ML19309D061
| ML19309D061 | |
| Person / Time | |
|---|---|
| Issue date: | 02/14/1980 |
| From: | Brown R, Jerrica Johnson, Whitesell D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19309D058 | List: |
| References | |
| REF-QA-99900107 99900107-80-1, NUDOCS 8004100034 | |
| Download: ML19309D061 (19) | |
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U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT REGION IV Report No.
99900107/80-01 Program No. 51300 Company:
Graver Energy Systems, Inc.
4809 Tod Avenue East Chicago, Indiana 46312 Inspection Conducted:
January 7-11, 1980 2
9 b/7. /9,ft)
Inspectors:
ossL. Brown,TontractprInspector Date' Component Section I Vendor Inspection Branch t
/
'f hk I
J. M. 7ohnson, Contrycfo'r Inspector Date Component Section I Vendor Inspection Branch
,/
I[/ff/9fd Approved:
/
Date'
/j+rD. E. Whiteself," Chief g' Component Section I Vendor Inspection Branch Summary Inspection Conducted on January 7-11, 1980 (99900107/80-01)
Areas Inspected:
Management meeting and implementation of 10 CFR 50 as related to the control of nonconformances and corrective action, and the field reported construction deficiencies in the containment vessels manufactured by this company. The inspection involved sixty-four (64) inspector hours on site by two (2) NRC inspectors.
Results:
In the areas inspected, no deviations from commitment or unresolved items were identified.
8004.1000 N
2 DETAILS SECTION I (Prepared by Ross L. Brown)
A.
Persons Contacted G. M. Ault, Program Manager
- J. Halfman, Manager of Quality Assurance
- D. L. Sanders, Senior Quality Assurance Engineer
- Attended exit interview B.
Initial Management Meeting 1.
Objectives The objectives of this meeting were to accomplish the following:
To meet with the Graver Energy Systems, Inc. (GES) management a.
persons responsible for the administration of the QA program and to establish channels of communications.
b.
To explain the NRC' inspection program including the LCVIP organization, VIB inspection methods and documentation.
To explain the White Book data and its distribution.
c.
d.
To describe the NRC evaluation of the ASME inspection system.
To determine the extent of the company'e. involvement in the e.
com.nercial nuclear business.
f.
To discuss the impact of 10 CFR Part 21.
g.
To discuss the scope of this inspection including the follow-up of constructions deficiencies that have been reported to NRC (these deficiencies are covered in Section I, Paragraphs C and D, and Section II, Paragraphs B & C).
2.
Methods of Accomplishment The preceding objectives were accomplished by a meeting with Mr. J. Halfman, Manager of Quality Assurance.
L
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n
3 a.
The Vendor Inspection Branch organization was described and its relationship to NRC Region IV and the NRC Headquarters component of the Office of Inspection and Enforcsment.
b.
The conduct of Vender Inspection Branch inspection was described and how the inspections are documented including the inspection report, responses to the report, how proprietary information is handled, the public document room and the White Book.
c.
The purpose, scope and status of the NRC's program for the evaluation of the ASME inspection system was discussed.
d.
The GES contribution to the nuclear industry was discussed, including current and projected activities.
e.
Status of the ASME certification of authorization and third part inspection arrangements.
3.
Findings The inspector was supplied with the following information:
Graver Energy Systems, Inc., facility located in East Chicago, a.
Indiana, is devoted 100% to the fabrication of components for the commercial nuclear industry, i.e. containment liners and associated items, fuel pool liners, storage tanks and pressure
- vessels, b.
The present contracts are scheduled for completion in late 1981 c.
The ASME Certificate of Authorization Numbers:
N-1211-1, N-1212-1, and N1213-1 issued for use at the East Chicago, Indiana, facility only; and Numbers: N-1211, N-1212 and N-1213 issued for use at various locations, subject to audit; all certificates expire in September and October, 1981.
d.
The Authorized Inspection Agency for the GES facility is Kemper Group (American Motorist Insurance Company). The inspection function is performed on a part time basis (pre-sently three days per week).
e.
At each construction site where Graver has nuclear contract responsibilities (i.e. River Bend).
Graver has a resident Senior Quality Assurance Engineer that reports to the Manager of Quality Assurance at the East Chicago, Indiana office (Corporate Headquarters).
1 4
C.
Reported "J" Weld Indications
===1.
