ML20083J423
| ML20083J423 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 01/06/1984 |
| From: | Wetterhahn M PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | |
| References | |
| NUDOCS 8401100145 | |
| Download: ML20083J423 (53) | |
Text
DXXETir U1Mic UNITED STATES OF AMERICA 84 JAN -9 A10:31 NUCLEAR REGULATORY COMMISSION OFF cE OF 3tcge n, 00CKE71NG & SEPvio Before the Atomic Safety and Licensing Boaf8ANCH In the Matter of
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
APPLICANT'S REPORT REGARDING THE INVOLVEMENT OF PHILADELPHIA ELECTRIC COMPANY MANAGEMENT IN ASSURING THE QUALITY OF WELDING AT LIMERICK GENERATING STATION Pursuant to the Atomic Safety and Licensing Board's Memorandum and Order Confirming Rulings Made at Prehearing Conference (October 28, 1983) (slip op. at 7) (see also Tr.
5840), I am transmitting Applicant's " Report Regarding the Involvement of Philadelphia Electric Company Management in Assuring the Quality of Welding at Limerick Generating Station."
Respectfully submitted, CONNER & WETTERHAHN, P.C.
l Mark J. Wetterhahn Counsel for Philadelphia Electric Company January-6, 1984 8401100145 840106 i
PDR ADOCK 05000352
.G PDR
6 e
s UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION Before the Atomic Safety and Licensing Board In the Matter of Docket Nos. 50-352 Philadelphia Electric Company
)
50-353
)
(Limerick Generating Station,
)
Units 1 and 2)
)
REPORT REG ARDING THE INVOLVEMENT OF PHILADELPHIA ELECTRIC COMPANY MANAGEMENT IN ASSURING THE QUALITY OF WELDING AT LIMERICK GENERATING STATION 9
y
a TABLE OF CONTENTS PAGE I.
INTRODUCTION 1
II.
PHILA DEL PHI A ELECTRIC COMPANY'S 3
MANAGEMENT OF THE LIMERICK WELDING QUALITY PROGRAM III SECHTEL POWER CORPORATION'S 13 MANAGEMENT OF THE WELDING PROGRAM AT. LIMERICK GENERATING STATION IV INTEGRATION OF GOALS AND 18 PHILOSOPHY INTO THE LIMERICK GENERATING STF.fl0N WELDING QUALITY PROGRAM V
VERIFICATION OF THE WELDING 27 QUALITY PROGRAM *S IMPLEMENTATION
I.
Introduction This report responds to the Atomic Safety and Licensing Board Memorandum and Order Confirmina Rulings made at Prehearing Conference dated October 28, 1983 (Slip op. at
- 7).
The Applicant and NRC Statf were requested to set forth how they assure themselves for Limerick that welding and welder qualification, and inspections thereof, meet the design criteria and welding codes, including par-ticularly how it is assured that non-qualified welders are not qualified by fraud as has apparently occurred elsewhere despite the presumed existence of a QA program. TR. 4895-99, 4902-04.
The Applicant will file a report supplyino this information about a month after the prehearing conference, and the Staff will file its information report about two weeks after the Applicant's report.
TR.4919.
This report describes the management policy of Philadelphia Electric Company and its contractor, Bechtel Power Corporation, relating to quality and how these policies have been implemented in the design and construction of Limerick Generating Station, with particular emphasis on welding-related activities.
The report describes both companies' welding experience and expertise and how the quality as-surance program combines the talents of both to provide a high quality welding program which meets all regulatory, code and Safety Analysis Report requirements.
The quality assurance program utilizer three levels of design verification, each of which will be described in this report.
Philadelphia Electric Company is the third level of review and verifies that Bechtel's design work results in e
clear instruction to the Bechtel construction forces.
Tho construction forces' application of these instructions, in the actual velding at Li 7erick, is also subject to a three-level verification program.
Philadelphia Electric Company is again at the third level to assure that the velding is being performed anc inspected in accordance with the requirements of the welding program.
All three of these levels and how they interact are also discussed.
The report also describes the controls used in hiring and testing welders to assure that only qualified craftsmen are assigned the important task of welding.
From a management perspective, the report describes how the design verification, inspection, surveillance, auditing and evaluation has enabled Philadelphia Electric Company to maintain control over the welding activities to assure the achievement of a high quality end product.
l l
l i
II Philadelphia Electric Company's Managem9nt of the Limerick Weldino Ouality Program 1.
Philadelphia Electric Company's Manacement Philosophy Philadelphia Electric Company is a nuclear-oriented utility.
The Company is an industry leader in the utilization of modern types of generating equipment.
The Company led the industry in implementing high pres-sure and high temperature fossil fueled units which required the development of expertise in welding.
The Company entered the nuclear era in 1959 with the con-mitment to build and operate Peach Botton Unit 1, a high-temperature, gas-cooled reactor.
Peach Bottom 2 and 3 (1100 megawatt, twin boiling water reactors) vent into service in 1974 and have set domestic industry records for performance.
An indication of Philadelphia Electric Company's com-mitment to quality is its development for Limerick 7
Generatino Station of a graded quality program that ap-plies to systems and components beyond those which are I
i required by regulation to be covered.
This graded pro-gram covers Balance of Plant systems (BO P) such as rad-waste and other nonsafety systems anich interact with I
safety systems.
Another indication of the Company's commitment to quality is its utilization of modified quality assurance programs for design and construction of certain nonnuclear facilities.
l l
Philtdolphia Electric Co;pany recognizes that in addi-tion to assuring safe operation, a quality assurance program is cost effective and strongly supports its program as a means of reducing costly corrective meas-ures through prevention, rather than subsequent detection.
2.
Philadelphia Electric companv's Ouality Goals Philadelphia Electric Company's experience in nuclear power at Peach Bottom has provided the basis upon which the company has built in establishing and implementing a quality assurance program for Limerick Generating Station.
The company realizes that the high reliabil-ity which is being achieved at Peach Bottom is the result of the high quality standards that the plant was required to meet during construction, and which conti-nue to be met now that the plant is operational.
l The high quality standards to which Peach Bottom was designed and constructed were developed through good engineering practices.
The reculations in effect at l
l the time were not as stringent and did not require the 1
same level of quality assurance as today's regulations.
