ML20151Z024
| ML20151Z024 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/17/1987 |
| From: | Lewis J, Rose J, Shevlin E TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20151Z000 | List: |
| References | |
| WP-03-BFN, WP-03-BFN-R00, WP-3-BFN, WP-3-BFN-R, NUDOCS 8808290139 | |
| Download: ML20151Z024 (14) | |
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l ' .,.I3 WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT WELDER QUALIFICATION AND CONTINUITY AT BROWNS FERRY NUCLEAR PLANT PREPARED BY
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WP-03-BFW Revision 0 I
WELDING PROJECT EMPLOYEE CONCERN
SUMMARY
SHEET WELDER OUALIFICATION AND CONTINUITY AT BROWNS FERRY NUCLEAR PLANT I.
SCOPE OF EVALUATION This report addresses seven employee concerns dealing with welder qualification and continuity in safety related applications at Browns Ferry Nuclear Plant (BFN). These concerns were grouped into four issues to aid in the evaluation effort.
Six of the concerns originated at Watts Bar and were evaluated for generic applicability to Browns Ferry. One concern is specific to Browns Ferry, initiated by the USNRC after a review of the Quality Technology Company files.
Text of the concerns is provided in the technical report (WP-03-BFN).
II.
ISSUES ADDRESSED BY CONCEttNS A.
The possibility exists that one welder could wold or complete a test plate for another welder.
B.
Welding by an uncertified we.1 der.
C.
Inadequato basis for velders' qualification continuity updates.
D.
Personnel whoso dutics do not requiro walding continae to have their qualification continuity updated.
III. ANALYSIS OF ISSUES ADDRESSED,.BY CONCERNS It should be noted that construction of the Browns Ferry Nucioar Plan'c was largely completed prior to the provisions of 10CFR50, Appendix D becoming mandatory.
A.
Two concerns raiso the issue that it may be possiblo for one wolder to wold, all or in part the test coupon for another welder during qualification testing.
Relative to Browns Ferry, these concerns are not factual.
No one except the Wold Test Supervisor is allowed to enter the test booth whilo a weldor is being tested.
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WP-03-BFN
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Revision 0 Paragraph III A of the technical report WP-03-B?N provides a detailed discussicn of this issue.
B.
The issua of welding being performed by an uncertified individual evolved from a USNRC review of the Quality Technology Company files.
There have been isolated occurrences of welders performing work outside their limits or qualification, i.e., diameter and thickness, or when their qualification continuity for the work could not be verified. These isolated occurrences were identified through :he ongoing TVA quality assurance activities and corrected. They do not represent a breakdown in the welder qualification program at BFN.
A detailed discussion of this issue may be found in Paragraph III B of WP-03-BFN-C.
The issue relating to inadequate basis'for welders' qualification continuity update stems from the TVA practice of using weld filler material issue as evidence of a welder having used a welding process. Also at issue is qualification continuity based on deposit of weld beads rather than complete weldments.
The TVA practices for welder qualification and qualification l(,
continuity are not in violation of code or commitment.
The methods employed at Becwns Ferry are similar to those in general use throughout the power construction industry.
Complete dohails of thic issuo are discussed in Paragraph III C.
WP-03-BFN.
D.
One of the concerns stntes that personnel whoso duties do not require welding continue to have their qualificction continuity updated. This would to f actual in any large construction or maintenAure operation, and is not a problem.
Details of this iscun are discussed in WP-03-DFN, Paragraph III D.
III.
COLLECTIVE SIGNIFICANCE No significant offect on hardware or the TVA Welding Program at Browns Ferry was identified.
The woldor performance qualification and qualification maintenance program at Browns Forry meets the requirements of Section 5 AWS D1.1-1972 and the current ASME Code,Section IX.
There have boon isolated instances of code and procedure violations in woldor qualification and continuity at BFN. These occurrences were ider9Afi.d and corrected by the ongoing TVA quality assurance activities, t.M dm not represent a breakdown in the wolding program.
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WP-03-BFN Revision 0 IV.
