ML20151Z079
| ML20151Z079 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 04/20/1987 |
| From: | Lewis J, Rose J, Shevlin E TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20151Z000 | List: |
| References | |
| WP-35-BFN, WP-35-BFN-R, WP-35-BFN-R00, NUDOCS 8808290158 | |
| Download: ML20151Z079 (14) | |
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, WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT WELD INSPECTION PROCEDURES AT BROWNS FERRY NUCLEAR PLANT PREPARED BY / SI_ 8/0 67 WP./ECTG
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REVIEWED BY *E. k, d[N6l DNC/WP REVIEWED BY -
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0 REVIEWED BY _ /nanw Y<
un /2 2 / - F '? CEG-H, WELDING s'
APPROVED BY___ ~ WO d. c4td2 --- - PROGRAM MANAGER
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Report Number WP-L -BFN ,
Rev Date k ~ision20' l Bh P
12420
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WP-35-BFN Revision 0 WELDING PROJECT EMPLOYEE CONCERN
SUMMARY
SHEET WELD INSPECTION PROCEDURES AT BROWNS FERRY NUCLEAR PLANT I. SCOPE OF EVALUATION This report add' esses five employee concerns dealing with the adequacy of weld inspection procedures in safety related applications at Browns Ferry Nuclear Plant. These concerns were grouped into three issues to aid in the evaluatior. effort.
A. Adequacy of inspection criteria.
B. Welding and brazing inspection of safety related ductwork.
C. Reporting of defects.
Text of the concerns is provided in the technical report WP-35-BFN under Attachment 1.
II. ANALYSIS OF ISSUES ADDRESSED BY CONCERNS BACKGROUND Field construction on Browns Ferry began in September, 1966.
Construction was largely completed prior to the provisions of 10CRF50 Appendix B becoming mandatory. TVA committed to Appendix B in July 1972.
ISSUES A. The issue relating to th's adequacy of inspection procedures evo'1ved from two concerns stating that the visual examination procedure for ASME Section III is not specific, and that prior to 1979 there was no specific weld inspection criteria for use by inspection personnel.
A review of the procedure history for welding at Browns Ferry (BFN) showed that these concerns are not factual. At the beginning of construction in 1966, inspection was performed by direct application of the governing codes. A system of procedures ~
evolved, end at the time TVA committed to 10CFR50 Appendix B these procedures contained or made reference to all et the detail and criteria necessary to facilitate weld inspectivn .
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WP-35-BFN Revision 0 A detailed discussion of this issue may be found in the technical report WP-35-BFN, Paragraph III A.
B.- One of the concerns states that subsequent to 1981, welding and brazing inspection for safety related HVAC ductwork was deleted from the Quality Assurance Program without adequate justification.
This concern originated at Watts Bar Nuclear Plant and was evaluated for generic applicability to Browns Ferry. Relative to
- Browns Ferry, the concern is not factual.
The ductwork at BFN was fabricated and erected using mechanical means. In mid 1986, welded modifications to sheet metal ductwork were specified. At that time, TVA emplaced a procedure which included all of the necessary inspection requirements.
Details of the evaluation of this issue are addressed in Paragraph III B. WP-35-BFN.
C. The issue relating to reporting of defects evolved from two concerns stating NDE inspectors can only write a Notice of Inspection on inservice related defects, and that preservice defects can only be identified by a Maintenance Request.
These concerns are partially factual, in that the Notification of Indication is the specified form for reporting of unacceptable results found during nondestructive examination. This is in accordancs with the TVA Nuclear Quality Assurance Manual. The part of the concerns relating to preservice defects is not factual.
3 Reporting of inservice and preservice results is discussed in
- detail in WP-35-BFN, Paragraph III C.
III. COLLECTIVE SICNIFICANCE
.The employee concerns addressed by this evaluation have no adverse hardware or programmatic effect at Browns Ferry Nuclear Plant.