The revised regulations regarding quality assurance and the industry wide improvement of quality techniques l'
have led to the present sophistication in quality as-surance programs.
Because of Peach Bottom and l
l Limerick, Philadelphia Electric Company has been in-l t
-g_
i
volved in the esturation of quality essurance.
At Peach Bottom the Company learned the value of quality assurance through the problems it encountered and the resolutions it worked out.
The Company has always been committed to high quality standards and, because of its experience at Peach Bottom, has committed itself to utilizing a strong quality assurance program to attain these high standards at its nuclear faciltities.
In an effort to provide continuity and to assure that the lessons learned at Peach Bottom could be effec-tively taken into account at Limerick, Philadelphia Electric Conpany contracted with Dechtel Power Co rpora tion, the Architect-Engineer for Peach Bottoa, to design and construct the Limerick Generating Station.
Bechtel formed the nucleus of its Limerick project team with experienced people from the Peach Bottom team.
For example, the Lead Field Welding Engineer at Peach Bottom and several of his staff continued in their same positions at Limerick.
Similarly, the team of project engineers, which is responsible for design, was also formed with experienced individuals from the Peach L
Bottom t'eam.
As a result of this continuity, Philadelphia Electric Company has developed an effec-tive working relationship through which the Company has established that Bechtel Power Corporation is aware of, and shares in its commitment to high quality standards.,
This coccitoont is reflected in Bechtol's design cnd construction work at Limerick.
3.
Philadelphia Electric Company's Welding Expertise Philadelphia Electric Company has in-depth experience and expertise in welding and welding-related activities in both nuclear and fossil olants.
The company employs degreed metallurgists in both the Engineering and Research and the Electric Production Departments.
These individuals have achieved and maintain their qualifications through formal training in various universities, industry seminars, and through years of working experience.
Engineering and Research Department is the organization responsible for the design and construction of the Company 's power plants.
Electric Production Department is responsible for the operation and maintenance of the plants.
Although the two departments have distinct duties, the knowledge gained from performino them is shared.
This is especially true in the netallurgical area.
The Company has established a Materials Engineering Group (MEG) composed ot engineers and metallurgists f rom both departments, along with a con-sultant metallurgist.
MEG meets on a regular basis to discuss material and weldino technologies and to ad-dress particular concerns which may arise.
This group is available to any CoJpany engineer who needs notal-lurgical assistance in resolvino a problem.
To support Philadelphia Electric Company's efforts in the welding area, the Company has an established metal-lurgical laboratory.
The laboratory is staffed by ex-perienced metallurgical enaineers and technicians.
They ha ve participated in material selection and metal-lurgical problem analysis.
In addition to the metal-lurgical laboratory staff, Philadelphia Electric Company has Nondestructive Fxamination technicians who are qualified to SNT-TC-1A requirements and several qualified welding inspectors.
To supplement these in-house capabilities, several area firms and recognized experts in the field are under contract with the Philadelphia Electric Company for assistance and con-sultation in welding.
Within the Company's quality assurance organization many of the individuals are graduate engineers and reg-istered as Professional Engineers.
Several of the key individuals are AWS Certified Welding Inspectors.
This quality assurance organization is in close contact with t
j the Company *s metallurgists for technical consultation I
l and assi'tance.
The quality assurance organization s
uses the Company's metallurcical laboratory for chemi-cal and physical property tests on materials as part of the pertormance of audits to determine the quality of i
materials. ;
i
The broad rango of exparience and integration of wald-ing knowledge enable the Company to properly monitor the welding performance at Limerick.
4.
Philadelphia Electric Company's Participation in Codes and Standards Activities Philadelphia Electric Company supports technical organ-izations both financially and through manpower support and membership.
These technical organizations esta-blish the codes and standards applicable to much of the design and construction of nuclear plants.
By being active in these organizations, the company provides it-self the opportunity to remain knowledgeable in the in-dustry practices and technologies.
Within the Engineering and Research Department, many individuals participate in technical committee work such as the ASME Boiler and Pressure Vessel Main Commitee and its Subcommittee and Subgroups.
In the welding area, the Company's Level III Nondestructive Examiner has been active in the American Society for Nondestructive Testing (ASNT) for most or his career.
He is past National President and member of the Board of Directors of ASNT.
Other organizations in which the Company participates are:
American Society of Mechanical Engineers (ASME), Edison Electric Institute (EEI), American Welding Society ( A W S), American Nuclear Society ( AN S), American Society of Quality Control.
(A SQC), Instituto of Electrical and Electronic Engineers (IEEE), Electric Power Research Institute technical groups (EPRI), and Boiling Water Reactor Owners e Group (BWROG).
5.
Philadelphia Electric Comoany Direction to Bechtel Power Corooration regardino Weldino Recuirements Philadelphia Electric Company contracted with Bechtel Power Corporation to design and construct Limerick Generating Station because of its expertise, manpower, and commitment to quality.
Philadelphia Electric, in accordance with the quality assurance program, oversees all aspects of Bechtel's work to continue to assure that high quality standards are being met.
The overall quality assurance requirements of the Limerick Project were established by Philadelphia Electric Company management at the beginning of the project and have been undated and emphasized on an as-needed basis.
Sechtel Power Corporation was directed to incorporate these quality requirements into its quality assurance program.
The quality assurance program, as it pertains to weld-ing design, consists of three levels.
At the first level, Bechtel preparet specifications, drawings, procedures and inspection olans to include all applica-ble regulatory, code and Safety Analysis Report requirements.
The preparation of these design docu-
_9_
Dents is closely coordinated so that collectively.thm documents f orm an ef fective welding program which provides the construction forces clear and detailed instructions.
The second level consists of a design verification by individuals or groups within Bechtel, oth?r than those who performed the Original design.
The scope and depth of this design verification by Bechtel is detailed in its quality assurance manuals which meet the Philadelphia Electric Company imposed requirements.
The third level is performed by Philadelphia Electric Company.
At this stage, Bechtel's work is reviewed to assure that the welding procram meets all the Company's quality requirements.
The review is perf ormed by Company engineers who have access to the Material Engineering Group for consultation.
Through this review the Company not only verifies that the design and regulatory requirements have been met, but also ap-plies its welding experience to recommend improvements in the welding program.