ROOT CAUSE(S)
Six of the seven concerns addressed by this evaluation were originated at Watts Bar and evaluated for generic applicability at Browns Ferry.
One concern, specific to BFN, was identified by the USNRC during a review of the QTC files.
Review of the deficiency reporting documents shows recurring reports of problems with qualification continuity.
These instances were, in most cases, traced to documentation problems.
The system of manually preparing and maintaining lists of welders' qualifications and update lends itself to error and omission.
V.
CORRECTIVE ACTION Watts Bar Quality Control Instruction QCI-4.02, Revision 8, provides an alternative to the manual maintenance of welder qualification continuity records. Implementation of a computerized control system at Watts Bar has been a significant improvement to the welder qualification and cont'.nuity program.
Qualification and continuity problems have been eliminated, principally due to implementation of the system described in WBN-QCI-4.02.
TVA should implement a system such as that described in Watts Bar l(k~
QCI-4.02 uniformly throughout its nuclear welding activities, VI.
REINSPECTION REQUIRED No.
VII.
ISSUE CLOSURE Open.
VIII. ATTACHMENTS 1.
Evaluation Report WP-03-SFN, Revision 0, l
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WP-03-BFM Revision 0 l( ~'
WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT WELDER OUALIFICATION AND CONTINUITY AT BROWNS FERRY NUCLEAR PLANT I.
SCOPE OF EVALUATION This report addresses seven employee concerns.
Text of the concerns is provided under Attachment 1.
Six of the concerns originated at Watts Bar and were evaluated for generic applicability to Browns Ferry. One concern is specific t1 Browns Ferry, initiated by the USNRC after a review of the Quality Technology Company files. The Browns Ferry (BFN) Welding Phase I Report, Weld Project Report WP-03-SQN, various audit and inspection reports, and the BFN procedure history were reviewed. The expurgated text of the concerns was compared with the requirements of the American I.
Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section IX, and the American Welding Society Structural Welding Code (AWS Dl.1), Section 5.
The findings presented herein are based upon the above noted reviews and di cussions with cognizant TVA Welding personnel.
II.
ISS'JES 1.DDRESSED BY CONCERNS A.
The possibility existe that one waldor could weld or completas a
test plate for another welder.
i B.
Welding by an uncertifled welder.
C.
Welders' qualification continuity upd.4tes.nde without objective evidence of the welder having used the specific process within the specified time frame, aidl rod istue slips 't. sed as the basis for update.
D.
Personnel whose duties have not requirod welding for several years continue to have their qualification continuity updated.
II.
ANALYSIS OF ISSUES ADDRESSED BY CONCERNS It must be noted that construction of the Browns Ferry Nuclear Plant i
was largely completed prior to the provisions of 10CFR50, Appendix B i
becomint, mandatory.
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WP-03-BFN
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Revision 0 l(k Notwithstanding the fact that the issues raised by the concerns were s
not subject to regulation for most of the construction period, the evaluation revealed that TVA at BFN did hcVe in plcee a program for welder performance qualification which met the requirements of ASME Section IX and AWS D1.0 (later replaced by AWS D1.1).
A.
Two concerns raise the issue that it may be possible for one welder to weld, all or in part, the test coupon for another welder during qualification testing.
These concerns, relative to Browns Ferry, are not factual.
Discussion with cognizant TVA personnel revealed that no one except the Weld Test Supervisor is allowed to enter the test booth while a wolder is being tested. Further, if the Weld Test Supervisor lesves the test shop for any reason, he collects all filler material prior to departure. Thi? makes it impossible for one welder to work on another's coupo.1 in the temporary absence of the Supervisor.
The weld test shop at BFN is similar to most, in that it is a relatively small area (approximately twelve booths) which makes supervisory conttol more positive than is possible in the general ccnstruction environment.
{ ((m B.
