ML20133C889
| ML20133C889 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek, River Bend  |
| Issue date: | 11/14/1984 |
| From: | KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20133C868 | List: |
| References | |
| FOIA-85-101 PROC-841114, NUDOCS 8507220030 | |
| Download: ML20133C889 (182) | |
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KG&E MANAGEMENT PLAN a
- NOVEMBER 14, 1984 (Revision 1) 4 4
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, 8507220030 850528
. VARRICC85-101 PDR, -
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P3.NAGDtENT PLAN FOR THE RESOLUTION OF CAR-19 Overview The etjectives of this plan are as delineated in CAR-19. These objectives will be met by p cviding objective evidence that each of the corrective actions specified within CAR-19 are satisf actorily imple-mented. The intent is to verify that both the hardware and p:=grammatic aspects of all safety related activities utill:ing AWS D1.1 welding are in compliance with the FSAR (i.e. AWS Dl.1 - 1975) and the Design and Construction Program Manual (Section 17.13).
The attached logi: chart illustrates tne approach to be used in providing the above mentioned verifications. The Corrective Actions associated with each of the steps on the logic enart are identified .
on the chart.
All Corrective Actions shall be i=plemented in strict accordance
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with CAR-19 including review and approval of specific items by KG&E CA where requested. Flow diagrams (attachments C-1 and C-2 of the CAR) have been and will centinue to be considered in developing correc-tive actions.
Upon completion of each cf the corrective actions necessary to resolve CAR-19, reports will be prepared which su.=arize action taken.
These su==ary reports will be used internally by - DIC in the preparation of evaluations which will be submitted to KG&E to be used in the prepara-tion of a final report.
Findings and Corrective Actions The following pages include the Findings and Corrective Actions
~~as presented in the subject CAR. The detailed activities required s
to implement each Corrective Action are listed beneath the Corrective
n 4ons.
- . . ..,e , n= baring. syste:. fe, findings and corre::ive actions used in CAR-19 correspond directly with those used herein. Fesponsible key personnel are also provided.
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.- Finding 81:
"The? results of the Document Re:Onciliation Task Force indicated that 1509 of 6516 :'S SWR 's for Safety Related Structural Steel Welds are =tssing."
RESPONSIBILITY la) " Based on DIC program requireeents assure that all of the welders and welding procedures were qualified to AWS Di.1."
K. Hollinesworth la-1 DIC develop AWS 01.1 attribute Onecklist B. ::ewton and review welding procedure and welder qualification procedure against this check-list; i-clude documentation of procedure review cycle.
K. Hollinesworth la-2 DIC perform statistical sc=pling plan in B. Newton a: ordance with ::IL-STO-1053 to verif'/ quali-
.fications of welders appearing on randomly sele:ted MSSWR's.
G. Stanlev la-3 M. Pitre Bechtel -review and comment on DIC Welding ..
Procedure Specification and Walder Qualifica-tion Procedure as to compliance to At:S D1.1.
D. Mauldin la-4 Provide report su==ari:ing the results of the above.
Ib) " Review tne DIC program for the purchase and control of filler material to ensure that only acceptable filler caterial was used in safety related welds.
Assure that both safety related and non-safety related filler materials were properly controlled
- to preclude improper application."
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I K. Mellineswerth ib-1 DIC review precedures for the purenase and
. B. .aw en
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control of filler :nd rase raterials and prepare descriptien,justificatien.
G. Stanlev lb-2 Sechtel review procedures for the purchase and control of filler materials and cc=. ment.
D. Mauldin lb-3 Prepara su==ary report.
.10 ) " Evaluate the adequacy of the OIC inspection criteria and procedures to determine if these elements could have adversely impacted the inspection results.
Document and' provide this evaluation to KG&E CA for review prior to inspection implementation.
Any changes in inspection criteria and procedures shall be provided to KG&E CA for review prior to implacentation, t
( D. Mauldin J. Ayres le-1 Levelop AWS and site specification attribute checklist related to inspection requirements.
Review C inspection criterza and procedures in accordance with checklists.
J. Avres le-2.0 Document this etaluation.
J. Avres ic-2.1'Sur.ari:e results cf 1c-2.0 and provide results to KG&E QA.
J. Ayres ic-2.2 Centinue furtner actions as -a result of
. Ic-2.0 evaluations.
J. Avres lc-3.0 Discucs evaluation with KG&E QA.
- 3. Piedon ic-3.1 KG&E OA provide input / comment on evaluation T. itale ct.1 of le-3.0 to D:C.
J. Avres ic-4 Prepare chances / revisions as- necessary and.
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5 submit to KG&E QA for review.
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D. 'tsuldin le-5 Prepare summary repor: : ems 10-1 througn J . Ay r e s --- -
ic-4.
L. Pardi ld) "Obtain a documented evaluation to determine the validity of inspections performed with the presence of paint on the weld."
K. Hollineswerth id-l Obtain information from other utility /AE's
.B. Newton that have developed a validation plan. <
B. Newton id-2 DIC Welding Engineering and 3eental P.eview; G. Brow'.
add site specific requirements / justification as necessary and develop site position letter.
G. Stanlev ld-3 Submit letter to KG&E for review and approval.
D. Mauldin Id-4 Prepare summary report items .id-l through id-3.
le) "Utili:e personnel certified to A::SI :45.2.6 -
1978 for the inspection of safety related structural steel welds. Inspections shall be performed in accordance with the DIC Quality -Program and training shall be performed . and documented to assure that inspectors are' cognizant of the DIC Quality program requirements."
- 0. Mauldin le-1 Incorporate CAR-19 Inspection Verification Plan into DIC procedure-QCP-VII-200, "Inspec-tien of Welding Process."
- . G. ~;estheff le-2 Inspectio. personnel to be certified to J. Fletcher A!:SI ::45. 2. 6 -
1978 in accordance. - with DIC certification program based on education and experieneo levels,
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L. Easterwood J. Fletcher le-:- Site specific qual;ft:attens .::11 he li ::ed
. . :o the .e-inspeer'an of stru:: ural
. . steel welds in a Cordance .e::h the requirements of OCP-VII-2CC.
D. Mauldin le ; Prepare suc .ary report items le-1 through le-3.
If1 "Perfor. a 100% reinspect en of all structurally signidicant safety related structural steel welds.
ri The identification of "stru :urally significant" welds shall be made by the Archite : - Engineer."
G. Brown J. Fletcher if-l Identification of " structurally significant" t welds by the Architect - Engineer.
" Structurally significant" jcin:s are defined' as all field welded goints ;nien support or potentially support safety related equ p-cent and building components. This c' as:cally inc* des all field welds on s::::: ural and miscellaneous steel with the exceptien of handrail, toeplates, grating,
- hee:<e red plate, stairs, ladders and =enerail supports. .
These are non-Q items unien typ cally see signifi: ant servlee' leads daring the cens :ue-tion process. Some are designated as II.' ,
however, II/I seismic loads are :ensidered
. to be less severe than service loads. Mono-rails have coen load tested as part-cf startup procedures.
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The j:ints are sele::ed y Seentel based en a review of ere:::=n drauings prepared by the stru=tural and ascellaneous steel-fabricators.
L. Easterwood if-2 Ferform re-inspe::icns in ace rdance with \
J. Fletcher the CAR-19 Inspe:: ion Verification Plan.
Use the project nonconformance program to obtain and documen a suitability for service evaluation of inaccessible welds.
- all identified deficiencies on Report an NCR.
Bechtel will perform a case by case evaluation
! of each joint inspected to determine ift as-built condition meets design allowables.
- if the as-built conditi:n is a signi-
'ficant deficiency in accordan:e with 100FR50.55(e).
any rework is required.
D. Mauldin if-2.1 Su=mari:e data from if-1, if-2.
J. Fletcher V. McBride if-3.0 Colle : relative data from FOR's, CVR's, O. Armstrong
- 0R's for additional structural welds and furnish to Beental.
1 7. McBride if-3.1 Collect- information and furnish to Bechtel D. Armstrong for evaluation 'to determine if any additional structurally significant welds were made.
i Reinspect any additional welds as directed
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from Bechtel evaluation.
i D. *tauldin if-4 Prepare summary report on data from items l
i If-1, 1f-2, if-3.
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Findina $2: "An Inspe= tion verifi:ation effert of safety-related structural steel welding, under:axen y AUS =crtified
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welding inspe=ters identified se feral :reas Of defleiencies.
These deficiencies have been :ategori:ed below:"
Undersi:ed welds Weld defects
- Incorrect configuration Weld underrun Weld underent RESPONSIBILITY CORRECTIVE ACTIONS D. !!auldin 2a) " Determine and document the " root cause" of the J. Ayres previous acceptance of deficient structural welds.
Analyze the HVAC Support, Ilectrical Support, Pipe-Whip Restraint and any other safety-related program e
( utili:ing AWS - Dl.1 Welding to ensure that :he same
" root causes" inherent in the stru: ural steel welding program were not generic to other p cgrams."
D. Meuldin 2a-1 Review evaluations of DIC inspection program ..
J. Ayres as perforred in Ic. Determine if procedures could contribute to " root cause".
D. *tauldin 2a-2 Review inspection training and certification D. Garrett procedures to verify :enpliance to A?:S:
N45.2.6 - 1978.
D. a ul f in 2a-3 Analyze the deficiencies found in structurally J. Ayres significant safety related structural steel welds as documented in the CAR-19 Inspection verification Plan utili:ing the original f
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- S SWR , the Re-Inspection Data Sheets, and the Architect Engineer evaluation.
J. Avres 2a-4 Identif- , cil safety related a:tivities atil :-
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in? AWS :>t.1 weldinr.
J. Avres 2a-5 Review previously compiled information rela-tive to inspe:: ion and acceptan:e of HVAC and Electrical Supports, and Pipe Whip Res-traints and any other safety related progra=
utilizing AWS 01.1 . Examples of compiled information include Construction Self Assess-ment, task force reports, CA sudits and surveillances.
D. Mauldin 2a-6 Su=mari:e results of any previous investiga-J. Ayres tions/ reports relatad to welding / inspection of above items.
- D. Mauldin 2a-7 Analyze progra
- .matic elements j
utilized in J. Ayres
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- 6 *he erection / welding of structural steel and .WAC and Electrical Supports, Pipe
- hip l
Restraints and other items. Develop list of progra==a:1c differences and determine extent to which these differences would influence " root causes".
D. Mauldin 2a-3 Provide summary report items 2a-1 through
< 2a-7 Finding 93:
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"A small numoer of safety related structural steel welds were not made or had missing material."
RESPONSIBILITY CORRECTIVE ACTIONS 3a)
, " Forward the "as-built" information to the Architect /
k, Engineer via an ::CR ' to obtain an engineering evalua-tion and disposition."
.. taraer,:eed Ia-1 "issing welds er J. Fle :ner
.a c r :.1 de:e::ed in ..e instecti:ns perforced in if snail ne de:u-o mented on ;;0R ; s i snowing :..e "sa-tuil:"
informatien. These ::0Risi shall be given to tne AE for evaluation and disposition.
- 3. 311 zard 3a-2 Verification of incorporation of design F. Ray:ner changes.
- 3. Vauldin 3a-4 Prepare su:. mary report.
Finding #4 One (1) weld was documented as having been inspected when in reality the weld was no: made. (Ref. ZiCR IS::
lO495CU)
_g RESPONSIBILITY CORRECTIVE ACTIONS 4a) "*nvestigate the concern to determine the roo:
cause of the error. I==ediately notify XG&E. Quality Assurance if any other proble=s of 'this nature are identified. Document the investigative actions.
Che notification of KG&E CA shall not preclude the issuance of an ';CR."
- 3. Mauldin 4a-1 D. Armstrong Evaluate the results of the CAR-19 :nspection
- lerification Plan (i.e., those inspecti:ns performed in ~ ifI and determine whether s pattern of deficiencies is found.
- 2. Ar- st rene F. Rayener 4a-2 Identify further actions required if a pattern of deft:1encies is found.
- 3. "auldin 4a-3 Prepare su= ary report.
Pindine a5:
"Obje: ive eviden:e 'that the -eenan:. al and : :::: :21
~,. weldit.g '.inspectien/dheurentatien ::: lers identified in KO&E QA Surveillance Pe;c:: 3-2 2 vere rectified has not been provided."
RESPONSIBILITY CORRECTIVE ACTIONS San " Provide ob]ective evidence tha: the ee:nanical and stru:: ural support welding inspec::en/documenta-tion proble=s identified in Surveillance Reper:
S-372 have been corrected. If such evidence is not available, research the extent of the proolem and take the appropriate remedial actions."
D. Mauldin Sa-1 Review and provide ob ective evidence that Mechanical Oeficiency Reports identified in S-372 have been correctly closed out.
- 0. "auldin Sa-2 2eview and provide ch:ective evidence th::
C'vil Oeficiency Pepor:s . dentified in 3-27; have =een :orrectly-closed out.
D. Mauldin Sa-3 Prepare su==ary report.
RESPONSIBILITY _96 REPORT D. Mauldin A final comprenensive report includan? all evaluations performed and the results Of activ:::es condue ed te provide ooge::ive evidence to satisfy the corrective ac-ions re utred :y CAR-l? will be ;;epared and subnit:cd i
to KG&E Ouality. This report will also include an evalus-i : en of dens::::: en/Ouality prog:ses in areas otner f'
nan A'45 31.1 weldine o- detern:ne :he 'n::ential of programnatic deficiancias.
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t-i STRUCTURAL STEEL WELDING PRESENTATION KANSAS GAS AND ELECTRIC COMPANY WOLF CREEK GENERATING STATION FEBRUARY 27, 1985
~~
i o KG&E/NRC MEETING I
f AWS STRUCTURAL STEEL WELDING l
PHILLIPS BUILDING = BETHESDA, MARYLAND + FEBRUARY 27,1985
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! INTRODUCTION l
- NRC i
- KG&E - Gene Rathbun; Manager Licensing and Radiological
! Services l GENERAL DESIGN PHILOSOPHY James Ivany; Civil Engineering Supervisor, Bechtel l
l QUALITY ASSURANCE PROGRAM AND HISTORY OF CORRECTIVE ACTION REPORT NO.19 William Rudolph; Manager Quality Assurance (WCGS) j WELDING HISTORY AND MANAGEMENT PLAN
' John Berra; Vice President - Operations, Daniel International Corporation f ENGINEERING EVALUATION Jeriy Brown; Civil Engineering Group Leader, Bechtel l
t INDEPENDENT REVIEWS Glenn L. Koester; Vice President - Nuclear
- Roger Reedy; Professional Engineer, Reedy Associates'
- Dr. John Fisher Professor of Civil Engineering, Lehigh University l
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- Dr. Geoffrey Egan; President, APTECH
SUMMARY
Glenn L. Koester l
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- STRUCTURAL STEEL WELDING IS DONE TO .
l AWS D1.1 - 1975 ,
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- AWS IS NOT CODIFIED .
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- CODE APPLICATION BY OWNER -
l ARCHITECT / ENGINEER
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A KG&E SUBMil I ALS TO
! NRC CONCERNING AWS .
! STRUCTURAL STEEL WELDING l
l l 10CFR50.551:eD REPORTS l
- October 17,1984 -KMLNRC 84-187
- January 18, 1985 - KMLNRC 85-025 l FINAL REPORT
- December 31,1984 - KMLNRC 84-238 l
- January 21, 1985 - KMLNRC 85-037
! SUPPLEMENTAL INFORMATION
- February 14, 1985 - KMLNRC 85-054
- February 15, 1985 - KMLNRC 85-057 l
- February 18, 1985 - KMLNRC 85-058 l
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8 POWER BLOCK GENERAL ARRANGEMENT N DIESEL GEN. BLDG.
) CONTROL BLDG.
AUXILIARY BLDG.
STORA E N COMMUNICATION CORRIDOR BLDG. 7 -__--
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RADWASTE BLDG. j L _.p _ _ - _J MACHINE SHOP TURBINE BLDG.
FUEL BLDG._ .
REACTOR BLDG. TURBINE PEDESTAL 9
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6 EXTEROR CONCRETE WALL
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EMBEDDED PLATE q. --
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50K 60K 60K
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/ COLUMNS l
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INTERIOR CONCRETE WALL MAXIMUM BEAM REACTION s.
FLOOR PLAN " _
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l The design, fabrication, erection, and .
! inspection of welded connections in struc-tural steel for buildings are governed by the following standards:
- Structural Welding Code AWS D1.1, developed
! by the Structural Welding Committee of the l
American Welding Society CAWSD l
- Specification for the Design, Fabrication, and Erection of Structural Steel for Buildings, developed by the American Institute of Steel Construction (AISCD .
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L Allowable shear stresses for fillet welds
!, are set at 30 percent of the weld metal l
ultimate tensile strength, whereas the i ultimate shear strength is in the range of 65 to 75 percent of ultimate tensile strength. .
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E7018 WELD METAL
! 80- (MINIMUM)
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ASTM A36 BASE MATERIAL i
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i STRAIN (IU/in)
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l Allowable stresses are specified at a level '
l below ultimate capacity for several l reasons, including the following:
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- Load Definition i
- Variations in Materials and Construction 1
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SUMMARY
BASIC DESIGN MARGINS l STRUCTURAL STEEL '
WELDED CONNECTIONS .
- CONSERVATIVE CODE ALLOWABLES l
a CONSERVATIVE DEFINITION OF LOADS .
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- CONSERVATIVE USE OF MINIMUM MATERIAL STRENGTHS -
- MINIMlZED VARIATIONS IN MATERIALS AND
! CONSTRUCTION 4
PLUS
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- CONSERVATIVE ENVELOPING OF MULTISITE
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- CONSERVATIVE DESIGN METHODOLOGY CONSEQUENCE CONSIDERATIONS l
- EQUALS LARGE FACTORS OF SAFETY AGAINST FAILURE I
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KGGE O.UALITY ASSURANCE PROGRAM OVERVIEW 10 CFR 50, APPENDIX B KGBE QUALITY ASSURANCE PROGRAM FOR DESIGN AND CONSTRUCTION INDEPENDENT AUDIT / SURVEILLANCE PROGRAM
- IDENTIFICATION, CONTROL, AND RESOLUTION i
OF HARDWARE AND PROGRAMMATIC DEVIATIONS CORRECTIVE ACTION PROGRAM ,
- NONCONFORMANCE REPORTS
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- CORRECTIVE ACTION REQUESTS / REPORTS
- OTHER CORRECTIVE ACTION VEHICLES
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AWS D1.1 STRUCTURAL STEEL WELDING
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CONCERNS BACKGROUND INFORMATION ' '
DIC CORRECTIVE ACTION REPORTS
- WELD DEVIATIONS J#Efhepsy,p
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- RECORD RETRIEVABILITY d 5- M e / #/
l< s /' A /f f h -f fy p g ,
~ 5 6 f L d'9 S f.s NRC TASK FORCE 4, ### 3/ .(Xf".#
CONCERNS WITH DiC CAR RESOLUTION l
KG&E RE-EVALUATION OF DIC CAR RESOLUTION -
ADDITIONAL x NRC INPUTS
- DOCUMENT RECONCILIATION e
-
- LIMITED WELD RE-INSPECTIONS POTENTIAL 50.55(e) l i KGBE QA~ CORRECTIVE ACTION REQUEST NO.19 KG&E CAR NO.19 MANAGEMENT ACTION PLAN
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KG&E QA CORRECTIVE ACTION REQUEST NO.19 PROGRAM OBJECTIVES
- DOCUMENT A CONSOLIDATED PROJECT PLAN
- ASSURE BY OBJECTIVE EVIDENCE THAT l AWS D1.1 SAFETY-RELATED STRUCTURAL STEEL WELDING COMPLIES WITH ALL QUALITY CRITERIA
- ASSURE THAT INSPECTION DOCUMENTATION '
REFLECTS APPROPRIATE INFORMATION AND IS:
- AVAILABLE
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- COMPLETE
- TRACEABLE
- EVALUATE OTHER AWS D1.1 SAFETY-RELATED
! WELDING ACTIVITIES l
i KG&E QA CORRECTIVE .
ACTION REQUEST NO.19 FINDINGS - OVERVIEW
- MISSING WELD RECORD DOCUMENTATION .
- WELD DEVIATIONS I
- WELDS NOT MADE/ MISSING MATERIAL
- PRESENCE OF WELD INSPECTION DOCUMEN-TATION WITHOUT PRESENCE OF WELD l
- VERIFICATION OF COMPLETED CORRECTIVE ACTION TO KG&E SURVEILLANCE REPORT S-372 l .
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0 KG&E CAR NO.19 MANAGEMENT ACTION PLAN .
QA VERIFICATION PROCESS ,
- TWO EXPERIENCED QA AUDITORS ASSIGNED ON A FULL-TIME BASIS
- IN-PROCESS SURVEILLANCES WERE PERFORMED I
- A THOROUGH AUDIT OF EACH CORRECTIVE ACTION STEP WAS PERFORMED
- RESULTS OF THE AUDIT AND SURVEILLANCES:
- CAR No.19 Management Action Plan was Effective .
- CAR No.19 Findings were Satisfactorily Resolved i
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KG&E QA CORRECTIVE ACTION REQUEST NO.19 I
SUMMARY
- KG&E Q.A CAR 19 RECOMMENDED CORRECTIVE ACTIONS - READILY ADOPTED
- KG&E MANAGEMENT ACTION PLAN - EXCEEDED
- CAR 19 RECOMMENDATIONS THUS PROVIDING A MORE COMPREHENSIVE TREATMENT OF AWS D1.1 WELDING CONCERNS l
- RE-INSPECTION OF VIRTUALLY ALL SIGNIFICANT SAFETY-RELATED STRUCTURAL STEEL WELDING -
- WITH AND WITHOUT RECORDS l
- EVALUATION OF OTHER AWS D1.1 SAFETY-RELATED WELDING PROGRAMS
~
i l
- EVALUATION OF OTHER SAFETY-RELATED -
l PROGRAMS BEYOND AWS D1.1
fi ilh!
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SUMMRY OF STRUCTIRAL STEEL ERECTIOff BUILDilI6 1977 1978 1979 1980 1981 1982 1983 19881
~
AWXILIARY C o a llEAETOR c: o a CollTRE C C ^
E.S.W.S. I: o a FUEL [] o a DIESEL GEN. O O a a Est. STAnt DATE O Est. Cone. DATE L\ Busi.nins TuamovEn DATE
9
\
l l
AWS D.1.1 - 75 !
- DESIGN OF WELDED CONNECTIONS WORKMANSHIP
- FILLER METAL REQUIREMENTS
- WELD PROCEDURE QUALI FICATION
- WELDER ,
QUALIFICATIONS INSPECTION
- f. A'22 ,
, --n-- , - -m-,----,,--.n e.w,---n - . .,- - ,
V SC EL _ A sl EOUS S"RUCTURAL l STEE_ W ELD R ECO RDS l 1
MSSWR l u
l I l
- DRAWING NUMBER
- JOINT NUMBER AREA / LOCATION
- BASE MATERIAL PIECE OR HEAT NUMBER ~
- ROD WITH DRAWAL DATA l
i o FILLER MATERIAL HEAT NUMBER / l LOT NUMBER i
o WELD PROCEDURE I
- WELDER IDENTIFICATION NUMBER
- QUALITY INSPECTOR 6
~
l 1
WELD Al i RIBUTES TO BE -
i INSPECTED PER AWS D1.1-75
- PRESENCE
- FUSION j
- LOCATION
- PROFILE
- - LENGTH
- OVERLAP
- SIZE
- POROSITY
- UNDERCUT
- ARC STRIKES
- CRACKS
- SLAG.
l
- CRATERS
- SPATTER '
l .
t
J .
WELDING HISTORY
SUMMARY
l
!
- ERECTION / WELDING PERFORMED IN 1977-1981 ,
I
- WELDING PROGRAM WAS IN ACCORDANCE
~
WITH AWS D.1.1-1975 l
i '
l I
l
CAR 19 MANAGEMENT PLAN PROGRAMMATIC REVIEW
- WELDERS O.UALIFIED IN ACCORDANCE WITH l
AWS D.1.1-75 l
- WELDING PROCEDURES IN ACCORDANCE WITH AWS D.1.1-75 i
l
- FILLER MATERIAL PURCHASE AND CONTROL IN l ACCORDANCE WITH AWS D.1.1-75 I
- INSPECTION CRITERIA COMPLIED WITH AWS D.1.1-75
- INSPECTORS CERTIFIED TO ANSI 45.2.6
- DOCUMENTATION IN ACCORDANCE WITH AWS l
D.1.1 AND ANSI 45.2 l
- KG&E SURVEILLANCE REPORT S-372 CLOSURE VERIFICATION
CAR 19 MANAGEMENT PLAN .
