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| 4 CoPV PACIFIC OAS AND E LE C T RI C C O M PANY pg g 77 BEALE STREET, S AN FR ANCISCO, C AllFOR NI A 94106 TELEPHONE ( 15 781 4211 N JUL 13 101 :20 m g; ;
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| June 29,1984 Milcp" PGandE Letter No. : DCL-84-243 Mr. Harold R. Denton, Director Office of Nuclear Reactor Regulation U. S. Nuclear Regule. tory Commission Washington, D.C. 20555 f- N Re: Docket No. 50-275, OL-DPR-76 Docket \ )
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| DiabloNo.Canyon 50-323 ouUnits 1 and 2[ .9 b) h l b GAP Allegations
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| ==Dear Mr. Denton:==
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| As stated in our letter DCL-84-239 of June 26, 1984, we are submitting responses to allegations from the Government Accountability Project (GAP) which have not been specifically addressed previously. These allegations are contained in GAP letters dated March 23, April 12, May 3, and May 31, 1984.
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| For each allegation, a unique DCP allegation number has been assigned, as i shown on the indices contained in Attachments 1, 2 and 3 All of the responses have been verified and the professional resumes of the verifiers have either been previously submitted or are attached to the enclosure.
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| Kindly acknowledge receipt of this material on the enclosed copy of this letter and return it in the enclosed addressed envelope. ,
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| Sincerely, l OtlGINAL $1GNED By J. O. Schuyler
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| [ Enclosure cc: D. G. Eisenhut i J. B. Martin H. E. Schierling Service List 9407230101 840629 PDR ADOCK 05000275 C PDR
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| j!
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| . ATTACHENT 1 '
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| INDEX CF ITEMS NOT INCLUDED IN REGION V, April 27, 1984 LETTER
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| ; Attach-ment Page Para. DCP j' No. No. No. Allegation No. Subject i 3/23/84 GAP letter 1 2 1) 111-1 Containment doors.
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| 3 2) III-2 Containment doors.
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| l 3 3)
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| III-3 Not directed at applicant or its contractors.
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| 2 1,2 Entire III-4 Not directed at applicant or its
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| - contractors.
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| 3 1,2 III-4 Not directed at applicant or its l
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| contractors.
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| 3 1) i III-5 Pipe supports non-compliance with App. B 4 2)
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| III-6 Pipe supports non-compliance with App. B 5 8), 9) III-7 Compliance with ANSI N45.2.6 i
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| 6 10) Welder certifications III-8 8 15),16) III-9 Falsification of records '
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| ) 9 20) l III-10 Harassment 10 21) III-11
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| ! Min valve wall thickness 10 22) III-12 Valve thickness test
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| ! 10 23) III-13 Welding i 3 1-2 111-14 i 3 Welding of CCW piping 111-15 Harrassment.
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| i, 4-6 III-16 Not directed at applicant or its contractors.
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| 1 j 1662d I
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| 4
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| ATTACHMENT 1 INDEX OF ITEMS NOT INCLUDED IN REGION V, April 27, 1984 LETTER (Continued)
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| Attach-ment Page Para. DCP No. No. No. Allegation No. Subject 4 2 III-17 1
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| Not directed at applicant or its contractors.
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| 2 5,6 III-18 Rebuttal to PGandE letter regarding small bore piping.
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| 3-7 7-11 III-19 Rebuttal to PGandE letter regarding pipe support gaps.
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| 7-12 12-19 111-20 Rebuttal to PGandE letter regarding pipe support cales.
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| 12-14 20-25 III-21 Rebuttal to PGandE letter regarding pipe support locations.
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| 14-15 26-27 III-22 Rebuttal to PGandE letter regarding pipe support locations.
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| 15-19 28-33 111-23 Rebuttal to PGandE letter regarding pipe support loads.
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| 19 34-35 III-24 Rebuttal to PGandE letter regarding rigid connections.
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| 20-22 36-42 III-25 Rebuttal to PGandE letter regarding U-bolts.
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| 23 43 III-26 Summary statement (not a specific allegation) 23-25 44-46 III-27 Rebuttal to PGandE letter regarding piping sample size.
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| 26 47-49 III-28 Rebuttal to PGandE letter regarding use of foreign steel.
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| 27 50 III-29 Rebuttal to PGandE letter regarding welding / management involvement.
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| 1662d _ _ ___ _ _ _ _ _ _ -
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| ATTACHMENT 1 INDEX OF ITEMS NOT INCLUDED IN REGION V, April 27, 1984 LETTER *
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| (Continued)
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| Attach-ment Page Para. DCP No. No. No. Allegation No. Subject 5 1,2 1) III-30 Rebuttal to PGandE letter regarding welding.
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| 2 2) III-31 Rebuttal to PGandE letter regarding welding.
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| 3 3) III-32 Rebuttal to PGandE letter regarding welding.
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| 3 4) III-33A Rebuttal to PGandE letter regarding welding.
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| 4 1 III-33B Rebuttal to PGandE letter regarding welding.
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| 4 2 III-33C Rebuttal to PGandE letter regarding welding.
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| 4 3 III-33D Rebuttal to PGandE letter regarding welding.
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| 5 entire III-33E Rebuttal to PGandE letter regarding welding.
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| 6 1 III-33E Rebuttal to PGandE letter regarding welding.
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| 6 2 III-33F Rebuttal to PGandE letter i
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| regarding welding.
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| ; 6 3 III-33G Rebuttal to PGandE letter
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| : regarding welding.
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| l 6 4 III-33H Rebuttal to PGandE letter regarding welding.
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| 6 5 III-33I Rebuttal to PGandE letter regarding welding.
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| 7 1 III-33I Rebuttal to PGandE letter regarding welding.
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| 1662d ATTAC E NT 1 INDEX OF ITEMS NOT INCLUDED IN REGION V, April 27, 1984 LETTER (Continued)
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| Attach-ment Page Para. DCP No. No. No. Allegation No. Subject 5 7 2 III-33J Rebuttal to PGandE letter regarding welding.
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| 7 3, 4 III-33K Rebuttal to PGandE letter regarding welding. '
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| 8 5) III-34 Rebuttal to PGandE letter regarding welding.
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| 9 6) III-35 Rebuttal to PGandE letter regarding welding.
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| 9,10 7) III-36 Rebuttal to PGandE letter regarding welding.
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| 11 8) III-37 Rebuttal to PGandE letter regarding welding.
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| 11,12 9) III-38 Rebuttal to PGandE letter regarding welding.
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| t 12 10) i III-39 Rebuttal to PGandE letter regarding welding.
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| 12 11) III-40 Rebuttal to PGandE letter regarding welding.
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| 12,13 12) III-41 Rebuttal to PGandE letter regarding welding.
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| 13 13) III-42 Rebuttal to PGandE letter regarding welding.
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| l 13 14) III-43 Rebuttal to PGandE letter regarding welding.
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| 0 1662d ___ _ _ _ ___
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| ATTACHMENT 1 INDEX OF ITEMS NOT INCLUDED IN REGION V, April 27, 1984 LETTER (Continued)
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| Attach-ment Page Para. DCP No. No. No. Allegation No. Subject 5 13,14 15) III-44 Rebuttal to PGandE letter regarding welding.
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| 14,15 16) 111-45 Rebuttal to PGandE letter regarding welding.
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| 15 17) III-46 Rebuttal to PGandE letter regarding welding.
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| 15 18) III-47 Rebuttal to PGandE letter regarding welding.
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| 15,16 19) III-48 Rebuttal to PGandE letter regarding welding.
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| 16 20) III-49 Rebuttal to PGandE letter regarding welding.
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| 17 21) 111-50 Rebuttal to PGandE letter regarding welding.
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| 6 2 1),2) 111-51 Inspector training.
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| 4 last 111-52 Inspector training certification.
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| 5 enti: s III-52 Inspector training -
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| 6 certification.
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| 1 III-53 Introductory statements. (not a specific allegation) 7 1-5 I 111-54 Rebuttal to PGandE letter regarding CCW welding.
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| 5-7 II III-55 Rebuttal to PGandE letter regarding A-325 bolts.
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| 1662d ATTACW1ENT 1 INDEX OF ITEMS NOT INCLUDED IN REGION V, April 27, 1984 LETTER (Continued)
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| Attach-ment Page Para. DCP No. No. No. Allegation No. Subject 8 1 last III-56 Falsification of records. -
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| l 2 2,3 III-56 Falsification of records.
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| l 2 4 III-57 Falsification of records.
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| ! 2 last III-58 Night Shift high j quality standards.
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| ! 3 2 III-59 Harassment.
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| l 3 4 III-59A Harassment.
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| l 4 3-5 III-60 Harassment.
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| l 9 3 4,5 III-61 Inspector qualification /
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| 3 training.
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| ! 4 1,2,3 III-61 Inspector qualification /
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| l training.
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| 4 5 2 III-62 Illustrative example of NRC 1
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| Allegation #430 6-8 II III-63 Quick fix - drawings control 9-10 IV III-64 Not directed at applicant or its contractors.
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| l 10 3,4 6) III-65 Falsification of QC document
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| { 6 14),15),16) III-66 Hold tags.
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| l t
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| 1662d i
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| i ATTAC E NT 1 INDEX OF ITEMS NOT IHCLUDED IN REGION Y, April 27, 1984 LETTER (Continued)
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| Attach-ment Page Para. DCP No. No. No. Allegation No. Subject 10 7 20),21) III-67 Harrassment.
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| ; 8 22) III-67 Harrassment.
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| 8 23) III-68 Night Shift high quality standards 8 24) III-68 Night Shift high quality standards
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| ., 8 25) III-68 Night Shift high quality standards 8 26) III-69 Night Shift high quality standards l 9 29) III-69A Welding 1 11 2 3,4 111-70 Unqualified welding inspector 4 2 III-71 Inadequate inspector training 1
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| 4/12/84 GAP letter last 1 4 IV-1 Summary Statements i
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| 5 first IV-1 Summary Statements l
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| 1 i
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| .l 4
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| i 1662d <
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| ATTACitqENT 2 INDEX OF ITEMS IN MAY 3,1984 GAP LETTER .
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| -i DCP Alleg.
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| Location Number Subject Stokes Aff.
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| 91 V-1 Inadequate training 1 V-2 Hanger 99-20 2 V-3 Out-of-dato manuals 2 V-4 Sign-off on revision 2 V-5 No signed return receipts 2-3 V-6 No return receipts 3 V-7 Mark obsolete procedures
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| " superseded" 3 V-8 Review of manuals 3 V-9 Documented review 4 V-10 Audited manuals 4 V-11 Review results 4-5 V-12 JP system / resolution 5 Y-13 Gap procedure 5 V-14 Exceptions flagged 6 V-15 Program control 6 V-16 Pipe insulation 7-8 V-17 Quick Fix 8-9 Y-18 Documenting DRs during Quick Fix l 9-10 V-19 Review of hanger l
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| 10 V-20 Instructions to checkers 10-1 V-21 Use of judgment l\
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| 1669d - - - -
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| ATTACl#fENT 2 INDEX OF ITEMS IN MAY 3,1984 GAP LETTER
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| (
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| DCP Alleg.
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| Location Number Subject 11 V-22 Information via phone calls 11 V-23 20 Hz vs 33 Hz 11 V-24 Support stiffness Anon. Aff.
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| "A" 9 1.2 V-25 Vendor welds do not comply with AWS D.1.1 2-6 V-26 Violations of ASTM /AISC codes on bolting requirements (a) oversized holes (b) turn-of-nut tightening (c) calibrated wrench tightening (d) reuse ie) inspection 6-8 V-27 Pullman " rewrote" App. B (a) restricted inspectors (b) lacked authority (c) no freedom Anon. Aff.
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| i "B" 9 l
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| 2 V-28A Pullman ESDs not in conformance V-288 with codes (a) elongated bolt holes (b) stuffed bolt holes 4 V-29 Hara'ssment 4-6 V-30 Not directed at applicant or its contractors.
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| 6 V-31 Not directed at applicant or its contractors.
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| 6-10 V-32 Same issues as Anon. Aff.
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| "A" 9 2-6 y
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| 1669d . .- - - _ - - _ _ -.
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| (
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| , ATTAGlMENT 2 INDEX OF ITEMS IN MAY 3,1984 GAP LETTER i
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| DCP Alleg.
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| Location Nuter Subject Lockert 9 1 V-33 Bolting program for rupture restraints inadequate 2 V-34 ESD 243 doesn't address AISC 2-3 V-35 NCR DC-2-80-RM-002 not addressed 3 V-36 QA breakdown 4 V-37 Should be 10 CFR 21 report 4-5 V-38 Improper resolution (a) Unauthorized weld modifications (b) Oversized holes accepted (c) Oversized holes packed (d) Oversized welds (e) Defective A-490 bolts 6 V-39 ESD 243 (a) Washer table out of date (b) No bolt acceptance criteria (c) Bolt torque tables not in compliance with code 6 V-40 Pullman did not have program for designchanges 7 V-41 Washer criteria improperly issued l 7 Y-42 Improper torque tables 7 V-43 Pullman did not train inspectors l to AISC bolting requirements l
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| 7 V-44 Defects in bolts not reported Parks 1 9 1 V-45 Gouge in accumulator line 3 V-46 Unit 2 support 97-38R -
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| excessive overweld i
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| 1669d l l
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| , ATTACHMENT 2 INDEX 0F ITEMS IN MAY 3,1984 GAP LETTER I
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| DCP Alleg.
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| Location Number Subject Parks 19 (cont'd) 4 V-47 Unit 2 beneath pressurizer -
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| shopweld notto AkS 5 V-48 Unit 2 auxiliary building - CSS lug attachment welds inadequate -
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| excessive shrinkage 6 V-49 Unit 2 auxiliary building -
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| CCW support -inadequate welding Parks 2 9 L
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| ! 1 V-50 1
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| Weld gouge near accumulator i
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| i I
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| l 16694 --. - - . . ._. _
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| l ATTAC%ENT 3 INDEX OF ITEMS IN MAY 31, 1984 GAP LETTER DCP Exhibit Page Para A11ega-No. No. No. tion No. Subject 1 1 1-2 VI-1 Stresses on concrete from Hilti quick bolts 1 1 3 VI-2 Ineffectiveness or the Quick 2 VI-2 1
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| Fix and Quality Control (QC) reporting systems 1 2 2-3 VI-3 Residual stresses unacceptable if bolts embedded too deeply 1 2 4 VI-4 Management insensitivity to 3 1-2 VI-4 bolting problem 1 3 3 VI-5 " Dry pack" solution ineffective i
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| 1 3 4 VI-6 PGandE and Pullman slow to 4 1,2,344 VI-6 resolve problem when identified 2 1 2,344 VI-7 RHR environmental qualification 2 1,2,344 VI-7 Problem #1 2 2 546 VI-8 Problem #2 2 2 7 VI-9 Problem #3 3 1 VI-9 2 3 283 VI-10 Problem #4 1655d -
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| III-1 and 2 It is alleged that:
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| : 1. Shortly after noon on Friday, February 24, the integrity of the containment was breached when an airlock door blew open at the 140 foot level of the main containment in Unit I. All access to the containment is through this entry, which consists of two pressurized airlock doors that can only be opened one at a time. After the first door is closed, employees have to wait in a space between the doors. while the second one is opened.
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| On the morning of the [ illegible or deleted] I was on duty as a security access guard. Since there were too many people coming in and out, I had to back them up. Two employees got stuck inside the airlock when the doors didn't open. [ illegible or deleted] reported the incident to [ illegible or deleted] sergeant, and a PG&E crew arrived around 20 minutes later. The workers who had been stuck were drenched with sweat, because temperatures are high during hot functional testing.
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| Around 45 minutes later the incident happened again; this time four to five guys were stuck inside. Again it took around 20 minutes for the PGAE crew to arrive. Shortly afterward [ illegible or deleted] was transferred to another post.
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| l When [ illegible or deleted] returned to the containment access door in early afternoon, [111egible or deleted] the i
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| containment had been secured and maintenance was at work on the doors. The crews described to me in detail what had l happened. The outer door to the airlock blew open when some employees opened the inside door. There was a i
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| tremendous pressure, described to me by employees who were
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| ! there as like a hurricane. Two fire watches standing near i
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| the outside were sucked clear through the airlock. A security officer was pulled toward the containment from around 15 feet outside the door, but held onto wooden l
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| scaffolding at the entrance. A foreman similarly was
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| !' sucked in but successfully grabbed onto a door jam. A j chair in the entryway flew into the containment at chest t
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| level . The outer door itself, which weighs several hundred pounds, swung open as if on a spring, according to witnesses.
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| l Pacific Gas and Electric (PG&E) officials Mielke and i
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| Thornberry came by to survey the damage. Maintenance employees told me that to repair it they would probably 1611d <-
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| have to borrow parts from Unit II. They explained that the doors are 15 years old and aren't made any more. (3/7/84, Anon. Aff. , Attachment 1, at 2-3.)
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| : 2. Maintenance workers described the cause of the accident to me as shear hin out from overuse. ges on the door which were already worn This concerns me, because the plant has not yet started operation. If the maintenance workers were correct, all safety-related doors should be rechecked to see if they are worn out before the plant goes critical.
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| (3/7/84 Anon. Aff., Attachment 1, at 3. )
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| On February 24, 1984, a maintenance crew was dispatched to Unit 1 to investigate door mechanism problems which had been reported a short time earlier. At or about this time a group of construction workers outside containment had opened the outer airlock door and entered the airlock. When the maintenance crew reached the airlock, another group of construction workers who were inside containment were attempting to open the inner door (the outer door was still open with i
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| l the crew entering the airlock waiting for door repairs). The l
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| l interlock mechanism then failed (pins sheared) which allowed the l inner door to open. Due to negative pressure in containment, the door opened rapidly once it was disengaged.
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| The door interlock mechanism (a device which prevents both doors from being open at the same time) had worn and then failed because of t
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| excessive force being used to open both doors at the same time. The interlock mechanism was repaired. Operation of the airlock doors has subsequently been controlled by designated door operators. This prevents personnel from trying to open one airlock door when the other is already open. As far as door hinges are concerned, the 1611d ! . . -_
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| l l
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| doors' structural integrity was not degraded or damaged. Since the problem was with an interlock mechanism, not the door itself, no further action to other safety-related doors was deemed necessary.
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| This event was covered by Nonconformance Report (NCR) DCl-84-0P-l*043, 1611d i
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| l III-5 It is alleged that:
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| : 1) I am particularly concerned that until at least 1982 l
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| t Pullman's program for pipe supports and pipe rupture restraints did not comply with 10 CFR 50, Appendix 8. I cannot understand why the NRC would not have covered this issue in Report 83-37, since that is what the NRC is all about. Presumably there should be some effect if the NRC's reccennendations are not part of the picture. In a previous affidavit I recalled how on several occasions Mr. Karner told me that we didn't have to comply with 10 CFR 50, Appendix B.
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| Mr. Karner was thoroughly familiar with company policy.
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| The official excuse was that Pullman's program complied with Section Three of the American Society of Mechanical I Engineers (ASME) 1971 code requirements, which are consistent with 10 CFR 50, Appendix B. (See June 13, 1978 audit, enclosed as Exhibit 1, at p 2.) 1Fe~ problem is that the ASME code did not cover pipe supports and rupture restraints. That left us on our own.
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| While PG8E paid general lip service to Appendix B, it did not enforce that policy on us through contract requirements. An October 13, 1977 Pullman memo on the NSC audit (Exhibit 2 at p. 2) explained, "We have not been required by PG&E to update to Appendix B." An unsigned, undated draft report on the NSC audit (Exhibit 3) explained further: "No attempt, however, was made to totally revise the program to incorporate specifics of 10 CFR 50, Appendix B." On page 9 of the draft, the author implies NRC approval for failing "to update the program to match Appendix 8...."
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| (3/22/84 Hudson Aff. at 3-4. )
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| i Strict compliance with 10 CFR 50, Appendix B, is not a licensing requirement for the design and construction of Diablo Canyon, Unit 1. As has been stated by the Appeal Board in this proceeding:
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| "The Commission's predecessor, the Atomic Energy Commission, recognized in promulgating Appendix B in 1970 that the nature of the construction process for a plant already being built, such as Diablo Canyon, Unit 1, precluded the complete and immediate application of the quality assurance criteria. In the Statement of 1414d .-- - - - - . - - - .
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| Considerations accompanying the final version of Appendix B, it stated that the criteria would be 'used for guidance in evaluating the adequacy of the quality assurance programs in use by hol permits and operating licenses.'g'grsTherefore, of construction contrary to the movants' suggestion, the applicant was not required to conform the construction quality assurance program for Unit 1 to Appendix B, upon the provision's effective date. Moreover, the applicant's comitment in the Final Safety Analysis Report (FSAR) to apply the Appendix B criteria to the extent possible for the construction of Unit I was completely reasonable." (ALAB-756 Sli December 19,1983, at 21.) p Opinion dated The PGandE Unit 1 QA program and the programs of all its contractors meet the intent of 10 CFR 50, Appendix B, to the extent possible, as is described in Chapter 17 of the FSAR.
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| Pipe supports and rupture restraints are erected to Pullman Precedures ESD 223 and ESD 243, respectively. These procedures provide detailed installation methods and acceptance criteria as required by 10 CFR 50, Appendix B, Criterien V. The remaining criteria of 10 CFR 50, Appendix B, are addressed in the Pullman Corporate QA Manual (although not in a criterion-by-criterion manner) and in the other ESDs that are fully applied to all phases of the pipe support and rupture restraint program. The contract requirements for the QA program for pipe supports are delineated in PGandE Specification 8711, Section 4, and for rupture restraints in PGandE Specification 8833XR, Section 3.
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| 1414d . - _ - . _ - -- . . - . - _ . . . - - _ _ _ . . - - _ - - - - . - . . .
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| It can therefore be seen clearly that the lack of strict compliance with 10 CFR 50, Appendix B, is not a violation of any rule, regulation, or commitment and does not, in any way, result in a decreased level of quality at Diablo Canyon.
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| J l
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| l 1414d I
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| i III-6 It is alleged that:
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| : 2) After conceding the problem of not meeting 10 CFR 50, 4pendix B, Pullman chose to perpetuate it. A November 3, 1978 program description (Exhibit 4) did not have any references to 10 CFR 50 in the charts and attachments for pipe supports and pipe rupture restraints. The ESD's
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| [ sic], or installation procedures, are the only guide for the QA program. (Id., Chart #3 and Attachment 3-1.)
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| i (3/22/84 Hudson A(TT at 4.)
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| As stated in the response to Allegation III-5, all requirements of 10 CFR 50, Appendix B, have been addressed in the pipe support and I
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| rupture restraint programs. The ESDs are not a guide for the QA program. Instead, they are an integral part of the QA program and their implementation, in conjunction with the Pullman Corporate QA Manual, meets the intent of 10 CFR 50, Appendix B.
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| t 14184 1
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| - . - _ . ~ . , .,- ._ .- ~__ ... . - . . . . ,_ . . - . . - __ _ _ . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ - _ _ _ _ . _ .
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| III-7 It is alleged that:
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| l
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| : 8) In Report 83-37 the NRC accepted uncritcally [ sic] PG&E and Pullman's position that Nondestructive Examination (NDE) personnel have met the American National Standards Institute (ANSI) N45.2.6 requirements since 1973 or 1974.
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| That is false. Management has recognized a problem since 1973, but as of July 1982, they had not upgraded the program to comply with ANSI N45.2.6. In the meantime, various managers reconnended commitments to henor ANSI, but it simply did not happen. For a December 1974 example of 1 the recommendations, see enclosed Exhibit 8. The Pullman l QA manager's July 1982 refusal to honor ANSI N45.2.6, is enclosed as Exhibit 9. Don't forget again, even ASME compliance would not cover the entire QA program, since ASE does not address pipe supports and rupture restraints.
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| : 9) The reason Pullman didn't meet the ANSI requirements is that it was not willing to pay for the experienced personnel required under the professional code. As Pullman's QA manager explained in a May 13,1975 memo (Exhibit ID), "[I]t is virtually impossible to comply totally to N45.2.6 because of experience requirements. We cannot hire personnel that meet the experience requirements for the salary scale we offer." (3/22/84 Hudson Aff, at 5-6.)
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| l ANSI N45.2.6 states that NDE inspectors "need only be certified in
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| ; accordance with the requirements specified in SNT-TC-1A and l
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| l supplements" (S* ANSI N45.2.6-1973, paragraph 2.2 and 1978, paragraph 1.2, attached as Exhibits 1 and 2, respectively.) Pullman I
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| NDE inspectors at Diablo Canyon have always been certified in accordance with the guidelines of SNT-TC-1A. ESD 235 was written to l follow the guidelines of SNT-TC-1A and all NDE personnel have been certified in accordance with this procedure. A certification program for NDE inspectors that complies with SNT-TC-1 A automatically l complies with ANSI N45.2.6. Certification to SNT-TC-1A is adequate l 1419d :
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| 4 for any NDE inspector to perform NDE on pipes, pipe supports, and rupture restraints.
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| In regard to the quote from the May 13, 1975, memo, Mr. Hudson once again has picked a statement out of context to buttress his unsupported allegation. He has left off the following two sentences of the quote which show his concern in a true light. The sentences are:
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| Even if the money were available, it would be difficult to find qualified people. We are taking the approach of a " qualification based on performance" in
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| ; a specific job.
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| l r Thus it can be clearly seen that: (a) The problem was not I Pullman's. At this time, there was just a shortage of qualified personnel in the industry. (b) Puilman then chose to follow an alternate course of action which is considered acceptable by the applicable standard, ANSI N45.2.6.
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| l 1419d ,
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| \
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| Exhibit 1 of Response to III 7 CUAI.tFICATIONS OF IN!PECTION, EX AMIN ATION. A*,D *ESTi ,G PER3GNNEL FOR TFE CONSTRUCTION PHASE OF NUCLEAR POWER PLAr.TS AN31 N45.2 61973 1.4 Definitions rnents by subjeetmg the item to a set of physical.
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| The following definition: are provided to assure chemical, environmental or operstmg conditions.
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| a uniform understanding of se:ected terms as they are Other terms and the:r definitions are contained used in tius standard. in ANSI N45.2.10, Quality Assurance Terms and Certiffcation (Personnel)-The action of deter. Dennitions.
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| snining, verifying, or attesting in writing to the qualifi.
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| cations of personnel. 1.5 Referenced Documents Construerion rhast- A period which commences Other documents that are required to be in.
| |
| with receipt ofitems at the construction site and ends c!uded as a part of this standard are eitheridentified when the components and systems are ready for turn. at the pomt of reference or described in Paragraph 6 over to operations personnel. of this standsri The issue er edition of the referenced document that is required will be specified either at Contractor-Any individual or organization en. the point of reference or in Paragraph 6 of this tering into a contract to furmsh items or ser ices to a standard.
| |
| purchaser. The term contractor includes the terms Vendor, Supplier, and Subcontractor or sub. tier levels of these where appropriate.
| |
| : 2. GENERAL REQUIREMENTS Eremination-A critical investigation of items by nondestructive methods. 2.1 Planning Inspection- A phase of quslity et ntrol which bv Plans shall be de$ eloped for assigning or staffing means cf examination, observation or messuremen't and training an adequate number of personne to per.
| |
| determines the conformsnee of rnsterials. suppines, form the required inspections.examinscions and tes:s components, parts, appurtenances. systems, processes and shs!! reflect the schedule of project activity so as or structures to predetermined quality requirements. to allow adequate time for assignment or selection and trsimng of the required personnel.The need for formal Irem-Any level of unit assembly, including taning programs shall be determmed. and such train.
| |
| structures, system, subsystem. subassembly, com. Ing activitie. shall be conducted as required to qualify ponent, part or material. personnel responsible for inspection. examination,and Owner-The person, group, company, or cor. testing; and other appropriate technical support per.
| |
| portation who has or willhave title to the facility or m. sonnelwhose work can directly or indirectly affect the stallation under construction. quality or reliabihty of those items delineated in the Proitet-A planned series of activities including all actions necessary to provide, utilize and maintain a 2.2 Certifica: ion facility or a portion thereof.
| |
| Esch persen who verifies conformance of work Qualifications-The characteristics or abilities activities to quality requirements sha!! be certified tv gained through training or experience or both that en.
| |
| his employer as being qualified to perform his $-
| |
| able an individual to perform a required function.
| |
| signed work. This certification sha!! be supported by l Quality Assurance-All those planned and sys. appropnste measures such as education or traming.
| |
| I tematic actions necessary to provide adequate con. tes:mg evaluation. and periodic review to assure3 the fidence that an item or a facility will perform satis. iniust and continued pronciency of each person.The factorily in service. effective period ofcertifiestion shall be established and at the end of the effective period of certifiestion',esch Quality Control-Those quality assurance ae.
| |
| tions which' provide a means of control and measure individus! shall be reeertified in accordance with the req :irements f this standard. Personnel mvolved in i the characteristics of an item, process or factlity to established requirements. the performance, evaluation and supervision of non.
| |
| de:tructive examinstions need only be certified in ac.
| |
| Testint-The determinstion or verification of cordance with the requirements specified m SNT.TC.
| |
| l the espabihty of an item to meet specified require. l A' and supplements.
| |
| 'SNT.TC.I A and Suppiesnents, " Recommended Pracine toe Nondeservestve Testing Personnei Quahricatmn and Cereir,.
| |
| y 7 pgg q g m.8 P og een n ,6 .e4 er ine society for Nondesirwine 1.siins, quired y shall m. elude mdoctrination of personne!
| |
| * te chieseo Avenu, Evansion, manon oo:os. with th c:hnics! objectises of the project; the codes 2
| |
| | |
| Exhibit 2 of Response to III 7 Page 1 of 5 ANSUASME N45.2.6-1978 J
| |
| AMERICAN N ATION At. STANDARD QUALIFICATIONS OF INSPECTION, EXAMINATION AND TESTING PERSONNEL FOR NUCLEAR POWER PLANTS J
| |
| : 1. INTRODUCTION This Standard is to be used in conjunction with ANSI N45.2.
| |
| 1.1 Seepe e requirements apply to personnel of the This Standard delineates the requirements for the
| |
| , owners, architect engineers, nuc!:ar power plant sys-qualification of personnel who perform inspection, tem designers and system suppliers, plant designers examination, and testing to verify conformance t and plant constructors, equipment supphers, outside specified requirements of nuclear power plant items testing agencies, and consultants. The ASME Boiler (structures, systems, and components cf nuclear and Pressure Vessel Code, as well as other ANSI Stan-power plants) whose satisfactory perfonnance is rc.
| |
| dards, have been considered in the development of quired to prevent postulated accidents which could the Standard, and this Standard is intended to be causs. undue risk to the health and safety of the pub-compatible with their requirements.
| |
| lic; 0: to mitigste the consequences of such accidents
| |
| - if they.were to occur. The requirements may also be extended to other items of nuclear power plants '
| |
| when specified in contract dccum:nts.
| |
| 1.2 Applicability It'is the responsibility of each organization par-The requirements of this Stand'ard apply to person- ticipating in the project to assure that only those per-nel who perforrn inspections,' examinatiores, and tests sonnel within their respective organizations who meet
| |
| . during fabrication prior to and dsirs r: cent ofitems - the requirements of this Standard are permitted to at the construction site, during ca.istruction, during perform inspection, examination, and te: ting activities preoperational and startup testing, and dwing opera , covered by this Standard thatyerify conformance to tional phases of nuclect power plants. The require- quality requirements.
| |
| ments of this Standard do not apply to persannel who - De organization or organizations responsible for perform inspections for government or municipal establishing the applicable requirements for activities authorities, or who perform as authcrized inspe:to s ; covered by this Standard sha!Lbe identified and the in accordance with the ASME Boiler an't Pmsure scope of their responsibihty. shall be documented.
| |
| ~ '
| |
| Vessel Code. The work of establishing selectica and training prac-The requirements of this Standard are not intended . tices,and qualification procedures and of providing to apply to personnel who only perform inspection, the resources ja terms of personnel, equipment, and examination, or testing ir accordance with ASNT services necessary to imple:nent the requirements of
| |
| -"Recommended Practics No? SNT-TC-1 A", since this Standard /may be delepttti to other qualified or-sanizations and such delegations shall also be docu.
| |
| ~
| |
| these personnel are certified in accordance with the Jeequusments of SNT-TC 1 A and its applicable suppie- mented. It u, the responsibility of each organization mort:. The' requirements of this Standard are op- using personnel covered by this Standard to conform tiond St the discretion of the employer, for applica- to the requirements of this Standard applicable to the tion to personnel who perform calibration or to c:afts , , organization's wod..,
| |
| man who perform insta?ation checkouts as part of '
| |
| i It is the responsibility of the organization perfonn-thek base lastallation responsibility to ready the ing these activitics'to specify the, detailed methods installation for preoperational tuting. and procedures for meeting the sequirements of this A
| |
| : g. ..
| |
| 7,
| |
| , e (s !
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| , 4
| |
| | |
| Exhibit 2 of Response to III 7 Page 2 of 5 OUALIFICATIONS OF INSPECTION. EXAMINATION AND TESTING PERSONNEL FOR NUCLEAR POWER PLANTS ANSl/ASME N45.2.6-1978 Standard, unless they are specified in the contract 2.1.2 Training.The need for formaltrainingprograms documents.
| |
| shall be determined, and such training activities shall 1.4 Definitions be conducted as required to qualify personnel who perform nspections, examinations, and tests. On the-1.4.1 Inspection. A phase of quality control which
| |
| * job participation shall also be includedin the program, by means of examination, observation, or measure-with emphasis on first hand experience gained through ment determines the conformance of materials, sup- actual performance of inspections, examinations,and plies, parts, components, appurtenances, systems, tests. Records of training. when used as the basis for processes, or structures to predetermined quality re- certification, shall be maintained.
| |
| 9"I"**"'' '
| |
| 2.2 Determination of Initial Capability 1.4.2 Examination. An element ofinspection consist.
| |
| ing ofinvestigation of materials, supplies, parts.com-g ;;;g g , . candidate for certification ponents, appurtenances, systems, processes, or struc- shall be initially determined by a suitab) evaluation tures to determine conformance to those specified dh dide's education' experience, training.
| |
| requirements which can be determined by such inves- test results. or capabihty demonstration.
| |
| tigation. Examination is usually nondestructive and 2.3 Evaluation of Performance includes simply physical manipulation, gaging, and measumment. .Ihe job performance of inspection, examination, and testing personnel shall be reevaluated at periodic 1.4.3 Testing. "Ihe deterriinstion or verification of intervals not to exceed three years. Reevaluation shall the capability of an item to meet specified require- be by evidence of continued satisfactory performance ments by subjecting the item to a set of physical, or redetermination of capability in accordance with chemical, environmental. or operating conditions.
| |
| Subsection 2.2. If, during this evaluation or at any 1.4.4 Refer to ANSI N45.2.10 for other definitions other time, it is determined by the responsible or-to be used in conjunction with this Standard. ganization that the capabilities of anindividualare not in accordance with the qualifications specified for the 1.5 Referenced Documents job, that person shall be removed from that activity Other documents that are required to beincluded until such time as the required capability has been as a part of this Standard are either identified at the demonstrated.
| |
| point of reference or described in Section 6 of this Any person who has not performed inspection, Standard.The issue or edition of the referenced docu- examination, or testing activities in his qualified area l
| |
| ment that is required will be specified either at the for a period of one year shall be reevaluated by a re-point of aference or in Section 6 of this Standard.
| |
| determination of required capability in accordance t with Subsection 2.2.
| |
| 2.4 Written Certification of Qualification l
| |
| ' The qualification of personnel shall be certifiedin
| |
| : 2. GENERAL REQUIREMENTS writing in an appropriate form. including the follow-yy %q inginformation:
| |
| l (1) employer's name Plans shall be developed for staffing, indoctrina-tion,and training of an adequate number ofpersonnel (2) identification of person being certified to perform the required inspections, examinations, (3) level of capability and tests and shall reflect the schedule of project ac-(4) activities certified to perform
| |
| [ tivity so as to allow adequate time for assignment or
| |
| [ selection and training of the required personnel, (5) basis used for certification, including:
| |
| t 2.1.1 ladectrination. Provisions shall be made for the (*) '''. '.ds of education, experience and l Indoctrination of personnel as to the technicalobjec- training tives of the project; the endes and standards that are (b) test results,where applicable j to be used; and the quality assurance elements that (c) results of capability demonstration are to be employed. (6) results of periodic evaluations 2
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| | |
| /
| |
| Exhibit 2 of R2spense to III 7 Page 3 of 5 OUALIFICATIONS OF INSPECTION. EX AMINATION ArJD TESTING PERSONNEL FOR NUCLEAR POWER PLANTS ANSI /ASME N45.2.6-1978 (7) resultsorphysicalexaminations,whenrequired nations, and tests;in supervising and certifyinglower (8) signature of employer's designated represen. level personnel;in reporting inspection, examination, tative and testing results; and in evaluating the validity and
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| ***9 I * '** ** ** I"' *
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| (9) date of certification and date of certification "" '
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| expiration 23 Physical 3A Level 111 Personnel Capabilities The responsible organization shall identify any A I.evel 111 person shall have all of the capabihties special physical characteristics needed in the perfor. of a level 11 person for the inspection, examin. tion mance of each activity. Personnel requiring these or test category or class in question. In addition,the characteristics shall have them verified by examina- individual shall also be capable of evaluating the tion at intervals not to exceed one year. adequacy of specine programs used to tram and test inspection, examination, and test personnel whose
| |
| : 3. QUALIFICATIONS qualifications are covered by this Standard.
| |
| 3.1 General 33 Eduestion and Experience-Recommendations The requirements contained within this Section define the minimum capabilities that qualify person. The following is the recommended personnel nel to perform inspections, examinations, and tests education and experience for each level.These educa.
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| which are within the scope of this Standard, tion and experience recommendations should be treated to recognize that other factors may provide There are three levels of qualification.The require.
| |
| reas nable assurance that a person can competently ments for each level are not limiting with regard to pufam a particular task. Other factors which may organizational position of professional status, but demonstrate capability in a given job are previous per.
| |
| rather, are limiting with regard to functional activities which are within the scope of this Standard.
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| fonnance a sausfactmy canpleum of capability testmg.
| |
| 3.2 Level i Personnel Capabilities 3.5.1 Level I l
| |
| A Level I person shall be capable of performing (1) Two years of related experience in equivalent the inspections, examinations, and tests that are re- inspection, examination, or testing activities, or quired to be performed in accordance with docu.
| |
| (2) High school graduation and six months of mented procedures and/or industry practices.The in. ,
| |
| related expuience in equhaknt inspecum, examina.
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| dividual shall be familiar with the tools and equipment to be employed and shall have demonstrated profi.
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| don, a tuung acMu, m ciency in their use. The individual shall also be capable (3) Completion of college level work leading to an of determining that the calibration status ofinspection Associate Degree in a related discipline plus three and measuring equipment is current, that the measur. months of related experience in equivalentinspection, ing and test equipment is in proper condition for use, examination, or testing activities.
| |
| and that the inspection, examination, and test proce. 3.5.2 Level ll dures are approv'ed.
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| gg g 7 3J Level 11 Poesonnel capabilities I in the corresponding inspection, examination or test
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| ! category or class,or
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| ! A Level Il person shall have all of the capabilities of a Level l person for the inspection, examination or (2) High school graduation plus three years of test category or class in question. Additionally, a related experience in equivalent inspection, examina.
| |
| - 1Avel 11 person shall have demonstrated capabilities in tion, or testing activities, or planning inspections, examinations, and tests;in set- (3) Completinn of colley level work leadmg to an ting up tests includmg preparation and set up of Associate Degree in a related discipline plus one year
| |
| . related equipment, as appropriate;in supervising or related expenence in equivalent inspection, examma.
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| masatainmg surveillance over the inspections, exami- Gon, or testing activities, or 3
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| I .__ _
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| | |
| Exhibit 2 of Response to III 7 Page 4 of 5 OUALIFICATl!NS CF INSPECTION, EXAMINATION AND TESTING PERSONNEL FOR NUCLE AR POWER PLANTS ANSI /ASME N45.2E-rS78 (4) Four year college graduation plus six months 4. PERFORMANCE of related experience in equivalent inspection,exami-Personnel who are assigned the responsibility and nation.or testing activities. authority to perform functions covered by this Stan-
| |
| * 3.5.3 Levellit dard shall have, as a minimum, the level of capabihty (1) Six years of satisfactory performance as a Level shown in Table 1. When a single inspection or test re-11 in the coeresponding inspection. examination or test quires implementation by a team or group, personnel category oc class,or not meeting the requirements of this Standard may be used in data.taking assignments or in plant or (2) High schoolgraduationplustenyearsofrelated equipment operation provided they are supervised er experience in equivalent inspection, examination, or overseen by a qualified individual participatingin the f testing activities; or high school graduation plus eight inspection, examination.or test.
| |
| years experience in equivalent inspection, examina.
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| tion, ce testing activities, with at least two years as Level II, and with at least two years associated with nuclear facilities-or if not, at least sufficient training 5. RECORDS to be acquainted with the relevant quality assurance A file of records of personnel qualification shall be aspects of a nuclear facility, or established and maintained by the employer. Collec-(3) Completion of college level work leading to an tion, storage, and control of records required by this Associate Degree and seven years of relatedexperience Standard shall be in accordance with ANSI N45.2.9.
| |
| In equivalent inspection, examination, or testing ac-l tivities, with at least two years of this experience as-sociated with nuckgr facilities-or if not,at least suf- 6. REVISION OF ANSI STANDARDS REFERRED ficient training to be acquainted with the relevant TO IN THIS DOCUMENT l quality assurance aspects of a nuclear facility,or When any of the Standards referred to in this docu-(4) Four. year college graduation plus five years of ment is superseded by a revision approved by ANSI, related experience in equivalent inspection, examina.
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| the revision is not mandatory until it has been incor-tion, or testing activities, with at least two years of porated as part of a contract.
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| this experience associated with nuc! car facilities-or f
| |
| if not, at least sufficient training to be acquainted Revisions to this Standard issued after the date of l
| |
| with the relevant quality assurance aspects of a nuclear a rpecific contract invoking this Standard may be used l by mutual consent of the purchaser and the supplier.
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| facility.
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| l l
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| l 1
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| l l
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| l 4 i .
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| a Exhibit 2 cf Rtsp:nse to III 7 Page 5 of 5 QUALIFICATIONS OF INSPECTION, EXAMINATION AfJD TESTING PERSONNEL FOR NUCLEAR POWER PLANTS ANSI /ASME N45.2.6-1978 Table 1 Minimum Leeels of Capability fortroject Functions .
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| Level L-l L il L Ill ,
| |
| Recoreng inspection, esamination. and testing dete' X X X impiamenting inspection, enemination, and testing procedures X X X Manning inspections, evolustions, and tests; setting up tests including properation and set 4sp of related equipment X X Evolusting the veli 6ty and etceptability of inspec-tion, enemination, and testing resJits X X Reporting inspection, enemination, and testing results X X
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| %#pervising equivalent or lower level personnet X X Ouelifying lower level personnel X X Evolusting the edeousey of specific programs used to trein and test ineoection, enemination and testmg personnel X Ouelifying some levet personnel X
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| *Escoot es esempted by Section 4 of thm stoneerd.
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| 5
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| | |
| III-8 It is alleged that:
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| : 10) In its Report 83-37 the NRC agreed with Pullman and PGteE that the personnel files demonstrate adequate records for welder and M)E certification. As~a result, the staff decided that NSC was wrong. That is false. A September 15, 1977 memo (signed September 22), from Pullman's Director of Quali1;y Assurance to the site QA manager (Exhibit 11), " Generic NDE and Inspection Records", including - " lack of evidence showing the necessar/ records
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| * to support the certifications; lack of any certifications; certifications dated "as much as a year" after the inspectors began work; and " lack of evidence supporting previous work experience and Level I and Level II qualifications at a previous employer", among many other deficiencies. The corporate conclusions of generic deficiencies were based on a review of 95 files.
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| The NRC looked at the same files and found nothing wrong.
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| What happened? (3/22/84 Hudson Aff. at 6-7.)
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| Nothing " happened." Personnel records have been reviewed by Pullman and the NRC and there are no inadequacies in certification other than i
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| an inconsistent fom of documenting qualifications. The memo cited by Mr. Hudson resulted from inconsistencies as to where and how the i
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| required information was recorded. When the necessary clarifications were available and the mcords were analyzed in greater detail, the education, experience, and training histories.could be extracted to verify that inspection personnel had the required qualifications.
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| i 1422d ,
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| | |
| III-9 It is alleged that:
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| : 15) The signatures on pipe ru)ture restraint weld process sheets -- which insure the wort was not done in an ad hoc manner -- were phoney. A blank sheet was signed anTthen xeroxed. This is evident from a review of multiple weld process sheets -- the signatures are too perfectly identical. I also confimed this practice with engineers fmm the early years. Examples are enclosed as Exhibit 18.
| |
| : 16) In Report 83-37 the NRC made the following finding on Page 18: "The inspector examined the 90 day welder's lo and found that no void existed between 8/72 and 12/72." g This was the basis for NRC findings. I don't know who is responsible but that statement is false. The April 1978 Pullman resp,onse to the NSC audit (Exhibit 19, at p. 25.)
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| concluded the opposite: "There is a void in the 90 day weld log from August,1972 to December,1972." Any excuse based on a purported reconstruction of the log cannot wash. The NRC should know, because g November 1983 report to Commissioner Gilinsky should have been reviewed by the NRC staff months before Report 83-37 was issued at the end of February 1984. In the last section of g report I challenged the reconstruction as not being reliable, due to inconsistencies and omissions that rendered impossible any confidence'in the results. (3/22/84 Hudson Aff. at 8-9. )
| |
| Item 15 _
| |
| Standard fomat process sheets were prepared for specific types of rupture restraint work. The mquired steps to be accomplished and inspection hold points to be perfomed wem in accordance with the approved procedures and were pre-typed and xeroxed to include the signatures of the preparer of the fom and the QA individuals who approved the content of the fom. These signatures indicate that the process sheet was correctly prepared, not that the inspections had been performed appropriately. The inspector signs the line
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| " Inspection checks approved by" and dates the signature upon 1589d _ _ _ . .
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| | |
| completion of his inspection. He maintains control of the process sheets and merely adds the restraint numbers and/or identification numbers (such as field weld numbers) as the need arises prior to the start of work.
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| The process sheets, when completed, are then turned in to QA for review and filing in the appropriate document package. Although there is nothing in the regulations or the AWS code to preclude the use of xeroxed signatures, it was subsequently decided to discontinue this practice.
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| Item 16 The 90-day welders log was reconstructed, identified as such in the response to the NSC audit, and was shown to the NRC during their investigation of the NSC audit. The log was reconstructed from available evidence to close or answer the " void" identified in the NSC audit.
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| l Mr. Hudson's allegation is based on GAP submittal of March 23, 1984, Exhibit #1, a letter from Mr. Hudson to Commissioner Gilinsky. Pages 24-30 deal with this issue. Mr. Hudson discusses DR 4713, which documented paper-handling discrepancies in regard to the containment i
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| i spray piping system welding. i4r. Hudson notes that the rod requisitions listed the actual welding material used (that is, SMAW E308-16, GTAW ER-308) and therefore the welding process. The 1589d l l
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| l l .- . - . . . - - . -
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| | |
| l maintenance of welder qualifications is based on the weld process used (SMAW, GTAW, etc.). Mr. Hudson then jumps to the three month gap in the welder log identified by NSC. He notes that the gap and the DR 4713 welding took place at the same time. Mr. Hudson then focuses on welder "N" and questions, if the listing of weld procedures based on the rod requisitions and process sheets is incorrect, how can the reconstruction of the 90-day welder log be correct? Mr. Hudson ignores the fact that the reconstructed log for welder "N" used his carbon steel welding, not his stainless steel welding on DR 4713, to show maintenance of his qualifications.
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| Since the weld rod requisitions listed the actual weld rod used, which relates directly to the weld process, requisitions can be used correctly as'a basis for updating welder qualifications.
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| It is recognized that some uncertainty may exist whenever such an effort is mquired. However, it is felt that sufficient evidence existed to accomplish this effort with a high degree of confidence.
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| i 1589d . - - _ _ _ - - _ - - _ - - . . - - _ _ - - _ . _ - - . .-------
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| | |
| III-10 It is alleged that:
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| : 20) Management's refusal to back me against harassment from production made it more difficult to do sqy job properly. To illustrate, on August 13, 1982 I attempted to report harassment -- sucn as rifling sqy desk and taking an audit notebook. Mr. Karner refused to let the memo be
| |
| !- sent, and threw it out. I kept a copy, which is enclosed j as Exhibit 24. (3/22/84 Hudson Aff. at 9-10. )
| |
| l l
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| Mr. Hudson's desk was located in the main QA/QC office. The security in this area was limited and at various times many desks had items i i
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| removed from them, including pencils, pens, stationery items, and personal belongings. There was no way to identify who may have l rifled Mr. Hudson's desk. However, to link any such losses to
| |
| " harassment from production" is going far afield, i
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| The memo in question was not thrown out but was forwarded to Mr. John Ryan, Pullman's Resident Construction Manager, for t
| |
| inforisation and further action if he deemed such action necessary, l
| |
| which he did not. Mr. Karner discussed the situation with l
| |
| Mr. Hudson, at which time Mr. Hudson was told that Mr. Karner did not plan to remain onsite 24 hours a day to guard Mr. Hudson's desk and that Mr. Hudson should take the necessary precaution!:.
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| Mr. Hudson's desk was accorded the same level of surveillance and t
| |
| security as the desks of all other individuals located in that area.