Based on a review of the Quality Technology Company ft:es, the USdRC voiced a concern relating to welding being performed by an uncertified wolder at Browns Ferry.
ihere have been isolated occurrences of welders performing work outsido their limits of qurlificettor., i.e, diameter and thickncst, or when the,4.c qualification continuity for the work could r.ot be verifled. These isciated occurrences were identified thecush the oi,go'.ng IVA quality assuranec activities and corrotted. They do rot repreget.t a breakdown in the welder i;ut.slification program at BFN.
Piping and mechanical welding was under proccdural control fecm the beginning of construction.
In March, 1965, the Division of Enginaceirt. Dest 6n issuoB che 'Qvalified soldins Proceduras and Welding specificottons foe Pleid Weldinf. of Principal Piplag, Low Pressure and Servico Piping, Steam Turbinos, and Boilor Conricc tions. " Iheso specificatione required welder performe(ee qualification to the latest edition of ASME Section IX rr USAS B31.1.
An engineer designated by the Project Manager was made responsible for "conductin; and cortifying perfo.'mance qualifications, and for keeping a record of all welders' qualification tests." Paragraph Q-26 required renewa) of a qualification when a wolder had not uced the specific process for a period of theco months or moro~.
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WP-03-BFN Revision 0 The ' Quality Control Handoook' was implemented in 1968. The level of specific detail one would expect to find in today's control i
systems was not in this early BFN procedure manuel.
There was, however, sufficient detail to show that welder qualification was the responsibility of the Construction Engineer.
Reference was made to the weldir.g procedures and specifications issued by the Division of Engineering and Design.
General Construction Specification G-27, Revision 0, "Quality Control for Construction in Piping Systems for Boiling Water Reactor Nuclear Power Plants," was issued in December, 1968. The construction Engineer was responsible for review and maintenance of welder qualification records.
At the beginning of construction, the control of welder qualification and continuity for structural welding was by direct application of the provisions of AWS D1.0 under the control of the Construction Engineer.
Review of Engineers' note and memoranda dated 1969 and 1970 showed that they were controlling welder qualification.
In October, 1970 Construction Procedure BF-60, ' Welders' Performance Qualification Testing' was issued to control all welder qualification ac EFN. This early procedure provided instruction for qualification testing. Maintenance of qualification continuity remained a process of direct code spplication.
Reference was made to ASME Section IX and AWS D1.0 for requalifications.
In May, 1971, BF-60 was revised to include instructions for maintenance of welder qualification continuity.
These instructions included a weekly report by the Foremaa showing which processes were used by each welder. A survey was required at least once each three months to ensure that no welding was performed by welders whose qualifications had expired.
Site Director Standard Practice SDSP-13.4, "Valder and Brazer Qualification and Continuity," is the current governing procedure for all welder qualification continuity activities at BFN.
Maintenance of welder qualification continuity is the responsibility of the Weld Test Supervisor.
Browns Ferry Nuclear Plant Standard Practice BF-6.2, "Quality Control of Welding," at 6.3.2.5 required that prior to the welder being allowed to start, his qualification would be verified by the Foreman and the QC Inspector.
In late 1986, Site Director Standard Practice SDSP-13.1 replaced BF-6.2 and made the same requirement at 6.3.2.5.
Site Director Standard Practice 13.2, "Welding and Brating Filler Material Control at Browns Ferry Nuclear Plant," at 6.6.2 provides control to prevent issue of filler material to an unqualified welder.
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WP-03-BFN Revision 0 Review of various inspection, audit, and discrepancy reporting docuu nts issued between 1968 and 1986 revealed that TVA at Browns Ferry has implemented a program for welder qualification and maintenatee of continuity which meets the requirements of AWS D1.1 and ASME Section IX.
This program has been regularly evaluated through AEC/flRC inspection, Quality Assurance audit. Construction Engineers' audit, inprocess inspection, and final review of pet, cess control documents.
Over the life of the plant, there have been several instances where an inspection report questioned the qualifice. tion or continuity of a welder. In most cases, this was shown to result from documentation errors, failure to post the welders' identification to the process control documents, or misfiling of documents.