Background===
Niagara Mohawk Power Corporation reported to NRC-Region I that several cases of lack of fusion existed along the J-bevel area of the welds joining the cadweld sleeves to containment plates (knuckle area) in the Nine Mile Point, Unit 2 Containment Vessel.
2.
Findings The inspector was informed by Graver management that Niagara a.
Mohawk Power Corporation cancelled its contract for this con-tainment vessel in December 1978, and that all documents (pro-curement, manufacturing, quality, etc) related to this vessel have been turned over ta the utility company, and were not available. The inspector therefore could not evaluate the vendor activities relating to the reported defective welding.
b.
Graver management stated that the containment vessels for River Bend Units 1 and 2, contain welds made with the same welding process, and these welds were also found to have several of the same type of defects when ultrasonically examined. The disposition of these deficiencies are covered in Section II, Paragraph B, of this report.
Graver management also stated that the automatic flux core c.
welding process used in welding the cadweld sleeve to the con-tainment plate, was used only in the manufacture of the Nine Mile Point-Unit 2 and River Bend Units 1 and 2 (Section II, B.
their report). The procedure for this welding process has been removed from the approved procedure list, and is.no longer used in making these welds.
d.
Graver management further stated that the a':tomatic flux core l
process may be used for other welds in the vessel, but these welds are then being ultrasonic examined, in addition to magnetic particle /
liquid penetrant and visual examined.
D.
Reported Lack of Post Weld Heat Treatment 1.
Background Information NRC Region II was notified on August 24, 1979, by Carolina Power and Light Company, that the valve chambers of the containment vessels for Shearon Harris Units 1 and 2 may have nozzles which have'not been post weld heat treated (PWHT).
5 2.
Findings a.
The inspector was informed that this contract had been termin-ated, and all of the pertinent QA/QC records and documentation had been either forwafded to Ebasco, the customer, or had been placed in archival storage, and would not be readily retriev-able for, review. The vendor stated that Ebasco hgd not informed them that the owner, Carolina Power, had reported a potential construction deficiency involving the PWHT of the valve chamber nozzles.
b.
Graver is of the opinion that the valve chambers including the nozzles were furnished in compliance with the contract and code requirements, and offered the following documents to support this position:
(1) Letter from Ebasco to Graver, dated June 20, 1979, which states in part; "We have reviewed our documentation package for the Unit 1 and 2 valve chambers and cannot locate the following:
(1) Post Weld Heat Treatment Records."
(2) Response to the above letter - Graver to Ebasco, dated July 11, 1979 which states in part, "There was no post weld heat treatment required on those vessels, so there are no PWHT records."
c.
IE Inspection Report No. 99900505/79-04,Section I, Paragraph C.3.d. states in part, "... An evaluation by Ebasco Licensing, Materials Engineering and Engineering determined this was not a reportable incident and the material could be used-as-is."
And Paragraph C.3.e states that, "Ebasco has analyzed the risk of this deficiency and has shown that it is not a serious risk.
It is possible that this requirement for post weld heat treat-ment could be eliminated for thi's type of valve chamber."
d.
The Valve Chamber is a complete vessel fabricated from SA-516, Grade 70 steel 1/2 to 1 inch in thickness therefore, it is exempt from PWHT as stated in ASME Section III, Article NE, Subarticle NE-4322, Postweld heat treatment is not required for vessels fabricated of materials stipulated in NE-2322(a) up to and including 1 inch in thickness at the welded joint.
E.
Control of Nonconformances and Corrective Action 1.
Objectives The objectives of this area of the inspection were to verify that procedures-have been established and implemented for:
e e
6 Disposition of nonconformances that provide for:
a.
(1) The control.of nonconforming materials, parts, or com-ponents to prevent their inadvertent use or installation.
(2)
Identification, documentation, segregation, and disposi-tion of nonconforming items and notification to affected organizations.
b.
Corrective action that provides for:
(1) Review and evaluation of conditions adverse to quality to determine the cause, extent, and measures needed to correct and prevent recurrence.
(2) Reporting these conditions and the corrective action to management.
(3) Assuring that corrective action is implemented and maintained.
2.
Method of Accomplishment The above objectives were accomplished by a review of the following documents:
GES-Nuclear Quality Assurance Manual (QAM) - Section XV-A, a.
Revision 2, Nonconformance System.
b.
QAM - Section XVI-A, Revision 1, Corrective Action System.
Nonconformance Reports (NCR) for Order No. 61040N, for both c.
suppliers and Graver shop from July 1977 - NCR No. 21 through November 1979 - NCR No. 93.
d.
