ML20062E559
| ML20062E559 | |
| Person / Time | |
|---|---|
| Site: | Washington Public Power Supply System |
| Issue date: | 07/02/1982 |
| From: | Mazur D WASHINGTON PUBLIC POWER SUPPLY SYSTEM |
| To: | Faulkenberry R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20062E537 | List: |
| References | |
| GO1-82-0415, GO1-82-415, NUDOCS 8208100150 | |
| Download: ML20062E559 (14) | |
Text
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G;qpq9 Washington Public Power Supply System Richland, Washington 99352. @M,09)372-5000 P.O. Box 968 3000 GeorgeWashingtonWay u
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July 2, 1982 G01-82-0415
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Nuclear Regulatory Commission Region V 1450 Maria Lane, Suite 210 Walnut Creek, California 94596 Attention:
Mr. R. H. Faulkenberry
Subject:
NUCLEAR PROJECT 1 NRC INSPECTION WNP-1 DATES OF INSPECTION APRIL 5-9, 1982 DOCKET NO. 50-460 CONSTRUCTION PERMIT NO. CPPR-134
Reference:
Letter RH Faulkenberry to RW Root NRC Inspection at WNP-1 Site dated May 3, 1982 The above reference letter delineated the results of the April 5-9, 1982 inspection of activities authorized by NRC Construction Permit No. CPPR-134. Further, the referenced letter identified certain activities which were not conducted in full compliance with NRC requirements set forth in the Notice of Violation enclosed as Appendix A.
These items of noncompliance have been categorized into a level as described in Supplement II of the Federal Register dated October 7, 1980 (45FR66754) as the Interim Enforcement Policy.
The specific findings, as identified, and the Supply System respcnises are provided h rewith as Appendix A.
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4 D. W. Mazur Acting Program Di ector DWM:JMS:Im cc: CR Bryant, BPA (399)
JP Laspa, Bechtel (860)
V. Mani, UE8C (897)
V. Stello, Director of Inspection, NRC A. Toth, NRC FDCC (899) e200100150 eposoa PDR A00CK 05000460 G
PDR gg.gg
NUCLEAR REGULATORY C0lHISSION REGION V 1450 MARIA LANE, SUITE 210 WALNUT CREEK, CALIFORNIA 94596 DOCKET NO. 460~AND 50-513 CONSTRUCTION PERMIT NO. CPPR-134 AND -174 Appendix A A.
10 CFR 50 Appendix B, Criterion XV and Section 17.1.15 of the PSAR state in part:
" Measures shall be established to control materials, parts or components which do r.ot conform to requirements in order to prevent their inadvertent use....
These measures shall include, as appropriate, procedures for... documentation,
... disposition, and notification to affected organizations.
Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in accordance with documented procedures."
Contract specification 9779-216 Revision 10 Modification 4 Paragraph A2.2.1.1 defines a nonconformance as "A deficiency in characteris-tic, documentation or procedure which renders the quality of an item unacceptable or indeterminate. Examples of nonconformance include: physical defects, test failure, incorrect or inadequate documentation, or deviation from prescribed processing, inspection or test procedures."
Paragraph A2.3.la further states in part:
"Nonconformances detected by a site contractor during... construction activities shall be documented on forms supplied by UE&C (Figure 1)."
Figure 1 is the nonconformance report form.
University Nuclear Systems Incorporated (UNSI) Procedure QCP/CP 22.0 Revision 5, paragrapn 5.13.1 states " Welded attachments such as those used for alignment, erection, or installation purposes shall be handled with the following provisions:"
Paragraph 5.13.11 further states "The inspector shall be notified of all temporary attachment welds to be made and shall document the locations, WPS and Welder ID on the IPI in accordance with QCP/CP 27.0."
UNSI Quality Finding Report QFR-81-l&4-9 dated July 10, 1981 lists four welded items installed but not documented and states in part that "a random sampling indicates that perhaps 30% of welds at WNP-1 are undocumented." The QFR was closed on October 23, 1981 with no disposition provided for the undocumented Unit 1 Quality Class I welds.
Contrary to the above, a nonconformance report was not written for the inadequate weld documentation and deviation from prescribed inspection procedures for the Unit 1 Quality Class I welds described in QFR 81-184-9 of July 10, 1981 and no disposition for these welds was provided.
