ML20081B805

Affidavit of Fc Breismeister,Dj Curtis,Mj Jacobson,Me Leppke,Gh Moore,Rg Oman,Le Shipley & Wh White Re Design QA

ML20081B805
Person / Time
Site:	Diablo Canyon
Issue date:	03/05/1984
From:	Breismeister F, David Curtis, Jacobson M, Leppke M, Moore G, Oman R, Shipley L, William White PACIFIC GAS & ELECTRIC CO.
To:
Shared Package
ML20081B795	List: ML20081B793 ML20081B805 ML20081B813 ML20081B823 ML20081B829 ML20081B832 ML20081B840 ML20081B845 ML20081B855 ML20087B999 ML20087P888
References
NUDOCS 8403120010
Download: ML20081B805 (101)

Text

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O UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION BEFORE THE ATOMIC SAFETY AND LICENSING APPEAL BOARD,

)

In the Matter of ) Docket Nos. 50-275

) 50-323 PACIFIC GAS AND ELECTRIC )

COMPANY Design Quality Assurance l

(Diablo Canyon Nuclear Power )

Plant, Units 1 and 2) )

I AFFIDAVIT (F F. C. BREISMEISTER, D. J. CURTIS, M. J. JACOBSON, M. E. LEPPKE, G. H. MOORE, R. G. OMAN, L. E. SHIPLEY, AND W. H. WHITE O STATE OF CALIFORNIA CITY AND COUNTY OF SAN

)

) ss.

)

FRANCISCO )

The above, being duly sworn, depose and say:

I, Gary H. Moore, an Project Engineer (Unit 1) for the Diablo Canyon Project.

I, Larry E. Shipley, an Technical Consultant for Piping for the Diablo Canyon Project.

I, Michael J. Jacobson, an Project Quality Assurance Engineer for the Diablo Canyon Project.

I, Robert G. Oman, an Assistant Project Engineer (Unit 1) for the Diablo Canyon Project.

I, Hyron E. Leppke, am Onsite Project Engineer for the Diablo Canyon Project.

DR 0 y ,1,

O I, Daniel J. Curtis, an Onsite Plant Design Group Supervisor for the Diablo Canyon Project.

I, Fred C. Breismeister, an Manager of the Research and j Engineering / Materials and Quality Services Group for the Bechtel Group.

I, Willian H. White, an Assistant Project Engineer, Seismic, for Diablo Canyon Project, Unit 1.

I. It is alleged that:

I There was only minimal training; initial assignments were received on the first day with an example of Bechtel calculations. (Stokes, 11/17/83, p. 2)

1. As Mr. Stokes has acknowledged, pipe support engineers are a select group with specialized knowledge and nationwide experience which nakes then uniquely qualified to do their job. As a result, mininun technical indoctrination and training are necessary.

2. Indoctrination and training of pipe support engineers assigned to the Onsite Project Engineering Group (OPEG) began with the process of selecting experienced, technically qualified engineers whose professional qualifications for properly performing pipe support design work were already established.

3. To ensure technical conpetence, pipe support engineers are hired in large part on the basis of interviews, educational qualifications, and previous experience. For both pernanent and temporary or " casual" employees, the professional credentials of all are required to be verified by either the Engineering or the Personnel Departments of Bechtel or PGandE. For contract enployees, such verification is a 1

contractual requirement for the contract fim. A thorough review of the

( engineer's work experience is confimed by senior engineering personnel.

4. A thorough review of the technical background of the engineers in the small bore pipe support group at the site shows that experienced, technically qualifted engineers had been hired with little or no need for additional instruction in sna11 bore piping calculations other than that nomally provided to familiarize then with the proper design criteria and project calculational nethodology. Most of the engineers had worked on two or nore other nuclear power projects, with nany having worked on five or more plants. All have at least a BS in Engineering or equivalent, and their mininun professional experience is one year; the naxinun professional experience is 14.5 years, and the average professional experience is greater than five years.

O s. in order to indoctrin te newis assioned enstae rs in Pro 3ect Procedurai requirenents, the Project provides fomal training in the Engineering Manual Procedures (EMP) which implements project QA requirenents. Those requirenents meet Criterion II of 10 CFR Part 50, Appendix B, and are set forth in the Nuclear Quality Assurance Manual (NQAM), and Bechtel Quality Topical Report, Rev. 3A (BQ-TOP-1) which has been approved by the NRC for the Project. Each engineer assigned nuclear safety-related work receives indoctrination and training in EMP in accordance with Procedure 2.1 of that manual. This course for the engineers identifies and describes the procedures applicable to their work. The training enphasizes the procedures on design criteria nenoranda, design calculations, design changes, drawing control, discrepancy reports, and nonconfomance reports.

6. PEI-15 specifies that the indoctrination and training are to be given within 30 days of assignnent to the Project. Training records indicate that approxinately 70% of all OPEG design engineers on the current OPEG roster received Engineering Manual training within 30 days of assignnent as required. Approximately 95% received such training within four.

nonths of assignnent. The majority of those instances where an engineer did not receive training within 30 days of assignnent occurred early in the Project. Project Audit 28.4, conducted in February 1983 and closed in May 1983, resulted in the correction of most of those discrepancies.

Since May 1983, only five OPEG design engineers have exceeded'the 30-day training requirement by nore than a few weeks.

7. In addition to these organized training sessions, working familiarity with DCP calculational procedures and pipe support design criteria was acquired by new engineers through the practical experience gained in originating prelininary calculations. Newly assigned engineers were given copies of conpleted example calculations to use as nodels for calculation fornat. Copies of project procedures, instructions, and criteria were made available for reference and adequate opportunity was given for the engineer to gain fani11arity with project calculation fomat and nethods. Supervisory personnel were available to answer individual questions and provide clarifications for points of uncertainty. Newly assigned engineers were assigned more experienced checkers to review their work for adequacy and correctness prior to its being issued.

3

.A i 4

q .,

s ' II .' It is Alleged that:

CentA)11ed documents were not inmediately received for work.assignnents. Field engineers were working to

' unverified xerox copies which were incomplete.

Management was not responsive to requests for controlled s

documents. (Stokes, 11/17/83, pp. 2, 4, and 5)

8. It is true that not every support engineer had an individual copy of coritr,olled design documents assigned to him. No such requirement exists

~

Jand such a policy or requirenent would create far nore problens than it night alleviate. However, an adequate nunber of controlled copies were l

available in the specific work area for reference use by all engineers.

9. Mr.' Stokes was assigned to the sna11 bore pipe support group of OPEG as one of 11 engineers in Novenber 1982. At the time of his assignnent, three controlled copies of the project piping design criteria were assigned to the support group which was located together in one trailer.

O io. er J no r> 1983. ** nonber of ensineers assioned to the nine soonert group in the trailer had increased to 35. Steps had already been taken to obtain additional copies of controlled documents for use by the expanded piping group. Additional controlled copies of design docunents were requested from San Francisco. These documents were received in Decenber 1982, and were distributed for use by the expanded pipe support group. It was soon realized that the documeni.s received, although identical, were not controlled documents, and therefore a further request was made in January of 1983 for additional controlled documents. Consequently, while there may have been sone inconvenience, copies of controlled and identical uncontrolled design documents were available within easy reach of every pipe support engineer. Thirteen 0 -

additional controlled copies were received and distributed in Februcry 1983. Mr. Stokes was assigned his own individual controlled copy in February 1983. In April 1983, all controlled copies were replaced by a conplete reissue of new coretrolled copies of the design documents.

III. It is alleged that:

Field engineers were working to records of calculations they brougnt fron other nuclear plants. Use of other plants' documents results in assumed load ratings for other nanufacturer's equipment that may not be applicable to DCPP. Assumptions used differed fron those on controlled docunents. Unique conditions of DCPP were not accounted f6r. (Stokes, 11/17/83, pp. 2 and 3)

11. Questions have been raised as to whether references, such as the following, in the posses:: ion of pipe support engineering personnel were used in lieu of approved work procedures:

o An interoffice nenorandun dated March 21,1983, " Guidelines for Calculating Design of Skewed Welds" o Westinghouse Nuclear Technology Division Data for calculating double cantilever supports o Bechtel GPD STRUDL II Computer Progran Users Manual CE-901 Novenber 3, 1983 o Bechtel GPD IOM dated Novenber 11, 1980, "GPD Pipe Support Neusletter No. 5, Beta Angle" o Control Data Corporation (CDC) Bechtel National Support Manager to Civil / Structural Projects staff, " Baseplate II User Aids" o Midland " Pipe Deflection Fornula" o UE & C Pipe Support Design Standard, August 15, 1979 O

12. Reliance on one's past experience is not unconnon in the profession and especially for pipe support engineers who, as Mr. Stokes acknowledges, have specialized talents based on past experience. Experienced engineers comonly have general reference material as a part of their personal and professional library. This type of naterial includes textbooks and handbooks, and typically provides standard formulas and tables, code discussions, example calculations, rules of thumb and other simplified, conservative methods in connon use in the industry. As general reference material, tt y are not controlled and, more importantly, they do not constitute acceptance criteria.

13. Project Engineering Procedures (EMP 3.3) require that calculations be sufficiently detailed so that qualified technical personnel can verify their adequacy without consulting the originator. References such as textbooks, catalogs, monographs, and other such accepted industry techniques nust be documented in the calculation when necessary to provide details of the design sufficient to allow an independent review. Their use then is checked and approved via the calculation review process.

14. The aSove identified docunents are references of the type normally found in an experienced engineer's personal library. We know of no instances where the references were inproperly used. In one instance, a non-project document was referenced as the source of a double cantilever deflection formula used in a calculation. It was a standard engineering 1 formula,-not unique to any particular project, and need not have been

. referenced in the calculation.

o

- . . -_. _. . _ - . . - = - - - .- - - . - - - - . .-.

I

15. Prior to May 1983, design calculations originated oy OPEG were O preliminary in nature since they were based on preliminary assumptions due to the absence of final thernal and seismic design data at that time. All such prelininary calculations have been subsequently reviewed and revised as the final design data have become available. These revisions of the calculations to final status were conpleted using the latest revision of project criteria and were subjected to Independent Design Verification Progran (IDVP) review.

IV. It is alleged tSat:

Supplier's ratings for U-bolts were one-third to one-fourth more stringent than clained on DCPP drawing 049243. This drawing represents a false statement.

PGandE relied on a series of suspect assumptions in order to exaggerate the load ratings. The 1978 PGandE U-bolt test program was biased by not reflecting actual plant conditions. Stokes was allowed to use lead ratings which failed sone of the U-bolts. Even if load ratings of U-bolts were accurate, the hangers to which they are attached would not meet design requirenents. (Stokes, 11/17/83, pp. 5 to 8)

16. A U-bolt is used in conjunction with other structural menbers to provide lateral restraint to a piping systen. It restrains the piping in directions perpendicular to the pipe centerline and provides both thernal and selsn-ic restraint, The ASME B&PVC,Section III, recognizes and provides detailed rules- for the qualification of pipe supports by three different nethods. They are analysis, testing, or experinental analysis.

17. ITT Grinnell qualified the U-bolt by analysis. To analytically represent the locd/ deflection relationship between the pipe and the t .

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I!-bolt becones a very conplex problem. To provide this qualification, O Grinnell simplified the relationship between the pipe and U-bolt to produce very conservative results from a nodel that can be handled analytically.

18. Testing provides a more accurate representation of the pipe /U-bolt interaction by including elements such as the distribution of the load on the U-bolt, the frictional resistance between the pipe and the U-bolt, and the pipe's influence on the U-bolt's defomation.

19. DCP Standard Drawing 049243 for small bore pipe supports uses load ratings that were derived in accordance with the intent of the ASME B&PVC Section III rules for qualification by testing and does indeed give higher load ratings than given by ITT Grinnell. These tests were conducted at the DCP site in 1978. It is true that these two methods, analysis and testing, can yield a facter of 4 difference. However, the i test results are closer to reality, whereas the analytical results are ,

only a very conservative approxination.

20. ASME Section III, Subsection NF-3260, provides the procedure by which U-bolt allowable ratings were developed. Per NF-3260, the procedure for load ratings consists _ of inposing a total load on one or more duplicate

- full-size sanples of a component support. The total load is to be equal to or less than the load under which the component support fails to perfom its required function. If a single test sample is perfomed, NF-3260 requires the load ratings to be derated by 10"..

21. The tests perfomed for the Diablo Canyon supports were more aunerous than the single test pemitted by the code but were less than the

" statistically significant sample" allot.ad by the code as an alternate.

The conservatisms adde:d in the generation of allowables are considered to be at least equivalent to a derating of allowables by 10%. The following is a surriary of conservatisns:

22. A mininun of four U-bolts were tested for three loading conditions for each pipe size. The loading conditions consisted of the application of side loading, tension loading and a conbination of side and tension loads (450). The allowables for tension and side loading were based on the lowest test load of all pipe sizes tested using a given dianeter U-bolt. The test loads used in the equations of NF-3260 represent the

! lowest tension and side test loads found for 1/4-inch and 3/8-inch l dianetec rod Usolts, respectively.

23. Added conservatism occurs in the interaction fomula with the application of both tension and side loading because the nininun tension test results and the mininun side loading test results are conbined.

24. U-bolt tonsion failure did not occur for any U-bolts for piping sizes 1

greater than 1-1/4 inches in diameter. The allouables were based on the testing nachine's capacity rather than the U-bolt's capacity.

l Therefore, substantial nargin exists for the larger U-bolts.

25. In sunnary, the load ratings for U-bolts neet the requirenents of the ASME Code for qualification by type testing, The use of allowable U-bolt ratings deternined by qualification testing will reliably ensure a conservative design and neets all design criteria.

26. Interaction equations for tension and shear are used in bolting applications. The form that the equation takes is dependent on the O

application. In accordance with ASME- Section III, Appendix XVII, paragraph 2461.3, the capacity of a bolt in a bearing type connection is detemined using the follr sing expression:

2 f'2 f F, 2 F,2 II where fe = conputed tension stress fs = conputed shear stress Fe = allowable tensile stress at tenperature Fs = allowable shear stress at tenperature

27. This is exactly the equation appearing on DCP Drawing 049243 which was used for the qualification of U-bolts. Because no guidelines are given in NF-3261 for the conbination of load ratings established for a particular restrained direction, tension and shear loads were combined in accordance with ASME Section III, Appendix XVII, paragraph 2461.3(a). This equation is used when stresses are calculated for bol ts. Accordingly, it is considered appropriate to use this equation for load ratings as stress and load ratings are directly proportional.

28. Although the interaction equation given in Section III, Appendix XVII, 2461.3 may not have been specifically intended to address bolts with conbined tension, bending, and shear, the results of test loading indicate that it is appropriate and conservative for this application.

29. The assertion that because Schedule 160 pipe was used in the test, any thinner wall piping could be danssed or " buckle" due to the U-bolt capacity is illogical. The naxinun capacity of the U-bolt and stress 0

analysis of the pip'ing at any particular support locaticn are two independent issues. Piping stress at any location in the piping systen is a function of the nonent in the piping component. The magnitude of this nonent is detemined by the seismic ccceleration at the given plant location and is therefore independent of the maxinun capacity of the U-bol t. The U-bolt allowable on the other hand, or maxitum capacity as derived fran the tests, is independent of the location in the plant or the piping to which it attaches. This concern seems to sten from a lack of understanding of the total design process, both stress and pipe support, and ASME requirenants. The analy. sis of the piping and subsequent satisfaction of all code requirements ensures that buckling of the piping will not occur.

30. The fact that the tests were not perfomed at elevated temperatures has no bearing on the load capacities developed in accordance with ASME Section III, Appendix XVII, paragraph 2460. Allowables for bolts are derived based on Ultinate Tensile Strength (SU). This value does not change between the anbient test temperatures and 6500F which qualified the U-bolts for all Seiscic Category i supports at the Diablo Canyon site. U-bolts have not been used in Seismic Category I applications where they wculd be on lines above 6500F.

- 31. During construction sone U-bolts may have been slightly bent to align the U-bolt legs with predrilled holes. Any such bending would be of a cold foming nature. It is connon practice to fom naterials by cold bending and this would tend to increase the yield strength properties of the U-bolt, This would create an even stronger naterial through cold O

working. It should be noted that the original foming of the "U" shape O is done by cold forning during the manufacturing process. In any event, this practice does not reduce the load capacity of the U-bolt.

