ML20080B403
| ML20080B403 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 06/20/1983 |
| From: | Schuyler J PACIFIC GAS & ELECTRIC CO. |
| To: | Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20080B398 | List: |
| References | |
| NUDOCS 8308050464 | |
| Download: ML20080B403 (8) | |
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PACIFIC GAS AND E LE C T RI C C O M PANY Eb'9db l
77 BEALE STREET. SAN FRANCISCO, CALIFORNI A 94106 (415) 781-4211. TWX 910 372 6587 J.O.SCHUYLER vitt retstet%r MuCLEAR P0aER GENtnafem June 20, 1983 Mr. John B. Martin, Regional Mministrator U.S Nuclear Regulatory Canmisision, Region V i
1450 Maria Iane, suite 210 Walnut Creek, CA 94596-5368 Re: Docket No. 50-275, OL-DPR-76 Docket No. 50-323 Diablo Canyon Units 1 and 2 IE Inspection Report 83-10/83-13 -- Notice of Violation
Dear Mr. Martin:
IRC Inspection Report 83-10/83-13, dated May 19, 1983, included a Notice of Violation comprising of one Severity level V violation for Unit 2 and two Severity Level IV violations for Units 1 and 2.
PGandE's response to this Notice is enclosed.
Sincerely,
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lundR Response to Notices of ViolmHan in M C Inspection Report 83-10/83-13 On May 19,1%3, MC Region V issued a Notice of Violation ('%tice")
containing one Severity level V Violation for Unit 2 (part A.1) eid two Severity level IV Violations for Units 1 and 2 (parts A.2 and B). 'Ihe
" Notice" cited the removal of " Red Hold Tags" prior to completion and approval of the entire nonconfonnance report and the failure to properly requalify two welders.
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'Ihe violations were described in the " Notice" as follows:
A.
"10 G R 50, Appendix B, Criterion V, as implemented by Section 17.1.5 of the FSAR and the PGandE Quality Assurance Manual,Section V, states, in part, that " Activities affecting quality shall be prescribed by doctanented instructions, procedures or drawings... and shall be accouplished in accordance with these instructions, procedures or drawings..."
1.
'Ihe Howard P. Foley Quality Control Procedure for Processing and Control of Deviations and Nonconformances, QCP-3, Revision 5, states, in paragraph 4.3 that, "When a nonconformance is noted, it shall be processed in accordance with this procedure on a Nonconformance Report by the Quality Department. 'Ihese reports require Pacific Gas and Electric Cmpany review and acceptance."
Paragraphs 4.3.1 through 4.3.10 of QCP-3 describe the review and approval cycle of the nonconformance report, culminating with paragraph 4.3.11, which states that, "When all of the above steps (paragraphs 4.3.1 through 4.3.10) have been cmpleted the Nonconformance Report shall be forwarded to Quality Engineering who shall coordinate removal of the Hold Tag (s) and file the report in the Quality Files."
Contrary to the above, discussions held with the then Acting Quality Control Manager on Mardt 31, 1983, identified that " Red Hold Tags," attached to structural steel I-beams at the 187' elevation of the Unit 2 Fuel Handling Building, and doctmnted on Nonconformance Report No. 8802-803, Revision 1, were removed by him from approximately ten of the fifteen locations on or about January 29, 1983. 'Ibe tags were removed prior to cmpletion and approval of the entire nonconformance report. Nonconformance Report No. 8802-803 was formally approved, cmpleted and signed on March 16, 1983.
'Ihis is a Severity level V Violation (Supplement II),
applicable to Unit 2.
l 2.
'Ihe Howard P. Foley Quality Control Prvcedure for Welder i
and Brazer Qualifications and the Qualification of Welding and Brazing Procedures, QCP-5, Revision 8, states in l
paragraph 5.1 that, " Welder qualification shall be effective providing the welder has used the process 1
qualified for within the following time periods: 6 months for welders qualified under Appendix "B", "C", "E", and "G" or 3 months for welders qualified under Appendix "I"."
Appendix C of the procedure describes the steps necessary to qualify a welder to the AWS D1.1 Structural Welding Code, latest revision, for groove we,lds of unlimited thickness. Successful completion of this qualification test also qualifies the welder for welding fillet welds on material of unlimited thickness. QCP-5 further states in paragraph 5.1.1 that, '*Ihe Quality Control Department shall monitor each welder for each process qualified within the time period above qualifications do not' lapse.7' to ensure that the welder's Contrary to the above, as of March 31,1%3, H.P. Foley Company Welder, (symbol "JX") had not ccmpleted the process requalification which was due to be completed on January 27, 1983. The welder was initially certified on February 29, 1980 to a AWS D1.1 Shielded Metal Arc Welding (SMAW) Process and monitored by Quality Control every six months afterwards, with the last process qualification performed on July 27, 1982. 'Ihe welder was included on H.P. Foley Active Welders List and was performing as a qualified welder as of March 31, 1983.
