ML20072J409

Responds to NRC 830329 Ltr Re Violations Noted in IE Insp Rept 50-275/83-08.Corrective Actions:Hp Foley Procedure QCP-5A Will Be Revised to Clarify Requirements for Stamping Welds by Welders & Inspectors

ML20072J409
Person / Time
Site:	Diablo Canyon
Issue date:	04/25/1983
From:	Crane P PACIFIC GAS & ELECTRIC CO.
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20072J383	List: ML20072J397 ML20072J409
References
NUDOCS 8306300093
Download: ML20072J409 (4)

Text

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PACIFIC OAS AND E LE C T RI C C O M PANY

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April 25, 1983 Mr. John B. Martin, Regional Administrator US Nuclear Regulatory Commission, Region V 1450 Maria Lane Suite 210 Walnut Creek CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Diablo Canyon Unit 1 Response to Notice of Violation -

NRC Inspection Report 83-08

Dear Mr. Martin:

NRC Inspection Report 50-275/83-08, dated March 29, 1983, included a Notice of Violation (Severity Level IV) . PGandE's response to this Notice is enclosed.

Very truly yours, J y

\ .

/

Enclosure

(

cc: Service List 8306300093 830624 PDR ADDCK 05000275 O PDR _

pGandE's RESFWSE 'IO N(TTICE OF VIOLATION IN NRC INSPECTION REPORT 50-275/83-08 On March 29, 1983, NRC Region V issued a Severity Level IV Notice of Violation as part of NRC Inspection Report 50-275/83-08 on Diablo Canyon Unit 1.

This Notice cited the failum of H. P. Foley, a MandE contractor, to perfom work in accordance with procedures or code requirments and a deficiency in the training program for welders and welding Quality Control Inspectors. The violation was described in the Notice as follows:

[ As a result of the inspectico conducted on February 28 - March 4,1983, and in accordance with the NRC Enforcanent Policy (10 CFR Part 2, Appendix C), 47 FR 9887 (!! arch 9,1982), the following violation was identified:

10 CFR 50, Appendix B, Criterion V, as implenented by Section 17.1.5 of the FSAR and the MandE Quality Assurance Manual Section V states in part that, " Activities affecting quality shall be prescribed by documented instmetions, procedures, or drawings. . .and shall be acccriplished in accordance with these instructions, procedures, or drawings. . ."

The Howard P. Foley Quality Control Procedure for AWS D1.1 Welding, QCP-5A, Revision 8, references in paragraph 2.0 the latest edition of AES D1.1 (the Stmetural Welding Code) as the applicable code for structural steel welding.

AWS Dl.1-1982 in paragraph 3.6.1 states that, "The faces of fillet welds may be slightly convex, flat, or slightly concave as ,

shown in Figures 3.6(A) and (B) with none of the unacceptable profiles shown in Figures 3.6(C)", and in paragraph 8.15.1.3 that, "All craters are filled to the full cross section of the weld."

AE D1.1-1982, "Camentary on Structural Welding-Steel", paragraph 6.5,

" Inspection of Work and Records", states in part that, " Die stamping of welds is not reccrriended since die stamp marks may fom sites for crack initiation."

The Horard P. Foley Quality Control Procedure for AWS D1.1 Welding, QCP-5A, Revision 8, states as follows:

paragraph 5.2, "Each welder shall be assigned a unique numbered and lettered identification stamp."

paragraph 5.2.1, "Each welder shall stamp his identification number in the proximity of his weld, in sufficient quantity to effectively identify his work."

paragraph 9.1, " Welds shall confonn as closely as practical to design requirenents and exposed faces of welds shall be reasonably smooth and regular."

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• paragraph 11.1, "Each welding inspector shall be assigned a unique I.D. stamp."

• paragraph 11.1.1, "Each welding inspector will stamp in i

. sufficient quantity to identify the accepted work."

• paragraph 11.5.1.4, " Fillet welds may be 1/16 inch undersized,

' providing that the undersized portion does not exceed 10% of

(

the total length of the weld."