'The weld inspection procedur'es in use at Brown's Ferry provide all of the details necessary to meet the requirements of Section 4, AUS D1.1-72 ASME Section III-83, ASME Section XI-83, and USAS B31.1.0-67.
IV. ROOT CAUSE The apparent root cause of the employee concerns relating to inspection criteria and reporting of defects is that the concerned employees were .
not fully aware of the content of the procedures.
Additionally, the early procedures were often not stand alone' documents. They made reference to codes or specifications for implementing instructions.
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(( (( WP-35-BFN Revision 0 The concerns related to deleting HVAC duct welding from the quality assurance program were originated at Watts Bar and evaluated for generic applicability to Browns Ferry.
V. CORRECTIVE ACTION:
No corrective action is indicated.
VI. REINSPECTION REQUIRED No.
VII. ISSUE CLOSURE Closed.
VIII. ATTACHMENTS
- 1. Evaluation Report WP-35-BFN.
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WP-35-BFN Revision 0 WELDING PROJECT EMPLOYRE CONCERN EVALUATION REPORT LWELD INSPECTION PROCEDURES A,T BROWNS FERRY NUCLEAR PLANT I. SCOPE OF EVALUATION This report addresses five employee concerns dealing with the adequacy of weld inspection procedures in safety related applications at Browns Ferry Nuclear Plant. Text of the concerns is provided under Attachment 1.
A review was made of the procedure and specification history of Browns Ferry Nuclear Plant (BFN) from the beginning of construction to the present time. The Sequoyah Weld Project Reports and Nuclear Safety Review Staff investigation were reviewed. The expurgated text of the concerns was compared with the requirements of the Power Piping Code, the Boiler and Pressure Vessel Code, and the Structural Welding Code.
The TVA procedures and specifications were also compared with the codes in effect during each phase of the procedure history. The findings presented herein are based on the above noted reviews and discuselons with cognizant TVA Construction, Engineering, and Quality personnel.
II. ISSUES ADDRESSED BY CONCERNS A. Prior to 1979, there was no specific inspection critecia for use by inspection pefsonnel. The visual examination criteria which covers ASME Section III is nonspecific.
B. Welding and brazing inspection of safety related ductwork was l deleted from'the QA program without adequate technical
( justification. .
C. NDE inspectors.can only write a Notice of Inspection on inservice related defects. Preservice defects can only be identified by a Maintenance Request.
III. ANALYSIS OF ISSUES ADDRESSED BY CONCERNS A. Two of the concerns stated that the visual examination procedure for ASME Section III is not specific, and that prior to 1979, there, was no specific weld inspection criteria for use by inspection personnel. One concerned individual believed that this problem existed at all TVA plants. While often requiring referenco to codes or upper tier documents for specific details, the early BFN procedure system for inspection of wolds was adequato.
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WP-35-BFN Revision 0 The current procedures provide all of the necessary workmanship standards and inspection criteria. Prior to and after 1979, adequate wold inspection criteria for use at Browns Ferry Nuclece Plant did exist. Thus, with regard to DFN, these concerns are not factual.
Field construction on BFN Units 1 and 2 began in Se'ptember, 1966.
It should be noted that construction of Ere T.: Ferry was largely completed prior to the TVA commitment to 10CFR50 Appendix B in July, 1972.
PIPING AND MECHANICAL WELDING PROCEDURES In March, 1965, the volume, "Qualified Welding Procedures and Welding Specifications for Field Welding of Principal Piping, Low Pressure and Service Piping, Steam Turbines and Boiler Connections," was issued. At this time, inspection and nondestructive examination (NDE) was the responsibility of the Construction Engineer. While some details for NDE were provided in this early specification, inspection was in general accomplished by direct application of USAS B31.1.0-196 7, the ' USA Standard Code for Pressure Piping.' This code specified the inspection requirements and the acceptance criteria.