WELDING HARDWARE REVIEW
- DEVELOPMENT OF SECONDARY INSPECTION l PROCEDURES L
- CERTIFICATION OF INSPECTORS
- IDENTIFICATION OF STRUCTURALLY SIGNIFI-f l CANT JOINTS BY ENGINEER l
- VALIDITY OF INSPECTION IN PRESENCE OF
!' PAINT
- FIREPROOFING REMOVAL j '
l
- INSPECTION OF STRUCTURALLY SIGNIFICANT JOINTS l
I
- _ _ _ _ _ _ _ 1 . - . _ . - - .. _?_-_-___-_
CAR 19 MANAGEMENT PLAN -
WELDING ~ HARDWARE REVIEW (Continued)
- INVESTIGATION OF MISSING WELDS WITH i l PRIMARY RECORDS i
- DOCUMENTING CONSTRUCTED CONFIGURATION l OF JOINTS l
- EVALUATION OF CONSTRUCTED CONFIGURA-l TION BY THE ENGINEER
- REWORKING JOINTS l
- ISSUANCE OF
SUMMARY
REPORT -
1 i
r 1r in 45
/ b" l b l',
G,a "
/ ,.,. , / .
C -
2 tw (MIN.) '
tw ~
~
tw ~
1" (M AX.)
ACCEPTABLE RETURN WELD ACCEPTABLE PROFILES
/ ~
f/
a ,. , + ____
,,,__.,s 2 tw (MIN.) _tw_ ~
1" (M AX.)
OVERRUN UNDERSIZE 4
/
gr/ __
tw = ReouiRED WELD tee 7 2 t w ( M I N.)
l 1" (M AX.)
UNDERRUN l
l
! CAR 19 MANAGEMENT PLAN CONCLUSIONS i
- PRESENCE OF WELD INSPECTION DOCUMENTA-f l
TION-WITHOUT PRESENCE OF WELDING WAS '
! CAUSED BY HUMAN ERROR
\
l
- WELD RECORD RETRIEVABILITY PROBLEMS DID NOT CARRY OVER TO OTHER PROGRAMS j
- WELDING PROGRAM IS IN ACCORDANCE WITH l AWS D.1.1-75 f
- ALL QUALITY CRITERIA AS SPECIFIED IN THE RELATED DESIGN DOCUMENTS ARE MET l
l
- ALL STRUCTURAL STEEL ERECTION COMMIT-MENTS IN THE WOLF CREEK FSAR ARE ll SATISFIED l
i
, 6; Structurally significant AWS field welded joints are joints which: -
- 1) support or potentially support safety-related
- equipment and building components,
- 2) are located in the Reactor Building, Auxiliary Building, Control Building, Diesel Generator Building, Fuel Building, or Essential Service
- Water System Pumphouse, l 3D were installed under the structural steel l
erection contract (Bechtel Specification l 10466-C122) or the miscellaneous steel erection contract (Bechtel Specification 10466-C132?, and f 43 were originally inspected under the Daniel l
International Corporation (DICD." Miscellaneous /
l Structural Steel Weld Records" CMSSWR) i inspection Program.
4
b i
WELD Al iRIBUTES TO BE INSPECTED PER AWS D1.1-75 l
l
- PRESENCE
- FUSION
- LOCATION
- PROFILE i
- LENGTH + OVERLAP
- SIZE
- POROSITY
'* UNDERCUT
- ARC STRIKES
- ~
1
'* CRACKS
- SLAG
- CRATERS
- SPATTER -
l l -
_ _ , . . _ . . _ . . ,...__m . _ .
I >
l REINSPECTION DATA AWS STRUCTURAL STEEL .
WELDING AT WOLF CREEK Structurally Significant Joints 2,670 Totally inaccessible Joints 119 2,551 Reinspected Joints 1,043
) Unpainted Joints I Joints Requiring Rework"' 82 67 l Additional Joints Reworked ..c , - :
n>
i 0 l
Significantly Deficient Joints (10CFR50.55(eD 1
(1) DESIGN ALLOWABLE STRESSES ARE EXCEEDED IN THE AS-BUILT CONDITIO f (2) DESIGN ALLOWABLE STRESSES ARE NOT EXCEEDED IN THE AS-BUILT' l THESE JOINTS ARE BEING REWORKED PER KGBE MANAGEMENT DIRECTION T l INSTALL MISSING AND UNDERLENGTH WELDS UNLESS PROHIBITED BY FIELD CONDITIONS.
ie I
\ l} ,' . . -;g '. A4 ' _-)
, Volcos cf meccured 1sg c100 af fillot l, weld from "AWS-A15C Fi!!ct Weld Study"
- l ) for the American Institute of Steet r
Construction tested by Testing Engineers, bi..d. cA, n., n 1,
. 60 & 1 - .,
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i es
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- #f g E7ML '4e' .bd M k-rs '
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.b' .b4' .bs' 'se' .ed 'sa' 'st 'ss' .'ed .'7c'
!7d l .'4/ .'4s' J
.aa' 54 'as' he' ha' .'sa' .'d 5s' he
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.n..s.r.4 5.. sin. t rit1.c v.14 (v) .
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-. . ~ .. _-_
-
- l FICURE D n = 432 ,
1 E = 1.191 1/4' s = .124 weld I a x = .02 n = 336 30 -
I = 1.143
- *** 3/8" 28 A x = .02 weld 26
- h 24 - - .
a = 288 l n 22 I = 1.053
- - s = .134 1/2"
$ { 20 A x = .02 veld I
.n 3, ,.
EEa 16 --
o 14 !
lhj 12 IUl10 8
6 4
2 -
9't53'
.73 '.7 7 '.81 '.8 5 '.8 9 '.9 3 '.97 ' 101' 105' 109'1.13 ' t17 '121 '125'129' ratio W actual W desired FIGURE E Ch. Eng. of Caterpillar Tractor Co. ;
Correspondence from Mr. W. C. Cadwell, Asst.
Peoria, IL Dec. 22, 1964 -
of 925 fillet welds checked from 1/8" to 1/2" 7 From this datat 688 (74.4%) from nominal (1.0) to 25% oversize (1.25) 15.2% corresponds to
. 96 (10.4%) exceeded 25% oversize (1.25) 1.02 141 (15.2%) under nominal, size (1.0) 10.4% corresponds to n = 925 I*
i = 1.112 -
i ' s = .109 *2 *o*=~_I = - 2.028s 70 . - .
ax= .02 ,
- a 60 . - (1.0285) (1.2595) '2=I
- h5
's 1.25 = i + 1.259s
"' "l' 50 . -
a h[
From this we get I. compare this g 5 = 1.11
/ \ s = .10 with AISC data ,
h
- 30 - -
I s s. .
c1
~ ~
15.2%
\ 10.4%
above .25 l
below nominal ,'p' %,% oversise ;
10 . -
size p *2% -
N i
- *1
- 85 ' 89
- 9 3 '.9 7 '1,01'1.05'tO9't13 '1.17 '121'12 5'129' 1.33'1.37'1.41'1 A5'
.73'.77'.81 .
ratio [WactualT .
7 (W desired / i
. . I 1
. _ _ _ , . _ . _ _ . _ . _ _ . _ _ _ _ . . _ _ , _ . . . _ .l
t O
1.00-t W :- .
- Q -
Y:,
O O.80 - .
e t- f
, 1-H s :f-o ~
Q ;
x y '-
H w O.60 -
w a w
e -
Di 3 m O
$ 6 OAO -
r M sm ALLOWABLE SHEAR STRESS ,
w J
W O.20 -
Z .
w H
. i i
O '
A441 A514 BASE METAL: A36 E110 E60 E70 E70 ELECTRODE:
SHEAR STRENGTH OF LONGITUDINAL FILLET WELDS WITH MATCHED BASE MATERIAL 9
I
- 1. 6 - '
i A g
/
. 1.4 - A
^ f 6 ~
A A' ,
A A
w A e Q
O 1.2 - A e a A A h
U -
^ g A ^
I $ A $ i F W 1.0 M O
z b.
W O -
e H
m 1 p
g e .80-
< Z w W .
I $
. m m g .60- -
- _a m .
z w '
! " 40.
- 1/4 SPECIMENS A- EAST COAST l
A-WEST COAST ,
.20 -
i .
l l 0 , , , , ,
E70 E70 E90 E70 E90 E110 ELECTRODE:
A36 A441 A514 BASE METAL:
l SHEAR STRENGTH OF TRANSVERSE FILLET WELDS WITH MATCHED BASE METAL
__m. _ _ .
o
~
WELDS SUBJECTED TO BENDING AND SHEAR (COURTESY CIVIL ENGINEERING
- AND PUBLIC WORKS REVIEW)
'a . g -
n h . g = g/,8 + fl - A ! ij lIL i
j
. - e = g/,' + 0.21." -*
i i 150 -
Resultant - -
i stress at *
, ultimate. A Go g A. A. .
- 100 -
- f -
- a*
- / .
L'
& A .,
g ,.
I 8*s **: .
.t . .g 50 48 . ,, ,,
[
f
! i i i i 0 2.0 2.5
! 0 0.5 1.0 1.5 k '
l .
f
, n = 133 .
gru)m = 0.84 20 crru = 0.09 l
FREQUENCY '
10 - .
~
I mL.
o.s o.8 1.o l' FILLET WELD ru WELD ELECTRODE Fu .
- i :
4 i
OBJECTIVE
- TO INDEPENDENTLY EVALUATE KG&E's i APPROACH TO THE RESOLUTION OF CORRECTIVE ,
ACTION REQUEST (CAR? NUMBER 19 AND MAKE
- RECOMMENDATIONS FOR A TIMELY CLOSEOUT l OF CAR 19
.l l
l
$i l- =
l .
~ ACTIVITIES
- 1) FINAL REPORT REVIEW (KG&E REPORTD 2D SITE VISIT (; FEBRUARY 15-17?
3? REVIEW OF SUPPORTING DOCUMENTS
- Weld Procedures
- Filler Metal
- DiC Inspection Criteria 4 .
l
- Reinspection Validation (; Painted?
- 4) WELD INSPECTION OF PAINTED dND UNPAINTED WELDS IN THE AUXILIARY AND REACTOR BUILDINGS SD DISCUSSIONS WITH KG&E, DIC, AND BECHTEL -
PERSONNEL ~
6D PREPARATION OF REPORT l
. =
l
1 RESULTS -
- RELATED WELDING ACTIVITIES ARE SOUND AND DOCUMENTED
- REINSPECTION PROGRAM HAS BEEN EXTENSIVE, PROPERLY PERFORMED, AND DOCUMENTED
- VALIDATION OF INSPECTION WITH PAINT HAS BEEN COMPLETED
- IMPERFECTIONS NOTED IN REINSPECTION ARE TYPICAL FOR C/Mn STRUCTURAL WELDING
- NO SAFETY SIGNIFICANCE OF THE IMPERFEC-TIONS -
i -
o CONCLUSIONS
!
- REINSPECTION PROGRAM IS SO.UND AND EFFEC-TIVE, AND ENSURES AWS D1.1 QUALITY WELDS l .
- IMPERFECTIONS ARE MINOR AND STRUCTURAL i INTEGRITY IS ASSURED ., ,
l l
i-
~
SUMMARY
BY GLENN L. K0 ESTER -
2/27/85 KGaE HAS ALWAYS HAD, AND CONTINUES TO HAVE A FIRM 6
COMMITMENT TO PROTECT THE HEALTH AND SAFETY OF THE PUBLIC AS WELL AS OUR OWN EMPLOYEES. THAT IS WHY WE UNDERTOOK SU H AN EXTENSIVE PROGRAM TO EVALUATE THE ACCEPTABILITY OF THE STRUCTURAL STEEL WELDING AT WOLF CREEK. AS YOU HEARD EARLIER, OUR REINSPECTION EFFORTS FOUND SEVERAL MINOR DEVIATIONS THAT GAVE THE APPEARANCE OF A HIGHER THAN EXPECTED REJECT RATE.
HOWEVER, THE PRIMARY REASON FOR THESE REJECTS RESULTED FROM THE "N0 TOLERANCE" INSPECTION PHILOSOPHY DISCUSSED BY MR. REEDY.
THE VAST MAJORITY OF THESE DEVIATIONS WOULD NOT BE REJECTED BY A s
QUALIFIED AWS INSPECTOR AT ANOTHER FACILITY UNLESS THEY WERE MAKING THE SAME TYPE SECONDARY INSPECTION THAT WE MADE. THE FACT THAT KG&E TOOK A MORE CONSERVATIVE APPROACH DURING THE REINSPECTION EFFORTS DOES NOT IN ANY WAY INVALIDATE THE INITIAL WELD INSPECTIONS. ,
l l
4 AS DISCUSSED EARLIER, THE REINSPECTIONS DID IDENTIFY A FEW JOINTS IN WHICH SOME WELDS HAD NOT BEEN MADE. THESE PRIMARILY ni RESULTED FROM A MISINTERPRETATION OF THE WELD DETAIL AND NOT
- FROM GROSS INADEQUACIES IN THE INSPECTION PROGRAM. white WE STRIVE FOR PERFECTION, WE MUST RECOGNIZE THAT HUMAN ERRORS CAN AND DO OCCUR. THAT IS ONE REASON WHY WE DESIGN AND BUILD THESE PLANTS WITH SO MUCH CONSERVATISM. THIS IS DEMONSTRATED BY THE FACT THAT NONE OF THE JOINTS WITH MISSING WELDS WOULD HAVE FAILED. A POINT THAT NEEDS TO BE EMPHASIZED IS THAT WE MEAN IT WOULD NOT HAVE FAILED UNDER THE WORST POSTULATED LOADING CONDITIONS. THIS WOULD INCLUDE NORMAL LOADING PLUS ANY LOADS RESULTING FROM A POSTULATED WORST CASE ACCIDENT.
i OUR PRIMARY OBJECTIVE IN THE OVERALL CORRECTIVE ACTION PROGRAM DISCUSSED EARLIER WAS TO ASSURE THAT WOLF CREEK IS STRUCTURALLY SOUND AND WILL NOT FAIL UNDER THE WORST POSTULATED ACCIDENT CONDITIONS.
WE HAVE'DONE THAT.
1 l
IN DOING SO, WE ALSO REAFFIRMED THAT THE AWS WELDING WAS DONE IN ACCORDANCE WITH THE APPLICABLE CODES.
6+
WE DID NOT LIMIT OUR REVIEW OF THIS MATTER TO WELDING ALONE. WE ALSO LOOKED AT OTHER AREAS TO ASSURE THEY WERE l
COMPLETED IN ACCORDANCE WITH APPLICABLE REQUIREMENTS AND IN A MANNER THAT PROVIDES ADEQUATE PROTECTION OF THE HEALTH AND SAFETY OF THE PUBLIC, WE ALSO HAD THREE OF THE LEADING AUTHORITIES IN STRUCTURAL i
STEEL WELDING INDEPENDENTLY REVIEW OUR PROGRAM TO ASSURE THAT WE WERE NOT TAKING A BIASED LOOK AT OURSELVES. AS YOU HEARD FROM THEIR DISCUSSIONS TODAY, FROM THEIR REVIEW OF THE VARIOUS ASPECTS OF OUR PROGRAM, WE DID A VERY THOROUGH, CONSERVATIVE, ASSESSMENT OF OUR AWS WELDING PROGRAM AND THEY FOUND NOTHING TO l l
QUESTION OR INVALIDATE THE CONCLUSIONS WE HAVE MADE.
i I SINCERELY BELIEVE THAT ANYONE KNOWLEDGEABLE IN ENGINEERING AND CONSTRUCTION PRACTICES WOULD HAVE TO' AGREE THAT KGaE'S CORRECTIVE ACTION PROGRAM VERIFIED THAT THE STRUCTURAL STEEL AT WOLF CREEK GENERATING STATION IS SAFE AND SOUND.
1 j
THIS COMPLETES OUR PRESENTATION ON AWS STRUCTURAL STEEL WELDING AT WOLF CREEK. WE FIRMLY BELIEVE THE RECORD IS CLEAR AND WJ ARE READY TO RECEIVE OUR OPERATING LICENSE AND COMMENCE LOADING FUEL AND PROCEED THROUGH POWER ASCENSION.
4 l
4 4
-4 . .. .
_ --r.. . _ . . . _ _ , _
i MANAGEMENT PLAN OVERVIEW
. Verify hardware & programatic aspects of safety related activities utilizing AWS Dl.1 welding are in conformance with the FSAR
. Implement in strict accordance with CAR 19 c
. Numbering system utilized in the plan
.q Example: 1. - Finding Nu @ r in CAR la. - Recommended corrective action in CAR la Actions planned in management plan We e
l
6 FINDING #1 - MISSING MSSWR'S ACTIONS
- a. Verify welders & procedures qualified to AWS Dl.1-75 8
- b. Verify pu & control of filler & base material was acceptable Verify inspection criteria and procedures did not adversely impact
~
c.
inspection results
- 73. Document validity of inspection for CAR 19 attributes with the presence of paint on welds
- e. Utilize personnel certified to ANSI N45.2.6 - 1978 for the CAR 19 inspection verification plan
- f. Perform a 100% reinspection of structurally significant welds with missing records
- g. Obtain and document a suitability for service evaluation of inaccessable welds
- h. Initiate an PCR for all identified deficiencies FINDING #2 - INSPECTION VERIFICATION PLAN HAS IDENTIFIED SEVERAL AREAS OF DEFICIENCIES ACTIONS
- a. Determine " Root Cause" of previous acceptance of deficient structural welds and analyze other AWS programs to determine if " Root Cause" was generic to those programs.
- b. Perform a 100% reinspectior of structurally significant welds having MSSWR's
- c. Evaluate the results of the completed Inspection Verification Plan l against the acceptance criteria i l
- d. Initiate the ICR for all identified deficiencies l 1
J
?
FINDING # 3 - MISSING MATERIAL AND WEEDS
- a. A/E perform "As Built" engineering evaluation and disposition
- b. Verify the incorporation of design changes
- c. Evaluate for Root Cause determination FINDING # 4 - MISSING WEID(s) WITH EXISTING DOCUMElfrATION
- a. Investigate to determine " Root Cause"
- Evaluate CAR 19 inspection verification plan results for patterns
- Identify further actions as required FINDING #5 - OBJECTIVE EVIDENCE THAT MEDENICAL AND STRUCTURAL WELDING /t0CUMENTATION IN KG&E QA S SURVEILLANGE REPORT S-372 HAS NOT BEEN PROVIDED
- a. Provide objective evidence for:
- Civil deficiency reports in S-372
- Meenanical deficiency reports in S-372
. -C*/vj 6
MAR 181985 MEETING
SUMMARY
DISTRIBUTION Docket File NRC Participants NRC PDR L PDR L. Martin, RIV NSIC R. Denise, RIV PRC System F. Miraglia LB#1 Reading File T. Novak Project Manager P. O'Connor B. J. Youngblood M. Rushbrook S. Diab Attorney, OELD P. O'Connor R. Hartfield*
OPA*
OTHERS bec: Applicant & Service List l
- Caseload Forecast Panel Visits y g p,, (;)uL
j#' *%o UNITED STATES
- e- /t NUCLEAR REGULATORY COMMISSION j
3., ., '
- e WMHINGTON, D. C. 20555 s *****
/
g ,, 1 g 1985 Docket No.: STN 50-482 APPLICANT: Kansas Gas and Electric Company (KG&E)
FACILITY: Wolf Creek Generating Station
SUBJECT:
SUMMARY
OF MEETING WITH KANSAS GAS & ELECTRIC COMPANY REGARDING THE SCHEDULE FOR COMPLETION FOR WOLF CREEK GENERATING STATION On November 28, 1984, a meeting was held with Kansas Gas and Electric Company (KG&E) to discuss issues related to the status of completion and future schedule for licensino of Wolf Creek Generating Station.
KG&E described recent organizational changes that have t'een implemented at Wolf Creek and introduced Chuck Mason the new Director of Nuclear Operations. KG&E emphasized that the plant is moving from a construction related operation into a preparation for operation mode under Mr. Mason who previously served as Plant Superintendent at Sequoyah.
KG&E stated that their current date of construction complete is December 31, 1984 and that the date is based on a no contingency, optimistic schedule.
They stated that the integrated leak rate test and structural integrity test were the major items on their critical path. They also stated that they were planning for a 50 day schedule between fuel load and initial criticality. -
T. Novak, Assistant Director for Licensing, NRR, stated that we would not issue a license before completion of all construction and we did not plan to issue a " fuel load only" license.
KG&E presented a detailed description of their plan to reinspect 100% of the accessible structural steel welds and provided a status report of the work that had been completed.
KG&E described a failure of the pressurizer power operated relief valves to close during a test and proposed a modification to correct the non-closure.
_ , m aa-
-?- h4. . 1955 Forest Rhodes, KGAE, described the results of leak rate testing on ECCS check' valves test results for some valves did not meet the acceptance criteria civen in FSAR Section 14.P.1.38. KGAE committed to document the results and submit a proposed resolution to NRC for approval.
Forest Rhodes described the KGAE proposed power ascension test program for the NRC staff.
Enclosure I lists the meeting attendees and Enclosure ? presents the visual aids used bv KGAE at this meeting.
Paul W. O'Connor, Project Manager Licensing Branch No. 1 Division of Licensing
Enclosures:
As stated cc: See next page i
)
h l
WOLF CREEK EP 1 r 1%5 Mr. Glenn L. Koester Vice President - Nuclear Kansas Gas and Electric Company 201 North Market Street Post Office Box 208 Wichita, Kansas 67201 cc: Mr. Nicholas A. Petrick Ms. Wanda Christy Executive Director, SNUPPS 515 N. 1st Street 5 Choke Cherry Road Burlington, Kansas Rockville, Maryland 20850 C. Edward Peterson, Esq.
Jay Silberg, Esq. Legal Division Shaw, Pittman, Potts & Trowbridge Kansas Corporation Comission 1800 M Street, N. W. State Office Building, Fourth Floor Washington, D. C. 20036 Topeka, Kansas 66612 Mr. Donald T. McPhee John M. Simpson, Esq.
Vice President - Production Attorney for Intervenors Kansas City Power & Light Company 4350 Johnson Drive, Suite 120 l 1330 Baltimore Avenue Shawnee Mission, Kansas 66205 Kansas City, Missouri 6a141 Regional Administrator Ms. Mary Ellen Salava U. S. NRC, Region IV Route 1, Box 56 611 Ryan Plaza Burlington, Kansas 66839 Suite 1000 Arlington, Texas 76011 A. Scott Cauger Assistant General Counsel Mr. Joe Mulholland Public Service Commission Manager of Power Supply & Engineering P. O. Box 360 Kansas Electric Power Cooperative, Inc.
Jefferson City, Missouri 65101 Post Office Box 4877 Gage Center Station Mr. Howard Bundy Topeka, Kansas 66604 Resident Inspector / Wolf Creek NPS c/o U.S.N.R.C Regional Administrator Post Office Box 311 U.S.N.R.C. - Region III Burlington, Kansas 66839 799 Roosevelt Road Mr. Robert M. Fillmore State Corporation Commission Brian P. Cassidy, Regional Counsel State of Kansas Federal Emergency Management Agency Fourth Floor, State Office Bldg. Region I Topeka, Kansas 66612 J. W. McComack POCH Boston, Massachusetts 02109
YAR 181985 WOLF CREEK 4 cc: Terri Sculley, Director Special Projects Division Kansas Corporation Commission State Office Building, Fourth Floor Topeka, Kansas 66612 Mr. Gerald Allen 4
Public Health Physicist 4
Bureau of Air Quality & Radit tion Control
. Division of Environment i Kansas Dept. of Health & Environment Forbes Field Bidg. 321 Topeka, Kansas. 66620 i
e i
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j
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ENCLOSURE 1 KANSAS GAS & ELECTRIC COMPANY MEETING HELD ON NOVEMBER 28, 1984 r
Name Organization l
C. Mason KG8E J. Bailey KG8E F. Rhodes KG8E
- 0. Maynard KG&E
, J. Berra KG8E W. Rudolph KG&E D. Ridgeway KG8E G. Rathbun KGSE G. Koester KG&E S. Shaw Westfoghouse W. Guerin Westinghouse J. McInerney Westinghouse M. Lacey Westinghouse J. Irons Westinghouse i G. Brown Rechtel N. Goel Bechtel J. Palermo KCP&L F. Crawford KCP&L M. Fletcher SNUPPS L. Martin NRC/ Region IV R. Denise NRC/Reginn IV F. Miraglia NRC/DD/DL T. Novak NRC/AD/L/DL P. O'Connor NRC/DL/LRAI B. J. Youngblood NRC/DL/LB#1
- S. Diab NRC/NRR/RSB t
i n
ENCLOSURf. 2 AGENDA for November 28, ]984 Meeting (KG&E, NRR, & Region IV)
I. Introduction (Otto Maynard)
II. Recent Organization Changes (Glenn Koester) .
III. Current Schedule (Chuck Mason)
IV.* AWS Welding (Bill Rudolph, John Berra)
V. PORVs (John Bailey)
VI. ECCS Check Valves (Forrest Rhodes)
VII. Power Ascention Test Reviews (Forrest Rhodes)
l I
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EEEE Oh COI5tHCTIVE ACTIN MM) DEST $19 PROGRAM OEDICTIVES
. DOCIMENT A COBE90LIDfLTED PRGHCf PIAN ASEMtE BY GLTECTIVE EVIDENCE,1HkT ABS Dl.1 SAFETY RE[ATED STRDCTURAL STEEL M[ DING CGPLIES WITH ALL QUALITY CRITERIA.
