ML20237K868
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nevision No.
4 Date:
6-07-7f Page:
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PACIFIC-GAS AND ELECTRIC' COMPANY ST AT10M'CCNSTRUCT10'; DEP ARTMENT DIAELO CANYO" PROJECT l
DIABLO CANYON RUPTURE RESTRAINT GENERAL REPAIR PROCEDURE _
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This procedure outlines the requirements for weld repairing of the defective' All welding repairs shall be made in.accordance with rupture restraints.
i' AWS'D1.1-79, Structural Weldina Code - Steel.
' 2.,0 BASE MATERIAL The Base Material shall conform to any one, or any combination, of the following:
1 ASTM A-36, A-441, A-572, A-515, A-516 and A-588.
For shapes, A-515 shall not be used.
3.0 FILLER METAL
' The Filler Metal shall conform to ASME Filler Metal Specification SFA 5.1, Type i
E-7018.
4.0 POSITION Welding shall be done in all positions.
5.0 PREHEAT AND INTERPASS TEMPERATURE The minimum The minimum preheat temperature shall be cs specified below.
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interpass temperature shall be the minimum specified preheat temperature, 5.1 and the maximum interpass and preheat temperature shall be 800 F.
Metal Thickness Temperature 50*F*
Up to 3/4" Over 3/4" through 1-1/2" 150 F i
Over 1-1/2" through 2-1/2" 225 F 300 F Over 2-1/2" The specified preheat and interpass temperature shall be mainteir.ed un-il Suitable preheat equipment and/or personnel 5.2 the completion of each weld.
shall be provided to assure compliance with requirements dtring periods of inact,i vity.
G708190433 870814 PDR FOIA PDR
'DEVINEB4-743
" Plates toLbe flame dried when below 70 F.
'0iablo Canyon Rupture Restraint'
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Procedure fio.
8322Xn-1 General P.epair P.rocedure Page:
2 of 3
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6.0 POST UELD )? EAT TREATME"T i
The ccmpleted. elds shall not be given a post weld heat treatment.
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- 7. 0 WELDING PROCESS All welding shall be done with the T,anual shielded metal arc welding process.
I 8.0 PREPARATION OF BASE METAL OR CAVITY FOR WELDING
/k 8.1 The edges or surface of the parts to be repaired shall be prepared by flame cutting, air are gouging, machining, drilling, grinding or any combination of these methods.
B.2 All flame cutting and art gouging of weld preparations shall be performed using the preheat temperatur. specified for welaing.
t 8.3 All flame cut and/or air are gouged surfaces shall be ground to bright metal.
k 8.4 After surface preparation, all repair areas shall be magnetic particle '
examined using Department of Engineering Research Procedure No. 3212,
" Magnetic Particle Examination of Welds in Pipe Rupture Restraints."
9.0
_ ELECTRICAL CHARACTERISTICS
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The current used shall be DC Reverse Polarity.
10.0 WELDING TECHN100E 10.1 A Welding Technique Sheet shall be prepared for each repair.
The Technique Sheet shall be submitted to P G and E for approval and shall include, as a minimum, the following information:
10.1.1 The configuration of the repair cavity or groove.
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The sequence of welding, including the electride sizes 10.1.2 to be used, along with the voltage and amperage to be i
used with each electrode size.
Extra care is required to sequence all weld repairs so that residual stresses and distortion are minimized.
Coped corner holes are not to be filled with weld metal.
10.1.3 The preheat requirements for the repair.
10.1.4 Peening requirements, if desired.
10.1.5 All special instructions concerning cleaning, weaving, or appearance of the weld.
i Procedure No.
63;Jxx-1 D.iab]p Canyon Rupture d..craint Page:
3 of 3 q
f General Repair Procedure i
10.0
\\ ELDIpG TECHN10VE - Continued i
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10.1 (ccrItinued) 10.1.6 The Nondestructive Test requirements for the repair.
Revision to the Technique Sheets shall be made only witN the approval i
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of P G and E.
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s-fi,11.0 NONDESTRUCTIVE TESTING The completed weld repairs are to be nondestructively examined in accordance The required with the requirements o'f Engineering Specification 8833XR.
examinations shall be performed at least 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> after completion of all full penetration and partial penetration welds which.'are thicker than 1/2 inch.
The examination of other welds may take place at anj time after completion of the weld.
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NUCLEAR REGULATO:4Y COMMisslON e
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94505 May 7
Docket Nos. 50-275 50-323
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77 Beale Street
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i Attention:
Mr.PhilipA. Crane,b.
l Assistant General Counsel l
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Subject:
NRC Inspection of Diablo Canyon Uni i
and This refers to the inspection conducted by Messrs T. W. Hutson, D. P. Haist and G. Hernandez of this offi
. D. F. Kirsch, 29, and April 5-6, 1979 Permit Nos. CPPR-39 and CPPR-69of activities authorized'by NRC Cce on March 2 construction your staff at the conclusion of the inspection. held i
er members of Areas examined during this inspection are described i l
inspection report.
I Within these areas n the enclosed i
terviews with personnel, and observations by the 4
s, in-pectors.
the scope of this inspection.No items of noncompliance with N) entified within t
Part 2. Title 10, Code of Federal RegulationsIn accor ractice,"
Document Room.the enclosed inspection report will be placed in th, a c to be proprietary, it is necessary that you submit aIf this re h
e NRC's Public to this office, within 20 days of the date of this lettwritten application
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that such information be withheld from public discl
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er, requesting must include a full statement of the reasons why it is clai osure.
information is proprietary.
The application med that the The application should be prepared so that L
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Review of Quality Records i'e' c.
The inspector examincd a licensee QC audit of1CUC weldE [ '
l performance qualification documentation and the~welde'r/qualifi-cxaminedforcompliancewiththelicensce'sQApr,tems$erc cation records of the three CUC welders. Thes'!i e
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No items of noncompliance or deviations were identified.
10.
Punch List _.
The inspector examined the licensee's punch list of remaining work items to be completed on Unit 1.
The punch list contained 194 items.
The licensee's General Construction organization publishes a weekly letter identifying incomplete work items which are reviewed by corporate project engineering personnel.
The corporate project engineering department publishes a listing of f
open design and construction items on a monthly frequency and plans to increase the frequency to bi-weekly.
The licensee stated that controls necessary to demonstrate and assure the completion of all necessary safety-related construction /
modification work activities, nonconformance and minor variation reports, punch list items, and design engineering activities would be formulated.
These controls will be examined during a subsequent inspection (275/79-07-03).
11.
Nonconformance and Minor Reports The licensce's nonconformance reporting system was examined for compliance with the QA program requirements.
Licensee records indicated that 11 NCR's and 115 MVRs remained to be closed out.
The inspector examined NCR's in the disciplines of civil (Nos. 78-RC-001 through 008), mechanical (Nos. 78-RM-001 through 009 and 79-RM-001 through 005), and electrical (Nos. 78-RE-001 through 010 and 79-RE-001 through 005).
NCR No. DCl-7b-RM-006 documented weld cracking problems observed on heavy weldments in highly restrained beams on the Unit 1 pipeway structure outside of containment.
The licensee had identified 78 cracked welds and was in the process of evaluating the situation and determining necessary corrective actions. The Unit 2 pipeway was being inspected by the licensee 9 determine if similar problems exist.
On March 4,1979, the licent 9 e informed Region V that this item was considered reportable under the requirements of 10 CFR 50.55(e) and that the required written report would he submitted.
The resolution of the NCRs examined appeared to conform to the licensee's QA program requirements.
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No items of noncompliance or deviations were identified.
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'1 Docket Nos. 50-275 50-323
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Attention:
Mr. Philip A. Crane, Jr.
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i Assistant General Counsel
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Gentlemen:
Subject:
NRC Inspection of Diablo Canyon Units 1 and 2 This refers to the inspection conducted by Mr. D. F. Kirsch of this office on July 23-26, 1979 of activities authorized by NRC Construction Permit Nos. CPPR-39 and CPPR-69, and to the discussion of our findings held by Mr. Kirsch with Mr. R. D. Etzler and other members of your staff I
- at the conc 1psion of the inspection.
Areas examined during this inspection are' described in the enclosed inspection report. Within these areas, the inspection cor.sisted of selective examinations of procedurer and representative records, inter-views with personnel, and observations by the inspector.
Based on the results of this inspection, it appears that one of your
,, i activities was not conducted in full compliance with NRC requirements, as set forth in the Notice of Violations, enclosed herewith as Appendix A.
l This item of noncompliance has been cate9erized into a level as described in our correspondence to all NRC licensees dated December 31, 1974.
This notice is sent to you pursuant to the provisions of Section 2.201, l
of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.
Section 2.201 requires you to submit to this office, j
within thirty (30) days of your receipt of this notice, a written state-ment or explanation in reply including -(l) corrective steps which have been taken by you and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full l
compliance will be achieved.
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10 pen) (275/79-13-01) '55.55(e) I tem:
Cracks in rupture restraint weldments.
(1) Examination of Program and Procedures The licensee conducted an investigation program to determine those types of materials and joints affected by identified deficiency and determined that the problem was associated with A-441 and A-572 grade 50 steel (high strength, lo,-; alloy steels). The program was recently
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expanded to include shop welds as well as field welds.
An examination of A36 steel welding (about 300 welds) had been conducted and, at most, only two indications had r
been found by the magnetic particle (MT) process (exam-ination by MT was in excess of AWS 0 1.1-79 requirements).
These indications were repaired by a minimal amount of r
grinding.
The inspector examined the following Kellogg and licensee procedures for compliance with Q.A. program and AWS D 1.1-79 requirements.
(a)
PG&E Department of Engineering Research Procedure No. 3212: Magnetic Particle Examination of Welds in Pipe Psupture Restraints (b)
Kellogg. Procedure No. ESD-243:
Pipe Rupture Restraints (c)
Kellogg Procedure No. ESD-273:
Q.A. Final Walkdown and Documentation Review - Rupture Restraints (d)
Kellogg Q.A. Instruction No. 142: AWS Welding Preheat and Interpass Temperatures (e)
Kellogg Q. A. Instruction No.143: NDE Requirements -
Struttural Velding N,o items of noncompliance or deviations were identified.
(2) Observations of Work and Work _ Activities The inspector examined the folloviing work activities for compliance with AWS D 1.1-79 and procedural requirements.
(a) Twenty field repair welds on Unit 1 restraint bent 4B.
(b) Ten field repair welds on Unit 1 restraint bent 6B.
(c) Three field repair welds on Unit 1 restraint 1000-126.
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Preheat operations and conditions on one field weld
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of restraint bent 6B and one field weld of restraint bent 9.
(e) Magnetic particle testing on 'one. field weld of restraint bent 4B.