This is a Severity Level V violation Supplement II, applicable to Unit 1.
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A.
SUPPLY SYSTEM RESPONSE UNSI QFR-81-1/4-9 dated July 10, 1981 was written to document a procedural violation in that the requirements of QCP/CP-22.0 and 27.0 were not being fully in>plemented.
The specific violations cited in the QFR were that craft foreman were not in all cases generating the documentation and notifying QC to perform inspec-tions as required by the procedures. The corrective action to the QFR indicated that retraining of craft foreman would be conducted and also stated that no action could be taken for WNP-4 due to the extended conctruction delay which had occurred with this Project.
Due to the extended construction delay, UNSI subsequently generated 4-CNCR-216-80 to provide an obvious status of those installations for which no documentation (installation or inspection) existed.
ACTION TO PREVENT RECURRENCE In reviewing the requirements of the contract specification and the AWS D.l.1 welding code, it was determined that 100%
inspection of tack welds is not required. AWS D.l.1 states in part:
"The inspector shall, at suitable intervals, observe the technique and performance of each welder, welding operator and tacker to make certain that the applicable welding requirements are met."
In addition, neither the contract specification or AWS D.1.1 requires documentinp the locations, WPS or welder I.D. for welds.
A review of the past work indicates the following:
l 1.
The tack welds which were part of a single pass weld were included in the inspection of the single pass l
welds and thus satisfies the intent of AWS D.l.1 for random inspection and provides assurance that the welding requirements were being met.
l 2.
Since documenting the location, WPS and welder I.D.
is not a requirement of the contract specification or AWS D.1.1 code, the missing information constitutes a procedure violation but the lack of this information l
does not cause the quality of the installation to be unacceptable which would warrant issuance of a nonconformance report.
3.
The UNSI QC program provides for the documenting of all the final weld inspections performed and an
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independent verification that all completed work has been inspected and accepted.
Therefore, although the missing craft documentation represents a procedure violation, it is not a condition which would require issuance of a nonconformance report.
Based on the above, it has been determined that the past work does not have to be identified on a nonconformance report and that the quality of.the welds is not in question.
In order to preclude repetition, UNSI has revised QCP/CP-27 which establishes a surveillance program of the welding activities, including temporary attachments, to assure the welding requirements are being met.
This procedure has also been revised to conform with the requirements of the specification and AWS D.l.1 code for documentation requirements.
B.
10 CFR 50 Appendix B Criterion V and Section 17.1.5 of the PSAR state in part:
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions procedures or drawings."
University Nuclear Systems Incorporated (UNSI) procedure QCP/CP 22.0 Revision 7 General Welding Standards dated November 11, 1981 paragraph 2.0 states in apart:
"The purpose of this procedure is to assure compliance with the requirements of... referenced codes and standards." Paragraph 4.2.2 lists "American Welding Society Structural Welding Code AWS D.l.1-77" as a referenced code.
Paragraph 4.1 states "This procedure is to be used in conjunction with approved UNSI WPS's."
A WPS is a Welding Procedure Specification.
Paragraph 4.1.1 states in part:
" Refer to the applicable WPS for the following:
4.1.1.1 - Base Metal and Specification; 4.1.1.7 - Typical Joint Designs" AWS D.1.1 - Revision 2-77 Paragraph 1.2 states in part:
" Steels complying with the' specifications listed in 8.2, 9.2 and 10.2...are approved for use with this code. Steels other than those listed may be used provided the provisions of 8.2.3, 9.2.4 and 10.2.3 are complied with." Paragraphs 8.2.3, 9.2.4 and 10.2.3 state in part:
"When a steel other than those listed...is proposed for welding construction,...the procedure for welding it shall be established by qualification..." Paragraph 2.6.1 of the Code states in part:
" Joints meeting the following requirements are designated as prequalified...conformance with the details specified in 2.7-2.14 and 10.13... joints meetings these requirements may be used without performing the joint welding procedure qualifi-cation tests."