Examples of these recommenda-tions which have been adopted include:
Directing Bechtel to control all weld filler metal
~
on site, both safety and nonsatety-related, to prevent the misuse of uncontrolled material in safety-related systems. _ -.
Dirrcting Brchtel to utilize tarked up drauings to scope and keep account of individual structural weld inspections.
This is beyond code and regula-tory requirements which would allow for one in-spection record to be utilized for several welds without uniquely identifying each weld.
Directing Bechtel not to use backing rings on flued head-to penetration welds; the use of these backing rings has caused problems in performing nondestructive examinations at other plants.
The following is a list ot weld-related documents which are prepared, reviewed and approved by Bechtel Power Corporation and then reviewed and approved by Philadelphia Electric Company:
Welding Specifications Welding Procedures Welding Filler Material Requirements Nondestructive Examination Procedures Selection of Nondestructive Testing Subcontractors On-Site Welding Administrative Controls Welder Qualification Drocedures Weld Piller Material Controls Welding Inspection Plans t
= _ _.
The thren-loval verification prograc applies not only to original design, but to any subsequent changes which come in the form of revisions.
The combined ef forts of Philadelphia Electric Company and Bechtel Power Corporation in the preparation,
~
review and approval of the above documents, result in a high degree of quality in welding-associated activities.
And as described later, the multi-tiered program of inspection and auditing has confirmed this conclusion.
l
! P w >
n v
.m,
+e,-
--re,
.-..>,--.,r
.- - - -,., ~ ~
,----m,
- - --- -,. --,,.~~
~.-
>w
---w
III. B':chtal Power Corporrtion's Manaan9ent of the Welding Quality Procras at Timerick Generatino Station 1.
Bechtel Power Corporation's Management Philosophy Bechtel practices the philosophy, and reinforces it through its programs, that cuality assurance is initi-ally a function of the group performing the work and not the sole responsibility of a separate quality as-surance group.
The Limerick Bechtel Project Manager implements the policies of the Quality Assurance Program at Limerick Generating Station throuah the project team organiza-tion which performs the engineering, procurement, con-struction and quality assurance functions.
Recognizing the importance of welding in nuclear power plants, a separate independent department, Material and Quality Services (MSQS) is responsible for providing direction on all facets of weldina.
The quality of welding at the Limerick Generating Station is achieved throuah the use of skilled person-nel, advanced planning, procedures, proper definition of job requirements, and appropriate supervision and technical direction.
Quality is verified through sur-veillance, inspection, testina, checking, and review of work activities and documentation.
Quality verifica- -
. _ _. =, _ _. - -_
tions aro ptrforctd by individuale cho are nct directly responsible for performing the work activity.
2.
Bechtel Quality Assurance Program Implementation The welding requirements of safety-related structures, systems and components at the Limerick Generating Station are ir, accordance with the Bechtel Quality Assurance Program an described in the Limerick Generating Station Application.
The design and con-struction quality assurance procram meet the require-ments established by Philadelphia Electric Company.
The Limerick Nuclear Quality Assurance Manual (NQAM) incorporates the Philadelphia Electric Company quality assurance requirements and provides detailed instruc-tions to the Bechtel Limerick Project Team to implement these requirements.
The NQAM, therefore, contains the requirements of the Quality Assurance Program to be followed by all Bechtel entities involved in the Li.*arick Generating Station.
Safety-related welding activities are performed within the requirements of the l
l NQAM.
l ASME p& essure retaining and comconent support welding l
I is performed within the requirements of the NQAM and the 9echtel Quality Assurance Manual (BQAM).
The BQAM is a more detailed subtier document to the NQAM which l
implements specific requirements of the ASME Code.
l L
3.
Bechtel Past ExpSrienc7 as Bass for Goals Bechtel has been involved in nuclear power plant en-gineering and construction from the inception of the nuclear power industry and has participated in en-gineering, procurement or construction activities in approximately 40 percent of the domestic power plants either in operation or under construction.
The ex-perience gained in these actf vities is f actored into enaineering specifications, QA programs, welding proce-dures and construction methods.
This is further supplemented by special centralized service organizations such as MSQS which has a staff of technical experts to assure that Bechtel remains cur-rent in welding technology.
MSQS is a department of approximately 125 professional personnel representing a total of approximately 2100 man-years of experience in such disciplines as welding engineering, construction welding, metallurgy, materials selection, corrosion, and nondestructive examination.
4.
Bechtel helding and Wold Ouality Requirements MSQS has the responsibility for qualif ying and prepar-ing all'Bechtel weldino procedures and maintains a laboratory to perform these qualifications.
All Bechtel welding procedures used on nuclear power plant construction are prepared by MSQS, approved by the Manager of MSOS and the Manager of Engineering, Bechtel -
Power Corporction.
The specifications and proc:dcrca for welding, qualifying welders, controlling weld metal, etc., for use at Limerick Generating Station are concurred with in a joint review by Engineering, Construction and MSQS.
Philadelphia Electric Company maintains control over these activities by reviewing and approving these specifications and procedures.
The list of approved specifications and procedures to be used are then transmitted to thejobsite.
Construction cannot deviate from the welding specifications without completing the entire review and approval cycle for their proposed revision.
MSQS furnishes the NDE proce-dures to be used by Bechtel personnel after the same review and approval as described above.
MSQS also reviews and approves NDE contractor procedures for use on the jobsite and is responsible for testing and cer-tifying all Bechtel NDE personnel on the jobsite to the requirements of the applicable codes.
5.
Bechtel Participation in Codes and Standards Activities Bechtel has been a leader in the industry in recogniz-ing the importanre of participatina in, and supporting, the activities of various code bodies.
This participa-l tion exists in all disciplines within Bechtal.
There i
are several hundred peoole carticioating in tnese codes I
and standards activities.
This involve 2ent in code regulated work promotes an awareness and understanding within Bechtel of the current positions of the code
! l
concittess on icportant catters reinting to the indua-try and provides an opportunity for Bechtel to initiata any required actions to clarify requirements, correct deficiencies or ambiguities, and to u;4ste requirements to reflect improvement in welding technology e
IV.
Intearation of Goals and Philosophy into Limerick Geheratina Station Weldino Program 1.
Desian Practices Welded joint designs at Limerick may be classified into two basic tyoes, structural and pressure retaining.
