ML20133C925
| ML20133C925 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/26/1984 |
| From: | KANSAS GAS & ELECTRIC CO. |
| To: | |
| Shared Package | |
| ML20133C868 | List: |
| References | |
| FOIA-85-101 PROC-841026-01, NUDOCS 8507220043 | |
| Download: ML20133C925 (29) | |
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KG&E MANAGEMENT PLAN i.
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OCTOBER 26, 1984 1
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VARRICC85-101 PDR.
e MANAGEMENT PLAN FOR THE RESOLUTION OF CAR 19 Overview The objectives of this plan are as delineated in CAR 19.
These objectives will be met by providing objective evidence that each of the corrective actions specified within CAR 19 are satisfactorily implemented. The intent is to verify that both the hardware and programmatic aspects of all safety related activities utilizing AWS D1.1 welding are in compliance with the FSAR (i.e. AWS D1.1-1975) and the Design and Construction Program Manual (Section 17.1B).
The attached logic chart illustrates the approach to be used in providing the above mentioned verifications. The Corrective Actions associated with each of the steps on the logic chart are identified on the chart.
All Corrective Actions shall be implemented in strict accordance with CAR 19 including review and approval of specific items by KG&E QA where requested. Flow diagrams (attachments C-1 and C-2 of the CAR) have been and will continue to be considered in developing corrective actions.
Upon completion of each of the corrective actions necessary to resolve CAR 19, reports will be prepared which summarize action taken.
These summary 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 to implement each Corrective Action are listed beneath the Corrective
,t
'The numbering system for findings and corrective actions used Actions.
in CAR 19 correspond directly with those used herein. Responsible key personnel are also provided.
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O Finding # 1:
"The results of the Document Reconciliation Task Force indicated that 1509 of 6816 MSSWR's for Safety Related Structural Steel Welds are missing."
RESPONSIBILITY la) " Based on DIC program requirements assure that all of the welders and welding procedures were qualified to AWS D1.1."
K. Hollingsworth la-1 DIC develop AWS D1.1 attribute checklist and B. Newton review welding procedure and welder qualifica-tion procedure against this checklist; include documentation of procedure review cycle.
la-2 DIC perform statistical sampling plan in accordance with MIL-STD-105D to verify qual-ifications of welders appearing on randomly selected MSSWR's.
G. Stanley la-3 Bechtel review and comment on DIC Welding M. Pitre Procedure Specification and Welder Qualifi-cation Procedure as to compliance to AWS D1.1.
K. Hollingsworth la-4 Provide report summarizing the results of the above.
Ib) " Review the DIC program for the purchase and control of filler material to ensure that only acceptable filler material was used in safety related welds.
Assure that both safety related and non-safety re-lated filler materials were properly controlled to preclude improper application."
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K. Hollinssworth Ib-1 DIC review procedures for the purchase and B. Newton control of filler and base materials and prepare description / justification.
G. Stanley Ib-2 Bechtel review procedures for the purchase and control of filler materials and comment.
K. Hollinasworth 1b-3 Prepare summary report.
Ic) " Evaluate the adequacy of the DIC inspection criteria'and procedures to determine if these elements could have adversely impacted the in-spection results.' Document and provide'this eval-untion 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.
L. Easterwood 1c-1 Develop AWS and site specification attribute l
D. Mauldin checklist related to inspection requirements.
i Review DIC inspection criteria and procedures in accordance with checklists.
ic-2 Document this evaluation.
Ic-3 Provide this evaluation to KG&E QA for review.
Ic-4 Prepare changes / revisions as necessary and sub-mit to KG&E QA for review.
D. Mauldin ic-5 Prepare. summary report items Ic-1 through ic-4.
L. Pardi Id) "Obtain a documented evaluation to determine the validity 4
of inspections performed with the presence.of paint on the weld."
K. Hollinasworth Id-1 Obtain information from other utility /AE's that have B. Newton developed a validation plan.
L.
B. Newton Id-2 DIC Welding Engineering and Bechtel Review; add site specific requirements / justification as necessary K. Hollingsworth Id-3 Submit to KG&E QA for review and approval.
