ML20151Z056
| ML20151Z056 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 08/18/1987 |
| From: | Lewis J, Pate B, Rose J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20151Z000 | List: |
| References | |
| WP-16-BFN, WP-16-BFN-R, WP-16-BFN-R00, NUDOCS 8808290149 | |
| Download: ML20151Z056 (12) | |
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l WELDING PROJECT EMPLOYEE CONCERN
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i EVALUATION REPORT l' STRUCTURAL STEEL PREWELD INSPECTIONS AT BROWNS FERRY NUCLEAR PLANT PREPARED BY eM AI.4 M/M87 WP/ECTC 0 ' ' '
REVIEWED BY \ab' h, O[/@/Ol DNC/WP REVIEWEDBYM Me ((hudr /
DNQA REVIEWED BY .#aoms 7 _M "w.
/1 2 / P Y CEG-H, WELDING
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APPROVED BY OAAAtA h. c4'd' PROGRAM MANAGER
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R'eport Number WP-16"-BFN Revision 0 \
Date R - /A- 0 7_ __ \
4 8808290149 880822 PDR ADOCK 05000259 p PNV I
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- ( WP-16-BFN Revision 0 EMPLOYZE CONCERN
SUMMARY
SHEET STRUCTURAL STEEL PREWELD INSPECTIONS AT BROWNS FERRY NUCLEAR PLANT I. SCOPE OF EVALUATION This report addresses seven employee concerns dealing with structural steel preweld inspections at Browns Ferry Nuclear Plant (BFN). These concerns were grouped into two issues to aid in the evaluation effort.
A. General Construction Specification G-29C, Process Specification 0.C.1.1, which allows uncertified welder foremen to perform preweld inspections, is in conflict with ANSI, AWS D1.1 and the TVA Quality Assurance commitments.
B. General Construction Specification G-29C is in conflict with the requirements of AWS D1.1 by allowing inspection of welds through
, carbo-zine primer.
- The text of the concerns may be found in the technical report l (WP-16-BFN) under Attachment 1.
II. ANALYSIS OF ISSUES -s0RESSED BY CONCERNS The issues addressed by this evaluation evolved from six concerns from other TVA sites that were applied to Browns Ferry for evaluation for generic implication and one Browns Ferry site speelfic concern.
A. One issue implies that uncertified welder foremen performing i
preweld inspections on installations they are directly responsible
} for is in violation of ANSI AWS D1.1, and TVA Quality Assurance Commitments. The change to Process Specification P.S.O.C.1.1, which allowed welder foremen to perform preweld verifications (fitup), prompted several questions regarding TVA's commitment to ANSI N45.2.5. These concerns resulted in a Bellefonte audit finding.
Results of an investigation and evaluation, initiated due to the Bellefonte audit finding showed that TVA was in compliance with its ,
quality assurance commitments.
This issue is discussed in detail in Weld Project Report WP-16-BFN, Paragraph III A.
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WP-16-BFW Revision 0 B. One issue implied that the General Construction Specification G-29C was in conflict with AWS D1.1 by allowing inspeciton of welds through carbo-zine primer. This issue is discussed in detail in. ,
Weld Project Report WP-02-BFN, and is not addressed further by this evaluation.
III. COLLECTIVE SIGNIFICANCE This evaluation revealed no hardware or programmatic deficiency.
IV. ROOT CAUSE(S) -
The basic reason for the employee concerns is the perception that the i 1
change to the process specification violated or contradicted the TVA I Quality Arsurance Program, ANSI N45.2.5 and the installation code AWS Dt.1. This perception evolves from the misunderstanding of the intent )
j os the construction code and TVA's commitment to the requirements of ANSI N45.2.5.
V. CORRECTIVE ACTION No corrective action is indicated.
VI. REINSPECTION REQUIRED No.
VII. ISSUE CLOSURE Closed.
VIII. ATTACKMENTS
- 1. Evaluation Report WP-16-BFN.
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WP-16-BFN Revision 0 WELDING PROJECT, EMPLOYEE CONCERN EVALUATION REPORT STRUCTURAL STEEL PREWELD INSPECTIONS AT BEOWNS FERRY NUCLEAR PLANT or s o.
I. SCOPE OF EVALUATION This report addresses seven employee concerns. Text of the concerns is provided under Attachment 1.
Six of the subject concerns originated at other TVA sites, and were generically applied to Browns Ferry Nuclear Plant (BFN). This evaluation is based on review of the BFN Welding Phase 1 Report, current and cuperseded process specifications and construction implementing procedures and the Weld Project Report WP-16-SQN. Also s reviewed were the BFN Corrective Action Reports, Nonconformance Reports, the TVA Topical Report, and the AEC/USNRC Inspection Reports.