In December, 1968, Construction Specification G-28, ' Construction of Piping Systems for Boiling Water Reactor Nuclear Power Plants,'
was issued. During the same month, Construction Specification G-29, Quality Control for Construction of Piping Systems for Boiling Water Nuclear Power Plants was issued. While more detail was provided than in the March 1965 specification, specific acceptance criteria remained largely by direct application of the code.
The Browns Ferry Nuclear Plant Construction Quality Control Handbook was also issued in late 1968. This wac'tne forerunner to the Quality Assurance Manual.
The handbook established a series of construction procedures.
Construction Procedure Bs'-45, ' Weld Quality Assurance Progran for Piping,' was issued in June, 1970. This procedure began to provide specific inspection criteria with Revision 1, issued in March, 1971.
Details of the fitup inspection were provided, along with cleanliness and control of purge dams.
At this time, final inspection was primarily by nondestructive examination (NDE). Liquid penetrant examination s'erved as the .
final visual examination for all welds.
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WP-35-BFN Revision 0 The ' Liquid Penetrant Examination Procedure,' BF-3, was issued in 1968. A review of this procedure showed the acceptance criteria to be slightly more stringent than that of the governing code, USAS B31.1.0.
Construction Procedure BF-11, ' Ultrasonic Inspection,' was issued in November, 1968. The acceptance criteria was included in the procedure. Construction Procedure BF-15, ' Radiographic Inspection of TVA Installed Piping,' initially referred to ASME Section III-1965 for the acceptance criteria.
Revision the code.
1 to BF-15 included all criteria without need to refer to In the early nineteen seventies, the ' Qualified Welding Procedures and Welding Specifications,' originally issued in 1965, had evolved into what is now the G-29 series of General Welding Process l Specifications. These specifications contained all of the necessary inspection and acceptance criteria, and continue to do so to date. The G-29M series provides the current criteria for piping and mechanical welding, and forms the basis from which the site implementing procedures are developed.
STRUCTURAL WELDING PROCEDURES As with piping and mechanical welding, at the beginning of construction the structural work was accomplished by direct application of the code under the direction of the Construction Engineer. The code was the 'American Welding Society Code for Welding in Building Construction,' AWS Dl.0-1966. AWS D1.1-1972 The Amert:an Welding Society Structural Welding Code, was later adopted as the code of record. This code specified the inspection requirements and the acceptance criteria.
In November,1969. Construction Procedure BF-29, ' Erection of Sacrificial Shield Structural Steel,' required the Engir.eer to be
! responsible for inspection. Visual examination was by direct l application of AWS D1.0., Most of the welds were required to be examined by liquid penet' rant in accordance with Construction Proceduto BF-3.
In May,1970 Construction Procedure BF-51, ' Quality Assurance i
' Recordkeeping for Structural Steel,' made the Mechanical Engineer responsible for inspection and documentation of all structural i
steel. Acceptance criteria was applied directly from the code. In November,1971, Procedure BF-51 Revision 1 referenced Construction i
1 Specification G-29 for the inspection and acceptance criteria. .
In 1970, General Construction Specification G-29C included Process Specification 3.C.S.1, which provided all of the inspecti'on and I
acceptance criteria required to satisfy the ' Code for Welding in l Building Construction. '
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C C WP-35-BFN Revision 0 This specification is the base upon which the site implementing procedures for inspection of structural welds are developed.
Specification C-29C continues to date to provide all of the details necessary for inspection of Structural Steel Welding.
B. One of the concerns states that subsequent to 1981, welding and brazing inspection for safety related HVAC ductwork was deleted from the Quality Assurance Program without adequate justification.
This concern originated at Watts Bar Nuclear Plant and was evaluated for generic applicability to Browns Ferry. Relative to Browns Ferry, the concern is not factual.
