ML20199A510

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Rev 1 to Procedure CP-EI-4.0-30, Review of Pipe Support Required Prior to Sys Operation
ML20199A510
Person / Time
Site: Comanche Peak, 05000000
Issue date: 12/06/1982
From: Leech B
TEXAS UTILITIES SERVICES, INC.
To:
Shared Package
ML17192A346 List:
References
FOIA-85-313, FOIA-85-59, FOIA-86-A-20 CP-EI-4.0-30, NUDOCS 8606120432
Download: ML20199A510 (54)


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TEXAS (7FILITIES SERVICES INC.. U"STRUCTICN REVISICH ISSUE PAGE O . CATE CDHTPOILED' COPY NO. , CP-kI-4.0-30 1 12/6/82 1 of 4 REVIDi OF PIPE SUPPCRP REwafD PREPARED BY bak d PRIOR TO SYSTD1 CPERATICN APPEVO BY h7r.s. i fy' /

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1.0 REFERENCES

1-A CP-EP-4.0 Design Control .

2.0 GENERAL 2.1 PURPOSE

  • To establish a method for evaluating piping support systems required for system operation ard . testing. These measures "are established to assure supports "as installed" are adequate per the provisions of Ref 1-A to prevent piping system over-stress durig systens opera-

! tion.

2.2 SCOPE This instruction shall apply to systems that have inconplete per-manent dead weight and thermal supports.

2.3 RESPONSIBILITIES The CP Project Mechanical and Pipe Support Ihgineers are responsible for providing technical direction and administrative guidance to their respective organizations.

1he Technical Services Supervisor has been delegated the responsibility for the general implenentation of this instruction 6 within Mechanical Engineering Technical Services (TS) organization.

It shall be the responsibility of the CP Project Pipe Support Engineer to evaluate the adequacy of tenporary supports.

Where specific individuals are designated by title in this instruction' it shall be understood that designees may be delegated to act in that capacity.

3.0 INSTRUCTICNS .

3.1 TEST SCHEDULE System boundaries will be defined by Canpletions. Where there are deviatiens fran the schedule, Start-up shall notify IS in writig -t icast 3 weeks prior of intent to perform the tests.

8606120432 860604 " ,,

PDR FOIA QARDE86-A-20 PDR -

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  • t l m TEXAS (7?ILITIES SERVICES INC. INSTRUCTION REVISION ISSUE PAGE
U DATE j CP-EI-4.0-30 1 12/6/82 2 of 4 3.2 TIDENICAL SERVICES REVIN i A review will be performed using "as-built" information to identify l permanent supports did are installed and tenporary supports d id j are required. If "as built" information is not available,15 shall

. initiate a walk dom by S personnel to verify support installation.

{ walk h packages will be prepared by a crafting as required.

i 5 will transmit (per Attachnent 1) to Pipe SLpport Engineering (PSE)

a list of temporary supports required to allow systent operation to

! proceed. 'me list will include information sud as line number, suppor:: ntmber and dead weight and' thermal loading conditions. Iceds ,

) whid are not shom crt the s'M drawirq shall be obtained fran the

! . appropiate analysis organization by 'IS. .

i I 3.3 PSE REVIDi -

Upon receipt, PSE will assure that tarporary supports are adaguate i for the specified loads, and initiate and verify installation activities of tanporary supports.

! Upon coupletion of temporary support installation, PSE will nctify i appropriate organizations per Attadment 2, that supports -

! "as-installed" are adequate to r M with system operation testing.

3.4 EXCDTIONS i

l Snubbers will not be installed for initial systen operation. All i spacers anall remain in place, unless testing'is conducted at .

i elevated tangeratures, to maintain C-C dimensions between brackets and clangs.

3.5 DOCEN N ETION A documentation package will be maintained in PSE containing calcula-tions, sketches, transmitt tis, etc., generated during the activities described herein. '

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TEXAS UrILITIES SERVICES INC. INSTRUCTICH REVISICH ISSUE PAGE O. DATE CP-EI-4.0-30 1 '12/6/82 3 of 4 I

' ATIACitiDTI 1 CPP-Tb: J.C. Finneran Glen Ibse, Texas

Subject:

CD1ANCHE PEAK STEAM ELECTRIC STATICN SYSTDi CPERATICN -

RE: (1) CP-EI-4.0-30 l (TYPICAL)

In accordance with Reference (1), Technical Services is providing the below listing of teaporary supports, Wilch need to be installed to ensure piping lines are adequately supported for systen operation.

LINE NLESER SUPPORF NLMBER LOADS (DW + Ui.) , RD1ARl(S

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H.A. Harrison

. Technical Service Supervisor HAH:HRD: DOI:ery cc M.R. McBay J.R. Johnson

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! I 4 TEXAS UFILITIES SERVICES INC. INSTRUCTIN REVISIN ISSUE PAGE EWIT

- CP-EI-4.0-30 1 12/6/82 4 of 4 I ATSCMENT 2 CPPA- ,

Tb: R.E. Cang Glen Rose, Texas l

Subject:

CQtANCHE PEAK STDM ELECTRIC STATIN Swim mEaATIm -

RE: (1) CP-EI-4.0-30 (TYPICAL) j Pipe Support Engineering has performed an evaluation per reference 1 of the su s rui installed in sub system numbsr on to assure the adequacy of supports, including temporary supports, for the safe operaticn of the system. Provided none of these tenporary supports have been removed and all adjustable supports have been properly set, the

support system is acceptable "as-installed".

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l (. J.C. Finneran '

i V./ Project Pipe Support Engineering l JCF:ery .

cc: M.R. McBay R.G. Tbison H.A. Harrison l -

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EFFECnvr i I PROCEDURE DATE PAGE BROWN & ROOT, INC. REVISION NUMBER

'D Y Cd 8t'7 \ U8TM CPSES JOB 35-1195 25 of 27 7

05/14/84 CP-CPM 6.9E

1. Temporary mechanical marking need not be removed provided that the requirements for impressions

. delineated above are met.

2. If the requirements for temporary markings in the above the mechanical markings shall be j paragraph are not met, removed prior to acceptance inspection by j machining, or wire brushing and shall blend smoothly into the surface contour without violating the minimum ,

wall thickness requirement. ,

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3. Ground-out areas, resulting from the removal of

) temporary markings, shall be inspected by the same f

< surface inspec. ion method and to the same acceptance standards as previously used to accept the base material.

3.16 INSULATION Piping and equipment insulation shall be installed in accordance with Specification MS-30.

If, in the opinion of the Insulation Superintenden e

( a specific item, the additional requirements will be delineated in accordance with Procedure CPM-6.3.

Prior to insulation of ASME-related items, a written releaseNon-ASME shall be obtained from the Site QA Manager.

piping may be insulated af ter TUCCO QA's acceptance of the pressure test and signature of the pressure test record.

l 3.17 PIPE HANGERS If the Piping should be erected in its permanent hangers. ,

permanent hangers are not installed, temporary hangers may be used. Piping may be temporarily supported from other piping provided adequate precautions Piping shallarenot taken be to prevent

, damage to the supporting pipe.

supported by valves, pumps, or other equipme is adequately supported.

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I j 26 cf 27 JOB 35-1195 7 ;05/14/84 CP-CPM 6.9E ,

) ll not be temporarily Unattended pipe attached to equipment wiwhich are re supported by items lumber, jack stands, chain falls, etc.hich are rigidly al support secured securely supportedd with hard supports wattach tr the pipe with all-thread ro , a rod, clamped-lashing, etc.

ld be run toward To ensure proper alignnent, piping shouCare shall be taken equipment. ting to equipment.

f equipment instead of fromnot to cold spring inimum of two piping wh When piping is connected to equipment, a mhall be provided; temporary or permanent supports s direction from Site ll be obtained.

supports cannot be provided, writtenEnginee 3.18 P1PE CONNECTIONS suctionTO ROTATING and discharge piping EQUIPM To ensure proper alignment, instead of fromiping should be run toward rotating equipmentThe conne equipment. sufficient piping andinstalled wh to the equipment should be after t

sufficient permanent hangers haveipment been when additional prevent the movement of pipe at the equ o piping was added to the system.

be installed and Permanent hangers and supports shalldicated on the drawin ctions being made to adjusted to the cold position as in prior to suction and discharge When permanent conne supports cannot be rotating equipment.

installed, temporary hard supports m approval from Engineering.

Rotatine Equipment Fit-ug lished by 3.18.1 Fit-up of pipe to equipment shall be accompovide accura .

adjusting the pipe and supportsuipment. to pr I without stressing the pipe or the eq l

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BROWN & Ruut, ww . i I NUMBr.x I 1 J

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. f CPSES -

27 cf 27 JOB 35-1195 7 ,05/14/84 1 CP-CPM 6.9E ,

is to be monitored The rotating equipment coupling alignment d weld out (or being moved during the suction and discharge fit-up anbolt f and.that the coupling alignment is ma n desired limits. d above, and the If temporary supports were used as permittewas conne suction and discharge f d so special care shall be exercised when remoThe M11

' supports. i tha't they may monitor the coupl ngbegins until the permanent the temporary support removal 4

support installation is complete.

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Annex 3 Conversation Record Allegation Number Aw -3V Time Date a M / - N

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Type t' Visit Conference Telephone k fpr <re7e ci p' re eme es a tib>-rs Incoming o'uring wa/4 -?%rovyA 'To *ds*r'c- Out9oing su eHana acro'vitx sk 04 7~ 2.

Name of~ Person (s) Contacted or in Contact With You Organization Telephone Number 31// wr c41 3M I6 a a

SUBJECT:

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SUMMARY

,. , ,. . ~ ,. . -r Name of Person Documenting Conversation '/, . ' , S 7 , . .~d Signature 5,4 ., <4 bb /-s Date eh. 5/

Name(s) of Other Persons Who Were Present During Conversation I have reviewed the. sumary of the conversati.on with the individual (s). named below and agree that it accurately represents the conversa n.

Signature of Person Providing Infonnation File: Allegation Work Package o cc: Project Director

  • Group leader Additional pages may be attached as needed. Additional pages should be identified, signed, and dated. p;Y

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Signature of Person Providing Infor1 nation _

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sser AW-31 Draft 8 11/01/84 -

. SSER

1. Allegation Group: Mechanical and Piping Category No. 2 y

Adherence to Welding Procedures

2. Allegation numbert AQW-28, AW-36, AW-54, AW-31, AQW-10, and AQW-30
3. Characterization: It is alleged that welding procedures were violated with respect to the following items:

(a) buildupofundersizewelds(AQW-28)

(b) downhand versus uphand welding (AW-36)

(c) weave bead versus stringe. head welding (AW-54) ,

(d) reinforcement of flare-bevel welds (AW-31 & AQW-10)

(e) quality control (QC) hold points for inspection of welds (AQW-30)

4. Assessment of safety significance:

To assess the safety significance of these allegations, the NRC Technical Review Team (TRT) identified and reviewed codes, specifications, procedures, and other documents applicable to each of the several allegations to determine requirements. Pertinent, U.S.

NRC' inspection reports (irs) were also reviewed. The resolution of each allegation is separately; addressed in the remainder of this report.

AQW-28 This allegation concerns t'he addition of weld filler metal to build up welds which are found by inspection to be undersize. Adding additional weld filler metal layers to an undersized fillet weld or an incompletely filled groove weld is not prohibited by the American Society of Mecha'nical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, the ANSI B31.1, Power Piping Code, nor the American Welding Society's Structural Welding Code, AWS D1.1. Furthermore, f

m 59

this accepted procedure is good practice in that the effects of welding on the base metal structure and properties, and on component distortion, is minimized compared with removal and replacement of the existing weld.

AW-36 Although the alleger refers to "uphand" and "downhand" welding, the correct tems are " upward" and " downward." This allegation concerns the use of the downward technique instead of the procedurally required upward technique for welding vertical joints in austenitic stainless steel plate during fabrication of the liner of the fuel handling facilities spent fuel storage pools.

The Technical Review Team (TRT) established, from Gibbs & Hill Specification 2323-SS-18, Revision 3, that weld fabrication was required to conform to the ASME B&PV Code, 1974 Edition,Section IX, and that welds were to be made by the inert gas-shielded arc welding process, technically known as the gas tungsten-arc welding (GTAW) process.

Visual examination by the TRT of welds in the as-welded (unground)

condition in fuel storage pools 1 and 2 established that GTAW had been j used.

(

For the GTAW process and when welding the austenitic stainless steels f

( (a class of alloys for which the ASME B&PV Code does not specify

! impact properties),Section IX, QW-410.16, of the Code defines a changefroMdownwardweldikhupwardweldinglasanonessential variable. The Code, therefore, considers this change to have no effect on the mechanical properties of the weldment and pemits the described change to be made to the WPS by revision or amendment without requalification. Furthermore, this change does not require welders to be requalified.

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' l The TRT notes that ASLB hearings document additional concerns on the  ;

subject of downward welding which are not directly related to this ,

allegation. As of October 1984, the Board has not yet ruled on these l

concerns.

l AW-54 This allegation concerns the welding of pipe supports using the weave bead technique prohibited by welding procedure specifications (WPSs),

rather than the stringer bead technique.

The TRT detennined that Gibbs & Hill (G&H) Specification 2323-MS-46A

! pertains to all nuclear safety class pipe hangers and supports. This specification applies the ASME B8PV Code, 1974 Edition, including Winter 1974 Addenda,Section III, Subsection NF, Component Supports supplemented by selected code cases and specified paragraphs, tables, i or figures from later code versions. Paragraph 3.11(b) of 2323-MS-46A l requires integral attachments for piping categories 1303-2 and 2003-2 to be impact tested. Impact testing of nonintegral supports is not l required. Subsection NF requires WPSs and welders to be qualified to i Section IX, Welding and Brazing Qualifications, of the B&PV code.

. G&H Specification 2323-MS-468, Non-Nuclear Pipe Hangers and Supports b relating to pipe hangers that support ANSI B31.1 piping also requiresSection IX to be applied to non-nuclear pipe hangers and supports.

1 p The TRT reviewed the requirements of the ASME B&PV Code, 1974 Edition, including Sumer 1974 Addenda,Section IX. For the Shielded Metal-Arc Welding (SMAW) process used for pipe hangers and supports, a change fromthestringerbeadtechniquetotheweavebeadtechniqueorvige )

p versa is a nonessential variable for qualification of the weld procedure specification (WPS), unless notch toughness is specified.

l-That is, a WPS may be changed from stringer bead to weave bead without

) requalification. The B&PV Code, therefore, considers the difference l between stringer beads and weave beads as having an inconsequential

)

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i effect on weld properties, except for notch toughness. If notch toughness is a requirement,then a change from stringer bead technique ,

to weave bead technique or vice versa becomes a supplemental essential variable and requalification of the WPS is required.

AWS D1.1-75 defines a stringer bead as a type of weld bead made without appreciable transverse oscillation and a weave bead as a type i of weld bead with transverse oscillation. Brown & Root (B&R) i l

defines a stringer bead as a weld bead in which weaving (transverse

{ oscillation) is permitted providing the bead width does not exceed 4D (where D is the diameter of the core wire of the electrode).

Each welder employed by Brown & Root (B&R) to work on hangers and pipe supports is qualified to WPS 11032. WPS 11032 specifies that the maximum bead width allowed is four times the core diameter of the electrode being used. WPS 11032 has been qualified and can be used when welding those materials that require notch toughness. The notch toughness values required (expressed as mils of lateral _

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expansion) are 11sted in Section III Division 1 Subsection NC table NC-2331-1. For material 5/8 inch and less, no test is required; for material 5/8 inch to 3/4 inch inclusive, 20. mils of lateral expansion is required and for material over 3/4 inch to it inch inclusive, 25 mils of lateral expansion is required. Test data from procedure qualification records (PQRs) used to support WPS 11032 show that the lateral expansion of the test e.oupons was in most cases at least' twice as high as that required. This indicates that using the weave technique (at least up to Pur core diameters) does not add enough additional heat into the material to alter the notch toughness properties to the. point that the required impact values cannot be met.

A visual inspection of pipe hangers by the TRT and the NRC resident inspector was conducted in the south yard tunnel (Unit 1) and at l

random locations throughout both units'. It was noted that all welds

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inspected had the proper type weld bead. This inspection does not support the alleger's allegation that " literally thousands of weaved welds exist at various locations on the site."

A search of the NCR log books for ASME and non-ASME fabricated hangers and supports revealed that only one NCR was written for welds that were made using weave beads wider than pennitted by the WPS. In this case it involved a hanger that did not require notch l toughness and was accepted "as is" by the site welding engineer.

AQW-10 and AW-31 The allegation originally stated there was a procedural question involving flare-bevel welds versus butt welds. However, based on identifying the subject allegation to that appearing in NRC Region IV inspection report (IR) 82-11, the TRT limited its evaluations to l reinforcement requirements for flare-bevel welds. The allegation relates in particular to partial penetration, single-flare-bevel groove weld joints between tube steel members and flat plates. The 3 joints are located along the rounded corners of the tube steel members. Support SW-1-173-720-543A was identified in IR 82-11 as an j example specified by the allegation, b

Documents reviewed by the TRT included component modification card (CMC) 56483; ASME B&PV Code,Section III, Subsection NF, Component Supports; and revisions 9 (March 11, 1982) through 14 (September 29,

'. 1982) of QI-QAP-11.1-28, Fabrication and Installation Inspection of l Safety Class Components.

The TRT found that CMC 56843 adequately specified a flare-bevel weld

- joint of the type described. It also found that this document specified subsection NF as applying to the subject support.

Subsection NF was found by the TRT to specify weld reinforcement

)

S

l limits for butt welds. These limits do not apply to flare-bevel welds since they are not butt welds. Finally, the TRT found that QI-QAP-11.1-28 specified requirements for two types of flare-bevel weld joints between structural tubes of the same size to ensure that weld grooves would be completely fillea; the procedure did not specify

! reinforcement requirements.

The TRT recognized an allegation by another source which pertains to the adequacy of a single flare-bevel weld design for tube steel connections. Although the ASLB has not yet acted on this issue, the TRT agrees that the assessment by the NRC staff, as presented in the hearings by the ASLB, is correct (Tr 6389-7036). The staff conclusion was that in any case where the flare-bevel weld profile is normal to the base member, and flush to the side plane of the tube steel '

attachment, the design requirements have been satisfied. Any

additional filler material where the profile tends toward the appearance of a fillet weld is considered reinforcement. There are no requirements provided in any code where reinforcement of flare-bevel welds takes credit for strength.

AQW-30 It is alleged that a weld (identified as 40-C-AF1) in the alternate auxiliary feedwater system (AF1) was repaired on a repair process l sheet (RPS) which was issued having weld technician (WT) holdpoints; because it was a safety-related weld, the holdpoint should have been

(

! QC inspected.

I l The TRT reviewed the weld inspection program which was developed through a series of ANI/QC meetings and correspondance. This program is a blend of WT and QC responsibilities and was approved by all concerned parties agreeing that it did comply with the requirements of the ASME B&PV Code, Section NA 4511, 1974 Edition through Sumer 1975 g

Addenda. The TRT review included the process by which weld data cards l (WDCs) and RPSs are generated and the methods used to assign WT, QC 4

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and ANI holdpoints. The Welding Engineer is responsible for preparing

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the WDCs and RPSs making all applicable entries of requirements including the assignment of WT and QC holdpoints to each sequence of I

activity. The WT holdpoints are assigned at the Welding Engineer's discretion. The QC holdpoints are assigned in accordance with the

~

tables and matrices provided in Construction Procedu CP-CPM-6.9G, St--

which is approved.by both B&R and TUEC Quality Assurance Management.

In a case where both WT and QC holdpoints are assigned to the same step, the WT inspection shall occur prior to the QC inspection. Prior to issuance to craft personnel , the WDCs and RPSs are routed through the ANI for a preliminary review and assignment of ANI holdpoints.

The weld number identified by the alleger is not traceable. However, a review of the weld documentation for the Auxiliary Feedwater System '

found no instance where a WT holdpoint was assigned in lieu of a QC holdpoint required by CP-CPM-6.9G. The Unit 2 walkthrough revealed that data packages containing all the required documents, logs and reports were adequately maintained at each work station. Also, a random selection of 12 data packages for completed welds was reviewed and was found to be in compliance with requirements.

During the course of other investigations, the TRT found deficiencies which are beyond the scope of this allegation, but which are relative to the procedural requirement to route welding documentation through the ANI for his preliminary review and assignment of ANI holdpoints.

These findings are as follows:

(a) NCR No. M-1860, dated 12/10/79, " Repair was completed as required

! by RPS without ANI review," (Ref. drawing BRP-SF-X-FB-41, FW-3, WDC No. 4319).

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(b) NCR No M-2690, dated 3/5/81, " Document violated B&R QA Manual, CPSES Trans. #28, Para. 10.4.2-10.6." (The NCR has undergone six revisions to add to and clarify the disposition). This violation-was caused by B&R's QA complying with a memo issued from the ANI l which stated effective February 25, 1980, that the ANI's f preliminary review of weld documentation (except new spool fabrications and RPSs) was no longer required. The duration of i this deficiency was for more than 13 months. The disposition of this NCR resumed the routing of weld data packages through the l ANI for preliminary review, revised the CP-CPM-6.9G to outline l ANI preliminary review requirements to preclude the issuance without such review, and required that the ANI shall review all 3

welding documentation that did not receive a preliminary review.

W (c) NCR No. M-3120, dated 1/7/82, MitsfI lists ' additional travelers (

(weld documentation E ich were not submitted to the b or preliminary review. The dates of activities and events that stem from the six revisions to the disposition of NCR M-2690 above overlap the dates of this NCR.

9

, 5. Conclusion and Staff Positions:

AQW-28 The TRT did not attempt to substantiate or refute this allegation regarding the buildup of undersize welds. It is the TRT's position that the allegation has neither safety significance nor generic implications.

AW-36 The TRT was able to neither subs *.antiate nor refute this allegation.

If downward welding was performed in accordance with a WPS requiring

upward welding, a technical violation of the WPS could have occurred.

It is the TRT's position, however, that the allegation has neither

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{ safety significance nor generic implications.

5

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AW-54 Visual examination of numerous hangers and supports by the TRT did not reveal that a weave bead technique in violation of the WPS was used to weld the hangers and supports. Per the requirements of WPS 11032 a welder may weave the electrode as long as the weld bead width in the WPS is net violated. At CPSES this is considered to be a stringer bead technique. Also, a review of the NCR logs revealed that only one NCR had been written for weave beads that exceeded the limitations of the WPS.

WPS 11032 is also qualified to be used for welding carbon steels that require notch toughness tests. Test data from the supporting PQR

  • shows that in most cases the lateral expansion is twice as high as required minimum values. Therefore, the TRT finds that this allegation has neither safety significance nor generic implications.

AW-31, AQW-10 The TRT has substantiated the allegation that there is no procedural control on the reinforcement cf flare-bevel welds. However, neither of the referenced documents have reinforce.nent requirements for flare bevel welds. Also, the referenced documents adequately specify flare-bevel welds to preclude incomplete filling of the weld joint groove. For these reasons, the TRT concluded that the allegation has neither safety significance nor generic implications.

AQW-30 The TRT concludes that the approved procedure for generating WPCs and RPSs does not establish WT holdpoints in lieu of QC holdpoints. Nor did the TRT's review of documentation substantiate the allegation.

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The TRT views the Weld Inspection Program to be unusual in that inspection" responsibilities are divided betwee.n WT and QC. However, the TRT finds no adverse safety significanceI compliance with the 4 program since it requires overall welding to be monitored by QC. The l TRT's position is that the allegation has neither safety significance nor generic requirements.

! The TRT's position toward the procedure violations (documented by i NCR), which were discussed in the assessment as being "beyond the j scope of the allegation," is as follows:

(a) The fact that an RPS can be issued to craft personnel and all the l steps of welding activity and inspections completed prior to detecting that the ANI's preliminary review had been bypassed,

  • indicates a weakness in the QA Program.

(b) For Quality Assurance to abide without question by the memo issued by the ANI stating that the ANI's preliminary review was not required is also an indication of QA weakness.

(c) The ANI, in the issuance of this memo, acted beyond the scope of his authority. If the ANI was fully aware of his scope of authority, duties and responsibility, the act of writing the memo l was a breach of duty and responsibility.

l If the ANI was not knowledgeable about his scope of authority,

! duty, and responsibility, the memo was an act of negligence.

i l 6. Actions Required:

AQW-30 Jni30'% 3&WXM hyb- h%*W-}

TUEC shall make a co6plete tabulation of all weld documentation that was not reviewed by the ANI per B&R procedures. The documents

tabulated shall be submitted to and reviewed by the ANI, who shall f

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l l then consider retroactive acceptance of the documentation. For

documents accepted, the ANI shall' classify and identify each document l or set of documents as one of the following categories and sign his i

approval:

{ (a) In this document there were no operations of a significant level

{ and no ANI holdpoints were required.

l (b) This document has no significant mandatory requirements.

However, ANI holdpoints would normally have been assigned. A complete review of activities and NDE documentation shows all f

j items of the package to be complete, and in compliance with i requirements.

(c) The level of significance in this document is such that mandatory

requirements were applicable. (In such a case, the ANI shall provide details of the method used for acceptance; whether the

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l review required analytical or mathematical models or any other l

clarification of evidence for acceptance.) This act.-:e.. ;hc." he (

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8. Attachments: None.
9. Reference Documents:

, 1. ASME B&PV Code, 1974 Edition including Summer 1974 Addenda Section III, Nuclear Components.

( 2. ANSI B31.1-73 Including Addenda through Sumer 1975, Power Piping l Code.  !

l 3. AWS D1.1-75, Structural Welding Code. i

! 4 Gibbs & Hill Specification 2323-SS-18, Revision 3, Stainless l f Steel Liners.

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5. ASME _B&PV Code,1974 Edition Including Sumer 1974 Addenda,Section IX, Welding and Brazing Qualifications.
6. NRC Region IV Investigative Report 50-445/79-15 dated June 21, 1979.
7. NRC Region IV Investigative Report 50-445/81-12 dated April 16, 1982.
8. Gibbs & Hill Specification 2323-MS-46A, Nuclear Safety Class Pipe Hangers and Supports.
9. CMC 56843, Revision 11.
10. ASME B&PV Code, 1974 Edition Including Summer 1974 Addenda,Section III, Subsection NF, Component Supports.

! 11. B&R QI-QAP-11.1-28, Revision 25, Fa'brication and Installation of Safety Class Components. ,

12. NRC Region IV Investigative Report 50-445/82-11 dated December 13, 1982
13. ASME B&PV Code Case 1734, Weld Design for Use for Section III, Division 1, Class 1,2,3, and MC Construction of Component ,

^

Supports.

14. B&R CP-CPM-6.9G, Revision 6, Documentation for ASME Welding i Fabrication and Installation Activities.

l 15. NRC Region IV Investigative Report 50-445/81-07 dated May 5,

} 1981.

j 16. Conversation Record with Don Doyle, B&R QC, dated July 17,

! 1984.

17. Conversation Record with Bill Wright, B&R Assistant Project l

Welding Engineer, dated July 16, 1984.

( 18. NRC Region IV Investigative Report 50-445/81-12 dated April

16, 1982.

l 19. Gibbs and Hill Specification 2323-MS-100 page 4-57.

20. ASME B&PV Code, Section NA 4511, 1974 Edition through j Sumer 1975 Addenda.

! 21 . NCR - M1860,12/10/79.

22. NCR - M2690 R.6. 3/5/81.

l i 23. NCR - M3120, 1/7/82.

13 -

10.~ This statement prepared byr E. G. Thompson Date C. Richards i

TRT Technical Reviewers l

Reviewed by:

Larry Shac Date Group Leader Approved by:

P Vincent Noonan Date Project Director L

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CoAes5 2.,Gew.4\( W % 3 i [0 M&PC 2 u 7 AQW-28. AW-36, AW-54, AW-31, AQW-10, AQW-30 4

1. On Page 4, a portion of Section IX, Paragraph QW-410.1 is quoted.

I suggest that the quote be expanded to better illustrate the point ,

the SSER author is making. l

2. The SSER refers in a number of places to "requalification of the WPS" (Page 5). It seems to me the weld procedure specification would be qualified (comply?) with the appropriate governing codes and standards.-

Hence, the term "requalification" seems incongruous since a procedure would either comply or not comply with governing codes and standards.

3. Some terms. require] efinition in the SSER text. See indications on i attached SSER.

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sser AW-31 -

DCP:

Draft 7 10/26/E4 SSER 1.. Allegation Group: Mechanical and Piping Category 2 - Adherence to Welding Procedures

2. Allegation number:. AQW-28, AW-36, AW-54, AW-31, AQW-10, A0W-30
3. Characterization: It i_s alleged that welding procedures were violated i

with respect to the following items:

I a) AQW-28 b'uildup of undersize welds b) AW downhand versus uphand welding c) AW weave bead versus stringer bead welding d) AW-31 & AQW reinforcement of flare-bevel welds e) AQW quality control (OC) hold points for inspection of welds i 4. Assessment of safety significance:

l l To assess the safety significance of these allegations, the NRC Technical Review Team (TRT) identified and reviewed codes, specifications and other documents applicable to each of the several allegations to determine requirements. Pertinent, U.S. NRC investigative reports (irs) were also reviewed. The resolution of

. each allegation is separately addressed in the remainder of this l

report.

l AQW-28

This allegation concerns the addition of weld filler metal to build up welds which are found by in
;pection to be undersize. Adding additional weld filler metal passes or layers to an undersized fillet h

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weld or an incompletely filled groove weld is not prohibited by the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, the ANSI B31.1, Power Piping Code, nor the

. American Welding Society's Structural Welding Code, AWS D1.1.

Furthermore, this accepted procedure is good practice in that the effects of welding on the base metal structure and properties, and on component distortion, is minimized in comparison to removal and replacement.of the existing weld.

AW-36 e-This allega' tion concerns the use of the downhand technique instead of

  • the procedurally required up-hand technique for welding of vertical joints in austenitic stainless steel plate during fabrication of the liner of the fuel handling facilities spent fuel storage pool.
  • The Technical Review Team (TRT) established from Gibbs and Hill Specification 2323-55-18 revision 3, " Stainless Steel Liners," whose scope includes the spent fuel storage pool, weld fabrication was required to conform to the ASME B&PV Code, 1974 Edition,Section IX, Welding and Brazing Qualifications and that welds were to be made by the inert gas-shielded are welding process, technically known as the gas tungsten-arc welding (GTAW) process. Visual examination by the TRT of welds in the as-welded (unground) condition in fuel storage ' ,. -

pools no.1 and no. 2 established that GTAW had been used.

For the GTAW process, a change from uphand to downhand welding may or may not be a nonessential variable, depending whether the requirements for the base material properties includes the requirement for notch-toughness test.Section IX of the ASME Code defines essential / nonessential variables as follows: (a) Paragraph QW-251.2 Essential Variables as those in which a change, as described in the e

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i l

specific variables, is considered to affect the mecha'nical properties of the weldment and shall require requalification of the

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Supplementary essential variables are required for metals for which other sections of the Code specify notch-toughness tests; (b)

Paragraph QW-251.3, Nonessential Variables as those in which a change, 4

as described in the specific variables, may be made in the WPS without requalification.

. The specific variables for the GTAW process are listed in Table QW-256 where column 256.2'(nonessential variables) references paragraph 4

410,16. QV-410.16 states this specific nonessential variable to be "a change fr'om upward to downward, or from downward to upward, in the progression specified for any pass of a vertical weld, except that a cover or wash pass may be up or down....."

  • The TRT notes that notch-toughness is not a requirement for austenitic stainless steel which is the material specified for the fuel pool liners. In this case, the WPS need not be requalified and the change _

from upward to downward progression is permitted providing the WPS is revised to reflect the downward progression. Furthermore, the welders performance need not be requalified for this variable. The TRT also notes that B&R did have WPS's that reflected downward progression.

The TRT notes that ASLB hearings document additional concerns on the subject of downfill welding which are not directly related to this

allegation. The Board has not yet ruled on these concerns.

l AW-54 This allegation concerns the welding of pipe supports using the weave bead technique prohibited by welding procedure specifications (WP5s) rather than the stringer bead technique.

The TRT detennined that Gibbs and Hill (G&H) Specification 2323-MS-46A, pertains to all nuclear safety class pipe hangers and supports. This specification applies the ASME B8PV Code, 1974 Edition

~ . . . - . ~ . .

- .- - _- ~a. _

I l

including Winter 1974 Addenda,Section III, Subsection NF, Comporert Supports supplemented by selected code cases and specified paragraphs, tables, or-figures from~ later code versions. Paragraph 3.11(b) of 2323-MS-46A requires integral attachments for piping categories 1303-2 and 2003-2 to be impact tested. Impact testing of nonintegral supports is not required. Subsection NF requires WPSs and welders to be qualified to Section IX, Welding and Brazing Qualifications, of the B&PV code.

G&H Specification 2323-MS-468, Non-Nuclear Pipe Hangers and Supports I

relating to pipe h'an'gers that support ANSI B31.1 piping .also requiresSection IX to be applied. to non-nuclear pipe hangers and' supports.

I l The TRT reviewed the requirements of the ASME B&PV Code, 1974 Edition, including Summer 74 Addenda,Section IX. Section IX, paragraph

  • 0W-410.1 states, "A change from the stringer bead TFttifiM0e to Y s 4 \

( *

" he~ ave bead technique, or vice versa."[This paragraph is a weld :4 />.f Iro'c'eiure nonessential variab1 7 f M he SMAW process unless notc [ "

{ toughness is specified. That is, a WPS y be changed from " stringer

~

l bead" to " weave bead" or vice versa without requalification of the WPS being required. The foregoing is evidence that the B&PV Code considers the difference between stringer beads and weave beads as having an inconsequential effect on weld properties except for

) notch toughness. Where the B&PV Code requires a weld to have

notch-toughness properties, QW-410.1 it a procedure essential variable for SMAW and may not be changed without violating the procedure f qualifice ion, s

t .

\

g AWS 01.1-75 defines a stringer bead as a type of weld bead made

$ without appreciable transverse oscillation and a weave bead as a type of weld bead with transverse oscillation. Brown and Root (B&R) j defines a stringer bead as a weld bead in which weaving (transverse

[

oscillation) is permitted providing the bead width does not exceed 4D j (where D is the diameter of the core wire of the electrode).

i

) Each welder that is employed by Brown and Rcot (B&R) to work on

}

l -

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hangers and pipe supports is qualified to WPS 11032. WPS 11032

. specifies the maximum bead width allowed. The width of the beac

  • allowed is four times the core diameter of the electrode being usec.

! A review of the ASME Section IX Code 1974 Nition, paragraph QW 250 does not list stringer bead /wtova bead as an essential variable unless f notch toughness is a consideration. If notch toughness is a requirement, then the supplemental essential variables of this sectior are also invoked. In this case a change from the stringer bead i technique to the weave bead technique or vice versa would require i recualification of the WPS. WPS 11032 has been qualified and can be l used when ew'lding those materials that require notch toughness. .The

notch toughness values required (expressed as F.ils of lateral expansion) are listed in Section III Division 1 Subsection NC table  ;

f NC-2331-1. For material 5/8 inch and less no test is required; for ,

material S/8" to 3/4" inclusive 20 mils of lateral expansion is required and for material over 3/4" to li" inclusive 25 mils of

, lateral expansion is required. Test data from procedure qualification j records (PQRs)usedtosupportWPS11032showthatthelateral expansion of the test coupons was in most cases at least twice as high-as that required. This indicates that using the weave technique (at least four core diameters) does not add enough additional heat into the material to alter the notch toughness properties to the point that l the required impact values cannot be met. A visual inspection of pipe j hangers by the TRT and the NRC resident inspector was conducted in the l south yard tunnel (Unit 1) and at randem locations throughout both units. It was noted that all welds inspected had the proper type weld bead. This inspection does not support the alleger's allegation that l

" literally thousands of weaveo welds exist at various locations on the

! site."

I i

l A search of the NCR log books for ASME and non-ASME fabricated l hangers and supports revealed that only one NCR has been written for 3 welds that were made using weave beads wider than permittec by the WPS. In this case it involved a hanger that did not require notch toughness and was accepted "as is" by the site welding engineer.

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Based on the data collected it is the opinion of the TRT that this allegation-has no safety significance, technical merit, or generi:

implications.

AQW-10 and AW-31 The allegation originally stated there was a procedural question involving flare-bevel welds versus butt welds. However, based on identifying the subje,ct allegation to that appearing in investigative report (IR) 50-445'/82-11, the TRT limited its evaluations to reinforceme'nt requir6ments for flare-bevel welds. The allegation relates in particular to partial penetration, single-

, t'lare-bevel groove weld joints between tube steel members and flat plates. The joints are located along the rounded corners of the tube

  • steel members.

Support SW-1-173-720-543A was identified in IR 82-11 as an example by the allegation.

Documents reviewed by the TRT included component modification card (CMC) 56483, ASME B&PV Code,Section III; Subsection NF, Component Supports, and revisions 9 (March 11,1982) through 14 (September 29, 1982) of QI-Q5P-11.1-28, Fabrication and Installation Inspection of Safety Class Components.

i The TRT found that CMC 56843 adequately specified a flare-bevel weld joint of the type described. It also found that this document j specified subsection NF as applying to the subject support.

Subsection NF was found by the TRT to specify weld reinforcement i

j limits for butt welds. These limits do not apply to flare-bevs1 weios since they are not butt welds. Finally, the TRT found that QI-QAP-11.1-28 specified requirements for two types of flare-bevel weld joints between structural tubes of the same size which ensurec that weld grooves would be completely filled but did not specify l reinforcement requirements. ,

The TRT recognized an allegation by another source which pertains to the adequacy of a single flare-bevel weld design for tube steel

[ connections. Although the ASLB has not yet acted on this issue, the

. TRT agrees"that the' assessment by the NRC staff as presented in the hearings by the ASLB, is correct (Tr 6389-7036). The staff conclusion was, that in any case where the flare-bevel weld profile is l normal to the base member and flush to the side plane of the tube

  • steel attachment, the design requirements have been satisfied. Any additional filler material, where the profile tends toward the

! appearance of a fillet weld, is considered reinforcement. There are

no re,quirements provided in any code where reinforcement to l flare-bevel welds takes credit for streng.th.
A0W-30 f It is alleged that a weld (identified as 40-C-AF1) in the Alternate L auxiliary) Feedwater System (AF1) was repaired on a repair process sheet (RPS) which was issued having weld technician (WT) holdpoints; -

f i being a safety related weld, the holdpoint should have been OC.

/ YE W(

The TRT reviewed the weld 'spection program which was developed through a series of N /QC meetings and correspondance. This program is a blend of WT and QC responsibilities and was approved by all

) concerned parties ag.eeing that it did comply with the requirements of

{ the ASME Code, Section NA 4511, 1974 Edition through Sumer 1975 Addenda. The TRT ' review included the process by which weld data cards (WDCs) and RPSs are generated and the methods used to assign WT, QC h and ANI holdpoints. The Welding Engineer is responsible for preparing the WDCs and RPSs making all applicable entries of requirements t .

including the assignment of WT and QC holdpoints to each sequence of activity. -The WT holdpoints are assigned at the Welding Engineer's discretion. The QC holdpoints are assigned in accordance with the tables and matrices provided in the Construction Procedure (CP-CPM-6.9G which is approved by both B&R's and TUGCO's Quality Assurance Management. In a case where both WT and QC holdpoints are assigned to the same step, the WT inspection shall occur prior to the QC inspection. Prior to issuance to the craft, the WDCs and RPSs are routed through the ANI for a preliminary review and assignment of ANI holdpoints.

The weld number as identified by the alleger is not traceable.

However, a review of the weld documentation for the Auxiliary Feedwater System found no instanca where a WT holdpoint was assigned

The Unit 2 walkthrough revealed that data packages containing all the required documents, logs and reports were adequately maintained at each work station. Also, random selection of 12 data package for completed welds were reviewed and were found to be in compliance with requirements.

During the course of other investigations the TRT found deficiencies '

which are beyond the scope of this allegation, but are relative to the .g ;,

procedural requirement to route welding documentation through the ,-

for his preliminary review and assignment of ANI holdpoints.

These findings are as follows:

(a) NCR No. M-1860, dated 12/10/79, -Repair was completed as required by RPS without ANI review" (Ref. drawing BRP-SF-X-FB-41, FW-3, WDC No. 4319).

N'

..i (b) N'CR No. M-2690, dated 3/5/81, " Document violated B&R QA Marual, CPSES-Trans. #28, Para.10.4.2-10.6." (The NCR has undergere six revisions to add to and clarify the disposition). This violation was caused by B&R's QA complying with a memo issued from the Ah!

j which stated effective February 25, 1980. The ANI's preliminary , , , , .

j review of weld documentation (except new spool fabrications and V 4

RPSs) was no longer required. The duration of this deficiency w .

. was for more'than 13 months. The disposition of this NCR M 5v/

j the routing of weld data packages through the ANI for preliminary I review, revis'ed the CP-CPM-6.9G to outline ANI preliminary review

] requirements to' preclude the issuance wi'thout such review, and 3 that the ANI shall review all welding documentation that dio net l receive a preliminary review.

(c) NCR No. M-3120, dated 1/7/82, which lists additional travelers

,, (weld documentation) which were not submitted to the ANI for 1 preliminary review.

l l -

l Note: The dates of activities and events that stem from the six f revisions to the disposition of the NCR in item (b) above, overlap the dates of this NCR.

, 5. Conclusion and staff positions:

r I A0W-28 l

}

The TRT did not substantiate this allegation regarding the buildup of f

undersize welds. It is the TRT's position that the allegation has no technical merit or safety significance, and there are no generic I implications.

AW-36 i

The TRT was able to neither substantiate nor refute the allegation.

f.

If downhand welding was performed in accordance with a WPS requirir; uphill. welding, a technical violation of the WPS could have occurrec.