. ASSURE THAT INSPECTION D00CMENTATION IS:
AVAIIABLE CXMPE2TE REFLECTS APPROPRIATE INFORATION TRACEABLE
. EVAURTE O!HER ADE Dl.1 SAFETY REIATED NELDING ACWITIES.
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EGEE Oh COIIIIIICTIVE ACTION RI! QUEST $19 FDDIMIS - OVERVIIBf 3
. MISSIldG NElim em DOCIMENTATION
. MED DEFICIBICIES
. WYM NOT MhDE/ MISSING MATERIAL
. PRESENCE W NEED IIEPETION DOC [ MENTATION WITHOUT PRESENT OF MED (1 IMITAICE NDTED)
. VERIFICATI(Bi 0F (IMPIETED CORRE!CTIVE ACTION 10 KG&E SDRVEIILANCE REPORT S-372 I
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11/27/84 FINDING fil - MISSING MSSWR'S ACTIONS C a. Verify welders and procedures qualified to AWS D1.1-75.
C b. Verify purchase and control of filler and base material was acceptable.
C c. Verify inspection criteria and procedures did not adversely impact inspection results.
C d. Document validity of inspection for CAR 19 attributes with the presence of paint on welds.
C e. Utilize personnel certified to ANSI N45.2.6 - 1976 for the CAR 19 inspection verification plan.
- f. Perform a 100% reinspection of structurally significant welds with missing records.
- g. Obtain and document a suitability for service evaluation of inaccessible welds.
- h. Initiate an NCR for all' identified deficiencies.
FINDING f:2 - INSPECTION VERIFICATION PLAN HAS IDENTIFIED SEVEFAL AREAS 0F DEFICIENCIES
- a. Determine " Root Cause" of previous acceptance of deficient structural welds and analyze other AWS programs to determine if
" Root Cause" was generic to those programs.
- b. Perform a 100% reinspection of structurally significant welds having MSSWR's.
- c. Evaluate the results of the completed Inspection Verification Plan against the acceptance criteria.
- d. Initiate the NCR for all identified deficiencies.
- e
11/27/84 FINDING #3 - MISSING MATERIAL AND WELDS
- a. A/E perform "As Built" engineering evaluation and disposition.
C b. Verify the incorporation of design changes.
- c. Evaluate for Root Cause determination.
FINDING #4 - MISSING WELD (S) WITH EXISTING DOCUr!ENTATION
- a. Investigate to determine " Root Cause".
-Evaluate CAR 19 inspection verification plan results for patterns.
-Identify further actions as required.
FINDING AS - OBJECTIVE EVIDENCE THAT MECHANICAL AND STRUCTURAL WELDIhG/DOCUf1ENTATION IN KG&E (.i SDWEILLANCE REPOET S-372 HAS NOT EEEN PROVIDED C a. Provide objective evidence for:
-Civil Deficiency Reports in S-372.
-flechanical Deficiency Reports in S-372.
"C" designates activity completed ,
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____________u.________
STATUS OF AWS Wtl DING INSPECTIONS AND ENGINEER!E EVAf IIATIONS
!!-27-04 .
TOTAL JOINTS Ju!NTS JOINTS MEQUlkliG ADDITIONAL JOINTS SIGNIFICANTLY DEFICIENT RMILDIE JQM 1phFhCIhp kVALUATt.D REWoas (1) To aX W G) JOINTS (10crase.ssfall Aamera raaf 630 370 400 2 23 0 REACWa 1210 1030 slo a 1 0 .
CouTROL 240 230 110 6 7 0 DIESEL c*Ekayan
- IOC to 80 1 2 0 .
i FREL 200 200 190 0 5 0 I iSuS !
FWWulegg 20 20 20 0 0 0 Tet&L 2420 2140 1620 17 34 0 l i-(1) DESICM al t mamI F STRESSES ARE EXCEEDED IN THE AS-SUILT CONDITION l l (2) DESIGN ALLCMASLE STRESSES ARE NOT EXCEtaED IN THE AS-SUILT COISITION.
TMESE JOINTS ARE REING REWORKED PER KG4E M* Mar'umf DIRECTION TO INSTALL MISSING Als aman mcTM WEIAS.
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INTRODUCTION THE WOLF CREEK PRESSURIZER POWER OPERATED RELIEF VALVES ( PORVS) ,
MANUFACTURED BY GARRETT, ARE 3" x 6" AND ARE SOLEN 0ID OPERATED. THEY ARE INTENDED TO CONTROL PRESSURIZER PRESSURE TO A VALUE BELOW THE FIXED HIGH-PRESSURE REACTOR TRIP SETPOINT FOR A 40% LOAD REJECTION ASSUMING FAILURE OF THE PRESSURIZER SPRAY SYSTEM. THEY ALSO PROVIDE A SAFETY GRADE MEANS FOR REACTOR COOLANT SYSTEM DEPRESSURIZATION TO ACHIEVE COLD SHUTDOWN.
ADDITIONALLY, THEY SERVE AS PART OF THE COLD OVERPRESSURE MITIGATION SYSTEM (COMS).
THE PORVs ARE NOT REQUIRED TO OPEN IN ORDER TO PREVENT OVERPRESSURIZATION OF THE REACTOR COOLANT SYSTEM FOR THE LOSS OF LOAD EVENT DISCUSSED IN THE OVERPRESSURE PROTECTION REPORT. THE PRESSURIZER SAFETY VALVES PERFORM THIS FUNCTION ASSUMING PRESSURIZER SPRAY AND PORVs FAIL TO OPERATE.
THE PORVs ARE ELECTRICALLY ACTUATED VALVES WHICH RESPOND TO A SIGNAL FROM THE PRESSURE SENSING SYSTEM OR TO MANUAL CONTROL. THEY ARE PROVIDED WITH CLASS lE DIRECT POSITION INDICATION IN THE MAIN CONTROL ROOM. FOR EACH VALVE THERE ARE INDICATION LIGHTS AND ALARMS THAT ARE ACTIVATED BY STEM-ACTUATED LIMIT SWITCHES.
FIGURE 1 SHOWS THE FUNCTIONAL SCHEMATIC 0F THE PORV. THE MODE OF OPERATION OF THE VALVE IS AS FOLLOWS:
THE VALVE IS A LINE-PRESSURE ACTUATED, SOLEN 0ID-CONTROLLED, RELIEF VALVE OF THE CAGED-PLUG TYPE. THE SCHEMATIC DIAGRAM 0F FIGURE 1 SHOWS THE UNIT WITH THE SOLEN 0ID DE-ENERGIZED AND THE VALVE CLOSED. INLET PRESSURE (EITHER VAPOR OR WATER) FLOWS INTO THE VALVE INLET CONNECTION AND IS PORTED THROUGH THE S0LENGID SEAT TO THE ACTUATOR HEAD CHAMBER OF THE VALVE. INLET PRESSURE IS ALSO PORTED UNDERNEATH THE PISTON AND THROUGH THE CAGE H0LES TO SURROUND THE PLUG. THE FORCES TENDING TO HOLD THE VALVE CLOSED INCLUDE THE PRESSURE IN THE ACTUATOR HEAD CHAMBER ACTING ON THE ENTIRE PISTON AREA AND THE ACTUATOR SPRING LOAD. INLET PRESSURE ALSO ACTS ON THE ANNULAR AREA BENEATH THE PISTON (AND OUTSIDE THE SEAT DIAMETER) IN A DIRECTION TO OPEN THE VALVE. SINCE THE ANNULAR AREA IS LESS THAN THE TOTAL PISTON AREA, THE CLOSING FORCE PREDOMINATES AND THE PLUG IS HELD DOWN AGAINST THE SEAT WITH A FORCE EQUAL TO THE VALUE OF INLET PRESSURE MULTIPLIED BY THE SEAT AREA.
WHEN THE SOLEN 0ID IS ENERGIZED, THE MAGNETIC FORCE ACTS ON THE SOLEN 0ID ARMATURE TO MOVE THE BALL FROM THE VENT SEAT (AS SHOWN) TO THE OPPOSITE SEAT, THUS SEALING OFF INLET PRESSURE FROM THE ACTUATOR HEAD CHAMBER. AT THE SAME TIME, THE ACTUATOR HEAD PRESSURE IS VENTED TO DISCHARGE THROUGH THE VENT SEAT OF THE SOLEN 0ID. WITH THE ACTUATOR HEAD CHAMBER NOW AT DISCHARGE PRESSURE, INLET PRESSURE ACTING ON THE ANNULAR AREA IS SUFFICIENT TO OVERCOME THE ACTUATOR SPRING LOAD. THE PLUG MOVES AWAY FROM THE SEAT IN THE DIRECTION TO OPEN THE VALVE.
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AS THE VALVE OPENS, PRESSURE INSIDE THE CAGE BUILDS UP UNDERNEATH THAT PORTION OF THE PLUG EXPOSED TO DISCHARGE PRESSURE. BECAUSE OF THE PRESSURE DROP THROUGH THE CAGE FLOW H0LES, THIS PRESSURE IS LESS THAN INLET PRESSURE BUT HIGHER THAN THE DISCHARGE PRESSURE. THE LARGE SEATING FORCE THAT EXISTS WHEN THE VALVE IS CLOSED IS THUS TURNED INTO AN OPENING FORCE, CAUSING THE PLUG TO MOVE TO THE FULL-LIFT POSITION.
WHEN THE SOLEN 0ID IS DE-ENERGIZED, THE BALL MOVES BACK TO THE SEAT AS SHOWN, SEALING 0FF THE PATH TO DISCHARGE AND REPRESSURIZING THE ACTUATOR HEAD CHAM 3ER WITH INLET PRESSURE. WITH THE PLUG IN THE FULL-LIFT POSITION, THE OPENING FORCE CONSISTS OF INLET PRESSURE ACTING ON THE ANNULAR AREA AND CAGE PRESSURE ACTING ON THE BASE OF THE PLUG. THE CLOSING FORCES (CONSISTING OF INLET PRESSURE IN THE ACTUATOR HEAD CHAMBER AND THE ACTUATOR SPRING LOAD)
OVERCOME THE OPENING FORCES AND CAUSE THE PLUG TO MOVE TOWARD THE SEAT.
DISCHARGE PRESSURE DROPS TO A MINIMUM AS THE VALVE RESEATS, AND THE VALVE IS ONCE M3RE HELD IN THE CLOSED POSITION BY A FORCE THAT IS EQUAL TO INLET PRESSURE MULTIPLIED BY THE SEAT AREA.
DISCUSSION OF VALVE MALFUNCTION IT WAS IN THE CLOSING MODE, DESCRIBED ABOVE, IN WHICH THE ' ALVES MALFUNCTIONED. SPECIFICALLY, THE VALVES WERE BEING OPERATED IN THE MANUAL MODE, DISCHARGING STEAM, AND BEING HELD OPEN FOR A PERIOD OF APPROXIMATELY 32 SECONDS. PRIOR TO OPENING THE VALVE, THE INLET PIPING (CONSISTING OF APPROXIMATELY FOURTEEN FEET OF VERTICAL DOWNWARD RUN LOOP SEAL) WAS FILLED WITH COLD WATER AS WERE THE VALVES THEMSELVES. THE VALVES ARE LOCATED IN A COMPARTMENT WHICH IS BELOW THE TOP OF THE PRESSURIZER. THIS LOCAT'.0N AWAY FROM THE TOP OF THE PRESSURIZER RESULTS IN VALVES BEING SUBSTANTIALLY COLDER
THAN IF THEY WERE AT THE TOP OF THE PRESSURIZER. VALVE AMBIENT TEMPERATURE AT WOLF CREEK IS APPROXIMATELY 90 DEGREES FAHRENHEIT.
THE PRE 0PERATIONAL TEST ITSELF REQUIRED APPROXIMATELY 32 SECONDS OF CONTINUOUS OPERATION TO ACHIEVE PRESSURE RELIEF OF 200 PSI. THE PURPOSE OF THE TEST IS TO VERIFY VALVE STROKE TIME AND LEAKAGE AFTER THE VALVE HAS BEEN OPENED FOR MORE THAN TWO SECONDS. THIS TEST SIMULATES CERTAIN CONDITIONS WHICH MAY BE ENC 0UNTERED DURING PLANT OPERATION SUCH AS LOSS OF LOAD. THE VALVE EQUIPMENT SPECIFICATION CONTAINS REQUIREMENTS SUCH AS: VALVE CYCLE TIME ; DISCHARGE FLUID RATES; NUMBER OF DESIGN CYCLES; ETC. THESE DESIGN REQUIREMENTS ARE ADEQUATE TO ASSURE THAT THE VALVE WILL PERFORM ITS INTENDED FUNCTION.
IN ADDITION TO ASSURING OPERABILITY THROUGH EQUIPMENT SPECIFICATION REQUIREMENTS, CONSIDERABLE TESTING HAS BEEN PERFORMED ON THESE VALVES. THIS TESTING INCLUDES PREOPERATIONAL TESTS AT OTHER FOREIGN AND DOMESTIC PLANTS AND THE FOLLOWING SUCCESSFUL TESTS AT WOLF CREEK. AT WOLF CREEK, TESTS PERFORMED IN 1HE AUTOMATIC MODE, DURING WHICH THE VALVE REMAINED OPEN FOR A PERIOD OF APPROXIMATELY TWO SECONDS. WERE SUCCESSFUL. ADDITIONALLY ALL WOLF CREEK TESTING PERFORMED WITHOUT A COLD LOOP SEAL WAS COMPLETED SUCCESSFULLY. FURTHER, A NUMBER OF ISOTHERMAL TESTS HAVE BEEN PERFORMED ON THE GARRETT POWER OPERATED RELIEF VALVES. THESE INCLUDE THE EPRI SAFETY AND RELIEF VALVE TEST PROGRAM, AND GARRETT OPERABILITY TESTS. IN THESE TESTS, THE VALVES CLOSED AS REQUIRED.
WHEN THE VALVES FAILED TO CLOSE WHEN SIGNALED AFTER THE DISCHARGE PERIOD OF APPROXIMATELY 32 SECONDS, THE MOTOR-OPERATED BLOCK VALVES. WHICH ARE INSTALLED UPSTREAM OF THE PORVs AND WHOSE FUNCTION IS TO PRECLUDE THE LOSS
0F REACTOR COOLANT IF A LEAK SHOULD DEVELOP IN A PORY, WERE CLOSED. CLOSING OF THE PORVs WAS OBSERVED TO OCCUR SIMULTANE0USLY WITH BLOCK VALVE CLOSURE.
THIS OCCURRED BECAUSE THE HEAD ACTUATOR CHAMBER (WHICH WAS ISOLATED) WAS AT APPROXIMATELY 500 PSIG, THE NORMAL DISCHARGE PRESSURE. CLOSURE OF THE BLOCK VALVE REDUCED INLET PRESSURE. SINCE THE ACTIVE AREA AB0VE THE PISTON IS THREE TIMES GREATER THAN THAT BELOW THE PISTON, THE 500 PSIG WAS SUFFICIENT TO OVERCOME THE FALLING INLET PRESSURE.
SUMMARY
OF INVESTIGATION THE POSTULATED CAUSES FOR THE VALVE MALFUNCTION CONSIDERED WERE: SOLEN 0ID FAILURE, PLUG TO CAGE BINDING, AND FAILURE TO GET REQUIRED FLUID PRESSURE TO ACTUATOR HEAD CHAMBER. PROPER SOLEN 0ID OPERATION WAS VERIFIED. THE FACT THAT THE VALVE OPERATED AS DESIGNED IN THE SUTOMATIC MODE AND INSPECTION OF THE VALVE INTERNALS SHOWED NO EVIDENCE OF BINDING (I.E., G0UGING ETC.),
ELIMINATED THE BINDING SUPPOSITION. THEREFORE, THERE WAS STRONG INDICATION THAT THE THIRD POSTULATED CAUSE, THAT OF FAILURE TO GET REQUIRED FLUID PRESSURE TO THE ACTUATOR HEAD CHAMBER, WAS THE SOURCE OF THE MALFUNCTION.
BY REVIEWING THE VALVE DESIGN IN CONJUNCTION WITH DETAILED MANUFACTURING DRAWINGS IT WAS DETERMINED THAT DIFFERENTIAL THERMAL EXPANSION BETWEEN THE VALVE CAGE AND THE VALVE BODY BORE IN WHICH THE CAGE IS HOUSED, WOULD CAUSE THE CAGE-TO-BODY ANNULUS TO BE REDUCED IN SIZE EVEN TO A POINT OF TOTAL CLOSURE. THIS ANNULUS SERVES AS A PATH FOR INLET FLUID TO TRAVEL TO THE SOLEN 0ID PORT AND EVENTUALLY TO THE ACTUATOR HEAD CHAMBER AS DEFINED PREVIOUSLY. TO VERIFY THIS SUPPOSITION, A SUBSEQUENT MANUAL TEST, SIMILAR 1 l
TO THE TESTS IN WHICH MALFUNCTION OCCURRED, WAS PERFORMED WITH THE VALVE BODY HEATED TO 228 DEGREES FAHRENHEIT. THE VALVE FUNCTIONED AS REQUIRED l l
PROVIDING STRONG SUPPORT TO THE PREMISE THAT DIFFERENTIAL THERMAL EXPANSION )
WAS THE CAUSE OF THE MALFUNCTION. IT SHOULD BE NOTED THAT BY HEATING THE VALVEBODYTO228DEGREESFAHRENHEITTHEVALVEBODYBOREWASINCREASEDBi -
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l SIX MILS WHICH RESULTS IN AN ADDITIONAL ANNULAR CLEARANCE UNDER THE FLOW CONDITIONS. '
IN REVIEW OF THE VALVE MANUFACTURING DRAWINGS, IT WAS DETERMINED THAT THE MAXIMUM AND MINIMUM RADIAL ANNULAR CLEARANCE AT AMBIENT TEMPERATURE WHEN THE PARTS (VALVE BODY AND CAGE) ARE MACHINED TO WITHIN SPECIFIED TOLERANCES ARE NINE AND SIX MILS (0.009 - 0.006) RESPECTIVELY WITH DIAMETRAL CLEARANCE BEING EIGHTEEN TO TWELVE MILS (0.018 - 0.012).
I BASED- ON THE INFORMATION FROM THE TESTING DESCRIBED ABOVE AND THE SMALL MANUFACTURING TOLERANCES, AN ANALYSIS WAS PERFORMED TO DETERMINE THE EFFECTS OF DIFFERENTIAL TEMPERATURE ON THE VALVE BODY AND CAGE. FIGURE 2 IS A PLOT OF THE RESULTS AND SHOWS THAT FOR 100 DEGREES FAHRENHEIT OF TEMPERATURE DIFFERENTIAL THE ANNULAR GAP IS REDUCED BY APPR0XIMATELY THREE AND ONE HALF MILS ( .0035) . THIS IS BASED ON THE EXPANSION OF THE CAGE WITH NO EXPANSION OF THE VALVE BODY. BY HEATING THE VALVE IN THE SUCCESSFUL TEST, j APPR0XIMATELY SIX MILS (0.006) ANNULAR CLEARANCE WAS ADDED DUE TO THE THERMAL EXPANSION 0F THE VALVE BODY AT ITS INITIAL CONDITION OF 228 DEGREES FAHRENHEIT. -
l THIS PHENOMENON WAS THEN ANALYZED TO DETERMINE THE EFFECTS OF GAP CLOSURE ON FLUID - FLOW WITH A HOMOGENEOUS' FLOW MODEL. THE RESULTS' SUBSTANTIATE THE HEATED TEST RESULTS AND THE DIFFERENTIAL EXPANSION PREMISE. SPECIFICALLY, FOR ALL RELIEF CONDITIONS, THE MINIMUM ANNULAR DIAMETRAL GAP BETWEEN THE BODY AND THE CAGE NECESSARY FOR THE PORY TO FUNCTION PROPERLY IS 1.12 MILS.
WITH THE VALVE STARTING COLD (90 DEGREES FAHRENHEIT) AND SUDDENLY EXPOSED TO HIGH PRESSURE STEAM (650 DEGREES FAHRENHEIT) IT WILL TAKE 5.75 SECONDS FOR THE ANNULAR ORIFICE GAP TO BE REDUCED FROM 15" MILS TO 1.12 MILS. IN
7.47 SECONDS, THE ANNULAR ORIFICE IS COMPLETELY CLOSED OFF. IF THE ANNULAR ORIFICE GAP STARTED OUT AT 18 MILS, IT WOULD TAKE APPROXIMATELY 9 SECONDS FOR THE GAP TO BE REDUCED TO 1.12 MILS. BY 11 SECONDS, THE 18 MIL GAP WOULD BE COMPLETELY CLOSED. IN THIS ANALYSIS THE CAGE EXPANDS AS A FUNCTION OF .
TIME AND TEMPERATURE AND THE THERMAL EXPANSION OF THE VALVE BODY DURING THESE TIME INTERVALS IS NEGLIGIBLE.
1 CORRECTIVE ACTION TAKEN THE VALVES UNDER DISCUSSION WERE DISASSEMBLED AND DIMENSIONS OF THE BODY BORE I.D. AND CAGE 0.D. WERE TAKEN. THIS SHOWED THAT THE DIAMETRAL ANNULAR CLEARANCES AT AMBIENT TEMPERATURE WERE NOMINALLY 15 MILS AND 18 MILS FOR THE TWO VALVES. A FIELD CHANGE NOTICE (FCN) WAS PREPARED TO MACHINE THE CAGES TO AN 0.D. OF 4.55 TO 4.57 INCHES, THEREBY PROVIDING A FINAL DIAMETRAL ANNULAR CLEARANCE OF 114 MILS AND 111 MILS RESPECTIVELY. THIS ACTION WAS TAKEN WITH FULL COGNIZANCE AND TECHNICAL SUPPORT / ASSURANCE BY THE VALVE DESIGNER / MANUFACTURER (GARRETT) AND WESTINGHOUSE.
IN DESIGNING THE VALVE TO MEET THE SPECIFICATION REQUIREMENTS, THE DESIGNER KEPT THE ANNULAR CLEARANCE SMA'LL S0 THAT IT WOULD SERVE AS A FILTER TO PREVENT ANY DEBRIS THAT MAY BE ENTRAINED IN THE FLUID FROM FOULING THE THREE-WAY BALL VALVE OF THE SOLEN 0ID. HOWEVER, THE VALVE MANUFACTURER (GARRETT) HAS DETERMINED THAT THE CLEARANCE PROVIDED BY THIS DESIGN NEED NOT BE THIS SMALL. GARRETT HAS ALSO CONFIRMED THAT THE MACHINING TO RESIZE THE CAGE IS A PRODUCT IMPROVEMENT.
SupetARY AND CONCLUSION THE WOLF CREEK PRESSURIZER PROVs FAILED TO CLOSE AFTER A DISCHARGE OF WATER FOLLOWED BY STEAM WHICH WAS CONDUCTED' MANUALLY FOR AN EXTENDED PERIOD OF
TIME. THE CAUSE OF THIS MALFUNCTION WAS DETERMINED TO BE DIFFERENTIAL THERMAL EXPANSION (VALVE BODY TO CAGE) RESULTING IN A RESTRICTION OF AN ESSENTIAL FLUID FLOW PATH TO THE VALVE ACTUATOR HEAD ASSEMBLY.
IDENTIFICATION OF THE CAUSE OF THE MALFUNCTION IS SUPPORTED BY TESTING IN OTHER OPERATING MODES, SUCCESSFULLY REPEATING THE FAILED TEST WITH REDUCED DIFFERENTIAL TEMPERATURES, AND A DETAILED ENGINEERING ANALYSIS. i l
A VALVE MODIFICATION, SPECIFIED BY WESTINGHOUSE AND CONCURRED WITH BY l
GARRETT (THE VALVE DESIGNER / MANUFACTURER) HAS BEEN MADE WHICH CORRECTS THE MALFUNCTION WITHOUT HAVING ANY DELETERIOUS EFFECTS ON VALVE FUNCTION, BASED ON THE INFORMATION CONTAINED HEREIN AND SUPPORTING DOCUMENTATION, IT IS CONCLUDED THAT THE GARRETT PRESSURIZER POWER-0PERATED RELIEF VALVES WILL FUNCTION UNDER ALL DESIGN CONDITIONS.
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FIGURE 1: 3" x 6* GARRETT PORY OWLU -
MODEL 3750014 COVERED IN SPECIFICATION G-955245, REV. 0 L
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AL = aA7D AL = Cage Growth (in.)
6 E = 7.6 X 19 in./in.*F
.020 D = 4.671 in. .,
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IW-3426 kakage (cc/hr) Press (PSIG)
Valve No. Size Specif.
