ML20198K479
| ML20198K479 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 12/09/1981 |
| From: | Purdy P BROWN & ROOT, INC. (SUBS. OF HALLIBURTON CO.) |
| To: | |
| Shared Package | |
| ML20197J316 | List:
|
| References | |
| FOIA-85-59 CPM-13.1, NUDOCS 8606040037 | |
| Download: ML20198K479 (184) | |
Text
-
\
1
. .- ; ARMS G INDEXE l
BROWN & ROOT, INC. PRCCEDURE _
E E ^ ~ "!
CPSES NUMBER REVISION ch DATE PAGE l
JOB 35-1195 l CPM 13.1 12/9/81 1 of 10 l 7 TITLE:
d - ORIGINATOR: u
_@_.# /3M/#/
DATE
/
GENERAL CALIB ^~. N :
PROCEDURE !
REVIEWED BY: Mas uldtw - J E!M
- /kl / /
u/~TUGCyd /DATE APPROVED BY b- # & 4t' #
CONSTRUCTION PROJECT MANAGER
/[-?-8/
DATE (ASME RELATED PROCEDURE'
/
o.i TABLE OF CONTENTS Q C /1/
1.0 INTRCDUCTION OON
1.1 PURPOSE C d.d b 1.2 SCOPE z)c/1/ #yl Con
- C R DURE ,
3.1 CALIBRATION FACILITY 3.1.1 Environment 3.1 2 Interference 3.2 STATUS OF M&TE ITEMS 3.2.1 Active Status 3.2.2 Inactive Status 3.2.3 Out-of-Calibration Status 3.2.4 Dropped From System Status 3.2.5 New Items 3.3 ACQUISITICN OF M&TE AND REFERENCE STAtiDi l 3.3.1 Procurement Responsibility l 3.3.2 Reference Standard Accuracy l 3.3.3 Certificates of Certification '
3.3.4 Off-Site Calibration Services 3.4 CONTROL OF M&TE REFERENCE STANDARDS 3.4.1 Inventory Identification Numbers l 3.4.2 Master Index 3.4.3 Calibration Stickers 3.4.4 Calibration Intervals 3.4.5 M&TE Issue 3.4.6 Tool Data Issue / Record Card j 3.5 CALIBRATION MANUAL 3.6 RECALL AND CALIBRATION !
3.7 DEFICIENT, DAMAGED CR LOST M&TE l 3.7.1 Deficient M&TE Evaluation Recorts i 3.3 EXTENSIONS OF CALIBRATICN INTERVALS I 3.9 TRAINING AND CERT!FICATION l 3.10 LIMITATICN ON USE :
3.11 SPECIAL STATUS OF PRESSURE GAUGES
+ ,
8606040037 860527 Y ~
CARDE85-59 PDR 'j
, /g
P. -
'C8 35-1195 Coraanche Peak Stea::: Electric Station Sheet 1 of 3 Construction Precacurs CCC'JME?iT CHAftGE ;0TICE .'tUMBE . c 7
This notice applies tc Const-uction Frecacure fic. 35-1195- cpu M. iRevision This change will be incer;cenad in the next revision of the crecaccre.
Change the precedure as follows:
Replace the following page with the attached .
Page 8 of 10 Add the following page Page 8a of 10 -
Reviewed by:
PW5 Ca:a Y
sr=wn & . Rec: Quality Assuranca ;a:a J / </ ,Q
- .gina
- cr l
l
/
m
! - '- D ,
r'1i Approved by:
Ll a vigA,4ed.byl e (a l ,
TUGeo Qtiali:' Assurar.ce Da:a
\
hhs ~
C ns- uction i n;ec: :danager 3 7/ 95-;a:a Acril 4, 1983 ufac:1ve Oa:a w
i e
i C'. -
JCB 35-1195 Cemanche Peak Staa:n Electric Station Sheet 1 of 3 Construe:ian Precacure OCC'JMENT CHANGE NOTICE NUMBER 4 This notice applies :s ccnstruction Precedure Nc. 35-1195- CPM 13.1 Revisien 7 .
This change will te inc:rporated in the nex revision of the ;recedure.