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| l l
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| 1490d i
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| | |
| III-11 It is alleged that:
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| : 21) The PG4E response to g report on minimum valve wall
| |
| , thicknesses is so incorplete and internally contradictory i
| |
| that it could be the t, asis for numberous [ sic]
| |
| allegations. I will list a few of the highlights here.
| |
| PG8E asserted that procedure qualifications tests were not necessary because the inspectors calibrated tnetr tools.
| |
| But that is a totally uncontrolled response, and one which
| |
| , the inspector should take anyway. Additionally, y January 1984 affidavit to the NRC and v January 1984 report on minimum valve wall thicknesses also demonstrated the unreliability of calibration data for the equipment.
| |
| In weany instances, there was no calibration data.
| |
| Obviously, this was no substitute for procedures whose reliability is proven by tests -- the normal QA foundation
| |
| -- especially for valves with key safety functions. I wonder if the NRC has considered this issue in connection with PG4E's request to waive previous licesning [ sic]
| |
| coundtments in the FSAR. (3/22/84 Hudson Aff, at 10.)
| |
| The thickness measurement itself, through use of a cathode ray tube (CRT) presentation, demonstrates the effectiveness of the measurement technique. Before and after all valve measurements, thickness reference blocks were used to adjust the CRT to ensure accurate thickness readings. These measurements of known thickness samples instill more confidence in the accuracy of the process than prior Procedure qualification could ever develop.
| |
| l Mr. Ed Martindale of Pullman, a qualified UT technician, ran the ultrasonic thickness program at the time that many of the data reports questioned by Mr. Hudson were made. Mr. Martindale has indicated his belief that all measurements included the performance of pre- and post-calibration. After a review of some examples of the 1425d l_ . - . - - _ - -
| |
| | |
| "no calibrated data" items that Mr. Hudson identified on Internal Audit 34, Mr. Martindale indicated there had been a paperwork oversight on the part of the UT technicians, but that the procedure itself had been followed fully.
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| l t
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| t l
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| l I
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| l i
| |
| l l
| |
| l l
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| 1425d '
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| | |
| III-12 It is alleged that:
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| : 22) PG4E's response on the inability of valve thickness test equipment to catch specific eccentricities were [ sic]
| |
| accounted for through a CRT screen. Unfortunately, the test procedure doesn't use a CRT screen. Instead, it uses Pulse echo digital readout equipment. (3/22/84 Hudson Aff.
| |
| l at 10. )
| |
| i l
| |
| The entire subject of valve wall thickness measurement was completely addressed in PGandE's Answer in Opposition to Joint Intervenors Motfon to Reopen on CQA, Arnold, et al. Aff. at 19-26. The thickness measurement process (and procedure) did use the CRT screen for
| |
| -l determining the actual thickness of all valves. Mr. Hudson is incorrect in stating that the applicable procedure requires the use of " pulse echo digital readout equipment."
| |
| l i
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| 1428d __ - _ _ .. -- . . _ - - - - _ _ - . . - . . - . - - - - - - _ _ _ - . . _ _ _ _ . _ _ _ - - . - _ - - - - -
| |
| | |
| t III-13 It is alleged that:
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| : 23) PG4E's responses to welding allegations suffers [ sic]
| |
| i from a gross omission. It fails to demonstrate that the procedures used to verify the quality of the welds were the 1 same as those specified by Code 7/8 to install the welds in the first place. From the sketchy infomation provided by '
| |
| PG4E, I know there are significant differences. (3/22/84 Hudson Aff. at 10-11. )
| |
| This allegation attempts to combine and compare two distinct sets of <
| |
| requirements and then attempts to characterize the found
| |
| " differences" as a " gross omission." Contrary to the allegation, there was no omission.
| |
| The quality procedures used to inspect, examine, and/or test welds were appropriate for the inspections, examinations, and tests specified in the construction code and/or the Project specification.
| |
| Contrary to the allegation, welding Procedure Specification WPS 7/8 does not, and need not, specify the procedures to verify the quality of the work.
| |
| Contrary to the allegation, the PGandE responses to the welding allegations were not " sketchy." They were answered in sufficient i
| |
| detail to accurately and succinctly set forth the facts. Mr. Hudson fails to identify what he considers to be "significant differences" i
| |
| between the quality verification and welding procedures. The fact that different types of infonnation are contained in the procedures 1499d l l
| |
| | |
| and that each procedure covers a distinctly different area of concern is understandable and proper as these were, after all, developed for different purposes.
| |
| 1499d -
| |
| | |
| 1 l
| |
| l l
| |
| III-14 and III-54 1 It is alleged that:
| |
| For example, in PG4E's {{letter dated|date=March 8, 1984|text=March 8,1984 letter}} to the NRC, DCL-84-097 (attached as Exhibit 1), PGLE tries to claim that there are no problems with welding on the component cooling water (CCW) lines when they are filled with water.
| |
| However, PG4E's attempted explanation is full of false and misleading statements to support the false conclusion that there is no problem with this welding.
| |
| First of all, PG8E says that the pre-heat requirement was satisfied because the water in the pipes was greater than 500F. The professor I spoke with, however, said that it is not even properly considered a pre-heat unless the temperature is at least 10U4. At 500F, the temperature isn't even high enough to drive off any moisture from the outside of the pipes.
| |
| It is interesting that PG&E doesn't even mention what the temperature of the water was. I suspect that PG4E is intentionally trying to hide the fact that the water in the component cooling water system, as it travels to the components that need to be cooled, is normally at about 620F to 650F, according to my own knowledge and what I've been told by other people who are still out at Diablo. This is because the component cooling water goes through a heat exchanger which cools it to the temperature of the ocean, which is usually roughly between 620F and 650F. PG8E is misleading the reader when it says that the water temperature is "well above 500", because it isn't enough above 500 to even drive off the moisture, such less to amount to a pre-heat.
| |
| Another way of looking at this is to consider the fact that pre-heat values are established partly based upon the thickness [ sic] of the material, and it is assumed that the back of the material is in air. However, since water has a auch higher thermal conductivity rate than air, the l
| |
| water-filled pipe acts like a thicker section of base metal, which would require a higher pre-heat value.
| |
| When PG4E failed to mention the actual temperature of the CCW system, it tried to obscure a very significant fact, and once the temperature is considered, it is obvious that welding to the CCW Ifnes with such cold water in them would
| |
| : be very difficult because of the rapid cooling of the weld and the likelihood of cracking would be greatly increased.
| |
| 4 f
| |
| 1516d i
| |
| -- -- ------,-,-.,-.-.-n,.e. - , . - - , , , . - -, _ . , ,, _ . , , , , _ _ , _ , _ - . _ _ . _c-,_ -
| |
| ,re--,----n-,
| |
| | |
| 4 Likewise, PGAE omits the crucial facts when it says that the main concern is cold cracking caused by hydrogen. As the professor confimed, the primary problem here is the quenching effect of the water. Because of the rapid i
| |
| cooling, the weld itself can crack, and there can be underbead cracking beneath the weld in the parent material.
| |
| This cracking problem is compounded by the fact that the t
| |
| welding was done on thin sections. The thin pipe walls would be rapidly cooled by the cold water, increasing the i
| |
| quenching effect, and making underbead cracking all the more likely. Because of this, PGAE is blatantly wrong when it says that the thinness of the sections " eliminates the possiblity of cracking." PG4E should have said that it increases the likelihood of cracking.
| |
| PG&E doesn't say that Pullman had actually qualified any Procedure to weld onto water-filled lines, and I strongly doubt that Pullman has qualified any such procedure. PG4E attempts to evade the issue by saying that an engineer
| |
| " reviewed and accepted" the welding before it was done.
| |
| Whatever that is supposed to mean, it doesn't meet the code j requirement for qualifying the procedure that is to be used. ,
| |
| I PGAE is also wrong in saying that the use of low- drogen rods " minimizes the possibility" of cracking. To gin with, hydrogen only compounds the problem ~of the quench rate. But in addition, some hydrogen is diffused into the
| |
| ! metal even from low-hydrogen electrodes, and there will l also be hydrogen from the moisture which the cold ifnes tend to collect, and which would not have been driven off because there was no real pre-heating. Thus, hydrogen cracking is an additional problem.
| |
| PG4E's excuses haven't explained away the fact that cracking is likely, primarily because of the fast quench rate, which PG4E totally ignored in its analysis. If PGAE actually wanted to eliminate the possibility of cracking, it should physically examine the welds themselves with appropriate tests, such as hardness tests to check the hardness of the welds and of the heat-affected zone.
| |
| Photomicrographs of the structures involved would also be recousanded for this circumstance.
| |
| The professor summed up PG4E's response as being due "either to gross ignorance or to a cover-up." I agree. .
| |
| Either PG4E does not understand the basic concept of the rate of cooling, or they are deliberately trying to mislead the uninitiated. (3/21/84 Anon. Aff., Attachment 7 at 1-5. )
| |
| 1516d '
| |
| I _ _ _
| |
| | |
| "I have read Pacific Gas and Electric's (PG4E) March 8, 1984 statement to the Nuclear Regulatory Commission, DCL-84-097, concerning welding on Component Cooling Water i (CCW) piping while it was filled with water. PG&E makes a number of material fa'se statements in that letter, that seriously affect the ultimate conclusion about the likelihood of cracking in the component cooling water lines.
| |
| "In particular, PG&E says that the fact that the sections welded were thin ' eliminates the possibility of cracking.'
| |
| l This is absurd. First of all, welding with water in the line means that as soon as a weld pass is made, the weld is
| |
| ' quenched' by the water, which acts as a heat sink.
| |
| Because of the rapid cooling of the thin material, it increases the possibility of cracking rather than elf af nating it.
| |
| "Not only is there a possibility of cracking, but cracking .
| |
| of these welds is probably occurring in the field. I was told within the past week of two welders who were working
| |
| : on a CCW line that their weld bead actually froze on contact. This means that the rate of quenching is so high as to increase the likelihood that cracking or a lack of fusion will occur.
| |
| l
| |
| 'In order to tell if these welds are cracked, Non-Destructive Examination (NDE) should be conducted. ,
| |
| However, Pullman does not require any NDE for this welding, and none is done.
| |
| "In addition to this, I have personally observed problems with porosity and cracking at the start and temination of the bead on these welds. If cracking is occurring on the surface, it raises the likelihood that there is porosity or cracking in the root pass, and in subsequent weld passes.
| |
| "Because of these factors, I think that PG4E's statenent is false when it says that cracking is unlikely in the velding done to the component cooling water system piping while it was filled with water. In fact, it is impossible to tell the extent of the cracking in the welding to these lines, and it should be thoroughly examined to detemine the extent of cracking." (3/22/84 Clewett Aff. at 1-2. )
| |
| Both the allegations from the NDE inspector, and the other from an anonymous alleger with secondhand hearsay from an anonymous Professor, have no technical basis and are in fact metallurgically 1516d
| |
| - _ - _ - - . - _ _ _ = - _ - _ . . - - - . . - _ - _ - - _ ___ .____. _ - - -
| |
| | |
| l i
| |
| t unsupportable. A CCW branch connection with reinforcing saddle that had been welded while filled with water has been sacrificed, exam md, and tested. There were no cracks. The metallurgical structure and hardnesses in the weld and heat affected zones (HAZ) were such that cracking would not be expected. The metallurgical structure is ferritic and pearlitic with some bainite. The CCW pipe l Heat Affected Zone (HAZ) had maximum hardness of only HB 210, the reinforcing pad maximum hardness was HB 255. This clearly shows there is a wide margin and no basis for concern. This data proves the allegers are wrong.
| |
| 0 It is alleged that temperatures less than 100 F are not considered preheat. This is wrong. The B31.1 and 831.7 codes Mich governs the
| |
| ~P iping work at Diablo Canyon both list 500F preheat for the materials and thicknesses of concern. ASME Section I and Section VIII also refer to 500F as preheat. The AWS D1.1 pemits prequalified welding of the specific A53 material with the low hydrogen electrodes with a preheat of 32 0F.
| |
| 4 Pullman's welding program requires the material to be dry independent of the preheating requirement. Thus, surface moisture is not a problem. In relation to this surface moisture, the professor should twcall that underwater welding can produce acceptable results.
| |
| The temperature of the water is not significant. Whether it was 500, 700, or 1000F, it would have minimal affect on the actual 1516d - _ - -
| |
| | |
| cooling rate in the weld, HAZ, or base metal in the temperature range 0
| |
| of concern. The 50 F preheat would have been valid and acceptable for much thicker material in accordance with code requirements and engineering fundamentals.
| |
| The primary concern for this type welding operation is hydrogen induced cold cracking in the weld idZ, sometimes raferred to as underbead cracking. Hydrogen induced cracking requires a source of hydrogen and a susceptible micr5 structure.
| |
| The quenching effect of water needs to be considered in relation to the material's critical cooling rate. Rapid cooling by itself is not a concern. For example, many plain low carbon steel materials e.re water cooled in the forming processes and others are intentionally quenched to refine their grain size and improve mechanical test results without detrimental effect. In fact the effects are beneficial. The fact is that for underbead cracking to be a concern the weld cooling rate must be so very great that the HAZ will form a hardened microstructure. For plain low carbon steel such as A53, the critical cooling rate to form a hardened microstructure is very rapid, approximately 1000F per second at 10000F. Unfounded speculation about cooling rates due to water quenching is absurd without considering the second half of the requirement, the material's critical cooling rate.
| |
| 1516d Thinness is important as it relates both to heat transfer and to restraint. As pointed out by the allegers, the water backing causes
| |
| ; the material to cool more rapidly, as if the material were thicker.
| |
| The heat dissipatfort issue by cooling water is not by itself a real concern. Weld cooling rates need to be considered in relation to the material's hardenability and critical cooling rate. When weld cooling rates and material critical cooling rates are considered j together there is no concern. As stated previously, the material did not harden. Thus there is no concern for heat dissipation. The thin wall large diameter pipe also minimizes restraint, which is a i
| |
| critical element in developing cracks. Thus PGandE was again correct as regards thin material. .
| |
| Forty years of industrial and research experience with Battelle underbead cracking tests show that welding with low hydrogen electrodes does not cause cracking in material which is much more hardenable and susceptible to cracking than the A53 pipe. These test data are significant because they demonstrate the importance of the low hydrogen electrodes. They are also significant because the Battelle underbead cracking test a'most completely immerses the test coupon in water. Base materials much more susceptible to cracking i
| |
| than A53 pipe have been welded with low hydrogen electrodes and did not crack even though the water temperature was 320F--ice water.
| |
| These data also prove there is no real concern for the CCW welding.
| |
| 1516d . - - _._.. _.--_-_- -.-_- __. -. - . ----_ - . - _ _-. - _ _ .- - -.
| |
| | |
| The amount of hydrogen recessary to cause cracking is inversely proportional to the hardness and degree of restraint. When low hydrogen electrodes are used, as they were at Diablo Canyon, the HAZ microstructure may be very hard and not crack. Whe : the HAZ microstructure is soft, as in the CCW case, the hydrogen tolerance is great--so great that low hydrogen electrodes were not necessary.
| |
| Thus, for the welding on CCW pipe filled with water, there was and is no basis for concern principally because: (1) The base material HAZ did not harden and (2) low hydrogen electrodes were used. There is a
| |
| : double margin.
| |
| The weiding procedure specification and welders were qualified as required by the codes. There is no code requirement and no technical reason to qualify on water filled pipe.
| |
| l The allegations regarding weld beads freezing on contact, starting porosity, and surface cracks at terminations relate to welder technique, not to water filled pipe. Weld beads will freeze on contact if the welding current is not set high enough or if the I
| |
| welder moves the are too rapidly. The presence of eater inside the pipe has little or nothing to do with the solidification of weld
| |
| , metal on the outside at temperatures in excess of 27000F.
| |
| Porosity, and especially starting porosity, is a welder induced defect generally caused by too long an arc length as controlled by 1516d l 1
| |
| | |
| the welder. Surface cracks, such as the crater cracks at the tennination of weld bead, are also induced by poor welding technique. Starting porosity and crater cracks are connonly ground out and the weld reworked.
| |
| The welds in question have been examined, tested, and accepted. A I
| |
| CCW branch connection was sacrificed and examined and found to be crack fret, and also found to have microstructure which was not crack
| |
| , susceptible.
| |
| The paragraphs above address the specific issues raised by the -
| |
| allegations. The following is a simple and direct discussion of the underlying tedhnical concerns.
| |
| Hydrogen cracking and, in particular, underbead cracking, did not occur in these welds because the two separate conditions which must j exist to induce the cracks were not present in the CCW welds. These 1
| |
| two conditions are a susceptible microstructure and the amount of hydrogen present.
| |
| i A si.sceptible microstructure must be present. Microstructure is related to both the weld cooling rate and the materials being welded. Welding cooling rates need to be considered along with the material's critical cooling rate (CCR). Provided the weld cooling rate is slower than the CCR, cracking will not be a problem. The CCR I
| |
| i 1516d l
| |
| | |
| is dependent upon the material's chemical composition. Cooling rates more rapid than the CCR cause a hardened microstructure to fom. The ease of forming a crack susceptible microstructure is described as "hardenability." One approximation of "hardenability" is the carbon equivalent. Steels with higher carbon equivalents are more hardenable, have slower CCRs, and are more susceptible to cracking.
| |
| l l
| |
| The A53 CCW pipes at Diablo Canyon are basically plain carbon steels I
| |
| and are essentially nonhardenable. These steels have such rapid CCRs that, with normal welding heat input, it is not possible to form a crack susceptible microstructure. In this case, the material A53 l Grade B, is such that a very high cooling rate is required to obtain the necessary microstructure. This very high cooling rate is not achieved even with water backing. This has been demonstrated by metallographicaly examining one of the CCW welds. This examination shows that the HAZ of the CCW piping is primarily ferrite and i
| |
| pearlite with some bainite. The maximum hardness of the CCW pipe was l HB 210. The maximum hardness of the reinfon:ing pad was a HB 255.
| |
| I This structure is not susceptible to hydrogen or underbead cracking.
| |
| f Hydrogen must be present in sufficient quantity to initiate cracking. As stated before, low hydrogen welding electrodes used were stored and controlled to preclude hydrogen pickup. This assures
| |
| ( that the amount of hydrogen charged into the weld is below the amount l required for cracking welds even those with susceptible -
| |
| I l 1516d 1 i-
| |
| | |
| microstructure. In this case, the excellent filler material control system would ensure a crack-free weld.
| |
| The amount of hydrogen required to cause cracks is primarily related to the material hardness. If a material is soft (as is the CCW material), then the hydrogen is not a concern and ordinary non-low hydrogen electrodes would have been acceptable.
| |
| The fact that low hydrogen electrodes were used means that there was a great tolerance for a hardened microstructure. Microstructures significantly harder than were found in the CCW pipe would have been acceptable. Thus, as regards both susceptible microstructures and hydrogen, the water filled CCW welding had significant margins, i
| |
| l I
| |
| l 1516d _-
| |
| | |
| l III-15 It is alleged that:
| |
| On March 13, 1984, there was a meeting between the Pullman leadmen and Pullman supervision, after which the leadmen told the Quality Control (QC) inspectors that starting
| |
| , immediately, for both Units 1 and 2. QC inspectors were not to write any Discrepancy Reports (DR's, which go to PG4E to l be dispositioned) and were only allowed to write Deficient l Condition Notices (DCN's), a Pullman in-house form.
| |
| I Thaty said that even if it should be a DR, to only write it on a DCN fom, that Pullman's Quality Assurance (QA) department would review them to see if there were any r conditions that required a DR, and that if so the QA
| |
| : department would write shem up.
| |
| When inspectors asked questions about this, the QC
| |
| , supervisors told them that this new procedure was ordered by Bill Kinnel, the head of the QA department, and that j Kimmel would issue a meno shortly.
| |
| Kisunel is the QA supervisor, and QA has no direct authority
| |
| ; over the day-to-day actions of QC personnel. In addition to this I am concerned that this new procedure violates
| |
| . 10 CFR Part 21,10 CFR 50.55(e), and 10 CFR Part 50 Appendix 8. (3/22/84 Clowett Aff, at 3.)
| |
| The entire issue of DCNs and DRs was previously addressed in PGandE's I Answer in Opposition to Joint Intervenors' Motion to Reopen on CQA, f Karner and Etzler Aff. at 36-39. That response stated in part that:
| |
| l Details of Pullman Power Products procedures for reporting deficient conditions are contained in ,
| |
| procedures ESD 268 (Field Procedure for Deficient Condition Notices (DCN), and ESD 240 (Field Procedure for Nonconformance Reporting called a Discrepancy Report (DR)). These procedures have been in effect since 1973 for ESD 240 and 1978 for ESD 268.
| |
| These procedures were prepared, reviewed, and approved by
| |
| , both Pullman QA/QC management and PGandE to be in i compliance with the Pullman QA Manual section for
| |
| ! nonconfomance reporting (KFP-10) and PGandE's 1399d l
| |
| | |
| i Specification 8711. These procedures give the specific details for preparation of a DCN and a DR. The DCN, as identified in ESD 268, is a method for field personnel to i
| |
| identify what they believe to be problems that violate procedures and which cannot be corrected during the nomal course of ccnstruction. In accordance with the approved procedure, ESD 268, PGandE is not required to review the DCN.
| |
| The DCN, by procedure, does require Pullman Engineering l concurmnce. If a DCN is prepared by engineering, it also requires Pullman QA/QC concurrence. This assures that both
| |
| ' Pullman disciplines are aware of the condition, have the opportunity to assure that all items are accurately depicted, and that all necessary infomation is included in ;
| |
| the DCN. The review by a Pullman QA/QC leadman, which is '
| |
| not mquired by procedure, was implemented to further assure that infomation is accurate, that all necessary infonnation was included, and to let upper levels of responsibility know of problems that are occurring. This review is not intended to delay submittal of these reports,
| |
| ' but is done to prevent further recurrence, to immediately provide additional training and instructions to the responsible parties, and to assure that these reports are
| |
| ; not rejected for lack of information at the next level of j review. With proper justification, a DCN can be voided at i arty level of review including that of the QA/QC manager.
| |
| If the DCN is voided prior to reaching the Pullman QA/QC manager, it is done so only with the concurrence and agreement of the originator or his first line supervisor.
| |
| If the DCN it.yoided at any stage of the process, the original DCN or a copy thereof is mturned to the l originator. Additional instructions have been implemented to assure that these documents are handled properly and ;
| |
| voidwi copies are.kept on file. The DCN can be dispositioned in various ways, one of which is identifying
| |
| , the problem on a DR.
| |
| The "new", procedure mentioned by Mr. Kimmel was merely a mstatement of the procedure which had long been in effect. This memo was issued to all QA/QC and Engineering personnel by Mr. Karner and Mr. Cornish en March 14, 1984. The actions involved herein violated no regulatory requirements.N -
| |
| A
| |
| , y
| |
| : 5) *
| |
| (,
| |
| : 1399d '
| |
| , 't
| |
| ...,_.._._.._.,.,._.___,,.,_.m..,____,___, _ ___.___ _ ,____.___. _ _ _ _ __.__. _ _ _ _ ___ ___ _ _ _
| |
| | |
| k III-18 It is alleged that:
| |
| : 5. In the Introduction to the February 7,1984 PGandE Letter No: DCL-84-046, under "2. Natum of Concerns," it is stated in Paragraph (b) that " discrepancies are or a minor nature and, when revised calculations or analyses were performed, all of the piping and sugports fully met the licensing criteria and commitments. I have two questions i in response: (1) How can PGandE be so sure that the above
| |
| ! statement is true when in Paragraph (a) they admit that j " discrepancies have been found in the small bore piping design wort"? (2) Were the effects of torsion accounted for? The calculations that I performed, including torsion, failed about 505 of the supports (these have been redone; was torsion removed?), and a co-worker, in his affidavit, says that he was not allowed to include torsion. (See attached Affidavit (Exhibit 1).) He was a member oT the Unit 1 team that is perfoming the present review. I will volunteer to review with the NRC a sample of the 110 supports recently reviewed by PGandE, both computer and hand-calculated.
| |
| ! 6 In reply to PGandE's conclusion that there is no reason
| |
| : to believe similar concerns exist outside OPEG, it should be noted that OPEG was not very different from the home 3 office of Bechtel or Westinghouse; all were under pressure to produce to meet schedule. If OPEG had problems with i document control, how can one conclude without looking at
| |
| ; the home office that it didn't have this problem also
| |
| ! (ille same?gible After or deleted] the PGandE's longoverall stringmanagemnt waserrors, of ca culation the I 4
| |
| question whether PGandE has now reviewed the calculations correctly. PGandE must demonstrate through a full review l that the calculations were based on the controlled
| |
| [ documents listed below. (Undated Stokes Aff.,
| |
| ; Attachment 4, at 2-3.)
| |
| Mr. Stokes appears to be meding isolated statements from the PGandE letter DCL-84-046 to the NRC, dated February 7,1984, out of context i
| |
| and sometimes in reverse order. In proper order, the letter states i
| |
| that " discrepancies have been found in the small bom piping design work," and then famediately follows with "Such discrepancies are of a 1413d :
| |
| f
| |
| | |
| ~
| |
| minor nature And, when revised calculaticas or analyses were ;
| |
| perfomed, all of the piping and supports fully met the licensing criteria a'nd cosuittments." As further explained in the letter,
| |
| 'kGandE was' able to make this assertion based on a detailed review of 1
| |
| l a sample of 110 small bore pipe support analyses. This subsequent review did include appropriate consideration of torsional effects in support design. The eppropriateness and acceptability of the support design review have subsequently been corroborated by extensive NRC staff technical' a.udits o'f this work.
| |
| l Mr.' Stokes' statements concerning the similarity between conditions
| |
| }~
| |
| at OPEG and those at the home office or Westipshouse are totally
| |
| ./
| |
| , unfounded speculation on~ his part, since he had no direct involvement l
| |
| l
| |
| ,, with either operation. The large bore effort was conducted (at the San Francisco home office) by an entirely separate design group at a different location.. Norecver, there were a wido range of different
| |
| , circumstances involved in the large bore pipce support design effort
| |
| ( .
| |
| which reinforce the.high confidence level' in tne quality of that work. These included the use of internal technical review groups to l review and monitor support designs and calculations prior to issue for construction, ready access to staff specialists for consultations l
| |
| on technical problems, greater emphasis on initial indoctrination and training, and wider use of periodic special training when required.
| |
| l l
| |
| 1413d - 2_-
| |
| e
| |
| - _ . - . - . . , , . . , - . - _ _ _ , . _ _ _ , _ _ , . . , - . _ _ . _ _ . . . , - - _ . . _ _ . - - _ , . _-- . ..__mm..____ . _ . -..
| |
| | |
| III-19 It is alleged that:
| |
| NRC Question: (Allegations 55 and 79, SSER 21) Gaps to reduce therinal 1oads (p. S): ,
| |
| : 7. From PGan C s response [to Allegations 55 and 79, SSER 21], it seems obvious that they have reviewed thermal effects with blinders on. In a plant subject to seismic i
| |
| excitation, the onl j wall penetrations (ywhich reliable cananchors are those such vibrate depending as on location) and anchors attached to walls, floors, or ceiling concrete i
| |
| ' or steel (they, too, can vibrate demnding on fixity of structure). In effect, no anchor siould be assumed completely in reduction of thermal load. For example, a large bore pipe is considered an anchor due to relative sire. However, unless the large pipe itself is anchored close to the small pipe branch line, its location cannot be relied on over the life of the plant in establishing the therinal gaps to reduce loadings to other supports. To illustrate: [ figures deleted]
| |
| : 8. De valid.pending on total conditions, use of gap may not be Either it should not have been used to relieve load I to small bore supports, or after every seismic disturtance i
| |
| these supports subject to increased load should be reviewed for gap and movement changes in location of TAM of large bore line. Also a similar effect occurs on a small bore line with a restraint on each end. If this line is quite long and the hold line is shifted due to seismic activity, the support at each end could be subjected to larger than designed-for loads. Example: [ figures deleted]
| |
| i 9. This may not be the worst case scenario: At time O the l Plant is cold. As it heats up, the line expands -
| |
| uniformly. This is because friction on the supports grows from the middle of the radial line out and produces balanced loading on each side of the center point until one end grows enough to encounter a restraint. The first end to hit is the right side after 1/16" growth; then this support in effect pushes or is pushed against by all l
| |
| friction loads on all supports as the line grows in the other direction of freedom. Time 0 on the right end is subjected to the sum of all frictilin force developed by internal supports. At some time in the future, during cold shut-down for refueling, a seismic disturbance occurs and the line shifts position. Expansion occurs as it did at Time 0_, only now the left end is the restraint.
| |
| 1416d - -
| |
| : 10. When gaps are used to relieve therwal load, there are certain requirements. I have never seen the load considered this way, with unequal placement or uncentered placement of the line in relation to gaps. The general assumption is that if there is 3/16" thermal expansion and there are a total of 3/16" gaps, then there is no thermal load to any support. This is not a conservative analysis, and I question whether or not the cases hypothesized above have been considered in the stress calculations and the resulting loads given to the support group.
| |
| : 11. Here, too, is the assertion that "these loads are derived from two totally different loading phenomena, one static (thermal), and one (ynamic (seismic)." The same questions and concerns are raised here as in the use of gaps to reduce thermal loads. PGandE continues to state that after re-performing analysis that the licensing criteria are met. I question why a different method was used for their systems initially if a problem did not exist. These new analyses should be reviewed in depth by an outside party. (Undated Skokes Aff., Attachment 4 at 3-7.)
| |
| Mr. Stokes goes to some lengths in his affidavit to hypothesize worst case piping configurations for which modeling of therwal gaps would not yield conservative results, particularly after a seismic event
| |
| , that could causa piping to reposition from its original cold position. He overlooks the fact that thermal gaps were considered carefully prior to their use. Further, he completely misses the point that in the very limited number of cases where this analytical technique was used, the particular piping configurations involved l
| |
| would lead to repeatability of the thermal piping growth with a high degree of confidence. Notwithstanding the above, and in order to 1
| |
| resolve its consideration as an issue, PGandE has made a commitment in PGandE letter DCL-84-214 to the NRC, dated June 7,1984, to remove
| |
| ; from the thermal analysis models all support gaps before the first 1416d scheduled refueling outage. The affecH analyses will be revised and qualification will be reviewed for pipe stress, pipe supports, equipment nozzle loads, and other analysis criteria. If modifications are required to allow the removal of gaps in the analysis, they will be completed during the first refueling outage.
| |
| Mr. Stokes also indicates his doubts about reanalysis done on calculations which originally used different stiffnesses for the same rigid support in static and dynamic pipe analysis and expresses skepticism about the reanalyses actually demonstrating qualification in accordance with licensing criteria. This is somewhat understandable when viewed in light of Mr. Stokes' lack of experience in piping stress analysis.
| |
| As noted, the calculations were reanalyzed and were shown to be qualified when stiffnesses were included for both load cases. The stiffness refinement was originally considered in the themal analysis in order to more accurately detemine the themal loading condition on a particular support. The seismic loading was not reassessed because it was not in question. The inclusion of stiffness in the seismic analysis was not done to gain some imagined or particular advantage.
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| l l 1416d i
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| | |
| III-2D It is alleged that:
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| : 12. I challenge the first line in PGandE's response, concerning engineering" judgments. Many of the so-called
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| " engineering ; udgments were not those of the individual engineers performing the calculations, but were suggestions made by group leaders who claimed to only want to see how the hypothesized change would affect a support that had been failing to meet design requirements. Although they told those doing the work that the suggestion would not be used, when the results came back and the stresses were now acceptaole, the engineer was either pressured into signing, or the calculation was given to another engineer who did not question the method used and just signed it off. I was given supports to perfom the analysis; when I demonstrated that a support was deficient and returned it to the group leader after it had been checked, I found that another engineer was perfoming the same calculation from scratch.
| |
| This happened to other engineers also. Although the group leader acted surprised when the engineer discovered the same suggested calculation being perfomed by another 1
| |
| engineer, to uty knowledge every person in the Unit 1 squad from November 1982 to March 1983 was aware of this happening. In retrospect, I realize that this multiple assignment of the same support occurred so frequently as to be intentional. I remember one time the same support was assigned to three engineers simultaneously by the same group leader, only to be discovered near completion of all three. Due to the number of supports that I was finding on a preliminary basis to be inadequate, I felt that the reason for the multiple assignments was to see which results were the most favorable to passing the support.
| |
| The others were thrown in the garbage can. This conclusion is based on the fact that no calculation package includes more than one original design.
| |
| : 13. In STRUDL modeling, possible errors by the engineer
| |
| ! involved things like Beta angles, which were required to crient the members correctly; the detemination of the proper Beta angle to be used in the model for structural steel angles; and especially unequal leg angles. Another modeling problem was that some engineea omitted the joint eccentricities where members are welded together. This ,
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| could decrease the stresses, since by the omission of these !
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| eccentricities the torsional loads were reduced. Another 3 problem in using STRUDL and hand calculations was the !
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| detemination of "Ky," "Kz," "Lg," "LZ. " (See attached excerpt from STRUDL Manual (Table 14.1 -- Parameters used 3
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| l 1423d . - . - .. ..-_ - - - . ._
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| | |
| by the 1963 and 1969 AISC Codes (Exhibit 2)) and Quan (ECA)
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| Memorandum to AISC Code Check Users (Exhibit 3). ) These were almost never correct.
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| : 14. Other problems were common in both computer and hand r calculations. The first resulted from the load case form.
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| (See attached Stokes' Loading Cases for Hanger Form and HP 41C Program (Exhibit 4).) Two problems came out of this:
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| (1) Teams of two were established early in the Project where one member checked the other's work and vice-versa.
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| The individual teams resolved between them the correct way i to fill out this form. Through discussions with other i
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| teams, we discovered that almost all had a different interpretation. On other design jobs, the checking was randomly assigned, so that the group inter-related and merged in practice. (2) The second problem was that typically all Load Cases A across were input to STRUDL or used in a hand calculation. In fact, there are more Load Cases (i.e. ,1, 2, 3, 4, 5) than just A and B. In the case of an anchor support where FX, FY, FZ, MX, MY, MZ are filled in for cases A and B, adding all possible
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| ! combinations of A and B under Case 1 will result in 36 l
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| ' possibilities. This number was never analyzed; only an assumed worst case was analyzed. Had anyone analyzed the Je cases, he would have lasted at best a month before being dismissed for production reasons. The significance of this is that no one can guarantee that each support was veriffed adec uately, except for tne most simple cantilever single Ioac (rx) or (FT) or (FZ) support.
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| : 15. Another problem involved the evaluation of torsional stresses on tte members of the supports. Some engineers use the " Torsional Analysis of Rolled Steel Section,"
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| published by Bethlehem Steel, which evaluates both the l warping normal contribution to bending stress and shear l effects. I am not surt where Bethlehem got the procedure, i
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| but the same method is developed in " Bending and Torsional Design in Structural Members" by C.P. Heins, published by Lexington Books (copyright 1975). I should note that the necessary projection for angles is not included in the Bethlehem data, nor is it completely developed in Heins' book. But the necessary factors can be found in other text: or calculated using analysis similar to that for structural channel shape in Heins' book. I used this method, and with the added shear stress and bending stress, many angles exceeded 1.0 in the interaction equation. The other method of torsion evaluation came from a book l
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| entitled, "The Design of Welded Structures" by Omer in SectionW.2.10:
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| Blodgett," Designing for Torsional Loading."
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| (See published by Linco 1423d l
| |
| | |
| Exhibit 5.) This method is limited to shear stress. Some
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| , problems occurred between Table 1 (Torsional Properties of Various Sections) and Table 4 (Torsional Resistance of Frame and Various Sections). Table 4 was sometimes used incorrectly. Another problem with this method was that on page 2.10-8 the equation T = 7t/A was used without considering equation would have resulted in substantial inc(rease to resultingTnax [ sic stress if it were considered.
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| : 16. Many times an angle would not pass with only the shear calculation per Blodgett. Since the Bethlehem method was more involved than Blodgett's, I resorted to a two-step analysis. I checked the angle using Blodgett and if the interaction was .75 or above I would then check it using the Bethlehem method -- including the effects of warping normal (bending stress) contribution. This usually would exceed the interaction value of 1.0 and fail the angle.
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| Other engineers did not do this because of management policy. (See Exhibit 1.) Other engineers and I felt that angles sholiTil be checked per AIsc Section 1.5.1.4.66 for unbraced length. However, we were not allowed to nor was any method allowable. given to compute a reduced bending stress
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| : 17. It is impossible to determine whether an error originated with the designer by looking at the type of .
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| error. The engineer should be asked if his engineering judgment was used or whether it was a suggestion from a supervisor. I believe an additional cause of discrepancies was suggestions by the supervisors, and this has been confirmed by w asking others.
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| : 18. At page ll, Paragraph 3, PGandE concludes: "The fact that when the discrvpancies were addressed the supports were accepted without modification substantiates the adequacy of the design process." It is g understanding that support No. 100-132 or another support did fail after being corrected. It is noted that six supports have not been finished. These could include the one that failed and continues to be analyzed.
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| : 19. It is also stated that "the methods and criteria were not modified for this evaluation." This implies to me two i possibilities: (1) all errors that have been found may still exist, and (2) things not included in the past still ,
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| are not included, as described in Exhibit 1 and g earlier disclosures. I volunteer g services again to the NRC in reviewing a sample of the 110 (Undated Stokes Aff., Attachment 4, at 7-12.) packages.
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| 1423d . . _ _ _ __. , _ _ _ - . _ _ _ _ _ . . _ _ _ _ . _
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| l 1 l j
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| \
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| 1 l
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| l I
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| In this allegation, Mr. Stokes seems to contend that once any pipe l l
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| support calculation has been done which does not demonstrate that the support meets criteria, no amount of additional analysis, ingenuity, or new perspective can ever be used to qualify that support. Once it
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| " failed" by his calculation, the support is apparently doomed. A l
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| more reasonable engineering approach to a design verification effort such as that undertaken for the Diablo Canyon Project (where one is l
| |
| evaluating a piping system that is already built) would be to expend additional effort to demonstrate qualification of pipe supports when feasible. Nonnal engineering methodology includes use of trial run calculations to evaluate various optional assumptions and analytical approaches as well as the use of the experience, expertise, and perspective of various engineers to resolve a problem. These methods were appropriately and legitimately employed at OPEG to demonstrate pipe support qualification to project licensing criteria.
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| Mr. Stokes goes on to detail several specific areas where he speculates that calc;;1ation deficiencies might exist involving Beta angle, joint eccentricities, use of the load case form, evaluation of torsional stresses, and evaluation of the effects of warping normal stress contribution. In fact, the review of the 110 pipe supports 1
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| design packages was done using a comprehensive procedural check sheet which specifically includes the items identified above in addition to numerous other technical points. The review has been completed, and 1423d - - - - - . - _ _ _ _ _ _ _ . . . . _ . - . _ _ _ _ . . _ . _ _ - _ _ . . ____.
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| | |
| l
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| \
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| in every case after any calculation discrepancies were resolved, the evaluation showed that all piping and supports fully met the applicable ifcensing criteria and counf tments. Furthermore, the adequacy of the support design review has been corroborated by the extensive NRC staff technical audits of this work.
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| l 1
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| l l
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| 1423d .. - . - - -
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| 1 III-21 It is alleged that:
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| : 20. PGandE states that "It has been industry practice to ignore the dead bands when perfoming seismic analysis." I agree. However, generally, industry and manufacturer i recommandations and good engineering practice also require that a snubber would not be used unless pipe movements required it and would not be placed close to a bilateral support unless it allowed sufficient pipe movement for the snubber to operate. In all plants and projects where I have worked, a snubber would usually be used with (a) a
| |
| ! rigid support in one direction and snubber in the other direction, or (b) snubbers in two directions.
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| : 21. In addition, when using a snubber near a one-direction rigid support, close attution would be given to how the t snubber and rigid restraint interfaced. In other words, a snubber would not be placed on the side of the rigid restraint where the pipe movement would cause the snubber clamp to hit the rigid restraint and restrict the axial movement. Most engineers issued the two packages (snubber and rigid) to the field together. Also, both packages would note that one should be considered in relation to the other on installation to pmvent interference pmblems.
| |
| j 22. Drawings on the other projects and the old drawings on l Diablo Canyon included the snubber movements so that j someone in the field could catch any installation interfemnce problems (Note: Originally in Unit 1 work, we included this data, but when someone decided it was unnecessary we were instructed to remove all movements.).
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| ! 23. In no case would I use a snubber when the themal displacement in that support direction was less than 1/16",
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| which is typically an industry-used value. Had these requirements been written into M9, there would be few dead band prod 1 ems at Diablo Ganyon.
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| 24 I have three concerns: (1) Why were these snubbers placed so close to bilateral supports and anchors? (2) In all cases where a snubber does not activate, was the stress anlysis for that load case redone omitting the snubber?
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| (See Snubber Displacement Chart (Exhibit 6).) (3) Has anyone reviewed the mcords to determine what was installed first: the snubber, the rigid restraint, or the anchor?
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| 1430d _ ___. _ _ . _
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| : 25. I think PGandE's sisunary of attachments is worth restating in different tems. Seven of fifteen snubbers do not lock up under Design Earthquake (DE) displacement, six of fifteen snubbers do not lock up under Double Design Earthquake (DDE) displacement, and four of fifteen do not lock up under Hosgri (Hos) displacement. Is it possible that 465 of all snubbers in the Plant are unnecessary? How much money was wasted due to (1) engineering design, (2) material, (3) construction, (4) re-evaluation, (5) removal, (6) possible risk to workers to perfom muoval if the plant is in operation? All as a msult of, inadequate design criteria by management. (Undated Stokes Aff.,
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| Attachment 4, at 12-14. )
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| Mr. Stokes begins this allegation by acknowledging that industry practice is not to include snubber dead band when performing seismic analysis. He then seems to contradict this by mentioning the " dead band problems at Diablo Canyon." First of all, the total number of snubbers installed at Diablo Canyon ir consistent with the number found at other nuclear power plants. While there are some snubbers installed at Diablo Canyon which are not needed to qualify the final installed piping configuration, they are mlatively few in number.
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| In no case do these unnecessary snubbers result in a piping overstress or a support overload. The presence of these snubbers, therefore, has no effect on plant safety.
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| l I
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| The Diablo Canyon design criteria are intended to define piping design mquirements consistent with plant safety, not to achieve the optimian usage of snubbers. Notwithstanding this lack of safety significance, but in order to reduce future maintenance requirements, PGandE has committed in letter DLC-84-060 to the NRC Region V, dated Febmary 15, 1984, to a snubber reduction program to eliminate all unnecessary snubbers by the second refueling outage.
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| 1430d , . _ - - _ - . - - _ _ _ - - -_ - - . - - . - _ _ _ _ _ _ _ _ - .
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| | |
| program to eliminate all unnecessary snubbers by the second refueling outage.
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| l l
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| l 1
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| * t l
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| 1430d _ _ _ _
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| i i
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| III-22 It is alleged that:
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| NRC Question: (Allegation 89, SSER 21)
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| Improper resolution of pipe interferences (p. 21):
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| : 26. When I wa: in Quick Fix for Unit 2. I deleted a i
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| support that was in the process of being installed when a Pullman field engineer brought this problem to sqy
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| , attention. Upon a visual inspection of the line configuration and support proximity, I questioned the necessity for adding a support at that location. I placed the support on hold for 24 hours until I could check with l the stress group to see why it was being added and whether it was necessary. Upon locating the stress engineer, I was told that the pipe was resting on a piece of unistrut and that ME101 would not allow a dead load seismic restraint and that a support had been modeled in. This support was unnecessary, as loads to all supports were in the neighborhood of 10 pounds. The stress engineer should have requested the removal of the unistrut or its movement, so as not to interfere with the pipe. However, upon discussion, he agreed that the support could be removed and told me the stress analysis would be corrected, and I agreed to void the design through Quick Fix to prevent its being installed.
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| l l 27. In the last line of its response, PGandE states that "it would appear that this situation demonstrates good comunication between Construction and Engineering, sound engineering practice, and a proper solution that resulted in a system that meets the design criteria." In fact, this
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| " proper solution" occurred only at sqy initiative, and I was later laid off for taking these kinds of initiatives. This
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| , kind of response cannot be assumed for other cases, and by l other engineers. (Undated Stokes Aff. Attachment 4, .
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| at 14-15.)
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| Although the specific instance Mr. Stokes relates in his affidavit 1
| |
| i occurred, it does represent a reaso.nable example of " good
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| , comunication between Construction and Engineering, sound engineering
| |
| ! practice, and a proper solution that resulted in a system that meets the design criteria." Mr. Stokes did identify the problem with the l
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| 1432d L
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| | |
| i pipe support. He did not mention that the removal of the unistrut also required reanalysis, redesign, and construction. The reason that the unistrut was removed was that it was more cost-effect.ive than installing a new pipe support. The fact that this positive outcome resulted due to Mr. Stokes' initiative is gratifying, since that was what he was being paid to do. Mr. Stokes' contention that he was later laid off for taking these kinds of initiatives is incorrect. His layoff was part of a planned force reduction.
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| l l
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| l l
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| 1432d . . . _ _ _--__ - - _ - . _ , _ . - - . . _ _ _ - _ . - . . _ _ . - . _ - _ _ __. .__ ____ _ _
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| | |
| III-23 It is alleged that:
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| NRC Question: (Allegation 79 and 88, $5ER 21) r.aiculation or tne Ioaa-carrying capacity or small bore piping suport (p. zz):
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| 1
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| : 28. PGandE states that "All final calculation packages are retained and pemanently filed. There is no regulatory or other project requimment to retain the intemediate or interactive analyses." However,10 CFR 50.34(b)(4) provides that "A final analysis and evaluation of design and perfomance of structums, systems, and components with l the objective stated in paragraph (a) (4) of this section i and taking into account any wrtinent infomation developed
| |
| ! since the submittal of the "'reliminary Safety Analysis l Report (P5AR)" (emphasis added). The proolem Is tnat ruanat.'s and Bechtel's final documents at Diablo Canyon ignore pertinent infomation developed in the design verification review. Vital data was not taken into i
| |
| account, incorporated or even referenced in the final calculations. It just disappeared. Consistent with standard industry practice, one would expect to find a steady progression to a more detailed, more technical, more expert calculation. This is in fact Bechtel's procedure or standard in practice at other plants, even though it may not be staTea in writing.
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| : 29. Having worked in the nuclear industry with and for Bechtel, I can describe the company's and the industry's standard practice for the history of a support analysis.
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| First, there is a preliminary calculation by the design engineer. He may approach the problem using several
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| ! proposed designs. These may be based on his knowledge and l creativity or on others' knowledge and creativity obtained through discussions. In any case, a final approach is decided upon and calculations are completed by him. This analysis is then given to a checker (an independeat reviewer). He will check technical points, Code sections l relied on, math, ease of construction, and cost competitiveness compared to an alternative. He either
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| , agrees with the results as they are or suggests changes and i
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| returns the package to the design engineer. The design engineer then mviews the checker's comments. He egy not agree, and then the designer and checker will have a discussion, usually coming to a mutual understanding. '
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| After the calculation is complete to the satisfaction of l
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| both the designer and checker, they sign it and the package j
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| is given to a supervisor for review and approval.
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| i i
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| l j 1426d '
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| | |
| Sometimes the supervisor (who would have greater experience) will ask for a complete redesign. The designer and checker then redo the calculation, sign it, and return it to their supervisor. He signs it. After his signature, the preliminary calculation becomes a final calculation package.
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| : 30. Later, new loads may be imposed due to a mistake being discovered. The calculation is then reviewed to see (1) if it is still acceptable; or (2) if it will require modification. These calculations are necessary as a basis for subsequent modifications. Even if the loads are of a preliminary nature, no need arises to remove the calculations showing non-compliance with Codes. In those cases, final loads can be compared against preliminary failing loads that are used to detemine if the support requires modification. In review of final loads against preliminary loads, in uany cases an engineer need only compare loads and reduce previous calculated stresses as a percentage reduction of load. In others, the results may not be so easy and an engfreer may redo some or all of the f calculations. When doing a later review for load changes, l many engineers do not review a previously checked l calculation if in the past it was passing. However, if the -
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| previous calculation was failing, complete review of the calculation would be necessary to see if errors had occurred that might be corrected and cause the support to pass before modifying it. (See attached example calculations on hanger 100-1FR-1 by both Gary Katcher and 6.R. Shaw (Exhibit 7).)
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| : 31. With respect to Exhibit 7, I would like to make several points. PGandE stated that they have sharpened their pencil to prove the supports adequate now, even though they failed under preliminary loads. A careful comparison of the calculation of Gary Katcher and that of j Shaw is instructive. Mr. Katcher's STRUDL model is considerably more detailed than Shaw's: (1) The cover sheet demonstrated that Katcher's version was performed before Shaw's; (ii) Katcher's includes more pages than Shaw's. Note on Katcher's three-sheet Summary his finding that base plates and anchor bolts failed; Shaw's didn't.
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| Note also the sketches in Katcher's drawing that show the detail to which he resorted in investigating in the field the true configuration; Shaw used Katcher's sketches.
| |
| Compare Katcher's load sheets load point by load point to Shaw's. The are identical. Both loads are the same not more advanced as PGandE has claimed to the NRC. Finally, compare calculations; Katcher's is more detailed than l Shaw's.
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| l 1426d I t - -.- . - - _ - _ _ _ .-_ ___
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| | |
| . 32. The only conclusion to be drawn is that Katcher sharpened his pencil while Shaw dulled his, unless the later model was a suggestion by his group leader to omit eccentricities or to introduce various other management-imposed inaccuracies. Also, I believe Mr. Katcher's work is a good, typical example of all the unused failing calculations that PGandE has admitted to thmwing away.