Discussion with Quality, Craft Supervision, and Engineering personnel revealed that most of the ductwork at Browns Ferry is mechanically joined using pockst or 'Pittsburg' joints. This includes fabrication of tho sections, and joining between abutting sections. Companion angles and stiffener angles were not widely used. Where used, they were joined to the ductwork with rivets.
Sealing was accomplished by caulking rather than by brazing or soldering. A large number of the supports are the dead weight trapeze type, not joined to the duct. Where restraint type supports are used, they are mechanically joined to the duct.
Mechanical joining and sealing of ductwork is an acceptable practice, used widely throughout the construction industry. In recent years, brazing, soldering, and various welding processes have also come into use. Often, some combination of the mechanical and welded or brazed methods are used for connections and sealing of ductwork.
- During construction, there was some schedule 40 piping used in the HVAC ducting system. This piping was eracted and inspected in accordance with the piping specification and procedures.
The first duct modifications requiring welding or brazing at BFN have occurred since the latter part of 1986. Modification / Addition Instruction MAI-39, ' Fab'rication, Installation, and Inspection of HVAC Duct and Supports' was issued in July,1986.
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MAI-39 requires at 8.1 that welding and/or brazing shall be inspected and documented in accordance with Standard Practice 6.2 l or Site Director Standard Practice 13.1. These standards refer to Nondestructive Examination Procedure N-VT-2, ' Visual Examination of AWS Structural Welds,' for the acceptance criteria.
In 1986, NDE Procedure N-VT-2 was revised to incorporato the
, requirements of AWS Dl.3, ' Structural Welding Code-Sheet Steel' for inspection of ductwork welding. The acceptance criteria'specified in N-VT-2, Paragraph 0 were compared with the requirements of AWS D1.3-81, Sections 4 and 7. NDE Procedure N-VT-2 was found to meet the requirements of the ' Structural Welding Code-Sheet Steci.'
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WP-35-BFN Revision 0 C. Two of the concerns state that NDE inspectors can only write a Notice of Inspection on inservice related defects, and that preservice defects can only be identified by a Maintenance Request.
These concerns are partially factual, in that the Notification of Indication is the specified form for reporting of unacceptable results found during nondestructive examination. This is in accordance with the 'TVA Nuclear Quality Assurance Manual.' The part of the concerns relating to preservice defects is not factual.
Part II, Section 5.1 of the NQAM requires in part that NDE results which are unacceptable shall be reported by the ISI Group on a Notification of Indication Form. This requirement applies both to preservice and to inservice discrepancies.
Dispositions to correct the condition under the plant maintenance program, i.e., restoration of the item.to original requirements, are processed on the Maintenance Request in accordance with tha NQAM, Part II, Section 2.1.
Dispositions other than restoration to the original requirements re treated as modifications and controlled by the NQAM, Part II, Section 3.2.
Section 2.1 of the NQAM at 5.4.1.1 states in part that any plant employee may initiate a maintenance request and submit it to his supervisor for further processing.
The Notification of Indication is clearly designed for use in recording deficiencies within the scope of a defined examination, in that it requires entries 'such as the Examination Report Number and the signature and certification levol of the examinor. The Maintenance Request is in part used to report any observation by any plant personnel, outside of the defined scepe o'f an examination area.
The reported coservatien may or may not be a deficiency requiring
.crection. These observations are evaluated by the appropriate
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',cineering personnel to' determine what action, if any, is required.
Discussion with the cognizant TVA ISI NDE Unit Supervisor revealed that actual practics at Bt-owns Ferry is in accordance with the NQAM.
- IV . COLLECTIVE SIGNIFICANCE This evaluation revealed no hardware related or programmatic deficiencies at BFN. .
The weld inspection procedures in use at Browns Ferry provido all of the details necessary to meet the requirements of Section 4, AWS D1.1-72, ASME Section III-83, ASME Section XI-83, and USAS B31.1.1.0-67.