The American Welding Society Structural Welding Code AWS D1.1-72. AWS D1.1-86 and American National Standard ANSI N45.2.5-74 were reviewed and compared with the text of the concerns.
II. ISSUES ADDRESSED BY CONCERNS A. General Construction Specification G-29C Process Specification 0.C.1.1, which allows uncertified welder foremen to perform preweld inspections, is in conflict with the TVA Quality Assurance Commitments, ANCI requirements and AWS Dl.1.
B. General Construction Specification G-29C is in conflict with the requirements of AWS D1.1 by allowing inspection of welds through carbo-zine primer 5
III. ANALYSIS OF ISSUES ADDRESSED BY CONCERNS A. Six concerns state that uncertified welder foremen performing preweld inspections on installations they are directly responsible for is in violation of ANSI, AWS D1.1 and TVA Quality Assurance Commitments. These concerns are not factual.
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WP-16-BFW Revision 0 In the foreword to ANSI Ne5,2, Quality Assurance Program Requirements for Nuclear Power Plants, it is stated in part.
". . . This standard sets forth the general provisions for planning, managin5, and performing overall quality assurance programs but does not define specific or detailed technical requirements for achieving quality . . . . " Paragraph 6 states in part " . . . Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures or drawings.
Instructions, procedures or drawings shall include appropriate .,
quantitative or qualitative criteria for determining that important activities have been satisfactorily accomplished . ... "
At paragraph 11 it states in part, " . . . .. program for inspection of activities affecting quality shall be established to verify conformance to documented instructions, procedures, and drawings for accomplishing the activity. Inspection activities to verify the quality of work shall be performed by persons other than those who performed the activity to be inspected . .. . " Paragraph 11 further states in part " . . . If inspections of processed items is impossible or dicadvantagecus, indirect control by monitering shall be provided . ... >
ANSI N45.2.5, "Supplemental Quality Assurance Requirements for Installation. Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants," Section 1 at 1.2 states in part " . . . The extent to which individual requirements of this standard apply will depend i
upon the nature and scope of the worx to be performed and the importance of the item or service involved . "
.. . Paragraph 5.5 requires in part that inspection of structural steel welding shall be performed in accordance with the provisions of AWS D1.1, Section 6, and inprocess inspections shall include joint fitup prior to start of welding.
l Addendum 1 to Process Specification P.S.3.C.S.2, Visual Examination of Welds was issued in February 1979. This change to P.S.3.C.S.2 allowed individuals who sere not certified inspectors to perform preweld verifications of structural wolds.
l This requirement was later adopted by P.S.O.C.1.1, Specification for Wolding of Structures Fabricated in Accordance With AISC l Requirements For Buildings. This change to P.S.O.C.1.1 was issued
! in revision (a) on September 1, 1981 and established the I
requirement that the welder foreman perform the preweld verifications.
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WP-16-BFN Revision 0 The change to Process Specification P.S.3.C.5.2 prompted several questions regarding TVA's commitment to ANSI N45.2.5. This issue was identified as a finding in the Bellefonte Quality Assurance Audit Report BN-W-80-08 and was determined to be significant and reportable as a 10CFR50.55(e) condition. It was reported as applicable to all TVA sites under construction. In response to the audit finding, an extensive investigation and evaluation of AWS D1.1, ANSI N45.2.5, and TVA's commitments were performed to determine what corrective action, if any, was necessary. In the area of weld fitup inspections, it was determined that TVA had been overly conservative in their past interpretation and that an "
inprocess (surveillar.ce) inspection by Quality Control would satisfy the requirements of AWS C1,1 and ANSI N45.2.5. TVA was in compliance with its commitment to ANSI N45.2.5. In that TVA has taken the same exception to ANSI N45.2.5 in the Topical Report for operating plants, the results of the investigation also apply to Browns Ferry.
DPM No. N73M2 Process Specification 0.C.1.1 at Section 6.2 requires in part that Weld Joint Dimensions (Fitup) shall be v'rified, by the welder foremen, to be correct using the quality et.atrol program of 6.3 to 6.7. Section 6.3 requires in part that each foreman's work be monitored, by QC, two.;g~n a surveillance program at least or.ce every two weeks to verify the foremen are properly performing the required activities of Section 6.2.