This is a Severity level IV Violation (Supplement II),
applicable to Unit Nos. 1 and 2.
B.
10 CER 50, Appendix B, Criterion IX, as inplemented by Section 17.1.9 of the FSAR and the PGandE Quality Assurance Manual,Section IX, states that, " Measures shall be established to assure that special processes, including welding, heat l
treating, and nondestructive testing, are controlled and I
accomplished by qualified personnel using qualified procedures l
in accordance with applicable codes, standards, specifications, i
criteria, and other special requirenents."
'Ihe 1980 Edition of the ASME Boiler and Pressure Vessel Code,Section IX, "Weldin j
of Qualifications",g and Brazing"I' Renewal of q;alification ofSubartic states that, performance qualification is required:
(a) when a welder or I
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welding operator has not used the specific process, i.e., metal arc, gas, submerged arc, etc. for a period of three months or more; except when employed on some other welding process, the period may be extended to six months; or (b) when there is a specific reason to question his ability to make welds.that meet the specification. Renewal of qualification for a specific welding process under (a) above may be made in only a single tests joint (plate or pipe) en any thickness, position, or material to re-establish the welder's or welding operator's qualification for any thickness, position, or material for which he was previously qualified.
Contrary to the above, on April 27, 1983, the IRC inspector identified that an H.P. Foley Campany Welder (symbol S-4) had been improperly recertified, on Feburary 19, 1983, to ASME Welding Procedure Specification (WPS) No. M-03, a Gas Ibngsten Arc Welding (GTAW) process. Quality records indicated that recertification was accomplished by having the welder strike an arc with the nonconsumable tungsten electrode long enough for the H.P. Foley Quality Control Inspector to take amperage and voltage readings and record these on an In-Process Welding Inspection Report. The report also indicates that no weld rod was issued during this time. The signature of the Quality Control Inspector on the In-Process Welding Inspection Report indicates acceptance of recertification of the welder to the particular velding process. This particular welder was listed on the H.P. Foley Active Welders List dated April 27, 1983. An examination of employer payroll and weld rod withdrawal records indicated that this welder was promoted to foreman on January 18, 1983 and had performed no welding since that date, though he was considered qualified and able to perform, as a result of the recertification test on Februrary 19, 1983.
This is a Severity Iavel IV Violation (Supplement II),
applicable to Unit No. 1 and 2.
4
PGandE RESPOEE TO ITDi A.1 - THE PRDR7tRE RDINAL CF " RED HID TAGS" Statement of Explanation During an inspection performed by H.P. Foley Quality Control De on December 27, 1982 for removal of two ground pads frm a 3/4'partment I-Beam on Colens 15 and 16 at elevation 137 of the Fuel Handling Building Hot Shop, it was discovered that the base metal had been gouged by grinding in fifteen locations.
Thegougingwasproperlydocmentedasadiscrepancyinaccordancewith H.P. Foley s approved procedures. An evaluation was made for each of the fifteen locations, eight did not require repair. However, it was determined that the seven other locations evaluated were determined to require repair by adding filler metal. The seven repairs were cmpleted and inspected by H.P. Foley Quality Control Department on January 29, 1983. These insmetions were docmented on H.P. Foley Weld Inspection Sheets. After tW work was completed, inspected and accepted, the " Red Hold Tag" was removed, prior to closure of H.P. Foley Nonconformance Report (N m) 8808-803. This action was a deviation of H.P. Foley Procedure QCP-3, which required the " Red Hold Tags" to remain in place until the NG is closed.
Corrective Steps Taken and Results Achieved H.P. Foley Procedure QCP-3 has been revised to allow rmoval of " Red Hold Tags" after inspection and acceptance of repairs by the Quality Control Inspector and prior to final closure of an N m.
The objective of the " Red Hold Tag" is to assure that once a nonconforming condition has been identified, no work or repairs begin until the nonconformance has been docmented, dispositioned and approved and that systems or equipment are not returned to service until repairs are c mpleted, inspected and accepted.
Since the Foley practice is to remove the " Red Hold Tags" only after the repair work vas accepted,"the quality of work was not empromised by the removal of '%d Hold Tags prior to closing of the non conformance report.
Corrective Steps Which Will Be Taken The revision of the H.P. Foley procedures provides adequate corrective actions and no additional corrective steps are necessary.