Change the precedure as fo11cws:
Replace the following pages with the attached:
Page 9 of 10 Fage 10 of 10 Reascn fer change: Additional requirement.
Reviewec by: ,
> s ,
d, 10 ~ l - & /O d-h U
-0 inat0r Data dr wn 4 Acct Quali y Assuranca Ja:a l
Reviewed bv:
', u / f 2, 4 Approved by: Oata
- I'JGCO Qualitf Assurance i
bkWr6Ci t&// /c///s>
Construc::cn d m;ect .danager ;a:a 10/6/82 dif ective Oa:a
.. t 14",
l l
e k
%. e - :.w , we. --
-+- -%. ..m - ~,
~
re -
JCB 35-1195 Ccraanche Peak Steam Electric Sta:1cn f Ccnstruction Frccecurt CCC'JftE.'lT CHANGE NOTICE nt:MSER 3 This notice applies to Ccnst action Frccedure No. 35-1195- CPf4 13.1 Revisien 7 .
This change will be incor; crated in the next revision of the prccedure.
Change the prccedure as fellows:
Replace the following page with the attached:
Page 5 of 10 Reascn for change: Change in requirement
, Revie.ved bv:
.[
. _ . . . - . . . . . _ / d T- /6f -7.1 M O 8- 2 0 1917.a ct ' Cate arcwn a fcot Quality Assurance C4:e t
Reviewsd,by: , C 7,[
Approved by:
4
- UGCo Quality Assuiance Da:e
. .u A- ed?n/ -g.92 9/16/82 - - -
Ccnstruc::cn Prc;ecc .wanager Ca:a iffecc1ve Oa a
\
1 ARMS O INDEXED Ccr.anche Pea : ectric Station 0 Sheet 1 of 2
- Ccnstruction Precacure CCCUMENT CHANGE NOTICE NUMBER 2 7
This notice a::olies to Ccnstruction Precadure No. 35-1195 CPM 13.1 Revisien .
This change will be incer;cra:ad in the next revision of the precedure.
Change the precedure as follcws:
Replace the following page with the attached:
Page 8 of 10 Reascn fer change: Additional requirements Reviewed b' fC 2- 'O 9 E2 arewn i Acc: quav 1 y Assurance Ja:e
' .'gina:::r ca:a a ite- b .f .
/.y. , d. 5/7 &
Approved by: '
Da:a i GC0 ga y Assura.ca O-%9L
.. /4 _tO*/ 3/18/82 !
Ccnstructicn ?m,;ect .Sanager Ca:a Effective Oa:a j l
= -
p+ 9 wv - d + **_
, si ,g6 9 -
- f,RMS
!NDEXED JOB 35-1195 Ccmanche Peak Steam Electric Mgion Sheet 1 of 3 Construction Procedure COCUMENT CF.AfiGE tiOTICE NUMBER 1 This notice applies to Construction Procedure No. 35-1195- CPM 13.1 Revision 7 .
This change w'ill be incorporated in the next revision of the procedure.
Change the procedure as follows:
Replace the following pages with the attached:
Page 5 of 10 Page 9 of 10 Reason for change: Additional requirements This change approved by: Reviewed by-
&/W// I "l5 *S'"
,' /s b ,
5 1ginator Cate Brown,& Rcot Quaid:y Assurance Oa:a Reviewed by:
/Mu, sir /-/]'9?. 1/15/82 Eff ective Ca:e v Construc:1on Fro,;ect Manager Ca:e
-g
" ' ~"# ' ~ ' ' ' ' - - , ,
PROCEDURE EFFECTIVE BROWN & ROOT, INC. NUMBER REVISION DATE PAGE
, CPSES -
JOB 35-1195 CPM 13.1 7 12/9/81 j 2 of 10 4.0 SUPPORTING MATERIALS
4.1 REFERENCES
0.11 LIST OF FIGURES 13.1-1 CALIBRATION STICKERS 13.1-2 TOOL DATA ISSUE / RECORD CARD 13.1-3 CALIBRATION REPORT l'3.1-4 DEFICIENT M&TE EVALUATION REPORT l
13.1-5 RS, CT, M&TE MASTER INDEX
1.0 INTRODUCTION
1.1 PURPOSE
]
The purpose of this procedure is to provide instructions to assure that M&TE items, which include tools, instruments, etc. ,
used in activities affecting quality are properly controlled, calibrated and adjusted at specified intervals to maintain accuracy within prescribed limits.