Inter-organization Correspondence Semi-annual Reports dated Februa ry 16, 1979, and October 22, 1979.
-Corrective Action Report - CAR No. 1.
e.
3.
Findings QAM - Section XV establishes a nonconformance control system a.
to:
prevent the use of nonconforming items; assign the responsibility for the identification, documentation and disposition of nonconformances.
b.
QAM - Section XVI establishes the Manager of-Quality Assurance responsible for the review of NCRs, audit reports, surveillance
7 reports, etc., for adverse quality trends. The review shall be documented by memorandum to upper management.
The Manager of Quality Assurance is also responsible for either revising and improving the quality assurance program or to issue a corrective action. report.
c.
The NCRs include the following information:
(1) Nonconformity (2) Cause (3) Action to prevent recurrence (4) Disposition (5) Material Review Board disposition (6) Applicable approvals Items c. (1) and c. (3) are entered by the Area Foreman.
d.
The Inter-Organization Correspondence memoranda were addressed to the President from the Manager of Quality Assurance.
Receipt of the reports was acknowledged by the President's initials on the reports.
No deviations from commitments or unresolved items were e.
identified in this area of the inspection.
F.
Exit Interview An exit interview was held with management representatives on January 11, 1980.
In addition to those individuals indicated by an asterisk in paragraph A of each Details Section, those in attendance were:
G. D. Westcot, President J. Galinsky, Manager of Engineering The inspector summarized the scope and finding of the inspection.
The inspector informed those present that GES will receive a copy of the inspection report for their review for proprietary information.
Management comments were generally for clarification only.
8 DETAILS SECTION II (Prepared by J. M. Johnson)
A.
Persons Contacted
- R. W. Bodley, Manager, Manufacturing
- M. J. Halfman, Quality Assurance Manager
- D. Sanders, Senior QA Engineer (River Bend)
R. Warren, QA Engineer
- Denotes attendance at the exit meeting.
B.
Report on Deficiency in Cadweld Sleeve J Bevel Welds (River Bend):
===1.
Background===
Letter RBG-6275 dated March 30, 1979 from Gulf States Utilities to the Director, Region IV, USNRC identified a potential reportable deficiency related to the welding of cadweld sleeves to base plates performed by Graver Energy Systems.
Subsequent letters confirm that this is a reportable deficiency and that it relates to lack of fusion, and slag inclusions in the J bevel area of the cadweld sleeve shop welds performed to Graver welding procedure 313 N.
Additional non-destructive examinations indicated that the scope of this problem is sufficient cause rejection of all the cadweld sleeve attachments (approximately 6,000).
These sleeves form load transfer structures-through the drywell, for reactor pedestal, weir wall, containment vessel, and containment loads.
2.
Objectives The objectives of this area of the inspection were to determine the following related to the cadweld sleeve welding deficiency:
a.
What caused the deficiency?
b.
Has corrective action been taken for the identified cadwelds?
c.
Has preventive action been taken?
d.
Have all possible instances of the problem been identified and corrected for this plant and any others?
c 3.
Method of Accomplishment
[
The preceding objectives were accomplished by examination and dis-cussion of the following:
d' 6
e
9 Gulf States Utilities letters to the Director, Region IV, USNRC:
a.
RBG - 6275 dated March 30, 1979; RBG - 6347 dated April 27, 1979; RBG - 6443 dated May 31, 1979; RBG - (no number) dated June 27, 1979 and attached complete report.
b.
Purchase Order No. RES 219.710-C056 for Job Order No. 12210/12330 to Graver Energy Systems.
Review included Contract Change Orders as well as the invoked Technical Specification No. 219.710 (Shop Fabrication and Field Erection of the Reactor Containment Vessel, Penetrations and Hatches; Drywell Head, Hatches and Steel Forms; and Shield Building Hatches.) These documents were examined to determine ASME Code applicability, contract technical and quality requirements, and any specific requirements pertinent to these welds and their nondestructive examination (e.g. Figure 3 of the Technical Specification).
Contract Change Order No. 22 requiring 100% replacement of cad-c.
Craver letter 2200; 4276 dated August 10, 1979).
d.
Graver Nuclear QA Manual, Revision 8, especially Sections I (General), 3 (Design Engineering), 8 (Welding QA), 9 (Nondestruc-tive Examination) and 15 (Nonconformances) to determine applicable requirements at the time of original fabrication.
Also, similar sections were reviewed in Graver Nuclear QA Manual - Edition II, which is the current manual revision applicable to the repair work.
