ML20151Z015
| ML20151Z015 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/04/1987 |
| From: | Lewis J, Rose J, Shevlin E TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20151Z000 | List: |
| References | |
| WP-02-BFN, WP-02-BFN-R00, WP-2-BFN, WP-2-BFN-R, NUDOCS 8808290137 | |
| Download: ML20151Z015 (12) | |
Text
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WELDING PROJECT i
EMPLOYEE CONCERN EVALUATION REPORT INSPECTION OF WELDS THROUGH CARBO-ZINC PRIMER AT BROWNS FERRY NUCLEAR PLANT PREPARED BY 4/
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11640
WP-02-BFN Revision 0 C
I(s EMPLOYEE CONCERN
SUMMARY
SHEET INSPECTION OF WELDS THROUGH CAR 20-ZINC PRIMER AT BROWNS FERRY NUCLEAR PLANT I.
SCOPE OF EVALUATION This report addresses nine employee concerns dealing with inspection of AWS welds after coating with carbo-zine primer in safety related applications at Browns Ferry Nuclear Plant (BFN),
These concerns were grouped into four issues to aid in the evaluation effort.
A.
The process specification permitted inspection of AWS welds through coating of carbo-zine primer.
B.
"There may have been thousands" of welds inspected through carbo-zine primer. There is no documentation to show which welds were involved.
, g-C.
Inspectors did not understand the coating thickness requirement and
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therefore could not have inspected for compliance with the
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specification.
D.
No documented pre-weld and inprocess inspection by certified visual inspectors.
Text of the nine concerns is provided in the technical report WP-02-BFN under Attachment 1.
II.
ANALYSIS OF ISSUES ADDRESSED BY CONCERNS The issues addressed by this evaluation evolved from a major roinspection effort at Watts Bar Nuclear Plant, and are approximately bounded by the yeces 1982 and 1983.
The scope or the evaluation is therefore limited accordingly, and excludes the construction era of BFN.
A.
The issue of allowing inspection of primed welds evolved from a series of weld sampling reinspections at Watts Bar Nuclear Plant.
In early 1982, the process specification and the implementing procedure were changed to allow certain reinspections of structura?.
weldments without removal of the carbo-zine primer.
Previous practice had been to remove all coatings prior to any inspection i
being performed.
The process specification in question was site unique for Watts Bar, and was never implemented at Browns Ferry.
The BFN specifications and procedures meet the requirements of ANSI /AWS D1.1 l
11640 Page 1 of 3
WP-02-BFN Revision 0 lP '
This issue is discussed in detail in Paragraph III A of the technical report WP-02-BFN.
B.
One issue concerns the possibility that at Watts Bar there may have been thousands of welds inspected through carbo-zine primer, that TVA reports indicate only 100 to 150 welds were involved, and that there is no documentation to identify which welds were involved.
This issue evolved from a Nuclear Safety Review Staff report on the practice of reinspection of primed welds at Watts Bar, and has no application to the Browns Ferry Nuclear Plant.
Paragraph Ill B of Report WP-02-BFN provides further details of this issue.
C.
The issue involving the weld inspectors not understanding the techniques for measuring coating thickness has no application to-BFN. The issue stems from a special reinspection requirement which was only implemented at Watts Bar.
This issue is discussed in WP-02-BFN, Paragraph III C.
D.
The issue related to Process Specification G29C not requiring documented fit up and inprocess inspection by certified visual inspectors has been addressed by Weld Project Report WP-16-BFN, and is not considered further by this evaluation.
III.
COLLECTIVE SICNIFICANCE No significant effect on hardware or the TVA welding program t.t Browns Ferry was identified.
TVA rules for cleanliness of structural welds at final visual examination at Browns Ferry Nuclear Plant meet the requirement of ANSI /AWS DI.1, Paragraph 3.10.1.
IV.
ROOT CAUSE(S)
The root cause of the employee concerns in this area is the TVA decision to apply Watts Bar employee concerns to cther nuclear sites for evaluation for generic implications.
V.
CORRECTIVE ACTION No corrective action is indicated.
VI.
REINSPECTION REQUIRED No.
/
VII.
ISSUE CLOSURE i
Closed 11640 Page 2 of 3
WP-02-BFN Revision 0 VIII. ATTACHMENTS 1.
Evaluation Report WP-02-BFN.
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1 11640 Page 3 of 3
44 WP-02-BFN Revision 0 WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT INSPECTION OF WELDS THROU3H CARBO-2INC PRIMER AT BROWNS FERRY NUCLEAR PLANT I.