V. It is alleged that:

For code breaks, boundaries of Class I seismic systens, there was not enough offset or space between the valves and the large bore piping to avoid unacceptable stress on the snall bore pipeline branches. The vendor had not received correct instructions since they were told to install the piping at roon temperature. DCPP requires seismic supports, and has to endure tenperatures in excess of 6500F. (Stok es, 11/17/83, pp. 8 and 9)

32. The tern " code break" is used to describe t'he section of a piping systen where the safety-related piping (Class I) changes to nonsafety-related (Class II) piping (see figure below), This " code break" section is

'always located on the Class II piping and starts at the valve which is r

k the point at which the fluid systen class changes fron Class I to Class II. Within the " code break" section is a systen of supports or an anchor that dynanically isolates the Class I piping from the remainder of the Class II piping. The " code break' section of the pipe ends when dynanic isolation has been acconplished. The crituia used to achieve the desired isolation, as discussen in the PGandE Phase I Final Report, require that the systen of supports that provides dynanic isolation be made up of either: (1) an anchor or (2) at least two lateral supports in each direction and one axial support. The anchor, or supports, are denoted as Class II* supports and are designed to the same criteria that are used for Class I supports.

l

Class-I = Safety-related

" Code break" section ,

Class II* = Nonsafety-related r, - but supported to achieve VALVE END OF isolatie of the Class I. piping CODE BREAK (" Code b.eak" section)

Class I Class II* Class II Class II = Nonsafety-related nonseismic design

33. In the above schenatic, the length of Class II* piping is not important

! as long as the code break requirements are net by providing supports or j an anchor. If the length of the Class II* section of piping can be shortened by relocating the Class II boundary closer to the Class I boundary, the systen would then require fewer Class II* suppcrts; this relocation is only accomplished by adding supports or an anchor to the code break section closer to the Class I boundary. As an exanple, assume that following the valve, the code break section included five bilateral supports (these provide support in both lateral directions at bd one locatfort) and then an axial support. All these supports would require Class 1 qualification. Two alternatives for inprovenent of the design that are acceptable and neet all licensing criteria are: (1) to add an anchor at the location of the.first bilateral support, or (2) to add an axial support at the location of the second bilateral support.

Both alternatives reduce the length of the code break and the number of supports requiring Class I qualification and meet all licensing criteria.

34. The allegation that the code break boundaries were relocated in violation of sone engineering precept, project instruction, or licensing criteria is fallacious. While it is true that the length of Class II*

l piping was minimized wherever possible by nodification or addition of I supports, there is no reason not to reduce the anount of the Class II*

piping to the minimun.

14 -

35. Independent of the vendor procedures for original installation, tre

- VO '

recent reverification effort has considered 100% of the code break

-issues as well as all systens with high tenperatures. Therefore, we are confident that sufficient offset or space exists between valves and large bore piping to avoid unacceptable stress on small bore pipe branches.

36. _ The allegation that the offset is insufficient to avoid unacceptable stress on the sna11 bore branch lines evolves from a nisunderstanding.

It apparently comes from a belief that ME-101 analysis of offset is less reliable than H-40. E-101 is a computer program that perforns static and dynanic response spectra modal superposition solutions. M-40 is a hand calculation technique based upon simply supported spans. Either technique is acceptable.

O  ;

VI. It is alleged that: l Engineers who questioned suspect assumptions were l transferred to Unit 2. Cooperative engineers plus new l recruits were assigned to Unit 1. (Stokes, 11/17/83,

p. 9)

37. Contrary to statements in the affidavit, no attempt was nade to determine personnel assignnents on the basis of objections or questions raised regarding Unit 1 activities.

38. . When the OPEG small bore piping group was established in the fall of 1982, all efforts were directed to Unit 1 activities. At the tine, there was no specifically defined scope of work or schedule for Unit 2 activities. Consequently, the entire OPEG snall bore piping group was assigned to Unit 1. By early 1983, the Unit 2 scope and: schedule were

defined and it becane necessary to increase OPEG nanpot '.r to support O Unit 2 work in addition to the ongoing Unit 1 effort. Accordingly, additional trailer space and engineers were obtained for that purpose.

The decision to establish physically separate teens for the two efforts was based on the desire to assure proper managenent of the two activities. The separate teams within OPEG facilitated independent scheduling, production control and output tracking, control of nanhour expenditures against separate project budgets, coordination with the two separate and independent Unit 1 and 2 project teams in San Francisco, and prevented internixing of calculations, calculation files, support drawings, and other potential administrative problens.

39. The basic consideration in establishing the nakeup of the two teans was to provide each with an essentially equivalent nix of new assignees, h engineers with more project experience and appropriate supervisory personnel, such that each project effort could be supported equally.

Security clearance for access to the plant was not a consideration in these assignnents since the relaxation of plant security procedures effective in March 1983, allowed all pipe support engineers equal plant access to Units 1 and 2.

VII. It is alleged that:

These Unit 1 engineers redid calculations entirely for all failed systens. The original calculations vanished with no mention of the failure. The calchlation logs were also rewritten and falsified. Unit 1 would have failed the reevaluation progran and required complete reanalysis. (Stokes, 11/17/83, pp. 9 to ll)

O

40. In verifying the adequac J designs at Diablo Canyon, engineering design practic. wit with both nucleai* and non-nuclear applications were followed, These engineering practices utilized iterative engineering calculations to verify a design that is consistent with the acceptance criteria. It is connon practice to do initial calculations using conservative data and simplified nethods.

This can save the tine and expense associated with more detailed, tine consuning, sophisticated calculations (such as conputer analyses). When an initial calculation u::ing conservative data denonstrates oae or more acceptance criteria are not net, an engineer performs ad?+%nal trial calculations that use more precise input data. Input data can be nodified by renoving unnecessary conservatism or by selecting more appropriate boundary conditions as an alternative to using progressively

• t more sophisticated approaches.

- 41. Typically, engineers are trained to employ the use of more sophisticated analytical techniques if initial conservative analyses are not acceptable. For exanple, a hand calculation might be replaced by a static computer run, then by a dynamic linear-elastic computer run, and finally by an inelastic time history analysis. All of these increasingly sophisticated analytical methods yield results that are entirely acceptable in accordance with the design criteria.

42. The net result of this engineering process is a completed analysis which nust be in full compliance with the design criteria and which neets all design paraneters. The docunentation of such an analysis constitutes support and verification of the final design. Intermediate calculations

_ _ __ _ ___ -______ _ ~

which are not part of the final calculations need not be retained.

'O Quality procedures do not require retention of these unapproved, 1

internediate calculations.

!. 43. ANSI Standard N45.2.9 (1979) does not require retention of intermediate calculations. The only calculations required to be retained are the l final calculations which reflect the analysis actually relied upon to show adequacy of ('esign. Superseded calculations are not required to be l

retained by regulation, reguletory guide, standard, or any procedure to L

which Diablo Canyon is or has been connitted to. Despite this fact, DCP procedures, based on judgnent ref the analyst and checker, call for retention of superseded calculational records "to the extent necessary to support and verify final designs." This allows an accurate reconstruction of each calculation. The cover sheet of each calculation package contains a change sheet which shows the history of all revised calculations. A review of these records indicates that nore than 70 calculations contain Mr. Stokes' signature in one of their versions.

The calculation logs may, however, be changed to reflect only the latest revision and signatory engineers. This normal practice does not constitute falsification of records as alleged.

VIII. It is alleged'that:

Management's first approach to make Unit 1 look good was to reduce code brea% spans. This was not done because there was no plausible explanation for it. Managenent

. decided to use new assumptions that would change the results fron fail to pass by assuning gaps that did not exist or vice versa. (Stokes, 11/17/83, pp.11 and 12) 0 L .

44. Since Mr. Stokes did not perfom any conputer piping stress analyses at Diablo Canyon, he was probably unaware of the applicable specific design requirenents. However, he is correct in noting that actual restraint clearances, or as-built gaps, are sometimes included in the qualification calculations as described in Piping Procedure P-ll (Section 4.6.2) when perfoming small bore piping stress analysis for themal expansion or themal anchor notion. The gaps that are included are physical clearances that exist between the pipe and a structural element. Themal loads can be elininated by gaps in pipe supports and, therefore, the inclusion of gaps in the qualification analyses is completely appropriate. In each case where gaps are included to reduce themal loads, adequate assurance is available that the gap can be relied on to be present throughout the plant lifetime.

45. Before any gaps were included in a piping stress analysis, Piping Procedure P-ll required as-built reverification. Accordingly, a plant walkdown was conducted to establish the actual gap configuration. The gap configuration was modeled and included in the documentation of the stress analysis calculation. This practice of including gaps to reduce themal loads is used in the industry as a nethod of accounting for actual plant conditions.

46. As a result of the NRC Staff's question enanating fron this allegation, a review of all snall bore piping stress analyses was conducted. The results of the review denonstrated that as-built gaps were included in 25 piping analyses affecting a total of 64 pipe supports. The 64 supports represent appr'o ximately 37, of the supports analyzed. As O

reported in the Project's supplemental letter to the Staff dated December 28,1983,16 of 25 piping stress analyses involved piping with service conditions below 2000F. In these 16 analyses, themal novenents are minor and not of technical concern. The 9 renaining pipe stress analyses involve 16 supports which is less than 1% of all the small bore pipe supports analyzed.

47. A description of the 9 pipe stress analyses in which as-built gaps were modeled into the computer analysis and the piping systen tenperature exceeds 2000F for nomal themal load cases was presented in the December 28, 1983, letter. These 9 analyses fall into two categories.

Category 1 gaps were nodeled to acconodate themal anchor movenent (TN4) of large bore piping. Since these gaps are caused by the themal novenent of large pipes and equipment expected to have repeatable h themal growth, the gaps are expected to be present throughout the plant's lifetine. All but one support falls in this category. Category 2 consists o* gaps nodeled to release themal loads and stresses induced by two opposing suppo:'ts restraining the pipe in the sane direction.

Because of. the piping configuration that exists, it is clear that the as-built gaps will renain throughout the plant's lifetine.

48. The consideration of actual restraint clearances, as described in the supplemental Decenber 28 letter, is a reasonable and adequate technique

'for the piping geometries involved. This method is consistent with the

' licensing criteria for Diablo Canyon and has gained widespread use in the nuclear industry where ignoring as-built gaps results in excessive themal loads.

l I IX. It is alleged that:

O Management assuned joint releases for rigid connections which means that welds which were in place were assumed to be nonexistent. (Stokes, 11/17/83, p.11)

L 49. " Joint releases" refers to a nethod of providing an accurate representation of end connections in structural nenbers. An initial calculation of a pipe support frame night conservatively assune that welded ends at structural nenbers are completely rigid. However, it is i.

obvious that no joint is completely 100% rigid. The structural nenber may have very little noment resistance in some rotational axes, and assuming rigidity is not representative of actual Isehavior. An engineer nay ncdel the joint to closely represent its actual physical characteristics. In many instances, the joint is modeled so'that no nonent resistance is offered by the steel to which the nenber is attached (i.e., assune that nonent loads are not transmitted). This nethod provides a more realistic nodel of the structural behavior of the frane.

50. The weld at the joint is still considered in the computer nodel and there is no intent or need to renove it since the forces transnitted by the weld and associated stresses are evaluated and verified to be acceptable. This practice is standard in structural engineerfng evaluations of frane structures.

X. It is alleged that:

Hangers still failed and nanagement requested designers to perforn reverse calculations to determine the naxinun loads that each hanger could support. After naximun loads were established, results were returned to the stress group. (Stokes, 11/17/83, p.12)

51. Different methods exist to qualify a piping systen to design criteria.

These nethods often require interaction between engineering designers.

An example of this can be seen in sna11 bore piping qualification where 1 the pipe stress analysis produces reactions or loads on the pipe supports. After obtaining the loads on the supports, the pipe stress analyst transnits results to the pipe support engineer for his use in qualification or design of the supports for these loads. The pipe support engineer reviews existing as-built pipe support drawings. If the. support is determined to be inadequate to sustain the given load, I

the support designer and the stress analyst may well review the systen to deternine if the engineering assunptions in the piping stress analysis have excessive conservatisn. An additional series of nore realistic calculations nay be perforned before it can be shown that the O gaert meet criter4 - T=4 arece== or rec ic#i t4oo n 1 ecc#r sever i times befo:e the support is qualified. Such an approach is a logical l

l and orderly nethod of qualifying small bore piping systens and does not 1

violate any design or licensing criteria or regulatory requirenent.

52. Another method used to qualify a piping systen invcives use of the naxinun capacity of the pipe supports for qualification. This nethod can be nore efficient than the nethod discussed above by reducing the nunber of interactions and recomputations between the stress analyst and the pipe support engineer. In this situation, the pipe support engineer calculates the maximun capacity of a support for each load case. This information is provided to a pipe stress analyst, who compares the f

computer results of the piping stress analysis to these naxinun O

Y w-,,- ,,-,n en , , - ,- - -.m ,-e-. >-,,-..,---nv,m-, ,..,,---,--.,,=n,-..---r,.,--n-n.,,,-,---,-,--,, .,,,,.-,-a,.---,-.,- , - - - , . , - - - - , - - , . ,

allowable loads. If the calculated support loads are in excess o' the allowable, the piping analyst may be able tc perforn a reanalysis iteration without requiring the pipe support engineer to recalculate stress in the support. This method does not alter the final result i

since both the piping and the supports must be shown to be qualified to the applicable licensing criteria. When the piping analysis is complete, all loads are transnitted to the support engineer for final acceptance, or support modification, and documentation. This reverse calculation technique is often used in the industry and is analogous to calculating an acceptable " load rating" of a support.

53. This question also conveyed the implication that intermediate or iterative calculations were being improperly destroyed. Such an inplication is erroneous. Pursuant to procedure 3.3 contained in the PGandE Engineering Manual, all final (i.e., approved) calculation packages are retained and pernanently filed. - There is no regulatory or project requirement to retain the intermediate or iterative analyses.

XI. It is alleged that:

Another technique of adding new supports within six inches of failed existing supports was used. The stress group then nodeled new support gap assumptions so that the new supports would handle most of the load. Instead of naking necessary repair for a pipe resting on a unistrut, this unintentional restraint was nodeled as a pipe support instead.of being renoved. The solution was to renove the unistrut and add a full-sized support.

(Stokes, 11/17/83, pp.12 to 14)

54. New pipe supports were added to small bore piping for many reasons; e.g., to neet code break, valve acceleration, or thermal criteria. In O

t -

some cases these new supports were located near existing supports. This approach would obviously have the effect of reducing loads on the existing supports. The small bore piping progran was explicitly conducted to ensure that all supports net the licensing criteria. In sone cases, conditions were nodeled where a structural restraint that was not a pipe support was present. For example, there are several instances in which a penetration was modeled as a seismic restraint.

When a support was modeled in the final analysis, either a support or restraint physically existed in the plant or, in the case of a design nodification, a new support point was nodeled in the stress analysis calculation. If a new support is added, a documentation number is assigned to the new pipe support and remains with it throughout the design, construction, as-building, and final engineering approval cycle. This documentation trail ensures that the support is constructed in accordance with the design requirements.

55. During the course of nodifying piping supports, interferences and obstructions were encountered. These were identified to Engineering and dispositions requested. As an example of this process, it was noted in oro case that a Unistrut bean for the support of electrical conduit was constructed near a pipe and subsequently identified to Engineering for disposition (Allegation 89 from SSER 21).

56. In a case-such as the one involving the above-nentioned Unistrut, Engineering went through the following process of qualification. Fi rst, an attenpt was made to requalify the systen with the added restraint of the Unistrut present. Ir this case it was not ossible to protect the O

l

- . Unistrut so the addition of a support at the location of the Unistrut was investigated. This investigation showed that the Unistrut was not required and it was renoved from the plant. All cf this was part of the iterative practice of qualifying *nstalled piping systen and is not unique to this plant. All applicable procedures were followed in this

. process and all design criteria were net. In fact, it would appear that this situation clearly denonstrates good connunication between Construction and Engineering, sound engineering practice, and a proper i

solution that resulted in a systen that neets the design criteria.

XII. It is alleged:

There was a coverup of defective naterials fron Pullman associated with a 50,000-pound bracket on a 20-inch line. The bracket was deforned and failed testing. ,

Management instructed that only visut.1 inspections be

,O '

performed on replacements. (Stokes, 11/17/83, pp.14 and 15)

57. The alleged material deficiency discussed in the affidavit was

! irivestigated. It involved support 1029-5CS, which is a constant rate spring support used as a dead load support on a 28-inch stean line (not 20-inch as alleged in the affidavit). The " cracks" nentioned in the affidavit were in fact laminations as deternined by ultrasonic testing which connonly occur in this type of SA-36 plate, and it is not surprising that ultrasonic or nagnetic particle testing would indicate this condition existed. These laminations do not detract from the component's load capacity. In addition, the pieces exhibited punching l

narks which the component nanufact9rer has certified do not affect the component's capacity or function.

58. To be conservative, the contractor returned four of the ten brackets

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included in the order while the two on 1029-5CS were scrapped.

