ML19309H925
| ML19309H925 | |
| Person / Time | |
|---|---|
| Site: | South Texas  |
| Issue date: | 05/15/1980 |
| From: | HOUSTON LIGHTING & POWER CO. |
| To: | |
| Shared Package | |
| ML19309H918 | List: |
| References | |
| NUDOCS 8005200664 | |
| Download: ML19309H925 (3) | |
Text
80 052 0 0&Yf 5
-INTERIM REPORT-STOP WORK ON SAFETY RELATED AND CODE WELDING May 15, 1980 1.
SUMMARY
As a result of inconsistencies, and several cases of non-compliance with higher tier commitments, relative to the STP Welding Program, Stop Work Notices S-19, dated 3/18/80 and S-21 A dated 4/14/80 were issued by the Brown & Root Site Quality Assurance Manager to stop welding activities which were performed to Welding Procedure Specifications qualified to the requirements of the ASME B&PV Code, and subsequently, to stop all Safety Related Welding and Welder Qualifications until adequate program definition and implementation was achieved.
It is postulated that the cause and pro-pagation of this problem was due to inadequate program definition, due in part to inadequately # fining comitments and program objective, in con-junction with insufficient program monitoring and implementation support from the affected organizations. Although a fomal safety evaluation has not been conducted, independent activities currently being pe, formed to reverify weld quality, through the mechanism of reviewing NDE results, will provide adequate evaluation of the impact on material conditions with the remaining impact being programatic in nature.
II.
DECRIPTION OF THE INCIDENT As a result of Houston Quality Assurance audits on Materials Engineering, ME-4, and the STP, ST-35, deficiencies were identified in the STP Welding Program which precluded the reconstruction of a defined and documented process from Welding Procedure Specification generation to the completion of a field production weld. Additionally, the identification of several incorrect practices concerning the practical implementation of the Welding Program substantiated a lack of effectiveness in implementing the require-ments or intent of the program. Although Audit Reports ME-4 and ST-35 have been issued, attached to this report is a synopsis of the major find-ings and observations which precipitated "Stop Work" action.
III.
CORRECTIVE ACTION Subsequent to issuing Stop Work Notices S-19 and S-21A, short range and long range corrective action programs were developed and undertaken.
These corrective actions that are to be taken prior to the release of safety related welding at the STP site were described in letters to Mr. Karl Seyfrit dated April 15, 1980 and May 14, 1980 (HL&P Correspondence Numbers ST-HL-AE-448 and ST-HL-AE-458).
IV.
SAFETY EVALUATION An analysis of the safety implications was not performed.
The assumption was made that the deficiencies in safety related areas could adversely affect the safety of the plant and emphasis was placed on ensuring that an acceptable level of safety is maintained.
T
1 Page 1 of 2 SYNOPSIS OF ME-4 AND ST-35 AUDIT FINDINGS AND CONCERNS 1.
Lack of detailed procedures for the implementation and control of weld pro-cedure specification qualification and testing as required by 10CFR50 (Cri-teria V & IX), ANSI N45.2 (Para. 6) and ASME Section III (NA 4400). ME-4 2.
Procedures containing quantitative / qualitative acceptance criteria not re-
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viewed and approved by cognizant discipline Level III as required by ANSI
/
N45.2.6 and Regulatory Guide 1.58. ME-4 and ST-35.
3.
Improper certification of test laboratories used to perfonn weld procedure specification qualification tests as required by 10CFR50 (Criterion VII),
ANSI N45.2 (Para. 8) and ASME Section III (NA 4440). ME-4 4.
Inadequate / incorrect inspection / acceptance criteria specified in site pro-cedures MECP-4 (welding of ASME III piping and supports) and MECP-1 (quali-fication of welders). ST-35 5.
Inadequate control of welder qualification activities (QC inspector not certified, visually rejectable test coupons submitted for radiography, in-adequate control of inprocess welding during qualification), in violation of ANSI N45.2.6,10CFR50 Criterion X, ASME Sections III (NA 4500 and NB 4300) and IX (QW 300.2) and AWS D1.1 (Para. 5.28). ST-35 6.
Inspection' instruments not calibrated /conformance checked as required by ASME III (NA 4610), 10CFR50 Criterion XII and ANSI N45.2.8.
(Includes usage of "ID BRASS" as fit-up inspection tool). ME-4 and ST-35 7.
Misuse of the Corrective Action system as defined in 10CFR50 Criteria XVI ANSI N45.2 (Para.17) and ASME Section III NA 4800. ST-35 8.
Number of NCR's written on filler material control since 10/79 (14), seven of which were written against the use of the wrong filler material with at least one of these seven for multiple violations.
ST-35 9.
Although the following item was not included in the audit report it was a contributing factor in the recomendation to stop work at the STP.
Training and certif' ation of inspection personnel perfonning activities nelated to welder qualification is less than ade-quate for nuclear application.
a.
Insufficient emphasis placed on procedural knowledge, b.
Inadequate tra'ning/ availability of inspection tools and gauges.
c.
Poor attitude exhibited by inspection personnel concerning reporting of deficiencies.
d.
Inadequate progrannatic content for nuclear application.
Page 2 of 2 SYNOPSIS OF ME-4 AND ST-35 AUDIT FINDINGS AND CONCERNS t
j 10.
Incomplete processing of 3 DCNs to the Technical Reference Document for
" Weld Joint Design Specification", as required by Engineering Procedure
]
STP-DC-013 paragraph 3.0 and 10CFR50 Criterion VI. ME-4 11.
Corrections were made to quality documentation which did satisfy the intent of ANSI N45.2.9 and 10CFR50 Criterion V.
ME-4 s
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