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9 Appendix A to Report No. PAR (DCNP)-NDE-3 March 6, 1984 Pa8e 1 of 2 Subject
.. 1/12/84 Review of Paragraph 5 on Pages 6 and 7 of Report #3 of Allegation Item 5A (Page 6 of Report #3)
ESD 247 specifies that it is a Magnetic Particle Procedure / Dry / Continuous Coil for B31.1 Code.
C.S #8711 Section 2.2.1 specifies that portions of the feedwater piping from the steam generators to the isolation valves are to be designed, fabricated, and erected per ASME Section I.
The MT Examination Records attached to DR #4662 (see attached) indicat e the Acceptance Standards to be ASME Section I.
This raises the question can a B31.1 Code MT procedure be used to examine ASME Section I piping and obtain results which are reliable.
Reply to AlleRation Item SA ASME Section 1 does not have any Magnetic Particle Examination (MT) requirements for piping welds.
Refer to Part PW of Section I,
1968 through 1977 Editions.
In other words, the Nondestructive Examination (NDE) requirements of ASME Section I were exceeded by applying ESD 247.
Allegation Item 58 (Pane 7 of Report #3)
The MT Examination Records attached to DR #4662 are dated 10-19-77 and 10-20-77 and the MT's were performed by D.
R.
Geske.
The M. W.
Kellogg (Pullman) Personnel Testing Record for D. R. Geske (see attached) indicated he was certified a Level II MT on 8-23-76 with a composite grade of 98%.
But the Testing Record under Examination Grades in Percent does not record any scores for the General, Specific, Practical Examinations.
It is not understood by this writer how a composite grade of 98% could be obtained when there are no recorded percentale scores for the General, Specific, and Practical Examination.
Both the SNT-TC-1A and M. W. Kellogg ESD 235 (NDE Personnel Qualification and Certification Procedure) require General, Specific and Practical examinations to qualify for Level II MT.
The Personnel Testing Record for D.
R.
Geske does not provide the necessary information to verify that Geske was properly qualified as a Level II MT Technician.
Reply to Allegation Item 5B
Reference:
American Society for Nondestructive Testing, Personnel Qualification and. Certification in Nondestructive Testing, Recommended Practice No. SNT-TC-1A, June 1980 Edition According to Subsection 8.4 (Grading) of the above Reference, the composite grade may be either a simple or a weighted average of three separate grades.
Further, a composite passing grade of 80% or greater, and separate grades of 70% or greater are recommended.
8708210134 870814 PDR FOIA DEVINE84-743 PDR
l J
Appendix A'to l
Report No. PAR (DCNP)-NDE-3 i
March 6, 1984 j
Page 2 of.'2 i
Let us determine whether Mr. Geske's composite grade of 98%
'would be possible with simple averaging' including one separate score of'(say) 70% or lower.
100 + 100 + 70 Composite Grade
=
3
=-90%
Now let us try the extreme weighting method.
Composite Grade = (0.4 x 100) + (0.4 x 100) = (0.2 x 70) 94%
=
As shown by these calculations, a composite grade of 98% is impossible with one single' grade of (say) 70% or lower.
l Prepared by:
,.'<t<4 # 8 M Kenneth A.
Ristau, Level III Reviewed by:
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Response to NRC Questions FOR INFORMA nGl Regarding Allegations Dated 11/14/83 ONLV 1.
Charpy test requirements for heat affected zones:
Paragraph 3-6, Section 2 of Specification 8833XR, Revision 15 specifies that
" Included in the procedures shall be provisions for testing the heat affected zone of welds for notch impact strength in conformity with provisions of Paragraph 2-1" Revision 9 of the Specification added a statement at the end of this paragraph to read "If required on the drawing." This statement is valid for all subsequent revisions including the current revision.
For rupture restraints inside containment, design drawings never specified requirements for Charpy testing.
For rupture restraints outside containment, drawing number 504950 note #16 specifies that "Charpy notch test for heat affected zones of welds is not required."
i 2.
Welding of tubular steel section with a 3/16" round bar backing strip:
I Ce:traints number 21/9&l0RR included a detail weld where a round bar backing strip was used.
In 1974, when NSC (presently Quadrex) revised the rupture restraints design for DCPP, it was decided that these rupture restraints are inactive and were identified as abandoned restraints. DCPP verification program verified this conclusion l
and issued a DCN #DC-0-EC-5485 transmittal #5 to abandon these restraints.
In addition, an engineering avaluation was performed and proved that even if the restraint is an active restraint, the weld as is will be able to transmit the loads used in the 1972 design file.
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I January 16, 1984 DER Welding Engineering has reviewed Pullman Power Products Procedures 15/16, 128, and 140.
In a few instances, these procedures have been interchanged for the welding of attachments to stainless steel containment spray piping.
In every case the procedure used was acceptable or compatible with the i
procedure specified on the process sheet.
For these weldments any of the j
three welding procedures could have been used to achieve acceptable welds.
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R. D. Kerr Pacific Gas & Electric Corporate Welding Engineer i
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R E C EIV E AU G 0 419f '
l Mr. Don Hetze1 nnsi y;pps; i, Project 2ngineer University Nuclear Systems, Inc.
llanf ord Project Caller Box 700 Richland, Washington 99352 Re:
Your Inquiry Regarding Flare Groove Welds, 2.3.1.4, AWS Dl.1-80
Dear Don:
This letter is in response to your letter regarding the referenced items in the Code.
If you satisfy all the requirements of S.I.1 of the Code and comply with 2. 3.1.4, you may conside rJha t the flate groove weld is a prequalifiedjint detail. fAdelitionally, '
[you niist Tiaks ran~ dom sectlons df FroduEtionT'eTd's for each pro-
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cedure or such further tests as the Engineer may require, to verify that the a f fective throat _is_ consistently being obtained _..
in productio_n.. The"requi red c f f ective throht~s of~ fisi~a groove welds'5Fe Tisted in Table 2.3.1.4.
As long as you ate oni', en-deavoring to maintain the offective throat required by Ta).le k
2.3.1.4, no further testing is required.
We trust this answers your questions on this matter.
Shou'i jou
- have any further questions, please do not hesitate to contciet.*
\\ our interest Y
in the structural Welding Code is appreciated.
Hope that the recent Mt. St. Helen's continuing eruptions have not bothered you too much.
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Davis, Secretary AWS Structural Welding Committec MVD:sa File:
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o FOR INFORMATi0N ONLY January 14, 1984 Response to NRC questions tesulting from H. Hudson allegations.
1.
Welding code requirements for pipe supports?
A.
Design of pipe supports is by Engineering Department usirjg Design Criteria Memo M-9.
AISC (and therefore AWS) is referenced as a basis for design.
B.
Welding procedures and welder performance qualifications for pipe supports are in accordarce with PG&E specification 8711 section 3, paragraph 4.12 (i.e. ASME Section IX).
2.
Fit up of flare bevel welds? Open butt welds?
A.
Flare bevel welds are not used in design as full penetrant We l t.
9 Where tube steel of the same size is welded using "T" joints or corner joints the possibility of root gaps exists and therefore fit up inspection is required and is a hold point on the process sheet.
Ref. ESD 223 paragraph 6.8.2.6.E. 1 C.
Tube steel which is welded across another tube or against a plate forming a flare bevel weld creates a " natural" weld joint.
These joints are easily prepared and as with fillet welds no fit up inspection is required.
If, however, a gap should form between the faying surfaces more weld than required would be deposited.
It is understood that the first pass would be similar to an open root butt weld and is not considered
)
in design. The remaining weld would exceed drawing requirements.
In addition, excessive misalignment and gaps is part of the criteria during inspection, ESD-223 paragraph 6.8.2.4. A. 2 Also, asbuilting is required, ESD-223 paragraph 6.8.2.6.H. 3 3.
Frequency of ultrasonic re-examination and procedure change?
A.
The frequency of ultrasonic re-examination was reduced from two tests per weld to one test because the number of tests originally planned for each weld was not achieving the purpose j
of the re-examination program (spec. 8833XR-001), to identify the cause of NCR DCl-83-RM-N001 and DC2-83-RM-N002.
However the scope of the re-examination program was not decreased.