It is the TRT's position, however, that the allegation has little technical merit and no safety significance.

AW-54 Visual examination of numerous hangers and supports by the TRT did net reveal that a weave b.ead technique in violation of the WPS was used to weld the hangers afd supports. Per the requirements of WPS 11032 a weldermayweavethEelectrodeaslon as the weld bead width-in the f ./

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WPS is not violated, At CPSEs his is considered to be a stringer F-.

bead technique. Also, a review of the NCR logs revealed that only one NCR had been written for weave beads that exceeded the limitations of

  • the WPS.

WPS 11032 is qualified to be used for weld'ing . carbon steels that require notch toughness. Test data from the supporting PQR shows that in most cases the lateral expansion is twice as high as is required.

Therefore, the TRT cannot assess any safety significance or technical merit to this allegation.

AW-31, A0W-10 The TRT has substantiated the allegation that there is no procedural control on the reinforcement of flare-bevel welds. However, neither i

of the referenced documents haVe reinforcement requirements for flare bevel welds. Also, the referenced documents adequately specify .

flare-bevel welds to preclude incomplete filling of the weld joint groove. For these reasons, the TRT concluded that the allegation has neither safety significance nor generic implications.

i .' '.

l AQW-30 The TRT concludes that the approved procedure for generating WPCs anc 4

RPSs does not establish WT holdpoints in lieu of QC holdpoints. -Nor

] did the TRT's review of documentation substantiate the allegation.

i

, The TRT views the Weld Inspection Program to be of unusual nature j where inspection responsibilities are divided between WT and QC.

However, the TRT finds no harmful significance to the compliance with the requirements since the program requires the'overall welding i

activity to' be. nionitored by QC, The TRT's position is that'the-allegation has no technical or safety significance.

j The TRT's position toward the procedure violations (documented by NCR) i which were discussed in the assessment as being "beyond the sccpe of

! the allegation,"~is as follows:

! (a) The fact that an RPS can be issued to the craft and all the steps i of welding activity and inspections completed prior to detecting j that the ANI's preliminary review had been bypassed, indicates a l weakness in the QA Program.

4 1

} (b) For Quality Assurance to abide without question to the ambiguous j memo issued by the ANI stating that the ANI's preliminary review was not required, is also an indication of QA weakness.

(c) The ANI, in the issuance of this memo, acted beyond the scope of his authority. If the ANI was fully aware of his scope of authority, duties and responsibility, the act of writing said

, memo was a Breach of Duty and Responsibility.

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, If the ANI was not aware or knowledgeable of his scop'e of authori y.

l duty, and responsibility, the act of writing said memo was Strict Negligence.

6. Actions Required:

f

~

For AW-31, AW-36, AW-54, AQW-10, and AQW None.

1 1 AQW-30 ,

l The NCR disposition that the ANI shall review all documentation that

had not received a preliminary review is general and the sign off statement that the'sE documents have been reviewed by the ANI is

~

f general.

! The TRT's position is that a complete tabulation is required of all

, weld documentation that was affected by the issuance of the "ANI Memo" i which includes the manner in which the ANI accepted each weld by one

!, of the following:

(a) There were no operations of significant level.and no ANI j holdpoints were required.  ;

! (b) No significant mandatory. requirements. However, in a normal ANI preliminary review, ANI holdpoints would have been assigned. The 4

level of significance is such that a complete review of i activities and NDE documentation shows all items of the package to be complete, and in compliance with the requirements.

L l (c) The level of significanceis such or mandatory requirements were

applicable. In-such a case, provide details of the method used for acceptance; whether the review required analytical or f mathematical models or any other clarification of evidence for acceptance.

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8. Attachments: None /

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! 9. Reference documents:

!' 1. ASME B&PV Code,1974 Edition including Summer 1974 Addenda l

~

Section III, Nuclear Components.  ;

) 2. ANSI B31.1-73r Ind:luding Addenda through Sumer 1975, Power Piping l

, Code.~ '

3. AWS 01.1-75, Structural Welding Code.

! 4. Gibbs & Hill Specification 2323-55-18, Revision 3, Stainless l

Steel Liners. . .

5. ASME B&PV Code,1974 Edition Including Sumer 1974 Addenda, l

! Section IX, Welding and Brazing Qualifications.

6. NRC Region IV Investigative Report 50-445/79-15 dated June 21, j 1979.
7. NRC Region IV Investigative Report 50-445/81-12 dated April 16, j 1982.

! 8. Gibbs & Hill Specification 2323-MS-46A, Nuclear Safety Class Pipe Hangers and Supports.

i 9. CMC 56843, Revision 11. *

10. ASME B&PV Code, 1974 Edition Including Summer 1974 Addenda,

! Section III, Subsection NF, Component Supports.

I

11. B&R QI-QAP-11.1-28, Revision 25, Fabrication and Installation j of Safety Class Components.
12. NRC Region IV Investigative Report 50-445/82-11 dated December l

i 13, 1982

13. ASME B&PV Code Case 1734, Weld Design for Use for Section III, Division 1, Class 1,2,3, and MC Construction of Component i Supports.

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Gbn A , G hM ).. I Category 2 Comanche Peak Open Issue Action Plan I

l Task: Welding - Adherence to welding procedures )

I Ref. No.: AQW-28, M-36, M-54, M-31, AQW-10, AQW-30

! Characterization: It is alleged that welding procedures were violated with respect to the following:

i A0W-28: Buildup of undersize welds.

I j AW-36: Downhand versus uphand welding.

AW-54: Weave bead versus stringer bead welding. ,

AW-31 & AQW-10: Reinforcement of flare-bevel welds.

AQW-30: Quality control (QC) holdpoints for inspection of welds.

i Initial Assessment of Significance: The allegations have been previously dispositioned in the following documents:

a IR 50-445/82-11 for M-31 and AQW-10 l IR 50-445/79-15 for M-36 IR 50-445/81-12 for M-54 4

TXX-4187, June 1,1984. Ref. Allegation #19 for AQW-28 TXX-4180, May 25,1984, Ref. Allegation #21 for AQW-30.

There appears to be sufficient specificity to warrant followup.

I

.! Source: Mechanical & Piping Category No. 2; see allegation list.

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Approach to Resolution:  !

1. Review testimony transcripts A-3 statement, 4-84-0061 dated 3/7/84, A38.B dated 5/24/82, IR-81-12 pg. 3, SRI interview report dated 8/25/82 (memo to BC) IR 82-11.
2. Review Region IV reports and TXX reports listed above on " Initial Assessment of Significance."
3. Review codes, specifications and other documents applicable to each allegation. ,
4. Review the requirements for welding process used relating to the situation for each allegation.
5. Discuss practices with welding and QC personnel as required.
6. Perforn visual insDections and observations as required.
7. Evaluate findings for generic / safety implications.
8. Report results of review / evaluations of alleo,tions.

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i Related Open Issues:

! 1. Using system codes from the tracking system open item list and

! identify any open items.

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2. Review activities necessary to close or partially close related I items.

4

3. While performing physical inspections, examine surrounding system, j

camponents, and structures for any apparent tefect or indicator of faulty workmanship.

4. Complete portion of IE Module on welding if it relates to effect made on allegation.

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AW-27 Liquid entrant materials nitial dis- 1 C 65E It -

18/83 leprope Iy certilled tion ART t i ASLB IR 8 8, 82-0 I i IR 82-1 .

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l A4W-2 Craft would satisfy a CMC Ltr to Applicant I 1 A-3 Statemen $0 #

on an inadequate weld by 4/24/84 Response ART

, i.eldine over it instead due 5/25/84 8Q ,

of following the pro-cedure of cutting it out then welding ,

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l CONTROLLED COPY CONANCliE PEAK NUCLEAR POWER PL ANT ALLECKTIONS AND/0R INVf5TicAIIONs SupetARY l CROSS REF./OR COMPLEIION ALLEGER-DAIE RECEIVED

) TA5K SOURCE 1 RACKING CAIEGORY 1-7 SCHEDULE 500BCE l $ ALLEGATION OR CONCERN Acil0N/51ATUS ANON CONFIO BN/DATE SYSTEM NO. ((A0 OPEN CONPLETE DOCIMENI PACE l p AQW-30 Safety related welds were Ltr to Applicant X 1 A-3 Statement repaired with weld tech 4/24/84 Response Ol/ ART i (W.T.) holdpoints instead due 5/25/84 l

of QC hold points in violation of procedures.

f -31 Procedural question 2 4-84-006'., 3/7/84 bjS

involving flair level g\ c., ART P. 7 A 17 l l welds versus butt welds kg e
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JWm23 Las QC procedures Review complete ASLB Pre-filed 1 Unknown (3/82) Testi- '

IR-80-02 testimony (Taylor) ART many did 5/24/82 P. 66  !

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. A.38.d. 15-80-02 AW-34 Temporary hangers welded 3 84-006; 3/7/84 Testi-without procedures AP' mony P. 24 AW-35 leproper procedures 1 84-006: 3/7/84; used on hanger welds ART 6 Statement,

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( AW-36 Welding procedures not Initial dis- A518 Pre 'eled 1 Testino . td 5/2 82 followed position I N Testle'ay (Taylor) ART l ' W.. W A.38.b.)

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'GFNERATI'NG CO. NONCONFORMANCE REPORT (NCR) g,gy, gggy UNIT STRUCTURE / SYSTEM ITEM / COMPONENT TAG /ID NUMBER LOCATION OR ELEVATION RIR NO.

Class 5 1 SWI Pipe Support FP-X-06-004-J05F 808' 11 1/2" N/A NONCONFORMING CONDITION -

d This hanger's weld exceed the maximum allowed bead width. (4 core wire diameters) y (3/8"). They measure 5/8". Weld filler material is deposited in only 1 pass and o indications show the weldina done in a weaving motion.

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    • REV PARA REFERENCE DOCUMENT-REPORTED BY: 1 DATE:

. Darlene Stiner f- 9,9 Al l DATE: I 3 QE REVIEW / APPROVAL: /

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O /d 124181 DEPARTMENT 7

ACTION ADDRESSEE

[ Engineering J. T. Merritt/Finneran

, DISPOSITION:

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   "                                           UNITED STATES OF AMERICA NUCL* EAR REGULATORY COMMISSION               M (             ,

850803

               -                             Before Administrative Judges-
                                                                                                           .f Peter B. Bloch,. Chairman       ,)
                                     ~

Dr. Kenneth A. McCollom Dr. Walter H. Jordan I ( Douwi. Gus. o -445 50-446 In the Matter of TEXAS UTILITIES ELECTRIC COMPANY, et al. (Application for Operating License) (Comanche Peak Steam El'ectric Station, Units 1 and 2) d)ctober- 11, .1984 1

                                                    ]EMORANDUM (difl M Conference Held This Morning)

A telephone conference call was held this morning among Peter B. Bloch, William Horin, Stuart Treby and Gerry Mizuno andhuanita Ellis.f During the call, the Board ascertained that Applicants filed a respon , sive filing on welding on September 28, 1984 The Board also inquired about whether the Applicants had responded sto CASE'S proposed findings of fact at I-5, consisting of a quote from \/ The Staff took the positM hr. Stinerfabout repairs of . weave welds. e that(Mr. Stiner'spemark should be understood in context, as p.irt of his concern that the weave weld need be ground down in its entirety. Ms. Elliftook the position that the remark is clear on its face and refers generally to the need for a hold point during the repair of a weave wel d. Applicants took no position on relevance and were unable to respond to the Board's question concerning whether they had responded to the cited paragraph. In light of the disagreeing interpretations, the Board reserved a decision on whether or noth. Stinerhaised the question of a hold / fg point. However, it reouested infonnation from Staff and Applicants ,

       /           concerning whether hold points are needed for cleanliness inspections or i

for surface indications of defects before proceeding to complete a weld f repair by adding a co5er pass. Judge Bloch stated that the Board members are not weld experts and were unsure why hold points were i F0lA-85-59 w, w

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Weld RIpair: 2

         ' required for fit-u'p and cleanliness before a new' weld is begun but a hold point for cleanliness appears not to be required before a cover        ,

pass is made orr a repaired weld made over the remaining portion of a weld that was previously found to be defective. Given the need to repair a defect, an explanation should be provided on why VT and PT examination need not be conducted before the cover pass is made. Judge Bloch stated that the Staff should include this matter in its [ schedule of target dates, now expected to be filed next week. Appli-l I cants' response date also could be set at that time. Ms. Ellis requested an extension of time of three days for filing a discovery request concerning cross-over leg restraints, citing competing l demands for her time, including a recent motion for sumary disposition 3 filed by CASE. Applicants opposed this based on their continuing objection to the need for such discovery and based on Ms. Ellis 's neglect of her obligation in order to file a non-required motion (the a motion for summary disposition), h.yever, the Board granted the request over Applicants' objections, stating that there was little reason to deny this extension, given other delays already affecting the case. The Board also notes here that Ms. Ellis's filing of the Sumary Disposition _ motion was related to her responsibilities in this case and represents a j l legitimate use of her time, f FOR THE ATOMIC SAFETY AND LICENSING BOARD Peter B. Bloch,' Chairman l ADMINISTRATIVE JUDGE { Bethesda, Maryland i

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 -l                            1                                 A            Okay.

M22-2

     !                        2                                  Q            Actually let's go to Page 9.                                        In regard to

!, 3 comments in Answer 8 on Page 9 regarding  ! .i 4 whether or not he has ever done any weave welding, do you  :,

   '                                                                                                                                                                                  *I i                             5      have any comments regarding that?                                                                 .
                                                                                                                                                                                      ;}

6 A Yes, He absolutely has done weave welding. j 7 When I wrote an'NCR on the hanger in 790, I first noticed i, j a the hanger was in a weave -- the welds were being weaved, . 9 so I went ancl got , who was the QC supervisor, [ to and he was in the hall in 790, so I asked him to come and  ! 11 look.at it with me. I didn't kant to -- you know, because e i l 12 this is a touchy situation, so I asked.him to please come i l g is an,d look at it'with me, since he was right there'anyway. He e 0 - l 14 did so, and when we climbed up there; well, he saw it, and ' 15 was we1 ding on the hanger, and we crawled down -- 16 we didn't say anything to He told me co tell' i 17

                                                                              , which was the foreman, to ct.it the hanger down,,
  • is which I did.

l 19 told me that he would cut it down, , 5 '20 all right? At that time, left. I didn't feel 21 like I needed him anymore. It was probably -- I don't 22 know exactly just.how long al period of time elapsed, but 23 not very long. ' ~ i 1 L '24 I was called back for'another. inspection. When i l j 25 I got there, they had no cut it down, so I asked why they i i r , t I -;

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              }'                                         had not. The faces of all the welds had been ground oct, 2
                                                       .so I was   told by                   that he ha'd checked with 1

3 Engineering and that Engineering had inetructed him^that3:,1

       -                                            d didn't have to, that a,s long as it was ground down to base                                                '

I I 5 ' metal and repaired, they didn't have to cut it down. 3 . 0

       .j                                                            JUDGE BLOCH:       Ground dowr. tio base metal?
              ]l                                               .
       ! !                                          7 THE WITNESS:       .Yes, s iz*, to parent metal.

Ei , 8

              }

t JUDGE BLOCH: That was -- what were you told? hi ' THE WITNESS. I was toid the engineer told him 6 l I0 1  ; if he ground the thing down to bare metal, base metal, - 2 M ' i JUDGE BLOCH: Ground it down? '

                                                                                                                                                               )     '

12 1 g l THE WITNESS: -- ground all the weld out, every F.i

                                                  '3 and rewelded all that out, it would be acceptable, and- he." 1#
                                                  'd
                .'. g;j                                didn't have to cut it down.

l

                 'l                               '3                                                                                                         )

JUDGE BLOCH: Do you have any idea what the HCR q i , 16

                                                       .nubtber is that we are talking about?                                                                  ,

i II THE WITNESS: No, sir. This was voided. I tried a

                                                ' '.s   to find it or find out, you know, and I had no luck.                                                  d i
                                  -             -                    JUDGE.BLOCH:       An NCR that's voided. would neverthel 4

20 have a number that would be -- , 21 {i, THE WITNESS: Yes, sir. . I don' t know why it's CC} d . c 22 j l I assure you, I wrote an NCR, and I placed a hold tag on CP8 23 hanger, but I tried to locate the .nber, and I have !no idef

               !                                  24 why it's not in theixecord.                                                                '

l 25 JUDGE BLOCH: You actually have looked at the DCd

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h I and have not -- j ' qc 22-4

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t 2 THE WITNESS: Yes, sir. I went over after -- when he

               'I                                3        all this came up, I went over and asked what happened to my
               .l.

I don't even remember when I went, but I asked the O j! 4 NCR. ,' f 5 .NCR coord'inator what happened to my NCR, and said, "I 6 don't have any record of it. " h said, "I don't have any f 7 record of it. I never did get it." P "} 8 JUDGE BLOCH: The NCRs have a unique numbering { l 9 system.

. hat!!

o .. [ l 30 THE WITNESS: 'fes, sir. b g'.jlj 2 ll JUD'GE BLOCH: Did you actually know that the number-bit !

  • 12 had been assigned to the NCR7 *
 ?           fI 13                               THE WITNESS:                          Yes, sir, because you see the QC ft
  • Id inspector themselves call for the number. So I called for the
p. .

15 number myself, and I% sure I wrote it down, I have no idea 16 where, and I~couldn't find the number. But I put the hold I 17 tag on the hanger, and she said she liad no record of it, but $ is she gave it to me over the phone. ( j 19 JUDGE BLOCH: Is this the incident that you 70 previously testified to? . 21 THE WITNESS: Yes, sir. Can I go ahead? f* , h, 22 JUDGE BLOCH:~ Please.

  • 73 THE WITNESS: Anyway, they had not cut it down.

F:- r 7' 'They ground it down to base metal and was told that was

  #cs                                             23         acceptable to,do as long as they had ground the metal all out, b

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mgc 36-6 1 ' .) Q b Just to be very sure, on'Page 5, Lines 12 to 14, 2 you say one o'f the things you were concerned with is

                    'l                                                                                        {               I
                             " excessive heat. input" when you weave weld.

4~ . i My question is, you are cbncerned abqut heat input,' S regardless of whether the maximum bead width limitation was o - exceeded or not?- - I - 7 A Yes, sir. ( - 8 ., . Q Any time you have any type or any amount of t 9 transverse osciallation, heat input'is a problem. 10 i A Dut not to the extent -- it would be a problem, l 11 ,  ; I would think, yes, but it wouldn't be a problem to the ! 12 i i extent that if it was over'the four-core wire diameters. 13 d' .i What is the basis for your statement on the same 14

                        .page, Lines 22 to 24, that Weld Procedure 11032 is

{ 15 interchangeable with and often used in p1' ace of 11065? - ! to A l

       .                                  I was just told it was interchangeable.

17 O Do you have any personal knowledge that it was used - 18 g in place of 11065 by welders?

19 A Il t

I don't have any personal knowledge of it. I was 20 told that it was used in place of -- that it was interchange-  : i 21 able.

                                      ~

22 p Q on Page 6 towards tha middle of the 7.I C ! 23 page, you indicate that you have done weave bending over the

          'ad                                                                                         ,

four-core wire diameter limitation; is that true? 25 A yes,

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         .I              mge 36-7 1 .             O l

Can you identify the specific locations and hangers ~ { 2 where you did that? j - 3 A No, sir. That has already been asked once, but i l  : 4 I couldn't. It's been.a long time ago, and I just don't

         )                            5   remember.

6 Q ,could you go to the plant, walk around and identify 7 those locations? s A I don't remember. L'1

                                                                                                 ~

9- Q Okay. , you understand that weave 10 beading in excess of that bead width limitation-is against II procedure. Why did you do it? .

         "                          12          A       Because I was told to.

I l ! J /; 13 O And who were you told to by? J l' T l 14 A Supervisors.. g is Q Can you.; identify those supervisors and the instaneS L r I. 16 in which that occurred'? ' 4 I

       .j                  -

17 A Can I identify every one of them that ever told me ! 1 [ 18 to weave welds? I. ,

                                  ,19           0       Why don't you start off listing them and perhaps 20    give us a few examples of when they did tell you that and 21    the location, if you can recall the locations where that 22    occurred.

h 23 A I can't recall locations. I can tell you my 24 foremen's names as well as possible, but I don't remember

                                .25      every instance that they all told me to do that.                  I've been k.'

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  !;c 36-8                                  I told on several occasions.                                                                                         -

d 2 Q I don't want to know the names of your foremen. .I. i 3 . E ' I want to know the names of the foremen who directed you or 4  ! any other person who directed you to weave weld in violation i

j ,

5  ? , of the procedures. i , {

6 JUDGE BLOCH
Do you know those names? i  ;

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l I i 37joyl 1 THE WITNESS: I've got to think of my supervisors.

                  $cA    Okay.                      --

3 JUDGE MC COLLOM: These are supervisors that you 4 say instructed you to weave. weld? l

                     $                -THE WITNESS:    Yes.

6 BY.MR. MIZUNO: 7 Q Excuse me, Weave weld in excess of

8 the limitat $n. _

L

                                                                                 ~

f 9 A Yes, sir. 10 That's i 1c ii att I can thinx of. , 12 Q On the same page -- ! 13 JUDGE _BLOCH: One second. Why? What was the 14 motivation they could possibly have? , i5 THE WITNESS: When you get a bad fit-up or some-16 thing like that, in some instances -- you could'put metal l ' 17 into it easier. - l 18 JUDGE BLOCH: It's fhster? 19 THE WITNESS: Well, it would be faster, yes, sir, 20 but you could put metal into it easier also besides being 21 faster. It would be faster, but you could also put metal 22 into it. ( 23 JUDGE BLOCH: Are you sure it would be faster.if 24 you did'it that way? , IS THE WITNESS: In my opinion, it would. To me it f.

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i was faster. i I 2 JUUGE BLOCH: You tried doing similar types of i 1 2 welds --  ; 4 THE WITNESS: -. i Ona regular basis I made stringer t 5 beads, and then'as compared to a weaved bead, it was faster. i

                                                                                                                                     =

6 { The reason it was faster is because to make a stringer bead, i

   !                    7

( you would make one and then you would go back and make {

   ;                   e           another                                                                                             f J                                            lapping about half-way over the first, then.go                             ,

9 back and make another lapping about halfway over the second, d

   }                  to i                             which would entail going up the piece or welding the piece                        >l N
   !                 11
                         ,        three different times, three different beads. If you weave                  e -:

i 12 it, [ 1 you are progressing slower up the piece. This was the $ 4 is thing about the heat input. P The slower you go up the piece, ' j 14 J-that I wasn't taking from a metallurgical standpoint. I is was just saying from common sense, if you hold the rod the're 16 long enough it's going to get hotter, hotter and hotter. 17 _ JUDGE BLOCH: If you traverse the same area' 4 is hori::ontally making the weave as opposed to doing it vertical l. y ,

)                ,19             three times, l                                                 it seems to me you have left about the same 20 l'

number of beads. I don't know why it's faster to do it one i 21 way than the other. 22 THE WITNESS: Well,'to make the stringer beads,

               , 23 you would make three, and to make the weave bead, you are t             24 washing it back and forth.       You are washing it.        When you 25 f                                get up to the top, you have done the whole thing in one pass,
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C, 10e316 37 joy 3 1 , JUDGE BLOCH: It goes faster. 37jo; I 2 THE WITNESS: Yes, sir; to me it did. 3 BY MR. MIZUNO: 4 Didn't you just indicate, that to Q 5 do the transverse oscillation, it was slower and therefore Isn't that contradictory to 6 you had a greater heat input? your statement? 7 L l s A You are progressing at the piece slower, but you 9 don't have to progress up it but one time and then you would You would be covering ' 10 have. about the same amount df weld. s i Il the same amount of area, is what I was trying to say. _ l l 12 Q I see. Does the amount of weld rod used or does . 13 the. amount of weld rod that is being burned as you.do a ( 14 weld differ between doing a t'ransverse oscillation versus I 15 doing a stringer bead?' , lo A .In my opinion, only in one instance that I can think' 37 of, and that would be, for example, if you made a stringer 1a bead, you progress up the piece faster; therefore, you would l

                            ,'3 make more area with one weld rod. You would go, say --

l' 20 depending on how long your weld was, but you might incke it 21 all the way to the top of the piece with one weld rod, l. 22 whereas if you were weaving with the transverse oscillation, 23 you would'not progress up the' piece nearly as far. You woul ! 24 have,the stops and starts in -your piece. So you wouldn't - , 25 it would take less area of the ' weld. r 9 9

                                                              ,                             9
                                                     . . . . .~ _ _ _ . _ _

t , *

  • =

l 10,317 t, 7 joy 4' i - Q Would that, then, require you to stop and change f I i 2 rods? ~ , e [ i 3 I A Yes, sir. e ! 4 Q Would that take some time? i !. s A L It wouldn't take -- just long enough to put one [ l 6 in the holder. t 2 3 - 7 Q How long would that - .can you estimate the time?' ' j e .p A . I don't know, 5 seconds, maybe. I don't know. f 9 i Q You are an expert welder. 10 A It would really depend -- yes, sir. It would [ i 11-really depend on the size of the piece of material you are , f 12 welding on, the length tha't 'you weld. L 13 JUDGE BLOCH: - - I don't think you meant what you 3 14 j said. L You said that the time it takes to change the rod i 15 depends on the length of the weld. 16 . THE WITNESS: No. No, sir. I He asked me how long . 17  ; ( it would take to change a rod, to get a different rod.' I . la i said about five seconds.  ; 19 l , JUDGE BLOCH: Okay. . 20 -- 5 BY -MR. MIZUNd: . 21 { Q Now, it is my understanding that on page 6 you } 22 f also state that you saw other' people do weave beading in

23 2'

excess of the weave -- the weld bead limitation. 'Is that true? ' i

25 A Yes, sir.

n

                                                                ~

IC 10,318 37jo . 37 joy 5 I Q Can you identify those people? For one was As I stated, I 2 A Yes, s ir. 1C3 watched him weave weld on the hanger in question on 790 4 elevation.

                                                                                   ?                               j 5                   0   ,

In addition to 6 MS. ELLIS: Could you repeat that? 7 BY MR. MIZUNO: a Q In addition to _could you identify 9 those people who you personally saw weave -- to A I can't remember exactly.any person except him, 11 but I have seen people weave weld,'yes. , 12 Q But you can' t remember -- - 13 A Exactly who? No, sir. . I' Q Was it often? 15 A Tha't's hard to say. I don't remember. I mean I 16 ' don't' remember every instance. 17 Q Could you go tu the plant and point out to a is person where -- 19 MS. ELLIS: Objection, Mr. Chairman. I believe we 20 are getting areas where the Board has offered CASE the 21 opportunity to go there on discovepy and that we would 22 identify areas but under a protective ' order. Is that not 23 correct?

                                                                   ~

24 JUDGE BLOCH: Under a protective order -- 25 - MS. ELLIS: I don't know if it's under a protectiv e

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                                                                                                                                                   ;              t 373cy6                  :             order.                                                                                                ll 2

i i JUDGE BLOCH: l 3 Your discovery, wasn't it, but I . 4 will sustain the objection because I think you just asked - the question about three minutes agos , 3 i  ! MR. MIZUNO: I asked a different question, Chairma n l 6 Bloch. My first question, which related to whether

                                                                                                                                                              )'

7 remember where could did ea're beading. g JUDGE BLOCH: 9 Can you remember the locat, ions where l l anyone else did the weave beading? If you can't, just say l to no. . i L u ' THE WITNESS: yO 12 No, sir, not other than ' BY MR. MIZUNO:' _ t 13 . g 14 Did you ever ask those people who you saw weav e

                                                                                                                                    ,               7 beading, weave welding in excess of the limitation, why     ,

1 is they were weave

                                                                   . violating the procedures?

16 A No, I hever did. l 17 At the time, I was a welder and , , 1 I didn't have no reason to be asking them. is them anything. I didn't ask i  : 19  !

                .                               Q 20 Can you turn to page 9 through 10 of your l) h r

testimony, and on page 9 from line 21 up to page 10 , line 1 21 37 - P4 22 A Yes, sir. , 23 MS. ELLIS: Just a moment. 24 What page was that? MR. MIZUNO: 25 10, line~ 3. That was page 9, line 21, to page f e b q ,

                        ,        ...,~.         ,    - - - - -                       --      - -          ----           -- ^ ^ ~ ~ ~ '

10,320 37 joy 7 i MS. ELLIS: I believe that's testimoni 37jo; y 2 isn't it? i

                                                               ~

3 MR. MIZUNO: Yes, it is. I'm sorry. ND 3* 4 BY MR. MIZUNO: 5 Q Page 10, line 4, up to line 12. ' A ~~Yes, sir. 6 7 Q Where did show you t'o do this l s practice? j .9 A In.the structural fab shop.

                                                                                                                       ,                                   [

no Q I'm a little -- I can't quite understand your -

in testimony as to exactly what the practice is. Let me describe the pziactice and tell me whether you agree that'
       .                                  12 13      that is what you are talking'about here.                          By beating the 1

14 flux off, you mean to take a weld rod'and somehow take off . is the flux.and.to use the bare metal rod in filling in a gap !- 16 and then welding over that rod? I { 17 A That's close but not exactly. If ye..u had a bad 18 fit-up or something like that, we take a rod, beat the flux l , 1 19 off, take another rod with the flux on, and strike your ! 20 arc,. and as your rod with the flux on burns down, you ! 21 would feed 'with the other hand the rod with no flux into 22 the molten puddle, thus melting the rod, and this would make h 23 more metal. In other words, make more filler for your , 24 weld. 25 Q And beating the flux off, you mean removing the (. i

1

  %                                                                                                                10,321
> m?37 joy 8                     i flux.

l

                                                                                                                                                            ,l' 2         A   - Yes, sir.

ND 37 3 i e J 1 i

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                                                                    ,,Q    PW WH       ? '%     -

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iC 10,322

T3 / 1 JUDGE BLOCH
Was that somehow faster, rather g
2 than puddling more?

3 THE WITNESS: If you had a real bad fitup, or a

                 !4 real wide gap you needed to fill. I was shown how to do this 5    so that if you -- in other words, if you'were going to make a
                 ;    a    bead and the gap was so wide that there was no way you could 7    do it without it: falling out, you could feed this rod in t

i, e there. You would have so much metal going into it, that it L ] 9 would actually be a lot easier to fill it that way. JUDGE BLOCH: Somehow held it in this place. ), 10

il THE WITNESS: Well, I can' t say it really held it ..

3 12 in place, bub you had more metal going into it -- I can't 13 really explain that. -

     ~
.i Id                   BY MR. MIZUNO:                                               ,

15 Q do you mean that the bare metal 16 rod would also be melted by the rod that you struck an arc $ 17 with? ' I is A Yes, sir. 19 Q And you would have twice as much metal? 1, I 20 . A Yes, sir. Yes, sir, additional metal. L. 2 Q Now, you indicate that you made a kind of weave L 22 welding with this type of practice. 23 Could you do it with other kind of welding, strinc 24 bead welding? ,l - 25 A I don't understand what your question is.

   '\. .-

V. I p .

{ i Q 10,323 l i mm2 1~ O i 2 This practice of beating the flux off and using it to fill in a. bad fitup, you indicate that you did this 3 using a weave weld. I d

                           .          A       Yes, sir.

5 V o 6 It was done in excess of the weave weld bead width. limitation? , 7 A a In some cases it would be exceeding the four-core-wire diameters; i 9 in some cases it might not, depending on how wide your gap was. 10 Q Il Could it also be done on what you call a stringer i i bead? - 12 A No, sir, no way. .

                             ' ~ ~

13 Q Why not? 14 A Because when you feed the bare piece of bare- ~ 15 16 metal into the oth~er molten puddle to keep it from just -- well , 17 to keep it from just bubbling up and -- it wouldn't weld right, la you would have to wash it back and forth with an i oscillating motion to get it, spread out like it would need to 19 go, " 20 t Q 10 21 did you ever identify this practice 22 as a problem in any of your previous testimony? A I don't remember.- 23 MR. MIZUNO: h should I save my 24 Chairman Bloc', motions to strike to the very end? 25 JUDGE BLOCH: We have never been so parsimonious e I l ' i I _

514,-6 , ic, 10589

                                                                    'O      Do you know A      Yes, I do.
    .             2 O      Could you tell us whether he was in your crew during,your                                           employment?

A No, he was not. 5 Q iDo you know whether he was working under iC. during your second term of employment? A I I ' don't believe' he was, but the way they do things

      -           8,                                                                 -

l i at Comanche Peak,'you know, there is no telling. I do know 9 . 1 76- one thing.. I never saw sgive any iristructions to and I never saw _ in the area that I worked in,'and I don't believe he was on crew. ,

           ] C,                                                      Q      Do you know a A      I have seen him out at work a couple of times, but 14 as he stated in his testimony, he doesn't remember me and
15 i I certainly don't remember'him being in the same area. He
16 could have been under the same general foreman, but I don't 17 g believe he was under at the ' time I worked for him.

19 Q Now on'the weave weld issue were you ever trained 3 20 - i to make a distinction between when a weave weld was 21 - l 4 appropriate and when it was not appropriate? 22 _ r A No, I was not. 2 > [:* 24 Q , Were you ever told of such a dis; tinction? i M b 25 A It had been mentioned to me on several occasions

 ,.                                             that weave welding was not allowed at Comanche Peak.

[. E0lA-85-Jgi. . ..

/- - 10590 7 1 Q Now when did it come to your attention that there ( s 2 might be some circumstances -- well, let me state that 3 question correctly. 4 Did it ever come to your attention that weave 5 welding might be appropriate in certain circumstances at 6 Comanche Peak? 7 A Would you rephrase the question. 8 Were you ever told in any context that weave weldinc O

                                                          ~
  • 8 could be' appropriate? '
                   ,                                   s
                                                                       ,                h 10              go, 3                                    ,

11 Q Do you have an opinion of your own whether it is 12 approp'riate under any circumstances? 13 A As in his previous testimony has stated, 14 if you believe what he has represented that if weave 15 welding under four core wire diameters is allowed at 16 Comanche Peak, then that would be true. But as I have 17 stated in my testimony, we are not talking about weave I8 welding under four coure wire diameters. We are talking cnd 14 about weave welding over four core wire diameters. cnd Sim Burns fols g wh tr 4]*

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                                               ,              -l_b                        j

e T15JRilajrb 10591 jl fis MS I C, ( 3 O Now, do you,have any examples of weave welding 2 Lat Comanche Peak over four core wire diameters? 3 ' A One instance was where.I mentioned in my testimony l d about the welder and that was--I 5 mentioned it to the Nuclear Regulatory investigatops.

  • I gave them the location of tihe particular hanger.

was welding o$ the hanger at the'

              ~N~g      8 time that I was sent down to remove him from wor'k at the l

W .' hanger by my foreman. L

                       'O He had been welding on'it -at th'at time to where
                           .the metal had become so hot that the metal was spitting out 12 on him and falling into the aislewav +have; and he turned to m
                       '3 me and says, " Hey, I can't get this--I can't get this weld to stay ~in; it keeps spitting out on me."

15 And I said, "Well, you've got it so hot, that's the reason why you can't keep the weld in there."

                      'I                                                                            '

He even had the metal crystallized, you know, out 18 four or fi.ve inches away from the weld, which was enough indication to me that there was damage on that parent metal. 20 7,in talking about what I call a gorilla weld, 21 big, strong and ugly. 22 And--- JUDGE BLOCH: You say "crystallyzed" out; what was

                     -24 the indication of that?

25 THE WITNESS: The indication would be'the blueing (. w.

i

                                     ~
                                                                     /g           10592 T5'-2

[

      -              1   that the--the tempered blueing of the parent metal.

l 2 And at that time I was instructed to. grind off

3 the surfaces of the welds, off; and buff out the blue temoered.

4 part of it so that it wouldn't be apparent; and then recao

, l
              .      5   itL i

l . 6 BY MR. HAGER:

I 7 0 Who instructed you to do that?

s a

  • A My foreman did.

9 Q Did seem aware that. this was an $ lo improper weld? . l 11 A I don't think he did. I think he at that time 12 that he was inexperienced in nuclear welding and that he

13 just wasn't ' aware of 'what the problem was that he, you know, id had created.

j 15 JUDGE BLOCH: What was your repair going to be like ? j 16 THE WITNESS: Well, it wasn't--see, I wasn't sent i ! 17 down to actually repair the hanger as would be required by i' 18 the code. 19 I was sent down there to move him off the hanger 20 so QC wouldn't come by and catch him, and to actually just l 21 cover the thing up and recap it--or to cap it; it hadn't l 22 been capped yet; but. cap it; and get rid of the crystallized 5

                  . 23   color that was on the side of the metal which, I did that l

1 l 24 with a wire brush. . ) 25 JUDGE BLOCH: ;And so the weld you did would have i i f. j w - a

                                                                                             ] C,                     10593 15-3                                                                                                                                            .
 'l Y
   %                           3 been unsafe?

2 THE WITNESS: Still unsafe, yes, sir.

                                                  ~

3 - JUDGE BLOCH: ' And yet you did it? d THE WITNESS: The weld that I did on the cap part 5 would be the required--by the code. f 6 Now, what was under that cap, what f 7 had put in tliere, was not. It would be a unsafe weld.

          ~

8 JUDGE BLOCH: And.the weld configuration itself _

                                                                                          .~                                                        g-would have been unsafe?                        ,

30 THE WITNESS: Right. - II JUDGE BLOCH: Did you complain to anyone about 12 ' being asked to do that? 33 THE WITNESS: Not at that time, no, sir. I# JUDGE BLOCH: Why not? 15 THE WITNESS: Well, for various reasons': at that 16 ( time I wasn't aware oftwhat-the effect of the heat would b~e

                            '7 into the metal, and that it did set up a dangerous effect.

Is And, like I'said, until I got into.the QA as.oects ! and got into reading welding manuals that explain why you 20 , get this blue'crystalization out to the side, that I under-21 stand that that was in effect just totally, you know, I 22 a bad hanger. I i 23 JUDGE BLOCH: You say the metal was " spitting" ' out at him? 25 THE WITNESS: Yes, sir, i = 4 ! %:r c 5 .

15.4 10594

       'l i

I JUDGE BLOCH: . Part of the metal was actually 4 2 i melting and falling out of the weld?

                                                                 ~

3 l THE-WITNESS: That was because he had applied too 4

                                '                                                                                              ~

much heat input to the metal. And it was an overhead weld. 8 And whenever you apply too much heat to it, you're--when you weld overhead, you're defying the law.of gravity anyway; I so--and then~ connected with too much heat input, then the metal does not solidify to remain into the place that you 9 -

  • I placed it. - -

JUDGE BLOCH: And part'of the metal is actually dripping onto'the floor? THE WITNESS: Richt. - JUDGE BLOCH: At that time yoididn't know that it 14 would make it unsafe? , THE WITNESS: No, sir.. JUDGE BI.OCH: Do you now believe that it would make it unsafe? l 18 THE WITNESS: Beyond a shadow of a doubt. i 19 i BY MR. EAGER: - 20 Q At'the time you were told to do your weld, did 21 i you have the belief that you were being instructed to cover i ' 22 something up7, 23 A No. l 24 Q Did Mr. Brown ever observe you while you were at I 25 . work? ' d .I l 9 6 _ , ,.m..._,,_. - - _ . - . _ - . , . . _ _ _ - . ~ . . . . - - - - . . - - - - - - - - - - - -

                                                                                                       ~ __ ~.
                   .r. ; .. . . . . ' : .:_                .

10595 4 15-5 ,3 - o I A No. e He's ne.ver. i 2 l Q Could you describe for us the amount of training

~

3 that you experienced in your welding at Comanche Peak? d A Are you referring to the weld technicians that j 5 come down and--like Mr. Baker stated in his testimony, about 6 l. the weld technicians that monitor welders severely, and that 7 ! this type of situation couldn't have happened? s . Most of the time the weld technicians that did the t -

                                                                                         .                                                                                                      L.

j , monitoring, I'd only seen one in the field' that ever checked ! 10 any of my welding parameters--correction:

                                                                                                                                                         ~

i 11 I've seen two in the. field, but only one of the 12

persons only one time.

13 1 The one that normally came around, I can't recall

                  'd

, his name. The one that normally came around to do the weld e 15 parameter check, all he ever did was to go over my welding lead up, put a amperage meter on it; he checked to make sure ' ! '7 that my welding machine was functioning procerly; and then

                                                                                                                                                                  ~

is , that was it. 6 We carried on a conversation about his tax 20 exemptions and what-have-you. 21 t And he checked the rest of them off without

22 actually doing the proper check.

I'm sure that Brown & Root records would indicate 24 who that technician was that did the monitoring. 25 O And it's your testimony that the monitoring , not* 9 9 _ , _ . , _ _ _ _ , - - _ - - - - , . _ - , - , , . ,,,.___,-,-n-.- , , _ , , ,

                                                                                               -      ~

_ _ _ . ._.g..... -- -- -- 15-5 10596

 ,g                             .

i

   \'                    '

was inadequate? I A , Most definitely. 3 Q Now, could you tell us about the-- JUDGE BLOCH: To be clear: i 8 . t The reason it was inadequate was things were  ! checked-off about which the technician could have had'no 7 . kowledge? - THE WITNESS: Yes, sir. g. He didn't check it'as he was required to. 10 One of the requirements is that they watch yos 11 actually run a pass. When you're in progression--in oth,er 12 words, they keep talking in all their testimony about that 13 they observed welders, that from their observations of watching _ welders actually welding, you know, they can tell whether 15 somebady is, you know, doing something wrong or doing it 16 incorrect. 17 But, none of these weld technicians ever had a is welding helmet on. 19 JUDGE BLOCH: Never had a-- THN WITNESS: They never had a welding helmet. 21 So that they could actually, physically, watch me make a 22 weld.