D. Mauldin Id-4 Prepare summary report items Id-1 through Id-3.
le) " 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 l
Quality Program and training shall be performed and docu-l mented to assure that inspectors are cognizant of the DIC Quality program requirements."
D. Mauldin le-1 Incorporate CAR 19 Inspection Verification Plan into DIC procedure QCP-VII-200, " Inspection of Welding Process."
W. G. Westhoff le-2 Inspection personnel to be certified to ANSI N45.2.6 -
K. Fletcher i
1978 in accordance with DIC certification program based on education and experience levels.
L. Easterwood le-3 Site specific qualifications will be limited to the J. Fletcher re-inspection of structural steel welds in accordance with the requirements of QCP-VII-200.
D. Mauldin le-4 Prepare summary report items le-1 through le-3.
If) " Perform a 100% reinspection of all structurally significant safety related structural steel welds with missing MSSWR's.
The identification of " structurally significant" welds shall be made by the Architect - Engineer."
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L. Easterwood if-1 Identification of " structurally significant" welds J. Fletcher by the Architect - Engineer.
"Struct'urally significant" joints are defined as all field welded joints which support or potentially support safety related equipment and building i
components. This basically includes all field welds on structural and miscellaneous steel with 4
the exception of handrail, toeplates, grating, checkered plate, stairs, ladders and monorail supports. These are non-Q items which typically i
see significant service loads during the con-struction 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.
The joints are selected by Bechtel based on a review of erection drawings prepared by the structural and miscellaneous steel fabricators.
L. Easterwood if-2 Perform re-inspections in accordance with the CAR J. Fletcher 4
19 Inspection Verification Plan.
Use the project nonconformance program to obtain and document a suitability for service evaluation of inaccessible welds.
Report all identified deficiencies on an NCR.
Bechtel will perform a case by case evaluation of each joint inspected to determine if:
as-built condition meets design allowables.
if the as-built condition is a significant deficiency in accordance with 10CFR50.55(e).
any rework is required.
D. Mauldin if-3 Prepare summary report items if-1 through if-2.
Finding #2:
"An Inspection verification effort of safety-related structural i
steel welding, undertaken by AWS certified weld inspections identified several areas of deficiencies. These deficiencies i
have been categorized below:"
Undersized welds l
Weld defects Incorrect configuration 1
RESPONSIBILITY CORRECTIVE ACTIONS L. Easterwood 2a) " Determine and document the " root cause" of the previous j
D. Mauldin acceptance of deficient structural welds. Analyze the I
l HVAC Support, Electrical Support, Pipe-Whip Restraint and 1
any other safety-related program utilizing AWS D1.1 Weld-1 ing to ensure that the same " root causes" inherent in the j
structural steel welding program were not generic to other programs."
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L. Easterwood 2a-1 Review evaluations of DIC inspection program D. Mauldin as performed in Ic.
Determine if procedures 4
could contribute to " root cause".
2a-2 Review inspection training and certification procedures to verify compliance to ANSI N45.2.6 -
78Property "ANSI code" (as page type) with input value "ANSI N45.2.6 -</br></br>78" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
K. Hollingsworth 2a-3 Analyze the deficiencies found in structurally B. Newton significant safety related structural steel welds as documented in the CAR 19 Inspection Verification Plan utilizing the original MSSWR, the Re-Inspection Data Sheets, and the Architect Engineer evaluation.
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L. Easterwood 2a-4 Identify all safety related activities utilizing D. Mauldin AWS D1.1 welding.
2a-5 Review previously compiled information relative to inspection and acceptance of HVAC and Electrical Supports, and Pipe Whip Restraints and any other safety related program utilizing AWS D1.1.
Examples of compiled information include Construction Self Assessment, task force reports, QA audits and sur-veillances.
L. Easterwood 2a-6 Summarize results of any previous investigations /
K. Hollingsworth reports related to welding / inspection of above items.
L. Easterwood 2a-7 Analyze programmatic elementt utilized in the erection /
D. Mauldin a
welding of structural steel and HVAC and Electrical Supports, Pipe Whip Restraints and other items.