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(f) Three portable rod ovens.for content correspondence to rod issue. slips and temp'erature requirements.
The licensee's specification Mo 8833XR-1 -(Diablo Canyon l
Rupture Restraint General Rebair Procedure) requires that repairs conform to AWS 0 1.1-79 (Structural Welding Code).
Pullman Kellogg Procedure ESD-243 and AWS D 1.1 require that " Arc strikes outside the area of permanent welds should be avoided on any base metal.
Cracks or blemishes resulting from arc strikes shall be ground to a smooth contour and checked to insure soundness.",
j wy Contrary to the above requirements, the following conditions GL were observed on July 24, 1979:
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k*W (a) Six single spot arc strikes and one arc strike about 3/4-inch long existed on base metal below FW-63 of Lf"*3 the upper box on restraint bent 48.
This field ' weld l
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was inspected and accepted by Kellogg on July 17, 1979.
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$.. s Ir d (b) metal near FW-65 of the lower box of restraint bent One arc strike about 3/4-inch long existed on base t-6.. c#(;.. @W.m= 48.
This field weld was inspected and accepted by r='t Kellogg on July 16, 1979.
(c) One arc strike about 3/4-inch long existed on base metal of a steel member above FW-78 of restraint bent 6B.
This field weld was inspected and accepted p 7.:
by Kellogg on July 4,1979.
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("3T.Q (d) Two arc strikes existed in. base metal above FW-84 on 1
p-M the lower box of restraint bent 6B.
This field weld was inspected and accepted by Kellogg on July 9, i
1979.
This is an item of noncompliance (275/79-17-01).
(3) Review of Quality Records
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1 The following quality records were examined by the inspector l
for compliance with AWS D 1.1-79 and procedural requirements:
(a) flumerous field process sheets associated with repair welds on restraint bents 4B and 68.
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1990 N. CAllFORNIA BOUL EVARO
,e SUITE 202, WALNUT CREE K PLAZA e,,,e WALNUT CREEK, CALIFORNIA 94596 EC
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' 20V ambmg Docket Nos. 50-275
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7 Attention: Mr. Philip A. Crane, Jr.
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Assistant General Counsel l
Gentlemen:
Subject:
NRC Inspection at Diablo Canyon Units 1 and 2 This refers to the inspection conducted by Messrs. D. F. Kirsch, D., P.
Haist and G. Hernandez of this office on October 23-26, 1979 of activities authorized by NRC Construction Permit Nos. CPPR-39 and CPPR-69, and to the discussion of our findings held with Mr. R. D. Etzler and other members of your staff at the conclusion of the inspection.
Areas examined during this inspection are described in the enclosed inspec-tion report.
Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
During this inspection it was found that one of your activities appeared to deviate from one of your commitments in the FSAR. This item and reference to the specific comitment are listed in Appendix A to this letter.
Please submit to this office, within 30 days of your receipt of this notice, your written comments concerning this item, a description of any steps that have been or will be taken to correct the deviation, and the date all corrective actions were or will be completed.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you believe to be proprietary, it is necessary that you submit a written application to this office, within (30) days of the date of this letter, requesting that such information be withheld from public disclosure.
The application must include a full state-ment of the reasons why it is claimed that the information is proprietary.
The application should be prepared so that any proprietary information i
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excess reinforcement of between 3/32. inch and 1/8 inch was observed to be a total of approximately 18 inches ~in length on a 6 foot long seam. On the top head to shell interior weld the same excess reinforcement was observed to be a total of approximately
.c 3 inches in length on a 20 foot long seam.
Both Unit 1 and i
Unit 2 tanks exhibited these conditions.
The Unit No. I and 2 VCT were constructed to the ASf!E Code Section III as Class C tanks.
Westinghouse Fabrication Drawing No.110F213 S.H. I specifies radiography in accordance with s
p(aragraph UW-51 of ASNE Code Section VIII.1968), paragraph
'j ASME Section VIII of joints to be radiographer may not exceed 1/16-inch for the reinforcement thickness of the VCT's.
Full radiography is required on VCT tank seams.
The inspector examined Westinghouse Ouality Control Releases QCR No. 5464 (Unit 1) and OCR No. 5688 (Unit 2) which indicate acceptability of RT film, records and visual inspections.
The excess reinforcement identified on the Units 1 and 2 Volume Control tanks appears to be a deviation from committment.
(50-275/79-22-01and50-361/79-12-02).
5.
Licensee Action on 50.55(e) Items (0 pen) (275/79-13-01 and IE Inspection Reoort 50-275/79-07) Cracks in rupture restraint weldments.
(1) General The licensee stated that they had in'stituted and completed an expanded program to evaluate every full penetration field weld on the Unit 1 pipeway by magnetic particle examination to establish the adequacy of their program for joint identification and repair. A sample of shop welds had been selected for exam-s ination to form a data base to establish the adecuacy of the originally specified inspection program applied by the vendor of the structural steel.
The results-of the shop weld examination program will be examined during a future inspection.
The licensee had begun an evaluation of the Unit 2 heavy section, highly restrained joints in the turbine building and pipeway.
The Unit 2 evaluation and repair efforts will be examined during a future inspection.
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'(2) Observation of Work and Work Activities The inspector visually examined about 150 completed or in-process repair welds on the following Unit I restraints in the' turbine building and pipeway:
Nos. 124, 125, 126 and 159; Bents 28, 3, 4, 6B and 9; and two pipe restraints in the Unit 1 betieen auxiliary and turbine buildings.
The welding appeared to conform to AWS D1.1 and procedural requirements.
No items of noncompliance or deviations were identified.
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(3) Review of Quality Records The inspector examined the following ouality records, as appli-t cable, associated with restraint 124 (welds 10A, B, C,17C) and examination rec (welds 9Aords, ulfras,onic examin,ation rec)o:rds,gnetifielkproj restraint 125 B C and 10A B and C ma particle sheets for grinding and/or repair, preheat and interpass temperature, I
base metal repair records, and "as-built" documentation.
The quality l
records appeared to conform to AWS 01.1 and procedural requirements.
No items of noncompliance or. deviations were identified.
6.
Pioe Supports and Restraints - Observation of Work The inspector randomly selected twelve Unit 2 pipe supports and re-straints and visually examined their installations for conformance with drawing requirements.
The selected design Class I support /
restraint types and drawing numbers are listed below:
i Support / Restraint Tyoe Drawing No.
J Mechanical Snubber 051398 SH.29 Mechanical Snubber 051398 SH.14 Mechanical Snubber 051394 SH.45 i
Rigid multiple support 051368 SH.13 Rigid multiple support 051348 SH.137 Spring hanger 051359 SH.110 Spring hanger 051358 SH.15 Rigid hanger 051359 SH.142
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Rigid hanger 051368 SH.10 Rigid support 051359 SH.7A Rigid support 051359 SH.113 Rigid support 051357 SH.124 All supports and restraints examined appeared to be irstalled in con-formance with the applicable drawing. No items of noncompliance or deviations were identified.
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UNITED STATES 4
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p SUITE 202, WALNUT CREEK PLAZ A e,,,a WALNUT CRE E K, CALIFORNIA 94596
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- h' Pacific Gas and Electric Company DitzUM 77 Beale Street San Francisco, California 94106 Attention: Mr. Philip A. Crane Assistant General Counsel Gentlemen:
Subject:
NRC Inspection at Diablo Canyon Units 1 and 2 This refers to the inspection conducted by Messrs. D. F. Kirsch and P. J.
Morrill of this office on February 11-14 and 20,1980 of activities auth-orized by NRC Construction Permit Nos. CPPR-39 and CPPR-69, and to the dis-cussions of our findings held with Mr. R. D. Etzler and other members of your staff at the conclusion of each inspection period.
l Areas examined during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, inter-views with personnel, and observations by the inspector.
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No items of noncompliance with NRC requirements were identified within the j
scope of this inspection.
i In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, J
Title 10, Code of Federal Regulations, a copy of this letter and the enclosed 1
inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you believe to be proprieury, it is necessary that you submit a written application to this office, within i
20 days of the date of this letter, requesting that such information be withheld from public disclosure.
The application must include a full state-ment of the reasons why it is claimed that the information is proprietary.
l The application should be prepared so that any proprietary information ident-j ified is contained in an enclosure to the application, since the application j
without the enclosure will also be placed in the Public Document Room.
If
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we do not hear from you in this regard within the specified period, the 1
report will be placed in the Public Document Room.
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. 4.
Licensee Action on 50.55(e) Items (0 pen?(79-13-01) Cracking in heavy rupture restraint weldments (See also LE Inspection Reports 50-275/79-13, 79-17, 79-22 and 76-26)
The inspector examined a sample of process sheets documenting the activ-ities of nondestructive examination, grinding and/or thermal cutting and repair of Unit I rupture restraint weldments and visually examined in process and completed repairs in the Unit 1 GE/GW area.
The accept-ance criteria utilized included licensee procedures and AWS D1.1 (Struc-tural Welding Code).
No items of noncompliance or deviations were identified.
The licensee noted that the final report required by 10CFR 50.55(e) was in preparation and was tentatively scheduled for completion about April, 1980.
5.
Licensee Action on IE Bulletins and Circulars a.
(0 pen)Bulletin 79-14 (See also IE Inspection Report 50-275/79-23):
The licensee submitted a response to Item 1 of the subject Bulletin by letter dated October 17, 1979 and comitted to a response to Items 2 and 3 for Unit 1.
The licensee was preparing the required response.
Discussions with responsible licensee engineering personnel in-dicated that design isometric drawings used in analysis for large bore and computer, analyzed small bore piping had been compared with field prepar'ed "as-built" isometric drawings.
Deficiencies identified were being resolved by reinspection and/or reanalysis.
The inspector examined the licensee's system for the resolution of discrepancies identified by the above comparisons and observed
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that the system appeared adequate to both identify and resolve discrepancies.
The licensee anticipated that engineering work and field work necessary would be completed about fiay,1980.
Actions required by the Bulletin for Unit 2 had not begun and will be addressed in future licensee submittals.
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UNITED STATES
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1990 N. C ALIFORNI A BOULEV ARD Y
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SulTE 202 WALNUT CREEK PLAZA j
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JAN 11 1980 l
Docket Nos. 50-275
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Pacific Gas and Electric Company D di 77 Beale Street
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7, g (C-San Francisco, California 94106 Attention: Mr. Philip A. Crane, Jr.
Assistant General Counsel Gentlemen:
Subject:
HRC Inspection at Diablo Canyon Units 1 and 2 This refers to the '
ection c nducted by Mr. D. F. Kirsch 'of this office on Decembe 3-13,1979 >
activities authorized by NRC Construction j
Permit Nos. CPPR-a C
.-69, and to the discussion of our findings held with Mr. R. D.
z er and other members of your staff at the conclusion i
of the inspection.