Browns Ferry Standard Practice SP BF-6.2, "Quality Control of Welding," issued at 6-29-83, at Section 6.3.3.1 states in part.
"Fitups shall be verified by QC Inspectors af ter components have been secured in place by tack welds or mechanical methods. The inspection shall be performed prior to welding per the requirements of N80E3 (now PMP 1502.07), N-VT-2 or N-VT-3 and applicable drawings." Site Director Standard Practice SDSP 13.1 "Quality control of Wolding Activities," which superseded SP BF-6.2 on 11-17-86, adopted the same criteria.
PMP 1502.07 Procedure No. N-VT-2 defines the requirements and acceptance standards for visual examination of welded joints in buildings and tubular structures in accordance with the requirements of the AISC Specification and the AWS D1.1 Code. In the scope of N-VT-2 it states in part that "Only whet. specified by the design drawing or by the work instruction, shall the inspector be required to verify the requirements of paragraphs 4.0 and 5.0."
Paragraph 5.0 identifies activities to be verified prior to welding to include fitup.
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WP-16-DFW Revision 0 AWS D1.1, Section 6, states "The inspector designated by the engineer shall ascerta8n that ail fabrication by welding is performed in accordance with the requirements of this code."
Section 6 further states "The inspector shall examine the work to make certain that it meets the requirements of Section 3 and 8.15, 9.25 and 10.17 as applicable." (Section 3 addresses workmanship requirements and Soction 8.15, 9.25 and 10.17 address requirements for final visual inspection.) Clarification of AWS intent on proweld inspections states, "Except for final visual inspection, which is required for every weld, the inspector shall inspect the work at suitable intervals to make certain that the requirements of -
the applicable sections of the code are met. Such inspection, on a sampling basis, shall be made before assembly, during assembly and during welding."
Surveillance or spot inspections of preweld and in process activities for AWS D1.1 appilcations is an industry wide practice.'
Design Engineering and installation drawings establish mandatory hold points based on need, significance of the installation and sound engineering judgement.
The TVA Topical Report TVA-TR75-1A does not mandate that a 100 percent fitup inspection be performed by quality on all structural installations. The Topical Report Revisions 2 through 9 require that inspection is performed during maintenance, modification and repair to verify conformance with applicable requirements.
Instructions covering these inspection activities contain appropriate inspection requirements, to include mandatory hold points, which are in accordance with the original design.
This requirement it clearly defined in Revision 9 where TVA's conformance status to ANSI N45.2.5 is stated as "Verification of preweld activities, including fitup, will be verified through selective QC inspection, unless 100 percent inspection is specified by DNE in design output documents." Even though this commitment was not as clearly defined in the earlier revisions of the Topical Report, the intent has remained unchanged. Thus, TVA has always been in compliance with its quality assurance commitment relative to fitup inspections.
B. One concern stated that the General Construction Specification G-29C is in conflict with the requirements of AWS D1.1 by allowing l inspection of wolds through carbo-zine primer. This issue is 1 discussed in detail in Weld Project Report Wp-02-BFN and is not l addressed further by this evaluation.
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Revision 0 IV. COLLECTIVE SIGNIFICANCE This evaluation revealed no hardware or programmatic deficiency.
V. ROOT CAUSE(S)
The basic reason for the employee concerns is the perception that the change to the process specification violates or contradicts the TVA Quality Assurance Program. ANSI N45.2.5 and the installation code. AWS D1.1. This perception evolves from the misunderstanding of the intent of the construction code and TVA's commitment to the requirements of -
VI. CORRECTIVE ACTION No corrective action is indicated.
VII. ATTACHMENTS
- 1. Employee concerns I.
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( WP-16-BFN Revision 0 WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT
&TTACHMENT 1 TEXT OF EMPLOYEE CONCERNS Evaluation Report WP-16-BFN addresses seven employee concerns. The text of -
the concerns is shown on the following pages.
BEM-85-001-001 BEM-85-001-002-BFN-85-001-001.
BFN-85-001-002-WBM-85-001-001-WBM-85-001-002-WI-85-030-007-1 p
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REFEREttCE - ECPS152J-ECPS132C FREQUENCY - REQUEST TENNESSEE VALLEY AUTHORITY -
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ONP - ISSS - RIIt! OFFICE OF TJUCLEAR P0HER PAGE -II Ef1PLOYEE CarJCERf1 PROGRAM SYSTEM (ECPS) Ruts TIME - 11:56 l Et1PLOYEE RUN DATE - 03/16el CATEGORY: lie N0!1 QA/QC 1RLDItJG HPCONCERf4
- 16 IllFORTIATI0tt DY CATEGORY / SUBCATEGORY PERFORIIA!!CE OF PREllELD INSPECTIO!1S S
N 1 REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN REF. SECTI!