SCOPE OF EVALUATION This report addresses nine employee concerns. Text of the concerns is provided under Attachment 1.
The subject concerns originated at Watts Bar Nuclear Plant, and were generically applied to Browns Ferry Nuclear Plant (BFN) for evaluation. This evaluation is based on review of the BFN Welding Phase I Report, current and superseded process specifications and implementing procedures, and the Weld Project Report WP-02-WBN case flie. Also reviewed were the BFN Corrective Action Reports and Discrepancy Reports issued from 1982 through 1985, and the USNRC Inspection Reports for 1981 through 1984. The American Welding Society lg-Structural Welding Code, AWS Dl.1 was reviewed and compered with the
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expurgated text of the concerns. The findings presented herein are based upon review of the above noted documents and interviews with cognizant TVA personnel.
The issues addressed by this evaluation evolved from a major reinspe: tion effort at Watts Bar Nuclear Plant, and are approximately bounded by the years 1982 and 1983. The scope of the evaluation is therefore limited accordingly, and excludes the constt.Jction era of BFN.
II.
ISSUES ADDRESSED BY CONCERNS A.
Process specification. G-29C permitted inspection of AWS welds through coating of carbo-zine primor.
Inspection of coated wolds is not in accordance with the Structural Welding Code
( ANSI / AWS D L.1).
B.
TiA reports inlicate that 100 to 150 welds were inspected through carbo-ziac primer.
There is no documentatiors to show which wolds were involved.
"There may have been thoucands."
C.
Welding Inspectors did not understand the 5 mil (coating thickness) limitation for reinspection of primed wolds, and thereforo could not have inspected for compliance with Specification G-29C.
D.
No documented preweld and in-process inspection by certified visual inspectors.
11650 Page 1 of 4
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WP-02-BFN Revision 0 I("
\\s III. ANALYSIS OF ISSUES ADDRESSED BY CONCERNS A.
Seven of the concerns state that the Process Specification (G29C Spec. 3.C.S.4 Rev. a) allowed inspection of AWS welds through a coating of carbo-zine primer.
The American Welding Society Structural Welding Code, ANSI /AWS D1.1, at 3.10.1 requires in part that "
. Welded joints shall not be painted until after the work has been completed and accepted.
Had these concerns originated at BFN, they would not have been factual.
Process Specification 3.C.S.4 !s a Watts Bar unique document. A review of the Nuclear Power inspection requirements shows that this specification was not implemented at BFN.
PMP 1502.07, Procedure No. N-VI-2, Visual Examination of AWS Structural Welds is the approved procedure for use on safety related items at all operating nuclear plants.
Discussion with cognizant TVA personnel revealed that inspection of coated welds has not been implemented for the operating plants, except as provided in N-VI-6, which is discussed below.
Since July,1986 Procedure N-VT-2 has required in part that weld surfaces shall be free of paint prior to performing visual examination. Earlier revisions of the procedure, while not specifically prohibiting inspection of coated welds, did not provide for such inspection practices.
A review of Browns Ferry Discrepancy ReportJ. Corrective Action Reports, and NRC Inspectien Reports for the time frame boundlag this issua revealed no indication that acceptance inspections were being performed on coated welds.
PHP 1502.07 Procedure No. N-VT-6, Visual Examination of Structural We.'ds Using the criteria of Nuclear Construction Issues Group Standard NCIG 01 does provide for inspection cf coated welds under certain cor.ditions.
Under the control of Process Specificatior; 0.C.1.2, the criteria of N-VT-6 may not be implemented unless raferences in the Topical Report or the SAR, is limited to structures in which f atigue life is r.ot the governing condition, and requires explicit approval on the drawing by the Engineer.
H-VT-6 at 6.2 states, "These acceptan e criteria aro intended to be used for the final acceptance of welds in the uncoated condition."
Paragraph 6.2 states that the critoria may also be used for subsequent inspections after the welds have been coated with the concurrence of the Office of Engineering.
Further guidance is given t'nat reinspections relating to weldment cracking may require the removal of coating or the use of appropriate magnetic particle inspection.
11650 Page 2 of 4
T WP-02-BFN Revision 0 Clearly, the above review shows that the requirement of AWS D1.1 at 3.10.1 is satisfied, in that quality acceptance of painted or primed welds at Browns Ferry is specifically prohibited by specification and implementing procedure.
It is equally clear that the provisions of N-VT-6 are for certain reinspections only, under strict control of the Engineer.