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| : 33. This comparison contradicts a number of statements
| |
| : made by DCP personnel at the December 15, 1983 meeting with the NRC Staff. One example: "[We] use more sophisticted l techniques, more advanced techniques to see if it is possible that more detailed, more thorough, more sophisticated analysis can show that the pipe and supports in its existing configuration is acceptable." (Transcript,
| |
| : p. 9.) This was a false statement. Simliarly, on page ll, secend paragraph: "Even the logic of an implication that
| |
| ! we intentionally mislead is faulty." For anyone to suggest that we would risk all of this effort to save a support on a half-inch line to keep from modifying a support on a 3/4 inch line is ludicrous in ny mind." It would be ludicrous to me, as well, on the above-stated premises. But it is l
| |
| not so ludicrous if the modification would exceed the l percentage detemined by the Diablo Canyon Project to require expansion of the sample and themby cause delay in the start-up of Unit 1. I have been told by supervisors that the cost per day to PGandE during any non-operation aeounts to about a million to a million and a half dollars. (3/23/84 Stokes Aff., Attachment 4, at 15-19.)
| |
| Mr. Stokes' apparent " understanding" of the record retention i
| |
| requirements for superseded calculations is simply wrong. The only calculations required to be retained are the final calculations which i
| |
| reflect the analysis actually relied upon to show adequacy of design. ANSI standard N45.2.9(1979) does not require mtention of intemediate calculations, nor does any NRC regulation, regulatory guide, standard, or procedure. The section of 10 CFR 50.34 which Mr. Stokes refers to in this allegation has to do with the Diablo Cartyon FSAR, not superseded calculations.
| |
| 1426d _ __
| |
| | |
| 1 A discussion of the history of the calculation for support 100-132 (calculation MP-444) was presented in PGandE letter DCL-84-046 to the NRC, dated February 7,1984, pages 31 and 32. Notwithstanding Mr. Stokes' preoccupation with the unique historical background of this support, the support has been shown to meet all licensing criteria without modification.
| |
| Mr. Stokes then erroneously interprets the small bore reverification sample program basis. The program was described in detail in the PGandE response dated March 6,1984, to Joint Intervenors' Motion to Reopen DQA, Attachment B, paragraphs 21 to 28. In that response i
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| PGandE states clearly that any technical matter for which a support failure was identified would automatically cause the sample to be expanded to address that concern generically.
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| l l
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| l l
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| l 1426d \ _ _ _ _ _ _ . . . _ _ _ _ _ _ _ _ _ _ _
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| | |
| l III-24 It is alleged that'
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| : 34. PGandE states that "no joint is completely 1005
| |
| ! rigid." This is true for the figure 1005, since the loads transferred to a joint cause strains that stretch the material making up the joint. From any basic strength of l materials or structural design text this can be shown.
| |
| l However, in many such texts, designs are postulated that for all practical purposes are 1005 fixed.
| |
| : 35. In many instances, the joint is modeled so that no moment resistance is offered by the steel to which the member is attached. In structures, these connections would be, for example, column to beam with angle clips. However, in pipe supports, almost all joints are designed as moment connections, at least to carry the moments induced and l
| |
| calculated at the joint. Also, to my knowledge the only l joint that would qualify for a moment release in any I direction is a single line weld about the axis along its length. It would still have 2 moment resistance. [ Example deleted]
| |
| All joints configurations [ examples deleted] and others should not have joint releases used. Some computer programs allow that factor as an input for the joint, but these ut.ually are no lower than .6 or 605 fixed. PGandE's response does not resolve the allegation or explain the use of joint releases for rigid connections. (Undated Stokes Aff. , Attachment 4, at 19. )
| |
| l l
| |
| Mr. Stokes apparently 1's not familiar with the use of the " joint release" technique as a method of providing an accurate representation of end connections in the analysis of structural .
| |
| members. He claims "All joints configurations...should not have joint releases used." This practice, however, is standard in structural engineering evaluation of frame structures. The NRC staff reviewed this issue and concluded in SSER 22: "However, the staff also finds the engineering basis and approach as described by the DCP acceptable and in accordance with current engineering practice," and 1435d - _ , _ .. _ . .
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| | |
| I l
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| l I
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| i i
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| later, "The issue of assumed joint releases for rigid connections is considered resolved."
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| l l
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| l l
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| 1435d . . . _ .
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| | |
| l l III-25 l It is alleged that:
| |
| l
| |
| . 36. Althougt PGandE's response mentions only section l W-3260 of ASE Section III, the section NF-3260 includes sections 3261, 3262, 3262.1, 3262.2, 3262.3, and 3262.4,
| |
| ; and U-bolts came under sections NF-3261, NF-3262, and E -3262.4 (component standard supports as defined in
| |
| , section F-1214). Also relevant is section E-3226.1 --
| |
| "8 earing Loads" -- which states, "(a) The average bearing stress for resistance to crushing under the maximun load, test loading, or l experienced any seismic loadings,as a result of design except loading, those for whic liTevei u nuits are designated, should be limited to yield stress (Sy) at temperature, except that when the distance to a free edge is larger than the distance over which the bearing load is a > plied, a stress of 1.5 Sy at temperature is permitted."
| |
| (Daphasis added.) (See ASME Section III, NF-3226.1, 3260 et seg. (Exhibit 8).T"This section in effect requires that i
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| U e support to the pipe not exceed the recommended bearing stress level.
| |
| 37 I believe an accurate calculation would show that at the point of loadng the pipe to the U-bolt, only a point contact occurs. It is obvious that any load applied on a point will have an infinite stress, which will cause the U-bolt to fail under this section. In B31.1, I should note Section 102.3.1(B): the " allowable stress values in
| |
| : bearing any be taken at 1605 of tabulated value." Even this section will dictate that a U-bolt not be used.
| |
| : 38. In ASE section F-1241.1 " Types of Component" --
| |
| standard supports are listed (U-bolt is not listed).
| |
| l Shoes, lugs, rings, clamps, slings, straps and clevises are l
| |
| listed. These load-trar.smitting hardware typically have common characteristics. They are form fitting and all have width. They all spread the load over a larger area of pipe than a U-bolt. I understand that the use of U-bolts by many in the industry is justified on the grounds that they offer a simple installation of a cheap component. However, their use at Diablo Canyon is not supported by local bearing stress calculationsi Note that even a component supplied as a catalog item should be chosen by the stress engineer to comply with all mquirements of the Code selected as the design basis, whether B31.1 or A5E Section W. I know many engineers fail to check bearing stress.
| |
| At other plants, after I raised this point, management decided to replace U-bolts or pad load area so that bearing stress was acceptable.
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| I 1566d . . - - - . _ . - - - - . . - - - - - . _ . - - -
| |
| : 39. In Paragraph (1) of its suunnary of conservatisms, PGandE states: "The test loads used in the equation of W-3260 represent the lowest tension and side test loads found for 1/4 in. and 3/8 in. diameter rod U-bolts, respectively." To illustrate my point, results are suunnarized below from the U-bolt test data sheets:
| |
| : 1. Pipe Size 1/2" Rod 1/4" Force at .025 Displaceaant [ sic]:
| |
| Run 1 = 1700 lb. (which failed)
| |
| Run 2 = 2600 lb.
| |
| Run 3 = 3500 lb.
| |
| Run 4 = 2300 lb.
| |
| Run 5 = 1800 lb.
| |
| : 2. Pipe Size 3/4" Rod 1/4"
| |
| , Force at .025 Displacewnt:
| |
| Run 1 = 1900 lb.
| |
| Run 2 = 900 lb.
| |
| Run 3-= 1300 lb.
| |
| Run 4 = 2000 lb.
| |
| Run 5 = 1900 lb.
| |
| : 3. Pipe Size 1" Rod 1/4" Force at .025 Displacement:
| |
| Run 1 = 4000 lb.
| |
| Run 2 = 2700 lb.
| |
| Run 3 = 1900 lb.
| |
| Run 4 = 3100 lb.*
| |
| Run 5 = 1800 lb.** (1700 at .025")
| |
| * Run 4 stopped for safety reasons
| |
| ** Run 5 carried to .0265 in.
| |
| : 40. Thus, the low tension values are as follows: 1/2" [d]
| |
| : pipe was 1800 lb. at .025"; 3/4" (d] pipe was 900 lb. at
| |
| ! .025"; and 1" [d] pipe was 1700 lb.; 3/4" [d] pipe with j 1/4" rod size tension load using PGandE's failure point of l .025 in. shows that the lowest failure is 900 lb. force.
| |
| Inserting this as TL in Equations E-3262.4 Level A Limits l
| |
| Load Ratio = TL x 1.0 ($ or Fall /Sy) using S = 32.8 at 2000F KSI SU = 65KSI, the load rating for this U-bolt would be 454 lb. per Dwg. 049243 Sh 261/2 pipe 1/4" bolt 1566d -. . . - - - . _ _ _ . - _ - - . _ . - . _ . -
| |
| | |
| l tension load case 142 = 2000 lb. In short, PGandE exaggerated the strength by owr four times.
| |
| : 41. PGandE's response does not explain how the data in the U-bolt Test Program became nor does it 049243 Sheet 26(Seeattached prove that the results are conservative.
| |
| Sh 26 of 049243 and 1/4" Rod Data Sheets (EHTbit 9).)
| |
| l 42. I am at the disposal of the NRC for an in-depth look l
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| at the U-Bolt Test Program and the results of the data.
| |
| (3/23/E4 Stokes Aff., Attachment 4, at 20-22.)
| |
| i The information relative to the development of "U" bolt allowances
| |
| ! was provided to Mr. Stokes over one year ago when he requested a copy of the test data from OPEG management. The NRC has reviewed the basis for U-bolt allowables and has found it consistent with the reverification effort. Numerous allegations have been made and satisfactorily answered, and still Mr. Stokes is unsatisfied.
| |
| The statements made in this allegation are either wrong, misquoted, or confused, and make response difficult.
| |
| It is obvious to anyone familiar with ASME Section III that when one quotes a main paragraph number all relevant subparagraphs are automatically included. For example, if one were to cite NF3260, it goes without saying that it includes the applicable sections %f3261, 3162, etc.
| |
| Mr. Stokes states, "Also relevant is section NF3226.1..." To the contrary, 3226.1 is a subparagraph under the general heading NF3220,
| |
| " Design of Plate and Shell Type Supports by Analysis." This 1566d paragraph is clearly not relevant or applicable. Furthermore, the Point that Mr. Stokes is attempting to make on " test loading" is wrong. The test load referred to in NF3226.1 is the pipe operational condition and not the method used to qualify the pipe support.
| |
| The point contact issue is apparently referring to Section NF3226.1 which is not applicable to the method of qualification by testing.
| |
| It is difficult to understand why Mr. Stokes steadfastly refuses to accept the results of a comprehensive testing pmgram but rather desires to prove by theoretical analysis that a U-bolt fails when the test clearly demonstrates that it doesn't.
| |
| ~
| |
| Mr. Stokes refers to a nonexistent ASE Section NF1241.1. -
| |
| Section NF1214 lists some of the component standard supports and states that Figure NF1214-1 shows typical catalog items. This figure shows a "U bolt" as a " Typical Component Standard Support Unit."
| |
| The load values cited are not the test / failure loads that NF3262.1 allows. These values are much higher than the valaes cited. The method used by PGandE to qualify U-bolts by test is consistent with the rules of Section NF, " Design by Load Rating."
| |
| l 1566d _ _ _ _ _ _ _ _ _ _ _ __- _
| |
| | |
| ~ _. _
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| l l
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| l III-26 It is alleged that:
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| : 43. I am reviewing documents supplied to the NRC and will also do my own research on references in this country to which I will submit an in-depth statement on applicability of Australian papers and any available U.S. information.
| |
| My contention is that the use of a nuclear plant as a proving ground for a new design is not in the interest of public safety. As a licensed professional engineer, I believe the use of this information is premature until the profession in this country is able to assimilate and verify its reliability for the unique conditions at a particular nuclear plant, such as Diablo Canyon. (Undated Stokes Aff., Attachment 4, at 23.)
| |
| Mr. Stokes contends that use of Australian data as the basis for design of unbraced angle members in bending should not be allowed until the profession in the U.S. has a chance to assimilate and verify its reliability. In fact, the AISC has endorsed the use of the Australian data. A reprint of the Australian paper " Safe Load for Laterally Unsuppcrted Angles" was published in the official Engineering Journal /AISC, First Quarter,1984. The AISC's position is summarized in the editor's note to the reprint. The editor stated: "The AISC Specification and Manual offers limited direct design criteria for such members." The paper was reprinted "in response to the many inquiries AISC has received on the subject."
| |
| The editor also mentioned that the Australian papers "have often been referenced in the past to provide requested design guidance." Thus, it is PGandE's belief that AISC has adopted the use of the Australian paper for design of angles in bending.
| |
| 1 1437d - 1-i r__.__.,_.y __ _ y .__ y _ , ,__
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| - . . - - - . . _ ._ , _m.,.__._.7__-m_.,___.__-.._y
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| | |
| i III-27 It is alleged that:
| |
| : 44. I was told, as were others, that a sample based on 5000 feet of pipe would be examined to justify the design of 25,000 feet; and that if 5% of these 5000 feet failed to meet criteria, then all 25,000 feet would have to be reviewed. Also, we knew of the generic categories of TERMAL, Seismic Anchor Movements, and Themal Anchor Movements code break and a,ctive valves.
| |
| : 45. PGandE states in Paragraph 2 of its msponse that the sample was 5000 feet for 25,000 feet and, in Paragraph 4, that it later changed to end up with 5000 feet for 15,000 feet. This contradicts the statement that "the initial sample selected in the fall of 1982 remained the ' sample' throughout the small bore reverification program." It appears evident that when supports failed in the sample and justified a complete review of all supports, PGandE reclassified those problems as generic rather than admit the need to review all supports.
| |
| : 46. If this statement is true on the other hand, then the supports in the sample which were reviewed as generic should still-be considered as sample supports. In that case, approximately 405 of the sample failed. This figure is based on the fact that the sample was used to justify 25,000 feet of piping originally, which later was reduced to 15,000 feet. The difference here,10,000 feet, would have been detamined to be generic. 10,000 feet divided by 25,000 feet is equal to 405. I have told the NRC that I l was failing about 505 of the sup> orts. I believe the difference,105, may be due to tw inclusion of torsion in ny calculations. In any case, under these circumstances, the review program must be expanded to a full review of the additional 15,000 feet. The results of the wort done are further in question, since the NRC Staff reported that nine l
| |
| out of twelve packages that they reviewed were unacceptable, due to one or more errors.
| |
| : 51. In conclusion since time does not permit a complete rebuttal to PGendE,s response, I would like to make one last point. In all of the responses I have read, no detailed calculation was included demonstrating that the issue raised through a specific example of support has been accurately resolved and is no longer a problem. Based on previous practices and the false statements that I can identify through personal experiences, these responses cannot be accepted without a verifiable public record of 1439d _ - - - . - - . . .
| |
| | |
| supporting data. I would like to see copies of specific support calculation packages that I will identify, with notes of problems originally discovered. These may be placed on public record, so that the quality of engineering work at Diablo Canyon can be reviewed by other interested parties.
| |
| I would like to restate that I an available to discuss with the NRC any of the issues relating to the subject matter of this Statement, to any earlier affidavits, or to any other matters concerning Diablo Canyon of which I as aware.
| |
| (Undated Stokes Aff., Attachment 4, at 23-25.)
| |
| The source of Mr. Stokes' misinformation concerning the san 11 bore
| |
| , sample program is not clear, but it most certainly did not come from his supervisors within OPEG. Specifically, the alleged 5% failure Itait 4 total'ly unfounded and without basis. No such limit was ever even considered for the program. Mr. Stokes apparently refuses to understand the basis for the sample and generic aspects of the small bore reverification program. He states "It appears evident that when supports failed in the sample and justified a complete review of all supports, PGandE reclassified those problems as generic rather than adult the need to review all supports." What he fails to recognize and/or understand is that by reclassifying a problem as generic, all supports which exhibited traits or characteristics similar to the problem support--that.is, those which had the same generic concern--g reviewed . -
| |
| l Mr. Stokes then concludes this allegation with a mathematical l
| |
| exercise which leads him to a conclusion that 405 of the sample supports faileo. This appears to arise from his arbitrary rejection r
| |
| 1439d , .
| |
| ~,-er.-,ee,wr---.---,----w---,-r,-----
| |
| | |
| of the generic review concept and his view that all support modifications under the generic review are failed sample supports.
| |
| I l
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| i l
| |
| l t
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| I I
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| 1439d - -, . - . - _ . - . _ . . _ . - - - _ _ . . . _ _ _
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| | |
| l l
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| III-28 It is alleged thn:-
| |
| : 47. In reply to PG&E's letter: DCL-84-083 Question 2, the true intent here was that foreign steel was being esed (not that it was from Japan). Canadian steel was adettted.
| |
| However, it is contended that steel with 1.5t radius does
| |
| . , . , not exist at Diablo. . I know this to be false. My supervisor, Jeff Van K1captenburg, had a piece of 2x2x1/4 tube on his desk which had one corner with a 1.5t radius.
| |
| He said he obtained it by having a piece cut from stock.
| |
| This fact, when combined with PG4E responses, leaves only one possibility. Steel from ar.otner country was used at Disblo.
| |
| : 48. PG4E response to questions 2b, 2c and 2d.
| |
| The problem betwean 1.5t, 2t or 3t is the magnitude of weld
| |
| - which AWS gives credit for, based on 5/16 n. If the condition exists where R=1.5t insfeaf cf R=3t as assumed by PGandE, the installation wovid result iP a condition that is 50% deficient frota original design. In some cases the joint detail might have to change. Instead of a butt joint (tube to tube) to plate might be required so that e fillet cap could be added to increase the weld. This is especially true on 2x2x1/4 TS.
| |
| : 49. AttachmentCofPG4E'sLettei. United Engineers state
| |
| ~'
| |
| that' when welding 3x3x1/4" tube that problems were l ~ encountered in obtaining 5/16 R welds. As a [ illegible or l
| |
| deleted] they recommended that a 1/8" electrode be required l
| |
| . for the first pass to ensure adequate penetration. This
| |
| , ' resolution should also be required for 2x2x1/4 tube.
| |
| L '3x3x3/16, and other tube stue. IJpon review of Pullman's
| |
| , -~ procedures, no limit of 1/8" eltt yode is required.
| |
| Therefore per PGAE's own statements,' welds on 3x3x1/4 tube
| |
| - and under are in question as to meeting the 5/16R amount I- which was assumed by design. (Undated Stokes Aff.,
| |
| Attachment 4, at 26-27.)
| |
| This issue was fully addressed in PGandE response to T. P Allegations JIR-18 and 19, provided in PGanhE letter DCL-84-239, dated June 26, '1964, to the NRC. ~
| |
| x ._
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| I
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| /;e 1
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| r /
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| /_ 1670d 'e ,
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| | |
| i l
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| III-29 It is alleged that:
| |
| : 50. I would like to also state that I have read the rebutal [ sic] to Pacific Gas and Electric (PG4E) comments concerning welding. I completely agree with the authors [ sic] beliefs and through w own personal efforts have substatiated [ sic] that almost no meetings have been held as contended by management to corect [ sic) the problaes at Diablo Canyon construction site. (Undated Stokes Aff., Attachment 4, at 27.)
| |
| It is not clear to which rebuttal regarding welding Mr. Stokes is referring, or what alleged problems the meetings were intended to address. There is insufficient substance in the allegation to pemit a meaningful response. However, each of the rebuttals regarding ,
| |
| welding is addressed separately separately in this filing, i
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| l l
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| 1653d ,
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| | |
| III-30 It is alleged that:
| |
| : 1. "If any misinterpretation concerning weld symbols occurred, steps were taken to prevent reoccurrence by conducting meetings with personnel or by clarifying procedures."
| |
| Response: P G A E's response to this particular concern is only partially true, In fact, Pullman has issued various revisions to ESD ' 23 (one of the relevant construction engineering documents in this instance), yet failed to reference American Welding Society Standard (AWS) A2.4 as being the standard for weld symbol interpretation. The significance of this is that the procedures still do not reference a governing, controlled document that establishes universal interpretation of welding symbols throughout the plant. This ambiguity can allow welding that does not meet the original design intent to be perfomed in the plant on Seismic Category I structures. Without a standard to use, it is impossible to have a quality assurance program to
| |
| . verify the " Design" to " Installation" criteria is [ sic]
| |
| properly applied.
| |
| .I further take exception with the position that extensive steps have been taken by management through meetings to' clear up the confusion. To imy knowledge, as of March 16,1984 meetings to discuss the weld program deficiencies have not been held with the field pre-inspect engineers responsible for implementing any changes .in established practices. I know this, for I personally would have been in attendance. I found this response puzzling, and questioned sqy lead, John Rhodes, as to P G 8 E's commitment to AWS A2.4. His response was that we were not coinnitted to AWS but were committed to whatever management told us to do. See attachment 7, interoffice nev randum 034318. This document states that not until October 15, 1983 did they require strict compliance with AWS A 2.4. (Undated Anon. Aff., Attachment 5, at 1-2).
| |
| The following allegations relate to PGandE's letter to the NRC Region V DC 040, dated Febmary 7,1984, which, as requested by the NRC, provided an overview of the weld symbols issues.
| |
| This letter included examples of some problems, and an 1501d - -. - _ _ . _
| |
| | |
| explanation of how those were accommodated. The letter pointed out that welding symbols are a part of a casumnication process. Welding symbols were addressed in PGandE letter DCL-84-166 to the NRC, dated April 30,1984. The over..ew on welding symbols from the letter is repeated here.
| |
| WELDING OVERVIEW WELD SYMBOLS The following twenty-two allegations are based on weld symbols: 171, 173, 174, 234 through 246, 248, 249, 252, 253, 254, and 263. These allegations represent 16% of the allegations in GAP II. The allegations come from only two sources: first, Mr. Stokes, and I
| |
| these were previously addressed; and second, GAP II anonymous affidavit attachments, which have not been made available. The allegations all fail for either a lack of substance, lack of context, technical errors, false or misleading statements, or a combination of i these reasons. The subject of weld symbols was discussed with the WRC and documented in PGandE's letter DCL-84-040, dated February 7,1984. It is recommended that the February 7th letter be reviewed to assist in understanding the msponse.
| |
| This overview is provided to keep the significance of the allegations in perspective. The total program l with regard to weld symbols has worked effectively l from design calculations to as-built structures.
| |
| American Welding Society symbols for welding have been I used at Diablo Canyon since its inception. Symbol l usage has been incorporated irM the project by l numerous references to contrac; wcifications and l other documents. AWS symbols ha, 'sen used as the common basis for connunication wi, ..a the United States welding industry, regardless of the fabrication I code specified or product constructed. As stated in AWS A2.4, the intent of symbols is to facilitate 1501d -. . _ _ . . . . . .. . . _ . _ - - - . - - . . _ . _
| |
| | |
| l comunication. The AWS symbols have been used by l common consent even where not specifically referenced, i just as the English language has been used at Diablo Cartyon. Symbols sty have occasionally been used l
| |
| imperfectly, but the requind meaning was conveyed and understood, and the use of any non-standard symbols has not resulted in unacceptable welds. The parallel between weld symbols and the written and spoken l
| |
| 1enguage exists in that grammatically imperfect language can effectively convey meaning and l
| |
| mquimments.
| |
| l l Engineering and inspection personnel have acquired knowledge of welding symbols through their experience, education, training, and use of references. Pullman has included questions regarding weld symbols in the QC inspectors' qualifications tests since 1974, and l
| |
| has included AWS A2.4 in the reading list for QC inspectors. Welding symbols are not difficult to master. In fact, approximately six symbols account for almost all field welds.
| |
| Due to the rapid expansion of the Diablo Canyon plant staff, specific training programs were conducted mgarding AWS A2.4 weld symbols. Three hundred and fift,y engineers and QC inspectors were trained during May, June, and July of 1983. Additional pre-certification training was conducted for the AWS Certified Welding Inspectors Program in June-July and November-December,1983.
| |
| PGandE letter DCL-84-040 provided an overview of the weld symbols issue. Examples of symbol concerns and unclear symbols were intentionally included.
| |
| Notations were made on example drawings contained in DCL-84-040 to show how the Project addressed the specific concern, and how the Project compensated for lack of specific or clear weld size infomation.
| |
| Previous correspondence was included with DCL-84-040 showing examples of how some imprecise weld symbols on previously issued drawings wem to be integrated.
| |
| Additional correspondence displaying examples of preferred symbols, labeled D0, ed non-preferred symbols, labeled DON'T, were also included. The D0s and DON'Ts were identified as applicable to new drawings.
| |
| In a few cases, specific narrow scope exceptions to the standard symbols have been documented. These 1501d l
| |
| l documented exceptions to A2.4 symbols use are wruissible and correct in the context of the Diablo i lartyon Project. )
| |
| Weld symbols cre not used in a vacuum but are part of a program of communication between design engineering and construction in the field. There have been, and will continue to be, additional verbal and documented communications between engineering and construction
| |
| ! clarifying design requirements. These communications
| |
| , are a necessary and proper method to assure that the welds required by the design are installed in the l plant.
| |
| As has been explained, the AWS welding symbols have been used at i Diablo Canyon since its inception. These symbols are the common basis for communication within the United States welding industry.
| |
| The fact that Pullman did not reference the A2.4 document in ESD "~
| |
| is of no consequence because the use of these symbols and their interpretation is inherent. Contrary to the allegation, this did not result in an ambiguity. Because the AWS welding symbols are commonly ;
| |
| available in references, this complaint has no merit.
| |
| l The assertion that the Project was not in compliance with AWS symbols until October 15, 1984, is also false. The alleger's Attackant 7 was included in PGandE letter DCL-84-40. This subject is also addressed in III-33G and III 37, below.
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| l 1501d 1
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| ^ ^
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| 1 l
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| l III-31 :
| |
| It is alleged that:
| |
| : 2. "Also, potential weld requirement misinterpretations were accounted for in the design process."
| |
| Response: A direct interpretation of this statement leads one to believe the engineers intentionally designed ambiguity into their design. This statement is ludicrous.
| |
| If the potential existed for misinterpretation and was i realized by management / engineering wh wasn't the situationremediedfromtheon-seti AWS D.1.1, paragraph 1.5 states that special conditions shall be fully explained by added notes or details. Had this basic engineerit.g practice been followed it would have minimized the confusion, the cost overruns and schedule delays. This position by P G & E/Bechtel management could only be an open admission to intentional cost overruns or gross mismanagement of their contractors. (Undated Anon.
| |
| Aff., Attachment 5, at 2.)
| |
| The alleger apparently considers the design process to be limited to the simple act of drawing a symbol on paper. The design process in fact is obviously more complex. The process involves the initial drawing, Construction's interpretation of the drawing, preparation of
| |
| ; the as-built drawing, and reconciliation of the as-built drawings.
| |
| I In this process, Construction systematically interprets weld symbols most conservatively making longer, thicker, larger welds where there may be questions. In reviewing the as-builts, designers use the l
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| l smaller, shorter interpretations if a symbol is ambiguous. At this i
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| stage, the designers do not take av credit for ambiguous or non-quantified symbols, such as square grove welds, seal welds, and heavy welds, unless the welds can be quantified.
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| 1675d - - - - _ _ - - - -_ - . - - . . . . - - _ _ _ - _ - . - - _ .__-_ _ -.
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| | |
| i PGandE letter DCL-84-040 to the NRC Region V, dated February 7,1984, contains numerous examples of special conditions being explained by added notes or additional details.
| |
| l i
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| l 1675d III-32 It is alleged that:
| |
| : 3. "The Diablo Canyon program is typical for the industry . . .".
| |
| Response: To me this statement reflects P G & E/Bechtel position that "we're not worse than the rest of the industry, don't pick on us." The relevant codes have been isolamented since the early 1970's. The failure to comply with these rules is a burden that rests upon P G A E 1rrespective of industry practice. (Include copy of " Focus on Nuclear". Attachment i 16).
| |
| To further illustrate this fact, it has long been a position that Pullman is erecting the plant in compliance with ANSI 831.1, and ANSI B31.7 with welders qualified to ASE Section IX. ANSI 831.7. paragraph 700.2 directly invokes AWS A.3.0 (Tems and Definitions). (Undated Anon.
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| Aff. , Attachment 5, at 3. )
| |
| This allegation does not assert that anything is incorrect; it simply expresses an opinion. PGandE's use of welding symbols was proper in accordance with ASME, ANSI, and AWS codes.
| |
| d I
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| 1503d __. _ _ . _ . -_ _ _ _ _ . _ _ __ _ _ _ _ . _ _ _ _ . - _ _ _ . . _ . . _ _ _ . _ _ _ _ _ . _ . . _ _ _ _ _ . _ _ -
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| | |
| III-33A '
| |
| It is alleged that:
| |
| 4 "The weld symbols used at Diablo Canyon are consistent with the standards specified in AWS D.1.1, Section 2.4".
| |
| Response: This author has been told on several occasions that AWS standards do not apply to Diablo Canyon, since it is being built to ANSI 831.1 ANSI 831.7 and welders qualified to ASME Section IX. Yet the ANSI standards and ASE codes do not directly reference the use of welding symbols at all. The only clarifying point made in the
| |
| , ASME/ ANSI co1es states that all joints must be detailed to give the installers the necessary information to insure the joint is welded as designed.
| |
| To my knowledge, there exists no controlled, centralized document on site that clearly defines the proper use and interpretations of weld symbols on the project. This shortcoming exacerbates the lack of uniformity in compliance with consistent practices of proper weld design.
| |
| Further, AWS 0.1.1 Section 2.4 as referenced in the P G & E
| |
| [ sic] response addresses only filler material and not weld symbols. The correct. AWS standard is AWS A2.4 " Symbols for Welding and Non-destructive Testing". (undated Anon. Aff.,
| |
| Attachment 5 et 3.)
| |
| It is correct that the AWS Dl.1 Structural Welding Code does not i
| |
| apply to piping or to pipe supports governed by ANSI 831.1 and 8 31 .7. Contrary to the allegation, there need not be a controlled centralized document on site that defines welding symbols. AWS welding symbols are the common basis for comununication just as the t
| |
| English language is. The Project does not and need not have a 1
| |
| dictionary available as a central reference; likewise, a central I reference to AWS welding symbols is not needed.
| |
| l l
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| l 1505d -. ,
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| | |
| III-338 It is alleged that:
| |
| To illustrate furthar, the use of improperly applied symbols or terms such as " typical" is abused on many Hanger drawings. An example of the unclear use of " typical" is shown on Attachment 1 Item 1 A Spring Hanger No. 20-145V.
| |
| The best use of this callout would be to indicate the welds at the two (2) joints where item 2 attaches to Existing 24W100. Note that no weld had been called out for item 2 to item 1 joints previously, since the circled arrow was the mason for this revision. This is not a minor problem. Almost every drawing issued has a question raised as to how the " typical" should be integreted and applied. In this example, it was cleared up by Engineering, but in others it isn't and in those cases each person in the chain has their own idea of what is the correct use and no consistent interpretatica is applied.
| |
| (Undated Anon. Aff., Attachment 5, at 4.)
| |
| The allegations regarding Spring Hanger 20-145V, Item 1, express the personal opinion of the alleger. The use of the typical symbol is perfectly clear. The drawing was indeed clarified and improved as pointed out by the alleger. Such a clarification is an acceptable practice even though it may not have been necessary. He is complaining that the welds on the opposite ends of a member were not specifically called out, although these were labeled " typical." It is wrong to state that no consistent interpretation was applied.
| |
| In a worst case, the joint in question, which relied on the typical call out, would have been unsymbolized and that in turn would cause a symbol to be applied. This issue has no technical merit. The l alleger has simply offered an opinion mgarding his preference for
| |
| ! symbolization.
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| 150?d .-
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| | |
| III-33C It is alleged that:
| |
| Another problem with Hanger No. 20-145Y is item 2. Here the use of a note " Seam Weld 4 PLCS" is incorrectly used.
| |
| A spring Hanger Bracket is a cold rolled plate which has a radius on the side where this symbol is pointing and the correct cr11 out would be for a flare-bevel grove weld or if radius is extremely small a fillet weld. Without investigation into the size of the brackets the correct weld symbol can not be determined by viewing the drawing, but under no condition would a seam weld be applicable.
| |
| When comparing this use to AWS A2.-Figure 22 it becomes cbvious that this use is incorrect. (Undated Anon. Aff.,
| |
| Attachment 5, at 4.)
| |
| The allegations regarding Hanger 20-145V, Item 2, seam weld, is a gross misrepresentation of fact. This weld symbol encircled by a scallopped balloon was intentionally included in PGandE letter DCL 84-040 to the NRC Region V, dated February 7,1984, as an example
| |
| ~
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| of a symbol problem, and how that problem was addressed. This scallopped balloon noted, " Weld not taken credit for in cale." The Project recognized the problem and compensated for it. The alleger is clearly making a misrepresentation when he cites this as an example of a symbol failure. It is, in fact, an example of a properly functioning program which addressed problems clearly and l
| |
| l directly.
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| 1509d l
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| III-33D It is alleged that:
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| In continuing, see Attachment 2. Item 1 DCN i DC-1-E-P-3858, line # 1-55-48-3, a class I line. The design calls for an unequal leg fillet weld, Item 1, which would result in one leg 01/4" long and the other leg 9 3/16" lona. However, on the drawing the weld design is depicted 5y a symbol without any expanded details to show which leg goes to which item and to assure compliance with j design requirements. (Undated Anon. Aff., Attachment 5, at 4.)
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| {
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| The allegation regarding lack of clarity for the location of unequal legs of a fillet weld is frivolous. It is obvious from inspection of the referenced attachment that the 3/16-inch leg belongs adjacent to the 2-inch Schedule 40, 0.154-inch-thick pipe stanchion and that the 1/4-inch leg is to be on the thicker run pipe. It would be absurd to do the reverse.
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| L i
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| i 15104 i
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| III-33E It is alleged that:
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| Significant problems result when weld symbols are not unifomly interpreted at the plant. See Attachment 3 Item 1 Hanger 58N-4R. The symbol indicates a full penetration flare bevel weld with a 1/4" fillet cap. When welded, the AWS standards allow you to take credit for 5/16 times radius of bend (R) " effective throat" partial penetration weld even though shown as a full penetration weld.
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| The addition of a fillet weld does not increase the structural strength of all joints when used unless the fillet size is increased in relation to size of tube steel welded. It does create a false impression of " additional" structural strength when in reality the strength only increases minime11y or not at all, (Undated Anon. Aff.,
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| Attachment 5, at 5.)
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| The example shown in affiant's Attachment 3, Item 1 Hanger 58N-4R, is a 1/4-inch fillet reinforcing a flare-bevel weld. This weld connects a length of 4 X 4 X 1/2-inch tube steel member to a 5 X 5-inch plate. The designer used an effective throat of 5/16-inch (0.31 in.) for the flare-bevel weld. The throat would increase to approximately 0.39-inch with the 1/4-inch fillet addition. This is well known by the designers. This issue is really moot since the designer only requires 35% of the flare bevel weld without reinforcement to qualify the support.
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| l The flare-bevel weld with a fillet cap was simply an as-built reflection of the installed support; it was not designed to have the fillet reinforcement. This fact is clearly stamped on the affiant's i
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| 1511d ,
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| w -w wr.,,_m-,--,-r,----,----, ~w r,,,,, wen,-n_ , - - - ..,--w-
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| | |
| exhibit. It is improper for the alleger to state this fillet weld gives a false impmssion; it does not.
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| i t
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| l t
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| 1511d l
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| i III-33F It is alleged that:
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| , On this same Attachment. Items 2 and 3 pose a different problem. The use of 3/16" and 1/4" as shown are per AWS A2.4 indications of the depth of preparation to be made. (Undated Anon. Aff. at 6.)
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| The alleger has identified these symbols as being in compliance with AWS. He claims these represent a problem.
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| He apparently intends to infom us of what this problem is at a later date. In the interim, our review shows that the designer has chosen not to include these welds in his calculations to qualify the support. The two adjacent 1/4-inch fillet welds shown in another view are more than enough to qualify this joint. There is no technical or safety problem.
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| I 1513d III-33G It is alleged that:
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| At this point I would like to emphasize the last ifne of Attachment 4 "All pipe support as-builts issued by General '
| |
| Construction after October 15, 1983 should have all weld symbols in conformance with AWS A2.4," and Attachment 7, last paragraph " Welding symbols in strict compliance to standard of AWS A2.4 " and Attachment 9 under Responses Item I where a contradiction to AWS A2.4 is expanded on as the correct use. It appears to me that the use of AWS A2.4 is not consistent by management. They only use AWS A2.4 when they want to, where they want to, and how they want to, but not as AWS A2.4 states it is to be used. (Undated Anon. Aff., Attachment 5, at 6.)
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| This appears to be another misrepresenation of facts and presentation out of context. The alleger's Attachment 7. dated October 10, 1983, addressed pipe supports and emphasized the need to comply with AWS.
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| Attachment 4, dated October 25, 1983, reconfirmed that pipe support weld symbols would comply with AWS A2.4. The alleger's Attachment 9 relates to HVAC work by different personnel, not to pipe supports.
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| In this case, the kinds of weld joints and material thicknesses used l in HVAC installations are different from pipe supports or structural
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| , steel. A minor prnblem was recognized with HVAC symbols and the Project addressed the problem, clearly identifying the symbol convention being used. This was a correct and appropriate Project action.
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| l i
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| It shnid be noted that all three of the alleger's attachments were also attached to PGand:'s letter DCL-84-040, dated February 7,1984, to the NRC. This allegation does not represent av new information, or have av technical or safety significance.
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| 1514d . - . _ . _ . _ . , _ . _ . . _ . . . _ _ . _ . _ . _ _ _ _ _ _ . _ _ _ _ _ . _ _
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| I I
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| III-33H It is alleged that:
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| On Hanger 1-36R, Attachment 5. Items 1 and 2 notes added to the design drawings specify "1/4" fillet weld - all accessible-typical." Not only are the design requirements ambiguous but the application of these requirements results -
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| in insufficient Quality Assurance criteria to qualify "what is accessible". There has to be a specific quanity Isic)
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| (size 8 length) of welds required by the design. It is not possible to conduct calculations on the basis of a phrase like ' all accessible" welds. there is no method to assure the engineer, who performed the calculations that theoretical welds be [ sic] used for calcuations were indeed welded in the field, or later verified from as-butit by Engineering correctly. (Undated Anon. Aff., Attachment 5, at 6.)
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| This allegation is also based on PGandE letter DCL-84-040, dated February 7,1984, to the NRC. The alleger's Attachment 5 was provided in PGandE's letter as an example of drawings for which SFHO engineers requested additional or clarifying information concerning as-built weld cenditions. The two locations referenced in this allegation did not require verification because loading conditions were satisfied even with a minimal amount of installed weld. This fact was confirmed by the fina) as-built drawings supplied after l construction which reported the actual installed weld.
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| l l
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| 1515d l 1
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| | |
| III-33I Attachment 6 Manger drawing 20-44R. Item 1 is a prime example of the abuse of "typicals" and "3 sides". The requirements specified in the example call for 9 welds on a '
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| angle member while simultaneously specifying 9 welds on a channel member. Item 2 Per AWS 2.4, indicates a full penetration weld with a 3/16" fillet. In trying to figure out what is intended here, see Attacissent 8 under Integral Attachment Do's Dont's. The callout is under Do's a partial or complete penetration weld on sides and 1/8" fillet on one end. This is ridiculous. One possible question is does this mean 3/16 preparation on partial penetration weld and 3/16 fillet or does it mean full i penetration with 3/16" fillet? Item 2 also has the arrow pointing at the member. It should point to the joint in question. (Undated Anon. Aff., Attachsen 5, at 6-7. )
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| In this case the alleger continues to present data and figures out of context. All of this was addressed in PGandE letter DCL-84-040, dated February 7,1984, which presented facts to the NRC.
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| The complaint about his Attachment 6. Item 1,1s. groundless. The
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| : meaning of weld "3 sides-typical" on both the angle and the channel, is clearly shown in his Attachment 6. The weld symbol arrow clearly points to the three outside surfaces of the channel, the two inside surfaces, and the vertical outside surface of the angle.
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| The alleger's complaint about his Attachment 6, Item 2 is, once again, totally out of context. This item was included in DCL-84-040 as an example of a problem and the figum contains its own resolution: " Partial penetration weld not taken credit for." This weld symbol was not well done. Symbols ifke this were the cause of the Project issuing the *Do's and Don't's" which were also included 1582d d
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| .n.--n.. , -.. , -
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| | |
| in DCL-84-040. The context of the figure is very clear. It indicates that fillet welds are to be generally used for lug attachments (except for nuclear Class A or, when fillet welds become large, partial or full penetration welds should be used). The i
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| alleger's opinion appears to have been based on an taproper i comparison of existing acceptable weld symbols with a new preferred design instruction. The symbols are understandable as used. The comparison between Attachment 6 and Attachment 8 is inappropriate.
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| l The questions asked regarding the alleger's Attachment 6, Item 2, wert answered in PGandE letter to the NRC, DCL-84-040, dated February 7,1g64.
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| 1 l
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| 4 1582d .
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| i III-33J It is alleged that:
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| AWS A2.4 paragraph 9.2.5 states in gart "except for square groove welds, the effective throat (E)'... (E)' onTy is thown for the square groove weld." The symbol requirements am clearly stated for square groove welds. In contrast, Hanger drawing 49-46A, attachment 11, Item 1 PG & E has used a size number to the left of the weld sy,mbol that should indicate the depth of preparation for the square groove weld. Further the " square-groove" weld symbol Appearing in the design drawing 25-8R, Attachment 10, Item 1, fr.Jicates a full penetration square groove weld 1/8" long. I submit that it must have an impact on ther QA when the weld symbols guiding the work are so inaccurs.e.
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| (Undated Anon. Aff., Attachment 5, at 7.)
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| This subject was addressed in an attachment to PGandE letter l
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| DCL-84-040, dated February 7,1984, to the NRC, as an example of communication clarifying requirements. See page 3 of the September 30, 1983, Pullman memorandum to and approved by J. Arnold, which is included with DCL-84-040 The square groove weld referred j to on hanger 40-46A, alleger's Attachment 11. (not 49-46A, as stated by alleger) is on a nonsafety-related angle frame mstraining line K-3249-3. This seal weld is not taken credit for and has no l safety significance. The square groove weld mferred to on hanger l
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| l 25-8R, the alleger's Attachment 10, is clearly indicated as, " weld not taken credit for in calculation." This was included in PGandE Letter DCL-84-040. The alleger has clearly misrepresented this case. There is no problem.
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| i l
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| l l
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| l
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| {
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| 1587d l 1 - - - - . - - - - - - -- -
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| III-33K 4
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| It is alleged that:
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| Attachment 11, page 2 of 2. Item 3, order of welding wrong-reading from line, groove weld should be first then fillet weld.
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| A thorough myiew of the hanger designs at the plant would reveal that even the most basic of all AWS weld symbols l "the field weld flag" is reversed on drawings. This is a small point and a non-safety related one, yet it does violate AWS A2.4 and illustrates the incompetence of employees. Note the drawings used in PG & E's letter No.
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| DCL-84-040 supplied by management are used as my I
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| attachments of incorrect symbols usage. (Undated Anon.
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| ; Aff., Attachment 5, at 7.)
| |
| The alleger's Item 3 on his Attachment 11 is an example of an
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| ; imperfect symbol which, nonetheless, has a perfectly clear meaning.
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| ; The designer wanted a fillet weld minforcement on a partial i
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| penetration weld. The requirement has been perfectly communicated even though the symbol is not perfect. This item mquires a minimal amount of common sense to understand. A quick myiew of this allegation shows that it consists largely of mismpresentation, incomplete review of the PGandE documents, and items taken out of context. In any event, we would agree with the alleger that this allegation is, as are his others, "a small point and nonsafety-related. " ~
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| l l
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| l
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| {
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| 1588d _ . _ _ - . _ _ - - . - _ _ _ . _ _ . - _ . _ _ . . - . . - _ - . _ - - . _ - _ _ - _ - _ _ _ - _ _ _ _ - _ - -
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| III-34 It is alleged that:
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| : 5. "For configurations that are somewhat difficult to symbolize, it is understandable that construction personnel might need periodic clarification of these symbols."
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| Response: If the joint symbol is too complicated to be uncerstood, then sound engineering practice would have been I to detail the joint in blow-up fashion to assure no confusion results. The proper response is not to perpetuate the use of drawings which cannot be understood.
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| AWS D.1.1 paragraph 1.5 states "special conditions shall be fully explained by added notes or details."
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| Management has, however, attempted on occasion to legitimize their abuse of AWS weld symbols by issuing menos, Attachments 7 and 8. Unfortunately, these menos
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| " clarify" by issuing contradictory instructions.
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| l Attachment 9, a February 6,1984 memo from F. A. Norsy to
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| ' M. Leppke,]he part: "[T intent on the engineering drawing for the" welds specifi partial penetration weld as shown below [ example in original] is that the fraction shown, not in parentheses, is to be the " effective throat."
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| l In contrast Attactament 12, page 2, paragraph 2, meno from l P. S. Brooks to D. A. Rockwell, dated August 24,1983 " Pipe Support Welding Symbols," states in part "the dimension placed to the left of partial penetration groove welds, when chaefered or beveled for welding, is depth of penetration, not weld size. ~
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| The disparity of application and use of weld symbols evident in these menos provides no assurance fue PG4E's Position that " weld symbols at Diablo canyon are consistent." The only consistency that a close scrutiny can reveal is the inconsistency that is widespread throughout the pksject. (Undated Anon. Aff., Attachment 5, at 8.
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| 1 This is the same issue as this alleger's previous complaint which we have numbered III-33G. As was explained above, the HVAC discipline l
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| recognized a symbol problem and the Project took corrective action to document and clearly identify the symbols convention being used.
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| This was a correct and appropriate action.
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| l 1364d !
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| The alleger has viewed this HVAC action outside its proper context and has contrasted it again to the standard pipe symbols convention used in the pipe support discipline. Each discipline is internally consistent.
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| l t
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| l 1364d t
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| III-35 It is alleged that:
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| : 6. "In view of this fact, welding symbols were used as only one means of conveying weld requirements."
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| Response: What other method exists to convey weld mquirements to the field? This author knows of no other viable method to accomplish this requirement and assure conformity. Since that was my job, I question whether this statement is false and/or misleading. (undated Anon. Aff.,
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| l Attachment 5, at 9.)
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| The PGandE msponse is again represented out of context. The relevant portions of PGandE letter DCL 84-040 to the NRC dated l
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| February 7,1984, are inserted here to show some other forms of I
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| communication which help to convey welding requirements. The alleger would wrongly have one believe that all symbols are always perfect, and that he has never asked a question or answered one.
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| Straightforward questions and answers are the simplest form of communication.
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| As stated in PGandE letter DCL-84-040, at pages 1-4:
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| A. Overview The weld symbols used at Diablo Canyon are consistent with the standards specified in AWS D1.1, Section 2.4. For configurations that am somewhat -
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| difficult to symbolize, it is understandable that construction personnel might need periodic clari-fication of these syu6ols. This is particularly true when uudificiations are performed on a plant that is alrea@ constructed, such as Diablo Canyon. In view of this fact, welding symbols were used as only one means of conveying weld requirements. To date, no situation has been identified in which misinter-protation of weld symbols has msulted in the l installation of unacceptable welds. Consequently, i them is no safety significance to this issue.
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| l 1366d ;
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| l l
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| : 8. Program Elements The Diablo Canyon Welding Program consists of the followfng:
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| : 1. Regular communication between Engineering and Construction personnel on weld design and intent.
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| : 2. Discussions between design engineers and construction personnel to clarify any special problems with integreting weld symbols.
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| : 3. Provision for substantial reserve margins in weld design.
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| : 4. Verification of design calculation without i
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| reliance on welds made to ambiguous specifications in design calculations.
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| D. Communication of Information Consunication on weld design and weld symbol use has taken several foms, including discussion sessions and j written direction'. With respect to the first method i
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| .of communication Engineering and Construction have conducted meetings to discuss welds, and this program will continue to assure proper communication of weld symbol use and weld design (Attachment 3). These sessions are comprehensive and widespread in that they are conducted with design engineers inspectors, and contractor personneI. field engineers, l
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| The design infomation pertinent to welding and weld l symbols provided by Engineering to Construction is supplemented by a significant amount of other types of communication. For example, cormspondence is transmitted between Construction and Engineering on a regular basis. A representative sampling of correspondence is provided in Attachment 4 to illustrate that questions regarding welding are thoroughly discussed and resolved. This infonsation is used by both Engineering and Construction to mvise ,
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| existing procedures and instructions and to standardize and clarify the intent of welding requirements. This process serves to ensure that the design intent is communicated to Construction and that construction implementation is communicated to Engineering. Design Engineering also sends engineers 1366d ,
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| b , g s N
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| i
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| '\ '
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| to the field in response to any questions which arise. Engineers are present when construction work is in paress to ensure that the designer's intent is provided to Construction and to resolve any possible installation difficulties. Attachment 5 contains a representative sampling of Engineering clarification provided in the field.
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| The process involved in comunicating and implementing the designer's intent has led to many discussions.
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| Items requiring interpretation are identified and s handled in the same general manner. Identification of most points requiring interpretation occur during l pre-field construction reviews, preparation of erection drawings, assembly of work traveler packages, and during construction but prior to QC acceptance.
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| Items requiring interpretation are resolved by:
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| 1 1. Referral to OPEG for design clarification.
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| l 2. Return to OPEG for design revision.
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| J '
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| : 3. Return to Engineering for design revision.
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| : 4. Review jointly by Engineering and Contruction for revision of field installation instructions, s In addition, during the QC review, or after final
| |
| % acceptance, the process identified above may be supplemented by issuance of a discrepancy report with Engineering input for resolution, or by issuance of a discrepancy reporc with the Project Team General Construction (PTGC) welding engineer input for r
| |
| resolution."
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| 3 Clearly, this program'is simply comon sense and is not false or misleading.
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| 1366d l ..
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| i I
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| III-36 It is alleged that:
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| I l'
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| : 7. "To date, no situation has been identified in which misinterpmtation of weld symbol's has resulted in the installation of unacceptable welds."
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| Res se: This is a false statement. From personal ion I know that many of the " situations" identiffsd in this rebuttal involve unacceptable welds. On several occasions, I authored menos (Attachment 14) questioning the application of welding symbols. Upon reviewing this response from PG & E (Attachment 15), I questioned John Rhodes,s PG 8 E commitment to comply with AWS His A2.4.theresponse Technical Coordin was that we were not committed to AWS A2.4, but were in '
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| fact committed to doing whatever management tells us to do.