Areas examined.during this inspection are described in the enclosed inspection report. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector.
No items of noncompliance with NRC requirements were identified'within the scope of this inspection.
In accordance with Section 2.790 of the NRC's " Rules of Practice,"
Part 2. Title 10, Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room.
If this report contains any information that you believe to be proprietary, it is r.ecessary that you submit a written application to this office, within 20 days of the date of this letter, requesting that such information be withheld from public disclosure. The application must include a full statement of the reasons why it is claimed that the
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The inspector examined the licensee resolution and corrective actions and found them to be as stated in the. letter of l
July 13, 1979.
The hanger inspection program accomplished for Unit 1 had provided verification and/or resolution to assure that the angular orientation of S6 braces conformed to Engineering i
Department specified requirements.
S6 brace tolerances are included as inspection criteria on the Unit 2 Raceway Support Inspection Sheets being used for the Unit 2 raceway support inspection program.
This item is closed.
b.
(Closed) Out-of-Tolerance Barton transmitters in narrow range steam generator water level control system.
(See also IE Inspection Report No. 50-275/79-17 The affected Barton transmitters had been returned from the manufacturer and bench tested by the licensee.
The inspector sampled the bench test data and examined the Westinghouse certification that the transmitters meet contract requirements.
The installation of transmitters was scheduled to' be performed
,in accordance with previously established licensee procedures.
l No items of noncompliance or deviations were identified.
This i
item is closed.
c.
(0 pen) Cracking in heavy rupture restraint weldments.
(
(See also IE Inspection Reports 50-275/79-13,.79-17 and 79-22)
The inspector examined a sample of process sheets for non-destructive examination (NDE), grinding and/or thermal cutting i
of Unit 2 rupture restaint welds, NDE records and "as-built"
. documentation.
The pullman sunmary sheet appears to adequately reflect the status of the weld sample examined.
No items of noncompliance or deviations were identified.
1 5.
Allegation of Faulty Concrete Construction 4
At the request of IE:HQ, IE:RV initiated investigative action to address an allegation of faulty concrete construction at Diablo Canyon. The IE:HQ request was apparently initiated in response to questions received from the California Governor's Offico and an attorney for interveners.
The particulars of the allegation are contained in paragraph VIII of Case No. 51676 filed with this Superior Court of the State of California for the County of San Luis Obispo and is quoted below.
The name of the alleger has been deleted.
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P-January 16, 1984 i
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i DER Weluing Engineering has reviewed Pullman Power Products Procedures 15/16, 128, end 140.
In a few instances, these procedures have been interchanged i
for the welding of attachments to stainless steel containment spray piping.
In every case the procedure used was acceptable or compatible with the j
procedure specified on the process sheet.
For these weldments any of the three welding procedures could have been used to achieve acceptable welds.
l M I. O. k W b R. D. Kerr Pacific Gas & Electric Corporate Welding Engineer 1
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_ DATE: '!)2-20-79 s.
'PORTIMO PqR(s):
Precual i fied
- hnican soecifiention fer:
Shielded Metal Arc Veldine of ASTM A-36, A-441,.
.57'4 CR. 50, A-5t!!, A-515 cnd A-516 in any applicable coa.bination in accordi.nce
'th Alls DI.1-79.
'se Petal:
The base metal shell confona to those listed obcve.
Other meterials be substituted uith the approval of the Cogni ant VeIdinc Engineer.
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This technione is em:lified fer welc'inc. 6f rateriais of nimiteo tnickness in accore.cnce with AWS 01.1-79.
lier Hetal: The filler metal shall conform to AWS SFA 5.1, Type E-7018 ien of Weldinn:
We'iding will be done in all positions, ycid progression if be vertics.1 up.
chert and _ i nte rras s Temne'rmture:
Preheat and interpass temperature shall mforr. to those specified below:
t,*.SE 14ETAL TH I CKNESS MlHIMUM FREHEAT MAXIMUM INTERPASS O
(Actucl)
F F
Up to 3/4" 50"F.
500*F.
Over 3/L*" through 1 1/2" 150 F.
500 F.
0 Over 1 1/2" through 2 1/2" 225 F.
500 F, Over 2 1/2" 300 F.
500 F.
'nen r.etal temperature is below 70 F, material will be fizrae dried.
The preheat enuirement of a joint is established by the thickest r.:errber be i ng j oi ned.
The reheat applies to both sides of the joint and to th~e~ cntire' length of the joint minimur. distorice as shown below:
TYPE OF VELD MATERI AL TH ICI' NESS (t) ' filf1(MUM O f STANCE Fr.0M PoitiT OF \\!ELO DEPOSIT Fillet, Partial f3 inches 3 inches Pen.f, 1/4 t, a r.d c r,etc) I; epa i r r
>3 inches
'(t) thickness of part 1/h t Full Penetration, All Thickness 2t Partial Fen. > b t, Go s e..He t a l
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pr WP5 No. AWb l-1 PAGE 2
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!teanliness:
All weld prep's will be free of rust, scale, grease, and other_
. contaminants for at least 1" from the weld prep edge.
Welding parameters are specified in the table cn page 3' of 3
iteld Parameters:
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',elding Technicue:
The welding technique shall be as follows:
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BEAD WIDTH - All welding'will be accomplished using the stringer-bead technique.
Weaving is allowed on the cover pass only to a maximum of 5 times the electrode diameter.
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B) 'INTERPASS CLEANING - All weld beads will be free of all slag prior to continuation of welding.
NEEDLE GUNS shall not be used for any cleaning operation.
C)
DEFECTS - All visable defects, i.e., porosity, crater cracks, cold lap, shall be removed prior to the continuation of welding by grinding or or filling.
D)
RUN-OFF TABS AND BACKING STRAPS - Run-of f tabs and backing straps will be used whenever possible.
Run-off tabs should be removed.
Backing straps need not be removed unless specified b'y the owner or his desig-nated representative.
Removal of run-off tabs shall be accomplished by thermal cutting within 1/8" of the weldment and then blended into the base metal by grinding.
Alternatively, removal may be entirely accom-plished by gri,n, ding.
Removal of backing straps will be accomplished,d by grinding or gouging to sound metal, and then back welded as needed.
When any thermal process is used, the applicable preheat requirements are mandatory.
Preheat may be maintained during grinding as desired.
l E)
BASE METAL BUILD-UPS - Base metal build-ups will conform in all aspects-l to this procedure.
F)
WELD PROFILES - Weld profiles will be as follows:
1 1)
Groove Welds - maximum reinforcement of 1/8" and shall blend smooth-ly into the base metal in accordance with the typical joint details and weld profiles, page 3 of 3 2)
Fillet Welds - size in accordance with the field drawing (+ 1/S,
-1/16 for 10% of weld length).and profile in accordance with the typical joint details and weld profiles, nage 3 of 3 3)
The final surface will be smooth enough as not to interfere with N.D.E. operations.
Preheat may be maintained during final surface conditioning operations.
4)
T-Joints and Corner Joints Groove Welds - maximum reinforcement of 1/8' and shall blend smoothly into the base metal with reentrant configurations in accordance with the typical joint details and pro-files, page 3 of 3
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AWS l-1
~3 of 3 PAGE DATE:
12-20-79
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APPROVALS:
Prepared by: /
@ /2-2S-7/ Cognizant Welding Engineer l
/ Z !2 c/[7f Q. A. Manager
. Approved by
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Task:
Allegation or Concern No. 214 y/
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ATS No:
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Characterization Code'7/8 and 92/93 not technically the same.
Implied Significance to Plant Design, Construction, or Operation See Task Allegation or Concern No. 103-119 l
Assessment of Safety Significance l
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See Task Allegation or Concern No. 103-119 i
i Staff Position l
See Task Allegation or Concern No. 103-119 Action Required See Task Allegation or Concern No. 103-119 f
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Allegation or Concern No. 215 b,
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ATS No:
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1 Characterization Code 92/93 not qualified for unlimited thickness.
l Implied Significance to Plant Design, Construction, or Operation See Task Allegation or Concern No. 103-119 1
f Assessment of Safety Significance l
See Task Allegation or Concern No. 103-119 Staff Position See Task Allegation or Concern No. 103-119 Action Required See Task Allegation or Concern No. 103-119 l
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Allegation or Concern No. 216 h lg>\\~\\f/
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' Characterization i
j Code 7/8 and 92/93 not interchangeable.
Implied Significance to Plant Design, Construction, or Operation See Task Allegation or Concern No. 103-119 Assessment of Safety Significance See. Task Allegation or Concern No. 103-119 Staff Position See Task Allegation or Concern No. 103-119 I
Action Required See Task Allegation or Concern No. 103-119 I
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Allegation or Concern No. 217 i
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Characterization El Pullman performed a QA coverup through use of 1978 meno.
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4 Implied Significance to Plant Design, Construction, or Operation See Task Allegation or Concern No. 103-119 i
Assessment of bafety Significance See Task Allegation or Concern No. 103-119 i
Staff Position See Task Allegation or Concern No. 103-119 f
Action Required 1
See Task Allegation or Concern No. 103-119 8W
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______________.______U
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S. D. Reynolds and W. J. Wagner OPINIONS based on Special Inspect on
.(1/3-1/20/84) Findings:
um:
ited Review of the allegations indicates in many cases that the items c ality were indeed nonforming or deficiencies to meet the licensee s qu d by the as l program, but were in fact picked up by the system, and answere The allegers in many cases questioned the system's answers and system.
d d " rules or to the system's authority to interpret " Codes and Stan ar s interpret some of the ambiguities or excessive conservatism in their The areas (licensee's or licensee's contractors) specifications.
ted allegers in many cases challenged the " Engineer's" authorities gran l 1 is by Codes and Standards rules (such as D1.1) where the intent of D.
l l " cook to require strict conformance to " cook book" methods where on y book design" rules are used, but where design by analysis or i
to calculation rules are used.D1.1 permits fairly broad authorit es the responsible " ENGINEERS."
There were items discovered that were non-conforming and in some case{
QC or were QC system violations, but the majority of the items were l
Engineering paper work " hits " that were picked up by the QA program, l l
" Break As-Built program, or Verification Program and do not represent a f
down of the QA Program" but rather an inability of the allegers to acknowledge the engieers rights to make engineering decisions.
l The investigation of these allegations indicated that there were no The safety problems resulting from the areas alleged to be incorrect.
current on going NRC independent inspection conducted by Lawrence Livermore Labs further substantiates this position.