In general, structural welds are made in accordance with the AISC specifications and the AWS codes.
Pressure retaining welds are made in accordance with the ASME code.
Early in the design process, the applicable codes are detersined for each structure, system, and component.
The desion process utilizies the require-ments and guidelines given in these codes and specifications.
Structural welds are specified to carry the design load of the connecting members.
Pressure retaining welds are designed to develop the strength of the adjacent base material.
The welds soecified are larger than those theoretically required to transf er the actual loads.
Some of the factors contributing to this margin are described i
below:
l (1)
Simplification of the welding requirements on design d.awings (e.g. an "all around" weld is spe-cified "' an a partial weld would do),
(2)
Minicuo sizcs of wolds ace based on thickncsm cf attached parts rather than on strength require-ments (i.e. the minitum fillet veld size for pipes is defined to be 1.09 x the nominal wall thickness of the piping).
(3)
For pressure retaining welds, Joint efficiency f actors may be assigned by the code dependent on the type of examination that the welds receive.
(4)
Calculated fillet veld sizes less than nominal are rounded off to the next larger nominal size rather than to the exact dimension required.
Factors of safety are used in the design of structures, systems, and components to cover a number of conditions such as:
uncertainties in load definition, variations in material properties, approximations used in analyti-cal methods and variations in construction.
Factors of safety are quite hich in ceneral, but are Ddrticularly high in deFign of Welds.
For example, even though weld metal has higher yield and tensile i
strength than the materials being joined, the stresses 1
l allowed in designing the connections are based on the strength of the connected material.
In addition, the j
allowable stresses for the base material are small com-pared to the ultimate caoacity of the material.
l
The uss of the above factors in eeld design halps to assure that the velds are able to withstand higher stresses than the structures, systems or components be-ing joined.
2.
Weld Proced ures Development and Selection Where the design dictates the use of welded connec-tions, welding procedures that meet the design prac-tices are prepared and qualified.
MSQS is responsible for the preparation and qualification of all welding procedures used by Bechtel personnel on Bechtel jobsites.
The qualification tests are performed, in most in-stances, in the Bechtel Welding Engineering Laboratory.
Bechtel naintains a large inventory or weld procedure qualifications covering a wide spectrum of materials, material combinations, thickness ranges, and weld processes.
As new weld processes and materials are in-troduced, new qualifications are pertormed and new welding procedures develooed accordingly.
In support of Engineering, M&QS reviews the welding requicements for a specific project which includes the
~
material types, rorms, and sizes involved and specifies the weld procedures which are permitted to be used on each application. -
Engincoring propsrcs project walding spccifications that include the pregualified approved welding
^"
- proced ures.
And as previously noted, Philadelphia Electric assures that all quality requirements are met by reviewing and approving the specifications including the welding procedures which are con tained therein.
These specifications and welding procedures are then transmitted to the jobsite and f rom this point on, no deviations are permitted without prior approval of Engineering and MSQS.
3.
Limerick Welding Procram Including Welder Oualitication Thc Limericx. field welding program covers all aspects of the welding opera tion including specifying and or-dering weld tiller metal, control and distribution of all weld filler metal, testing and training of all vel-ders, authorization to weld, in process inspections, field surveillance, problem solving, technical support,
-A drawing review, final inspection, and record keeping
_and traceability systems.
' Limerick Field Welding Engineerina is responsible for
?~
providing on-site direction to construction personnel involved in welding activities.
Field Welding Engineering is comprised of peoole with a broad mix of skills including graduate metallurcical and welding en-gineers, journeymen welders, and document control sp'ecialists.
Presently thirty welding engineers repre-
~
D p,'
?
sent a co bined welding exonrienco levol of 514 yocrs, of which 241 have been in the field of nuclear welding.
That averages to seventeen years of welding experience per engineer, of which about one half is in nuclear welding.
Sixty-six percent are journeymen welders, fifty-five percent are certified for Level II NDE exa-minations, and forty-three percent are AWS certified welding inspectors.
This level of experience, combined with the availability of the Bechtel home office MSQs department, provides an efficient and experienced team to implement the Bechtel quality urogram.
The Limerick welder qualification program is designed to assure that only qualified welders are permitted to weld.
The following describes the steps taken to pre-clude the possibility of " stand-ins taking a welding a
test to qualify another person.
Upon arriving at the Limerick jobsite, an applicant for employment as a welder is directed to.he timekeeper's office where a check of the union's ref erral is made.
If the applicant is determined to be eligible for hire, a badge number is assigned.
At this time the applicant fills out an employment record and must present his/her Social Sec'urity card and two other forms of identification.
When the above steps are conplete, the applicant's pho-tograph is taken and a oicture badge is issued. _
The cpplicant is than escorted to the wold tcat shop by the union steward.
The veld test shop engineer checks the applicant's picture badge and fills out the " Welder Test Qualification Summary" and the " Welder Questionnaire".
The aoplicant is then assigned a test
- booth and is given a copy of safety regulations, tool box inventary and work rules for the weld test shop, which he signs.
The work rules, for which the appli-must sign, clearly state that he is the only per-cant son allowed in his assigned test booth and that any vi-olations are cause for termination of his qualification testir.g and employment at Limerick.
The weld test shop engineer explains the welding proce-dure the applicant will use to take his test and then supplies the applicant with evaluation coupons which he must tack weld together.
The test shop engineer evalu-ates the fit-up obtained during tack welding and, if satisfied,. instructs the applicant to complete the welding of the evaluation coupons.
The test shop engineer closely monitors the applicant's l
l performance and inspects the evaluation coupon veld af-l ter each layer or filler metal is deposited.
The eval-l uation is terminated at any point where it is evident 1
that the applicant is not capable of producing accepta-ble production welds.
If the applicant is not capable, ne/she is told so.
Payroll is contacted to make ar-
! l
rangsconts for his/her check, and the stewcrd is called to escort the applicant off site.
All welder candidates must take this evaluation test prior to being permitted to begin their qualification testing.
The evaluation test, which is beyond any code or regulatory requirement, precludes the possibility of an unqualified welder using false credentials.
Even a welder with current qualifications from another Bechtel jobsite who makes application for employment at Limerick must complete all of the above steps including the evaluation test.
If such an applicant successfully demonstrates his welding ability during the evaluation tes t, his qualifications are accepted.