~
1.2 SCOPE The scope of this procedure covers the acquisition, control, issue, recall and general calibration instructions for M&TE required in support of B&R activities at this site. The respon-sibility for implementing the recuirements of this procedure for M&TE peculiar to the Field Engineering Department is delegated to the Senior Field Engineer, i 2.0 GENERAL Measuring and test equipment (M&TE) shall be calibrated against measurement standards (reference standards) having known rela-tionships to National Standards where such exist. If reference ]
l standards do not exist for a particular item of M&TE, the basis for calibration shall be in accordance with the manufacturer's recommendation and paragraph 3.3.
l Such devices as rulers, scales and tape measures, which are not likely to drift during use, need not be calibrated against calf-bration standards.
C
- -v
-A
- . _ , m -
PROCEDURE l EFFECTIVE BROWN & RCOT, INC. '
NUMBER REVISION OATE PAGE I
CPSES JOB 35-1195 CPM 13.1 7 12/9/81 3 of 10 l
3.0 PROCEDURE 3.1 CALIBRATION FACILITY 3.1.1 Environment The Calibration Supervisor will assure that during periods when items are being calibrated, the environment of the Calibration Facility is within the proper limits or that corrections are made for specified variations in temperature and humidity.
The environment within the Calibration Facility shall be con-trolled to 750 + 10 F and 0-60% Relative Humidity.
3.1.2 Interference Calibration Facility equipment which can be adversely affected by outside vibration, shall be effectively isolated by the use of shock abscrbing pads under equipment upon which calibration is performed.
7 Radio Frequency Interference (RFI), electromagnetic interference (EMI) and radiation are not factors adversely affecting the cali-bration activities in the Calibration Facility which are covered by this procedure.
. 3.2 STATUS OF M&TE ITEMS 3.2.1 Active Status
" Active" status of an M&TE item indicates that the iten is within prescribed accuracy requirements and suitable for use. The status is documented by a Calibration Report (Figure 13.1-3) in the item's history file and a Calibration Sticker (Figure 13.1-1) attached to the item or its container. The Master Index will j
also reflect the status as " Active".
3.2.2 Inactive Status
( " Inactive" status of an M&TE item indicates that the iten is within prescribed accuracy requirements as of last calibration, l but is not presently required for use. The status is dccumented l
by a Calibration Report in the history file, " Inactive" sticker l (Figure 13.1-1) attached to the item, and is stored in a segre-gated and environmentally controlled area. The Master Index will I reflect the status as " Inactive". An item will be recalibrated when removed frcn " Inactive" status if the calibration incerval s_, originally assigned has expired.
e
~
1 PROCECURE EFFECTIVE BROWN & ROOT, INC. NUMBER RE/ISION DATE PAGE CPSES JOE 35-1195 CFM 13.1 7 12/9/81 4 of 10 3.2.3 Out-of-Calibration Status "Out-of-Calibration" (00C) status of an M&TE item indicates that the item is not within prescribed accuracy requirenents, is lost, is stolen, or is damaged. The status is documented by a Calibra-tion Report in the history file for the item and an "00C" sticker (Figure 13.1-1) is attached to the item, with the exception of lost or stolen items. The Master Index will reflect the status as "00C".
"00C" items will be stored in a segregated area until repaired or dispositioned.
3.2.4 Oropped Frem System Status
" Dropped From System" (DFS) status of an M&TE item indicates that the item is no longer in the calibration program and has been disposed of through proper channels. The status is documented by a Calibration Report in the history file for the item. The Master
- Index will reflect the status as DFS with a comment indicating disposition and date.
3.2.5 New Itens Items which are received, but not immediately required, may be stored in a segregated Class A storage area until needed and then processed as new items.