(1) Contrary to the above, the following WPS's for Quality Class I welds listed materials which are not listed in 8.3, 9.2 and 10.2 of the Code and have not been established by qualification:
o WPS 100 Rev. 3 dated December 31, 1980 lists ASTM A 283 GrC, and AISI 1012-1028
o WPS 101 Rev. O dated January 16, 1981 lists ASTM A 283 GrC and AISI 1025-1028 o
WPS 125 Rev. 4 dated February 5, 1982 lists ASTM A 283 GrC o
WPS 126 Rev. 2 dated July 15, 1981 lists ASTM A 283 GrC (2) Contrary to the above, WPS-100 Revision 3 dated December 31, 1980 specifies the following welded joint details for Quality Class I welds which are not in conformance with the details specified in section 2.7-2.14 and 10.13 of the Code and have not been established by qualification:
o AWS and WPS Joint designation B-Pla-root opening of 0-1/8" vs Code required 0-1/16" o
AWS and WPS Joint designation B-Pla-weld reinforcement not specified vs Code required 1/32-1/8" o
AWS and WPS Joint designation BLlb-root opening of 0-1/16" vs Code required 1/2 T-1/2 T + 1/16".
o AWS and WPS Joint designation BU4a-root opening of 0-3/32" vs Code required 1/4 - 5/16".
AWSandWPSJointdgs gation B-U2a-groove angle 60 -70 o
vs Code required 45 (3) Contrary to the above, the following WPS's for Quality Class I welds as prequalified weld joint configurations whereas flare groove weld configuration details are not specified in 2.7-2.14 and 10.13 of the Code.
o WPS-100 Rev. 3 dated December 31, 1980 o
WPS-101 Rev. O dated January 16, 1981 o
WPS-125 Rev. 4 dated February 5, 1982 o
WPS-126 Rev. 2 dated July 15, 1981 This is a Severity Level V Violation, Supplement II applicable to Unit 1.
B.(1) SUPPLY SYSTEM RESPONSE ASTM A 283 GrC is an acceptable material for AWS use since ASTM A 283 GrC is listed as an acceptable product form of ASTM A 36 in the ASTM standard. No further corrective action is required for the ASTM A 283 GrC material.
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The 216 contractor has determined through an internal review of their procurement documents that no AISI material has been procured in the past. Since none of this material has been procured, procedural qualification is not required for past work. No further corrective action required.
ACTION TO PRECLUDE RECURRENCE The reference to AISI material will be deleted from the WPS.
The revised WPSs will be submitted to the Engineer for approval by June 25, 1982.
B.(2) SUPPLY SYSTEM RESPONSE o
AWS and WPS Joint designation B-Pla-root opening of 0-1/8" vs Code required 0-1/16"
Response
No corrective action is required. AWS D.l.1-77 indicates under Table 2.10.3 that the minimum effective throat for material up to 1/4" is 1/8"; therefore material which is 1/8" thick or less would have an effective throat equal to 100% of the material thickness. Under complete penetration welds paragraph 2.9.2.3, the root opening of the joint is minimum.
It may be detailed to exceed the dimension shown by 1/16 inch.
To substantiate this position, AWS Dl.1-81 allows a root opening detailed 0-1/8" for joint B-Pla which is consistent with the position noted above.
o AWS and WPS Joint designation B-Pla-weld reinforcement not specified vs Code required 1/32-1/8"
Response
The WPS will be revised to clarify the requirement. The completed welds meet the requirement based on QCP/CP 22.0 Para. 5.14.3.5 which requires a 1/8" maximum weld reinforcement and WPS-100, Rev. 3 Joint Detail B-Pla which details a convex contour symbol.
When welded with the SMAW process a 1/32" minimum reinforcement is produced, o
AWS and WPS Joint designation BLib-root opening of 0-l/16" vs code required 1/2 T-1/2 T+ 1/16".
Response
Since the WPS indicates that for joints without backing, grinding or gouging to sound metal shall be performed and the workmanship tolerance for such gouging joints is + 1/16", -1/8" there is no condition adverse with the quality of the hardware.
UNSI also qualifies all welders using backing. Therefore, the UNSI procedural requirements specify full penetration joints to be welded with backing or, without backing followed by backside grinding and welding.
For clarification purposes only, the WPS will be revised to show conformance to AWS 01.1-77. No further corrective action is required.
o AWS and WPS Joint designation BU4a-root opening of 0-3/32" vs Code required 1/4 - 5/16".