If the applicant's evaluation coupon is acceptable, he/she is directed to begin the weld test.
After clean check and fit up has been accepted on the test coupon, it is vibroetched for identification.
The information etched includes the applicant's initials and craft num-ber, the welding procedure used, the position, the date and the test shop engineer's initials and badge number.
The applicant proceeds with the test weld and the test shop engineer performs in process and final visual in-spection of the welding.
If all of the applicant's work is satisfactory to this point, nondestructive and/or destructive testing of the test coupon is per-formed for the final determination of the applicant's
- 24 s-
abilit y.
A successful applicant is then taken to th@
Field Welding Engineer's office to have his/her qualif-ications logged and receive his/her qualification book.
The appropriate Superintendent is notified that the applicant is ready and the steward is called to take the applicant to the Superintendent.
Folloging assignment in the field, continued field sur-veillance also ensures that only qualified personnel are on the job.
Random " badge checks" are~ performed regularly to verify that only authorized workers are on the job, and the individual perf ormance of welders is monitored by their Superintendent.
Poor performance will result in the Superintendent sending the welder back to the test shop for training and/or requalification.
The system of controlling the cualitication of welders has been in effect at the Limerick jobsite throughout
-the years of construction, with additions and revisions from time to time to improve the system.
In conclusion, with the number of identification checks made at the time office, the forms and other informa-tion signed, the hours of parsonal contact with the weld test shop enoineer, the precautions of identifying all coupons and the contact with other personnel in receiving their qualification book, the possibility of - _ _, _ -
a " stand-ina taking the test for an applicant is virtu-ally nonexistent.
t i
7 r
f,
h
V.
Verification of the Wn1dino Ouality Prcorents Inplesantation 1.
Three-Level Verification Procram The three-level verification program mentioned earlier utilizes the defense in depth concept.
Earlier, the three levels which assure that the Limerick design con-tains high quality standards were discussed.
This sec-tion deals with the three levels of assuring that the construction is in accordance with the design.
The first level, defined as the quality control inspec-tion function, is performed by Bechtel Power Corporation's quality control organization which is in-dependent from the construction forces.
Quality control is responsible for assuring that the final end product meets the specified design requirements.
The second level, defined as the quality assurance sur-veillance function, includes the auditing and/or sur-veillance performed by Bechtel Power ;orportion's quality assurance organization which is independent f rom the construction f orces and Quality Control.
The third level, defined as the quality assurance au-diting function, is performed by Philadelphia Electric Company 's quality assurance organization which is en-tirely independent f rom all Bechtel organizations.
Philadelphia Electric Company oerforms quality as-surance audits and surveillances to assure that the -
quality assurance progrcos of the first and s:cond level organizations are actually functioning as required.
In addition, Philadelphia Electric Company reviews specifications, site procedures and other required documents furnished by Bechtel Power Corporation to assure that the necessary quality requirements have been incorporated in these documents.
The three organizational levels of the verification program, as they relate to welding at the Limerick Generatina Station, are described below.
2.
Bechtel Power Corooration Quality Control Weld Inspection Program the purpose of the construction quality control program f or inspect ion, examination and tect control is to verify conformance of construction activities on welded safety-related structures, systems and components with the applicable requirements.
This is accomplished by the use of quality control inspection instructions tailored f or the Limerick project which specify the in-spection activities required, the insoection criteria, and the method and frequency of the inspection activities.
Construction Quality Control also provides documented evidence that the completed construction ac-tivities conform to the program requirements.
Quality of workmanship is monitored by Field Weld Engineering and Quality Control Engineering on an in- -.
process basis.
Final visual exacinations aro parforatd by Bechtel Quality control Engineers on safety related installations prior to submittal for Nondestructive Examination (NDE) operations.
Upon an acceptable visual examination, the assigned Quality' Control Engineer flags the component and initiates a Nondestructive Examination Request Form.
This request form outlines the method of NDE to be performed, describes the component and its location and, if appli-cable, notes the welder who performed the work.
This request form is submitted to Welding Quality Control where the supplied information is transferred onto an NDE Work Request Form and submitted for NDE.
Bechtel Welding Quality Control monitors and witnesses NDE operations performed by subcontractor personnel to assure NDE operations are performed on the correct itets and within the parameters established by the ap-plicable NDE procedures.
Bechtel Welding Quality Control Engineers witness 100 percent of the ultrasonic examination performed by the subcontractor and review 100 percent of the radio-j graphic film submitted by the subcontractor for tech-1 nique, film quality and comoonent acceptability.
l Bechtel Quality Control also assures that the proper i
l welding instructions are oiven to the cratt prior to the start of work.
This is accomplished by reviewing,
each weld joint field welding checklist which Field Welding Engineers prepare.
Welding Quality Control Engineers review the checklists to assure entries by the Field Welding Engineers are correct and conform to the governing installation requirements.
This in-line review requirement also serves to keep Quality control avare of all new welding starts.
The inspections, examinations and tests performed by Construction Quality Control assure that the installa-tion is in compliance with design specifications and compliance with the Bechtel Quality Assurance Program.
In addition, the Hartford Inspection Agency, acting as the Authorized Nuclear Inspector, also reviews inspec-tion plans and establishes randon inspection hold points for ASME Code-related welding.
The authorized Inspector reviews 100 percant of the radiographic tila on ASME installations.
Hartford Authorized Nuclear Inspectors also observe welder oerformance qualifica-tion tests and review radiographic film on welder per-formance qualification tests for compliance to ASME Code requirements.
3.
Bechtel Power Corporation Ouality Assurance Weld Quality Audit Program A.
Bechtel QA Program Steos The activities associated with field welding on the Limerick Station are controlled by the Project Quality Assurance Program which has been evalu-ated, approved and monitored by Bechtel Quality Assurance Management, Philadelphia Electric Comoany and the applicable regulatory authorities (ASME and NRC).
The Bechtel Quality Assurance Program for the construction of the Limerick Generating Station contains several methods which provide for the verification of the construction welding program by Quality Assurance.
These methods include audit and monitoring of field ac-tivities by the Project Quality Assurance group and Management Audits of Quality Assurance.
1)
Proiect Audits Project audits are accomplished by the use of the Master Audit Plan (M A P) as a planning tool, which defines the frequency and scope att each audit area.