The explanation for the reduction in tests is contained in Bechtel M&QS Report D0H-013-01. 4 B.
The ultrasonic procedure for re-examining the welds in the sample I
was changed.
Originally each weld in the stC e was to be tested twice, once using Pullman's ESD-234 ud ance using PG&E procedure 3523. After a portion of the sample had been re-examined it was determined that Pullman's procedure could not reliably be repeated and that PG&E's procedure exceeded the requirements of AWS Dl.0-69.
- Therefor, he re-examination FOR INFORMA1st ONL t'
J FOR INFORMAh<
- 3. B continued:
ONLY procedure was modified as a control to determine which welds were acceptable per minimum AWS acceptance criteria.
See Bechtel Memorandum DOH-112-03. 5 C.
Once the cause of NCR DC1-83-RM-N001 was identified the entire program became moot since the problem had been previously identified on NCR DC1-79-RM-010 and corrective action taken three years earlier.
4.
Welding.echnique Specification AWS 1-1 not referenced on Rupture Restraint process sheets?
A.
AWS 1-1 is not specified on restraint process sheets and is not required. According to Pullman's ESD-243 all welding on restraints
)
is per AWS.
Process sheets for restraints are only used for welding j
restraints per Pullman's ESD-264.
ESD-243 is called out on process sheets for welding parameters except weld complete and ESD-243 specifies the Welding Technique Specification AWS 1-1 parameters in areater detail than AWS l-1.
These requirements q
are often in e: ass of AWS 1-1 and AWS Dl.l.
FOR INFORMATei;t ONLY l
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FOR INFORMATiON January 18, 1984 ONLY 1
Response to NRC questions resulting from H. Hudson allegations.
l.
What was basis for omitting U.T. of full penetration welds <9./16" on rupture restraints?
A.
Prior to 1979 full penetration welds 5/16" and larger in rupture j
restraints were ultrasonically examined.
Evaluations of Pullman's i
U.T. procedures for rupture restraints revealed problems with
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certain aspects of the procedures.
In order to overcome the limited scanning capabilities of Pullman's procedure and to 1
provide a more accurate means of defining defect size and location i
Engineering directed Department of Engineering Research (DER) to develop a r.ew procedure based on AWS Dl.1-79.
This procedure was 3523 " Manual Ultrasonic Examination of Welds in Plate and Pipe Rupture Restraints Diablo Canyon Power Plant, Unit 1".
B.
Procedure 3523 does not in all aspects meet the requirements of AWS Dl.1-79.
In particular 3523 does not require examination of welds in material 5/16" to 9/16".
This departure was based on technical limitations encountered during procedure development and qualification.
C.
Engineering was aware of the procedure limitations and applications.
In addition Engineering had imposed a requirement for magnetic particle testing of all full penetration welds.
D.
It was Engineering's intent that procedure 3523 or an equivalent j
procedure be used for future rupture restraint work.
This intent is repeated in Engineering Report 411-80.93 part 6.0.
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January 16, 1984 FOR INFORMa nVa
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ONLY j
Pullman Power Products Procedure 88/89 was reviewed previously by PG&E l
and approved for use in limited cases for Rupture Restraint weld repairs.
The Rupture. Restraint weld repair work was completed in accordance with NCR-DC-1-79-RM-010 whid. required the use of AWS Dl.1-79.
Paragraph 1.3.4 of. AWS D1.1-79 allows the use of other welding processes providing they have been properly qualified and documented.
In addition, as stated in paragraph 5.2, the Engineer at his discretion may accept evidence of previous qualification of the joint welding procedures to be employed.
PG&E used the ASME Procedure qualification test for Procedure 88/89 as a basis for acceptance.
E5.8 0 ~ Ar R. D. Kerr Pacific Gas & Electric Corporate Welding Engineer FOR INFCRuiAliisa ONLY l
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FOR INFORMATIOld l-ONLY i
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CLARIFICATION OF WELDING PROCEDURE SPECIFICATIONS FOR RUPTURE RESTRAINTS PG&E specification 8833XR required that the fabrication and installation of Pipe Rupture Restraints be done in accordance AWS Dl.0-69 or D1.1-72.
Subsequently, PG&E determined that Pullman Power Products used ASME qualified procedures, such as 7/8.
This procedure did not meet in all respects the preheat requirements of AWS Dl.0-69/Dl.1-72.
Insufficient preheat may have caused welding related defects that were documented 1
in NCRs DCl-78-RM-008, DCl-79-RM-006, DCl-79-RM-007, and DCl-79-RM-010.
The restraints were evaluated and defective weldments were repaired.
All repair welding and new installation work from that point on were welded with PG&E approved written procedures to ensure adequate preheat.
These procedures either meet AWS Dl.1-79 or were approved for use under i
the requirements of AWS D1.1-79 paragraph 5.2.
N. S. N::^
4 R. D. Kerr Pacific Gas & Electric Corporate Welding Engineer l
I Foil INFORMATiON ONLY l
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FOR INFORMATION January 12, 1984 ONLY i
SUBJECT:
DISCONTINUANCE OF WELDING PROCEDURE 88/89 AND WELDING TECHNIQUE SPECIFICATION AWS 1-3 USED FOR WELDING PIPE RUPTURE RESTRAINTS.
In early 1982 I challenged Pullman Power Products use of Welding Procedure 88/89 on the basis that it was not qualified in strict accordance with AWS. At that time I was not aware of welding technique specification no. AWS 1-1.
For some reason our office did not have a copy.
In February l
1982 we received a letter from Pullman addressing the applicability of Welding Procedure'88/89 with AWS 1-1.
From a production point of view it was my opinion that Welding Procedure 88/89 was of very limited usefulness on Rupture Restraints. After a discussion with my supervision it.was decided to discontinue the use of Weldino Procedure 88/89 with AWS 1-3 on Rupture Restraints.
I added the statement about a. review to placate the Contractor, no review was ever intended.
R. D..Kerr, P.G.&E. Corporate Welding Engineer,has reviewed the procedure and found'it acceptable as' approved for use on Rupture Restraints.
c' Em Robert Torstrom l
POR INFORMMaun ONLY i
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'N7EROFFICE MEMORANDUM
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1 PACIFIC GAS AND ELECTRIC COMPANY l
BECHTEL POWER CORPORATION 1o R.D. Etzler o.i.
November 23, 1983 5,om G.Y. Cranston/G.H. Moore r,le No.
146.20 Project Engineering - Units 16 2 of sub en Governing Code for Qualification i
of Velders and Welding Procedure ei 45/10/ C29 E nens.on 8-2963 Attention:
D. A. Rockwell The subject of the governing. code for qualifying welders and welding procedures, was raised by J. Miller and others of General Construction.
Project Engineering representatives met with Fred Breismeister of M&QS and Dixon Kerr of Dept. of Eng. Research.
Based on Fred's and Dixon's recommendations, we suggest that the following statement be incorporated into ESD-223:
"For welding on pipe hangers, supports, and rupture restraints, welders and welding procedures shall be qualified to ASME Sec tion IX and/or AWS Dl.l.
Please inform Pullman Product Co. that the acceptance criteria and documentation requirements es established in the existing Project j
Specifications and other documents shall not be altered by this statement.
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INTEROFFICE CORRESPONDENCE DATE November 30, 1982 I
To H. W. Karner FROM C. M. Neary j
SUBJECT A307 and A108 Materials
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Per your request, I have evaluated A307 and A108 materials to deter-mine if they may be considered as P-1 materials as specified in Section IX of the ASME Code.
1 Materials are assigned into P-Number groupings on the basis of com-parable base metal characteristics such as composition, weldability, and mechanical properties (see 0W-421).
On this basis, materials not listed under a P-Number grouping may be considered as having a P-Number grouping by detennining that the material in question is equivalent to a material with a P-Number listing.
This justifica-tion was used in the evaluation of the A307 and A108 materials.
The A307 material on site is in the form of nonheaded anchor bolts (studs).
Paragraph 1.3 of ASTM A307-80 require, that such studs j
meet the requirements of A36 steel. A36 steel is covered by the
]
P-1 grouping.
Theerfore, A307 may also be considered a P-1 material, i
The A108 material on site is in the fonn of Nelson studs.
ASTM A108 has no tensile strength requirements.