              .       23 All they've got is a little black box, in most 24 cases--I'm saying a briefcase-type thing--that has the 25 amp meter in it, that they used to check.       And then they've s

Y

                        . a _. .                . . . . .                ..
    . 15-4                                                           m ,                    10597 I"

l$ !/ l * ' got a note pad that they actually have the sheet that they're db 2 checking all the stuff off on. 3 Now, they're required, as testified, d l they're required to do several things. And one of them: . is 5 toactually,physicaliy,checkyourweldermaterialcan. They' don't do any of that. 7 t JdDGE BLOCH: .Okay. That's one thing that you a think they Ehould have~done. .

                 '                                                                                              L So--what, are they' checking someth'ing off on the                           ~
               'O form about the weld filler material can that they should not II have checked off?

I THE WITNESS: Yes, sir.

               'O dUDGE'BLOCH:           .What other things was ,it do you know that they were checking off that they couldn't have known?

THE WITNESS: I couldn't say without having one of the inspection sheets in front of me.

               'I But if I had one, I would be glad to name every-18 thing that they didn't check off.                                 -      -

(Pause) MR. HAGER: I don't think we have one. 21 (Pause) 22 That.should be with testimony. JUDGE BLOCH: It's in the transcript, in that 24 Case. l 25 l MR. MICUNO: Yes.  ; ! W 9 8

                                                                                                 =             .

J.

            ' 21-4
                                                                                                         %                  10705

( If there was prepared

                                                                                          ~

1 JUDGE BLOCH: Okay. 2 rebuttal testimony, you could ask a more specific question 3 without being leading. - d BY MR. HAGER: l 5 o Ied-like you to tie in the Blodgett book that i 6 we spent so much time.with -- 7 g"UDGE BLOCH: I think he did that. He said there was a d.ifference in the Blodgett book with respect to a a' ' 9 how thick the material is. 10 BY MR. HAGER: i il Q Can you explain why that's important? 12 A In other words, I made a statement tha - 1c 13 had did a test on, I believe it was'three-quarter or 3/8ths 14 inch material on a three-quarter inch hole, and what I said a 15 was, was why didn't he do it on a two inch thick material { 16 with -- ,

                                                                             ~

l 37 JUDGE BLOCH: We already got that. Not only g 18 that, we're going to get the Blodgett book, and' we don't 19 have to go any further with that. , i 20 BY MR. HAGER: i  ! 21 O Now what does the effect of a higher tensile 22 strength have on that process? j l ' 23 A Well, the higher tensile -- you're talicing about I 24 in reference to the parent metal? - l 25 Q Right. I o

   .i
                                                                                                                                                     ~

Fo\A-85-59

m. a .

21-5 1Cs 1 MR. T '..ULDS: _ To bare metal? 2 THE WITNESS: To parent metal. 3 In reference to the strength of it, whenever you 4 weld on parent metal and you apply too much heat up above 5 a certain range -- I won't quote it off the top of my head -- 6 you break down the molecular structure of the parent metal, 7 which changes the grain growth. If it's not allowed to cool a properly, it cools too fast or too slow, it will cause ,. S 9 the grain growth when it's in its completed cooling stage 30 to have been altered from the original grain growth. i 11 JUDGE BLOCH: Is this a particular. problem for 12 steels where their carbon content is no more than .3 percent? 13 THE WITNESS: Well, .3is--(Mr. Bake testified Id that it was considered to be low carbon steel. 15 JUDGE BLOCH: I don't care whether it's low l 16 carbon steel or high carbon steel. Is this problem of . 17 heat -- i

18 THE WITNESSs At .3, yes, it is.

I i l' JUDGE BLOCH: It is a problem in those steels? 20 THE WITNESS: Yes. l 21 JUDGE BLOCH: Do you have an authority for that? 22 THE WITNESS: Yes, sir, from .3 to'.45, I believe, 23 ,4, r 24 JUDGE BLOCH: No. .3 and below, I want to know 25 if this heat problem is a problem for steels at .3 or below. l i [

     ,Er
   .          . , _ . . _ . _ . _ .... . . _ _ . . .          ._.       . .. ~ ...._ _ .      _ _ . _ . . _ . _ . _   . . . . . . _ _ _ . . _ _ . _ _ _ . _ . . ~ . . . .

2I-6 1o707  ; l 1 THE WITNESS: It is for .3, but below .3, no. 2 JUDGE BLOCH: All right, so at .29 and below, } l 3 . 3 'it's no problem? l d THE WITNESS: No. i j 5 MR. REYNOLDS: You asked for authority and you 6 didn't get an ancwer'. {. i ! 7 JUDGE BLOCH: I don't need authority for his i e a saying that it's no problem. - i' 9 MR. REYNOLDS: .3 is a problem is what he said. j 10 JUDGE BLOCH: I think~his problem is the break i . i 11 point on mild steel is less than .30, so if we say .30, 12 that is the break point, and I think he's referring to a j 13 different range of steel. Id BY MR. HAGER: i i

                                                                                                                                                                          ~

i 15 Q Could the tensile strength drop lower than the f ! 16 base metal? I 17 MR. REYNOLDS: Mr. Chairman, we have no indication i 18 in this record that this man is qualified to answer the l' question you just asked him. We can do voir dire now for F 20 the convenience of the record, but for him to make this i ! 21 statement without any technical basis for saying it -- i 22 JUDGE BLOCH: I agree, he's not a metallurgist. 23 I do think there could be a problem in our record because of 24 the break point on the steel being at .30. I'm not sure 25 whether that particular reading is included as a mild steel

        \

[ wer 5 i 4 't I h

1 I or in the next category of steel. You might'want to clarify 2 that in further testimony. 3 I don't think we need this witness' testimony 4 on.it. Only if it will correct a misstatement or misleading 5 testimony that youve given. 6 THE. WITNESS: It will. It will. Attachment B 7 to my testilmony, if you re' a d' through there, I think it will  ! a demonstrate my encern for the carbon content. - 9 . 6 MR. REYNOLDS: Attachment B is not evidence - i 10 { in this proceeding. You might as well tell us to go out 11 and read the dictionary. This has no probative value, 12 it's not evidence. . 13 JUDGE BLOCH: It hasn't been qualified as 14 evidence in this proceeding at this point. Other experts -- 15 THE WITNESS: This is a welding book supplied to by Comanche Peak. If, you know, you're saying that 17 Comanche Peak is supplying books to their welders that's is not qualified, that's --

                                       ~

19 JUDGE BLOCH: It was provided by comanche Peak. 20 We do have testimony to that effect. On what grounds car we 21 exclude it? 22 MR. REYNOLDS: The testimony was that 23 bought this book on recommendation from a fG 24 JUDGE BLOCH: That she was ordered to get it. 25 That's what the testimony says. (*. kr e

   ,                                                                              'w .

e t-

                         ,_ ,             .    -+..- . .        ..
   ',         ,   .                                                                                         10837 9-12 l~         -     -

jQ 0 1 it is the actual point where the Board granted the Applicants' 2 motion; I believe that the Board struck it on the basis of 3 the fact that this issue was not previously raised up to this d point. 5 And the Staff was going to report back to the , 6 Board,that it was going to look into this area. 7 Anii on that basis the Board--but, I think it's a still valid. - 9 JUDGE BLOCH: We didn't strike'it because it was - 10 raised in other contexts. There's no reason to have it in 11 here.' It's not an independent issue. So we won't have to 12 reverse that. There's nothing lost by it, by sticking with 13 our previous' ruling. Id BY MR. REYNOLDS: 15 Q We were on page 13, line 18. 7C 16 .

                                                       .MR. HAGER: 'Does that mean it's stricken again, 17        or--

18 JUDGE BLOCH: We consider it stricken here; 19 since it is redundantly in other parts of the transcript, 20 I don't think you've lost anything. 21 BY MR. REYNOLDS: 22 Q You were told not to grind.all the base metal. 23 Who told you not to grind? 24 A My foremens did. . 25 Q Who were they? 4[

                                                        ~
      ~

F01A-85-59 mo

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

10838 ,, 9-13 , it f O. 1 A Do you want to name them, a list of all them that 2 ever told me this? 3 - Q~ Yes? ' d A Is that what you're asking? I 5  ; Um-huh?

Q
  • A -

7

                                   ;          (Pause) 8                     ; JUDGE BLOCH:         .Before you continue:          what's the     ,

system going through your mind? You're actually remembering i E 30 instances in which these particular'suoervisors told you 33 this? , 12 THE WITNESS: (Nodding affirmatively.) ' 13 JUDGE BLOCH: Okay.

                             ~

3d THE WITNESS: There was a guy named l C ' le i 17 (memummut There were oth'er foremens, like, I was loaned out is j to them, like, one day at a time, I can't remember what their l' names were. 20 In other words, the reason for this statement was 21 l the fact that we didn't have time to grind out the carent 22 metal to get the line bought-off. And that's the reason why 23 they told me not to do it. (~ 24 BY MR. REYNOLDS: Q Yuh, I'm not talking about time. I'm tialking about t a e G

                     . .. . .            .     ;- ~            - -   .        ..  .
              ~
               *
  • 10839 9-14 f :-
 'o      -                    I    who told you?

2 A Okay. 3 ' The people that I just said are people that I d can just off the top of my head name. But there are others . 5 that I can't think what their names are. 6 Q What is wrong with that repair procedure? 7 JUDGE BLOCH: Well, befpre--I'd like to ask: a The first foreman you worked for told you that; A E'

                               '    right?

10 THE WITNESS: Yes, sir. .

                              '                     JUDGE BLOCH:     Now, what would the occasion have 12    been, since you already knew that was what was expected, 'for 33     other foremen to tell you the same thing?

Id THE WITNESS: The same instance to where I was is put on a hanger to do a repair weld, and I came up to.them

                                   and said, "where do you want me to grind the parent metal
                               'I    back out,"--which,       I, myself, I don't agree that th'at would i
                               '8    be an acceptable way to rectify the fact that the parent I'
                                   , metal had been, you know, had had damage done to the parent 20 metal.

I But it's, like, apparently accepted out at Brown & Root as the way to repair is to grind the weld material out, completely out, back down to parent metal; and then 24 reweld it.

                                     ~

25 So that when I'd go to ask my foreman, you kn6w,

_, ,m...... . . . . . . _ . _ - . ~ . . _ _ .._ .

       > 9-15    '

I i/ '

       '                       I   do you--is that what you want me' to do, is to goudge all that 2    outuback down to carent metal and reweld?
                                            ~                           ~

3 They'd say, "we don't have no time, just whatever j 4 you have to do to it to where it's accepted by visual." 5 BY MR. REYNOLDS: 6 Q What is wrong with that repair procedure?

 ,                            7           A        What is wrong with it?

I - a Because any damage done to the parent metal from 9 excessive heat input would not be repaired in. the parent ' e i4 10 metal. 4 { 11 'O But you just said that your appropriate repair

 ,                          12    would be to grind out all the weld?                              '

13 A No. My--would you rephrase that? 14 i If you want to know what my--what I think should j 15 be done: the whole hanger should be cut down, and a new j 16 one reconstructed. 4 37 Q I believe you just testified that your recommended 18 approach would be to grind out the weld?--comoletely? 1 19 A No, that was-- 20 JUDGE BLOCH: That was not his testimony, 21 Mr. Reynolds. 1 22 BY MR. REYNOLDS: 23 Q So the real concern here is to repair the damage 24 to the parent metal that you.say would occur due to excessive

;                           25   heat input?

a 1 8 4 i l .. . .

9-16 'f c2, 10841 I A . Correct. 2 And what damage would that be? Q A' 3 ' The damage being if you rose above the temperature d I can't put it off the top of that would cause the damage. j 5 my head. And that being embrittlement, embrittlement of the t ' 6 parent metal. 7 Q Ydu mean that the excessive heat causes the 8 embrittlement? ,

                                   'A         Yes, sir.                                      '
                                                                                                  .         ?-

30 Q I thought it was the cooling-down that caused

                       "     the embrittlement?               ,

12 g The excessive heat is what alters the cooling' t 13 rate, you see.

                                                                                              ~

Q But I thought you didnt have a problem with is embrittlement if the cooling rate was proper? 16 g You don't. But when you reweld over four-core

                       '7 wire diameters, then you do.

18 JUDGE BLOCH: is this'the only you , are worried about: the heat?. Is it the heat from the reweld, l 20 and that's the only thing you're worried about? 21 THE WITNESS: No, sir, I am concerned with 22 ' entrapped slag, and to the technique used;'there's many , 23 things. That's what I was saying:

                      -24 In our previously filed testimony it'was in 25 question-and-answer form.                         [didn'thavetheability

[' l

9-17 10842 f 0 1 to read my mind to know what questions to ask me, you see. 2 So, therefore, it left out so much substance to my testimony 3 that, that's the reason why I tried to come back to clarify 4 to the Board with. additional affidavits, what--that that was , 5 just left out due to the process of us being required to put  : 6 it in question-and-answer form'. 7 There are many problems that I'm concernad '?ith 1 4 a to damage to the parent metal, not just the weave welding 9 itself; but the weave welding in connecti6n with not controll? ' l i 10 ing the heat input, not preheating, and not cleaning your 11 welds. They are all in cotaection.

12 JUDGE BLOCH
Okay. I think we have enough and
13 beyond.

ENDT17 14 j JRB:jrb l MS f1s 15 ! 16 , 17 l 18 l 19 , 20 t L 21 4 l 22 L 23 24 > 25 l { o'r (i i (

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10843

 *Sio 10~1  -

1 JUbCE BLOCH: Okay. I think we have now gone 4 4 2 beyond. .

      .-                  3                      BY MR.' REYNOLDS:

4 'O But, , it is correct, isn't it, that 5 your concern with damage to base metal is a function of

                                                        .             \

6 heat input only?,  ! 7 A Correct.

       ~
              .           8                 Q                  on;page 14 at lines 15 through 18, 9          do you have any firsthand knowledge about'the ASME recertifi-t              E 10 cation of Brown and Root?

11 A po 1 have any firsthand knowledge about it? 12 Q Yes. 13 A Other than reading the report itself, that is the 14 firsthand knowledge I have about it. 15 Q What report? l 16 Exhibit 590,

                                           .A
17 Q Whose exhibit, CASE's?

I 18 3 CASE Exhibit 590. 19 MR. REYNOLDS: 'Mr. Chairman, I move to strike i 20 this testimony. The document will speak for itself. He 21 has no firsthand knowle<!ge of this AS.ME survey.. Using wdrds 22

                                    .such as "my understanding" and "I believe" clearly imparts 23 no personal knowledge.                                         ..

4- MRs BAGER: He is simply designating where he s 25 got his understanding from. e

Sim"10-2 , 1 JUDGE BLOCH: I am sorry, Mr. Hager? Y 2 MR. HAGER: It is simply a reference to material 3 that he has read. 4 JUDGE.BLOCH: Is that responsive to the question 5 that he has no personal knowledge? 6 MR. HAGER: Well, he has personal knowledge of

                        ?  the report it;self.                 I mean he l's not purporting here to have
                       .8  any more personal knowledge than that.                          I think that is 8  a statement that doesn't need to be struck.                                                 .E 10                   JUDGE BLOCH:                The sentence may be struck because 11 it has no probative value.                        On the.other hand, I am not s

12 sure why the applicants care to have it struck. It is 13 struck. 14 BY MR. REYNOLDS: 15 Q On page 15, line 7 you state that one of the 16 hangers you told Mr. Driscoll about. Can you identify that 17 hanger specific' ally? 18 A Let me read what this is in reference to. 19 (Pause.)

                     "                     JUDGE BLOCH:                 The hanger you were ' fired for.

THE WITNESS: Oh. Yes, I can. JUDGE BLOCH: Can you do that for the record? TPE WITNESS: To identify the hanger?

                                                         ~

g JUDGE BLOCH: Do you actually know the number'? s. THE WITNESS: Let me look through some of my i 1

                      . -_ . . . . . .                      __. _ _                            .     - . . . mm                         . - _ .                          . . . _ . . . . . _                  ..
              ',                                                                                                                                                       .                     10845 Sim 10-3                  1       material here.                                   It is written down.
       /

8 2 (Pause .') 3 I believe that was hanger H-CC-1-SB-038-010-3, 4 and I get my reference from CASE Exhibit 666-C,.page 37 5 which is the sanitized notes provided by the NRQ where I i , e give them a diagram about the two-inch limited space. i 7 MR., RAGER: That is also referenced in the 8 September testimony I am told. , 8 , (Pause.) ,

                                                                                                                                                               .                                               E 10                                 JUDGE BLOCH:                              Mr. Reynolds,.'would,a break help 11        you to go faster'?

12 MR. REYNOLDS: (Nodding negatively.) 13 Mr. Chairman, we would like to move to strike I4 the testimony on page 15, lines 13 through 24 because they 15 raise a new issue not raised before in this proceeding. The 16 witness has testified with regard to downhill welding about 17 limited access, but this goes beyond the scope of just i 18 downhill welding. I am really focusing on lines 20 through U 24. JUDGE BLOCH: Lines 20 through 24? 21 MR. REYNOLDS: Yes. Strike 13 through 19 from 22 my motion. Strike it from my motion. MRS. ELLIS: What? gr MR. REYNOLDS: Strike lines 13 through 19 from 25 my motion, and I now ask you to strike from the record lines

C 1 - BY MR. REYNOLDS: 2 O It i's your testimony that no foreman of yours 3 ever told you to transverse oscillate? d A I can't say that -- 5 MR. HAGER: I think he's already asked - 'that 6 question'has been asked and answered more than one time. 7 MR. REYNOLDS: I don't know what the answer is. 8 JUDGE BLOCH: I think it's legitimate.to ask 9 the witness to think again abouf. it. He'.s giving him an 10 opportunity to think about it. . 11 THE WITNESS: Let me clarify that. I testified 12 on one occasion where I had been instructed by to weave weld, and that was where he beat the flux d f

                                                                                                 ~

13 14 the electrode and hold it into the -- due to a bad fit -up, 15 and weave the electrode over the bare electrode.- So.I 16 guess really the answer would be yes, I have been instructed 17 by a foreman to weave weld. If that's what you're getting ( 18 at. l 19 JUDGE BLOCH: When you use weave weld there,

                                                                                           ~
           .20   you are? not talking about more than four core diameters, 21   though, are you?

22 VOICE: Yes, he is. i i f 23 j , JUDGE BLOCH: You are? You were specifically 24 told lin'that instance you should do it more than four core 25 wire diameters?.

 ~.                                      t                     .

F0lA-85-59 a I. . M 7) '

   .   .   .crl4-13                                                       10899 3

[- . F.. i (

  • 1 THE WITNESS: As a matter of fact, he even took 1

2 the welding rod and beat the flux off of one of them and I 3 'showed me what he was talking about. If we hadn't done it I d that way, they would have had to stop working on the hanger 5 and would have had to cut the hanger down to refit it. l 6 JUDGE BLOCH: I understand that you have to 7 oscillate to put that extra material up there, once you

                                                            =

e beat the flux off. ,I don't understand why you have to do l i '

                   '    it more than four core wire diameters.      '

10 THE WITNESS: That comes'When you're trying to Il put more filler material in it to get it welded out. a 12 JUDGE BLOCH: It's not possible to do less f > 13 than four core wire diameters and use that technique? 14 THE WITNESS: I'm not going to -- being as you 15 used the word it's not possible -- _ 16 JUDGE BLOCH: It's not practical, it's not l 17 feasible, you couldn't do it that way? 18 THE WITNESS: Well, you might could. I -- I 19 don't think I could. l 20 JUDGE BLOCH: You couldn't? l 21 THE WITNESS: l No. 22 BY MR. REYNOLDS: 23 So Mr. Coman was the only foreman t' hat told you Q j 24 to do excessive weave welding? 25 A Yes. That just came right out and showed me how s b b

E u# ** ( arl4-14 1 . r 3 to do it, yes. 2 JUDGE BLOCH: And none of: the other foremen told 3 you to- do less than four core diameter, but that it was d okay to do it that way? 5 THE WITNESS: I don't understand. 6 JUDGE BLOCH: Did any of the other foremen -- 7 think carefully now -- tell you that you could oscillate, 8 but less than four , core wire diameters? l 9 THE WITNESS: No, they never told me one way or 30 the other that you could do it less than four core wire Il diameters. It wa's always my understanding that the 12 weld procedure gave the requirements for the -- . 33 JUDGE BLOCH: We're not talking about the 3d procedure. We're talking about what the foreman told you. 15 THE WITNESS: The foreman never told me one 16 way or the other, except for 17 BY MR. REYNOLDS: 18 Q On) ll h you state that one instance where I l' mentioned in my testimony -- this is line 3 -- one instance ' 20 where I mentioned in my testimony about the welder 21 Where is that in your testimony? Can you help 22 me witl that? 23 JUDGE BLOCH: kr.Reynolds,wouldyouobject , 24 if Ms. Ellis finds it first? 25 MR. REYNOLDS: No. We can move on if she wants

*e I

e e

jrb 10902 flCAR
    .   ?
  • dr
 ,        4                    1 BY MR. REYNOLDS:

l 2 Q Can you tell us in regard to your statement on l l 3 line 6, what is the location of this particular hanger? 4 A I have a problem with giving these--giving 5 Applicants all these locations as to--and one being is that 6 there's still to be an on-site visit, the way I understand 7 it. 8 Now, I've already given too much-- 9 JUDGE BLOCH: One second: ' 10 My understanding is that there is not to be an

  • 11 on-site visit.

12 MS. ELLIS: Mr. Chairman, I think that the re' cord 13 should reflect that we have decided not to proceed as the 14 Board has suggested as.a discovery matter; because we're is concerned about the cost and so forth. - 16 We are also concerned about the fact that it might 17 be necessary to do destructive examination in order to prove 18 some of these points. l' I don't know that that would be the case, but we 20 certainly didn't want to preclude it. I 21 We did not want to go to the plant and point out a 22

 ,                               location and not be able to do whatever examination was 23 necessary, having pointed it out to the Applicants, so they 24
  ;                              could come along and correct it.

25 j The other. option which we had which we had sought i s ..

6-2 -- ge 7' 3 I to pursue was to go with Mr. Collins, with NRC Region IV 2 office. We had discussed this with him, had even talked

                                                      ~

3 about oossible tentative dates. d There have been developments then which have 5 led us to the point where we do not feel comfortable dealing

  • 6 with Region IV. We still plan to pursue this with the NRC 7 at the natidnal level.

8 And we don't want to have to reveal any specific 9 locations at this point, until'we do thata. 10 MR. REYNOLDS: Then I suggest that this entire

        ~

3' line of testimony be stricken. 12 We cannot respond to testimony where we're kept 33 in the dark as to the specifics. Id JUDGE BLOCH: Could you please summarize to me , l- ' 15 what the testimony is about, Mr. Reynolds? 16 MR. REYNOLDS: Yes. 37 It's about a hanger on which is welded, and tha was later brought in to weld [ l' on; which M believes was an illegal hanger and 20 an unsafe hanger.

  ';               21                                         We don't know where it is.                We don't know'.the 22                   identification of the hanger,                                                 .

23 So we can't respond to the line of.testimdny. f 24 MR. HAGER: Of. course, that doesn't affect the 25 . relevance of the testimony. .And we would be willing to allow q L-

                                                                                                                        .                     v*
      .                                                                                                                              *        *e e
           *crl4-15                                                            10901 f

6 1 to look and then we'll come back to it. 2 Shall we move on? JUDGE BLOCH: 3 . I take it this is something on 4 which you're legitimately in the dark? 5 MR. REYNOLDS: Yes. Yes. 6 MS. ELLIS: On transcript page 4213, beginning 7 with line 18. snd 14 8 9 . to

                               ~

11 12 13 14 15 _. 16 17 18 19 20 21 22 23 24

                                                                                      ~

25 4r i i l l t

qG

 '.i.

sim 16-10 1 BY MR. REYNOLDS:

  • Q on.10591, line 9, who is the foreman 3

to whom you refer? 4 A What.line? 5 Q Line 9. - 6 A , At that particular time they had three different i 7 foremen down there. I can't recall exactly which one was 8 the particular one that was there at that time. i 8 JUDGE BLOCH: What does the word "down" mean in 10 that sentence? Does it mean anything, "I was sont down"? 11 THE WITNESS: Just sent to the area. JUDGE BLOCH: To the area from some distant ar'ea? 13 THE WITNESS: Well, I worked in the immediate I' area, but around the corner from where this particular spot { 15 is. That is just a term that I use. 16

    .                                     JUDGE BLOCH:   What was the reason you v.ce sent L                         17
to-do that by the foreman?

l 18 THE WITNESS: Because it was in the middle of a 19 hallway and they was afraid that QC would come by and $ catch,this problem and write an NCR on it. I 1 21 JUDGE BLOCH: You mean from the distance that you 22 I' and the foreman were standing you could tell from there r that the practices were wrong?

  \                      24 e'                                THE WITNESS:   He came and got me.and I went down
 ,, (.

25 to where he was welding at a e r ill in 1 s . i

                            ~-           .

C 10925 ys 16-11 g the process.of making his welds when I observed him doing f 2 this. 3 JUDGE BLOCH: So the foreman saw him first and 4 t' hen ca'me to you? 5 THE WITNESS: And got me and, like I said, that, 6 was part of my job was to get these inexperienced welders

                                                 ~

7 lined out to where they got used to what they were doing. 3 He caxa to me and told me to go down there and tell 9 to get off of the hanger and go 'do somethi,ng else. Actually 10 I finished the cleanup on it and f.inished capping it and 11 everything. 12 JUDGE BLOCH: How frequently were your foremen

  • 13 changeht?

14 THE WITNESS: Just off $nd on all the time. That ! 15 was one of the problems. Like I can't remember his name, l 16 but they would take people from th'e carpentry department f which knew very little about the hanger department and put 17 l 18 them in charge of all of us. That is why they had so many 19 problems down is putting unqualified foremen in the position 20 to finish the lines out. ? 21 JUDGE BLOCH: Is that the first time you talked ) i 22 about using carpentry forem,en in a welding shop? 23 THE WITNESS: ' Yes, sir. . 24 JUDGE BLOCH: There is no new issue that that 25' is related to. l 1

  • a

s . .

                                                                  ..                         7 C--                    4086 BY WITNESS                                                                          -

d 2 A No, sir, in my opinion it's not controlled. 3 4 What do you mean by a " controlled substance"? Q 4 BY WITNESS

            . 5                   A              Well, it's supposed to only be in the hands b

l 6 of the QC personnel. No one else is supposed to have it 7 at all. . , X g 8 4 Now throughout your testimony you're referred 9 to weave welding -- no, weave -- 10 BY WITNESS  : g 11 A Weaver beading. Yes, sir. 3 d 12 4 could you describe to me the difference ~ z 13 between weave beading and other kinds of welding? . l 14 BY WITNESS , 2 15 A Yes, sir. I have a sample here, if you would i n* - g a 16 like to look at l't; and it will show you. It will sort

           @   17        of help, if you'd like to see it.

, I l  % 18 . G Yes, I would. But I'd like for you to try to i E i 19 put it into words for the record, too. i l $ ' j 20 BY WITNESS - 21 A okay. A weaved bead is a. bead that has been g 22 made using transverse os'cillation. I 23 t 1 i O That's moving back and forth -- g- 24 BY WITNESS . i 25 A i t Yes, sir, that's correct.  !' ALDER' SON REPORTIN T. ""

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g 4087 y I didn't do that. 7;:::,21 () 2 A stringer bead is a bead made using no 3 transverse oscillation. h 4 G Okay. Strictly upon the length of the weld? 5 BY WITNESS j 6 A - Ye s , sir. In a vertical or a horizontal, 7 or whatever the case might be, manner. e7 8 8 4 And a weave weld goes perpendicular to the d d 9 long axis of the weld? 10 BY. WITNESS C

               .g         11                 .        A             Well, say, just for example, making a verti-it y        12          cal weld, well, there would still be --                                         Now, I'm giving j             13          you an example.                           Say, they were making an uphill verti-l       14          cal weld.

l a: 15 A weave bead would be one using transverse . f as 16 oscillation, like you were showing. It would still be g 17 g going uphill, but it would be using a lot more stops and

               $         18

_ starts, a lot more metal, because you would be going so E g es 19 wide that each time you would be cutting in the base l 20 metal. 21 l O okay. 22 pg __ _ 23

     ,                24 25 ALDERSON REPORTING COMPANY. INC.

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4088

      -1 m. .                  1        BY JUDGE COLE:

d' 2 g I believe I understand that. - g

3 BYWITNESS[  :

4 A. Okay. r  != 5 l 0 What is bad about doing it that way? 7c, 5 6 BY, WITNESS H, 7 A 'Well, the stops and starts would be one thing , X . g 8. that I would think woul,d be a real had factor. d d 9 z In a stiinger bead, the width of the head and w 10

                      ~

the way it is. welded is you would,get more length as far II

  • as your weld.
                  ,g         12                                                   '

gay if you were, going to put in, just for

                .,9 13 g                 example, a quarter-inch weld, you would,get                                                                                 -- or a l

14 three-eighths, whatever the case might be, you would, get

                                                                                                                                                                         ~

15

                      $                 more length per bead out of a stringer bead than you would u

y 16 a weave bead. o . g 17 n G Is this the reason why you have more stops e: *

                      $      18 and starts; you'd need to put in more welding rods?

E g BY WITNESS 'IC 20 A Yes, sir. You keep . washing it back and forth 21 in this oscillating manner and you' d use more rods . h 22 So, therefore, you'd have to start. 23

            ,                                       G               Okay.        I's there any particular problem U-                 24 associated with stopping and starting with respect to the l                        25 integrity ~of the weld?

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4089 _, 1 BY WITNESS

        \

2 A I just feel like it would be the more weaker 3 part of the weld. , 4 G I've' heard it said many times from different I '

              =       5      people -- and I don't mean to testify here, but I'm
 !            5 l              l       6      trying to,get information - .that in a well-done weld, 7      that strongest' part of the' structure would be at the 2

g 8 weld. I've heard that said many times, and you select d d 9 weld rod material that generally would result in a product A h 10 that is at least as strong as the base metal into which 3 .

j 11 you 're a welding or to which you are connecting. ,

t2 , ( 12 If that -is the case, what is the significance fQi)l 5j-13 of weave welding versus other kinds of welding from a u l

               $i 14       structural viewpoint, from the strength of the material?

IC l u 15 SY WITNESS 10 At the points where you ,have your s tops and dat j 17 starts, your weld, I feel like, would be weaker, of the h 1 18 weld itself now, at those points; and at that point, if E I9 you were going to,get porosity or you had any problems g E

with your weld, that is where you would,get it mos t- likely.

21 Now I'm not saying there would be no cases j where you would,get any problems, but you would have more 1

    -                23       porosity and such as that in the stop and start of the f

f b weld, cracks and such as'that. 25 g And if a properly conducted penetrant tes t ALDERSON REPORTING COMPANY. INC.

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D A 00 Qc . l I was conducted, that would answer it; would that be 2 correct? 3 BY WITNESS ,

    @             4               A     Defects that would be open to the surface,
  • 5 yes, sir, unless;it had. trapped something inside the i E -
          ]       6      weld, some slag or something of that nature.

R 8, 7 If it's not open to the surface, it wouldn ' t l X g 8 pick it up, n o'. ' d d 9 0 Okay. 2 i I have this exhibit in front of me. h 10 What can you tell me about this metal plate to which z_ 11 two critical plates are attached?

                                                                                                        ,     g f      12      BY WITNESS 13               A     Okay. In                                       he'll go ~7C.-
         $       14 more into that, but I can tell you, on one si'de, on your 15 left side, I believe -- ri.glit.                           made that weld, y 16            and on the other side, the one that's all junked up.                             I e                                                                                                    ,

I7 h can't see from here, but anyway - , _ b 18 -

         -                        G     Yes, it does appear to be more crudely made.

E 8 at BY WITNESS MRS. STINER: 20 A Right. There.was a pipe welder from Comanche 21 Peak made that weld, and it is in an oscillating fashion. Part of it is, yes, sir. 23 p . 0 And what is .the problem with that l weld, other 24 than it's lumpy experience?

                         //

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c-4091 1C 2 3 _, 1 BYWITNESS( lh 2 A. It's an oscillated -- you can see by the l 3 f ace that. the os cillating pattern.  ! 4 0 Yes. g 5 BY WITNESSI

                  ?
                  ]         6              A. You would have co-lap, undercut.                                                         In that R

f

                  &         7 particular one, you have a little bit of both, but you X
                  ]         8 have a lot of co-lap in that one, and then you would d

d 9 z

                    ,              have definitely undercut, I would think.

10 g ve never seen one in the time I've been

                  ~
                  =

II

                  %                inspecting where you have not had undercut where it was ts
y 12 on a support, becaus'e when it's oscillated back and forth, I

13 s 5M it's going to cut into the base metal when they wash l h 14 their rod to..the side and oscillate it from side to side'. r g 15 u When they sc: to the side where their base 16 mer.a1 connects, it will cut into the base metal; and, w d 17 therefore, they would get undercut. l i 4 b 18 G Okay. I guess my -- I'm trying to make sure E 19

                $                  that there's some significance, other than aes thetics and 20 the use of weld rod material that might be expensive, and 21 it may even take you longer to make a weave bead than a 0                    22 vertical bead.                                                                                                          ,

23: What are the differences from a structural A"'*. U viewpoint'on the strength of the weld itself? 25

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  ; .t' 2              A. At-the points designated as the stop and 3       start where your porosity or your:.--: andrat the.2edgetof
,                       4       the base metal, at the toe of your weld.where         f       you would i
'                =      5      'get undercutting, these parts would tend [ to be weak.

3 I l 2 6

  • They could possibly break op;en, cause cracks, 6, 7 and I feel lik'e that if welds of this nature were under X

g 8 stress, if the're was any porosity at all, say if a d . j 'I 9 penetrant test had not been done, there was some slag z 10 trapped under,where it would not be open to the surface, l

;                =                                                                                                       1' II g                5              if it had any sort of seismic movement at all, it could
;                D

{ 12 break open and, therefore, ruin th'e whole weld, maybe the 8

'6's
,                g 13        whole support.

H 14

!                                      a      res,.I understana.

11 D 15 BY WITNESS 7O E I0 A. Yes, sir. a - I7 g This accident that you referred to on Page h m

                 $i   18    -

53 and 54, this was an electrical short-circuit problem a g 19 g that burned out some metal?

               .                BY WITNESS                    _

C I 21 j A. I'm not really sure exactly what the problem 22 Os

  • at the time it happened was. 'I was doing an inspection on J 23 860 level of Reactor 1,.and I looked up. I climbed down

] , 24 ) g from the scaffold just about the time enough to look up 1 25

                            . ,and see a cable, a lead' cable, a welding cable is what ALDERSON REPORTING COMPANY,INC.
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v B A. Yes. CASE Exhibit 666C contains the " sanitized" notes which , Mr. Driskill took during his investigation which resulted in NRC I & E

#n              Report 81-12.           Case Exhibit.666D is an' analysis of these notes and of the infonnation contained in the report itself.                                  I believe this analysis I

was prepared by Mrs. Ellis, the CASE representative. Q. Which of the allegations containhdain'I & E Report t:1-12 did you provide supporting or additional evidence for? A. I gave the NRC investigators a lot of infomation. I told them about the misuse of torque seal, improper hilti bolt torquing, welding practices that were not al. lowed under procedure, lack of control over weld D

              ' rods and other weld filler material, and other areas which were not even                                    .
                                                                                                     ~

2 documented in the investigation. ' #

 ..n                            ..

4 Q. Let's take them one by one as they pertain to the allegations in 4 the I & E Report. Allegation il states, " Numerous pipe supports were 5 fabricated utilizing weave welds which are prohibited by procedure." Did 3 you support this allegation? f A. Yes. - Q. Please elaborate on the details of the infonnation which you pro-h vided to the NRC investigators, as well as any further infomation which h you may have concerning this practice. A. First of all, let me say that weave weldin is no allowed at CPSES. When I was in welding training school, 7C, y instructor, g w told me that welding in a weaving motion is not allowed. And'at the time I was practicing welding vertical he infomed me that my weld was looking real

 ,           good but I couldn't do it that way, for me' to ~ hold my rod still because weaving i.

l

  • F0iA-85-59 gg

4148 I h . 1 or oscillation was not allowed. As a QC inspector, I was aware of the fact that weave welding was not 2(f 3-) allowed because of my welding training. 'It also stated in CPM 6.9 Appendix 4 D that bead width over 4 cord wire diameters wide is not allowed. Depending 5 on the size of the weld you are using, if you are using 1/8" rod, that's 1/2", 6 in other words, four times.whatever size rod you're using is the maximum bead 7 width. allowed. I 8 Q. Has anyone ever told you that weave welding was allowed? g A. Nobody ever really told Ne that it was allowed, but after I finished 10 my training in WQTC, I was.sent out to train to weld on an I-beam at a 450 11 angle. I was told on this I-beam to put a stringer bead all the way around . 12 it and then put a 5/16" weave weld'on the top with one pass. I welded up one 13 sample, set it all up, tacked it up, and started welding on it by making one 14 pass around it and welding up one side with two stringer beads. The Instruc-015 tor came in and looked at and told me that I needed to do it in one pass, to I 16 weld it in - to oscillate my rod and do it in one pass. This was weave wel-17 ding. He didn't actually tell me to weave it, but to oscillate it. In- '

        '18                             BF mind, these are the same things.

19 The weave welds which we told the NRC investigators about were not on

  !      20                              I-beams, they were on tube steel, which was not supposed to have weave weld-21                              ing on it.

22 Q. Did you relate specific instances of weave welding to the NRC 2M investigators? O 24 A. Yes. I told them specifically about Hanger # TWX-039714A35R on the 25 elevation 790 in the Auxilary Building. O .

                                      .                                                                                           -\
               ~

41.49 4c I 1 Q. Please provide details about this incident. A. On March 26,1981. I inspected the hanger referenced above for torquing. Upon.this initial inspection, I noted there were weave welds on 4 the hanger. I did not do anything about it at first. Later, when ! returned i for final inspection of the torquing, I again noted the weave welds, I noted 5

6 these defects in my personal log book as. seen on Attachment 0 to this testi-
 '. 7                many. The welder who was welding on the hanger at the time, Armond (sp?), was 8            instructed by me to stop work on it.              I noted that the welds were weaved in 9            a weave pattern and triat this ex(eeded the limits that the procedure allowed.

. 10 I crawled down from where.I was inspecting the pipe hanger and went down the 11 hall. There I saw a superintendant named and took him to see - l 12 the welds in question. He saw them himself. I asked him what should be done to correc't" ft and he told me to have them cut it down. I told them to do so j 14 and the foreman told me that the crew would do so. 15 A few days later I was called back to finally. inspect th'e same hanger. 16 and found that the welds' faces had been ground off. Therefore, I could not 17 see the weave-pattern face. I applied a hold tag and got an NCR number from 18 the NCR coordinator and told my superintendant Harry Williams what had been ! 19 done. The craft then ir.fonned their supervision that an NCR was being written. t 20 Their supervisor and my superintendant and myself met at the hanger. I showed 21 the welds to my supervisor and told him that and I had 7C 22 personally witnessed the weave welds,te' .; ...A. At that time, their super-visor and their craft foreman both informed my superintendant that the welds 24 that were weaved had been cut out.and re-welded. I asked the foreman if the welds had been cut down to bare metal and he replied that they had been. . 2@5 . i 1 .

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1 Q. In order to adequately repair .the weave welds, is it necessary t'o 2 cut them down to bare metal? h A. . If you want to be sure that a . weld is done according to procedure, 4 yes. You have to grind down 150 the bare metal and put a whole new weld in. 5 It should be done with stringer beads. 6 Q. What did you do next? 7 A. ' I turned in the hanger package to the weld filler material log. (WFML). 8 The log showed that the rods issued on the day for this hanger totalled 18 (for 9 the days which the welds would have been repaired). This particular support 10 was 8" tube steel that required flare-beveled welds on a large part of the jj supports. Absolutely in no way, based on my experience as both a welder and , 12 an inspector could these welds haye been re-welded if they had been cut down . h to bare metal with that number of rods. I brought this to my superintendant's 14 attention and he informed me that I would have to buy this support off, that 15 is, I would have to sign it off as having been properly repaired. Since I 16 could not see if the welds were still weaved as the faces had been ground off, 17 I asked him to call for a radiographic test. In my opinion, I felt that it .

 . 18             would show the pattern of the internal beads. He told me that the test would jg          not do that and that he would not allow me to have it done.

20 Q. Before you obtained the NCR number for this hanger, did you put a 21 hold tag on it or just verbally order the work to be stopped? 22 A. In accordance with the procedure for issuance of an NCR, 2 I applied a hold tag prior to obtaining the NCR number from the NCR 2f coordinator. 25 - m

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                                                                                                                          ~4151 NO Qi 1                       Q.      After                                nstructed you to buy off this hanger, did you      7 C.