Cat CERif flut1BER CAT CAT D LOC BF BL SQ !!B
_ - = --- ----- - --- REPORT ORIGIti CAT - 1. '
CONCERN DESCRIPTION SUBCAT - 1 DEtt-85-001-00101 !!E 50716 N BLti 1Y Y Y Y T50227 2 SR SR SR SR QTC BELLEF0 tite - THE GENERAL CONST. SPEC
. G-29C, PROCESS SPEC. 0.C.I.1 IS IN CONFLICT HITH THE TVA QUALITY ASSUR ANCE Cat 1MITNENTS AS STATED BY THE TV A TOPICAL REPORT, TVA-TRTS-1A, IN TH AT PROCESS SPEC. 0.C.I.1, SECTION 6.
O ALLu.4S UNCERTIFIED HELDER FOREt1Ett, IIHO HAVE DIRECT RESP 0tiSIBILITY FOR 'L THE INSTALLATI0tl, TO PERFORM PRE!! ELD
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IllSPECTI0flS. HUCLEAR PO!!ER CONCF'Itt
. CI HAS NO FURTHER INFORt1ATIO!I. CS Qti R2)ISSUES ADDRESSED IN RPT HP-16-SQtt BEM-85-001-00201 HE 50716 N BLN .1 Y Y Y Y T50227 QTC 2 SR SR SR SR BELLEFONTE - UtiCERTIFIED HELDER FORE MEtt ARE REQUIRED BY TVA TO PERFORM P RE!! ELD It1 SPEC' TONS ON INSTALLATIONS THEY ARE DIRECTLY RESPO!!SIBLE FOR HH ICH IS A VOILATION OF AtlSI REQUIREt1E 11T S . 13UCLEAR POWER CONCERN. CI HAS f40 FURTHER INFORMATION. (SQN ISSUES ADDRESSED IN RPT HP-16-SQN R2)
BFM-85-001-00101 HE 50716 !! Bltt 1Y Y Y Y T50221 2 SR SR SR SR QTC BELLEFONTE - THE GEllERAL CONST. SPEC
. G-29C, PROCES3 SPEC.O.C.I.1 IS IN C0f3FLICT HITH THE TVA QUALITY ASSURA NCE C0tD1ITt1ENTS AS STATED BY THE TVA TOPICAL REPORT, TVA-TR75-1A, I!1 THA T PROCESS SPEC. 0.C.I.1, SECTI0ft 6.0 ALLOWS UNCERTIFIED HELDER FORT 1EN,IIH O HAVE DIRECT RESPONSIBILITY FOR THE O
IllST AL L ATION, TO PERFORM PREllELD Iti SPECTIDf1S. 14UCL EAR PO!!ER C0flCERN.
CI HAS 110 FURTHER INFORMATI0ft. (SQN ISSUES
) ADDRESSED IN RPT HP-16-SQN R2 C0!!CERtJS ARE GROUPED BY LAST 2 DIGITS OF SUBCATEGORY NUMBER.
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REFEREllCE - ECPS132J-ECPS132C FREQUEffCY - REQUEST TE!1NESSEE VALLEY AUTHORITY OFFICE OF flUCLEAR P011ER PAGE -
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EMPLOYEE C0flCERf! PROGRA!! SYSTEM (ECPS)
EMPLOYEE CONCERf1 INFORf1ATIO!1 BY CATEGORY / SUBCATEGORY RUf1 DATE - 03/16/
CATEGORY: !!E. fl0!1 QA/QC llELDIllG HP - 16 PERFORilAllCE OF PREHELD IllSPECTI0tlS S
H 1 REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL REF. SECTIl CONCERf1 HUf1BER CAT CAT D LOC CONCERN
--- ----- - --- BF BL SQ HB REPORT ORIGIN CAT - II CONCERf1 DESCRIPTION SUBCAT - l' BFf1-85-001-00201 !!E 50716 ft BFt1 1Y Y Y Y T50221 QTC 2 SR SR SR SR BR0!1ff'S FERRY - UNCERTIFIED HELDER F OREMEN ARE REQUIRED BY TVA TO PERFOR M PRE-HELD INSPECTI0f15 ON INSTALL ATI ONS THEY ARE DIRECTLY RESP 0flSIBLE FO R l!HICH IS A VIOLATIO!! 0F AftSI REQUI RE!!Ef4TS. NUCL EAR PO!!ER C0flCERN. CI HAS 110 FURTHER INFORf1ATIOff. (SQtt IS SUES ADDRESSED Ill RPT llP-16-SQft R2) #\
ll3M-95-001-00101 QA 80103 S HB!i 1Y Y fi Y T50227 QTC HATTS BAR - THE GEf1ERAL CollST. SPEC.