9 >2235
> B -8948A 19" 30 cc/hr 699 al/hr
>2235 19" 30 cc/hr 699 al/hr 268 m -8948B >2235 m -8940C 19" 39 cc/hr 699 al/hr 6824 (1) 699 al/hr 478 >2235 E -89483 19" 30 cc/hr >2235 p-8956A 19" 30 cc/hr 690 ml/hr 799 39 cc/hr 699 al/hr 2464 (1) >2235 p -8956B 19" 30 cc/hr 600 al/hr 914 >2235 P -8956C 19" 690 al/hr 9 >2235 p -8956D 19" 30 cc/hr * >2235 p -8818A 6" 18 cc/hr 369 al/hr 18 ,
l 369 al/hr (3) >2235 D-8818B 6" 18 cc/hr >2235 D -88180 6" 18 cc/hr 360 ml/hr 5998 (1) 6" 18 cc/hr 36e ml/hr (3) >2235 p -88183 6" 18 cc/hr 369 ml/hr (3) >2235 BB-8949A >2235 6" 18 cc/hr 360 ml/hr 19 E -8949B >2235 E -8949C 6" 18 cc/hr 360 ml/hr (3) 6" 18 cc/hr 360 ml/hr (3) >2235 E -89493 >2235 6" 18 cc/hr 360 ml/hr 76 U -8841A 6" 18 cc/hr 360 ml/hr 929 (1) >2235 U -8841B 3" 9 cc/hr 180 ml/hr 96 >2235 m-8815A >2235 p-v010 2" 6 cc/hr 120 ml/hr 454 p-v020 2" 6 cc/hr 120 ml/hr 5 >2235 p-v639 2" 6 cc/hr 129 ml/hr 136 >2235 p-v04e 2" 6 cc/hr 120 ml/hr 14 >2235 2" 6 cc/hr 120 ml/hr 62 >2235 m-v001 2" 6 cc/hr 12e al/hr 15e6 >2235 m-v002 m-vee 3 2" 6 cc/hr 129 ml/hr 8.5 >2235 2" 6 cc/hr 129 al/hr 4 >2235 m-ve94 >2235 2 -v001 1-1/2" 4.5 cc/hr 90 al/hr 144 4.5 cc/hr 90 al/hr 138 >2235 as-v022 1-1/2" 4.5 cc/hr 90 ml/hr 128 >2235 E-V940 1-1/2" 4.5 cc/hr 99 ml/hr 96 >2235 E-v959 1-1/2" 99
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i Page : I Notes:
- 1. These valves exceed required limits and l will be reworked and retested. l I
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- 2. ICS pressure for the balance of testing l was being controlled at >2235 psig by SU3-BB95. For the period 9-16-64 I through 10-94-84 there were two pressure transits resulting in an ICS pressure of <2235 (9-23-84 and 9-28-84 through 19-91-84). No check valve leak test data was recorded on those dates.
- 3. 1btal actual leakage recorded = 29,965 oc/hr which = 5.45 gal /hr. Utilizing E GS Tech Spec para. 3.4.6.3.f value of 1 GM total leakage leaves us with a margin of 54.55 gal /hr.
Performance of OfP-m-419-M recorded a total leakage of 9.124 galanin which =
7.44 gal /hr.
7.44 gal /hr (CWP results)
-5.45 gal /hr (m93 results) 1.99 gal /hr to account for leakage of the five 6" check valves which do not have recorded leakage data (see Page 1) .
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e otd"% UNITED STATES
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NUCLEAR REGULATORY COMMISSION y * .(*;Eg WASHINGTON, D. C. 20555 Q,:~ljl ,
- NAR 2 61985 Docket No.: STN 50-482 APPLICANT: Kansas Gas and Electric Company (KG&E)
FACILITY: Wolf Creek Generating Station
SUBJECT:
SUMMARY
OF MEETING WITH KANSAS GAS AND ELECTRIC COMPANY REGARDING THE OPERATIONAL READINESS OF THE WOLF CREEK GENERATING STATION On January 15, 1985, a meeting was held with Kansas Gas and Electric Company (KG&E) to discuss the operational readiness of the Wolf Creek It had Generating previously been Station. This meeting was held at the plant site.
scheduled to be held on January 10 and had to be rescheduled for January 15, 1985 due to weather conditions.
The following two scenarios which were exercised by KG&E operating personnel on the Wolf Creek simulator.
(1)' Main steam line break outside containment
- plant at full power; Xe at equilibrium
- power reduced to 75%
- unrelated control rod drop
- leak in main steam line
- main steam isolation valve on affected steam generator fails to close (2) Primary system leak in centrifugal charging pump letdown line
- unrelated, inadvertent Safety Injection
- bomb threat received
- bomb explodes, causing primary system leak
- The operating crew for these exercises consisted of two reactor operators, one senior operator, and one advisor. The advisors are on operating crew to All three of the operators in this provide commercial operating experience.
exercise hold Senior Operator Licenses as do most of the operators at Wolf Creek. The exercises got off to a rather slow start and a minor simulator problem. As we proceeded into the scenario the pace picked up and theThe re-
, sponse and performance of the crew met the demands of the situation. In Energency Operating Procedures were appropriately used in the exercise.
summary the crew generally demonstrated their ability to use the procedures and the adequacy of the procedures for coping with operating conditions throughout the identified scenarios.
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s RAR E G 1985 It was noted that using senior operators as reactor operators may have some adverse impact on maintaining the chain of command because the senior operator, serving in the reactor operator position, tends to act without receiving clear direction from the senior operator in command of the shift.
Following the simulator exercise, the staff toured the plant with KG&E operating personnel and observed plant conditions.
At 1:15 p.m., the NRC staff met with KG&E staff in the Education Center.
The staff was represented by the following participants:
Paul O'Connor Pro.iect Manager, Licensing Branch No. 1 Division of Licensing, NRR .
- 8. J. Youngblood Chief, Licensing Branch No. I, Division of Licensing, NRR Robert Bernero Director, Division of Systems Integration, NRR Dennis Ziemann Chief, Procedures and Systems Review Branch, Division of Human Factors Safety, NRR John Collins Acting Deputy Director, Office of Inspection and Enforcement Richard Denise Director, Wolf Creek Task Force,-Region IV Robert Smith Inspector, Region IV James Knight Acting Director, Division of Engineering, NRR The agenda for the management visit to Wolf Creek is provided in Enclosure 1 and the slides used by the applicant are provided in Enclosure 2.
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KAR 2 6 1585
- 3-Based on the staff's observations during the tour and the presentation by KG&E we concluded that schedule for completion of preoperational testing related to ECCS sequencing and shutdown sequencing are on the critical path to licensing and that the applicants' schedule for licensing by February is optimistic and can only be achieved by completion of the outstanding preoperational tests on a schedule to permit the staff adequate time to review the results prior to declaring the plant ready to license.
Paul W. O'Connor, Project Manager Licensing Branch No. 1 ,
Division of Licensing
Enclosures:
As stated e
9 I
WOLF CREEK us ". '995 Mr. Glenn L. Koester Vice President - Nuclear Kansas Gas and Electric Company 201 North Market Street '
Post Office Box 208 Wichita, Kansas 67201 Ms. Wanda Christy cc: Mr. Nicholas A. Petrick Executive Director, SNUPPS 515 N. 1st Street 5 Choke Cherry Road Burlington, Kansas Rockville, Maryland 20850 C. Edward Peterson, Esq.
Jay Silberg, Esq. Legal Division Shaw, Pittman, Potts & Trowbridge Kansas Corporation Commission 1800 M Street, N. W. State Office Building, Fourth Floor Washington, D. C. 20036 Topeka, Kansas 66612 Mr. Donald T. McPhee John M. Simpson, Esq.
Vice President - Production Attorney for Intervenors
. Kansas City Power & Light Company 4350 Johnson Drive, Suite 120 Shawnee Mission, Kansas 66205 1330 Baltimore Avenue Kansas City, Missouri 64141 Regional Administrator Ms. Mary Ellen Salava U. S. NRC, Region IV Route 1, Box 56 611 Ryan Plaza Burlington, Kansas 66839 Suite 1000 Arlington, Texas 76011 A. Scott Cauger Assistant General Counsel Mr. Joe Mulholland Public Service Commission Manager of Power Supply & Engineering P. O. Box 360 Kansas Electric Power Cooperative, Inc.
Jefferson City, Missouri 65101 Post Office Box 4877
- Gage Center Station Topeka, Kansas 66604 Mr. Howard Bundy Resident Inspector / Wolf Creek NPS c/o U.S.N.R.C . Regional Administrator Post Office Box 311 U.S.N.R.C. - Region III l Burlington, Kansas 66839 799 Roosevelt Road l Glen Ellyn, Illinois 60137 i I
Mr. Robert M. Fillmore Brian P. Cassidy, Regional Counsel State Corporation Commission State of Kansas Federal Emergency Management Agency Fourth Floor, State Office Bldg. Region I Topeka, Kansas 66612 J. W. McCormack POCH Boston, Massachusetts 02109 l
l l
GAR 2 6 ISMS WOLF CREEK l
cc: Terri Sculley, Director Special Projects Division Kansas Corporation Commission State Office Building, Fourth Floor Topeka, Kansas 66612 Mr. Gerald Allen Public Health Physicist Bureau of Air Quality & Radiation Control Division of Environment' Kansas Dept. of Health & Environment Forbes Field Bldg. 321 Topeka, Kansas 66620 C
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i ENCLOSURE 1 f
AGENDA FOR MANAGEMENT VISIT TO WOLF CREEK ON JANUARY 10, 1985 Item
- Location Time Education Center 8:30.AM Simulatdr Exercise Plant Tour and Discussion Wolf Creek 10:15 AM with Operating Personnel Generating Station Lunch Wolf Creek -
12:15 PM Cafeteria Meeting 1:15 PM -.
- 1. Organization Staffing and Training
- 2. Operational Experience .-
- 3. Operational Readiness
- 4. Selected Technical Issues .
- a. Plans for preventative maintenance l
- b. Structural Steel Welding
- c. Quality First Program Status ;
- d. Fire Protection Modifications
- e. Construction Appraisal i
- f. Callaway Lessons Learned ,
- g. Technical Specifications ,
e n
ENCLOSURE 2 NRC MANAGEMENT READINESS VISIT January 15, 1985 S
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g WOLF CREEK GENERATING STATION
4 NRC MANAGEMENT READINESS VISIT January 15, 1985 e
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Nuclear Department Organigation Glenn Koester (Vice-President - KG8E)
Plant Organization, Training, & Experience Forrest Rhodes (Plant Manager)
Preventive Maintenance Philosophy Forrest Rhodes (Plant Manager)
Technical Specifications Forrest Rhodes (Plant Manager)
Callaway Lessons Learned Forrest Rhodes (Plant Manager)
Structural Steel Welding John Berra (Vice-President ;-Daniel)
Construction Appraisals Dick Grant (Director - Quality)
- Q '
Quality First Kent Brown (Group Vice-President.- KG&E)
Fire Protection Modifications John Bailey (Direi: tor Engineering & Technical Services)
, Operational Readiness Assessment Chuck Mason (Site Director - Director Nuclear Operations) 4
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NUCLEAR DEPARTMENT ORGANIZATION Glenn Koester 6
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NUCLEAR DEPARTNENT ORGANIZATION- ,
VICE PRESIDENT - NUCLEAR
- Manager
- see Nuclear g Licensing Services Division I I I I I Admins'tra tive Con s t'ruc tion Nuc1' ear Engfneer Quality Services Bra nc h Operation Technical Branch Division Branch Service (Wichtta Branch (Wicht ta and Site) (Site) (Wiciti ta) . & Site) l I I Wolf Creek Manag'ement Nuclear Nuc' Lear lluman Gene ra ting Sys tems Plant Services _
Quality Resources S ta tion Division Engineering Division Assurance
, (Wichita & Division Si te ) (Site ) (Wic hi ta) (Wic hi ta ) (Wic hi ta) (Wichita) l I l Conf ig'ura tion Nuc' lear I I Quality Nuclear Nuclear Management Plant Eny' iron- Sa f'e ty Ansurance
~Coord ina to rs Training S tar tup
- Records Engineering men tal Engineering (Wic hi ta) Division Management, Assessment (Site)
(Site & Document (Site)
Wi c hi ta) (Site) Control (Site) (Site) Quality budget / (Wic hi ta ) Control Accounting Con t rols (Site)
(Wichita &
Si te )
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b LOCATION OF "HOME OFFICE" DIVISIONS SUPPORT PERSONNEL I
DEPARTMENT HQ WICHITA - -
ADMIN SERV WICHITA WOLF CREEK NUC OPNS IlQ WICHITA WOLF CREEK NUC TRAINING WICHITA WOLF CREEK TECH & ENCR SERV WICHITA WOLF CREEK MGMT SYS WICHITA WOLF CREEK NUC PLT ENCR WICHITA WOLF CREEK '
NUC SERV WICHITA WOLF CREEK QUALITY ASSUR WICHITA WOLF CREEK i
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PR0pESSIONAL "HOME OFFICE" DIVISION I' EMPLOYEES LOCATION.
WICHITA SITE PROF & TECH PROF & TECH DEPT HQ.............. 2 4 4 ADMIN SERV........... *
- 10 18 NUC OPNS HQ..........
25 NUC TRNG......... 1.
I TECH & ENGR SERV HQ.. O 7 2 MCHT SYS.........
57 7 NUC PLT ENGR.....
38 11 NUC SERV.........
I1 44 QUALITY ASSUR........
130 112 LOCATION TOTALS...
TOTAL (HO DIVS)...... 242 9
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' HOME OFFICE EMPLOYEE '
EXPERIENCE BASE
SUMMARY
, MILITARY JOB WOLF-COMMER'L NUC OPR RELATED CREEK TOTAL DIVISION NUC OPR 16.5 18.5 3' 78 NUCLEAR OPERATIONS 40 (7.5)
TECH & ENCR SERV 500.5 108 25 215.5 152 NUC PLT ENCR 101 121 313.5 NUC SERV 62.5 (6.5) 29 44.5 56 22.5 123 MCMT SYSTEMS 42 544 139.5 779.5 QUALITY 54 (11) 102 28.5 131.5 1
ADMIN SERV 4
-( ) Denotes years of SRO or RO license Experience
~***** TOTAL HO DIVISIONS EXPERIENCE = 1926 years *****
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(
6 YEARS OF EXPERIENCE t
COMM'L MILITARY JOB WOLF NUCLEAR NUCLEAR RELATED CREEK i
' 17 3 4 25 DIR NUC OPNS MGR OPNS SUPT 10 (2.5) 7.5 .5 2 4 4 2 9 DIR ENGR & TEC SER 17 - 2 11 MGR NUC ENGR
- 4 9 10 MGR NUC SERV MCR NUC TRNG 6.5 5.0 2 .8
- - 10 1 DIR QUALITY
- 2 3 3 MGR QA (SITE)
- - 20 2 MGR ADMIN
- SERV
- - - 11 MGR MGMT SYS 4.5 - 3 3 MCitFAC& ANAL 5 7 MGR RAD & LIC SERV 3 (2) -
2 MGR LICENSING 2 (.5) - -
4 d=
. a.
1
PLANT ORGANIZATION, TRAINING & EXPERIENCE PREVENTIVE MAINTENANCE PHILOSOPHY TECHNICAL SPECIFICATIONS CALLAWAY LESSONS LEARNED Forrest Rhodes ___ ,
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Plant Organization
- Plant Manager-1
-Secretary-1
-Supt of Maint-1 -Supt of Operations-1 -Supt of Tech Supp-l -Supt of Plant Supp-l -Supt of Regulatory-1 Quality and Admin
-General Clerk-1 -General Clerk-1; ,
-General Clerk-1 -General Clerk-1 Services
(
-Maint Sves Supvr-1 -Ops Coord - Ops-1 -Reactor Eng Supvr-1 -Fire Prot Spec *-1 -General Clerk-1
-Maint Engr-6 fShiftSupervisor-7 fReactorEngineer-2 fTrainingSpec-1
-Maint Tech -4 -Supervising'Opr-6 -Engineering Spec-1
-Mat Cont Supvr-1 -Reactor Opr -I&C Supervisor-1 -Chief of Security *
-Mat Coord Sup-l -Station Opr 50 -Engineer / Spec-4 fSecurityStaff -Safety Specialist-1
-Storeroom Sup-l -Utility Helper -I&C Coordinator-2 fWarehouseAtt-7 -I&C Spec-5 -Nuc Medical Spec-1
-Utility Supvr-1 -Ops Coord - Plan- -I&C Tech-46 -Results Eng Supvr-1
-Utility Mech-3 ning and Projects-1 -Utility Helper-6 fResultsEng-22 -Site Dnerg Planning
-Lead Bldg Svman-3 -Engineer / Spec-0 -frad Comp Eng-1 Administrator-1
-Bldg Serviceman-12 -Surv Coord-l -Comp Eng/ Spec-4
[SystemAnalyst-1 -App Prog Trn-6 'IOrAL 27_ -DocumentContSupv-1
-Maint Supp Supvr-1
-Doc Cont Clerk-14
-Mech Supvr-2 -Site Chemist-1 -Analy& Film Opr-16
-Welder-3 'IOrAL 6_9, fhanistrySupvr-4
-Machinist-3 -IIP / Chem Tech-14 -Admin Supvr-1
-Load Mechanic-3 -Utility Helper-6
-Mechanic-22 flerk-30
~
-Utility Hlpr-14 -Site Health Phys *-1
-Electrical Supv-2 filP Supervisor-5 '10 ras. 68~""
-Lead Electrician-1 -IIP / Chem Tech 25
-Electrician-13 -Utility Helper
-Utility Hlpr-7
-HVAC Supervisor-1
'IOTAL 136 fliVAC Mechanic-5 TOTAL 119 *For technical matters of an inmxliate nature the respective individual reports directly to the Plant Manager.
. Wolf Creek Generating Station Revised Organization Chart 1-09-85 TOTAL PLANT 421 Supersedes Oiart dated 12-06-84
STAFFING Hl:QUIRD4ENT BY 12/85 WOLF CREEK - OPERATIONS DATE: 1/09/85 5 le 15 20 25 30 35 40 45 50 55 69 65 70 75 AuTH. l. l l l l l l l FR4 AGERS 6 ///6/A ' ' ' ' ' ' '
SUPERVISORS 39 ////////////////32////////////// -7 (35)
ENGINEERS 49 ////////////////33//////////////A -7 (85) (SU-12)
PIOFESSIONALS 3 / J ) '
CRAeTs PECHANIC 28 ///////13//// -15 l(85)
ELECTRICIAN - 14 ///////13////-1(85)
WELDERS 3 /3/
MACHINIST 3 51(85)
HVAC MEEH 5 -5l(85)
UTIL HELPER 46 ///////////////////35/////////////A -11 l(85) .
TECHNICIANS COMPUTERS 6 /3A -1(85)
IIP /CHDi 33 ///////////////31///////////// A-2l(85)
I&C/ RELAY 46 ///////////////////38////////////////A -8 l(85)
-4 l(85)
MAINTENANCE 4 CLERICAL RMS 30 //////////////27//////////A -3 (85)
OTHER 36 /////////////////34/////////// /////}-2 (85)
BIDG MAINT 15 ///6/A -9 l(85)
WAREHOUSE 7 ///7//A ;
SRO 13 /////13/////A RO 19 /////////19///////A !
NSO 25 /////////////25/////////A l
M AL Almi- 421 TOTAL ON THE JOB- 343 - EMPEDYED OPENINGS 1985- 78 STARTUP '12 - OPENINGS s
SWtiARY OF EXPERIENCE BASE Ccmtiercial* Military Nuclear Nuclear Job Related Wolf Creek Experience Exoerience Experience Experience Total 230.5 26.5 126.0 453.0 Operations 70.0 (30.5) 25.1 417.2 116.2 569.5 Maintenance 11.0 (5.0) 17.0 17.5 29.0 98.0 Adninistration 34.5 (24.0) 116.7 99.5 170. 5 182.45 569.15 Technical Support 6.0 13.5 76.5 49.5 145.5 Plant Support (1.5) i
. 17.0 14.5 27.5 15.5 74.5 Training . (4.0) 400.1 735.7 518.65 1909.65 TorMs 255.2 (65.0)
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9 STRUCTURAL STEEL WELDING John Berra S
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'1 PAR OA CORRf!CTIVE ACTICN REQUEST 519 PROGRAM OELJECTIVES
. ; M..I
. DOCDENT A QXGX.IDATED PRCLTECT PLAN '
ASSURE BY OELTECTIVE EVIDDCE, 'IHAT ANS Dl.1 SAETrY REIATED ::iTMA.w.s%L STEEL WEIDIIC CDMPLIE5 . . _- -
WITH AIL QUALITY CRI':'ERIA.
. ASSURE 'nULT INSPECTICN DOOCMEtfrATION IS:
AVAI[ABLE O2d2[EIT R Nu APPROM1 ATE INFDRMATICli TP.m .
EVAU: ATE Cr1HER ANS D1.1 SAFEfY RELATED WEEDING ACT/ITIES.
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-s TOTAL JOINTS - 11,150 (Shop Welded, Field Bolted, or Field Welded) _
FIELD WELDED JOINTS - 2,669 (24% of Total Joints)
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^
INSPECTIONS AND ENGINEERING EVALUATIONS ,
JOINTS ADDITIONAL
, TOTAL JOINTS SIGNIFICANTLY REQUIRING JOINTS 10 BE BUILDING JOINTS EVALUATED DEFICIENT JOINTS REWORK (1) REHORXED (2). .
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AUXILIARY 693 693 . 0 7 37 REACTOR 1300 1300 0 69 15 CONTROL 265 265 0 3 13 6IESEL GENERATOR 98 98 0 2 2 FUEL 277 277 0 0 6 ESWS P'UMPHOUSE 36 b6' O O O TOTAL 2669 2669 0 81* 73
- s. .
(1) DESIGN ALLOWABLE STRESSES ARE EXCEEDED IN THE AS-BUILT CC.'.DITION .
(2) DESIGN ALLOWABLE STRESSES ARE NOT EXCEEDED IN THE AS-BUILT CONDI- -
TION. THESE JOINTS ARE BEING REWORKED IN ACCORDANCE WITH KG&E MANAGEMENT DIRECTION TO INSTALL MISSING AND UNDERLENGTH WELDS.
F
+60 of these joints are polar crane radial stops installed to one typical detail.
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CONSTRUCTION APPRAISALS Dick Grant o :)
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CONSTRUCTION APPRAISAL KG&E ACTIONS IN ADDITION 'IO ,
WCIE QUALITY PROGRAM e April,'83 e Initiated Conbined Review Group (CRG) and Walkdown Teams for S/U turnover. (Combined-KG&E & Contractor) e Quality Assurance Dept. Walkdown Team formed to mea,sure effectiveness of the above program.
e stry-July '83 B C conducted for KG&E:
"0VERAEL STAWS E ADl!IQUACY OF NOGS QA ACTIVITIES" -
e Oct.-Feb. '84 INPO:
"CONSTRDCTI0ti PROJI!CT EVALDATION" e May-Aug. '84 Delian Cdrp. conducted for KG&E: '
"00ts m a.LT10N SELF ASSESSMENr" e Nov. '84 NRC performed an assessment of KG&E's CSA:
"SPICIAL CONS'I1tDCTION VERIFICATION INSPECTION"
- Bechtel performed "79-14 Walkdown" e
KC&E QA Dept. has performed extensive Audits (103 '84) & Surveillances (267 '84) e Mard '84 e KG&E established " QUALITY IST PROGRAM" to address quality concerns of individuals onsite & exit interviews.
G e-G O
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. QUALITY FIRST Kent Brown 9
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1 QUALITY FIRST PRIMARY OBJECTIVES
.,k I. PROVIDE A SYSTEM WHEREBY ALL KG&E EMP[DYEES AIO M ONSITE CONTRAC'IORS MAY PRESENT QUALITY CONCERNS 'IO AN APPROPRIATE ORGANIZATION EUR RESO[ BRION WI'IH0(fr
'IHREAT OF RETALIATION 'IO 'IHOSE PERSONS EXPRESSItJG 'INE CONCERNS.
II. ESTABLISH 'IME NirESSARY ADMINISTRATIVE AIO INVESTIGATIVE MEASURES 'IO ENSURE 'IHAT QUALITY C)NCERNS RELATED 'IO 'IHE SAFE OPERATIONS, QUALITY OF WORK, COMPLIANCES WI'IH REQUIREMENTS OR MANAGEMENT ARE APPROPRIATELY EVALUATED, INVESTIGATED, DISPOSITIONED, VERIFIED AND DOCU'OTTED.
, GALITY FIRST SIMRRY TorAL NUPBER OE' PERSONNEL INTERVIEWED WITHOUP CONCERNS 4,314
'IUPAL tXREER OF PERSONNEL INTERVIENED WITH CONCERNS 239 -
s,. J ;'
'IUTAL NUPEER OF PERSO901 INTERVIEWED 4,553 ~
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QUALITY FIRST SUttRRY TorAL NUMBER OF CONCERNS 686
'IUPAL tOBER OF QUALITY RE[ATED CONCERNS SUBSTANTIATED 178 4.