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WP-35-BFN Revision 0 The TVA welding program at the beginning of construction relied on direct application of the applicable codes for inspection instructions. These codes provided the specific inspection requirements and acceptance criteria. A specification and procedure system evolved, and in July, 1972, when TVA committed to compliance with 10CFR50 Appendix B, this procedure system provided all of the details necessary for performance of weld inspection in the mechanical and structural areas. The early procedure system was cumbersome, in that the procedures of ten referred to the specifications and in some cases to the codes for the acceptance criteria.
The system evolved to the present set of nondestructive examination procedures, extracted from the G-29 specifications. These procedures provide all of the necessary inspection criteria.
The HVAC ductwork at Browns Ferry was fabricated and erected using mechanical means. When welded duct modifications waro specified, an appropriate procedure was emplaced.
The system for reporting of weld and weld related defects at Browns Ferry is in accordance with the Nuclear Quality Assurance Manual.
V. ROOT CAUSE The apparent root cause of the employeo concerns relating to inspection criteria and reporting of defects is that the concetned employees were not fully aware of the content of the procedures.
Additionally, the early procedures were often not stand alone documents. They made reference to codes or specifications for
!mplementing instructions.
The concerns related to deleting HVAC duct welding from the quality assurance program were originated at Watts Bar and evaluated for generic applicability to Browns Ferry.
VI. CORRECTIVE ACTION No corrective action is indihated.
VII. ATTACHMENTS
- 1. Text of Employee concerns.
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WP-35-BFN WELDING PROJECT EMPLOYEE CONCERN EVALUATION REPORT
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1 ATTACHMENT 1 i TEXT OF EMPLOYEE CONCERNS Evaluation Report WP-35-BFN addresses five employee concerns. The text of the concerns is shown:on the following pages.
IN-85-406-002-PH-85-012-IO3 II-85-102-006-II-85-102-007' II-85-102-011' t
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REFEREECE - ECPS132J-ECPS132C FREQUENCY - REQUEST TENNESSEE VALLEY AUTHORITY OFFICE OF NUCLEAR POWER PAGE -
~1 ONP - ISSS - Riin RUN TIME - 11:56 '
EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
EMPLOYEEHP CONCERN RUN DATE - 03/16/t CATECORY: HE NON QA/QC HELDING - 35 INFORr1ATION DY CATEGORY / SUBCATEGORY QUESTIONABLE INSPECTION PRACTICES S
H 1 REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN REF. SECTIL CONCERN NUMBER CAT CAT D LOC BF BL SQ IIB CAT - UL REPCRT ORIGIN
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CONCERN DESCRIPTION SUBCAT - 35 IN 406-00201 HE 50735 S !!BN 1Y Y N Y T50013 2 SS SS HA SS QTC PRIOR TO 1979 THERE HAS NO SPECIFIC HELD INSPECTION CRITERIA FOR USE BY 02 HE 50709 S HBN 1N N Y N INSPECTION PERSONNEL. IT IS BELIEVE 2 NA NA SS NA D THAT THIS PROBLEM HAS VALID TVA SY STEM HIDE- ALL PLANTS. (SQN ISSUES A DDRESSED IN RPT HP-09-SQN RI)
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PH 012-X0301 HE 50735 S HBN 1Y Y N Y PH-85-012-XO3 T50077 2 SR SR NA SR QTC HELDING AND BRAZING INSPECTION OF SA #
FETY-RELATED HVAC DUCTHORK HAS DELET 02 HE. 50705 S HBN 1N N Y N ED SUBSEQUENT TO 1981 FROM THE QA PR 2 NA NA SR NA OGRAM HITHOUT ADEQUAT JUSTIFICATION HATTS BAR UNITS 1 & 2. SAFETY REL ATED DUCTHORK. ADDITIONAL DETAILS A RE AVAILABLE IN FILE. (SQN ISSUES AD DRESSED IN RPT HP-05-SQN RI) 2 CONCERNS FOR CATEGORY HE HP - 35 CONCERNS ARE GROUPED BY LAST 2 DIGITS OF SUBCATEGORY NUMBER.