Project audits are per-tormed to cover each area annually or at least once within the life or a short tern activity.
Regularly scheduled audits are l j
supplearnted with additional audits cn an "as-needed basis".
The MAP for Limerick Project contains eight audit areas that specifically address welding activities and two audit areas that address nondestructive examination activities.
One of these areas includes forty-two elements of verification of welding activities, which in-clude filler metal control and distrubution, welder qualification, Bechtel NDE personnel qualification, in process welding activities, welding procedures, weld repairs, Quality Control activities, post weld heat treatment, weld record documentation, and Quality control inspector qualifications.
In addi-tf 7n, the MAP includes the audit of subcon-tractors performing nondestructive examina-tion of welds to verify their conformance with project requirements on the control of procedures and personnel qualifications.
Project audit reports, including all defi-ciencies noted during the addit and their scheduled completion date, are prepared and distributed to the responsible project l
management.
All deficiencies are followed up i
and closed out by oroject quality assurance personnel after verification of the audit d organizations' response to audit findings.
2)
Proiect Monitoring Activites Monitoring activities are not intended to be as wide in scope as project audits, but are more in-depth, verifying the in-process controls.
When determining the monitoring activities to be performed, previous monitor-ing and auditing results are considered.
The monitoring activities cover applicable or.go--
ing activities, utilizing construction and engineering schedules to determine the areas to be monitored and the frequency of monitoring.
Monitoring includes checks for compliance to project quality program control requirements and the observance of inspection activities, reviewing records and checking work activities.
Deficiencies noted by Project Quality Assurance during monitoring activitieF are documented.
The documented deficiency is transmitted to the applicable management en-tity for requested corrective action.
Completed action is verified by Project Quality Assurance prior to closeout..
3)
Menacement Audits The project construction activities are au-dited by Bechtel Quality Assurance Management.
The QA Management audit plan in-cludes the audit areas of welding and nondes-tructive examination control.
The QA Management Audit Team includes technical spe-cialists from the MSQS support group who review project welding and nondestructive ex-amination and related activities, in addition to QA auditors who review other project quality related activities.
The welding related activities audited include welding process control, weldino documentation con-trol, welder qualification and weld filler material control.
At the completion of the QA Management audit, an audit report is transnitted to Philadelphia Electric Company and Bechtel Power Corporation oroject management.
This report identifies all observed deficiencies which are docunented as audit findings requiring corrective action.
After comple-tion of corrective action by the audited or-ganization, quality assurance personnel i
verify that the action is complete and ade-l 34 -
L
quate before the audit finding is esnsidar d closed.
4.
Philadelphia Electric Company's Weld Audit and Evaluation Procram A.
Philadelphia Electric Company's OA Procram Philadelphia Electric Company's third-level verif-ication f unction of welding at Limerick is directed by management through Philadelphia Electric Company's Quality Assurance Program, for the design, construction and pre-operational phases of the project.
This third-level function is accomplished by the performance of audits and surveillances which cover inprocess welding and the weld-related activity of the first two levels of the verification program.
This audit and sur-veillance program provides assurance that welding activities are acconolished in a manner that meets the Federal regulations and the plant's design criteria and verifies that the first two levels of the program are effective.
These audits and surveillances are performed by nembers or Philadelphia Electric Company's quality assurance organization who are qualified to the requirements of ANSI N45.2.23.
" Qualification of l
Quality Assurance Program Audit Personnel for Nuclear Power Plants".
The scope and purpose of l.
audits are prodotorcined and written checklists are prepared to conduct the audits.
The audits are conducted in accordance with the requirements of the implementing procedures of Philadelphia Electric Company's quality assurance program.
The results of the audits are documented, reviewed and evaluated by the quality assurance organization and then forwarded to manaaement for its review and action if necessary.
Surveillances are utilized by Philadelphia Electric Company a s " mini-audits".
As compared to audits, they are limited in secpe, usually con-sisting of the verification of only one activity.
As such, surveillances are very useful in the au-diting process.
An audit to cover an area such as welding may be scoped to verif y weld rod control, welder qualification, welding technique, inspec-tions, etc.
If one of these areas is found to be deficient, a limited-scope surveillance can effec-tively follow up on the identified area.
Over 350 surveillances have been conducted throughout the course of the project.
1 B.
Weldino Audit and Surveillance Fesults To date, Philadelohia Electric Company's quality assurance personnel have, on a planned and perio-dic basis appropriate to the status of the design.
and construction activitics, conducted over 1500 audits.
Of these audits, over 400 have been scoped, either in total or in part, to cover veld-ing and welding related activities.
The results of these audits have confirmed that the first two levels of the quality program are working effec-tively to assure that Limerick Generating station will be a safe and reliable plant.
However, this does not mean that the audits have not identified areas that need improvement.
The lack of identification of such areas in an un-dertaking as larce as the Limerick project would raise questions regarding the effectiveness of the audits.
The same audit process that has identi-fied such problems has also been used to verify that they have been satisfactorily resolved.
4 An example of the functioning of the audit process in the welding area was the identification by Philadelphia Electric Company's quality assurance l
organization of a matter requiring significant in-provement; poor quality welding in the safety-related HVAC systems and components was recognized
{
throu'gh numerous audit findings.
The corrective actions necessary to resolve this matter consisted of strengthening the HVAC subcontractor's entire quality assurance program with particular emphasis in the area of inspections.
Evaluation of the J y--.-.--.
~
y
problem revealed that the subcontractor did not have enough inspectors to handle the work load, and the inspectors it did have were not performing at an adequate level.
This situation was remedied through increasing manpower and intensive training.
Philadelphia Electric Company's quality assurance organization devoted a considerable amount of time and audit activities to assure that.the corrective actions taken were appropriate and successful.
This included assigning an auditor full time for approximately one year to monitor the HVAC subcontractor exclusively.
Since the interim period when the HVAC subcontractor reinspected previous work, made repairs where necessary and reestablished its quality assurance program, Philadelphia Electric Company's audits have verified that previous HVAC welding problems have been resolved and that the quality assurance program is working effectively to preclude recurrence.
Philadelphia Electric Company is confident its audit program works well.
The overall scheduling i
of audits as well, as the techniques utilized in performing the audit function, provide this confidence.