Develop list of programmatic differences and determine extent to which these differences would influence
" root causes".
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D. Mauldin 2a-8 Provide summary report items 2a-1 through 2a-7.
2b) " Perform a 100% reinspection of all structurally signif-icant safety related structural steel welds having MSSWR's.
/
The identification of " structurally significant" welds shall be made by the Architect / Engineer."
i L. Easterwood 2b-1 Proceed as in item if.
J. Fletcher D. Mauldin 2b-2 Provide summary report.
Finding #3:
"A small number 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 /
Engineer via an NCR to obtain an engineering evaluation and disposition."
L. Easterwood 3a-1 Missing welds or material detected in the inspec-J. Fletcher tions performed in if and 2b above shall be docu-mented on NCR(s) showing the "as-built' informa tion.
These NCR(s) shall be given to the AE for evaluation and disposition.
D. Blizzard 3a-2 Verification of incorporation of design changes.
F. Raycher 3a-3 Evaluate and determine probably cause of 3a-1.
D. Mauldin 3a-4 Prepare summary report.
Finding #4:
One (1) weld was documented as having been inspected when in reality the weld was not made.
(Ref. NC'R ISN20495CW) gets
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RESPONSIBILITY CORRECTIVE ACTIONS 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 of KG&E QA shall not preclude the issuance of an NCR."
L. Easterwood 4a-1 Evaluate the results of the CAR 19 Inspection D. Mauldin Verification Plan (i.e. those inspections performed in if and 2b) and determine whether a pattern of this type of deficiency exists.
4a-2 Identify further actions required if a pattern of deficiencies is found.
D. Mauldin 4a-3 Prepare summary report.
Finding #5:
" Objective evidence that the mechanical and structural welding inspection / documentation problems identified in KG&E QA Surveillance Report S-372 were rectified has not been provided."
RESPONSIBILITY CORRECTIVE ACTIONS Sa) " Provide objective evidence that the mechanical and structural support welding inspection / documentation problems identified in Surveillance Report S-372 have been corrected.
If such evidence is not available, research the extent of the problem and take the appropriate remedial actions."
R. Harper Sa-1 Review and provide objective evidence that Hechanical L. Payne Deficiency Reports identified in S-372 have been correctly closed out.
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Deficiency Reports identified in S-372 have been i
i correctly closed out, t
l D. Hauldin Sa-3 Prepare summary report.
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RESPONSIBILITY #6 REPORT j
P. Halstead A final comprehensive report including all evaluations performed
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i and the results of activities conducted to provide objective evi-dence to satisfy the corrective actions required by CAR 19 will be prepared and submitted to KG&E Quality.
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SCHEDULE OF CORRECTIVE ACTIONS CAR #19
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10/26/84 CORRECTIVE ACTION START / COMPLETE DATES la-1 DIC develop AWS D1.1 checklist; review 10/18 - 10/26 welding and welder qualification procedures.
1 la-2 DIC perform statistical sampling plan 10/27-11/02 to verify welder qualifications.
la-3 Bechtel review / comment DIC welding and In process - 10/27 welder qualification procedures.
la-4 Report summarizing la-1, la-2, la-3 11/02 - 11/08 lb-1 DIC review procedures for purchase 10/22 - 10/27 and control of base and filler material.
Ib-2 Bechtel review procedures for purchase In process - 10/25 i
and control of filler materials.
Ib-3 Esport summarizing 1b-1, Ib-2 10/28 - 10/30 1c-1 Develop AWS/ site specification checklist.
10/18 - 10/24 r
Review DIC inspection criteria and procedures.
Ic-2 Document evaluation ic-1 10/18 - 11/03 1c-3 Provide evaluation to KG&E QA 11/04 1c-4 Prepare changes / revisions as necessary, 10/18 - 10/26 submit to KG&E QA Ic-5 Prepare summary report items ic-1 through 11/08 - Completion Ic-4.