2 SR SR f1A SR G-29C, PROCESS SPEC. 0.C.I.1 IS IN 02 11E 50716 S HBN 1Y Y Y Y C0!1FLICT IIITH THE TVA QUALITY ASSURA 2 SR SR SR SR flCE C0t1MIT!1E!1TS AS STATED BY THE TVA TOPICAL REPORT, TVA-TR75-1A, III THA T PROCESS SPEC. 0.C.I.1, SECTIO!I 6.0 ALLO!!S UNCERTIFIED l-lELDER FOREf1 Eft, I!HO HAVE DIREc' RESPONSIBILITY FCR T HE If1 STALL ATIOff, TO PERFORI1 PREllELD If1SPECTIONS. 110CL EAR Poller C0!JCERTI.
CI HAS fl0 FURTHER INFOR!1ATIO!I. (SQ fl R2)ISSUES ADDRESSED IN RPT !!P-16-SQfi If Bff-3 5- 0 01-0 02CI !!E 50716 N SQft 1Y Y Y Y V50227 QTC SEQUOYAH - UNCERTIFIED llELDER FOREME 2 SR SR SR SR fl ARE REQUIRED BY TVA TO PERFOR!l PME IlELD INSPECTIONS ON If!STALLATfdNS TH
, EY ARE DIRECTLY RESPONSIBLE FOR Ilh!C H IS A VIOLATIO!I 0F AflSI REQUIRE!1ENT S. HUCLEAR PO!!ER C0!1CERN. CI hAS N #
O FURTHER If1 FORMATIO!I. (SON ISSUES A h DDRESSED If1 RPT HP-16-SQ!1 R2) '
CO.JCER!is ARE GROUPED BY L AST 2 DIGITS OF SUBCATEGORY fiUMBER.
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a REFERE!!CE - ECPS132J-ECPS132C FREQUErlCY - REQUEST TErlilESSEE VALLEY AUTHORITY Of1P - 1555 - Rict OFFICE OF flUCLEAR P0llER PAGE -
~5 EMPLOYEE C0tlCERif PROGRAll SYSTEM (ECPS) RUti TIME - 11:56:
CATEGORY: IIE tJ0ft QA/QC HELDI!JG EMPLOYEE CONCERN INFORf!ATIO!! BY CATEGORY / SUBCATEGORY RUN DATE - 03/16/
llP - 16 PERFORI1Af1CE OF PREllELD INSPECTIONS S
H I REPORT APPL SUD R PLT 2 SAF RELATED HISTORICAL CONCERN REF. SECTI CONCERT 1 fJUtlBER CAT CAT D LOC BF BL SQ HB REPDRI DRIGIN CAT - H:
_ ______ CONCERN DESCRIPTION SUBCAT - 14 lli 030-00701 IIE 50716 5 HBil 1 Y' Y Y Y 7501BS QTC 2 SR SR SR SR THE HBN FSAR COMMITS TVA TO THE REQU 02 IREMENTS OF AHS D.1.1 FOR STRUCTURAL
!!E 50702 S 51Bil 1Y Y Y Y HELDING. C0flTRARY TO THESE REQUIRE 2 SR SR SR SR MEr4TS, THE G-29C PROCESS SPECIFICATI Oil !!AS MODIFIED TO REFLECT LESS STRI t1GErlT It:SPECTION REQUIRE!!Et4TS (E.G.
VISUAL IllSPECTION OF HELDS THROUGH P AIllT (CARDO ZINC PRIMER) A!!D HD DOCU O f1EllTED IllSPECTION BY CERTIFIED VISUA L INSPECTORS (FIT-UP, Itt-PROCESS) PR
' IOR TO FIllAL I!JSPECTION.) CI HAS FIO ADDITIO!!AL IllFORf1ATI0ti. tiUC. Pot!ER DEPT. C0!JCERit. (SQti ISSUES ADDRESSED Ill RPT HP-16-SCf1 R2) 7 CONCERilS FOR CATEGORY HE HP'- 16 C0t1CERflS ARE GROUPED BY LAST 2 DIGITS OF SUBCATEGORY fiUMBER. -
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