Audits have been scheduled to cover all aspects of the work activities while taking into consideration the quantity, difficulty
. L
and iaportance of each activity.
As prsviously mentioned, Philadelphia Electric Company has per-formed over 1500 audits.
Where these audits have identified nonconformances, the audit activities have been increased or Bechtel has been directed to perform additional inspections to. determine the extent of the problems.
In the majority of in-stances, a nonconformance is investigated and found to be an isolated case.
The HVAC welding problem was an exception, but demonstrates the ef-fectiveness of the audit orogram.
Philadelphia Electric Company also utilizes audits to r.onitor the corrective actions taken to resolve problems identified by Bechtel.
All Bechtel Power Corporation's Nonconformance ReDorts, Management Audit Reports and Quality Assurance Audit Reports are sent to Philadelphia Electric Company.
If there are any questions about any item in the Bechtel reports, the quality assurance organiza-tion performs an audit.
This has been ef fective in assuring Philadelphia Electric Company manage-ment that Bechtel's entrective actions are satisfactory.
For example, Bechtel identified a problem with large pipe hanger welds.
The problem was caused by the lack of coordina tion between the two disciplines of Quality control (QC) which were inspecting the hangers.
Piping QC was inspecting._.
the installsd configuration 01 the hangers and Welding QC was inspecting the hanger welds.
Upon notification from the construction forces, Welding QC was inspecting the welds and closing its in-spection plans.
Piping QC also inspected each hanger, and sometimes, identified conditions which required rework.
If the rework required new welds to be made, Welding QC was not always informed and since its inspection plans were already closed, there was a potential for welds to go uninspected.
The resolution to the problem required reinspec-tion ot all large pipe hanger welds.
To preclude the possibility of future problems, the weld in-spections were performed on the same inspection plan as the configuration inspections and by the same QC discipline.
The piping quality control encineers were cross-gualified to be able to per-form both inspections.
Philadelphia Electric Comoany's auditing of this Bechtel identified problem and its resolution as-l sured that the root cause of the problem was properly identified.
For example, had the cause bee'n poor inspections rather than lack of coordi-l nation, it could have affected more than just large pipe hangers.
The auditing also verified that the piping quality control engineers were l I
i-
properly qualified and proficient in their rolding inspections.
5.
Communications with Management Philadelphia Electric Company's quality assurance or-ganization prepares weekly, monthly and annual reports to inf orm the Vice President of the Engineering and Research Department, to whom it reports, of all the quality assurance matters related to the Limerick pro ject.
The Vice President also receives all audit and finding reports.
The receipt of these reports often results in the Vice President initiating discussions with the Company's Manager of QA and/or the QA Pield Branch Head.
These discussions are made to obtain additional information or updates or to give direction in certain matters.
There are numerous other communications with the Vice President necessitated by the normal course of conduct-ing the quality assurance organization's business.
Notification to the Vice President is required whenever a "Stop Work" order is issued or whenever an identified problem is considered potentially reportable to the "S' top Work" is issued by the quality assurance NRC.
A organization when it determines that the continued practice of certain activities could result in a degra-dation of quality.
The Vice President also becomes in-volved in the quality assurance organization's matters.-,.
when responses to finding renorts bacono oxcessively overdue.
Failure of an audited organization to respond to a finding report results in successive request let-ters from escalating levels of management up to the Vice President.
The Vice President also receives and discusses with the quality assurance organization the results of Bechtel Power corporation's QA reports as well as reports from several outside organizations which audit the Limerick project activities.
In addition, the Vice President holds a monthly project status meeting at which both Philadelphia Electric Company's and Bechtel Power Corporation's quality assurance organizations report on the progress they have made in obtaining and verifying corrective actions to past findings as well as new pro-blems which may have been identified.
6.
Outside Acencies Verifications of the Weldinc Quality The welding quality assurance program at the Limerick generating Station is also subject to review and verif-ication by five independent outside organizations:
A)
The American Society of Mechanical Engineers
( A SME')
Becntel Power Corporation has maintained its cer-tificate to install nuclear pressure retaining components by receivinq certification from the ASME.
ASME tcaos cudit ovary threo (3) ystre eith welding being one of the major areas covered.
B)
National Board ' of Boiler and Pressure Vessel Inspectors Members of the Board participate in the ASME sur-veys and in the decision to grant the certificates.
In addition, members of the National Board certify the Authorized Nuclear Inspectors who perform the ANI inspections described below.
C)
Hartford Steam Boiler Inspection and Incurance Company Hartford maintains a staff of Authorized Nuclear Inspectors ( A NI) on site as required by the ASME Code.
These inspectors monitor ASME welding-related activities and have the authority to as-sign hold points on construction activities past whien construction cannot proceed until their in-spection is satisfactorily completed.
In addi-tion, Hartford supervision performs semi-annual audits of applicable Bechtel activities associated with ASME Code welding.,
D)
Joint Utility Msn ge00nt Audits (JUM A)
Philadelphia Electric Company has been a partici-pating member i.1 a Joint Utility Management Audit Group (JUMA) since the late 1970's.
This group annually audits the Philadelphia Electric Company quality assurance oroanization's activities.
These J0MA audits of Philadelphia Electric Company are conducted by senior supervisory quality as-surance personnel from other utilities.
E)
Institute of Nuclear Power Operations (INPO) -
Construction Project Evaluation (CPE)
The INPO Construction Project Evaluation was developed as a standard method of evaluating utilities
- nuclear construction programs.
Philadelphia Electric Company supports INPO CPE and has actively participated in the development and trial of the Phase I evaluation.
The above organizations' evaluations, auditing and verifications of the Limerick project have all been positive.
The ASME audits have resulted in the exten-sion of Bechtel's ASME Certificate of Authorization.
j The on-site Authorized Nuclear Inspector has verified that ASME welding is done in accordance with the Code requirements.
The semi-annual audits by Hartford have never identified a major problem.
And, every JUMA au-l !
W dit and INPO cycluation have concluded that the Limerick Generating Station quality assurance program is eff ective and is beina ef fectively implemented.
None of the evaluations or audits has revealed a weld-ing hardware problem.
The INPO evaluations and JUMA audits go beyond verifying conformance to the established programs.
INPO and JUMA also evaluate the prograss and make recommendations for improvement.