Nelson specifies the chemistry meets the following requirements.
Ca rbon.
.23% max.
Manganese.....
.90'; ma x.
Phosphorus.....
.04% max.
.05S max.
These chemical requirements f all within those for A36 steel.
The lack of a tensile strength requirement allows us to consider these studs as A36 steel.
As A36 is a P-1 material, the studs are also a P-1 material.
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PACIFIC GAS AND ELECTRIC COMPANY BECHTEL POWER CORPORATION 1r M.E. Irppne D*
January 6, 1984
- D.J. Certis F'ie No 925
- 5. site Prziect Engineering Group s+
Effective Throat of F'are Gr oce Welds e
Jobsite gese 3064 AWS Dl.1 Section 2.3.1.4 allows the use of an effective throat of 5/16R (where R = Radius of Round Bar) for Single Flare Groove Welds without performing a w ld procedure qualification.
It is accepted as being a con-servative effective throat that can be increased if additional verifica-tions are made in accordance with Section 2.3.1.4 (2) of AWS D1.1 Verifications have been made which substantiate the effective throat assunp-tion of 5/16R as being conservative. One verification was done at the Diablo Canyon Jobsite by Pullman Power Products and a secord verification was corducted by Pullman power Products and United Engineers and Constructors at Seabrook Station.
Tests at the Seabrook Station were conducted using standard P-1 Pullman Power Products Welding Procedures. The Technical Report describing the verification is attached as Attachment #1. The purpose of this verification was "T) verify, as a minimtrn, that the effective throat thickness for a flare-bevel-groove weld when filled to the solid section of the bar will be equal 5/16R, where R is equal to the radius of the bar."
Four sizes of structural Tube Steel were welded using 3/32" and 1/8" dianeter E7018 elec-trades in the flat, vertical, and overhead welding positions.
The results frm the Seabrook Station verification showed that the actual penetrations exceMM 5/16R by as much as a factor of 1.0 to 2.4 with a average factor of 1.7.
The least amount of penetration occured when 3" x 3" x \\" tube steel was welded using a 3/32" electrode in the flat position.
In that case, the penetration equalled 5/16R.
Tests at the Diablo Canyon Jobsite were corducted using Pullman Pome Products Diablo welding procedures. A brief strmary is attached as Attachment #2. Tne tests were perfonned to verify that the actual penetrations met or exceeded the effective throat of 5/16R for the worst case identified by the verification done at the Seabrocik Station. Six tests were conducted to determine the typical l
penetrations which would be achieved for flare bevel' joints when welding 3 x 3 x k tube steel using 3/32" ard 1/8" E7018 electrodes in the flat position-l L
. 2: :;m l
All tests indicated that amount of penetration exceeds 5/16R by a farwr of 1.4 to 1.7.
i The code acceptance of an effective throat of 5/16R without gaalification I
is conservative. Furthemore, tests made at the Diablo Canyon Plant and I
the Seabrook Station ocnfim this point.
It is therefore appropriate for the desicner to assume an effective throat of 5/16R for single flare croove welds.
If you have any questions or ccments.cc, this subject please do not lesi-l tate to contact me.
I 1
Thank you, I
Dan Curtis D. Curtis/jb Reply Requested: No Attachments: Yes cc: S. Chitnis J. Iongworth L. Mangoba V. Juneja D. Tateosian l
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....:......... c-........,..n s : :. :.. r.......: _r. :... :...... G m....... s s :. m :.. Purpose - Tc verify, as a tir.itur, :ht: :he effee:ive :hros: :hickness fr: a flert-bevel-pr::ve ve;d when fi;1ed :: the s:;id se::ier ef the bar vi'1 be e ca. 5 ';6 7., where F is e:;ual te :he radius Cf the bar. ha:cria's - Tubular s teel sizes 3" x 3" x (", /" x 4" x 1/E", 6" x 6" x b" and 2" x E" x h" AI-'M A500 was used. Welcing Process - The shielded metal are velding process was used, u:f-
- 11. zing SFA 5.1, E7018 electrodes with multiple passes.
Prehea: and Interpass - The minicur. preheat and interpass te=perature vas in accordance with ASNI/AWS D1.1. Table'4.2. Procedures for Shielded Mets.1 Arc - The welding was done in the vertical, overhead and flat planes utilizing 3/32" and 1/8" diameter electrodes in each position. The welding parameters were as follows: .s 3/32" - DCRP, 70-120 a:ps, 20-27 volts, 2 ipm min. travel, 1/8" -DCRP, 115-165 a=ps, 21-27 volts, 2 ipe tin. travel. Qualification - The sampics vare sectioned for visual examination. The velds were free from cracks and there was thorough fusion between adjacent layers of veld metal and the base metals. The velds, in general, were visually acceptable. Conclusion - In general, 3/32" O electrodes showed good penetration ex-ceeding the mini =u: throat thickness by approximately 50% except there vere some problems with the 3" x 3" x k" tubes. The small radius did not per=it the depth of penetration. The 1/S" O electrodes showed excellent penetration for exceeding the "4n4m"* throat thickness for the flare-bevel-groove welds. It is retou:nended that the Contractors be direc:ed to utilize 1/8" O electrodes fer the first pass to insure adequate pene-tration.
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kWA.WNWYY ,'h /, 'w ElPullraan Power Product: Corporation Ir ' D;atto can; ~ k es. p.:,:. Post Off. e E:n St7 DATE: DECENCER 9, 19:3 h ia Bea:n.C u e at u a Tettonene e t: (n.nt( TO: D. RO N ELL, FG&E FRCM: H. KAR'iER, C;A/0^
SUBJECT:
f;PS BEAM ATTACH"ENT BBD-18 AfiD FLAT.E EEVEL WELDS 1 The NPS beam attachment BBD-18, which was in the possession of the NRC, has been examined by M.T. and U.T. Please find copies of the results of these examinations attached, i The NRC discussed with Pullman Power Products weld penetration for flare bevel welds on tube steel as used at Diablo Canyon. An investigation had previously been conducted by Pullman Power Products and United Engineers and Constructors, Inc., at Seabrook, Station on this subject. This infonnation was l presented to the NRC at Diablo Canyon for their review. Their review revealed that the minimum required throat was most difficult to obtain on small si7e tube steel (3" x 3") when using 3/32" electrode in the flat position. As a result of this determination and discussions with Mr. Sam Reynolds of the NRC, Pullman Power Products prepared several sample welds at Diablo Canyon using 3" x 3" tube steel in the flat position with 3/32" electrode. Measurements were taken in the presence of Mr. Reynolds. The formal results of these sample welds are attached. If you have any questions, please do not hesitate to call. Harold Karner QA/QC Manager hK: sam Attachments' (originals) cc: A. A. Eck w/ attachments -t'- P. Stieger F WM +
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v. i< 1 4 E}: Pullman Power Products Corporation V i' l' l' 018blo CanyM N@ ear Ef 0;t:t Pest Office Bor 257 Avils Beach Cavernia 9N24 Telepnene (8:5,535 22% December 8, 1983 RES"LTS OF FLARL BEVEL PENETRATION TEST o On December 8, 1983, Pullman Power Products conducted tests to determine the typical penetrations which will be achieved for flare bevel joints. The material used was 3" square tube steel to 1/4" thick plate. All welding was performed in the flat position with 3/32" and 1/8" E7018 electrodes. Results are as follows: Minimum Required Actual Throat Throat (5/16 R) 3/32" Electrode 1/8" Electrode T7732" 7/32" 5/32" 15/64", 17/64" 15/64" 7/32" 1 1 = I i fgn~; i cc: H. Karner C.M. Near File QEG Welding Engineer ] s. .e v.. W I- .,e,a m g .+ wu. y
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- 5. Qualification
] I k l l L l Part 4 procedures which are to be employed in executing con-f GeneralRequirementS tract work under this Code shall be qualified prior to use i to the satisfaction of the Engineer, by tests as prescribed { in Part B of this section.The Engineer, at his discretion, j 5.1 Approved Procedures may accept evidence of previous qualification of the joint w elding procedures to be employed?"' - 5.1.1 Welding procedures which conform in all respects to the provisions of Section 2, Design of Welded Con-nections, Sectien 3. Workmanship, Section 4 Technique, 5.3 Welders, Welding Operators, i ) as well as pertinent provisions of Section 8. Design of and Tackers i New Buildings, Section 9. Design of Bridges, or Sec-tion 10, Tubular Stmetures, whichver is applicable, 5.3.1 All welders, welding operators, and tackers to be shall be deemed as prequalified and shall be exempt employed under this Code shall have been qualified by from tests or quali0 cation, except that all groove and i fillet weld procedures for weld metal and base metal tests as prescribed in Parts C, D, and E of this section. l with a minimum specified yield strength of 90,000 psi 5.3.2 Radiographic examination of a welder's or welding (620 MPa) or higher shall be quali0ed prior to use by operator's qualification test plate or test pipe may be l tests as prescribed in 5.2 of this Section to the satisfac-made in lieu of the guided bend tests prescribed in Parts tion of the Engineer. C and D of this section, Note: The use of a prequalified joint welding procedure \\ l is not intended as a substitute for engineering judgment in the suitability of application of thesejoint, welding pro-5.4 Qualification Responsibility cedures to a welded assembly or connection. 5.1.2 All prequalifiedjoint welding procedures to be used 5.4.1 Each manufacturer or contractor shall conduct the tests required by this Code to qualify the welding shall be prepared by the manufacturer, fabricator, or con. procedures, t) actor as written procedure specincations and shall be available to those authorized to examine them. A sug-5.4.2 The Engineer, at his discretion, may accept evi-gested form show, g the information required in the pro-dence of previous qualification of welders, welding op-m cedure specification is given in Appendix E. erators, and lackers to be employed. 5.1.3 A combination of qualified or prequalified joint welding procedures may be used without quali0 cation provided the limitation of essential variables applicable to each process is observed,
- 21. The Engineer should accept properly documented evidence of presious qualification tests.
