 1/19/83.
The alleger's concern is that the square groove weld does not conform to AWS D1.1 prequalified joint designations B-Lla, for single sided square
groove welds, however, C-Lla is similar to the square grooves welded by Pullman although it is. corner joint.
In accordance with AWS D1.1 (para) 5.2 rules for consideration of SCIX qualifications, the Pullman PQR's could have been considered applicable but no such licensee claim was made. As previously stated Pullman PQR's AWS-13 through 20 (11/9/83) indicate the engineering justification for square groove welds in the
' range of applicable root openings and thicknesses welded.
Final licensee resolution is withheld pending completion of the DR's with the MVR document, however, the PQR's adequately qualify the welding by testing.
- 12. ' Allegation No. 116 - The alleger questioned the generic qualification of Pullman WPS documents for ASME and/or AWS D1.1 welding.
I Although the allegation is correct in many cases about QC paperwork errors and in some cases correct about substitution of one welding process and/or WPS document for another without sufficient changes to QC paper work, technical reviews indicate compatible welding processes were employed in all cases.
Review of Pullman PQR documentation for engineering justification of velding in accordance with current ASME SCIX rules and AWS D1.1 (through j
utilization of the ENGINEER'S prerogatives in paragraph 5.2) indicates the following scope of qualification which can be applied to various applicable WPS documents: (this review includes only PQR's for as welded fabrication.
All PQR's were qualified without preheat i.e., 50-60 F.
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j All employ.70KSI carbon steel filler metals'except for P8 materials which 1
f utilized ER308 and/or E308-16 filler metals.
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Review of the Pullman PQR's permit the following welding (per Codes and i
Standards rules).
Welding ASME P1 materials to themselves with the SMAW process with 1.
single sided joints with backing, double sided joints, and open butt joints in thicknesses from 1/16" to 2.0."
Welding AWS Group I materials to themselves (SHAW) as above (1).
2, Welding AWS Group II materials to themselves (SMAW) and to Group I 3.
materials as above except thickness range 3/16" - 2."
Welding SA500, A441, and A588 to meet ASME SCIX requirements 3/16" 4.
to 2" with the SMAW process as above (1).
Welding ASME P1 and AWS Group I materials using the GTAW process in 5.
open roots with or without gas backing and for deposited metal
-thickness ranges to 0.436."
i A memo from Karner (Pullman) to Arnold (PG&E) dated 1/16/84, 6.
indicates that Pullman has engineering justification for GTAW AWS Group II materials with open butt joint designs, however, the PQR was not available for review at the time of this writing.
1 7.
Welding ASME P8. materials to themselves with the SMAW process on backing (single sided or double sided) from 3/16" to 1.4."
i 8.
Welding'ASME P8 materials to themselves'with the GTAW process with consumable inserts or on backing _(metal') from 1/16" to 0.56."
I 9.
Welding ASME P8 materials to themselves with ths GTAW process or an 1
open root with backing gas from 1/16" to 0.56."
l The above procedures also qualify for tack welding with SMAW or GTAW for all materials with applicable compatible filler metals.
The following PQR's were reviewed:
(indicated by explicit PQR identification number or by PQR Laboratory Test Number): ML9-39(2),
ML7-63, ML7-64, 57233-6-3, 71-35-9, ML71-55, ML71-30, 71-35-3, ML7-71, l
PQR2749, PQR2748(2), PQR467-S3-BR-2, PQR-AWS-13 to 20, and PQR-AWS-9 to 12.
I Materials' utilized in the PQR test assemblies reviewed include:
a.
(ASME P1)-SA106B, SA515, SA516, b.
(AWS Group I)-A106B, c.
(AWS Group II)-A516GR70, A588, A441 d.
(ASME P8)-SA312GR304 l
i e
A summary of the qualification ranges defined by Pullman is reported in i
Specification Change Notice No. 2 to ESD 227 dated June 17, 1976, which was approved by the Pullman QA Manager and the PG&E Engineer.
3.
Allegation No. 117 - The alleger questioned the application of the SMAW I
process utilizing copper chill bars for plug welding of mis-drilled i
holes. The alleger stated that copper is not considered as a weldable material for the process employed.
The alleger is correct in stating that copper chill bar techniques we're utilized for plug welding mis-drilled holes and that copper is not considered a weldable material for the process employed.
Review of the application of the technique indicates its use was very limited.
Pullman addressed this subject in a memo from Neary and Karner (Pullman) to Arnold (PG&E) dated January 11, 1984.
Pullman indicated (correctly) that this is not an unusual technique for plug welding and is discussed in Chapter 24 of the AWS Handbook. Review of rec.ords indicates that the root side of welds were visually examined and examined by MT methods.
Fissuring, when observed, was repaired.