3.3 ACQUISITION OF M&TE AND REFERENCE STANDARDS
- 3.3.1 Procurement Responsibility
! M&TE will be procured through the Calibration Supervisor with
! ranges, accuracies, precision, durability and special features l necessary to support constru,ction and inspection functions on l
the project.
l j Departments requiring new M&TE may initiate the field requisition i for the device. The field requisition shall be marked "M&TE ITEM" and shall include, as a minimum, the following information (when applicable):
i I
~e-o -, .--- , , _, . . , - - - - ~ - - - - - - - - - - -- , . -
PRCCEDURE ' EFFECTIVE l BROWN & ROOT, INC. NUMBER REVISION DATE l' PAGE CPSES i l JOB 35-1195 l l CFM 13.1 , 7 12/9/81 i 5 of 10
- 1. Manufacturer's name, make, and model number (if known).
- 2. Accuracy requirements as established by Design Specifications, code requirements, construction procedures or industry practices.
- 3. Certificates of conformance or certificates of calibration when required.
- 4. Available literature regarding calibration, adjustments, maintenance, repair and recommended spare parts lists.
All purchase requisitions for new M&TE items shall be reviewed by the Calibration Supervisor.
3.3.2 Reference Standard Accuracy Reference Standards, when not limited by the state-of-the-art, shall have an accuracy four times better than the M&TE to be cal ibrated. Calibration curves shall be maintained and used for each reference standard when necessary to provide better accuracy.
3.3.3 Certificates of Certification .
Certifications shall contain the fcilowing information:
- 1. Manufacturer's name, make, model number, and serial number.
- 2. Identification of calibration standards with serial or cali-bration report number.
- 3. Notation of active status of calibration standards used.
- 4. Calibration date.
- 5. Signatures and titles of personnel responsible for calibration.
- 6. B&R purchase order number.
3.3.4 Off-Site Calibration Services Off-site calibration services shall be obtained only from suppliers approved by the CA department. If the item is to be serviced but not calibrated, the supplier need not be qualified by QA. The field requisition shall be reviewed by the Calibration Supervisor for cali-brated items that require service, repair or recertification by an off-site laboratory or manufacturer. The field requisition shall include the following information:
t 1. Certificates of calibration to include, in addition to paragrapn 3.3.3 above, the calibration data in the "As received" condition, as well as data after adjustment (if adjustments are made).
CFM 13.1 Rev. 7 CCN #3 9/16/82 Sheet 2 of 2
~ .._. _ ..___ _ _.. _ . _ _
PROCEDURE EFFECTIVE BROWN & ROOT, INC. NUMBER REVISION CATE PAGE CPSES i
CPM 13.1 7 12/9/81 6 of 10
- 2. Approved calibration procedures if item requires calibration
- by an off-site laboratory (NBS and state labs apprcved by NBS are exempt frcm this requirement).
3.4 CONTROL OF M&TE AND REFERENCE STANDARDS 3.4.1 Inventory Identification Numbers Each acceptable item of M&TE will be assigned a unique inventory identification number, i .e. , M&TE-1234, RS-45, CT-1097. Inventory identification numbers shall not be re-used.
The Inventory Identification shall be scribed, electroetched, or stamped directly on the item in a conspicuous place and in a manner which shall not alter the item's characteristics or accur-acy. When an item cannot be identified directly, its respective storage container shall be so identified, i.e. , gauge block sets and weights.
3.4.2 Master Index The Calibration Facility shall establish and maintain a Master Index (Figure 13.1-5) which is the record of all assigned items by inventory identification number. The Master Index will include the identification number, description (nomenclature and model number when available), calibration date, calibration due date, calibration interval, current status and accuracy, and may contain additional information as determined necessary by the Calibration Supervisor.
3.4.3 Calibration Stickers Items received with acceptable certification and items initially calibrated on-site shall have a completed calibration sticker applied to the item and placed under the control of the Calibration Facility, except as noted in paragraph 1.2. The Calibration Sticker will contain the unique M&TE item number, the 'date of calibration, due date for calibration and initials of a certified calibration l
person. Certification papers received with a calibrated item will be retained in the iten's history file.