2 do so? - A. I told him that I did not feel comfortable about the situation, nor l. !4 did I feel that either the foreman or the general foreman were telling the 5 truth about the welds. - I did not think that they had been ground down to 6 the bare metal. The foreman was nd the general foreman wasb 7 C-7 I told

                                                                           )that since he felt comfortable and satisfied        7C 1

8 with the repair, that he should sign it off. He told me that it was not his I - ,9 job to sign off on completed repairs; it was mine. This was a very frustra- .10 ting situation for me as an inspector. On April 8, after the repairs had been 11 completed on the weave welds, I went back to the hanger and wrote it up for . 12 base metal defects because I knew that someone would s'ign off on the weave , Th l welds. I don't believe that I ever signed off on this hanger, I assume someone 14 else did. Attachment P to this testimony shows a portion of my log book from 15 April 8,1981, where I inspected the hanger and noted base metal defects. 16 Q. What, in your opinion, is the safety significance of the use of 17 weave welds? - 18 A. I am not technically able to tell you what the exact metallurgy situa-19 tion would be as far as breaking down or making the metal stronger or weaker, but i

  ,20               my personal opinion would be that it would make the weld weaker because you're 11                washing a larger area and you're cutting into the base metal every time
  !2                you cut.into each side. And that weakens it and you're also not supposed to i
  !                 cut into the, base metal.                   I don't understand how you cou'1d keep from cutting
 . !4'              into your base metal because you're washing from side to' side.
                                                                      ,sle        s~ 4 5                     A weave weld takes more                    r-' t s'   -' '~  ^"e sMA yoaa   , d 1 L my personal b

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4152 l 'O 1 opinion is that a start. and stop is the weakest part of the weld. Weave welds i 2 have been used at Comanche Peak on both Q and non-Q components. Class 5 hang-ers are not Q but are in safety related' areas, so if the thing came apart and 4 a piece of hanger pulled off, it could damage a, critical pump or critical tank 5 or something of that nature. I did tell the NRC investigators that I felt. 6 it had safety significance, but I don't tiiink I went into that much detail. 7 The other significant aspect of weave welds is that there are no QC hold

,        8                      points on the repair of these welds. Once the face of the weld has been ground g

off and recapped, there is no wa$ that an inspector can tell if the weld has i 10 been repaired by gouging .it down to the bare metal. 11 Q. You stated that you related the instance of weave welding at the . 12 790 elevation to the NRC investigators. If you look'on page 7 of I & E Report ' n. 1 b 81-12, the first paragraph, you will see that it refers to an interview with 14 individiJal B. To the best of your recollection, does the information contained 15 in this paragraph accurately reflect what you told the NRC about the weave 16 welds? l

17 A. No. I in no way stated that the weave weld "was. subsequently
  • ground
  • l l
  • 18 out and correctly rewelded when the appropriate supervisors were notified."

Ig My statement concerning this one instance was that I had broughtit to the at-l 20 tention of the supervisors and that I was told to buy it off. I also told them 21 that I had checked the rod issue and only about 15'or 18 rods were drawn for k 22 this hanger, making it impossible for the welds to have been reweided completely. l 23, Q. Does CASE Exhibit 6660-8 contain the segments of Mr. Driskill's notes I b 24 which apply to what you said in reference to this allegation? 25., A. Yes. It is quite obvious that Mr. Driskill's own notes do not agree ' D . f"* S'** *f * * . r t.T,*,*:D 4g.v*r m. . .s*;w; .T:.tr wt:'** .n *,*.m"'.*4"*ermwat.Mr='*.= 1* t ata M .** * *. 6 .

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             ~

4153 C l with what the I & E Report says. I did not say that the repairs were done i 2 correctly, I simply- said that '*I couldn't prove it was weave welded.'" That is what I mean when I ray that there are no QC hold points. Once a weld has 4

                                               ~

been ground smooth, you can't tell if it has been weave welded. E I would also like to point out that on CASE Exhibit 666C-16 (Mr. Driskill's 6! notes on my statement on weave w ids), the' top of the page wk.ich sa s 7 8

                                               "(      my extension number in my offic6. The time when I could be reached there was 11:30 until 12:00.                      If the NRC is so concerned 9         about confidentiality in it's " sanitized" documents. I sure can't understand
                                                     ~

10 why they ..culd leave this in clear as day. Il Q. Do you have a. copy of the NCR which you wrote on the weave welds . 12 at 790'? - A. N'o. ,This is the only copy of the NCR's that I have written that 14 I do not have. I never received a copy of this NCR and when I asked about

. 15         it. I was told by my supervisors that there was never anything to my 16         NCR and that it had been voided.            I was told this a long time ago, soon after 17         the weave welds were " repaired".                                                          -

18 Q. Is this the only instance of weave welding that you related to the 19 NRC7 20 A. I believe this is the only instance that I told them about. I did 21 tell them that it was ustd in others but that I did not have the specifics. 22 Mold them about weave welds all over the site; it was a comon practice. I have written one other NCR on weave welds, hcwever, this was after 24 the NRC investigation. On , I wrote an NCR on weave welding in

   '25          the Auxilary Building at the 812' level.                 I have attached this as Attachment e
                                                   ~
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J' . . ! 4154 j

O 1 Q to this testimony.- The disposition on this NCR was "use as is". j 4

12 Q. Allegation- #2 of I & E Report 81-12 (page 5) states, " Holes are . b ] F) drilled in various types of pipe supports, cable tray supports, and plates, 4 and when, on occasion, they are found to have been drilled in the incorrect

5 location the holes are~ filled, utilizing an illegal plug weld." Did you 6 provide the NRC with any information concErning the use of plug welds?

7 . A. Yes. I made the. statement to them that it happens at Comanche Peak 8 all the time, that plug welding is also a connon practice. When I was a wel-g der, I even got so good at making plug welds that I could do it with one rod. 10 They asked me what the safety significance of plug welds were and I told them

11 that the way it would be handled, you would wash it over one side; well, I -

12 told them the details. On the side you're welding on", you've filled the hole, ' but on the other side you'll have slag and coating, etc. Then when you flip 14 it over, tahat you've actually got is a hole about 1/2 full. Then I would take 15 my hammer and chip out all I could chip out.. Then I'd take the other half l16 of the rod and wash it over the other side. With the end result, you couldn't 17, tell just by looking, but you would have all that slag trapped in the middle. * ' ' 18 The safety and quality significance of this is that if the plug tempered lg with the base metal, it could create a weak spot. Consequently, the weld it-l 20 self would break. These supports were designated to be installed in several 4 l 21 areas of the plant. As a welder, I was instructed on numerous occasions i ' 22 to plug weld holes on Q hangers without a QC inspector being present. Again,

2h it is the same problem as with the weave welds. There are no QC hold points

. c{g 24 during the welding process. Once this welding process is complete, there is no 25 sure way to tell what the quality of the weld itself is. e . l y ,1 =3 +.7. ***/ s., r* ;.

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4210

     ~1'                                       Q.      Are the statements contained in your 9/8/81 statement true and correct?

2 A. Yes, they seem to be as far as I can tell from the " sanitized" copy

     )                       of the statement.                         I'm not sure that it's clear from the statement what I 4                   meant about the hole in the floor. I can't read some portions of the statement

, 5 because they've been blacked out. My primary concern is that many of the 6 allegations made by me and b Darlehare not even contained in it. 7 Q. Please tell us specific details about your concerns with the I&E l 8 . Report (gl-1,2, 2 Staff Exhibit 178). Please refer to CASE Exhibit 6660 page 9 numtners so it will be easier to follow. 10 A. On CASE Exhibit 6660-2 under " Areas Investigated," not all of the 11 allegations are listed. 12 Q. All right. Let's save.those until last and go through each allega- . D MJ tion first. 14 A. On CASE Exhibit 666D-6, under Item 2, " Investigation of Allegation, 15 Allegation No.1," it states " Numerous pipe supports were fabricated utilizing 16 weave welds which are prohibited by pmcedure." There is one item referred l i 17 to in the " sanitized" notes which should be clarified. Where it stated that t . 18 " Weave welding violate the C-101 A-10 welding procedures, as I know it," 19 C-10 and A-10 are actually codes for a welding process. The welding procedures l 20 for the C-10 and A-10 welding process codes are Meet.,11065, and 10046. I basA I 21 The precedure that states that weavywelding is not to be used is CPM-6.9j //e 3.2.j

                                       //86 ( 3 6A i s e # fe
  • 22 This is also indicated on the Weld Parameter Guides issued from the rod shack 23 to each welder when material is picked up; if you go over the maximum bead b width, you'd be weave welding. Or s IF Se- *S* b5* *nt o Seil ' ~ a Y' "' b

we ming g eh.ha. L- o s *. w e s. b e.J. . 25 Q. Who gave you your instructions about weave welding? m V , F0lA-85-59 p 9g- _

h

      '             ~

9_ - 4211 i A. I was told by rqy first welding instructor, hke Adcox)while I was 2 in the welding training center in November of 1979, not to weave weld. g When I was given the CPM-6.9 procedure class, I was instructed by 4 the instructor that weave welding was not allowed on the jobsite; I don't 5 remerrber his name. This was around January 1980 or so. I don't 6 remember the exact time. 7 ) The kecond time I was employed in June of 1981, after I was tested 8 and certified, I was told to practice welding on an I-beam for a while before 9 I worked in the field. (Kenneth Golden) the testing instructor at the Welding 10 Qualification & Testing Center (WQTC), came into my booth and told me that bs4 11 I was running stringer 4 passes on the I-beam and he wanted me to cap it with 12 W a 5/16" weavegpass instead of running a stringer bead. He got mad at me 4 because I told him I didn't think weave welding was allowed on the jobsite.

    %2 14                     He said, that's the way you're going to have to do it because we've been having 15                      trouble wi th ~-beams . So I did it the way he said.

16 This was what I was told during my training. 17 When I was in the field, I was told by red Coleman) my foreman, that 7 C, ! 18 rather than run a bunch of little stringer beads to weave it in to build a . i L 19' floor since it was impossible to run stringer bead root passes because of the i 20 size of the fit-up gap. At that time he also told me that it didn't make any 21 difference what was under the cap -- to just put anything in there that you i 22 could get in there'(which sometimes consisted of breaking the flux off of the 23 rods, dich he showed me how to do, and sticking a welding rod up in there to run over to get your filler material in there) -- because what we can't ! Q 25 see, QC can't see. I was also instructed by him not to let QC see me doing l - h i

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       'I                 any of that.               I knew it was not right, but I did it because he told me directly 2               to do it that way and I was afraid I would get fired if I didn't.

h Q. When was the next time you were told either to or not to weave weld? 4 A. From that point on, to the best of my recollection, I wasn't really 5 told to weave weld. From then on I was instructed to repair weave welds that 6 other welders had made; I was told not to grind all of the base metal out but 7 just to grind off the surface and cap it so it would appear to-be a sound weld. 8 Q. Who told you to do that? , 9 A. Every foreman I ever worked for --(Fred Coleman, Larry Thompson 10 there was another one but I don't remember his name (he was there only a short 11 time), and killy Cartrette these were foremen during my(first employmenh 7O a 12 Comanche Peak. Also hinsny Greef who was my foreman during my(secon employment. 7 c There were a couple of other ones whose crew I was on for just a short time; (.) 14 I don't remember their names. ! 15 Q. Did you ever question any of them about what you were being told to 16 do? I 17 A. Yes. In fact, I asked (Fred Colemah one time what would happen -- y c, ( 18 would I get fired -- if I was caught doing that. He replied, probably not l 19 but don't let them see you doing it; there is a possibility. i 20 Don't let who seeing you doing it? i Q. 2I A. QC. They also said don't let the NRC see you doing anything. j 22 Q. Wh'y did he tell you this? i 23 A. BecauseIaskedhim,look,(Fred I'm greener than all get out right 7C f P d now (this was just after I had been hired (for the first time). I asked him l 25 what if the NRC comes up and asks me about a particular procedure? He said e ~..

       '- )                                                                                        ,

l l

l I d., 4213 0T fust tell them you'll get your fereman and come get me. l l 2 Q. On 6660-6, under " Investigative Findings ," it states " Individual h A stated that numerous examples of weave welds on pipe supports could be i 4 found in the South Yard Tunnel..." Did you identify other areas where weave 5 welds could be found7 , 6 A. Yes, I did. I told them that in the Auxiliary Building, the North 7 Yard Tunnel, the North Pump Room, the Reactor 1 Demineralized Water Tank Room, 8 and c.very place I had ever worked, weave welds, porosity, undercut and overlap 9 could be found . . . unless the. surfaces of the welds were ground off and the 10 welds were capped (as the I&E Report states). 11 Q. Also under " Investigative Findings," is is stated that " Individual 12 A identified three welders whom he believed would corroborate this allega-

g. tion... Individual A identified five additional welders whom he ' stated wre 14 aware of this practice." Do you remember the names of the welders?

15 A. The initial three were hoy McCombs, Al Marcoot) and I believe fFred IC 16 Colunan but I'm not cartain. I don't remember any other names at this time. 7 C, 17 Q. How'did you know about all the weav.e welds? 18 A. Because one particular fellow who was put into the fiel' ,d by the name 19 of(Armond I'm not sure of the spelling), continually made bad welds; I had to 7c

        '20                  follow him around and repair his bad welds. I also heard other welders . con-l I

21 stantly complain about having to work and rework other people's bad welds all 22 the time and put our symbols on them. The South Yard Tunnel was one area where i j 23 I identified a specific hanger. There were also other specific hangers which I identified by the location; they should have been able to follow my directions 25 and find the specific hangers I told them about. (Darleny also offered to take 7C, i 1 G - i 4

              .                                       e' 4 4 8   -

3

                                                                                                  -
  • 0 $ g e me .
                                                   . = .  .            . _ _ _ .      - . -     _.
.m 1 them down' and show them the specific hangers. l
.       2               Q. By "them," to whom are you referring?

ihi A. The NRC Investigators. 4 Q. Was there any other reason you knew personally that weave weldino 5 had been done? 6 A. Yes. I told the investigators that I myself had repaired numerous 7 welds that had been weaved. One in particular was done by the welde Armond 8 -- I repaired welds of his in the South Yard Tunnel -- this was the basis of 9 my allegation of weave welds in the South Yard ' Tunnel. It's not clear at 10 all in the I&E Report that I had told them tt.at I persor. ally had done weave ) 11 welding under direct orders from my supervisors. Also(my wife Darlene told 7 C, i 12 them the same thing. . i Qw Q. On page 5 of the I&E Report (the seventh page of Staff Exhibit 178), 14 there is a discussion of " Examination of South Yard Tunnel Hanger Welds." ) 15 Is that the area you were discussing where you identified a specific hanger? 16 A. Yes. It says in that paragraph that "It was noted that all of the l 17 welds on these pipe supports were the approved stringer bead type welds and 18 no evidence of grinding was apparent." Then in the very next sentence it is 19 stated "Some welds did exhibit evidence of grinding, but had weld characteristics 20 which made it possible to identify the type weld used as stringer beads." 21 (Emphases added.) 22 Q. Would a visual examination of the pipe supports have proved whether 23 or not weave welding had occurred?

       .3 Q                  A. Most definitely not. As previously stated to the investigator, 25        if they ground the face of the weave weld off and capped it using the proper

[

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C_s 4213 oY stringer bead cap, it would be impossible to detemine whether or not there 2 had been weave welding. Probably the only method to detemine whether or not

          @               weave welding had occurred would be radiography, and I'm not sure that would 4             even reveal the pattern of the weld.

5 Q. In your opinion, is the existence of weave welds an indication that 6 the existing weld is weaker or merely that there had been a failure to follow , 7 procedures ? 8 A. Both. And the investigators missed the main point of what I was . I 9 trying to get across -- that there's no procedure set up to make sure that ( 10 QC can be certain repairs of weave welding are done correctly. The only i 11 thing QC inspectors check (at least usually) is the final completed repaired , 12 weld. There should be QC hold points set up where the inspectors check to be sure that the weld has been properly ground out before continuing the Q~ 14 repair, then a hold point to check during the repair to be sure stringer i 15 beads were being used, and then the final hold point to check the final re- \ . 16 paired weld. That's the only way to be certain the repair has been done right. 17 The way it's being done now, it makes it easy to just grind off the surface i . l 18 and cap it with the proper stringer bead. That way QC never knows whether 19 it's been repaind right or not. It makes the QC inspection of the repair 20 a big joke. 21 Q. Is there anything else regarding weave welding? l 22 A. Yes. Throughout the " sanitized" notes, many of the coments made 23 by(Darlene)are shown under Individual A. They're sort of all mixed in with c:

         'o\              what I said to the investigator. And part of what Individual B, whom I believe 25             to behy wife Darleh 4.11 kle,                                     E a s M S =4* r S jr i nef     eva-      bdwAd-in he.             fM             t ag. < k .         ,_

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                                                                 ,                                   4216 l

h CASE Exhibit pages 6660-6 through 6660-11 contain the information l' Q. 2 from the I&E Report (Staff Exhibit 178), followed by applicable coments h from the " sanitized" notes supplied by the Staff (CASE Exhibit 666C). please l 4 look over pages 666D-6 through 6660-11 and tell us if there are any other 5 problems you see regarding Allegation 1. 6 A. Yes, there am several. At the bottom of 6660-6, what was apparently j 7 stated by me was actually stated by(Darlene)to the investigator. It concerned TC 8 an incident whenhhe)had suspected that a welder hadn't properly ground down 7C 9 a weave weld before capping it.' When(she,) inspected it,(she) noticed that the Tc 10 welder had used only 20 rods. Since(she)had been a welder (herself, shh knew Tc,, i 11 that it would not have been possible to properly repair the weld using only ,

                                                                                                             ~

12 20 rods. (She) called her) foreman and told him about'it, and he told (hef to 7d h buy it off. l 14 Q. By " buy it off," what do you mean? - 15 A. To go ahead and sign off on it:, to approve it as having been done 16 right. f 17 Q. And did(she) buy it off? . .

> . 18                       A. I don't think so. I believe that's the one(she)wouldn't accept and          7c

( 19 wrote an NCR on. You'd need to check with(hed for all the details on it. 7c ! 20 And on 6660-8, it says that Individual B((Darlene))"mcalled one 7c 21 occasion when a weave weld was noted during an inspection, but was subsequently i 22 ground out and correctly rewelded when the appropriate supervisors were notified." j (Darlene)gave them at least one specific hanger number in the Auxiliary Building Tc J}.

       'i/              at elevation 790. This is even shown in the investigator's own notes toward 25              the bottom of 6660-8. And(,she)never said it was " subsequently ground out and         7 d.,

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ib i h correctly rewelded when the appropriate supervisors were notified." hhe)said A I (she)was told by(her$ supervisor to sign it off and that(he)couldn't prove it b l

s Tc.

was weave welded. he)also told them that weave welding was done often. 4 Q. All right. Is there anything else? 5 A. Yes. On 6660-9, under " Interview of BAR Employees," it says "Indi-i 6 viduals C, D, and E stated that they had observed inexperienced welders use l 7 weave welds, but that these were always ground out and mwelded when identified... 8 None of these individuals were aware of the existence of any components contain-9 ing weave welds which were not properly repaired." j 10 But following that, in the part from the notes, it says that Indi-

!                  11                           vidual D actually said "usually capped or ground." "Usually capped" doesn't -

12 necessarily mean that they were ground down and repaired right. And it doesn't specifically say in the notes that Individual D "wasn't aware of the existence 14 of any components containing weave welds which were not properly repaired." 15 One of the things that bothered me when the investigators were talking to '

.                 16                            us was that they weren't interested in even talking to us about anything if I

17 we didn't have a specific hanger number or location. I suspect that's probably I' 18 the way they were when they talked to the other individuals they interviewed ) 19 during the investigation. Probably Individual D didn't know of any specific i l 20 hanger numbers. But that doesn't mean that he necessarily was implying that ! 21 there weren't any components containing weave welds which were not properly

22 repaired.

And Individual E is shown as specifically saying that "is a lot of weave welding going on on hgrs." (He (oralso sheapparently said that inex- '[ C, 24 25 perienced people were doing weave welding and that the foreman made welders

;h f

t 1 I .

;         "t. % .m:t- n~. r m.=w"- m ~~m-n-m --~ -- v a r . r                                             -

E k.. , 1 " grind smooth." When you say " grind smooth," that doesn't necessarily mean

      ,2-        that the weld was properly M down and repaired correctly. It could just as easily mean that the foreman made th'e welders just grind off the top smooth 4         and then recap it with a stringer bead.            It also says that Individual E said 5         "can't ID areas." This could mean that Individual E knew there were other r s.

6 areas where weave welding. existed or where it had not been properly a;;r.na6. . : . 7 but.just didn't know the specific hanger numbers. 8 Then Individual C is shown as saying that "'had one guy doing it' 9 (blacked-out) - quit. exp weld have repaired most of his work." Apparently 10 they had someone like me go back and repair this guy's bad welding. But 11 it says "have repaired most of his work." (Emphasis added.) What about - 12,, the rest of it? And there's nothIing in the notes to indicate that Individual ua . . _ _ _ _ .._ rf C said that weave welds were "always ground out and rowelded when identified." 14 It also says that Individual C stated "QC insp's will catch it." As I stated _ 15 before, without hold points, it's impossible for the QC inspectors to know f I 16 whether the save welding was repaired right or not. l And this is even confinned in the hotes by Mr. Taylor, the Resident 17

  ~

18 Reactor Inspector. On 6660-11, it says under " Examination of South Yard l 19 Tunnel Hanger Welds," that "It was noted that all of the welds on these pipe f. ! 20 supports were the approved stringer bead type welds and no evidence of grinding 21 was apparent. Some welds did exhibit evidence of grinding, but had weld char-

  • A acteristics which inade it possible to identify the type weld used as stringer 22
     ,?}

beads. No evidence was found to support Individual A's contention that weave i G ? 24 welds were used in the South Yard Tunnel." , ,,25 But on 6660-11 where it shows the notes for Mr. Taylor, it states "As

        ~Y                                                               .

0 0

4219 v.L.) 1 Ind A stated some could have been ground or capped and it would be impossible 2 to tell ." This confirms what I stated. And the notes also say "few no evidence

               !       via visual exam." That doesn't necessarily mea ~n that what I said had been 4           disproved, just that you couldn't tell by visually examining them.

5 Q. Is there anithing else about Allegation 1? 6 A. Well, it just doesn't seem to be good investigative practice to me 7 to handle the investigation the way it was handled. It looks like the in-8 vestigator didn't make any effort to find out exactly what a weave weld is, 9 what procedure it violates, what the correct procedum should be, what the 10 consequences of using the incorrect procedum would be (assuming the alle-11 gation was ' correct), or who instructed me not to weave weld. It also seems 12 strange to as that there were no notes included by Mr. Taylor, even though he's the one who did the investigation on 6660-11 under " Examination of

           }

I 14 South Yard Tunnel Hanger Welds."' Did he just keep all his notes in his i 15 head and then tell Mr. Driskill about them? 16 Q. Perhaps we can find out about that. Is there anything else 'you'd 17 like to say about Allegation 17 , 18 A. No, not at this time. 19 Q. Did you have problems with regard to Allegation 2 in I&E Report 80 81-12 (Staff Exhibit 178), beginning on page 6660-12 of CASE's Exhibit? 21 A. Yes. Allegation No. 2 states " Holes am drilled in various types 22 of pipe supports, cable tray supports, and plates, and when, on occasion, 23 they are found to have been drilled in .the incorrect location the holes are a.. . tj filled, utilizing an illegal plug weld." And under " Investigative Findings " 25 it is stated: "

                                                      ... Individual A was interviewed and stated that holes are m

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      . . . ~ . . m,  - . _                     ,.. .....,........;...,.....-,.,.-....-........ . , . . . . . . .

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                                                                     ~18 -

1 drilled in pipe sup' ports and cable tray supports to facilitate bolting them 2 in place. He stated that on occasions een it is detennined that the hole was m J drilled in the incorrect location, it .is filled in utilizing a plug weld. 4 He stated that another hole is then drilled in the proper location on the 5 component. Individual A stated he had the impression, based on connents made 6 by various supervisors that plug welding was not an accepted practice." 7 This does not accurately reflect what I told the investigator. As 8 indicated in his notes on 6660-12, I also told him in answer to his question 9 as tc what would happen if I did get caught making a plug weld that anyone 10 who got " caught by QC will get written up." I also told him "I've done this 11 several times myself," and that my foremen even stood around and watched , 12 for QC. I told him that I "know some are in the North Spreader Rm" (in the .

        ,     ,)             Auxiliary Building). I told him that nearly every hanger in the South Yard 14              Tunnel was cut down at some time or another to be repaired (this referred to l             15               the weave welds and was not part of the allegation about plug welding). They b             16              had to be repaired because of bad welds, incorrect hanger-to-pipe clearance.

17 . the pipes themselves were not in the right locations and weren't straight . 18 (they sort of snaked around up and down). A lot of the new ones they put in I' had weave welds on them because of the push to get the hangers reinstalled. 19 1 j 20 I personally witnessed (Hal Goodson, Doug Frankum, Charlie Scruggs, Ken Liford, 7 21 James Calicut and two other gold hats whose names I don't personally know, 22 tell my gold hat,(Ronnie Johnson) that if he didn't have a particular line 23 bought off down there by 5:30 that afternoon, him and his whole crew would be L r.:. . 9' kicking their hats out the gate (be fired); there was profanity.. hollering, e 25 and cussing by these gold hats to my supervisor. Because of this, all of l D U . i

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               'I                   us welders had the feeling that' they were trying to shaft honnie Johnson) i 2                    so we did what we .were told to do --we ground off the surface. of a lot of h                        weave welds, we welded up on hangers with rods that were checked out in other 4                    people's names, and anything it took to cover everything up and get it all 5                    bought off, because we were afraid for our jobs.                                               It was an impossible task 6                    to do properly, and it wasn't done properly. But it was done.

l i 7 Q. Please continue. l 8 A. The notes on 6660-12 continue with what I told Mr. Oriskill, that 9 I "have asked several foremen 'what if QC catches me'" -- I was told " don't i 10 get caught." The investigator's report misses the whole point of what I was 11 trying to t' ell him -- that no Oc was around when these plug welds were being , 1 12 done, and that once the hole was " plugged and redrilled" and " cosmetically l l '3) blendedd in, it was " impossible to tell" that it had ever been done. I also 14 told him that the possible safety significance of that was that once the hole

                                                                                                                                                                     ^

l j 15 was filled and another hole was drilled overlapping the original hole, it's 16 possible due to vibration, heat stress, and so on, that the Hilti bol't contained 17 in the new hole might actually wallow out and becane loose. And another safety 18 aspect of this is the fact that the procedure (if there is one for plug welding) 19 was not followed and the QC inspection would be unable to catch it. l 20 On 6660-14, under " Interview of B&R Welders," it states that "Indi-l 21 viduals F end G stated they had never been involved with plug welding, and ! 22 both stated they understood that it was not an authorized practice." But i 3 the "sanitiznd" notes state that Individual F said " don't allow plug welds

          ?'

a,nymort," which would seem to mean that they had been allowed in the past. 25 Then on page 6660-15, under " Interview of B&R QC Inspectors," it says that re.. 3., - ..

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N 4356

    -6                   1                       I think I know what the "that" you are
         <              2    referring to there is , but could you tell me?

T C. 3 BYWITNESS,hR. STINER) h 4 A I believe I'm referring to plue w=1 ding, and

                .       5    the repairs of weave welds and bad welds.

5 l 6 4 So that refers back to Lines 6 and 77 7 BY WITNESS MR.~STINER X l 8 A Yes, sir, I believe so. d d 9 4 All right. On the following page, on Lines 19 and 20, you indicate that you had to follow one of I10 , lp 11 the welders around to repair his bad welds. l 12 BY WITNESS MR. STINE h :a. 13 A Yes, sir. l 14 S In response to a question you were asked 15 earlier today, you indicated that your dissatisfaction a 16 with the problem of repairing welds and that not being a a[ e II satisfactory way to solve the problem. h I8 I got the impression that when a bad weld was I h 39 ! g identified, one of the tasks, among others, that you

,                    20      performed at the plant, was to conduct repairs on faulty 21 welds.

22

      @                                          I got the impression that you felt that was 23 '    unsatisfactory, and that the end result was not a i      (-)
       ]                     satisfactory weld.                   Is that correct, sir?                 Did I e                     25
interpret your answer correctly?

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      -7                 1         BY WITNESS MR. STINER) 2                          L   Well, that was my answer, but I really think 3          I need to clarify myself on that matter.

4 4 Could you do that, sir? 5 BY WITNESS R. STINER l 6 L What I was talking about, when they sand a 7 welder that was'in the position like I was, when they send 8 him to repair a weld, it's not in the fashion that you d d ' would imagine by procedure to repair that weld. ' 10 Most of the time they don't want you to gouge

                 !a    II all the filler material out back down to base metal.                                    They 12                                                                                                      '

just want you to grind the surface of the weld off, so h j I3 wher a you can' t see any imperfections underneath that I I4 cover pass and you can't really see the configuration of the top weld; and if it is to such a degree to where I the weld is just totally fouled up, you know, all they . want you to do is just grind the surface off and recap it. 18 - So what I meant by that was that actually when 19 l l I refer to me repairing the welds, I really wasn't t 20 l repairing the welds as provided by procedures. 21 They were just covered up, in other words. 22 . 4" g so that you participated in continuing these ( 23 . faulty welds?

       'h                         BYWITNESS(MR. STINER)                      ,                                                 70
23 3

A Under the advice of my foremen, yes, sir. ALDERSON REPORTING COMPANY. INC. I ..y.w-.v..,-~-~~.~?sa.s

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  • 4358
      -8                                      1                                             4            Sir, with respect to the identification of A' :/.                              2                 faulty welds, I asked grs. Stiner) some questions about I                      L 1c_

, 3 weave welds andwhykhe)thoughttheyweredeficient. i h 4 Could you answer that similar question? What's

       .                                     5                so bad about weave welds?

{ l 6 BY WITNESS MR. STINER I A. Yes, sir. Besides being out of procedure, 2 3 8 you set up a case to where you are supposed to use a d 9 heat temperature indicating stick or crayon to check the 10 inner pass temperature. 11 f . .._ ! a

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     '                                                                                                          4359
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       -                   1    BY WITNESS MR. STINER) 9   '

N 2 A , ( continuing) When you weave welds , you are 3 actually braising this inner pass temperature if you are

         .Q C                 4    not checking it correctly.

g5 Weave welding would transmit =are heat into f6 the heat-affected zone, which would actually in effect c

                  !7 g

break the parent metal down, the molecular structure of R 8 the metal itseif, would break it down, would cause the rJ d 9 austenitic, I believe, if that's the correct phrase, type 10 of action to happen on the parent metal, which would cause h,11 it to be brittle and hold less strength. , 9IN 3 l12 Actua11y', the parent metal around the weave w g I3 weld could actually be weaker than the weld, you see. 14 Is this associated with some sort of rapid 4 I15 quenching or something? fIO BY WITNESS hR. STINER) , II

p. L Well, it's associated -- when you get into
                  "      II inner pass temperatures, th.ey are set up for a reason

' h' l I so that you don' t break your molecular structure of the

                         #      parent metal down, and that's one of the reasons why 21

) stringer heads don't transmit as much heat into the 22 d affected area. 23 ' g Anything further7 i h BYWITNESS(MR. STINERh , A. Yes. I might also add th.at, like (shay was J ALDERSON REPORTING COMPANY, INC. , ,

   . _ [.            _                   [2                        11                  U._         i-         _                 .i

4360 .

           -10                    1     talking about starts and stops.                             I'll give you an indication rr
                    .k           2      here on this piece that I brought.

3 . The top portion of this weld, which is h 4 approximately, I would say, approximately an inch and a 5 quarter long, was made with ul:E.-i70-18 one-eighth-inch l 6 welding rod.' 7 ok a'y . The stringer heads ran in conjunction

g i

3 8 with the fillet weld here, were also made with 1-E-70-18 d . d 9 due-eighth welding rod. 10 So, therefore, there are no starts or stops I II l from Point A to Point B,.which where if you weaved it .

;                         =

I ( 12 in, as indicated right here, you wo'uld have a start here 5 I3 h j and a stop here. j I4 Then you would also have another start and a 15 stop, consequently, about every inch and a quarter all i I' i si the way through that whole weld, which starts and stops d - , II are supposed to be cleaned before each pass; but when you 5 II are set up in a situation to where you are being told, h " j .g "We've.got to get this hanger bought off today," you have to pass some of those points in order to get the 21 production out that the foremen themselves are trying to ! @ require. ! JUDGE COLE: I have no further questions. h Thank you.

j. 25l. //

ALDERSON REPORTING COMPANY. INC.

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4361 1-11 1 BOARD EXAMINATION iC, n - 2 BY JUDGE McCOLLO'M: 3 4 , How long does it take to do a weave weld for J 4 a given pass with the same amount of metal in it as it 5 does to do a string.-- I mean, a weave bead as compared to l 6 a string bead? 7 BYWITNESS(MR.' STINT. 8 A. They are probably the same amount vf time. d 9 4 Why, then, do people choose to do a weave 10 bead in preference to a string bead? g '7C, II 5 BYWITNESS(MR.STINER f B s y 12 A. . In most cases when you'are welding with

  • b I8 an E-70-18 rod on the type of materials that we weld on i.. , I g I4 out there, a b.ot. of times you are unable to run a stringer l15 si I8 bead unless you are really, you know, an expert, or what I would consider to be an expert welder.

1 e . l, k II some of the ine.xperienced welders, by II

                                 ' washing their bead or weaving their bead, they can actually b     19

!. j make it appear to be a more sound weld. l 20 In other words; when they get through they 've i got a large area covered, that they can just grind the l A 22

g surface off, which makes it much faster to apply the i 23 l

weld. 24 Q 4 I thought you j ust said, though, that you could 25 ! weld the same length of bead by either direction in about ALDERSON REPORTING COMPANY. INC. t ,. . .... . . _ w .,., .. . . . . . . - - - - - . - . - . . . ... -...

4 4362 '

       -12                      1     the same time?

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BYWITNESS(MR. STINEh 3 A , No, sir. What I was saying was that a stringer h 4 bead would be much longer than the weave head. 5 I'm not.sure I understand what your question l 6 is. 7 g Well, I'm j ust trying to . figure out. I have 8 two one-foot lengths that I want to put a bead on. g 9 BYWITNESS(MR. STINERh i 10 A Right. lm 11 And I do it by weave heading, and it takes.a 4 S ] g 12 certain length of time. . h 13 BY (ITNESS MR. STINER Q I4 A Right. l15 g Now, then, if I do it by string heading, does ai 10

!                                    that take a longer or shorter time, much longer or much i                         ei 17 l                                    shorter?

II

                         ,-         BY WITNESS MR. STINER                                                                                           ye, k    I' g                        A          It depends on the size, really.                                 It's --

i

                              #                   g          All right.                        I'll put it another --

21 BY WITNESS R. STINER 22 F'f;' A Yeu've got more starts and stops to clean i 23

up, you see what I'm saying, so actually, the weave t .

24 l i, j. beading -- I'm just theoretically saying that the weave i 25 ! beading would probably take longer because you would have ALDERSON REPORTING COMPANY. INC.

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IC 4363 ( ,-13 1 more starts and stops to clean up; whereas, with one WD 2 stringer bead you would only have one start and one stop. 3 S I'm puzzled why people choose to do a weave l 4 bead anyway? l 5 BY WITNESS R. STINER Q

                $       6            A      'Because, actually, it's easier for a person 7   to weave their weld than just to run a s tringer bead.

l 8 That's one of the reasons why they require mos t of the d d 9 welders that come out there to take some kind of practice.or 1 10 practice 2 training *. hours ; is what they call it, so that II h they can acquire the stringer head technique. , 3 ( 12 4 I believe you did say that you did not have*-- .

        'b            II oritmayhavebeenkrs.                  Stine       -- did not have       ~T C.

I# metallurgical knowledge? f

                      '     BY WITNESS       R. STINER                                                 O, A       Right.      (She'      the one that stated that.        ,

l

       .        h                    4       okay.      What about yourself?
                           'BY WITNES      MR. STINER 19 l                   ,A       I have very limited.

20 4 All right. Where did you base your conclusion ' 21 that if you heated too hot, like you would with a weave A 22 V bead, that you would lose some strength or make it 23 i brittle, I believe you said? O

  • avWITNESS@R. STINE9, ,

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 !                    u              A,      Yes.

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      . .                                                                                                                                                                                              h 43G4 G                                      Where did you get that information?
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b BYWITNESS(R. STINEhh A , I have read several publications on welding, which referred to some of the terms that I've mentioned in my testimony.

          .t                                                      Also, the Section 9 and Section 3 of the ASME Code refer to inner pass temperatures.                                                                                                                              Mos t of my assumptions are based on what I have read from Brown &

Root procedures and ..the ASME Code and the AWS Code. S But as far as quantitatively knowing what has happened in the way of the strength, you of your , personal knowledge donht have any Nnowledge on that; is . that correct? BYWITNESS(MR. STINE3 )(1 A Well, I have basically some, as I was a

           . welding foreman for Advance Petroleum for quite some time.

I had to actually evaluate the effects of a weld on a particular joint, which actually involved reading the specifications from the manufacturer; of the welding rods. S Kow did you evaluate the strength? BY WITNESS R. OTINE) A How did I evaluate it? Well, we did it by trial and error, more or less. 4 What do you mean, " trial and error"? What ALDERSON REPORTING COMPANY. INC. ,

C. . 4365

        -15                      I        was your trial?

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             .*                  2        BY WITNESS MR. STINE
 !                               3                     A         We had to weld up particular joints and put 1                                                        ,

h 4 them on like a bend test. type deal to see if they would 5 withstand a certain amount of pressure without breaking, g . _ _ _ E7 . l ls a d 9 ., 10 g . In g 12 .

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? .. og. - . 7C b CPSES WELDING ISSUES' l WEAVE WELDING Issue Reference Lead instructed by h hASE666,p.9', ( 2.s o-is 7C 1. that transverse o'scillation Tr. 4211. , ! of weld rod (weave weldino) not ~ pemitted at CPIE!F. , ,

2. M tol'd to use a 5/16" weave CASE 666, p.9 7C cov pass on I beams by Tr. 4211. -
              <                                                     a testing instructor at the WQTC.

3 .* . was told by CASE 666, to weave weld due to fi -up gaps; pp. 9-11, .. ~I C and to make sure that QC did not Tr. 4211 ~

                 "                        identify this.                                                                                                        .
   /                        4.                             _ states that " weave welds"                                       CASE 666, p. 11,                       7 C.
                                     'could be ound at:
1. South Yard Tunnel Tr. 4213..
2. Auxiliary Building ..
3. North Yard Tunnel _
                  "                           4.       North Pump Room                                                                                                 ..
5. Unit 1 Demineralized .

Water Tank om -rC

6. Every place worked
                    ,       5.          [ 6 repaired a weld on a                                                              CASE 666, nan er which was ori             nally done                                        pp. 11-12;     .

by -in South Tr.4213-14g ~7 C nn 1. In a s te visit, 10.591-594,

                        ')                                  originally identified                                             10.597.A 1,192-3,
         ,-                                 anger          1-017-005-Y35R as the                                              11,209.
       \; ', . -                    , hanger that this occurred on.                                                            39,,g 3 go7f After reviewing the documentation                                                                           ".

p . *, , ,6,,,9 .j-,,,, g ,,..,...,,,

      .A t the, plan               i ntified hanger.

hin'gn.

         ,,                                           17-004-Y35 The        R'for thi        hanger is CASE 968, following Tr. 11180.

y 6. M believes that ' Tr. 11.192-3; 7C,' - CT-1-017-005Y35R may have been 11.209... ' removed down in approximately , June / August of 1980. (M. . states that there are base metal defects on this hanger. F0WB . m m" '-

J fC . . Issue Reference lead

7. No QC hold points to check if repairs CASE 666, p. 13, g were done correctly. Tr. 4215. - ~7 C.

disagrees 'w/ repair pro-l cedure o grinding down, and using a cover pass.

8. Nearly every hanger in South Yard CASE 666, p. 18

'  ; Tunnel was removed to be repaired. Tr. 4220g ,

9. CASE 666, p. 18 ~7 C.

l Tr. 4220. r

!           ,                        other su rvisors                hats) j                                                                   supervisor,
with temination '

!. f a pipe ne segment was not i completed before the end of the day. .

10. claim that Tr. 4087-89,v 7 i
                                    . stops and starts on_a weave weld ~           4 :: 00.         '

j . are weaker. -

11. states that weave Tr. 4359,V welds result in his concerns with 4363-64.

7c l interpass temperatures, which may j rise to the point that the molecular - s structure may break down, leading j to brittleness and strength reduction.

12. I M claims that weave beads Tr. 4361-63. J J are not faster to do than stringer 7C beads, but instead are used because .

they are easier to do. c 13. Heat input a problem result in adverse' Tr. 10,706; I changes to base metal for weave welds - 10,784-5. ! problem for steels at .3 KmFabove ' I carbon content.

14. Effect of preheat on cooling rate. Tr. 10,786-89. .

l 15. Lack of preheating causes a reduction Tr. 10,801-02. j in weld strength. ! . 16. M weave weldt.d on support Tr.10.591[ i which he orfgTnallyTn:ntioned at 10,900-902, Tr. 4213. - 10,924-5. 7e s i

                                                                                                ,       b,    .                .

g

                                  --__----m-      --- -- ----- ~ . - - - - - - - - - - - -                  -- - -------- -                       --                    '- '

3 h' Issue Reference Lead

17. did welding on attachments Tr. 11.047-51. gg
18. Heat input' is a problem with both Tr. 11.051-52.-

stringer and weave welding. 74

19. ' . state M were CASE 919 p.1. I quali ie to Welding Procedures 11032 "T C 11046, 11065. ,.
20. ( performed, and CASE '

mye seen ot ers in violation rform istave weldina 4 Tr. g ,p.6; . 10.314. 7c diameter J: ' - ,, ; o limitation.J was directed r "' - to weave welo n vi icable '.' rocedures

21. believes that some of the CASE 919. pp. 7-8;
                        ~ materials he worked on were required to be impact-tested. Doesn't remember Tr. 779-83, see also Tr. 10.830-31.

7c hangers or locations.

22. laims that he perfomed CASE 919. pp. 8-9.

welds where the base metal was he,ated to the point that it turned blue. He 7 C'

  • implies that this is indicative of excessive heat input. ,
23. liege that welders CASE 919 pp. 8-13.

do not check interpass temperatures Board requests ~7c, using temperature indicating crayons. Staff to conduct I inquiry into this matter. Tr. 9955-

60. 10257-58, 10262.
24. alleges that welding was CASE 919, p.9.

per orme Board

                                       ~when temperatures were
                         >elow freezing.

requests Staff to TC conduct an inquiry into this matter. Tr. 9947-50.