Response
No corrective action is required since WPS-100 Rev. 3 details joints B-U4 and B-U4a on the same sketch. The root opening of 0-3/32" applies to detail B-U4.
The root opening of 1/4"-5/16" for detail B-U4a is denoted in the sketch by an "a" in parenthesis (a).
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AWSandWPSJointdgsingationB-U2a-grooveangle60-70 o
vs Code required 45 -55
Response
Corrective Action Based on a limited review, the contractor has not found any ingtanceswhereweldsweremadewithananglegreaterthan 65. However, procedure qualification in accordance with AWS Section 5, to qualify the groove bevel with an angle greater g
than 65, will be performed upon resumption of construction activities at the WNP-1 Project.
The WgS sgall be revised to detail the correct groove angle of 45 -55. The joint as previously detailed apparently included I
thefituptolerancesofAWSDl.1-f7. However, the fit up tolerance allows an increase of 10 befondthatdetailed.
o This results in the groove bevel of 65 -70 not being in compliance with a prequalified status. The revision to the WPS will be completed by June 25, 1982.
The corrective action taken will preclude recurrence.
B.(3)
The following WPS's for Quality Class I welds as prequalified weld joint configurations whereas flare groove weld configuration details are not specified in 2.7-2.14 and 10.13 of the code.
o WPS-100 Rev. 3 dated December 31, 1980.
o WPS-101 Rev. O dated January 16, 1981 o
WPS-125 Rev. 4 dated February 5, 1982.
o WPS-126 Rev. 2 dated July 15, 1981.
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a B.(3)
SUPPLY SYSTEM RESPONSE No corrective action is required for the four (4) identified WPSs. WPS-125, Rev. 4, dated February 5,1982 does not address flare groove welds. For WPS 100, 101 and 126, the requirements of AWS D.1.1-77 Para. 5.1 are satisfied and the requirements of 2.3.1.4 are complied with including Table 2.3.1.4 for effective throat. Therefore the joint design is considered prequalified.
To comply with AWS Para. 2.3.1.4 (1)'the flare groove welds were examined for all characteristics, including effective throat, at the time they were made.
Inspection documentation of welds is performed as described by the WPS and as required by UE8C Engineering approved UNSI Procedure QCP/CP 22.0, Rev.
8, Para. 5.14.3.4, which states; "The minimum effective throat of partial penetration flare groove welds in which one or both members of the joint is solid round bar stock, shall be 5/16 (0.31 or 31%) R for flare bevels and 1/2 (0.50 or 50%) R for flare vees where "R" is the radius of the smallest bar member of the joint. For flare groove welds not involving solid bar where one or both members of the joint is formed sheet metal or formed structural type members such as channel or tubing, the effective throat, as a minimum, shall equal the thinner member involved.
Note:
Industrial experience has shown that the acceptability of effective throats of flare groove welds in HVAC installation can be readily determined by visual inspection because of the material size and thicknesses involved. Accordingly, acceptance of such welds shall be determined by visual inspection to satisfy provisions of AWS Dl.1 paragraph 2.3.1.4 in lieu of sectioning construction welds.
If insufficient throats are detected, additional weld disposition shall be made as required to correct the conditions."
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STATE OF WASHINGTON)
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COUNTY OF BENTON
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R. W. Root, being first duly sworn, deposes and says:
That he is the l
Assistant Program Director-Construction and has been delegated the full I
responsibility and authority to act for the Program Director, WNP-1/4, for the WASHINGTON PUBLIC POWER SUPPLY SYSTEM, the applicant herein; that he is authorized to submit the foregoing on behalf of said applicant; that he has read the foregoing and knows the contents thereof; and believes the same to be true to the best of his knowledge.
DATED
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, 1982 i
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'R. W. ROOT /
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On this day personally appeared before me R. W. ROOT to me know to be the individual who executed the foregoing instrument and acknowledged that he signed the same as his free act and deed for the uses and pur-poses therein mentioned.
GIVEN under my hand and seal this /jf day of f
, 1982 f
U bAfIt A ouaV No)*ary Public in and for the State i
of Washington Residing at ///4 O
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ATTACHMENT 1 N Comments on Nashinoton Public Power Supply System Response Letter G01-82-0415 dated July 2, 1982 to Items of Noncomoliance identified in IE Inspection Report 50-460/82-07.