NUPBER OF OPEN CONCERNS RESTRAINING FUEL IDAD G -
at NUMER OF PMING CONCERNS (N0fr RE[ATED TO FUEL IDAD) 3 e
7.7/VNOSH3d 30 839HnN
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. FlRE PROTECTION MODIFICATIONS John Bailey 5
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OPERATIONAL READINESS ASSESSMENT 9
Chuck Mason
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N-5 STAMP PROGRAM' COMPLETION ze.. DiC N-5 STAMPS 21 TO-GO AS OF 10/1/84 23 ..
WESTINGHOUSE N-5 STAMPS 11 TO-GO AS OF 10/1/84 E'5 --
27 .
, ACTUAL gg. .
PROJECTED O *'
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ll OVERALL PROJECT FUEL LOAD R$STRAINTS .
2000 .
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i 1500 - '
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500 - '
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I I I I I I I oi I 0 .
11-8 11-15 11-22 11-29 12-6 12-13 12-20 12-27 i-3 1-10 1-17 03 JAN 85 WEEK ENDING .
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SURVMILLAADe TE(TING MODE 6 INITIAL
- i ACTUXL-j' - - -PROJECTED 160 -
- 150- '
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-[ j MEETING
SUMMARY
DISTRIBUTION NRC Participants Docket File '
NRC PDR P. O'Connor L PDR B. J. Youngblood flSIC R. Bernero PRC System D. Ziemann LBf1 Reading File P. OiConnor J. Collins '
Project Manager R. Denise, RIV M. Rushbrook Robert Smith, RIV !
Attorney, OELD J. Knight R. Hartfield*
OPA* l OTHERS t
bec: Applicant & Service List i
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- Caseload Forecast Panel Visits
+
con = n w new.i.or h/ _ /j INTEROFFICE CO R RES PON D ENC E To: R. M. Grant FROM: G. L. Fouts KWCLKQ-84-010 ;
DATE: December 27, 1984
$UBJECT: Wolf Creek Generating Station Corrective Action Request No. 19 Final Report 2
Attached is the Corrective Action Request (CAR) No. 19 - Final Report which provides documented evidence of implementation of the KG&E Management Plan for the Resolution of CAR 19. Please note that Management Plan Item la3 concerning welder qualification, remains as an open item. .
ary L F ~ outs Cons uction Manager
, GLF/JEF/nw r
Attachment:
Corrective Action Request No. 19 - Final Report ec: J. Berra w/a i
J. H. Smith w/a
, O. Maynard w/a '
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KANSAS GAS AND ELECTRIC COMPANT FINAL REPORT
(
CORRECTIVE ACTION REQUEST NO. 19 e
FINAL REPORT KG&E CORRECTIVE ACTION REQUEST NO. 19 TABLE OF CONTENTS I. Executive Summary II. Introduction III. Objective l
IV. Discussion of Findings and Corrective Actions V. Conclusions VI. Appendix A. KG&E Corrective Action Request No. 19 i B. KG&E Management Plan C. Procedure Change Notice No. 14 to QCP-VII-200 D. Bechtel Analysis of Structurally Significant Joints / Welds E. Reports on Inspection of Welds through Paint
- 1. Letter BLKES-1348, C. M. Herbst to G. L. Fouts, 11/05/84
- 2. Letter KNPLKWC-84-065, J. A. Bailey to G. L. Fouts, 11/13/84 F. Lehigh University Report -
Structural Steel Welds at Wolf Creek Generating Station G. White Paper on Wald Evaluations by Reedy, Herbert, Gibbons &
Associates, Inc. of August 11, 1983.
H. DIC Program Assessment I. Referenced documentation and filed location (separated by Correc-tive Action).
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1 of 33
! I. CAR-19 EXECUTIVE
SUMMARY
Because of deficiencies (i.e., undersize, undercut....) previously found
- in fillet welds on ASME and Special Scope hangers, DIC performed a random )
i reinspection of structural steel fillet welds in February, 1983 in all "Q" j designated buildings in the Powerblock. This reinspection indicated that an j unacceptable percentage of structural steel fillet welds were deficient in the Auxiliary, Control and Fuel Buildings. A Corrective Action Report (CAR
< 1-W-0029) was initiated by DIC to implement reinspection, and nonconformance l reports were generated to document and disposition deficiencies noted.
i' Subsequent to the issuance of CAR 1-W-0029 it was determined, during the course of document reviews in the Building turnover process, that Miscel-i laneous Structural Steel Weld Records (MSSWR's) could not be located as
{ procedurally required for all structural steel welds in "Q" designated j buildings. These missing MSSWR's resulted in DIC issuance of CAR 1-C-0031.
i The concerns addressed in CAR's 1-W-0029 and 1-C-0031 as well as other i items listed in the " Introduction" section of this report caused KG&E Construction Quality Control to initiate a limited inspection verification j program. Through this inspection program additional concerns were raised as a result of the inspection verification results.- These results identified i instances of missing welds which had no inspection records, two missing welds 2
which had inspection records, and welds with inspection records that did not completely comply with project inspection and documentation criteria. The i
( results of . the verifications combined with the missing weld inspection records identified the need for a formalized action plan to fully investigate
! \ the concerns and formulate corrective action as necessary. To accomplish a this KG&E QA initiated Corrective Action Request 19, describing the concerns
! and recommending corrective action on October 17, 1984. Based on the correc- '
i tive actions recommended by CAR-19 and additional actions deemed warranted in j support of the investigations, a Management Plan was developed to designate j the nature and extent of the investigations.
! The Management Plan covered three basic categories of investigation and ,
4 evaluation. One category was a process of reinspection to identify 'and '
evaluate actual hardware conditions in the field. A second category addres-sed the programmatic aspects of Structural Steel erection through evaluation of both construction and quality program procedures. A third category addressed related considerations such as other AWS D1.1 applications, evalua-
) tion of missing welds identified during the reinspections, evaluation of 4
acceptable inspection records completed for welds found to be missing, and review and evaluation of surveillances, audits, and reports pertinent to AWS
- welding. Although not ' initially in the scope of KG6E CAR-19, non-welding
! related quality programs were reviewed for comparable programmatic deficien-
- cies. In accomplishing this KG&E ~ and DIC conducted an extensive program ,
- assessment of the Piping, Hanger, Mechanical, Electrical and Civil disci- ,
i plines to ascertain the adequacy of the construction and quality programs I
! ' instituted. This program assessment was conducted by KG&E ~ and DIC Management
! representatives, and concluded that a satisfactory level of confidence exists
- to assure compliance of these to 10CFR50, the FSAR, ANSI N45.2, and design !
- and procedural requirements.
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The intent of the program evaluation was to evaluate the various l j cor.struction and quality programs / procedures to determine their compliance to l the AWS D1.1 Welding Code and FSAR commitments. This evaluation included 3
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2 of 33 l ..
l' relevant aspects of the various related programs from the initiation of
- purchase orders for procurement of structural steel and welding materials, to
{ final installation and quality acceptance. The procedures for receiving, i
, storag;e and handling of materials were evaluated, as well as compliance of l
- j. procedures for training and certification of inspectors to ANSI N45.2.6 and l
- welder qualification to AWS requirements. The procedure reviews included a thorough evaluation from their origination through subsequent revisions, l including an analysis to assure current conformance to design document
! requirements. No findings were noted that were determined to be contributing j factors to inadequacies in AWS D1.1 applications, although some procedural i inadequacies were discovered and reconciled.
All other safety-related programs utilizing AWS welding were analyzed to
{ ensure that the root cause identified as the reason for previous acceptance of deficient structural steel welds was not inherent, or impactive, to these l programs as well. The method of documenting weld inspections, control of i this documentation,. and accountability to assure all required documentation was retrievable was researched for AWS D1.1 welding applications in raceway supports, electrical equipment, mechanical equipment, fire dampers, safety-
, related HVAC ductwork and supports, miscellaneous steel and embed fabrica-l tion, and pipe whip restraints for assurance that problems similar to those
{ encountered in structural steel did not exist. Previously compiled infor-li mation including Construction Self Assessment Reports, KG&E QA Reports and Surveillances, DIC QA Reports, DIC Project Monitoring Program Audits, and DIC Corrective Action Reports were reviewed to determine if the results of
, previcus investigations indicated other potential problem areas relevant to l AWS D1.1 welding. No findings were noted that could be considered to be 1 contributing factors to inadequacies in AWS D1,1 programmatic applications. i
- j. An analysis of hardware installations for other project applications of AWS J D1.1 uelding identified one other area to be investigated for AWS welding j problems. This is in the area of electrical equipment installations where ,
1 the method of permanent installation is by welding the equipment mounting
- frame to foundation embeds. DIC is ' addressing ' this potential problem on j Corrective Action Report No. 1-EW-0046. ~
Reinspection of field welds was conducted utilizing AWS Certified l Welding Inspectors who were also certified to the DIC Quality Program.
j requirements of ANSI N45.2.6. Inspections were performed in strict
! compliance to the Inspection Verification Plan which established inspection ,
i criteria and documentation requirements, and was incorporated into an existing DIC Quality Procedure, QCP-VII-200, and approved by DIC, Bechtel, j and KG&E.
I DIC and Bechtel research substantiated that all welders and welding j procedures applicable to AWS 'D1.1-1975 welding of' structural steel
- installations were qualified in accordance with AWS requirements. Research j by DIC and Bechtel resulted in assurance that the programs and procedures for i the purchase and control of weld filler materials used in AWS D1.1 applica- ;
! tions were in compliance with AWS requirements, and were properly implemented
- on site.
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- Tae retrievability and control of Miscellaneous Structural Steel Wald
{ !
Record.s was thoroughly researched, and a determination made that inadequate implementation of DIC . Construction procedures was the primary contributing l factor relative to retrievability and accountability problems in this area. ;
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3 of 33 i -
An evaluation of the DIC Quality inspection training program demon-1 strated that this program and related procedures were in compliance to ANSI l N45.2.6. Further investigation concluded that Quality inspection training i was appropriate and adequate during the structural steel installation time 4
frame.
- An evaluation of DIC Quality inspection proce,dures and criteria
- applicable to the original structural steel installation / inspection period 4 revealed several procedural inadequacies. A thorough analysis of the j omission of each inspection criterion of AWS D1.1 structural steel applica-j tions was accomplished, with the conclusion that no adverse impact had resulted from these procedural inadequacies relative to AWS D1.1 welding
- inspection.
i i Inspection criteria to be used in the structural steel reinspection
! activities was procedurally -defined and training of all personnel completed j prior to reinspection initiation. Sufficient technical justification was
! established by Bechtel to validate inspection of welds through a predeter-j mined maximum thickness of paint. An analysis of reinspection results j determined the root cause of the previous acceptance of deficient structural l welds to be due to DIC inspection implementation differences relative to
! inspection vs. reinspection techniques, and inadequate implementation of applicable DIC procedures during original inspection efforts. These inspec-tion implementation differences are discussed elsewhere in this report, 1 referencing the Reedy, Herbert, Gibbons documentary included in the Appendix, j section VI.G.
j' Two joints (each missing one weld) of the two thousand six hundred
! sixty-nine (2,669) reinspected (representing more than 11,000 welds) had documentation reflecting the installation of these welds when in reality they were not installed.
! Research revealed no evidence to indicate that either was a case of i deliberate falsification. Additional investigations did indicate that human
! error was the cause of incorrectly documenting these nonexistent installa-1 tions.
- Reinspection found that approximately two (2) percent of the inspected j
welds were not installed as required by design documents. These errors were primarily due to craft / engineering confusion relative to installation drawing j details and requirements. Failure to install these welds and materials, although in some cases determined to be significant in. impact to stress
! allowable calculations, would not have resulted in material or structural i
failure if left uncorrected, j The total number of joints subjected to the reinspection program.was two i thousand six hundred sixty-nine (2,669). These joints were selected by i Bechtel as structurally significant (See Appendix IV. 'D) with the
- - distribution being
- 693 in the Auxiliary Building, 1300 in the Reactor i Building, 265 in the Control Building, 98 in the Diesel Generator Building, j- 36 in. the ESWS Pumphouse, and 277 in the Fuel Building. The reinspection ;
j documented an as found condition regardless of the weld acceptability. All i results were forwarded to Bechtel 'in the form of inspection data sheets for '
evaluation. This evaluation was based upon Bechtel's review of reinspection
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data accumulated and nonconformance reports (NCR's) generated. The evalua-l tion for structural adequacy was made based upon this cumulative data that l'
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4 of 33 reflected the as-built condition of the structurally significant joints prior to any rework or repairs. No deficiencies were identified, which if left uncorrected, would have adversely affected the safe operation of the plant.
The results of this evaluation provides assurance that Safety Related AWS D1.1 structural steel welding complies with all Quality criteria as specified in the related design documents, and is within the tolerances of acceptable deviation as determined by the Architect / Engineer.
Joints that in the as-built condition were determined to exceed the design allowable stresses were all reworked. In addition joints in which the design allowable stresses were not exceeded in the as-built condition but were missing welds, were also reworked.
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- 5 of 33
- II. INTRODUCTION TO CAR-19
! A series of activities as identified below pertaining to weld inspection at Wolf Creek ultimately led to the issuance of KG&E CAR-19 addressing AWS D1.1 Structural Steel welding concerns.
In September, 1980, DIC initiated Corrective Action Report 1-M-0007 due i
to improper inspection technique application, which required 100'. reinspec-tion of all socket welds on small bore piping installed prior to June, 1980.
l Subsequent to this reinspection effort, DIC generated Cerrective Action Report 1-W-0019 on August 17, 1982, due to a significant quantity of fillet
- weld discrepancies being identified, which required 100*. reinspection of all fillet welds on ASME and Special Scope piping haners made prior to April 1,
- 1981. DIC performed a random reinspection of st_uctural steel fillet . welds in February, 1983, in all "Q" designated buildings in the Powerblock to J determine whether structural steel welds may have been deficient as a result i of the same root .. cause relative to CAR 1-W-0019. It was determined from these - reinspection results that an unacceptable percentage of structural
- steel welds were deficient in the Auxiliary, Control, and Fuel Buildings.
- Thus CAR 1-W-0029 was initiated by DIC to implement reinspections, and I nonconformance reports were generated to document and disposition the deficiencies noted.
i As a result of documentation review prior to building turnovers DIC initiated CAR 1-C-0031 in August, 1983, to document that Miscellaneous a Structural Steel Weld Records (MSSWR) could not be located as required by procedures for all structural steel welds in "Q" ~ designated buildings.
!' Nonconformance Reports were generated to document missing MSSWR's in each of
- these buildings.
! KG&E and DIC site management held meetings in May, 1984, to further 2
discuss retrievability of MSSWR's and the problems that had been identified
! to date. Concerns were expressed through KG&E Quality First to KG&E i Construction Management regarding the acceptability of "Use-As-Is" ,
I dispositions given to NCR's written as part of CAR 1-C-0031's corrective action in July, 1984, and KG&E Management requested DIC to generate a
- revision to CAR 1-C-0031 in letter KWCLC 84-814 of July 30, 1984, in response
! to some concerns noted. Revision 6 to CAR 1-C-0031 was generated by DIC in.
l response to KG&E's concerns. .
KG&E Quality Assurance performed a detailed review of DIC CAR 1-W-0029 and 1-C-0031 in August, 1984, identifying numerous concerns to KG&E Construc-
- - tion. In response KG&E Construction began a documentation reconciliation task on August 13, 1984, to determine which safety-related suuctural steel '
i i
weIds did not have' supportive MSSWR's.
j On August 17, 1984, KG&E Construction Quality Control initiated an j Inspection Verification Plan to provide an accurate assessment of the l "as-built" conditions of . safety-related structural steel welds without i MSSWR's. DIC and KGEE Management discussed revision of this ' inspection l program on August 30, 1984.
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KG&E, DIC and Bechtel made a joint presentation to an NRC Task Force on l September 10,.1984, which identified the belief at that time that the problem j was one . of document retrieval, and not a hardware problem. The NRC Task 4
6 of 33 e
Force discussed the problems with KG&E again on September 13, 1984, during which KG&E Management agreed to perform a sample hardware inspection of six (6) randomly selected structurally significant joints in the Reactor, Fuel, Control, Auxiliary, Essential Service Water, and Diesel Generator Buildings.
This inspection resulted in the discovery of missing welds and missing structural. members, which were reported to the NRC by KG&E under 10CFR50.55(e) on September 18, 1984. Subsequent meetings were held with NRC Representatives on September 23, 1984, and September 28, 1984, to status
' inspection efforts and provide information updates. An AWS Welding meeting was held with the NRC on October 19, 1984, on site ' relative to structural steel welding, with a follow-up meeting on October' 22, 1984, in which KG&E Management discussed AWS structural steel welding concerns with the NRC.
On October 17, 1984, KG&E Quality Assurance issued CAR-19 to KG&E Construction to obtain corrective actions associated with AWS Dl.1 structural steel welding. The findings addressed in CAR-19 included missing MSSWR's for safety-related structural steel welds; deficiencies being identified in previously accepted structural steel welds, missing structural welds or missing structural material; and documentation that a weld'was inspected and
! accepted, but no weld was installed.
KG&E and DIC Management representatives subsequently developed a logic chart to organize resolutions . relative to CAR-19 's concerns, a Management i
Plan to implement corrective actions, and published a CAR-19 Corrective Action Schedule to provide a means for tracking corrective action progress.
In addition, KG&E Management contracted Lehigh University to review the problems associated with the structursl welds in the structures at Wolf Creek Generating Station. The results of their review is included in Appendix VI.T of this report.
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.,.' III. CAR-19 OBJECTIVES i
To document a consolidated project plan for the identification, evalua-tion acd resolution of problems associated with Safety-Related AWS D1.1 Welding.
To provide assurance, based on objective evidence, t_ hat AWS D1.1 Valding of Safety-Related Structural Steel complies with all Quality Criteria as specified in. the related ' design documents and is within the tolerances of acceptable deviations as determined by the Architect / Engineer. r To provide assurance that the documentation which supports the inspec-tion of safety related structural steel welds is:
- Available - Complete - Reflects appropriate information - Traceable to the item or activity To evaluate supporting elements of the DIC Quality Assurance Program to
, ensure that those elements were adequately and effectively implemented to demonstrate that the DIC welding of Safety Related Structural Steel, HVAC Supports, Electrical Supports, Pipe Whip Restraints and any other AWS D1.1 safety related welding activities were in compliance with the FSAR (i.e. AWS D1.1 - 1975) and the Design and Construction QA Program Manual, Section 17.1.B.
To eva$uate DIC' Construction / Quality programs in areas other than AWS D1.1 welding to determine the potential of programmatic deficiencies.
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8 of 33 IV. CAR-19, DISCUSSION OF FINDINGS AND CORRECTIVE ACTIONS The KG&E Management Plan for the resolution of CAR-19 was developed by DIC and KG&E Management personnel to document a consolidated project plan for the identification, evaluation and resolution of problems associated with safety-related AWS D1.1 welding. The intent of this plan is to verify that both the hardware and progra=matic aspects of all safety-related activities utilizing AVS DI.1 welding are in compliance with the FSAR and the Design and Construction Program Manual.
The logic chart for the resolution of CAR-19 was developed to illustrate the approach to be used in providing the verifications needed for implementa-tion of satisfactory corrective action. The Corrective Actions as described in the KG&E Management Plan are identified in the flow of activities as designated on the logic chart. The logic chart is included as an attachment to this report in the Appendix, section VI.B.
Five (5) findings were included in CAR-19. The detailed activities and investigativt actions required to implement each Corrective Action are delineated in the KG&E Management Plan. The process of corrective action for each finding generated by CAR-19 entails multiple activities. Each finding and it's respective corrective actions are discussed in detail in the following. Supportive and/or investigatory documentation for each finding as discussed in this section is delineated in the Appendix, section VI.I.
' Finding #1 of KG&E CAR-19 stated, "The results of the Document Reconcil-lation Task Force indicated that 1509 of 6816 MSSWR's for Safety Related Structural Steel Welds are missing".
Six (6) corrective actions were prescribed as appropriate for the resolution of this finding and related concerns. These corrective actions were focused toward programmatic evaluations, procedural criteria evalua-tions, and a reinspection program utilizing certified inspectors. Following is each of the six (6) corrective actions for Finding #1 with an analysis of the investigative actions taken and a summarization of each corrective action's results in accordance with the KG&E Management Plan's directions.
Corrective Action la)
" Based on DIC program requirements assure that all of the welders and welding procedures were qualified to AWS D1.1."
This activity was subdivided into three elements of research. These elements included development of an AWS D1.1-75 Attribute Checklist analyzing individual attributes relative to the welding process. The checklist lists all AWS requirements and compares those requirements with DIC Construction Welding Procedure requirements, in each case citing explicitly how the corresponding DIC procedure addresses separate AWS criteria. This checklist is conclusive data that provides evidence of all AWS D1.1-75 criteria being adequately addressed by DIC Construction Welding Procedure, CWP-506, " Welding of Carbon Steel". An attachment to this checklist documents the procedure review cycle for CWP-506, showing that each revision from 09/14/78 through 1
the current revision dated 05/21/81 was consistently reviewed and approved by b the individuals designated that responsibility.
9 of 33 of this activity was the s.tatistical sampling of AWS
- A second element The total quantity of
" Welder qualifications in accordance with MIL-STD-105D.
retrievable Miscellaneous Structural Steel Weld Records (MSSWR) applicable to AWS welding was initisily identified to define the total population to be used in selecting a sample size. A " Single Sampling Plan for Normal Inspec-tion" was utilized, randomly selecting MSSWR's for review of welders' quali-i fications. This sample included a variety of welders, a variety 1978-1984 of AWS welding procedures, a representative sample of welders during the time frame, and sampling from welders working in all Powerblock buildings.
Identification of welders was taken from the MSSWR s and welder qualification records (W-105). These were then reviewed to assure that each welder was qualified to the weld procedure entered on the MSSWR at the time of weld installatien.
represen-A sample size of two hundred (200) was selected Based as being upon most Table II-A of-l tative, given the previous considerations. (96%) Acceptable Quality Level MIL-STD-105D, DIC desired a ninety-six percent (AQL).
This AQL accepts fourteen (14) rejectable units from a sample of two hundred (200), and rejects the entire population when the fifteenth (15) 3 i rejection of the sample is observed.
Research performed by DIC Welding Engineering revealed thirteen (13) entries on MSSWR's, with only four (4) of these considered "rejec-incorrect table" due to the nature of the discrepancies. All thirteen discrepancies i were due to incorrect entries being made on the MSSWR, with nine (9) of the entered as N-1-1-A-6 rather than thirteen having the weld technique N-1-1-A-6A. These two weld techniques were evaluated by DIC Welding Engi-
~ neering by comparison of attributes and essential variables, and it was l determined that no adverse impact existed. The four (4) entries considered rejectable were due to welders incorrectly entering a welding procedure number for which they were not qualified on an MSSWR.
A Nonconformance Report, 1SN 20984CW, was generated to document all thirteen (13) discrepancies noted, and was recommended for a "Use-As-Is" This Nonconformance Report has been
' disposition by DIC Welding Engineering.
reviewed and disposition concurrence received from Bechtel, closing the NCR.
1 The third element of this activity was a review by Bechtel of DIC Welder Qualification Procedure and the DIC Welding Procedure Specifications to assure compliance to AWS D1.1-75.
Welding Procedure, CWP-502, Bechtel reviewed DIC Construction
" Qualification of Welders", all revisions up to and including Revision 19.
This review indicated full compliance with the AWS D1.1-75 for revisions 1 through 18. However, Revision 19 does. not strictly comply with AWS D1.1-75 in the following areas.
- 1. CWP-502 Rev. 19, Paragraph 3.2 ' allows the DIC Project Welding Engineer to specify joint details not listed-in Appendix II.
I
- 2. Joint designs for figures 5.2, 5.3 and 5.4for of Appendix II do not welder performance comply with AWS D1.1 joint designs l 1
qualifications.
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CWP-502 Rev. 19 does not specify the . test positions for_ AWS D1.1 3.
welder performance qualifications.
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- 4. CVP-302 Rev. 19 does not specify the radiographic or mechanical
) testing requirements for AWS DI.1 welder performance qualifica-tions.
Nonconformance Report ISN21472MW has been generated to document these i deviations and is awaiting disposition.
P Bechtel randomly selected ~ Welding Procedure Specifications (WPS) from MSSWR's applicable to structural welds in the 1978-1984 time frame. The review of the WPS' indicated full compliance with AWS D1.1-75 with one exception, undercut criteria, which was allowed by theThree Wolf of Creek Final the WPS' Safety Analysis Report, Revision 0, October, 1979.
permitted undercut to be acceptable provided the depth did not exceed 1/32 4
inch, which is a relaxation of AWS D1.1-1975 undercut criteria.