XIII. It is alleged that:

Pipe stress and support engineers were nomally not allowed to prepare Discrepancy Reports. Foley and Pu11 nan, however, regularly prepared these documents.

(Stokes, 11/17/83, p.15)

59. Training is required of all engineering personnel shortly after assignnent to the project which includes indoctrination ir. the purpose and use of a Discrepancy Report (DR), as well as a Nonconfomance Report (NCR), and a Design Change Notice (DCN). Project training records indicate that Mr. Stokes attended this training on November 8,1982, shortly after his arrival onsite. NCRs are addressed in Engineering Manual Procedure 9.1 and DRs are addressed in Engineering Manual p%J '

Procedure 10.1.

60. Procedure 10.1 provides that any individual can identify a potential discrepancy and bring the natter to the attention of the responsible Engineering Department group leader or supervisor. The supervisor is responsible for detemining, after investigation, whether the identified iten is a non-confomance, a discrepancy, or neither, and directs that the appropriate report be prepared. During the course of the OPEG piping design effort, there were nunerous instances identified by engineers which required discussion and clarification of the design basis for itens which were unclear to specific engineers. This is not unexpected in the nomal course of design engineering activities where solutions to engineering problems are developed. Identification of O

I . -.

l

" potential discrepancies" which, upon further investigation, proved to

'O be of no concern were not frequent, but did occur from time to tine.

61. A DCN is a document used by engineerirg to effect a nodification to an approved specification, drawing, or supplier document that results in a plant nodification or revises any other design document or license

. requirement. Contrary to the allegation, it is not a docunent for engineers to initiate nodifications in response to QC inspections unless the inspection should result in a redesign nodification. Procedures controlling the use of DCNs are addressed in Engineering Manual Procedure 3.60N for Unit 1 and Project Engineers Instruction No.16 for Unit 2. Contrary to statenents in the affidavit, nunerous DCNs have been initiated by OPEG pipe stress and pipe support engineers to nodify pipe routing and pipe support designs as required by their engineering analysis. Between January and October of 1983, over 200 such DCNs were initiated by OPEG engineers. How Mr. Stokes could be unaware of this fact and yet have the knowledge of how the process worked that he alleges he has is, at best, curious.

62. Numerous controlled copies of the Engineering Manual were provided as reference docunents within the various OPEG office spaces and were easily available for use in clarifying any questions which might arise concerning DRs or DCNs.

63. Contrary to statenents in the affidavit, neither Foley nor Pullman activites_ are controlled by the PGandE Engineering Manual and they consequently do not prepare Engineering DRs or DCNs. Documents used by Foley and Pullman which are called a DR or a DCN are different docunents

. from thos2 described in the Engineering Manual.

XIV. It is alleged that:

.O In the three DRs written by Mr. Stokes, flare bevel, flare V and other partial penetration groove welds for pipe supports were deficient. However, managenent insisted AWS' standards did not apply to DCPP. (Stokes, 11/17/83, pp.16 and 17)

64. The effective throat of flare bevel and flare-V groove welds are in accordance with AWS Dl.1 Structural Welding Code prequalified conoition. In the case of flare bevel welds, the effective throat is taken as 5/16R, where R is the corner radius. This approach is very conservative and AWS D1.1 recognizes the conservatisn of this approach by not requiring qualification. Had the project desired, even larger effective throats could have been justified per AWS D1.1.

65. In accordance with AWS D1.1., Section 2.1.3.1 and documented understandings between Engineering and Construction, dimensions are not O rea 4rea riere areeve eies. t< ai=e <e#,ere #et Prev 4ded. *"e

-neaning of the synbol is to weld the flare groove joint out flush with the corners. ESD 223 Section 6.8.2.6 0 requires a visual inspection to ensure that the weld is acceptable. The design of welds does conform to the requirements of AWS D1.1. The' requirement to completely fill groove jointi, flush provided the nost simple and conservative instruction to construction and inspectors. This eliminated the need for a dinension and related field neasurments.

66. Bevel angles are not required to be placed on the design weld synbols as these are included with the Weld Procedure Specification (WPS) which provides direction to both the weldar and weld inspectors. Flare groove joints do not have bevel angles and bevel angles cannot be shown on the 1

l

O design weld symbol. It is not necessary to limit the bevel angles to those given for prequalified welds in AWS Dl.1 Figures 2.9.1 and 2.10.1.

67. Dimensions, such as the depth of bevel (S) and effective throat (E), are not required to be placed on the wold symbol per AWS D1.1 Section 2.1.3.1 for complete penetration welds. For partial penetration joints, AWS Dl.1, paragraph 2.1.2.1 recommends, but does not require, S and E dimnsions on drawings. In the case of intersecting members creating weld joints which AWS D.l.1 considers partial penetration welds (for

. purposes of qualification), but which have no welo groove bevel edge preparation, it is meaningless for the designer to specify S (bevel groove depth) because there is no bevel groove preparation. EDS-223 provided an effective and simple alternative to measuring (S) and (E)

O dimensions. For the joints between skewed intersecting members, it is impossible to directly measure dimension (E) (effective throat).

ESD-223 provided. an instruction which specified the simple measuring gauge to be useu ond a conversion table relatins the design drawing dimension to an easily measured dimension. The use of the gauge and the table means that the Pullman inspectors did not need effective throat t

(E) on the drawings, and it was appropriate to take that dimension off

. drawings because it cannot be measured.

68. It is not necessary to adjust the fillet weld leg size to have all the welds in a joint have the same effective throat. Adjustments are made

-in the weld calculations to account for the varying effective throats and the consideration of the local dihedral angle has been made in the

. calculations. Even though fillet weld symbols have been used for

. v

!4 dihedral angles less that 600, calculations are performed to ensure O- that the weld qualifies as a partial penetration weld with the proper throat reduction. This reduction is in accordance with the requirenents of /,ISC and AWS.

69. Pullman Power Products procedures reference the PGandE sp;cification to which pipe supports are to be installed and the codes to which the weld

, procedures specifications (WPS) are qualified. For the WPS which are qualified, it is not necessary, and inappropriate for Pullman QC to inspect the welds to the AWS Dl.1 prequalified joints. The weld precedure specification, ESD-223, and the design drawings contain everything needed to inspect the welded joint. Flare groove welds are inspected in accordance with the requirements of ESD-223.

70. It is not necessary for Attachnent I of ESD-223 to provide limitations for the minimum dihedral angle for interr.ecting structural shapes. The limitations on the dihedral angle would be governed by the design drawings used. Throat adjustments are reflected in the weld design calculations. The calculation adjustments have taken into account the effect of skewed dihedral angle rather than perpendicular connections, and have considered that acute angle connections will not have conplete fusion to the weld root, due to possible slag inclusions.

XV. It is alleged that:

The second Stokes DR stated that angle nenbers were two-to-three tines too long for the allowable bending stress standard used under the AISC code. The angles could buckle under pressure. One hundred franes of 300 checked contained violations. (Stokes, 11/17/83, pp. 17 and 18)

The M-9 conputer analysis for angles omitted the relevant provisions of the American Institute of Steel Construction (AISC) code for allowable bending stress, contrary to licensing cornitnents. (Stokes,1/25/84, Tr. 15-21 )

71. In paragraphs 71 thru 78, the following synbols are used.

List of Symbols B = Length of angle leg t = Thickness of angle leg L = Length of span Fy = Mininun Yield Strength bf = Width of Conpression Flange

72. The criteria for the use of angles as laterally unsupported beans subjected to bending forces were based upon evaluations initiated in

~

1977. Project-specific criteria were required because the AISC Manual of .wl Construction (Ref.1) does not provide guidance for angles with laterally unsupported spans greater than 76.0 b f

/ d/fy. The tern 76.0 bf/ % is the allowable span for an unbra:ed length of a nenber not neeting the requirements of Section 1.5.1.4.6a of Reference 1. However, these criteria were developed for I beans and not specifically for angles. Reference 1 does not provide criteria for laterally unbraced nenbers greater than 76.0f b /W. The lack of specific guidance in this area has been recognized in the literature (see Reference 2).

Howevar, AISC recognizes that special investigations are necessary for angles with laterally unsupported spans greater than 76.0 yb / %.

This is indicated on page 2-21 of Reference 1 where a statenent is O

l provided which explains the use of angle load tables. The statenent is as follows:

"The tables are not applicable for angles laterally unsupported or subjected to torsion; for such nenbers a

. special investigation is necessary."

73. Because the AISC did not completely address the design of laterally unsupported angles, PGandE perfomed a literature search in 1977 to determine if other infomation was available which would be adequate to develop criteria. In late 1977 it was found that a theoretical solution to the design of laterally unsupported angle beans was available. The theory had also been verified with extensive testing. The theory and the testing were completed in Austra.lia (Reference 3, 4, and 5).

74. In the Australian tests, various sizes of angles were characterized by different B/t ratios. Angle sections with B/t ratios between 6 and 16 (Reference 5) have been tested. The na.iority of angles at Diablo Canyon fall .within this range. The only angles at Diablo Canyon not falling into this range have B/t values less than 6. However, at this end of the range (beans with B/t less than 6 are less slender) the data can be used conservatively since the net effect is to allow an increase in acceptable unbraced lengths. Based on the tests and comparison to structural theory, simple fomulas were developed in Reference 5 for use in the design of laterally unsupported angles in bending using several different nethods of load application.

75. For all the various angle sections and load cases investigated, Reference 4 reconnends that an allowable bending stress of 0.66 Fy nay

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be used if L/t is less than 300. The Diablo Canyor. . roject Design Criterie M-9 limits the maxinun bending stress to 0.0 Fy and a maxinun L/t ratio of 270. These limits used at Diablo Canyon fall withia the reconnendation of Reference 4 and are therefore acceptable.

76. DR is3-042-S, written by Mr. Stokes, questioned the acceptability of certain ur. braced angle nenbers because the unsupported spans of those nenbers are greater then 76.0f b / K per sectioc 1.5.1. 4.6b of Reference 1.

77. It should also be pointed out that the 18 pipe supports identified in the DR 83-042-S as discrepant have been reviewed. All of the angle bean spans are found within the Project Design Criteria.

78. It is concluded that the Project Design Criteria on the design of laterally unsupported angle beans has adequately covered the length

[ greater than 76.0 fb /IFy .

References

1. American Institute of Steel Construction (AISC) Manual of Steel Construction, Seventh Edition, AISC, New York.

l l

l l

2. B. F. Thonas, J. M. Leigh, M. G. Lay, Civil Engineering Transactions,

! 1973, The Institution of Engineers, Australia.

1

3. B.F. Thonas and J. M. Leigh, The Behaviour of Laterally Unsupported Angles BHP Melb. Res. Lab. Rep. MRL 22/4, December 1970.

l i

O l -- - - _ _ _ - - - - - _ . - . - _ _ . _ _ _ _ - - _ _ _ _ _ - _

4.- J. M. Leigh and M. G. Lay, Laterally Unsupported Angles with Equal and Unequal Legs. BHP Melb. Res. Lab. Rep./ MRL 22/2, July 1970.

5. Safe Load Tables for Laterally Unsupported Angles, Australian Institute of. Steel Con-truction, September,1971.

XVI. It is alleged that:

The third Stokes DR stated the distance between the center of Hilti bolt holes was not verified as the sane length required and specified on the drawing. QC had '

neasured the distance between the centers of plates attached to the bolts whereas location of the bolts is supposed to be control for the location of the ple.tes.

As a result, whole packages could be in the wrong location. (Stokes, 11/17/83, pp.18 and 19) l 79. The capacity of a concrete anchor bolt is a function of the bolt length 1

(enbedment), bolt material, and concrete strength. Anchor bolt capacity relates to a shear cone of concrete originating at the end of the anchor i bolt enbednent. This cone projects at a 450 angle to the surface. If two anchor bolts are placed close enough together that their shear cones 1

l overlap, some of the strength of the anchor bolts may be lost. The 10d (belt diameter) criterion between anchor bolts was established to assure this would not occur. ,

l 80. All shell type anchor bolts on Diablo Canyon have an embednent of less than five bolt diameters. Since the anchor bolt center lines are ten bolt diameters apart, the shear cones can never overlap. Hence the anchor boits retain their full capacity. The capacity of an anchor bolt is determined by test. The test for a shell anchor is nomally LO

I-l perfomed on one anchor at a time. The anchor bolt will develop that l full capacity so long as no adjacent anchor bolt is less than then 10 bo3 diameters away. In other words, the criteria that determines the required spacing is solely a function of concrete failure theory and test results which are categorized by bolt dianeter.

t

81. Tests to validate this premise were conducted in 1962 on a Phillips i

I shell type anchor. The results reported no reduction in capacity for ten bolt diameter spacing. It is true that the recornendation in the Hilti catalogue is to space the bolt s 10 hole diameters apart. However, when the actual shear cone is developed, the results are bounded by the 10d bolt criterion, B2. The allegation as to the measurement of the centers of plates rather than the location of bolts is difficult to understand. The design h location of a base plate is defined on the hanger detail and is dimensioned to the building structure, i.e., elevations and colunn ,

lines. On the other hand, the required anchor bolts are defined with respect to the base plate, not the building structure. During the installation, the design location of the base plate is marked on the wall and an instrument is employed that locates reinforcing bar within i

the concrete. The rebar locations are also narked on the wall. Anchor bolt locations are then selected that nost closely approximate their design locations without cutting the rebar.

83. If anchor bolt locations relative to the base plate are within established construction tolerances fron the desMn location, construction proceeds. .If the location is outside of tolerance, the O

e-w Pipe Support Design Tolerance Clarification (PSDTC) group would be asked

('

for approval to deviate and upon completion of the installation an as-built drawing would be transnitted to Engineerint; for final approval as required by procedure. In the manner described above, both the plate locations relative to the building and the bolt holes relative ~ c the plate are known, documented, and receive Engineering approval resulting in all licensing criteria being net.

l I

XVII. It is alleged that:

Access to Quality Control and NRC personnel by enployees was restricted. (Stokes,2/8/84,p.1)

84. Diablo Canyon Project written procedures stress bringing potential

! problems to the attention of engineering supervision in a timely manner .

so that appropriate steps can be taken to ident.ify and inplement any O corrective action necessary to resolve the concern and prevent future recurrence.

85. Engineering Manual Procedures covering Discrepancy Reports (Procedure l

I 10.1, paragraph 3.1) and Nonconformance Reports (Procedure 9.1, paragraph 4.1.1) both specifically state that anyone who believes he has identified a potential engineering discrepancy or nonconformance should bring the natter to the attention of the appropriate Engineering Department group leader er supervisor for resolution.

l l 86. These clearly written project procedures do not restrain or prevent 1

engineers from discussing potential problems with representatives of quality control or the NRC. These procedures recognize that many concerns raised by engineers are of a nature that may easily be resolved

by the supervisor who pusesses a broader knowledge of the project. If needed, the supervisor may involve staff specialists or engineers from other disciplines to assist. :n no event does nanagement discourage engineers, or any other person, from raising legitimate concerns. (See Exhibit 1, dated March 22, 1982, and referencing previous policy statenents dating back to the 1970s.)

87. Quality Assurance and Quality Engineering personnel have been physically located within OPEG and have been available at any time to discuss and assist with the resolution of quality problems. Training sessions were held in support of the written procedures. The training sessions on the Engineering Manual procedures, which are nandatory for engineering personnel, specifically include a description of Discrepancy-Reports and Nonconformance Reports. Project records indicate that Mr. Stokes received this training in November 1982.

88. During the course of quality audits or NRC inspections of engineering work, auditors nay ask questions about which individual engineers may not be well enough inforned to provide accurate, comprehensive responses. An individual engineer night be questioned about work he is not directly involved witi and therefore not be speifically faniliar f with in detail, or about nore general progran aspects of which the individual engineer nay not have an overall perspective. An excellent example i's Mr Stokes' lack of knowledge as to the justification (Australian test data) for use of angle-shaped nenbers (see January 25, 1984 transcript, p.126). -To ninimize a nisinforned response to auditor questions, a knowledgeable supervisor normally participates during l

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1 audits of these kinds. If questions are raised that cannot be answered by those present during the audit or inspection, they should be presented to a supervisor or someone else to assure that the responses are complete and accurate. This policy is intended to ensure that accurate infomation is provided during audit activities-and does not restrain or prevent engineers from discussing problems with " quality contr01" or the NRC.

89. Additionally, the Bechtel Power Corporation, San Francisco Power Division Instruction 3-17, "10 CFR Part 21, Reporting of Defects and Noncompliances," applies to and is implenented by the Diablo Canyon Project. This instruction defines responsibilities, establishes requirements, and provides-guidance for actions necessary to meet the reporting requirements of 10 CFR 21. Procedural requirenents to l_

initiate evaluation and reporting pursuant to 10 CFR 21 are also contained in this instruction. The instruction is posted in Diablo l

Canyon Project work areas for reference. Also, DGar.dE has posted 10 CFR 19 reporting instructions and a copy of Fom NRC-3 which gives guidance for contacting the NRC and the regional NRC phone nunbers and addresses. These documents have been posted in all PGandE facilities (i.e., PGandE headquarters, construction offices, and operating l facilities as well as in the OPEG offices).