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| Further, management has developed an excuse for not finding fault on welding that did not comply with the original requirements as specified on the hanger drawing, and ESD.
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| Instead they have opted to not include the field weld in l the hanger calculations, and claim it was unnecessary for stress. requirements in the first place. If the weld was unnecessary, why was it specified? By this criteria the original hangers we replaced would have oeen acceptable.
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| Management would not have developed this excuse if the welds were all right to begin with.
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| Further, I question whether the welds are unnecessary, my
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| ; concern on this matter can be illustrated by Attachment 6,
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| ; Item 2 Hanger drawing 20-44R. In this instance there is no i
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| record stating what the bevel (fit up) was, since QC inspection does not document the bevel angle and root gap. ,
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| Assuming a 3/16" 450 be/e1 the partial penetration weld specified would result in 1/16" effective thmat. (Per ANS A3.0, effective throat is defined as the minimum distance from the root of a weld to its face, less any reinforcement.) Further AWS D.I.1 gives the relationship between depth of preparation and effect1.e throat for a bevel weld (in this instance, assming a 450 bevel, 3/16" minus 1/8" = 1/16" (E)). PG SE has added a note to this drawing stating that r.o credit was taken for the partial penetration weld. By this inference they can only be taking credit for the 3/16" fillet weld (overlay). The problem is that in this installation the fillet weld is irrelevant in the hanger calculations due to tis [ sic]
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| specified application. In order for the fillet weld to contribute to the structural calculations in this 1367d l L - _.- - - ---...-_.- - --_ _- --- _ _ . --- - - - - - _ r
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| 7_..
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| s- .
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| ~
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| l l .
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| l
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| , application, its Wid. size would have to have been twice as
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| _- large, or 3/8". [0versized welding is discouraged per
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| ' PG 4 E instructicas.] This leaves me to wonder: it [ sic]
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| PG A E did not take credit for the partial penetration weld, and they cannot take credit for the fillet weld, then how did the hanger calculations pass? See Attachment 18 l .~ 76F sketch.
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| ~~
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| To illustrate: for PGI E to make a broad statement that some welds can be thrown out, see Hanger 2033/25 SL (Attachment 17 and 173) Levision 0 of DC-2-E-P-14584.
| |
| . Item 7 was welded to the embed plate with a 1/2" fillet weld.on both sider, of ths' tube steel with no weld on the heel or toe. Revision:1 was issued to add the full penetration weld on the toe of item 7 to the embed plate.
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| ~
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| If the hangers am so overtiesigned at the start, why increase the overdesign? Why cause the additional work on an existing hanger that will just about be impossible to bevel without removal, when these welds are not required?
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| l Or, is it possible'that these (and other) welds are really required? (Undated Anon. Aff., Attachment 5, at 9-10.)
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| The alleger's Attachment 14 does not address weld symbols; it addresses the work rate of preinspection engineers perfoming their constructability review.
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| l Also contrary to this allegation, all efforts were made to standardize on AWS 2.4 weld symbols. If questions arise on how a weld symbol was to be interpmted, a PSDTC engineer could be asked to clarify the design intent. The final as-butit drawing showed the ,
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| actual weld installed.
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| The allegation concerning welds that are subsequently detemined to be unnecessary in whole or in part indicates the alleger has little understanding of the weld design process and time constraints.
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| l 1367d ,
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| | |
| Welds are frequently specified before all loads are finalized. The original load asstaptions are generilly conservative, resulting in the welds being larger, longer, and thicker than absolutely necessary. This is more economical than delaying the design until all loads are precisely known. Another conservatism occurs when designers specify welds to fully develop the load capacity of the member joined rather than the actual loads. Therefore, if a weld's quality or dimension is uncertain at the time when actual loads are known, it may be most effective (and conservative) to abandon the weld for design purposes and not consider it in the calculations.
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| The actual loads and the as-built are then reconciled when the facts
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| ! are all available.
| |
| The alleger's Attachment 6' , Item 2 is such a cese. The alleger's analysis of the 3/16 partial penetration weld situation is faulty.
| |
| This allegation is essentially the same as an anonymous allegation made the night of April 11-12, 1984, during the NRC sponsored plant l
| |
| tour Mr allegers. The response to that allegation was made in l PGandE letter DCL-84-170 dated May 2,1984 The response clearly shows the effective throat of the fillet weld is maintained. PGandE did not take credit for the partial penetration groove effective throat because it was not conff reed. However, PGandE did not assume the weld groove was a void. The alleger's assertion that a 3/8-inch fillet weld is needed for this condition is absurd.
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| 1367d l
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| The reverse case, that of additional loads, is shown in the alleger's Attachments 17A and B which show that a hanger drawing was revised to i
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| add a weld across the toe (ootuse side) of a skew tube connection which was originally welded only along the sides. This clearly shows that the design process was working properly. Frequently fillet welds across the obtuse side were not cost effective and were omitted in the original design. When the revised loads were known, the addition of a groove weld across the toe was required in revision 1.
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| The alleger has grossly overestimated the difficulty of preparing the tube steel for the required weld.
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| No technical or safety concern has been raised in this allegation.
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| l 1
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| I l
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| 9 1367d
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| ~
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| III-37
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| ~
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| It is alleged that:
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| : 8. " Consequently, there is no safety significance to this issue."
| |
| Response: The safety significance is the lack of ary previous standard until October 15, 1983. In ny opinion it 1
| |
| is impossible to avoid safety significance if the welders and inspectors did not know what was expected of them.
| |
| AWSA2.4 is to be the standard now. Yet to my knowledge
| |
| , there has never been comprehensive training in the General l Construction Department, Engineering or other departments to insure its use or the consistency of its interpretation. In general, field work pitvious to and after October 1983 remains shrouded in ambipity.
| |
| Questionable, or undocumentable wo't practices constitute an unreviewed safety question and should be thoroughly reviewed and corrected. (Undated Anon. Aff., Attachment 5, at 11.)
| |
| The a11eger is expressing his opinion and lack of knowledge. The weld symbols issue has no safety significance. AWS welding symbols have tseen the t, asis for communication since the Project's inception.
| |
| As stated in PGandE letter DCL-84-166, to the NRC, dated April 30, 1984, pages 47-49:
| |
| ; This overview is provided to keep the significance of
| |
| : l. the allegations in perspective. The total program with regard to weld symbols has worked effectively from design calculations to as-built structures.
| |
| American Welding Society symbols for welding have been used at Diablo Canyon strece its inception. Symbol usage has been incorporated into the project by numerous references to contract specifications and other documents. AWS symbols have been used as the common basis for consnunication within the United States welding industry, regardless of the fabrication code specified or product t.onstructed. As stated in 1368d __ _ _ - _ _ , - _ _ _ . _ ._ _ __ _ _ _ _ _ . _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ __.
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| T_ . . _. . _ . . ._ ___ _ _ _ T $ __ _ . T.~_T ~ - ~
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| AWS A2.4, the intent of symbols is to facilitate communication. The AWS symbols have been used by
| |
| .__ .. cosmon consent even where not specifically referenced, just as the English language has been used at Diablo Canyon. Symbols may have occasionally been used 1.-- imperfectly, but the required meaning was conveyed and understood, and the hse of any non-standard symbols
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| '~
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| has not resulted in unacceptable welds. The parallel
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| , between weld symbols and the written and spoke language exists in that grammatically imperfect language can effectively convey meaning and requirements.
| |
| Engineering and inspection personnel have acquired knowledge of welding symbols through their experience, education, training, and use of references. Pullman has included questions regarding weld symbols in the QC inspectors' qualifications tests since 1974, and has included AWS A2.4 in the reading list for QC inspectors. Welding symbols are not difficult to master, in fact, approximately six symbols account for almost all field welds.
| |
| Due to the rapid expansion of the Diablo Canyon plant staff, specific training programs were conducted regarding AWS A2.4 weld symbols. Three hundred and fifty engineers and QC inspectors were trained during May, June, and July 1983. Additional pre-certification training was conducted for the AWS Certified Welding Inspectors Program in June-July and November-December,1983.
| |
| PGandE letter DCL-84-40 provide an overview of the weld symbols issue. Examples of symbol concerns and unclear symbols were intentionally included.
| |
| Notations wert made on example drawings contained in DCL-84-40 to show how the Project addressed the specified concern, and how the Project campensated for lack of specific or clear wald size information.
| |
| l Previous correspondence was included with letter i DCL-84-40 showing examples of haw some imprecise weld symbols o.i previously issued drawings were to be j interpreted. Additional correspondence displaying l
| |
| examples of preferred symbols, labeled D0, and non-preferred symbols, labeled DONT, were also included. The D0s and DONTs were identified as applicable to new drawings.
| |
| 1368d __ _ . _ _ _ . _ . _ . . _ _ _ . _ . _ . _ _ _ _ _ _ _ _ _
| |
| | |
| In a few cases, specific narrow scope exceptions to the standard symbols have been documented. These
| |
| - documented exceptions to A2.4 symbols use are permissible and correct in the context of the Diablo Caryon Project.
| |
| a Weld symbols are not used in a vacuum but are part of a program of communication between design engineering and construction in the field. There have been, and will continue to be, additional verbal and documented communications between engineering and construction clarifying design requirements. These connunications are a necessary and proper method to assure that the welds required by the design are installed in the plant.
| |
| The alleger is incorrect in asserting that comprehensive training was lacking and that the work was ambiguous, The Project conducted weld symbols training for 350 engineers and inspectors in the spring of 1983. Pullman has included weld symbols in its reading list for many years. Weld symbols are easily learned through prior training, education, work experience, or simply picking up commonly available t references.
| |
| J l
| |
| l l
| |
| 1368d - 3- i i
| |
| | |
| III-38 It is alleged that:
| |
| : 9. There is "[rJegular communication between engineering
| |
| . and t.onstruction personnel on weld design and intent.'
| |
| Response: To sqy knowledge, the on1 such regular comun1 cation has been between the { Quick-Fix Engineer",
| |
| and a " Field Engineer" on specific problems with hangers in question on an as needed basis, not on a scheduled basis.
| |
| In most instances only the " engineers" involved with the problem would have an intimate knowledge of the solution.
| |
| Historically, the inadequate coinnunication left a pathetic record. In one instance, a Bechtel team member "as-built" a support. He was apparently untrained in welding symbols and inspection. This is evidenced by his mport stai.ing
| |
| " heavy weld all around". How can you factor " heavy weld all around" into a hanger stress calculation, or assure that it has an " effective heavy throat?" No one communicated to us what was intended. You just had to guess.
| |
| The contentions identified in this rebuttal am sufficient to confim that communication between department. managers is still lacking also. (Undated Anon. Aff., Attachment 5, at 11-12.)
| |
| The Project's response was not meant to iseply regularly scheduled meetings in'a fomal environment. The regular meetings referenced were, in fact, the very ones the alleger acknowledges from his own experience.
| |
| The " heavy-weld all around" example cited does not support a lack of communication. This note was placed on the drawings before the "Bechtel team" was even on the job. This issue was previously responded to in PGandE letter DCL-84-166 to the NRC, dated April 30, 1984, page 89:
| |
| 1371d l
| |
| | |
| During the Project's Corrective Action Program, certain pipe support as-built drawings were found to contain incomplete weld descriptions, such as the exarple
| |
| " Heavy-weld all around." When an incomplete weld
| |
| ' description was found, the support was analyzed assuming
| |
| ~
| |
| the weld did not exist; or, if it was necessary to include the weld in the analysis, a documented reinspection was performed to accurately describe the weld. This follow-up doctmentation was incorporated in the design calcuations and as-built drawings. Contra y to the allegation, the analysis was proper, l
| |
| i I
| |
| l l
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| 1371d _, ., . __
| |
| | |
| . . . . ~ . . .. . . .
| |
| III-39 It is alleged that:
| |
| : 10. There were "[d] iscussions between design ent,ineers
| |
| "~
| |
| and construction personnel to clarify any special problems with interpreting weld symbols."
| |
| Response: Refer to responses #1, 4, 5, 7 and 9. In sqy TpTnTon, they demonstrata that this PG & E claim, similar to other assertions, also is false. (UnJated Anon. Aff.,
| |
| Attachssnt 5, at 1-2.)
| |
| The a11eger is allowed his opinion; however, even he acknowledges in his affidavit, under paragraph number 9 (III-38), comunication between the " Quick-Fix Engineer" (design engineer) and " Field Engineer" (constructien personnel). PGandE letter DCL-84-40, dated February 7,1984, provides additional examples of comunications between design ano construction regarding symbol interpretation.
| |
| r I
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| I I i 1372d L - - _ , - _- . .
| |
| | |
| L. _
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| III-40 .
| |
| It is alleged that:
| |
| : 11. There is P3rovision for substantial reserve margins in weld design
| |
| }
| |
| ~
| |
| Respanse: This statement on face value is invalid without a comprehensive review of each calculation package to
| |
| ~
| |
| verify that stress loads are low enough such that unwelded or unqualified welds can safely be neglected. Example:
| |
| Attachment 13 Item 1 knd #7 above with Attachment 17A and 178. (Undated Anon. Aff., Attachment 5, at 12.)
| |
| The allegation presents one element of the overall program out of context. The full context as set forth in PGr.ndE letter DCL-84-040 to the NRC, dated February 7,1984, page 2, is:
| |
| : 8. Program Elements The Diablo Canyon Welding Program consists of the following:
| |
| : 1. Regular connunication between engineering and construction personnel on weld design and intent.
| |
| ! 2. Discussions between design engineers and construction
| |
| ; personnel to clarify any special problems with interpreting weld symbols.
| |
| : 3. Provision for substantial reserve margins in weld design.
| |
| : 4. Verification of design calculation without reliance on welds made to ambiguous specifications in design calculations.
| |
| As has been previously described in III-36, there are several generalized conservatisms in all designs. These include combining loads based on the assumption they will act together; assuming the minimum specified strength for the material; postulating loads in excess of actual, then sizing welds to support the assumed larger 1373d -1
| |
| | |
| . .m _ .- . - t = . : .- -
| |
| ~
| |
| loads; sizing welds to sustain the material load' capacity rather than the actual loads; and providing closely spaced redundant supports.
| |
| -~~ ~
| |
| The alleger's Attachments 13 (78-1595L) and 17 (2033-255L) prove nothing about the general case for substantial reserve margin in weld design. Attachment 13 is the pre-inspection markup of 78-1595L. It shows an example of a square groove weld for which no credit is taken. Attachment 17 is a design revision of 2033-255L calling for an additional weld resulting fmm increased loading due to finalized piping loads.
| |
| l .
| |
| l 1373d __ -,_ .__ _ _ __
| |
| | |
| l l
| |
| )
| |
| I
| |
| ; .. . l
| |
| _ It is alleged that:
| |
| r"~ 12. " Verification of design calculation [was made] without
| |
| .1 reliance on welds made to ambiguous specifications in design calculations."
| |
| . .. Response: This assertion needs supporting proof and explanation to be meaningful. Who decides what were
| |
| , ambiguous weld symbols? If, upon review of field welding, welds were found not to be in compliance with requisite engineering design documents, why weren't they repaired rather than factored into the load calculations? If the welds were not necessary initially for stress / loading considerations, why were they specified to be performed?
| |
| Why were ambiguous symbols not fixed? See Attachment 13, Item 1. (Undated Anon. Aff., Attachment 5, at 12-13.)
| |
| Again, the alleger is entitled to his unsupported opinion. PGandE ''
| |
| letter DCL-84-040 provided numerous examples of unclear symbols for j which questions were raised by a variety of personnel.
| |
| As wa stated previously (III-36) in the later stages of l
| |
| l coastruction, when all the loads are finalized, it is possible to I
| |
| abandon some welds, in whole or in part, for design calculational purposes. This approach is more effective than reworking hardware for unnecessary and frequently trivial reasons. At this stage of work, it is much quicker and less costly to do calculations based on actuality rather than to perfom unnecessary rework.
| |
| l l
| |
| The questions reganiing welds which are subsequently found to be unnecessary are addressed in response to the design conservatism allegation above, III-40. The ambiguous weld symbols are not i
| |
| 1374d 1
| |
| | |
| corrected when these welds are abandoned for design purposes because it is costly to revise drawings and the revision serves no purpose.
| |
| l l
| |
| l l
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| l l
| |
| 1 l
| |
| l l
| |
| 1374d -
| |
| i
| |
| [
| |
| | |
| '~~..~:::., ..~,...'... . '~~-~~
| |
| III-42 '
| |
| It is alleged that:
| |
| : 13. " Weld installation reviews perfomed early in the 1.. design verification program (1981) consisted of reviewing ali available as-built information and perfoming plant
| |
| __. walkdowns to obtain additional information."
| |
| Response: The "as-built" of 1981 and previous "as-built" performed by Pullman were perfomed without any universal standard or specification, by untrained and sometimes unqualified inspectors. This process did not provide enough :: curate ir.Tornation to adequately assure a comprehensive repair program. (See, e.g., use of meaningless weld", that came tems out for engineering of the walkdowns.work, Pagesuch as " heavy )
| |
| , supra.
| |
| (Undated Anon. Aff., Attachment 5, at 13.)
| |
| This allegation consists of unsupported opinion. The issue of " heavy weld" was addressed above (III-38). The Pullman personnel perfoming as-built reviews are qualified in accordance with ESD 235 and 237.
| |
| The process is conducted using the universal standards found in ESD 223. These procedures wre applicable long before 1981.
| |
| 'l l
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| 1 l
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| l 1375d _- _ _ _ _ - . _ - - . , _ . _ - - . _ - _ _ _ _ _ _ _ . - - - -- . _ - _ _ - - - - - - - - - - - - - -
| |
| | |
| III-43 It is allaged that:
| |
| . 14 " Welding codes specify minimum weld sizes to ensure
| |
| .2.. that adequate fusion with the base metal is achieved. When
| |
| .. welded components are subjected to an analytical evaluation, the weld stresses are almost always low."
| |
| Response: This comment is incorrect. Many supports require more than the minimum, as when full penetration welds are specified. On the other hand, too much welding creates high stresses. If in fact management's assertion is correct, wtty were menos issued to stop the flagrant "over-welding" of hangers at the plant. Over-welding in some cases can be as detrimental to structural soundness as undwerwelding. The excessive heat generated by the process can result in the excessive distortion of the base metal, l metal being more susceptible to crack propagation and brittle fracture, if the metal temperature is improperly controlled. (Undated Anon. Aff., Attachment 5, at 13.)
| |
| The 211eger has again presented material out of context. The original statement.in PGandE letter DCL-84-040 was . correct. The next l
| |
| sentence in DCL-84-040 is, "This is especially true for electrical raceway and HVAC suppports." Marty codes, AISC, AWS D1.1, and ASME NF do have minimum weld sizes as functions of the material thickness and the weld sizes are not related to loads.
| |
| l The alleger is mixing apples and oranges again. The code minima at l
| |
| Diablo Canyon relate to the building, electrical installations, and HVAC installations. Pipe supports built to different codes were not subject to code imposed minimum weld sizes.
| |
| The principal reasons for avoiding overwelding is that it is costly and time consuming. This is especially true in the context of pipe supports (hangers).
| |
| 1376d - - . _ . - . .. . - _ _ .. . - - _ _ -_ - _ - - - . -- -
| |
| | |
| Base metal distortion is not a problem provided the final assembly is
| |
| - within its design tolerances. For the kinds of steels used, the
| |
| ', thicknesses used, and the design used in construction of pipe supports, excessive welding is not a metallurgical or welding concern.
| |
| i f
| |
| l 1376d I
| |
| . _ _ . - _ T-*"' ' - - - _ _ _ . , _ _ _ _ _
| |
| | |
| . . - . . . - . . . . - ~ . . . . . . . . . . . . . . . . . . . . . . . . . . . .
| |
| III-44 It is alleged that:
| |
| : 15. " Designers, using as-built drawings, did not take
| |
| - cmdit for welds in design calculations if the weld T configuration was not clearly shown or if interpretation of
| |
| . weld symbols was not consistently made."
| |
| Response: This is so false that frequently the opposite occurred.
| |
| A n use of this symbol in the field has been assumed to be 3/16" preparation, with a 450 preparation angle (at present). Under traditional practices, engineering specifications would have allowed the angle to be as small as 37-1/20 Standard practice in the field resulted in a 3/16" fillet cap weld overly on a 3/16" partial penetration bevel weld. For reasons discussed in response
| |
| #7 the analysis pertaining to attachment 6 would apply in thIs case also. The significance of this problem is that the weld symbol directed engineers to take credit for effective throat size of welds that add nothing to the structural strength of the hanger. (Undated Anon. Aff.,
| |
| Attachment 5, at 13-14. )
| |
| This subject. 3/16 inch partial penetration groove welds with reinfon:ing fillet, is also addressed in Allegations III-36 and 50 and in response to the NRC sponsored plant tour for allegers. The concern for 37-1/20 bevels was originally addressed in PGandE letter DCL-84-083 to NRC Region V, dated February 29, 1984. Jobsite interviews with the NRC staff and supplemental information provided to the staff in relation to the alleger's plant tour also address these issues in PGandE letter DCL-84-170, dated May 2,1984, and DCL-84-200 dated June 1,1984.
| |
| 1377d - - = _ - - - - ..- .
| |
| | |
| l III-45
| |
| ~
| |
| It is alleged that:
| |
| , 16 ' Engineering and construction have conducted meetings
| |
| . 1 ;-- to discuss welds, and this program will continue to assure proper communication of weld symbols use and weld design (attachment 3)."
| |
| l Response: Refer to responses 9 and 10 for discussions on meetings. Further, as of March 16, 1984 the referenced Attachment 3 was not issued to the field or at least to anywhere that I or anyone I know at Diablo Canyon has worked.
| |
| A further example of the inadequacy of management's attempts to assure proper interpretation of symbols and design requirements is evidenced by Attachment 7, a memo from G. V. Cranston to R. D. Etzler dated October 10, 1983
| |
| " Clarification of Pipe Support Weld Symbols" and Attachment 8 meno from G. V. Cranston to R. D. Etzler dated October 10,1983, "Do's and Don'ts for Welding Symbol s. " These two menos, both from the same individual j and dated the same day, in theory were authored to clearly '
| |
| define the proper use of weld symbols. Yet a close scrutiny of page two of both Attachment 7 and 8 reveals that they offer contradictory instructions. In one memo (Attachment 8), the author presents the use of a particular sydol to ensure that the resultant weld is what was desired. instructs personnel to " don't" use the same weld symbol.The other meno, by contrast,(Undated Attachment 5, at 14-15.)
| |
| The alleger claims to be unaware of the jobsite training programs regarding weld symbols which were conducted in May, June, and July of 1983, in which 350 engineers and inspectors rwceived training in weld
| |
| . symbols. Attachment 3 to PGandE letter DCL-84-040 is almost
| |
| , identical to the weld symbol handout distributed in those l
| |
| . sessions. Thus, the allegation that Attachment 3 to PGandE letter DCL-34-040 was not distributed onsite is false. A copy of the l jobsite handouts was in fact given to an NRC inspector onsite. ,
| |
| 1 1378d -
| |
| 1-l
| |
| .,. - , - - ,----. . - ,- - ~ , - - . . _ . , , - -,
| |
| _ _ . . _ . , _ , _.__..,__n.__-.
| |
| | |
| The alleger'a .*.stachment 7 was an Engineering to Construction
| |
| . . _ (930-CA2) clarification of pipe support weld symbols that had been
| |
| : used previously. The symbols used were not wrong; however, they were not as clear as they could have been. The figures attached to
| |
| ~~~
| |
| alleger's attachments graphically showed the requirements. The '
| |
| alleger's Attachment 8 was an Engineering to Construction meno (929-CA2) that clearly identified the preferred practice and a nonpreferred practice labled "D0 and DON'T" respectively. It was correct and logical that some of the less than perfect symbol identified in the 930-CA2 (alleger's Attachment 7) would be brought forward, labled DON'T and that the preferred D0 symbol would be shown l in 929-CA2 (alleger's Attachment 8).
| |
| i i
| |
| 1378d l
| |
| | |
| III-46
| |
| _PGandE Position:
| |
| : 17. "These sessions am comprehensive and widespread in
| |
| * that they are conducted with design engineers, field engineers, inspectors, and contractor personnel."
| |
| ~
| |
| Response: Again this statement is false, or at least overwnelmingly misleading. The author can remember that as of March 16, 1984 only one meeting was held that even vaguely resembled those taken credit for. It was neither comprehensive nor widespread. (Undated Anon. Aff.,
| |
| Attachment 5, at 15.)
| |
| This issue was addressed in PGandE letter DCL-84-166, dated April 30,1984, in which it was noted that the job site training Programs regarding weld symbols were conducted in May, June and July of 1983. It could be that the alleger's memory is faulty.
| |
| O 1379d i_ , __ _ _ _ . - - - - _ __ __. . . _ _ _ _ _ . , _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ . _ _ _ _ . _ _ _ _ _ _ _ _
| |
| | |
| . . _ = . . .- = . . . ..- ..
| |
| III-47 It is alleged that:
| |
| : 18. "The design infomation pertinent to welding and weld
| |
| '. symbols provided by Engineering to Construction is
| |
| ~ suppplemented by a significant amount of other types of connunication. For example, correspondence is transmitted between Constmction and engineering on a regular baits. A representative sampling of correspondence is provided in Attachment 4."
| |
| Response: Refer to response #16 for examples of communication transmitted between departments.
| |
| Attachment 4 referenced in this statement as attachment 7 and 8 hem.
| |
| A further example of the referenced attachment 4 makes use of weld symbols not recognized by AWS. Tb issuance of this document perpetuates and legitimizes the abuse of welding symbols in the field. (Undated Anon. Aff.,
| |
| Attachment 5, at 15.)
| |
| This is simply an opinion, without factual support.
| |
| As is shown by the attachments to PGandE letter DCL-84-040, dated February 7,1984, there was effective communication between Engineering'and Construction on the subject of weld symbols.
| |
| The issues raised in the alleger's #16 (III-45) were addressed and shown to be out-of-context comparisons. The communications did not legitimize the abuse of weld symbols. The communications clarified i
| |
| previously used, but less than perfect, acceptable symbols and, in fact, emphasized the need for more clear symbols.
| |
| 1380d . . - .- - _ . -
| |
| | |
| ... General Construction shall issue all the as-builts of pipe supports for Unit 2 with welding symbols in strict compliance to standard AWS A2.4." This is hardly " legitimizing improper symbols."
| |
| b l
| |
| l 1380d . . - _
| |
| | |
| . r. .; _ ._ _ _ _ _=_ _ _ _ w _ _ __ . - _ _ . _ - . .
| |
| It is alleged that:
| |
| , 19. "The angle is to be in accordance with either the i prequalified or specially qualified procedure.'
| |
| Response: Per the MS codes "the angle is to be in accordance with either the pre-qualified or specially qualified procedure." However, engineering was infomed
| |
| ( that for design, only MS D1.1 prequalified stick weld 6 process was to be used. This presents a problem, since the weld precedures on site required only a 37-1/20 prior to June 28,1983 fit up bevel angle. By MS code this bevel angle applies only to pipe joints as described in MS l
| |
| D.1.1. In Figures 2.9 and 2.10 the angle requirement for
| |
| !
| |
| * stick" process allows two options: 1) 600 angle with no deduction of weld and 2) 450 angle with a deduction of 1/8". The site Engineering standard (ESD 223) did not comply with either of the options allowed by MS D.1.1. In fact, it limited angles to 150 (00 to 1800 for skewed
| |
| -T joints). Not only does the MS code fail to pemit such a small angle, it does not even specify a reduction factor (e.g., minus 1/8") that would compensate for a 150 ,
| |
| ! angle. The deviatica is so far from " standard industry l practive". [ sic] that there isn't any standard way to account for it. Management's practive [ sic] of adapting the " pre-qualified welds" allowed under MS without the necessary qualifying angles resulted in an assumed l installed angle of 450 Under MS codes this would l require a deduction of 1/8" more weld per fit-up than
| |
| ! allowed for in the design calcualtions of the hangers. In other words! in most instances the hanger would have received 1/8" less weld (minimum) than required. (Undated Anon. Aff., Attachment 5, at 15-16.)
| |
| l This entire subject was addressed in PGandE response dated March 6, 1984, to Joint Intervenors' Motion to Reopen on DQA, Breismeister, et al_., affidavit at 28-30, 51-53, 57-59. The proper weld effective throats have been used in the calculations to accomodate the root conditions.
| |
| l l
| |
| l 1381d -_. -. . _ - _ . - - _ . . - . _ _ _ - _ - _ _ - - _ - _ .- _ _ -
| |
| | |
| .:...-..4_-.... -
| |
| l It is alleged that:
| |
| : 20. " Generally, the construction forces have inter
| |
| ,J these symbols by insta11ating the stronger joint.' preted Response: This statement is dishonest without data to support its noncredible conclusion. It implies that the welder / fitter teams in the field erecting Class I Siesmic i
| |
| restraints knew by intiution [ sic] what the engineer really intended in his ambiguous Category I designs. I know from discussions that this assertion is false. And if they didn't know what was wanted in the first place, how could I they do it better? (Undated Anon. Aff., Attachment 5 I at 16.)
| |
| This allegation should be read in conjunction with allegations III-31 and III-50. Craftsmen see the same types of welded connections over and over again, especially on pipe supports and seismic restraints.
| |
| l It is not uncosmon to see welds all around a connection when lesser welds were specified. It is not uncommon to see fillet welds reinforcing groove welds in corners, where only groove welds were specified, and it is very cosmon to see oversize fillet welds.
| |
| Stronger joints than specified are not uncommon.
| |
| 0 1382d l
| |
| | |
| 2 III-50 ---
| |
| It is alleged that:
| |
| ~ ~ '
| |
| : 21. "The designers have interpreted them conservatively by reducing the assumed strength of the joint."
| |
| 1
| |
| - Response: This statement is inherently false for specific examples above. To illustrate, it is not possible to reduce.the strength of a 3/16" partial penetration weld with an allowable effective 1/16" throat in the bad calculations. What value could be assigned in the resulting calculation? Any value less than 1/16" could make the calculation (s) show the hanger failing under its own weight.
| |
| One final point should be added. The NRC staff has concluded that workers were not afraid to ra1se problems at
| |
| ~
| |
| Diablo Canyon. It is true that I wasn't afraid to raise issues. But g willingness to defend the integrity of g profession cost me g job. The last incident occurred after I submitted a February 15, 1984 memorandim confirming verbal management pressure to pre-inspect in 4.5 hours (Attachment 14). It is impossible to document and identify deficiencies in that amount of time. It is only possible .
| |
| l to accept whatever is in the field. That makes the program worthless as a reliable indicator of anything. After I submitted the meno, g- supervisor stopped talking with me.
| |
| j In a March 6,1984 memorandum (Attachment 15), management l
| |
| confimed the scheduling pressure as described.
| |
| ! Unfortunatley, I was laid off within a few hours of
| |
| ! receiving the confimations. My last day on the job will l
| |
| be March 23,.1984. (Undated Anon. Aff., Attachment 5, at 17.)
| |
| This allegation should be reviewed along with related allegations l
| |
| III-31 and III-49.
| |
| l The alleger keeps reiterating a single concern that relates to a 3/16-inch partial penetration weld with a fillet reinforcement. This was addressed in III-33E, III-36, and III-44. As has been pointed out and acknowledged by the alleger, creatit was not taken for partial l
| |
| 1383d . _ . _ _ _ - __ ._ _ _ _ . _ _ _ _ _ - _ _ _ _ _ _ _ _____
| |
| | |
| -----.... - . . . . .:. . = a. . . . .
| |
| penetration welds if they were unconfimed. The relation between these welds and fillet welds also has been discussed. The allegation
| |
| .;,0.'
| |
| has no merit.
| |
| The alleger, a preinspection engineer responsible for constructability reviews, was not layed off for documenting deficiencies as alleged. The alleger was originally hired by PTGC on March 31, 1983, and, as part of a scheduled force reduction, was let go on March 23, 1984. His ranking in March 1984 was 143 out of 147.
| |
| Subsequent to his layoff by PTGC he was hired by Pullman on April 9, 1984. He currently works for Pullman.
| |
| 1383d t
| |
| | |
| l t
| |
| III-51 It is alleged that: .
| |
| 1.) Pullman never required the prerequisites of schooling and on the job training per ANSI N45.2.6, paragraph 3.1.2 of its inspector candidates for Level II capabilities.
| |
| Currently there are inspectors who hired in as SNT-TC-1A Nondestructive Examination personnel and who have been subsequently upgraded to Level II visual, dimensional, and welding inspectors. Many of these people do not have a four year degree and two years of experience or a high school degree with four years experience, as required by ANSI N45.2.6.
| |
| 2.) Neither Pullman nor PG&E told the Pullman inspector that he was certified to and responsible for ANSI N45.2.6 Level II capabilities. Pullman's certification card for the inspector does r.ot reference ANSI N45.2.6, the required basis for certification. (3/21/84 Lockert Aff. at 2.)
| |
| It was not until 1983 that Pullman Power Products was first required by PGandE Specification 8711 to develop a Quality Assurance Program in accordance with ANSI N45.2. This requirement has been fully met.
| |
| First, as a point of correction and clarification, there is no paragraph 3.1.2 in ANSI N45.2.6-1978 (see Exhibit 1 attached).
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| Second, Pullman is in full compliance witt. the training requirements of paragraph 2.1.2, " Training," (see Exhibit 2 attached.) in that a training program was established that included an on-the-job participation requirement. Finally, ANSI N45.2.6, paragraph 3.5 states (see Exhibit 1 attached) that the education and experience requirements listed in the standard are only recommendations that can "be treated to recognize that other factors may provide reasonable assurance that a person can completely perfone a particular task.
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| Other factors which may demonstrate capability in a given job are 1429d -I-
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| l previous performance or satisfactory completion of capability testing." Pullman uses this option from time to time to qualify fnspectors and all qualification, training, and testing rn: cords are
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| , 4 documented and maintained on file.
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| t :' _
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| l Although Pullman does not specifically "tell" inspectors that they l am certified to and responsible for ANSI N45.2.6 Level II l
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| l capabilities, the Pullman certification card issued to inspectors i plainly lists the level of certification and states that the inspector "is qualified in accordance with Pullman Power Products l procedures to perform duties as indicated on the back of..." the 1
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| certification card. There is no requirement anywhere that an i
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| inspector be specifically told that he is qualified to N45.2.6, and it should not make any practical difference whether or not the individual knows that he is qualified to N45.2.6.
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| Pullman Procedure ESD 278 specifically describes the responsibilities of the inspector in paragraph 2.0, the capabilities of a certified inspector in paragraph 5.5, and the fac't that all personnel engaged in inspection and testing activities are qualified and certified in accordance with ANSI N45.2.6. It is expected that qualified I inspectors are capable of reading and understanding this document if they choose to do so.
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| 1429d ,
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| l l
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| i Exhibit 1 of Response to III 51 OUALIFICATIONS OF INSPECTION, EXAMIN ATION AND .
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| , TESTING PER$0NNEt.FOR NUCt. EAR POWEA PLANTS , , . , ,. ANSI /ASME N45.2A-t978
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| ~
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| (7) resultsorphysicalexaminations,whenmquired nations, and tests;in supervising and certifyinglower level per.onnel;in sporting inspeedon, examination, .
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| . . (8) signature of employer 4 designated spresen. .
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| - and testing results; and in evaluating the validity and sadw - . ... . .
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| . . c. .- - acceptability of inspecdon, examination, and test s ."T~
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| s (9) date of certification and date of certification msdu.
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| . i.. **pir*8388 11...#..
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| 33 physissi 3,4 I,,,as lit pe,sannel Capahsides
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| .;* 'fhe sesponsible organizadon s'saR Identify any A hvel III person shall have s3 of the capab3 ides special physical characteristics nerdad la the perfor. of a hvel !! person for the inspection, examination i mance of each activity. Personnal requiring these or test category or class in queadon. In addition,the characteristics sher how them verified by exarnina. hdividual shall also be capable of evaluating the l tion at latervals not to exceed one year. adequacy of spec.fic programs used to train and test
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| . Inspection, examinados, and test personnel whose
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| : 3. QUAllpiCATIO985 qualifications are covered by this Standard.
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| 3.1 General 33 Eduardon and Experienoe4ecommendetsons The requirements contained within this Section dsfine the minimum capabilities that qualify person. The following is the ' recommended persones!
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| I nel to perform inspections, examinations, and tests educatlas and experience for each lew!.nese educa '
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| which are within the scope of this Standard. , tion and experience secomnwndadoes should be tnated to W- est oder factws may preside There are three levels of qualification.The squire. seasonable assurance that a person can competently ments for each level are not !!miting with regard to pedam a perticular task. O&er factas w'ich n may orgaizational position 'of professional status, but
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| { rather, are limitir ; with regard to functional activities demonstrate capability in a givenjob are previous per.
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| famance or satisfactory completion of capability which are within the scope of this 5tsadard.
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| tesdag.
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| 3.2 LevelI personnel Capabilities 3.5.1 Leveli A hvel I person shall be capal'de of pe: forming (1) Two years of related experience in equivalent the inspections, exarr.inatirms, and tests that are re. Inspection, examination, or testmt; activities, or quired to be performed in accordance with docu. Q) High what graduadon and six mones of mented procedures and/or. industry practices.De in. n 8te expuince in equent inspeedon, exanma.
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| dividual shall be familiar with the tools and equipment den, m tudng acdvida.w to be employed and shall heve demonstrated profi.
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| ciency in their use. The individual shall also be capabic Q) Completion of college level work leading to an of determining that the calibration status ofinspection Associate Degree in a related discipline plus three snonths of related experience in equivalentinspection, and measuring equipment,is current, that the measu,.
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| ing and test equipment is in proper condition for use, examination, or testing activities, and that the inspection, examination, and tem proce- 3.5.2 Lewi11 .
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| (1) One year of satisfactory performance as hvel I in the corresponding inspection, examination or test 3.3 Leveill personnel Capainlities -
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| category or class,or A hvel 11 person shall haw aR of the capabilities (2) High school graduation plus three years of of a hvel I person for the inspection, examination or related experience in equivalent inspection, examina-test category or class in questica. Additionally, a tim, w inting activities, or hvel 11 person skall have demonstrated capabilities in planning inspections, examinations, and tests;in set- Q) Completion of college lewl work leading to an ting up tests including preparation and set-up of Associate Degree in a related discipline plus one year related equipment, as appropriate;in supervising or misted experi:: ice in equivalent inspection, examins-l' - maintaining survedlance over the inspectier s. exami- tion, or testing activities, or I ,
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| t i
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| . , , - - --,-~-,,,,,-r---,,,-,,,.-n
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| Exhibit 2 of Response to III 51 OUALIFICATIONS OP INSPECTION. EXAMINATION AND ANSI /ASME N45.2A-t#7s TESTING PERSONNEL POR NUCLEAR POWER Pt. ANTS - ..--- ---
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| ~
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| y Standard, unlem they are specified in the contract 2.1.2 Training.no need for formaltrainingprograms shall be determined, and such training acdvities shall documents.
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| be conducted as required to qualify personnel who 1A Denseden* ,
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| perform inspections, examinadons, and tests. On.the.
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| , SA.1 Inspection. A phase of quality coetrol which job participation shall also be included in the program, with emphasis on first. hand emperience gained through
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| ~ ~ ~ by saeans of examination, observation, or measun-ment determines the conformance of materials,sup- actual perre mance of inspections,samninstions,and tests. Itecor 4 of training, when used as the basis for pHes, parts, components, appurtenances, systems, certificatfor,shd be maintained.
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| processes, or structures to predetermined quality re-N*"*"I'* 2.2 Detern instion of tal$ai CapabiHty 1 A2 Examination. An element ofinspection consist. W da u fa cerdGca h lag ofinvestigation of materials, supplies. parts.com- shall be initially determined by a suitable evaluation ponents, appurtettences, systems, processes, or strue. d b Mh's h% g% mg tuas to &tennha confonnance te those specM test remst?s,oc canebility demonstration.'
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| =-
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| mquirements which can be determined by such inves.
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| tigation. Exaninstion is usually nondestructive and 2.3 Evaluation of Performense includes simply physical manipulation, gaging, and De job performance of inspection, examinadon,
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| "**"*"*"'* and testing personnel shall be reevaluated atperiodic 1A3 Testing. De determination or verification of intervals not to exceed three years.Reevaluadon shall the capability of an ftem to meet specined require- be by evidence of continued satisfactory performance ments by subjecting the item to a set of physical, oc redetermination of capability in accordance with chemical, environmenta!, or operating conditions. Subsection 2.2. If, during this evaluation or at any ,
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| , " other time, it is detennined by the sosponsible or-(' 1.4.4 Refer to ANSI N4$.2.10 for other definitions ganisation that the capabilities of anindividual are not to be used in conjunction with this Standard. in accordance with the qualifications specified for the
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| ' 1.5 Rsfer need Documents job, that person shall be amomi from that activity unta such time as the required capsbility has been Other documents that are required to be included demonstrated.
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| as a part of this Standard are either identified at the point of reference or described in Section 6 of this Any person who has not performed inspection.
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| examination, or testing activities in his qualified ares Standard.he issue or edition of the referenced docu-trunt that is required wCl~ be specified either at the for a period of one year shah be reevaluated by a re-determination of required sapability in accordance point of seference or in Section 6 of this Standard.
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| with Subsection 2.2.
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| 2.4 Written certifiescon of Chsalirieseson De qualificat?n of personnel shall be certinedin
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| : 2. GENERAL. REOtJtREMENTS writing !n an appropriate form including the follow-i"Ei "f '**' "
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| * 2.1 Plannig (1) employer's nar se Plans shall be developed for stafnng,indoctrina. ( ) identincadon of pemn being certined tion,and training of an adequate number ofpersonnel (3) level of capability ,
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| to perform the required inspections, examinations, and tests and shall reflect the schedule of project ac* (4) activities certified to perform tivity so as to aDow adequate tirne for asagnment or (5) basis used for certificadon,'ncluding:
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| i selection and t.taining of the required personnel.
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| (a) records of education, experience and 2.1.1 Indoctrination. Provisions shall be m-de for the training indoctrination of personnel as to the technical objee. @) tut rmits, when appucaWe tives of the project; the codes and standards that are (c) msults dcapaEty &monstradon
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| [ to be used;and the quality assurance elements that (6) results of periodic evaluations are to be employed.
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| 2
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| l l
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| :- 3 ...- . . . . .
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| III-52 It is alleged that:
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| : The Quality Assurance requirements at a nuclear power plant
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| : can be viewed as a pyramid with the most important requirements at the top. The next lower tier would hold more requirements as the nature of the wort becomes diversified and more specific. The lowest tier would be the actual instruction to each person for each act
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| - requiring quality control in the construction of the l plant. Each tier supports and hopefully ing1pdes all i
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| CFR ANSI N45.2 f
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| ASMI,AWS, ASTM, AISC CENCII AND CONTRACTORS PROCIDUR Impplicable requirements from the tier above it. Pullman inspectors were not certified to ANSI N45.2.6 requirements and neither were they allowed to conduct themselves as inspectors capable of recognizing problems within the quality assurance pyramid because Pullman inspectors were blocked from obtaining information beyond company procedures and boxed in the lowest tier of the quality assurance pyramid. For PG4E to make the statement that Pullman QC inspectors were certified to ANSI N45.2.6 -
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| requirements without telling the inspectors or allowing the inspectors to conduct themselves as such, appears to be only for the purpose of misleading the NRC into granting a license before a complete evaluation of construction j Quality Assurance problems has been completed. (3/21/84 Lockert Aff, at 4-5.)
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| As indicated in response to Allegation III-51, and contrary to this allegation, all Pullman QC inspectors are certified in accordance
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| ' with ANSI N45.2.6. As to the allegation that ''fullman inspectors were blocked from obtaining information beyond company procedures and boxed in the lowest tier of the Quality Assurance pyramid,"
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| 1433d _ .-..- ,; . ____ -_..- . _ _. __ -. - -- - _ -_....._-_-. --
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| ..p . =
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| =. . . _ _
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| Mr. Lockert has attempted to translate his own experiences, where he was repeatedly warned not to leave his assigned work area without appropriate supervisorial notification and approval, into this broad charge. Inspectors are not blocked from researching codes and
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| ~~
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| standards specific to pmblems that arise during the course of inspections. However, they are directed to request pemission to leave their assigned work area before pursuing such research, and to make their leadsen aware of the problem identified or document it on i
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| l^
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| ( the appropriate reports; then, appropriate action can be taken by the responsible individuals and the inspector can continue his inspection work. There is no institutional freedom for inspectors to roam the site at will despite Mr. Lockert's claims to the contrary. As was previously indicated in PGandE's . Answer in Opposition to Joint Interveners' Motion to Reopen on CQA, Karner and Etzler Aff. at 19-22:
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| 1
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| : 30. "At no time has any inspector, Mr. Lockert included, been forbidden to research applicable codes and standards or other pertinent documents. However, such research activities must be perfomed within the time constraints of the individual's assigned activities. In the case of QC inspectors, they are assigned to specific activity areas in the plant and are required to be in those areas to sign off on the work being perfomed when the appropriate hold points are reached. Mr. Lockert was not teminated for mertly being physically outside of his assigned work area to do research, but rather, he left his assigned work area without asking the pemission of his leadman or supervi;or, and his whereabouts were unknown for extended periods of time. Such absences led to work stoppages and/or delays. Had Mr. Lockert requested the necessary approvals, or had he pursued his research during other available times, the information he desired could have been easily obtained as it is always readily available. It can be further pointed 1433d 2-
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| out that in most cases, the need for QC ins'pectors to perform such research is minimal. The procedures in use generally reflect the requirements of the relevant specifications, codes, and standards. Thus, the
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| - originating documents should not need to be researched
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| ; once the procedure has been approved.
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| The statement by Mr. Lockert that PGandE is attempting to mislead the NRC into "grai: ting a license before a complete evaluation of construction Quality Assurance problems has been completed" is untrue and is based upon his ineccurate perception of Pullman's Quality Assurance Program and the role and responsibilities of the inspectors.
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| l o
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| 1433d l
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| l It is alleged that:
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| l PG8E has also made false statements in its Februa 17 l
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| 1984 letter to the NRC concerning the welding of A 325,
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| .- bolts. (DCL-84-067, attached as Exhibit 2.) PGAE tries to l sidestep the fact that cold cracking is more likely when high-strength materials are welded, by saying that, " cold crackin is easily detected by visual inspection." I couldn'g t believe that PG4E would make such a statement, so I discussed this point, also, with the professor. He said that PG4E's statement was the most ridiculous thing he had heard in years.
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| In fact, cold cracking is not easy to detect visually because it usually occurs in the interior part of the weld or in the parent material, and therefore is not visible as a surface crack. A cold crack can gradually grow until it reaches a critical size, and then can take off as a
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| " running crack", rapidly growing in size (at a speed of 1500 feet per second), which can lead to the sudden total failure of the welds. I as told that because of such running cracks, more than 30 of the Liberty Ships built for the U.S. Navy in World War Two suffered catastrophic cracking and sank.
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| On February 29,1984, PG4E sent the NRC a supplement'to their attempted explanation of welding A-325 bolts (DCL-84-J78, attached as Exhibit 3). This describes an after-the-fact effort to qualify the welding of A-325 bolts.
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| Asih from the fact that welding procedures are supposed to be qualified before +5e work is done, there are several flaws in PG4E's process. First of all, PG&E is wrong in saying that "approximately two days" is " adequate for Itydrogen....to diffuse into the base metal." In fact, the problem with cold cracking is that it can develop long after the weld is done, as much as six months or more.
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| Even more incredibly, PG8E says that they will perforvi a liquid penetrant test to show the acceptance of the procedure. However, liquid penetrant testing can on1r detect surface cracks, while the main problem with cc ed cracking is that it is underbead cracking which doesn't show u_g on the surface. So PGAE's testing on which they
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| [ sic] propose to retroactively qualify the welding of A-325 bolts is the wrong test. It will be unable to detect the kind of cracks that are most likely to occur.
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| 1656d l L _ _ . _
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| ~ , ..
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| ~
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| Once again, PG&E is either amazingly incompetent or they have deliberately tried to mislead the NRC and the public
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| .with this explanation. ~"~
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| I have only reviewed a small sample of the PGAE responses in this affidavit. However, they represent an example of
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| - the quality of PGAE's analysis of problems brought up to the NRC. I believe that the NRC is being seriously misled
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| - by PG&E in their responses. PGAE is playing fast and loose with the facts, apparently to try to cover up previous mistakes. I hope the NRC, through lack of technical knowledge, doesn't hastily accept PG4E's false and misleading explanations. Local residents here in San Luis Obispo county deserve better. The NRC should make sure that they demand the truth from PG&E before they vote on allowing the plant to go critical. (3/21/84, Anon. Aff.,
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| i Attachment 7 at 5-7.)
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| This allegation is without merit and essentially the same as that authored by Mr. Lockert. The DCL-84-195 response to NRC allegation nimbers 450 and 460 completely covers the issues raised here.
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| There is one new twist which is in fact irrelevant to the case at hand. The liberty ship running crack concern is related to different i
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| materials in very large and restrained structures that were not welded with low-hydrogen electrodes.
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| f As has been indicated before, this was and is of no technical concern for the A325 bolts because these were welded with low hydrogen ;
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| j electrodes, the welding heat caused the heat affected zone to be soft, and the two inch long, 5/8-inch diameter studs do not develop significant restraint. Thus cracking is not a concern. However, as indicated in PGandE letter DCL-84-161 to NRC, dated April 27, 1984, l
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| the pipe support design has been revised to require that the base l
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| 1656d l
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| 1 s 1
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| . ._ _ . . _ _ . . ~ - __...,_.m.,m. _ _. _ ._. _ . . . _ . . _ , . _ _ _ _ . . _ . . , _ _ _ . _ . . _ - _ _ _ _ .