Id-1 Obtain information necessary to validate Complete inspections performed with paint on welds.
Id-2 DIC/Bechtel review id-1 information; add In process - 10/26 site specific requirements and justification.
Id-3 Submit to KG&E Quality Assurance 10/25 - 10/31 Id-4 Prepare summary report items Id-1 through 11/08 - Completion Id-3.
le-1 Obtain approval of CAR #19 Inspection Complete Verification Plan by KG&E QC, DIC Quality Engineering and Architect Engineer.
le-2 Certify inspectors to ANSI N45.2.6 - 1978 10/15 - 10/21 le-3 Provide site. specific qualifications of 10/18 - 10/21 inspectors.
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SCHEDULE OF CORRECTIVE ACTIONS o
CAR #19 10/26/84 CORRECTIVE ACTION START / COMPLETE DATES le-4 Prepare summary report items le-1 through 11/08 - Completion le-3.
If-1 Identification of structurally In process - 11/01 significant welds by Bechtel.
If-2 Perform re-inspection of all structurally In process - Completion significant safety related structural stcel welds with missing MSSWR's.
If-3 Prepare summary report items If-1 through 11/08 - Completion i
If-2.
j 2a-1 Review evaluations performed in Ic.
10/24 - 10/26 i
Determine if procedures contribute to " Root l
Cause".
l 2a-2 Review inspection training and 10/18 - 10/27 certification procedures.
1 1
j 2a-3 Analyze deficiencies found during the 11/01 - 11/20 CAR #19 Inspection Verification Plan, j
2a-4 Identify all safety related activities 10/17 - 10/22 utilizing AWS D1.1.
i 2a-5 Review previously compiled information 10/21 - 10/25 3
relative to all other programs utilizing AWS D1.1.
2a-6 Summarize review in 2a-5.
10/23 - 11/03 2a-7 Analyze programmatic elements utilized 10/18 - 10/30 in various safety related AWS D1.1 welding activities. Determine extent to which programmatic differences would ir. fluence
" Root Causes".
2a-8 Provide summary report items 2a-1 through 11/08 - Completion 2a-7.
2b-1 Perform 100% re-inspection of all In Process - Completion structurally significant safety related j
structural steel welds having MSSWR's.
2b-2 Prepare summary report.
11/08 - Completion i
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3a-1 Document missing welds or material on In Process - 11/09 NCR's; submit to Bechtel.
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s SCHEDULE OF CORRECTIVE ACTICES 4
CAR #19 10/26/84 CORRECTIVE ACTION START / COMPLETE DATES 3a-2 Verification of incorporation of Complete i
Design Changes.
3a-3 Evaluate and determine prob,able cause 10/18 - 11/11 of 3a-1.
3a-4 Prepare summary report.
11/12 - 11/13 4a-1 Evaluate results of CAR #19 Inspection 10/27 - 11/10 Verificction Plan to determine " Root Cause" of missing welds with inspection documentation; determine if pattern exists.
4a-2 Identify further actions if required.
10/30 - 11/11 4a-3 Prepare summary report.
11/12 - 11/13 Sa-1 EssureMechanicalDeficiencyReports 10/18 - 10/30 in S-372 have been correctly closed out.
Sa-2 Assure Civil Deficiency Reports in 10/18 - 10/30
'S-372 have been correctly closed out.
Sa-3 Prepare summary report.
11/08 - Completion 6
Prepare final report - submit to KG&E Quality 11/22 - 11/28 3
1 DOCU V El\\~~
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...g e..N INTEROFFICE CORRESPONDENCE
'IO:
G.L. Fouts '
IGJGC 84-002 FKM R.M. Grant DME:
October 17, 1984 SUBJ1!Cf Corrective Actico Request (CAR) No.19 Attached is Corrective Action Request (CAR) #19 which is beirs issued to obtain corrective actions to prohlans associated with safety-related AWS D1.1 structural steel welding.
Dlease respond to this Corrective Action Request by conpleting Section 5 of the subject CAR.