In 1982 there was one instance where, due to an error in the process specification, welders used one process to requalify for all pec: esses in which they were previously qualified. For example, a shielded metal are test might have also been used to update a gas tungsten arc welding qualification.
This was identified through the ongoing quality assurance activities via Corrective Action Report 82-165. After a review of all welder qualifications, the affected welders were properly retested, with no failures. The process specification and implementing procedure Kere revised. Based on the fact that all of the affected welders passed the retest and that tho Weld Test Supervisor had observed each of the welders practice in all of the processes for which they were qualified, it was determined that this incident had no adverse hardware effect.
'/hile there have been isolated occurrences of welders operating outside the parameters for which they were qualified or after a qualification had expired, the majority of the reported qualification and continuity problems can be traced to documentation errors.
Browns Ferry has historically used manually prepared documents to verify and suspense welder qualification and continuity. The repeated manual preparation of qualification lists will inevit, ably lead to error and omission.
C.
Th:ee concerns state that welder qualification continuity is ur) dated Cither without objective evidence of the welder having used the process, or on the basis of wold rod issue slips. Two of the concerns state that qualification is updated by having the welder run beads of filler rather than completing an entire weld.
There is no code or regulatory requirements which specifies the method to be employed in verification that a welder has used a process within the prescribed time.
TVA has historically used the issue of weld filler material as a basis for verification that a welder used a given process.
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WP-03-BFN Revision 0 In Inspection Report 82-22, while closing a previously unresolved item, the USNRC accepted the use of the rod issue slip as a basis for qualification maintenance.
It should also he noted that this is a widely practiced method throughout the power construction industry.
If a welder's qualification is allowed to expire, AWS D1.1 and ASME Section IX require that one test coupon be made for each process in which the qualification is to be restored. Where the welder's qualification has not expired, observation or the individual using the process is an acceptable means of updating his continuity.
Also, the Weld Test Supervisor may not have recently had an opportunity to observe a we) der's performance, and ask him to place one or more beads in addition to verifying the issue of filler material within the prescribed time limit, j
The Weld Test Supervisor at Browns Ferry considers the filler material consumed rather than the filler material issued.
He compares the amount issued with the unconsumed amount returned.
If, in his judgement, the welder has consumed an insufficient amount of filler material during the qualification period, he may ask to observe the welcer's performance prior to continuing the qualification. This observation would not normally require welding a joint to completion.
Rather, the Supervisor is interested in the proper application of techniques such as are length, angle of the weld rod, and manipulation of the puddle of molten metal.
Thus, TVA practice at Browns Ferry meets the appropriate code requirements, and exceeds the procedural requirement for ensuring that the welder use each process for which he is qualified within the specified time frame. Also, SDSP-13.4 does not take advantage of a provision in ASME Section IX at QW-322 which allows a three month extension of qualification for one process when a welder uses another pr c?ss for which he is qualified.
D.
One of the concerns states that personnel whose duties have not required welding for several years continue to have their qualification continuity' updated.
This would be factual in any large construction or maintenance operation.
There is no reason to prohibit the niaintenance of quellfication continuity based solely on the fact that an employee's duties do not require welding on a regular basis. Many welders progress to Foreman or higher, and occasionally weld to maintain proficiency.
This may be done on production work or in practice at the weld test shop. In maintenance of these qualifications, all of the contenis discussed above apply.
There is an advantage to having this small, usus11y highly experienced pool of additional welders maintain their qualifications.
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They can be used in an emergency to perform welding operations when others may not be available, or when unscheduled work requires additional welders for short periods.
Maintenance of welder qualification for personnel whose duties normally do not require welding is not a violation of code, commitment, or procedure.
IV.
COLLECTIVE SIGNIFICANCE The welder performance qualification and qualification maintenance program at Browns Ferry meets the requirements of Section 5, AWS D1.1-1972 and the current ASME Code,Section IX.
No adverse effect on hardware was identified during this evaluation.
There have been isolated instances of code and procedure violations in welder qualification and continuity at BFN.
These occurrences were identified and corrected by the ongoing TVA quality assurance program.