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| 4 I
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| Pl ates be welded in lieu of relying on the A325 welded bolt connections.
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| O O
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| l i
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| i 1656d . 3-
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| ~~ - - - . . . _ - - .----. . .
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| III-56 It is alleged that:
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| For example, when I was at Atkinson, I observed an
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| .. inspector sitting at his desk in the office, repeatedly l signing someone else's name to a whole stack of documents.
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| It turned out that an inspector had left Atkinson, and l after he left someone decided that there were a number of I documents that he should have signed or initia11ed. So, instead of re-inspecting the work, or even trying to get the first inspector to try to mconstruct the paperwork, Atkinson chose to have another inspector forge the signatum of the first inspector. Since he was doing this in the office I assume that it was done with the knowledge of management, and probably at their direction, to r.ake the papemort good-looking, even if inaccurate.
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| Also while I was at Atkinson, during the time that seismic i
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| modifications were being done to the turbine building, I discovered that someone had signed :J name as having inspected some work that I knew quite wei! I had never inspected. At that time Atkinson had two shifts, and I discovered that it was a person on the other shift who had '
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| forged g name. I confronted.his about it and he admitted that he had signed g name, and the signature was corrected. He did not, to the best of g knowledge, ever forge g signature again.
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| Incidents like this one point out the need for QC persc9r.e1 to always be alert to the possibility of being set up, so I as to taks the rap for having approved bad work, a tactic that has been used to fire people at Diablo. (3/21/84 Anon. Aff., Attachment 8, at 1-2.)
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| The allegations relating to large scale signing of sorcone else's name and forging of signatures are unsubstantiated and untrue. As structural modification work started on the first few bays of the turbine butiding, a more detailed inspection / documentation system was developed to provide specific inspection traceability for the documentation of each unique welded or bolted field connection (Guy
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| ! F. Atkinson Company (GFACo) Fom FE-1). The existing (initial) 1403d _ - . _ _ , __. _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ --
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| l I
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| inspection documentation considered several joints or connections at a common location as a single entity. Multiple forms identifying the
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| .- previously completed and inspected joints were prepared from the
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| ~ '
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| ' single previously completed inspection forms by QC lead inspectors or by a QA engineer. The original QC inspector was contacted for confirmation and initialing / signing of the inspection forms for each numbered joint for which he was responsible. This might account for the observation by the a11eger that an inspector was seen repeatedly signing documents. However, such signings were with the individual's own name, not that of others. In cases where the original inspector was not available or when inspection of the joints could not be verified by review of the inspection documentation, the work was either reinspected or the incomplete or missing information was documented through an NCR.
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| 1 Obviously, no one can be absolutely certain that isolated instances where individuals surreptitiously signed the name cf another
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| ' inspector to a form did not occur. However, such a practice was neither sanctioned nor condoned by PGandE or its contractors. Anyone identified to management as having done this would have been dealt with severely. Specific avenues for reporting of failures and
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| ; defects (and forgery / falsification) were set up under the requirements of 10 CFR 21 and were made known to all employees.
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| Neither the alleger nar anyone else brought forth any information about this alleged act of forgery, which supposedly occurred over 1403d five years ago, to the attention of management via aqy one of the available avenues or in any other manner before this instant
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| . affidavit.
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| .2 N
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| 9 l
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| 1403d
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| - 3-
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| III-57 It is alleged that: ,
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| The same problem exists at Pullman. I have been told by e- two separate QC inspectors at Pullman that they were upset that Harold Karner, the QA/QC manager, had forged their names on documents. At least one of them was talking about hiring a lawyer, although I do not know if he did.
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| (3/21/84 Anon. Aff., Attachment 8, at 2.)
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| This allegation is based on hearsay and the fact that it is totally devoid of factual content makes it impossible to respond to in detail. Mr. Karner categorically dentes having ever forged the name of anyone to QA/QC documents and the fact that no one has come forward with such a claim, either through the many available techanisms on-site or through the appropriate off-site law enforcement authorities,'would appear to indicate that, the Intervenors' affiants have made an unfounded accusation.
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| l l
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| 1554d . . - . - - -- . . , . . - . _ . - . - . - - _ . - - - . _ . . - - - _ . . . . - _ . . - - - - - - .
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| III-58. III-60 and III-67
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| . .i It is alleged that:
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| : The particular reason I was concerned about the possibility l -- of being set up at Atkinson is that another inspector and I, who were on the swing shift at the time, had a reputation for taking a firmer attitude toward inspection than that of the inspectors on the day shift, because we tried to insist that the work be done right. This led to a series of verbal confrontations because the word was put out that the swing shift was going to be shut down because of us. The other inspector had the tires of his car punctured. (3/21/84 Anon. Aff., Attachment 8, at 2-3.)
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| Shortly after that incident, I was physically retaliated against by two ironworkers. One of them asked me to inspect the rooc pass on some welding. To get to it I had to climb down below the floor level, and as I was down there, another ironworker dumped a bucket of water, cf indeterminate quality, on g head. The ironworkers had coordinated this to get me down there so they could dimp the water on me.
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| When I told my leadman about this, he told me that since I was leaving soon anyway to go to work for Pullman (I did plan on leaving in approximately two weeks) that he would put someone else on the job, and I should just lay low for sy remaining time at Atkinson.
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| For the next two weeks I did essentially no inspection work. In effect, the ironworkers had succeeded in running me off the job. No one ever took any action against either of the ironworkers, and I did not press the issue sqyself because I was leaving. (3/21/84 Anon. Aff., Attachment 8, at 4-5.)
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| 20 One of my crew suffered cmde harassment after an inspection. Construction crews from two floors above, or around 35-40 feet, doused him with mopwater from the blue room. That means they dumped mopwater on him from the bathroom.
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| i
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| : 21. Construction crews threatened inspectors with personal l bodily harm as reprisal for interfering with production.
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| ; For example, in a March 8,1979 swing memorandum (Exhibit 5) one of y inspectors described an ironworker's 357 rumor and you. "357" referred to a ".357 Magnum" i handgun.
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| 1355d i
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| .:--*T
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| : 22. Constmction crews repeatedly threatened me with phsical retaliation for obstructing production. Threats included such incidents as gang rape by ironworkers.
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| j Although I didn't take the threats seriously, after one
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| . incident I returned to the parking lot % truck was .
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| tilted on its chin and there were two flet tires, from being slashed. (3/9/84 Hedrick Aff. at 7-8.)
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| The issue of the tire slashing was previously discussed in the PGandE Answer in Opposition to Joint Intervenors' Motion to Reopen on CQA,
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| * Karner and Etzler Affidavit at 46-48. Unfortunately, the incidents involving the dousing of an inspector with water and the slashing of I
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| tires did occur. However, the implication on the part of the affiant that such incidents were condoned or overlooked by GFACo (or any other contractor on the site) is not substantiated by the facts. The incidents in question were fully investigated by GFACo management when their occurrence became known to management. Although it was impossible to determine that all of the facts were exactly as alleged, GFACo paid for replacement tires for the inspector's vehicle and took steps to minimize the likelihood that such incidents could reoccur.
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| It should be pointed out that incidents of this nature, actual or I
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| alleged, are not unheard of on any construction project. On a project of this magnitude, it is impossible to police all personnel and all activities at all times. In addition, an inherent conflict of interest exists between the production oriented crafterkers and 1
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| the quality responsibilities of the inspectors. This conflict can i result in flared tempers or petty acts of retribution if matters are 1365d .
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| -w--
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| y.r-,_,,----.c.,7,y_.y.--.3-mw., __y__,m..,..%, _ . , . , , , , , , , .., _ - - - -___-m.. . _ _ _ . _ _ _ _ _ . _ _ _ _ _ _ _ - .
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| | |
| i
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| ..........~'~~
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| not handled with tact and diplomacy. Harassment and threats are not condoned by PGandE or its contractors and appropriate disciplinary
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| $ action is taken when evidence is available to corroborate 1 complaints. Without such evidence, however, it is impossible to press charges or take other " positive" actions. It is unclear just which actions the allegers would have wanted GFACo to take without the necessary witnesses or proof of who committed the incidents.
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| Craftworkers are told, in no uncertain terms, that any such actions will not be tolerated and inspectors, hopefully, learn to handle the l
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| l, act of rejecti;.g the work of others in a diplomatic manner.
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| 1355d l i _ - . - _ . - . _ _ _ _ _ . . _ , . __
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| I l
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| 1 I .
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| l III-59 and III-68 l ._ .
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| It is alleged that:
| |
| . Atkinson did shut down the swing shift, and each of us was a transferred to the day shift, soon after which an l
| |
| 1ronworker superintendant [ sic] threatened me, saying that l . . . .
| |
| I was not going to " pet away with" the same things on day
| |
| ' shift as on swing sh' ft, and I had better watch out. I was te intimidated. (3/21/84 Anon. Aff., Attachment 8, at i
| |
| : 23. Management was openly hostile to the night shifts
| |
| [ sic] high quality standards, and around April 1979 abolished our entire shift. There was little question
| |
| , about the reason for abolishing the shift. Supervisors informally told us ^Jie mason was that it was not economical to keep our shift when we wouldn't buy the work.
| |
| : 24. This cancelling our shift was the last incident after
| |
| : a period of management hostility against the night shift.
| |
| Earlier management had warned us to ease up on our
| |
| ; . standards.
| |
| i 25 When management cancelled the night shift to eliminate a production obstacle, it also sacrificed the best qualified inspectors for the Hosgri modifications on the t turbine building. Most of the inspectors on night shift I went to Cal Poly during the day where they were in the i
| |
| midst of advanced engineering or welding programs. When the night shift was cancelled we inherently lost those inspectors, since they were scheduled for classes during the day. By contrast, the day shift inspectors left to cover everything consisted primarily of individuals whose '
| |
| basic qualifications were that they needed the work and passed a one-week inspection course. (3/9/84 Hedrick Aff.
| |
| , at 8. )
| |
| Contrary to the allegation, the FACO night shift was disbanded in I April 1979 because the FACO work w s entering the completion stage (FACO left the site in August 1979). The amount of work remaining and simple economics dictated that a single day shift was all that was necessary to complete the work on schedule. The allegations that FACO management advised the night shift to " ease up on its i
| |
| 1354d - _ - - . - -. - . - - - . . - _ - - _ . - - - - . - _ . . _ . . -
| |
| | |
| ItandardsE or that the "best malified inspectors" were sacrificed when the night shift was disuanded are unsubstantiated. All
| |
| ~"
| |
| , inspectors, both day shift and night shift, were qualified through
| |
| ~T training / certification to perfom their assigned inspection duties in
| |
| ~ - - ' " ~
| |
| r professionally acceptable manner. At no ti:ee did GFACo management instruct their inspectors to sacrifice quality for production. In fact, management always stressed quality workmanship and standards.
| |
| All inspection activities on all shifts were perfomed to the same standards.
| |
| 4 l
| |
| l 1354d !
| |
| | |
| ~
| |
| -- - ^--
| |
| l .
| |
| l
| |
| .n..... . s. . -
| |
| III-59A It is alleged that:
| |
| As I checked the temperature, the welder demanded to know f -
| |
| +
| |
| "what are you doing?", suggesting that he didn't even know the requirements fer maintaining the temperature of the work above a certain minimum.. And when I told him that he was in violation of the code he got very upset, especially becauseaboutsixfeetcfweidinghadto,..egroundout. .
| |
| (3/21/84 Annn. Aff., Attachment 8, at 3-4.)
| |
| The alleged fact that a single welder was supposedly found to be unaware of specified preheat and interpass temperature requirements is not indicative of any generic problems at Diablo Canyon, but instead clearly demonstrates that the Quality Control program was working properly. However, it would be prudent to question whether the events actually happened as they are recounted by the affiant.
| |
| Deper. ding on which word the welder emphasized or the inflection of his voice when he asked, "What are you doing?" (as he saw the inspector climbing up to him), the alleged query may we'.i have reflected either anger or bemusement on the part of the welder, rather than the alleger's interpretation of procedural ignorance.
| |
| In any case, the fact that the QC l3spector was aware of the failure to follow the guidelines of the appropriate welding procedure and that he caused the "six feet of welding" to be ground out and redone properly, is a clear indication that the QC program was functioning as it was intended to. If there were no expectations that inspectors
| |
| ( would uncover anomalies in the course of their activities, then there would be no need for inspectors and inspections. The fact that the i
| |
| 1356d . _ _ _ _ _ . ___._____..__.__ _ _,_-_ _ . _ ._.
| |
| | |
| f
| |
| _ ___.~.-
| |
| ...'. .~_~:T ~ '. _ .T .. . .
| |
| welder got "very upset" when told that he had to grind out the material and ruweld is not unexpected as such a task would most certainly be arduous and leave him open to admonishment from his supervisor. The experienced " upset" or even anger is not an uncommon
| |
| ~
| |
| emotion to encounter under these conditions.
| |
| One constant thread of contention seems to run through this and other similar affidavits. The implication is that the identification of a discrepancy in the course of a mandated inspection process automatically bespeaks shoddy workmanship or a progrannatic breakdown. To the contrary, such an event indicates the reason for such inspections and the fact that the quality inspection process
| |
| ! does work. Deficiencies are identified and corrected throughout the l
| |
| l course of any project with no resultirg adverse impact on the end I
| |
| product.
| |
| 1 l
| |
| l l <
| |
| l 1356d l
| |
| | |
| l
| |
| - 4u . ..:---- ..
| |
| ~ ~
| |
| T% - .
| |
| . t . _
| |
| l
| |
| ! III-61
| |
| ~
| |
| ~ n--
| |
| : 3. . . _ It is alleged that:
| |
| I have spoken with many of these inspectors and the
| |
| ~ ~ ~ ~
| |
| majority of them agree that they feel they were not qualified or trained properly to perform their work. Most of them have stated that they would not care to have their previous work inspected.
| |
| The problems we were experiencing in our QC program of not having enough qualified inspectors, was (sic) also evident in the Pullman field engineering department. Although field engineers had a somewhat limited responsibility in regards to design work, they were given the power to make field changes - called quick fixes - that in some instances completely altered the original design. I will expand on this later as a separate issue.
| |
| With very few exceptions the people that Pullman hirea as field engineers had no previous nuclear experience, had no previous experience in any related field such as oil refinery or pipeline work, and had no engineering degree.
| |
| Nor did Pullman train the field engineers any more thomughly than the QC personnel, and so they had to take the same sort of on-the-job training approach while the wort was proceeding. As inspectors, we were expected to identify er:,urs made by field engineers. But for much too long a period, we had a " blind leading the blind" system.
| |
| (3/21/84 Anoi;. Aff., Attachment 9, at 3-4.)
| |
| This allegation is based on hearsay. QC inspection has been constantly evolving into a more and more complex art. The dramatic expansion of Diablo Canyon QA/QC procedures attests to that. All inspectors develop and improve their own inspection methods and techniques as time on the job increases. Their work, after any 1
| |
| extended period on the job, should obviously be superior to their initial efforts. This might explain the alleged statement that "most of them have stated that they would not cart to have their previous l work inspected." Field work is sample reinspected by PTGC before
| |
| )
| |
| l
| |
| ! 1438d ,
| |
| I
| |
| , . - . --- ---- _ . , . , - . _ - . - - _ _ _ . , _ - - _ , _ _ _ . . . . . , _ , , , , , ,.,.-y. m_ ._mm- - w, , . - - __
| |
| | |
| -- ? -- -. ...___u. __ ... _'. ~ ~ ~ ~ .."~~
| |
| final acceptance of the work and all documentation is reviewed for
| |
| [ accuracy and completeness before the installation is deemed totally acceptable and complete. The reference to a " blind leading the blind" system is a misleading one since all aspects of erection and inspection are described in detail in the applicable Pullman procedures and inspectors receive adequate training prior to being
| |
| " turned loose" on the job. In the event of uncertainty in any area of inspection, an inspector could go to his leahan or supervisor for information, direction, instruction, or clarification. The inspectors were not inadequately prepared nor were they left on their own, as is inferred in this allegation.
| |
| $1nce the alleger is a QC inspector, he is not responsible for hiring engineers and themfore cannot provide any detailed information (other than Jiearsay) about the qualification of engineering personnel.
| |
| Engineering personnel are hired by the Chief Field Engineer or the Engineering Supervisor only after their msume and/or application are reviewed and evaluated. Field engineers am hired based on a combination of their education and previous experience. Although a degree is not a premquisite, degreed engineers are hired preferentially over non-degreed engineers.
| |
| After hiring, they are required to complete the requirements of a Pullman Engineering Instruction which details the training 1438d . . . . .
| |
| | |
| ~
| |
| - mquirements of engineering personnel. Completion of these
| |
| .;, . requirements is documented and the records are kept in the individual's personnel file. Because of their previous education and/or experience background, the field engineers need only familiarize themselves with the jobsite practices and procedures to be able to perform their work in an acceptable manner. Thus, the allegation that Engineering and QC personnel were not adequately trained is patently false.
| |
| 1 l
| |
| l l
| |
| 1438d . .. .- . _ _ _ _ _ . _ _ - . .._ -.. -- .- . . . . . . . . - _ _ . - _ - . - _ _-
| |
| | |
| III-62 It is alleged that:
| |
| . As an example, procedures for rupture restraints using
| |
| .;. ESD 243 and the American Welding Society (AWS) code are quite different from pipe suoports using ESD 223 and the American Society of Mechanical Engineers (ASME) code. This led to great confusion and far too may mistakes by all concerned. The problems were so numerous that separate departments wem set up to perfom only one type cf work.
| |
| This seemed to help alleviate some of the problems, but only after many errors were made that still exist in completed work. (3/21/84 Anon. Aff., Attachment 9, at 5.)
| |
| The alleger's claim that "may errors were made that still exist in completed wort" is so vague that a direct response is impossible.
| |
| However, when one considers the numbers and various levels of inspection and reinspection that the supports and restraints have been subjected to, the alleger's clain of many errors or generic problems is not reasonable.
| |
| The reason that separate groups were established was to maximize f engineering and craf t efficiency and to enhance connunication between the engineering staff and craft workers. It is apparent that the i
| |
| alleger was not privy to the management decision process to split the l two groups. Themfore, he has no firsthand know1 edge of the factors that go into such a decision.
| |
| l .
| |
| I 1
| |
| 1600d t
| |
| t l '~ ~~ ~ T :
| |
| . . . :. .~ T
| |
| ~^
| |
| III-63
| |
| - - . It is alleged that:
| |
| Another generic failure at Pullman that I think has seriously compromised the quality of Pullman's work is the lack of effective drawing control, and therfore [ sic]
| |
| t inadequate control of the design of the plant. The
| |
| ! drawings issued to the field for wort often needed modifications that were outside the tolennces allowed by Pullman's procedures, the ESD's. Toacconglishthese design changes a system called " Quick Fix - later changed in Unit I to Pipe Support Design Tolerance Clarification -
| |
| was instituted. The Quick Fix form is filled in by a Pullman field engineer and then cosigned by a Bechtel field engineer. Thus the quick fix was a change of design made in the field. The basis for these design changes was
| |
| , strictly a matter of the engineering judgement of the field engineers as to what seemed like it would work. There was no requirement for any load or stress calculations.
| |
| The situatior. is made worse by the manner in which Quick Fixes art often prepared. Often they were hand drawn under poor conditions and were in many cases impossible to interpret. The Quick Fix program was designed to expedite construction, and therefore there was pressure to write Quick Fixes hastily.
| |
| Practically every drawing issued would require at least one -
| |
| Quick Fix, and I have seen as many as thirty-five Quick
| |
| ; Fixes for a single hanger. This can make interpretation very hard, because s veral Quick Fixes could address the same item and describe different solutions. Some would '
| |
| supersede and void portions of the drawing or of other Quick Fixes, but it was difficult or, at times, impossible to clearly understand what was intended.
| |
| J At times, a complete redesign occurred thorugh the use of Quick Fixes. The Quick Fix became the design, but they were not controlled nor were they stamped as approved for construction as the original drawing was required to be indicating that they were controlled copies, ready for use in construction.
| |
| Presumably, the completed work was submitted to PG&E for reanalysis. However, because of the often confusing nature of Quick Fixes, and the lack of control, I doubt that the drawings submitted to PG4E accurately reflect what exists in the field. ,
| |
| E
| |
| 'l 1402d . - . - _ _ - . _ _ . . -... - -. - _ - _ - - . _ . . _ - _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
| |
| | |
| . I feel that considering the conditions and pressures that we are [ sic] mquired to work under, anything less than a clear and precise drawing to wort from is bound to promote mistakes and faulty workmanship, and to leave the ultimate quality of the installed work as a big question mark.
| |
| : 2. (3/21 /84 Anon. Aff., Attachment 9, at 6-8.)
| |
| ' ~~~
| |
| Contrary to the allegation, design modifications which occurred by means of the Pipe Support Design Tolerance Clarification (PSDTC) g.rogram were accomplished by use of controlled documents and a controlled process. Regardless of whether the initial design j solution to a construction problem was hand-drawn, the final installation was as-built, mceived QC and QA inspection, and was verified according to procedure by Engineering to ensure that the
| |
| " front-line" solution met design and licensing criteria.
| |
| It is true that there were occasions when the design issued'to the
| |
| ! field needed modifications which exceeded the limits of the authority
| |
| : granted to Pullman as set forth in its procedures. In such cases, proposed modtfications were initiated by the Pullman field engineer and reviewed, approved, and numbered by the PSDTC engineer.
| |
| It is true many PSDTCs were hand-drawn; however, hand-drawn drawings were clear and explicit. Mr. Stokes claims that many of these drawings were impossible to interpret; however, the craftsmen had no pmblem interpreting the drawings and constructing the hangers in accordance with the PSDTCs.
| |
| 1402d l I
| |
| - _ - _ _ _ _ - _ _ , _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . , _ _ i
| |
| | |
| .? .. s. . . . . . ss . ......o.o.s..._ . - . s . . . , . .s
| |
| *;g .g . 1- T :.. - ,.,.,,....:...... . ,._ .g; i" It is also true that some drawings required multiple modifications for a single hanger. However, all PSDTCs that affected a large bore i hanger were assembled and transmitted along with the final as-built drawing to San Francisu for final design acceptance. Pursuant to procedure, Pullman field engineers prepared as-built drawings of the hangers based upon all the information contained in the hanger package, including all PSDTCs. The as-built drawing was then verified against the actual as-built condition in the field by Pullman field engineers, and the final as-built drawing was verified by Pullman QC and QA. This ensured that all PSDTCs that affected a
| |
| ! large bom hanger were accurately described on the final as-built drawing sent to SFHO for engineering review.
| |
| Contrary to the allegation, Pullman effectively controlled PSDTCs and prepared final as-built drawings for small bore hangers. The final drawings were prepared by the Pullman field engineers to ensure that they accurately depicted field conditions. Quality Control then verified in the field that the drawings accurately depicted the field conditions. The Pullman Quality Assurance review group then verified that the final document package contained the original design and all PSDTCs to ensure that each ites that required a PSDTC was documented in the final hanger package. The installed hangers received two individual as-built inspections in addition to a final Quality Assurance review to ensure that all design information was recorded.
| |
| Following all revit vs all necessary load-or-stress calculations were 1402d - - . _ _ - - . _ - _ _ _ . . _ . _ _ . _ _ . - . _ _ _ - _ _ - _ -_ ._ - - - -
| |
| | |
| { . .. . . . . . . . . A..... . A - ... .. l .
| |
| ...-__~
| |
| . . . - - . . . . , . . . . = . - - . .
| |
| perfonned when Project Engineering received the final as-butit drawing for final as-built evaluation. The only difference between
| |
| : the small and large bore process was that the final large bore hanger package sent to SFH0 for engineering review contained the PSDTCs and the final as-built drawing; whereas, the small bore package sent to OPEG for engineering review contained only the final ts-built drawing
| |
| (
| |
| without the PSDTCs.
| |
| l Contrary to the implication in the allegation, there was no requirement to stamp the PSDTC as approved for construction because the very existence of the signed-off PSDTC meant that the change was l approved for construction.
| |
| Mr. Stokes fails to recognize the totality of the PSDTC program which ensures that all changes receive the same level of engineering review and approval as a design originating in San Francisco and continues to foc is on'his narrow role in the process.
| |
| l l
| |
| 1402d - _ _ _ _ . . _ _ - . _ - - . - . . , _ . _ . _ _ . . . _ _ _ _ _ . _ . . _ . _ , _ , _ _ . - . . _ _
| |
| | |
| =--- ......_: . . _ . .
| |
| l III-65 It is alleged that: --
| |
| *; 6. Management had quality control documents falsified to l
| |
| "- upgrade the incomplete inspection records. Other personnel I doctored the records to add infomation that hadn't been included by the initial inspectors, after the originators c
| |
| had left the job. To illustrate, separate detailed
| |
| ! inspection records were created and substituted for one check mark that approved multipe [ sic] welds in the earliest records. I was an ewitness to this practice.
| |
| (3/9/84 Hedrick Aff at 3-4.
| |
| The allegation that management had quality control documents falsified is, itself, false.
| |
| This issue is apparently the same one that has been addressed in the response to Allegation III-56. As is stated in that response, as modification work on the first' few bays of the turbine building proceeded, it became apparent that it would be useful to provide documentation for each unique joint, connection or plate rather than collective documentation for several joints, connections or plates at a common location. Multiple foms identifying the previously completed and inspected joints were prepared by QC lead inspectors or by a QA engineer from the previously completed collective foms. The original QC inspector was contacted for confimation and initialing / signing of the inspection fom for each numbered joint for which the inspector was responsible. When the original inspector was not available or when inspection of the joints could not be verified ty mvfew of the inspection documentation, the work was either reinspected or the incomplete or missing infomation was documented through an NCR. There was no falsification of documents.
| |
| 1406d
| |
| - - - = . = - = - .:. -
| |
| III-66 It is alleged that:
| |
| : 14. At management instructions production crews ignored
| |
| .- and/or removed hold tags I had issued. In fact, production crews worked for three days on the welds in one case. In that instance even the production foreman supported sqr reject tag because he knew the welds could not pass ultrasonic testing (UT) examination. Even the welder wanted to hang a new plate. The techniques were so poor that lack of fusion was a near certainty. But management overrode the reject tag. (See Jul memorandum, enclosed as Exhibit 4)y 2e, i,78 swing
| |
| : 15. Another instance where production crews removed the hold tags is described in the March 8,1979 swing memorandum, enclosed as Exhibit 5. Production didn't take any metal out or remove the weld as they should have.
| |
| Instead, crews just ground it down so you wouldn't know that a weld was there.
| |
| : 16. During the summer of 1978 the hold tag log book was .
| |
| falsified to erase any reference to a hold tag I had handwritten. Consistent with usual practice I had issued and logged in by hand hold tag 026 one evening. The hold tag involved a violation that occurred from damage when an erection aid was removed from a gusset plate. In the process, about 1/4 inch divit had been ripped out from the base metal when the erection aid was broken off. The next day after I filed my entry in the log the secretary took that page and on a new page typed the entries up to aqy hold tag 026. Then she stopped and returned the typed version to the log. Eventually, someone else logged in a new hold tag 026. Mine vanished. To sty knowledge the violation was not fixed. A copy of the relevant log page is enclosed as
| |
| . Exhibit 6. (3/9/84 Hedrick Aff. at 6.)
| |
| The general subject of how " Hold" and " Reject" tags which were used to control questionable or rejectable work has been previously discussed in responses to NRC Allegations #408, #409, and #410 which were filed with PGandE letter DCL-84-145, dated May 29, 1984. As paragraph 14 of Mr. Hedrick's allegations appears to use " Hold" tag and " Reject" tag interchangeably and the circumstances associated 1408d ---.____ _ . .
| |
| | |
| =
| |
| _ . . = . - - . ..
| |
| with the specific welds are therefore not clear,'it is impossible to respond to this allegation in detail. However, under no circumstances was a generic management directive issued to ignore any such tags issued by Mr. Hedrick.
| |
| Mr. Hedrick implies that once a " Hold" tag is issued, it may never be l
| |
| l removed by anyone other than the inspector who originally placed the tag. This is untrue. In certain specific cases, if the welds were in progress and could be ground out and rewelded such that they would pass a UT examination, the decision to continue with the welds (rather than cutting them out and starting over) was valid. In all cases, a " Hold" tag could be removed after a detemination of an appropriate course of action or the acceptability of the existing weld. Such a detemination coeld only be made in conjunction with QA and/or Engineering. The ultimate acceptability of the welds would be indicated on an inspection fom signed by a QC inspector.
| |
| Paragraph 15 of Mr. Hedrick's allegations relates to " Hold" tags associated with excessive weave and oversized welds. These concerns were addressed in response to EC Allegation #420 (Mr. Hedrick's Paragraph 7) which discussed the generic resolution of excessive weave and oversized welds. Further, as described in response to NRC Allegation #416 (Mr. Henrick's Paragraph 3), the identified excess welding was ground down in preparation for UT inspection in i accordance with previously defined and accepted procedures.
| |
| 1408d l
| |
| l . . . . .
| |
| Mr. Hedrick's allegation that "the hold tag log book was falsified" was refuted in PGandE's response to NRC Allegations #408, #409, and
| |
| - M10. That response indicated that "Apparently, Mr. Hedrick's ' Hold' tag was incorrectly entered in the ' Reject Tags Issued' log and
| |
| ~
| |
| subsequent correction of the log deleted this incorrect entry."
| |
| There were no requirements for the listing of a " Hold" tag unless such a tag resulted in a nonconfnmance report (NCR). Had Mr. Hedrick's " Hold" tag met this criteria and had it been entered in the proper log, "NCR Hold Tags Issued", it would not have been deleted. The work tagged by Mr. Hedrick, as described in Exhibit 6 l
| |
| of his affidavit, was likely determined by the day shift QC supervisor to be work in progress and approved methods and procedures
| |
| .for repairing the base metal existed. Thus, the tag was removed and the required work perfonned.
| |
| Therefore, all of the activities of " management" addressed herein were conducted in an appropriate manner.
| |
| 1408d i
| |
| | |
| 1
| |
| .. l III-69 It is alleged that:
| |
| : 26. Management was not satisfied merely to dissolve my shift. Around April or May I was transferred to conduct an audit in the vault as punishment for our inspction record. It was unusual that a supervisory welding inspector would be auditing documents in the vault for 30 dvs.
| |
| When after around a month I found too many violations and correction action became backlogged, the pattern of retaliatory transfers continued. I was sent back to the field as a weld inspector until the end of the contract.
| |
| (3/9/84 Hedrick Aff. at 8-9.)
| |
| It is no't uncommon for experienced inspectors to be assigned the task of auditing internal documents during periods of diminished activity l
| |
| elsewhere.
| |
| It is assumed that an experienced inspector would be able to perform the auditing activities in a timely and efficient manner.
| |
| Neither the assignment nor the period of time involved was unusual.
| |
| As a point of clarification, the " vault" alluded to by Mr. Hedrick i i
| |
| not an airlhss, closet-like " black hole" structure but, in reality, is a well-lit, interior room, with limited but ample working space for at least four individuals.
| |
| Mr. Hedrick's assignment did not result in "too many violations" and the corrective action system did not become backlogged as he sta He was sent back to the field because the auditing activities were at en appropriate breakpoint and a need had been identified for additional QC inspection support.
| |
| 1639d
| |
| | |
| .. . =_ ,_ - - ___-_ ___ . .-. - _ - - - . - _ . -
| |
| i III-69A i It is alleged that:
| |
| e
| |
| : 29. Undociamented welds, perfomed by unknown welders, were a commen occurrence. Even if the weld were repaired, there
| |
| . would only be documentation identifying the second welder j who fixed it. Them was no way to identify the original welder whose wort was deficient. On site we jokingly referred to those undocumented welders as " ghost welders,"
| |
| (See February 14, 1979 memorandum, enclosed as Exhibit 8.)
| |
| (3/9/84 Hedrick Aff, at 9.)
| |
| The response to NRC Allegation #399 filed with PGandE letter DCL-84-195, dated May 29, 1984, addressed the subject of undocumented welds in greater detail. " Undocumented welds, perfomed by unknown welders" were not a common occurrence at Diablo Canyon as is l
| |
| l alleged. In cases where names of welders were not identified on inspection documentation (Hedrick Exhibit 8), subsequent follow-up by QC inspectors usually resulted in identification of the welders as required on GFACo Fom FE-1. In cases where the name of the welder could not be 'detemined, the welds were documented on an NCR as a basis for a$ceptance or rowelding.
| |
| i l
| |
| 1410d l
| |
| | |
| III-70 It is alleged that:
| |
| This is even more disturting when considering my first period of employment as an Electrical Inspector. I was at
| |
| =
| |
| the mercy of the crafts if the work I was to inspect on ary i given assignment required knowledge in addition to that of welding. This is because I did not have nor ever have had in depth trahing in the electrical field.
| |
| thmerous times I quizzed supervision as to why I was perfoming the inspections.without a level II inspector in attendance. The response to my inquiries was that "the were working on upgrading me to a level II inspector." y i' Finally I felt that ny concerns were a dead issue and ceased quizzing supervision about the situation. (3/20/84 Anon. Aff., Attachment 11, at 2.)
| |
| The alleger assumes that in order to be a qualified electrical inspector an inspector must be an electrician. Although this is the opinion of the alleger, there are no code or specification requirements that electrical QC inspectors be electricians.
| |
| Inspectors execute inspection activities to verify confomance of the electrical work with documented instructions and predetamined j requirements in procedures, specifications, and drawings. All acceptance criteria are contained in these documents. The QC inspector detemines whether or not the component meets the inspection criteria based on the criteria and not on whether the inspector himself would be capable of perfoming the work inspected.
| |
| During his first period of employment, the alleger received extensive on-the-job training in the use of Quality Control Procedures for electrical inspection of raceways and supports, electrical equipment, 1404d i
| |
| and associated welding. In fact, records indicate that he received more than 90 days of on-the-job training, which is twice the amount required by procedure. Therefore, one would expect that he was adequately trained to determine the acceptability of the work he inspected.
| |
| Level II inspectors are authorized to evaluate the validity and acceptability of inspection, examination, and test results of a Level I inspector. It is acceptable for a Level II inspector to monitor the Level I inspector's work. The monitoring can be accomplished by reviewing the inspection data generated by the Level I inspector, observing the Level I inspector's work, or reinspecting the weld inspections perfomed by the Level I inspector. The Level II inspector is responsible to evaluate the work of the Level I inspector to the extent necessary to satisfy himself that the work of the Level I inspector is acceptable.
| |
| 1 Level I inspectors may perform, but are not limited to, inspections
| |
| * hich entail a measurement of discrete variables with prvdefined tolerances from the nominal dimensions. These inspections may be perforised and documented without participation of a Level II inspector at the time of the actual inspection.
| |
| The fact that supervision was trying to upgrade the alleger to a Level II inspector indicates that, the Level II inspector responsible 1404d .
| |
| | |
| ., . . . . . . ~ . .. . ,. .. . -. ... .. . .
| |
| for monitoring the alleger's work was quite satisfied with his performance as an inspector and does not support the implication in the allegttion that it was for the purpose of avoiding inspection l'
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| requirements.
| |
| h 3
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| I l
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| l i
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| l l
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| 1404d - _ _ - _ . - _, .__ .-. ._ . _ - . . _ _ . , . - . . -
| |
| | |
| It is alleged that:
| |
| I To further illustrate the inaccuracies of the PGandE J:. letter, I was expected to fill out g own Training Record 7 documenting my " training" received in the " training program," which was largely non-existent. To the best of
| |
| ; . =.. my recall, I can only remember one, possibly two group training seminars. These group meetings were mostly futile, in that they covend very little relevant infonnation to educate or assist me in the perfomance of
| |
| ! my duties. (3/20/84 Anon. Aff., Attachment 11, at 4.)
| |
| 4 Contrary to the allegation, inspectors in training did not fill out their own training' records to document the training mceived.
| |
| Training in procedures orientation was accomplished by private meding of the pmcedure by the new inspector and on-the-job training on how to properly implement the procedures. During the reading phase the new inspectors were required to account for their progress insofar as the amount of material they had read. However, the progress record kept by the new inspector was not considered the I
| |
| official capification of the training received by the new inspector as implied in the allegation. The supervisor has the responsibility of documenting satisfactory completion of training requirements, and it is this documentation that is m11ed upon as evidence of training.
| |
| The allegation is correct in stating that the group seminars did not attempt to educate or assist the new inspectors in the performance of l
| |
| their duties. The group seminars were never intended to educate
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| /
| |
| i
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| ! inspectors in the inspection process. The seminars were designed to l
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| 1405d _
| |
| | |
| . _. . . .- _ _ . _ _ _ = _ - - -_ _. ..
| |
| I focus upon the role of inspections within the regulatory process.
| |
| The specific training in the procedures and conduct of inspections was accomplished by reading, familiarization with pmcedures, and
| |
| -: practical implementation during the on-the-job training.
| |
| As stated in PGandE letter DCL-84-195, dated May 29,1984, in response to NRC allegation #378, based upon the information provided j in the affidavit and a review of Foley records, only one individual's
| |
| ! employment history in terms of dates of employment and job assignment matches the infonsation contained in the affidavit. Contrary to the allegation, that individual received extensive training under
| |
| , supervision of a qualified inspector during both of his periods of
| |
| ( employment.'
| |
| * 4 During his first period of employment, the alleger received extensive on-the-job training in the use of Quality Control Procedures for electrical inspection of raceways and supports, electrical equipment, and associated welding. In fact, he received som than 90 days of on-the-job traininge which is twice the amount required by procedure.
| |
| During the second period, the alleger received documented training in 10 CFR 50, Appendix B, PGandE Specifications 8802 and 8807, and the following Quality Control Procedures:
| |
| 140Sd I
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| i 1
| |
| " Processing and Control of Deviations and Nonconfomances"
| |
| ['~QCP-3~
| |
| . QCP-5A "AWS D.1 Welding (Structural Steel)"
| |
| '- " Instr.11ation of Electrical Equipment"
| |
| , QCP-7 p- QCP-9 " Installation and Inspection of Stud and Shell Concrete Expansion Anchors"
| |
| , QCP-10 " Power Control and Signal Wires" QCP-10A " Installation of Coaxial and Triaxial Cables" QCP-11 " Cable and Wire Terminations" QCP-17 " Initiation of Work" HPF-El " Installation and Documentation of Non-Class I Systems ECO i '
| |
| E-162 and E-161" HPF-E2 " Installation and Documentation of Fire Alam, Cardox System, Deluge System and Smoke Detectors" f
| |
| 'hPF-E3 " Installation and Documentation of Non-Class I System ECO E-203" HPF-E4 " Installation and Documentation of Non-Class I System ECO E-194" Therefore, the a11eger received adequate training to perfom his duties and there is no basis to the allegation.
| |
| i i
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| l 1405d !
| |
| l
| |
| | |
| ......a.m................... . . . . . . . . . . . .
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| j . .. _.... .. _ .. _ . _ - . . . -- - - -
| |
| IV-1 _
| |
| It is alleged that:
| |
| * I believe that this is just more than sloppy mport writing and a full understanding of how bad the welds mally are can be attempted only after the data appropriate for PG4E's report is found for the period of time that the weld was made. It is true that F. W. 212 no longer exists because it has been mplaced but that leaves the seven other nozzle to pipe welds that were performed with the same WPS that the original F. W. 212 was welded to. (4/10/84 Lockert Aff. at 4-5.)
| |
| Each of the points raised in the summary on pages 1 and 2 and the i
| |
| 1 last of page 4 and top of page 5 of Mr. Lockert's affidavit have been l fully and completely responded to in PGandE letter DCL-84-195 dated May 29,1984. As was shown in great detail, none of Mr. Lockert's allegations has any merit.
| |
| Although the details are in the response referenced above, a brief sununary of the main points is set forth below.
| |
| There were no false statements made in 1977 regarding the steam generator feed water nozzles. The material in question was an ASME Section IX P128 material, not a P3 material. This is confinned by j ASE Section IX and Mr. Lockert's exhibits about the i
| |
| Californf a-authorized inspector. Mr. Lockert refuses to accept this fact.
| |
| 1658d P- -. .
| |
| t
| |
| ,; The permanent steam generator reheated. nozzle welds w
| |
| '. Specifically, FW 197 was preheated, as is docu charts. ,
| |
| mented on recording There were no QA program problems.
| |
| The reports required werv provided and documentation of these reports is contai referenced response. ne1 in the Mr. Lockert's detailed comments been fully addressed. nalyses report on have the failu The pt-evious response was full, ,complete and
| |
| ! presented all the relevant data.
| |
| including advance notice to the NRC and in all the steam generator feed water e s were nozzles to pi
| |
| . inspected internally (in fact, the feed water o p
| |
| permit access) and repaired as required.
| |
| pGandE's entire handling of the steam generator f eed water nozzle problem was proper, correct, and responsible regards both as engineering and quality assurance.
| |
| This began with the initial telephone notice to the NRC when the problem was revealed and continued until final closecut approximately a year later
| |
| /
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| 1658d
| |
| -2
| |
| | |
| ~
| |
| T . . - . . : .' ^ T ~~ ' "~ . . . . . _ _ . .
| |
| V-1 It is alleged that: ._
| |
| $ In the April 2 transcript on page 33, Mr. Shipley states "The supervisor treins the new employee, although new means 1 .. . new to Diablo and not new to the process. He trains that person on the job, carefully checking the first work that
| |
| ~ ~~
| |
| ne does." During the time I spent under Mr. Mangoba, the pipe Support Lene supervisor, I saw new people brought into the design group who were given other engineers' work to check before ever performing afty desfgn wont of their own.
| |
| Thf s was a result of 1) pressure to get the work done and
| |
| : 2) the new ud MHyle were slower as originators than the people who been on the job longer 3) by giving the new l personnel work to check instead of design, production was l
| |
| ' not effected. Employees still in Mr. Mangoba's trailer told me that this practice followed him in the March 1983 nove to the new unit 1 trailer. The trailer staff was comprised of a fifty-fifty split between new employees and old employees. As of that date none of the unit 1
| |
| ( calculations had been completed. (4/30/84 Stokes Aff.
| |
| l at 1. ) 1 Mr. Stokes questions the adequacy of the on-the-job training provided First, it should to pipe support engineers newly assigned to 0 PEG.
| |
| be reemphasized that, as Mr. Stokes has acknowledged, pipe support engineers possess specialized knowledge and experience which qualifies them to do their jobs. In general, minimum technical A thorough review of the indoctrination and training are necessary.
| |
| technical background of the engineers in the small bore pipe support group at the site shows that experienced, technically qualified engineers had been hired. Thus, there was no need for additional technical instruction regarding how to make small bore piping calculations other than on-the-job training normally provided to familiarize them with the project design criteria and project calculational methodology. Most of the engineers had worked on two l 1409d
| |
| [
| |
| | |
| ! or more other nuclear power projects, with mariy having worked on five
| |
| ]_ . or more plants. All have at least a BS in Engineering or equivalent, and their minimum professional experience is one year; the maximum professional experience is 14.5 years, and the average professional experience is greater than five years. Thus, these OPEG engineers did not need specific training in the technical methods of perfoming small bore calculations since they altwady had the technical
| |
| ; expertise to perform the calculations.
| |
| 1 The on-the-job training consists of an appropriate level of Project-specific indoctrination by a supervisor or others with project experience to familiarize new engineering personnel. This l training included identifying project standards, describing the work process and design criteria, and acquainting the new employee with i the organization and his responsibilities. A new design engineer, ;
| |
| i who worted in very close physical proximity to his associates, was given various assignments involving original design, reviewing, or checking. problems were frequently discussed with associates and supervisors, reference documents were readily available, and precedents existed as a result of prior design work.
| |
| In this context, the fact that newly assigned engineers might be given other engineers' work to check before actually originating a I
| |
| calculation themselves is entirely normal, appropriate and acceptable.
| |
| r 1409d l ,.._. - ___ _._-.__. _ __ .. _ ._ _ _ _ __ _ . __ . _ _ _ , _ _ __ , - ._.
| |
| | |
| g...__.__.... . . . . . . . . .
| |
| It is alleged that:
| |
| On page 35 Mr. Shipity continues by stating "I believe that
| |
| : Mr. Y' n's appmach to the problem would have been extremely conservative. I believe that the analyst's approach to the problem was a reasonable representation of the piping and support when taken together." I am aware of the problems which the INtc discovered in hanger gg-20 and I am sum that if the professors teaching in the e insering schoola were eclied on whether Mr. Yin or the person.wl am taking the most reasonable approach, the results would show that Mr. Yin's would be considered the most reasonable, as I sy self [ sic] do. (4/30/84 Stokes Aff, at 1.)
| |
| Mr. Stokes questions the masonableness of the simplified representation of a pipe support used in the analytical model of the support for qualification, and he speculates that the more precise model advocated by himself and Mr. Yin would be prefermd in a poll of engineering professors. pGandE's point in the cited transcript i
| |
| passage is that the level of detail used in the simplified modeling l
| |
| representation is entirely adequate to demonstrate support l qualification, given the relatively conservative nature of the support design and small magnitude of the loads involved. While levels of modeling sophistication even more precise than those advocated by Mr. Stokes do exist and could be undertaken, the fact remains that the simplified a'nd conservative model used does lead to l support qualification and is fully acceptable.
| |
| , 1411d/ !
| |
| | |
| 1 ;
| |
| ?
| |
| V-3 l
| |
| It is alleged that:
| |
| Mr. Kahler en page 65 testiffed that "In their
| |
| - investigations, they identified that in 0 PEG group, them !
| |
| were sixty three manuals containing one hundred and thirty
| |
| ; . three criteria documents, four hundred and twelve procedures, and fifty one instructions were review [sfc] -- l to give you an idea of the scope that was done for this '
| |
| particular issue. The results of that review showed that J
| |
| ninety percent of the documents were - that were under
| |
| ' control, were properly and correctly in place. In no cases, did they find og out of date criterf a." Note the l 4
| |
| words used by Mr. Kahler following the second pause "that were under control". Was this an attempt to avoid making a '
| |
| false statement? Even though no statement was made as to whether av rovfew was made of the documents of personnel who were not assigned control documents to see if they i possessed old out-of-date control documents, evidently Mr. Kahler was aware that out-of-date documents did and probably still do exf st in the employees' control and use.
| |
| (4/30/84 Stokes Aff. at 2.)
| |
| Mr. Kahler's transcribed remarks concerning the results of the mytew of the 63 controlled manuals assigned to 0 PEG engineers clearly do not apply to any uncontrolled copies of procedures or instructions which Mr. Stokes feels may have been in the possession of OPEG !
| |
| l l engineers. The use of such uncontrolled documents was not authorized. While it cannot be stated with certainty that no such <
| |
| unauthorized material existed, the engineers were inst.m'cted to use only current and properly controlled procedures, instructions, and criteria.
| |
| {
| |
| t i
| |
| i J
| |
| q 9
| |
| i 1412d/ !
| |
| | |
| i
| |
| . . .' . ~ ~ ~ ~ ~
| |
| V-4 V-5 and V-4 l It is alleged that: _, ;
| |
| l On page 46 Mr. Kahler states that " engineers would receive a precedure, sign off that he had received it". This :
| |
| statement is either misleading or false depending on how Mr. Kahler used the word engineers. During my employment and as one of the few to have controlled documents I received any revisions and was asked to sign only once for receiving them. In using the term en indicating management and the clerks?gineers I know it didn'twas he i apply to the casuals er job shoppers. (4/30/84StokesAff.
| |
| at2.)
| |
| * Mr. Oman continues with this ridiculous assertion on page !
| |
| 49 and I quote "and the control and distribution of those :
| |
| procedures was managed by the project administration group, ,
| |
| using a system of signed returned mceipts." The only way this statement can be true during tne time I was in OptG is that the pro themselves. ject I amadministration assuming thatgroup signedseeinistration the project the receipts includes management and clerks. (4/30/84 Stokes Aff.
| |
| , On page 72 Mr. Oman states "there was always a return i receipt system with distribution of instructions." The only return receipt I saw was when I received my first documents, never later. (4/30/84 Stokes Aff. at 2-3.) l
| |
| , Mr. Stokes' allegations question the existence of a m turn-receipt system for distribution of piping discipline procedures, i instructions, and criteria at OptG. Such a system does, in fact,
| |
| ) exist on the project and is evidenced by Mr. Stokes' own statement I that he signed a receipt for his original controlled manual
| |
| (
| |
| assignment. During the period Mr. Stokes was assigned to OPEG, the Administration Gmup at OptG die sign the receipts for procedure
| |
| (
| |
| I i 1415d/ t
| |
| | |
| revision distributtons, return them to San Francisco Home Office (SFH0) Project Administration Group, and distribute them to the appropriate manual holders within OPEG. This was done in an attempt
| |
| ~
| |
| to more closely monitor revision distributions and timely receipt acknowledgments. Project records indicate that Mr. Stokes was assigned a controlled manual of piping procedures and instructions in February 1983, and by his own admission he did receive revisions to these procedums.
| |
| l f
| |
| 1415d/
| |
| .1.
| |
| V-7 It is alleged that: _. ._
| |
| Mr. Kahler again states on page 73 that "The requirement is
| |
| .:. that if an engineer wishes to keep an outdated procedure in his manual, he is required to mark it as a superseded pro:edure, clearly mark it as superseded." I was never Instructed either orally or in writing that if I wished to keep the old procedures that I should write superseded on them. (4/30/84 Stokes Aff. at 3.)
| |
| The practice of maintaining outdated procedures, particularly in the same binder with current procedum revisions, is discouraged because of the obvious potential confusion that can result. Engineering Manual Procedure 5.1 states that obsolete pages may be kept for reference if each page is marked in a manner which clearly indicates that it is superseded.
| |
| r O
| |
| 1559d [ _
| |
| | |
| V-8, V-g and V-10 It is alleged that:
| |
| , On page 73 everyone attempts to get into the action when
| |
| ; Mr. Vollmer asks "How often are the supervisors supposed to review their employees manuals for current status?" Mr.