Examination of one Corner Junction (No. 22E-30-61060N) on hold e.
at Graver (NR(/21, 22E - 30) to observe configuration of J bevel cadwelds on base of plate.
f.
Weld procedure No. 313N (used to weld sleeves to plates) titled Single "J" Groove Cadweld Sleeve. This is a fully automatic Flux Core Arc Weld procedure (FCAW - Automatic). which was qualified to ASME Code Section IX requirements.
The Procedure Qualifi-cation Record (PQR) is dated 7/29/76 and the weld procedure was approved by Stone and Webster on 8/24/76.
Note that the procedure has now been voided and is no longer in use.
g.
Graver Drawings: NL 10401 B, Revision 1, Assembly and Detail of Corner Junction Items E30A and E31A; NL 10401C, Revision 2, Shop Assembly of Items EA 30 and EA31.
These drawings indicate weld procedures to be used and NDE (nondestructive examination) to be used on specific joints.
h.
Shop traveller for Corner Junction E31 to review documentation of fit up examination, welding and NDE examination, Magnetic Particle and Visual, and welding rework.
10 i.
Magnetic Particle (MP) procedure MPE-9 and its acceptance 5/17/77 by Stone & Webster and 3/29/78 by the ANI (Authorized Nuclear Inspector).
j.
Visual examination procedure VE-II, Revision 2, and its accept-ance by Stone and Webster on 4/25/77 and by the ANI on 8/21/78.
k.
Qualification and eye examination records for two NDE examiners who performed NDE on certain of these welds, for the processes used (MP and Visual).
Qualified Welder List for the time frame (early 1977) when cer-tain of the subject welds for 22-E30-1 were performed by a welder designated as Oval 27.
He is listed as qualified for FCAW -
Automatic, the process used.
Rework procedures and Stone & Webster approval:
RCS-1, Revision m.
4 (Removal of Cadweld Sleeves); WP-1, Revision 2 (Welder Per-formance on Cadwelds); CSSI-1, Revision 4 (Cadweld Sleeve Replacement Surveillance and Inspection).
These procedures delin-eate requirements and controls for this rework.
Weld procedure used for rework and S&W approval:
319N, Revi-n.
sions 4 and 5 (Single "J" Groove and Fillets).
This is an SMAW (Shielded Metal Arc) manual welding procedure and has been qualified to ASME Code Section IX requirements.
o.
Cross-checked six welders listed on rework travellers for their inclusion on the Qualified Welder List for the Procedure used (319N).
p.
Reviewed records required per RCS-1 for EA30, Repair No. 16 for cavity examination per MPE-9, cavity repair and reexamin-ation and x-ray of the area to procedure RE9.
This was a base plate repair after cadweld removal, q.
Reviewed traveler for IE30, Sleeves Nos. 2 and 27 for the MP examination of the base plate, visual and MP examination of the final weld, and Visual and MP examination at weld deposited for sleeve no. 2.
Stone and Webster also observed MP of the base plate and final inspection.
Stone and Webster E and DCR (Engineering and Design. Change r.
Report).o. P-M-(G)-193 dated 12/13/79 concerning clarification N
of NDE requirements of the specification (Job order 12210).
- This will be incorporated in the purchase order by contract change order.
11 4.
Findings Graver Management indicated that they have not written a defi-a.
ciency report or an internal nonconformance report relative to this discrepancy, because it is their position that the original welds met the applicable ASME Code requirements and the contract requirements. The welds had also passed the pull test require-None had been shipped to the River Bend site prior to ments.
the rework.
b.
ASME Code 1974 - Edition,Section II, Division I and Section III, Subsection NE, Class MC, were not imposed across the board by the purchase order, or the technical specifications.
Selected sections of the code were imposed on certain items.
The subject structural steel base plates, and cadweld sleeves, are not required to be code-stamped items; and therefore there were no ANI (Authorized Nuclear Inspector) hold points, or inspections of these welds.
The only containment parts required by the specification to be code stamped, are the penetrations, personnel air locks, etc.
The Technical Specifica-tions did, however, impose Section V, and Section IX require-ments of the ASME Code on all welding and NDE.
It also con-tained a chart identifying the general types of welds, and the NDE required for each type.
The type of weld for the J bevel cadwell sleeve joints, required visual inspection and MP/LP exam-inations only. The specification also stated in part " Magnetic Particle -
The methods shall be capable of detecting surface and subsurface discontinuities."