• paragraph 11.5.1.7, '*Ihe weld shall be clean and free of -

slag." ]

Contrary to the above the NBC Inspector found several procedtral violatims at the 182' elevation of the Unit 1 Fuel Handling Building. These violations concerned welder and Inspector identification stamps and weld deficiencies.

The violations were listed in a table and the Notice concluded with the following:

[ All of the above welds had been examined and accepted by H. P. Foley's Quality Control Inspectors on or before February 7, 1983.

This is a Severity Ievel IV violation (Supplanent II). ]

Statement of Explanation

' The H. P. Foley Company has in place approved procedures which delineate the responsibilities and methods required to execute and verify specific activities which affect the quality of components, equipnent, material and services requiring Quality Assurance.

Regarding the NRC Inspector's finding on the stamping of the welds, the Code (ASW D1.1) does not require the welder's identification stamp but does require the Inspector's stamp. The contractor's procedure (QCP-5A), however, requires that both the welder's identification stamp be affixed in the proximity of his weld "in sufficient quantity to effectively idatify his work", and requires that the Inspector's identification stamp be affixed "in sufficient quantity to identify the accepted work".

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' Six welds were identified as having no welder identification stamp or weld inspector's identification at each weld. We believe the requirenents of AWS D1.1 and procedure QCp-5A were interpreted too strictly. Neither the code nor the procedure require a weld inspector's stamp for each weld.

The welds on the connections in question were so closely spaced that one weld inspector's identification stamp would be sufficient to identify the acceptance of all the welds in the welded connectial.- In the cases noted,

. the identification stamp serves only as tenporary traceability because the welded connections are painted upon final acceptance of the weld. 'the welder and the weld inspector are presently traceable to each weld by the Work Traveler and the Weld Inspection Sheets. These are retained as a lifetime document at'the plant. Neither the code nor the procedire explicitly state the meaning of " sufficient quantity". The contractor's procedure will be revised to provide a more consistent criteria for welders and l inspectors to follow.

Regarding the NRC Inspector's finding on the acceptability of the welds, PGandE has determined that certain corrective actions are appropriate.

These are described in the following sections, f - . - - -- _ .- -.__ _ , _. _ _ , _

l l

I Corrective Steps Taken and Results Achieved PGandE initiated a discrepancy mport imediately upon confimation of the weld discrepancies noted by the Region V Inspector on March 4,1983. In addition, the Quality Control Department perfomed an expanded inspection aimed at detemining the extent of occurrence of similar discrepancies. As a result of this inspection, Nonconformance Report No. DOO-83-RC-N001 has been issu3d.

Corrective Steps Which Will Be Taken The following are the corrective steps which will be taken:

1. H. P. Foley Procedure QCP-5A will be revised to clarify the requirenents for stamping of welds by welders and inspectors.

2. Training of H. P. Foley Welders and Quality Control (QC)

Inspectors will be reviewed and additional tmining conducted to assure familiarity with inspection requirenents.

l 3. A reinspection of 10% of the completed welded connections l

for the Unit 1 Fuel Handling Building modifications shall be conducted. The results of the reinspection will be documented and attached to Nonconfomance Report No. DCO-83-RC-N001.

4. Filler metal shall be added to the identified undersize welds as required to neet design and weld pmfiles in accordance with AWS D1.1.

5. The craters identified at the weld end temination will be removed by grinding and additional filler metal added where required.

6. Slag will be removed where identified and the weld will be reinspected.

7. In the fillet welds in which the welder had stamped his identification number on the weld, the identification numbers j

shall be removed fmm the weld by grinding. Reinspection will assure that the weld size is acceptable.

8. The fillet weld which was identified as 1/8" undersize shall I have filler metal added as required by design requirements.

Date When Full Compliance Will Be Achieved

- Revision of Procedure QCP-5A will be completed by May 6,1983. -

The review of the training pmgram and additional training of welders and QC Inspectors will be completed by May 6, 1983.

The reinspection and all weld mpair will be completed by May 15, 1983.