ML20151Z038
| ML20151Z038 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/21/1987 |
| From: | Lewis J, Rose J, Shevlin E TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20151Z000 | List: |
| References | |
| WP-06-BFN, WP-06-BFN-R00, WP-6-BFN, WP-6-BFN-R, NUDOCS 8808290143 | |
| Download: ML20151Z038 (14) | |
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WELDING PROJECT EMPLOYE2_CONCERM EVALUATION REPORT INSPECTOR TRAINING AND CERTIFICATION AT BROWNS FERRY NUCLEAR P M PREPARED BY d - _
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SUMMARY
SHEET INSPECTOR TRAINING AND CERTIFICATION AT BROWNS FERRY WUCLEAR PLANT 1
I. SCOPE OF EVALUATION This report addresses six employee concerns dealing with the qualification and certification of welding inspectors perfot ains safety related work at Browns Ferry Nuclear plant. These concerns were grouped into four issues to aid in the evaluation et' fort.
A. Adequacy of welding inspector training.
B. ISI inspectors asked to perform inspections for which they were not qualified.
C. The Topical Report has degraded ANSI N45.2.6 with regard to qualification of inspection personnel.
D. An inspector should be a welder in order to know what to look for '
in a good weld.
l Text of the concerns is provided in the technical report (WP-06-BFN) under Attachment 1.
II. ANALYSIS OF ISSUES ADDRESSED BY CONCERNS A. Three of the concerns state that the training and experience of the welding inspectors is inadequate. The text of the concerns indicates that with two weeks to two months training, an otherwise inexperienced individual is allowed to perform weld inspections.
It is true that TVA issued limited weld inspection certifications based in part upon two. weeks of on the job training. This is not a problem, in that the training and testing was appropriate for the activities performed within the limits of the certifications. The
! Division of Nuclear Power qualification and certification program provides for such limited certifications, i
This issue is discussed in detail in WP-06-BFN Paragraph III A.
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Wp-06-BFN REVISION 0 B. Two concerns stated that ISI inspectors were asked to perform inspections for which they were not qualified. This concern is factual. It has no adverse effect, however, in that the verifications were not actually performed by the ISI Croup.
The issue evolved from the Inservice Inspection Group being asked to support Plant Quality Control in performing certain walkdown inspections. It was then learned that part of the work was outside the limits of the ISI inspectors' qualification, and they were removed from the assignment.
A detailed discussion of this issue may be found in Paragraph III B of WP-06-BFM.
C. One of the concerns stated in part that "The Topical Report has
' bastardized' ANSI N45.2.6 regarding qualification of insp9ction/ examination personnel."
Relative to welding inspectors, this concern is nct factual. TVA treats welding inspectors as nondestructive examination personnel.
The qualification and certification program is patterned an the guidelines of the American Society for Nondestructive Testing Recommended Practice SNT-TC-1A rather than ANSI N45.2.6.
Details of this issue are discussed in WP-06-BFN, Paragraph III C.
D. One of the concerns states that an inspector should be a welder in order to know what to look for in a good weld.
There is no code or regulatory requirement for a welding inspector to also be a welder. In the American Welding Society Certification Manual for Welding Inspectors, it is recognized that experience as a welder is of benefit to the inspector. It is, however, also stated that whether or not this is a requirement is the employer's option.
, III. COLLECTIVE SIGNIFICANCE No ef fect on hardware or the' TVA welding program at Browns Ferry was identified. The TVA program for qualification and certification of
) welding inspectors at Browns Ferry Nuclear Plant meets the requirements i
of the approved Quality Assurance Manual. This program satisfies the requirccents of U3NRC Regulatory Guide 1.58. Revision 1, as amended by the Topical Report.
IV. ROOT CAUSE(S)
The probable root cause of the employee concerns in this area is a lack of understanding on the part of the concerned individuals of the TVA program for qualifying and certifying welding inspectors.
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REVISION 0 Additionally, it is probable that the short t. raining time for the limited weld inspection certification led to a perception of program !
degradation. ;
V. CORRECTIVE ACTION l
No corrective action is indicated.
VI. REINSPECTION REQUIRED No.
VII. ISSUE CLOSURE Closed.
VIII. ATTACHMENTS
- 1. Evaluation Report WP-06-BFN, Revision 0.