The exception to the AWS D1.1-75 undercut criteria exists in Revision 0 of the Wolf Creek Final Safety Analysis Report, Section 3.8.3.6.3.3, dar.ed October, 1979, and was also added by a revision to Bechtel Civil Specifica-tion C-122 and C-132, the design specifications . applicable to the structural steel connections in the CAR-19 reinspection program. Based upon these facts the Bechtel Material and Quality Services Department (M&QS) determined that the WPS' used during erection / installation of structural steel members did comply with AWS D1.1-75. Paragraph 1.1.2 of AWS D1.1 defines the " Engineer" as the duly designated authority who acts for and in behalf of the Owner, and l
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the exception to AWS undercut criteria was documented in the FSAR to comply with this paragraph.
' It is Bechtel M&QS' conclusion that the review of the DIC WPS' and supportive documentation demonstrates that the welding procedures used by DIC during structural steel installation did comply with the AWS D1.1-1975 Structural Welding Code Edition when used concurrently with supportive design documents and the revisions to the FSAR.
In conclusion, the three elements of analysis included in the research l '
performed on Activity la offer assurance that all DIC welding procedures were i
l qualified in accordance with AWS D1.1-75 requirements.
- . Corrective Action Ib) l
" Review the DIC Program for the purchase and control of filler material j
to ensure that only acceptable filler material was used in safety related welds. Assure that both safety related and non-safety related filler materials were properly controlled to preclude improper applications."
This activity was divided into two elements of research, those being;
' the DIC review of. procedures for the purchase and control of filler and base materials, and Bechtel's review for the purchase and control of filler materials.
DIC Civil Engineering performed an in-depth review of the DIC Program for purchase of structural and miscellaneous steel and found the DIC Program to. be in accordance with the requirements of Bechtel. Specifications 10466-C-121 (Purchase of Structural Steel), and 10466-C-131 (Purchase of
' Miscellaneous Steel). These specifications and 'their respective DIC
11 of 33 procedures were found to adequately address applicable requirements for assuring correct material specification, grade, marking, traceability and other Quality Assurance requirements. In addition these specifications and procedures provide for buyer verification of any or all of the established specification requirements.
The DIC procedures applicable to procurement activities are as follows:
AP-VII-01 Development and Approval of Bidders List AP-VII-02 Requisitioning of Daniel Procured Materials, Equipment and Service AP-VII-03 Bid Requests AP-VII-04 Receiving and Processing Bid Proposals
' AP-VII-05 Issuing Purchase Orders and Change Orders .
During a self-initiated KG&E review of safety-related procurement records in January, 1984, several cases were identified in which DIC purchase orders did not comply with all A/E specification requirements. As a result of these findings, DIC initiated a Corrective Action Report (CAR) 1-G-0036, to perform a complete review of all purchase orders to verify compliance to specification requirements. This investigation encompassed the review of f' five hundred thirty-six (536) safety-related purchase orders to assure hardware ' and documentation to be in compliance with specifications. Any discrepancies identified during this review were documented on Nonconformance Reports for resolution by DIC, KG&E and the A/E. Those nonconformances
- identified relative to structural steel were determineG to be all documenta-tion related with no hardware impact. All corrective actions were completed, all Nonconformance Reports resolved and closed, and Ciarrective Action Report 1-G-0036 was closed on 05/24/84.
DIC Civil Engineering accomplished a detailed study of the control and issuance of base materials applicable to structural steel installations.
This review was based upon a thorough analysis of material control require-monts for this application in the following DIC procedures:
AP-VIII-02 Material and Equipment Receiving AP-VIII-03 Identification, Marking and Inspection AP-VIII-04 Receiving Discrepancies AP-VIII-03 Material Storage and Control AP-VIII-07 Material Issue QCP-IV-111 Erection of Structural Steel and Pipe Whip Restraints WP-IV-111 Structural Steel and Pipe Whip Restraint Erection
12 of 33
- This review investigated such areas as the use of Structural Steel Fabrication Requests, requisitioning and issuance of the materisl to craft for erection, maintenance of traceability through heat number transfer for material that is divided, and documentation of this heat number on permanent plant records. DIC Civil Engineering's research concluded that acceptable control and utilization of base materials is maintained through DIC programs and procedures.
Bechtel's Materials and Quality Services Group furnished information based on their research to ensure that the DIC Procurement program had in fact resulted in the proper filler material being purchased and subsequently utilized in structural steel ins +allation activities. This review was documented in attachments to a letter from B. W. Bain of Bechtel Materials and Quality Services to Gary Stanley on 10/16/84. This analysis entailed the following activities: (1) A review of purchase orders / certified material test reports for conformance to AWS D1.1 requirements to verify that all heat numbers for welding filler material are acceptable for structural steel installations, (2) A comparison of all E7018 weld rod heat numbers issued to the DIC Rod Room during the time frame of structural steel installation /
erection to verify that correct filler material was used, (3) A review of the DIC weld filler material issuance control procedure / program to ascertain that welders were only issued filler material for the welding procedures to which they were qualified, and applicable to the work being performed.
The results of these investigations were positive, with no discrepancies being found. This effort further substantiates that correct weld filler material was utilized in structural steel erection.
DIC Welding Engineering reviewed the procedural details relative to issue of weld filler materials, identifying the control of filler materials explicitly for field issue as well as test shop issue. This review indicates that control is adequate, with supportive documentation, thereby assuring proper filler material issue. DIC Welding Engineering also noted that Quality Inspection performed, as required by DIC Construction Procedure QCP-VII-200, Inspection of Welding Process, random surveillances of welding process attributes. Among the attributes covered by this surveillance are that filler material control is implemented according to applicable welding procedures, and that the welder is currently qualified to the weld technique to be employed.
bIC Welding Engineering performed a review of the specification and procedural requirements relative to the purchase, issue and control of filler materials. It was determined that only E7018 electrodes have been used in AWS Dl.1 applications, as required by all site AWS Dl.1 welding techniques.
All E7018 electrodes purchased by DIC are required to conform to AWS A5.1 (Specification for Mild Steel Covered Arc Welding Electrodes). To substan-tiate this f act DIC Welding Engineering performed a review of all purchase orders that involved E7018 electrodes. All these purchase orders were proven to have adequate documentation to justify that the electrodes conform to AWS specification AS.I.
l Based upon procedural requirements, weld filler material issue controls, l
and random Quality Inspection surveillances, assurance has been provided that l
I only acceptable filler materials have been utilized and that control has been '
as required for all AWS D1.1 applications.
13 of 33 Corrective Action Ic)
" Evaluate the adequacy of the DIC inspection criteria and procedures to determine if these elements could have adversely impacted the inspection results. Document and provide this evaluation to KG&E QA for review prior to inspection implementation. Any changes in inspection criteria and procedures shall be provided to KG&E QA for review prior to implementation."
This activity was divided into two elements. The first element was a review of DIC weld inspection criteria contained in QCP-VII-200. The inspection criteria was reviewed to determine compliance with AWS D1.1-75 and Bechtel Specifications 10466-C-132. The second element was to evaluate the results and determine if these elements could have adversely impacted the inspection results.
An AWS D1.1-75 and Bechtel Specification attribute checklist was developed by DIC Quality Engineering. Inspection criteria defined The in QCP-VII-200, Appendix II was reviewed in accordance with the checklist.
review indicated that currently QCP-VII-200, Revision 20, meets or exceeds the inspection criteria as delineated in AWS D1.1-75 and the Bechtel specifications. The review of the QCP-VII-200 procedural history revealed most criteria was presented verbatim from AWS or the Bechtel specification.
Other criteria, although not verbatim, was interpreted as being in compliance with AWS and the Bechtel specification. The review did indicate four (4) areas of inadequacy. The following is a list of these areas and the time frame affected:
- 1) Oversized Welds - 4/18/78 - 5/2/84 (Revisions 2 - 19)
Inspection criteria for oversized welds was not delineated in QCP-VII-200 during this time frame.
- 2) Convexity - 3/30/77 - 1/18/83 (Revisions 0 - 15)
During the time frame 3/30/77 through 12/15/81, QCP-VII-200 required the Quality Inspector to utilize the Weld Technique Sheet for compliance. During the time frame 12/15/81 through 1/18/83, QCP-VII-200 required: " Fillet welds may be slightly convex / concave." During the entire period, the following criteria was not delineatedat' in QCP-VII-200 or the Wald outside corner joints, the Technique Sheets. "Except convexity shall not exceed the value of 0.1S plus (+) 0.03 inches where S is the actual size of the fillet weld in inches."
- 3) Cracks - 12/15/81 - 5/26/82 (Revisions 9 - 11)
Inspection criteria for cracks was not delineated in i l
QCP-VII-200 during this time frame. .
I j
- 4) Lack of Fusion - 12/15/81 - 09/22/83 (Revisions 9-16)
/
Inspection criteria for lack of fusion was not delineated in b QCP-VII-200 during this time frame.
performed determine if these procedural l
An evaluation was to The inadequacies could have adversely impacted the inspection results. l I following is the results of the evaluation:
l
14 of 33 10466-C-122 and
- 1) Oversized welds: Bechtel Specifications This revision required 10466-C-132 were revised 4/18/78.100*. or 3/8" greater than oversized welds not to exceedDuring a civil retrofit review specified, of Bechtelwhichever is less.and DIC procedures, this procedural specifications inadequacy was identified. Nonconformance Report ISN 16988CV documented this deficiency and resulted in a recommended disposition of "Use-As-Is". Based on Bechtel's concurrence with this disposition, the omission of this item is considered to have no adverse impact to inspection results.
4
- 2) Convexity - Bechtel specifications required welds to meet convexity limits as delineated by AWS D1.1 until 12/08/82.
After this date, Bechtel specifications altered the convexity requirement by stating that fillet welds need not satisfy
- convexity limits of AWS D.1.1. DIC Procedures have delineated criteria as " welds may be slightly. concave / convex". Based on procedural control and the relaxed specificationtocriteria, inspec-this item is considered to have no adverse impact tion results.
3 & 4) Cracks and Lack of Fusion - Inspection criteria for cracks and lack of fusion were inadvertently omitted during general revision from DIC inspection procedures on 12/15/81. The criteria was reinstated in site procedures on 3/26/82 for cracks and 9/22/83 for lack of fusion. The absence of this
{ criteria occurred af ter the completion of main frame struc-i tural steel erection (5/81). However, to establish that there was no impact in other AWS D1.1 applications due to the 1
omission of these items, twenty-six (26) DIC welding inspec-tors were interviewed. 'Ihese interviews were used to determine the following.
~
l
- 1) Procedures'used for training and inspection.
4'
- 2) Inspection attributes addressed during training.
- 3) Inspectors' awareness that cracks / lack of fusion criteria was omitted from procedures for a period of time.
- 4) Did inspectors inspect / reject welds for cracks and lack
' of fusion? r The inspectors interviewed had. inspected structural steel welds as well as HVAC and electrical support welds during the time frame in which the 4
occurred. .In all cases . inspectors _ indicated that procedural deficiencies Inspectors they had inspected / rejected welds for cracks and lack of fusion.
were aware of the procedural deficiencies, however, they continued to inspect / reject for cracks _ and lack of fusion. This is further substantiated The rejection based on re-inspection results conducted on structural steel. the total
' rate for cracks and lack of fusion is -minimal when compared to number of welds inspected. !
l In conclusion, tho' review of weld inspection criteria utilized during- '
the history of this project did indicate _ areas of procedural deficiencies.
these I However, based on the above information, it has been determined that ;
' inadequacies did not result in generic inadequacies in AWS D1.1 welding.
1
^
l 15 of 33 1 l
4 Corrective Action id)
"Obtain a documented evaluation to determine the validity of inspections performed with the presence of paint on the weld."
This activity was divided into three elements: obtain information from l other utility /AE's that have developed a validation plan, with a subsequent review by DIC Welding Engineering and Bechtel and the addition of site specific requirements and justification, and Bechtel's submittal of a
' position letter' to KG&E for approval.
DIC Management obtained information from Carolina Power & Light Co., and
' Ebasco Services Incorporated relative to the validity of inspections per-formed with paint on the welds. This information was utilized by Bechtel in conjunction with their additional research to establish an A/E's position to KG&E. In summary, this position, more explicitly defined in letter BLKES-1348 from C. M. Herbst to G. L. Fouts, is: "With the exception of a number of attributes, fillet welds which have been coated with up to four (4) mils of primer and in some cases, up to an additional ten (10) milsThose of topcoat can attributes be visually inspected to the AWS D1.1 acceptance criteria.
which cannot be fully evaluated are of little or no concern on the structural steel at WCGS."
This letter was submitted to KG&E, and subsequently KG&E discussed the j validity of inspections performed with paint on welds with NRC representa-tives. KG&E Nuclear Plant Engineering reviewed letter BLKES-1348, concurring l
with the position stated by Bechtel in their letter KNPLKWC 84-065 of i
November 13, 1984 1
Corrective Action le) l
" Utilize personnel certified to ANSI N45.2.6-1978 for the inspection of safety related structural steel welds. Inspections shall be performed in accordance with the DIC Quality Program and training shall be performed and documented to assure that inspectors are cognizant of the DIC Quality program
! requirements."
1 This activity was divided into three elements. The first element required incorporation of the CAR-19 Inspection Verification Plan into DIC The Construction ' Procedure QCP-VII-200, " Inspection of Welding Process".
second element required inspection personnel to be certified in accordance with the' DIC certification program and ANSI N45.2.6-1978. The third element defined that the inspectors' site specific qualifications would be limited to the reinspection of structural steel welds in accordance with QCP-VII-200.
The Inspection Verification Plan was developed through the combined efforts of DIC, KG&E, and BPC personnel. Revision 0 was reviewed and approved by KG&E . Quality Assurance on 10/19/84.not Although Revision 0 to the issued until 10/19/64, j Inspection Verification Plan in QCP-VII-200 was some inspections were performed prior to this date by personnel qualified to accomplish these inspections. The same inspection criteria was utilized in these. efforts, and all personnel performing these inspection functions were evaluated to ascertain their qualifications to be concurrent with the later
- certification requirements for KG&E CAR-19. Further discussion of these personnel is included in this discussion of Corrective Action le) on the i
Ic of 33 following pages. A meeting was held with the Quality Inspection personnel on 10/20/84 to discuss the impact of the Inspection Verification Plan on their activities and to ensure their understanding of the plan. As a result of this meeting, a new revision, Revision 1, was issued to incorporate inspector Revision 1 of the Inspection feedback and KG&E Quality Assurance comments.
Plan was then incorporated into DIC Quality Procedure Verification On 11/2/64 KG&E Quality QCP-VII-200 with Procedure Change Notice 014 Assurance, DIC, and BPC personnel held a meeting to address KG5E Quality Assurance concerns on gouges. Subsequently Revision 1 to PCN-014 was issued to incorporate these concerns into the Inspection Verification Plan.
It was decided that all personnel performing inspection verifications under the CAR-19 Inspection Verification Plan should not only be AWS Certified Welding Inspectors, but also be s ite certified under ANSI N45.2.6-1978.
ANSI N45.2.6-1978, Section 3.5.2 makes the following recommendations for education and experience when certifying Level II personnel: .
- 1. One year of satisfactory performance as a Level I in the corresponding inspection, examination or test category or class, or .
- 2. High School graduation plus three years of related experience in equivalent inspection, examination, or testing activities, or
- 3. Completion of college level work leading to an Associate Degree in a related discipline plus one year related experience in equivalent inspection, examination, or testing activities, or .
- 4. Four year college graduation plus six months of related experience in equivalent inspection, examination, or testing activities.
When considering the certifiability of candidates, DIC management ensured that all personnel met the recommendations of section 3.5.2, ANSI N45.2.6-1978.
A training program for inspectors was established on 10/17/84. The l program consisted of self study material covering the following subjects:
- 1. Quality Orientation
- 2. DIC Administrative Procedure AP-VI-02, "Nonconformance Control and Reporting"
- 3. The KG&E CAR-19 Inspection Verification Plan -(PCN-014 to l QCP-VII-200)
Additionally, a meeting was held on 10/20/84 with the inspectors to i explain the contents of the Inspection Verification Plan, and to answer any questions they might have about the program. In order to ensure the capability' of each candidate, a Field Practical Examination was also ,
I administered.
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I
! 17 of 33 l
Certification files were compiled on each inspection candidate and are
! available for review in DIC Quality Training. Each file contains a copy of the inspectors resume', a signed copy of the Education / Experience evaluation
- form, a copy of the inspector's eye examination, the document of certifica-J tion, the field. practical examination, and the letter of recommendation.
1 Additionally there is a training summary documenting the completion of required training and the training conducted on DIC Quality Procedure QCP-VII-200, PCN-14, Fevision 0 and Revision 1.
Each certification file was reviewed by the DIC Quality Training
> Supervisor to ensure all candidates met the recommendations of ANSI N45.2.6-1978. Each file was again reviewed by the DIC Project Quality Manager (DIC's Certifying Authority) prior to the signing of the Document of Certification. The completed certification files were audited by KG&E Quality Assurance with no findings.
Eleven (11) personnel (Inspectors A through K) were involved 'in Structural Steel Inspection Verification prior to the issuance of KG&E CAR-19. These personnel were attached to DIC Engineering and were qualified, but not certified prior to the issuance of KG&E CAR-19.
In addition to the eleven (11) personnel above, an additional eleven (11) persennel (Inspectors L through V) were involved in Structural Steel
~
Inspection Verification after the issuance of KG&E CAR-19. The certification status is given below:
i i
i i
i J-r 1
4 4
- =
18 of 33 STATUS INSPECTOR Certified
( 1) A Certified
( 2) B Certified
( 3) C Certified
( 4) D Certified
( 3) E
( 6) F Qualified *
( 7) G Qualified
- Certified
( 8) H Certified
( 9) I (10) J Certified Certified (11) K (12) L Certified Certified (13) M Certified (14) N Certified (15) O Certified (16) P Certified (17) Q
' Certified (18) R Certified (19) S (20) T Not Qualified **
Certified (21) U Certified (22) V NOTES:
were involved in Structural Steel Inspection
- Personnel who Verification prior to the issuance of KG&E CAR-19, but were not involved in Inspection Verifications after the issuance of KG&E CAR-19 were investigated and qualified, but were not certified as they had already left the site or were assigned to other non-inspection related activities.
- Several attempts were made to verify Inspector T's experience after he left site. DIC Quality Training was unable to verify enough experience to qualify Inspector T's to ANSI N45.2.6-1978. All of Inspector T's work was reinspected by certified personnel.
Corrective Action If)
/ " Perform a 100*. reinspection of all structurally significant safety identification of " structurally related structural steel welds. The significant" welds shall be made by the Architect - Engineer."
19 of 33
" Structurally significant" joints were defined by Bechtel as all field welded joints 'which support or potentially support safety related equipment and building components for the purpose of this Corrective Action activity.
This basically included all field welds on structural and miscellaneous steel with the exception of handrail, toeplates, grating, checkered plate, stairs, ladders and monorail supports. These are non-Q items which typically see significant service loads during the construction process. Some are designated as II/I, however, II/I seismic loads are considered to be less severe than service loads. Monorails have been load tested as part of startup procedures, and were therefore not included in the scope of structur-ally significant items requiring reinspection. The joints were selected by Bechtel based on a review of erection drawings prepared by the structural and miscellaneous steel fabricators and a review of Field Change Request (FCR's),
Nonconformance Reports (NCR's), Construction Variance Requests (CVR's) and Structural Steel Fabrication Requests determined applicable.
The DIC Nonconformance program, as defined in DIC Construction Procedure AP-VI-02, "Nonconformance Control and Reporting", was utilized to obtain and document a suitability for service evaluation of welds that were inaccessible
, due to physical location or embedment in concrete. All deficiencies identi-fled during reinspection activities performed in accordance with Procedure Change Notice - 014 to DIC Construction Procedure QCP-VII-200 were identified on nonconformance reports for further dispositioning and resolution.
Bechtel performed a case by case evaluation of each structurally
, significant joint inspected according to the data furnished on Inspection Data Sheets and nonconformance reports. Their evaluation provided a determination of whether each structurally significant joint's as-built condition met design allowables, whether the as-built condition was a significant deficiency in accordance with 10 CFR 50.55(e), and whether any rework or repair to each joint was required.
The following is a statistical summary of the evaluation completed by ,
Bechtel on all structurally significant joints:
~
. . . - _ _ . . . - - =
20 of 33 TOTAL AWS WELDING INSPECTIONS AND ENGINEERING EVALUATIONS JOIhTS ADDITIONAL SIGNIFICANTLY I TOTAL JOIhTS JOIhTS PIQUIRING JOIhTS TO BE DEFICIENT JOINTS (IOCFR30.55(e) )
BUILDING JOIhTS INSPECTED EVALUATED REWORK (1) REWORKED (2) 7 42 0 AUXILIARY 693 693 693 13 0 1300 1300 1300 69 REACTOR 3 18 0 CONTROL 265 265 265 DIESEL 2 2 0 GENERATOR 98 98 98 1
0 6 0 FUEL 277 277 277 ESWS 0 0 0 PUMPHOUSE 36 36 36 81 83 0 TOTAL 2669 2669 2669 u
/ (1) DESIGN ALLOWABLE STRESSES ARE EXCEEDED IN THE AS-BUILT C (2) DESIGN ALLOWABLE STRESSES ARE NOT EXCEEDED IN THE AS-BUILT CONDI-TION. THESE JOIhTS ARE BEING REWORKED PER KG&E MANAGEMEhT DIRECT l TO INSTALL MISSING AND UNDERLENGTH WELDS.
4 Finding #2 of KG&E CAR-19 stated, "An Inspection Verification effort of safety related structural steel welding, undertaken by AWS certified weld inspectors identified several areas of deficiencies. These deficiencies are i categorized as: undersized welds, weld defects, incorrect configuration, weld underrun, and weld undercut."
One (1) corrective action was determined to be appropriate for resolution of this. finding, although this primary corrective action was subdivided into seven (7) research/ data accumulation activities.
. Corrective Action 2a)
" Determine and document the " root cause" of the previous acceptance of deficient structural welds. Analyze the HVAC Support, Electrical Support, Pipe-Whip Restraint and any other safety-related program utilizing AWS D1.1 Welding to ensure that the same " root causes" inherent in the structural steel welding program were not generic to other programs."
This summary reviews activities 2a-1 through 2a-7 of CAR-19 to determine the root cause of the previous acceptance of deficient structural welds and analyzes those ,roor causes to determine if . they were inherent to - other safety-related programs utilizing AWS D1.1 welding.
21 of 33 4
A review of DIC Quality procedures was performed by Quality Engineering to determine if any historical procedural inadequacies could have been a contributor to " root cause". Although some historical deficiencies in inspection criteria were found to have existed, research demonstrated that some of the procedural inadequacies occurred after the vast majority of structural steel erection activities had been completed. Interviews with a sample of Quality Inspectors revealed that inspectors were cognizant of the omission of two other criterion (lack of fusion and cracks) during an appli-cable time frame, but inspected for these deficiencies in spite of their omission. Based upon this cumulative research procedural weld inspection inadequacies are not considered to be contributors to " root cause" of previous acceptance of deficient structural welds.
DIC Inspection training and certification procedure AP-VI-01 was used to train and certify Quality inspection personnel during the structural steel to erection time frame. This procedure was analyzed to verify compliance ANSI N45.2.6-1978, and was found to be in accordance with ANSI requirements.
An evaluation of ANSI N45.2.6 requirements revealed that DIC procedure AP-VI-01 was in full compliance to ANSI requirements for the structural steel erection. time frame and through all subsequent revisions to date.
1 The " root cause" of the previous acceptance of deficient structural welds has been determined to be due to inspection implementation and inadequate implementation of related procedures. Each of these contributing factors has several facets that are considered to be partial reasons for
" root cause".
Differences in inspection techniques and consideration of inspection attributes for the original inspection time frame vs. the CAR-19 reinspection time frame are definite root cause contributors. The differences indicated are common to the nuclear construction industry and have been recognized as prevalent at many projects. A white paper documentary prepared by recognized nuclear construction consultants Reedy, Herburt, Gibbons and Associates, Inc.
dated August 11, 1983, clearly defines the subject dif ferences during their
' in-depth analysis of weld inspection on nuclear sites. (See Appendix IV.G)
The differences cited, inspection technique and inspection attributes, are addressed in section I of this white paper, " Continuous Measurement of Fillet Welds". The paper states that until about 1980 accepted inspection practica did not entail 100% physical measurement of each inch of welding, but rather depended upon individual inspector's evaluation of the weld's acceptability. Around 1980 QA/QC Inspectors began using fillet weld gauges to measure each inch of fillet weld to verify that the specified minimum weld size was met for the continuous length of weld. This physical measurement gradually replaced the previous accepted practice of visual judgement. The paper concludes that there has been a progression of the practice of physically measuring each inch of weld to a serious extreme.