1.
Finding A is a noncompliance for failure to follow procedures relating to documentation of nonconforming conditions.
NRC inspection determined that a random sample by UNSI indicated that 30% of the welds at WNP-1 were installed with no craft-documentation and no inprocess or final QC inspection which represents an ongoing failure to follow procedures.
It is this matter which we consider should have been documented on a nonconformance report.
Additionally, although not part of the item of noncompliance, a similar situation existed at Unit 4 where essentially none of the welding was in-process or final inspected by quality control.
Your response concludes a nonconformance report was not required at Unit 1 since it has been subsequently determined that the quality of hardware was not affected at Unit 1.
As cited in our nonccmpliance, your contract specification 9779-216 Revision 10, Modification 4, Paragraph A2.2.1.1 defines a noncomformance as "A deficiency in characteristic, documenta. ion or procedure which renders the quality of an item unacceptable or indeterminate.
Examples of nonconformance include:
physical defects, tes, failure, incorrect or inadequate documentation, or deviation from pre cribed processing, inspection or test procedures".
Paragraph A2.3.la further states in part: "Nonconformances detected by a site contractor during... construction activities shall be documented on forms supplied by UE&C (Figure 1)."
Figure 1 is the nonconfonnance report form.
It appears that, at the time of the discovery of the lack of inspections in Unit 1 and 4, the deficiency in documentation rendered the quality of the items indeterminate.
Further, the lack of inspections fit the example of a deviation from prescribed inspection procedures. Therefore, the problem clearly f.it your specification's and ANSI N45.2's definition of a nonconformance.
It further appears that USNI's failure to document the conditions on a nonconformance report was an additional example of failure to follow prescribed procedures, but more significantly in this case, the failure was on the part of UNSI quality assurance management versus working level crafts.
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It is noted that the NRC inspector had requested you investigate the lack of weld inspection and to document the condition on nonconformance r:-ports in October 1981 as documented in our inspection report 50-460/81-09 prior to the ance of.the item of noncompliance.
We consider the item of noncompliance valid since at the time of its issuance there was no documented rationale for the acceptance of the uninspected welds.
Accordingly, please provide additional information regarding actions taken to ensure nonconformances are documented and reviewed in accordance with prescribed procedures.
2.
Finding B is a noncompliance dealing with UNSI welding procedures not meeting the requirements of AWS D.l.l.
The specific issues, the supply system response and the additional information required are discussed below:
a.
Issue: Several weld procedure specifications list materials not specified by AWS D.l.1 as prequalified materials.
Response: ASTM A 283 Gr C is an acceptable material since it is listed as an acceptable product form of ASTM A 36 and no AISI material has been procured.
Discussion:
It appears that ASTM A 36 does not list ASTM A 283 Gr C as an " acceptable product form". ASTM A 36 lists ASTM A 283 Gr C as an acceptable appurtenant material when delivered with ASTM A 36 i
material.
Information Required. Please provide a revised response regarding ASTM A 283 Gr C material. Additionally, please describe what actions ha,e Leen taken to improve the quality of procedure review by contractors and the engineer to ensure code and standard requirements are met.
b.
Issue: Joint designation B-Pla root opening 0-1/8" vs Code required 0-1/16".
Response
No corrective action is required.
Under complete penetration welds paragraph 2.9.2.3 the root opening is a minimum.
It may be detailed to exceed the dimension by 1/16 inch.
Discussion:
Paragraph 2.9.2.3 applies to complete penetration welds.
Joint B-Pla is a partial penetration weld.
AWS D.l.1-77 does not provide root opening latitude for partial penetration joints.
Information Required:
Same as paragraph 1 above regarding procedure review.
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Issue: B-Pla weld reinforcement not specified vs Code required 1/32"-1/8".
Response: The WPS will be revised.
Requirements for a maximum weld reinforcement are contained in the body of QCP/CP 22.0 paragraph 5.14.3.5.
The process of welding by SMAW produces a 1/32" minimum reinforcement.
Discussion: The requirement for.1/8" maximum reinforcement is contained in the body of QCP/CP-22.0, however, your reference to paragraph 5.la.3.5 appears to be backside reinforcement of sheet metal welds.. Paragraph 5.11.1 appears to be the proper paragraph regarding maximum reinforcement.