Date When Eb11 Compliance Was Achieved Eb11 cmpliance was achieved on May 20, 1983 after PGandE approval of H.P. Foley Procedure QCP-3.
-5 PGandE Rampmaa to IIEM A.2 - EXPIRED QUALIFICATIN OF WlEER Statement of Explanation Notice of Violation states that the H.P. Foley Conpany Welder (Symbol JX) did not perform welding necessary to maintain a current qualification status afterJanuary 27, 1983, and H.P. Foley retained this welder on the
" Active Welders List" as of March 31, 1983. This welder was, in fact, qualified during this period of time as explained below.
The method an auditor or inspector would use to determine the status of a welders qualification would be to review documentation contained in the certification folder maintained by the contractor for each welder. The certification folder normally contains the welder certification test report for initial certification of each welder, any related training documentation and in process weld inspection reports used to extend a welder's qualification for a specific weld process. As the result of a clerical error, the in process weld ins metion reports were not included in the welder's (Symbol JX) folder at tw time the inspector made an examination of his record.
PGandE Quality Control Department conducted a search of the H.P. Foley Co. Files. As a result of this search in process weld inspection reports were found which showed that the welder in question (Symbol JX) had performed welding to the SMAW process on October 26, 1982, January 20, 1983, and February 9, 1983. Based upon the above work his AWS qualification was current at the time of the NRC inspection.
Corrective Steps Taken and Results Achieved The certification folder now contains the appropriate documents necessary to verify his current qualification status. Furthermore, the qualification records of the other welders have been reviewed to assure that they are current. The clerical staff has been instructed to carefully follow established procedures to assure that the folders are maintained current.
Corrective Steps Which Will Be Taken Adequate corrective actions as described above have been taken and no l
additional corrective steps are necessary.
Date When Full Compliance Was Achieved Based on the explanation provided above, PGandE believes that full compliance with the AWS code has been continually maintained.
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PGandE RESIDEE TO ITEM B. - IMPROPER RECERTIFICATIN OF WIEER Statement of Explanation The IRC inspector identified that an H.P Foley Company Welder (Symbol S-4) had been improperly recertified. PGendE and H.P Foley Q.C.
Departments conducted independent investigations conceming H.P. Foley Company practices for mainraining welders certifications. The results of the investigation indicated that from 1979 to present, H.P. Foley Company had the policy of mainenining the certification of welders promoted to foremen or suoervisors. The policy was to require these persons to perform welding to the applicable procedure on a periodic basis to keep the certification current. The method consisted of a welder performing welding in a test booth to the specific processes he is qualified.
In the specific case noted, the Q.C. Inspector did not have proper training to determine the amount of welding required by the welder in order to monitor qualifications. Therefore only partial fulfillment of requirements for recertification were achieved. It was determined that this situation was an isolated occurrence and that a generic problem does not exist.
Corrective Steps Taken and Results Achieved The following corrective actions were taken by H.P. Foley Company to avoid the recurrence:
1.
H.P. Foley Co. has, in an interoffice memorandum of April 30, 1983 to all Q.C. supervisors, discontinued the policy of maintaining the certification of welders promoted to foremen or supervisors, and has re::oved these persons from the " Active Welders List" and has voided their applicable certificates.
2.
H.P. Foley Co. in the interoffice memorandun to all Q.C. supervisors, required that in order for a welder to maintain a current qualification status he must either have welded a complete production weld subject to full Q.C. Inspection or weld a test plate utilizing the required process with a min 4== of root pass and final pass inspection by a Q.C. Inspector. These instnetions will be incorporatcd into Q.C. procedures during the next procedure revision.
3.
Docunented training has been conducted for all Q.C. Inspectors and welders with regard to the requirements for maintaining current welder certifications.
4.
The inspector involved has been re-instructed as to the exact requirenents of and his responsibility with regard to welder recertification.
PGandE has also reviewed the practices of Pullman Ibwer Products with regard to this matter. Pullman is the only other site contractor currently engaged in Code welding. 'Ibe Pullman welders promoted to foremen have approprir.tely maintained their qualification status current by perfoming welding to the specific applicable process prior to expiration. 'Ihis welding is inspected and dom-ntad by the Pullman Quality Control Department.
Corrective Steps Which Will Be Taken Based on the actions described above, PGandE believes that adequate corrective actions have been taken. 'Iherefore, no additional corrective steps are necessary.
Date When Eb11 Compliance Was Achieved Eb11 compliance was achieved on April 30, 1983 when the interoffice memorandtun was issued by H.P. Foley Co.
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