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WP-06-BFN REVISION 0 WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT INSPECTOR TRAINING AND CERTIFICATION AT BROWNS FERRY NUCLEAR PLANT I. SCOPE OF EVALUATION Six employee concerns. Text of the concorns is provided under Attachment 1.
The Browns Ferry Weld project Phase 1 Report, the APTECH Report and Weld Project Report WP-06-SQN were reviewed. The Topical Report. USNRC Regulatory Guide 1.58, ANSI N45.2.6, and ASNT Recommended Practice SNT-TC-1A were compared with the expurgated text of the concerns. A sample of inspector training and certification records was reviewed and compared with the implementing procedures. The findings presented herein are based on the above noted reviews and interviews with cognizant TVA personnel.
II. ISSUES ADDRESSED BY CONCERNS A. Welding inspectors were inadequately trained prior to 1981.
Personnel with no experience inspected welds af ter a two week training program. Qualification and training of AWS weld inspectors is questionable. Level II certification is granted with only two months undocumented on the job training.
B. ISI inspectors were asked to perform inspections for which they were not qualified.
C. The Topical Report has degraded ANSI N45.2.6 regarding qualification of inspection / examination pe,rsonnel.
D. An inspector should be a welder in order to know what to look for in a good weld.
III. ANALYSIS OF ISSUES ADDRESSED BY CONCERNS A. Three of the concerns state that the training and experience of the welding inspectors is inadequate. The text of the concerns '
indicates that with two weeks to two months training, an otherwiso inexperienced individual is allowed to perform weld inspections.
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wp-06-BFN REVISION O It is true that TVA issued liuited weld inspection certifications based in part upon two weeks of on the job training. These certifications were limited to verification of weld size, length, and location. This is not a problem, in that the training and testing was appropriate for the activities performed within the limits of the certifications. The Division of Nuclear Power qualification and certification program provides for such limited certifications.
The procedure history for qualification and certification of welding inspectors at Browns Ferry was reviewed. Several cognizant TVA personnel were interviewed to determine the training and experience of the inspection personnel ever the life of the plant.
Additionally, a sample of the qualification and certification flies for personnel who had been certified by TVA for up to ten years was reviewed.
The three Browns Ferry units were in commercial operation prior to the issue of USNRC Generic letter 81-01, which required all licensees to either commit to Regulatory Guide 1.58 and ANSI N45.2.6 or provide an alternate plan for qualification of inspection personnel.
It is important to note that TVA welding inspectors are treated as nondestructivo examination (NDE) personnel under the guidelines of the American Society for Nondestructive Testing Recommended Practice SNT-TC-1A, rather thmn as inspectors under the rules of ANSI N45.2.6.
Review of the procedure history of Browns Ferry Nuclear Plant (BFN) and discussion with cognizant TVA Welding and Quality personnel revealed that during construction, visual examination of safety related welds was not performed as a separate function. Rather, all safety related welds were examined by the liquid penetrant (PT) process. Visual inspection was performed in conjunction with the PT exam. Discussion with TVA Welding and Quality personnel indicates that liquid penetrant examiners were trained in visual weld inspection and most,of the inspection personnel employed at BFN during the construction era completed the Training and Technology Program, a course of instruction in NDE methods conducted by Union Carbide Corp. at Oak Ridge Tennessee. This program was initially one year, and later reduced to six months duration. Discussion with a former program instructor supports other evidence that all NDE examiners were instructed in visual veld inspection.
In September,1969 Construction Procedure BF-27, Program for Administration of Nondestructive Testing Personnel Qualification and certification was issued. This procedure established training and experience requirements, general, specific, and practical examination requirements, and certification of NDE examiners, 13930 Page 2 of 7
WP-06-BFW REVISION O At this point, weld inspection was still being performed in conjunction with the PT examination. Visual inspection was not e addressed in this early procedure.
Construction Quality Assurance Procedure 2.3, Revision 5 Qualification Training, and Certification Requirements for Nondestructive Examination Personnel was issued in April,1981 to include the requirements for visual welding inspectors.