Stone and Webster did perform vendor surveillance on this con-c.
tract during this time frame, but had not identified any hold points for welding of the cadweld sleeves, so there is no docu-mentation, available at Graver of Stone and Webster surveillance of these specific welds.
d.
It is not clear whether the vendor has determined specifically why such a high percentage of the welds failed. The welding proce/are was qualified in accordance with ASME Code,Section IX; however, it is no longer being used.
Graver management stated that production conditions were less controlled than conditions during qualification and this may have been a causative factor.
Volumetric NDE examination was not required by the purchase e.
order and technical specification.
The ability of MP to detect subsurface discontinuities is limited, in depth, and is not a substitute for volumetric examination.
Therefore, the lack of fusion was not identified by the NDE method specified.
12 f.
The deficiency resulted primarily from the two interrelated conditions described in d. and e. above. These are:
(1) Weld procedure 313N, although properly qualified to ASME Code Section 9, resulted in a number of production welds with rejectable indications.
(2) The NDE method specified in the procurement documents and used was inadequate to identify the rejectable indications (i.e. internal lack of fusion and discontinuities).
g.
Corrective action has been taken as follows.
The rework has been completed for the cadueld sleeves, including replacement of new sleeves.
The rework was required by Contract Change Order No. 22.
The rework was primarily done in the Lansing Satellite Shop (non-code). Repairs were made by a manual welding procedure, 319N, which was qualified in accordance with ASME Code Section IX, and approved by Stone and Webster in accordance with contract requirements.
There were additional controls added including training, increased surveillance, and additional MP requirements.
Procedures providing added controls include CSSI-1 (Cadweld Sleeve Replacement Surveillance and Inspection), WP-1 (Welder Performance on Cadwelds) and RCS-1 (Removal of Cadweld Sleeves).
These changes, including the examination by MP at certain stages of welding for a percentage of welds, should provide assurance that the weld deposited material has fused with the base metal, h.
Preventive action has been taken by Graver, as follows. The weld procedure 313N which produced a high percentage of defective welds, is no longer used.
It was used only for welding the cadweld sleeves on the Nine Mile Point and River Bend projects. The welding problem had been identified earlier at Nine Mile, and has been documented as a reportable deficiency by the utility.
Graver has been released from that contract and therefore does not know the current status of the rework or whether the utility has determined its reportability order 10 CFR 21.
There do not appear to be any further generic impli-cations.
i.
Preventive action taken by Stone and Webster consists of the following.
Stone and Webster have expanded their NDE require-ments in Specification No. 219.710..The NDE expansion includes a requirement for partial penetration welds and fillet welds over 3/4 inch, to be MP or LP examined at their 1/2 points, and full penetration welds to be MP or LP examined each 1/2 inch l
of weld depth.
It also specifies that all MP examinations shall l
use the prod method for magnetizing the material.
The revised spec also clarifies the NDE requirements for specific components, 1.
13 i.e. radiograph flued-head welds.
The clarification is designed to eliminate misinterpretation of the buyer's requirements.
j.
All possible instances of the problem have been identified.
Note that a similar construction deficiency was identified earlier on the Nine Mile Point project.
This will be corrected at the site by construction contractor, Chicago Bridge and Iron (CBI). Graver used weld procedures No. 313N only on Nine Mile and River Bend fabrication.
For the Millstone fabrication, these welds were performed to a manual welding procedure, and Graver management stated that this problem does not exist on Millstone.
k.
Followup at Stone and Webster is indicated to assure that con-tract requirements to Graver were adequate and conform to the respective SAR commitments for River Bend and Nine Mile Point.
1.
No deviations or unresolved items were identified within this area of the inspection.
C.
Report on Deficiency in Tee Welds in Corner Junction Assemblies (River Bend):
1.
Background Information Letter RBG-6549 dated July 12, 1979 from Gulf States Utilities to the Director, Region IV, USNRC, reporting a construction deficiency concerning the "T" welds made by Graver Energy Systems.
Subsequent correspondence indicates that the 45 Ultrasonic scan used by Graver failed to disclose discontinuities and cracking in the root area of the welds and therefore may not be adequate to achieve a reliable exam-ination.
The Tee weld is a full penetration double-bevel groove weld at the junction of the containment base plate with the liner.
The River Bend Containment is a free-standing unit.
2.
Objectives The objectives of this area of the inspection were to determine the following related to the Tee junction welds:
What caused the deficiency?
a.
b.
Has corrective action been taken for the identified Tee welds?