) 5.2 Other Procedures
- 22. Only the requirements listed in Appendix E. Table E2.
Code Requirements That Mas be Changed bs Procedure Quali-ne,iicn 7,,,,, ma, 3,,,,i,a o nen is, proc,oo,, is ycant;,e Except for the procedures exempted in 5.1, joint welding by tests. No other code requirement may be changed by pro-cedure qualification. 65
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DS' '*5 ' illt H. tr. T E L LGGG. CCH7 AN Y a o, vie.o= o.. ut w. me o=4%. e c o PER50HHEL TESTitlG R ECORD 3Aut F -Bewome. SUBJEC1 LEVEL GRADE DATE EXAMINED BY RE-EXAHlhED BYi GRACE f 01TE Radiography 18 Magnetic Particle 11 fB,V d-25-77 M f Liquid Penetrant il 4 Visual inspection 'I Uciding inspection Radiation Safety Ultrasonics i ._EX AMlH ATIOtt GR ADES IN PERCENT SUBJECT GENE RAL E X AN. lSPECIFICEXAH. l PRACTICAL E XAH. l COMPO$1;r Radiography l t ltognctic Particle 93,3
- / '7. 2.
l /60,6
- 90. g Liquid Penetrant
,,q Y ' Visual inspection j ppd- @.* Welding inspection ,gM hl N ' . Radiation Safety n \\@VI Ultrasc'nics hb PERCENTILE WElGHT SU8JECi lGEMIRAL EXAM. f 5?ECIF IC E X!.u. l PU 0ilC AL EIN. ! LEVE. Radiography .5 .3 l 2 l li llagnetic Particle 4 i .3 .3 l ,1 l Liquid Penetrant 4 .3 l .3 l -_ _11 l l j Visual 16spection .5 4 1 11 l l .ciding inspection l l Radiaticn Safety Ultrasonics' .5 l .3 2 11 f l l
i PERSONNEL QUALIFICATION AND CERTIFICATION PeabTyTesting ueTsoo M3antric gaa71 cts gO,m 33.eo nev., 7,3,78 Level 11 NAME F. Brander 6092 LOC / TION OC/lO NO. 0795 11-23-77 OAT EDUCATION dACKGROUND (Use second sheet for additional listings) CO RSE OF fA^ U^ SCHOOL OR 1*JSTITUTION LOCATION DATES A DEGREE j Army / Navy Academy Carlsbad CA General 1953-1957 4 yrs Graduate l University of Colo Denver, C0 Geology 1957-1958 1 yr None UCLA Los Angele: Engr 1959-1961 2 yrs None TRAINING (Use second sheet for additional listings) h0MANY R LOCATION SUBJECTS DATES HOURS U ON Million Co Santa Ana, CA Nondestructive (0JT) 1976 180 Peabody Testing Los Angeles, CA 1977 1 yr EXPERIENCE (Use second sheet for additional listings) METHOD OTHER METHODS COMPANY LOCATION DATES Position Hrs., Mo., Method Hrs., Mo., or Level or Years & Level or Years Million Co Santa Ana, CA 1976 MT-II 7 mop NUT-II 16 yrs OMTN {fi)\\rst.- PT-II 16 yrs Peabody Testing Los Angeles, CA 1977-pres c,n (f}?b J ' ' VISUAL ACUlTY EXAMINATION _n1 7~3 Results acceptaole C s a ceptaoie X.] Results on f.le C Results attached QUALIFICATION EXAMIN ATION RESULTS: Examination No, MT-2-0477 TEST POINTS X = TEST ADMINISTERED BY CATE SECTION SCORED PERCENTILE' SECTICN SCORE. Gene ai 89 X.3 26.7 J. Taylor 11-23-77 $xcific 87 X.3 25.1 J. Tavlor 11-23-77 Practical 92 X.4 36.8 J, Taylor 11-23-77 COMPOSITE POINT SCORE' $8,6 es.,ed.= dual procedures for percentile weights and mammum passen0 scores. The above information is accurate and true to the oest of my knowiecge. (2){ '8/? .( ~ Employee Signaure Date Examiner S:enature Date CERTIFICATION l t have reviewed 're acove qualifications anc certif y tre emcicyee meets the reesirements of a Lavei Tecnnihc' n in accor::ance withb wk. Q. M<- T Lwl2 C"'Y% s'W i~ C G c m. M4 h sa n48 - D*RC n W a
Dust e4e ist g, it, g g ((030.canp an y a coveteou os cut s,wa ewc ons;oza no PER50HHEL TEST!!1G R ECORD )AHC k. l. M E.ADOW S $UBJECT LEVEL GRADE DATE lEKAMINEDBY RE-EX AHlhED BYl GR ADE l O A T P.ad i oo ra phy 11' Hagnetic Particle N 7-M 9 MI Liquid Penetrant 11 Visual Inspection 11 Velding inspection Radiation Safety Ultrasonics 11 4 ') .EX AMlH ATION GR ADES iH PERCENT SUBJECT GE NE RAL E X AW. f5PECIFICEXAH. l PR ACTICAL EIAM. l C O'4 P O $ t T i Radiography a liagnetic PartIc1e 9/,. /,, d /.. /,, l /00.O 88, S' Liquid Penetrant ,,f Nhl ' Visual inspection ,g v Velding Inspection n p,ff hs ) \\,*:. Radiati'on Safety g cfg5N..W Ul t rascin ics e(M E'O pv PERCENTILE WEICHT SUBJECT GENERAL EXAM. l SPECIF IC EX AM. lPRACilCALEn4 l L E V E '. Radiography .5 .3 I 2 l 11 i Hacnctic Particle 4 .3 .3 Liquid Penetrant 4 .3 i .3 __,l_I_ ) Visual inspection ,g ,4 ,I I Uc1 ding inspection l j ( l Radiatien Safety Ultrasonics- ,5 .3 2 ll { 1 i
I. ] '%CC)C}IlOdCI ] I A_ PTM In'dividual v eccrd of Cortifientinn 1 h /-k ~ EMPLOYEE' Bob Meadows ~ DATE 3'-27-78 ADDRESS. ) EDUCATION j DATE 'I l
- 1938-1946 Grammar & JR Hi.