I 3.4.4 Calibrstion Intervals Calibration intervals will be established for each item of M&TE (including RS and CT items) by the Calibration Suoervisor based on use, environment, durability, type of item, required precision, I. manufacturer's reccmmendations or any special requirements dic-s_, tated by applicable codes or specifications. The Calibration i
1
PROCEDURE EFrECTIVE BROWN & RCOT, I?iC. tE3ER REVISION DATE PAGE CPSES JOB 35-1195 CPM 13.1 7 12/9/81 ,
I of 10 Supervisor may alter an established interval, except where pro-
- hibited by Code, based on demonstrated stability or other factors affecting measurement control. To increase the calibration in-terval, the item (or family of items) must have had thrse successful calibrations during the last three intervals or one year, whichever is less. When calibration intervals are changed, similar items with valid calibration stickers need not be recalled for calibration until their individual calibration intervals expire.
For ASME Code items, the following items of M&TE shall be re-calibrated at the specified intervals:
- a. Pressure gauges - before and after each test or series of tests. A series of tests is that group of tests using the same pressure test gauge or gauges which are conducted with-in a period not to exceed two weeks;
- b. Clamp-on ammeters - when used to check welding equipment;
- c. Voltage and amperage meters on automatic welding equipment 7 shall be calibrated if used for monitoring or recording essential or nonessential variables. Where such meters are not used for these purposes, the meters need not be cali-brated ; .
- d. Charpy impact test machines (once a year, using specimens ob-tained from the U.S. Army Materials and Mechanics Research Center);
- e. Temperature instruments for impact testing (once every three (3) months).
3.4.5 M&TE Issue
-- " G _ a m m ,.. - s w2+M l 1ssu inn clNM PolitiveTeiiTificafion cne oYgg per signing out the item should be obtained before the item is l rel eased.
Daily issues are to be returned to the Calibration Facility by the end of the shift with the Issue Record Card. When the item is returned, the Issue Record Card will be marked with the return date and filed.
Long-term issues to various departments may be keot out of tne Calibration Facility until the next calibration due date. The receiving de:'artmer#shal1 ma.intain a r,ggf their issue of these C M&TE items. W-
~.. m --- = L e n 6 = L D - t e
I PROCEDURE E.:FECTIVE !
BROWN & RCOT, INC. NUMBER REVISION DATE PAGE CPSES l
JOB 35-1195 CPM 13.1 i 7 12/9/81 l 8 of 10 l l
- 1. M&TE/ Identification Number
- 2. Date of issue
- 3. Item on which the M&TE was used.
A " confidence check" to insure accuracy of an M&TE item may be performed ay any time. The " confidence check" will include the necessary portions of the applicable Calibration Instruction (IEI) and will be documented. Items which .are " confidence checked" immediately prior to issue should have the check noted on the Issue Record Card in the " cal-check" space.
3.4.6 Issue Record Card The Issue Record Card shall be maintained by the person checking out the item. The individual will record the date of use, the item (s) installed, inspected or tested with the M&TE item during the issue period, and values obtained whether daily or long-term issue.
- ^
__Mt=>1r ,= _- -- z:;- z-- - -w ---_ m--
EE 1%iM, EXCEPTION: Tool Data Issue / Record Cards are not required to '
be completed for the following:
- 1. OFT gages not used for final acceptance by the Paint Department;
- 2. Electrical measuring devices used by Welding Engineering for Welder Parameter monitoring;
- 3. Electrical measuring devices used by personnel for reasons other than final acceptance, e.g. personnel safety or in-process checks. In such cases, it shall be identified on the record card that the item was not used for final acceptance;
- 4. When an item is checked out and not used, the only entry required shall record that the M&TE was not used.
CALIBRATION MANUAL The calibration Supervisor will approve detailed calibration in-structions (IEI) for each item or family of items to be calibrated by S&R. A copy of each approved IEI will be maintained in Cal-ibration Facility along with a copy of this procedure.
The "IEI-Series Calibration Manual" is a compliation of individual calibration instructions. When individual IEI's are revised or added to the series, the Title Page and Contents sheet for the entire manual is revised to reflect the latest cor, tents and a
~
. review / approval signature sheet will be made each time the series
! is revised, e
CPM 13.1 Rev. 7 CCN #5 4/4/83 Sheet 2 of 3
PROCEDURE ! certciIVE BROWN & ROOT, IriC. NUMBER , REVISION DATE PAGE CPSES JOB 35.1195 CPM 13.1 l 7 r 12/9/81 Sa of 10 i i i Each IEI shall contain the following basic information where applicable:
- 1. Identify of the item.