I c.
Has preventive action been taken?
d.
Have all possible instances of the problem been identified for
{
this plant and any others?
1 l
i S
14 3.
Method of Accomplishment The preceding objectives were accomplished by examination and dis-cussion of the following:
Gulf States Utilities letters to the Director, Region IV, USNRC:
a.
RBG-6549 dated July 12, 1979 and attachment; RBG-6698 dated September 12, 1979; RBG-6681 dated November 12, 1979.
b.
Purchase Order No. RES 219.710 - C056 for Job Order No.12210/
12330 to Graver Energy Systems.
Review included Contract Change Orders as well as the attached Technical Specification No. 219.
710 (Shop Fabrication and Field Erection of Reactor Containment Vessel, Penetrations and Hatches, etc.) -These were examined to determine ASME Code applicability, contract technical require-meats, and specific requirements pertinent to these welds and their nondestructive examination (e.g. Figure 3 of the Technical Specification).
Graver Nuclear QA Manual, Revision 8, especially Sections 1 c.
(General), 3 (Design Engineering), 8 (Welding QA), 9 (Nonde-structive Examination), and 15 (Noaconformances) to determine applicable requirements at the time of original fabrication.
Also, similar sections were reviewed in Graver Nuclear QA Manual - Edition II, which is the current manual revision applicable.
d.
Examination of one Corner Junction (No. 22E-30-6106N) on hold at Graver (NR#21 on 22E-30) to observe configuration of the Tee weld.
e.
Weld procedure No. 302N, used to perform the Tee Junction weld, titled Double Bevel Groove Welds. This procedure requires one or two manual Shielded Metal Arc Weld (SMAW) passes and the weld-out by automatic Submerged Arc welding (SAW).
The automatic weld machine was a dual Laad Dart 2108. The procedure was qualified in accordance with ASME Code Section IX and the Procedure Quali-fication Record (PQR) is dated October 15, 1976.
The weld pro-cedure was approved by Stone and Webster on 11/10/76 for Revision 1 and 9/14/77 for Revision 2.
f.
Qualified Welders List for the time frame (1977) when certain of the Tee welds were performed by welders identified by Hex 37 and clock No. 1452.
These welders were listed as qualiff.ed for the procedure used (302N).
g.
Graver Drawings: NL10401B, Revision 1, Assembly and Detail of Corner Junction, Items E30A and E31A; NL10401A, Revision 6,
15 Assembly and Detail of Corner Junction Item E31; NL10401, Revision 7, Assembly and Detail of Corner Junction Item E30; NL10401C, Revision 2, Shop Assembly of Items EA30 and EA31.
These drawings indicate weld procedures to be used and NDE to be used on specific joints.
h.
Shop traveler for Corner Junction E-31 to review documentation to fit up examination, welding, and NDE examinations (Ultrasonic Testing (UT) Magnetic Particle examination (MP) and Visual).
i.
Visual examination procedure VE-II, Revision 2, and its accept-ance by Stone and Webster on 4/25/77 and by the ANI on 8/21/78.
j.
Ultrasonic Testing procedure UE-9, Revision 2, approved by Stone and Webster 3/2/77.
It is signed by Conam, Level III UT examiner, k.
UT report for E-31 dated 6/7/77 indicating performance to pro-cedure UE-9, Revision 2 (Conam procedure no.59-UT-075, Revision
- 2) and showing no reportable indications.
It is signed by a Conam Level II examiner.
1.
Letter dated 4/7/78 from the ANI indicating review of Special Process Procedures (including the applicable NDE procedures).
Letter dated 8/21/78 from the ANI verifying the demonstration m.
to him of UT Examination procedure UE-9, Revision 2.
Personnel qualifications for three (3) UT Level II Conam per-n.
sonel who performed UT on the subject Tee welds.
(Note that Graver subcontracted UT examination to Conam).
Approved Suppliers List dated 8/31/77 showing Nuclear Energy o.
Services (Conam Division) to be a qualified supplier of services for UT.
p.
Graver Nonconformance Report (NCR) No. 72 dated 3/22/79 identi-fying that a suitable UT technique was not employed to assure total examination of the Tee welds.
Rework required reexamin-ation by Graver UT personnel utilizing technique sheets approved by a Level III UT examiner. Also, the subcontractor Conam was removed from the Approved Supplier List.
The NCR is approved by Graver.
q.