Regarding your resp;nse that minimum reinforcement is achieved through welding by SMAW, we concur, if welding is properly performed, that this is the normal case. However, in certain cases, such as lack of fill, minimum reinforcement may not be achieved.
Information Reauired:
Same as paragraph 1 regarding procedure review.
In addition please provide some further discussion of the minimum weld reinforcement.
d.
Issue: BL-lb root opening of 0-1/6" vs code required 1/2T - 1/2T +
1/16".
Res3onse: The WPS indicates that for joints without backing, bac(side grinding to sound metal shall be performed followed by backside welding.
Discussion: While backside grinding to sound metal and backside welding should produce sound metal welds, it remains that both the root opening requirement and the backside grinding requirement are both AWS requirements.
Information Required:
Same as paragraph 1 regarding procedure review.
e.
Issue: BU2a - groove angle 60 - 70 vs Code required 45 - 55.
Response
Basedonalimitedreview,thecontractorhasnotfoung any instances where welds were made with an angle g5 eater than 65.
Procedure qualification to an angle greater than 65 will be performed.
Information Required.
Same as paragraph 1 regarding procedure review.
We infer that the procedure quali cation to "an angle greater than g
65 " will include angles up to 70 2
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Issue:
Flare groove welds are shown as prequalified welds in seve al procedures but are not shown as prequalified in AWS D.1.1.
Response: No corrective action is required. WPS-125 Revision 4 does not address flare groove welds.
For the other WPS's the requirements of AWS D.l.1-77 Paragraph 5.1 are satisfied. The requirements of 2.3.1.4 are complied with because the flare groove welds are inspected at the time they are made.
Industrial experience has shown that the acceptability of effective throats of flare groove welds in HVAC installations can be readily determined by visual inspection because of the material size and thickness involved. Accordingly, acceptance of such welds shall be determined by visual inspection to satisfy the provisions.of AWS D.1.1 paragraph 2.3.1.4 in lieu of sectioning construction wclds.
Discussion: We concur WPS-125 Revision 4 does not address flare groove welds.
We do not concur that the requirements of AWS D.l.l.-77 Paragraph 5.1 have been satisfied.
Paragraph 5.1 states that joint welding procedures that conform in all respects to the provisions of Section 2 shall be deemed prequalified.
Section 2 paragraph 2.6 provides the requirements for joints which can be designated a: precualified, that is, conformance with the details specified in 2.7 through 2.14 and 10.13. The discussion of and
' requirements for flare groove welds are not contained in 2.7 through 2.14 or 10.13, they are contained in Section 2.3.
Therefore, flare groove welds are not prequalified.
Additionally, we do not concur with your statement that the require-ments of 2.3.1.4 are complied with because flare groove welds are inspected at the time they are made by quality control personnel.
Paragraph 2.3.1.4 requires random sections of production welds for each welding procedure to verify the effective throat has been achieved.
The difficulty of achieving sufficient throat in flare groove welds is caused by the joint geometry at the root of the weld. Lack of throat is caused by lack of penetration in that narrow root geometry.
Visual inspection of the completed weld cannot determine the root
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penetration and therefore cannot determine if effective throat requirements have been achieved.
We do not concur that industrial experience has shown the acceptablity of effective throats of flare groove welds in HVAC installations can be readily determined by visual inspection because of material size and thickness involved.
Please note that flare groove configurations are used in the HVAC structural support welds and the procedures in question are for materials up to 3 inches in thickness.
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Information Required:
Please provide the same information as required in paragraph 1 regarding procedure review. Additionally, please readdress your position and actions regarding the prequalified status of flare groove welds.
3.
Other Comments a.
Your response to Finding B does not indicate that your staff performed a review of the UNSI WPS's and determined that there were other areas where.the WPS's did not meet AWS D.l.1 requirements.
In-your revised response please include a discussion of your staff's findings and any actions taken to resolve those findings.
b.
Please assure that your general response to these items of noncompli-ance meets the requirements of 10 CFR 2.201 which requires your reply to include:
(1) Corrective steps which have been taken by the licensee, and the results achieved; (2) Corrective steps which will be taken; and.
(3) The date when full compliance will be achieved.
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