| |
| Oman answers "I believe the procedure either specifically ,
| |
| states which I believe it does that it's a monthly l requirement, that the supervisor review the manuals of the l engineers under his supniston on a monthly basis." Then i Mr. Trosler says that I just spoke with Myron Leppke and he infomed me that the procedure had been to perfom this periodic basis,". review sic) (top on aofmonthly page 74) (basis. Recently During g it was changed to a involvement with OPEG I never saw nor was othemise made aware that w supervisors perfomed this inspection. !
| |
| (4/30/84 Stokes Aff. at 3.) l Mr. Tresler continues to be mistaken on page 74 about :
| |
| whether this review is documented. "I'm sorry, it is documented." "It's documented as a re , those @
| |
| individuals assigned to monitor 0 PEG." Mr.port Vo by @llmer says "It's an audit function of theirs?" Tresler "Yes" "No, I s4y it is documented, it is documented in an audited report." Then following a pause "I'm sorry. As a clarification, this is Mike Tresler again. Apparently, the audits being perfomed by the supervisors are not i documented but there are audits perfomed by the @
| |
| organization within OPEG to verify that the audits being the supervisors are effective." Mr. Tresler performedb{tgiveup.
| |
| still doesn When asked by Mr. Vollmer "so, how do they audit an activity that's not documented?" Tresler says "they audit the manuals to verify that the supervisors' reviews are effective." To g knowledge this review was never documented nor conducted by w supervisors ,
| |
| nor was av audit ever performed on g documents to see if '
| |
| they were up to date and even if they were in order that i
| |
| ! finding would not prove that the supervisor was perfoming '
| |
| i this review. (4/30/M Stokes Aff, at 3-4.)
| |
| The practice of regular periodic audits of piping procedure and instruction manuals by supervisors is a current procedural
| |
| . requirement at OPEG. This fact is clarified on page 75 of the transcript by Mr. Tresler who further noted that, in the past, audits !
| |
| ! 1417d -
| |
| 1 e- -, .---... - - .~ - , _ _ , , , ,__e-_. ,-.--er,.-m, ._..,,m,
| |
| | |
| wem perfonned but not on a fixed frequency. The need to improve the maintenance of controlled procedure manuals was recognized and !
| |
| . documented in PGandE letter DCL-84-046, dated February 7,1984. On
| |
| ~
| |
| page 41 of that letter it is noted that " Procedure P-1 was revised in 1
| |
| Rev. 4 dated January 20, 1984, to require a monthly supervisory review of all controlled manuals to assure that orocedures.
| |
| 4 l
| |
| instructions, and criteria are kept current." In the transcript (pages 73-74), Mr. Tresler clarified a more recent change to the :
| |
| procedure which requires such reviews on a periodic basis with the ;
| |
| ; intent that reviews be perfonned at whatever frequency is necessary i
| |
| to ensure adequate control exists. It may be more frequent than monthly. These revisions to Procedure P-1 were not in effect during the period of Mr. Stokes' employment at Diablo Canyon, which would 1
| |
| account for his lack of familiarity with them. As previously pointed out, none of the calculational errors found in the support calculation packages were related to document control.
| |
| I 1417d !
| |
| I_ _ . _ __ _ ____ _ _ _ _ _ . _ _ _ _ . . _._-
| |
| | |
| l i
| |
| l !
| |
| L V-11 .
| |
| ; It 16 alleged that: ;
| |
| I find the statements made on page 84 by Mr. Kahler that 4 >. "In our reviews, we concluded that there was no effect on i the design process." and was followed by Mr. A111sgn that ,
| |
| "Not only on the product but on the process." (sicJ to be
| |
| ~
| |
| . ridiculous. This is in light of the following facts 1l that p64E has admitted that they have found that approximately 745 of the small bore calculations have what i I they consider minor problems and an additional 225 which !
| |
| ! required completely redoing in order to be confident of the ;
| |
| 1 initial work 2 ;
| |
| welding pmblems) that 1since on units I submitted 4 2 PGM /BECHTELsy DRissued have on generic :
| |
| scores of memorandums and made procedure changes in an {
| |
| attempt to clear up many questions ranging from the design '
| |
| 3 group to the field construction personnel, 3) PG4E has !
| |
| spent the last several months trying to explain away sy ;
| |
| allegations of 04 problems, destruction of doch.eents '
| |
| ' technical deficiencies in the calculations (such as ,
| |
| omission of eccentricies [ sic), secondary stresses from -
| |
| , torsion, anchor bolt spacing requirements per the i manufacturer and M-g tw Pipe Support Design Manual issued j hy PGE, and the failure to limit structural angle members 1ength per AISC Sect. 1.5.1.4.46 the use of gaps to reduce i themel loads to supports, the pIacement of snubbers rigids and anchors close to other supports, and others) which were substantiated by Mr. Yin and many remain unresolved. ;
| |
| ; (4/30/84 Stokes Aff. at 4.) l i Mr. Kahler's.cannents in the cited transcript passage are taken out i of context by Mr. Stokes. Mr. Kahler is simply stating that as a result of the Project's mytow, there was no apparent effect on the ,
| |
| j small bore design process or the final design product resulting from problans related to out-of-date procedures at 0 PEG. Mr. Stokes has .
| |
| l extrapolated from this conclusion referring solely to 0 PEG work, to design work by other design groups as well as to construction. l I
| |
| Clearly, the cited transcript passage by Mr. Kahler is not intended, i nor does it in fact, have such a broad applicability.
| |
| 1420d/ ,
| |
| | |
| .ea V-12 -
| |
| It is alleged that: .
| |
| ' i' Mr. Meno11 asks a pertinent ystion about the Diable
| |
| : Problem (DP) program on page 33 "Did ary of these DP's have
| |
| .: dispositions on generic bases that effect (sic) other l
| |
| - packages or more generic implications that you really need i to document it so that ou can handle it in all applicable l cases, not just on a si le case." Which is answered by i Mr. Tresler "No." Each was specific to a discipline and j was not a plant generic issue or concern". During the time [
| |
| I was employed at the site I know management suppressed l the use of Desi ,
| |
| Reports (DR'5) gnNon-Conformance and Change Notices (DCN's)
| |
| Reports Discrepancy (NCR's). DP's !
| |
| were used to report problems on specific hangers, problems about a list of hangers and frequently generic both units 1 & 2. (4/36/84StokesAff.at4-5.)problemson t r
| |
| l Mr. Stokes' understanding that Diablo Problems (DPs) were used to I report generic problems is incorrect. ops were used to document j guestions by Construction to Engineering. The answering of a DP did not authorize Constrwetion to deviate from the established design.
| |
| Only the issuance of a design change notice (DCN) in accordance with
| |
| . approved procedures could authorize such a deviation from the original design. In fact, DPs were used to document specific items i 'within a particular discipline.
| |
| i -
| |
| i 1 Mr. Stokes' claim that management suppressed the use of DCNs, DRs, j and NCRs is incorrect and is not supported by any facts. l l
| |
| . l t
| |
| 6 I
| |
| 4 1560d . I 1
| |
| l
| |
| | |
| 1 l
| |
| l c._ . - t_ :
| |
| V-13 .
| |
| It is alleged that: j On pase g5 Mr. Shiple in explaining the lack of a !
| |
| grocedure en the use of p ps the lack of a procedure en !
| |
| developing a 'RL over R criteria, buckling, the engineer i must determine what that end condition is and apply the !
| |
| appropriate factor in order to arrive at the proper !
| |
| result. It's a well-known engineering technique and it is :
| |
| not considered necessary to instruct the engineer precisely '
| |
| in each and every case which one he should use." He closes en page g5 with 'we believe that a specific procedure is not required because it's cannon engineering practice." I have worted as a structural engineer for the past g years j en many nuclear projects and even though these principles '
| |
| are taught in colleges, they are the most incorrectly used. They may be calculated close to correct on simple !
| |
| structures, but on complicated pipe supports when time is !
| |
| Ifmited by the demand for quantity rather than quality !
| |
| almost no one perfories these types of detailed analysis or :
| |
| get (sic] them right if the (sic] do attempt them. '
| |
| rrocedures are needed to refresh memories and provide consistency in application. (4/30/84StodosAff.at5.) ;
| |
| In this allegation, Mr. Stokes apparently holds the view that the application of certain basic engineering principles must be closely !
| |
| contro11ed by detailed procedures in order to prevent esperienced, i I
| |
| educated engineers, who are involved daily in a fundamentally repetitive design process, from forgetting how to properly apply j i
| |
| these basic principles. We believe this is too harsh a view by ;
| |
| Mr. Stokes of his own capahtlities as well as those of his peers.
| |
| i The project's practice of ..et requiring a specific procedure for l well-known engineering t.echniques and common engineering practices is l consistent with noma) industry practice, and is considered to be !
| |
| 1
| |
| ; entirely appropriate for this type of engineering work.
| |
| l !
| |
| l I !
| |
| l 1641d =1- ['
| |
| t t
| |
| | |
| V-14 It is alleged that: ;
| |
| Mr. Soffell follows up on page 102 with *1's wonderine I
| |
| whom cases of gaps and/or jefnt releases, that 1s tM l exceptions, am flagged so that the checker is kind of, so ;
| |
| ! to speak being asked, do you agree with what I've done i i
| |
| here.' his is responded to by Mr. Shipley "0kay. So l there's a pfece of paper that says, hey, I did this. In .
| |
| the computer model you would sea a gap in the actual input i to the analysis, in the output and se forth." The answer ;
| |
| is NO, the exceptfons are not flagged. The only M you would be able to find them is to know of their use isy method) or perfom an in depth review of each analysis package. (4/30/ M Stokes Aff, at 5-6.)
| |
| ; The question being asked in the cited transcript passage concerns how clearly the specific use of themel gaps or joint releases is l
| |
| ! documen6ed in a support calculation such that the calculatton checker would note their use. Mr. Shipley's response states that use of these techniques would be apparent in the support computer model input and output. The point befag made is ' that an engineer
| |
| {
| |
| sufficiently competent to check the calculation could clearly ascertain that these techntquos wem used. Mr. Stokes contends that I this could only be found by an in-depth mytow of the analysis package. That is precisely what the checker of a calculation does in I
| |
| 3 the process of his work.
| |
| l 13g1d 1-L
| |
| | |
| l 1
| |
| v-is .
| |
| It is alleged that:
| |
| ,. Mr. Shipley again on page 112 misleads everyone with "It
| |
| ; was a very we.1-contro11ed program". Careful review of 1 7 specific information supplied by Mr. Tateosean [ sic]
| |
| demonstrates that Mr. Shipley's conclusion was false. It l
| |
| ~
| |
| was not a "very well controlled program". Mr. Tateosean l
| |
| [ sic] states on page 113 "Or, cited interferences, I've gone l back and talked to the stress engineer who was on the walkdown". What criteria was [ sic] established and followed to distinguish cited interferences from those ,
| |
| which weren't cited as interferences? With only 10 people '
| |
| who performed the stress walkdown, why didn't Mr. Tateosean
| |
| [sicJ question them all, and not just the stress engineers? He also states "other interferences on these lines, but in his judgment, what he saw here was really interferences that weren't interferences because the -- it was such a slight interfemnce." Was this program conducted on intuition as was [ sic] the design calculations Mr. Shipley speaks of on page 1477 What was the criteria which each member could apply to decide consistently what l was an interference? (4/30/84 Stokes Aff. at 6.)
| |
| Contrary to Mr. Stokes' allegation, the stress walkdown program was in fact a very well controlled program for the purpose for which it was intended. Mr. Stokes was not involved in implementing this program andlapparently does not understand its purpose. On page 109 of the transcr:fpt',-Mr. Shipley, in readir.g from the applicable
| |
| ~
| |
| procedure, clearly, states tnat the purpose of the stress walkdown j effort "is to. reifew the installed condition of large bore Class 1 piping and confim that they satisfy the design calculations. Since confirmation of the dimensions given in the piping isometric or piping support drawing are within the scope of the as-builting ,
| |
| -programiimo detailed measurements are required as part of the walkdd. effort." The subject being discussed at this point in the
| |
| \
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| 4
| |
| 'N
| |
| | |
| transcript involved Mr. Yin's inspection report observation that the stress walkdown procedures were inadequate because they didn't 1 l
| |
| . address some of the information and documentation that are required ;
| |
| # by USNRC IE Bulletin 79-14. It is emphasized on page 109 of the transcript that "the stress walkdown program was never conceived to be arty part of the 79-14 Bulletin requirement, it was not designed to measure things," and "the specific walkdown under consideration was
| |
| , developed on this project to identify potential interferences before plant heatup commenced, and that was its only requirement." On transcript page 110, it is further emphasized that there is no NRC requirement or Project coenitment to do stress walkdowns, and the task was undertaken simply as an additional measure to minimize potential interference problems during initial plant heatup.
| |
| l l The identification of potential interferences was based upon the 1
| |
| engineering judgment of the walkdown team members who were experienced' stress and pipe support engineers. They documented their observations when, in their judgment, the observed potential interferences might jeopardize the validity of the applicable design calculation. They were not required by procedure and, in fact, did l not document any observations which did not meet that standard. The l
| |
| [ overall quality and success of the implementation of the stress walkdown program has now been confirmed by the relatively trouble free initial plant heatup sequence, which was completed in April 1984, and the low power testing program, which was completed in May 1984.
| |
| 1421d/
| |
| V-16 It is alleged that: _ i Mr. Tateosean [ sic] says on page 113 " Typically you had an inch and a half or so of insulation, and we're talking about calcium silicate insulation and it has the abil< ty to
| |
| - ~ ' crush that much or more." Had Mr. Tateosean's [ sic] stress walkdown been provided criteria such as that provided in the FIELD ENGINEER P0CKET HANGER REFERENCE which 8ECHTEL went to the trouble and expense to write and then changed their mind about issuing, even the crushing of calcium _
| |
| silicate insulation would have become important. I would like to quote from BECHTEL's proposed FIELD ENGINEER P0CXET MANGER REFERENCE on pages 1-10 and 1-11 under " NOTES: PIPE INSL'LATION CHART".
| |
| Forth [ sic] paragra >h, "Most insulation failures are caused by water entering tirough breaks in the finish, such as expansion crack, or un-flashed openings, therefore, particular attention should be given to complete detailed specifications in mgard to weatherproofing."
| |
| From paragraph 5. "The usual insulating materials and jackets for heated piping and equipment allow the moisture to escape in the fom of vapor. However in-the medium temperature range, and where shut-downs are frequent, moisture in the insulation is not driven off and water damage is most likely to occur. For these conditiuns, the insulation should be thoroughly dry before applying the jacket, the surface of the pipe should be primed and painted and corrosion-restraint [ sic] wire er bands used for secu,rin' g the insulation. If possible, insulation should be applied to high temperature piping while heated ;
| |
| to insure the complete dryness of the completed installation."
| |
| l From paragraph 6. "The layout of insulated piping and equipment should provide adequate clearances for proper application of the insulation and also safeguard against mechanical damage during nomal operation and maintenance." (4/30/84 Stokes Aff. at 6-7.)
| |
| 1424d i 1
| |
| | |
| ~"
| |
| The response to 'this allegation is contained in the response to NRC #484 in PGandE letter DCL-84-195, dated My 29,1984, page 158, paragraph 330. As stated therein: l
| |
| : 1. Pages 1-10 and 1-11 contain general information concerning piping insulation, which is nonspecifc in nature, presents commonly used practices, and identifies factors which can be considered in selection and application of insulation...
| |
| The reference to safeguarding against mechanical damage to insulation during construction and maintenance can hardly be construed to apply to the very minor, localized crushing of calcium silicate insulation credited for resolving certain stress walkdown findings. The small number of cases identified where this occurs has been analyzed by Engineering and found to be acceptable. The booklet accurately reflects the geraral policy in effect on i this Project with the exceptions noted.
| |
| Identification of these items as technical concerns reflects a lack of understanding on the part of Mr. Stokes of acceptable insulation application practices.
| |
| 1424d - - . . . _ . - - - - - - _ . . - . - - . - - - .
| |
| | |
| ~
| |
| = -
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| _=.-- .-
| |
| V-17 It is alleged that:
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| 1 In his discussion of the Quick Fix program on pa Oman says, "they would, on a case by case basis,ge make128 a Mr.
| |
| judgment based on their knowledge of M-9 which is the guide lines for design of Class 1 pipe supports and restraints for the project, the design criteria for pipe supports.
| |
| They would make a judgment on a case by case basis whether an expanded tolerance, a deviation beyond that specifically allowed by ESD 223 could be made while still maintaining an acceptable suppo,rt design." I personally know that some of the Quick Fix engineers were hired and placed in the group without ever perfonsing any calculations or spending any time learning what was in M-9 or ESD 223 nor were they l given a copy of Instruction 12 which supposedly defines the
| |
| ! res l Mr.ponsibilities Oman's statement and authorities of the is misleading in Quick that heFix group.
| |
| implies the engineers have knowledge of the documents mentioned above.
| |
| Can we expect Mr. Oman to supply us with the negative elements as well as the positive without a specific question on point? Would the fact that the QF engineers were not trained in the performance of their assigned tasks bear on the quality of their work? Mr. Yin was not aware ,
| |
| that some of the QF engineers had never. worked in any '
| |
| sspect of the review prograu on Diablo Canyon before becoming/30/84 him. (4 Stokes Aff. at 7-8.) Quick Fix engineers, until I pointed th l
| |
| This allegation is essentially identical to allegation JIR-11, responded to in PGandE letter DCL-84-239, dated June 26, 1984.
| |
| I Several practical points should be recognized regarding the subject of this allegation. .
| |
| : 1. Pipe support engineers employed at OPEG, including PSDTC engfreers, were technically qualified and expe'rienced.
| |
| : 2. Most nuclear power plant construction projects utilize some fom of program similar in many ways to the PSDTC program, which l
| |
| l 1480d !
| |
| | |
| i I
| |
| I
| |
| - . . . . .. . 1 relies on engireering judgment to develop field modifications of l pipe support designs to facilitate their installation. Such
| |
| . programs utilize various forms of official, documented approval at a later date, as does the Diablo Canyon Project through its
| |
| ~
| |
| "as-built" acceptance program. This type of program is certainly not unique to Diablo Canyon and was familiar to most of the PSDTC engineers.
| |
| : 3. Diablo Canyon Pipe Support Jesign Criteria M-9 is not fundamentally different from the corresponding criteria used by other projects where OPEG engineers had gained their prior experience. It does not represent a radical departure from criteria with which they were already fant11ar. As a practical matter, an experienced engineer would not require e'xtensive
| |
| 't study to gain a working familiarity with M-9.
| |
| : 4. PSDTC engineers did not perfom calculations to verify their judpents, but rather, relied on their experience to detemine the acceptability of proposed changes to support designs. The validity of such judgments by experienced engineers would not be expected to vary widely from one project to another due to differences in design criteria. Simply stated, an experienced pipe support engineer has a good understanding and " feel" for an adequate support design, particularly when making adjustments to an existing design which is known to be adequate.
| |
| 1480d '
| |
| | |
| l l
| |
| : 5. The vast majority of engineers who were ever assigned to the
| |
| _ PSDTC group wem alrea@ fant11ar with M-9 at the time of their
| |
| # assignment by virtue of prior experience in pipe support work !
| |
| I involving its use. The few exceptions gained experience with l
| |
| M-9 while working with other members of the PSDTC group. These :
| |
| few exceptions do not invalidate the program as Mr. Stokes would suggest.
| |
| : 6. Not every PSDTC team member was assigned his own copy of M-9.
| |
| Practically speaking, an engineer worting within the plant did not carry a copy of M-9 around with him. Copies of M-9 were available in the PSDTC group's in-plant office area in the turbine building which afforded rea# reference access in a centralized location.
| |
| : 7. As discussed in numerous prior submittals, the judgments made by PSDTC engineers were never the final qualification for the pipe
| |
| ; support. In all cases, the PSDTCs were included in the as-built drawing of the support and the as-built drawing was subsequently reviewed, checked, and approved under the formal engineering process. The as-built acceptance process involved review of the revised support design and performance of necessary calculations for qualification of the design. Where qualification could not be shown, a new design was issued for construction. This comprehensive process of review and acceptance of changes made 1480d . ._ .__. __--, - . . . - . - _ - _ _ - . _ _ _ . _ --.__- - - - -. . - .
| |
| | |
| l i
| |
| by PSDTCs as a part of the as-built acceptance program has been corroborated by recent NRC staff audits.
| |
| w e
| |
| l 1480d l l
| |
| | |
| V-18
| |
| , It is alleged that: __
| |
| ~
| |
| . Mr. Oman states on page 127 "Also, those modifications 2 . .. . which -- or those hangers which a preexisting condition was
| |
| . detemined to be unacceptable were not handled under this program. They were documented by discrepancy reports
| |
| =~ within Pullman Piping Contractor and General Construction." During the time I was in Quick Fix, almost
| |
| , none of the existing problems were written up on
| |
| ! discrepancy reports. This was because I was the only QF engineer to have controlled documents for most of the program and I was the only QF engineer (to av knowledge) to have a copy of a amorandum which was written to clear up cuestions involving the operation of the program. This cocument states that a DR had to be issued against existing supports before I could issue a Quick Fix (QF) resolving the problem. Often when I demanded a DR the field engineer for Pullman would walk awaty saying he had been instructed to get it resolved without having a DR issued. In discussions with the QF engineers on different shifts, I found that another Pullman engineer on their shift had gotten a QF from them without a DR being issued.
| |
| He continues on the bottom of 127 to state "Upon completion of construction of that support, the as-built package, the entire as-built package nf that support, was included in the original design and any subsequent tolerance clarifications were all incorporated into one as-built package which was returned to er.gineering for acceptance of the final as-built condition in accordance with project
| |
| ! procedures." In discussions with the unit 1 personnel, I was told that they never saw any QF's when approving an as-built, only the as-built drawing. I was told that hardly any one [ sic] reviewed these in any detail; they just rubber stamped them OK. (4/30/84 Stokes Aff, at 8-9.)
| |
| The contents of this allegation are included in Allegations JIR-12 through JIR-15 of Exhibit 6 to Joint Intervenors' June 11, 1984, Reply to PGandE and NRC Staff Answers to Joint Intervenors' Motions to Reopen Design and Construction Quality Assurance, and Allegation III-63 of March 21, 1984, Anonymous Affidavit, Attachment 9 to {{letter dated|date=March 23, 1984|text=March 23, 1984, letter}} to the NRC, from the 1491d l
| |
| )
| |
| | |
| l
| |
| ~
| |
| Government Accountability Project. The PSDTC program is described in its entirety in Applicant's responses to those allegations.
| |
| The first part of the allegation was addressed in PGandE's response to JIR-13. As there stated, the actual memorandum that was released did not assign any responsibility to the PSDTC engineers to ensure that a contractor quality document (DR or DCN) was issued. Mr.
| |
| Oman's statement is correct.
| |
| Regardless of whether DCNs or DRs were written, all installations as modified under the PSDTC program were verified to ensure that design and licensing criteria were satisfied, thus ensuring no defect. The PSDTC was never the final design qualification for a pipe support modification. All modifications authorized by the PSDTC were formally reviewed and approved by Engineering, using controlled procedures as part of the as-built acceptance program. Consequently, there are nd undocumented and unreviewed conditions involving pipe supports which were created as a result of the PSDTC program.
| |
| l Regarding the second part of the allegation, as pointed out in applicant's response to Allegation III-63, the engineer who reviewed and approved a small bore modification did not receive a PSDTC with
| |
| ; the as-built drawing. 0*EG engineers only received the final as-built drawing with the P;DTC modifications incorporated in the drawing for use when perfoming the as-built verification.
| |
| 1491d ;
| |
| | |
| V-19 It is alleged that:
| |
| On page 129 Mr. Oman states "the fact that every tolerance
| |
| -- clarification is included in the as-bult package and is 7 reviewed as part of the final hanger acceptance, leads to
| |
| . the conclusion that particular finding would not af fect the final qualification of the supports." See comments paragraph above.
| |
| Mr. Shipley states on page 145, "I'm actually reading from the February 7th submittal that acceptable with minor supplemental calculations or coments, is 78 percent.
| |
| Acceptable with detailed calculations, which means that there was something found that the reviewer felt that without additional work, he was not able to justify it on
| |
| : the basis of the original calculation alone -- that was 17
| |
| [ illegible or deleted]. And, unacceptable is zero. -
| |
| That was at the time of this dociment. At that time there were six supports that had yet to be completed. They have since been completed and they are also acceptable. So, that would bring the 17 to 22 percent, today."
| |
| 4 I would like to point that all through the April 2 transcript the -17 percent figure has been used without any correction being proffered by PG4E/BECHTEL. The first I believe is on page 42 when Mr. Yin and Mr. Shipley used it, the second was the quote above, the third is on page 156 when it was used by Mr. Faulkenburg and Mr. Shipley again, and the forth is on page 160 when it was used by Mr. Taylor
| |
| ; and Mr. Shipley again. I am sure there are other locations where the 17 percent is used without a correction when the number should be 22 percent. Maybe I expect too much i
| |
| l voluntary infomation but 22 seems more significant than i 17. (4/30/84 Stokes Aff. at 9-10.)
| |
| l Ironically, the references to 17 percent rather than 22 percent, of the calculations reviewed having been demonstrated to be acceptable with additional detailed calculations, were made primarily to avoid l confusion by maintaining consistency with the statistics previously submitted in the PGandE letter being quoted. Contrary to Mr. Stokes' l
| |
| 1567d _ ._ _ _ . _ _ ..-_ _ _ -___ _ -___.. _ _ -. _ _ _ . _ _ __ _ . _ _ _ _ _
| |
| | |
| . -- __ ~_ . _ _ . . . . . . _ . _ _ . .
| |
| View. the significant point being made is not 17 or 22 percent, but rather that qualification to ifcensing requirements has been demonstrated for all supports reviewed.
| |
| 0 l
| |
| 15674 - 2-
| |
| | |
| )
| |
| :. 22: - .._ .. . - - .:.:. . - . . . . . .
| |
| V-20 .
| |
| It is alleged that: :
| |
| I Mr. Vollmer on page 147 asks "what sort of instructions are ;
| |
| the checkers given, who perfons that evaluation." Mr.
| |
| 1-- Shipley replies on page 147 that "there is an intuitive i
| |
| ability of the designer, an ex understand small bore piping."perienced This point is designer, followed to up on by Mr. Manoli on page 154 with this comment: "So, it leaves. I think a hole here, where a person can just mJe judgments and thinks that the support is adequate." I would like to add that we were asted by group leaders to use our judgments on all most [ sic] everything in the design. The worst use of this was when we all followed i
| |
| management's directive to take for granted that the supports as installed were installed under a valid Quality Assurance (QA) program. This I discovered was far from the truth. How much credibility can be given a reverification program which was based on intuition? There wem so many assumptions which had no tmth or basis which were never questioned in the review program that I can not [ sic] see Sow anyone living in the vicinity of the plant can be safe with Diablo operating. The omission of information supplied by PG4E/BECHTEL similar to that supplied by me above,84 (4/30/ Stokes Aff at 10.)I feel is relevant for the companies credibility.
| |
| Mr. Stokes uses unconnected quotes from different parts of the l
| |
| transcript completely out of context in order to conclude that the l
| |
| verification program was based on intuition. This is a distortion of the cited transcr ..t passages which, when mad in their entirety, clearly relate only to the level of detail achieved in the checking of small bore pip support calculations. The point being made is as stated in PGandE letter 00i.-84-046, dated February 7,1984:
| |
| Both the originator and reviewing engineer focused on the parameters of primary importance to the adequacy of the support. Although satisfactory for criterion and safety considerations, the level of rigor associated with these supports was different from that l
| |
| i 1568d I
| |
| i achieved in other parts of the plant. In general, this variation in rigor is clear to those familiar with design practices in power plant and industrial
| |
| - plant facilities throughout the country. More
| |
| - importantly, the rigor of design documentation varies
| |
| : according to (1) the importance of the system, (2) the 2 degree to which the system design my be challenged (large loads vs. small loads), and (3) the conservatism which exists in the design.
| |
| The level of rigor of the small bore design documentation was technically consistent with the number of supports and the conservatism and structural redundancy inherent in the designs; however, compliance with quality program documentation was less than fully achieved in some instances.
| |
| Mr. Stokes notes that "we were asked by group leaders to use our judgments on all most [ sic] everything in the design." His reluctance to use his judgment is unusual, since engineering judgment is a principal attribute of a qualified engineer. Mr. Stokes' remarks about supports not. installed under a valid QA prograra are incorrwet and simply not supported by the facts.
| |
| l 1568d ,
| |
| i - . . . . ~ . . . - - - . . - - _ . . . , . . . _ . . . - - - - - . - .-. - ,.___ ,___.- ,,____.___ ___ .--.- _ . . . . , . _ - , - _
| |
| | |
| V-21 It is alleged that:
| |
| . On page 157 Mr. Tresler says "The judgments were used more in the small bore that [ sic] it was in the large bore.
| |
| 4 And I think that Larry is trying to point out also that this is industry practice. Is that correct?" Mr. Shipley replies "Yes". It is my experience that Diablo Canyon if it is industry practice to be at the lowest end of the scale and had I worked on any plant that I believed to be as unsafe as Diablo then I would never have gotten to work on Diablo for I would have become a WHISTLEBLOWER on that plant. (4/30/84 Stokes Aff, at 10-11.)
| |
| Mr. Stokes apparently takes issue with the statement that, as an industry practice, engineering judgment is used more in small bore pipe support design than it is in large bore pipe support design.
| |
| The statement is well founded in actual industry practice. Mr.
| |
| Stokes also voices his personal views on the relative safety of the
| |
| ~
| |
| Diablo Canyon plant compared to other facilities. Mr. Stokes' opinions represent a personal view based on very limited knowledge i
| |
| and perspective.
| |
| 1427d - . _ ,
| |
| | |
| V-22 - - - -
| |
| It is alleged that:
| |
| ~
| |
| Mr. Tresler makes the statement on page 171 that "There was
| |
| . a very short period of time where tw vehicle of phone
| |
| : 2. . . . . calls were [ sic] used in lieu of the normal process," and he continues on page 172 with "I don't know -- a month or
| |
| ~~
| |
| so, the work was expedited by use of the phone call, and the intent was that those calculations would not be finalized until the written information came through." I was on site from Nov. 8,1982 until Oct. 14,1983 and during this time the phone was consistently used to obtain necessary design information and almost none of the engineers documented these calls since no phone memorandum forms were available. Only a few of us indicated in the calculation that it was preliminary and that a written reply was necessary. (4/30/84 Stokes Aff at 11.)
| |
| The transcript passage cited in this allegation involves a discussion of those small bore pipe support design loads which were calculated l in the SFHO, transmitted by telephone on a preliminary basis, and later documented by a formal transmittal. As stated by Mr. Tresler in the transcript, this practice was used for a limited period of time (approximately one month) to expedite completion of the small bore support design calculations. Before and after that limited
| |
| ! period of time, the small bore support design loads which originated in SFHO were transmitted to OPEG only by transmittal of the corresponding piping stress analysis.
| |
| Mr. Stokes takes this limited discussion out of context and applies l
| |
| it to all telephone conversations with SFHO. Conversations with SFHO certainly did occur continually, not just for a one-month period.
| |
| 1569d i l a
| |
| | |
| )
| |
| However, these calls wers not to be used to document final design inputs for small bore pipe support calculations. . . . _
| |
| e 1569d
| |
| - 2-I l
| |
| i l
| |
| | |
| V-23
| |
| { It is alleged that:
| |
| . On page 175 Mr. Knight asks "0kay. So, for the record
| |
| . : .025 was the criterion?" and was answered by Mr. Shiple,y
| |
| '~
| |
| "Yes, sir." Mr. Knight asked again "And it was the only criterion that was employed?" and Mr. Shipley replied again "Yes". This is not true we also used .009 inch.
| |
| Both of these values wem supplied to us in M-9. The .025 value was for 20 hertz and .009 was for 33 hertz. (4/30/84 Stokes Aff. at 11.)
| |
| Mr. Stokes is confused about the Diablo Canyon criteria for allowable support deflection and associated natural frequency. The Project ifcensing commitments, and the basis for the Project criterion on this point, require limiting support deflections in the restrained direction to 0,025-inch which corresponds to a natural frequency of 20 hertz or greater. Compliance with this criterion will meet Project 1feensing commitments. As a ' matter of Project preference, in the design of any new Class I support or modification of any existing Class I support, efforts wem made to provide a design which resulted i in a naturai frequency of at least 33 hertz in the restrained direction, which corresponds to a static deflection of no more than 0.009-inch. This latter value was not a Project criterion required for compliance with licensing commitments, but was selected to provide additional conservatism for new support construction.
| |
| l l
| |
| 1551d .
| |
| . . . , , - ...,..,.m4_.,,_ ,,m. , . , . . . _ . , _ _ _ . , . . ,,_,._p, _ , , _ , , , , _ _ _ _ s-...._,_,,____.,,_,,,.._m.m,g_m, ,. _ , _ _ _ , , . . ..,. . -_[
| |
| | |
| - _ _ _ _ _ . - _ - _ _ _ _ _ _ _ _ _ - _ - _ _ = _ _ _ - . - -__. _ - _ _ _ _ _ - _ .
| |
| ~~
| |
| V-24 It is alleged that: _
| |
| Mr. Shipley on page 178 sus "The 20 hertz is -- is - is
| |
| . '. only a criteria. It clearly doesn't set a pass / fail
| |
| .- situation for the support ". As one of the criteria we wem designing to, the support failed if it did not meet this requirement. I wonder now after considering Mr.
| |
| Shiplays' statement if those supports which we failed due to insufficient stiffness wem later changed to passing?
| |
| (4/30/84 Stokes Aff. at 11.)
| |
| The minimum pipe support natural frequency value of 20 hertz referred to by Mr. Stokes in this allegation is a value established to simplify piping stress analysis by allowing the stress saalyst to assume that all supports meeting the 20 hertz criterion are rigid for purposes of stress analysis. This does not imply that a pipe support is automatically unacceptable if its natural frequency is less than 20 hertz. For such cases, the actual stiffness of the support can be used in the stress analysis to demonstrate piping qualification.
| |
| This is a somewhat more cumbersome but entirely acceptable method.
| |
| Supports do not " fail due to insufficient stiffness," as Mr. Stokes asserts, simply because their natural frequency is less than 20 hertz.
| |
| l I
| |
| 1558d - - - - . . . _ . . - . . . . - - , . . . - . . - -
| |
| | |
| ... .s. . . . . . . . . . . . . . . - . . . . . . .. . . . . . .
| |
| V-25 and V-26
| |
| --. It is alleged that.
| |
| I had intended to identify some examples of unacceptable wortmanship with respect to the following three codes and specifications:
| |
| : 1. Vendor welds not complyino with applicable AWS Code DI.1 Section 8.15 " Quality of Welds".
| |
| 8.15.1 Visual Inspection. All welds shall be visually inspected. A welG snaII be acceptable by visual inspection if it shows that
| |
| , 8.15.1.1 The weld has no cracks.
| |
| 8.15.1. 2 . . . . .
| |
| 8.15.1.3 All craters are filled to the full cross section of the weld.
| |
| 8.15.1.4 Weld profiles are in accordance with 3.6 8.15.1.5 Irrespective of length, undertut shall not exceed the value shown in Fig. 8.15.1.5 for the primary stress direction category applicable to the area containing the undercut. Further, the undercut may be twice the value pemitted by Fig. 8.15.1.5 (for the aplicable stress category) for an accumulated lengh [ sic] of 2 in, in arty 12 in. (51 nei in 305 inn) length of weld, but in no case may undercut on one side be greater than 1/16 in. (1.6 nui), the pemitted length should be proportional to the actual length.
| |
| : 2. Violations of ASTM /AISC Codes governing bolting requirements on Rupture Restraints, and Class 1 structural steel installations. The Manual of Steel Construction (AISC), specification for structural dotnts using AsIM A325 or A490 Bolts", section 3. '80LTED PARTS" states, l
| |
| (a) The slope of surfaces of bolted parts in contact with the bolt head and nut shall not exceed 1:20 with respect to a plane normal to the bolt axis. Bolted steel parts shall not be separated by gaskets and shall fit solidly together after the bolti are tightened. Holes may be punched, sabpunched and reamed, or drilled, as required by the applicable code or specification. Standard holes shall have a diameter nominally 1/16-in. in excess of the nominal bolt diameter.
| |
| Where shown in the design drawings and at other locations approved by the designer, oversize, short 1632d ,
| |
| | |
| := =. . .r : .. - - - . . ... ..
| |
| slotted, and long slotted holes (see Table 7 in Commentary) may be used with high-strength bolts 5/8-in. diameter and larger in connections assembled as follows:
| |
| )
| |
| i
| |
| ~
| |
| : 1. Oversize holes may have nominal diameters up to: '
| |
| 3/16-in. larger than bolts 7/8-in, and less in diameter,1/4-in. larger than bolts 1-in in diameter, and 5/16-in. larger than bolts 1 1/8-in. and greater in diameter. They may be used in any or all plies of friction-type connections. Hardened washers shall be installed over oversize holes in an outer ply.
| |
| : 2. Short slotted holes are nominally 1/16-in, wider than tne bolt diameter and have a length which does not exceed the oversize diameter provisions of subsection 3(a)1 by more than 1/16-in. They may be used in any or all (illegible or deleted] or
| |
| . bearing-type connections. The slots may be used ,
| |
| ! without regard to direction of loading in friction-type connections but shall be normal to the
| |
| ! direction of the load in bearing-type connections.
| |
| Hardened washers shall be installed over short slotted holes in an outer ply.
| |
| 3 Long slotted holes are nominally 1/16-in wider
| |
| !, than the bolt diameter and have a length more than allowed in subsection 3(a)2 but not more than 21/2 I times the bolt diameter. The slots may be used without regard to direction of loading in friction-type connections but shall be nomal to the airecuon of the load in bearing-type connections.
| |
| Long slotted holes may be used in only one of the connected parts of either a friction-type or bearing-type connection at an individual faying surface.
| |
| l Where long slotted holes are used in an outer ply, a i plate washer or continuous bar of at least 5/16-in.
| |
| ! thickness with standard holes shall be provided. This I washer or bar shall be of structural grade material,
| |
| ! but need not be hardened. If hardened washers are required to satisfy Specification provisions, the hardened washers shall be placed over the outer l surface of the plate washer or bar. These washers or bars shall have a size sufficient to completely cover the slot after installation. '
| |
| i i
| |
| 1632d l
| |
| ,,__ _. _ _ _ _ _ . __,_m
| |
| | |
| (b) When assembled, all joint surfaces, including those adjacent to the belt head, nuts or washers, shall be fme of burrs, dirt, and other foreign material that would prevent solid seating of the
| |
| . parts. Paint is pemitted unconditionally in
| |
| ..l--. Dearing-type Connections.
| |
| 5 INSTALLATION (c) Turn-of-Nut Tightening When the turn-of-nut method is used to provide the bolt tension specified in subsection 5(a), there shall first be enough bolts brou condition to insure [ sic) ght thattothe a "parts snugoftight" the joint are brought into good contact with each other. Snug tight is defined as the tightness attained by a few impacts of an impact wrench or the full effort of a man using an ordinary spud wrench. Following this initial operation, bolts shall be placed in any remining (sic) holes in the connection and brought to snug tightness. All bolts in the connection shall then be tightened additionally by the applicable amount of nut rotation specified in Table 4, with tightening progressing systematically from the most rigid part of the joint to its free edges. During this operation there shall be no rotation of the part not turned by the wrench.
| |
| (d) Calibrated Wrench Tightening When calibrated wrenches are used, they should be set to provide a tension at least 51 in excess of the minimum bolt tension specified in subsection 5(a).
| |
| The wrenches shall be calibrated at least once ea:h working day for each bolt diameter being installed.
| |
| Wrenches shall be recalibrated when significant changes am made in the equipment or when a ,
| |
| l significant difference is noted in the surface condition of the bolts, nuts, or washers. Calibration shall be accomplished by tightening, in a device capable of indicating actual bolt tension, three typical bolts of each diameter from the bolts being installed.
| |
| When adjusting the wrenches to provide the requimd tension, it shall be verified during actual installation in the assembled steelwork that the calibration selected does not produce a nut or bolt head rotation from snug tight greater than that i
| |
| l 1632d '
| |
| i I
| |
| | |
| _. . .. .. . - - _ - - _ - - - - . _ - - ..= - _- - - _
| |
| ~ ~
| |
| T ::=-- .- E-T ' Y ~.. : .r- .....- . . - .
| |
| permitted in Table 4. If manual torque wreiches are
| |
| , used, nuts shall be in tightening motion when torque
| |
| ' ~
| |
| is measured. _
| |
| l i . When using calibrated wrenches to install several i
| |
| ..; bolts in a single connection, the wrench shall be returned to " touch up" bolts previously tightened, which may have been loosened by the tightening of i
| |
| subsequent bolts, until all are tightened to the
| |
| : prescribed amount.
| |
| 1 (f) Rouse A490 bolts and galvanized A325 bolts shall not be mused. Other A325 bolts may be reused if approved by the engineer responsible.
| |
| Retightening previously tightened bolts which may have been loosened by the tightening of adjacent bolts shall not be considered as a reuse.
| |
| 6 INSPECTION (a) The Inspector shall detemine that the mquirements of Sections 2, 3, and 5 of this Specification are met in the work. When the calibrated wrench method of tightening is used, the Inspector shall have full opportunity to witness the calibration test prescribed in subsection 5(d).
| |
| (b) The Inspector shall observe the installation of bolts to detemine that the selected procedure is properly used and shall determine that all bolts are tightened. Bolts installed by the turn-of-nut method may reach tensions substantially above the value given in Table 3, but this shall not be cause for rejection.
| |
| COMENTARY C5 INSTALLATION
| |
| ; Where long slotted holes are used, experimental evidence has shown that a plate washer or continuous l bar of at least 5/16-in. thickness with standard holes
| |
| ' is necessary to provide adequate bearing. This washer l or bar shall be of structural grade material but need not be hardened. However, if hardened washers are mquired to satisfy Specification provisions, the hardened washer shall be placed over the outer surface I of the plate washer or bar.
| |
| l l
| |
| l l 1632d !
| |
| l
| |
| ._----____.---.-.a._--- .- -
| |
| | |
| 4
| |
| : 3. Exangles of non-compliance with Pulman [ sic] Power Products own Engineering Specifications - Diablo (ESD's).
| |
| My concerns relating to ASTM /AISC Boltin Requirements led to a review of an internal PPP document Tensioning -
| |
| 7 ESD-243" Authored by R. L. Werner, which deals with the inadequacy of ESD 243 with respect to under tensioning and over tensioning of A325 and A490 bolts. This document also delt [ sic] with the implementation of the disposition of NCR DC2-80-RM-002, dated 11-19-80. Page 3, paragraph 5 states:
| |
| Bolts which have rejectable indications shall be discarded and replaced with new bolts and new nuts.
| |
| If bolts are grouted in wall the connection shall be "As-Built" and the As-8uilt submitted to the assigned engineer for review and disposition.
| |
| This document leads me to believe that PG&E provided explicit instructions for the handling of' accessable [ sic]
| |
| and fairly easily resolved problems and provided a built-in escape clause for problems that were inaccessable [ sic] or required extensive rework. (4/18/84 Anon. Aff.,
| |
| Exhibit 2, at 1-6).
| |
| Although the alleger " intended to identify some examples of unacceptable workmanship," no specific examples are cited. He cites at length from the AISC without giving any specific examples of Concern.
| |
| l It should also be noted in passing that the allegation cites the Eighth Edition of the AISC Manual of Steel Construction, whereas the Seventh Edition is the licensing basis of this plant.
| |
| Allegations regarding the quality of vendor welds have been addressed in PGandE letter DCL-14-114, dated March 22, 1984, in relation to l Bostrom Bergen and in response to the April 11-12 NRC sponsored night l
| |
| 1632d ,
| |
| - . - , . _ . _ . . _ _ _ _ _ . _ . , . _ _ _ _ , _ _ _ _ . _ _ _ _ _ _ _ _ _ . - - , . . . , , _ _ . , _ , , _ . _ _ _ _ . _ _ . _ _ . - _ _ . . _ _ , ~ _ . _ - . . . . . . . _ _ _ . - . _ . _ _ _ _ ~ . . . _ _ . .
| |
| | |
| )
| |
| I tour for allegers. A similar allegation coming from that tour was l addressed in PGandE letters DCL-84-170 (May 2,1984) and DCL-84-200
| |
| . (June 1,1984) and Allegation V-47 herein.
| |
| . l O
| |
| e 1
| |
| 1 1632d - 6-
| |
| | |
| V-27 i
| |
| It is alleged that:
| |
| . Another document I myiewed was PPP EMPLOYEE SELF-STUDY '
| |
| l
| |
| .-- BOOK #2 relating to Pullman's version of 10CFR50, Appendix l I 8. "QuaIity Assurance Criteria for Nuclear Power Plants."
| |
| The Pullman version differs substantially from the legal
| |
| ! version with respect to organizational structure for the QA program. The official version reads as follows:
| |
| .i I. ORGANIZATION ,
| |
| The applicanti shall be responsible for the establishment and execution of the quality assurance program. The applicant may colagate to others, such as contractors, agents, or ernsultants, the work of estan11sning and executing the quality assurance program, or any Mrt thereof Det snail retain respons1olitity sic] therefor. The authority 6nd duties of persons and organizations performing
| |
| ' structures, systems, and commnents shall be clearly estan11sned and delineated 11 writing. These activities include both the perfoming iuiiRTons of attaining quality oDdectives and tne quality assurance runcu ons. Ine qual'ty assurance functions are tnose of (a) assuring snat an appropriate quality assurance pmgram is estaD11sned and effectively executed and (D) verifying, such as by checting, audtting, and inspection, that activities affecting the safety-related functions nave seen correctly performed. Tne persons and organizations performing quality assurance functions shall have sufficient autnority and organ 1zational freedom to identify quality problems; to initiate, recommend, or provide solutions. Such persons and organizations perfoming quality assurance functions snali report to a management level sucn tnat snis required autnority and
| |
| ; organizational freedom, including sufficient j Thaependence from cost and schedule when opposed to safety considerations, are prow 1ded, secause or Ine many varisoies involved, such as the number of rsonnel, tne type of activity oeing performed, and e oca 1on or locations wnere activities are perfomed, the organizational structure for executing ,
| |
| I tne quaitty assurance program may take various forms provided that the persons and organizations assigned
| |
| , tne quality assurance functions aave this required
| |
| ! autnority and organizational freedom. Armspecuve of l Ine organizational structure, the Individualts)
| |
| I i 1585d i
| |
| | |
| l l
| |
| 4 assigned the responsibility for assuring effective execution of av portion of the quality assurance
| |
| ; program at any iocation wnere activir,ies suoJect,so T,ms appenaix are seing perrows snali nave airect access to sucn levels of management as any se
| |
| ,; , necessary to perrom tnis function.
| |
| ~
| |
| (Footnote 1.) While the tem " applicant" is used in ,
| |
| j these criteria, the requirements are, of course, appiicanie arr.or sucn a person nas receiven a iicense i j to construct and operate a nuclear powerplant [ sic; or i a fuel reprocessing plant. Tnese criterta w111 also se usea ror guiaance in evaluating sne adequacy or
| |
| ! wa111;y assurance programs in use ny noicers or construction pemits anc operating 11 censes.
| |
| (NOTE: Those parts of 10CFRSO, App.B. I. ORGANIZATION that are omitted or paraphrased in Pullman's version are underlined.)
| |
| The Pullman version is as follows:
| |
| The applicant shall be responsible for the establishment e% execution of the quality assurance !
| |
| program. The applicant may delegate to other '
| |
| organizations tne work of establishing ana executing the gality assurance program or any part tnereof, out snait retain responsto111ty snerefore. The authority and the duties of persons and organizations perfoming quality assurance functions shall be clearly i estanitsnea anc celineates in writting (sic). Such :
| |
| l persons and organizations shall have sufficient authority and organizational freedom to identify '
| |
| quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
| |
| i In general, assurance of quality maires management t measures whicn provide snat tne snaivtaual or group j
| |
| assignea the respons1btitty for enecIttng, auditing, j
| |
| fnspecting, or otnerwise vertrying snat an activity .
| |
| nas seen correctly perromeo 1s trssenaent or tne Individual or group strectly respons1 Die for ,
| |
| perroming the spectric activity.
| |
| (NOTE: Pullman's paraphrases are underlined in the l above quote. i l
| |
| i The rest of appendix B is typed verbatim except for the
| |
| ! amission of the words " fuel reprocessing plant" where they i occur. % " official version"is (sic) ((35 FR 10499as amended at 36 FR 1 j
| |
| June 27, 1970, r
| |
| FR 32100 Jan. 20,1915.)) !
| |
| l l
| |
| isasd j I
| |
| l
| |
| | |
| Had Pullman complied with the legal version of 10 CFR 50
| |
| - App. B, the proper respect for safety m1ated work could have been maintained throughout the compa g. However, the Pullman version pervaded the attitudes of the supervisors involved. Their attitudes served to restrict inspectors i ;. like gself from broadening our knowledge of the
| |
| - requirements and attempting to document and seek out resolution to safety-related problems. Pullman's arrogance i . - , in rewriti The
| |
| ; lack of augthe law on (uality Assurance disturbs me.rity and intependent fre
| |
| ! inspectors to cut through red tape and follow a problem to a conclusion can be traced back to the omissions and paraphrases of the legal Code. Pullman's caissions effectively placed the inspectors in a position of accepting only work shown to them rather than striving to prevent recurmnce of problems in workmar. ship and design. ,
| |
| ; I was unaware of Pullman's omissions and thought they had given us a real copy of 10CFR50 App.B to stub. In fact, in g first Affidavit I identified a requirement to l
| |
| maintain a separate QA/AC department as a requirement of l 10CFR50 App.B even though this requirement is casually addresses [ sic] in the Pullman relaxed version. It is l l clearely (sic] defined in the legal version. I am deeply '
| |
| l
| |
| ; concerned with Pullman's relaxed version because of the attitude of senagement to relax requirements even further in practice. .