I 90. The nethods described above have been available to projec', personnel to ,

l process a design issue which they felt could potentially affect the safe design, construction, or operation of the Diablo Canyon Power Plant.

I O

v l

l XVIII. It is alleged that:

Alien engineers (green card holders) were enployed and intinidated by fear of dismissal, to approve incorrect design practices. - (Stokes, 2/8/84, p. 2)  ;

91 . Managenent has not and does not practice intimidation in order to supervise engineers in the perfomance of their work. Only U.S.

citizens or Green Card holders were employed as pipe support engineers in OPEG. Further, pernanent residency (green card holders) in the United States allows a person the rights of a U.S. citizen except the right to vote. (8 U.S.C.S. Secs. 1101, 1251}

~

92. If an enployee on green card status is laid off or teminated for any reason, this temination has no influence on their pemanent residency status. They are free to stay in the United States and seek other enploynent in exactly the sane nanner as a U.S. citizen. It is obvious that even the neans to intinidate an alien engineer as alleged by Mr.

Stokes simply do not exist.

XIX. It is alleged that:

The Quick Fix or Pipe Support Design Tolerance Clarification (PSDTC) progran was not subjected to controlled documents, the engineers and QC inspectors were not provided clear instr'ictions, those instructions that did exist (the June 16, 1983 neno) were insufficient I to define the authority of the PSDTC engineers, there was no fomal review of the Quick Fix work, and the Quick Fix l

l progran bypassed the fomal QA reporting requirenents which prevented reporting of serious hardware deficiencies. (Stokes, 2/8/84, pp. 2 to 4) <

93. In January 1983, a special team of pipe support engineers was established within OPEG whose assignment consisted of direct engineering liaison with General Construction resident engineers and Pu11 nan Power O

Products. craft personnel. The purpose of this group was to provide expeditious resolutions of minor construction difficulties in the installation of large and small bore pipe supports in order to mininize construction delays. The responsibilities and authorities of this group were originally provided in Onsite Project Engineering Guide 4.0 on January 7,1983. This guide was superseded by Project Engineer's Instruction (PEI) 12 on March 11, 1983, which defined the PSDTC progran. . The practices defined by these two documents were based upon an identical philosophy and intent, and all guidance previously provided to construction under OPEG Guide 4.0 was again reviewed by engineering for compliance with the requirements of PEI 12 upon its issuance.

94.- As provided in the procedure, field construction problems were defined as pipe support installation problems which could not be resolved using O *" rei *4 ir re trictive ce==*r ct4 #

• i r #ce exPi4c4*i> =* ted 4-Pullman Power Products document ESD-223, " Installation and Inspection of Pipe Supports". Construction tolerances contained in ESD-223 were those that could be applied to any pipe support in the plant without additional er.gineering justification. Changes beyond those tolerances nay be pemitted based upon the criteria contained in Diablo Canyon Design Criteria Memorandum (DCM) M-9, " Guidelines on Design of Cla s I Pipe Supports and Restraints." Field construction problems were referred to PSDTC team engineers who, based on their engineering judgment and knowledge of DCM M-9, would, on a case-by-case basis, detemine whether use of expanded tolerance linits could be authorized to resolve the construction prcblen while maintaining an acceptable

, support design.

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95. Where field resolutions could be made, in the judgnent of the PSDTC team engineer, they were docunented on individual PSDTC foms provided in i Attachment A to PEI 12. Field construction problems which, in the judgnent of the PSDTC engineer, could not be resolved without a design change, were returned to General Construction for fomal referral to ,

Engineering as a DP report requesting hanger redesign in accordance with 1

other project procedures. Pre-existing pipe support configurations found to be in noncompliance with appropriate design and construction documents were referred for disposition as a Pullman Discrepancy Report or Discrepant Condition Notice in accordance with Pullman procedures.

96. The PSDTC engineers were selected from experienced engineers at the jobsite. It was felt that they, Mr. Stokes included, would be in the best position to know whether qualification of the supports could be demonstrated. In no case, however, was the modification nade by the PSDTC engineer allowed to be the final design qualification.

Notwithstanding Mr. Stokes' apparent lack of knowledge, all the PSDTC group's modifications received final engineering review and approval as i part of the as-built acceptance, as required by nrocedures P-10, I-37 and I-40 discussed below.

97. When a PSDTC fom was completed, a copy was attached to the pipe support design package and was treated exactly like the original design package in order to assure that standard quality control procedores were applied to all work accomplished by General Construction. Upon completion of construction of the support, the complete as-built package, including any PSDTC foms associated with that support, was forwarded by i

j Construction to Engineering for final acceptance in accordance with project engineering procedures. These procedures are P-10, "0 PEG Small Bore Piping and Hanger Review Procedure;" I-37, " Instructions for Incorporation of Field Correction Transnittals;" and I-40, " Instructions for the Disposition of As-Builts Associated with Design Change ,

Notices." During the period of Mr. Stokes' employment, final large bore support as-built acceptance was completed by the project engineering team in San Francisco, while final small bore pipe support as-built acceptance was completed by OPEG.

! 98. 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 prepared and issued for Construction.

- +

99. The PSDTC program was neither a substitute for nor a deviation from the formal design and construction quality assurance processes for pipe supports. As stated in paragraph 2.2 of PEI-12, the procedure was specifically not authorized for use in lieu of a Discrepancy Report or a .

Design Change Notice. The program was reviewed and approved for use by both Units 1 and 2 project engineering as well as the project quality 1

assurance organization, all of whom signed PEI 12 when it was issued for implementation. In August 1983 an audit was conducted by the PGandE QA Department which resulted in the overall conclusion that the control of design changes by OPEG appeared to be effectively implenented. One finding was identifiad with respect to use of the PSDTC forms. In response to this finding, special training sessions were held in October O

n l

l l - .- __ __

1983 for all PSDIC ennineers to emphasize the limitations on the use of PSDTC foms and to assure that Design Change Notices would be initiated when required by DCP procedures.

100. Uncontrolled documents we.e not used to promulgate PSDTC progran procedures. These procedures were defined in PEI 12 as supplemented in ESD-223, copies of which were provided to the PSDTC team. The detafis of the program implenentation were emphasized with PSDTC engineers in periodic discussions and training sessions. The June 16, 1983 neno, referred to by Mr. Stokes as an illustration of inappropriate cornunication of progran procedures, was, in fact, written by General Contruction to the piping contractor to reiterate construction procedural requirements already well established. Sumarized, the neao states that the PSDTC progran is not a corrective action progran and may not be used in lieu of construction discrepancy repcrts (DRs and DCNs).

This meno was not applicable to the PSDTC engineers and as such did not receive distribution to then.

101. As stated previously, a discrepancy report rather than a PSDTC form was used to document a pre-existing pipe support ecnfiguration which was found to be in noncompliance with appropriate design documents. The i

PSDTC fom is not a discrepancy report and dces not take the place of one. It may, however, be used to provide disposition for a discrepancy report written by construction. The PSDTC engineer is not, however, I

required to nonitor writing of discrepancy reports by construction.

This would explain why Mr. Stokes did not always see then. Construction discrepancy reports are produced as required by construction procedures.

, O ,

L L

43 -

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. _ _ _ _ . . _ _ . . . ._____,____..,r. .____m__. , , . . _ _ _ . . _ , . . _ _ , . . , . . , , _ . . . _ , . . , _ . . _ _ . - _ . , , _ , , _ , _ . , , , , . _ . ,

. - -. =.

XX. It is alleged that:

Final calculations do not include assunption sheets which would allow specific errors to be tracked. (Stokes, 2/8/84, pp. 4 and 5) 102. In the small bore piping qualification program, important input ,

information for the pipe stress analysis, e.g., nozzle load acceptance, was 'ect tc revision since additional changes in seismic response spectru and other related analyses were in progress. However, prelininary data were available to allcw initial " assumptions" in the analysis to be made. Such calculations were noted as preliminary on the calculation log and in the calculation itself.

103. We believe that Mr. Stokes is referring to these " assumption" sheets that were used to track this preliminary infomation. As data were l

l finalized, the sheets were revised to reflect the updating of preliminary infomation to a final resolution. When all data were final, the sheet was no longer required. The calculation was approved

-as final, and these assunption sheets were discarded. When the calculation reached final status, the calculation naster log was updated to show that all prelininary assumptions had been resolved by noting the calculation as final in the log.

104. An after-the-fact " paper" trail of all the various changes to preliminary input data is not required. Final docunentation includes only the final input data as required by ANSI N45.2.11 (1974). The final input data is retained in the form of input sheets and assunption l

sheets for all calculational packages.

O 44 _

XXI. It is alleged that:

O.

V Expansion anchor bolts have not been evaluated with respect to I&E Bulletins 79-02 and 79-14. Infornation in PGandE's January 27, 1984 letter is inconplete and of .

suspect accuracy. Expansion anchors would fail during Hosgri and DDE. (Stokes, 2/8/84, p. 5).

105. Initially, design of all expansion anchors installed at Diablo Canyon was in confornance with PGandE's engineering standard drawing 054162.

Subsequently, pipe support base plates and expansion anchors were requalified to conply with the NRC's design recomendations in I&E Bulletin 79-02*. Expansion anchors used in other applications (e.g., I raceway supports and HVAC duct supports) renain in conformance with Drawing 054162 requirenents.

106. The NRC specifically linited the applicability of the soneuhat n' ore stringent recomendations in I&E Bulletin 79-02 to larga bore and conputer analyzed sna11 bore pipe supports. As stated in the bulletin, operational problems had been experienced in expansion anchors installed in pipe supports. These problens were attributed to factors that primarily apply to pipe support designs (e.g., cyclic loads and flexible baseplates).

107. PGandE's January 27, 1984 letter addressed expansion anchors used in applications other than pipe supports. The January 27 letter provided an overview of the basis of the Drawing 054162 design criteria and included tabulations of the factors of safety achieved by using the Drawing 054162 criteria. In addition, this letter aridressed testing and

• Mr. Stokes' references to I&E Bulletin 79-14 are erroneous, as the I&E O' Bulletin does not address expansion anchors, but addresses as-built b piping.

evaluations perforned to confim the adequacy of expansion anchors whose  !

installation was not in complete conformance to Drawing 054162 requirenents.

108. As reported in the January 27, 1984 letter, design factors of safety are almost always well above 3 for Hosgri and DDE load cases. A factor of safe 1;y of 3 is considered to be fully acceptable by the industry. The January 27, 1984 letter reported that certain hypothetical limiting conditions night result in a few anchors having a factor of safety less than 3. However, an expansion anchor randon sampling progran, which was perforned subsequent to subnittal of the January 27, 1984 letter, found that out of nore than 100 electrical supports, having nore than '

400 anchors, there was no case in which an anchor had been installed i

such that its factor of safety was below 3. These results were reported i to the NRC Staff by a letter dated February 16, 1984. Further, contrary to the statenent made by Mr. Stokes, this encompasses all load caser, including Hosgri and DDE. Expansion anchor design, including actual l <

safety nargins and redundancy, is reasonable, conservative, and neets all ifcensing criteria.

XXII. It is alleged that:

Due to deficient design drawings for welding, inconsistent and incorrect assumptions were made about certain welds. (Stokes, 2/8/84, p. 6)  ;

109. Contrary to the allegation, there were no deficiencies in the design <

drawings. The Diablo Canyon design groups use a corner radius (R) equal to 2T (where T is the thickness of the tube steel) for tube steel with a 1

1

-g-

I

~

perimeter of less than 14 inches. A corner radius of 2-1/2T was used for perineters greater than 14 inches. In no case was a corner radius of 3T used. These conditions are reiterated by a March 4, 1983 nenc fron Dan Curtis to Diablo Canyon Unit 1 pipe support group and a March 21, 1983 neno fron Leo Mangoba to OPEG pipe support engineers.

4 110. Mr. Stokes alleges that Japanese tube si. eel with a radii of 1.5T was used at Diablo Canyon. That allegation is false. Pullman Power Products purchase orders indicate that naterial shall be donestically manufactured as required by the contract. We have researched all structural steel mill certificates to determine origin and have confirmed that no Japanese tube steel has been received. We have deternined that two purchases of a small anount (3000 ft) of Canadian tube steel has been used; however, the manufacturing was per U.S.A.

. requirenents.

c. .

111. F'fty pipe supports with tube steel menbers with perineters greater than 14 inches were chosen at randon and the corner radii were nessured. In

[

' a few cases radii insignificant 1y less than 2-1/2T were neasured. The f testing described below has shown that for the radii slightly less than 2-1/2T, an effective throat of 5/16R is obtained and the design requirenent net. The tests also show that the 5/16R requirenent is net when the radii are 2T.

i 112. AWS Dl.1 Structural tielding Code Section 2.3.1.4, allows the use of an effective throat of 5/16R (where R = outside corner radius of tube steel) for single flare groove welds without performing a weld procedure qualification test. The 5/16 R dimension ~'is accepted as being a

!O

conservative effective throat that can be increased if additional verifications are made in accordance with Section 2.3.1.4 (2) of AWS 01.1.

113. Test prograns have been conducted which substantiate the effective throat assunption of 5/16R as conservative. One test progran was performed at Diablo Canyon by Pullman and a second test proggan was conducted by Pullman and United Engineers at Seabrook Station.

114. The tests at the Seabrook Station were conducted using standard Pullman Welding Procedures for carbon steel materials. The technical report describing the tests is attached as Exhibit 2. The purpose of this test program was "To verify, as a mininun, that the effective throat thicknest for a flare-bevel-groove weld when filled to the solid section of the bar will equal 5/16R, where R is equal to the radius of the bar." Four sizes of structural tube steel were welded using 3/32" and 1/8" dianeter E7018 electrodes in the flat, vertical, and overhead welding positions.

115. The results from the Seabrook Station tests showed that the actual effective throat equalled or exceeded 5/16R (where R is 2T for tubing with a perineter less than 14 inches and 2-1/2T for perineters greater than 14 inches) by as much as a factor of 1.0 to 1.92, with an average factor of 1.4. The nininun effective throat occurred when 3X3X1/4 tube steel was selded using a 3/32" electrode in the flat position. In that case, the effective throat equaled 5/16R.

116. Tests at Diablo Canyon were conducted using Pullnan's Diablo Canyon Project welding procedures. A brief sumary is attached as Exhibit 3.

- The tests were performed to verify that tne actual effective throat net )

l O ,

C' or exceeded the 5/16R for the worst case identified by the test progran j perforned at Seabrook Station. Six tests were conducted to deternine the typical effective throats which would be achieved for flare bevel joints when welding 3X3X1/4 tube steel using 3/32" and 1/8" E7018 electrodes in the flat position.

l 117. All tests done at Diablo Canyon indicated that the anount of effective throat exceeds 5/16R by a factor of 1.4 to 1.7.

118. In conclusion, field investigations and tests at Seabrook and Diablo Canyon denonstrate that the design requirenents concerning effective throat are consisten+. with as-built conditions.

XXIII. It is alleged that:

Weld procedures and techniques failed to compensate for v weaknesses in design drawings. (Stokes, 2/8/84, pp. 6 and 7) 119. As discussed above, the design drawings had no deficiencics or

" weaknesses" that required welder or welding procedure conpensations.

120. All weld procedures are written and qualified to ASME Section IX and/or AWS D.1.1. The weld procedures were not intended, and do not allou, welders to conpensate for " deficiencies in design drawings."

121. Weld procedures assure that a completed weld will develop the required I

strength for the type and size of the welds specified in the design drawings. For exanple, the qualification tests for a full penetration weld would ensure that the specified strength of the naterial is developed or exceeded.

[d

122. The engineer specifies a weld type and size as detemined by

( )

U/ comprehensive welJ size calculations. The welding is controlled by procedures and is perfomed in a nanner thtt ensures the strength of the weld as specified by the designer is obtained.

123. Weld procedures are nost definitely not written to allow the welder the flexibility to select weld electrode sizes to conpensate for what a welder night perceive as a shortconing in design. Contrary to the Stokes inplication that only 3/32-inch dianeter or smaller welding electrodes were acceptable to conpensate for design deficiencies, and that 1/8" dianeter electrodes were incorrectly used, the tests referenced above have shown that the 1/8-inch dianeter electrodes are acceptable.