No adverse trend was identified. The evaluation showed that welder qualification was the subject of Management, Quality Assurance, and Engineering attention throughout the history of this plant.
V.
ROOT CAUSE(S) g-I(s Six of the seven concerns addressed by this evaluation were originated at Watts Bar and evaluated for generic applicability at Browns Ferry.
One concern, specific to BFN, was identified by the USNRC during a review of the QTC files.
Review of the deficiency reporting documents shows recurring reports of problems with qualification continuity.
These instances were, in most cases, traced to documentation problems, wherein the welder was actually qualified for the process in use but the qualification was not documented correctly.
In some cases, the documentation was correct, but cot immediately available in the file.
The system of manually preparing and maintaining lists of welders' qualifications and updates lends itself to error and omission.
l VI.
CORRECTIVE ACTION i
l Watts Bar Quality Control Inspection QCI-4.02, Revision 8, provides an alternative to the manual mainterance of welder qualification continuity records. The Foreman certifies on the Welding Material Requisition that the welder has used the process on the date given. A copy of the requisition form is then forwarded to the Weld Engineering Unit for entry in a computerized listing.
This avoids the errors attendant to repeatedly making manual listings. An added advantage is the computer capability to project expiration dates well in advance, thus avoiding the likelihood of a welder or his supervisor allowing a qualification to czpire.
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WP-03-BFN Revision 0 C
Discussion with cognizant TVA Welding personnel indicates that implementation of this system at Watts Bar has bsea a significant improvement to the welder qualification and continuity program.
Qualification and continuity problems have been eliminated, principally due to impivmentation of the Jystem described in WBN-QCI-4.02.
TVA should implement a system such as that described in Watts Bar QCI-4.02 uniformly throughout its nuclear welding activities.
VII. ATTACHMENTS 1.
Text of employee concerns.
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Revision 0 WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT ATTACHMENT 1 TEXT OF EMPLOYEE CONCERNS Evaluation Report WP-03-BFN addresses seven employee concerns.
The text of the concerns is shown on the following pages.
EI-85-021-002 HI-85-077-N17 IN-85-346-003 IN-85-426-002 IN-85-480-004 IN-85-725-X14 IN-85-725-X15 l((
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y GEFERENCE
- ECPS132J-ECPS132C TENNESSEE VALLEY AUTHO*2TY FREQUENCY
- REQUEST PAGE 1s ONP - ISSS - RUM OFFICE OF NUCLEAR P0llER EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN TIME - 11:56:<'
EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY RUN DATE - 03/16/F CATEGORY: HE NON QA/QC HELDING HP - 03 HELDER PERFORMANCE QUALIFICATION CONTINUITY S
H I REPORT AFPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN REF. SECTIC COMCERN NUMBER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION SUBCAT - DE CAT
- HE EX 021-00201 HE 50103 N HBN 1Y Y Y Y IN-85-352-001 QTC THERE IS NO F ETHOD/DBJECTIVE EVIDENC T50069 2 SR SR SR SR E TO VERIFY THAT A HELDER HAS USED A SPECIFIC PROCESS WHEN THEIR HELD CA t
RDS ARE STAMPED /UP-DATED BY QC.
NO FOLLOH-UP REQUIRED - NO ADDITIONAL I NFORMATION AVAILABLE. (SQN ISSUES AD DRESSED IN RPT HP-03-SQN R3)
HH 077-N1701 NE 50103 N BFN 1Y N N N NRC NRC IDENTIFIED THE FOLLOHING CONCERN 2 SP NA NA NA FROM REVIEN OF THE QTC FILE:
"HELD ING BY UNCERTIFIED HELDER AT BRCHNS FERRY."
IN 346-00501 HE 50103 N HBN 1Y N Y Y IN-85-352-001 QTC HELDER CERTIFICATIONS ARE UPDATED ON T50026 2 SR NA SC SR EVIDENCE OF ROD HITHDRAHAL SLIPS.