Philadelphia Electric Company has evaluated the INPO and JUMA recommendations.
Some of the recommendations which Philadelphia Electric Company has adopted include:
Having Bechtel transmit NCR's to Philadelphia Electric Company as soon as they are disposi-tioned so that the Company can review the disposition and make any desired comments orior to the start of rework or repairs.
Prior to this recommendation being iQple-mented, NCR's were only torwarded once a
(
month.
1 Having Field Change Reguests trended to
. determine if repeated PCR's are the result of poor original design work.
I i
Having Philadelphia Electric Company quality assurance organization develop a formal notification system for establishing hold l
I points during audits.
Prior to inplcocnting this recommendation there was no formal procedure to establish an audit hold point.
Having Philadelphia Electric Company develop an escalating corrective action request policy.
This has been previously discussed in the " Communication with Management" section.
The results of these outside acencies' evaluations and audits have been beneficial to Philadelphia Electric Company.
They have reported to the company's manage-ment on tne effectiveness of the program from a diff-erent persoective and this has further increased the conIidence the Company has in its quality assurance program which, in turn, leads to a higher degree of confidence in the welding ouality.
7.
Philadelphia Electric Company Manacement's Perspective of Welding At Limerick Philadelphia Electric Coroany is confident that the welding on the Limerick Project meets the Company's ob-jectives for Limerick to be a safe and reliable plant.
The com p'e t'en t people Philadelphia Electric and Bechtel have working within the quality assurance program have led to this confidence.
The three levels of verifica-tion applied to the design of the welding program and three levels of verification applied to the welding
- 46
4 parforced within the progren, have enabled Philadelphia Electric Company to maintain a constant awareness and control of the welding activities.
There will be several hundred thousand safety-related velds at Limerick.
With this volume cf activity there is potential for occasional welding problems and some have been experienced at Limerick.
- However, Philadelphia Electric Company is confident that the problems have been identified and the Company has moni-tored their satisfactory resolution.
In conclusion, the Limerick quality assurance program, which encompasses all phases of welding, from design to final verification, has been effective in assuring that the welding meets the quality requirements and satis-fies the design criteria required for the safe opera-tion of the plant.
l l
l l
l l
l !
- o e
..j i
UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the Matter 7f
)
)
Philadelphia Electric Company
)
Docket Nos. 50-352
)
50-353 (Limerick Generating Station,
)
Units 1 and 2)
)
CERTIFICATE OF SERVICE I _ hereby certify that copies of " Applicant's Report Regarding the Involvement of Philadelphia Electric Company Management in Assuring the Quality of Welding at Limerick Generating Station" dated January 6, 1984 in the captioned matter, have been served upon the following by deposit in the United States mail this 6th day of January, 1984:
Judge Lawrence Brenner (2)
Atomic Safety and Licensing Atomic Safety and Licensing Appeal Panel Board U.S. Nuclear Regulatory U.S. Nuclear Regulatory Commission Commission Washington, D.C.
20555 Washington,.D.C.
20555 Docketing and Service Section Judge Richard F. Cole Office of the Secretary Atomic Safety and Licensing U.S. Nuclear Regulatory Boara Commission U.S. Nuclear Regulatory Washington, D.C.
20555 t
Commission l
Washington, D.C.
20555 Ann'P. Hodgdon, Esq.
Counsel for NRC Staff Judge Peter A. Morris Office of the Executive Atomic Safety and Licensing Legal Director Board U.S. Nuclear Regulatory l
U.S. Nuclear ~' Regulatory Commission l
Commission Washington, D.C.
20555 l
Washington, D.C.,20555 i
1 Hand Delivery
e; N % %,.
' Atomic Safety and Licensing
. Steven P. Hershey, Esq.
Board Panel Community Legal U.S". Nuclear Regulatory Services, Inc.
~
Commission Law Center West North Washington, D.C.
20555 5219 Chestnut Street Philadelphia, PA 19139
' Philadelphia Electric Company ATTN:
Edward G. Bauer, Jr.
Angus Love, Esq. 101 East Vice President &
Main Street Norristown, PA General Counsel 19401
- ~
2301 Market Street Philadelphia, PA 19101 Mr. Joseph H. White, III 15 Ardmore Avenue Mr. Frank R. Romano Ardmore, PA 19003 61 Forest Avenue Ambler, Pennsylvania 19002 Robert J. Sugarman, Esq.
Sugarman & Denworth Suite Mr. Robert L. Anthony 510 North American Building Friends of the Earth of 121 South Broad Street the,D,elaware Valley Philadelphia, PA 19107 106 Vernon Lane, Box 186 Moylan, Pennsylvania 19065 Director, Pennsylvania Emergency Management Agency Mr. Marvin I. Lewis Basement, Transportation 6504 Bradford Terrace and Safety Building 7
Philadelphia, PA 19149 Harrisburg, PA 17120 Phyllis Zitzer, Esq.
Martha W. Bush, Esq.
Limerick Ecology Action Kathryn S.
Lewis, Esq.
P.Or Box 761 City of Philadelphia 762-Queen Street Municipal Services Bldg.
Pottstown, PA 19464 15th and JFK Blvd.
Philadelphia, PA 19107 Charles W. Elliott, Esq.
Brose and Postwistilo Spence W.
Perry, Esq.
1101' Building lith &
Associate General Counsel Northampton Streets Federal Emergency k;.h,
- Easton, PA 13042 Management Agency 500 C Street, S.W., Rm. 840
.l Zori G. Ferkin, Esq.
Washington, DC 20472 s.
Assistant Counsel Commonwealth of Pennsylvania Thomas Gerusky, Director I
-Governor' c-Energy Council Bureau of Radiation 1625 N. Front Street Protection Harrisburg,.PA 17102 Department of Environmental
~'
Resources 5th Floor, Fulton Bank Bldg.
Third and Locust Streets Harrisburg, PA 17120 1
.5 *
.a
't Jay M. Gutierrez, Esq.
U.S. Nuclear Regulatory Commission Region I 631 Park Avenue King of Prussia, PA 19406 James Wiggins Senior Resident Inspector U.S. Nuclear Regulatory Commission P.O. Box 47 Sanatoga, PA 19464 O
Mar Q'. "Wetterh&hn e
l l
l i