It is not uncommon for this technique to produce some fissuring in the root passes due to exceeding the alpha solid solubility limits thus producing a low meeting hot short grain boundary constituent resulting in fissuring.
As the root sides of the holes were repaired where required and the design requirements for the soundness of the plug weld area is minimal, this is not considered a safety problem.
l l
l l
l l
'I 14.
Allegation No. 118 - ESD 243 (Pipe Rupture Restraints) paragraph 2.8 q
l requires welder qualification in accordance with AWS D1.0-69.
A " Note" was added contradicting this requirement. This " Note" which represents a i
deviation from Spec. 8833XR may not have received proper review and i
I approval by PG&E.
l
. The inspector reviewed PG&E NCR No. N002 which documents that Pullman had not qualified their welders to AWS D1.1 for structural steel welding as required by Spec. 8833XR. This NCR was initiated on June 10, 1983.
ESD 243, from Octover 15,.1974 to June 9, 1981, in para 2.8.1 required all welders to be qualified in accordance with AWS D1.0-69.
However, a
" Note" was added allowing for welder qualifications in accordance with ASME Section IX in lieu of AWS D1.0-69.
Authorization for this " Note" was initiated on October 18, 1982, on a PG&E memorandum from W. R. Hersey (Site Project Superintendent) and M. R. Tresler (Site Mechanical Resident Engineer) to M. H. Chandler (Manager Site Construction) and R. S. Bain (Construction Superintendent) of the PG&E San Francisco Engineering Office. This was subsequently approved by A. Wather (Senior Mechanical Engineer, PG&E). This memorandum allows field welding and inspection to Spec. 8833XR with the exception that welder and weld procedure qualification will be in accordance with Spec. 8711 which requires ASME performance qualification test.
This memorandum is documentary evidence of compliance with AWS D1.0-69 and later editions that allow the Building l
Commissioner or Engineer (PG&E) to accept evidence of previous qualifications of welders qualified in accordance with ASME Section IX.
The alleged concern was that welder's qualified to ASME IX instead of the AWS Code contributed to the cause of rejectable welds identified in PG&E
-4 a
e
\\
i nonconformance reports; this is not true as explained in alleged concern
{
number 7.
This item has no safety significance.
15.
Allegation No. 124 - ESD 261 internal audit procedure requirement for a 10 day response time to the audit findings were not being met.
l
'This allegation is true. Prior to September 1, 1983, the' majority of audit findings were not responded to within the 10 day requirement.
The inspector reviewed Pullman procedure ESD 263 entitled " Internal Auditing Procedure of Field QA Program by Field Staff." This procedure is used by the Pullman internal auditor for auditing of the quality assurance program implementation for erection of piping hanger and rupture restraints. The two audits described in this allegation, scheduled audit 32 and unscheduled audit 35, were examined for compliance to ESD 263.
Scheduled audits involved the preparation and approval of audit checklist, pre-audit and post-audit conferences and the reporting of findings on an Audit Action Request (AAR).
The unscheduled audit is an informal audit requested by management, supervisor, or by the internal auditor; checklist and preaudit conference is not required.
Prior to September 1, 1983, ESD 263, para. 10.1 required that AAR's be responded to within the (10) calendar days after receipt of report. On September 1, 1983, ESD 263 was revised to provide an extension of the 10 day requirement if justified and approved by the ( A/QC manager or the internal auditor.
This activity is documented on the AAR Due List L
- =
4 (Appendix E). :The effectiveness of the implementation of the current revision was examined by the inspector'and found to be satisfactory.
' Audits 32 and 35' violated this 10 day response time requirement, with no evidence of'a request for extension in the documentation package.
When questioned by the inspector, the QA/QC manager agreed that the 10 day requirement had not been met, for the following reasons: (1) the QA/QC department was understaffed in most of 198'3 (approximately 50 personnel in 1983 compared to 200 today) and (2) the magnitude of the audit findings required vast amount of research and verification. This problem.
was identified and documented as a result of a Pullman Corporate Audit conducted January 10-10, 1983.
The corrective action reply addressing the magnitude of the audit finding is documented in Pullman interoffice correspondence from H. W. Karner (Site QA/QC Manager) to A. A. Eck (Corporate QA Director, Williamsport, PA) of April 8, 1983.
l Even though this item has no safety significance, it does represent the l
lack of proper management control by the Pullman QA/QC department to implement the requirement of ESD 263.
I
- Staff Position
)
Review and follow-up of this allegation has resulted in the following inspector conclusions on the licensee's actions in the design and fabrication i
of pipe supports and rupture restraints.
1, 1.
In the case of pipe supports, the licensee did not writ'e.an explicit design document for pipe supports and, therefore, permitted confusion
-between those requirements which applied to various classes of pressure boundry piping and those requirements that applied to supports of this piping.