8' yrs I '1946-1950 .. High School 4 yrs TRATNEtG RECORD g _DATE " METHOD .}IOURS IDCATy} 1964 . Magnetic Particle. 60 Don Bosco Tech Inst-l 1964 . Magne' tic' Particle . 40 Cromer Mfg? & Eng ' ' ', 1973 ~ Magnetic Particle. , 40' Mobile Insp,. 1973. Magnetid. P. article' 40 .. Peabody. Testing /Ma'gnaflux .. a. ~ -~ EXPERIENCE RECORD DATE liETHOD ' EMPLOYER ' YEARS s 1950-1973 .. Magnetic Particle cromer Mfg %h 22-1/2, 1973-1973 Magn' tic. Particle Mobile'Insp n. U 1 yr e 1973 Magnetic Pa.rticle Peab (Q'.A,(sf,fhg-Magnaflux 4 yrs. V'. ,,.. g g.o? @... ~ VISION TEST _Near Visien , Color Vision: I' Distant vtsten . 2.0 Uncorrec e 'Co _b "-h ::.. Uncorrected RE LE 2.& ( ((,, N / g Corrected RE 2d rwe RE 2 / Da'te N -3 N Y Due Date: C T: ~ Remarks: Certification Expires 7-13-80 ~ EXANI"ATION Date Methed 7-13-77 Magnetic Particle ASME Sect _III, RDT F3-6T, MIL-STD 410, SNT-TC-1 A Composi:e S. gore.89.04 Level II (Ganaral P:t Dercentila 2 Cnac"dr oc" oe -er* % ~ 4' 'd ,p . Dr.calne;.':.."N.'W L. J)w/; _ + Practical 95?; Percentile.4) .s.. Lgygtl;) f'/ am.-.-.
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//. PAwis $UBJECT LEYEL GRADE DATE EIAMINED DY RE-EXAHihE0 BYl GRADE l D A TE P.adiography ll //d le/Ju ~ F Itagnetic Particle 11 9V.3 /,-25-79 (.iquid Penetrant il ~ Visual i ns p.c c t i on il Velding inspection Radiation Safety Ultrasonics 11 EX AMIN ATION GR ADES IN PERCENT SUBJECT GE NE RAL E X AM. l$PECIFICEXAH. l PRACil CAL E I AN. l CCHPO$tTE Radiography / 93.,3 flagnetic Particle
- 94. /,
S/,J /SO Liquid Penetrant Visual Inspection Welding inspection nQi Y V n{hM Radistion Safety e r, . \\ N'D l' 'd tiltrasonics nO
- -v PERCENTILE WEIGHT EXAM. l $PEClf IC EX AM. lPRACTICALEx.'.1 !
L!vE. SU6 JECT l GENERAL = Radiography .5 l .3 l 2 i 11 tiocnetic Particle 4 .3 .3 11 i lLicuidPenetrant 4 l .3 .3 11 I l 4 1 Il (Visual I rtsp ec t ion .5 l Uciding inspectico [RadiationSafety f Ultrasonics .5 3 2 l 11 j l l I
._l PECCONNEL QUI.'LIROAs.,Ji1 AliD CERTIFICAT!0'i J cz.j (. PeabudyTestig uE1sOo nAcneTIc g C g eD,m 33.9o nev., 2,s,78 J HERBERT B. PAYME LOCATION _ LOS ANCELE.:2 NAME ~1**7 9 - OClio NO. DATE 2 EDUCATION BACKGROUND ~ (Use seconal sheet for additionallistings) D[EE COUR OF $CHOOL' OR INSTITUTION LOCATION DATES g UDY High School Tulsa, Oklahoma General 1963 4 Graduate l 1 TRAINING (Use second sheet for additional listings) "Y OR CO 'pUT LOC ATION SUBJECTS DATES HOURS N U.S.Airforce Chanute, Ill Magnetic, Penetrant 1966 2 month: AMF' Tubo-scoph Anchorage, Alaska 1975 3monthd Peabody Testing Lo's Angeles 1979 2 month ( EXPERIENCE (Use second sheet for' additional listings) ~ METHOD OTHErt METl'ODS j COMPANY ' LOCATION DATES Position Hrs. Mo., Mett.od Hrs-, Mo.. or Level or Years & Level or Years U.S.Airforce Chanute, Ill' 1966-1971 MT-II 5 yrs AMF TUB 0-scope Anchorage, Alaska 1975-1979 MT-II 4 yrs Peabody Testing Los Angeles 1979-pres- - nta
- r. n p n \\ v s -
VISUAL ACulTY EXAfAINATION g th ~ O {J Re:ults on file O Resvits attached q F.e ett, a:cepta' le OR S: pta e QUALIFICATION EXAfAIN ATION RESULTS: Examination No.MT-2-0477 TEST PO!'JTS X
- TEST ADMINISTERED BY DATE
$ 5 CTIC,N SCORED PERCENTILE' SECTION SCORE
- cen:rai 88.0 X.3 26.4 R.E.HigOins, Sr. Lev II 6;1-79 tou
- 83.0 X.3 24.9 n.F. Piggin <.s-I nv TT 6-b20 Practic3' 05,5 X.4 34.2 J. Taylor Level II 6-1-79 CowOri1E PO'NT SCORE.
85.5
- See individual procedures for rarcent;lo weights and minimurn passing scorcs.
The above inf ormaticn h accurate and truo to the t't.st of my knowledn,3, ll _j1 k D ' Emp'oyce Sig,ato/c D':ta '
- I
, j!/p / Exorniner Signatued Date m CERT!FicATICN I t.aa revior c1 the above quit;ifications and ctartify the employee (nects Inc rcQuiremonth of a Level Tec: ncien m 2:ccreance nth ('titification Cp tl ! b. SWnSuic D..te :.1 Cu ' s Con
- i cle OC/lb Na.
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W. T E L LOGG CO)1P AN Y a oivmou c,* evs cw. e~c ondeu r co 4 PER50iH1EL T ESTlHG R ECOPD lDM $ BJrX)(2 $UBJCCT LEVEL GRADE 01TE lEXAMINEDBY RE-EX AHthED BYl GR AEE l D A Tf Radiography I l' ~ Hagnetic Particle If f4.5 4-25-M ,d7M Liquid Penetrant Visual inspection Welding Inspection Radiation Safety Ultrasonics il - 4 ,EX AMlH ATION GR ADES IN PERCENT $UBJECT GENE RAL EX AN. l SPECIF IC EX AM. l PRACTICAL EIAH. l CCMPOSIT Radiography j /do o 94< [ llagnetic Particle 93, 3 90 9 Liquid Penetrant my3? \\/ ' '\\T hN UO ' Visual Inspection _,,..,. n t-" Velding Inspection hk II.\\kIU ' . Radiation Safety . i Ultrasonics 1 PERCENTILE WEICHT EXAM. l SPECIF IC EX AM. l PRACTIC AL E XN. ! t i v E '. SUBJECT l GENERAL Radiography .5 'l .3 l 2 l 11 Macnetit Particle 4 l .3 .3 _II Liquid Penetrant 4 ) .3 .3 11 l Visual inspection .5 4 .I If l l Welding inspection l l > Radiation Safety ' Ultrasonics .5 .3 2 l ll I
6 s -e ) PERSONNEL QUALIFICATION AND CERTIFICATION PeabTyTesting METHoo Magnetic Particle Form 33.90 Rev.1 7/3/78 Leve' F NAME Richard Ridenour, t.oCATION, 6092 l10-18-78 bb07 OCllD NO. DATE EDUCATION BACKGROUND (Use second sheet for additional listings) COURS OF ^ ^ SCHOOL OR INSTITUTION LOCATION DATES A OY OE R High School Los Angelos, General 1966-1969 3 yrs Graduate Long Beach City Long Beach Drafting 1969-1970 1 yr none College TRAINING (Use second sheet for additional listings) COM NY LOCATION SUBJECTS DATES HOURS g U lON Magnaflux Corp ASN1 Los Angeles, CA Mag & Penet 1978 40 Peabody Testing Los Angeles, CA Mag, Xray 1976 4 mos i EXPERIENCE (Use second sheet for additional listings) METHOD OTHER METHOOS COMPANY LOCATION DATES pas, tion Mrs., Mo., ' Method Mrs., Mo., or Level or Years & Level or Years Peabody Testing . Los Angeles, CA 1976-pres II 2.5 yrs RT-II 2.5 yr ; me ntM h VISUAL ACUlTY EXAMINATION _ g M (. b'Q *.* gs JQ Results acceptable C ce t o @ Results on file C Results attached QUALIFICATION EXAMINATION RESULTS: Examination No. MT-2-0477 TEST POINTS X = TEST ADMINISTERED BY DATE SECTION SCORED PERCENTILE' SECTION SCORE. k 6 Ni6GJ"S m-18-79 General 90 ya 97 n Socif >e 80 y.1 pa n 10-18-78 10-18-78 Practical 90 X.4 36.0 COMPOSITE POINT SCORE
- 87.0 0 See individual procedures for percentile weights and mir imum pasung scores.