THE PROCESS MAY NOT HAVE BEEN USED I N THE APPLICABLE TIME PERIOD. 90 DAY OR/80 DAY, DEPENDING ON ASME OR AHS
. (SQN ISSUES ADDRESSED IN RPT HP-03
-SQN R3)
IN 426-00201 HE 50103 N HBN 1Y Y Y Y IN-85-352-001 QTC UPDATING OF'HELDER CERTIFICATIONS IS T50065 2 SR SR SR SR INADEQUATE IN TH." f A HELDER IS ONLY REQUIRED TO PRESENT THEIR CARD FOR UPDATING AND SUMETIMES IS ASKED TO R
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UN A BEAD-NEVER A COMPLETE HELD.
N 0 FOLLOH-UP. (SQN ISSUES ADDRESSED I N RPT HP-03-SQN R3)
IN -C5-480-00401 HE 50103 N HBN 1Y Y Y Y IN-85-770-002 QTC HELDER CERTIFICATION UPDATE IS INADE T30031 2 SR SR SR SR QUATE. PERSONNEL MAY HORK IN A POSI TION THAT DOES NOT REQUIRE ANY MELDI NG FOR 5-6 YEARS BUT CERTIFICATIONS ARE CONTINUALLY UPDATED. HHEN THESE.
PERSONS RETURN TO HELDING NO TESTS ARE CONDUCTED. THEY JUST RUN STRING LRS TO UPDATE CERTIFI ATIONS. (SQN I SSJES ADDRESSED IN RPT HP-03-SQN R3)
CONCERNS ARE GROUPED BY LAST 2 DIGITS OF SUBCATEGORY NUMBER.
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REFEREllCE
- ECPS132J-ECPS132C TENNESSEE VALLEY AUTHORITY PA?E 2
FREQULf3CY
- REQUEST CFFICE OF fluCLEAR P0HER CUN TIME - 11:56:='
O!1P - 1555 - Rilft EMPLOYEE C0f!CERf4 PROGRAM SYSTEM (ECPS)
RUN DATE - 03/16/* ;
EMPLOYEE C0f4CERf1 I!1FORf1ATIOff BY CATEGORY / SUBCATEGORY CATEGORY: !!E F40ft QA/QC HELDING HP - 03 HELDER PERFORMAtlCE QUALIFICATION CONTINUITY S
H 1 REPORT APPL REF. SECTIt SUB R PLT 2 SAF RELATED HISTORICAL CONCERN CAT
- Hf CONCERfi NUf1BER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION SUBCAT - 02.
If3 725-X14PT HE 50119 S HBN 1N N Y N IN-85-725-X14 QTC HELDER RECERTIFICATION PROGRAM HAD I T50167 2 NA NA SR NA NADEQUATE SUPERVISORY OVERSIGHT:
IT COULD HAVE BEEN POSSIBLE FOR A GOOD 02 NE 50103 S HBN 1Y N N Y HELDER TO 11 ELD THE TEST PLATES FOR 2 SR NA NA SR AN INCAPABLE HELDER.
DETAILS KNDHN TO QTC, HITHELD TO MAINTAIN CONFIDEN TIALITY. (SQN ISSUES ADDRESSED IN RP T HP-19-SQft RI)
Iff 725-Y1501 HE 50119 S H3N 1N N Y N IN-85-725-X15 QTC THE CONTROL *0F HELDER RECERTIFICATIO T50167 2 NA flA SR NA N TEST PLATES HAS INADEQUATE: TEST PLATES BEGUf1 BY OllE HELDER COULD HAV 02 HE 50103 $ HBN 1Y Y N Y E BEEN COMPLETED BY All0THER HELDER.
2 SR SR NA SR DETAIL KN0!!!1 TO QTC-HITHELD TO MAIN T4iti CONFIDEFITIALITY. (SQft ISSUES AD DRESSED IN RPT HP-19-SQN RI) 7 C0f1CERNS FOR CATEGORY HE HP - 03 C0flCERf15 ARE GROUPED BY LAST 4 DIGITS OF SUBCATEGORY NUMBER.
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