25. states that grinding is CASE 919. p.13-14; n table repair for wave welds. Tr. 10.839-41. 7O also a -

thisassessment.)ppearstoagreewith , O j

  • 4
 ;                                                                                                                                         ..          h
                                                           ,            ..        ..- .. m _
                                                                                             ~

g

                                                           . Issue                            Reference                                  Lead DOWNHILL WELDING                ,
                                         ~

terminated for reporting CASE 666, pp. 29, R / - y ' gouge on a pipe. This gouge was 35-41. Tr. 4231, c' # C

                     '                 reported on NDER No. 2899, and                          4236-42, 10,606-620, p/

g'/ @ references Drawing CC-1-58-038. 10,622, 11.016-017. CASE implies that use of an;NDER .. O- instead of NCK*is a deficiepcy. , Tr. 10,624-26. 7 c* Limited access: situations may make a .f M* L ' , ' downhill weld easier to do than an uphill weld. of L' ' f

                                                     ) performed Do'wnhill welds."           Tr. 10,625-28 I      3 l
                                      'where weld rod metal is allowed to                              +                                              'l C.

Vs ' dribble down, covering joint, without moving rod down. .

4. claims that y_emee Tr. 10,314-317. .

q welding is faster than stringer - beading. . al?eges that Mike Adcock CASE 667,

5. 7 C'-

nstructed not to oscillate her pp'. 23-24 - W# weld _ rod duringMtraining at the CPSES weld training school. Tr. 4147-48.*- Hanger TWX-039-714-A35R was f rica- CASE 667, 6. ted us welds don by pp. 24-27,

                                                                             'and                Tr. 4148-51;-
s. 10,143-10,200. 7C-rote ..

on a er r no d base metal defects), approved this hanger, after t e we s were ground down and recapped. Hanger BR-X-181-707-A45R was fabrica- CASE 667, 7. ted weave welds. NCR M-82-00584 pp. 29-30. (CASEExhibit667-Q)documentsthis Tr. 4153-54. .

                                                                                                         ~

condition. CASE 919, p.15. 7 C--

8. perfonned a downhill'
    /                                      weld in an area which had limited access.

l ,

I -- --' - - - - - - - - - - - --- --- - - - - - - - - - - - - - - 5 c, . ( ' Issue Reference Lead g 9 Downhill welding results in lack CASE 919, pp. 15-16.

      ,    ,                  of penetration, entrappment of slay,                                                                          7C.

( 1ack of fusion. Downhill welding is performed for welding on plate 1" or more thick, as indicated in Attach-t ment B to CASE 919. . d PLUG WELDING , 2 .

1. 1982 AWS DI.1 Code, 9 3.7.7 recommends Tr. 10',681-82.

not to use " plug welds."

2. 11 inch ' diameter hole on two inch Tr. 10,698-99.

thick plate would require 2 minutes to ! weld, without cleaning the weld passes. I 3; ( M alleges that he performed Tr. 10,670-680, 7 c, plug welds which were not authorized 10,700-09. by weld engineering, in part due to l production pressures. ..

4. welded misdrilled holes Tr. 4220; CASE 667, )

i without Q inspection of the welds. p.22. Tr. 10,990- 7C Some were in the north cable spreading 11,005, 11,008-009. i room, which he worked in for " weeks." / 5. welded misdrilled holes Tr. 11,011. Tc in the cable spreader room. .

                                                                                                                         ~

[ 6. welded misdrilled Tr. 11.011. 7e oles in the south yard tunnel.

                       ~

f , u 7. Only two rods required to " plug weld" Tr. 10-698-99, a 11" hole in a 2" thick plate. 11.158-59. .I 8. repaired af sdrilled holes by welding without chipping out slag, Q p.22. lC 1 and without proper authorization. Any - defects in the weld were hidden from visual inspection by grinding the weld, and spraying the metal with gray primer paint. 1 h 9. infers that there was no CASE 666, p. 18; 7c lj author zation to repair the misdrilled CASE O1 p. 22; holes since he had other welders / Tr. 4220 .

                  ,             foremen watching-out for QC inspectors.

e e o

                                                                      -_..-._-_--7.-..                                                                                     - -
 'o Issue                           Reference                                              Lead
10. I ~ repaired misdrilled holes CASE 667, pp. 30-31, 7C
                    -            'on "numero_us occasions" by welding, but chipp d out sla with chipping                             CASE Tr. 41 @54-55, 10,286.pp. 21-22, - 2 hamme' .                                indicates that
           -                      these repair welds were also done without proper authorization.                                                                 .
  -                          11.                            alleges ha                          Tr. 10,286.                                           !

l di ted . . ,y,, e  ! to " plug weld" in viol tion of G.1' l

                                                                                                                                                  / ,7 - N.C-proc                res on fabrication tables           '                                         -

located in the turbine building. WELD R00 CONTROL

1. WFML for Hanger SI-1035-032-535R indi- CASE 667, cates that approximately 75 weld rods pp. 40-41,  ;

were utilized in the' fabrication of Tr. 4164-65. this hanger, which is an overly large ,, amount. This indicates that weld rod control program is not functioning.

2. found two bundles of weld CASE 667, p.41, rods which she believes were abandoned. Tr. 4165. 7e No corrective action was taken on this '

item. l 3. wrote an NCR on a welder CASE 667, p.42, o ai e to turn in all unused Tr. 4166. 70 weld rods.

4. Rod shack employees do not count used Tr. 10,636-640. -
                    .             weld rod stubs, but mathematically V.

p + determine the amount of used or damaged rods. . This occurs because there is a large number of welders checking in weld rods at the close of the shifts. -

5. M'used rods that had been Tr. 11.128. ~7 C exposed for 2-3 days in welding at
                                   " chiller room."
6. used weld rods that Tr. 11,128. TC-had been exposed for 2-3 days in l ,

welding at the north and south yard tunnels. l

I- - l' p, , _7.

                                                                                                          .1c l                                                            issue Reference                         t.ead
           ,7.                    Welders will' keep rods overnight                           CASE 919, pp. 18-19.

to save time, an because of produc-tion pressures. Lindicates TC. he has seen many welders keep rods for 2-3 days.

      '. I8.                     Welders:lo'an weld rods to one another, CASE 919, p.19.
           ',                      in part;because of production pressures.                             ,
           ~ 9.                    Porosity in root or intermediate                           CASE 959,p.21.

i passes (resulting from the use of contaminatedweldrods)canbe obscured by a cover (" cap") pass. o *e e 6 I 2

                                                                                       .                        .                                               I l

f .

. ~... ;.u.: E.. . .

Q r l' OTHER ISSUES Issue Reference Lead

1. Improper repair of concrete where a CASE 666,

[ cone of concrete was removed along pp. 24-27, with Hilti bolt in Safeguard Building. Tr. 4226-29. T c. ~ This wa n doc nted and ported I to QC. tat can confirm his allegation.

 ,                  2.                ha first hand knowledge             Tr. 10,629-31.                 7C that                  as wrongfully termi-nated by Applicants.-
3. M alleges that vendor CASE 667, -

7C i welds on diesel generators were p. 14-15, . deficient. Tr.4138-40. (

4. put( M on 60 CASE 667, 7c.

day probation when she had a valid p. 4142, medical excuse. Tr. 4142. -

5. Fished to speak CASE 667, 7e with NRC concerning problems at pp. 44-45, CPSES 1. Tr. 4168-69.
6. A and a female) from CASE 667 -

the NRC found a iscrepancy(nthe pp. 67-69, 70 visual tests for and Tr. 4191-93. hat this esulted in harrassment of l 7. work s ation was moved CASE 667, 68-72, Tc leveral times, which inks may Tr. 4193-96. be a form of harrassment. - 4 8. ~ alleges that there were CASE 666, pp. 42-45, I many "coun erfeit" hangers, where Tr.'4243-46. I heat numbers were stamped on junk [Mrs. Stiner's allega- 7, L material, and the material then used tion appears to be  ;

n the fa rication of hangers. confirmed by Judicial l.- identifies H-CC-1-SB-038- E in Herr /Driskill
!                         010-3 as one hanger. He also states             hand-written notes for that a class 5' hanger in the South             J.R.81-12]                                     .

p - Yard TunneT was also constructed of ! . scrap material. e . _.~. .. ..

__. . - ._. ._ . ._;~. . . . _ . . . . . - _ . Issue _ Reference Lead

49. weld '

on a "coun rfeit" CASE 667, hanger. dte: testi- pp. 47-48, mon on this' mat r th t Tr. 4171-72. may be confused w t re o their

                          ,     ecollectio on plug welding done by l              l
10. Failure to re-check welders symbols Tr.!i10,479, A on WFML in package for hanger which Tr.:10,483-84.

has been removed and re-welded will CASE 919, p. 20. result in a failure to properly . Board asks for account for weld rods.  ! Staff inquiry i'nto this matter. Id. ( IJ. Weld technicians did not actually Tr. 10,596-10.603. j check parameters mf welders in the , field. -

12. Carpentry foreman are assigned as Tr. 10,925-27. -

welding supervisors. , 1 f y 13. performed welds CASE 919, p.9-10; cre a bare we

                            ~

rod was melted 9950-55. Board by a second weld rod (" gap welding"). requested 3taff to Such welding was utilized to fill conduct an inquiry . large gaps in hang rs whi h we e not into this subject. correctly fitted. s Tr. 9950-55, 10324-5. - use this technique by . S S I

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Brown & Root,!nc. Post Office Box 1001, Glen Rose, Texas 76043 8RF - 9265 . April 4, 1979,

'~ Mr. J.T. Merritt Texas Utilities Services, Inc. P.O., Box 1002 - Glen Rose. Texas 76043 1 h 4 Texas Utilities Services, Inc. ' Comanche Peak Steam Electric Station , , 1981-83 2300 MW Installation Approval of Welding Procedure Specification

Dear Mr. Merritt:

Attached are copies of Brown & Root, Inc. Welding Precedure Specifications

for review and approval by Gibbs & Hill, Inc.

These Welding Procedure Specifications are to be used in conjunction with the following Materials Engineering Specifications: MES-105, WES-16, CP-CPM 6.9 Please review / approve the following subject procedures at your earliest j convenience: Document No. Document No. - Document No. i Carbon Steel Procedures Dissimilar Metal Procedures Nickel and Nickle Alloy Procedures WPS 10030 Rev. 4 WPS 13011 Rev. 1 i 10031 3 14010 1 WPS 60012 Rev. I t 10032 8 15010 1 60013 2 . 10047 2 18010 4 60017 .1 11010 3 18011 3 60018 2 11011 4 18012 3 60019 2 i 11012 2 18013 3 11013 3 18014 2 Stainless Steel 11020 3 18015 2 Procedures 11021 3 84220 3 WPS 83011 Rev. 4 1 11031 2 84320 2 88012 4 1 11032 5 84520 3 88021, 5 11033 1 88022' 6 ^ 11034 1 P-3 Procedures 88023 5 11035 2 kTS 33010 Rev. 1 88025 2 i 31063 2 88032 5 11065 1 P-5 Procedures

.                                                       WPS 55010 Rev. 1 i

e

  • F0lA-85-59 mn -
   ~

drtdyn0' Root.Irx:. BRF - 9265, Page 2 of 2 Document No. Automatic Procedures * Carbon & Stainless Steel ' WPS.99020 Rev. 4 99021 1- - 99022 1 99023 2 99024 1 99025 2 99026 1 99027 1 99028 2 99029 1 Very truly yours, BROWN & ROOT, INC.

                                                                                                                      ?

U. D. Douglas Project Manager . cc: J.T.'Merritt (IA 1L) CPP-A-01444 j L.A. Ashley (IA 1L) ' ARMS.(0,1L) #praed: YbYf J.T. Mar (it(, Jr.

                                                                                                                    ~
                                                                                                                            $ 5- M
                                                                                                                        ' ' Date '/

Engineering & Construction Manager l l l . I i l l

i . e WEl.OING OuRE No. i , HousT@N. TEXAS EV StoM S PAos 1 or 2 WELDING CODE SUPPORTING POR(S) ASME8&PV 0101Rn157 Rav 2 SECTION IX WELDING PROCEDURE SPECIFICATION 0101AB138 Rav 2 t .

                                                           ~

3 D AJe 4 l ! WELDING PROCESS (ES)

1. Shielded Metal Are TYPE Manual IAfr U
2. N/A TYPE N/A _

8ACU ) nm l BASE METALS (QW-4031 POSTWELO HEAT TEEATMENT (QW-407) j P No. 1 Gr. No..H/.A.to P No 1 Gr. No. M/ A Type N/A Thickness Rangs .on? ehm _nAA IN. Temperature N/A 'F l Un14=4 ted N/A

Pipe Dia. Rang, IN. Time Range l

Range for Fillet.Tp All 0;e Unlimited IN. i i GAS (QW-408) { FILLER METALS (QW-404) Shielding Gas 1. N/A i F No.1. 34 2. N/A Percent Comp. N/A ! A No.1. N/A. 1 2. N/A Shielding Gas Flow Rate N/A CFH (min.) SFA Spec. No.1. 5.1. 5.1 2. N/A Purge Gas N/A Flow Rate N/A CFH (min.) f

AWB Class. No.1. E6010. E7018 2. N/A Trailing Shielding Gas Composition M/A l Siae of Electrode 1.'l/'12-5 / 32 2. N/A IN.

Siae of Filler 1. N/A 2, N/A IN. ELECTRICAL CHARACTERISTICS (QW-408) i { ! Electrode - Flux Class M/A Current 1. DCRP 2 N/A . Canesmeble insert N/A Amps Range 1. 40-220 2 N/A Volts Range 1. 18-30 2. N/A Tunyten Elec. Size / Type N/A f

POSITION (OW-406) TECHNIQUE (QW- 410)
Welding Position All StringerorWeeve 8ead 1. Strinner 2. N/A

. Weiding "rw :': . E6010 Down. E7018 Un 8eed Width See Page 2 ! Orifice or Gas Cup Size N/A IN. (min.) i PREHEAT (OW-408) initial and Interpass cleaning: Weiding surfaces shall be wire brushed I Prehest Temp. 60 ,F (Min.) or yound as required to remove slag, scale or other contaminants, f inerpens. Temp. Range 60-500 *p wgg ,, N/A Prehest Maint. N/A Oscillation 1. N/A 2. N/A IN. (max.) JOINT DESIGN (OW-402) Contact Tube to work distance N/A IN. Groove Design Sinela V Multiple or Single Layer 1. Multiple JointType 08 Yan C3 N/A 33 N/A (Per Side) 2. N/A Backing Matt Type N/A Multiple or single electrodes Single Travel Speed (Range) 1. N/A 2. 5' IPM l - t REMARKS Jm l

r .

EENEENS E ON_Y n [ PREPARATIOPIA L Cd.a./ OVA (, n' DATE 3-30-M Feb. Codes: ANSI B31.1 T i - !) _

                 *2M, .FIM
                    /

4 17 P,w: CPSuS y-3-W Job bio. CR-0172 Chality Assuraf f e[ R j . -

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_mr - . m , mm

WELCING TECHNIQUE SHEET O

 ,                                            P NO. 1 GROUP N/A TO P NO. 1                 GROUP N/A                                    ,     ,,         g THK. RANGE                    .062 thru .688                             IN.                   PAGE       2 OF 2 Tvem4L mint otsiGNs PERMrTTED                                                                     pooTop5NiNo o.s.       N/A             iN.

s.s N/A su, ) 2 ! Lx h m A M xM A A 3 VM/MRh

ffg gg . ,

m mxxxxmy i_n mme Gap & Land: 3/32" + 0

                                                                                                          - 1/32" WELDING PARAMETERS                                                                                    ' SINGLE VALUES ARE MINIMUM FILLER METAL
  • gas ELECTRICAL DATA TRAVEL SPEED LAYWe SIZE Pl.OW RATdCFMI AMPERAGE VOLTS eaocE= nNa A=cu= Tva , oi.A TYPE.l. .A,.G. .A, G. n~i WlOT,H n,,
                                                                                              ,,,E m ,U ,GE 1-4       SMAW             3/32    E6010                  N/A     N/A      N/A    DCRP         40-80      22-30       N/A            3/8 SMAW             1/8 E6010                      N/A     N/A      N/A    DCRP          70-130 22-30          N/A           1/2 SMAW             5/32 E6010                   '

N/A N/A N/A DCRP 110-170 22-30 N/A 5/8 ALT SMAW 3/32 E7018 N/A N/A N/A DCRP 70-120 18-28 N/A 3/8 36 SMAW 1/8 E7018 N/A N/A N/A DCRP 90-160 18-28 N/A 1/2 on SMAW 5/32 E7018 N/A N/A N/A DCRP 110-220 18-28 N/A 5/8 enEHEAT TEMP. 60 *F (Minj SACK GOUGING METH00 N/A INTERP Ass TEMP. 60-500 *F CONTACT TusE To work DisT. N/A su,g i 3 PM EHE AT M AINT. N/A oniFms on cup slZE N/A IN. (minj TUNGSTEN ELECT. SIZE & TYPEN/A IN. wEtotNG rnoGREssioN.- E6010 Downward Ewn .N/A E7018 Upward INSTRUCTIONS

1. The interpass temperature (above 150'F) shall be checked using temperature indicating crayons or an approved equal. .
2. Tack welding shall employ the parameters for the root pass.
3. Tack welds shall be couplete fusion; the st' arts and stops shall be tapered by grinding so that the initial pass can properly consume the tack.
4. All welding shall utilize stringer beads.

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

M houston, TEXAS Welding Procedure Specification No 0101AB138 os. 8-4-78 Supporting POR No 0101AB138 Revisions 2 3-30-79 2 WELDING PROCESS (ES) 1- Can Tunesten Are TYPE Manum 1 ,

2. Shielded Maent Arc TYPE Manumi l

BASE METALS (QW-403) POSTWELD HEAT TREATMENT (OW-407) i P No. 1 Gr. No. 1 to P No.1 Gr. No. 1 Type N/A Thickness Range .187 thru 1.812 IN. Temperature N/A *F Pipe Dia. Range Unlimited Time Range N/A GAS (OW-408) FILLER METALS (QW-404) Shielding Gas 1. Arnon F No.1. 6 2. 4 Percent Comp. 100 A No; 1. 1 2. 1 Shielding Gas Flow Rate 15 Mf". CFH (min.) SFA Spec. No.1. 5.18 2. 5.1 Purge Gas Arno" Flow Rate 5 CFH (min.) AWS Class. No.1. E70S-2 2. E7018 Trailing Shielding Gas Cornposition N/A Size of Electrode 1..NI.A._ 2. 3/32.1/8.3/16 IN Elae of Filler 1. 3/32,1/8 2. N/A IN. E LECT R ICA L CHAR ACTE R ISTICS (QW-400) Electrode - Flux Class N/A Current 1. DCSP 2. DCRP Consumable insert N/A Amps Range 1. 80-130 2. 70-220 Volts Range 1. 8-12 2._ 20-30 Tungsten Elec. Size / Type 1/16"-1/8"/EUTh-inr2 POSITION (QW-406) TECHNIQUE (QW-410) Welding Position 6c Stringer or Weave Bead 1. Std"?"" 2 sed"?"" Welding Progression ifwmed Bead Width 1 1/8 2. 5/R IN. (max.) Orifice or Gas Cup Size 1. 7/16 2. N/A IN. (min.) PREHEAT (QW 406) Initial and Interpass cleaning: Welding surfaces shall be wire brushed Preheat Te.wp. 150 *F (MinJ or yound as required to remove slag, scale or other contaminants. Interpass Temp. Range 150-500 *F Method of back gouging N/A Preheat Maint. N/A Osci!!ation 1. N/A 2. N/A IN. (max.) JOINT DESIGN (QW-402) Contact Tube to work distance N/A IN. Groove Design Si"'I* U Multiple or Single Layer 1.Multiole Joint Type OB Yan Cl M/A BS N/A (Per Side) 2. Multiole Backing Matt Type N/A Multiple or single electrodes Sinnie Trevel Speed (Range) 1. 1-3 22-8 IpM Sketch / Comments l Land: 3/32" + 0 - 1/32" Cap: 3/16" + 0 - 1/16" Pr r d by Approved by l ' }

a. J WN(? 3-so-n /2.P () M 9,-y 19 WEL3ING MGINEF, RING DATE MATERIALS ENGINEERING DATE /

1 ap HOUSTON, TEX As 01AB138 2 PROCEDURE QUALIFICATION RECORD 0101AB138 2 WELDING PROCESS (ES) 1. Cas Tungsten Arc TYPE Marual

2. Shielded Metal Arc TYPE Mantal BASE METALS LOW-403) JOINTS LOW-402)

Matt. Spec. SA- 333 To SA- 333 Type or Grade 6 - 6 l I P No. 1 Gr. No. 1 To P No. 1 GrNo. 1 Coupon OD 8.625 Thickness .906 IN. l 1 O. D. Range Qualified Unlitnited Thk. Range Qualified 1. 187 .250 2. 187-1.562IN Land: 3/32", Gap: 3/16" Total Thk. Range Qualified 187 thru 1 R17 IN. Uoint desigt used) 1 1 I FILLER METALS (QW-404) GAS (QW-408) F. No.1. 6 2- 4 Shielding Gas Argnn A No.1. I 2. '1 Flow Rate 1 5-20 CFH SFA Spec. No.1 5 1R 2.91 Purge Gas Arman AWS Class. No.1. E70S-2 2.E7018 Flow Rate 5 '50 CFH Size of Electrode 1.Not rec. 2. 3/32.1/8 S IN Size of Filler 1. 3/32.1/8 2. N/A IN. ELECTRICAL CHAR ACTERISTICS (QW-409) Electrode - Flux Class. N/A Current 1. DMP 2 DN Consumable Insert 1. M/A Amps Range 1. 90-120 2, An-210

Trade Name N/A Volts Range 1. 10-17 2- 71-1n POSITION (QW-406) TECHNIQUE (QW-410)

Welding Position 6C Stringer or Weave Bead 1. S trinner 2, Stritimer Welding Progression UDward Beed Width 1. 3/8 Mar- 2. 5/8 Mar. IN. i Orifice or Gas Cop Size 1.7/16 & 1/2 2. N/A IN. N/A 2. N/A PR EHEAT (QW-406) Oscillation 1. IN. Preheat Temp. 15 0 eF Multi or Singia Layer 1. Multiple

interos.
Temp. 150-500 *F (Per Side) 2. Multiple POSTWELD HEAT TREATMENT (QW--407) Multiple or Single Electrodes Single i Type N/A Travel Speed Range 1. 1.5-1.8 2. 2.1-7.2 gpg Temperature N/A *p l

Time Range N/A ( , TENSILE TEST Specirnen Ohnensions (INj Ultknees Unit Character of Fouure Ultimees Total No. F4 No. whten Thickness ^* UN* 3 Lond Lin. Stroes pel AndLosetion 1 QW462.1(b? .745 .716 .533 41.900 78.611 Base Metal l 2 QW-462.1(b? .748 .725 .542 41.700 76.937 Base Metal l, GuloED eEND TESTS Rossis Fleasit No. Fle. No. Type No. F4 No, Type

1 QW462.2 (a) SB Satisfactorv _L. 0W-462.2 (a) ji3_ Satisfactorv 5 2 3W-462.2 (a) SE Satisfactory 4 OW-462.2(a) RB mmh afar enev 4 Welder's Name Don L. Riza. Martin Sonchak S.S. No. 450-04-7704. 456-40-9922 L Who by virtue of these tests meets welder performance requirements.. Laboratory Test No. 78-162 Test Conducted by B&R Materials Engineering Lab. Address
3100 Clinton Drive. Houston, Texas j per C. E. Dawson oete July 31, 1978 l We cartify that the statements in this record are correct and that the test welds were prepared. welded and tested in accordance with the requirements of Section IX of the ASME Code.
  ,                                                                                     Signed 8ROWN & ROOT. INC.

(Manufacturer) Date By

 ?

i

Housr6N. TEXAS 01h1AB138 2 SUPPLEMENTAL TESTS cysgs CR-0172 TOUGHNESS TEST TYPE Charov "V" PER ASTM A370 SIZE 10mm, x 10tma : Specimen Test Notch Energy Mils Lat. Exp  % Shear Identification Temp Location Ft-Lbs 1 0 *F - Base 82 . '.'054 30 2 0*F Base 59 .037 30 3 0*F . Base 98 .064 40 1 0*F Wald 119 .064 40 2 0*F Wald 117 .062 40 3 0*F Wald 47 .032 20 1 0*F HAZ 155 .065 50 2 0*F HAZ 137 .060 70 3 0*F HAZ 121 .070 99 Radiographic Report of Procedure Qualification: Radiography was accomplished in accordanc with ASME Section V, Article 2. The acceptance criteria of ASME Section III, Division I, Subsection NB was met. t l l We certify that the statements in this record are correct and that the tests were conducted in aa:ordance with the above listed WPS/POR and per requirements of the listed code / standard (s). Signed Brown & Root, Inc. Date 4'4'7 sy - ^

                                                 /
                                                                                              \

e

       .-                        . - - .       - - - ~ . . .           .. .           - -                         . . -                                 - . .                   . . .

j _ . . - - 9 g HOUSTON, TEX A8 l Welding Procedure Specification No 0101BB157 Data 12-19-77 Supporting POR No 0101BB157 Revisions 2 3-30-79 2 WELDING PROCESS (ES) .1. Shielded Metal Arc TYPE Manual

2. N/A TYPE N/A BASE METALS (QW-403) POSTWELD HEAT TREATMENT (QW-407)

P No. l__ Gr. No. I to P No. 1 Gr. No. 1 Type N/A

                                .062 thru .I36                              IN. Temperature N/A                                                                                       ap Thickness Range Pipe Dia. Range      Unlimited                                        Time Range N/A                                                                                              ;

GAS (QW.-408) . FILLER METALS (QW-404) Shielding Gas 1. N/A F No.1. 3 2. N/A Percent Comp. N/A l , A No.1 N/A 2. N/A 8 Shielding Gas Flow Rate N/A CFH (min.) SFA Spec. No.1. 5.1 2. N/A Purgs Gas N/A Flow Rate.N/.A.CFH (min.) AWS Class. No.1. E6010 2. N/A Trailing Shielding Gas Composition N/A Size of Electrode 1. 1/12 1/8 9 N/A IN. Size of Filler 1. M/A 2. N/A IN. ELECTRICAL CH'AR A ERISTICS (QW-4914 5 Electrode - Flux Class N/A Current 1. DC 2. N/A Consumable insert N/A Amps Range 1. 60-120 2. N/A Volts Range 1. 20-28 2. N/A i Tungsten Elec. Size /Typ N/A POSITION (QW-406) TECHNIQUE (QW-410) Stringer Welding Position 6C Stringer or Wem Bead 1 9 N/A Welding Progression Desend Bead Width 1. 1/2 2. N/A . IN. (max.) Orifice or Gas Cup Size 1 N/A 2, N/A IN. (min.)

;         PREH EAT (QW-.406)                                                    Initial and Interpass cleaning: Weiding surfaces shall be wire brahed Preheat Temp. 7f1              *F (Min.)                              or ground as required to remove slag, scale or other contaminants.

Interpass . Temp. Range 70-600 *F Method of back gouging N/A 4 Preheat Maint. M/A Oscillation 1. N/A 2. N/A IN. (max.) JOINT DESIGN (QW-402) Contact Tube to work distance N/A IN. Groove Design sinele V Multiple or Single Layer 1. Multiple Joint Type OB Yaa Cl N/A 33 N/A (Per Side) 2. N/A Backing Mad Type N/A Multiple or single electrodes SI"EI*

 ,                                                                              Trevel Speed (R ange) 1.                  3-8                             2. N/A                      iPM Sketch / Comments i

l l Bevel: 37 1/2* 1 2 1/2* 1.and : 3/32" + 0 - 1/32" Cap: 3/32" + 0 - 1/32" l . Prep e i by Approved by (

  • 3 =& ~')9
  • k*$#7f WELE ING EkiNEERING DATE MATERIALS ENGINEERING DATE L - -

i _ - Brown & Root,Inc. __.1.- ~2mS7 2 1 wrs No. PROCEDURE QUALIFICATION RECORD 0101BB157 2 l WELDING PROCESS (ES) 1: Shielded Metal Arc TYPE Manual

 .                                                    2.       N/A                                                                       TYPE N/A                                       1 BASE METALS (QW 403)                                                      JOINTS (QW-402)

Matt. Spec. SA- 106 ToSA_ 106

  • Type or Grade B -

B 7 P No.._1_.Gr. No.L To P No..l __ Gr No.1 Coupon OD 2.375 Thickness .218 IN. Ran Qualified 1.. 46 2 N/A IN.

                                                                                                          *                           /      e      D : /         . G8P: 3/32" Total Thk. Range Qualified          . 0M rh ru .436                  IN.           (Joint design used)

FILLER METALS (QW-404) GAS (OW-408) F. No.1. 1 2 N/A Shielding Gas N/A A No.1. N/A 2 N/A Flow Rete N/A CFH SFA Spec. No.1.5.1 2. N/A Purge Gas N/A AWS Qass. No.1. E6010 2. N/A Flow Rate N/A CFH Size of Electrode 1.3/32.1/8 2. N/A IN. Size of Filler 1. M/A 2. M/A IN. ELECTRICAL CHAR ACTERISTICS (QW-409) Electrode - Flux Clase. M/A Current 1. DN 2 N/A Consumable Insert 1. N/A Amps Range 1. 70-10Q 2. N/A Trade Name N/A Volts Range 1. 22-27 2 N/A POSITION (OW-405) TECHNIQUE (QW-410)

  • Welding Position 6G Stringer or Weeve Beed 1. S tringer 2. N/A Welding Progression Downward ~ Bead Width 1. 1/2 Max. 2. N/A IN.

Orifice or Gas Cup Size 1. N/A 2. N/A IN. PR EH EAT (QW-406) Oscillation 1. N/A 2. N/A IN. Preheat Temp. 70 *F Multi or Single Layer 1. Multiple , Interpass Temp. 70-600 *F (Per Side) 2. N/A POSTWELD HEAT TPEATMENT (QW-407) Multiple or Single Electrodes SiDEI* Type N/A Travel Speed Range 1. 4-8 2. N/A IPM Temperature N/A *p Time Range N/A TEN 51LE TEST Specknen Olmenolone (INJ Ultknese Unit Cherasser of Feeure , Ultkneen Total l No. Fle. No. Width Thiekness AreellN.2I Load Lb. Stroes pel And Locetion _1_ OW-462.1(c) .510 .184 . 094 6.786 72.191 Weld Metal 2 QW-462.1(c) .514 .171 . 088 _ 6.174 70.159 Base Metal GuloEO eEND TESTS Remalt Ramsit No. Fle. Ne. Type No. Fig. No. Type 1 QW-462. 3 (a) FB Satisfactory 3 QW-462.3 (a) RB Satisfactory 2 QW-462.3(a) FB Satisfactory 4__, QW-462.3(a) RB Satisfactory Weider's Name Martin Sopchak S.S. No. 456-40-9922 Who by virtue of these tests meets welder performance requirements. Laboratory Test No. 77-308 Test Conducted by B&R Materials Engineering Lab. Address: 3100 Cinton Drive, Houston, Texas per G. E. Dawson geto December 2, 1977 We certify that the statements in this record are correct and that the test welds were prepared, welded and tested in accordarwe with the requirements of Section IX of the ASME Code. Signed RP OWN & ROOT. INC. (Manufacturer ! os,e 4 3 - 77 ,y 8.8 ~ - N

C%% W% 'h 4

,1-U. S. NUCLEAR REGULATORY COMMISSION REGION IV Investigation No.       50-445/81-12

, 50-446/mi-A4 Docket Nos. 50-445; 50-446 Licensee: Texas Utilities Generating Company I Facility: Comanche Peak, Units 1 and 2 Investigation at: Glen Rose, Sommervell County, Texas Investigation conducted: August 7, October 8-24, and November 23-24, 1981 Investigators: Q'S , LSA Je , b ~ e.. e- C D. D. Driskill, Investigator, Investigation and Date Enforcement Staff M 4 -T V R. K. Herr, InvestigatdY, Investigation and Date Enforcement Staff Reviewed by: =c - I8L l Date l E.IEnfor ement StaffH. Johnson, Director, Investigation and Approved by: - l' O

  • JA E. Gag /11ardo, Director, Division of Resident, Date
,                                      Reactor Project and Engineering Program l

l i

              ,_ONUb'M [h p /XV b

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.. . .  :. . - . ~
                                                                                                        .w.w.                        -         -
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i . 2 l Summary: l Investigation co6 ducted on August 7, October 8-24, and November 23-24, 1981 (Report No. 50-445/81-12; 50-446/81-12) Areas Investigated: . , Individual A alleged that improper welding techniques have been utilized on some pipe supports; holes drilled in various components are illegally plugged; some hilti bolt QC inspectors do not conduct their inspections in compliance with procedures; there is a lack of control on a substance called Torque Seal (used to ensure integrity of inspected hilti bolts); and a hole in a concrete floor was not reported to QC, as required, prior to repair. This investigation involved 48 hours by two NRC investigators and one NRC inspector. , Results: Investigation of the above identified allegations disclosed no evidence support-ing the claims of Individual A. Numerous interviews of Comanche Peak Steam , Electric Station (CPSES) construction personnel, Quality Control Inspectors and Craft Supervisors were conducted, in addition to inspections of areas identified by Individual A which allegedly exemplified his claims. 4 e i 1 i i i f i i

      '                                                   3 El   Q     $ /-l Z fo)

INTRODUCTION a Comanche Peak Steam Electric Station, Units 1 and 2, are under construction in Sommerve11 County, Texas, near the town of Glen Rose, Texas. Texas Utilites Generating Company (TUGCO) is the construction permit holder with Brown and Root, Inc. (B&R), as the constructor and Gibbs and Hill, Inc. (G&H), as the architect / engineer. . REASON FOR INVESTIGATION On July 21, 1981, Individual A telephonically contacted the NRC Region IV Duty Officer and alleged that defects existed in pipe welds within the CPSES Auxiliary Building. Individual A provided no additional information and agreed to be personally interviewed at a later date.

SUMMARY

OF FACTS On August 7, 1981, Individual A was interviewed regarding his concerns related to construction activities at CPSES. During this interview, Individual A

identified the following matters as having potential, adverse safety signifi-cance:

p h'7 . Numerous pipe supports were fabricated utilizing weave welds which are prohibited by procedure. j _ l 2. Holes are drilled in various types of pipe supports, cable tray supports, ! and plates, and when, on occasion, they are found to have been drilled in the incorrect location the holes are filled, utilizing illegal plug welds.

3. There is a lack of control on a product called Torque Seal which is used on hilti bolts, once they have been inspected and torqued. This lack of control could lead to a questionable integrity of bolts which are marked with this substance.
4. / Some hilti bolt QC inspectors dd not properly ensure that bolts are V correctly installed and torqued prior to documenting their satisfactory l

l installation. l S. - In November 1980, the removal of a hilti bolt from the floor in the Safeguards Building resulted in a cone-shaped section of concrete being I removed, which extended through the floor. A general foreman and foreman I had this hole repaired without properly notifying the QC Department.

6. Welders are not keeping their rod cans plugged in during the work day, s

(During a subsequent interview of Individual A, he withd.ew this allega-tion, stating the problem had been corrected.)

1 l l

                                                         .4 l
1. Persons Contacted  ;

Licensee Emoloyees 4

                     *R. G. Tolson, Site QA Supervisor, TUGC0
                     *J. T. Merritt, Manager, E&C, TUCI Other Persons Contacted Individual A through L
  • Denotes those attending exit interview.
2. .Investication of Allegation Allegation No. 1 byb3 umerous pipe supports were fabricated utilizing weave welds which are prohibited by procedure. ,
Investigative Findings v On September 8, 1981, Individual A was interviewed concerning his safety-
                                                                  ~

related concerns at CPSES. Individual A stated that during his employment at CPSES he became personally aware that numerous pipe hangers were fabri-cated utilizing weave welds. He stated that according to his instructions weave welding was not to be used on any jobs at the site. He additionally stated that weave welding violates written procedures at the site, as he knew them. Individual A stated that numerous examples of weave welds on pipe supports could be found in the South Yard Tunnel, unless the surfaces of the welds were ground off and the welds were capped. Individual A identified three welders whom he believed would corroborate this allega-tion. Individual A went on to state that " literally thousands of weaved i welds exist at various locations on the site." He stated that many of l these have had the top surface of the weld ground off and the weld capped l with the required stringer bead. Individual A identified five additional , welders whom he stated were aware of this practice. 19 i I (

                                                                             .                  *Y

_ w

   ,-                                                                        5 Interview of B&R Employees On September 8, 1981, Indiviudal B, a Brown & Root Mechanical Quality Control inspector at CPSES, was interviewed regarding the use of weave welds. Indiviudual B stated that weave welds are used in some instances.

Individual B recalled one occasion when a weave weld was noted during an inspection, but was subsequently ground out and correctly rewelded when the appropriate supervisors were notified. On September 16, 1981, Individuals C, D, E, F, and G, all B&R structural

                \),jf*k     welders at CPSES, were interviewed regarding the use of weave welds. All agreed that weave welds were not authorized for use at CPSES.                    Individuals l                 C, 0, and E stated that they had observed inexperienced welders use weave welds, but that these were always ground out and rewelded when identified.

Individuals F and G stated they had never observed weave welds used at CPSES. None of these individuals were aware of the existence of any components containing weave welds which were not properly repaired. Examination of South Yard Tunnel Hanger Welds On September 10, 1981, a visual examination of the numerous pipe sup orts (hangers) located in the CPSES, Unit 1, South Yard Tunnel, was conducted by Mr. Robert Taylor, Resident Reactor Inspector, NRC, and reporting investi-gator. It was noted that all of the welds on these pipe supports were the approved stringer bead type welds and no evidence of griding was apparent. Some welds did exhibit evidence of grinding, but had weld characteristics which made it possible to identify the type weld used as stringer beads. No evidence was found to support Individual A's contention that weave welds were used in the South Yard Tunnel. Allegation No. 2 Holes are drilled in various types of pipe supports, cable tray supports, and plates, and when, on occasion, they are found to have been drilled in the incorrect location the holes are filled, utilizing an illegal plug l weld. l ! Investigative Findings On September 8, 1981, Individual A was interviewed and stated that holes are drilled in pipe supports and cable tray supports to facilitate bolting them in place. He stated that on occasions when it is determined that the hole was drilled in the incorrect location, it is filled in l utilizing a plug weld. He stated that another hole is then drilled in ( the proper location on the component. Individual A stated he had the impression, based on comments made by various supervisors, that plug welding was not an accepted practice. i i

 \

9

            ^     - - - -
                                                                  .6 Interview o'f B&R Welders On September 16, 1981, Individuals C, D, and E were interviewed regarding the use of plug welds. Each stated they had repaired holes in various

! components utilizing plug welds on numerous occasions in the past. l Individuals F and G stated they had never been involved with plug welding, and both stated they understood that it was not an authorized practice. Interview of B&R OC Irioectors , On September 15, 1981, Individuals H, I, and J were interviewed and stated they have observed on numerous occasions holes which were filled, utilizing

       ,                      the plug welding technique. Each stated a QC inspector is required to
<      ,                       inspect the plug welding of holes (which is authorized by procedure) to determine if it is done properly and does not violate hilti bolt spacing j                              requirements.

I Allegation No. 3 *

       ,                      There is a lack of control on a product called Torque Seal which is used on hilti bolts once they have been torqued and inspected. This lack of

( control could lead to the questionable integrity of bolts which are marked' t with this substance. t . . - l Investigative Findings On September 8, 1981, Individual A stated he was concerned about the j lack of control of the product Torque Seal, which he stated was placed on a hilti bolt after it had been torqued and verified by a QC inspector. I He stated QC personnel are the only personnel onsite who are authorized to possess Torque Seal, and possession of Torque Seal by a member of craft i is grounds for dismissal. He stated that he knows that Torque Seal is ! occasionally in the possession of craft personnel and that they use it. ! Individual A explained that when a hanger is installed using hilti bolts, a hilti bolt QC inspector is supposed to verify the torquing procedures. ! He stated this inspector will then put Torque Seal on the bolt to ensure l that it is not moved. He stated that when a QC inspector does a final QC l inspection, at a later date, of the hanger he/she checks to ensure that I the Torque Seal has not been broken. Individual A stated he is personally aware that anchor bolts are moved and craft personnel replace the Torque Seal, therefore, the integrity of the Torque Seal is questionable. Indi-vidual A was unable to identify any personnel at CPSES who could provide additional information concerning this allegation. Interviews of B&R Quality Control Insoector , On September 15, 1981, Individuals H, I, J, and K were interviewed regarding i the misuse of Torque Seal. Individual H stated he has never observed any problem relating to the use of Torque Seal, nor has he ever observed craft i

       . , _ ._ _ _ _ .. _ .- . _ . _ .._. _ ... _.__ _ _ ... _ . . _ . _ _ .                                        . _ . ~ _ _ _ _   ._ _._

y i

personnel in possession of the product. Individual I stated that there
,                                                             have been several occasions when he has found hilti bolts containing Torque i                                                             Seal, however, no documentation existed relating to its receiving the

, required inspection. Individual I stated that on these occasions the hilti bolt was retorqued and sealed prior tu the appropriate documentation i being prepared. Individual J recalled two occasions when he was given tubes of Torque Seal by craft members. He stated he assumed that it had

been dropped by a QC inspector and the craft member was turning it in.

l Individual J stated he had once heard an unsubstantiated rumor that craft

,                                                             personnel used Torduei   Seal, but he' had no information which would substantiate this rumor. Individual K was aware of no misuse or impro-priety concerning Torque Seal.

l Interviews of B&R Welders ) On September 16, 1981, Individuals C, D, E, F, and G were interviewed. ! Individuals C, E, F, and G stated they were not aware of any craft per-sonnel being in posussion of Torque Seal, nor had they heard rumors *that craft personnel had utilized the' substance. Individual G stated he has,

on several occasions, observed pipe f.itters with Torque Seal; however, l he did not know what they had done with it. Individual G also stated
that he has, on several occasions, found empty Torque Seal tubes lying on ~

the floor at the site. Allegation No. 4 l ! Some hilti bolt QC inspectors do not properly ensure that bolts are correctly installed and torqued prior to documenting their satisfactory installation. l- Investicative Findings On September 8, 1981, Individual A was interviewed and stated that some hilti bolt QC inspectors do not always perform a proper inspection of * ! hilti bolts subsequent to their installation. He stated that, in many cases, j these inspectors just give the Torque Seal to the pipefitter to put on the bolt without their conducting the inspection, in the required manner. He stated their procedures require that they (the QC inspectors) visually l inspect the torque wrench for proper calibration dates, and that they l document the numbei of the wrench on their inspection reports. He stated they also must watch the torquing and verify that it is done properly. He stated they are then required to apply Torque Seal upon satisfactory l completion of these steps. i Interview of B&R QC Personnel On September 15, 1981, Individuals H, I, J, and L were interviewed regarding ,

hilti bolt QC inspection practices. None of these QC personnel were aware
of any improprieties concerning the inspection of hilti bolt installation.

l

i .