| |
| i Based on g knowledge of e.at Pullman classifies as a QA program I have serious doubts as to the ability of their version to " stand alone" under the real requirements of 10CFR50 App. B. This is not resperisT51e behavior.
| |
| l (4/18/84 Anon. Aff., tahibit 2, at 6-9.)
| |
| The " Pullman version" accurately addresses all of the aspects of the full, unabridged version of 10 CFR 50, Appendix 5. Although in hindsight it might have been appropriate to note that Pullman had paraphrased the Appendix, when the " legal version" is compared to
| |
| " Pullman's version," there is no significant departure from the f intent of the actual Appendix B. It should first be noted that the Pullman " version" of Appendix 5 in Self Stu@ Book #2 is not a !
| |
| Pullman document that " stands alone", but is a part of a general 1585d ,
| |
| , - . - . . , _ - . , _ . . _ _ _ . , _ _ _ ~ ~ _ _ . -- -
| |
| | |
| ~. ....
| |
| desertption of Pu11ren's quality assurance involvement. This study beck,is not pait of an approved procedure, specification, or the QA s Manual n.pd should be viewed in that light. The book was not and is A. ' not^a eaanhti.ry reading requirement for certification of any QA/QC personnef'and is no longer being used as a controlled self-study guide or as'part of the current reading if st utilized for training. l Jo wort is conducted or performed in accordance with this book.
| |
| Insofar as Pullman's training of QA/QC Inspectors is concerned, the
| |
| - applicable aspects cf Appendix B are those which deal with the quality ' assurance functions. The " Pullman version" in the self-study
| |
| ' manual was written 1n t. hat light. Appendix B states that, " quality issurance functions are those of (a) assu:-ing that an appropriate quality assurancetprogram is established and effectively executed and
| |
| ('b) verifying, such as by checking, auditing and inspection, that activities affectir.; the safety-related functions have been properly performed.". The QA/QC personnel do not perform safety-related functions; they only verify that activities affecting these functions have fan properly' performed. The " Pullman version" emphasizes establishment of ther quality assurancs functions.only. Hence the paraphrasing approach was used. Where personnel involved in quality assurance' functions are conc rr.ed,. the context of Appendix B has not been alterad or diminishhd,. as'is alleged.
| |
| ~
| |
| 1585d
| |
| - - .4 -
| |
| 5
| |
| , = ., --e.-,--------,-,_.---,,v,-- .--,_."_.--,---_.---,,,___'_e---._-~~,--. . _ . , , , - - -_ .-...---,--,---v--,-~~--w-
| |
| | |
| ;. ----=--..,-..=.
| |
| .i : : ... . .
| |
| As mentioned in Appendix 8 (both " versions"), " sufficient authority and organizational freedom" shall exist "to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation cf solutions." This can be either on an individual or organizational level. Both " versions" go on to say that reporting shall be to a management level that is independent of the individual or group that has caused the quality problem. Appendix B also allows the flexibility to create an organization that will address quality problems in any manner appropriate as long as independence from the cause is maintained. The quality assurance organization can choose to " seek out resolution to safety-related problems" through avenues other than the originator of the quality problem report. In other words, the individual who identifies a quality problem does not have to follow completely through to resolution any problem that he or she has identified as long as the quality assurance organization has established a method of addressing such problems. Pullman's organization allows its inspectors to continue on with QC functions in support of construction efforts so that the inspectors don't get tied down in research and follow-up efforts. Support quality assurance personnel are employed to handle research, back-up documentation, resolution, implementation and verification of correction of quality problems.
| |
| The statements by the alleger that proper respect for safety-related work was not maintained throughout the company and that the " Pullman 4
| |
| 5 1585d :
| |
| | |
| . - - = ._--- _ _ . . _ _ _ _ _ . _ . _
| |
| ~~"
| |
| version pervaded the attitudes of the supervisors involved" and that "their attitudes served to restrict inspectors like styself" are unsubstantiated statements of opinion and cannot be acknowledged or i answered as no specific incidents or examples are cited. The
| |
| -- statement that inspectors lacked authority and independent freedos "to cut through the red tape and follow a problem to a conclusion" cculd be " traced back to the omissions and paraphrases of the legal code" is inaccurate because, as has already been explained above, the inspector does not personally have to follow a problem through to a conclusion if the quality assurance organization has created a way to do so, which is the :ase with Pullman. There is no requirement in the Appendix B that an individual who identifies a problem must be the same individual who follows the problem through to resolution.
| |
| Pullman provides a system of review and disposition / resolution by individuals at management levels for problems in workmanship. These individuals connunicate corrective measures to the fabrication / erection portion of Pullman to improve the quality of workmanship and, at the same time, enforce implementation of the corrective measures. Design is not Pullman's responsiblity, but PGandE's. Arty design problems discovered by inspectors are ,
| |
| docimented and addressed to PGandE for evaluation.
| |
| l I
| |
| 1585d , , _ _ _ _ _ _ _ . _ _ _ _ _ _ ._ _ _ . . _ _ . _ . _ . _ _ __ _ - . . _ _ _ _ . . - _ _ _
| |
| | |
| l V-2sA It is alleged that:
| |
| ' The ESD's I was expected to perform sqy inspections to were
| |
| ' supposed to confom to the AISC/ ASTM codes, when in actuality they often conCicted with them. This is especially important oecause the ESD's did not reference any requirweents pertaining to the shape or size of the hole the anchor bolts were mounted in.
| |
| I identified the deficiencies of the ESD to sqy supervisor,
| |
| [ illegible or deleted) on several occasions. In each instance I was instructed to inspect to the ESD's because Pullman worked to them and not to codes.
| |
| [ illegible or deleted] discovered a structural support on the Unit 1 pipe rack where six of the eight mounting / bolting holes were elongated to the point where the washers could not cover the holes. [ illegible or deleted] researched [ illegible or deleted] supervisors, fellow ins drawings. pectors (old timers), engineers, and the design The design drawing showed no enlongated [ sic]
| |
| holes. In all cases the personnel advised that:
| |
| : 1. Work was performed by another contractor;
| |
| : 2. Not to worry; l 3. PG4E knew about it, it was old work and was accepted as is.
| |
| [ illegible or deleted] had to accept these statements as being gospel, mainly because there was insufficient documentation in existence and available [ illegible or deleted] to dispute their claims. (4/18/84 Anon. Aff.,
| |
| Exhibit 3, at 2-3.)
| |
| Since this allegation lacks specifics, it is impossible to respond in any detail. The subject of the adequacy of using standard round washers for structural steel bolted connections with slotted holes was previously addressed in full in PGandE's letter DCL-84-162, dated April 27,1984. This letter indicated that:
| |
| 1590d - - . - . - - - -.-_.- -. - . . _ - _ - - - - _ _ _
| |
| | |
| ...the governing code, AISC, 7th edition, first printing, contained no specific requirements for connections using slotted holes. A few of the pipeway structure bolted connections contain slotted holes with bolts and' washers that wem installed in accordance with this edition of the AISC code. In subsequent printings of the 7th edition of the AISC code, requirements for adding plate washers to slotted hole connections were included to ensure that the bolts would have adequate bearing area against the base metal. Siwe the existing bolt washers do not completely cover the bolt holes, Engineering performed an analysis of the existing configuration of the pipeway structure connections. This analysis found that the washers provided sufficient contact with the base metal such that the actual bearing stresses were within allowable stresses given in the AISC code.
| |
| 296. The implications in the allegation that these bolts wem not installed in conformance with the AISC code and that PGandE incorrectly accepted this condition
| |
| ' are unfounded. The subject bolted connections were t
| |
| installed in accordance with the then existing AISC code, and engineering analysis demonstrates that the connections are fully acceptable."
| |
| The Pullman ESDs are written to be in compliance with PGandE specifications and the applicable codes. All ESDs, including those for rupture mstraints, have been reviewed and approved for use at Diablo Canyon by PGandE.
| |
| i Pullman's direct responsibility is only for its own work. In instances when potential deficiencies are identified in the work of other::, it is Pullman's responsibility only to bring these items to the attention of P6andE. Therefore the noted responses could all be proper when used in the appropriate context. It is understandable that an inspector could be told by his lead or supervisor that the existing items were indeed supplied and installed by others with the 1590d .
| |
| ,--,--,-e, , ,-,-,--,,..,----,,,,_m--.
| |
| | |
| knowledge of PGandE and therefore no further action was required by Pullman.
| |
| This individual seems intent on pursuing work beyond the contractual requirements and constraints of his employer. In Allegation V-288, he indicates that he had the freedom to and did consult with PGandE inspectors. It is presumed and expected that these latter unnamed individuals pursued the matter to an acceptable conclusion.
| |
| l I
| |
| 1590d !
| |
| I
| |
| | |
| V-288 It is alleged that:
| |
| This type of problem was widespread throughout the plant.
| |
| I had discovered [ illegible or deleted] similar situations in Unit 1 Reactor Building and Unit 2 Reactor Building. In some instances I found the crafts had stuffed the holes with short sections of soft tie-wire to serve as packing.
| |
| I could not understand this practice. When I questioned what document none could provided be provided. the instructions I consulted the pipefitters for
| |
| [ sicthis practice) involved, my supervisor, PG4E insgectors and the engineers. Their reply was that we had always done it this way, PG4E is aware of it and had accepted it as is."
| |
| To me, this constituted covering up poor workmanship by virtue of oral procedure or at best by internal memo rather than by approved procedures or AISC/ ASTM codes. (4/18/84 Anon. Aff., Exhibit 3, at 3.)
| |
| Rod packing of holes was an approved practice in accordance with Pullman QA Instruction M4 which was first put in effect in 1974 This instruction was included in ESD 243 during the period that most of the work involving bolt holes was initially performed. Although this instruction was dropped from the ESD in 1979, when the need arose in 1982 to mvalidate this process, PGandE reconfirmed (via response to DQs 278 and 450) that this practice was still considered l acceptable. Current PGand Design Drawing M47253, revision 4, also i
| |
| shows this practice as acceptable.
| |
| The practice has been re-reviewed and found acceptable as reported in PGanE letter DCL-84-220 dated June 3,1984. Thus, the practice is permitted by formal procedures, is not a cover-up for " poor workmanship," and is an acceptable engineering practice.
| |
| 1593d I l
| |
| | |
| i V-29 It is alleged that:
| |
| 1 My persistance [sf c] in persuing [ sic] these examples of non-compliance wi'.h the codes led to sty being harassed in the perfonaance of my job. Finally, in [ illegible or deleted] 1981, I had the opportunity for other employment awaty from Diablo Can I famediately seized it even with a reduction in pay. yon.I was relieved to be removed away from the harassament [ sic] and the butting of sqy head against a brick wall. roblems I had identified i
| |
| However continued to bother me. the p(4/18/84 Anon. Aff., Exhibit 3, at 3-4.)
| |
| The allegations of harassment are sufficiently vague to preclude a l detailed msponse. Harassment of inspectors was not practiced or condoned by Pullman management. This individual seems to have been upset by his inability to personally pursue issues all over the site and on work perfonned by other contractors. That was not his job.
| |
| He brought his matters of concern to the appropriate personnel and it
| |
| , was their job, not his, to resolve the issues.
| |
| A review of the Pullman records was undertaken to see if any of the inspectors resigning in 1981 had complained of harassment. No such complaints have been found. Nor have any of the inspectors who resigned in 1981 come forward with any complaint until the recent affidavit.
| |
| i l
| |
| I 1591d l
| |
| l 4
| |
| )
| |
| V-32 ,
| |
| It is alleged that:
| |
| I feel that had I been allowed to accompany the tour I could have provided first-hand examples of workmanship that would have violated the following code mquirements from the Manual of Steel Construction (AISC), Specification for
| |
| " Structural' Joints Using AblR A325 or A490 Solts," Section 3 BOLTED PARTS, Section 5, INSTALLATION; Section 6, INSPECTION; and COMENTARY, Section CS:
| |
| : 3. BOLTED PARTS (a) The slope of surfaces of bolted parts in contact with the bolt head and nut shall not exceed 1:20 with
| |
| ! mspect to a plane nomal to the bolt axis. Bolted
| |
| ; steel parts ssail not be separated by gaskets and 4
| |
| shall fit solidly together after the bolts are j tightened. Holes may be punched, subpunched and reamed, or drilled, as required by the applicable code or specification. Standard holes shall have a diameter nominally 1/16-in. in excess of the nominal bolt diameter.
| |
| ~
| |
| l Where shown in the design drawings and at other locations approved by the designer, oversize, short slotted, and long slotted holes (see Table 7 in Commentary) may be used with high-strength bolts 5/8-in. diameter and larger in connections assembled as follows:
| |
| 4 1. Oversize holes may have nominal diameters up to:
| |
| l 3/16-in. larger than bolts 7/8-in and less in diameter,'1/4-in. larger than bolts 1-in. in diameter, and 5/16-in. larger than bolts 1 1/8-in. and greater in diameter. They may be used in any or all plies of friction-type connections. Hardened washers shall be installea over oversize holes in an outer ply.
| |
| : 2. Short slotted holes are nominally 1/16-in. wider than the bolt diameter and have a length which does not exceed the oversize diameter previsions of subsection 3(a)1 by more than 1/16-in. They may be used in any or all plies of friction-type or 4
| |
| bearine-type connections. The slots may be used witnout regard to direction of loading in friction-type connections but shall be normal to the direction of the load in bearing-type connections.
| |
| Hardened washers shall be insta' led over short slotted holes in an outer ply.
| |
| Y 1645d i 1
| |
| -uwen---,-o,-v , - -- , _ , _ , + , _ _ , , , - - --
| |
| __n _,mw.m v m w-m m ar-~ m w y--
| |
| : 3. Long slotted holes are nominally 1/16-in. wider than une ooit alameter and have a length more than allowed in subsection 3(a)2 but not more than 21/2 times the bolt diameter. The slots may be used i without regard to direction of loading in friction-type connections but shall be nomal to the strectfon or the loaa in bearing-type connections.
| |
| Long slotted holes may be used in only one of the connected parts of either a friction-type or bearing-type connection at an individual faying surface.
| |
| Where long slotted holes are used in an outer ply, a i plate washer or continuous bar of at least 5/16-in.
| |
| thickness with standard holes shall be provided. This
| |
| ' washer or bar shall be of structural grade material, but need not be hardened. If hardened washers are required to satisfy Specification provisions, the hardened washers shall be placed over the outer surface of the plate washer or bar. These washers or bars shall have a size sufficient to completely cover the slot after installation.
| |
| (b) leien assembled, all joint surfaces, iricluding those adjacent to the bolt heads, nuts or washers, shall be fme of burrs, dirt, and other foreign material that would prevent solid seating of the parts. Paint is pemitted unconditionally in bearing-type connections.
| |
| 5 INSTALLATION (c) Turn-of-Nut Tightening When the turn-of-nut method is used to provide the bolt tension specified in subsection 5(a), there shall '
| |
| t first be enough bolts brou condition to insum [ sic] ght thattothe a "parts snug of tight" the joint are brought into good contact with each other. Snug tight is defined as the tightness attained by a few impacts of an impact wrench or the full effort of a man using an ordinary spud wmnch. Following this initial operation, bolts shall be placed in any remaining holes in the connection and brought to snug l tightness. All bolts in the connection shall then be i
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| tightened additionally by the applicable amount of nut i rotation specified in Table 4, with tightening t
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| * progressing systematically from the most rigid part of '
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| the joint to its free edges. During this operation l 16asd ... - - - _- - _ - . _ _ . - . - _ _ - . _ _
| |
| | |
| i l
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| there shall be no rotation of the part not turned by the wrench.
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| (d) Calibrated Wrench Tightening When calibrated wrenches are used, they should be set to provide a tension at least 55 in excess of the einfune bolt tension specified in subsection 5(a). :
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| The wrenches shall be calibrated at least once each worting day for each bolt diameter being installed.
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| Wmnches shall be mcalibrated when significant changes are made in the equipment or when a significant difference is noted in the surface condition of the bolts, nuts, or washers. Calibration shall be accomplished by tightening, in a device capable of indicating actual bolt tension, three typical bolts of each diameter from the bolts being installed.
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| When adjusting the wrenches to provide the required tension, it shall be verified during actual installation in the assembled steelwork that the calibration selected does not produce a nut or bolt head rotation from snug tight greater than that permitted in Table 4. If manual torque wrenches are l used, nuts shall be in tightening motion when torque is measured.
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| When using calibrated wrenches to install several >
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| bolts in a single connection, the wrench shall be returned to " touch up" bolts previously tightened, which may have been loosened by the tightening of
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| ' subsequent bolts, untti all are tightened to the prescribed amount.
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| j
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| ; (f) Reuse A490 bolts and galvanized A375 bolts shall not be
| |
| ' reused. Other A325 bolts may be reused if approved by the engineer responsible.
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| I Retightening previously tightened bolts which may have been loosened by the tightening of adjacent bolts shall not be consf Nred as a reuse.
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| 6 INSPECTION l- (a) The Inspector shall detemine that the requirements of Sections 2, 3, and 5 of this i
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| Specification are met in the work. When the 1608d !
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| l
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| | |
| calibrated wrench method of tightening is used, the Inspector shall have full opportunity to witness the calibration test prescribed in subsection 5(d).
| |
| (b) The Inspector shall observe the installation of bolts to detemine that the selected procedure is properly used and shall detemine that all bolts are tightened. Bolts installed by the turn-of-nut method may reach tensions substantially above the value given in Table 3, but thfs shall not be cause for rejection.
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| COMENTARY C5 INSTALLATION Where long slotted holes are used, experimental evidence has shown that a plate washer or continuous bar of at least 5/16-in. thickness with standard holes is necessary to provide adequate bearing. This washer or bar shall be of structural grade material but need not be hardened. However, if hardened washers are required to satisfy Specification provisions, the haroened washer shall be placed over the outer surface of the plate washer or bar.
| |
| The examples I could have identified to the NRC on the plant tour wculd have been Code violations with respect to:
| |
| : 1. Design drawings not specifying elongated holes;
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| : 2. Hole sizes outside of Code Specifications;
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| : 3. Torquing method;
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| : 4. Bolt reuse; 5 Examples of " packing" violating foreign material specifications. (4/18/84, Anon. Aff., Exhibit 3, at 6-10).
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| This allegation has been completely addressed in response to Allegation V-26 above.
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| 1645d !
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| I l
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| i V-34 It is alleged that:
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| ' A discussion of the Bolting Program for Rupture Restraints as practiced by Pullman is best discussec' through Pullman D.R. 4342, PG4E Nonconformance Report DC2-80-RM-002, and my own inspection experience dated late-July to mid-December of 1983. PG4E required that Pullman adhere to Contract Specification 8833XR for structural steel erection
| |
| , (contract includes Pullman's Rupture Restraint Program).
| |
| 8833XR specifically states that structural steel erection be conducted to the AISC Steel Construction Manual, Seventh Edition.
| |
| AISC's specifications for structural joints using ASTM A-325 and A-490 High Strength Bolts has provided values for minimum fastener tension in Table 3, page 5-195.
| |
| Basically, this Table requires that all A-325 and A-490 H.S. holts be tightened to 70h of their tensile strength measured in tension. When turn-of-nut tightening is used the additional requirements of Table 4, page 5-196, are specified. Note that the turn-of-nut rotation is dependent i
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| on:
| |
| : 1) Disposition of outer faces of bolted parts.
| |
| : 2) Bolt length.
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| Additionally, thread pitch should be mentioned because it is a factor in the determination of the required turn-of-nut rotation to, achieve the spectfled tensile bolt
| |
| ! preload. ,
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| Pullman's ESD 243-1 983 Torque Instructions per Charts A, i A1, 8 and Field Process Sheets prepared by Pullman Field
| |
| , Engineers, simply, do not take into account the
| |
| ! pre-requisites of the AISC Manual. (4/26/84 Lockert A,ff.
| |
| at 1-2. )
| |
| ESD 243 is in compliance with the AISC manuel for all connections that are torqued to the 705 value. The AISC requirements are based on this value. Connections that were torqued to a value less than 70s (i.e., 255 to 50s) as specified by ESD 243, were evaluated and specified by Engineering. Thus, these connections meet the 1416d - _ . - . - - . - . - _ - - - _ - - . .
| |
| | |
| , 3 - - -,e --
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| applicable design mquirements. The torque and bolt reuse requirements of AISC do not apply to connections that are torqued to then values because the bolt is considered unused for " reuse criteria" until it has been tensioned by torque or turn of the method to 70 percent of its ultimate tensile strength.
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| O i
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| l l
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| l l
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| l i
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| 1616d - - - - - . - _ _ - _ _ . - _ _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ _ _ _ . _ _ _ _ _______ ______.____ _ _ ____
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| | |
| V-35 and V-36 It is alleged that:
| |
| Non Confomance Report DC2-80-RM-002 initiated by Robert Torstron on 11/19/80 and [ sic] dated 12/12/80 for Cormctive Action states:
| |
| SHEET 1: Cause of Non Conformance Pullman Power Products' Rupture Restraint Program has had inadequate design change control, inspection performance, and control.
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| SHEET 2:
| |
| | |
| == Description:==
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| : 1) a. Out of tolerance gaps behind base plates... nuts not engaged per requirements.
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| i
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| : b. ...There are cases of material and welds not conforming to the specification.
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| : 2) a. Welds exist which do not have documentation.
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| : b. Modifications have been perfomed...and have not been documented.
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| : c. There are bolts that have ' Torque Seal'... However, inspection records do not exist....
| |
| RESOLUTION,:
| |
| Pullman Power Products shall perfom a documented inspection of all bolted and welded connections and appifcable documentation, required by the Specification, as set forth in approved contractor's ESD's in order to:
| |
| : 1) Identify connections which do not confom to specification requirements, and
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| : 2) Identify connections which do not have required documentation. (4/26/84 Lockert Aff. at 2-3.)
| |
| I would first like to point out that the cause of the NCR indicateTTTomplete breakdown of Quality assurance with mspect to Pullman's Rupture Restraint Program meeting 8833XR Specification requirements. Of course, Mr. Torstros 1617d .
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| | |
| I l
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| did not use those exact words but one only has to look at the resolution of the NCR to sa that PGAE required Pullman to do a 1005 reinspection of "all bolted and welded ,
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| connections and applicable documentation" required by Specification 8833XR. (4/26/84 Lockert Aff. at 3.)
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| All that Mr. Lockert has done in these allegations is to copy documents that were generated in accordance with the QA/QC program and then allege that the program was not effective and did not function as designed. However, the reinspection and repair of rupture restraints is an issue which was fully documented and mported to the NRC several years ago. The NRC Region V inspectors Welt actively involved in the assessment and resolution of this issue.
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| If17d ._.
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| - _ - - - - - - - - -. - - - - - - - - - - - - - -- --- - - --- - ---~-~-'~~
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| | |
| V-33 It is alleged that: . l I have reason to believe that the Bolting Program for Rupture Restraints in Units 1 and 2, conducted during late July to December of 1983, by the Pullman Power Product <
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| [ sic] Corporation has failed to meet licensing requirements. I use the word " licensing" because the
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| " Corrective Action" part of the Final Safety Analysis Report (FSAR) has not functioned as reported per 17.1.16 paragraph of the FSAR, "The Quality Assurance Program requires that conditions jeopardizing quality be promptly
| |
| , referred to responsible parties and that appropriate steps be taken to correct such situations." (4/26/84 Lockert Aff. at 1. )
| |
| The bolting program for rupture restraints in Units 1 and 2 meets all i-licensing requirements and ESD 243. This program also meets the AISC criteria for bolted connections as explained in response to
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| ;. Allegation V-34 below.
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| l l
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| l l
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| e 1616d l ,
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| | |
| V-37 It is alleged that:
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| Second I would like to point out that Mr. Torstrom refers !
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| lifllie,non-confoming conditions as Deficient Conditions; I do not feel deficient is the correct word. A departure from the requirements of 8833XR (a Procurement Document) is a " Deviation" defined by 10CFR21.3(e).
| |
| ! The deviations occured [ sic] in work that had alrea# been accepted by Pullman's Quality Assurance people as meeting the Design Drawings and 8833XR Specifications. AlreaQ being QA/QC accepted, the Rupture Restraints with deviations included were being offered to PGK as an ,
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| acceptable installation by Pullman. The deviations can now be s en of as " Defects" wr the 10CFR21.3(d) definition.
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| It s Id be pointed out t1st the defects were not reported per 10CFR21.21. (4/26/84 Lockert Aff. at 3-4. )
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| ! The reinspection and repair of rupture restraints is an issue which was fully documented and reported to the NRC several years ago. This program was evaluated and reported to the NRC in accordance with 10 CFR 50.55(e), which is the applicable federal regulation for reporting a construction deficiency.
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| 1623d l !
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| ! l l
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| I d
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| i V-38 t
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| It is alleged that:
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| Now lets [ sic] discuss the Resolution and Cormctive Action in Torstron's ER of 12/12/80. Proper resolution required an identification of "all bolted and welded connections" which did not confom to 8833XR Specification 1
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| rs@irements. Further, it was stated that:
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| i Pullman Power Products has developed and implemented a program which assures adequate l control of design ciumge. Training and indoctrination pmgrams have been developed and implemented which assures adequate performance of i
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| inspection personnel.
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| 1 Attachment 1 of ER DC2-80-RM-002 cornetly show:: that the minimum tension for High Strength bolts (ASTM A-325 and A-490) is 705 of the minimum tensile strength. However, Anchor bolts used as "Through bolts" in concrete walls and floors and Anchor bolts cast in concrete are allowed to be tensioned to 555 and 255 of the minimum tensile strength, mspectively. If the Anchor bolts happen to be A-235 or i
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| A-490 bolts, which I know for a fact that many of them are, then the instructions of the ER are an ap'pamnt deviation from the requimments of the AISC Manual, paragraph 1.23.5 Table 1.23.5. In other words, the resolution of the l
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| bolting problem was resolved by instructions to deviate from the requirements of the AISC Manual.
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| I do not know if ER DC2-80-RM-002 had been closed by the I
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| time I was employed by Pullman (July of '83). I do know that I was not instructed in the resolution requimments of the ER and that Pullman did not report defects that still existed in Rupture Restraints from July to December of 1983. Defects that I had noted that had not been previously reported were:
| |
| i i
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| : 1. Unauthorized modifications to fillet welds that TNcroached on bolt or washer land areas.
| |
| : 2. Oversize holes alma (y QC accepted outside the Blerances of ESD 243 and AISC Manual, i
| |
| : 3. Oversize holes in base plates packed with steel Tods and wires without the benefit of an approved Pullman procedure. (This work was performed to a memo from Mr. Torstmo in violation of 10CFR50 App B, Criteria V and VI.)
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| 1647d l
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| | |
| ~.-
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| : 4. Oversize welds beyond that allowed by AWS D1.1 and Eyond that allowed by Pullman's ESD 243,
| |
| : 5. Defects in A-490 bolts had been found after the Elts had been " dedicated" by Pullman's QA Receiving Department and sent to the field for installation.
| |
| (4/26/84 Lockert Aff, at 4-5.)
| |
| Attachment 1 of NCR DC2-80-RM-002 provides the tensioning requirements for ASTM A-325 and A-490 bolts used in rupture restraints. The tensioning requirements for pemanent steel-to-steel requirements meet the AISC requirements. Tensioning requirements for bolts in other than steel-to-steel connections are not within the jurisdiction of the AISC code. The design of these bolts are provided for in engineering calculations, including the tensioninr, requirements. The tensioning requirement for steel-to-steel connections which are periodically detensioned'and reused are based on engineering evaluation. These bolts were tensioned to levels below yield to allow their reuse.
| |
| Final disposition of DC2-80-RM-002 will be made when resolution of all items is complete. The disposition of all alleged defects will be complete prior to disposition of the NCR. It should be noted that this NCR is for construction of Unit 2. A similar NCR has already been closed out for Unit 1 construction.
| |
| In addition to the NCR, PGand has addmssed overs'ze hole questions by the NRC in PGandE letter DCL-84-220, dated June 3,1984.
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| 1667d l
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| ,- . , , , --..,--__,-.,-.--.--.-.-.----.--..-,,,~~___.-,,,1..- . . , - . - _ . _ , - . - . . . . . . _ . . - - - - - , - _ - - - - - - - - - - -
| |
| | |
| . . __ . - . - - - . . _ - _ _ . - =_. - - _ _ - - - - - - . - - . - . _ _ _ _ _ _ _ _ _ _ - -
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| In response to NRC questions on this issue PGandE stated::
| |
| PIPE RUPTURE RESTRAINTS INSIDE CONTAINENT The rupture restraint base plates are anchored to well or floor concrete. In cases where the base plate holes were oversized, the gaps were filled with steel rods to enable the bolts to transfer the load to concrete. These were detemined to be limited to rupture restraints installed j inside containment (Reference drawing M47253, Rev. 4). A total of 2M anchor bolts were affected.
| |
| Six rupture restraints having 15 oversized anchor bolt holes were identified as being the typical cases and the amount of steel mds packed into the oversized holes was dccumented.
| |
| Details of this resolution are preses,ted in Attachment 1
| |
| [ Exhibit 1 attached] along with technical justification of this arrangement.
| |
| , The review of rupture restraint documents shows that when steel rod was used on rupture restraint base plates installed inside the containment, it was recorded on process sheets. Twenty packages out of a total population of 222 rupture restraints installed outside the containment were reviewed, and it was found that the process sheets did j not indicate that steel rod was used in these restraints.
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| i !
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| j e
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| l l 1H7d i .
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| . - , - - , - - , - , - - . ,.-.-n ,_,,,__,-n_..,-._____.-_,___,.__._._.,___ n-__-n,_____._
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| | |
| Exhibit 1 of R:spt:nse to V 38 Page 1 of 5 i
| |
| Attachment PIPE RUPTURE ES1RAINTS INSIDE CONTAINENT i BASEPLATE OVERSIZE NOLE - R00 PACKING DETAIL
| |
| : 1. Statement of Concern A concem has been refsed regarding the acceptability of the shear transfer detail used for owestas baseplate anchor bolt holes. This
| |
| ! ASE steel rod (1/4-in. maa. diameter) to fill the space b haseplate and anchor belt.
| |
| : 2. Be ckersund !
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| i The shear transfer detail usf ag A36 red packing ts confined to rupture i astraints located inside contatement. Application of this detail is i
| |
| specified on drawing M47253 Rev. 4 I applied to the Esbedmont " Class" A, 8, and C embedments.3The oursize and forty-six anchor bolts use this detail. Two hundrwd The detailing practice used by the steel fabricator shop was to oversize the baseplate in accordance with the AISC " Detailing for Steel Construction" manual.
| |
| Table 7-1 of that manual mcommends the following:
| |
| Table 7-1.
| |
| Recommended Hole $12es for Anchor Bolts Solt stze , Nole size 3/4" to 1" fac1. Ofameter + 5/16"
| |
| ; ~
| |
| Over 1" to 2" incl. Diameter + 1/2" Over 2" i Ofameter + 1" i
| |
| The abow building AISC table recommends the anchor bolt hole sizes for construction. nom Since the Project specification required confomance to the AISC criteria, the steel fabrication with oversize holes was withir the specified limits. Nomever, the rod packing detail was dowloped to provide a positive mechanism to transfer shear from the baseplate to the anchor belt. The shear is transfered by hearing between the baseplate and the rod packing / anchor bolt shank. This detail was
| |
| ! I The tem Esteenent Class refers to the type of ambeduent detail used.and is not misted to safety class.
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| . . . . , , ~ n w e . . ..
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| l r. ,
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| a \
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| If15d/001m ' \
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| I
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| . e
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| | |
| l Exhibit 1 of Response to V 38 Page 2 of 5 '
| |
| approved by o'agineering for use in the f asta11ation of rapture restrefnts faside ecstainneet.
| |
| OCP understands the current concerns regarding the red packing shear transfer detail to be:
| |
| : a. The sdeguacy of the red packing under the bearing loads imposed under design conditions, and
| |
| : b. Possible relattie movement betueen the baseplate and anchor bolt due
| |
| , to red packing compaction. '
| |
| : 3. Field Survey DCP construction personnel conducted a document survey and interviewed knowledgable construction personnel to verify the extent of the rod i
| |
| packing detail. The use of red packing was noted on construction process sheets. A review of rupture restrafat documentation confirmed the use of this detail inside contafament. A review of 20 of the 222 outstde containment restraint packages revealed no use of this precedure.
| |
| Pullman power Products and PGend General Constrwetton (GC) personne1' with historic knowledge of the rupture restraint fastallation were interviewed by GC management personnel. Interviewed personnel confirmed that the red application. packing detail mes confirmed to inside containment
| |
| : 4. Field Evaluation Engineertng deffned a represents 11ve bample of fnstde contafnment rupture restraints for field inspection of anchor bolt packing. The sample selected included the Priority Code "C" restraints (crf tical to Civil) s (pecified Precedure byP-37, the "Precedure for phrasuring Not Gaps on Rupture Restraints" Revis1on 1).
| |
| The ffeld inspectfon sample mes modiffed by limiting inspection to:
| |
| a.
| |
| Restraints that were accessible without the installation of scaffolding, and restrefnts which did not represent an excessive safety hazard to personnel,
| |
| : b. Restraints and/or bolts which did not require disassembly or rigging for nut removal.
| |
| Fifteen belts were inspected. Thirteen restrafats were in the Prferity Code "C" category. Eleven of the 13 restrofats were anchered to concente using the red packing detail. Only 6 of the 11 restrofats could be accessed without scaffeldtag. Fffteen nuts could be removed from these sia restraints withest disassembly of structurel components.
| |
| - ~. L1 7 -- .
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| __ _ _ _ . - - - _ _ _ _ - _ - - _ _ _ . = - _ _ _ -_ -
| |
| | |
| Exhibit 1 of P:sponse to V 38 Page 3 of 5 An initial inspection en May 23 and 30,1g84, identified five "morst case" red packingand/or leese redjacking cases.voids. "Werst Case" bolts were those with visibly June 1, Ipse, to seasure bolt offsets and rod packing densities.A The followup results of the June 1 inspection were used for a quantitative engineering evaluation. ,
| |
| : 5. Ensineerine Evaluation )
| |
| Engineering evaluated the following aspects of the rod packing detail:
| |
| Red packing ultimate bearing capacity compared ts anchor bolt ultimate stmngth design Ifmits for shear.
| |
| i Worst case baseplate displacement relative to the anchor bolt associated with red packing compaction.
| |
| : a. Searing Capacity - Rod packing Material The rod packtm materf al is confined between the bolt body, baseplate, waswr/ nut and the wall / floor slab.
| |
| flattening of a red is considered self-limiting. Local deforming Local contact or forces wh< ch result in plastic deformation of the rods will result in increased rod. contact area. The limiting case is full flattening of the Normal bearing stress on the rod material was evaluated for the limit state case of rods completely flattened to 1005 compaction. The predicted normal bearing stress, for bolts at the design shear force limit ranges from 375 of the faulted allowable bearing stress for 1-in. bolts to 50s of the alloweble for 3-in. bolts. The allowable bearing stress was computed in accordance with the AISC Section 1.5.2.2 bearing stress criteria, factored for the faulted pipe break condition.
| |
| l b. Baseplate Displacement Baseplate displacement can occur due to loose packing (constmetion packing tolerance allowed up to 1/8-in. aps) and due to deformation of the rod material. The worst case di lacement was predicted by:
| |
| Camputing the density of the rod packing as measured in the field.
| |
| Assuming complete compaction of the rod material between the bolt and baseplate, i.e., the rod asterial is fully plastica 11y deformed to a aero void state.
| |
| Even in the fully displaced state therv would be some amount of void left in the interspaces between the compacted inds. Nomever, based upon a conservative estimate of the assumed condition of no void the ensimum Leedicted 1/4 in. displacement of the baseplate telative to the an,cher helt woold
| |
| . gg M****
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| Irisd/ cola ,
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| - - . . - _ . - - . . _ - . - _ _ _ _ _ _ _ _ _ _ . - - -- a
| |
| | |
| Exhibit 1 of Response to V 38 Page 4 of 5 The norst effect of besoplate relative displacement occurs when one bolt is in faitfal contact with the baseplate and the other bolt is separated by lesse red sackfag (see Ffgure 5-1). In the illustrated case. Bolt a uR11 resist the sheer lead fusediately. Bolt A will gradually resist ahear as the red packing campacts. As Bolt B defoms Seit A will facreasingly mstst shear.
| |
| The embedded anchor bolts for restraints inside contafament are ductile. Embetont depth is sufficiently deep to develop the full tensile design strengtt of the bolt. Research has indicated that deeply embeded bolts (wtth respect to tensile cespacity) are also ductile in shear. Illustrations of bolt ductility are found in:
| |
| The 011gaar11, Slutter and Fisher " Shear Strength of Stud Connectors in Lightweight and Nemal. weight Concrete," AISC Engineerins Journal, April 1971.
| |
| Fisher and Struik, Guide to Design criteria for Bolted and Riveted Joints, Section 4.z.z soits sueJected to snear, isie.
| |
| The 011gaard AISC Ensincerins Journal experimental investigation studies the behaviour of steel stue connnectors embedded in concrete and loaded in shear. 011gaard observed that 5/8-in. and 3/4-in. diameter shear studs achieve maximum strength at laternal displacements of 0.23 in, to 0.42 in. . 011gaard further observed that the studs exhibit " substantial inelastic defomstfon before failure", and that "at ultimate load there -
| |
| uns no sudden failure evident." These results indicate that the concrete anchors can still provide the required sheer resistance at displacements of 3/8 to 1/2 of the bolt's diameter. The worst case projection of bolt displacement associated with loose rod packing is equivalent to 1/6 to 1/5 of the bolt's diameter.
| |
| The Fisher Criteria for Bolted and Riveted Joints reports on the shear deformation senavtour of Aun and Aeso Doits in steel-to-steel connections. The typfcal shear-defomation curve for standard A325 and A490 bolts show sheer deformations of about 3/16 in. at ultimate. It is espected that the ruptum restraint bolts, which are larger than typical structural bolts, have higher defomstfons at ultimate strength.
| |
| In sammary, the inherent ductility of bolting material in steel-to-steel connections and embedded in concrete, allows relative base plate to anchor bolt displacements in excess of 1/4 in. while mtaining the connections lead carrying capacity.
| |
| : 6. g l Belt holes for rupture mstreints baseplates inside containment were cuersfaed for insta11atten. The spaces between the besoplate and anchor helt more encheafsu. pocked Ffeld inspection with red materf al to provideevaluation and ensfasering a posittweindicate sheer transfer that the teasplate may displace up to 3/16 in, to 1/4 in. miatise to the anchor helt. Sheer efemettens of this magnitude am considered acceptable bened on evere11 structeml system ductflity and the nature of rupture feetraint "one tfee" feeding. Bearing force on the red packiny material uns evolueted and considered acceptab e. In sammary, the red packing sheer transfer detail speciffed by drewf ag 44H53 Rev. 4 is adegnete for its fatsaded functfen. ,, .
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| 121Ed/90lk ',. , "
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| | |
| Exhibit I cf R:sponse t6 V 38 Page 5 of 5 eneste casevensPanacT
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| # 4 caa.c.no -
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| er J'%uew S-1 nav. eso -
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| ,J ev sats cuscaso sv SATs Joeseo umso 1
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| r saae Ptah Bolt A % ryr. Aod sching
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| /
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| s he ar-m i
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| D ott B i
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| l l
| |
| i
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| ; 7 7 1.. ." ", , . g' *
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| ;r ,,
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| ...-e ~d w g l -
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| 1
| |
| \
| |
| | |
| I
| |
| , v-3e, 4i, 42, and a ;
| |
| It is alleged that:
| |
| (In addition to the above mentioned hardware problems, !
| |
| Pullman's ESD 243 of late 1983 had precedure written into the Ruptum Restraint Program:) problems
| |
| : 6. The tables provided for the description of acceptable l Wshers had not been updated per the requirements of AISC, ;
| |
| Sec 5 Page 191, para. 2(a).
| |
| L Acceptance criteria for High Strength bolts was [ sic]
| |
| not defined in ESO 243. Filed [ sic] Inspectors did not know, nor were they legally able to reject bolts that were defective per ASTM A-490 ASTM A-325, and ANSI 818.2 I requirements.
| |
| [
| |
| : 8. Bolt Torque Tables in E50 243 wem still out of l Toupliance with AISC Manual requirements as late as ,
| |
| ' December '83 Discussions with Pullman Field Engineers I Dale Warren and Larry Werner indicated that although the i l
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| ' tables had been recently updated, they stf11 do not meet '
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| A15C Manual mquirements. (4/26/M Lockert Aff, at 5-6.)
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| b) Field Engineer Dale Warren issued the proper Washer !
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| Criteria for erself without notification or acceptance by '
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| Pullman or PGal 04 Departments. QA/QC Manager Harold 4 i
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| ' Kamer when notified of out of date Washer Criteria in ESO '
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| 243, dId not issue a Non-Confomance Report nor update the !
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| present ESD 243. (4/26/M Lockert Aff. at 7.)
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| c) Pullman did not have the proper Torque Tables in effect l three years after the writing of NCR DC2-80-RM-002.
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| l (4/26/M Lockert Aff. at 7.)
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| \
| |
| : 11. Defects in bolts wem not reported per a NCR. I was WIEble to mport ther defects I had found in A-490 bolts l because I uns not allowed to consult the procurement l documents needed to ~
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| Pullman Supervisor, groper as Ne 1p generate such le specifically a report.
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| prevented me '
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| i sayin I
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| ! from of referencing g area. (See Oct.17 theseindicent documentsofby(sic) LockertgLetter that I was out :
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| Pddressed to Mark Padovan, U$letC dated 1/2/M.) (4/26/84 Lockert Aff. at 7.)
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| 1ssed .i. l L _ _ _ _ _ _ _.__. ~ _ . . . - - - - - - - - - " - -
| |
| | |
| 3 None of these allegations am new and all have been responded to previously. The allegation about the use of washers was previously answered in reply to INtc $$ER 22, allegatioh #129G (DCL-84-186, May 17,1964). That answer said, in part, that:
| |
| "This allegation has been addressed in PGandE response dated March 19, 1984, to Joint Intervenors' Motion to Roopen on CQA Geske et al. Aff. at 22-23. As stated in the response,,the puI1EnTs0 was more conservative than the current industry standard. Because ESD 243 was more than adequate, there was no pressing need to advise a11 other inspectors of a pending revision. ESO 243 is in the process of being revised..."
| |
| Although when initially submitted, it was intended to conform the revised ESD to the present ASTM A 436 industry standard, subsequent discussions have indicated that full-scale adoption of this standard cannot be achieved. However, the revised ESD will explain the acceptable washer criteria in sufficient detail to ensure that all insta11attons are accomplished in an acceptable menner.
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| The issue of acceptance criteria for high strength bolts has been previously addressed in response to NRC aIIegation #242 (DCL-84-195, May 29,1984).
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| The response to J! #118 states:
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| : 45. Not only is the allegation in the Motfon incorrect, it is not supported by the underlying Lockert afffdavtt.
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| Mr. Lockert said nothing about tne procedure covering installation of pipe rupture restraint bolts." The 15944 ,
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| _ . , , . , . - . , . .,--,,,----~--------er-+wm-~ *~'~*~^'m^"*'--
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| | |
| [
| |
| affidavit refers to the criteria for accepting or rejecting the bolts, not the pmcodure for installing them.
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| : 46. The affidavit strites that there were no rejection criteria for ti:e bolts in ESD 243. This is correct.
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| The criteria for accepting bolts are procurement )
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| criteria and, as such, they would not be found in ESD 243. The correct action for Mr. Lockert to have taken was to reject the bolts with the " visible
| |
| - forging laps" - which he did - and then refer the rejection to receiving-QA perscrtnal to determine whether the bolts met acceptance criteria, an action which he did not take. As a Pullman Field QC Inspector, checking procurement specifications was outside the scope of both his training and job duties. This was exactly what Mr.' Lockert's supervisor told him. He was at no time told to accept the bolts because the rejection criteria were not in the ESD, as alleged in Mr. Lockert's affidavit.
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| : 47. The acceptance criteria for the bolts are properly specified in the procurement documents. The acceptance criteria for the installation of bolts are contained in the ESD. Thus, the allegation that there were no " rejection criteria" is simply not true.
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| Once again, intervenors have resubmitted an issue previously addressed under the guise of a "new" allegation. It is neither "new" nor true.
| |
| The issue of bolt torque tables is also not new. Pullman Power Products, in a letter to PGandE's R. D. Etzler, dated July 19, 1982, expressed their concerns and questions about the bolt torque tables in ESD 243. PGandE provided the values to tighten all future rupture restraint bolted connections in letters dated February 22,1983, and March 14,1983. . .The letter used the AISC Manual 7th Edition dated February 4,1976, as a mference. The values issued in the referenced letters have been used since February 22, 1983.
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| 1594d -
| |
| ,e ve - ,,--- - ---e -,.m,. _ ,---,_e _,_,_.--,-,,,,,4.,,,,,
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| ,,L - - - - -,,n .,,_~,,n,..
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| ,,,, ,-__------,n, . - - - - - , - - - - - - - , - - - - - _ - - - - - - - - - -
| |
| | |
| i l
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| 1 1
| |
| The process sheets for tightening of rupture restraint bolts reflect the values specified by PGand since February 22, 1983. These process sheets are reviewed and approved by both Pullman QA and PGand prior to field issue and work implementation. The applicable documentation package for each specific restraint includes a reference to the PGand requirements.
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| The values for tightening bolts on rupture restraints, as specified by PGandE, are indeed in effect and are in accordance with the AISC Manual to the applicable as explained in response to Allegations V-34 and V-38 above.
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| t l
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| l 1594d 1 l
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| - - . - - - - - . - - - - - - - - - -- 1
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| | |
| l v-4o It is alleged that:
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| : 9. Pullman Power Products did not develop nor implement a program to control design changes.
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| i a) Design Drawings did not reflect unauthorized modifications to fillet welds because no As-Built Drawing was generated by Engineering when they were notified of such modifications. (4/26/84 Lockert Aff. , a t 6-7. )
| |
| This allegation has been previously addressed in PGandE's response, dated March 19, 1984, to Joint Intervenors' Motion to Reopen on CQA, Bretsmeister, M., Aff. at 38-39. The fillet welds in question am actually fillet caps over full penetration welds. They were in excess of the weld size required by design.
| |
| Mr. Lockert asserts that unauthorized grinding occurred on these American Bridge shop welds on a ruptum restraint. The grinding was perfonned in order to allow adjacent bolts to be properly installed.
| |
| American Bridge drawings usually include specific instructions regarding the grinding of welds to allow bolt installation. All grinding is in accordance with these drawings. If grinding is required, the operation is controlled by a process sheet. In those cases where the drawing does not address grinding, a design question (DQ) is forwarded to PGandE for evaluation of whether grinding can be allowed.
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| 1633d . - . .
| |
| | |
| In general, ary oversize weld my be ground to the acceptable size to improve cosmetic contour, or to peruf t bolts, nuts and other mating parts to fit, without changing the applicable drawing.
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| 1 i
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| l I
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| l 1633d . . .. . __. ..
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| | |
| l l
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| v-43 It is alleged that:
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| : 10. Pullman did not train nor indoctrinate inspectors to the requirements of the AISC Manual for Bolting.
| |
| (Accidental reinspection of work accepted in late '82 or early '83 revealed hole sizes outside the tolerances of the AISC Manual.) (4/26/84 Lockert Aff. at 7.)
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| Mr. Lockert refuses to accept the fact that the PGandE-approved procedures, such as ESD 243 for rupture restraints, contain the criteria to which the inspectors are required to inspect and there is no need to review the AISC code, as he states.
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| On-the-job training as well as testing on the requirements of ESD 243 are given to inspectors working on rupture restraints. ESD 243 includes the bolting requirements for rupture restraints. This procedure is available in the field for the inspectors' use should ag question arise. The inspectors, including Mr. Lockert, inspect the holes to the criteria of ESD 243 and the design drawing. If the holes exceed these tolerances, then the condition is identified to PGandE for disposition.
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| ; Lead men, engineers, supervisors, and PGandE personnel are also available to answer questions and provide interpretation of the requirements. Mr. Lockert, during his time on the job, availed himself of all these avenues.
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| 1646d .
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| | |
| V-45, 46, 47, 48, and 49 It is alleged that:
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| ITEM #1, Tag. #2: Elevation 116. Unit 1 Reactor Building.
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| Line Designation NO.52-254-10, in the area of Pressurizer and Reactor Coolant Pump 1-2.
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| Problem
| |
| | |
| == Description:==
| |
| Neld attaching Safety Injection accumulator 11ne to nozzle of the cold leg line (N0.52-254-10). On the side facing Reactor Coolant Puup (RCP) is a grinding gouge in the pipe at the pipe-weld interface approximately 3/8 inches long,1/8 inch at widest point and 1/16 inch deep (dimensions as visually determined by NRC Inspector - no measurements taken). Additionally, there appears to be a slight amount of undercut at two locations. The undercut is approximately 5/8 inches on the weld side facing the RCP and approximately 1 inch at 1200 from the side away from the RCP.
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| Code Violation: American Society of Mechanical
| |
| ' Engineers (ASPE) Section III, " Rules for Construction of Nuclear Power Plant Components - 1977 edition, Division I General Requirements, Subsection NB, " Class 1 Components", para NB-4424 " Surfaces of Welds",
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| "As-welded surfaces are permitted, and for piping the '
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| appropriate stress indices given in Table NS-3683.2-1 shall be applied. However, the surface of welds shall be sufficiently free from coarse ripples, grooves, overlaps, and abrupt ridges and valleys to meet (a) through (f) below:
| |
| (a)...
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| (b)...
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| (c) Undercuts shall not exceed 1/32 inch (0.8m) and shall not encroach on the required section thickness.