{v XXIV. It is alleged that:

Weld procedures, specifically Pullnan ESD-223, did not require joints to be welded flush for flare or bevel welds. (Stokes, 2/8/84, pp. 6 and 7) 104. Pu11 nan Power Products Specification ESD-223 establishes the procedures for the installation, inspection and documentation of the final ass <mbled configuration, i.e., as-building of oipe supports. The current version of ESD-223 does not pemit flare groove welds to be installed without the weld profile at least flush with the flat portion of structural tubing. Past revisions to ESD-223 have had provisions for neasuring flare groove welds which were not welded flush. However, these provisions of ESD-2?.3 were not used at Diablo Canyon because the Unit 1 design drawings did not pemit less than a flush weld.

O

~

v 125. The Diablo Canyon Unit 1 pipe support design groups did not specify

-)

dimensions along with the flare groove weld synbol. The flare groove weld symbol alone requires that the flare groove weld be filled at least flush. .

126. Because the flare groove weld synbols on the design drawings did not specify or permit flare groove welds as being other than flush, Construction was required to provide welds which were flush. This was verified by QC inspection. If Construction had provided flare groove i

welds that were not flush, Engineering would have detected and not accepted the weld during the as-built review progre.n.

127. To verify that this was done consistently, a randon sanple of flare 4

bevel welds was inspected to determine if they were welded flush. A total of 233 welds were exanined. All were found to be welded flush, except for minor variations in five instances. Four welds were 1/16" under flush and the fifth one was 1/32" under flush over a part of its length. The effective throat on each of these five cases was, however,

[ within the desiga requirenents.

128. In sunnary, ell flare groove velds were intended and specified to be flush. The _ design engineers had control over final acceeptance of the welds through the as-built approval process. Verification, through a ,

. sanple reinspection, has assured that the welds are, in fact, adequate.

XXV. It is alleged that:

" The allowable angle of skewed fillet welds is unacceptable. (Stokes, 2/3/84, p. 8)

C e

n -, . - - . , . - - - - - - -

l C

4 129. Contrary to the allegation, the angles, bevels, and weld configurations specified by Pullman in their procedures were qualified in accordance with ASME Section IX and/or AWS D.1.1 dnd were conpatible with design assunptions.

130. ESD-223 did not provide dihedral angle linitations for skewed fillet welds. Limitations for dihedral angles, where applicable, were provided in the design drawings. ESD-223 does not and ns.2d not limit the ,

! application of skewed fillet welds since such limitations are a design concern, not an installation concern. For buildings, there are no j specific limits on the dihedral angle to which a fillet weld can be applied. The AWS D1.1 Code limits the prequalified status and the nethod of qualification of skewed fillets. Ske, ad fillets for angles less than 60 degrees are considered by AWS D1.1 as partial penetration welds for purposes of qualification. Mr. Stokes has confused the L ESD-123 provisions for partial penetration welds with skewed fillot welds. ESD-223 has a requirenent for measuring skewed fillet welds by using a special gauge.

131. .The fact that the partial penetration weld table ir.::1udes a 150 angle for this type of weld is only of academic note, since an angle that i

shallow was never specified by Engineering on the design drawings.

I XXVI. It is alleged that:

37-1/20 groove welds were improper.ly used. (Stokes, 2/8/84, p. 7-8) 132. Mr. Stokes is correct in stating that the 37-1/20 weld preparation i angle for groove or partial penetration welds does not satisfy the O

t -

.-.-------.=---.--..-_x,

l requirements' for prequalified joints in AISC/AWS. However, these Codes do not require exclusive use of these prequalified weld joint configurations. The codes simply state that these prequalified joint configurations may be used without further testing. The codes also provide that other joint configurations are allowed, but they first must be tested to demonstrate acceptability. The groove welds nade prior to June 23,1983 were qualified by testing based upon a 37-1/20 weld preparation angle as set forth in paragraph 146 below.

XXVII. It is alleged that:

ESD-223 and welding procedures were not available to welders. (Stokes, 2/8/84, p. 8) 133. ESD-223 addressed installation and inspection requirenents for pipe supports. The docunent is not a welding procedure specification (WPS) and there would be little reason for a welder to have a copy of.

ESD-223. Welders need not have copies of a W?S in their possession.

They need only be familiar with and have access to WPSs. WPSs for pipe supports are so fundamental and basic that the qualified welders would not need copies in their possession during welding activities. As set forth in the affidavit of Richard Etzler, filed contenporaneously herewith'(paragraphs 6 and 7) welder qualification, testing, and

[

certification ensure welder knowledge of proper weld procedure.

'XXVIII. It is alleged that:

l The ESD-223 fillet weld table is inaccurate and does not use the same effective leg as San Francisco design

. . engineers assuned. (Stokes, 2/8/84. p. 8) l(

i

( , [ -

134. Attachment I to ESD-223 has a table which converts the design weld synbol dimensions to convenient working dimensions for construction and

, inspection personnel to use, because the direct measurement of the design dimension required on the weld symbol is not possible for skewed weld joints. The use of a table converting design dimension to a working measurable dinension is a fairly connon practice and improves l quality control functions by naking neasurenents easier and more direct. Mr. Stokes has confused this table for partial penetration welds as being a fillet weld table.

- XXIX. It is alleged that

Inspection personnel were not qualified to the AWS Code and were not issued weld symbols. (Stokes, 2/C/84, p. 8) 135. The AWS Structural Welding Code did not, vhen Diablo Canyon started, and lO does not today, require AWS qualified inspectors.

be issued the AWS weld synbols. Knowledge of these synbols, like much Iaspectors need not other material, is part of an educational, experience or training background.' These symbols are connonly available in references and need not be issued to inspectors.

XXX. It is alleged that:

The Quick Fix pipe support engineers renoved illegible weld synbols to inproperly receive appraval by QC inspectors. (Stokes, 2/8/84, p. 8) 136. The purpose of the PSDTC group was to assist in clarifying, on a ,

case-by-case basis, pipe support design tolerances which were not explicitly included in Pu11 nan Power Products Specification ESD-223, O

r

" Installation and Inspection of Pipe Supports." This activity was controlled by PEI Nunber 12. An integral part of this activity was the interpretation and clarification of weld synbols.

137. As construction workers encountered weld symbols about which they had sone questions or as they encountered welds which could not be perfor'ned due to inaccessibility, the drawing was referred to a PSDTCG engineer for interpretation or adjustment. During that process it is very p possible that PSDTC engiaeers may have substituted welds which provide effective throats sufficient to neet design criteria for welds which are inaccessible or impractical. In these cases, the PSDTC engineer would elininate the old weld synbol and provide a new weld synbol. An example would be when two sides of a flar.ge are required to be welded with fillet welds, but where only one side is inaccessible. A PSDTC engineer 1

nay substitute a groove weld with the same or greater effective throat and the sane sectional properties as the fillet welds originally

pecified. The PSDTC engineer naking this kind of change would not require access tc the support calculations because there is no decrease in the support capacity. Such changes are comon and are documented in the appropriate PSDTC forns. A conplete calculation package, including the as-built banger drawing is reviewed for final acceptance as set forth in paragraph 139 below.

138. No welds which are necessary for the structural integrity of a support have been eliminated by PSDTC engineers without one of the following alternatives being taken:

(a) Substitution of a weld which provides at least an equivalent

- effective throat;

~ - . , . _ __. .

(b) Modification to the weld pattern to compensate for the renoved O weld;

' ~

(c) Reference being made to the design calculations to ensure that the structural integrity of the support was maintained; (d)' Providing other mechanical connections to achieve equivalent i strength.

139. The engineering decisions of the PSDTC engineer are verified during the as-built review process. At that time the as-built drawing would reflect the final weld configuration, as specified by PSDTC, and this configuration would be evaluated by another design engineer to assure 4

-the qualification calculation:, were compatable with the revised weld

'*- configuration.

f XXXI. It is alleged that:

l QC was not provided with proper instructions and l- calibrated tools to measure radii of flare and flare

bevel elds on an as-built basis. (Stokes, 2/8/84, pp. 8 I

and 9)

! 140. There are no specific Diablo Canyon or general code requirenents i.

existing for field measurement of the radius of outside corners for structural tubing. Dinensional ard nechanical requirenents are controlled through purchase specifications. Pullnan Power Products purchase orders required that naterial be donestically nanufactured to ASTM A-500 specification required tolerances.

1 41 . Flare welds (flare bevel and flare groove) are perfomed on tube steel

[

conponents. Design documents indicate where such flare welds are to be

. installed. Pullman Power Products approved standard ESD-223 requires 0

J ,

s

such welds to be flush with the face of the tube steel. Pullman Power

'O -Products Quality Control Inspectors verify acceptability by applying this criteria. Weld gauges are issued to Pullman Power Products Quality control Inspectors to facilitate their inspections.

142. As discussed in paragraph 127 above, a recent randon sanple of flare bevel welds was reinspected i.o assure flush welds.

XXXII. It is alleged that:

Pullman changed its procedure to standardize weld bevel for partial penetration welds to 450 in June 1983.

However, welds prior to that date did not neet this requirenent. (Stokes, 2/8/84, p. 9) 143.. There was a procedure change in June 1983, by Pu11 nan that standardized i the weld bevel used for partial penetration welds on pipe support

. components to 450 This action, however, was not the result of any action on the part of Mr. Stokes. A large influx of QC inspectors around that time made it necessary to develop a more standardized ,

approach to the pre-weld fit-up neasurenent. Hence, the 450 angle was chosen as a standard with which nost inspectors were faniliar, not to l provide a more acceptabic nethod of welding. As described below, the i

I 37-1/22 bevel angle has been qualified by tests and it was and still renains an acceptable bevel angle.

144. In a recant inspection, the NRC Staff questioned what bevel angle was l

used on carbon steel support nenbers. The review showed that current and recent practice has been to use 450 bevels. This was based upon a June 28,1983, neno to QC inspection, observations in the field, and interviews by the NRC Staff with several QC inspectors. The reference O

Ib

by Mr. Stokes to a June 23, 1983, meno by Russ Noble does not appear to be related to the allegation as described, but refers to stainless steel weld procedures 15/16 snd 129 to be used for welding butt joints in the pressure boundary of piping. The meno did not a;; ply to partial penetration welds for pipe supports.

145. Notwithstanding the above, PGandE has reviewed welds prior to June 1983. Conversations with QC inspectors and production personnel who have been onsite from the early stages of the Project indicate that the practice was to provide a 450 bevel angle. However, the weld procedure, 7/8, which is applicable to pipe support installation, allows bevel angles of both 450 and 37-1/20 and therefore, one night assune there are welds with bevel angles of 37-1/20 146. To qualify the 37-1/20 bevels, Pullman perfomed tests to detemine lh the anount of effective throat that would be obtained using their welding procedures in a tee joinc, welding 3/4" plate with a 5/8" deep partial penetration weld bevel at 37-1/20 using the shielded netal a c process. This joint configuration is a liniting configuration because it does not provide the accessibility of a butt joint. In this case, the design engineer would have assumed a 1/8" reduction in the 5/8" seld size which would give an effective throat cf 1/2". The actual measured

' throat on the test weld exceeded that required by the designer (1/2").

147. In addition to the tests perfomed by Pullman, existing partial penetration welds were examined from previously installed naterial which had been renoved from the plant. One had a bevel angle of 37-1/2 0 (plus or ninus construction tolerances) on a 3/4" base plate to support l

-=- .- -

77/19SL. Its effective throat was measured in tuo places (5/8" and 43/64"). Both these neasurenents net or exceeded the value required by design (5/8" which is 1/8" less than the depth of bevel prepcration).- ,

148. In surriary, the designer specified partial penetration welds that were compatible with single bevel weld preparation angles used by construction. The designer derated these partial penetration velds by 1/8" to account for the lack of fusion at the root. Further, sectioning and neasurement of actual test coupons of typical joints denonstrate that the procedures used by Pullman on partial penetration welds with T

bevel angles of 37-1/20 produced effective throat dimensions that were compatible with the designers' requirenents.

XXXIII. It is alleged that:

As a result of Mr. Stoke's inquiry incorrect buildin novements were changed to reflect proper buiWing novenent. ( tokes, 1/25/84, Tr.11-13).

149. The seismic displacen>dnt of the buildings is provided in DCM C-28 which was originally issued on October 7, 1982. .In this design criteria memorandun, deflection of the base of all the structures for the Hosgri i

evaluation is considered as zero since, as it always has been, the seismic evaluation was based on a fixed base nadel. The fixed base

nodel is, of course, an idealization of the actual case, but for all practical purposes it is a reasonable idealization for the relative i

deflection between adjacent buildings at Diablo Canyon. Contrary to Mr.

! Stokes' allegation these deflections have never been changed as a result of Mr. Stokes' connents, or for any other reason, since they are correct and meet all criteria.

- _ - . _ __. _ . - _ _ _ _ . _ _ _ . _ _ _ _ _ _ _ _ . _ . . .. _ _ _ _ _ _ _ .. _-_ __ _ . _ a _ _ _ _ _ _ _ _ . . _

. = . -- ~ . . - . . .

s.

.150. Fcr the DE/DDE evaluation, a modal was used for sone structures which had soil or rock springs at the base. For this type of nedel, an actual deflectior. was determined and, for the case of the Auxil,iary Building and Containnent, these deflections, to the nearest 1/100 of an inch, were 0.00 and 0.05 inches, respectively. These deflections were reported in Rev. O of DCM C-28 and in every subsequent revision. The models used for the other two structures for which DE/DDE analyses were perforned, Turbine Building and Intake Structure, need fixed base nodels. These deflections were, therefore, zero. Regardless of the calculated value of deflection, fron a practical point of view, no safety ' problem exists s'.nce the novement is extremely small for any I

earthquake notion.

XXXIV. It is alleged that:

In 1983 a nanagement representative from San Francisco, Mr. Dan Curtis, refused to answer rmerous questions and challenges from site engineers who Delieved that Document 049243 was not a conservative basi:: for the seismic redesign program. (Stokes,1/25/84, Tr.13-14) '

151.- Drawing 049243 contains eleven standard support details with associated

. allowable load ratings. The authorized standard supports and acceptable paranetric limits are prequalified by a worst case analysis, the calculations for which are located in San Francisco. So long as the qualified 1md ratings are not exceeded, use of a prequalified support results in an acceptable design. The very nature of the worst case analysis and the'establishnent of acceptable linits results in a 4 conservative but efficient nethod of qualifying sn 11 bore pipe l0 m , _ _ -_ _ -_ . _ _ _ . ..__.____._.___._.__.a_ . . _ . . _ _ _ . _ _ _ .

supports. While PL&E did send an engineer to the site to discuss drawing 049243, his purpose was only to explain recent changes in the procedure and not to discuss or " defend" snall bore criteria as inferred by Mr. Stokes. (See Affidavit of Daniel J. Curtis.) The presence of such person should not be taken to mean that the project at any time considered the use of 049243 to be inappropriate or unconservative.

XXXV. It is alleged that:

Management did not freely distribute professional codes that supposedly paralleled computer analyses relied on by engineers in the seismic design review. In some cases the only reference materials to guide the engineers were the conputer analyses. That is improper, as nanagement effectively conceded in the fall of 1983 through instructions that the conputer analyses were merely a guide and not neant to replace the professional codes.

Unfortunately, the program had officially been conpleted

. when nanagenent disclosed the non-binding nature of the computer analysis. (Stokes,1/25/84, Tr.16-17,120-31) 15.2. This allegation is unclear and not true due to Mr. Stokes' confusion between industry codes and computer codes (the referenced transcript pages do not discuss conputer analysis). A proper reading of Mr.

Stokes' transcribed cocnents, together with his ot'her allegations, leads one to relate this issue to his disagreenent with Diablo Canyon Project criteria (DCM M-9) for angle sectioned nenbers and U-bolt load ratings.

Mr. Stokes alleges that only the AISC code specified bracing criteria for long " angles" and ITT Grine11's U-bolt load ratings should have been l allowed instead of the criteria in DCl1 M-9. This is but one exanple of i

Mr. Stokes' limited understanding of why project specific requirements are used. Mr. Stokes' lack of knowledge as to the basis for these

.o

. ~ . L. . - - - _. .

I project requirenents has led him to allege that indus.try codes and standards were not used. In actuality, indstry codes do ellow the use of testing or other more sophisticated methods to develop project l

specific standards which are then used in lieu of code specified values.

153. The transcript (Tr.121-2) indicates Mr. Stokes' confusion and disagreenent with code provisions that allow for more sophisticated nethods or, in these cases, test data as discussed earlier in paragraphs 16-01 and 76-81. In fact, in the technical discussion with Dr.