Your schedule for implenenting corrective actions and an explanation of any actions you have already taken should be subnitted to.
me by October 24, 1994.
P21G/dkb cc K.R. Brown G.L. Koester F.J. Dtz$dy W.J. Rudolph II c.E. Parry C.G. Patrick I
1 g r-60 Fev. 2/84 3 53531 WCLF CREEK GENERATI!G SMTICN CORRECTIVE ACTION REQUEST
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CAR 10.
19 1.
COtOITION DESCRIFIION:
See Attached.
2.
RESPONSISLE CIGWIZATION:
KG&E Construction 3.
CAUSE CF CC CITICN QA Program breakdown associated with safety-related AWS Dl.1 structural steel welding.
4.
M 'OED CCRRECTIVE ACTIOJ:
See Attached.
A -#1-8 Y M
/dO fk Peviewer U Date Qtfala:p Brancn Representative Date 5.
SCEJLE FCR IMPLEMDCATICN CF ACTICN:
l Responsible Supervisor Date 6.
NBC REPCRTABLE: h tb 7.
S'ICP WORK ACTION TAKC1: Yes h
9/18/84 See Attacned Iblephone If Yes, Report 4 Call Record 8.
CCRRECTIW. ACTION VERIFIED - Metncx1 ot Vertrication:
Quality Branch Representative Date Supervisor Date 9.
CAR CICSED:
Yes Quality Brancn Papresentative Date supervisor Cate
- 10. APPROVAL DAE Director - Quality
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A.
Obiectives e 1b docment a consolidated project plan for the identification, evaluation and resolution of problems associated with Safety-Related AWS Dl.1 Welding.
e To provide assurance, based on objective evidence, that AWS Dl.1 Welding of Safety-Related Structural Steel cm plies with all Quality Criteria as specificed in the related design doc e ents and is within the tolerances of acceptable deviations as determined by the Ardtitect - Engineer.
e To provide assurance that the docunentation which supports the inspection of safety related structural steel welds is:
- Available
- Cmplete
- Reflects appropriate information
- Traceable to the item or activity e 'Ib evaluate supporting elements of the DIC Quality Assurance Program to ensure that those elements were adequately and effectively implemented to denonstrate that the DIC welding of safety related structural steel, HVAC Supports, Electrical
- Supports, Pipe Wip Restraints and any other AWS Dl.1 safety related welding activities were in ocrrpliance with the FSAR (i.e.
AWS Dl.1 1975) and the Design and Construction QA F %
Manual, Section 17.1.B.
B.
Definitions 1
Joint
- A structural steel welded m.
Cdon.
A joint nay ocnsist of n earous welds.
A joint may also be referred to as a m.AT.lon.
- A continuous largth of weld material with only one start and me stop.
MSSWR
- Miscellaneous Structural Steel Weld Recordt a form used by DIC to doctanent installation and inspection data for welds made to structural steel.
4 AWS Dl.1 - American Welding Society's Structural Welding Code.
This code covers welding requirenants applicable to welded structures.
It is to be used in conjunction with any omnplementary code or specification for the design and constructicn of steel structures.
I Miscellaneous Structural Steel - See Attachment B for Caplete Definitim.
Structurally Significant Welds - See Attachment B for Caplete Definition.
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Bacsaround Inammaticn e IG&E Surveillance Report S-372 (October, 1981) identified a Quality P.@u-. breek&swn due to the following deficiencies:
- Missing ins
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- Inocmplete/pection documentation 1.,w, resoluticn of identified electrical, mechanical and structural weld documentation deficiencies.
4 S e Surveillance Report resulted in the issuance of DIC CAR
- 9.
G R $9 pertained exclusively to the major finding of the Surveillance Report, that being electrical support weld i
inspection h==ntation.
An agreement between IC&E and DIC Quality Management was reached that required IGEE to issue a CAR if the DIC resolution was unsatisfactory to IC&E.
e DIC CAR No. 1-E-009 (October, 1981) was subsequently issued to address the electrical support weld inspection h=="tation concerns identified in the Ic&E surveillance Report.