/ The atieve information IS Accutate and true to the test of my knowiedge, c-g Y 4hns-e / L 'N i I I f l <w ^ /['-J %' - 7 4 6 Employee Signature Date Examiner S gnature/ / Cate CERTIFICATION I have reviewed the aceve cuahfications and certify the employee meets tre recurrements of a Level ~, Tecnn.c an in accorcance with $ $ A) b d i t! b h IN h 22 t g c g g g g :,t'are gg.j 7 y g D ate,0 f_Cer pf{,capop Title QC/ID No. Date Certification Expires ________________-___-_a
c. Problem Statement ~ Allegation Number: 121 -ATS Number: RV-83-A-0074 BN Number: BN-84-014 1/24/84 i Problem Statements Allegation 121 consists of many related statements which can be summarized as follows: There are inadequacies in the implementation of the quality assurance program documenting the ultrasonic verification of valve wall thicknesses and the repair of valves found below minimum wall thickness. It is also alleged that pressurizer safety valves were designed to the. incorrect code. Each of the statements made in this allegation are listed below, along with any necessary references or clarifying commentary. The underlining is not part of the original allegation, but has been added to emphasize the major point. Opening Statement i "The U.S. Atomic Energy Commission, in 1972, requested Pacific Gas and Electric Company to verify at the Diablo Canyon Nuclear Plant that valves important to nuclear safety installed or to be installed at the facility meet the minimum wall thickness requirements of the specified codes or standards. Major Quality Assurance Program Deficiencies have been identified in the PG&E/ M.W. Kellogg (Pullman Power Products) Quality Assurance Records for the Ultrasonic thickness measurement of these valves. The Nuclear Regulatory Commission should review these deficiencies to determine if the use of these valves important to nuclear safety will effect the safe operation of Unit #1 and #2 reactors at the Diablo Canyon Nuclear Plant." A. "The ultrasonic thickness measurement of Reactor Coolant Pressure Boundary Valves has not been controlled and accomplished using a qualified procedure." 1. "There is no evidence of a Procedure Qualification Record (PQR) documenting that the ultrasonic measurement procedure (ESD 236) is qualified by a proven demonstration (procedure qualification test) i I of valve wall thickness measurement. This is a nonconformance to 10 CFR 50 Appendix B IX and XVII, and PG&E Contract Specification
- 8711.4.3.23 and 4.3.29 (referenced in ESD 736)."
2. "There is no evidence of a Procedure Qualification Record l documenting that the ultrasonic measurement technique (ESD 236 j Proce M e) is demonstrated to have a maximum error in repeatability j' and accuracy of not more than 2% of the wall thickness as required I by the A.E.C. letter of 6-20-72 (page 2, paragraph 2)." { i I 3. "There is nn documented evidence of procedure verification tests as required by ESD 236.6.7 (see attached U.1.A. #34, Quality Audit { I Checklist, page 15) to determine that transducers will be of suitable frequency, size, and adopted with shoes, wedges, or saddles g
1 e .e as each valve measurement requires. It is alleged that PG&E/M.W. Kellogg (Pullman Power Products) did not perform " procedure verification test" to determine transducer requirements. Without " procedure verification tests" documentation there is no assurance that the transducers used were of a suitable frequency, size, and adopted with shoes, wedges, or saddles as each valve measurement requires." Commentary on Statement A.3. i A M.W. Kellogg Interoffice Correspondence (IOC) dated 4-17-73 stated that j available transducers are good only for flat smooth surfaces and that ( there are no adapters, shoes or wedges. The IOC stated that Kellogg will need to order new transducers and equipment. This raises questions about the appropriateness of the transducers used to perform the measurements. The IOC further recommends that the effect of surface contour and roughness be tested prior to mailing reportable results. Based upon this IOD, the alleger goes on: "There is no documented evidence of the testing of surface contour and roughness for effect as referred to in the IOC. This testing should have been a part of the procedure verification tests for which there are no records. The IOC concludes it is doubtful that any meaningful results can be obtained at this time and it is definite that none can be reported until the above mentioned problems are solved. Without documented records of Procedure Qualification Tests and/or procedure verification tests, there is no assurance that these problems were resolved." 4. "The ultrasonic measurement of Reactor Coolant Pressure Boundary Valves for body wall thickness (curved surfaces) is a special process. ESD 236, as well as ESD 244, did not conform to 10 CFR 50 Appendix B IX and PG&E C.S. #8711.4.3.23 requirements for special processes to be controlled and accomplished using qualified procedures. M.W. Kellogg's (Pullman Power Products) ESD236 and ESD244, do not conform to 10 CFR 50 Appendix B XVII and PG&E C.S.
- 8711.4.3.29 requirements to maintain records, such as qualification of procedures and equipment, adequate to document and assure quality
) of material and work." l l Commentary on Statement A.4. It was determined in I.A. #101 by the Pullman QA/QC Manager H. Karner that these two ultrasonic procedures were not nondestructive testing procedures but were used to measure material thickness and therefore did not require " Procedure Qualification Records" (Procedure Qualification Tests), The alleger contents that: ..."PG&E C.S. #8711 Section 4.3.23 i f (Qualification of Processes and Personnel) states Contractor shall assure that special processes such as welding, heat treating, and nondestructive testing are controlled in accordance with applicable codes, standards, specifications, etc., and that special processes are accomplished by f qualified personnel using qualified procedures." l l l L
\\ = The alleger further contends that the Pullman QA/QC Manager's determination was a..." hopeless rationalization by the QA/QC Manager to cover up a serious breach in the Quality Assurance requirements for special processes as required by 10 CFR 50 Appendix B and PG&E C.S.
- 8711.