Hartznan, Mr. Stokes sunnarized the basic cause of his disagreenent:

"I would like to nake a statenent: that I have never professed to be a PhD in one specific area of all the allegations I have brought up. ' I only profess to be a practicing engineer with reasonable knowledge of industry practices, as any other engineer, and nore in some cases. Anything that is new research, unaccepted as an 4

industry whole, has no ,,,, int being in a new plant, in rty opinion." (Stokes, Tr. 129-30) 154. .Therefore, Mr. Stokes rejected, as not meeting code requirenents, project criteria that were based on testing or more sophisticated methods. Such judgments regarding licensing criteria are beyond Mr.

Stokes' specific job and overall professional experience.

155. The technical adequacy of the project requirements (DCH M-9) for U-bolt load ratings and angle section numbers has been described previously in paragraphs 16-31 and 76 to 81.

1 I

l l XXXVI. It is alleged that:

1 The M-9 conputer analysis for angles onf tted the relevant p(rovision "AISC") code of the forAmerican allowableInstitute bendingofstress, Steel Construction contrary to

.[

.' f'io

- - . . . _ _ . . - _ . . - _ . _ . _.. _ . . , . . _ _ ___m_..__.______._._

l licensing connitnants. Management officials stopped l O engineers from using that section of the code, because con.p11ance required angles to be cut out and replaced witn tube steel, or at least reinforced through braces.  ;

(Stokes,1/25/84 Tr.15m21) l 156. The technical aspects of this allegation are addressed in paragraphs 16  !

to 81 above. The basis for the nanagenent direction for use of the Project specific criteria is discussed in paragraphs 152 to 155 above.

XXXVII. It is alleged that:

Managenent imposed inconsistent standards for l

nodifications in the seismic design review: as the number of modifications approached the limits beyond which PGandE had corriitted to expand the sanple, nanagenent refused to fix deficiencies, even if obvious , '

and more severe than those previously corrected.

Instead, engineers conducting the first round of

- calculations were told to make assunptions contrary to fact, such as restraints that did not exist. (Stokes, 1/25/84, Tr. 23-24) '

O 157. This statement is inconsistent with the small bore piping sanple plan and results identified in the PGandE Phase I Final Report for the Design Verification Progran. The plan consisted of a connitment to review a specific size sample for certain design considerations and to evaluate the results of this review. A specific acceptance criteria established for evaluation of the review results, such as the 5 percent linit f alleged by Mr. Stokes, was never set. The details of the small bore reverification program are set forth in the History of Onsite Engineering Affidavit filed contenporaneously herewith. (Attachnent B).

l 158. All modifications found to be required during the review of the sanple were identified by cause. The cause was then related to a design consideration and the Generic Small Bore Program was expanded to address O

l

. - _ . - - . . . . . = _ . - - . _ -

4 this consideration for all affected piping and supports. The following l issues, initially a part of the sample progran, were transferred to the i

generic progran when it was detemined that the existing design did not meet all licensing requirenents: .

1. Conputer thema11y analyzed sna11 bore piping and associated seismic analysis,

2. Equipnent seisnic and themal anchor novenent, ,

3. Unusual concentrated nass configurations, e.g., nuncious valves or equipment in c concentrated configuration,

4. Nozzle loads on equipnent which were upgraded to show compliance with seismic criteria, and

5. Vents and drcin:. l 159. All piping and supports have been reviewed and are shown to be qualified for those design considerations related to the generic progran.

160. No nodifications were found to be required for those design considerations addressed snd qualified by the sample progran; therefore, it was not necessary to set an acceptance criterion, such as the 5 percent Mr. Stok(s alleged.

XXXVIII. It is alleged that:

Bechtel issued out-of-date conputer STRUDL nanuals to engineers in the seismic-design review. Inexplicably, the office at Diablo Canyon was not on the route slip for

,~

. updated naterials on the computer, and even after that 4 deficiency was corrected the naterials consistently were outdated. The nanual .provides backup infomation to engineers who wanted to check or go beyond the progran.

Engineers in the seismic design review did not have written procedures to guide their use of the STRUDL conputer progran. As Mr. Stokes explained, "All we had i O

-H-1 l

._ .- __________u...____. _ __ _ _ _ ___ _ _ ,_

q was the form handbook of a STRUDEL [ sic] progran ninus  !

Q the pertinent information such as the model load points." (Stokes,1/25/84, Tr. 27, 29,146-47) 1 61. For static analysis used by pipe support designers, the Bechtel STRUDL user's nanual consists of two docunents:

1. MIT STRUDL II, The Structural Design Lar:guage Engineering User's Manual, Volume 1, Frane Analysis, MIT Research Report R68-91.

2. STRUDL III User's Manual.

1 162. Bechtel's Data Processing Library issues the revisions and user infomation bulletin to the controlled copy holders. Contrary to Mr.

Stokes' allegation, three OPEG engineers had controlled copies of the  ;

STRUDL user's nanuals.

163. The first document is essentially the basic user's manual dich has not '

been revised since its first edition in Novenber 1968. This docunent is not a Bechtel controlled document. It was originally issued by MIT, Cambridge Massachusetts. The conplete STRUDL input can be prepared from this manual.

1 64. The second document provides specific instructions, such as how to run STRUDL on Univac; STEEL DATA code, and other enhancenents to nake it easier for the user.

165. Knowledge of the first docunent allows the user to prepare INPUT files l

correctly for running STRUDL. Experience in the use of the STR*UDL  :

progran and a mininun of three years of nuclear pipe support experier.ce were requirements for hiring OPEG job shoppers or casuals in pipe i support design. Therefore, it was not necessary to prepare written procedures on the use of STRUDL. In addition, because the basic STRUDL L

l V . . _ - .

l' d

user's manual has not changed in 16 years, Stokes' concern about O uncontrolled copies of the nanual is largely acadenic.

166. Input foms were also established for OPES to ensure: (1) unifomity of

. input, (2) consistent consideration of maxinun load combinations ard (3) increased efficiency by eliminating rewriting the nandatory STRUDL connands. More load cases and other connands for the analysis of the pipe support frame could be added as required by OPEG engineers, I- including Mr. Stokes.

XXXIX. It is alleged that:

Engineers in the stress group. relied on outdated seismic data that was necessary for their calculations. It took up to six months to receive updates, by which tine the newly-arriving naterial was out-of-date. (Stokes, 1/25/84, Tr. 29)

167. Design of snall bore piping relies upon seismic spectra inputs fron DCMs C17, C28, and C30 developed by the Civil discipline and seisnic anchor

. novements (SAM) of large bore piping to which the snall bore piping connects. It is nomally desirable to delay the analysis of snall bore piping until all such inputs are finalized. However., the Project recognized that some schedule advantages could be gained by beginning with prelinihary seismic input assumptions for the analysis of small bore piping, with final analysis being completed as final seismic input l

'became available. The use of this initfA1 preliminary input data is not of concern since subsequent finalization of the calculation would have corrected any differences in the input infomation. The process of ensuring that the. latest seisnic input was used in calculations was r

O 1

. . .- = . .. .

1 e , controlled by Piping Procedure P-27. This procedure required docunented  ;

review of all calculations affected by C-17, C-28, and C-30, to perfom

~

new analyses where required, and to respond, in writing, when all actions were complete. While it was recognized that response spectra and structural novenents were undergoing a complete review, controlled copies at the seismic input crite-ia were assigned to OPEG in early 1983. As C-17, C-28, and C-30 were finalized, the reviews required by piping procedure P-27 were perfomed thus assuring that all final input infomation was included in the calculations.

B XL. It is alleged that:

Bechtel's ccaputer progran did not have an adequate "menory" for engineers to conduct full analyses of complex hangers. As a result, engineers had to igaore relevant factors as the ucrst case scenarios for force on O the support frane. (Stokes, 1/25/83, Tr. 27, 29, 38-39) 168. In perfoming pipe support work on various nuclear power plants, Bechtel has never experienced a case where STRUDL nemory limitatfors prevented I the analysis of any pipe support frane.

169. Bechtel's STRUDL conputer progran allows the analysis of problems which i

require up to 262K nenory. Analysis of a suppcrt with fifty joints and more than 45 loading cases should not require nore than 80K nenory. In l: fact, a STRUDL analysis perfomed on a pipe support for another project had more than 200 joints and 45 load cases and only required 120K of nenory. At Diablo jobsite, calculations of 155 joints and 32 load cases and 57 joints and 49 load cases have been successfully run.

O I . _ _ . ~

170. The 30K nenory limitation at Diablo Canyon is one that is imposed by the O type of output being requested. If it'is desired to have results inmediately printed on the sane teminal that the input was prepared, then a limitation of 80K nust be imposed. However, if the engineer does not require innediate response, a batch node of operation can be selected and full 262K menory can be used.

171. The problens encountered by Mr. Stokes in perfoming computer analysis seen to sten from his lack of knowledge of the efficient application of the STRUDL computer progran, rather than a limitation on progran nenory.

172. An onsite STRUDL specialist was available for consultation who provided F guidance, as needed, to the pipe support personnel, including Mr.

Stokes, for the efficient application of the STRUDL.

173. Mr. Stokes also expressed concern (Tr. 87-88) about not being allowed to perfom all aspects of the calculation process. At Diablo Canyon, two groups were involved in STRUDL analyses. STRUDL input data were i prepared by pipe support engineers who are skilled in the application of ,

STRUDL for pipe support frane analysis. The second group consisted of conputer operators who did not do any engineering work. The conputer operators are skilled in the computer operation of the STRUDL progran.

This division of effort has resulted in an efficient operation because the engineers were relieved of non-engineering effort, such as typing in their own input files. Mr. Stokes is cpparently conplaining about not being allowed to perfom the clerical function of typing in the STRUDL input.

O

XLI. It is alleged that:

i O There was no consistent procedure or criterion to guide engineers who checked calculations in the seismic design review: they could check whatever they wanted through any nethod. (Stokes,1/25/84, Tr. 31-32) 174. Mr. Stokes is sinply nistaken in this allegation. Engineering Manual 4

Procedure 3.3, " Design Calculations", Section 4.2, identifies the requirements for checking calculations. As shown in the following 4

quotation from the procedure, the procedure identifies the itens to be checked, acceptable nethods to perforn the check, and the checker's actions if the calculation is unacceptable:

" Checking of the calculations shall include:

a) Checking the basis of the design, such as the design nethod, design concept, proper use of design criteria,

l. s and assumptions.

~

i b) Checking the design loads, forces, flows, currents, voltages, naterial properties, foundation conditions, etc.

t c) Checking the results, d) Casparing the results with the drawings to assure ,

conformance of dimensions, materials, etc.

! Manual calculations shall be checked using an alternate

, calculation nethod if possible. When alternate calculations are not feasible, the calculations nay be checked by.a detailed review of a copy of the originals.

This copy shall be clearly marked to indicate that it is the calculation check.

Computer calculations shall be checked for:

a) appropriateness of the progran to the design or analysis b) correctness of inputs

1 c) reasonableness and application of outputs d) conpletenarj )f Computer Calculation Index Sheet infornation.

When the checker has determined that calculations require correction, the calculations shall be presented to the originatoe for correction. The checker shall check the corrected calculations."

175. In addition, the Piping Group developed an implementing procedure P-6,

" Procedure for Assenbling Pipe Support Calculation Packages." This procedure includes an additional checklist of specific itens to be included in each calculation.

176. Experienced engineers at Diablo Canyon are utilized in both an originating and checking function for pipe support calculations, as Mr.

Stokes states in the transcript, page 31, from the January 25, 1984, neeting with the NRC. Therefore, engineers who have the experience 1

l O necessary to originate a calculation and provide the documentation

package for that calculation are certainly capable of checking similar calculations by another engineer without additional detailed procedures. No additional training or instruction in how to check a calculation is required beyond the training in the Engineering Manual Procedures.

! XLII. It is alleged that:

After the NRC obtained certain work packages at Mr.

Stokes' suggestion on December '8,1983, managenent

- directed a purge of relevant files to renove any evidence of previously destroyed or censored work by engineers who failed hsngers but were later overruled. (Stokes, 1/25/84, Tr. 41, 81-82)

O

- .- _ . _- - . - _ _ _ . -. =_= __- -_- . . _ . _ -

177. We categorically deny ever purging files or records. As stated before,

') no approved calculations or app.oved revision to a calculation have been destroyed, altered, or purged. The Diablo Canyon Project does not retain calculations that have not, been approved. This practice is 4

standard industry practice r.s confirmed by discussion with other individuals on Bechtel nuclear projects as well as other architect / engineering firns.

178. Mr. Stokes has grossly exaggerated the number of small bore piping calculations that he produced. In fact, from our records, Mr. Stokes was the originating engineer on 59 calculations and the reviewing engineer on 39 calculations. Of these 98 calculations, 56 of then related to Unit 1, including 13 involving pipe stress analysis, and 42 of then related to Unit 2. The discrepancy between the 300 he estinates (Tr. 83) can be explained rather easily when one considers that there

}

L was not a requirenent to produce calculations at the rate of 1.5 hangers per day. In fact, the assumed < ate for work scheduling was actually 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per support (see paragraphs 192-193). Coincidently, Mr. Stokes' time sheets for the two ; onth period from mid-Parch to mid-May 1983 indicate that he averaged 16.25 hours2.893519e-4 days <br />0.00694 hours <br />4.133598e-5 weeks <br />9.5125e-6 months <br /> per support calculation.

Additionally, Mr. Stokes was assigned to the PSDTC group, where he would l

not produce calculations, for about four months out of his eleven nonth enployment history and about 1 nonth of this history on Unit 1 involved piping stress analyses and not hanger calculations. Therefore, one p

! would have expected Mr. Stokes to have produced about the sanc nunber of l

l calculations that appear in our records for the 6 nonths he worked in

hanger calculations.

1 L

p XLIII.

It is alleged that:

l When assumptions of loads were changed for preliminary calculations on pipe supports that previously had failed, l

. typically no one redid or checked the entire '

calculation. This step was necessary to determine tnat the new conbination of variables in its entirety would support a conclusion to pass the pipe support. In Mr.

Stokes' judgnent, this allowed hangers to pass which should have failed. (Stokes,1/25/84, Tr. 50-51) 1 179. Design data for a pipe support calculation, such as loading information and piping novenents, are supplied to the pipe s';pport engineers by the piping stress engineers. However, these design data may have been derived from assunctions or preliminary infornation. This process is described in detail in paragraphs 102 to 104 ab'ove.

180. Once revised preliminary design data is received, all pipe support calculations are reviewed to assure qualification to current pipe loads, displacements, and acceptance criteria. These reviews cause various degrees of calculation revision. The extrenes of the revision are: (1) sinply documenting compliance to revised load and displacenent input in cases of inputs that are less severe than those used in the previous analysis, and (2) coaplete recalculation, including support nodification.

1 81 . In cases of partial calculation revision, the previous calculation is retained to complete the design qualification calculation.

l l

XLIV. It is alleged that:

Mr. Stokes was unaware of the nomenclature for calculation revisions. (Stokes,1/25/84, Tr. 51).

182. The small bore piping portion of the Corrective Action Program began in the' Fall of 1982. It involved review and analysis of the installed l V(3 l

l t

L piping and pipe supports to show qualification or to develop nodifications where necessary ti$at would result in qualification under the program.

183. The pipe support modifications issued under the verification progran involved either changes ta . existing supports or the addition of entirely new supports. In the case where modifications to existing supports were necessary, the documentation of the pre-existing support configuration was designated as Revision 0. This included all approvals granted under the jurisdiction of pre-1982 procedures.

184. The initial version of' calculations conpleted for such supports under the reverification progran was designated Revision 1 of that support calculation, with subsequent revisions nunbered sequentially thereafter. In the case of the addition of an entirely new support, the initial version of the reverification program calculation was designated Revision 0, with subsequent revisions numb.tred sequentially thereafter.

Letter revisions of calculations were not used.

XLV. It is alleged that:

Mr. Leo Mangoba, _ the Bechtel official who supervised engineers in the pipe support group, approved the seismic review calculations en masse over several days without studying and properly reviewing the work. Mr. Mangoba did not even get to the calculations until a few days before the end of the program. Supposedly Mr. Mangoba's appr; val was one of the checks and balances on the quality of the calculations, but it was pro forma.

(Stokes, 1/25/84, Tr. 52.)

185. It is true that at the end of the progran Mr. Mangoba approved approximately 100 calculations in a several day period. However, to state that they were not properly reviewed is incorrect. Mr. Mangoba O  :

4

- 73'-

had instructed five other senior experienced engineers to perfom a detailed technical content review prior to providing the final calculation packaga for his approval. These reviews were done in addition to the nomal checking of the calculations.

1 86. Mr. Mangoba then approved the calculations as required by Engineering Procedure Manual. This final approval authority was assigned to only two individuals in OPEG pipe support group in order to provide consistancy in the final docunentation packcge.