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Task:
Allegation or Concern Nos. 103, 104, 105, 106, 107, 108, 109, 110,
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r lil, 112, 113, 114, 115, 116, 117, 118, 119, 214, 215, 216, and 217 ATS No:
RV-83-A-0074 EN No:
84-009 (1/16/84) i Characterization Multiple allegations associated with a failure of the licensee and Pullman Power Products to meet required codes and standards for welding pipe supports and pipe whip restraints.
i Implied Significance to Design, Construction or Operation The failure to meet stated codes and standards in the fabrication of pipe supports and pipe whip restraints may result in components which would not perform their intended safety function.
Assessment of Safety Significance The allegations or concerns discussed in this section were received in the form of a 35 page letter from the alleger to a NRC Cocnissioner.
Attached to the letter were numerous documents provided to support the allegers concerns.
The staff's general approach to address these concerns was to interview the alleger, examine the contractors and licensee's written requirements, examine pertinent procedures, documentation, and to conduct interviews with personnel, as appropriate.
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i The alleger's written submittal and interviev included multiple cross referencing of issues.
The staff'did not examine every example of each type j
of issue individually, but instead focused on the substantive technical and-quality concerns by grouped topics.
Many of the issues were toe cs which had i
been formally documented and addressed by the licensees and contractor's control' programs.
The staff directed special attention to where the licensee and contractors addressed these items in a responsible manner.
The staff has placed the issues into 21 topics.
These are discussed individually below.
I 1.
Allegations 103, 104 and 105:
Pullman Welding Procedure Specification (WPS) 7/8 was inappropriately i
applied in that deviations from WPS 7/8 existed in the following areas:
(a) structural shapes, (b) weld joint geometry, (c) materials Staff Position (a) The alleger is correct that WPS 7/8 was used to weld structural shapes in addition to piping and plate as specified in the WPS.
However, the structural shape of the mer.ber is not required to be included in the WPS. All structural shapes, such as W, H beams and angle iron, shall have the connecting sections prepared to conform to the weld joint configuration of the qualified WPS.
The structural shapes are identified on the design drawings.
1 A
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.3 (b)
The alleper is correct in stating that the WPS doemnents do not adequate'.y illustrate all joint types which are welded.
kTS 7/8 is qualified in accordance with ASME Section IX requirements which indicates in QW 402.1 that a change in joint type is 5 con-essential variable.
Lack of description of all types of joints utilized is contrary to Section IX rules and requi ces a revision to the kTS.
lioweve r,
.his is an adrainistrative change only and does not require requalification of the VPS.
1 i
(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 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.
Staff Position i
A e
ta' r e alleger is correct that in come cases QC failed to clearly-
.dentify on the weld process sheets when welding was to be conducted to the WPS plus the. Welding Technique Sheets.
However, the use of Velding Technique Sheets to amplify and clarify WPS docume t n s is an a reepted 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 sp ecific 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
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approved by the licensee.
QA/QC personnel normally monitor 1
I 2
a implementat:f on of programs and procedures, the fact that they may l
i have assistled in writing the implementing procedures does not support the-conelusion that QA/QC is auditing its own work.
1 (c) The alleger is correct that ASTM ASIS 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 cornsidered as a pressure vessel material.
However, A515 was proper 1:." qualified and is acceptable material for welding structures _in compliance with AWS D1.1 rules.
3.
Allegations 109.end 110:
The alleger stat.es that structural steel pipe supports were not designed, fabricated and erected to the American Welding Society (AWS) code. He further states tmat the PG&E Contract Specification 8711 requires pipe supports to comply with the applicable standards of the ASTM, ANSI, ASME, MSS, AWS, and PF::. Additionally, 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 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:
s.
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- The Ame ri, van Welding Society D1.1 permits the ENGINEER to " accept evidence,..
previous qualification." It is normal practice to
-his~as. permitting ASME Section IX welding qualification interpret D1.1 qualification by testing.
In addition, the '711 in lieu of 8
Specificat....on Section 3 (para.4.11 and 4.12) require performance and procedure aalification in accordance.with Section IX.
Based on the-welding qualification methods utilized by Pullman staff rev a as,
meet ASME : 2.ection IX requirements.
The materis. is for pipe' support welding were:'A36, A500, SA515, I
SA516, and volting materials A307, and A108 (grades 1010-1020).
The that each of these materials is suitable and allowable staff foun; for ASME p; de support welding.
The staff revie'e:! Pullman procedure qualification documentation for engineering jus; _ fication for welding in accordance with current ASME
(
Section IX and A.,3 DI.1 rules (through utilization of the ENGINEER'S
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prerogatives in 7, a ragraph 5.2).
This review included the procedure qualifications f',r "as-welded" fabrications and the following types of to P1 material using shielded metal are 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 i
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.
l
-___r___-__-_____
.4 All.WPS documents were properly qualified for AWS welding, all structural steelffabrication met AWS requirements. Therefore, no contract specification change was required or needed 4.
Allegation 111 and'112:
L
.~
Contract Specification No. 8833XR was not officially-changed / revised to.
reflect that procedure qualification in accordance with ASME Section IX may be'used in lieu of AWS DI.0-1969.
Staff Position:
The staff found that no contract specification change was required because the AWS' Code allows qualification of "other processes" and
~
" evidence of previous qualification" of. joint procedure qualification.
In this case, Pullman Power Products provided evidence of qualification to ASME Section IX,.which is allowed by the AWS Code.
Therefore, no contract specification change or revision was needed since no deviation from the contract specification bad taken place.
5~
Allegation 113:
Contract Specification No. 8833XR requires welders to be qualified to the AWS Code, instead Pullman utilized welders qualified to ASME Section IX to perform the scope of work required by the contre t.
OI 4
-Staff Position
(
The staf f found that ASME Section IX qualified welders are qualified to AWS rules if the AW3 thickness criteria isproperlyaddreised. The staff found that the AWS thickness criteria was properly addressed and
-therefore, the Pullman welders were qualified in accordance with Contract Specification No. 6633XR requirements.
The licensee's and contractors practice of.using ASHE/AWS qualified welders.is reasonable and acceptable in this case.
i 6.
Allegation 1141 Pullman utilized welding procedures which have not been tested for notch toughness in the weld Heat Affected Zone (HAZ) for weldments made under Contract Specification 8833XR (pipe restraints).
Contract Specification 8833XR requires in Section 3.6 such qualification.
The Pullman practices in this area represent a ' deviation from the contract specification.
[
Staff Position The alleger is correct in that Contract Specification 8833XR does require HAZ notch toughness verification.
However, this requirement was clarified with a contract revision which indicated that notch toughneas is required (only) if specified on the drawing.
I
v Licensee correspondence and staff reviews indicate that RAZ notch toughness is not required, and therefore, the design of the rupture restraints does not require welding qualification documents demonstrating
.HAZ notch toughness. The licensee position that notch tougKness I
verification is not required is documented in a licensee to NRC memo l
dated Janaua ry,18, IES4. Notch toughness in the seld RAZ is not a code f
i or NRC requirement for rupture restraints.
Therefore, the alleger is correct that the Pullman practices in this area appear to represent a deviation from the contract specification, however, the staff found that because of the licensee correspondence referenced f
above no deviation from Contract Specification 8833X had occurred, 7.
Allegation 115:
No Contract Specification Change Notice was issued authorizing the deletion of full penetration welds less than 9/16 inch effective throat from the ultrasonic examination program for the repair of pipe rupture restraints.
1 Staff Position The staff's examination of licensee documents and discussions with engineering and quality assurance individuals revealed that the licensee's Engineering Department did not formally revise or process a design change allowing a deviation from Contract Specification 8833XR,
~~ This item is not considered a safety problem because all paragraph 7.21.
the technical requirements and procedures for ultrasonic examination were reviewed and approved by the licensee. However, it does represent an unauthorized change which is not in strict compliance with Engineering Department Procedure No. 3.6 " Design Changes." This failure to formally change the contract specification appears to be an oversight on the part of the licensee, since all appropriate reviews were conducted, and approvals obtained.
Therefore, the alleger is correct that no contract specification change was initiated, however, based on the above no safety significance is attributed to this administrative oversight.
8.
Allegations 116 and 117:
Pullman weld procedure code No. 88/89 was used to weld plate when the procedure was qualified for pipe ~ welding under ASME Section IX.
The Pullman weld procedure was never qualified in accordance with the AWS Code as required by Contract Specification No. 8833XR.
Staff Position The staff found that no contract specification change was required because the AWS code allows qualification of "other processes" and
" evidence of previous qualification" of joint procedure qualification.
In this case, Pullman Power Products provided evidence of qualification of WPS 88/89 to ASHI Section IX, which is permitted by the AWS Code.
The AWS Code states that qualifica, tion on pipe sball also qualify for plate.
1 l
l l
I Therefore, no contract specification change or revision was. needed because no deviation from contract specification had taken place.
1 l
9.
Allegations 118 and 119:
~
l l
1 l
Pullman Pc er Products uses a Welding Technique Sheet (AWS 3-1) to allow Gas Tungsten Arc Welding (GTAW) and a material (ASIS steel).
Neither of which are not allowed by the AWS Code.
l l
Staff Position l
This allegation is addressed as two parts as follows:
a.
Gas Tungsten Arc Welding is not allowed by the AWS Code (Allegation 118)
The alleger is correct that the gas tungsten arc welding (GTAW) process is not specifically covered in the body of AWS D1.1.
However, AWS D1.1 (paragraphs 1.3.4 and 5.2) permits qualification of "other processes" and " evidence of previous qualification" of joint procedure qualification.
Pullman Power Products has demonstrated proper ASME qualification of this process and is, therefore, considered satisfactory for welding supports and restraints.
l
a l
-s' l
The GTAV -elding process was qualified in accordance with AWS DI.1 provisions; therefore, there is no safety or quality managen,ent
.significan:e attributed to this allegation.
i l
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b.
Grade ASIS Steel is a Material not Listed as Approved in the AWS Code (Allegation 119)
The alleger is correct that ASTM ASIS steel is not listed in AWS D1.1 as an approved welding material.
A515 steel-is not listed in AWS D1.1 because'the steel is normally considered as a pressure vessel material.
However, A515 was properly qualified and is acceptable for welding structures in compliance with AWS DI.1 rules.
10.
Allegations 214, 215, 216, and 217:
The use of Code 92/93 to weld pipe rupture restraints when the process sheets specified Code 7/8 and Pullman's justification for this change 'is a raajor breach in the welding Quality Assurance Program.
-Introduction The alleger' refers to a September.15, 1978 memorandum to file from the Assistant QA/QC Manager. This memorandum states, in part, "Both weld codes 7/8 and 92/93 are qualified to allow welding of unlimited thickness on structural members under AWS requirements.
Technical aspects of both procedures are the same."