The documentary cites that there is no requirement either, in the. ASME Section III Code or AWS D1.1 Standard to continuously measure the full length of fillet welds. Both ASME and AWS permit deviations from minimum size fillets as documented in ASME NB/NC/ND - 4427 and paragraphs 8.15.1.7 and s
9.25.1.7 of AWS D1.1. The paper further contends that inspections can and
'- should be made on a random basis to determine nominal sizes with no detriment to safety. Additional sections of this documentary address " Undercut Provisions of AWS D1.1" and " Encroachment on Minimum Thickness" with similar conclusions.
' 22 of 33 r
DIC research has shown that the inspection technique ireplemented during erection / inspection of structural steel at Wolf Creek was in accordance with common industry practice as stated in the previously referenced docueentary.
Inspectors were of the understanding that visual judgement was acceptable as an inspection technique in checking for nominal weld size, and that visual
- cvaluation rather than 100% physical measurement of fillet welds was accep-able for assuring that welds met visual inspection attributes.
l Given these considerations, one should expect a reinspection program i
using current applicable techniques to find deficiencies in welds previously accepted. The reinspection technique is one of 100% physical measurement of all attributes applicable rather than the visual judgement initially employed as acceptable during the structural steel erection time frame, i
With the previous considerations in mind, an examination of the weld deficiencies identified during reinspection and their relative significance i to the overall integrity of the initial inspection effort is in order.
i _
l The scope of the CAR-19 reinspection effort identified two thousand six hundred sixty-nine (2,669) joints requiring reinspection. Of the two l
thousand six hundred sixty-nine (2,669) total joints, two thousand eight j
hundred seventy (2,870) welds exhibited discrepancies of the more than
- eleven thousand (11,000) welds reinspected according to procedure i QCP-VII-200, Procedure Change Notice 14. Each weld reinspected could have ;
potentially contained five (5) categories of deficiencies accordirig to the
+
method utilized for tracking during the CAR-19 program, those being:
i
- undersize, defects (cracks, lack of fusion, incomplete penetration, overlap, slag inclusions, porosity, craters), underrun, undercut and configuration.
Of the two thousand six hundred sixty-nine (2,669) structural joints in-spected, the following quantities of weld deficiencies were noted by cate-i gory: 1,061 undersize, 330 defects, 476 underrun, 107 undercut, and 1,562 j configuration. ,
4 i The quantities of deficiencies noted for the three categories following
! are minor based upon a percentage comparison to the total number of welds reinspected. The approximate percentages for each of these three categories i are, underrun 4%, undercut 1%, defects 3%. These percentages are within expectations considering reinspection emphasis and the previously noted differences in inspection technique and accepted inspection practice.
i Further statistical analysis revealed a majority (more than 60%) of the welds rejected for undercut discrepancies to be in excess of the 1/32" allowable undercut criterion by less than 1/16". A majority (approximately 60%) of the welds found to be underrun were underrun by less than 1/2". An analysis of i the attributes contained within the ' defect' category revealed only small l
. quantities in each. Based on the above statistical analysis , the discre- l pancies identified in the categories of underrun, undercut and defects are i not considered to be contributors to the root cause that previously accepted welds were found deficient upon reinspection. 1 The quantity of welds rejected that did not meet the minimum leg size as specified on - the design document, or exceeded the code allowable 1/16 4
inch undersize for less than 10% of the length of the weld, represents a j . percentage of 9% deficiencies for the total welds inspected. Discussions with DIC inspection personnel and Quality Management aware of approved ,
inspection practices utilized during the structural steel' erection time frame indicated that inspection methods .were similar for this period to 1
4 1 l
- _ - ._ _ _ _ _ _ ~. ._. - - . _ _ . ~ _ ~ , _ _ _ _. _ - - - . __ ____ '
23 of 33 3
i those described in the previously addressed documentary by Reedy, Herbert, "ibbons
, and Associates, Inc. Of the welds identified as being undersize, more than 90*. were undersize by less than 1/8", further substantiating that inspection methods were as previously described. Based on the above evaluation, the quantity of deficient welds identified as being undersize is considered an indicator that previously accepted inspection techniques was the root cause of previously accepted welds being found deficient upon reinspection.
The quantity of welds indentified during reinspection exhibiting configuration deficiencies represented 13*. of all deficiencies for the total welds inspected. Of the total number of deficiencies, more than 80*. were revealed by research to be directly attributable to one design change implemented in February, 1978. This Design Change Notice C0011, Rev. 7 j dated February 23, 1978, changed detail 10 on drawing C0011 to limit the length of the return welds on beam clip angle to embed plate welds. The significant number of discrepancies identified in this category indicates that the design change was not given sufficient emphasis by DIC Engineering,
' craft, and Quality Inspection to enable deviations from this requirement to be adequately controlled. This category is the largest single contributor to
" root cause" of previously accepted deficient structural welds. Bechtel, as the Architect Engineer, performed. an evaluation of all welds reinspected to i determine which welds were acceptable from a technical viewpoint relative to allowable stress calculations and which welds would require rework in order to meet this criterion. From this evaluation 2389 joints were determined to be technically acceptable whereas 81 required rework. These statistics,
( revealing that 97% of the joints reinspected were technically acceptable, are f.ndicative that the relative degree of significance of the deficiencies identified due to reinspection is minor.
j Those areas utilizing AWS D1.1 welding other than structural steel were i identified as: Pipe whip restraints; miscellaneous steel and embedment fabrications; fire dampers and safety-related ductwork and supports; elect-rical raceway supports; electrical equipment installation; and stud welding. ,
Previously compiled information including Construction Self Assessment Reports, KG&E QA Reports and Surveillances, DIC QA Reports, DIC Project Monitoring Program audits, DIC Corrective Action Reports and correspondence
' was reviewed to determine results of previous investigations of AWS D1.1 welding. No findings were noted during this review that could be considered contributing factors to root - cause. Electrical II/I support welds were reinspected by Bechtel (ELKC: 009) through the " Sampling and Inspection Program for Electrical Support Welds" (7/84). Three hundred nine (309) were inspected and found acceptable. Electrical Quality Welding Inspectors performed inspections on Class IE support welds racewa'y (8/82). Pipe whip restraint welds were 100% nondestructively tested. HVAC ductwork support
. welds were 100% reinspected through implementation of DIC Corrective Action
- Report CAR-1-M-0012 and a traveler system was initiai:ed to maintain better control and accountability (3/82-1/83).
Programmatic elements utilized in the inspection and documentation of the various applications of AWS D1.1 welding differed depending upon the Quality discipline responsible for inspection activities. The following s methods were utilized in the applications noted to provide inspection documentation:
24 of 33 i
a) Raceway Supports - Raceway Support Checklist b) Electrical Equipment - Quality Equipment Mounting Checklist in addition to MSSWR's c) Fire dampers and safety-related ductwork and supports Mechanical Travelers 1
5 d) Miscellaneous steel and embed fabrication - MSSWR's e) Stud welding to embeds - Surveillance Reports
- f) Pipe Whip Restraints - MSSWR's in addition to Nondestructive Examination Reports q
All the methods utilized above were effective in providing , inspection assurance and documentation of the respective activities when properly implemented. The travelers utilized as well as the other checklists noted provided a closed loop system where individual accountability for a weld was required, controlled, and documentation verified accurate and complete by Quality personnel. Conversely Miscellaneous Structural Steel Weld Records 3 (MSSWR's) were used in an open-ended system for Main Frame Structural Steel Installations where craft construction personnel were responsible for con-trol, maintenance and proceising of this record following its completion.
This system proved less than satisfactory in some applications, resulting in
(~
Corrective Action Reports.
In summary the programmatic elements as described in DIC procedures for each application of AWS D1.1 welding are adequate when properly implemented by the persons responsible for those activities. MSSWR's utilized in documenting structural steel weld connections were the subject of inadequate implementation of procedural requirements, resulting in the problems being addressed in this report. The research accomplished in completion of this activity revealed no inherent " root cause" generic to all programs utilizing i AWS D1.1 welding, but rather indicates that the root cause of the previous acceptance of deficient structural welds was as delineated earlier in this section.
Finding #3 to CAR-19 stated, "A small number of safety related structural steel welds were not made or had missing material."
Corrective Action 3a)
" Forward the "as-built" information to the Architect / Engineer via an NCR to obtain an engineering evaluation and disposition".
All missing welds or missing material detected in the reinspections performed were documented on nonconformance reports reflecting the as-built condition found by inspectors. Of the two thousand six hundred sixty-nine (2,669) joints reinspected (more than 11,000 welds) only two hundred
- seventy-three (273) welds were identified as missing where the applicable design drawing required their installation. Of the two hundred seventy-three
25 of 33 welds not installed, one hundred twenty (120) were applicable to the polar crane girder radial stops (44%), ninety-seven (97) were due to beam seats not installed (36%), eighteen (18) were due to missing welds on six (6) pressurizer support welds (7.0%), and the remainder (38) due to missing welds on clip to beam or plate installations (13%).
Under the purview of KC&E Construction, a detailed investigation was undertaken by DIC Engineering and Management personnel to determine the root causes of missing welds and materials in each case. Significant points of that investigation included: grouping of missing welds / materials into categories to aid in research; compilation of factual data and analysis for trends / patterns; a thorough review of all applicable design change documents that may have deleted some of the items in question; visual examinations of the areas where installations should have been made; and interviews with craftsmen, craft supervision, DIC Engineering and Quality personnel for information that may have added to root causes.
Missing welds and materials were grouped into categories based on similarities that could be determined to exist in function or construction sequence. Five groups were defined, those being: beam seats and attachment welds, pressurizer support welds, Polar Crane girder radial stop welds, miscellaneous materials and associated welds, and beam to channel clip welds (for one application only). Each of these groups is discussed in detail in the following paragraphs in presenting the respective data accumulated and the conclusions drawn.
Beam seat installation welds accounted for ninety-seven (97) of the missing welds identified. Upon investigation several reasons were found as contributing factors to the root cause of failure to install beam seats as required. All beam seat connections in question were relevant to installa-tion detail 10 on drawing C0011, which gave no required weld size, but referenced note 14. Note 14 stated, "When end reaction exceeds maximum weld size capacity provide seat angle." Discussions with personnel available who were involved with structural steel installations revealed that this note may have been incorrectly interpreted as an ' option' for beam seat installation.
This resulted in a craft opinion that the beam seat was intended as a con-struction aid to be used only during the erection process and then removed.
This contention is supported by the fact that ninety-three percent (93%) of the areas / records examined pertaining to beam seat installation revealed that the beam seats were installed prior to the beam's installation. Seventy-two percent (72%) of the embed plates investigated showed evidence of temporary welds made to attach a beam seat as a construction aid during the erection sequence, but the beam seats were not found installed upon field investiga-tion. A majority of the beam seat associated welds missing were the beam seat to beam welds, which further indicates the questionable beam seats were tack-welded to the embed, used as a construction aid, then removed prior to welding to the beam. These above factors substantiate that the root cause of missing beam seat welds (i.e., beam seats not installed) was due to a mis-understanding of the beam seats' intended application as a permanent instal-lation. This root cause conclusion is supported by the data accumulated and discussed in the preceding paragraphs. All missing beam seats and their respective required welds were installed as a part of KG&E and DIC Manage-ment's direction.
s r
r
26 of 33 The missing pressurizer support welds totaled eighteen (18) welds on six (6) supports. The six (6) supports with missing welds are all of the upper supports for the pressurizer beam foundation, and all six (6) supports were found to be welded identically to each other. One inspector performed all final visual inspections of the pressurizer supports, indicating a possibility of human error being a contributor to root cause. Investigation results indicatec a misinterpretation of erection details and requirements as the primary root cause of the eighteen (18) missing welds. Twenty-four (24) welds not detailed as required installations were added but not required by design drawings. The conclusion reached for root cause of the missing welds on the pressurizer supports is that DIC construction craft and Quality personnel misinterpreted the installation details and applied this misinter-pretation consistently in the construction and inspection of all six supports. Nonconformance report ISN 20509CW was generated to document these circumstances and all missing welds were installed as a part of the disposition.
The Polar Crane girder radial stops were the subject of one hundred twenty (120) missing welds. These missing welds are documented on noncon-formance reports ISN 21308CW, ISN 21309CW, ISN 21310CW and ISN 21311CW.
Facts gathered during the investigation of these missing welds indicate that a series of drawing revisions and misinterpretation of erection installation details resulted in DIC construction error in not making all required welds on sixty (60) radial stops. The appropriate facts are as follows:
/' American Bridge Drawing E117 (C-121-8360) was revised concerning the radial stop connection. Two of the three revisions to section A were attempts to clarify the desired weld configuration at the radial steps.
Revision B to American Bridge drawing E117 was produced to clarify where actual welds were expected. .
Revision C of Drawing E117 in part added "one side only" to the inner "C" portion of the radial stop welds.
Bechtel Drawing C-OS2963 concerning the polar crane girder radial l stop welds was altered at Revision 6 to note on Section A that the l weld on the inner "C" indention was to be made on one side only. I l
The MSSWR's documenting the radial stop welds made indicate 1 erection during 2/80-3/80, before American Bridge drawing E117 J
clarified the installation detail on Revision E, dated 12/80.
Upon reinspection NCR #1SN 21196CW was initiated describing the !
deficiency in nonexistent radial stop welds. The NCR was voided in-process I by the CAR-19 Inspection Supervisor due to a misinterpretation of require-ments according to details on the American Bridge drawing E117, that seemed to indicate a weld installation detail requirement concurrent with the actual welds found installed during reinspection. Based upon the preceding facts, it is concluded that the root cause of missing Polar Crane girder radial stop
~r welds is due to unclear weld detail installation requirements as projected on the American Bridge drawing E-117, and subsequent incorrect interpretation of weld installation requirements by DIC personnel.
1 27 of 33 .
'i The missing welds identified for installations involving other
!- miscellaneous materials and welds missing are of a smaller quantity.
[ Thorough investigation revealed the root cause of these missing welds to be due to a lack of formal follow-up and inadequate statuses of completed work and the subsequent completion of unfinished work. The missing welds on the Incore tubing supports revealed that all investigatory information supports the hypothesis that these missing welds were not installed due to oversite.
The four lateral support brackets, two at each of the vertical angle supports (Incore tubing supports) located 32' -
2 3/4" north of the Reactor Center
! Line and 4' 10" east and west (one each direction) of Reactor Center Line on Drawing GOS2919 were addad by revision to drawing GOS2924 after the supports had been presumed completed.
Nor.conformance report ISN 21273CW documents missing welds on channel clips to beam attachments. The channels that American Bridge Drawing
- C121-10675 shows welded to a beam web along A2 at Elevation 2042' are bolted instead. The channel clips are bolted to the web using the same bolts as 3
removable beams on the opposite side of the web. Research found that the installation of the channel and removable beam was late in the construction
- sequence of this area, also. Since the channel clips and removable beam clips
, are bolted through a beam web with the same bolts, the channel clip attachmer.t welds were probably assumed to be unnecessary by the construction personnel responsible for installation.
If the removable beams had been disconnected for the purpose of
- construction, it would have become necessary to weld the channel clips to the beam web .st that time. The beams and channel in question were installed late
(- in the construction sequence of the area, removal of the beams never became mandatory, the welds were not a recognized priority and were never installed as required. The root cause of these missing welds is due to DIC error in assuming the bolted connections were acceptable rather than the required welds. In the miscellaneous group, investigations revealed that welds or I
material found missing were those welds or materials ' that would not impede construction progress related to that connection.
Findits #4 to CAR-19 stated, "One (1) weld was documented as having been l inspected.when in reality the weld was not made. (Ref. NCR ISN 20495CW) . "
Corrective Action 4a)
! " Investigate the concern to determine the root cause of the error.
Immediately notify KG&E Quality Assurance if any other problems of this ;
nature are identified. Document the investigative actions. The notification 1
of KG&E QA shall not preclude the issuance of an NCR."
l The results of the CAR-19 inspection effort were tracked and each case - l where a misuing weld or missing material was identified was researched l thoroughly _- by DIC ' Engineering to determine whether documentation existed pertinent to the installation of the missing weld / material. Miscellaneous Structural Steel Weld Records (MSSWR's) were reviewed to determine if a trend or pattern existed. Nonconformance reports identifying missing welds were compared to MSSWR's to determine if there were repetitive occurrences.
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28 of 33 4
Applicable drawings were reviewed for similarities in beam numbers, floor layout and beams at similar locations in an attempt to further identify possible sources of confusion. As a result of the investigations conducted only two (2) cases were identified where inspection documentation existed for
- welds not installed.
t The first case is the installation of beam No. 324B2 and its connection to an embed in the Auxiliary Building. All available information indicates that DIC Quality Inspector W made a human error when documenting the inspection of this beam connection. A review of the drawings shows that the beam configuration and floor layout in the area (elevator shaft and equipment hatch) directly beneath the beam connection in question are very similar. In addition, the beam below beam 524B2 connects at the same building coordi-nates.
It is possible that Inspector W could have been one elevation beneath
, where he should have been when inspecting the connection. Out of the i
multiple welds inspected by Inspector W this problem occurred only once. If actions which would result in other conclusions had occurred, it would be reasonable to assume that they would have occurred repeatedly. Inspector W's signature appears on over eight hundred (800) MSSWR's. Each MSSWR could
] . document multiple weld inspections, therefore, Inspector W very likely inspected over one thousand (1,000) structural steel welds, with the result that this type of problem occurred once. A telephone conversation between i Inspector W and DIC management personnel concerning this incident revealed no information that Inspector W could offer, since he could not recall the k specific connection from the more than eight hundred (800) he inspected. The root cause conclusion in this case is human error.
- The second case is the installation of beam No. 95B5 to an embed in the Control Building. All available information suggests that DIC Quality Inspector X made a human error when documenting the inspection of this beam connection. The MSSWR documenting this connection shows Inspector X's confusion.in that he entered the joint number incorrectly when filling out i
this portion of the MSSWR, then lined through, initialed and dated his error, and entersd what he thought was a correct entry. Drawing K6711-XI-I-E13 details this connection, but is unclear in that it does not designate the connection number for the beam clip to embed weld, and only lists the beam l
seat number (91M1).
i Further research revealed that Inspector X completed one hundred eighty-three (183) MSSWR's during his tenure on site, but only six (6) of i
these MSSWR's were related to structural steel weld ' inspections. This is
- indicative that Inspector X was possibly confused by the details on the erection drawing. It is probable that Inspector X attempted to document the welds attaching the beam clips to beam 95B5, since no retrievable MSSWR is on file for these welds. These circumstances are documented on nonconformance report ISN 20798CW for disposition and resolution. The root cause conclusion in this case is human error.
j Finding #5 of CAR-19 stated, " Objective evidence that the mechanical and i structural inspection / documentation problems identified in KG&E QA Surveil-
! lance Report S-372 were rectified has not been provided."
l l --- . -
29 of 33 Corrective Action Sa)
" Provide objective evidence that the mechanical and structural support I welding inspection / documentation problems identified in Surveillance Report l S-372 have been corrected. If such evidence is not available, research the extent of the problem and take the appropriate remedial actions." Activity 5a was broken down into two categories. Sa-1 was to . review and provide objective evidence that Mechanical Deficiency Reports identified in S-372 have been correctly closed out. Sa-2 was to review and provide objective evidence that Civil Deficiency Reports identified in S-372 have been correctly closed out.
A total of forty-two deficiency reports were reviewed encompassing the departments of~ Civil, Civil / Welding, Mechanical, and Mechanical / Welding which are identified in S-372. Below is a brief description of the closure to each Deficiency Report (DR). (Deficiency Reoorts underlined.)
- 1. 6451 was upgraded to an NCR (INN 4969CW) because all welds were encapsulated in concrete and deemed structurally acceptable by the A/E.
- 2. 6536 and 6538 were "Close in Process" because the hangers were
" VOIDED"; hangers were removed mechanically, and Quality inspected the area to insure soundness of the affected structure.
[.
( 3. 6559, 6557, 6560, 6568 pertained to electrical raceway hangers. DIC Mechanical / Welding inspectors performed inspections to ensure the soundness of the removal area after cut down, according to DR disposition. The reinstallation of these hangers was inspected by DIC Electrical Quality Inspectors and documented on Electrical Quality Raceway Support Checklists.
- 4. 6535,.6537, 6539, 6576, 6575, had dispositions calling for cut down of hangers only, therefore only the verification for the inspection of the soundness of the removal area was required.
- 5. 6585 disposition was "Close in Process" because no hanger could be located in the area called for by the Deficiency Report. The two closest hangers have the required documan-tation and their respeccive documentation is attached to the Deficiency Report.
- 6. 6249, 6250, and 6349 have MSSWR's to reflect proper closure, but the hangers are now voided. Based on this research an inspection of the applicable Building, Location, and Area (BLA) for these hangers was initiated and the hangers were verified as cut down.
- 7. The remaining Deficiency Reports have MSSWR's attached to reflect the proper documentation for the safety-related attachment welds. This group of Deficiency Reports numbers 26 total.
t
30 of 33 No violations of 10 CFR 50 Appendix B exist in Items 1 thru 5 as defined in the criteria of KG&E Surveillance S-372. The violations listed in S-372 pertained to welding documentation on Structural Steel. The dispositions for the deficiency reports in items 2 thru 4 require the removal of deficient welds. In some cases MSSWR's were used to document the removal so these MSSWR's show blanks (or as non-applicable) for W-100, weld technique, filler material, etc. These should not be mistaken for incomplete MSSWR's for required welding, since MSSWR's are not required for this activity.
In summary, all deficiency reports in KG&E Surveillance S-372, have been reviewed and proper closure verified. All the deficiency reports were closed properly according to the results of our investigation.
l DEFICIENCY REPORT /!
6248 6454 6557 6568 6249 6455 6558 6569 6250 6456 6559 6570 6280 6457 6560 6571 6349 6535 6561 6572 -
6449 6536 6562 6573 6450 6537 6564 6574 6451 6538 6565 6575 6452 6539 6566 6576 6453 6556 6567 6577 6585 6588 ,
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h 31 of 33 V. Conclusions l
The technical evaluation of WCGS structural steel significant joints, which was performed by Bechtel based upon reinspection data accumulated, established that safety related AWS Dl.1 structural steel welding complies with all Quality criteria as specified in the related design documents, and is within the tolerances of acceptable deviation as determined by the Architect / Engineer. This evaluation for structural integrity was based upon this cumulative data that reflected the as-built condition of Bechtel identified structurally significant joints prior to any rework or repairs. j Two thousand six hundred sixty-nine (2,669) structurally significant joints were identified by Bechtel and were subsequently reinspected by D:C Certified Quality Inspectors who were all also AWS certified Welding Inspectors. Eighty one (81) of these significant joints required rework due to design allowable stresse: being exceeded in the as-built condition. None of the structurally significant joints where discrepancies were identified would have failed if left uncorrected.
Research accomplished by DIC and Bechtel persennel substantiated that all DIC welders and welding procedures applicable to AWS Dl.1-1975 welding of structural steel installations were qualified in accordance with AWS requirements. Additional research resulted in assurance that programs and procedures applicable to the purchase and control of weld filler materials used in AWS Dl.1 applications were in compliance to AWS requirements.
r Investigations into site implementation of these requirements and procedures i provided assurance that implementation had been effective and properly controlled by DIC during project construction activities.
The retrievability and control of Miscellaneous Structural Steel Weld Records (MSSWR's) was investigated, and a determination made that inadequate implementation of DIC construction procedures was a contributing factor to retrievability and accountability problems with MSSWR's relative to struc-tural steel applications. Thorough analysis of each applicable program was undertaken by DIC Quality Engineerning to determine if similar programmatic or procedural requirements existed, and whether inadequate implementation had resulted in similar deficiencies. The results of these assessments deter-mined that no programmatic problems existed in any other AWS Dl.1 application relative to inspection documentation required for weld inspections. Evalua-tions of each application identified that more efficient documentation methods were utilized, and in each case there was more effective control of the required documentation through its initiation and processing cycles.
Review of Quality Assurance historical audits. and surveillances and an evaluation of procedural implementation adequacy further assured no problems existed in any other AWS Dl.1 application similar to the MSSVR retrievability problem on structural steel welding.
Hardware applications of AWS Dl.1-1975 requirements were also analyzed to determine if the root causes applicable to the previous . acceptance of deficient structural steel welds were of' potential impact in ' applications other than structural steel. Reinspection and Corrective Action reports existed in every case to ensure the acceptability of installed hardware where
, AWS Dl.1 welding was utilized except in Electrical Equipment foundation b welds. DIC Management determined that a subsequent investigatory effort was ;
necessary to provide data to ascertain the possible existence of deficiencies in welding and shimming in these installations. DIC Corrective Action Report 1-EW-0046 was initiated to document and accomplish these activities. <
1 I
I __
32 of 33 DIC Corrective Action Reports (CAR) 1-W-0029 and 1-C-0031 were evaluated to determine why neither of these documents resulted in the appropriate identification and effective resolution of structural steel welding and documentation problems prior to KG&E Corrective Action Request 19. CAR j 1-W-0029 was found to be effective for the scope of welds identified. A '
conclusion was reached, however, that if a larger sample size had been utilized for CAR 1-V-0029's scope of inspection activities, that corrective action concurrent with that identified for KG&E CAR-19 may have been decided appropriate as resolution for the identified problems.