XLVI.' It is alleged that:

Management did not have necessary documents frou vendors and nanufacturers to guide calculations on required

supports for vendor purchases such as valves. The omission helgs to explain why engineers based their analysis on past experience at other plants brought in fron previous jobs. Managenent at Diablo Canyon did not O send drawing details and support conditions to valve nanufacturers and other vendors for approval. The

. vendor's review and approval is necessary to assure that the component is being used as intended. This omission was unique in Mr. Stokes' experience in the nuclear industry. It represent: nore necessary infomation that

< was missing from the seismic design review program.

(Stokes,1/25/84, Tr. 54-55.) -

187. The design of valve supports and qualification of the valves for support location and forces was not perfomed based on "past experience" as alleged but, instead, was based upon specific approved criteria, procedures, vendor supplied data, and review and design standards.

-188. Piping qualified by computer analysis includes the nodeling of each remotely operated valve. These nodels include the location of the valve and operator center of gravity (C/G) and nass. The C/G location, mass, and allowable accelerations are provided by the vendor and are O

, V l

l documented in Design Criteria Documents and drawings. In a very few cases, presumably the omissions alleged, the valve supplier was no longer in business and therefore could not provide the location of the valve C/G. In these cases the valve C/G was assumed to be two-thirds the distance from the valve center line to the top of the operator based upon previous experience. This instruction is contained in Piping Procedure P-11. The calculated valve acceleration provided by the conputer analysis is compared to the vendor allowable to show qualification. If support of the valve is required to meet criteria, the analysis is reperforned with the added restraint included. The analysis results provide forces on the support and valve. These forces are then converted to equivalent valve accelerations and compared to 1 supplier allowables to demonstrate qualification.

189. Piping designed by manual nethodology, as directed by Design Criteria Menorandun M-40, required supports to be installed on all remotely operated active valves. The supports were installed in pairs: one on the pipe at the valve and one on the operator. This methodology ensured that there was no differential novement between the pipe, valve, and

valve operator and assured valve qualification for both stress and operability considerations.

l l 190. Guidance for design of. valve supports was provided by design standards.

L However, all valves restrained by valve supports were reviewed by either the supplier or an independent project engineering group to ensure that valve integrity, operability, and accessability for maintenance .<ere l

L provided. The review was directed by written procedure and the results are documented.

l l

-^

- . - -. - _- ._ _ - _ . - . ~ _.

XLVII. It is alleged that:

Managenent's production schedule for the seismic design review made it impossible for engineers to think clearly, let alone produce consistently high-quality calculations. For extended periods, they were instructed to conplete 1.5 hangers per day on a schedule of seven days and 84-120 hours per week. (Stokes,1/25/84,Tr.  ;

62-63, 89-91).

1 91 . As Mr. Stokes himself states in the transcript (Tr. 89),1-1/2 hanger design completions per day was not a mininun standard for continued enployment. The unit rate for support design calculations used in i

scheduling work was assuned to be 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per support as an average for all supports. Sme simple supports would require less tine while nore complex supports would take longer.

192. During one period fron December 1982 through January 1983 there were two three-week periods when abnormally high overtine was worked to support unusual schedule denands. These periods were broken up by the two week Christnas holiday period when a substantially reduced level of overtine was worked by these engineers not on vacation. During these two periods, there were only eight instances when an individual engineer's

. weekly time charges exceeded 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br />, with the naximun being 114 hours0.00132 days <br />0.0317 hours <br />1.884921e-4 weeks <br />4.3377e-5 months <br />. With the exception of these two abnornal periods, time charges for OPEG pipe support engineers averaged approxinately 65 hours7.523148e-4 days <br />0.0181 hours <br />1.074735e-4 weeks <br />2.47325e-5 months <br /> per week.

XLVIII. It has been alleged that:

In sone instances engineers approved hangers solely on

-- the basis of conclusior.s in file 049243 for similar pipe i supports, without any independent evaluation. This was i known as the " cookbook" approach. (Stokes,1/25/84, Tr.

l 75-76, 91.)

Lo I . . . - . . . . , . _ _ . . - . . . - . - . _ - . - - . - - - . . -

- .. . _ ._ =- - - . - - - -. - . - .. - - _ - -

I l

193. .We agree that certain sna11 bore pipe suppo. is were designed based solely on the drawing 049243.

194. It is connon practice in the nuclear industry to provide conservative prequalified load rated design standards to be used in the design of I small bore piping. Extensive calculations or testing results provide the necessary docunentation to show qualirications of these standards to all applicable licensing criteria. The drawing 049243 describes many of these pre-qualified standard pipe supports used on Diablo Canyon.

195. It is not necessary or required for each engineer who uses drawing 049243 to review all the backup docunentat'on to ensure that the calculations or tests do indeed neet the licensing criteria. However, these docunents are available for inspection by the NRC.

196. khen a prequalified standard design was used to qualify an existing support or to design a ncw support, all aspects of the appropriate .

support parameters were compared to the requirenents of Drawing 049243.

f If any paraneters did not neet these requirements, the supports would be designed by individual analysis and fully docunented.

XLIX. It is alleged that:

Early in the seismic design review, nanagement instructed engineers to check a blank on the fom that the calculation results would not affect the Final Safety Analysis Report ("FSAR"), despite the engineers' protests that they did not know what was in the FSAR. Eventually, blank forms were just xeroxed with the "X" filled in and distributed to the engineers for their calculations. The only way the engineer could ensure accuracy was by whitingout what was already there. (Stokes,1/25/84, Tr. 96-97).

197. The calculation cover sheet referenced in the allegaLion is the standard cover sheet required by Engineering Manual Procedure No. 3.3, Design I - -. - - ,, ,__ - .__ - - - . - - - . _ . . _ _ _ _ , __ . . _ _ _ _ . _ _ _-

Calculations. The sheet contains the requirement' to check if the calculation affects the FSAR.

I 198. The Diablo Canyon piping procedures, themselves, ensure that the design and analysis methodology and criteria comply with all licensing requirenents including those contained in the FSAR. Therefore, implementation of these procedures by pipe support designers a:sures that the requirements of the FSAR are net. This process provided the ,

basis for supervisors' instruction to subordinates to check the "SAR i

change required 'No' hox". Fipe support design engineers activities are directed by these written criteria and procedures, so that engineers, .

including Mr. Stokes, need not be familiar with the FSAR.

i L. It is alleged that:

Engineering calculations that called for field modifications were altered after complaints fron construction, without the knowledge or approval of the 1 originator. Tempering with calculations in this manner was highly improper. The significance is that in an unknown number of cases, corrective action required on the basis of documented engineering analysis was informally circumvented. The basis for revising the nodifications is unknown. (Stokes,1/25/84, Tr. 98A)

! 199. A careful reading of Mr. Stokes'> transcribed remarks indicates that his conplaint involved the nodification of a support sketch to resolve construction interfercr:ces. This, of course, is the process involved in or the PSDTC progran for which Mr. Stokes, hinself, volunteered.

200. There is nothing improper with minor nodification of a support sketch by a qualified support engineer. to resolve a constr uction problen. Such l

nodifications would be subsequently reviewed by other qualified engineers as part of the.as-built approval process.

201. It was inpractict.1 to have each support design engineer always provide the solution to construction problems and to review the as-built drawings to approve the changes to the specific supports that they had originated. Engineers in the PSDTC progran, including Mr. Stokes, developed solutions to construction problems and nodificd the design support sketch to reflect this solution. These changed as-built drawings wre subsequently reviewed and approved by support design engineers.

LI. It is alleged that:

Multiple engineers independently produced preliminary calculations on the sane hangers. Besides being wastefnl, this practice gave nanagement the option to throw out the calculations that failed hangers and keep those that passed. (Stokes,1/25/84, Tr.99-100. )

, ( 202. Tne same hanger support was not intentionally assigned to nultiple engineers to perforn qualification calculations and, therefore, provide an option for management to accept only calculations showing qualification.

203. Snall bore pipe supports were assigned to derign engineers by support identification nunbers. This process normally assured that each engineer was assigned a different support from that assigned to other engineers.

204. Occasionally several supports, each having different identification nunbers, are " ganged" together with interconnected structural menbors.

205. Such a " ganged" support cannot be analyzed correctly by different engineers separately analyzing each support since loads from one support

, g nay be transferred to another support.

'd

4 206. ~When the approving supervisor discovered that a " ganged" support was assigned to several engineers due to the nultiple identification nunbers for individual supports, individual support calculations were superseded and the " ganged" support, with all connected individual supports, 4

reassigned to one engineer for calculation. Therefore, while aspects of the allegation are correct, the nischevious intent alleged is false.

LII. It is alleged that:

Managenent officials overruled engineers who attempted to calculate the effects and stresses of torsional loads, created when pipe supports were twisted to tighten then during installation. This is an obsolete technique in the nuclear industry, and according to a former engineer in the seismic design review, it is hardly ever used unless totally qualified by structural calculations.

Eagineers were told not to calculate for torsion and were overruled when they did. The stated reason was that "the hanger would fail." (Stokes,1/25/84, Tr.103-04,123.)

207. Contrary to the allegation, a check- for torsion in angles is required, where applicable. Piping Procedure P-6, " Procedure for Assembling Pipe Support Calculation Packages" provides standard form: to be used in the preparation of calculation packages. Attachment F to P-6 provides a checklist for STRUDL frame analysis. One of the itens requiring entry is a check for torsion. This check evaluates the shear stresses that result from tcrsion in the angle sections.

208. Mr. Stokes further alleges that induced warping or bending effects as a result of torsion in angle sections have not been considered. Warping is not a phencnenon that occurs in angles. The only stresses induced in menbers where all plane sections remain plane are shear stresses.

Sections which renain plane after twisting include open sections O ce=Pr4 4 9 t e t"4 rect eie . sec* eie er tee sectie - 1 these

,,>--vw,,-,,-e~,.---n .

sections the only stresses resulting fron torsion are shear stresses and, therefore, warping or benaing effects are not considered since they do not exist.

209. Tuo textbookt which explain in more detail the phenonenon of torsion in  :

angles and the resulting stresses are the " Steel Designers Manual",1/

. pages 105 to 116 and the Bethlehen Steel Handbook entitled " Torsion Analysis of Rolled Steel Sections =2/ page 72.

21 0. It is true that some computer programs, such as GTST%DI., do consioer the effects of warping due to torsion. However, these programs do not, for the reasons mentioned earlier, address additional normal stresses created by warping effects of torsion on angles.

211. On the Diablo Canyon Project, the shear stresses resulting from torsion in angles art added to other shear stresses and conpared to AISC allowables for shear. In the case of angles, no increase on bending

-stresses due to torsion was included, nor is it necessary for the reasons described above.

References:

1) Steel Designers Manual 4th Edition f

Granada Publishing Limited 1221 Avenue of the Americas N.Y., N.Y. 10020 i 2) Torsion Analysis of Rolled Steel Sections Bethlehen Steel Corporation 81 -

t

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- - , - , - -+_ , . ,., ,,. . --, , -.- ,.,- n ,,,,,,p. ----,-,,e,, , . , , . . , _ . , _ , , , , , , , , - - - ,

7 . ,- -

LIII. It is alleged that:

Engineers onsite had to wait up to a week to obtain infomation on the telephone from San Francisco that would nomally be on the drawings and was necessary to draw engineering conclusions. Combined with scheduling requirenents, this systen created pressure on engineers  ;

without the benefit of data on which they would nomally rely. There was no system or procedure to verify the i accuracy of design infomation received on the telephone from the San Francisco offices. In the absence of any 1 such procedures, the data was unverifiable despite engineers' doubts about its accuracy in some cases.

(Stokes,1/25/84, Tr.110-112) 212. It is possible that, durina certain. periods, onsite personnel nay have had a delay in obtaining infomation from San Francisco. To minimize this inefficiency, onsite engineering personnel were temporarily relocated to the home office in order to provide data to onsite engineers. This infomation was transmitted in some cases by phone in order to expedite the perfomance of prelininary calculations.

Engineering Manual Procedure 6.1, Section 4.4 specifically states that all design information provided verbally must be confimed in writing.

Engineering Manual Procedure 3.3, Section 4.1.2 provides that data requiring verification at a later design stage be identified and the calculation cover sheet marked " Preliminary" until verified. This was the procedure used for such circumstances throughout the reverification program. While this practice is allowed, it was not commonly used except for brief periods or special cases. In all cases, data was subsequently provided by nomal document control procedures ano verified prior to finalizing affected calculations.

O 1

4

' LIV. It is alleged that:

The initial records for hanger calculations later covered by the seisnic design review are totally unprofessional and unacceptable due to the inadequate underlying documentation, as well as the lack of signatures and evidence of a checke or other approval for the great najority of ' calculations. The records are so deficient that the seismic design review nust be expanded from a sample to cover 100% of relevant hardware, Reliance on a sample assuned the existence of a conprehensive, if questionable, base of professional engineering calculations. In Mr. Stokes' professional judgnent, such a base did not exist. The plant cannot be licensed on the basis of a sanple base of minimally-acceptable engineering calculations. (Stokes,1/25/84, Tr.113-15) 213. At the time that the original design of small bore piping was undertaken, the small bore pipe support design, including support '

spacing, was specified by design standards. These standards included prequalified, load rated standard support details in PGandE Drawing l 049243, the calculational basis of which vere prepared by PGandE's Mechanical and Nuclear Engineering Department in San Francisco. Fullman Power Products detailed and installed supports as specified by this I

standard.

214. Engineering authority was delegated to General Construction to approve l

ninor modifications to these details where required to facilitate installatien, provided that the original design intent was naintained. ,

In sone cases, simplified calculations were performed to justify these deviations from the standard details. In sone cases, supports were found by inspections to have been installed at variance with specified l standards, and contractor discrepancy reports were written to docunent i

these problens. In order to resolve the DRs, calculations were perfomed to qualify the installed condition.

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o 21 5. In sunaary, every small bore support was docuiented by an individual U support drawing which had received engineering acceptance based upon the prequalified standard of Drawing 049243 or authorized deviations fron 049243 justified by calculations where required. The complete e r ecords of the drawing 049243 calculations were maintained in the San Francisco engineering offices, which would explain Mr. Stokes' lack of taniliarity with them.

LV. It is alleged that:

At the time of Mr. Stokes' departure, plant operators did not have access to a centralized document center with all infomation necessary to respond to conditions in the plant. This could compromise operators' ability to nake all decisions from the control roon in an energency.

(Stokes,1/25/84, Tr.115-16) 216. Document systems, controlled by procedures, are in place, which ensure that plant operators have inmediate access to all drawinos and docunents necessary to safely operate and naintain the plant.

21 7. The Design Control Procedure, Engineering Manual Procedure 3.60N, requires review of all safety-related design changes by the Plant Staff Review Cormittee (a plant operations coraittee) prior to release for construction. The procedure also requires the operations organization to be infomed upon construction completion of each design task. The operating organiz& tion has procedures which interface with 3.60N to ensure that this current information is distributed to all document control centers and individuals identified in their drawing distribution lists. Upon completion of construction and as-bcilts submitted to O

Engineering, the pemanent plant record drawings inportant to safe operation and maintenance are revised to incorporate the changes and l I

, issued within one month.

. 218. The PGandE Records Managenent Systen (PJ45) provides a computer-based I nultiple cross-index listing of all important plant records. This listing provides reference to the location of records on microfilm. '

This system is accessible from the plant, and all microfiln required for safe operation and maintenance is available to the operating organization.

LVI. It is alleged that:

Mr. Stokes reported errors in the M-9 conputer analysis, '

which incorrectly instructed engineers to consider small-bore baseplates and non-computer analysed piping lines as rigid. In fact, the baseplates and lines are O flexible. The assumption was inconsistent with other instructions to cciculate displacement for the bolts on the basephte. (Stokes,1/25/84, Tr.138-41. )

?,19. Design Criteria Memorandun M-9, " Guidelines for Design of Class I Pipe Supports," states in paragraph 6.8.1.1; "Small bore pipe support base plates on non-computer analyzed lines nay be considered rigid for purposes of pipe support evaluation."

- This assumption is in agreement with the requirements of NRC I&E Bulletin 79-02 for pipe supports on piping systens that were qualified by conservative alternate analysis rules or " span tables." '

220. In instances where baseplate flexibility could significantly affect the frequency of the pipe support, it has been considered. An exanple is the inclusion of baseplate flexibility when calculating the natural LO 85 -

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( frequency of a simple cantilever; bean. Accordingly all simple

,} cantilever beans with baseplates included consideration of base plate flexibility in tne natural frequency calculation. In more complex structures, the nonent resistance of the frane reduces the effect that any baseplate flexibility would have. As a result, baseplate flexibility is ignored since its effect is insignificant to the overall support natural frequency. However the flexibility is considered in calculation of anchor bolt loads in accordance with I&E Bulletin 79-02 and Diablo Canyon licensing connitnents.