Reinspection under the rules of NCIG-01 has in recent years come into widespread use throughout the nuclear industry.
This practice represents a proper exercise of the Engineer's judgment rather than a violation of the Structural Welding Code.
B.
One concern states that at Watts Bar there may have been thousands of welds inspected through carbo-zine primer, that TVA reports indicate only 100 to 150 welds were involved, and that there is no documentation to identify which welds were involved.
This concern evolved from a Nuclear Safety Review Staff report on the practice of reinspection of primed welds at Watts Bar.
In that the provisions of Process Specification 3.C.5.4 were not implemented at BFN and that the specifications and procedures specifically prohibit acceptance inspection of coated welds, this issue has no application to the Browns Ferry Nuclear Plant.
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C.
One concern stated that AWS weld inspectors did not understand the "5 mil" provision for inspection of carbo-zine primed welds as described in Process Specification 3.C.5.4, and therefore could not
, ave inspected for conformance.
h This concern relates to a specific requirement of Process Specification 3.C.5.4 that reinspection could be perfotmed on primed welds only where the prime coating did not exceed 5 mils thickness.
As stated above, the subject process specification was not inplemented at Browns Ferry.
The issue therefore has no application to the Broans Ferry Nucicar Plant.
D.
One concern stated in part that Process Specification C-29C did not requiro documented fit up and in-process inspection by cortified visual inspectors.
This concern has been addressed by Wald Project Report WP-16-BFN, and is not considered further by this evaluation.
IV.
COLLECTIVE SICNIFIC/dlCE This evaluation revealed no adverse effect on hardware or the TVA welding program at Browns Ferry Nuclear Plant. The IVA welding program at BFN meets the requirement of The Structural Welding Code.
AWS Dl.1-72 at 3.10.1.
11650 pago 3 of 4
D
'JP-02 -B FN Revision 0 7.
ROOT CAUSE(S)
The reason for the employee concerns relating to inspection of coated welds at BFN is the application of Watts Bar concerns to other TVA nuclear sites for evaluation for generic implications.
VI.
CORRECTIVE ACTION No corrective action is indicated.
VII. ATTACHMENTS 1.
Employee Concerns
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o WP-02-BFN-Revision 0 WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT ATTACHMENT 1 TEXT OF EMPLOYEE CONCERNS Evaluation Report WP-02-BFN addresses nine employee concerns. The text of the concerns is shown on the following pages.
IN-85-458-001 IN-86-019-001 NS-85-001-001 PH-85-040 001 WI-85-013-003 WI-85-030-007 WI-85-030-008 WI-85-041-006 WI-85-041-008 f
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!EFERENCE
- tCPS132J-ECPS132C TEllflESSEE VAttcY AUTHORITY PAGE IR EQUE!!CY
- REQUEST OFFICE OF llUCLEAR P0llER
.1 RUti TIME - 11 : 55 - *-
HIP - ISSS - RIE1 E!!PLOYFE COIICERN PROGRA!! SYSTEM (ECPS)
EMPLOYEE C0!!CER!I IIIFOR!!ATIO!! BY CATEGORY / SUBCATEGORY RUll DATE.- 03/16/a
- TEGORY: HE 110H QA/QC llELDIllG WP - 02 IllSPECTIO!10F HELD 3 THROUGH PAIllT S
H I REPORT APPL REF. SECTIC SUB R PLT 2 SAF RELATED HISTORICAL C0!ICERil C0flCERif HUMBER CAT CAT D LOC BF BL SQ IIS REPORT ORIGIrl CollCERil DESCRIPTIO!!
SUBCAT - 02 CAT
- IIL til 458-00101 glE 50702 tl ilBil iY Y Y Y Ill-85-458-001 QTC TVA USED IMPROPER If1SPECTION CRITERI T50105 2 SS SS SS SS A FOR Alls HELDS - MEf10 FROM Kil0XVILL E (POSSIBLY EllDES. 1980 OR 1981) ALL OHED IIISPECTI0tl THROUGH PAltlT.
IllDI VIDUAL FR0f1 Kil0XVILLE (K!!0Hil) IrlVEST IGATED THIS, BUT RESULTS ARE UNKil0llN CI HAS fl0 MORE IllF02MATION. (SQN ISSUES ADDRESSED Ill RPT HP-02-SQN R2
)
(Il 019-00101 HE 30102 H HBN 1Y Y Y Y QTC CI IS Cat!CERNED THAT HELDS HERE ACCE T50219 2 SR SR SR Sk PTED THROUGH CARBO-ZIllC.