In June,1981, in USNRC Inspection Report 81-16, the Inspector noted that the implementing procedures for visual examination required that the examiners for visual inspection only be qualified for liquid penetrant or magnetic particle inspection methods. ASME Section XI required that the inspectors be qualified by examination for visual examination. At this time Procedure N-VT-1 was the implementing procedure for visual examination. This issue was closed by the NRC in July, 1982. In Inspection Report 82-22 the Inspector verified that N-VT-1 had been revised to require certification of visual weld inspectors. TVA had certified 20 inspectors to the new procedures, and training was continuing on an as needed priority basis.
The Division of Nuclear Power Certification Program for Nondestructive Examination Personnel, PKP 0202.14 Revision 0 includes the current requirements for welding inspectors in the operations activities. For construction activities, the requirements are currently defined in the Division of Nuclear Construction (DNC) Quality Training Program Manual Section III-2.
The DNC Quality Training Program Manual and the DNP PKP 0202.14 outline the training and certification requirements in the manner prescribed by The American Society for Nondestructive Testing Recommended Practice SNT-TC-1A. It should be noted that SNT-TC-1A does not specifically deal with visual examination. The cover of the document states that it is intended as a guideline for employers to establish their own written practice for the qualification and certification of their NDE personnel. This is further clarified in Articles 1 and 2. .
ASME Section XI, Rules for Inservice Inspection of Nuclear Power i
Plant Components requires that visual examination personnel be qualified and certified in accordance with the rules of SNT-TC-1A.
TVA has therefore established experience, training, and testing requirements using the other forms of NDE shown in SNT-TC-1A as
, guidelines.
l An apparent inconsistency exists between the DNC and DNP programs.
The DNC program requires three months experience and 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> training, where the DNP program requires six months experience with j
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> training for Level II welding inspectors.
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( V Wp-06-BFW REVISION O Discussion with cognizant TVA Quality Assurance personnel revealed that the Division of Nuclear Quality Assurance (DNQA) is in the process of issuing one procedure to control all welding inspector qualification and certification in the TVA system. This will resolve the inconsistency noted abovo.
A limited weld inspection certification has been issued to inspectors at TVA nucicar plants, including BFN. Due to the nature of this certification, an unusually short training period was required. These certifications allowed the inspectors to verify weld identification and size only. PMp 0202.14, at Paragraph 4.1.4 .,
provides for such limited certifications for specific applications.
A sample of the training and qualification records for personnel awarded this limited certification was reviewed by an outside contractor's Level III welding inspector. The personnel certified for verification of weld size and identification received an eight hour training session at the power Operetions Training Center, followed by a two week on the job training program, passing a general, a specific, and a practical examination was required prior to certification. A review of the records showed that the inspectors were trained in all of the necessary techniques used to verify weld size for both 90 degree and skcwed fillet welds. Use of the appropriate tools was included in the training. The examinations were more than adequately comprehensive to demonstrate proficiency within the limits of the certifications. The certification document described the limits of qualification in accordance with the TVA program.
Discussion with a cognizant TVA Qual'.ty Supervisor revealed that the purpose of this limited certification was to complete follow up work on the USNRC Bulletin 79-14 program. While the verification activity was primarily configurational, one of the requirements was to verify weld size.
A group of experienced hanger inspectors was trained to perform the weld size verification in conjunction with the mechanical verifications.
To provide additional assurance that TVA welding inspection personnel are properly certified for the activities being performed, a sample of the certification files was reviewed.
Weld records were used to identify inspectors who had performed visual examinations of piping and structural welds. It was then verified by the certification files that the inspectors were certified for the activities performed.
Training and experience used as a basis for certification was compared with the program requirements. Each of the files reviewed showed the individual to have had the required training and experience.
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WP-06-BFN REVISION 0 In most cases, individuals certified for visual inspection also had prior experience in liquid penetrant and/or magnetic particle testing. Additionally, most of the inspectors had received approximately 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> additional training at the time of recertification. This additional training is not required by the program.
During this review, it was noted that a previously identified discrepancy relating to certification dates had been corrected for later documents. Effective dates are now being entered on the certification document. -
It should be noted that the reviews of the training and certification records described above was not intended to be a statistically valid sample.