B. " Pullman Power Products' Unscheduled Internal Audit #34 of 254 Valve Wall Thickness Data Reports found that traceability of the thickness readings obtained could not be assured as required by ESD 236.4.1 and that traceability for certification of equipment calibration from the manufacturer or any calibration organization could not be { assured as required by ESD 236.4.2. The Valve Wall Thickness Data j Reports did not provide the proper information necessary for ( I traceability. The more significant Quality Assurance Discrepancies are listed below: 1. "None of the 254 Data Reports audited listed the size, shape, or type designation (manufacturer's designation or description) of the transducer used to perform the valve wall thickness measurement as required by ASTM E114-63.6.1.2 (referenced in ESD 236.3.2 and 5.1)." 2. "Most of the Data Reports do list a transducer serial number but ESD 236 Documentation Packages do not provide any information or description for transducers by serial number." 3. "Seven Data Reports do not list a serial number of the UT thickness tester used to make the measurements." 4. " Nineteen Data Reports did not list the testing frequency or nominal frequency of the transducers used to make the inspections." 5. " Nineteen Data Reports list both the Nortec NDT-120, SN#12224, and the Branson Sonoray Model 303B, SN#18060, as the UT thickness tester used to make the valve measurements. But there is only one set of . calibration information and valve body wall measurement results for each Data Report. The actual UT equipment used to make the valve measurements cannot be determined for the purpose of traceability." 6. "Two hundred and seven Data Reports referenced serial numbers for UT thickness tester equipment that could not be traced to documentation for certification of equipment calibration from either the manufacturer or any other calibration organization as required by ESD 236.4.2." 7. " Fourteen Data Reports do not list serial numbers for the micrometers used to check the calibration accuracy on the valves by a mechanical means. The micrometers used to make the valve measurements cannot be determined for the purpose of traceability." 8. "Eighty four Data Reports referenced serial numbers for micrometers that could not be traced to documentation for certification of ) equipment calibration from either the manufacturer or any other calibration organization as required by ESD 236.4.2." j i ___________J
9. "Six Data Reports do not list any information concerning the step-wedge blocks used for calibrating the UT tester equipment." 10. " Eleven Data Reports do not list pre or post operation calibration information." 11. " Forty two Data Reports indicated the valves as below the minimum allowed wall thickness but the Data Report forms were signed in the j item #7 space that indicated the valves were physically marked as acceptable." 12. "Many Data Reports were found to have original information whited out and new information inserted. There are no signatures of persons making the changes or explanations for the changes." 13. " Eleven Data Reports did not have a complete measurement inspection of all areas of the valves as required by the procedure. There is no documentation authorizing the incomplete measurements." 14. " Fourteen valve locations, listed by Westinghouse Letter #PG&E2080 to be measured, had no documented evidence (Data Reports) of being UT examined." 15. "Two of the 20' valves physicaly checked had serial numbers that did not match the Data Report serial numbers." C. "There is no documented evidence in the ESD 236 Documentation Packages that M.W. Kellogg (Pullman Power Products) or PG&E complied with (the] A.E.C. requirement: In certain instances, you may wish to repair valves found to have wall thickness below the specified minimum. In such instances, you are requested to provide to this office for our review the proposed repair procedure, including a description of techniques to be used to verify the acceptability of the repaired components." 1. "There are 47 Data Reports that indicate that valves were below minimum wall requirement. U.I.A. #34, A.A.R. #8 identified two valves (Locations #2-PCV-455A and 42-PCV-455B) that were weld repaired to meet minimum wall requirements. But the ESD 236 Documentation Packages do not specify which of the valves were weld repaired. It is an item of concern, that the KRC should investigate, as to which valves were weld repaired or renlaced." 2. "The ESD 236 Documentation Packages do not provide any informat3on as to the weld procedure. sed to weld repair valves in Locations
- 2-PCV-455A and #2-PCV-45sJ and any other valves that might have been weld repaired. There is no documentation available that assures that the A.E.C. reviewed and approved the weld procedures used or the description of techniques used to verify the acceptability of the repaired valves. The NRC should determine what valves were weld repaired; if the weld procedure used was acceptable; and if the technique used to verify acceptability was adequate."
\\ l l l l l
s \\ D. "The Westinghouse supplied " pressurizer safety valves" (reactor coolant pressure boundary valves) do not comply with PG&E C.S. #8711 Section 2.2.1 Code requirement to be designed, manufactured, and fabricated to i ANS B31.1." Commentary on Statement D. "PG&E Construction Specification (C.S.) #8711.2.2.1 states The reactor coolant piping and pressurizer surge lines of the reactor coolant systems have been designed, manufactured, and fabricated to ANS B31.1 with { applicable Nuclear Code Cases and will be furnished by Westinghouse. C.S. #8711 Section 2.1 and 2.16 states reactor coolant system except for main coolant loops and pressurizer surge line are to be designed, { fabricated, and erected per ASME Boiler Code Section I." AEC Letter of 6-20-72 states: "Specified Minimum Wall Thickness", as used above, means the wall thickness required by the relevant codes and standards (e.g. ASA B31.1 (1955); USAS B31.1.0 (1967); USAS B16.5; MSS-SP-66) in effect on the date of the purchase order". Westinghouse Letter PG&E 2080 of 7-25-72 states: " Note that the pressurizer safety valves for Diablo C.anyon Units 1 and 2 were designed to meet the requirements of Article 9 of the ASME Boiler and Pressure Vessel Code, Section III (1968 Edition). The valves were not designed to meet the minimum wall thickness requirements of ANSI B16.5". 1. The apparent nonconformance of Westinghouse supplied " pressurizer safety valves" (reactor coolant pressure boundary valves) to PG&E C.S. #8711 Code Requirements indicates noncompliance to 10 CFR 50 Appendix B Section III Design Control, Section IV Procurement Document Control, Section VII Control of Purchased Material, Equipment or Services, and Section XV Nonconforming materials, Parts or Components. This Statement was completed March 6, 1984. 4 h, l,, .>Trank(A. Casella Technical Reviewer _.------J
rw IA se nud Task: Allegation or Concern No. 122 %lh$ ATS No: RV-83'-074 BN No: D V/ l r-3 a farv "2 1 L L L% u Characterization: l l i Some nondestructive evaluation (NDE) procedures used by Pullman were not i properly qualified. One procedure was issued after inspections were i performed. Pullman did not report difficult problems to PG&E, and the quality assurance (QA) system did not implement adequate or timely corrective actions for audit discrepancies, t Implied Significance to Plant Design, Construction or Operation i Lack of approved NDE procedures or use of nonqualified NDE procedures for l l inspecting pressure boundary welds, fasteners, or'other retaining devices ) implies unreliable inspection and reduces confidence in the effectiveness of l primary pressure boundaries. Inaccurate or untimely corrective actions to j quality assurance audits may indicate a breakdown in the quality assurance i program. I i Assessment of Safety Significance i The alleger is an ex-employee of Pullman Power Products who, in his role as l internal auditor in the QA group, performed a quality audit in January 1982, of various NDE work accomplished from 1972-1973. The alleger was concerned j that the audit findings were not properly addressed by his employer, in their grY W h
) ~o i response in March 1983 that they were not addressed in a timely manner. The i findings are itemized as issues in this allegation. The steff's approach to resolving these issues was to examine the Pullman quality assurance audit report provided by the alleger, examine the Pullman response to each audit finding, assess whether the response was adequate, and assess the significance of each audit finding and response. The licensee commented on the allegation by letter on February 29, 1984; and further reported by telcon on March 8 and-9, 1984. These comments were also examined: A. A Pullman Internal Audit (No. 101) discovered five NDE procedures and two UT thickness measuring procedures that did not have Procedure Qualification Records (PQRs). The NDE procedures were Engineering Specification Diablo (ESD) 234, 241, 246, 247, and 270. The ultrasonic thickness (UT) measurement procedures were ESD 236 and 244. The alleger is concerned that these discrepancies were not adequately or promptly corrected. Staff findings: The procedure titles are identified as: ESD 234 - Ultrasonic Inspection of Groove Welds ESD 241 - Ultrasonic Examination of Safety Yoke Rods on 3707RAXG-21 i Safety Valves i ESD 246 - Magnetic Particle Procedure / Dry / Continuous Coil B31.7 4 ESD 247 - Magnetic Particle Procedure / Dry / Continuous Coil B31.1 1 l l
- 4..,
.l a . ESD' 270 - Liquid Penetrant. Examination Procedures,-' AWS for pipe rupture restraints ESD 236 and ESD 247 - Ultrasonic thickness measurement: 1 The staff finds that there are no technical problems with the corrective '{ action taken by' Pullman. However, corrective action was not prompt,_and-this problem is addressed in item 10. Procedure qualification tests and reports were required for each of the five NDE procedures, ESD 234, 241, 246, 247 and 270. The UT procedures, { ESDs 236 and 244, did not require PQR's as they were not special: I processes ' and their procedures were actually qualified each time a test was made. This issue on UT procedures was completely addressed and resolved under item A of allegation number 121.- Pullman responded to the internal audit issues dealing with ESD 234, 246 and 247 by performing procedure qualification tests. ESD 234 PQR is dated October 1, 1982, ESD 246 and 247 PQR's are dated November 9, 1982. In each case procedure qualifications were performed satisfactorily, ( indicating the procedure was fully capable of detecting specified discrepancies, i Pullman responded to the lack of a PQR for ESD 270 by stating it was t similar to ESD 210, which had a PQR, and that ESD 270 would be revised to