ItlSPECTORS HERE DIRECTED VIA MEMO TG ACCEPT HC LDS THROUGH PAINT. CI COULD fl0T PRO e.
VIDE Ally ADDITI0 rial IllFOR!!ATI0tl. Url IT 1.
C0flSTRUCTI0ft DEPT. C0tiCERN (
SQft ISSUES ADDRESSED IN RPT HP-02-SQ fl R2)
IS 001-00101 IIE 50702 !! ;!Bil 1Y Y Y Y HS-85-001-001 QTC HELDS (AHS) IriSPECTED SUBSEQUENT TO T50022 2 SR SR SR SR PROTECTIVE COATING (CARB0 ZINC PRIMER
) APPLICATI0ti; FIllAL VISUAL HELD EXA MIllATI0ft OF STRUCTURAL HELDS IN CATE GDRY I STRUCTURES. It!CLUDIllG PIPE HA flGERS, CABLE TRAY SUPPORTS APID DUCT SUPPORTS; U!IIT 1 8 2 (SQti ISSUES ADD RESSED Ill RPT HP-02-SQll R2) pH 040-00101 HE 50702 N li3ti 7Y Y Y Y IN-25-458-001 QTC QA NANGERS HERE FREQUEllTLY PAINTED B T50203
- c SR SR SR SR EFORE THE HELDS NERE IIISPECTED.
AUX.
B UIL DIllG, REACTOR BUILDIll3 SI, ELE V. 742'-0", & 745'-0".
1983.
C0tiST RUCTION DEPT. CarlCERN. CI MAS NO FU RTHER DETAILS. (SQft ISSUES ADDRESSED IN RPT HP-02-SQN R2)
C0!!CERits ARE GROUPED BY LAST 2 DIGITS OF SUSCATEG0kY NUf1BER.
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O REFERE!!CE
_ CPS 132J-ECPS132C TEffMESSEE Va_ EY AUTHORITY
- - I PAGE FREQUEllCY
- REQUEST OFFICE OF tlUCLEAR P0llER
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CIIP - ISSS - Rlut EMPLOYEE CollCERf1 PROGRAM SYSTEM (ECPS)
RUM TIME - 11:54.-
EMPLOYEE Cat!CERif IllFOR!1ATI0tl BY CA12 GORY / SUBCATEGORY RUll DATE - 03/I4/E CATEGORY HE ll0L QA/qC llELDII:3 IIP - 02 IllSPECTI0tt OF H2LDS THROUGH PAINT S
H 1 REPORT APPL REF. SECTIt SUB R PLT 2 SAF RELATED HISTORICAL C0!!CERN C0tlCER!l !!Uf!BER CAT CAT D LOC BF BL SQ HB REPORT ORIGIll C0tlCERN DESCRIFTI0ft SUBCAT - 0; CAT
- Hi III 013-00501 HE 50702 !! HIN' IY Y Y Y WI-85-013-003 QTC G29C (CONSlRUCTION SPECIFICATIONS)AL T50114 2 SS SS SS SS LOHED HELDS TO BE IllSPECTED AFTER PA IllTIllG FR0!! 1981 1HROUGH THE Ello 0F
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THE !!ELDIllG sat 1PLI!!G PROGRAM. THIS IS Ill VIOLATIO!I 0F AHS DI.l.
CI HAS NO MORE IllFORMATI0fl.
(NOTE: THIS I TEM IS CURRE!!!LY UtIDER INVESTIGATION BY ERT.
THE REVISInti liAS MADE TO S EPARATE lHE ORIGINAL 003 C0tiCERN IrlT 0 TH0 DISTINCT CONCERilS.) (SQti ISSUE S ADDRESSED IN RPT HP-02-SQN R2)
HI 930-00701 HE 50716 S HBH 1Y Y Y Y QTC THE HBN FSAR COMMITS TVA TO THE REQU T50185
- 2 SR SR SR TR IREMEllTS OF AHS D.I.1 FOR STRUCTURAL HELDING. C0!!TRARY TO THESE REQUIRE 02 WE 50702 S HBN 1Y Y Y Y MEllTS, THE G-29C PROCESS SPECIFICATI 2 SR SR SP. SR Off HAS MODIFIED TO REFLECT LESS STRI flGEllT INSPECTI0tl REQUIREMENTS (E.G.