The root causes of the problems identified in the IGEE Surveillance Report were determined by DIC to bet i
4
- ne lack of notification by the responsible craft to Quality inspectors that welding activity was scheduled to cxmmence.
-L%w processing and filing of weld records.
- The existance of a single part doctanent as m --d to a triplicate type form to record inspections.
The was-Rive measures taken by DIC involved the retraining of construction engineering personnel and the placanent of l
limitaticns en the authorization level required to initiate the dispositions to Deficiency Reports.
Se CAR ms closed in i
Novenber, 1982.
e DIC CAR l-4f-0029 (Martti, 1983) was initiated to address sane weld inspecticn imintancies in the Auxiliary, Control and Ebel M 1 Mngs.
To investigate the extent of the problem 241 welds were inspected of which 147 were identified by the inspectors as deficient.
To resolve the condition identified on the CAR, NCR I W10381PW was generated.
The evaluation of I
the NCR involved another inspection by Welding Engineering which resulted in the determination that only 22 welds exhibited p3tentially significant conditions and were subse-i quently evaluated by the Architect - Engineer and dispositioned "use-as-is".
Based on the NCR and its closure, DIC closed i
CAR l-W-4029 in October,1983.
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DIC CAR l-C-0031 (August,1983) states in part:
"MSSWRs used to document safety related structural steel welded w...ections through out "Q" designated areas is LW=te. A senple survey made by (DIC) Q.E.
has shown 16.4% of the required MiSWRs cannot be located for all "Q" welds in the Fuel Bldg. A survey of 6 erection / design drawings in the Reactor Bldg revealed 24% of the welds are missing doctamntaticn.
In additicn, M/W Quality has initiated a NCR (ISN119570f) to document 42 missing MSSWRs t
for welds in the ESWS Ptanphouse."
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%e CAR was dispositioned to write an NCR for each safety i
related M1Mng to address the missing MSSWR's.
Although ths CAR remains open, the proposed justification for closure is based in part on the closure of DIC CAR 1-W-0029.
e Current Project Actions I
- Doctanent Reconciliation Task: On August 13, 1984, a doctanent recenciliation effort was initiated at the direction of project nanagement to determine Wtich safety related structural steel welds identified on design drawings were lacking inspection h== itation in the form of MSSWRs.
- Inspection Verification Plant On August 17,
- 1984, an inspection verification effort was initiated at the direction of project managenent to provide an accurate assessnent of 4
the "as-built" conditions of safety related strucutral steel welded m.rdone with unretrievable MSSWR's.
These activities are being performed by a ocsbined team of DIC and Architect - Engineer AWS Certified Welding Inspectors under direct supervision of ICriE Castructicss QC. These activities 4
are being performed in ac mrdance with written instructions issued by ICsiE Castruction QC Mticts reflect the criteria of AWS D1.1-1975 and the applicable Architect - Engineer design documents. %e results of these verifications and the review of Surveillance Report S-372 have caused the finiings in Section E of this report to be issued.
D.
Requirements te welding of safety related structural steel w.-rdons at WCIIS is governed by welding code AWS D1.1-1975.
h e WCXiB FSAR invokes this code for endt safety related structure. In additicas, SNUPPS project specification 19466 C-122 (Q) Rev. O through 14 entitled
" Technical Specification for Centract for Erection of Structural Steel for the (SNUPPS)
Power Plant" and specification 16466<-132(Q), Rev. O through 8 titled " Technical Specification for Erecting Miscellaneous Metal for the Standardized Nuclear Unit Power Plant Systen (SNUPPS)" requires structural steel welds to be performed in accordance with AWS Dl.1-1975, with exceptions in the criteria for undercut (para.
8.5.2) and weld convexity (para.
8.5.3).
E.
Findings - Tscacts - par-nanded Ocerective Acticms The five findings listed below were identified during the two WCGS managenent assessments described in the ' Background Information' section of this report and a review of Surveillance Report S-372 by ICriE OA.