2 21 . The Bechtel procedures referenced by Mr. Stokes (Tr.141) require consideration of baseplate flexibility for calculation of natural frequency of cantilever beans. This was precisely the practice at Diablo Canyon.

222. In discussions with the NRC Staff (Tr. 148, 149), Mr. Stokes indicated that the STARDYNE computer code was not used for Diablo Canyon.

Instead, the progran BASEPLATE II was used when " flexible plate theory" was required. Mr. Stokes is apparently unaware that BASEPLATE II is nerely a preprocessor for STARDYNE. BASEPLATE II transfoms the relatively simplified input infomation required for baseplate analysis into nore conplicated STARDYNE input format. It seens fronic that an engineer who apparently probed with such attention to minute detail in 8 sone areas of support design was unaware of this computer progran application.

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LVII. It is alleged that:

Similar to the experience of Mr. Stokes and others in the pipe support group, engineers in the stress trailer were transferred after challenging suspect changes -- such as elimir.ating eccentricities -- in the models for thc seismic design review calculations. The reluctant engineers were replaced by personnel who cooperated with questionable nanipulation of nodels. In fact, there were considerably more personnel shifts in the stress group than the pipe support group. (Stokes,1/25/84, Tr.151)

223. As with the pipe support group, the stress group experienced reassignnent of some persor.nel to the Unit 2 small bore effort in the Spring,1983. However, this did not involve physical transfer of personnel since almost all stress group personnel could be located in 4

the one trailer which they already occupied. Contrary to statenents in the allegation, no attempt was made to transfer personnel in the piping stress group on the basis of objections raised regarding analysis nodeling techniques. It is true that, as with pipe support analyses, a difficult or troublesome stress calculation might be reassigned to a different engineer to take advantage of greater experience or ,

familiarity with acceptable alternate calculation techniques. We reject the inp11 cation that reassigning calculations for this purpose is l inappropriate.

LVIII. It is alleged that:-

Contrary to nanagement assertions at the December 15, 1983 neeting with NRC staff, the calculations that replaced those rejecting pipe supports were not not-refined and sophisticated. In fact, the opposite was true: less sophisticated analysis was used. The models i for subsequent calculations eliminated the unique eccentricities relevant for particular pipe supports.

(Stokes,1/25/84, Tr. 85-86,152-53.)

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224. We are sare of only two situations which, upon initial observation 3 O might appear to support Mr. Stokes' allegation. In one case, as

. outlined in Mr. Stokes' neeting with NRC', hanger 100-132 was analyzed with less sophisticated nodeling techniques to denonstrate its ,

qualification. To the best of our knowledge, including.the rereview of over 100 support design calculation packages, this was a unique case.

, (Also see the Affidavit of Alex Shusterman) 225. A second situation which could have led to this allegation. Mr. Stckes believed (Tr.134) that if a support component exceeded ATSC criteria for bending of angles or ITT Grinnell's U-bolt load capacity, the support was not qualified, even though it would be acceptable under the less conservative Diablo Canyon Project criteria. Mr. Stokes was willing to accept only the AISC and Grinnell load ratings as qualification criteria.

226. In such a situation, engineering supervision would then g!ve the

, calculation to an eq: ally qualified engineer to review in accordat:ce with project criteria, whereupon it was qualified. This sequence might 4

lead one to believe':

(1) Since Mr. Stokes failed the calculation, it was given to another engineer to qualify.

I (2) Less conservative rules were used when the support would not qualify.

h While both these statements are literally true, they are the result of perfectly acceptable techniques for resolving a problem.

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227. However,;in a more general sense, the ca k culations were, in fact, based on nofe sophisticated nethods, since the project specific criteria for angles and U-bolts ware based upon detailed. evaluations and test results.

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Dated: March 5,1984 9

' FRED C. SKEI5MEISTER AL DANIEL J. ___ TIS

&b PYRpNE.LEPPK

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q hQ~ $. Nh.m RODERI G. OMAN I Xh.M _x - w g LARRY E. PLEY T

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$la~C/OL WILLIN4 H. WHilt.

Subscribed and sworn to before ne this 5th day //

of March,1984. A , /V.

GARY H. 100RE a"Y w.a m. m_

r Mcy J. Lenaster, v SEAL MICHAEL J.~ JACOB 5DN

! Notary Public in and for the City and County of San Francisco, State of California.

l My comission expires i April 14,1986.

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$ NANCY .!. LEM ASTER M

Fj. O 3 noTuvFr.ux :can;AEM l ;c - -

CliY AND COUNTY OF .

A NJ D '.M,. N' SAN FhANCISCO 8) j V Commission Espires Aptd 14,1996 N l

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List of Exhibits ,

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Exhibit 1 PGandE Memorandun dated March 22, 1982 Exhibit 2 United Engineers and Constructors, Inc. Report, Attachment C, May 20, 1983.

Exhibit 3 United Engineers and Constructors, Inc. Report, Attachment D, May 20,1983.

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Exhibit No. 1 PO3 8WJ.CingPANY t*CRt6 PACIFIC GAS AND ELEC7TRIC COMPANY orncr or ras CHAIRMAN March 22, 1982 TO: PGandE OFFICERS, ENGINEERS, TECHNICIANS AND OTHERS DIRECTLY INVOLVED IN THE COMPANY'S NUCLEAR FACILITIES This letter is to reemphasize the Company's long-standing commitment to design, build, and operate safe nuclear power plants and in achieving this commitment to require all employees to practice fundamental honesty and to adhere to Nuclear Regulatory Commission ("NRC") rules and regulations.

This is also to reemphasize that our communications with the NRC must be open and allow a free flow of information. We must be ever alert to any possible

(- misleading or ambiguour statements inade either in oral or written communications. Any such misstatements must be corrected immediately upon discovery. Nothing less than full and open communication between the Company and the NRC can be tolerated.

In October 1975, PGandE formalized its general policy concerning employee conduct (Standard Practice 735.6-1).

The statement of policy establishes a Company philosophy regarding work conduct emphasizing that:

"It is the policy of this company that employeer, shall at all times continue to l pract. ice fundamental honesty. Employees i

' shall not, nor attempt to: deceive, defraud, or mislead the Company, other employees, or those with whom the Company has business or other i relationship; ... misrepresent the Company or-its emp3oyeen; ... withhold l

their best efforts to perform their work to acceptable standards; ... violate

! applicable laws; or conduct themrelves at any time dishonestly or in a manner which Company."

would reflect discredit on the This policy is particularly important to all' employees engaged in work concerning nuclear power.

1

To All Addressed March 22, 1982

(

In April 1976, Mr. J. D. Worthington, and again in 1980, Mr. J. O. Schuyler, issued a memorandum to all personnel involved in the Company's nuclear power work which described a program to permit such personnel to discuss their concerns regarding nuclear power. The August 1980 letter stated that:

• l

"[Our) purpose is to again reaffirm the '

Company's strong commitment to the protection of its employees and the general public against any unsafe situation with respect to these nuclear facilities and, further, to assure that you have every opportunity to communicate freely to your Company any views you might have on the safety of nuclear facilitiss. >

"We believe that you appreciate your right and obligation to express yourselves on matters of safety and that you have the dedication and individual initiative, insofar as your

( responsibilities are concerned, to see that our nuclear facilities are designed, constructed, and operated in a safe manner.

"To give you added opportunity to ask questions or to express your views on any aspect of the safety of nuclear l

i facilities, including those outside your own sphere of responsibility, we encourage you not cnly to talk to your supervisor, but also, if you wish, to l

any one of the following people who have been designated a review team to answer questions and to evaluate the views of any employee who wishes to express any concern whatever about the safety of nuclear facilities:*

We are proud that the application of these policies of openness in finding and evaluating safety issues led l directly to the discovery by PGandE personnel of the " mirror i

image" error at Diablo that otherwise might have gone undetected.

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i

To All Addressed March 22, 1982 f

Recently, in February of this year, Mr. R. C.

Thornberry issued a separate memorandum to Diablo Canyon Power Plant employees which reiterated the Company's policy concerning adherence to government rules and regulations.

We must of and operation strive our for perfection nuclear units. in To design, construction, attain this goal, it is necessary that we all exercise our best efforts to resolve problems we encounter in our work. When problems are encountered, they must be inmediately identified, clearly defined, and brought to the attention of your supervisor. This approach should facilitate the evaluation of, and formulation of timely and effective solutions to, any problem.

all levels.

Constructive recommendations are encouraged at Our goal is to design, construct, and operate our nuclear facilities with full margins of safety and full compliance with NRC requirements. Strict adherence to the above policies will be met.

will provide added assurance that this goal

( .tk.

F. W. MIELKE, r.

&^ B. W. SHACKELFO cc: Officers Department Heads Division Managers All Concerned Personnel l

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. Exhibit No. 2

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• SM: 4579A

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Date: Eay 20. 19E2 File No: 21.,E,1 ,

UKTTD EKCIKED.5 & CON 57.UCTORS INC. '

, TECIDTICA1. RDORT Date: May 20, 1983 Purpose of Report  : Qualification and varification of Tiare-Bevel Greeve Walds - Square Tube Distribdtion: M. P. McKenna DEC591 W. J. Duffy CEC 529 D. C. Turnquist E C589 E. C.141thead DEC294

5. J. Pattisen DEC262 A. Scadopadhyay DEC589 R. W. Gregory R C585 M. 3. Lasota UEC5E9 .

E. E. Serg UEC196 P. E. Jathaveda: UEC767

5. C. Sethi , DEC286 3. Basu E C5ES Y. M. Alaan UEC196 5. C. Madaras CIC569

5. N. Caruso M C290 C. W. Mourar UEC392 J. P. Whoriskey E C296 R. A. Mills TEC292

( J. R. Slotterback. 11U0 3. J. Eusalton UECSE9 D, I. Ebonds 07U4 C. P. Ealani 09U4

1. M. Reyes UEp143 J. M. Benenati 09US R. R. Bryans DEC262 5. E. Guha UIC2E2 M. A. Edga UEC164 J. E. Julian EEC262 R. C. Savonty UEC786 M. J. Kenop'r.a 07EE G. A. Gallant UEC262 DCC Tield IIC185 P. A. Leone DEC591 DCC - PA 0601 C. T. Rigamenti 0704 SM Tile UECibi

3. C. Levine -UEC262 l J. P. Cannon 14U3 I. J. Esplan 17U4 Baport Prepared Ey: / / s T. R. frelo l Esport Approved Sy: \l'S h -

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T. P. Tassa11o. Jr.

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SM: 4579A

- Date: May 20. 19E3 File Bio!.11.E.1 o -

- S A'IFICATION A C TERIFICATION OT '

. i FLARI BETEL GRDOTI WE:.D!

Purpose - To verity. as a ulaima=, that the effective throst thickness for a flare-bevel-groove weld when filled to the solid section of tan bar will be equal 3/161 where R is equal to the radius of the bar.

Materials e Tubular steel afses 3" x 3" a %". 4" s 4" x 3/8". 6" x 6"

, E %" med 3" a B" a " ASD! A500 was used.

Walding process - The shielded metal are welding process was used. uti-11 aims STA 3.1. E7018 electrodes with multiple passes.

Preheat and Interpass - The =i=4== preheat and interpass temperature '

was in accordance w(th AEK1/AWS D1.1. Table 4.2. '

Procedures for Shisided Metal Arc - The welding was done in the vertical.

( everhead and flat planes stilicing 3/32" and 1/8" diameter electrodes in each position. The welding persneters were as follows:

3/22" - D2?.70-120 amps. 20-27 velts 2 ips ain. travel.

1/8" -DCIP.115-165 amps. 21-27 volts. 2 ipa zin. travel.

Qualification - The sa:gles are sectioned for risus 2 ===*antioe.

The welds were free from cracks and there was thorough fusion between adjacent layers of weld metal and the base metals.

The welds, is. general, were visually acceptable.

Conclusion - In general. 3/32" S electrodes showed good penetration ex-esadicg the minimar. throat thickness by approzinstely 501 except there were some problems with the 3" a 3" s k" tubes.

l The easil radius did not permit the depth of penetration.

The 1/8" # alectrodes showed excellent penetration for asceeding the =taima throat thickness for the flare-bevel-groove welds.

It is recommended that the Contracters be directed to utilise 1/8" # electrocas for the first pass to insure adeguate pene-tration.

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_,_ Exhibit No. 3

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AIPullman Power Products Corpob[ ion c y

h p% cae.n,uye wps' Prwet 24 DATE: DECDSER 9.1983 ,.

10: D. ROCKWELL. PG&E FROM: N. NAENER. 04/QC ,

SU8 JECT: WP5 SEAM ATTAtl#ENT 880-18 AND FLARE MYEL WELti h NPS beam attachment 880-18, which tes in the possession of the NRC bas been examined by H.T. and U.T. Please find copies of the msults of these examinations attached.

'The NRC discussed with Pullman Power Products weld penetration .

for flare bevel welds on tube steel as used at Diablo Canyon. .

. An investigation had previously been conducted by Pullman Power Products and United Engineers and Constructors. Inc.,

st Seabrook. Station on this subject. This information was presented to the NRC at Diablo Canyon for their review.

(

Their review revealed that the minimum required throat was most difficult to obtain on small size tube steel (3" x 3")

wher, using 3/32" electrode in the flat posit;on.

As a msult of this determination and discussions with Mr. Sam Reynolds of the NRC. Pullman Power Products prepared several sample welds at Diablo Canyon using 3* x 3' tube steel in the flat position with 3/32" electrode. Measurements were taken in the presence of Mr. Reynolds. The formal results of these sample welds are attached.

If you have any questions please do not hesitate to call.

w -

Marold Karner 94/QC Manager NK:sse Attachments' (originals) cc: A. A. Eck w/ attach..ts P. StieGer File

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Page 1 of 2

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Pull' man Po'ner Products Corporation Canyon test Propct

- AsenasSch.coweme93424 e Desophone 905) h2356 December 8, 1983 3ESULTs,er FLARE BEVEL FENETRATICII TEST en December 8,1983, Pullman Power Products conducted tests to determine the typical penetrations which will be achieved for flare The material ased was 3* aquare tube steel to 1/4*

bevel joints.

thick plate.

All welding was performed in the flat position with i Results are as follows:

S/32* and 1/8" E7018 electrodes. .'

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stinimum Required &ctual Throat Throat (S/16 R) 3/32" Electrode 1/8* Elsetrode

{ * *2732' 7/32' 15/54*, 17/64* 15/st" l s/32*

l 7/32" fg'-  :

C.M. Wea ocs 5." Earmer OEc welding Engineer File

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ATTACMENT D i

Pullman Power Products Corporation e

DATE:

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DECEER 9.1983 -

f % W E N '

TO: D. ROCKWELL. PGSE FROM: N. KARNER. QA/QC

SUBJECT:

RPS BEAM ATTACMNT 880-18 AND FLARE BEVEL WELDS The NPS beau attachment SBD-18, which uns in the possession of the NRC, has been examined by N.T. and U.T. Please find copies of the results of these examinations attached.

J

.The NRC discussed with Pullaan Power Products weld penetration .

for flare bevel welds on tube steel as used at Diablo Canyon. .

l .

An investigation had previously been conducted by Pu11aan Power Products and United Engineers and Constructors. Inc., '

at Seabrook, Station on this subject. This information was presented to the NRC at Diablo Canyon for their review.

~

i hir review revealed that the einfaum required throat was most difficult to obtain on eas11 size tube steel (3" x 3")

when using 3/32" electrode in the flat position.

As a result of this detemination and discussions with Mr. Sam Reynolds of the NRC. Paliaan Power Products prepared several sample welds at Diablo Canyon using 3" x 3" tube steel in the flat position with 3/32" electrode. Measurements were taken in the presence of Mr. Reynolds. The formal results of these sample welds are attached.

If you have any questions. please do not hesitate to call.

w -

• Harold Karner l

• QA/QC hanJger HK:ssa Attachments * (originals) cc: A. A. Eck w/ attachments P. Stieger File Page 1 of 2

Pull' man Power Products Corporation '. ,

p Canyon Nuclear Project postOmesaos361.'

Ases SeSch, Cahtsense 93424

• 7teephone 905) 505 2356 December S. 1983 SESUITS,OF FLARE BEVEa, FINETRATIOtt TEST on Decer 8,1983, Pullman Power Products conducted tests *A determine the typical penetrations which will be sachieved for flare The material used was 3" square t'Ae steel to 1/4" bevel thick plate.

joints. All welding was performed in the flat position with Results are as follows: ,

3/32' and 1/3' 37018 electrodes. ,.-

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&ctual Throat Miniman NAToired Throat (5/16 R) 3/32" Electrode 1/8" kloctrode

• 2732' 7/32" 15/64", 17/64" 15/64*

5/32" 7/32"

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