VISUAL IllSPECTICA 0F HELDS THROUGH P AIlli (CARBO ZINC 3RIMER) APID NO DOCU MEllTED INSPECTION dY CERTIFIED VISUA L INSPECTORS (FIT-UP, IN-PROCESS) PR IOR TO FIllAL INSPECTION.) CI HAS NO ADDITIONAL INFORMATION.
NUC. P0HER DEPT. CONCERil. (SQN ISSUES ADDRESSED IN RPT HP-16-SQtt R2)
III 030-00801 HE 50719 S HBN 1N N Y N QTC THERE MAY HAVE BEEli THOUSANDS OF NEL T50185 2 HA NA SR Na DS INSPECTED THROUGH CARBO-ZINC PRIM ER.
HONEVER, TVA REPORTS IllDICATE T.
02 HE 50702 S HBN 1Y Y li Y HAT Of1LY 100-150 HELDS HERE IllSPECTE 2 SR SR !!A SR D IN THIS MAffilER EVEft THOUGH THERE I S !!O DOCUMENTATI0fl IDENTIFYIllG HHICH HELDS HERE IllSPECTED THROUGH CARBO-
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ZIrlC PRIllER. IlUC. P0HER C0tlCERN. CI HAS NO ADDITIO!1AL IllFOR!!ATI0ff. (SQN ISSUES ADDRESSED Ill RPT HP-19-SQN R 1)
C0flCERNS ARE GROUPED BY LAST 2 DIGITS OF SUBCATEGDRY NUMBER.
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- EFEREi!CE
- ECPS132J-ECPS132C 1Et!NESSEE VALLEY AUTHORITY PAGE
-3 REQUE!!CY
- REQUEST OFF1CE OF HUCLEAR P0HER RUtl TIME - 11:56 f.
illP - 1555 - Rita EKPLOYEE C0!!CERil PROGRA!! SYSTEM (ECPS)
RUN DATE - 03/16/3 EMPLOYE2 C6NCERt! IllFORflATI0tl BY CATEGORY / SUBCATEGORY f
'TEGORY: HE 110N QA/QC HELD 1;10
!JP - 02 lilSPECTIO!I uF HELDS THROUGH PAI!!T S
H 1 REPORT APPL REF. SECTIO SUB R PLT Z SAF RELATED HISTORICAL C0tlCERN CAT
- IIE CollCERt! !! UMBER CAT CA(
D LOC BF BL SQ llB REPORT ORIGIN CollCERt! DESCRIPTION SUBCAT - 02 t II.-85-041-00601 HE 50702 !! HBN 1Y Y Y Y
EX-85-032-005 QTC AHS HELD It1SPECTOR(S) (UNK!!OHN) DlD i
T50193 2 SS SS SS SS NOT UtiDERSTA!ID THE "5 MIL" PROVISION i
FOR IllSPECTION OF COATED (CARBO-ZIsi-l C PRIMER) HELDS AS C0!!TAINED IN REVI SIONS OF SPECIFICATION G-29C, PROCED i
URE QCP-4.I3, AND HEHORANDUM DATED N OVEMBER 1981. IllSPECTOR(S) REFERRED i
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EFORE COULD NOT HAVE IMPLEMEllTED/ Ills TO CRITERIA AS "MILLIAMPS" AND THER 1
PECTED FOR C0tlFORt1At1CE. CI HAS NO A DDITI0tlAL INFOR!!ATI0tl. NUC P0HER DE PT. C0!!CER!i. (SQti ISSUES ADDRESSED I N RPT HP-02-SQN R2)
'!I 041-00801 HE 50702 N HBN 1Y Y Y Y I73-85-458-001 QTC PROCESS SPECIFICATION B3.C.S.4 0F G-T50193 2 SS SS SG SS 29C PERMITTED INSPECTI0tl 0F AHS HELD S THROUGH COATIllG (CARBO-ZIllC PRI!1ER
) FOR ELEVE!! N0!1THS AFTER EllGIt!EERIN G EVALUATIO!!/ TEST SH0HED THAT HELD Q i
UALITY (POROSITY, CRACKS, ETC) COULD 1
NOT BE IllSPECTED THROUGH PAINT. NU C POWER DEPT. C0t1CERN. CI HAS NO AD DITIO!!AL IllFORMATION. (SQN ISSUES AD DRESSED IN RPT HP-02-SQti R2) 9 C0t1 CERT!S FOR CATEGORY HE HP'- 02 C0!! CERT 1S ARE GROUPED BY LASY 2 DIGITS OF SUBCATEGORY NUMBER.
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