I
.)
i Ar,sessment of Safety Significance The staff examined the referenced memorandum and supporting d o cun,enta t i on. Based on this review, it is clear that the alleger has four issues in question. The following is a characterization of these four issues along with the,sta f f's, conclusions:
a.
Allegation 214:
The alleger's concern was that Welding Procedure Code 7/8 and 92/93 were not identical. He lists a number of welding parameters which are different between the two weld procedures. The staff found that i
the alleger is correct the procedures are not identical, though from a technical standpoint they are both acceptable for the work required (the rupture restraint work). 'This allegation appears to l
be an~ apparent misunderstanding on the alleger's part on the interchangeability of the welding procedures.
b.
Allegation 215:
l This concern is whether or not Code 92/93 is qualified to allew welding on unlimited thickness structural members under AWS Based on staff examination of AWS D.1-1 and Pullman's requirements.
use of Code 92/93, the staff concludes that Code 92/93 has been properly qualified.
i c.
Allegation 216:
This issue is that Code 92/93 is not a suitable substitute for Code 7/8.
As. mentioned in item 1 above, even'though,.the two~
I i
documents are not technically identical, they are both technically adequate for the work that was performed.
Therefore, there is no 0
safety significance associated with this issue.
i a
d.
Allegation 217:
l i
a Based on the alleger's concerns that the above three issues were safety significant, the alleger concluded that Pullman's QA/QC management attempted "to cover up a serious breach in the Quality i
Assurance program for welding Pipe Rupture Restraints...." However, because of the existence of the Assistant QA Manager's memorandum and the alleger's misinterpretations discussed above, the staff
^
cannot see any objective basis for the conclusion that a " cover up" was attempted or existed.
To the contrary the Pullman memorandum makes it a formal document available for all to see and review.
Staff Position l
The allegation is not substantiated.
It may have been generated, in part, because of a misinterpretation of the September 15, 1978, Interoffice Memorandum.
I
i, i.'
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1
.s Action Required None.
I-1 11.
Further A11egatisons I
A further staf f.. examination of the alleger's submittal disclosed the following inforniation:
This allegation eyelates to the installation of the Unit I containment 1
j
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spray ring piping; in 1972. A review of the records associated with this
]
activity resulted in the identification of discrepancies between the weld process sheets a:Ad weld rod requisition documents. These discrepancies were docucented sn Pullman Discrepancy Report (DR) No. 4713, dated April 14, 1983.
The alleger contends that the Discrepancy Report misrepresents the discrepancies in order to cover up more significant Quality Assarance/ Quality Control problems. More specifically the alleger states that:
DR No. 4713 did not identify the fact that the Production Department a.
disregarded. the process sheet and the specified weld procedure and substituted their own unauthorized and unapproved-weld procedure (Code 15/16),
b.
The DR does not address the failure to detect the discrepancies at the time they occurred.
6
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The DR states tt.at all welders were qualified, when, in the c.
alleger's. opinion one welder's (Welder "N") qualification status cannot be assured for the time period involved (since the Ninety Day I
Welder's Attivity Log was not maintained from August 1972 to i
December 1972).
Staff Position To address these issues the staff reviewed the DR, the contractor's response to the DR,. examined evidence of weld procedure approval and interchangability, examination of welder activity logs, process sheets rod requisition documents, and other records.
The allegers concerns are addressed below:
1 Use of unapproved and unauthorized weld procedure Code (Code 15/16).
a.
A staff examination of the veld procedure in question (Code 15/16) disclosed that it had been properly qualified and approved.
Therefore, the alleger's statement that unapproved procedures were used is incorrect.
The statement is correct that the record discrepancies make it somewhat unclear as to which specific procedures were used.
The staff, therefore, requested the licensee f
to perform a technical review of weld procedure interchangability.
The conclusion of the review was that, for the veldments in question, any of the welding procedures listed could have been used to achieve acceptable welds.
The staff concludes that there is no
I
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technical significance to the record discrepancies in this case.
I The general implications of record errors follows in item b.
b.
Failure to detect the discrepancies at the time they qtcurred indicates a significant breakdown.
j l
The alleger contends that since the personnel involved in the work at the time (crafts, QC/QA, supervisors) failed to detect the discrepancies and that this is indicative of a significant breakdown. The staff examined the situation to determine whether the record discrepancies were widespread (significant) or somewhat i
isolated. To assess-the magnitude of the record' discrepancy problem, 300 weld process sheets were reviewed.
100 for the Containment Spray System, 100 for Chemical and Volume Control System and 100 for Component Cooling Water system.
These prccess sheets 1
are for welds (piping to piping, attachments to piping, and pipe 5
supports) completed between April 1972 and October 1975.
There are i
2 531 weld rod requisitions associated with these process sheets. -The staff examined results of these reviews. The results showed that 20 weld rod requisitions records (15 Containment Spray, 5 Component Cooling Vater) have a WPS listed on them that is not in agreement
{
with the process sheet.
This equates to 3.7 percent.
Based on the-results of the review it does not appear that record discrepancies were a widespread problem.
)
._- _ _ - - - -_- -_=_ - __ - _ _ _ _ - _ _ _ - _ _ _ _ _
- ~
A were appropriately qualified.
It'does not appear that Discrepancy Report No. -4713 misrepresents the scope of the problem.
It appears
)
that licenscee and contractor managenient handled 'the problem in a b
j acceptable manner.
1
-Overall Staff Positiom The staff's review of the above allegations disclosed that there were minor, isolated weaknesses. ir, implementation of the contractor's and licensee's However, thtese discrepancies were not widespread and were primarily program.
administrative in nat.ure.
The welding processes, welding procedures, welded materials, welders and nondestructive' examinations were found to be in accordance with' the re quired' codes and standards.
In general, it appears that the licensee and his contractor managed their activities in a reaso:.able manner.
Action' Required None.
e 1
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Task:
Allegation or Concern No. 149 l
num
)
.ATS No.: RV 84A016 BN No.:
Characterization Fo[eydidnotsubmitHVACas-builtinformationduring 1981/82; as-built may I
not be checked against design.
Implied Significance to Plant Design, Construction, or Operation i
If true this concern may result in instances where the HVAC system or supports l
l may not perform as intended by the designer.
l l
Assessment of Safety Significance 1
The staff requested that the licensee conduct an evaluation of this concern.
The licensee found that the installed condition of the duct work conformed to design. This was further reinforced based upon satisfactory completion of flow balance and pressure differential testing. The licensee stated that the as-built conditions of support structures was in the process of evaluation.
Therefore, the staff feels that further evaluation of this concern would not likely result in any new management or quality performance issues.
Action Required Y 4'sf
- This item will be turned over to PG&E for evaluation and - mvloGua.
The i
k licensee will be required to provide the results of their evaluation, and any necesssary corrective actions, to the staff in writing.
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. ATS No. :
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number
-Chnreeter zi ation d structural steel and tubing heat ma' Foliy production may have falsifiewere provided)
(No specific examples h truction, or Operation racords.
1 I*rplied Significance _to Pla is that this concern involves on ly minimal t
The staff's face value assessmen safety significance.
e' Assesament of Saf ety Si_JLnif.iC.a,_,c f
h of no specific examples of sucf assuring alleger indicated that he knewproduction was in the process owas told tha falsification but stated that Foley The The alleger was in order.
d tubing that quality documentat on was in the area of steel anhis process several i
i being resolved by Foley product on i l certifications and that in tctor inspect materia field to verify traceability to mater a The lled piece.
instances required that a QC inspewas stenciled onto the instailed, production that a material heat numif the material was not so stenc n material ber alleger had heard that, a traceability number based upo was a there research the records and select Thus, the alleger concluded that could be l
type, shape and time of documentation of installed materia s isove.
possibility that traceability only minimum falsified.
involves even if true, this concern hased as an The staff considers that, Foley structure steel was purc d with, and receipt material which was suppliehysical an saf'ety significance because d off-the-shelf, commercial gra eevidence of pro eceipt 1
/
/
inspected for Stainless steel tubing is mainlyof conformance llowing installation.
d e
inspected and supplied with evi encand hydrostatically tested fo
/
and physical properties N
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Thus, the staff considers that exhaustive evaluation of this concern would not
]
likely result in any new significant management or quality performance issues.
Action Required This item will'be turned over to PG&E for evaluation and r e
,1.....
.i,,h.
r.,.ir.d t.,r.vid. th. r...,t.. th.ir.v...ti...
..d necessary corrective actions, to the staff in writing.
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Problem Statement Allegation #(s):.I 4 h llN
~~
9 V gq A 00 ( b i
ATS No.(s):
3 BN(s }:
L This document lists (or directly references) each allegation or concern i
brought to the attention of NRC personnel. The purpose of this statement sheet is to assure that all points raised by the alleger are covered.
If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s).
(This can occur if, for example, a line concern was received in an interview).
Problem Statements (use extra sheets as necessary)
Allegation //
Verbatum Statement or Reference
) 9k k/N 6
Comentarv e%%
,~
J Date This Statement was Completed %
LO-CH Technical Reviewer Signature i
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Task:
Allegation or Concern No. 151 BN No.:
ATS No.: RV 84A017 Characterization (1) Foley installs too many' conduits on supports; (2) inspection reject rate
~
E is too high for supports.
(No specifics were provided)
Implied Significance to Plant Design, Construction, or Operation The staff's face value assessment of this issue is that it constitutes minimal safety significance.
Assessment of Safety Significance The staff's review determined:
(1) The licensee has specified definitive design and installation critieria for the maximuc, number and size of conduits and (2) this allegation is that may be installed on a particular support, vague, with no specific examples provided. The alleger did not provide any this locations, or other information to support documentation, conduit support The staff and NRC consultants (Lawerence Livermore Laboratory) allegation.
have examined several hundred conduit supports in the past without identifying any significant problems.
Staff Position The staff's evaluations indicate that this issue would not result in any new significant management or quality performance issues.
Action Required This item will be turned over to the licensee for evaluation and r n.
The licensee will be required to provide the results of their evaluation and y
any necessary corrective actions to the staff in writing.
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Task:
Allegation or Concern No. 153
)
ATS No.: RV 84A017 BN No.:
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' Characterization
)
.2
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Fo1 y specifies 1/8" welds on 3/32 clamp material.
ml f
Implied Significance to Plant Design, Construction, or Operation i
The staff's initial assessment indicaten that this issue is of minimal safety i
significance.
Assessment of Safety Significance The alleger's concern is'that an oversize wel'd is being specified (i.e. 4/32" (1/8) to 3/32 clamp material). The staff had previously examined welding in this area (uni-strut /superstrut) and found no significant problems.
The staff's evaluation indicate that this issue would not result in any new significant management or quality performance issue.