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| (d)...
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| l (e)...
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| (f)If the surface of the weld requires grinding to meet the above criteria, care shall be taken to avoid reducing the weld or base metal below the required thickness."
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| 1638d ,. _
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| | |
| The discrepant condition identified by the witness violates the code requirements with respect to being " free from coarse ripples, grooves, overlaps, [ sic] and abrupt ridges and valleys to meet (c) and (f)." (4/17/84 Parks Aff, at 1-3.)
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| ITEM #2. Tag #4: Unit 2 Reactor Buf1 ding, Elevation 115, '
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| support 97-3R in vicinity of RCP 2-3.
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| Problem
| |
| | |
| == Description:==
| |
| " Excessive overweld has caused excessive snrtntage of SS line. This was supported to be a full penetration weld with fillet cap and is as specified. The overwelding can damage the pipe because calcultions don't account for residual stresses caused by such overwelding."
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| Code Violation: United States of America Standard
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| 'USAS bower) Piping" (note:531.7-1969 " Code for Pressure Piping - Nuclear this standard now is known as ANSI-831.7), foreword " FABRICATION REQUIREENTS AND THEIR CORRELATION WITH DESIGN", page XVI paragraph 5.
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| "Even hanger attachment detafis are covered. For Class 1 piping, complete penetration welds are required. The designer must consider all stresses in the attachment as well as their effect on the-pressure retaining part."
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| The welds in question do not confom to the stated intent of the " Nuclear Power Piping" code with respect to the residual stresses induced by the overwelding.
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| It is the concern of this particular anonymous witness that these residual stresses should have been but were not a factor in the design calculations. (4/17/84 Parks Aff. at 3-4.)
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| ITEM #3. Tag #5: Unit 2 Reactor Buf1 ding, large restraint wall. attachment (around surge line), beneath Unit 2 Pressurizer.
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| Problem
| |
| | |
| == Description:==
| |
| "Shopwelding is supposed to conform to AN5 Dl.1 standards. The inner welds are excessively rough and of a such a profile that they would not confore to AWS D1.1. The welds are ragged."
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| Code Violation: American Welding Society (AWS)
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| Structural Welding Code - Steel, paragraph 8.15 1638d )
| |
| | |
| " Quality of Welds", subparagraph 8.15.1 " Visual Inspection." "All welds shall be visually inspected.
| |
| A weld shall be acceptable by visual inspection if it shows that 8.15.1.1 The weld has no cracks 8.15.1.2 Thorough fusion exists between adjacent i
| |
| leers of weld metal and between weld 1 metal and base metal 8.15.1.3 All craters are filled to the full cross section of the weld 8.15.1.4 Weld pmfiles are in accordance with (para.) 3.6 Lweld profile]"
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| The weld in question does not confom to the requirements specified in paragraph 3.6 [ weld profiles]
| |
| or the evident thorough fusion requimments as stated in 8.15.1.2 (4/17/84 Parks Aff. at 4-5.)
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| ITEM #4 Tag #6: Unit 2 Aux 1111ary Building, area GW, elevation 115, line No. 2-S2-265-8 (Containment Spray Discharge Pipe - 4 lug attachments between S and T line.)
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| Item _
| |
| | |
| == Description:==
| |
| " Lug attachments are called out to se in incn niset welds on three sides. Actual size is 7/16 inch fillet or less."
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| Problem
| |
| | |
| == Description:==
| |
| " Actual size is alleged to be less than or equal to 7/16 inch which is 1/16 inch less than required. The excessive welding used in the design of the lugs attachment welds, when welded to Schedule 1D stainless thin wall pipe, has caused l
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| ' excessive shrinkage. The excessive shrinkage causes residual stresses in the pipe which has not been accounted for in the design or stress analysis. The position of the clamp is such that there is a torsional
| |
| ! force applied to the lugs, because the clamp cannot contact the wall of the pipe due to the shrinkage.
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| l This torsional force is not accounted for in the design and compromises the pipe integrity."
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| l 1638d - _ _ _ _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ - - ~ _ _ _ _ . _ _ _ _ _ . . . _ _ _ _ . _ . _ _ . . . _ . _ _ _ _ .
| |
| | |
| Code Violation: Refer to " Code Violation" discussion in uut rz, Tag M". The welds in g estion do not conform to the stated intent of the Nuclear Power Piping" code with respect to the residual stresses induced by the welding or the torsional force applied to the lugs due to excessive shrinkage. It is the concern of this particular anonymous witness that these stresses should have been but were not a factor in the design calculations. (4/17/84 Parks Aff. at 5-6.)
| |
| ITEM #5. Tag # 7: Unit 2, Auxiliary Building, Area 2H, support 413-131R arou M CCW line.
| |
| Problem
| |
| | |
| == Description:==
| |
| "Eight lug attachment welds are required to De full penetration welds on three sides.
| |
| Actual weld is not a full penetration weld, but is, instead a fille' weld, contrary to the design."
| |
| Code Violation: American Welding Society (AWS) - A2.4
| |
| - Is symbols for Welding and Non-Destructive Testing," paragraph 9.0 " Groove Welds," subparagraph 9.2.2 " Complete Joint Penetration Required." "When no depth of groove preparation or effective throat is shown on the welding symbol for single-groove and symmetrical double-groove welds, complete joint penetration is required.
| |
| Symbolgrovidedon
| |
| [ i
| |
| \ \ " Detail for weld (s) in question.
| |
| PGandE has stated in their letter, DCL-84-040, "The weld symbols used at Diablo Canyon are consistent with the standards specified in AWS..." and in an Interoffice Memorandum " file no. 930,146.20, CA2) dated October 25,1983 that "all pipe support as-builts issued by General Construction after October 15, 1983 should have all weld symbols in conformance with AWS A2.4."
| |
| 1638d - - __ - _ - ,
| |
| | |
| The welds in question were incorrectly performed because of lack of proper interpretation of the j
| |
| weld symbol utilized on the design drawing. It 1 is the concern of this particular anonymous '
| |
| witness that this discrepancy provided an example of code compliance violation due to a lack of intimate knowledge with AWS A2.4. These particular welds had been inspected and accepted by Pullman Quality Control and PGandE Quality Control prior to the discrepancy being identified by a Pre-Inspection Engineer. (4/17/84 Parks Aff. at 6-7.)
| |
| These allegations previously have been fully responded to in PGandE letters to the NRC, DCL-84-170, dated May 2,1984, and DCL-84-200, l
| |
| dated June 1,1984. These letters answered the questions which were raised during the midnight tour on the night of April 11, 1984.
| |
| l r
| |
| I e
| |
| i 16m _ _ _ _ _ . _ . _ . _ _ _ . ~ . _ _
| |
| | |
| l V-50 It is alleged that:
| |
| On page 1 of the 4/17/84 statement, under Item 1, Tag #2, a weld (RC-2-16) was identified on the Safety Injection Accumulator line as having a grinding gouge and was undercut. This condition is in violation of ASME III para.
| |
| with respect to the undercut and the " grinding gouge."15-4424"SurfacesofWelds"I4/30/84ParksAf
| |
| . at 1. )
| |
| This allegation is based upon the entire eight-page Affidavit of Richard D. Parks, dated April 30, 1984. Contrary to the allegation, the non-linear indication at Weld RC-2-16 on the Safety Irdection Acciseulator Line is neither a gouge nor an undertut.
| |
| This subject has been addressed in two PGandE letters to the PRC:
| |
| No. DCL-84-170, dated May 2,1984, and No.. DCL-84-195, dated May 29, 1984 DCL-84-170 was prepared in response to the items identified on April 11,1984, by the anonymous allegers, and DCL-84-195 was prepared in response to the GAP III and IV petitions. For the third time, the weld is acceptable.
| |
| The allegation relates to a condition that was pointed out during the NRC-sponsored plant tour conducted the night of April 11, 1984. The day after the tour, the weld was ir.4pected by two welding engineers who are AWS certified welding inspectors. The alleger apparently 1
| |
| thought that a slight difforence in thickness between the flattened weld crown and outside well of the pipe was an undertut. However, he was mistaken. The difference was not an undercut, but the rusult of I differences in the outer dimensions of the welded pipes. I 1
| |
| 1492d .- -- - .-- . - . - - - -
| |
| | |
| l The welding engineers also identified a mark in the pipe fitting just below the field weld which was not an undercut. The metal was unifomly discolored with no bright metal exposed. The mark was present in the fitting prior to the field weld completion. i Contrary to the allegation, it can be detemined that minimum wall thickness requirements have been maintained. The depth of the alleged gouge area in question has been detemined by mechanical measurement to be 0.031-inch deep. Engineering review has detemined that the 10-inch diameter schedule 140 pipe has a nominal wall thickness of 1.000 inch with a manufacturing tolerance of minus 12.55, which my result in a minimum wall thickness of 0.875 inch, r The design requirement for wall thickness for this line, based on pressure and temperature considerations, is 0.748 inch. As stated above, the depth of the ground area is 0.031-inch deep. Based on a worst case of 0.875 inch, minus 0.031 inch, a reserve margin of 0.096 inch still exists above the minimum design wall thickness requirement. The weld condition is proper.
| |
| l t
| |
| ; Since the remainder of the affidavit draws conclusions based upon the incorrect assumption that Weld RC-2-16 was defective and upon facts contained in public documents written by both the NRC staff and PGandE, the mconnendation for a comprehensive reinspection is without merit.
| |
| 1492d I
| |
| VI-1, VI-3 and VI-5 It is alleged that:
| |
| The allegations concern stresses on the concrete from Hilti Quick [ sic] Bolts which may result in failures of the bolts themselves. The alleged conditions include--1) deep embedment; and 2; failure to consider the possible design offects when bolts are installed too close to the back of other bolts from opposite sides of concrete walls.
| |
| The particular examples am on safety related work, specifically in the GE area, 85 foot level elevation in the Auxiliary Building just outside the containment wall. They help support an anchor-type hanger in Component Cooling Water (CCW) system 14. The witnesses described these specific examples as illustrative of a generic condition.
| |
| Tne problems have been reported on Quick Fix process sheets and recently on a Deficient Condition Notice (DC4). There still has not been effective corrective action, although one witness estimated that the problem should have been reported to the RC with in [ sic] 24 hours under 10 CFR Part 21 due to its potential to cause failure in a safety-related system. The witness was deeply concerned l
| |
| with the potential for the bolts to shake right out of the wall during an earthquake, unless there is a full review and any necessary corrective action. (5/22/84 Devine Aff. at 1).
| |
| The first alleged problem is that bolts were embedded a minimum of 10.5 inches into concrete that was only 12 inches thick. Although the witnesses were not aware of specific calculations to demonstrate whether this condition were [ sic] acceptable, I was infomed that unacceptable msidual stresses can result if bolts are embedded too deeply into the concrete. Allegedly an inspector on-site has re were [ sic]
| |
| quested considered relevant butback-up has notdata to see received any if the problem response.
| |
| Mr. Stokes infomed me that at most nuclear plants in his experience the concrete is 24 inches thick when embedeent is that deep.
| |
| I was told that the origin of the problem was instructions on design drawings to achieve a minimum of 10.5 inches embedmont. Allegedly the deep embedment had been considered necessary to achieve the required strength for the structural loads--the hangers. The potential problem nds on whether the consequences from excessive nt also were taken into account. As one witness 1610d l
| |
| ~ ~ ' ~ ' ~ ~ ~ ~
| |
| | |
| said, "It doesn't do much good to fix one problem by cmating another that may be worse." (5/22/84 Devine Aff.
| |
| at 2.)
| |
| They also were concerned that the corrective action at the time was ineffective. The " solution" was to " dry pack" the voids left when the concrete fell out. " Dry packing" means applying filler to the void that does not have any structural value. In other words, %e corrective action was ineffective from a design perspective and was only applied to a few examples for a potentially generic condition. (5/22/84 Devine Aff. at 3.)
| |
| These concrete expansion anchor concerns were previously addressed in response to NRC questions transmitted by PGandE letter DCL-84-203, dated June 1,1984. Recapping the previous response: Questions have been raised regarding the adequacy of Hilti Kwik-Bolt expansion anchors when (a) embedded deeply into thin concrete elements and (b) installed in close proximity to each other from opposite sides of concrete elements. As specific field problems occurred relative to these subjects, engineering evaluations wem made on a case-by-case basis.
| |
| Regarding question (a). Diablo Canyon expansion anchor installation criteria do not limit the depth to which Hilti Kwik-Bolts may be installed. Hilti engineers have mcommended to some of their clients that the embedment depth be limited to 805 of the concrete element thickness. This recommendation is based on Hilti's judgment that deeper embedeents may result in concrete spalling on the back side of the concrete element when hammering the anchor into the hole.
| |
| Neither Hilti nor PGandE is aware of arty analytical or test data that 1610d I
| |
| | |
| s l
| |
| l validate this recommendation. Further, Hilti has not published this recommendation as it is not considered to be an installation requirement but rather an optional precautionary measure.
| |
| +
| |
| At Diablo Canyon, QC inspectors noted a few cases in which concrete was spalled during installation of Hilti Kwik-Bolts in a thin (12-inch) slab. The spalling occurred either while hassering the bolt into the hole or during the torque-setting operation.
| |
| Subsequent inspection found that the spalled concrete did not extend ,
| |
| into the concrete surrounding the anchor wedge. The anchors were set in accordance with normal installation procedures and held the final torque, 360 ft-1b. The spalled areas were then repaired by drypacking. The drypacking precedure was followed simply to preclude any'ironmental exposure.
| |
| Anchoring of Hilti Kwik-Bolts is achieved by forcing spring steel clips at the wedge-shaped base of the anchor into the surrounding concrete. Expansion anchors are not loaded in compression, so the concrete below the clips carries no load. Further, spalling of the concrete below the clips does not affect the strength of the concrete shear cono that anchors the bolt when it is subjected to tensile l
| |
| loads. While spalling of the concrete below a Hilti Kwik-8olt is not desirable, it does not affect the adequacy of the anchor. Thus, there is no technical reason to limit the depth of embedmont.
| |
| 1610d 1 i
| |
| | |
| Regarding question (b) Diablo Canon expansion anchor installation f procedures do not require mapping of anchor locations on opposing sides of concrete elements. In practice, it would be difficult to accomplish this mapping within the accuracy necessary to identify close spacing of anchors on opposite sides of walls and slabs. Since most of the concrete in the safety-related structures at Diablo Canon is thick (greater than 12 inches), and most of the expansion anchors require installation at relatively shallow embedments (less than 6 inches), the potential for this type of overlapping to occur is extremely low.
| |
| Hilti is currently perfoming tests to quantify the effects of closely spaced anchors installed in opposite sides of concrete elements. These tests are being perforised at the mquest of another utility and are being monitored by cognizant NRC personnel. A final report is not expected to be completed until August 1984, but i
| |
| preliminary indications are that there is no significant reduction in f anchor strength, even when the anchors are installed as close as 1-1/2 bolt diameters (center-to-center). These preliminary results l
| |
| support the judgment of the Hilti engineers (and that of PGandE Engineering) that an overlapping condition has a negligible effect on the adequacy of the anchors.
| |
| l l
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| l 1610d 1
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| -- .. -. -.- - - . . - - , . . . - - . - - - - - . .~.- -.-.- - --- - .---..--- . , ,
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| | |
| VI-2, VI-4 and VI-6 It is alleged that:
| |
| Beyond technical significance, if true the accounts below of the two major bolting issues demonstrate the ineffectiveness of the Quick Fix and Quality Control (QC) mporting systems to identify, disclose and correct all rehted deficient conditions. They also demonstrate a pattern of maragement non-response to a significant issue that has been raised repeatedly over the last year. Both the effects -- bolting -- and the cause -- mismanagement --
| |
| should be corrected before Diablo Canyon-goes casamercial.
| |
| (5/22/84 Devine Aff. at 2.)
| |
| The nature of management's response may be as signficant as the bolting problem itself. Last June a QC inspector identified the issue to Pullman Power Products (PPP) engineers. Despite recognition of specific problems and individual generic corrective ccndition action--the was never use of "thru-bolts"--the addressed.
| |
| i Last June 28 a different inspector allegedly also identified a similar problem, but in this instance a Pullman engineer disregarded the warning and responded that structural integrity would not be effected [ sic].
| |
| Unfortunately, the engineer was mistaken. During installation, concrete cones directly beneath three relevant bolts suffered a structural failure: the concrets popped cut. The allegers were concerned that the concrete failure could cause the bolts to fail as well. (5/22/84 Devine Aff. at 2-3.)
| |
| In 1983 Pacific Gas and Electric (PG4E) engineers also were alerted to this problem and instructed the relevant Pullman engineer to resolve it. As seen by the recent DCN, i however the problem wasn't resolved. The new DCN allegedly was filed several weeks ago but Pullman i
| |
| management has not msponded. The witnesses inquired whether Pullman is violating the NRC 24 hour reporting requirements for significant conditions. They told me that for all practical purposes the embedmont problem is the j
| |
| < same as last year, and the quality of the bolting remains indeterisinate after three attempts to work within the system.
| |
| Allegedly the DCN author raised an ancillary question whether there was any design consideration for the
| |
| ! structural effects when Hilti Quick Bolts are embedded too closely to each other from opposite sides of the concmte.
| |
| 1620d In that circumstance the zones of structural influence from the bolts might conflict, leading to the possibility of structural failure such as cracking and resulting voids on the concrete. As with the embednent problem, the witnesses 1 were concerned that this could cause failure of the bolts i themselves, and compromise the hangers and the lines being supported.
| |
| The anonymous witnesses stated that in fact there have been instances when bolts from one side had been hit during the drilling and installation of bolts from the opposite side.
| |
| Those types of conditions were found as late as last fall.
| |
| The occurrences suggested to the witnesses that design control had been inadequate to prevent the conflicts.
| |
| The witnesses told me that both technical issues were identified on Quick Fix process sheets. In fact, the bolting embedment was verified by QC inspectors and placed on the back of Quick Fix sheets. But the relevant as-built drawings do not reflect this specific information. They only reference the 10.5 inch minimum requirement. As a result, specific information on the Quick Fix sheets was factored out of the as-built reviews.
| |
| The witnesses emphasized that the specife examples may be t
| |
| generic because so many other instances of voids, cracks, l -buried drain pipe, foms left in concrete and dry packed knock outs are still being Identified in the field.
| |
| (5/22/84 Devine Aff. at 3-4.)
| |
| These allegations identify two specific cases of field problems dispositioned by PSDTCs. In the first specific case, the PSDTC disposition substituted through bolts for the concrete anchor bolt required by the original design. The through bolt installation exceeded the original design requirement in its ability to support
| |
| ! load. The second specific case occurred on June 28, 1983. In this l case concrete chipped out below the bottom of the concrete anchors
| |
| ! and was again identified by the PSDTC process. The condition was f evaluated and dispositioned to leave the anchors installed since the l
| |
| l chipped concrete was below the bottom of the anchors and the anchors 1620d _ - - - - . .
| |
| | |
| . 1 wem set and torqued thereby achieving an acceptable installation.
| |
| In neither of these cases did engineering evaluation determine that an NRC reportable condition existed or that a " generic" problem existed. Based on engineering evaluation, no problems existed and, as such, these construction matters were not brought to management attention. Construction expansion bolt problems continued to be handled on a case-by-case basis.
| |
| 1 Approximately one year later, May 4,1984, a Pullman QC inspector expressed his " concern" about an expansion anchor problem. He used the Pullman Deficient Condition Notice (DCN) as a vehicle to express his " concern." He also contacted the hotline program and cited these two specific cases as typical of his " concerns." The DCN was not '
| |
| written by either of the inspectors who were involved with the actual installation. Neither inspector had doctamented arty concerns with respect to the resolutions of either installation. '
| |
| Management msponded by reviewing the. engineering evaluations performed for the previous PSDTCs. Included in this re-evaluation I
| |
| were all the questions and concerns identified by the originator of the DCN. A summary of this re-evaluation was provided in response to NRC inquiries and is recapped in msponse to Allegations VI-1, VI-3, and VI-5. The re-evaluation again concluded that no unsafe condition or " generic" problem exists. The individual uno originated the DCN has been contacted and the disposition of his " concerns" is being discussed.
| |
| 1620d _ _. _ __ - . - - - - . . - . . - _ _ _ _ _ _ _ _ _ . - , _ - _ _ - - _ - , -
| |
| | |
| The fact that individual instances of installation problems are identified and resolved on a case-by-case basis indicates that appropriate inspections and controls that are so important to a sound construction quality assurance program are being implemented.
| |
| Management's response and subsequent engineering re-evaluation illustrates its fim comunitment to a sound quality assurance program.
| |
| l I
| |
| l l
| |
| i i
| |
| I
| |
| )
| |
| 1620d !
| |
| ~~
| |
| - - - _ , _ - - _ _ _ . - , _- - . . - - - - - - - - - - . - - ~ . - - - - - - - - - - - - - - - - - - - - -- ~ ~ ' ~ ~ ~ ~ ~ " ~ ' ~ ~ ~ ' '
| |
| | |
| VI-7 i
| |
| It is alleged that:
| |
| Probiem #1: During the "As-butit Inspection", the responsible QC Inspector identifled that the 5/8" studs holding the valve motor to the seismic valve support plate (piece #1, Attachment 1 page 9) had never been replaced.
| |
| These studs were required to be changed by the original Design Change #0C-2-E-P-10544, (refer to Note #2 Attachment
| |
| #1, page 7). This deficient condition was doctmented on a DCN (Attachment 1 page 16) and identified that a Deviation Report should be submitted to PG4E. This should have resolved the over ridden [ problem; however, sic) and his the original DCN changed by A. inspector Weinsteinwas on 2/27/84. A Weinstein's justification for his action is described on page 17 of Attachment 1.
| |
| The individuals that I reviewed this problem with informed me that the reason the studs had to be replaced was 1) due to the addition of a 1/2" support plate being bolted to the motor housing, it was necessary to ensure sufficient projection of threads, and 2) the existing old studs had visible indication of damaged threads. Apparently the craft, when disassembling the valve to make the modification, had used vise-grips to back the studs out of the motor. Thus to ensure adequate strength with respect to fastening / torque requirements the studs should have been j rwplaced. They were not.
| |
| | |
| == Conclusion:==
| |
| If the threads on the studs in question were in fact damaged, they should have been replaced. Paragraph 3 on page 36 Attachment 1 identifies that if an doubt existed on the studs, " good maintenance practice { would have been to replace them. Unfortunately, they were not.
| |
| (5/22/84 Parks Aff. at 2.)
| |
| l Tne QC inspector properly documented that the studs had not been replaced when he performed the final as-built inspection. The requirement for stud length is that they must be of a length sufficient to provide for full nut engagement when the nut is torqued. TM existing studs meet this requirement. The studs need '
| |
| not have been replaced because the studs installed were of adequate 1523d _ .__ _ _
| |
| | |
| length to ensure full nut engagement after the 1/2-inch plate was installed. Therefore, the engineer properly dispositioned the DCN.
| |
| This was confirmed by a Pullman meno dated February 27,1984, and approved by PiGC.
| |
| The Attachment i refemnced in the affidavit is a portion of PGandE's Department of Nuclear Operations Environmental Qualification Maintenance Training Manual. The manual and NUREG-0588 address the environmental qualification of the valve, not its seismic mounting.
| |
| The documentation package for Hanger 413-143SC and DCN 1350-011 have been reviewed. These documents have no notation of " Damaged Studs."
| |
| In addition, these studs were inspected by PGandE and the NRC Staff on June 27, 1984. All nuts have full thmad engagement. One stud has indication of one flattened thread at the end of the ' stud. This is very minor in nature. This thread is approximately 1/2-inch past the nut. It was obvious that the minor flattening was not caused by
| |
| " vise grips." The studs are acceptable and meet all bolting criteria.
| |
| 1523d VI-8 It is alleged that:
| |
| Problem #2: The uncontrolled disassembly of an EQ Nuclear Safety Related Valve without use of a controlled procedure resulted in damage to the valve and discharge of personnel involved. This is documented on pages 35 and 36 of Attachment 1. This incident resulted in the generation of an MVR; that was deemed to be only a violation of Project Instruction #8 (Tagout Procedure) and a "PPP in-house ljon-Compliance Report". However, ti:s MVR was marked as not mportable" and "not a Non-Conformance", despite its relevance for NUREG-0588 compliance.
| |
| | |
| == Conclusion:==
| |
| Due to the significance of the valve and the conflicting statements on reportability, it should have been deemed " reportable" and reported to the NRC.
| |
| (5/22/84 Parks Aff. at 2.)
| |
| The valve was not disassembled. The nuts holaing the hanger plate were removed. The valve motor operator and the valve body separated when the motor was operated.
| |
| The MVR properly identified the real problem as safety of personnel, i
| |
| not a problem with improper disassembly as alleged. This concern has no relevance to NUREG-0588 as claimed.
| |
| Each construction mishap is not required to be reported. The incident referenced was properly documented in accordance with the QC program.
| |
| The primary reason for discharging the personnel involved was violation of the clearance and tagging procedure. The Project's first priority is safety. The process sheet specifically stated that P
| |
| 1522d .
| |
| e a - - - - , , - - . . , , _ ,,_____,,y,____ _ _ - - _
| |
| . - _ , _ , _ _ , _ , , , , ,,,,,..__,._-,,--.,_.__,,____.,_.,._.__._,,-._,-.._,.,_---._m-
| |
| | |
| . 1 I
| |
| Engineering must be contacted to arrange for a safety clearance. The Personnel involved ignored this requirement and were terminated for cause.
| |
| Unfortunately, the person that provided Mr. Parks with the documentation copied Minor Variation Report M4490. Had he copied the revised MVR M4490-R1, it would have been apparent to Mr. Parts that NCR DC2-84-RM-N003 was generated to resolve any further problems identified during valve support installations.
| |
| Finally, the subsequent documented inspection and repair of the valve demonstrates that the environmental qualification of the valve has been maintained.
| |
| l l
| |
| l l
| |
| i 1522d l
| |
| | |
| VI-9 It is alleged that:
| |
| Problem #3: Attachment 1, page 38, "EQ Effects on Maintenance" states in part ... provide detailed description of maintenance work perforised as input for failure analysis (trend) stu#."
| |
| However, a review of Valve Maintenance Report (fMVR [ sic) -1845), Attachment 1 page 41, does not include a listing of "what damaged parts were repaired or how they were repaired." (5/22/84 Parks Aff. at 2-3. )
| |
| The repair of the Unit 2 valve was not necessitated by deterioration or failure due to operating conditions; therefore, detailed descriptions of maintenance work perforised as input for failure analyses (trending) stu# is not required.
| |
| The section of NPO training manual entitled "EQ effects on maintenance" addresses the requirement that EQ equipment be qualified for the operating life and when exposed to radiation, tamperature, chemical spray, high energy line break, etc. The requirement to provide detailed description of maintenance work perforined is part of a failure analysis " trend" stu@. The trend stu @ is used to evaluate repairs that are necessitated such as exposure to radiation, temperature, high-energy line break, etc. None of these conditions exists in Unit 2 at this time.
| |
| As stated in the training manual, " Materials considered susceptible to postulated worst case environment are all from nonnotallic groups. Examples which we will encounter are: motor and cable
| |
| ) 1521d . . _ _ _ . _ _
| |
| | |
| l l
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| l installations, lubricants, seals, molded switch materials, gasket materials, and special conductor teminations."
| |
| In accordance with the EQ program, the portions of the valve which required EQ documentation were specified and the necessary gaskets replaced. This is shown by Item 7 of Exhibit A-1, page 41 to Mr.
| |
| Parks' affidavit. The only repair that was required was the removal of a small scuff mark on the valve stem threads. This was accomplished by stoning and buffing with emery cloth. The valve was then tested using written approved test procedures. All parameters were within approved acceptance criteria.
| |
| For Unit 1, NPO currently complies with NUREG 0588 as interpreted in SER Supplement 15. This program will be in place in Unit 2 prior to fuel load. In addition, General Construction has a test status log of all tests that am performed for both EQ and non-EQ equipment.
| |
| 1521d __ _ -. _ , . _ _ _ _ . _ . . _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
| |
| | |
| VI-10 It is alleged that:
| |
| Problem M: A letter from D A. Rockwell to P. Stiegen (Attachment 1, page 34) identifies that the practice of ,
| |
| installing seismic valve supports to EQ valves could be l i
| |
| violating EQ requirements. The letter requires Pullman Power Products (PPP) to respond and provide "a list of all seismic valve supports completed or presently being worked" ,
| |
| by March 5,1984. This is a problem because valves that l have alrea# been disassembled to install the seismic supports may have alrea$ violated EQ Nuclear Safety Related Requirveents and have gone unreported. In the instance of FCV-641 A, the violation occurred 10 months before the problem was officially " flagged" to PPP for EQ compliance.
| |
| | |
| == Conclusion:==
| |
| There is an apparent deficiency in PG4E's training program to acquaint personnel with the requirements of EQ and Nuclear Safety Related Equipment.
| |
| (5/22/84 Parks Aff, at 3.)
| |
| 1 .
| |
| As stated in the response to VI-8, the generic issue of training Unit 2 personnel has been addressed and resolved in accordance with NCR DC2-84-RM-N003. The EQ valves that were modified in Unit 1 were modified by Nuclear Plant Operations (NPO) in accordance with the EQ
| |
| ! Program.
| |
| I i.
| |
| I T
| |
| 1520d -
| |
| - vi e-- - - , . - %--g.y,e---,,.,.4%v _
| |
| | |
| UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter of e s. Oa275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY )
| |
| (Diablo Canyon Nuclear Power )
| |
| Plant, Units 1 and 2)
| |
| AFFIDAVIT OF D. B. MIKLUSH STATE OF CALIFORNIA )
| |
| COUNTY OF SAN LUIS OBISP0 The above, being duly sworn, depose and say:
| |
| I David B. Miklush, am the Maintenance Manager for the Pacific Gas and Electric Company at the Diablo Canyon Power Plant.
| |
| I l
| |
| 1
| |
| | |
| t . -*
| |
| )
| |
| l My responses to the following allegation numbers in PGandE Letter No.
| |
| DCL-84-243, dated June 19, 1984 are true and correct to the best of my knowledge, information, and belief.
| |
| 111-1, and III-2.
| |
| Dated: June 28, 1984 ,
| |
| ?f
| |
| _ 'O'. BT Miklush Subscribed and sworn to before me this 28th day of June, 1984 6 /N Wendy Sproul0 '
| |
| Notary Public in and for the City and County of San Luis Obispo l State of California l My commission expires Jur.e.30, 1986 l ,- - _-______________
| |
| l l OFFICIAL SEAL' l < V/ENDY $PROUL
| |
| , fe0TAire svetsc . CAut0#8vtA
| |
| ( <
| |
| kl4 lb!$ C9fSPD COUNTY
| |
| _ . ,_.- ? ' ? * # h_ f _f 2-I
| |
| ,p-~-- , - ---u ,-u.- - -- y
| |
| | |
| ~
| |
| UNITED STATES OF AMERICA NUCLEAR REGULATORY ComISSION
| |
| )
| |
| In the Matter of )
| |
| ) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY )
| |
| )
| |
| (Diablo Canyon Nuclear Power )
| |
| Plant, Units 1 and 2) )
| |
| )
| |
| AFFIDAVIT OF H. W. KARNER STATE OF CALIFORNIA )
| |
| ) -ss.
| |
| COUNTY OF SAN FRANCISCO )
| |
| The above, being duly sworn, depose and say:
| |
| l l I, Harold W. Karner, am Quality Assurance / Quality Control Manager for l the Pullman Power Products Corporation.
| |
| l l
| |
| l 6
| |
| 1519d - .. . . . . --- - . _ _ . _ _ - _ . - - . . . - _ _ _ _ _ . . - _ .
| |
| | |
| ~
| |
| l l
| |
| My responses to the following allegation numbers in PGandE Letter No.
| |
| DCL-84-243, dated June 29, 1984 are true and correct to the best of sqy 4 knowledge, information, and belief.
| |
| III-5, 6, 7, 8, 9, 10, 11, 12, 15, 51, 52, 57, 61, 62.
| |
| V-27, 28, 29, 39, 40, 41, 42, 43, 44.
| |
| VI-1, 3, 4, 5, 6 Dated: June 29,1984 ' ,
| |
| H. W. Karner Subscribed and sworn to before me this 29th day ~
| |
| of June,1984 U. NEAL MADISON NOTARY PUBUC --CAUFOURA CITY AND COUNTY OF
| |
| . SAN FRAhCISCO
| |
| [,7 h- /7df4 ,
| |
| m,r - - % on.27, toss Cynthia Neal madison Notary Public in and for the City and County of San Francsico State of Califo mia My commission expires December 27, 1985 l
| |
| I
| |
| | |
| UNITED STATES OF AMERICA NUCLEAR REGULATORY C0lWISSION
| |
| ) '
| |
| In the Matter of )
| |
| ) Docket Nos. 50-275 PACIFIC GAS AIO ELECTRIC ) 50-323 C0W ANY )
| |
| )
| |
| (Diablo Canyon Nuclear Power )
| |
| Plant, Units 1 and 2) )
| |
| )
| |
| AFFIDAVIT OF F. C. BREISMEISTER AND M. E. LEPPKE STATE OF (ALIFORNIA )
| |
| ) ss.
| |
| COUNTY OF SAN FRANCISCO' )
| |
| The above, being duly sworn, depose and say:
| |
| : 1. Fred C. Breismeister, am Manager of the Research and Engineering / Materials and Quality Services Department, San Francisco Area Office, for the Bechtel Group.
| |
| I, Ptyron E. Leppke, am Onsite Project Engineer for the Diablo Canyon Project.
| |
| 1 1519d _ _ _ _ . . .-. . _ .
| |
| | |
| Our responses to the following allegation numbers in PGandE Letter No. DCL-84-243, dated June 29, 1984 are true and correct to the best of our knowledge, information, and belief.
| |
| III-13, 14, 27, 28, 29, 30, 31, 32, 33, 34, 35, 36, 37, 38, 39, 40, 41, 42, 43, 44, 45, 46, 47, 48, 49, 50, 51, 55, 63.
| |
| IV-1.
| |
| V-25.
| |
| Dated: June 29,1984 '
| |
| _M k
| |
| . c. Bretsmeistcr M. E. Leppte Subscribed and sworn to before me this 26th day .. . l of June,1984 C. T. NEAL MADISON NOTARY PUBUC -CAL 50tNIA CITY AND COUNTY OF.
| |
| SAN FRANCISCO O T Med-hd'A~ 1 i. -
| |
| ~ c~ ~ " ""
| |
| ==unua--
| |
| cynthf a Neal-Madison Notary Public in and for the c City and County of San Francsico i State c.f California My consission expires l
| |
| December 27, 1985 l
| |
| l l
| |
| l ,
| |
| | |
| l l
| |
| l UNITED STATES OF AMERICA NUCLEAR REGULATORY COMISSION
| |
| )
| |
| In the Matter of )
| |
| ) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY (Diablo Canyon Nuclear Power )
| |
| Plant, Units 1 and 2) )
| |
| )
| |
| AFFIDAVIT OF L. E. SNIPLEY, R. G. OMAN, M. R. TRESLER., AND N. J. TUHOLSKI STATE OF CALIFORNIA )
| |
| ) ss.
| |
| COUNTY OF SAN FRANCISCO )
| |
| The above, being duly sworn, depose and say:
| |
| l I, L. E. Shipley, as Technical Consultant for Piping for the Diablo Canyon Prvject.
| |
| I, R. G. Oman, as an Assistant Project Engineer for the Diablo Canyon Project.
| |
| I, M. R. Tresler, am Assistant to the Unit 1 Project Engineer for the Diablo Canyon Project.
| |
| * I I, N. J. Tuholski, an a Civil Engineering Supervisor for the l Diablo Canyon Project.
| |
| I 1
| |
| 1641d l
| |
| : w. . - - - _ _ . - - - _ . . - . . - - - _ _ _ .- . _ _ . - -. __-
| |
| | |
| Our responses to the following allegation numbers in PGandE Letter No.
| |
| DCL-84-243, dated June 29, 1984 are true and correct to the best of our knowledge, information, and belief.
| |
| III-18, 19, 20, 21, 22, 23, 24, 25, 27.
| |
| V-1, 2, 3, 4, 5, 6, 7, 8, 9,10,11,12,15,16,17, 18, 19, 20, 21, 22, 23, 24, 26, 32, 33, 38.
| |
| VI-1, 3, 5.
| |
| Dated: June 29,1984 l_'_ 1 ,
| |
| I L.' E. snipiey 7 C (.un R. G. UNRn M. R. 7Fesler 1/ba N.7.Tuholski l
| |
| t l Subscribed and sworn to - - - - - - - - -
| |
| l before me this 29th day C. T. NEAL MADISON of June,1984 Nofm PUBUC -CAUFORINA CITY AND COUNTY OF l . SAN FRANCISCO
| |
| ~
| |
| W . Y.
| |
| Cynthia Neal-Madison Notary Public in and for the City and County of San Francsico
| |
| , State of California
| |
| % commission expires December 27, 1985 1641d - . .
| |
| | |
| l l
| |
| UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION
| |
| )
| |
| In the Matter of )
| |
| ) Docket Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY (Diablo Canyon Nuclear Power )
| |
| Plant, Units 1 and 2) )
| |
| )
| |
| AFFIDAVIT OF W. N. HARRIS STATE OF CALIFORNIA )
| |
| ) ss.
| |
| COUNTY OF SAN FRANCISCO )
| |
| The above, being duly sworn, depose and say:
| |
| I, W. N. Harris, was a Quality Assurance Manager at the Diablo Canyon j Power Plant for the Guy F. Atkinson Company.
| |
| l l
| |
| i -
| |
| 1641d . - - - - - _ - _ _ - _ . - . . - _ -_ . - _ . . . . . - . - _ - _.- -
| |
| | |
| % responses to the following allegation numbers in PGandE Letter No.
| |
| DCL-84-243, dated June 23, 1984 are true and correct to the best of my knowledge, infomation, and belief.
| |
| III-56, 58, 59, 59A, 60, 65, 66, 67, 68, 69, 69A.
| |
| Dated: June 29,1984 W. N. Harris Subscribed and sworn to before me this 29th day of June,1984 CT.E MDM
| |
| ~
| |
| /b
| |
| @ NOTMYy, PU30C my r CITY AND COUNTY OF g
| |
| -CAUF0
| |
| ""~~
| |
| Cynthia Neal-Madison Notary Public in and for the City and County of San Francsico State of California
| |
| % comission expires December 27, 1985 l
| |
| l I
| |
| l 1641d l l
| |
| l I
| |
| | |
| I UNITED STATES OF AERICA NUCLEAR REGULATORY CON 4ISSION
| |
| )
| |
| In the Matter of ) ,
| |
| ) Docket Nos. 50-275 i PACIFIC GAS AND ELECTRIC ) 50-323 1 C(WANY )
| |
| )
| |
| (Diablo Canyon Nuclear Power )
| |
| Plant, Units 1 and 2) )
| |
| )
| |
| AFFIDAVIT OF D. A. ROCKWELL AND J. E. HERBST STATE OF CALIFORNIA )
| |
| ) ss.
| |
| COUNTY OF SAN FRANCISCO )
| |
| The above, being duly sworn, depose and say:
| |
| I, Donald A. Rockwell, am Special Projects Engineer for the Pacific Gas and Electric Company at the Diablo Canyon Nuclear Power Plant.
| |
| I, J. E. Herbst, am a Senior Engineer for the Pacific Gas and Electric Company, l
| |
| 8
| |
| -- - -- ,- -- - _.--.-,--,.---..,,-m,-- - - , - - - - . - - - , . - - , , . , - , - < - , , - - ----------,-e----.m-.---,y- ---- .- ------ , , -----
| |
| | |
| a a __aa, ,,- , _,, .--
| |
| a - - .._ - --
| |
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| Our msponses to the following allegation numbers in PGandE Letter No. DCL-84-243, dated June 29, 1984 are true and correct to the best of our knowledge, information, and belief.
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| III-63 V-34, 35, 36, 37, 45, 46, 47, 48, 49, 50 VI-7, 8, 9,10 Dated: June 29, 1984 -
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| I U. A. Rockwell s
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| % /E. Herbst l Subscribed and sworn to before me this 29th day C. T. NEAL MADISON of June,1984 NOTARY PUBUC -CAUF0 BRA CITY AND COUNTY OF SAN FRANCISCO
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| /% Ny C,mmuuan lassu SmL 21, INS Cynthf a Neal-Madison hotary Public in and for the City and County of San Franesico State of California
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| % commission expires December 27, 1985 i
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| UNITED STATES OF AMERICA NUCLEAR REGULATORY COMNISSION
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| )
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| In the Matter of )
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| ) Dochet Nos. 50-275 PACIFIC GAS AND ELECTRIC ) 50-323 COMPANY )
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| (Diablo Canyon Nuclear Power )
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| Plant. Units 1 and 2 )
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| )
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| AFFIDAVIT OF DeVERNE 6. DUNNUM. JR.
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| STATE OF CALIFORNIA )
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| ) ss COUNTY OF SAN LUIS OBISPD )
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| The above, being duly sworn, depose and say:
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| I, DeVerne G. Dunnum, Jr., have been employeed by the H. P. Foley Company and assigned to the Diablo Canyon Nuclear Power Plant for four months. I am currently the QA Supervisor of the Special Task Force. I am responsible fcr research and response to eng,loyee gaality concerns, implementing the training program for H. P. Foley personnel and respond to NRC l inspections related to allegations concerning H. P. Foley's Quality Assurance program.
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| l I attended Whitman College, Walla Walla, Washington, from 1972 to 1974 r
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| majoring in engineering and law. In 1979 to 1980 I matriculated at Walla l Walla Community College where I attended courses in welding.
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| I have eight years of experience in Quality Assurance and Engineering programs of nuclear power plants for which the last seven year have been in the capacity as a supervisor.
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| From 1976 to 1981 I was employed by Westinghouse Hanford at the Hanford Environmental Development Laboratories in Richland, Washington. During my tenture I work on a variety of tasks such as:
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| - The Breader Research and Development Department for which the proto-type Clincs River Breader Reactor driver full assemblies were designed a.1d built.
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| - Test Article Development which I was responsible for engineer's assembly and inspection of the General Electric Grid Driver fuel assemblys.
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| - In February 1981 1 joined J. A. Jones Construction Company as a Senior Quality Assurance Engineer certified as a Level II. In March I was promoted to a QA Records Supervisor for which I held until the end of October 1982.
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| l In November 1982 I joined Henry J. Kaiser as a Quality Assurance Records Supervisor and shortly later accepted the engineering position of Technical Services Supervisor. As the Technical Services Supervisor my responsibilities
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| ; included, work package preparation (piping / mechanical), work package control, engineering walkdown of all piping and mechancial supports. Technical Engineering review and resolution to NRC inspections related to allegation involving Henry J. Kaiser installations.
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| My resp:nses to th2 following allegation numbers in PGandE Letter No.
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| OCL-84-243, dated June 29, 1984, are true and correct to the best of my knowledge, information, and belief.
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| III-70, and 111-71 Dated: June 29, 1984 . - - - /_ "
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| DeVERNE 6. DUNNUM, JR.
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| STATE OF CALIFORNIA COUNTY OF SAN LUIS 08ISP0 55 Subscribed and sworn to before me this 29th day
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| ; of June, 1984 WITNESS MY HAND AND OFFICIAL SEAL
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| ^ ^ ^^^~
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| OFFICIAL SEAL IDA DUTRA t- % DIJTRA CA'.tt:RNIA
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| @ N0ncy r ; .JAN 2. !!?'_k
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| pH t* :5 03;$PO COUT ley comm e.;lrcs y
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| 1 PROFESSIONAL QUALIFICATIONS Professional qualifications for the following affiants have been previously submitted in the PGandE Response to Joint Intervenors' Motion to Reopen the Record on Design Quality Assurance. (March 6,1984)
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| Fred C. Breismeister Myron E. Leppke
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| . Michael J. Jacobson Robert G. Oman Larry E. Shipley Michael R. Tresler Professional qualifications for the following affiants have been previously submitted in the PGandE Response to Joint Intervenors' Motion to Reopen the Record on Construction Quality Assurance. (March 19,1984)
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| Harold W. Karner -
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| Donald A. Rockwell l ,
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| In addition, statements of the Professional Qualifications for the remaining affiants are either enclosed with their affidavit or attached to this submittal.
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| l David B. Miklush De Verne G. Dunnum l W. N. Harris Julius E. Herbst Neil J. Tuholski l
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| l 1627d i l - _ _ _ _ _ . _ _ . . _ _ _ . _ _ , . ~ . _ _ . . _ _ . _ _ . _ _ . . _ .
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| PROFESSIONAL QUALIFICATIONS OF DAVID B MIKLUSH ,
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| Iqy name is David B. Miklush. I have 12 years of experience as a mechanical engineer, the majority of it in the field of nuclear engineering.
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| Since February 1978 I have been employed by PGandE. From February 1978 to June 1980 I was a Power Production Engineer in the Technical Department. I became a Senior Power Production Engineer in June 1980 and held this position through February 1983. These assignments were in the surveillance testing and engineering evaluation areas of Diablo Canyon. From February 1983 to the present I have been the Maintenance Manager in charge of the Mechanical and Electrical Maintenance Departments.
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| I j I graduated with a B.S. in Mechanical Engineering from UCLA in 1972. I have a P.E. License in Mechanical Engineering from the state of California and I hold a Senior Reactor Operator License at Diablo Canyon.
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| i From September 1972 through April 1976 I was employed by the General l Atomic Company and participated in the Technical Graduate Program with three 6-month assignments in manufacturing, design engineering, and site startup at l
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| l the Fort St. Vrain Nuclear Power Plant. From August 1974 to April 1976 I was permanently assigned to Fort St. Vrain in construction and operations.
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| From April 1976 through February 1978 I was employed by General Electric Company as a Design Engineer with responsibility for BWR refueling, fuel handling, and auxiliary service bridges. This assignment consisted of the verification of vendor hardware designs and initial design of the fuel grapple for BWR 6.
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| PROFESSIONAL QUALIFICATIONS OF WILLIAM N. HARRIS My name is William N. Harris. I an employed by the Guy F. Atkinson Company as Quality Assurance Manager in the construction division office.
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| l I an a Professional Engineer registered in the State of California and am an ASIE Level III Inspection Engineer.
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| In 1950, I began working as a mechanical engineer for the California Research and Development Company at Livermore, California, and at Argone National Laboratory in Chicago, on nuclear research projects. In 1953, I joined E. I. Dupont as an engineer and tested nuclear components for increased mactor productivity and safety at the Savannah River Laboratory, Nouth Carolina. I entered the U. S. Navy in 1955 and spent three years with the Naval Reactors Branch of the Atomic Energy Connission (AEC) reviewing i
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| designs of components for nuclear-propelled ships. Following sqy discharge, I continued sqr work with the AEC until 1962 as project engineer responsible for l
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| evaluating designs for nuclear reactors for power production.
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| In 1962, I became a member of the joint venture of Astron-Blume-Atkinson at the Stanford Linear Accelerator Center. As a project engineer, I was msponsible for coordinating the engineering design of the major accelerator structures. In 1966. I was amployed by t;.e Guy F. Atkinson Company as Data Pmcassing (DP) Department Manager. I held this position for the next two 1682d .
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| years during which the initial data processing system was installed. I spent the following year in the construction division office assisting in scheduling i and quantity surveying DP applications.
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| In 1969, I was assigned to the Diablo Canyon Nuclear Power Plant as Quality l Assurance Manager and continued in that capacity untti 1973. During this assignment, I was responsible for the development and management of a program to ensure acceptable workmanship, materials, and equipment associated with the Project.
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| 1 In 1973, I mturned to the construcion divsion office where i provided guidance ared assistance to nuclear and hydroelectric projects concerning l quality assurance and qual,ity control requimments. In addition, I am currently working on special assignment with the Company's Diversified
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| ! Operations Group as Senior Research Associate.
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| l PROFESSIONAL QUALIFICATIONS OF JULIUS E. HER8ST Itr name is Julius E. Herbst. I have 24 years of experience as an electrical engineer including 23 years with the. Pacific Gas and Electric Company.
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| I graduated in 1950 with a degree in Electrical Engineering from Ingenieurschule Polytechnikum Giessen, hermany.
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| From 1950 to 1959 I was amployed as an electrical engineer for Lahmeyer G.M.B.H., Frankfurt, Germany with responsibility for transmission line design. From 1959 to 1961 I was an engineer with Western Knapp Engineering Company, San Francisco, California with responsibility for the design of a 50KV transmission line.
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| Since 1961 when I joined PGandE I have had increasingly responsible positions. I worked on Diablo Canfon from 1970 to 1972, and again in 1982 4
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| where I was responsible for the seismic requalification of the Class IE equipment to new H0SGRI requirements and the associated extensive testing program. From 1982 I have been a Senior Engineer with responsibility for the environmental qualification of electrical equipment for the Diablo Canyon
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| ; Project. ,
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| 1627d 1
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| Y PROFESSIONAL QUALIFICATIONS OF NEIL J. TUHOLSKI
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| % name is Neil J. Tuholski. I an employed by Bechtel Power Corporation as a Civil Engineering Supervisor on the Diablo Canyon Nuclear Project. I am a graduate of the University of California with a BSCE (1963) and a MSCE (1972) and am a Registered Engineer in California. Prior to joining Bechtel in 1973, I worted for four ye0rs for the U.S. Navy Snip Research and D'evelopment Center in Maryland.
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| Since September 1982 on the Diablo Canyon Project I have been the Deputy Civil k Group Supervisor with responsibility for the containment building design gro'up as well as the coordination of field activities. Prior to this assignment I ,
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| worked for three years as Civil Group leader on the Limerick Nuclear Plant, two years as the testing activity leader in the Applications Engineering Group in Bechtel's Research and Engineering Operation, and as a Senior Engineer for several mining projects and the Midland Nuclear Power Project.
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