s .o add the PQR from ESD 210. It has been subsequently determined that ESD 270 was never used. The details concerning ESD 241 are discussed in item B below. ~ B, There are a number of related allegations concerning ESD 241 (ultrasonic examination of safety yoke rods on 3707 RAX 6.21 safety valves): B1. There was no PQR. B2. The procedure was issued after inspections performed by the 1 procedure were completed. B3. The threaded portions of the rods were engaged in the atting hole during the test while a Dresser instruction specified that they not be. B4. The rods were not dye penetrant (PT) testing or MT tested as recommended by Dresser and an internal Kellogg memorandum that was based on the Dresser recommendation. B5. The Dresser and ESD 241 procedures differed in reference points for sensitivity determination. B6. The test reports lacked the following information entry surface, 1 calibration block description, calibration method, and calibration i frequency. 1
) { B7. The test reports did not follow the format referenced in ESD 241. ] l B8. In addition to these technical issues, it was alleged that Pullman i QA/QC did not properly responded to this audit finding.; A memo attached to Audit Action Request (AAR) Number 1, dated January 13, 1983, states that ESD 241 is a special procedure to supplement PG&E and manufacturer's examinations. The memo further states that a nonconformance does not exist and a Deficiency Report (DR) is not necessary. "A written response indicating this will be considered basis for closing this portion of AAR." It was alleged that this action constituted a cover up of serious breach in the QA program. Staff Findings: This issue does not fall under the purview of the Pullman QA system. Dresser Industries, manufacturer of the steam generator safety valves, requested that PG&E perform UT inspections on yoke rods to assure certain discontinuities were not present. They requested that the tests be performed to Dresser procedure DC-66-3050-27-2. PG&E engineering complied and sent engineering instruction SP-52-166 to initiate the work under the Dresser procedure by Pullman. Pullman performed the work and supplied the data to Dresser. I This explains the lack of an internally generated procedure prior to tests being peric;wed. ESD 241 was subsequently generated to narrow down the Dresser procedure, which was much broader in scope, in case it was ever needed again by Pullman. It was further determined as the procedure
j ^ \\ J was being documented that a PQR was not necessary because the procedure was qualified each time the equipment was calibrated. The standard manufactured for the test contained a sample notch and flat bottomed hole that defined acceptance criteria, and that standard was used for setting system sensitivity and gain at each calibration. Although the inspector has determined that allegation item B is not a j i safety concern parts B1 through B8 are addressed for the record: Bl. There was no PQR necessary, the test was qualified for ability to detect the unacceptable discontinuity each time the instument/ transducer system was used to test a rod. B2. ESD 241 was not called out for use in the test, it was merely formalized for future Pullman use after the Dresser initiated testing was completed. B3. The Dresser instruction was a production test procedure. The valves were tested at DCNP after assembly. The Pullman Level III examiner responsible for the test determined that inspection with fasteners inserted would in no way compromise the accuracy of the inspection. The staff agrees with this conclusion. B4. The PT and MT requirements of the Dresser instruction and subsequent Kellogg memo were considered to be trivial compared
ii-j to the sensitivity of the UT inspection, and therefore not t i 'done. This is not a violation of ESD 241. \\. B5. The allegation is'true - ESD 241 required two reference ( 1 sensitivity points while the Dresser instruction required only one. The difference was in a more conservative direction. i B6&B7 The documentation information and format did not comply with ESD 241 requirements because they were done to the Dresser procedure. B8 In light of the information presented above, the memo attached to AAR number one can be seen to be valid - there was no nonconformance, no DR was necessary. I 1 The staff concludes that there was no " cover up," nor was there C( i i " serious breach" in the QA program. The staff further considers that the Pullman response for the allegees deficiency report was proper. C. Only two of the reven ESD's identified as not having PQRs were reported to PG&E by DR for disposition. Pullman did not meet their spec.ification requirements to report all the conditions adverse to quality to PG&E. Staff Findings: Pullman assessed the findings of the audit and decided i only two procedures out of the seven cited constituted possible problems
to quality assurance. The inspector agrees that ESD 246 and 247 were the only procedures where a lack of PQR's would have any significant effect on safety or quality, and that Pullman's discussion is reasonable. D. DR 4662 identified the lack of a PQR for ESD 246 and 247 to PG&E. PG&E accepted all work examined by ESD 247 "as is" but did r.ot accept any work performed under ESD 246. Staff Findings: There was no work performed under ESD 246. The Level III examiner that developed ESD 247 developed similar ESD 246 simultaneously, but ESD 246 was never used. Thus, there was no need to accept any work performed under this procedure. E. NDE procedures that had PQRs performed after the inspections were completed did not have approval signatures by Pullman or PG&E management. Staff Finding: The PQRs were signed-off by a Pullman employee certified to ASNI NDE Level III, but were not approved by Pullman and PG&E management. Subsequent to audit 101, these procedures were reviewed and signed off by required management. Additionally, all NDE records were reviewed for proper approval and signatures. Pullman's response here is adequate. F. Concerning ESD 247, the MT procedure was written to ASME code B31.1 to inspect feedwater piping designed to ASME Section I.
'6 Staff Findina: There is no discrepancy here. ASME Section I has no requirement for NT of pipe welds (PART PW SECT I, 1967-78 edition). The NDE requirements of ESD 247 thereby exceeded the requirements of the design code. G, A magnetic particle inspector's certification records were incomplete - the composite NT examination grade was not supported by documentation of the three individual examinations. Staff finding: Although the qualification certification sheet had spaces l for general, specific, and practical exams, the revision of SNT-TC-1A in effect at the time the work was accomplished did not specifically require these individual exam grades. Hoveover, an analysis by the inspector of various combinations of individual exam grades using both simple and weighted averages shows that a composite score of 98 percent could not have been achieved if any individual score was below the passing level of 70 percent. i PG&E searched the certification records and found the exams that this NT inspector had taken. His scores were: General-100 percent, Practical 93.3 percent, Specific 200 percent. A weighted average of T these score is 98 percent. H. The procedure qualification tests (PQT) for ESD 246 and 247 were performed using different equipment than was used during the inspection. l
Staff Finding: The machine used for the actual test was a KH-15, with a 1000 amp capacity. The PQT was done with a P-90, with only a 700 amp capacity. The equipment used for the after-the-fact PQTs supplied less current than did the original equipment. Since direct current dry MT penetration and sensitivity is a function of amperage, the PQT could not have been more accurate or sensitive than the original test. The Pullman response by Discrepancy Report (DR) 4662 is adequate, the original tests were qualified by these PQTs. I. The use of seven unqualified procedures puts the work examined into a questionable status. Can NDE procedures be qualified after they are used? Staff finding: Obviously it would be more desirable to qualify a procedure prior to use. In cases where this was not accomplished, post inspection qualification does validate a procedure. If the post inspection qualification test were to indicate problems, a modified procedure would need to be written, and all applicable inspection would have to be repeated. J. Internal audit (IA) 101 Audit Action Request (AAR) #1 findings were not t corrected promptly. The QA/QC Manager is alleged to have deliberate 1v procrastinated on these findings to avoid identifying problems to management for which he could not formulate proper corrective action. It i is further alleged that the Pullman Corporate Director of QA failed to expedite corrective action after he became aware of the delay.
'+ .4 Staff Findinas: The inspector agrees that the alleger's concern over the lack of a prompt response to AAR #1 is valid. The chronology of events presented in the allegetion is accurate. The QA/QC Manager admits that this was not given appropriate priority; however, he attributes this to each of resources at the time. The inspector notes that the issue were finally dealt with and closed out in March of 1983 and were handled responsibly. PG&E has implemented the following corrective action: PG&E has reinstructed the Pullman QA/QC Manager regarding the desirability and necessity for prompt, effective and adequate response to potentially adverse findings. Ia addition, PG&E has taken action to increase their involvement in the process of supervising their contractor's QA/QC supervision. The final claim of this statement, that the Pullman Corporate Director of QA failed to expedite corrective action, is not true. The alleger left one ' document (on which he was copied) out of the statement and exhibits of this allegation. That document was a memo from the Corporate Director of QA to the QA/QC Manager, dated June 24, 1982, reinstructing Pullman QA people to be more o timely in response to audit findings. Staff Position: 1. There are no technical problems which may have resulted in inadequate or inaccurate NDE testing. I
'i 2. With the exception of the prompt response to the AAR #1 issue in item J, none of these concerns (Items B through J) repretent-a significant irregularity in the control of work. The inspection could not confirm that the delay in resolving the audit was an effort to cover;it up. 3, The Pullman response to-the January 82 audit, completed in March 83, was responsive and appears technically adequate. Action Required: PG&E has initiated corrective action that should alleviate the recurrence of 1 issues similar to item 10. The staff will examine this area in the conduct of the routine inspection program. No further action is required. l l
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