                                                             .g

~ Individual I specifically stated that all the QC inspectors do very good work and have no objections to climbing to difficult areas to ensure that hilti bolts ~are properly installed. Interview of B&R Craft Personnel

On September 16, 1981, Individuals C, D, E, F, and G, all B&R structural

! welders, were. interviewed. Individuals C, D, E, and G each stated that the hilti bolt QC inspection personnel generally always do a good job in their inspections.of hilti bolt installation. Individuals C, D, E, and F ~ each stated that occasionally some inspectors will not clie.b to a difficult area to conduct a closeup inspection, but will watch from a , distance and accept the hilti bolt installer's word that the torquing was ! completed properly. (Each stated this ha pens on a very infrequent i basis.) These individuals also stated that on many of these occasions an j adequate inspection can be done from a distance away from the torquing i operation, explaining that the clicking of the torque wrench can be heard and that the operation can be observed without the inspector "looking over your shoulder." Individual F stated he was not aware of any i hilti bolt QC personnel violating the required inspection criteria.

  • i Allegation No. 5 '

4 In November 1980, the removal of a hilti bolt from the floor at the 852

15. vel of the Safeguards Building resulted in a cone-shaped section of concrete being removed, which, extended through the floor. A general foreman and foreman had this hole repaired without properly notifying the

! QC Department. Investigative Findings On September 8,1981, Individual A was interviewed and stated that in i about November 1980, he had been instructed to remove a hilti bolt from the l floor on the 852 level, Safeguards Building. He stated that when the I hilti bolt was removed, an approximately 14-inch diameter section of j concrete broke loose, and was subsequently removed from the floor. He

stated the hole was cone-shaped and that it extended all the way through

! the floor. Individual A stated he apprised his foreman regarding what had

happened, and that the foreman and general foreman had later advised him to

[ utilize glue and grout to fill in the hole and several other small holes i which were in the area. Individual A stated that while in the process of

grouting the hole, he had been removed from the job, and it had been

! covered with plywood in order that QC personnel would not see it. ! Individual A stated the hole was later repaired by other personnel and j that the QC Department was never apprised of this incident,'as required. Examination of Identified Area t On' September 10, 1981, an examination of the alleged patch in the concrete ? floor at the 852 area of the CPSES Safeguards Building was conducted by

Mr. Robert Taylor and reporting investigator. As stated by Individual A j -
                                                          .g an area on the floor, adjacent to pipe support No. cc-1-137-700-E63R, was found to be discolored .nd gave the appearance of having been patched.

~; ' Subsequent to this examination, Mr. Taylor examined the ceiling of the area below this alleged patch and found that no discoloration or evidence of a patch was present. i Other Investicative Aspects j On September 10, 1981, Mr. Robert Berry of B&R QC instrumentation, and formerly a concrete Quality Control Inspector, was contacted and agreed to research the CPSES records to determine, if possible, what documentation was on file concerning the alleged patch. Subsequently, Mr. Berry advised 4; Mr. Taylor that no NCR or other documentation was on file which would ! confirm that the identified area was a patch. Additionally, Mr. Berry ! advised that he had personally conducted a test on the discolored area, i which consisted of putting water on the discolored area and removing the smooth surface of the concrete. He stated this exposed aggregate (a

 ;                   gravel substance found in the concrete used for the original pour)

I would not have existed had the floor been patched with " dry pack" (the 4 . grout-like substance normally used in patching concrete which does not contain aggregate). Mr. Berry stated this finding would lead him to the conclusion that what appeared to be a patch was only an area where the !

 ,                   original surface sheen had been "spaled off." (Investigator Note: Mr.

Taylor agreed with the assumption presented by Berry based on the facts j available. Further interviews regarding this matter were not possible due to the fact that all persons, identified by Individual A as having know- - ledge of this matter, were found to have terminated their employment with Brown and Root. Lastly, the safety-related significance of this > alleged problem was nonexistent.)

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~ MYMN Post Office Box 1001, Glen Rose, Texas 76043 r,,,, w nm BRF #11286 November 7,1983 Mr. J.T. Merritt, Jr.  ! Texas Utilities Services, Inc. ) r; P.O. Box 1002 1 I

     !!    Glen Rose, Texas 76043                                                                         ,

h  !

t Texas Utilities Services, Inc.

l Comanche Peak Steam Electric Station l Approval of Welding Procedure Specification 1

Dear Mr. Merritt:

Attached is a copy of Welding Procedure Specificatio WP 0, Rev. 7 for review and approval by Texas Utilities Services, Inc. {MNs j, This Welding Procedure Specification is to be used in conjunction with the following Brown & Root Specifications: CP-CPM 6.9 WES-031 Please review / approve subject procedure at your earliest convenience. Very truly yours, BROWN & ROOT, INC. l ' I O.C. Frankum Project Manager DCF/W J /tln APPROVED: Attachment cc: J.T. Merritt ARMS (0) , s J. Keller r--

                                                                 / (T.' M9(ritt, Jr.             Date Engr. & Const. Mgr.

_ _ F0iA-85-59 mes

                                        .       .- .    . ~ . . .       -      -

Douun& Root.kL INTEROFFICE MEMO IM - 26386 November 7, 1983 TO: G.R. Purdy FROM: W.E. Baker

SUBJECT:

Approval of Welding Procedure Attached is a copy of Welding Procedure Specification WPS 11020, Rev. 7 for your review and approval. This Welding Procedure Specification is to be used in conjunction with the following Brown & Root Specifications: CP-CPM 6.9 WES-031 Please review / approve subject procedure at your earliest convenience. i -

                                                                          >> f A l a W.E. Saker Sr. Project Welding Engineer f

APPF0VED: si WEB /J2H/ tin Rfl J gSD.PrMect QA Manapr nhlin Data cc: File es,$ S $ 9

HOUSTON, TEXAS

                                                                                                                                                           ~

M 11020 WELDING PROCEDURE SPECIFICATION CHANGE NOTICE CURRENT REVISIONS ARE INDICATED BY CHANGE BARS. REV. DATE ORIGINATOR 1 6-4-73

3. Bronicki k VAh69.

O

                                                                                                                                                                     . E # 6u Ma, L _

2 10-28-78 J. Bronicki ( 3 3-30-79 J. Bronicki /ci # & # # e> 6m 4 10-12-79 J. Bronicki f #' //m # 1 n W 5 3-19-80 T. T. Ph4114n= 4'.R O JJa_-1 1 6 2-17-82 W.E. Baker ///.hs-M4A 7 1 1-7-R '4 3.E. Ilite #[ // h_/ REVISION NO. DESCRIBE THE CHANGE l 1 Revised joint details and bead widths. 2 Deleted reference to travel speeds. 3 Recyped on new form. Added the following information: ( fillet veld thickness and diameter, electrode - flux classification, preheat maintenance, joint description, trailing shielding gas, tungsten size and type, bead type, . initial ar.d interpass cleaning, back gouging method, oscillation and root spacing. Noted PQR re ' vision. Adjusted amparage and voltage ranges.

4. Added pYehea". maintenance, peening, cup size range, root spacing and notes 6 and 7. Revised fillet veld thickness ranges. Noted PQR revision. Added layer thickness limitation. ,

l 5 Revised to correct white-outs, minor typographical errors, add PQR 0101AA109 Rev. 5 and Note: i "COMPLIIS to 1974 EDITION, S74 & W74 ADDENDA" and j signature, date line. 6 Changed PQR designation to allow increase in base metal qualification to 1.00" maximum thickness. 7 Reinstated PQR 0101AA109 Rev.5 to lower thickness range from .187" to .062". Added statement that non-metallic or nonfusing metal retainers not allowed. Incorporated ICN. I

  • REVISIONS MUST BE APPROVED BY THE MANAGER OF MATERIALS ENGINEERING OR HIS DESIGNEE i .*
  . .                                                              ...z-. -                 .                           :.              - --

2-was.cssso pnocsouna no. I Bn:mn&Rootsince ._ GD "."c.I7 pass 1 ost 2 WgtogNG CODE i SUPPORTING POR(St

                                                                                                                      .           l                0101AA127 Rev. 0 WELDING PftOC                               d               ,I               0101AA109 Rev. 5 sectIQm ix FNAllHTDin lier nw                              U v

WELDING PROCIE(ISI 1 Gas Tunasten A75 " "M" d ua W E" EI

2. N/A Tyyg N/A
  • POSTWELD MEAT TREATMENT IQW-407)

SASE METALS IQW-.403 j P No I Gr.No..ll2 to P No I N.No.182 Type N/A ) Thiekness Rang, .062 thru 1.00 IN. Temperseure N/A ep , Pipe Dia. Rang, Unlimited IN. ' Time Range N/A . I Range for Pillet.Thk. 3/4" ** Da Uniimited IN.

  • Not to be used for materials with mnre than .30% carbnn. GAS (OW 4(2)

PILLER METALS (OW-404) Shielsling Gas 1. Arcon F No.1. 6 2. N/A Pwoont Casnp. 100 A No.1. I 2. N/A ShiaWing Gas Plose Mme 15 CFN (min.) SFA Spes. No.1._ 5.18 2. N/A Purge Gee Arcon (5) pg., R , 5 CFN (min.) AVE Class. No.1. FD70L7 2. N/A TreHing hisisAng Gas Carneseiden N/A Sise of Elsesrede 1. N/A i N/A IN" Sime of Paler 1. 3/32. 1/8 i N/A IN. ELECTRICAL CNARACTERISTICS (QW.40el Electrosis Plus Class N/A Current 1. DCSP-Nonnulsino , N/A . Canamnates insert N/A Asnes Range 1. 50 - 150 2. N/A vests Range 1. 8' - 14 2. N/A Tunyeen Eles.Sise/ Type 1/16 - 1/8" EWTH 1 or 2 l POSITION IQW-408) TECHNIQUE (QW-4101 Weiding Position All stringer orWeeve Seed 1 17.rinoer 2. N/A l Wedding hw'n Unward Seed Wiskh* See Page 2 Ortfiss er Ges Cup Size I/4 - I/2, IN. PREHEAT (QW-408) laitial and Interpens cieening: Weiding surfesos shall he wire brushed Prehest Temp. 60 *F O N or yound a required to remove slag, assie or other eentamenents. Intemees . Temp. Rangs 60 - 475 *F Method of back gauging Grind - Prehest Maint. N/A *p Oegasoden 1 N/A , N/A IN. I JOINT DESIGN (QW-402) Centest Tube to work distenes N/A IN. Groove Design Sinole V Multiple er Single Layer 1. 80th JointType Og Yet Cl N/A gg N/A (Per Side) i N/A S Med T N/A Multig e g or eingi, eggety. ages Si nal e nmtagicnrnnnrneinnmetal N/A Treved speed (Rangel 1. 1.0 - 2.8 2. Ipg I retainers not allowed. Peeninr Not Allowed REMARKS ** 1/2" maximum throat thickness for ANSI B31.1 when welding to a pressure part. Prior to the start of welding, the exiting gas shall be checked for oxygen content. It must be 2% or lower before welding can contnence. Maintain purge for at least l two layers (f.e. root and one fill).. l PR RATION A TE dikVAL /k7/n Pen, c des. ASME Section III, ANSI B31.1 [/ ff y.ft p,g CPSES l fNW'N"'3')""' e ,ense e nMe Je. No. en 01,2

                                                                                                                                                                                    s6a m s m ocso m s no.

WELDING TECHNIQUE SHEET Psec. I estou,1&2 TO P'peo. I esecur 1&2 THK.RAf0GE .062 - 1.00 us. pasa 2 w 2 N # 8"'*"" "'" nooT opsuuss ca l/16-3/16, m, i

am N/A _ ges, i

S ' i W///##%R i LwwwhA%W l IV///////Ah N***" VA A 7

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1ssLDise$ PaftAtaETastS oggggggg VALUES Amt MINildWM peLLan nortAL ens eLactnicALnaTA (6) TnAVat - ***"-

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) LAvue g ,,,3 m m PLosenATderes Tvras seeista pumas 'oLAm. Anspanaos nassos woLTs massoa

                                                                                                                                                                                                              ,9 ,

en; 1-2 GTA or 3/32 ER705-2 Argon 15 5 DCSP 50-150 8-14 1-2.8 3/8 i 8-14 1-2.8 3/8 ) GTA 1/8 ER705-2 Argon 15 5 DCSP 50-150 i 3& GTA 3/32 ER705-2 Argon 15 N/A DCSP 50-150 8-14 1-2.8 3/8 on GTA 1/8 ER705-2 Argon 15 N/A DCSP 50-150 8-14 1-2.8 3/S Maximum depot it thickness of iny single layer st all not exceed 5/16". I pggageno Not Allowed 3 PRSMsAT TEMP. 60 e, esaaJ gae nousingingynoo Grind j essTarv ass T ese. 60 - 475 ey N/A coseTACT Twat To suont Dest. 3 j Pn8MEAf tSafsff. N/ onerscs on cupssrs 1/4 - 1/2 J, wmastau stact.siss a m 6- 8 "- sustomsomosmassoon Uowarri

                                                                                                                                                                                                                   ~

gt r2 m stn ucteoses 9 b 1. Preheat and interpa'ss temperature (above 150*F) shall be checked using j temperature indicating crayons or an approved equal.

2. Tack welding shall employ the parameters of the root pass.
3. Tack welds shall be complete fusion; the starts and stops shall bit tapered
by grinding so the initial pass can pmperly consume the tack.
4. All welding shall utilize stringer beads.
5. Purge may be deleted for socket welds or when specified by the Project Welding

[ 5 Engineer. . 6. Non-pulsing mode.

7. Variation in the joint geometries shown above is permitted provided the joint j is single welded or double welded and the root spacing is maintained within i the specified tolerances.

4 i i 1 i k ..

C00E g Houston.TEXA3 0101AA127 Dete 2-16-82 weiding Procedure Soecification No Revisions Gas Tungsten Arc Welding TYPE Manual 1. CELDING PROCESS (ES) N/A TYPE N/A 2. POSTWELD HEAT T REATMENT (OW-407) 8ASE METALS (QW-403) N/A Gr. No. 1 to P No. 1 Gr. No. 2 Type P No. 1 N/A *F Th ckness Racge .187 - 8.00 ** IN. Temperature Unlimited Time Range N/A Pipe Dia. Many

                                  ** Use 1 1/2" clate for testina materini.

GAS (QW 408) Shielding Gas 1. Argon FILLER METgLS (OW-404) N/A Percent Comp. 100% F No.1. 2. 3 N/A Shielding Gas Flow Mate 15 CFH A No.1. 2. N/A 5.18 2.N/A Purge Gas N/A Flow Rate CFH SFA Spec. No.1. N/A AWS Class No.1. ER70S-2 2.N/A T railing Shielding Gas Composition 2.N/A IN. Sue of Electrode 1. N/A Site of Filler 1. 3/32-1/8" 2.N/A IN. ELECTRICAL CH AR ACTERISTICS (OW-4091 DCSP-nonnulaimr ,2, M/A Electrode - Fium Class N/A Current 1. N/A Amps Range 1. 50 - 200 2. M/A Consumab e insert Volts Range 1. O ~ 10 2. N/A Tungsten Elec. Size / Type 3/32.1/8 EWTH-1 or 2 POSITION (QW-405) TECHNIQUE (QW 410) 3G Both 2 N/A Weiding Position Strinyt or Weeve Beag 1. Upward 5/8' 2. N/A IN. (Max.) Welding Progression Seed Width 1

2. N/A IN.

Orifice or Gen Cuo Site 1_1/2" Initial and interpass cleaning: Welding surf aces shall be wire brushed PR EH E AT (QW-406) Prea setTemo 60 op gg,n.) or ground as required to remove slag. scale or other contaminants. 60 - 500 *F Method of back gouging N/A Intercess . Temp. Rany N/A *p Prehest Maint 2, N/A IN. Uscillation 1. N/A ! N/A IN. l JOINT DESIGN (QW-402) Contact Tube to work distance l Single V Multiple or Single Layer 1. Multiole Groove Desig, N/A Joint Type 08 Yes Cl N/A 33 N/A (Per Sidel 2. Si"RI' Seeking Mat' Type N/A Multiple or single electrodes

                                                                                                                  .5   -          5.0                               2. N/A             IPp/

Trevel Soeed (Rangel*1. Peening Not allowed Sketch / Comments I

1. Maximum thickness of any single layer shall not exceed 5/16".

l

2. Deposit a minimum of 3/4" to a maximum of 1" filler metal on a test plate 1 1/2" thick.

Croove- 60' included angle.

                                                                              -         Root opening- 1/8" - 3/16" Land- 1/16" 1

Precared oy Aporowed by

              /dJ' b oA $ $U)__ Z*//a -O                                                         lN            >&$h                                                  d-/6*?2 DATE WELDING ENGINEERl4G                       DATE                                  MATERIALS ENG[EE' RING

HOUSTON. TEX As 010 27 0 i wPS No. PROCEDURE QUALIFICATION RECORD 0101AA127 0 WELDING PROCESS IES) 1, Gas Tungsten Arc Welding TYPE Manual

2. N/A TYPE N/A BASE METALS (QW-403) JOINTS (QW-402)

Meti. Spec. SA- _ 516 To SA_ 516 Groove Type or Grade 60 _ 1 70 Angle: 60* 1/16" h P No. 1 Gr. No. 1 To P No. GrNo. 2 Land: .4:7 Coupon OD N/A Thickness 2.00" IN. Hoot I , O. D. Range Ouaufied Unlimited op,ning: 1/gn ) Deposited We6d Metal Thk.1. 8125" 2._ N/A IN. B. S. Mati.: NS- (Joint Design Used) FILLER METALS (OW-404) GAS (OW-40s) - 6 2. N/A Shielding Gas Argon F . No. l . 1 N/A Flow Rate 15 CFH A No.1. 2. SF A Spec. No.1: 5.18 2.N/A Purge Gas N/A AWS cass. No.1. W O5-Z 2.N/ A F Rm N/A g N/A 2 N/A IN. i Site of Electrode 1. 3/32, 1/8" 2. N/A Site of Filler 1. IN.

?

Electrode - Flux Class. N/A Current 1. DCSP nonouisineE 2. N LECTR ICAL CHA N/A N/A Amps Range 1. 75 - 220 2. ( Consumabfe Inurt 1. Volts Rangel. 11 - II 2 N/A Trade Name N/A Tungsten , Elect. Size / Type 1/5.. mTu ? [ POSITION (QW-405) TECHNIQUE (QW-410) Welding Position 3G Stringer or Weeve Bead 1. Both 2. N/A Welding Progression Upward Beed Width 1. 3/4" 2. N/A IN.

2. N/A Orifice or Gas Cup Site 1. 1/R - 1/2" IN.

PR EHEAT (OW-406) Oscillation 1. N/A 2. N/A IN. Proheat Temp. 70 *F Mults or Single Layer 1. S'u t ein le intercess Temo. 70 - 475 *F (Per Side) 2. M. POSTWELO HEAT TREATMENT (QW-407) Multiple or Single Electrodes M"? la Type N/A Travel Speed Range 1. 1.04 - 2.80 2. N/A gpy h Temperature N/A 'F Peening Moe milowed Tims Range N/A Backgouging method N/A [

$                                                                                                     TENSILE TEST Scotwnen                    Dimoneions (IN.)                                  Ultimsee Totmi               Ultimses Unit                  Charetter of Failure No.                            WW1h                 Theckness A#**(iN' I        Lead Lb.                   Street 988                        And Losetion F 4 No.

_,1_ OW462.1(a) .878 1.002 .880 57.410 65.239 Ductile-Gr.60 B/M 2 QW462.1(a) .870 1.001 .871 59,440 68,243 Ductile-Gr.60 B/M l GUIDEO O ENo TESTS Rensit Reasit No. F ee. N o. Type No. F4 No. Tyee 1 QW462.2(a) Side Satisfactory 3 QW462.2(a) Side Satisfactory

2 QW462.2(a) Side Satisfactory 4 QW462.2(a) Side Satisfactory Weider's Name Martin Sopchak S.S. No. 456-40-9922 Laborotory Test No. 82-8 l Test Conducted by B&R Materials Engineering Lab. Address
3100 Cinton Drive. Houston. Texas per Josaf Bronicki Date Feb. 2,1982 j We certify that the statements in this record are correct and that the test welds were prepared welded and tested in occordance with the requirements of Section IX of the ASME Code.

] 1 Signed BROWN & ROOT. INC. (Manufacturer) Date M-M~N sy U - -. -> > E . t- ~ . _ . . . . _ _ ._ _.- _ _ _ . . . _ _ . , _ _ , _ _ _ _ _ . _ , , _ _ _ _ _ _ _ , _ , _ _ _

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

l

 '                                                                                                                                                         0101AA127            l houston. TEXAS          _

Joe No. SUPPLEMENTAL TF.ST RESULTS CHARPY "V" NOTCH TESTS (PER ASTM A370) SPECTMEN SIZE: loan x 10mm . TEST TEMPERATURE AND MEDIUM: +30F. Dry ice and alcohol THERMOMETER NO. 044 SPECIMEN ENERGY LATERAL EXPANSION PERCENT NO. (FT. LBS.) (IN MILS) SHEAR Wald Metal W-1 90 82 80 W-2 136 83 80 W-3 113 85 70 i Base Metal . Grade 70 . BM-1 68 56 70 BM-2 92 63 80 BM-3 62 50 70 l Heat Affected f Zone-Grade 70 HAZ-1 119 77 90 HAZ-2 89 81 80 HAZ-3 87 70 80 . Base Metal Grade 60 BM-1 196 Incomplete fracture Not recordable l j BM-2 181 Incomplete fracture Not recordable EM-3 225 Incomplete fracture Not recordable I Heat Affected l Zone-Grade 60 i HAZ-1 123 89 80 l BAZ-2 122 83 90 ! HAZ-3 121 85 80 l Test conducted by B&R Materials Engineering Lab. Lab No. 82-2 Address: 31ginggigHouston,Tenas 2-2-82 Per Date j l l We certify that the statements in this record are correct and that the test wolds were propered, welded and tested l in accordance with the above listed POM and per requirements of the rwted code / standard (s). l Brown & Root, Inc. i w Date 2-16-82 gj j '_ *p G

!g I l -= . MMN s.oueroes.rox.s h 8'* '

  • Weiding Procedure Spesinseuen No 0101AA109 Da 1-19-77 Ra'i- 5 3-14-80 jj Gas Tunasten Arc TYPE Maan=1 .
     }             WELDING PROCESS {ESI                              1

,! 2. W/A TYPE N/A 1 POSTWELD HEAT TREATMENT (OW-407) e BASE METALS (QW-403) P No. 1 Gr.No. I te P No._3 Gr. No. 1 Type N/A

                                                 .062 thru .688                             IN. Temperature              N/A                                                  'F l :1                 Thickness Rany N/A

! Pipe Dia. Many Un14=* tad Time Range i i _ .-. GAS (QW-40BI j FILLER METALS (OW-404) Shielding Gas 1. Armen l! F No.1. A No.1 0 1 2. 2. N/A N/A Percent Comp.

                                                                                                    ~Sh 100 m iding Gas Flow Rose 15 Kin.                                           CFH l

SFA Spec. No.1. 5.18 2.W/A Purge Gas Armon plow Rase 7 Min. CFH AWS Class. No.1. E705-2 2.N/A Trelling Shielding Gas Composiden N/A , l I Siae of Electrode 1. N/A 2 N/A IN. Siae of Filter 1. 3/32. 1/8 2.N/A IN. ELECTRICAL CHARACTERISTICS (OW-4001

                                                                                                                              "                 2. M/A Electrade - Flus Class N/A                                                       Current 1.

' ' Consumstpie insert N/A Amos Range 1. 80-110 2. M/A II"IA 2. EIA Voim Range 1. 8 ' Tungsun Elec. Sdype 1/16"-1/ 8"/ttirh-1 nei ! POSITION (OW-406) TECHNIQUE (QW-410) Weiding Poetion 6C Stringer or Weeve Seell 1 E*F4""*' 2 IIA i i Welding Progression Unitard Seed Wide 1. J/8 Maz.3, N/A IN.

!                                                                                                    Orifice or Gas Cup Sise 1 1/4-1/2             2.       W/A                     IN.

! PR EME AT (QW-408) Initial and interpass stemning: Welding surfases shall he wire trushed , Preheat Temp. 60 *F (Min.) or yound as required to remeye slag, assie or other sentamments. interpass . Tomo. Range 60-150 *P Method of heck gauging WIA l Prehest Maint. 60 l Uscillation 1. N/A 2. N/A IN. l JOINT DESIGN (QW-402) Contest Tute to work distenes N/A IN. Groove Design #4a*1a Y Multiple or Single Layer 1. Multinle {

!                  Joint Type 08 Ya*                                 Cl M/A        SS 8/A           (per Sidel                     2.         3/A Baskig Moti Type M/A                                                             Multiple of single electrodet             Sintle l

l Trevel Speed (Range) 1. *0-l*O 2. N/A lpg i p.,n;ng Not Allowed ( Sketch / Comments 4 l l I Bevel: 37-1/2*

  • 2-1/2*
Land
3/32" + 0, -1/32' I P ared Aporowed the gh. / 3-14-80 t //.ig 3-14-80 WELDING ENGINEERING ( DATE MATERIALS ENGINEERING DATE 5_.-_. .
                                                                                                                                                                                                                      )

4 f t, MousTom.Tuxas ups me. 0 09 5

!C                                             PROCEDURE QUALIFICATION RECORD                                                                                           0101 AA109                       5 J

j WELDING PROCESS (ESI g. Gas Tunasten Arc TYPE Manual i

  • 2_ N/A '

TYPE N/A l k SASE METALS (Qw-403) JOINT 5 (QW-402) l 1

       ,.              Matt. Spec. SA- 106                              To SA-             106                   Groose
  • Type or Grade 3
                                                                   ~

3 73*

'                                                                                                                   Angle:

P No. __1._ Gr. No._ 1.To P No. 1 GrNo. 1 Land: 1/32" Cocoon OD 2.375 Theckness .344 IN. Root I O. D. Range QuesGod Unlimited opening une n=e. .3 Deposited Weld Metal Thk.1 3M 2. N/A IN. S. S. , t g Total Thk. Range Qualified .062 thru .688 IN. Moti.: N/A ' s Usint Deser Used) I$ FILLER METALS (QW-404) GAS (OW-40BI ! ? F. ho.1. 6 2. M/A Shiesding Gas Armen l' ' A No.1. 1 2. n/A Flow Rees 13 CFH SFA Spec No.1, L la 2.Mli Purgs Gas AN" A #$ Class. No.1. 170s- 2 2 w/A Flow Rees 7 CFH !* Size of Electrode 1.Not Recorded 2 N/A IN.

,                     size of Filler 1,           3/32. 1/8 2                   N/A                      IN. ELECTRICAL CyRACTERISTICS (QW                                     )
Electrode - Flum Class. N/A Current 1. II 2. N A Consumable Insert 1. N/A Ampe Rangel *'W 2. B/A j Vales 1- h14.4 2 N/A
 ' f                 Trade Nee                              N/A                                                 Tungmen          Sae/ Type           Wat Racorded I

l! POSITION (QW-405) sc TECHNIQUE (QW-4101 i We6 ding Position Serinyt er Weeve Seed 1 Strinner 2. N/A ' l Weiding Progression Unward Seed Width 1. 5/16 2. N/A IN. Orifies or Gas Cup Sao 1. 1/' 2_N/A IN. l PR EHEAT (QW-406) Oscalation N/A IN, , Prehest Temp. 60 'e F Multi er Single Layer 1. Multiple interness Temo. 60-550 *F (per Side) 2. N/A I POSTWELD MEAT TREATMENT (QW-407) Multiple or Single Electrodes Single l

      !              Type                           N/A                                                         Travel Speed Range 1.               .8-1.5                g, N/A                       gpg Temperature                    N/A                                                  *F Peening                                Not Used l              Time Rang,                     N/A                                                         Sackgeuging method                 N/A l .                                                                                                     TS80stLE TEST scannen                        o nmane 4:n.3                                      unkneesToese           ustamens unit                   cherusar et penure l

No. p ag. No. waeth Theehness A8 4 8 *28 Lese Lh. sees eal And lesetion

                   ;,l_     OW-462.1(c)                  .495              .223                    .1104          8.450                     76.539                 Itama Maent j                      2_ OW-46 2.1(c)                    .497              .184                    .0914          6.740                     73.741                 n==a Maesi ousoeo sewo Tests negat No                 p as. New           twee                                                                                                                   nee.st No.         F4 Na,               Type 1    OW-462.3(a)                      T3         Satistactory                                 1    OW-462.3(a)                 33._,         Satisfactory 2    OW-462.3(a)                      FB         Satisfactory                                  4   OW-462.3(a)                 RE            Satisfactorv

! Welder's Name _ Don L. Risa S.S. No. 450-04-7704 Laborotory Test No. 77"1 Test Conducted by B&R Matersis Engineering Lab. Address: 3100 Qinton Drive. Houston, Texas pe, J. M. Hale os,e January 18, 1977 We certify that the statements in this record are correct and that the test weeds were prepared, welded and tested in accordance with the requirements of Section IX of the ASME Code. I Saeed BROWN 4 ROOT. INC. (Manufecturer) Oate gy I l

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                                                        .\w, 4 9 3 C P M 6,9                sb6% ee w\% (cL.ac %)

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m e .., t . l l l s l F01A-85-59 < .. .. - . _ .-. ...- . _m_.f3

C d et*h h A W M) MI 9 h3 rva n zNs4 28 . .. _ _ i Interview of M

                                    ~

On Septenber 15, 1983, a former Brown & Root, Inc., welder l at CPSES, was interviewed by NRC Investigator H. Brooks GRIFFIN in Arlington, i Texas. W related the following four instances which he represented as ! intimidation that he had presented in his testimony before the CPSES ASLB: (1) M stated thnt in April 1981, his fererar.. W.c , g g him to substitute a scrap piece of I-beam into a hanger, and he

                          @ followed M instructions.

l l (2) pstated that in February 1980,M, a supervisor, instructed him to perfom some improper " plug welds" while he W qq --e.]......-- - i (3) Msaid that in about Septenber 1980,MM

                          % and M M , threatened 6 (a i                 (        B&R employee) and his crew (includingM with tertnination if                    /
              ,f          they did not finish welding a pipe before 5:30 p.m. @ aid

( , the pipe was completed in a hurry with many deficiencies, and he f believed the pipe was accepted by QC. (4) Msaid that in July 1981,6 his foreman, instructed him to make an improper " downhill weld" to cover a gouge in a pipe. , Msaid he was caught by his foreman showing the gouge to a OC inspector after he had refused to cover the gouge. %said he f i was terminated a few days later. i i f Mprovided the NRC with a signed, swom statement. Attachment (7), that ! identified locatiuns of the above described deficiencies.Mtecht.h.a1 concerns were forwarded to Region IV staff for evaluation. I F01A-85-59  ! ) . p11V E _

                 ..___.m.                . _ ~ _ _ _ _ _
                                          .                                    _          m          _ _ _

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  • QSQ' %Qf
                                             % b get NN March 16,1984 Mr. Bill Baker This is a listing of all Mainsteam and Feedwater Large Bore Pipe Hangers, in Unit 2 with welded attachments that might require Charpy Impact Tests.

These documentation packages have been researched and welder BNU does not appear on any of the attachment welds. FW-2-017-454-CS2K DESIGN IN PROCESS 097-434-C62R 101-409-C52K 017-438-C62K 017-444-C72K 017-446-C72K 017-700-C42K 017-701-C52R , 017-703-C62R 018-700-C52R 018-704-C62K 020-408-C52K 020-700-C52R 095-701-562K MS-2-001-412-572R 001-413-S72R 002-419-S72R 002-420-S72R 003-420-S72R 003-421-S72R 004-416-572R 004-417-S72R , FW-2-017-441-C72R INSTALLATION IN PROCESS Ol8-444-C72K 018-451-C62K 019-401-C42S 037-402-562R 095-404-C62R 095-405-C62S 095-408-C62S 095-sil-C62K 095-413-C625 097-402-S62R 097-418-C62R 097-437-C625 097-442-C625 F01A-85-59 .

f' Y Page 2 March 16,1984 FW-2-098-403-C62R INSTALLATION IN PROCESS 098-406-C62S 098-408-C625 l 098-411-C62S 099-404-C62K 102-404-C62S 103-401-562S 104-409-562R 104-410-S62R 105-406-562R 105-409-S62R 105-410-562R 105-411-562R 106-401-562R 106-410-S62R 111-402-S625 { 112-402-S625 MS-2-001-405-C72K 002-408-C72K

  • 003-405-C72K
003-407-C72K 003-409-C72K 003-410-C72K 003-414-C72K 004-407-C72K 004-409-C72K

) 073-413-552R I 073-418-C52R l 074-428-S52R ! 075-404-552R 076-406-SS2R 150-402-CS2S 150-403-C52R 150-405-C52R 150-415-CS2R 150-425-C52K 150-429-C52K 150-431-C52R 150-433-C52K 150-439-C52K i 150-441-C52K i 150-448-C52K l 150-454-C52K i 150-462-C52K i 150-467-C52R i l l

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                            . ;,.e..:,tL .P' age                                   n: s
                                      ..       . March,16,1984
                                  .                               ;,              c..-
                        .      'l
  • MS-2-151-418-C52R INSTALLATION IN PROCESS
                                      , l,                            151-437-C52R                                                                                                                                                                     .
                                      ~~

151-438-C52R 151-440-C52K 151-446-C52K 151-448-C52A 223-401-572K 240-401-572K 345-403-C52K 345-407-CS25

                                                               =

MS-2-150-404-C525 INSTALLATION COMPLETE 150-413-C52R 150-420-C52R 150-435-C52K . a 4151-411-C52R Gary Maedgen F h6 .'g i 9 s . f

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                                                    -                            Gibbs & Hill, Inc.
                                                          -                      Specification 2323-MS-100 Revision 8 July 5, 1964 Page 4-57
e. Field welds not meeting the delta-ferrite requirements shall be repaired or removed in accordance with an approved
,                          procedure.                 Repair shall tua made only upon written direction.

4.34.7 (Q) The contractor shall provide control over his welding operation to minimize sensitization of stainless steel welding. In addition to heat input and interpass temperature and other variables covered by this section, the Contractor shall be limited to two (2) repairs for each weld defect. If the defect , has not been eliminated in two (2) attempts, the contractor shall submit to the owner a procedure for further repairs and sensitization control. When a weld is completa1y removed for any' reason, the Contractor may proceed to restore the weld joint configuration and replace the weld in accordance with the approved welding procedure. I.* any weld defects are evident in the replacement weld, the Contractor shall submit to the owner a procedure for repair and sensiti=ation control to remove all such

defects. In no case shall a weld be completely removed and replaced more than twice without specific Owner approval. In no case shall a weld be removed and replaced more than twice without

, specific owner approval unless the areas adjacent to the weld j that are susceptible to sensitization are removed and documented by the Contractor. , 5 1 4.35 (Q) BRITTLE FRACTURE CONTROL FOR FERRITIC STEELS

a. Class 2 materials in the heat affected zones shall be impact tested and accepted in accordance with paragraph NC-2300 of i the ASME Code where specified. This testing shall be done in addition to any requirements of the ASME material specifications. .
b. Class 2 materials supplied to piping categories 1303 and l 2003, including all welding and bolting materials, shall be l , impact tested unless exemp. d by paragraph NC-2311 of the i

Section III code, i

c. Impact test temperatures for materials with 2 1/2-inch I

maximum thickness shall be 32 F or lower. * {. d. Impact test temperatures for Class 2 materials exceeding j 2 1/2-inch in thickness shall be developed in accordance with

paragraph NC-2332.

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, as required in NC-2200 for the tensile test specimen (a) Establish a reference temperature, RTum; this
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of maximum stress. The notch of the C, specimen (1) Determine a temperature, Tum, which is at shall be nor r.al to the surface of the material. or above the ail-ductility transition temperature by

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dropweight tests; NC-2330 TEST REQUIREMENTS AND (2) At a temperature not greater than (Tum + ACCEPTANCE STANDARDS 60 F) each specimen of the C, test (NC-2321.2) shall exhibit at least 35 mils lateral expansion and not less NC-2331 Pressure Retaining Material with 2% than 50 ft Ib absorbed energy. Retesting in ac-in. Maximuss Tm=== cordance with NC-2350 is permitted. When these Pressure; retaining material other than bolting with mqu mments am inet, Tum is the refmace temp-nominal wall thickness 2% in. and less for vessels, wat Rn tanks, piping (pipe and tubes), and material for IT - pumps, valves, and fittings with pipe connections of does not meet the specified properties, conduct additional C, tests (NC-2321.2) to determine the nominal wall thickness 2% in. and less shall be tested as required by(a)and(b) below. t*InPaatm T, at which they are met. In this case the y (a) Test three C, specimens at a temperature lower afmace temperatum RTum -, T, - 60 F.Thias the than or equal to the lowest service temperature.t All mfmnw teinperatum, RTum,is the higher of Tum - three specimens shall meet the requirements of Table and (T,, - 60 F). l (4) WlienaC, test lias not been pedwmed at NC-2331-1. (Tum + 60 F), or when the C,testat(Tuw + 60 F)w .- 3 TA8LE NC.23311 does not exhibit a mmimum of 50 ft Ib and 35 mils ~ MEOUIRED C, VALUES FOR PRESSURE lateral expansson, a temperature representing a s l ! RETAINING MATERIAL OTHER THAN minimum of 50 ft Ib and 35 mils lateral expansion i BOLTING WITH 21/2 IN. MAXIMUM may, be obtained from a full C, impact curve THICKNESS developed from the rnimmum data points of all the C, tests performed. _j.;* Y y (b) Apply the' procedures of (a) above to base material; heat affected zone and weld metal from tin W< 5/S or less No teat roquired i weld procedure qualification tests of NC-4330; and t. 4 j '*j$ 25 / the weld metalof NC 2431. - our i.112 to 21/2 ind. 40 (c) Consideration shall be given to the test temp-erature requirements of hydrostatic testing of the (b) Apply the procedures of (a) above to the base vessel (NC-6212). material; the heat affected zone and weld metal from (d) The lowest service temperature shall not be the weld procedure qualification tests of NC-4330; lower than RTum + 30 F unless a lower temperature and the weld metalof NC 2431. is justified by methods emniar to those contained in Appendix G. NC-2332 Manerials with TW=== Exceeding NC-2333 ' Bolting Materials 2% is. For bolting materials, including studs, nuts, and Pressure retmmng materials other than bolting with bolts, test three C, span =*as at a temperature no nominal wall tinckness exceeding 2% in. for vessels, higher than.the preload temperature or the lowest tanks, piping, tubes, and materials for pumps, valves service temperature, whichever is less. All three 1 and fittings with any pipe connection having nominal specimers shall meet the requirements of Table NC. wall thickness greater than 2% in. shall meet the 2333-I-requirements of (a) through (d) below. . NC-2340 NUMBER OF IMPACT TESTS ! itou,est service tamperature is the minamum tempwature of the REQUrnm

fluid rotasant by the component or. alternauvely. the calculatai NC-2341 Plates j volumetne averngs esetal temperature expected dunng nonnel
operauos whenever the pressure within the component exceeds 20 One test shall be made from each plate as heat Pw cent of the preoperational system hydrostatac test pressure. treated. Where plates are furnished in the unheat ,

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asterlat fase_tehe4_ ehalt be tested for leyest restatseos. Cherry-type specifsed . tes. set test sh4LL be la accorsease ette see appsacante eetiek as to A345 SA 370. .

2. sehjn.:t to the prestatens of paragraph 3.7.3.84) of this aposittentles. .
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4. 2." 3CN les ytre le permitted for the fattooing drip pets le the itses of

to. tic.s tud. Thu ee4a otti has cometerbered to match the end preparettees the 3C't 80 ytse )

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specitteetten 2323-es-43a

                                                                                                                                      .            se,teles 4                                                                f match 8, 9982 appeedts 9                                                            , ,

Page 27 l

                                                                                                      '                                                                                                                I, tititS_8t ERFica                                                                                         i E4159981 escasas_gtas class 2 er 3                                                                 ,

t tatlas i Pressere' 2e45 ret, mastsee Teeper4 tere 650 r , gagggIgla carben steet er asas speciftsaties listed botes for each ites. II88

  • 4* to se le* to 24*
3. and esatter size seamless Ceestreetten soselves seaetese

) 54-131 Grade 66es 34-333 Stade 6eea

 '                               Asat spee.           54-133 Grade 64 e 9                                                                    lee schedgle              168                                     12e 4                                                                                                                                                                                                                             /

i E11113sa to to 88 108 to 248 size 28 4ed esatter 3* seastees seamlese er Type Forged seamless solded , l . Bett-sold Bett-sete ~ eett-sete [ Jetet socket Welded 54-424 erede 54-428 erade l d - ASSE spec. sa-354 Gaade LF 2 5a-428 erade NFL-6 er BFL-68eB er ett-64e3 or l

    .                                                                                          SA-354 Grade LF24eD 34 350 Stade 34 350 Stade 1F2                                           j LF2                                                                         ,

6884 lb schedete 168 schedete 120 schedete See  ! sattog \  ? l Elsassa 4 to se les to 20e l ' size 28 and esatser 3* Ferged Forged Type For Jed .