Graver NCR no. 77 dated 5/22/79 identifying linear discontin-uities in Tee welds previously examined and accepted by the UT subcontractor. The NCR requires reexamination by UT and rework at the River Bend Site utilizing a qualified Shielded Metal Arc
16 Weld (SMAW) procedure. Also required is utilization of an acceptable UT technique for the examination of further welds; and modification of the welding procedure and equipment.
The NCR is approved by Graver.
r.
Graver NCR No.77, Revision 1, dated 12/19/79 requires repairs at the site with Graver Welding Process Nos. WRCJ-1 and 305N, which have been properly qualified.
This NCR is still being processed.
Graver Corrective Action Request (CAR) No. 1, and attached s.
report titled "Cause and Corrective Action Analysis Covering Sub-Surface Defects Found in River Bend Corner Junction Tee Welds" dated 12/4/79.
t.
UT procedure to be used at the site for acceptance of rework (and all UT) is procedure No. UE-9, Revision 3 (or Revision 4, if approved).
It requires the use of a technique sheet which is developed and approved by a Level III for different weld configurations.
UE-9, Revision 3, is signed by a Level III con-sultant from supplier of services, Calumet Engineering Services.
The procedure appears to be approved by Stone and Webster, although the stamp and signature are blurred, r
Approved Vendor Lists dated 7/28/78 and 9/20/79 showing Calumet u.
Engineering Services as an approved consultant for Level III UT services.
Weld repair procedure (to be used at the site for rework) No.
v.
WRCJ, Revision 0, and its approval by Stone and Webster on 9/17/79.
Weld procedure (to be used at the site for rework) No. 305N, w.
revision 8, and applicable PQR.
This procedure has been qualified in accordance with ASME Code Section IX and approved by Stone and Webster.
Stone and Webster E and DCR (Engineering and Design Change x.
Request) No. P-M-(G)-193 dated 12/13/79 concerning clarification of NDE requirements of the specification.
This will be incor-porated in the purchase order by contract change order.
It is more specific about required NDE, and for'UT specifically it now requires use of UT transfer method (except for specified conditions).
y.
Stone and Webster TWX No. BBTX-079-087 dated 7/30/79 stating that an SRT (Shipping Release Tag) has been issued, and instructing Graver that the documentation package shall include NCR#77. Also, UT Data is to be supplied, the 24 corner junctions shall be identified as Nonconforming, and the defects are to be reworked in the field to procedures approved by Stone and Webster.
l
17 Stone and Webster Certificate of Compliance is dated 8/3/79 z.
shipping the Corner Junctions (know to be nonconforming).
Shipping Release Tag (SRT) No. 27694 releases certain corner junctions and lists N and D (Nonconformance and Disposition)
Nos. LOO 8 and LOO 4 and E and DCRs Nos. P-M-(G)-142 and P-M-(G)-147.
aa.
Graver letter dated October 16, 1979 to Suziedelis of Stone and Webster, Rhode of Niagara Mohawk, and Carlson, of USNRC (Region I) identifying a potential 10 CFR 21 Reportable Condition with respect to linear discontinuities on Tee welds on the base ring assembly of the primary containment liner at Nine Mile Point.
This is a similar condition to the one identified on River Bend, in that the same welding process was used (and, presumably, the same UT procedure and personnel).
The Graver letter indicates their inability to pursue this for further investigation and, if needed, rework, since they have been removed from the contract.
Hence, further action is up to Niagara Mohawk.
4.
Findings The causes of the one reported deficiency and one potential a.
Part 21 notification, related to the Tee welds are:
(1) welds with rejectable indications and (2) UT technique failing to disclose discontinuities.
b.
Graver NCR No. 72 was issued 3/22/79 delineating the UT problem.
Graver maintains that the UT problem was caused by the UT tech-nique used by the subcontractor for these welds rather by a faulty UT procedure.
The 45 scan used by Conam did not cover the entire weld. No technique sheets for different weld config-urations were used to indicate UT scan required.
The failure of weld procedure 302N in a percentage of production c.
welds, although it had been properly qualified in accordance with ASME Code Section IX, has been evaluated by Graver.
302N is a manual and automatic procedure with one or two passes performed by manual SMAW (Shielded Metal Arc Welding) and the weldout by machine SAW (Submerged Arc Welding) by a Dual Head Dart 2108 Machine.
Graver NCR (Nonconformance Report) No. 77 dated 5/22/79 states as cause of the nonconformance:
" Unacceptable weld bead shape and penetration of the root pass area in the first sub-merged are pass caused by major variations in the welding current and variations in electrode position." Further evaluation docu-mented in Summary Status Report dated 12/4/79 indicated errors in the original evaluation of the cause.