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REFERENCE
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- ECPS132J-ECPS152C .*
FREQUENCY - REQDEST TENNESSEE VALLEY AUTHIRITY ~ ~ '
ONP - ISSS - Rint OFFICE OF NUCLEAR P0HER PAGE -
l EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN TIME - 11:56:+
CATEGORY: HE NON QA/QC NELDING EMPLGYEE CONCERN HP - 44 INFORMATION BY CATEGORY / SUBCATEGORY RUN DATE - 03/16/J ADEQUACY OF INSPECTIONS S
H I REPORT APPL SUB R PLT 2 SAF RELATED CONCERN NUMBER CAT CAT D LOC HISTORICAL CONCERN REF. SECTIC BF BL SQ HB REPORT ORIGIN CAT - ut.
CONCERN DESCRIPTION SUSCAT - 4:
XX 102-C0601 QA F0201 S BFN 1N N Y N TS0172 QTC 2 NA NA SR NA BROWN'S FERRY: THE VISUAL EXAMINATIO 02 HE S0744 S BFN 1Y Y N Y N PROCEDURE HHICH COVERS ASME SECTIO N II IS VERY NON SPECIFIC. NUCLEAR 2 SR SR NA SR PONER DEPT. CONCERN. CI NAS NO ADDI TIONAL INFORMATION. NO FOLLOW UP RE QUIRED. \
1 CONCERNS FOR CATEGORY HE HP - 44 CONCERNS ARE GROUPED BY LAST 2 DIGITS OF SUBCATEGORY NUMBER.
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.7EFERENCE FREQUE!!CY
- ECPSI3?J-ECPS!32C
- REQUEST TErlNESSEE VALLEY AUTHORITY OrlP - 1555 - RII1 OFFICE OF fluCLEAR P0HER PAGE - '
I EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN TIME - 11 S4:*
EMPLOYEE RUN DATE - 03/16/i CATECORY: HE N0tt QA/QC HELDING HPCONCERil
- 43 INFORMATI0tl BY CATEGORY / SUBCATEGORY REPORTIllG OF DEFECTS S
H I REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL REF. SECTIC
--C0tlCERtl NUMBER CAT CAT D LOC C0tlCERN
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CONCERN DESCRIPTION
, SUBCAT - 43 XX 102-00701 HE 50545 N BFN 1Y Y N Y T50172 QTC 2 SR SR NA SR BROWN'S FERRY: NDE INSPECTORS CAN Ott LY HRITE A NOTICE OF INSPECTION ON I N-SERVICE RELATED DEFECTS. PRESERVI CE DEFECTS CAN OrlLY BE IDENTIFIED BY A MAINTENAtlCE REQUEST. NUCLEAR P0;l ER DEPT. CONCERN. CI HAS NO ADDITIO S
NAL RED. INFORMATION. NO FOLLOH UP REQUI fws XX 102-01101 NE 50545 $ SQN 1Y Y N Y T50172 I-85-735-SQN QTC 2 SR SR NA SR SEQUDYAH NDE INSPECTORS CAN ONLY HR 02 ITE A NOTICE OF INSPECTION ON IN-SER HE 50999 S SQN 1 il N Y N VICE RELATED DEFECTS. PRESERVICE RE 2 NA NA SR NA LATED DEFECTS CAN OtlLY BE IDENTIFIED BY A MAINTENANCE REQUEST. fiUCLEAR P OHER DEPT. CONCERN. CI HAS NO FURTH ER INFORMATION. NO FOLLOH UP REQUIR ED. (SQN ISSUES ADDRESSED IN NSRS RP T I-85-735-SQN) 2 CONCERNS FOR CATEGORY HE HP - 43 C0tlCERNS ARE GROUPED BY LAST 2 DIGITS OF SUBCATEGORY NUMBER.
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