I
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Action Required p p o r1'v *
- The l
This item will be turned over to PG&E for evaluation and-r - ^1n+4an-
,t licensee will be required to provide the resulte of their evaluation and the necessary corrective action to the staff in writing.
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Task:
Allegation or Concern No. 154 1
ATS No:
RV-84-A-0017 BN No:
7 C racterization
\\
Foley does not specify adequate inspection criteria for anchor bolts.
1 Implied Significance to Plant Desian, Construction, or Operation See Task Allegation or Concern No. 25 l
Assessment of Safety Significance See Task Allegation or Concern No. 25 l
Staff Position l
See Task Allegation or Concern No. 25 Action Required See Task Allegtion or Concern No. 25 i
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This document lists (or directly references) each allegation or concern brought to the attention of NRC personnel.
The purpose of this statement sheet is to assure that all points raised by the alleger are covered.
If the problem statement is not clear as to who, what, where, when, or why regarding the issue, the commentary section will amplify the statement. The commentary section will also be used if there is apparent conflicting information or if there is no or very little original information available which describes the concern (s).
(This can occur if, for example, a line concern was received in an interview).
Problem Statements (use extra sheets as necessary)
Allegation #
Verbatum Stateraent or Reference k
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\\ INTEROFRCEMEMORANDUM DiaMDCanyonProject PACIFIC QAS AND ELECTRIC COMMNY BECHTEL POWER CORPORATION 8"'
October 27,1983 ~
R. C. Thornberry/J. D. Townsend D
- ' " - 146.10 h*" 0, H. Moore Piping fl6nge Analysis 5'e"*
o' FrojectEngineer Requirements M
46/10/C33 t-8-02963 The following is Project Engineering's input to Ituelear Plant Problea Report DC143-WP0iT8.
The int 6nt AH5! B31.7.1969 Ccitfon with 1970 addenda, is to require detailed calculation fer f Tanges on Class 1 and 2 piping only for non-standar The requirements for Class I coupenents expitef tly states that only This is stated non standard flanges require Analysis per paragraph 1704.6.for Class 2 comp fianges.
in parepraphs 1703 and 1-704.7.
perspraph 2 704.5 is that only non-stardard flanges will t2 analyzed to This This is consister,t to the Claas 1 criteri6.
paragraph 1-704.5. interpretation is supported by both PGLE KANI, end Becht Furthernere, four code expert.s who were involved with the originalThey development of the B31.7 code were contacted.
of 831.7 was that only non-standerd f f anpas need to be 1-704.5.
A tearch of B31.7 code suppiter, 6nd one is a consultant to the Iridustry. cases 6nd interpret subject.
Therefore, since only standard flanges per B16.5, which have been f
qualified for systent design pressures and terrporasuns, have been usee we conclude that detailed analysis is not required.
Please contact D. C. Crosby if you have any further questions.,
/ /W
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oort DCCrosby/kb j
Reply P.eciested: No cet LE5hdpley 7Nercade CYCo nston J
5Schitnis CJadelrc.t E.rpn 0? n.
L RHanninga 190 fthalafalid.
Riayice h?O i
PHirschberg DEHardie act:cior ur hy' LWoenck MPO
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Questions for Interpretations Question: Under the rules of USA Standard 831.7-1969 Edition with 1970 Addenda, what code analysis is required for the following flanges:
a) Class I standard flanges meeting the requirements of ANSI B16.5-196S edition; L
b) Class I special flanges not designed in accordance s
to the requirements of ANSI B16.5-1968 edition; i
c) Class Il standard flanges meeting the requirements of, ANSI B16.5-1968 edition; d) Class !! special flanges not designed in accordance to the requirements of ANSI B16.5-1968 edition; e) Class III standard flanges meeting the requirements of ANSI B16.5-1968 edition; f) Class III special flanger, not designed in accordance with the requirements of ANSI BI6.5-1968 edition?
i Question: Under the rules of USA Standard B31.7-1969 Edition with 1970 Addenda, what code analysis is required for bolting material in the following flanges:
a) Class I standard flanges meeting the requi.anents of ANSI B16.5-1968 Edition; b) Class I special flanges not designed in accordance with the requirements of t.NSI B16.5-1968 Edition; c) Class !! standard flanges meeting the requirements of ANSI B16.5-1968 Edition; d) Clas:; 11 special flanges not designed in accordance with the requirements of ANSI B16.5-1968 Edition; e)
Class III standard flanges meeting the requirements of ANSI B16.5-1965 Edition; f) Class III special flanges not designed in accordance with the requirements of ANSI B16.5-1968 Edition?
f I
I Question:
Does Division 1-703 of USA Standard BSI.7-1969 Edition with 1970 Addenda obviate the requirement for perforitSg the flange f'
analysis of Subdivision 1-704.5 by stating that " components that meet the requirements of... Subdivision 1-704.7 satisfy the req;irements of Division 1-704 and only the analysis required by Division 1-705 need be performed" since Subdivision 1-704.7 refers to Table 1-726.1 which contains a reference to ANSI B16.5, E
" Steel Pipe flanges and Flanged Fittings"?
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n-- Under Extenmal Presmaev A,=cnme+-+=1 ans efs stdesneg rin.g,sqis.
B = fa:Sr deteri-mdfroen the appin:able chan NC.3833.1 General. Rules are givem in this para.
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graph for determmieg the thickmens seder etterna!
shal m sdenm8 nh6 at the deiugn metal
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pressure loadmg in spherical shells, cylmdrical shells with or wiihout stiffenmg ring,ind tubular products temperatwe consisting.of prpes, tubes, and fittinp. Charts fx b,-ourade dameter of the cylindrical shou determining the stresses in shc!!s and hemisphermal course or tube under connderation, in, heads are given in Appendix VII. For ves6els de-E=maduim of clastbry of matenal at design Si ned to NC.3200.see NC 3246, temperature. psi (for this value, see Table I-8 O ' U ** **"* "80 *" ""I" '" **
NO.3133.2 N======dansre. The symbols used in thn matenal't**Perature 1me of se appW para 6raph are danned as follon:
chan m Append & VII.
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.ing about its neutral axis parallel to the aus case of cylinders havmg D/T values less of the 6 ell,in.* (msn')
san 10. see NC.3133.3(b). Also factor r o avadabk moment ofinertia of the combined wre determmed from the appucabic chan in rm;.shell cross sectaos about ks metara! axis.
Appendia VII for the materal used m a punael ta. tin sbell, ia.* (mm3. Tk vMth of,4 stiffening ring, corresponding, to the factor #
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, :,4:.f,..,.,,
Ie) Ybere pya#6 Kvdem have estabbabsd pits.
k#
f- (thbesic IR6ttanal alkrers.Me stress at mmimum sure.tempeg+n rg raging, wtEh do ac( C114r.d to the ke044)lataperauert,pai upper IEstarkki temperatwu, lash pesamurd by this -
"Essebesic instenal aBowable stress at mamuan Sub-ah theprense-tesaperapasranags between
'" - (bot)tasaperamre, psi those -- W A and the uppsc matepallemperature f,/"= stress range reduction factor for cyche condi. -
tindt may be duerminsdta nocordamoe,yethe raleet tions for total number, N of full temperature of tlus Subsectgn,,, g y,;,,,,.,;;,,,9, ; 4y
',f, cydes over tout number of years during
- o., g.#s.,. 3,. 4 ';.. -2.,,
wtuch system is expected to be in service NG3Q2.2 Piping Pn,dusas Met % Synne frein Table NO3611.2(c).1 h3 Swund it be M unie ausshods (f ';
covered by this hh it is'lassaded that th
"(1) In desermmmg the b.uic mataki a.ibaabIe 8"'^#"*** " d*"3"'8f 'P'ag psodmas aot noe
~
P streassa,, S, and S, joint effmence need not be manu: en rcr shall consply wNs tbs respa.nssatsnF.3,J applied.
NO3640 and NC-3e40ardotherappsc (2) Screes reduct&on factors aPph, essentid to i
ments of tha Suhu~= fos the r
,a nomeonosive service and to corrosson restsu.nt mate.-
~ - -
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rials, wbsse employed to minimite the reducuon in.
cyebe life caused by corrosive action.
ratinpahallax be e< mead v t "v A (3) If the rang;e of temperature change varies, l
espiwalent fo!! temperature cydn may be computed NC3611A ConsWerar==, sur LocalCeeJanums and as fonows:
Truma h r (a) Woere piping spteca operatafat discrect
- = Ng + r,8N, + r,8Ny +.... r,5N, presswes are connected by a valve or"vabcs, tho'
, f.
valve or valm shd be %+d for the higher whd pressure system reqturements of presem and temper-N,= number of cycles at run temperature.. acute. The bwer p:cause synteto shd be demy;ned in change, A Ts. for whkh emn=
accxdance mth (t),(n and (3) beb=.
d) Tr.: rec.uirement of the higher preuurc stress,J,5 h MW sygem shsdl be me; N,, N,,....N,= numbst of cydes at lesser temperh.
g g,,,.g g,,,,f,yg g ture ebesgs., A Tu A T,.... A T r,, r,,.... r,=(ATME,), (E RF,)..... (MJ' be included to pro:ect the lower pressive system in a
accords me with NC-7411.
@ 8Y (3) Anure cadmth all the conditions of
=the e d. any leuer temperature (a)through(e)bebwI for which the *=~ n-stresA S has been calculated.
(0) FM=at check or remote actuated valves ahrl! be med in series at the intercasmeccon.
(f) AHousMr Stressfor Nornpcant Stresset The or a check m r,: ries with a semote actantoi valve.
einawable stress due to any single non-repeated.
(In Wta.. rM*21 or electncal contrMs
- ,,pohor movetnent (e.g., predicted bmidmg se'.tle-are p ovilei. rehni nt e.d dame cxr.atrob sbi.b be ment) calculated in accordance with Eq. (10m) muahd whub mli prevent she inure = W g afMGM52.3(b)shall be 3.0S,.
valves from openmg wtan the pressure in the high 136 o
q w z : mc j
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r 1 NC.M45-NCJ6sfJ SECn0N til. DEVI5 EON l'- SUBSECDON NC i
t = minimum tischness.ia.
(b) Ranged joints not included in Table SC 3132-t=pname W calanlaned for the I she be daigacd in accordance with XI 3000.-
ynn desugehaprandh o(loading assag and proceduru NC-3M7.2 Pwaneset Bleda. The mmimum re-quired thickness of pennanent blanks (Fy NC.
inNC W t'.