Collectively, these represent a breakdown of the constructor's Quality Assurance program.
This conditicrt was caused by an apparent inconsistent application of weld inspection i
criteria, failure to inplement re aral requirements for docu-i menting inspections, and failure to inplement effective amw.ive actions for identified deficiencies.
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Pirdiru $1 '!he restits of the Document Rocare11 Mim Task irwH=ted that 1589 of 6816 M! stats far omfety related structaral staal welds are missing. (See Attadnent 80 Irreact:
Without the documentation for the structural welds, the following areas.are indeterminate:
- welder identification and qualification
- Filler metal traceability
- Visual inspection results
- Qualified weld procedures specificaticn used 1
i Reccznanded Corrective Actions:
Actions la through lh below will adequately address all of the concerns identified in Firding #1 and the " root cause" concerns associated with Finding #2.
la. Based cm DIC program requiranants, assure that all of the "
welders and welding procedure specifications were qualified to AWS Dl.1 - 1975.
lb. Review the DIC program for the purchase and centrol of filler l
material to ensure that only acceptable filler material was used in safety related structural steel welds.
Ic. Evaluate the
=A-u=7 of the DIC inspecticn criteria and procedures to determine ~ if these elements could have adversely impacted either the results of the initial inspec-tiens or the results of the verification plan.
Document and provide this evaluaticn to lad!: QA for review prior to any additional inspection implenantation.
Any changes in inspection criteria and procedures shall be provided to IGJ!:
QA for review.
4 Id. Obtain a documented evaluation to determine the valirHty of inspections performed with the presence of paint on the weld.
le. 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 emn4=nt of the DIC Quality Inspection program requirenents.
If. Perform a 100% reinspection of all structurally significant safety-related structural steel welds with missirs; MSSWR's.
'Ihe identification of " structurally significant" welds shall be made by the Architect Engineer (See Attachment B).
Inspect the welds per roccumendations ic, id, le, Ig, lh and 2a.
Ig. Use an NCR to obtain and h== st a suitability for service j
evaluation of inaccessable welds.
I lb. Report all identified deficiencies on an NCR.
.. _.... _... -...,..... _. _ _ _ _..,. ~,. _ _. _ _ _. _........ _ _ _, _., _ _,. _, _, _.,
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Page 5 Finding $2:
An inan=r+4r= verifimtien effort of safety-related structural staal weldisq, undertaken by AMS certifed weld L idon iriad several armes of.
e d=fid anti==.
%ese d=FiM ant-i==
have been
@ halemag
- Under=i==d welds
- Wald defects
- Incorrect omsfiguration
- weld underrs=
- weld undercut Innact:
nese deficiencies could jeopardize the structural integrity of the connecticn.
Re_u... rded Corrective Actions:
Actions 2a through 2d below will adequately address all of the concerns identified in Finding #2 and the investigative actions required by Finding #5.
2a. Determine and docment the " root cause" of the previous accep*m of deficient structural welds.
Analyze the HVAC
- Support, Electrical Support, Pipe-Whip Restraint and any other safety-related
.u.4-u utilizing ANS Dl.1 Welding to i
ensure that the same " root causes" inherent in the structural steel welding m=u were not generic to other programs.
2b. Perft :m a 100% reinspection of all structurally significant saf'
-related structural steel welds having MSSWR's.
Se ide., -fication of " structurally significant" welds shall be made oy the Architect - Engineer (See Attachment B).
Inspect the welds per reccmmendations ic, id, le, Ig, lh, and 2a.
2c. Evaluate the results of the cmpleted Inspection Verification Plan against the acceptance criteria used in Acticn Ic.
2d. Any identified deficiencies shall be doct ented en an ICR.
Finding 93: A small ramtser of safetr-related structural steel welds were not nede or had missing material.
Imoacts
@ e structural integrity has possibly been jeopardized.