With the generation of DIC CAR 1-C-0031 DIC Management recognized that documentation did not exist for all structural steel welds as procedurally required, and nonconformance reports were generated to document these
'Use-As-Is' dispositions were assigned to these nonconformance
~
inadequacies.
reports based upon the existence of defined programs and procedures that required 100% inspection and documentation of structural steel welding activities. An assumption was made that although required documentation was not 100% retrievable, the programs in place during structural steel installa-tion / inspection activities did result in all installations being completed and inspected.
Neither CAR l-W-0029 nor CAR 1-C-0031 required matching of MSSWR's to structural steel welds or welded connections. If this had been a required corrective action for either CAR, the prc61 ems identified in portions of KG&E CAR-19 would have been realized.
i The findings addressed in CAR-19 in addition to missing MSSUR's included s'
deficiencies identified in previously accepted structural steel welds, missing structural welds or missing structural material, and documentation that a weld was inspected and accepted, but no weld was installed.
An evaluatior. of the DIC Quality inspection training program demon-strated that this program and related procedures were in compliance to ANSI N45.2.6. Further investigation concluded that Quality inspection training was appropriate and adequate during the structural steel installation time frame. An evaluation of DIC Quality inspection procedures and criteria applicable to the orf ginal ~ structural steel installation / inspection period revealed several procedural inadegnacies. A thorough analysis of the omission of each inspection criterion of AWS D1.1 structural steel applications was accomplished, with the conclusion that no adverse impact had resulted from these procedural inadequacies relative to AWS D1.1 welding inspection.
Inspection criteria to be used in the structural steel reinspection activities was procedurally defined and training of all personnel completed prior to reinspection initiation. Sufficient technical justification was established by Bechtel to validate inspection of welds through a predeter-mined maximum thickness of paint. An analysis of reinspection results determined the rooc cause of the previous acceptance of deficient structural welds to be due to DIC inspection implementation differences relative to inspection vs. reinspection techniques, and inadequate implementation of applicable DIC procedures.
33 of 33 Two (2) of the welds on joints reinspected were initially thought to be documented as being installed when in reality they were not installed.
Research revealed no evidence to indicate that either was a case of delibe-rate falsification. Additional investigations resulted in a conclusion that human error was the cause of incorrectly documenting these nonexistent l installations.
Reinspection found that some welds and materials were not installed as required by design documents. These errors were primarily due to craft /
engineering errors relative to misunderstanding of installation drawing details and requirements. Failure to install these welds and materials, although in some cases determined to be significant in impact to design stro'ss allowable calculations, would not have resulted in material or struc-tural failure if left uncorrected. All missing welds will be installed in accordance with a KG&E Management directive.
As a result of those concerns identified in KG&E CAR-19 DIC conducted an' assessment of the programmatic aspects of the Piping, Hanger, Mechanical, Elsctrical and Civil disciplines to ascertain the adequacy of those programs
~ihstituted in the construction of Wolf Creek Generating Station. Other than the . concern identified in DIC CAR 1-EW-0046 the program -assessment has established a high degree of confidence in the adequacy of the overall DIC Construction program to assure compliance with 10CFR50, ANSI N45.2, FSAR, design and procedural requirements. The cause of the adverse conditions identified in KG&E CAR-19 and DIC CAR 1-EW-0046 is limited to these areas in
(
(
that all other . areas of work which would have been rendered inadequate or suspect due to the identified root cause have been adequately addressed )
1 through subsequent means such as retrofit or reinspection programs.
l After completion of the program assessment, which addresses all aspects j of the DIC Construction programs in total, and as they might have been i affected by the identified root cause of deficient structural steel welds, it is the conclusion of this assessment that all significant problems have been identified and are being adequately addressed and resolved through appropriate corrective actions.
This program assessment is included in the Appendix, section VI.H of the KG&E CAR-19 Final Report, and has concluded that a satisfactory level of confidence exists to assure compliance with 10CFR50, - ANSI N45.2,' the FSAR, {
l and Design and Procedural requirements. J l
The objective of KG&E CAR-19 was to establish by review of Construction and Quality programs, as-built conditions, nonconformance identification and-correction and by design evaluation and/or rework that al1~ structural steel l erection commitments in the Wolf Creek Final Safety Analysis Report were ,
i satisfied. -Through the cumulative . efforts- in the resolution of CAR-19
( assurance was' obtained that all significant Quality criteria as specified -in
! : the related ~ design documents were satisfied, . within the tolerances of accep-l table deviations as determined by the Architect / Engineer.~
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- INTEROFFICE CORRESPONDENCE
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10: G.L. F uts ' :CCC E4-C02 FICM R.M. Grant h DPsT: Oct:ber 17, 1984 Sunn!cr: Cc =ective Action Request (CAR) to. 19 Attached is 0 =ective A:tien Recuest (CE) *19 hich is bei.g issued t:
cbtain co nee.ive actions to Orchlers associated with safety-rela:sf ;4.3 Dl.1 st- actural steel wlding.
Dlease rescend to this C=cective Action Request by co :leti .g Secti n 5 ef the subject CAR. Your schedule f iglernenting cc=ective a:- r s and an explanatien of any actiens y:u have already taken stcald be suhutted to. e by Oct:bar 24, 1994.
.:?3/dkb cc: K.R. Bron .
G.L. Koester F.J. Duddy e W.J. Rudolth II C.E. Ps=y C.G. Patrick
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- 1. C:uaz=cu c a:.r:=u:
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See Attached.
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- s. . .ceCe%., .-2 . u., . ... . .n.. ..i:
KGi~J: Ccnstruction J. w- . ..-. c C: C, ,. .. - . .. ....
CA P.-cgran breakdcwn associated with safecy.related AWS Dl.1 struct :.ral steel welding.
.. en,. m. A C.: w- . .- : n.. . .. .., t :
See Attached.
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A -n - 0 4 Y AHI /O - *PY Faviewe:U Ca:e Ccal.:y 3:an= Representa::ve Oa:e
- . :s..:. .. : : ,.R . .cw. -,,..n
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Fesper.s cie icperviser Cata
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V.. s . av . r : ..:es @.
9/1S/84 des Atta=ed Telephone If Yes, Paper:
- Call P.eccrd
- 6. CO..'if.C'!Tr CICN Fr. -dF;f ) - Fetn::2: C; '.'e:1;;ca tion:
Quality 3:a..cn ?.apresanta::ve Cate Supervisc: Ca:e
- 9. CAR C R C: les C' Jai ".*/ stancn r,epresen:a:1'.'e -
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'J. AIF?C/AI CA'S 01:ec:c: - r.ua11;y t
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A. Cbiectives.
e To decirnerte a c=nsolidated p=cject plan f= 2e identification, evaluati:m arzi resolu-*. cf . uls::s assoc:.ated with Safecy-Related AWS Dl.1 Weldi.w .
e To provide assurance, based en objective evidence, cat AM D1.1 Weldirs; of Safety-Related St=ct=al Steel c==) lies wit all Cuality Criteria 'as specifiesd in de related design dec=ur.ts and is witin the tolerances of acceptable devia i c.s as dete=ined by the Architect - Engineer.
e To pr:-ride assurance dat the doc =e.ntatim which su;cer.s Se insmeeti:n of safety related st=c=ral steel welds is:
- Available
- - Ccrimlete
- Reflects am. late infcmati=n
- Traceable to the iten or activity e To evaluate st.w irry elernents of the DIC Cuality Assura .cs P::c sm to ensure that th::se elements were adaraataly arxi effectively i. plementai to denenstrate that 2a CIC soldi.y ef.
safety related st=ct=ral steel, INAC S=9c s, Slec ri=al S=perts, Pipe Khip Restrai=s and any eter ;W Dl.1 safety
( related weldira activities were in % 1irn=e with de F.T.'a (i.e. ;W3 Dl.1 - 1975) and the Cesign and C=.st== icn CA Pp t Mar"=' , Sec-d ~s 17.1.B.
1 Defini'd- :s 3.
I Joint - A st==. al steel welded connec.i n. A joint ray 1
cermist of re.:nereus welds. A j0i= :ay also be referred to as a c==ee.icn.
Weld - A cc=i=ucus leng2 of weld =aterial vid Only ene start ani one step.
MSSWR - Miscellaneous St== ural Steel Weld F.ecc:d; a fers used by DIC to dec.:nem installation arxi inspec.icn data f:
welds made to st===al steel.
- .3 C1.1 - A erican Weldi x;- Society's St=ctural Weldi
- q Cede.
his code ecvers widing recuirements applicable to welded- stru = res. It is to be used in cenjun=ien with any c:2 plenen.ary cede er spec 4-*-4 n f=r de design ard c=st== icn of steel st==ures.
'41scellaneous St===al Steel - See Attachnen: 3 f:r C=plete Cefini*' ~s.
St=== ally Significa= Welds - See Attaci:ne= 3 f= C= :plete b Cefiniti n.
Page 2 C. B&l A T:_^==m'4 e t
.e. Eu Surveillance Repert S-372 (Oct:ber, 1981) identified a Cuality E ,. a breekckwn due to the foll=vi:q deficiencies:
- Missing inspecticas doeurantatien
. - Ina:r1plete/ improper resoluti::n of identified electrical, rischanical and structural weld docirnentatien deficiencies.
Om
- 9.
Surveillance Re;crt resulted in the issuance of DIC C.M Surve411 = =
CAR 49 pertained exclusively to the :rajor finding of de Report, that being electrical stm weld inspection docu:9entation. An agreenent between EE and CIC Cuality Management was reached that required EE '4 issue a CAR if the DIC resolution was t= satisfactory to CE.
o DIC CAR tb.1-E-009 (Ceh, 1931) was su N aquently issued to address the electrical support weld inspection doct. r unts icn concerns identified in the EE Surveillance Report. De :::x:t causes of the problems identified in the EE Su::veillance Reprt warn determined by DIC to be: *
- he lack of notificatien by the resgensible craft to cuality inspecters that welding activitf was scheduled to c:rrence.
- I. ;=cper processing and filirq of weld roccrds.
"he existance of a single par: dec nent as cypesed to a,,,
triplicate type form to reccrd inspecticos.
W.e corrective :neasures taken by DIC involved de retrainirq of
(
' c=nstructica engineering personnel and the placanent of li.titatiens on the authorizati:xt level requirsi to initiate ce dis:csitions to Deficiency Paperts. W.e CAR was closed in Neverrber, 1992.
e DIC CAR l-W-0029 (March, 1993) was initiated *4 addrese scrne weld inspecticas inccasistancies in the Auxiliary, Cent.el a:xt Fuel *41 d 4 =s. 'Ib investigate the extent of the problem 241 wilds were inspected of which 147 were identified by the insper:ecrs as deficient.
To resolve the c=rditica identified en the CAR, NCR ISN10381PW was generated. W.e evaluatica cf the ICR involved another inspectica by Weldi.g ." gineeri g which resulted in the determinatien that cnly 22 welds exhibited pctentially significant conditi:ns and were subse-cuently evaluated by the Architect - Engineer and dis;csiti:nad "use-as-is". Based en the !CR a-d L.s closure, CIC cicsed CAR 1-W-0029 in Oct:ter,1983.
4 e DIC CAR l-C-CD31 (August,1983) states in part:
" MSS'<;Rs used to doc.. . ant safety relatsi structural steel wided c=nnectiens thre.:gh out "Q desig .ated areas is inadequate. A se=cle survey :ade by (CIC) Q.E. has shcwn
- 16.4% of the required MSSWRs cannet be located f=r all "Q" welds in the Fuel Bldg. A survey of 6 erecticn/ design drawirgs in the Reactor Bldg revealed 24% of de welds are missirs dec. nentati::n. In additien, M/W Cualitf has initiated a CR (1SN11957CN) to doctrnent 42 :.issing MSSWRs f:r velds in the ESWS Ptr phouse."
_ - _ - _ _ _ _ . . ._ - _ _ _ . . __ _ ~, . __.
\ .
. Page 3
- Se CMt was dispsiti:nmi to writs an :ER f:r eacn saf =f related M41'"W o address ths mi: sing MSSWR's. Al@cugh de CMt raiains cpen, ce pr:pesed jus ifi:1-d t Sr cl==re is basui in part on the clesure of DIC C'Jt 1-ri-0029.
- Current Project Acti=ns
- Dectnent Recenciliatien Task's Cn Aucus: 13, 1934, a c 8
- nent reconcilla len effer . was initiated at de directs. n of project nanagenent to dete:: .ine whic safety related
' struc=ral steel welds identifisi en design drawings were lacking inspectica dec.:nentatien in de f = cf MSSWRs.
- I seeetien Verification Plant Cn Aucus 17, 19M, an inspec::=n verifica :=n effe: %as i .itiated at te direc-%:
cf project anagenent to provide an ac=: rate assessment of 2e "as-built" c:nditions of safety related stru=utral steel welded cc:r.ec-4 s with unretrievable MSS'aT s. O.ese activities are being perfor:ned by a c:221.ed tea:n cf DIC and Arditect - E:qineer AWS Car ** *d ed Weldirq Inspecters u-der direct supervision of IC&E Ccristruction CC. Sese activities are being perfemed in accordance with - written fr.st== lens issued by IC&E C:nstruction CC %hich reflect de criteria Of L3 D1.1-1975 and the agslicable Architec: - Encineer design dec: rants. W.e results of 2ese verificati:ns ard de rev:.sw.
cf Surteillance Report S-372 have caused de fi-dirgs in Sec-4~1 E cf this report to be issued.
('
D. Reccire:nnts The w=1d'7 cf safety related stru:=:ral steel w...ectiens at Mr.3 is crierned by welding enie L3 D1.1-1975. he WCCS ISAR irr. ::kes '
dis cafe fer each safety related st==_=e. In additi n, SNUPPS project specificaticrt 10466-C-122 (Q) Rev. O tr:xagh 14 entitled '
"~e&_.ical Specificati=n Sr C:ntract f== Erection of St===al l Steel 2r the (SNUPPS) Pcwer Plant" a:vi specifi a icn 10466-C-132(Q), Pav. 0 2:cugh 8 titled "'"ech .ical Specificati n !
f= Erecting Miscellanscus Metal for de Starda-dized !.tclear Urdt P wer Plant Systen (SNUPPS)" recuires st===al steel sulds to be pererned in accordance with L'S C1.1-1975, with excepti:ns in d e criteria er u= der ..t (para. B.5.2) ard seld ~_:riexity (para.,
3.5.3).
, E. Findires - T:xacts - Fw .+ded C:rreceive Acad s -
he five firdi:qs listed belew were identified d=irq ce re FCCS
' a.. age ent assessmen s described in de '?.ack.,. .:-d Inf:r ati:n' see:::n cf tis re:cr . a:xi a review of Surteillance Repe= S-372 l by FGLE CA. Oclisc:ively, esse represe . a breakdron =f 2.s
- :::stru=:r'.s Cuality Assurance er::ctram. S.is c nditi n %2s caused by an arpa. rent 1.censistent applicati== cf weld irwien
. criteria, fail =e to i:=slenent p:cced=al re=ir.=nen s er d:cu-
- nentirg i scocticns, a:xi fai1=e to ir::lement effective c rrect:.ve
( ac i: .s f= identified deficiencias.
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. Page 4
(' F4-**-n $lt, 'lts . results of the
," n~w -=-re L mh M i ziicated that 1509 cf 6816 .5552s fi=r safety related stmceural staal welds are WT. (See Atu:rrner. 3)
I.=act: Without ce h =Patien f=r ce strue..:ral wlds, ce f=12= wing areas are iMeta 4 . ate
- Walder.identificatien aM q.:alification Finer retal traceability
- Visual ir.spection results Cualified weld e wedares specificati:n used Ree: Tended Cc: ec_ive Actiens: Actions la creugh ih belcw will adeq.ately acdress au ci the c:ncerns identified in FiMing al and de "r:ce cause" ccncerns a99ev-dated with Finding 42. -
la. Based en DIC y.m..m regairemen*s, assure that all of the welders and welding pecced re specificati ns were gaalified to AWS Dl.1 - 1975.
Ib. Review the DIC m a fer the purchase and centr:1 of finer
- aterial to ensure that cnly acceptable finer nacerial was i
used in safety related struct.:.al steel wlds.
ic. Ivaluate the adecuacy of the DIC inspectiat criteria a.xi-proced=es to dete=.ine~ if these el e nts c:ald have adversely i...aaeted e1 2 er c e results of the initial inspec-(. tiens er te results of the verifica:icn clan. Dec= ant aM pr: vide this evaluati:n to m&E CA f : review pric: to any 1
a:iditienal i.spection 1::plemen_atien. Any danges in inspec icn criteria and precaiures shall be pr:vided to :-1.42 CA f r review.
Id. Cbtain a doe...unted evaluati:n to deter.ine the validity of inspecti:ns perf==ad with 2e presence of pain ~ en de weld.
le. Utilize persennel certified to ANSI N45.2.6 - 1978 f=r c e inspecticn of safety-related str.:=t=al steel welds.
Inspections shan be perfermed in a==::rdance with the OIC Cuality Pr: gram and traini:q shall be perf =ed aM do=',:nented to assure that inspect =rs are cognirant of de CIC Cuality Inspecti:n pr: gram regairenants.
if. cerf== a LOM rei.wien of an st .:::=any significant safety-related s ruc ural steel welds wie missing .MSSWs.
~he iden:4 ~ i-- of "stru::=any significant" wlds shan te :ade by ~ de Architect -
Engineer (see Attac:.an: 3).
Insoect ce wlds per rrr.2 ...+cd.ati ns 10, id, le, Ig, lh and 2a.
, Ig. Use an T2 to c' :tain arxi doe.:nent a suitability f : serv:.co evaluatien of 1.acesssable welds.
4
' Ih. Reper: all identified defi lencies en an m R.
-9 9999999999999999999999999999999999999 4
6
- . - , . - . - , ~ . - - - - e - - - - - , .-n--.e. .-r... - - , , - - , , ,- -n.,----
Page 5 Fi~-*i:=r 42: An 4 M4--* ver4 *4 4-., e_ h of safety-related ai i M steel w=1a4 y, undertaan by 12 certifad weld ir.scoct=rs idwi #' =.4 several areas of A=P
- 4 5 =. ' heme ^=M'-*~-'= have bea:n a _ _: w belows
- t.hdernized walds
- Weld defects l
- Ir_ t ecmciguratica
- weld cre_. - l
- Weld undere::t I. ract: hese deficiencies could jec M ee de st=ct=21 integrity of the cennecticn.
Recc: mended Cccective Actic .s: Actiens 2a th. :-agh 2d belcw will a:iequately accress all c: :ne cc:.carns identified in F1-di.g 32 and te ir/estigative actiens required by Fi : ding .5.
2a. Cete=ine a:xi doc =ent the ":cet cause" of 9.e previcus acceptance of deficier.t st=c=ral welds. Ie.aly:e d e :-i ."ec Suptc = , Elec rical Support, Pipe-hhip F.estr in. and arf Other safety-related progran utild-4 g IMS D1.1 Weldi.g o ensure tat de same "r=ct causes" inherent in the st===s.1, steel weldi:q %.e.:n sere not generic to cher r.w.s s.
( Ib. Peric= a 100% reinspec-J.cn of all st=== ally signific:=
safety-related s c.:==al steel welds havir.g t'5SW's. he
'da--"'-'ti:n of "stru=urally sien: fica =" welds shall be
- ade by te Arditect - E:Wineer (See Atta9:nent 3) . In.w te welds per rh...#.rdatiens ic, id, lo, Ig, lh, arxi 2a.
2e. realuate the results of te c=pleted Inspecticn Verificatica -
Plan against the acce=tance criteria used in A =ien ic.
Id. A::y identified deficiencies shall be dee.- ented en an :G.
Firrii:n 43: A sral.1 r2=:ter of safety-related s*e:ral steel welds were not r:ade or had raissirs rnatarial.
- ta=: "'he s* :==al i tn egrity has ,cessibly been jeccardized.
F.ecc:n end=d Ceree-ive Ac i n: he fellcwing a=ien and te l en=:.neer:.:q =sp::s =cn ,..11 adecuately address FL-dirg *3.
2a. Fer ard to "as-cuilt" L.fc= a tien t.o de Architect -
Encineer via en :C to cetsin an engineeri.g e/aluatien and dis;csiti:n.
-+ l I
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I 1
i
- w
-rage 6
.yra.iner $4 ' Cne (1) wald m 2 --
a =" as hav m' been inseeet:xt Wien in reality the weld m rme =ade. (Ref int ISS29495cf)
L ract: to inspec or who made the errer c=uld have f.. , cly doct:nented other welds. ' he structural integrity has possibly been jees:e.r,*.ized.
_?s_ ...Edad c=n ective Actien T..e folloei:x; a -im will ade-cuately a: dress Fin = ng a4.
4a. I::vestigate the concern to deter: ine de ::ct cause of 2e
- e. .&. L rnadiately notify IGEE Cuality Assurance if any oder p=blerns of this nature are identified. Doc.:nent ce 1::vestigative actions. The ne*'"ca*'m of IGEE CA shall net preclude the issuance of an ICR.
Fi:xiirzr $5: Ctrjective evidence tlat the martianical and stextural w = u ivry ir..n=r.tien/r*re--=nenticn W- idanufissi in IC&E CA Surv=411== Repcrt S-372 were rectified has r:ot been petridad.
- L ra=: tere is a ;cssibility est ce =mchanical arx1 strue ural su m welding inspec =n/d:x:rentatien pr:blem identified in the Surveillance Repc:: were not ce=ected.
PS.< ...cded ce rective Action: te foll= sing acti:n will ade-quatary accress Firn2:x; n.
Sa. ?= vide objective evidence that ce :nechanical and stru===ral support welding inspec 'm/ doc nentatica p: bica identified in Surveillance Report 5-372 have been ec cec.si. If such evidence is nc available, research the extent cf 2e problem and take the appr:griate rernedial actiens.
F. Pe.g._...-Jed Cc=setive Acticn Ficw Di.H_ rt ::ns See a.ttac!_ent C.
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ACA~.P.C."" A 4
DATE: */19/*4 _
LE 39LN*C _
TIME: "Ts 00 '
IE: - 20675-VI52 TE: _50564-152 TELEPuCNE ChLL RECO*4D TO: Lawrence Martin FRCM: CMavnard. BRudolon.
"L19dsav. CPorrv COMPANY: NRC Decien IV ADDRE55: Arlineten. Texas TELEPHONE NO.: 817/960-9100
SUBJECT:
(use anx)
Potential 10CFR50. 55 (e) Inscoction of Welds.
We infccmed Mr. Martin that during cur re-inscoction of welds fer which we had nc inspection records, we identified 4 welds en tpe containment instrumentatien c=cler tubingplatfrom that were and not 4 lateral suoports fer the incere
, g
(.
investigating to determine whether er installed. not the ccnditicn We ar e was documented and why they had not been installed.
.O. ~.- w .M.ITj /'*,. T .,
3.Y. 3$ @
..,s.
cs ACTICN REQUIRED AND DATE: Licensing c=crdinate 30-day repcrt -
due 10/18/84 i DISTRILUTICN: G M= ester H Eundy/B Sartlett/W Guldamend F Rh=das F Duddy R Pcque/F Zaval M W111 tams G Fcuts R Hagan C Parry /M Lindsay ;
R Grant
,1 Jennsen W Rudolcn J Bailey /D Prichard ,, l G Rathbun A Beat ,.
R Glover S Eaiken 3 ,
/
L Stevens G Baker ! j[//// , j/ .j , .;-
? / / 4/if F Field B M2yer ,
( si gnatur e) ~ ~
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Defini+8m of M4=11== St *xt=al swl:
Miscellaneous Structural Steel is divided inte ;,o (2) ta =s pur;cses of this CAR.
.: the A. Main Pr.nre and Aswinted L-.
Main fra.e welds are t.
%se welds en st===al steel ec .r.ectiens which
- cfs. sup;:crt the rain building ficers (cen=ete er gra.ing) and drawing" Fcr efficiencf, rather these connectiens are identified on a "per e
basis individually. Therefore, than categer4 4 4 each piece of steel include certain "asacciated" connections, suchwelds as,itcisher inevitable than tha these which supccrt rain buildi.m flecrs a.M roof, which are depicted steel.
en drawings prirarily show:.ng rain building flecr arxi reef B. Miscella:wees Miscellanec.:s welds connect steel which does ret su= pert rain
- buildi.g ficers er reefs (i.e.,
classified as rain fra:ne er associated all st=c=ral steel welds net r welds). his dees ret include hand-rails, t M lates, and sir.ilar ite s.
- 2. Cafini'i~t of St:=_: rally SienHicant Nelds:
hose velds which are required in the ec=)leted build 4 g st==ure to support and p r.sce
~4elda fer tempera:y su;gerts, safety related ecui.2nent and buildire exponents.
tee-plates, and sinilar nec-safety related supports, ha.
ite.s M -rails, sic;n:.ficant by this definiai m. are net censidered to be st=== ally o
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