A =sms o(==4mmanal atowanoss (NC M13)
M47.21) she be calculated from the foUmng equauca (c) t'annarren to c&osures may be made by
,+a welding, extmdmg or threadin6. Connections to the where doeure shall be in accordance with the linutations provided in NC 3643 for branch connecdom. If the r =the nunimum requned thicknew.in.
aime cf the openmg is greater than ona-half the inside t-the pressure desp thicknew calculated from diameser of the closure the opening shallbe deugned the eqados oclaw as a reducer in accordance with NC 3648.
A = the sum of the mechamcal allowances, in.
(d) Other opentnp in closures shall be reinforced NC-%I3) in accordance with the requirements of reinforcement
' ' #' ( le S req f
roement in any epu through the center of the operang and normal to the where surface of the closure shall not be less thAu the 4= me inuh dimmeter of the pet for M or quantityorde,where f;,.t faa flages or the pitch diaracter of the r
ds-diameter of the hushed opening, Eatet fm resined guketed 6an ea,in.
s r=pecuure desip thickncu for the closure, in.
P = bcs.p Pressure, p;a 1
S - ttr. allawabh stren in accordance with
'I e
Taoks 17.0 NC.3647 Pressure Desip of Ragni Jolats and NC 3ed7.3 Temsporary Biaaks. Blanks to be used Blanka for teu purrue only shall have 'a minimum thick-neu net leu than the pressure dcap thickness, t.
878' NC.3647.1 Manged Jolat5 calculated u in NC-E.2 above. cacep: that r shall (a) Flanged joints manufactured in accordance not be less than the test pressure and the allowable
.%ith the standards listed ir. Table NC 3132-1, as strun. 5. ruy be takes as 95% of the spect6ed limited by NC M12,1. sht.!! be considered as meeting mirumum yield strength of the blank matenal(Tables tbc regarements of NC-M.
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Task:
Allegation or Cot.eern No.183 ATS No:
RV84A004 BN No:
9 Characterization Alleger use of hard drugs in portable toilets on site.
Implied Significance to Plant Design, Construction, or Operation Assessment of Safety Significance Staff Position hensitive l
l Action Required l
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Task:
Allegation or Concern No. 183 ATS No:
RV-84-A-0004 RN No:
1 Characterization
~..
Alleged Drug Use.
Implied Significance to Plant Desian, Construction, or Operation 1
Of concern is the measures that PG&E has taken to identify and curb suspected drug use and sale on site. Also of concern is the possibility that the judgement of those craft people or quality assurance inspectors suspected of J
drug use may have been impaired to affect the quality of safety-related work at the plant.
Assessment of Safety Significance See Task Allegation or Concern No. 71 Staff Position See Task Allegation or Concern No. 71 Action Required See Task Allegation or Concern No. 71 sh v
[l/f /.T
'N fo&NS EA)
WALTER B. SCOTT, P.E.
429 Gularte Road rpg Arroyo Grande, CA 93420 f
(
November 22, 1983 1
l,.
Secretary, Main Comittee ASME Boiler and Pressure Vessel Comittee American Society of Me.chanical Engineers l
United Engineering Center 34S East 47th Street New York, New York.10017 i
Dear Mr. Secretary:
Please find attached three questions for interpretation of USA Standard B31.7-1969 Edition', " Nuclear Power Piping", with 1970 Addenda.
i l
Although this standard is old and not used for design of new piping i
i systems, older-installations were designed to.these rules and ASME Section X: requires that consideration be given to the original design standard.
Thankyou for your attention to these questions.
Sincerely, j
I Walter B. Scott WBS:ms Attachment
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Problem Statement Allegation No. 182 ATS No:
RV-84-A-006 b
. Allegation No.
Ver/atim Statement or Reference 182 Bolts on the CVCS, RHR and RCS did not meet ASME code spec's.
They were overtorqued. The PORVs and safeties were included in this problem.
In fact, an engineer by the name of Walt Scott was moved out of an engineering position and into a warehousing position when he found this problem. The alleger indicated that this was hearsay, Commentary In conversation with Mr. Walt Scott, he added that improperly designed flanges were being used in Class 2 piping, and that some flange bolts had been overtorqued.
i Date This Statement was Completed. #cccW /,; /q Af ik __
Ihtteil Techdical Rsviewsr' Signature
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RV-84-A-006 Allgation # 181 - Poor, inaccurate and incomplete surveillance test records for diesel generator ' system exist at Diablo Canyon.
)
i Finding - Discussions with the alleger revealed that the main' concern of this
]
allegation was that failures of the diesels to start wN not properly being counted.
Specific instances were where plasticeverbr ntake for painting w n.n protection caused a failure to start and where dhe exha'ust caused the operators cw.jeem $ -e to terminate the test, d ese events were not considere es of the diesel engines k 44* AA h Ad N Mp6 M
8N Regulatory Position C.2.e of Regulatory Guide 1.108 evision 1, August 1977 is referenced inTechnical jpecificatiors' table 4.8-1 and established the requirements C. s.
- e for determination of valid test failures and suc, esses.
Section,(2)ofthe
,j referenced regulatory guide concludes that a..',' malfunction of equipment that is not part of the defined diesel generator / design should not be considered *--
{
1 E
valid test br failures This section is interpreted to include such things as l
l the plastic air intake cover and smoldering rags on the exhaust.
Review of the i
licensees procedure for diesel testing found,if' acceptable per the requirements of the regulatory guide on this topic.
Discussions with the alleger concluded j
that he agreed with this regulatory guide position and interpretation; therefore, c
the allegation is not substantiated 1
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P' ANT SYSTEMS L
3/4.7.4 AUXILIARY SALTWATER SYSTEM LIMITING' CONDITION FOR OPERATION 3.7.4.1 - At least two auxiliary saltwater trains shall be OPERABLE.
APPLICABILITY:. MODES 1, 2, 3 and 4.-
' ACTION:
With only one auxiliary saltwater train OPERABLE, restore at least two trains
.t'o OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />'or be<in at least HOT STANDBY within the-next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
SURVEILLANCE REQUIREMENTS 4.7.4.1 At least two auxiliary saltwater trains shall be' demonstrated OPERABLE atlleast once per 31 days by verifying that each valve (manual, power operated or automatic) servicing safety. related. equipment that is' not -locked, sealed,
-or otherwise. secured in position, is in its correct position.
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DIABLO CANYON - UNIT 1 3/4 7-12 1
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PLANT SYSTEMS BASES 3/4.7.1.5 MAIN STEAM LINE ISOLATION VALVES The OPERABILITY of the main steam line isolation valves ensures that no more than one steam generator will blowdown in the event of a steam line rupture.
This restriction is required to 1) minimize the positive reactivity effects of the Reactor Coolant System cooldown associated with the blowdown, and 2) limit the pressure rise within containment in the event the steam line rupture occurs within containment.
The OPERABILITY of the main steam isolation valves within the closure times of the surveillance requirements are consistent with the assumptions used in the accident analyses.
3/4.7.2 STEAM GENERATOR PRESSURE / TEMPERATURE LIMITATION The limitation on steam generator pressure and temperature ensures that the pressure induced stresses in the steam generators do not exceed the maximum allowable fracture toughness stress limits.
The limitations of 70 F and 200 psig are based on average steam generator impact values taken at 10 F and are sufficient to prevent brittle fracture.
3/4.7.3 VITAL COMPONENT COOLING WATER SYSTEM j
i The OPERABILITY of the vital component cooling water system ensures that sufficient cooling capacity is available for continued operation of safety related equipment during normal and accident conditions.
The redundant cooling capacity of this system, assuming a single failure, is consistent with the assumptions used in the accident analyses.
3/4.7.4 AUXILIARY SALTWATER SYSTEM I
The OPERABILITY of the auxiliary saltwater system ensures that sufficient j
cooling capacity is available for continued operation of safety related equipment during normal and accident conditions.
The redundant cooling capacity of this system, assuming a single failure, is consistent with the assumptions used in the accident conditions within acceptable limits.
DIABLO CANYON - UNIT 1 B 3/4 7-3
_____-_------_-----__---___------__-_-____-_-----_-_w
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PLANT SYSTEMS C
' 3/4.7.3 VITAL' COMPONENT COOLING WATER SYSTEM LIMITING CONDITION FOR OPERATION l
3.7.3.1 At least' two vital component cooling water loops shall be OPERABLE.
APPLICABILITY:
MODES 1, 2, 3 and 4.
' ACTION:
i With only one vital. component cooling water loop OPERABLE, restore at least two loops to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
4 SURVEILLANCE REQUIREMENTS 4.7.3.1 At least two. vital component cooling water loops shall be demonstrated i
OPERABLE:
At least once per 31 days by verifying that each valve (manual, a.
power operated or automatic) servicing safety related equipment that I.
is not locked, sealed, or otherwise secured in position, is in.its correct position, b.
At least once per 18 months by verifying that each automatic valve servicing _ safety related equipment actuates to its correct position on a safety injection test signal or' containment isolation phase B test signal, as appropriate.
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DIABLO CANYON - UNIT I 3/4 7-11
i I'
7 9 PLANT SYSTEMS.
l BASES l
l 3/4.7.1.2 AUXILIARY FEEDWATER SYSTEM The OPERABILITY of the auxiliary feedwater system ensures that the Reactor Coolant System can be cooled down to less than 350 F from' normal operating conditions in the event of a total loss of off-site power.
Each electric driven auxiliary feedwater pump is capable of delivering a total feedwater flow of 440 gpm at a pressure of 1135 psig to the entrance of i
the steam generators.
The steam driven auxiliary feedwater pump is capable of' delivering a total feedwater flow of 880 gpm at a pressure of 1135 psig to the entrance of the steam generators.
This capacity is sufficient to ensure that adequate feedwater flow is available to' remove decay heat and reduce the Reactor. Coolant System temperature to less than 350 F when the Residual Heat Removal System may be placed into operation.
~
3/4.7.1.3 CONDENSATE STORAGE TANK The OPERABILITY of the condensate storage tank with the minimum water.
volume ensures that sufficient water is available for cocidown of the Reactor l
1 Coolant System to less than 350 F in the event of a total loss of off-site d
power.
The minimum water volume is sufficient to maintain the RCS at HOT-STANDBY conditions for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> with steam discharge to atmosphere.
The contained water volume limit includes an allowance for water not usable because of tank discharge line location or other physical characteristics.
f i
i 3/4.7.1.4 ACTIVITY l
i The limitations on secondary system specific activity ensure that the resultant off-site radiation dose will be limited to a small fraction of 10 CFR Part 100 limits in the event of a steam line rupture.
This dose also includes the effects of a coincident 1.0 GPM primary to secondary tube leak in the steam generator of the affected steam line.
These values are consistent j
with the assumptions used in the accident analyses.
DIABLO CANYON - UNIT 1 B 3/4 7-2
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Additionally, the limited design change authority for NPO will provide improved design change capability. This will be followed during normal
-[
inspector activities.