  • Ferged Weld-seck eeld-seek , ,.

Julet sect et-we8Je-l Weld-esset 8 5a-554 Grade 24-358 erede 34-350 erede  ! Asas spec. sa-the acade LF 28e8 LF 2sas tr 2ses Lt 2ess 8500 lb 1588 lb ,

                      '           sattog                1549 lb                                   1584 th                                     schedele 134 Schedste 948
  • Beseed to schedete les sch*edete les
  • e e e

{ _ ' r~, 4 W 4' -  ! i sabbs a alta, see. j } spectiteatten 2333-es-43&  ; novielen e sarch e, assa j, appeedts 8 i i Page 24 !  ? 4 i i i

!                                                                     titite_atssituatie GI5995L2992     scentegt                                              q l     '

agn gas coes Class 2 er a - t I-I . I samaliass e l stas 2* and maatter i Type Forged  ! l sectet westeed Jotat  ! asas syuc. j

j .
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u,,, d c. ,s. n s l sha&R emot thee to.getroments of the , I E9dta EtlE_4Rd_stSIElE sysocificattee sheets of this appeedts. i l' , ,l sete te amaterlat fecatsbed shall be tested for tepest restatence. I Charry-type tapact test shall be in accordabce eith the I { j

                                 .syytic.able outbed to specitted la asas 34-370.                                                             !'

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    ','.          .                                         a.       2- ) NW JM N A U. S. NUCLEAR REGULATORY CGOESSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No. 50-44N79-15; 50-446/79-15 Docket No. 50-445; 50-446                                 Category A2 Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas     75201 Facility Name: Comanche' Peak, Units 1 & 2 Investigation at: Comanche Peak Steam Electric Station, Glen Rose, Texas j

Investigation conducted: May 29 through June 4, 1979

              'nspectors:                        22 -^                                        2/[79 R. G. Taylor, Reactor Resident Inspector, Project Sections    Date W          : ^ == "

W. A. Crossman, Chief, Projects Section 6/ Elf 71 Date 2 Approved: M  ;- $/Z/[7 W. A. Crossman, Chief, Projects Section Date ~ Investigation Summary: Investigation on May 29 through June 4. 1979 (Report No. 50-445/79-15: 50-466/79-15) Areas Investigated: Special investigation of allegation received regarding improper and potentially very poor welding of inter-plate sesas in the Unit 1 Refueling Pool, spent fuel pools, and transfer canal of the common facility Fuel Handling Building. The investigation involved twenty-eight inspector-hours i by the Rasctor Resident Inspector (RRI) and the Chief, Projects Section. 3 Results: The allegations were neither specifically confirmed nor refuted. l The allegations, if confirmed, would have no safety significance. No items l of noncompliance or deviations were identified. J 1 4 t t 4 s0A m& 1 AK

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1 . i

,r INTRODUCTION i

! Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 are under construction in Somervell County, Texas, near the town of Glen Rose, Texas. Temas Utilities Generating Company is the Construction Permit holder with l ! Brown and Root, Inc. as the constructor and Gibbs and Hill,.Inc. as the } Architect / Engineer. , REASON FOR THE INVESTIGATION y i The Region IV Reactor Construction and Engineering Support Branch received l a telephone call from a former CPSES employee who reported several allegations j indicating a potential breakdown in the CPSES Quality Assurance program and ! a possible threat to the health and safety of the public. The substance of

the allegations also appeared in an edition of the Fort Worth Star-Telegram published on May 30, 1979.

i i SUttlARY OF FACTS 1 ! The Region IV Reactor Construction and Engineering Support Branch received ! a telephone call on May 25, 1979, from a party who identified himself as a j former CPSES employee who had worked as a Boilermaker welder. The call was , taken jointly by the Branch Chief and the Section Chiefs of the Projects Section and the Engineering Support Section who in turn provided the infor-l mation to the assigned Resident Reactor Inspector at CPSES on May 29, 1979. l The allegations were reviewed with the alleger in an interview which took i place on May 30, 1979, at his home. Each of the following allegations relate i to welding of stainless steel liners in the Unit 1 Reactor Containment Building j or in the common Fuel Handling Building:

                                                                               ^
1. Allenation No. 1 1/

I Welding and weld repairs on the liners were difficult because water free l concreting activities had run down the leak chase channels and out past , j the backing strip into the weld area. Welds finally completed were very poor; some welds had been slugged with weld rod and others were so thin l j that if buffed a second time with 120 grit, they would not have passed PT (Penetrant Test). l ! 2. Allenation No. 2 l There are problems with the gate guide (refers to a gate in the Reactor Containment separating the refueling pool frce a small storage pool and i the transfer canal). ! 1/The statements above are the allegations as received. Clarifications obtained j ' free the alleger during the interview of May 30, 1979, are indicated by parenthesis. ! ( > f . .

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a. -The gate guide between the large and small pool was welded in the shop. When the gate guide was installed in the pit, the and bevel was cut off so it could be fit-up. When the guide was installed, it was not rebeveled and where a fillet veld of 3/8" was required, only 3/16" fillet veld was made.
b. The gats guide had to be welded to both sides of the liner. When welding the back side, the velder had to crawl down between the rebar

! to get to the weld. The position was so crowded that the welder ! could not make a good weld. Also, the welder couldn't see what he was welding very well. f c. Six inches of the chase channals were left off the gate guide and added after the gate guide was installed. The rebar was so thick j in the areas where welding was performed that "you could hardly . get your finger through, such less the welding torch." Consequently, ! the welds were not made properly. l 3. A11eastion No. 3 l Welders have no experience. They spend as much as 80 hours trying to j make a test veld. They finally learn how to make a weld that will pass , the qualifying test and then when they get into the field they don't know what they're doing. { t j 4. A11eastion No. 4 i ! There is " lots" of QC coverup. QC is " buying-off" on welds over the phone. One QC inspector bought off a seas before he ever saw the sepa and it was ! not a good weld because water was coming through while the weld was being l made. (The buy-off involved was joint preparation and cleanliness prepar-atory to welding). l.

5. Allenstion No. 5 i

! p Brown and Root is not following proe=d === in welding the liner plate. I e (The procedures referred to are welding procedures and specifically refer l to use of a down-hand welding technique being used versus the procedurally [ required up-hand technique). l 6. Alleaation No. 6 i ! Some of the top seans 18" above water level on the fuel pool had backing { strips tack welded to the liner plate. There are places where the plate

did not cover the backing strip. He would not guarantee the weld. The weld was probably 60% rust, sir, concrete, etc.

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                                 . . _                            .._ _ CONCLUSIONS Review of the CPSES Final Safety Analysis Report, Project Specifications and Engineering Drawings, as they pertain to the liner fabrication and installation, have led to the following conclusions relative to each allegation stated in the Summary of Facts above. To better understand these conclusions, the following considerations are necessary:

The liner systems are not installed to prevent or mitigate the conse-quences of any of the postulated design basis accidents, but rather are installed to prevent an excessive burden on the liquid waste collection and disposal system and to allow the wall and floor area to be more easily decontaminated after pool usage. The liners as a functioning element are, therefore, not considered safety related and are not normally included in the NRC inspection program. The liners, as passive elements and parts of the building structure, are usually classified into seismic Category I since if one or more of the liner plates were to become detached from the wall, serious damage could be done to stored fuel assemblies. The plates are, therefore, secured to the concrete supporting structure with a system of weld studs attached to the back of the plate and embedded into the concrete. The weld stud system is not a factor in these allegations. ,

1. Allenation No. 1 The RRI, based on the interview with the alleger and with other welders, has become reasonably sure that there were difficulties encountered by the welders with water, moisture and in some instances with concrete on the veld surfaces and that in some instances, the welds may not be com-pletely sound internally. These welds, however, serve no strength purpose and need only to be smooth and leak free, factors which are established by visual inspection, dye penetrant examinations, and by vacuum box tests of the joint after it is complete. The allegation, while probably true, has no safety consequence.
2. Allenations No. 2.a. b, & c These collective allegations, while probably true in a substantial sense, also have no safety consequence. The weld joints in question only need to be smooth and leak free in the case of a. and b. and leak free in the case of c. The welds do not serve to lend strength to the structure.
3. Allenation No. 3 The project specifications for all welding, including the pool liners, require that welders be qualified under the requirements of the American Society of Mechancial Engineers, Boiler and Pressure Vessel Cede, Section II or a comparable requirement such as those of the American Welding 4

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t . Society. Section IX of the ASME requires that a welder must perform .

                   .              a weld process involved and the as-welded coupon must pass specified tests uhan complete. No time limits are specified or implied as a requirement in Section IX for making the qualification test coupon weld.

The RRI has verified previously that the site welder qualification pro-gram is in full compliance with Section IX. ! 4. Allenation No. 4 l The RRI examined the circumstances surrounding the specific portion of ' i the allegation and discussed the matter with the QC inspector directly involved. It appears that this man, on occasion, was depending on the inspections performed by a fellow inspector and so recorded on the , appropriate weld data card. h joint was covered over with tape after it had been inspected for cleanliness and fit-up and the inspector re-j leased it over the phone based on the record card entries. Water in the i leak chase channels appears to have been a constant problem. h QC inspector may have made a judgement error in not re-examining the joint, l ,but not withstanding, the joint had been inspected and found satisfactory i at that time. The RRI did not investigate the alleged " lots" of QC coverup because of the lack of specifics.

5. A11eastion No. 5 As noted in the Summary of Facts, the general allegation of failing to'  !

t follow procedures was subsequently refined in the interview with the i alleger to relate specifically to an occasion where the alleger was a /8 i directed by his supervision to weld down " ' ~*he than up-hand as,,,,,, p ,u ,7c ' j required by the welding procedures. Section I O dicates that such j j a change is in the category of a no @n ... u u variable is not a prohibited change in the procedure, if recorded. It appears 4 a j that the change was not recorded. Interviews with other welders on the l J

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  • denied directing the alleger to perform out-of-procedure h RRI, there- i fore, has no mechanism by which to confirm the allegation. Again, assuming l that the alleger did weld down-hand instead of up-hand for whatever reason, l l the consequences of such an action are essentially meaningless as related J

to a weld, since such a change has no effect on the finished weld of the l type involved. . _ _ . . , _ , _

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6. A11esation No. 6 C4.~p ~, ., r t,s. see. ~rw ~7' l

o thot o rM a. 1 N particular welds '2 question are even less consequential than the other i seas welds in a functional sense. These welds, which are above the water i line in the pools, do .t need to be leak free, just smooth for the purposes i of easy decontamination. N allegation, while perhaps true, has no conse-j querce. D' I' ,

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1. Perseas Contacted A11ezer The allager, hereaf ter identified as Individual "A " is a former employee of Brown and Root, Inc. (the site general contractor). The person iden-tified himself as a former welder assigned to the millwright / boilermaker

( unit of the construction force.

     ,                         Principal Licensee Employee Site Quality Assurance Supervisor ~

Brown and Boot. Inc. Project Construction Manager M111 wright / Boilermaker Superintendent Individual "3," a welder currently working as a pipefitter but who was a Boilermaker Individual "C " a welder currently working as a pipefitter but who was a Boilermaker Individual "D," a quality control inspector who was assigned to inspection of pool liners

2. Backaround of A11ematioss Individual "A" contacted the Region IV office at approximately 9:25 a.m.

on Friday, May 25, 1979, to express concerns about the welding activities which had taken place on the spent fuel pools, cask loading pool and the transfer canal in the common Fuel Bandling Building for both Units as well as that work accomplished in the Unit i refueling pool and temporary storage pool installed in the Rasctor Containment Building. The RRI was notified of these allegations on Tuesday, May 29, 1979, (May 28 a holiday) and initiated an immediate investigation. The first point of ' contact was the licensee's site Quality Assurance supervisor who informed the. AAI that he was aware of the allegations, since his company had been apprised of them by a newspaper reporter employed by the Fort Worth Star-Telegram. The site supervisor also informed the REI that another welder. Individual "B " had enpressed similar concerns to the Project Construction Marager on May 23, 1979, ) and that concerns had been forwarded to site quality Assurance for investigation. ) The RRI was provided an informal memorandum giving the results of the investigation dated May 23, 1979. b n li R l 1 0 6= 0 sg b q _ n ,_ ' d

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t Individnal "A" also contacted the Project Construction Manager en May 24, - ._

!                                                1979, and expressed essentially the same concerns as those expressed by                                                 ,

Individnal "B" and which in turn he expressed to the Region IV office on May 25, 1979. It appears that Individual "A" and his supervision, up thronsh the Project Construction Manager, had reached a substantial point of disagreement and Individual "A" voluntarily terminated his employment i at the site as of May 24, 1979. The voluntary termination is a matter of j record in Individual "A's" employment file.

3. Investination l The RRI initiated the site phase of the investigation by extensively j reviewing the CPSES Final Safety Analysis Report in order to ascertain j

the safety classification of the various pools and pool liners involved i in the allegation and to review the functional descriptions. Reference to Section 3.2, "Classificatien of Structures, Components and Systems," in the FSAR does not indicate the liners as being safety related although f the buildings in which they exist are shown to be in seismic Category I. Paragraph 3.3.3.7.1 provided a commitment to test the liner seams via a

vacuum box for leak tightness and briefly described a leak chase system behind the liner seams. Paragraph 3.8.4.1.3 provided a brief additional l

description of the function of the liners. Figures 9.3-9 and 11.2-4 revealed that the extensive leak chase system has lead-out piping which leads to a building sump and hence into the liquid radioactive vaste ,

collection and disposal system.

j The RRI then obtained Project Specification 2323-SS-18, Revision 3,

                                                   " Stainless Steel Liners," to ascertain what requirements the design engineer i

had established for the liners. The RRI noted the following significant items from the specification: 1 - l'

s. . The design engineer invoked the general quality assurance requirements of 10 CFR 50, Appendix B on the fabrication and installation work.

I i b. The design engineer provided three full pages of detail requirements relative to the system of studs to be welded to the reverse or concrete backed side of the liners.

c. The design engineer made reference to the inter-plate seas welds only by requiring that the welding procedures and welders be qualified to ASME, Section IX. Criteria for finished welds require that, " Surfaces of all welds shall be smooth and free of any irregularities such as serracions, ridges, crevices, or pinholes which may make it subsequently difficult to achieve an effective washdown of the liner surface." Under testing the design engineer provided the following, "All seas welds shall also be tested by vacuun box for leak tightness for their entire leath." No other quality requirements were imposed on the seas welds.

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j The C I then (btained the desi S-0834

i fabries, tion and installationSI-0560, c MI-0581, a de: iga detail drawings for th .

rough Bailding h se drawings between the refueli In addition, the RRI obtainedp

  +                                                                                                                 e gate guide installed in the                           C vendor taken collectively,   ng poolshowed   and the temporaryontainment             stora
     ?                                                   would be supported by and anchhad                                                                         ge pool. des e liner          plates           andconc    thee gate g sides free           plate-to of         the plate plates and ored provid u

and to headed the gate surrounding g idby rete waL 1 1s a ve structure. e frame. studs welded e no attachment intouilding the basi t system had been designed such th tN RRI a in the "T" headed stud leak install ti only leakage of to provide disposal.might occur would a very low a resistance onbeand d that the seas welds to seismic ner s vestedwe age path for the pool water and re necessary rained to an appropriately that desiwhat gned method Region Chief in ord IV Reactor Constructio& on May 30, 1979 RRI interview in allega,tions information and received over the t ler to gain additional info c s Section g; included in this reportclarifications were ase. ephoneeach 25, 1979. on Mayon of the relative to s' had only very recently In become addition, h holding the plates in place and Individual "A" a knoted in the9 S c nowledged that he ki and disposal of any aware c o ection leakagethat poi the whi stud sted eak forsystem hchase cha !es [, The RRI interv might occur.nt for controlled collection if N'

                                    "B" onlyalso Individual                          cameon May 30,       to1979  thQA      (This     supervisor,iewed                                             Indiv      hb of the licensee's representati 1, 3 and 6, but indicated                                   e attention ve.)

a The allegations arransment of the RRI through he h dreviewed wasth allowe in detail N TA a "B" who further indicated that a he worked h dessentially "A" wereeAllegat confirmed assista h[gy had be been instructed not not no complaints in to thef Allegation l 2 a ns about lack rea and as those obtained in the intervib RRI interview b[N GEt indicated that he perhaps wa on May 31, 1979  ? ,y3<

                               "A" in Allegation 3 esperience before co.                                   s    one       of    the       personsew              with      Individual,"R."with                     fd Individual "C" He        also mias to work at CPSES       indicated                 that   and   henone    hadireferred !g                    to
                                                                                                                                                                                        .~iby a

hours to make his weld test cHe was given some very limite . s f escessive. p[1 i He now thinks oupon, that heo is a aduration go d that weld he nowof process, en used fifty-two y e%,e , welder. considers to be PM ! pW,h; 9m \ yrW>; .,D, 8 1 if,

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                                              - The RRI interviewed Individual "D" on May 30, 1979, and again June 1,-1979, -                             ,

j to develop any facts relative to the specific allegation of " buying-off" l

   ;                                            joints over the phone. Individual "D" categorically denied that he, or to j                                                his knowledge any other QC inspector assigned to this work area, had ever
                                                " bought-off" a designated inspection point without making the required
 !                                              inspection.. On June 1, 1979, Individual "D" indicated that there had been l                                                very few occasions when he had given consent to the welders to weld up a seas that, by the inspection reports, had been previously inspected for i                                                fit-up and cleanliness. He also indicated that he and others had repeatedly j                                                stopped work on welding of seems where it came to their attention that water 1                                                or moisture was interfering with good welding.

i The RAI interviewed the Rollermaker Superintendent on June 4, 1979, relative to his knowledge and/or participation in any of the allegations. He cate- , gorically denied ever directing welders to make welds where water or moisture was present, but acknowledged that it was a constant problem. He indicated that he finally received engineering permission to drill holes through the l liner at the ends of the leak chase channels so that air could be blown through to dry out the channels and that this action helped a great deal.

He indicated that he had continuely attempted to impress the welders with the importance of making good seas welds.
4. RRI's Assessment of the Liners

! The RRI observed some of the welding work on the refueling pool in the' Unit No. I containment during the latter part of 1978 and the early part of 1979

incidental to making inspection of other activities in the same work area.

j The welding appeared to be normal and the dye penetrant exmM antions appeared to be properly accomplished. The finished surfaces examined have been uni-formily smooth and appear sound. The RRI also examined some unfinished areas in the Unit 2 spent fuel pool and can appreciate the difficulties that may be ' encountered in removing some of the concrete laitance from the vertical weld joint areas. 1 i I 1 l l i i l I i I c .

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ggy Docket No. 50-445/Ept. 79-15 ,- -

                                                   .50-446/syt. 79-15                                       ,
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                 .                       Teams tftflities Generettag Coupesy                                                                -          .                                       .

ATER: Mr. R. J. Gary .Emmestive Vice President and General Manager .

                                                                                                                                                           ?                            -

2001 Bryan Tower l Dallas, Teams . 75201~ q. wr. .gentleasa:

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~ This refers to the investigation condesteh by Mosers. R. L iTaylor'and . W. A. Crossaan of our, staff on May 29 through .hana 4,1979. of activities

                                                                                                                                                                                                                                                                                  .                     .i
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authorised'by NaC Construction Penuits Es. CrFR-126 and 127 foe the -=aha - l . Feak iacility, Units Mo. 1 and 2, concerning allegations by a former Cannache . ( Peak employee. - . ..

                                                                                                                                                                                                                   ..                               j                    ,

{; The invadtigation and our findings are discussed in the enclosed tavestigation *

                                     ,. report.                .e                          ".-                 ..                            .,-
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No items ,of noncompliance or deviations were identified.

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svan'though no items of aancompliance with EgC requirements were identified , during this investigation, we did find that the allegations were essentially j true. We also noted during this investigation that a thread of continuity i esisted between this investigation and others recently conducted relative to ,3 j

  -                                         alleged problems with site management and quality control in eartain areas                                                                                                                                                                                     !

of construation. Although we feel that the major orgeaisational changes you

                                        .mada in' January 1978 have strengthened the Q&/QC progrant at Comanche Peak, we j                                            cammot ignore the fact that we are contianing to receive allegations concerning                                                                                                                                                                                f-l construction practices. Takam individinally.theae allegations, some of which                                                                                                                                                                                    l ;

I have been substantiated. do not appear to have any significant adverse impact , l on the scaformance of your plant to NaC canniements. . Dnrever, as we discussed .]. j in our meeting with,you and Mr. Fikar, in our office on June 22, 1979, whea e I ' thsee allagations are taken collectively, there appassa to be a , morale problan l

                                        . which is evidenced by several of the allegers and may be attributabla, la*

part, to comumentention problaas .between the workers and supervision. In 'our .

Jnaa 22 meeting, you ladisated that you would look into these apparent , , .l.

eaumanisation problaas along with tho' adequacy of QA/qC fadoctrination of i plant'aupervision and Workers and taka appropriate action to correct any

                                         'w==h===e==              that you deteet in thsee areas. We' intend to follow this matter l

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Temas Utilities Generating Company ' - In assordamse with Seatica 2.790 of the Mac's " Rules of Practima," Part 2 Title 10, Code of Federal Eagulatises, a espy of this latter and the ametaand

  • tavestigation report will be placed la the ERC's Publia Docussat Boss. If ths report osatains any infornation that yen believe to be proprietary, it is
asesenary that you outmit a writtaa app 14aa*4= to this offias, withia 20 days
                                                                                                         == that sush'informatian be withbald fraa of the data of this latter, a q                                               _

public di=aiaeure. The app 11astion mast laslada a full statammat of the reasons why it is slaimed that 'Se informatiam is propriatary. The app ===*=4w 11astion should > be prepared so that any . oprietary informatiam identified is ta en enclosure to the applicar.ica, sinsa the application withest the amala==ve will also be placed in the Public Document Room. If we do set haar fraa you in this regard within the specified period, the report will be plaamd in the Publia ,

          .                   Document soon.

Should you have any questions eencarmias this investigation, we will be p1=amad to discuss them with you. . sanearely. Original s;.:ned by .

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l . W. C. Seid1a, Chief . l ~ Reester Canstrusties and I . ,Eng4mmering Support Bummek Ens 1moures ,, IE Investigation Report No. 50-445/79-15 ' t 50-445/79-15 -

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8 1 Teams Utilit. w Generating Company  ; . I ATIN: Mr. R. C. Schmidt, Project Manager . . j 2001 aryan Tever '

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                      ,.J R 4 4m2E                                                                          .!j A.38.'b. NRC Inspection Report 79-15 reported an                          investigatio
                                                                                                          ^i 4

a , series of six interrelated allegations concein{ng the ,

welding of the stainless steel liner system in the fuel '

The allega-

~

handling facility spent fuel storage pools. tions, simply stated, indicated that welding conditions . were very poor; that welders were unqualified; tha,t- QC ' inspections were inadequate; that weldino procedures were{ ' n4 fellowedt and that at least one weld seam was large { { The investigation indicated that the

                       . rust aind concrete.

allegations concerning poor welding conditions were sub- - l stantially true and that some of the welds might well be The allegation about unquali-of relative low strength.

             "            fied welders was found not to be the case in a tec sense, since each welder had passed the necessary tests.

It was apparent that the alleger meant that the welders The matter of QC were not competent in his opinion. inspections and welding out of procedure could neither_be substantiated nor refuted since it was iust nne ee ., In any case, the matter . word with no other confirm ha l was considered to be unimportant since the welds in l question were seal welds rather than strength welds an not of any safety significance. ' l A.38.c.6 NRC Inydstigation Report 79-22 related to f ' allegations by a former Comanche Peak employee which f I appeared in a news article of the dniversity of Texas at i F0lA-85-59 nr .

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6. Investigation of Allegations Relative to Qualifications of Personnel and Adeouacy of Procedures The SRIC investigated allegations obtained during an interview -

wi'ch an alleger on August 24, 1982 2/. The allegations were as follows,

a. Eight B&R quality control ' personnel may not have either high school diplomas or General Educational Development (GED) certificates and, therefore, are not qualified. to be inspectbrs. The alleger stated.

that his infor'mation was b'ased on either direct

 '                          conversations or overhea'rd . conversations among the various persons he associated with.                                                                                    ..
b. One relatively new S&R quality control inspector who.

had been a craft-force person was being certified in the various QC disciplines at a far faster rate than seemed reasonable to the alleger.

c. Two B&R quality control personnel assigned to the alleger's work group were being trained for something '

but the alleger could not determine what it was or why. I B&R quality control procedures do not provide for the / h pp ,d . maximum allowable reinforcement on flare-bevel welds v used on component (pipe) supports. An example was stated to be a large frame located in a stairwell of the Unit 1 safeguards building. - t

e. The alleger stated that he had seen documents that indicated that he had been given 175 hours of training *
  • in the performance of liquid penetrant testing (PT) during the month of April 1982. He stated that he had
              ,             received no such amount of training and that the
  • document was, therefore, false.

The alleger provided the SRIC with specific names of persons in regard to allegations a, b, and c during the interview. The SRIC has made the following findings regardingleach of the above specific allegations: .

a. 0,f the eight persons identified by the allager as not -

meeting the minimum educational. requirements, five were ., found to have docunents verifying their high school graduation obtained by B&R from their respective schools. The remaining three had GED certificates on file in their personnel jackets. This allegation is refuted. _. subsequently appeared at the Atomic Safety and Li sing ar earin lating to Comanche Pe'ak on and discuss'ed his.'pfrior allegations to NRC expanding on some points. The

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b. The person singled out by the alleger as acquiring .

certi.fications too fast was found by SRIC to have acquired discipline certifications in areas where his resume would indicate prior experience gained both as a craft employee of B&R and during other past employment. In each case the records indicated that the person had passed the necessary examination prerequisite to certification. This allegation is also refuted. c. Two persons. singled out by the allegar as being trained . for some unknown purpose were found to be young,

                                        'i nexperienced persons who were being given training in one or more of the quali.ty control discipline areas essentially as contemplated by industry standards (ANSI N45.2.6 and/or SNT-TC-1 A) and the B&R procedures.

The training involves some amount of formalized classroom training in quality control as a generality and in specialized fields. In addition, the person receives

                                     ' on-the-job training under the supervision of certified inspectors . Depending on the exact discipline area, this training may involve from 3 months to 1 year before they are considered to be qualified. Each candidate fo'r certification must also take and pass an examination pertaining to the discipline area in which he will work.
The nature of the allegation was such that. it was a speculative on the part of the alleger and thus cannot be i

' either substantiated or refuted, although th'e information obtained from the training records indicated nothing i unusual to the SRIC.

d. Relative to the lack of procedural controls of the amount '

of reinforcement on flare-bevel welds, the SRIC found that the procedures provide criteria if the flare-bevel weld is a butt weld, but have no criteria if the weld Is of a dirrerent configuration such as a tee or corner joint. j The applicable code for the component supports involved is' subsection NF of Section III of the ASME Boiler and Pressure Vessel Code. None of the various subsections of Section III, including NF, contain any criteria for control of weld reinforcement other than that pertaining to butt

                                     ' joints which is defined by the code as "A joint between two members lying approximately in the same. plane." Hence, the B&R procedures are comensurate with the code requirements.

i The SRIC would note that the alleger, during the interview, expressed a primary concern in this matter in regard to

welds between square structural tube steel welded on a
side to a plate where, because of the rounded corner of the tube, the welds become a flare-bevel type weld. The joint configuration is that of a " tee" joint rather than a
,                                     butt joint.            Any' weld material more than that required to

] just fill the flare-bevel groove could be considered L

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i . 9 3 r.einforcement but would look much like a standard fillet [ weld. . Such a weld reinforcement would generally be beneficial since the ccnceivably sharp right angle of the true " tee" joint woul-d be avoided. The SRIC located the  ; particular support identified by the alleger and examined i both the structure itself and the quality documentation related to it. The support, identified as SW-1-173-720-543A, j was found to be a relatively large frame that acts as a f support for three pipe ru'ns that are ultimately attached to the frame. -The design drawing coupled with CMC 56843 ' indicate that there are approximately 30 flare-bevel welds. on the frame with 8 being of the type of most concern to the alleger. All eight exhibit ser.e amount of weld reinforcement with four having a drawing requirement for ' up to a 5/16 fillet weld overlay which could be viewed as reinforcement. It would appear that the alleger's concerns are neither supported by code requirements nor j by good engineering practices and, therefore, must be ( considered refuted. J

e. The SRIC found an interoffice memorandum dated June 15, 1982, in the alleger's B&R training file. The subject of the memo-randum was " Documentation of On-The-Job Training" and pertained directly to the alleger by name. The memorandum states that it is an attestment by a certified Level II inspector that the alleger had received 175 hours of on-the-job training in liquid penetrant examination. In someone else's handwriting, there is

' a note "I month-April 1982 to May 1982". The SRIC interviewed the person who signed the certification as the Level II inspector. This person was also the alleger's superv.isor at the time that ' the certificate was issued. The supervisor stated that he had been asked by B&R quality engineering to issue such a certificate and that he did so. In response to a question, the supervisor stated that there was no documentation to back-up the training other than that which was conducted in a classroom atmosphere. The supervisor stated that the alleger had been assigned to one or more of the people in the supervisor's group, who were Level II inspectors, for many weeks prior to his issuance of the certi-l fication an~d that he felt that the alleger must have had at least l 175 hours of training in the process. The alleger has specifically stated that he did not receive any such amount of training, Under the ~ circumstances, the allegation is con-sidered substantiated. . .. In order to understand the consequences of this allegation, the SRIC. reviewed the regulatory background and the B&R implementa-I tion thereof. The basic industry recommendation or policy on the certification of nondestructive examination personnel is i contained in a document comanly referred to as SNT-TC-1A published by the American Society For Nondestructive Testing. ASME has adopted the document by reference in several sections

p ._ 13

                                                                                                                         /
g. Page 4847, lines 11 through 17: " Pipe Hanger on Safeguard 1 -

Auxiliary Building boundry line at elevation 825, approximately, has' flarb-bevel weldment between tube steel and one-inch base plate made without a procedure covering it a o Billy ~ Snellgrove--correction. According to .on

  • Comanche Peak, butt weld procedures are applied to are-beve1 weld requirements."

Finding - This allegation is substantially the same as the llegatibn c ntained in d. of paragrpah 6, with the exc,eption that tatement to the Board is somewhat more vague. The e ieves at the more definitive allegation in paragraph 6 , is the primary concern to the alleger and that the finding relative . . to allegation d. remains valid.

h. p 4848, lines 4 through 11: "I asked the question 'Why was
                                                 ) certified as Level II inspector with          and PT.in eri           less than six months?'         Also,           was given                 .

fort ho on-the-job training in MT in pril or May by in.a three part memo. This could be verified by . exar.ination of the use of MT Yoke calibration-cards or calibration . record which would be available there on the QC calibration laboratory itself." . Finding - The SRIC reviewed current cards refl'ecting the issuance of MT yokes as suggested by the. alleger. The cards for the germaine period were not reviewed since they had been placed. in archive files. The SRIC judged the cards to be of little value in determining whether or not a particular person had received the necessary training since the on-the-job training can - be many other things, such as reading, that are well short of actually using a tool or gauge. Further, the cards reflect only issuance of a yoke on a per day basis without any notation for how long it wa's used within the day. And yet further, it is . probable that a certified inspector would draw the yoke rather than an as yet uncertified trainee, hence, no record of use by ' the trainee. As to why the named person had what was apparently accelerated training in MT and PT, the SRIC would observe that

                   ,              the number of certifict.tions an. inspector has, has a direct bearing on his pay grade.. The regulations ~.(SNT-TC-1A) permit simultaneous training in two or more discipline areas at the                                     !

same time with it being possible to obtain the necessary work  : time experience in both of the above disciplines in as little ' as 4 months. The nature of this allegation is that it can neither be substantiated or re'futed, but is considered to h' ave e little technical merit.- E E l a

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          !    SROWN & RCOT, 1I.C.                                                                              ISSUE                           l CPSES                                  .1 UMBER                        RE't!SION            CATE               PAGE         g as as.tiss SEP 291982            as ce 62            ,
                                                    'OI-GAP-ll.1-28                             14                                                  1
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            -  -                                               APPENDIX B U.S. NUCLEAR REGULATORY CC$NISSION REGION IV Report:              50-445/82-11 & 50-446/82-10 50-445 & 50-446                                 Category: A2 Dockets:

Licensee: Texas Utilities Generating Company 2001 Bryan Tower Dallas, Texas 75201 l

                                                                     .                                        i Facility Name: Comanche Peak, Units 1 and 2 Inspection At: Comanche Peak Steam Electric Station, Glen Rose, Texas Inspection Conducted: April through September 1982 Inspector:                                        - ~        b               /3-3*82-R. G. Taylor. Senior Resident Inspector -                 Date Construction (SRIC)

Approved: M-4 ~

                                                                                                  /) 82-T. F. Wester 1 nan, Chief, Reactor Project Section A      Date i

Inspection Summary Insmeetion Conducted During the Period April through September 1982 (NR; Report 50-445/82-11) i ! Routine and special inspection, announced, by the Senior Areas Inspected: Inspector (Construction) including facility tours, as-built pipe and support program, investigation of allegations, and participation in ASLB hearing. The inspection involved 94 inspector-hours onsite and 510 hours on ASLB by - one NRC inspector. Results: Within the areas inspected, two violations were identified: (1) failure to inspect installation of seismic shims in polar crane brackets, and (2) failure to properly train and indoctrinate QC personnel. Insaction Conducted During the Period April through September 1982 I (NR; Report 50-446/82-10) Areas Inspected: Routine, announced inspection by the Senior Resident l l Inspector (Construction) consisting of plant tours. The inspection involved 35 inspector-hours by one NRC inspector. l ! Results: Within the areas inspected, no violations or deviations were j identified. k f i ea % -- - F01A-85-59 N)/O f

                                             .. :: . :=             : .             .     . . . . .
                                                                                                                                                          ~

2 l DETAILS

1. Persons Contacted Texas Utilities Generating Company (TUGCO)
                                    *R. G. Tolson, Site Quality Assurance Supervisor                                                                                            ,
                                    *D. N. Chapman, Quality Assurance Manager                                                                                                   I
                                    *B. R. Clements Vice-President, Nuclear                                                                                                     l Texas Utilities Services Incorhorated (TUSI)
                                    *J. T1. Merritt, Engineering and Construction Manager R. Kissinger, Project Civil / Structural Engineer J. Finneran, Project Pipe Support Engineer Other Personnel 4                                    *G. R. Purcty, Project Quality Assurance Manager, Brown & Root The SRIC also interviewed other licensee and Brown & Root (B&R) employees during the inspection period. ,
  • Denotes those persons who attended management meetings with the SRIC during the inspection period.
2. Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (50-445/82-09-01; 50-446/82-04-01):

Procurement Doctmentation. These items involved inadequacies of vendor test docisnentation relative to the physical properties of . 10,000 bolts in accordance with ASTM A-325. The licensee obtained proper test doctmentation from the vendor which indicate proper i physical property values. The licensee hcs also perfonned confinnatory tests of an additional 20 bolts which closely correlate with the vendor documentation. The licensee has s reported that the majority of bolts were used for electrical cable tray and conduit applications. The licensee has reported that he has screened all other purchase orders for fastener materials for strict compliance to the terms of the respective orders. Four errors were identified relative to vendor documents which have been corrected. The SRIC has reviewed the confirmatory tests discussed above and found them satisfactory. This item is, therefore, considered closed. 4 I _ _ _ . _ . . . _ _ _ _ _, _ . _ . . _ _ _ . _,~ _ . . - _ . _ _ . _ _ _ _ _ , . _ . , - . __ .

y- . _ . . ___ _._

                                                                      <~
              ..                           e l                                                           .

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                                                                                                         )

f 3. Site Tours 1 i The SRIC made a nimber of general site tours during the inspection 6 period to keep abreast of the status of construction and of the overall

- housekeeping for both Units 1 and 2. At the end of August, the i licensee estimated that Unit 1 was approximately 91% complete in regard to construction. On the basis of his tours, the SRIC believes this estimate to be substantially correct.

a No violations or deviations were' identified. l ! 4. Piping and Support As-built Verification Prooram The licensee has developed a comprehensive as-built verification program for piping systems and the supports thereof in response to IE Bulletin 79-14. The primary onsite participants in the program are the licensee's Technical Services group which initially updates pipe support isometric drawings and support drawings based on all available information at a given point in time. Essentially this effort consists of incorporating into the original design drawings the various design change authorizations and component modification card (CMC) changes that have been made. The updated package is then provided to the as-built unit of quality assurance that has the responsibility to survey the pipe run involved, including the location and configuration of the supports. Variations from the provided design are noted in the isometric and/or individual support l; drawings, as approprirde. The information is returned to Technical i Services and is then transmitted to the architect-engineer for I revie'w and for inputing to the stress analysis of the piping run. o a The SRIC selected a portion of one pipe run that he observed to i have a peculiar support scheme as a means of verifying the

;                       effectiveness of the program. The support scheme was peculiar in that there was an uninstalled but simulated seismic snubber approximately 6 inches from another support that had been installed such that the motion the snubber was designed to allow was already solidly blocked. The SRIC contacted the appropriate personnel 1

in both of the site groups involved in the as-built program and j found that the run had been as-built verified several months ago without notation of the blocked condition. During the interview 1 process, it was discovered that a CMC had been issued since the i as-built verification had been made that altered the support the SRIC had observed as blocking the snubber action and on the basis - of the SRIC's observation, it was apparent that the craft had iglemented the CMC but that the doctanentation of the QC inspection of the modification had not yet flowed through the administrative

 '                        network to Technical Services and on to the QA verification group.
  '                      Subsequently, the licensee's engineering manager informed the SRIC 6

I i

l l

           .                                                           4       -                                                 -                    j

[ *he thert wm design probless involved with the run that he and his people were working on, and that 1r would be several i > days before they would reach a conclusion. This matter will be considered.as an unresolved item until such time as the resolution of the engineering problem is developed. The piping run involved in this matter is that displayed on isometric drawing BRHL AF-1-SB-003 and the supports are AF-1-058-004-533K and AF-1-008-005-533R. (Unresolved item 8211-01) i No violations or deviations were identified.

5. Investioation of Alleoations Per'tainino to the Unit 1 Polar Crane During June 1982, the SRIC was informed that allegations had been
         -                          made by a former construction worker regarding the construction and operability of the Unit 1 polar crane 1/. The allegations were:
a. Shims for the rail support system had been altered during installation in some unacceptable manner. l
b. The crane rail moves during crane operation such that a large gap develops that could lead to failure. -

) The SRIC obtained Drawing 2323-51-0515. " Reactor Building Liner l Details and Crane Support Details," in order to better understand the support and restraint system. The drawing indicated that the single circular rail was supported by a series of 28 girders which were supported by a series of brackets welded into the building liner with anchorage into the building concrete. In addition, between each set of supports at about the mid-point of each girder, there was a radial type restraint also welded into the liner and anchored in the concrete. The drawing indicated that the girders should be shissed, as required, off of the support brackets to provide a substantial degree of levelness. The radial restraint brackets were also indicated to have a uniform 1/4-inch shim between that portion attached to the building and the portion attached to the top of girders. The rails were shown to be attached to the girders by several welded clips per girder. The welding was shown only to the girder which would provide radial restraint to the rails but would also allow the rail to slip in a circumferential direction. The SRIC learned that Chicago Bridge & Iron Company (CB&I) had been contractually responsible for the erection of the reactor building , liner, including installation of the entire crar:e support system but excluding erection of the crane itself. The SRIC interviewed the onsite CB&I project superintendent and learned that they had - installed the crane rail support system in accordance with their contract, including the referenced drawing. He stated that when his company had finished their work, there were gaps left in the f 1/ The alleger, Mr. Miles, subsequently testified at the Atomic Safety and Deensing Board hearing relating to Comanche Peak on July 28,1982,about

 !                           these allegations to the NRC relating to the polar crane.                                                            .
                                                                                                                           ~ ~ '                    ~
1. .

y j restraint brackets since the reactor building was locally tut-of-M wMla N nil systa hu been required to be j round and centered on the as-built center of the building. He indicated that B&R had had considerable difficulty in l i . erecting the crane because of interferences and because

the crane wheels did not seem to fit the rails. He indicated that he thought that B&R had later installed j additional shims in the laterial restraints and indicated that neither .his company nor himself were responsible for that work.

i The SRIC then obtained a design change authorization that depicted the installation of shims of a relatively special

design to fill the restraint gaps based upon measurements apparently supplied by B&R field personnel to the engineer.