Rs u...=cded Corrective Action:
The folloaing action and the l
eng2r.eering disposition will adequately address Finding #3.
l 3a. Forward the "as-built" information t.o the Architect Engineer via an NCR to obtain an enginesting evaluation and dispositicn.
i
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0 Page 6 Finding Ms One (1) weld was Anrsmar*mi as having been inspected den in reality the weld was not :ade. (Ref. NCR ISGM950t)
Intmet: 'Ihe inspector so made the error could have W1y
@==nted other welds.
The structural integrity has possibly been jeopardized.
i Rectmnended Corrective Action:
The following acticn will ade-quately address Find 2ng 94.
4a.
Investigate the concern to determine the root amuse of the error.
T==diately notify IC&E Quality Assurance if any other problans of this nature are identified, nrv,M the investigative actions. The notification of IGEE CA shall not preclude the issuance of an NCR.
Finding $5: (bjective evidence that the mecbanical and structural waiaing 494rmfanc,-areme irm #1=m== ider*i Mad in EEE OfL Survm411mer= Report S-372 were recti N =4 has not hamn provided.
Imcect:
'Ihere is a
possibility that the mechanira1 and structural support welding inspecticn/d<v'==ntation problems identified in the Surveillance Report were not corrected.
Recartnended Corrective Action:
'Ihe following action will ade-quately address Find 2ng #5.
Sa. provide objective evidence that the mechanical and structural support welding inspecticn/doctanentation problens identified in Surveillance Report S-372 have been corrected. If such evidence is not available, research the extent of the problem and take the appropriate remedial actions.
F.
Rectmnanded Corrective Actica Flow Diagrams i
See Attachment C.
1 1
4 l
I
~..
.J
X kJ - '.
AWACHMINT A LE: KSLNRC DATE: 9 /18/g4 TE: 40675-K152 TIME: 3:00 TE: 53564-152 TELEPHONE C'ALL RECORD FROM: OMaynard. BRudoloh.
TO: Lawrence Martin MLindsav. CParry COMPANY: NRC-Recion IV ADDRESS: Arlinoton. Texas i
TELEPHONE NO.: 817/860-8100 (use ink)
SUBJECT:
Potential 10CFR50.55(e) Inspection of Welds.
Martin that during our re-inspection of welds for We informed Mr.
which we had no inspection records, we identified 4 welds on the containment cooler platfrom and 4 lateral supports for the incore instrumentation tubing that were not installed.
We are investigating to determine whether or not the condition was documented and why they had not been installed.
RECSVED sezsg4
...,,.,c:S, _
m.
ACTION REQUIRED AND DATE:
Licensing coordinate 30-day report -
due:
10/18/84 DISTRIBUTION G Koester H Bundy/B Bartlett /W Guldemand F Rhodes F Duddy.
R Pogue/F Zaval M Williams G Fouts C Parry /M Lindsay R Hagan R Grant J Bailey /D Prichard,,
M Johnson W Rudolph A Beat G Rathbun R Glover S Seiken
/
.//
4//
L Stevens G Baker
~~ ignature [
(s F Field B Meyer
\\
e ATDOM!NF B 1.
Definitim of Mi=r=11mneous structural Steel:
Miscellaneous Structural Steel is divided into two (2) parts for the purposes of this CAR.
A.
Main Free and Amwinted Marters:
Main frame welds are those welds on structural steel connections which support the main building floors (concrete or grating) and roofs.
For efficiency, these connections are identified on a "per drawing" basis rather than categorizing each piece of steel individually.
'Iherefore, it is inevitable that this category will include certain " associated" connections, such as, welds other than those which support main building floors and roof, which are depicted on drawings primarily showing main building ficor and roof steel.
B.
Miscellaneous Miscellaneous welds connect steel
. hich does not support main w
building floors or roofs (i.e.,
all structural steel welds not classified as main frame or associated welds).
'Ihis does not include hand-rails, too-plates, and similar ites.
2.
Definiti m of structurally Significant Welds:
Those welds which are required in the catpleted building structure to support and protect safety related aqni = =nt and building w w
.a.
Welds for ternporary supports, non-safety related supports, hand-rails, toe-plates, and similar items are not considered to be structurally significant by this definition.
1
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