No items of noncompliance or deviations were identified.
!!I li 17.
Auxiliary Saltwater' System (ASW) Pressure Transient j0 i i
l The. licensee's resolution of LER 82-09 and unresolved item 82-29-01 identified a design change that added a vacuum breaker to the ASW (a
.j check valve that vents).
The vacuum relief was designed to prevent ASW pressure transients that were caused by water column separation on pump t
shutdown. The vertical height difference between the turbine building elevation and'the intake structure induced backflow through the pump to the intake structure. This flow caused the vacuum and attendant pressure transient. The licensee has confirmed that temporary vacuum breakers I
have been installed and tested. The licensee plans to install permanent i
vacuum breakers that will be made of brass to better withstand the
)
saltwater environment at the first refueling outage.
This temporary modification is considered adequate to close the open item 82-29-01.. To close LER 82-09, it remains for PSRC to review an engineering analysis on pipe structural capacity given the previous water hammer experience.
7/,,
No items of noncompliance or deviations were identified.
(
18.
Exit Interview An inspector, Mr. Mendonca, met with licensee representatives (denoted in paragraph 1) on September 2, 1983, and discussed the scope an,d findings of the inspection.
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Plant house'.ceping and cleanliness.
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The inspectors talked with. operators in the control r",,,,",
,....-2.
The discussions centered on pertfrn'"'
t>
. plant personnel.
plant conditions', procedures, "M"fI' # '
. relating to genc e and other topics ' elated to the work activities inv"lV'"I' i
g,v ' ;
The inspectors examined a licensee nonconformance rel""4
'+', 8' /
, g,i. i o n,.
DC0-82-MM-N059 Pressure Transient in ASH System, to Vcri r,.
t deficiencies were identified, tracked and resolve
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i (pressure spikes) were observed on ASW pump starts HUI},ge the NCR system.
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nonconformance is to investigate' the phenomenon an't li,g
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process (See paragraph 4, Surveillance, of this relH8PIThis item will ti l information).
. (50-275/82-29-01).
J No items of noncompliance or deviation was identifle'l' j lj ')'
l 3.
Maintenance
'"8n'lu i pnn n t Maintenance activities for the diesel generators were t.gvl',
l ' d.l.. "" '
ty' that proper approvals, system clearance and tests of,'
inspectors during the month.
Observations by the IH H
were performed, as appropriate, prior to conductin<l '"d I",,h
'U'"
t related systems or components.
The inspectors verf f !"'I iP rel "I",' ;
personnel performed the maintenance using appropridi 8"[g,g %1.,
i d':tua l
procedures. Replacement parts.were examined to determ l h I I""
i D"I performance of maintenance activities, the inspector ** V"hli"P,,n certification of materials, workmanship and tests.
to-Ul""'
ll, "18 proper fire protection controls and housekeeping.the maintenance activity i
returning the system or component to service (.see l'afd'U gp Surveillance).
No' items of noncompliance or deviations were identifl'"I' I
4.
Surveillance Surveillance testing on the diesel generator (SurvelII'","h
)
Procedure M-9A) and the Auxiliary Saltwater System (,'I
Procedure 17.8 Ad 2) were reviewed by the inspectors.
~
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3 The diesel generator test was terminated due to high cooling water temperature.
THe problem was believed to be caused by the ventilation paths to the radiator not being configured as _ designed (a roll down door was open).
The licensee verified that with the door closed the diesel pasu d the test.
The licensee plans a special test program to establish acceptable ventilation system configurations.
This will be carried as an open item until the special test program is satisfactorily completed (.50-275/82-29-02).
The auxiliary saltwater system test program was at the tsunami i
drawdown stage when ~ indication of a potential pipe break (i.e., high pump motor amperage and reduced system. flow) was observed.
System hydrostatic tests and inspections were conducted to find the break, but no leakage was found.
On retest, the system passed the tsunami drawdown test. This problem of potential pipe break indication is continuing and will be covered under the open item previously discussed in paragraph 2 (Operational Safety Verification) of this report (82-29-01).
No items of noncompliance or deviations were identified.
5.
TMI Task Action Plan Items Auxiliary Feedwater System Evaluation, Short Term Requirements a.
(II.E.1.1)
The inspector verified that emergency operating procedures have provisions for transfer of pump suction to the fire water tank (safety grade) on loss of the Condensate Storage Tank (CST) level and that valve position is verified by two operc ers in accordance with a sealed value checklist subsequent to testing or maintenance.
This closes this item.
No items of noncompliance or deviations were O m
.M
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b.
Auxiliary Feedwater System (AFWS) Evaluation, Long Term Requirements (ll.E.1.1)
The inspector verified that:
CST level indication is redundant and safety grade AFWS flow is safety grade The AFWS suction valve position pointer has been replaced with a steel plate that was drilled and secured in place with a tack welded bolt.
Additionally, this valve is on a sealed i
valvo checklist i
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U. B. NuCL E AR RE GUL Af oR Y coMMl1310N j
LICENSEE EVENT REPORT EXHIBIT A couvaotstoco l l I l l I s,La Ast ensur on tver att asoviare automuarios l
B. IC I Al Of C I Pl1 l@%l010 l 0101010 l 01010 l 010_ l@[4 l11 111 l 11@l l l 61C.t64@
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Po O'*."J LL_J@l0 i s t ol 0101217153... li 0 l 017 l 812 @L,,1_101118 I 812 l@
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Io irl IPrior to fuel' load. testina oer@ formed on the Auxiliary Saltwater (ASW) eveur orscarrio~ ano eno.a.t co~staucucts I
Io is j i system has revealed that the system is susceptible to water hammer effectsi Iduring anticipated operational transients. These transients include pump o.
1 i rip and restart sequences such as would occur following a loss of offsite t
o.
ipower. The peak pressure observed during this testing exceeded the 100
- i. 9 i
go j,i ipsig system design pressure specified in the FSAR, however, no system i
r,o F.7.. Degradation was observed which would have (Continued __on attachment) 1 C ot C i
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et cause otscai,riou aso coansc rivt Actious @
- 1. ioi lThe cause of the system waterhammer is believed to be water column separ r ri rT11ation and subsequent column recombination at a coint of significant oicinct IiTl) Islope chance. Further evaluation of the event and ASU $vstem desian is be-I i
riTTl l ng conducted. Results of the evaluation will be reported in a revision to_l
, 3311this LER.
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' Attachment to LER 82-009/01T-0 10.
EVENT' DESCRIPTION AND PROBABLE CONSEQUENCES (Continued) prevented the system from perfonning its intended function.
This event has in no way affected public health and safety.and is reportable under Technical Specification 6.9.1.12.1 l
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&n Task:
Allegation or Concern No. 182 ATS No:
RV-84-A-006 BN No:
Characterization:
Several alleged improprieties occurred at Diablo Canyon that are included in this allegation.
Specifically:
1).
Standard design flanges were used on Class 2 piping instead of flanges J
designed in accordance with Subdivision 1-704.5 of USAS B31.7-1969.
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i 2).
Bolts on flanges in the CVCS, RHR, and RCS systems did not meet ASME code specifications in that they were overtorqued. The PORVs and safety valves were' included in this problem.
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4 3).
An engineer by the name of Walt Scott was moved out of an engineering j
position into a warehousing position for identifying these problems, k
q The alleger indicated he had heard these items but had no direct knowledge.
Implied Significance to Plant Design, Construction or Operation Overtorqued bolts and use of improper flanges can affect the integrity of systems required to achieve and maintain safe shutdown of the plant.
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' Assessment of Safety Significance The ' staff addressed the allegation by interviewing Mr. Scott, reviewing the
' licensee's FSAR commitment to codes and standards, and reviewing the applicable code requirements.
In addition, the Office of Nuclear Reactor Regulation'(NRR) was consulted for their position concerning code requirements. The concerns will be addressed one at a time.
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The interview with Mr. Walt Scott concluded that he had in fact identified these previously mentioned problems.
One problem involves interpretation of USAS B31.7-1969, a standard that the licensee has commited to in their Final Safety Analysis Report. The above standard requires that flanges used in Class 2 piping be designed in accordance with Subdivision 1-704.5.
The contention arises in that the licensee has used standard design flanges in accordance with Subdivision 1-704.7 of the above standard and USAS B16.5, vice Subdivision 1-704.5 as required. The licensee has verified this to be true, but considers that this is an alternate method deemed acceptable by USAS B31.7-1969.
This topic was discussed with Bob Bosnak, Mark Hartzman and Frank Cherny of the Mechanical Engineering Branch in NRR and documented per telecon dated February 9,1984. The issue was also raised with the same individuals per telecon on March 7, 1984. The staff concluded that the use of standard design flanges per Subdivision 1-704.7 is an acceptable alternative.
f Mr. Scott has pointed out that during assembly of flanges in the RHR j
system, bolts were torqued in excess of the code allowed yield strengths.
This was done'to assure fire seating of the flange gasket. However, this h'igher torque _value did not exceed the actual yield strength of the bolts i
as determined from certified material tests that were corroborated by-
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hardness tests.
4 This issue was also discussed in a telecon with NRR on February 9, 1984, and again with the same individuals per telecon on March 7, 1984. The staff concluded, based on these discussions with the Mechanical Engineering Branch of NRR, that the torquing of bolts that exceeded code allowed yield strength, but not actual yield strength, is an acceptable approach allowed by USAS B31.7-1969.
Mr. Scott indicated during the interview that he w.as independently pursuing this issue with the applicable ASME Code committee and will provide additional comments to NRC if he feels it necessary.
In regard to the allegation that Mr. Scott was moved out of an engineering position for identifying these problems, an interview was conducted with Mr. Scott's former supervisor, as well as Mr. Scott, by the resident inspector, to determine its validity. Neither party confirmed the allegation.
Staff Position
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7-1). ' Although the~ allegations concerning flange design and overtwrcquing of bolts are true, the staff found out these items had already been properly considered by the licensee. The staff-considers this acceptably resolved.
I 2).
The staff concludes that Mr. Walt Scott was not moved out of his engineering position into a scheduling position for identifying the above i
mentioned concerns, and therefore this allegation is unfounded.
Action Required If the ASME. code interpretation differs from NRR's evaluation, which is highly j
unlikely, the staff should reconsider the finding -
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Task:
Allegation or Concern No.177
,. krwu \\l:-p &';
ATS Noi RV84A007 BN No:
' Characterization RHR pump suction line valve control.
Potential damage to RHR pumps due to loss of suction as a result of a single failure.
Implied Significance to Plant Design, Construction, or Operation i
Assessment of Safety Significance l
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Staff Position i
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Sensitive Action Required 1
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