- 2. " The licensee did not clearly identify the various quality classes of pipe supports which resulted'in requirements far exceeding codes and standards requirements for some of those supports that.are not associated with Class 1 piping.
This causes confusion in answering questions where the
- 4 l
1 answers are based on an engineering understanding of lesser requirements, where these answers appear to be in conflict with the " classless" basic specification do~cument.
1 3.
The' licensee specifications included broad sweeping " motherhood" statements (e.g., 8711 Section 3 (para) 2.1) which appear to commit to many codes and standards rules without clearly designating in the document how these apply. This results in confusion in interpretations of quality and engineering rules.
(e.g., All piping...shall be designed and fabricated to comply with...and applicable standards of ASTM, ANSI, ASME, etc.).
4.
The licensee's acceptance of Pullman welding programs which are designed to address pipe welding and are clearly not explicit to piping supports and pipe restraints introduced confusion into the qualification, fabrication and inspection operations.
l l
I
e 5.
The licensee did not clearly and explicitly indicate in the engineering of pipe support specification the relationship of the design-considerations of AISC, the utilization of the prequalified joint design assumptions of D1.1 (i.e., effective' throat penalties) and how the D1.1 prequalified welding rules do not apply to the welding when other parts s
of D1.1 are used in design.
6.
The licensee did not establish and disseminate to design, fabrication and QC a manageable PG&E welding symbol matrix system at the time when the decision was made not to commit to standard AWS A2.4 symbology.
r 7.
The licensee failed to develop clearly defined generic site-wide
" positions" in areas where a sufficient number small items indicated a potential generic problem, e.g., (1) the substitution of one welding WPS or welding process with another one of equal quality where qualification data (PQR's) could have been handled with a generic matrix document and generic answer referenced where applicable and where required, (2) the repeated welding symbol interpretation question required a generic site answer (which is currently'in preparation).
/
8.
The lack of sufficient licensee welding engineering personnel available to review contractor's welding documents, initiate necessary licensee documents and recognize areas of fabrication requiring special attention or supervision resulted in problems such as the pipe rupture restraint cracking and utilization of materials of fabrication not clearly covered by welding documents.
The lack of sufficient site welding engineering
personnel also applies to Pullman (and although not addressed in this allegation applies to Foley).
These comments may indicate the licensee's lack of engineering " common sense" in welding related areas, but based on investigation of these allegations do not represent a failure of the " hardware" to comply to minimum codes and standards rules. These comments indicate a weakness of the licensee's system to explicitly indicate some requirements related to welding and to clarify I
apparent disparate references in specifications. The engineering significance of the stated allegations indicate that no safety problems have been i
identified.
1 s
Action Required Ch' i
Request a study be performed not the staff position concerns, specifically focusing on the management involvement and control-over the work performed at Diablo Canyon.
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A Purpose ofl' c;#eport E...Qualificntien and Verif4. cation of Tlare-Bevel Grtieve gg f a t.,, e
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.a g h. f' $ a til i U.j k.. t k>&;:al.9*::%},GMAk.f.p%; ? G.u.
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Ptir eseh;IT[vapif['te4$(e minimueb that 'the ef fective throat thicknent
$?.f.;feFF.114 elegrbove. veld /khen filled to che seli6 se': tier, l
)W;T}M,'b.k"., ef; thi' barf kfliSbe" equal' 3/16' R. where lis equal to
.ofitht bare.b 'A M.'s O
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Haterials N tuNuiay leeel'sises 3" x 3" x %"l 4" k'4" x 3/8",
6" x 6" m%dA '. xY.N and, 87. M. 8",' x.:.",',, ' ' ASni A300 was used,
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g',elding,,FreceM-Thy shieldN metal' are veJ dinr prorets we ua.ed, utj-i g:W i.b.0,v 11sinscSTA!5.loE70.lSyalectrodes with multipfc. passes, W.
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.s Preceduras fkr; Shielded Hetal-Are t The'veldirts was,done in th'e vortical.
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i travel.
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-... :....e p i}'pg,$pationM'The. AaSlesTitre sectioned'for visuaI examination.
ualifi Thh %e'1'de werePfree from.cpacks pnd there was thorough fusien i,..as[ N..M The' walds 'in.generaldwere visunfly 'seceptable.th' between adjacent 1&yers of y h!, 'C(W M e a t ? y h M,, $nn:.% g. ".t e m.? '.
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- f,In' general d../32Ly G~ electrodes showed good penetration er.-
Why eseding the %knifouk throat ' thickness by approximat;cly 501 i-M.h PL except'therF W rf somb probJems with the 3" x 7" x'k" tubes.
j.y;.,h'h The heali tidiuf did'iot permit the depth' of penetration.
lQ The 1/8"'M'41e ttedes showed excellent penetration for exceedinj:
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L g',M.. W"/M.',,It' isitetemmendedthat the.contirectors be directed to utilize
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