Drawing.SK-82032 " Polar Crane Supports - Additional Shim l Requirements," had been issued by the engineer during j November 1977, but was not released via Design Change l Authorization 9672 until March 1981. Noting that the design change authorization was annotated to be a safety-related docunent, the SRIC requested that any l germaine quality control documentation on file be provided i to him as soon as possible. After a short period of time, the SRIC was infonned that no such documentation appeared i to have been generated. The SRIC then asked that the crane l be operated in a slow manner such that it would transverse l the entire reactor building circumference at least once and i that it then be placed in a de-energized condition for an t inspection as soon as reasonably possible, considering that it was in nearly constant use. On or about June 22, 1982, l the crane was transversed for the SRIC and was noted to j operate very smoothly. Based on hearsay that the structural iron workers had probably installed the additional shims, l if indeed they were installed, the SRIC encountered the ! general foreman of this group after the crane run observa-tion. The SRIC asked the general foreman if he could - recollect if his people installed the shims in question. He indicated that he did ramenber the work and, further, i that it had been done over several weekends during May or i June of 1981. When asked if he could ramenber whether QC had been involved he said he was not really sure but did ( not think so. A short time later, the licensee's civil structural engineer , visited the SRIC and stated that his group, which had the ' responsibility, had failed to issue an " Operational Traveler" - that would have provided the interface between QA/QC and the craft labor force to have had the fabrication and installation - j of the shims inspected. At this point the SRIC detennined that a violation of Appendix B had occurred regardless of ( exact status of the shims themselves. The licensee ! subsequently disabled the crane and inspected several of the radial restraints and found that indeed some of the shims had been altered to a condition other than that contemplated by the designer.

..~_...m..-- _ __, . . . . _ _ _ _ _ _ _ _ . _ _ . . - . _ _ _ _ . _ . . . . . _ _ _ . . . _ . _ _ _ _ __

   .                      ~

6 l f Regarding the matter of the operability of the crane because of rail gaps, the SRIC has pmviously indicated that the crane ran very smoothly during a demonstration run in June 1982. The SRIC ascertained that additional rail clips of a forged type designed to hold heavy railroad rail were installed via Design Change Authorization 6437 and that these clips should have the effect of preventing circunferential rail movement. The SRIC was also informed by the licensee that the basic cause of the earlier rail movement was an inadequate design by the crane manufacturer in that he had failed to provide a tangential offset within the crane trucks that caused the wheels of a given truck j to bind on the curved rail and thus drag the rail around. The licensee has stated that this design error has been corrected

     --                     which is apparent from the way the crane now operates.

For the record, the SRIC would note that the polar crane is classified in the licensee's FSAR as seismic Category II with no nuclear safety aspects. During noral power operation of 4 the facility, the crane is parked and in a de-energized condition. Its primary use, during refueling operations, is to lift the i reactor vessel head. Seismic Category II is defined in the FSAR - Section 3.2 as those couponents or systems whose continued I function (during or after a seismic event) is not required, but whose failure could damage another component such that it could i not satisfy its safety function. In effect, the crane must only stay in place during a seismic event and thus not damage another component. The SRIC accompanied a Region IV investigator during an c interview of the foriser construction worker who made the actual i allegation. The interview was conducted several days after conclusion of the SRIC's investigation. The a11eger provided more details about his allegation than was originally given to the NRC but without adding any inforination that changed the results or conclusions of the investigation. The alleger made l an appearance before the Atomic Safety and Licensing Board in the matter of TUGC0 during the hearing phase that took place from July 26-29, 1982. Neither the alleger's prefiled testimony nor his statements during the hearing revealed a need for any change in the investigative findings. i 1 i l 1 r .

                                                                            . ~ . . . . . .          . -

9 - 3'\ ra n- yw/ tz - n 1t/f3ff 2 7

6. Investigation of Allegations Relative to Qualifications of Personnel and Adecuacy of Procedures .

The SRIC investigated allegations obtained during an interview I with an alleger on August 24,19822]. The allegations were as follows:

a. Eight B&R quality control personnel may not have either high school diplomas or General Educational Development (GED) certificates and, therefore, are not qualified to be inspectors. The a11eger stated that his information was based on either direct conversations or overheard . conversations among the various persons he associated with,
b. One relatively new B&R quality control inspector who had been a craft-force person was being certified in the various QC disciplines at a far faster rate than
-                                       seemed reasonable to the alleger.
c. Two B&R quality control personnel assigned to the
alleger's work group were Leing trained for something but the alleger could not deterinine what it was or wlyy.

I d. B&R quality control procedures do not provide for the gu-/O -, maximum allowable reinforcement on flare-bevel welds used on component (pipe) supports. An example was ] stated to be a large frame located in a stairwell of F the Unit 1 safeguards building.

e. The alleger stated that he had seen docunents that indicated that he had been given 175 hours of training i

in the performance of liquid penetrant testing (PT) 4 during the month of April 1982. He stated that he had received no such amount of training and that the document was, therefore, false. I The alleger provided the SRIC with specific names of persons in g regard to allegations a, b, and c during the interview. The SRIC has made the following findings regarding each of the above specific allegations: 1 1

a. Of the eight persons identified by the alleger as not i meeting the minimum educational requirements, five were

] found to have docunents verifying their high school 1 graduation obtained by B&R from their respective schools. l The remaining three had GED certificates on file in their personnel jackets. This allegation is refuted. I , subsequantly appeared at the Atomic Safety 2/ The alleger, and Licensing Board hea relating to Comanche Peak on September 15, 1982, 3 and discussed his prior allegations to NRC expanding on some points. The * ] ~a llegations made at the hearing are discussed in section 7.

j. ,
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                       ,                                                    .Z~d #o- W cf #2-//
    .              .                                                    ,         /a-/l.1{S'2.

8 .

b. The person singled out by the alleger as acquiring
certifications too fast was found by SRIC to have i acquired discipline certifications in areas where his

! resume would indicate prior experience gained both as a craft employee of B&R and during other past employment. 3 In each case the records indicated that the person had

passed the necessary examination prerequisite to i

certification. This allegation is also refuted. i c. Two persons singled out by the alleger as being trained t for some unknown purpose were found to be young, inexperienced persons who were being given training in one or more of the quality control discipline areas ~ i . essentially as contemplated by industry standards

(ANSI N45.2.6 and/or SNT-TC-1 A) and the B&R procedures.

The training involves some amount of fonnalized classroom i training in quality control as a generality and in 4 specialized fields. In addition, the person receives on-the-job training under the supervision of certified i inspectors. Depending on the exact discipline area, this

tr,aining may involve from' 3 months to 1 year before they i are considered to be qualified. Each candidate for i certification must also take and pass an examination

< pertaining to the discipline area in which he will work. i The nature of the allegation was such that it was

speculative on the part of the alleger and thus cannot be

. either substantiated or refuted, although the information i obtained from the training records indicated nothing l unusual to the SRIC.

                                    ~

h@ d. Relative to the lack of procedural controls of the amount ! of reinforcement on flare-bevel welds, the SRIC found f/ ! that the procedures provide criteria if the flare-bevel hQ fgo weld is a butt weld, but have no criteria if the weld is k rf,fl*p[ of a different configuration such as a tee or corner joint.

                                           .he applicable code for the component supports involved is ubsection NF of Section III of the ASME Boiler and l                     3

((q

                            /            Pressure Vessel Code. None of the various subsections of Section III, including NF, contain any criteria for control f                       $#

of weld reinforcement other than that pertaining to butt ( joints which is defined by the code as "A joint between two members lying approximately in the same plane." Hence, the

           )

s ^ B&R procedures are connensurate with the code requirements. e TEETRic would note that the alleger, during tWiHFerview, (" expressed a primary concern in this matter in regard to

                             .           welds between square structural tube steel welded on a side to a plate where, because of the rounded corner of the tube, the welds become a flare-bevel type weld. The

[ i joint configuration is that of a " tee" joint rather than a i

                           \             butt joint.      Any weld material more than that required to just fill the flare-bevel groove could be considered -

l

N fr qq g.g ,

                                                                            '2lGff2 j              reinforcement but would look much like a standard fillet                              !

wel d. Such a weld reinforcement would generally be I benef.icial since the conceivably sharp right angle of the

                           ,              true " tee" joint would be avoided.      The SRIC located the particular support identified by the alleger and examined
                         ,               both the structure itself and the quality documentation related to it. The support, identified as SW-1-173-720-S43A, was found to be a relatively large frame that acts as a support-for three pipe runs that are ultimately attached to the frame. The design drawing coupled with CMC 56843 f                        indicate that there are approximately 30 flare-bevel welds 3                         on the frame with 8 being of the type of most concern to y                           the alleger. All eight exhibit some amount of weld reinforcement with four having a drawing requirement for up to a 5/16 fillet weld overlay which could be viewed as reinforcement. It would appear that the alleger's concerns are neither supported by code requirements nor by good engineering practices and, therefore, must be considered refuted.

L --

e. The SRIC found an interoffice memorandum dated June 15, 1982, in the alleger's B&R training file. The subject of the memo-randum was " Documentation of On-The-Job Training" and pertained directly to the alleger by name. The memorandum states that it is an attestment by a certified Level II inspector that the alleger had received 175 hours of on-the-job training in liquid penetrant examination. In someone else's handwriting, there is a note "1 month-April 1982 to May 1982". The SRIC interviewed the person who signed the certification as the Level II inspector.

This person was also the alleger's supervisor at the time that the certificate was issued. The supervisor stated that he had been asked by B&R quality engineering to issue such a certificate and that he did so. In response to a question, the supervisor stated that there was no documentation to back-up the training other than that which was conducted in a classroom atmosphere. The supervisor stated that the alleger had been assigned to one or more of the people in the supervisor's group, who were Level II inspectors, for many weeks prior to his issuance of the certi-fication and that he felt that the alleger must have had at least 175 hours of training in the process. The alleger has specifically stated that he did not receive any such amount of trai ning. Under the circumstances, the allegation is con-sidered substantiated. In order to understand the consequences of this allegation, the SRIC reviewed the regulatory background and the B&R implementa-tion thereof. The basic industry recommendation or policy on the certification of nondestructive examination personnel is contained in a document comonly referred to as SNT-TC-1A published by the Areerican Society For Nondestructive Testing. ASME has adopted the document by reference in several sections w

                   ,pg."_

i.m - Ay -M Kb dhw %% a , 4~N,4 M M efN'&T*48 hWO h

                . ..          .   . -     .: n ..                                           . . . . . ~
                                                                                                                                                                  . . . ~ ._. .

+ .. 10 f i .of the Boiler & Pressure Vessel Code including Section III. The NRC has also effectively adopted it by endorsement in Regulatory Guide 1.58. B&R has issued Procedure QI-QAP-2,1-1 i to implement the requirements of SNT-TC-1A. The SRIC's i review of this procedure indicates that it is conniensurate ' i with the requirements. For liquid penetrant inspection, the procedure requires that a person never previously certified l

in the process receive a total of 20 hours of specific training l in the process and that he also be given 3 months of " Work ,

Time Experience (WTE)" in the process to achieve Level II j certification. The alleger was credited with 2 months of  : I work time experience based on work time gained at another l BAR project. A footnote in the procedure extracted from i

SNT-TC-1A, however, qualifies the WTE requirement by stating I

that credit for experience may be gained in two or more  : 1 i disciplines at the same time, and that only 25% of the total J ( time need be gained in a specific discipline. SNT-TC-1A also i states that 1 month is equivalent to 175 hours based on a standard 40-hour work week and allows computation on the basis of hours if the work week is other than 40 hours. Neither l SNT-TC-1A or the B&R procedure require or recommend any other documentation of the WTE than a certification such as was ! issued but there is the strong implication for the need to have specific knowledge of such time. The supervisor admitted g j that he did not have specific knowledge of the alleger's WTE i time nor was he aware of the footnote referred to above. He , I thought he was actually attesting to 175 hours of WTE in f liquid penetrant inspection. Another element entering 'into t this matter was that fonnal full certification of the alleger

 -                                     by the site NDE Level III making the alleger a Level II PT examiner was issued nearly 2 weeks prior to the supervisor's certification of WTE. yet the formal certificate states that one of the elements of the certification was WTE gained at l

CPSES. As mitigation, the a11eger was given 24 hours of < classroom training in liquid penetrant examination and success- [ > fully passed an examination on the process prior to his certification by the Level III person. The mcord also reflects that the alleger had been previously certified as a

Level II liquid penetrant examiner by B&R at another project

! (STP) and, further, that he had been previously so certified by two employers other than B&R going back as far as 1974. [ The site Level III would have been perfectly cormet if he had i chosen to certify the alleger entirely on the basis of his past F certifications and experience without either further training or examination at this project but apparently elected not to do i so. The record shows at least two personal errors; one on the (,dtt of the alleger's supervisor for issuing a certification . ! relative to the amount of WTE without certain knowledge, and another on the part of NDE Level III for issuing the fomal r

certification of alleger as a Level II examiner without the L

( ' e 1 - 7

    .                                                     11 l

supervisor's certification of WTE in hand. It also appears ) that the supervisor was inadequately trained in .his responsi- ' bilities under the program and procedure. Taken as a whole,  ; 1 it appears that the intent of Criterion II of Appendix B has been violated in the area of training and indoctrination as

necessary to assure proficiency of personnel to perform i activities affecting quality. Under the circunstances, it

! would also appear that the violation is of a re.latively minor i nature since it has not been shown that the alleger was less j than competent to perfone his tasks.

7. Investication of. Allegations Made by Bob Bronson
Mr. B. W. (Bob) Bronson made a limited appearance before the Atomic j

Safety and Licensing Board hearing in the matter of TUGC0 (Comanche i Peak Steam Electric Station. Units 1 and 2) on. September 15, 1982.

Mr. Bronson's statement begins on page 4845 of the hearing record j and continues through page 4853. The SRIC has reviewed these pages s

and has extracted the following allegations therefrom. The SRIC fincing issuediately follows each allegation. I a. Page 4845, lines 24 and 25; page 4846, line 1: "There is wide-l spread use of lesser qualified mechanical / welding inspectors in completions quality engineering. Example: Ted Neely." Finding - The allegation is in the area of an opinion without ! any stated standards. The person named by the alleger was i found to meet the qualification standards for his position. This was substantially the same allegation as b. in paragraph 6.

b. Page 4846, lines 2 through 14: "In reference tn Oral Deposition f of Gordon Purdy, 8/23/82, page 38, Line 10, '--that quite

[' honestly, I told him that I was through putting trainees in the QC slots, that I was looking for totally and completely qualified personnel. ' This is not true. For example: Cheryl Dennen and Walter Trautschold--I hope that name is i pronounced correctly--T-r-a-u-t-s-c-h-o-1-d*-these two people i are quality control OJT trainees and were at the plant the i last time that I knew. Gordon Purdy has violated the statement I he made in his deposition." Finding - This allegation is substantially the same as allegation

c. in paragraph 6 with the addition of the quote by Mr. Purdy.

i The SRIC has reviewed the training and certification records for i the persons muned by the alleger and has found them to meet applicable requirements. Mr. Purdy has stated to the SRIC that g his quote was made in the context of direction or guidance to his subordinate supervisors regarding future hiring practices at about the first part of 1982 and was never intended to retro-L actively affect personnel already undergoing training or that it I was intended to be an absolute order. [ .. L' t

                        -                                                             12
             ~
c. Page 4846, lines 15 through 18: "When I was working in the materials expressly forbidden evaluation, by materials verification my lead man to write NRC's group (, I wasNCR's?)

on arty item other than the traveler piping directly inspected by me." l Finding - The SRIC has not been able to confinn that the ! statement attributed to the alleger's lead man was made or not l since apparently no third party was involved. The lead man, in l an interview with the SRIC, denied this allegation. This allegation can neither be substantiated nor refuted.

d. Page 4846, lines 19 through 23: "There are inspectors who are deficient on ASNI N45.2.6 requirements. They are missing their high school documentation and I have set there in the hanger t group many times and heard these particular individuals
                  -                         discussing this lack of diploma."

1 Finding - This allegation is the same as allegation a. in 4 paragraph 6, and the finding is the same, i.e., refuted.

e. Page 4846, lines 24 through 25; page 4847, lines 1, 2, and 3:
                                            "This mag particle certification carbon steel coupon has been

- used consistently, and so many times, that inspectors who have used it, know from metnory the indications, shapes,1engths and ! locations and this particular coupon has been in use out there for two years." Finding - This allegation is without regulatory merit since there are no requirements on how often test coupons must be changed. The SRIC would observe, however, that the only time an inspector uses the test coupon twice would be in the event of recertification which occurs only at 3-year intervals.

For a person to remember the alleged level of detail appears remote in the judgement of the SRIC. Likewise, it appears remote that a certified inspector would be able to describe, in detail, the indications to a candidate for certification. The i allegation is considered refuted.

i

f. Page 4847, lines 7 through 10: "Jeff McComas, Hanger Inspector, l

i was pennitted to take his certification examination with l approximately two years interim between the specific-general . tests and the practical." Finding - The training and certification records pertaining to the person named by the alleger have been reviewed by the SRIC. 4 The record shows that the person received some training in magnetic particle inspection as much as 2 years ago and also shows that the person was given additional training during l June 1982, and was tested on all three parts of the examination - series with the practice aspect being given on June 2, 1982,

  ,                                           followed by the written tests on June 24, 1982. There are no regulatory requirements regarding the sequencing of the test.

The allegation is considered refuted. 4

)                                                                                                                                                    .      .

4 .

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I i 1 . . . l 13 V l g. Page 4847, lines 11 through 17: " Pipe Hanger on Safeguard 1 - Auxiliary Building boundry line at elevation 825, approximately,

has flare-bevel weldment between tube steel and one-inch' base i plate made without a procedure covering it, according to Billy i Sne11 grove--correction. According to Billy Snellgrove on Comanche Peak, butt weld procedures are applied to flare-bevel l weld requirements."
                                                                         'Findino - This allegation is substantially the same as the j                                                                             allegation contained in d. of paragrpah 6, with the exception that
Mr. Bronson's statement to the Board is somewhat more vague. The i SRIC believes that the more definitive allegation in paragraph 6 j is the primary concern to the alleger and that the finding relative
.. to allegation d. remains valid.

i [ h. Page 4848, lines 4 through 11: "I asked the question 'Why was ! Ted Neely certified as Level II inspector with MT and PT in ! period of less than six months?' Also, Ted Neely was given l forty hours on-the-job training in MT in April or May by

J. Patton in a three part memo. This could be verified by i examination of the use of MT Yoke calibration cards or calibration ~

( record which would be available there on the QC calibration laboratory itself." Finding - The SRIC reviewed current cards reflecting the l 1ssuance of MT yokes as suggested by the alleger. The cards for ! the germaine period were not reviewed since they had been placed i in archive files. The SRIC judged the cards to be of little i value in determining whether or not a particular person had l received the necessary training since the on-the-job training can [ be many other things, such as reading, that are well short of l actually using a tool or gauge. Further, the cards reflect only l issuance of a yoke on a per day basis without any notation for ! how long it was used within the day. And yet further, it is

. probable that a certified inspector would draw the yoke rather
than an as yet uncertified trainee, hence, no record of use by

, the trainee. As to why the named person had what was apparently

accelerated training in MT and PT, the SRIC would observe that l the number of certifications an inspector has, has a direct

! bearing on his pay grade. The regulations (SNT-TC-1A) permit l simultaneous training in two or more discipline areas at the L same time with it being possible to obtain the necessary work time experience in both of the above disciplines in as little , as 4 months. The nature of this ' allegation is that it can l neither be substantiated or refuted, but is considered to have i little technical merit. l l l e

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

14 4 Page 4848, lines 12 through 17: "I have received 175 hours of i. OJT PT. This item was discussed with Mr. Taylor, the NRC resident

                                                                                                                                ]

inspector at Comanche Peak, in our meeting. This is a training i documentation falsification. No such training time has been  ! acknowledged, nor can it be proven. That is, who was the Level II - who observed or signed for me?" - l Finding - This allegation is the same as allegation e. in paragraph 6, with the findings also being the same.

j. Page 4849, lines 13 through 23; "A component modification card was authorization granted by weld engineering to cover deviations from traveler blueprint. A CMC was in or would be generated by welding engineering or hanger engineering in a high percentage
      -                     of the packages inspected by me. Now, this CMC--that is the first time I have come across this particular type document. This is a deviation which can be granted by welding engineering or hanger                                     i engineering department, if I, as the inspector, came across a                                       l dimension or something which was different from the original 4

blueprint." Finding - This allegation regarding the use of CMC seems to renect the opinion of the alleger, perhaps based on his past experience. The CMC must be considered as a field design change and, therefore, within the purview of Criterion III of Appendix B which requires only that such changes shall be subject to the same controls and reviews as the original. design. The CMC may be issued after the change has occurred to documen.i. the as-built condition. The allegation is considered substantiated, but 4 having no regulatory or technical merit.

k. Page 4849, lines 24 and 25; page 4850, lines 1 through 10:
                             " Excessive grinding of welds by craft personnel prior to final inspection. Why is this being done out there? Very few weld-ments which I inspected were in the as-welded condition. What I mean in the as-welded condition, you see the weldment, the ripples in the weld surface itself, left there by the electrode during the welding process and there at Comanche Peak, I would 2

estimate that seventy-five percent of the weldments which I looked at were all ground down like a machined surface. Also, why does.the craft grind the toe of the weldment 360 degrees in some cases, causing an undercut condition or a near under-cut condition?" Finding - The grinding of weld surfaces is neither prohibited nor encouraged by the applicable codes and standards, but is sometines necessary if one of the foms of nondesrtictive examination is required. Relative to the grinding of the j I i I i

f

..- 15 toe of welds, it is probably being done to remove
questionable undercut and is an acceptable way of doing

- so within the ASME code except when the material is reduced to less than allowable thickness. Based on the ' SRIC's experience at Comanche Peak, the craft have ground a substantial majority of the welds to make them easier to inspect and easier to apply protective coatings to. l Again, this allegation is considered substantiated but j without regulatory or technical merit. l ! 1. Page 4850, lines 14 through 25; page 4851, lines 1 and 2: !* "During inspection of hangers in Auxiliary Feedwater Room 2 I was on a scaffold with a craft worker inspecting a reworked i hanger. I had the required safety gear and was tied off to existing structure but craft was not tied off, primarily i because he was missing a lanyard on his safety belt. When ' we clinbed off the scaffold, I was asked why I did not use ' the ladder. The craftsman was visited by the safety man j and was given no citation. February,1982. Wayne Mansfield, j inspector, was observed not tied off, in which case was given a safety violation citation from safety and this is in violation j of OSHA regulations, which I understand are in effect out there." l ' Finding - This allegation regarding the use of personal safety

equipment is not within the purview of NRC regulations.

? ! m. Page 4851, lines 11 to 18: " Material verification. In the material verification group, I have probably come across fifteen to twenty hangers which lacked completely any material i traceability. They had no heat numbers of any kind. I'd turn them in to the material verification group and told them I wouldn't sign them off, usually gave them to Danny Leigh. I don't know what happened to them. As far as I know, they were never corrected."' Findito - Regarding the lack of material traceability of hangers, i the SRIC interviewed the one named person within the allegation. ! This person stated that he had never received any such reports ( from the alleger at cny time. The purpose of the group the person interviewed supervised, and in which the alleger worked for a , period of time, was to inspect and research, as necessary, where ! the documentation on a particular hanger was not completely j clear prior to final code certification of the hanger. The proper course for the alleger to have followed when the inspection i criteria was not satisfied was to prepare a nonconformance report ! (NCR) which he apparently did not do. This allegation can neither be substantiated nor refuted due to its vagueness. I I I

f is

n. Page 4851, lines 19 through 23: " Bill Sne11 grove, g supervisor l I

in the hanger group, told me to buy off Hilti bolts which had already been torqued and had torque seal applied by someone else when I came to make the final inspection. I followed his request." Finding - The SRIC has accepted this allegation as true without - further interview or Investigation since the alleged statement is consistent with his observations of the installation and QC inspection process of hangers during the past several years. By way of explanation, the installation of the Hilti bolts into their holes is & very early event in the installation of a hanger since the bolts must be placed in holes that have been drilled without cutting the embedded reinforcing steel. This requirement frequently results in bolt patterns somewhat nonsymmetrical. Generally, after the bolt pattern is established, the pattern is measured and the baseplate drilled to fit. Very frequently, the baseplate will be then installed and the Hilti bolts tightened (torqued) to set the locking wedges. When this is the case, QC inspection is perfomed during the tightening process and the torque seal is applied. The QC inspection records for the support are also annotated that reflect that torquing has been accomplished and accepted. With the baseplate now in place, the installation of the remainder of the hanger would then take place and might extend over a period of several days, weeks, or even months. When the hanger is finally all complete, a final inspection would take place but without the necessity to reverify Hilti bolt tightening if the torque seal has not been disturbed, hence, the idea of the use of torque seal. The alleger did not state that the supervisor's instructions extended to the acceptance of obviously loose Hilti bolts or to those where the torque seal had been disturbed; he simply stated what is a nomal installation process with accompanying fr$poness inspections. The allegation is substantiated but has f4 ' technical merit."

o. Page 4852, lines 19 her :5; page 4853, lines 1 through 7:
                                     "In a deposition of L, coon A rdy, he states: ' Reg. Guide 1.58
                       -             says the only acceptable alternative to a high school education is the General Education Development Equivalency.'         In g conversation with Mr. Taylor, with the NRC, about this, Mr. Taylor indicated to me that as long as prior service has been acceptable to Brown and Root, the Grandfather Clause generally would allow people to work without a high school education or a GED, to work as QC inspectors. What is the Grandfather Clause? Where is it written up? I'd like to see 4

i it, but Mr. Taylor mentioned this to me." e e NM

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1 Findino - The SRIC wishes to acknowledge that the statements j attributed to him by the alleger regarding a " Grandfather Clause" were substantially as made by the SRIC. The phrase

                                           " Grandfather Clause" is fmquently applied in . situations
where state or federal regulations regarding the certification

! or registration of individuals to perfom certain functions ' are involved and these regulations are changed subsequent to i a given individual's initial certification or mgistration. A typical situation is that of registration as a professional engineer. Some~ states have allowed persons meeting certain ! experience criteria to be registered when the regulation s first becomes effective. Later, the state may require other factors, such as education, experience, and the passing of a ! written examination in order to become a professional engineer. - The earlier registration on experience alone, however, is not ! voided and remains in force. In the specific case involved, i Regulatory Guide 1.58 Revision 1, became effective on September 1, 3 1980, as NRC guidance. The licensee accepted commitment to l Revision 1 of the Regulatory Guide in Amendment 15 of the FSAR i on April 30, 1981. Prior to that date, the licensee was not connitted to either the basic version of Regulatory Guide 1.58 5 or to Revision 1, although he had unofficially followed the i basic version for several years. The basic version of Regula-1 tory Guide 1.58 endorsed N45.2.6 with very few qualifications ! and did not state that a high school or equivalent education l was necessary but rather only reconnended it. Revision 1 of ! Regulatory Guide 1.58 revised the NRC position on education such as to essentially require that all candidates for certification

      -                                    as QC inspectors under N45.2.6 have a high school education or L                                           a GED certificate. The key word is candidate since that is defined as "a person who seeks office, honor, or title, etc." by the SRIC's dictionary 7us, any licensee or licensee agent encicyee certified as a QC inspector under N45.2.6 prior to April 30, 1981,

. would be an incumbent rather than a candidate and could retain ! his certification without necessarily having either a high

school education or a GED certification and, thus, was considered

! " Grandfathered." The SRIC has discussed this matter with senior personnel of the Quality Assurance Branch of the NRC Office of

Nuclear Reactor Regulation who concurred that the SRIC's interpretation was correct.

! 8. Other Activities ' During the inspection period the SRIC also assisted and/or participated in a number or routine and special inspections and investigations performed by Region IV inspectors and investigators. The SRIC also participated in the hearings before an Atomic Safety and Licensing Board on the matter of TUGCO's application for an operating license for Comanche Peak Steam Electric Station. j .. li 0 -_ _ _ _ ~ -_ _._ m - _ - _ _ _

7 -- I

l 18 l l

1

9. Unmsolved Items Unresolved items are matters about which more infonnation is required in order to ascertain whether they are acceptable items, violations, or deviations. One such unresolved item is discussed in paragraph 4. (8211-01)
10. Management Interviews The SRIC met with one or more of the persons denoted in paragraph 1 on April 6. June 24, and July 1. 9,15, and 19,1982, to discuss inspection findi~ngs and the licensee's position on the findings and other matters.
         *e 1

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                                                                                                                 -Agw-a DEC 131F                             Aqg                ;o Dockets:        50-445/82-11 nw-s a 50-446/82-10 Texas Utilities Generating Company'                           .

ATTN: R. J. Gary, Executive Vice President & General Manager 2001 Bryan Tower Dallas, Texas 75201 Gentlemen: This refers to the inspection conducted by our Senior Resident Inspector, Construction, Mr. R. G. Taylor, during the period A3ril throuch Seotember ~ Mc, of activities authorized by NRC Construction 3ermits CPPR-126 and CPPR-127 for Comanche Peak, Units 1 and 2, and to the discussion of our findings with Mr. R. G. Tolson and other members of your staff during inspection. Areas examined during the inspection and our findings are discussed in the enclosed inspection report. With.in these areas, the inspection consisted of selective examination of procedures and representative records, interviews , with personnel, and observations by the inspector. During this insoection, it was found that certain of your activitfes were in violation with NRC requirements. You were notified of one such violation by our letter of July 7,1982, to which you have responded. A second violation - is forwarded as Appendix A to this letter and, consequently, you are required to respond to this violation, in writing, in accordance with the provisions

         .        of Section 2.201 of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations.                Your response should be based on the specifics contained in the Notice of Violation enclosed.                       Details of the item enclosed with this letter are included in the enclosed inspection report.

i l In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures I will be placed in the NRC Public Document Room unless you notify this office, by telephone, within 10 days of the date of this letter, and submit written application to withhold information contained therein within 30 days of the j date of this letter. Such application must be consistent with the

requirements of 2.790(b)(1).

Officiar q ff J

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Cc.M 2 ; krW l o 4 W 30 3 %2 NF-3000 DESIGN NF.3275-NF-3292.1 included in the stress analysis of the piping system for types shown in Fig. NF-3291(a)-l and described in (1) g allof thespecifiedconditions. through(6) below. 7 (/) Full penetration butt welded groove joint,

   /                   NF 3276         Structural Ated=.ats                            sketc,h (a),

j Structural attachments (NF-1221) may be of either (2) Double fillet welded lapjoint, sketch (b), , the integrat or nonintegral type. I3) Full penetration groove welded tee joint, h NF 3276.1 Integral Attachments (U) Full penetration groeve welded corner joint, (a) Integral attachments include ears, shoes, lugs, sketch (d), cylindrical attachments, rings, and skirts that are (5) Full fillet welded teejoints, sketch (e), fabricated so the attachment is anintegralpart of the (6) Anglejoints, sketch (f). piping component. Integral attachments shall be used When anglejoints are used for connecting a transition in conjunction with restraints or braces when mu!. in diameter to a cylinder, the angle, a, of Fig. NF-tiaxial restraint in a single member is required to be 3291(a)-l sketch (f) shall not exceed 30*. O maintained. (b) Integral lugs, plates, and angle clips, used as (b) A tapered transition having a length not less than 3 times the offset between the adjacent surfaces part of an assembly for thesupportorguidingof pipe of abutting sections, as shown in Fig. NF 3291(b)-1, may be welded directly to the pipe, provided the shall be provided atjoints between sections that differ materials are compatible for welding and the design is in thickness by more than % of the thickness of the adequate for the temperature and load. thinner section or by more than % in., whichever is NF-3276.2 Noolategral Attachements less. The transition may be formed by any process that will provide a uniform taper. The weld may be (a) Nonintegral attachments include clamps, partly or entirely in the tapered section or adjacent to slings, cradles, saddles, straps, and clevises. it. This paragraph also applies when there is a (b) When clamps are used tosupportverticallines, reduction in thickness within a spherical shell or it is recommended that shear lugs be welded to the cylindricalcoursc or plate. Pi Pe to prevent slippage. (c) When the use of backing rings will result in (c) In addition to the provision of (b) above, undesirable conditions such as severe stress, cor-clamps to support vertical lines shall be designed to rosion, or erosion, the requirements of NF-4240 shall support the total load on either arm in the event the be met. load shifts because of pipe or hanger movement or both. NF-3291.1 Design Stress Intensity and Allowable NF 3280 DESIGN OF BOLTS b'"* We u. Umits of desgn stress intensity for welded joints for plate and shell NF 3281 Design for Normal and Upset type supports shall not exceed the applicable design D "dNI'"' stress mtensity value or allowable stress value for the base metal being joined or the electrode being used. The number and cross sectional area of bolts. Temperature differences between the component and required for the design conditions of NF-3 t I2 shall be its support and, where applicable, expansion or determined in accordance with the procedures of contraction of a vessel produced by internal or O., . Appendix XVII. The a!!awable bolt design stress external pressure, shall be considered. values shall be the yield strength values of Table I-13.3 of Appendix I multiplied by the applicable design factors of Table XVII 2461.I-l. NF-3292 Permissible Types of Welded Jolets la IJaear Type Welded Supports NF-3290 DESIGN OF WELDED JOI!VTS The permissible types of welded joints used in NF 3291 linear type supports shall be as stipulated in XVil-Pp--- !C Types _of_ Welded. Joints 2450. In Plate and Shell Type _W41ded SUPPorn NF 3292.1 Allowable Stress IJades.The allowable (a) All welded joints in plate and shell type stress limits for welds in linear type supports shall be j supports shall be continuous and shall be one of the as set forth in Table NF 3292.1 1. l .. 41 F0lA-85-59 w -

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NF.3293-NF.3311 SECTION III, DIVISION 1-SUBSECTION NP

                                    .         s                    .                                                                        t=   ,

GROOVE WELD FILLET WELDED SUTT JOINT tal . LAPgJO, INT j l I qm 1 A k i i GROOVE WELDED T. JOINT GROOVE WELDED CORNER JOINT I*I (d) 4 l

                                                                                                                                                          +-Rs a    .-

t FILLET WEL.D,E D T. JOINT R$  : ANGLE JOINT (f) FIG. NF.3291(a)U PERMISSIBLE WELDED JOINTS FOR COMPONENT SUPPORTS NF-3293 Perndssible Types of WeidedAts NF-3300 DESIGN OF CLASS 2 AND la_ E --_ x t standard Supsts CLASS MC COMPONENT SUPPORTS The permissible types of welded joints used in component standard supports and connections shall NF 3310 GENERAL REQUIREMEN'IS be as stipulated in NF-3291(a) and NF 3292. NF 3293.1 Design Seems Intensity and Allowable NF 3311 Acceptability Stress Lladts foe Welded Jolets. De limit of design

                       ,                                                                     ne requirements for acceptability of Class 2 and stress intensity or of allowable stress for weldedjoints Class MC component support design are given in (a) for component standard supports shall not exceed the                      g,                                     ,      ;

applicable design stress-intensity value or allowable stress value for the base metal being joined. Temp- (a) De design shall be such that the design stresses erature differences between the component and its will not exceed the limits given in this Subarticle. support and, where applicable, expansion or con. Table NF 3132.l(b) l indicates the rules to be used traction of a component produced by internal or for the various classes and types of design procedures. external pressure, shall be considered. The applicable table of allowable stresses for a given , 42 9

           ~                                                                                                                                     - - - - .-

i N F.33 t l -N F.3391.1 SECTION 111, DIVISION 1-SUBSECTION NF material to be used with a specific design procedure is NF.3321.4 Faulted Conditions. (In course of prep- A s- 1 stipulated inTable NF-2121-1. aration.) (b) De design procedure shall be one of those referenced in Table NF-3132.l(b) l applicable to NF-3330 . DESIGN OF LINEAR TYPE i Class 2 or Class MC component supports. SUPPORTS BY ANALYSIS 1 c) The esign details shall conform to the rules of M hi M st a h M m k satisfied for the Design and Operating Conditions are as given in NF-3230. I NF-3320 DESIGN OF PLATE AND SHELL

                                    'IYPE SUPPORM BY ANALYSIS                        NF.3340                DESIGN OF COMPONENT

' ANDARD SMRU BY NF-3321 Stress IJadts - ANALYSIS NF 3321.1 Design Conditions. The stress limits The design of component standard supports shall which shall be satisfied for the Design Conditions .- be m accordance with NF 3320 or NF-3330. j (NF 3112) stated in the Design Specifications are a e e Si ess. The allowable value 4y 3 6 of this stress due to weight and other sustamed loads ,s i I as follows: Component supports may be designed by ex-perimental stress analysis in accordance with Ap-

, ,                                           ofS n                         (I)         pendix II.

I

    ;               where                                                            NF 3360                DESIGN BY LOAD RAT 1NG

!; ei - membrane stress as defined in NF.3213.5, psi Component supports may be designed by load !# S= allowable stress value from Table I 12.1 rating in accordance with the requirements of NF-3 60. Ib) General Membrane hs Bending Stress. The allowable value of general membrane and bending NF-3380 BOLTING DESIGN ! I stresses combined due to weight and other sustained ' The Provisions of NF-3280 apply. i loadsis as follows:

'   l                                                                                 NF 3390               WELDED JOINT DESIGN
    !                                     ai + os f 1.5 S                 (2)

NF 3391 Perndssible Typse of Welded Jointe where la Plate and Shu *I'm W as- bending stress, which is the variable com- ne types of weldedjoints shall be as stipulated in (! j ponent of normal stress (described in NF-3213.6) applied to the full shell cross section NF-3290 for Class I component supports,except that for groove welded T-joints, groove welded corner l or the thickness of the plate section under ( consideration joints, and fillet welded T joints, as shown in Fig. NF-3291(a) 1, sketches (c), (d), and (e), respectively, the Q. (c) ne maximum tensile stress at the contact welds may be intermittent instead of continuous. . surface of a weld producing a tensile load in the throuShthickness direction of plates r.nd elementsof NF 3391.1 AllowableStressIJanits rolled shapes shall be limited to 0.5 S as shown in Fig. (a) Stresses in welds in plate and shell type supports NF 3321.l(c) l. shall not exceed the allowable tensile, compressive or s shear stress value, as applicable, stipulated in Table NF 3321.2 Norunel and Upset Conditions.The stress NF 3292.1 1, for the base metal beingjomed. Temp-

      !        limits which must be satisfied for the Normal and                      eratum Wennees tween the component and h I

Upset Conditions shall be the two limits stated in NF- support and, where applicable, expansion or con- - 3321.1, Design Conditions. traction of a vessel produced by internal or external

                                                                                                    ~

NF-3321.3 Eanergency Coeditions. (in course of pressure shallbe considered. preparation.) (b) The maximum tensile stress at the contact o i - t

   . , _ _ _ __ m                                               . . _ _        _ _ . _
                                                                                              . _ _ . _ . . ~ . , _ , . _                                        . .         _ ,.       _.              _.      .

__ . . h. - - . . . . - i

         .-                                                                                        NF-3000 DESIGN                                                             N'!.3391.1-N F.3400 l              surface of a weld transmitting a tenute load in the
f l f through thickness directica of plates and elements of 2 e < os s rolled shapes shall be limited to 0.5S, as shown in Fig.

NF-3321.I(c)-1. A;LJLn$L;L;LJLsk ' I NF 3392 Permissible Types of Wald Joimes in Lineer Type Supports f j The types of welded joints shall be as stipulated in j Appendix XVII-2450. ! NF 3392.I A5ewableSeemsuudes 4 (a) Stresses in welds in linear type supports shall not exceed the values set forth in Tak NF 3292.1 1. l (6) The mammum tensile stress at the contact j q7 p surface of a weld transmitting a stress in the through l thickness direction of plates and elements of rolled ,

l*3 shapes shall be limited to 0.35,. but not more than %

j f of the minimum tensile strengthof thesteel,asshown in Fig. XVII-2211(c)-1. l e < o.s s l' sL n A sL;L n NF-3393 PerselasiMe Typse of Wald Joimes in Component Standard Supporte The permissible types of welded joints for com-

              @                   l                                                              j I

ponent standard supports shall be as stipulated in NF-339I and NF-3392. i NF.3393.1 Allowebleseemsunies j Stress limits for welds in component standard }l '% supports shall not exceed the allowable limits sti-

pulated in NF 3391.1 or NF-3392.1. .

U P l w NF 3400 DESIGN OF CLASS 3 i COMPONENT SUPPORTS

                             . - u shawn unene stam in the in sh ihicknees dimetsen j                                  of plates and elements of round shapes, evaluated at the
                    ,                                                                                                    The design of Class 3 component supports shall be conteet point of the weed one with the elenwnt wrfase.
                             '" ^ " "'d                                                                         in accordance with the requirements of NF 3300, using one of the design proceduresindicatodin Table FIG. NF.3321.1(el.1 ILLUSTRATIONS OF MAXI.                                             NF 3132.l(b).I for Class 3 construction. The ap.

l MUM DESIGN STRESS IN THROUGH THICK. plicaW table of allowable stresses for a given material l NESS DIRECTION OF PLATES AND ELEMENTS to be used with a specific design procedure is j OF ROLLED SHAPES slapulatedin Table NF 2121 1. i 1 C 1 45

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4 i

(A Cvg %j kGb3 -l Oj M 3)) thl CASE CASES OF ASME SOILER AND PRESSURE VESSEL CODE Approeed by Counca, Noeember 3, !975 Case 1734 Wold Design for Use for Section III, Divieion 1, Class 1, 2, 3 and MC Conseustion of C:r;: : t Supports, legany: What alternate rut e may be used for welded . joints as referenced in NF4291(a) and Fig. NF4291(a).1 for Section DI, Division 1. Case 1,2,3 and MC plata

     .                           and almil type Component Supportaf Reply: It is the opinion of the Committee that as an alternate to the requirements referenced in Section III, Division 1, NF.3291(a) and NF.3291(a).1 the following                        .

rulee may be used for Section 111, Division 1,Osas 1,2, 3 and MC construction of olete and shell tvn Comoo. neat Supports: 3 a Mwelded joint between a surface and a

         )                        closed tubular section or a closed formed section, as shown in Figs.1,2 and 3, may be used on plate and shell type component supports.

(2) & completed Data Report shall reference this Cane. l lm P g j[ ' l l  ? l l l l

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                                                                 -c.              ,

'l j PlG.1 FIG. 2 P10. 3 i l 4 i w e, S., w u. m3 y l F0lA-85-59

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