NCR No. 77, Revision 1 dated 12/19/79 has therefore been issued to show the cause as follows:
" Excessively deep sub arc weld penetration on initial sub arc passes due to (a) use of an insufficient number of
18 manual weld passes prior to the start of sub arc welding, and (b) use of excessively high welding current on the first two dual-head sub are passes."
d.
ASME Code 1974 Edition,Section II, Division I, and Section III, Subsection NE, Class MC, were not imposed across the board by the purchase order or technical specification.
Selected sections are imposed on certain items'.
The subject welds are not Code-stamped and hence there were no ANI (Authorized Nuclear Inspector) hold points or inspections. The only containment parts required by the specification to be code-stamped are the pene-trations, and personnel air locks and equipment hatches.
The Technical Specification did, however, impose Section V and Section IX requirements of the ASME Code on all welding and NDE.
It also contained a chart (Figure 3) identifying general types of welds and the NDE required for each type of weld.
The specific "T" weld required Visual Inspection and 100% UT examination.
It was stated by Graver that although Stone and Webster performed e.
vendor surveillance on this contract during this time frame, they had not identified any hold points for the welding of the Tee joint.
Therefore, Graver had no documentation available to indicate the extent of Stone and Webster surveillance over these specific welds.
f.
Rework has not yet been performed in the field.
Work on River Bend Unit 2 (Job 12330) has been indefinitely suspended, and Graver stated that the rework of the Tee welds for unit 2 cannot be implemented until work is resumed.
g.
Corrective action will be as follows.
Manual welding procedure (305N) which has been properly qualified in accordance with ASME Code Section IX and approved by Stone and Webster per con-tract requirements, will be used for the site rework. Welds will be examined Visually and by UT per approved UT procedure supplemented by approved technique sheets. _Therefore, rework should be acceptable.
Monitoring will be at the site.
h.
Preventive action concerning weld procedure 302N is on Graver NCR No. 77, Revision 1, which needs the approval of Graver's MRB (Materials Review Board) prior to implementation.
Shop weld procedure 302N will need appropriate revision, including increasing manual passes from 1 to 4, and reducing weld current on the first two dual-head sub arc passes from 450-550 amps to 350-400 amps. The procedure will be requalified if necessary.
i.
Concerning identification of all possible instances of the Tee weld problem, Nine Mile Point and the NRC have been notified of
~
19 the potential defects on the similar welds at Nine Mile Point by f
means of Garver's letter noted 10/16/79 reporting a potential Part 21 deficiency.
Also, Graver NCRs nos. 72 (3/22/79),
77 (5/22/79) and 77, Revision 1 (12/19/79) identify the problems and Gulf States Utilities letters to NRC Region IV indicate notification to the proper authorities.
j.
Concerning the identification of all possible instances of the welding problem, Graver is currently performing further testing and evaluation of the only other welds performed using weld procedure 302N on River Bend. These are the welds for 49 vertical stiffeners, which required only Visual and Magnetic Particle examination for acceptance.
UT examinations are now being per-formed to determine whether rejectable indications exist, that MP would not disclose. These welds will be reworked if they are found to be unacceptable.
k.
Preventive action will include the following:
(1) the revised UT procedure, UE-9 is now supplemented by technique sheets for each weld configuration.
The technique sheets indicate the UT scan technique in detail. Forexample,fortheweldsinquestion the technique sheet requires a seam at 0 and 45 and 70.
(2) The revised UT procedure, UE-9, Revision 3, or Revision 4, if approved by Stone and Webster, will be reviewed by the ANI and demonstrated to him as being capable of identifying reject-able indications.
1.
Concerning the idantific: tion of all possible instances of the UT problem, UT has been used by Graver only on the Nine Mile Point and the River Bend jobs.
Graver stated that the Tee welds for both jobs are the only completed welds of this configuration which were tested by the subcontractor using the prior UT pro-cedure.
They believe that this defines the scope of the UT problem, and that the use of the technique sheets, the revised UT procedure, and Graver personnel will prevent the recurrence of the problem.
No deviations and no unresolved items were identified in this m.
area of the inspection; however, a follow-up will be made during a later inspection to determine result of Graver testing and evaluation of 49 vertical stiffener welds performed to weld procedure 302N.
If Graver determines that rejectable indication t
exist, Graver corrective and preventive action can be evaluated at that time.