B. Two concerns stated that ISI inspectors were asked to perform inspections for which they were not qualified. This concern is factual. It has no adverse effect, however, in that the verifications were not performed by the ISI group.
One of the concerns also stated that when removed from the assignment, the ISI inspectors were replaced by other unqualified personnel. No evidence to support this part of the concern was found.
Discussion with cognizant TVA ISI personnel indicates that ISI inspectors are only assigned to inspections within their respective areas of certification. Each of the ISI supervisors contacted stated that he made a point to ensure that personnot are qualified for the tasks assigned.
One of the supervisors stated that approximately two years ago (early 1985), the ISI group was asked to assist in the (USNRC Bulletin) 79-14 walkdown. When the program actually began, it was learned that the loaned inspectors woro expected to perform tasks for which they were not trained or certified. Examples of these tasks are mechanical measurements and configuration voritications.
The ISI inspectors were removed from the assignment. They did not actually perform the tasks for which they were not qualified.
Discussion with a second ISI supervisor supported this account of the incident.
C. One of the concerns stated in part that "The Topical Report has
' bastardized' ANSI N45.2.6 regarding qualification of inspection / examination personnel." Relativt to welding inspectors, this concern is not factual.
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WP-06-BFN REVISION 0 The welding inspector in the TVA system has historically been treated as a nondestructive examiner. Weld inspection has evolved as a separate subdiscipline within the NDs field. During construction and early in the operational era, visual inspection was performed as part of the liquid penetrant examination.
It is true that the experience requirements for certification as a welding inspector are not in accordance with ANSI N45.2.6. Rather, TVA conducts the qualification and certification program under the rules of SNT-TC-1A. Topical Report TVA-TR75-1A states that ASNT Recommended practice SNT-TC-1A-1980 will be used to qualify and -
certify nondestructive examination personnel. Also, as mentioned in A above, ASME Section XI requires that visual examination personnel be qualified under the rules of SNT-TC-1A.
D. One of the concerns states that an inspector should be a welder in order to know what to look for in a good weld.
There is no code or regulatory requirement for a welding inspector to also be a welder. In the American Welding Society Certification Manual for Welding Inspectors, it is recognized that experience as a welder is of benefit to the inspector. It is, however also stated that whether or not this is a requirement is the employer's option.
i As the nuclear construction industry has matured, the role of the welding inspector has continually expanded. The inspector is often qualified in several inspection procesces, each requiring in depth knowledge of the application techniques and the acceptance criteria. He routinely deals with several different codes, standards and procedures. Quality assurance activities have broadened in scope to include every aspect of construction, maintenance, and modification. Welding inspection and nondestructive examination has evolved into a separate profession, making it no longer practical to assign craf tsmen or engineering j personnel to inspection duties.
[ IV. COLLECTIVE SIGNIFICANCE l
The TVA program for qualification and certification of welding inspectors at Browns Ferry Nuclear Plant meets the requirements of the approved Quality Assurance Manual. This program satisfies the requirements of USNRC Regulatory Guide 1.58 Revision 1, as amended by the Topical Report.
This evaluation revealed no hardware or programmatic deficiencies.
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l WP-06-BFW !
REVISION 0 i
V. ROOT CAUSE(S)
The probable root cause of the employee concerns in this area is n lack of understanding on the part of the concerned individuals of the TVA program for qualifying and certifying welding inspectors.
Additionally, it is probable that the short tralning time for the limited welding inspection certification led to a perception of program degradation.
VI. CORRECTIVE ACTION 4 i No corrective action is indicated.
VII. ATTACHMENTS
- 1. Text of concerns.
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WP-06-BFW REVISION 0 WELDING PROJECT ,
EMPLOYEE CONCERN EVALUATION REPORT ATTACHMENT 1 TEXT OF EMPLOYEt CONCERNS l
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SON-86-035-00201 HE 50206 il M il IY !! ti il flSRS 2 55 NA IIA IIA Dt'RIflG AN INTERVIElf C0 TIT ACT THE CI 5 TATED AtID L AIER DOCUttE!!TED THAT THE CI AtID F ELLOII ISI III5PECTORS !!ERE RE 110VED FROM PERFORHING !!EL D INSPECTIC IIS BECAUSE THEY HERE fl0T QUALIFIED. L ;
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