- 2. Calibration equipment and reference standards to be used.
- 3. Checks, tests, measurements and acceptance criteria.
- 4. Sequence of operations.
- 5. Special instructions where necessary.
- 6. Connection diagrams where appropriate, d
J e
1 4
%d*
I i'
-n
~* 5' Sheet 3 of 3 CPM 13.1 Rev. 7 DCN #5 4/4/83
.. - . - _ ~ - _ - - - - -. . . _ . . .-_- . _
l I I PROCEDURE EFFECTIVE l BROWN & ROOT, INC. NUMBER REVISION CATE l PAGE CPSES i l i
JOB 35-1195 i l i CFM 13.1 I 7 l 12/9/81 l 9 of 10 3.6 RECALL AND CALIBRATION The Calibration Supervisor shall be responsible for the maintenance of a Calibration Recall Schedule through the Master Index program and the timely recall of items for calibration. Items will nor-mally be recalibrated on.or before the calibration due date.
If the calibration due date of an item expires before it is re-turned to the Calibration Facility, a Deficient M&TE Evaluation Report will be issued to the user of the item and a copy submitted to the Site QA Manager.
The person performing the calibration shall complete a Calibration Report (Figure 13.1-3). He shall record the appropriate data and remarks, sign and date the report. The Calibration Supervisor
! or Engineer will review the report for the reference standard used in calibration.
If the calibration results are satisfactory, in accordance with the IEI, a new calibration sticker will be placed on the item and the item will be returned to the active status. The Master Index will
, then be updated to show the new calibration date and due date. -
4 3.7 DEFICIENT, OAMAGED OR LOST M&TE 3.7.1 Deficient M&TE Evaluation Reports If an M&TE item is found out-of-calibration (00C) or is lost /
stolen, a Deficient M&TE Evaluation Report (Figure 13.1-4) for the item shall be prepared. For lost or stolen M&TE, a note will be added on the M&TE index indicating it is lost or stolen.
All Issue Record Cards and Tool Data Record Cards for the M&TE item since the last successful calibration er confidence check and the Calibration Report will be attached to the Deficient M&TE Evaluation Report. One copy of the report will be filed in the item's history file and one copy will be forwarded to QE for evaluation. If the evaluation by QE' indicates that previous i
activities on which M&TE were used is unacceptable, QE snall pre-j pare an NCR in accordance with QA procedures and the Deficient M&TE Evaluation Report will be closed and will reference the NCR number.
Completed Deficient M&TE Evaluation Reports will be returned ta the Calibration Facility and filed in the item's history file.
3.8 EXTENSIONS OF CALIBRATION INTERVALS b When requested in writing, the Senior Staff Engineer may permit the use of reference standards of M&TE items beyond their cali-e CFM 13.1 Rev. 7 DCN #4 10/6/82 Sheet 2 of 3
_.__.m.._., . . _ . _ . _ _ . . _ . . . . _ _ _ . _ - . _ _ - . . _ _ . - . . , . _ - . - ~ . . -~. _ _ _
PROCEDURE EFFECTIVE BROWN & ROOT, INC. NUMBER REY!SION DATE PAGE CPSES
! l l
JOB 35-1195 l l CPM 13.1 7 i 12/9/81 1 10 of 10 bration due date provided there is sufficient justification. The request shall identify the item (s), intended use and length of extension requested. The item shall be calibrated immediately at the end of the extended period to verify accuracy. While in effect a copy of the approved extension request shall be filed in the item (s) history file and the Master Index updated to show the ex-tended calibration due date with a ccmment referring to the extension.
The request for calibration extensions shall have the concurrence of QA.
3.9 TRAINING AND CERTIFICATION All Brown & Root employees having a functional responsibility covered by this procedure shall attend the QA Department Indoctrination course as described in the QA Personnel Training Manual, and additional training as outlined in CP-CPM 2.1.
3.10 LIMITATION ON USE Calibrated items may be calibrated over part of their range. These items may be issued for use provided they are labeled in a distinctive '
manner, indicating the usable range. The Calibration Report shall show that the item is to be used on a limited basis.
3.11 SPECIAL STATUS OF PRESSURE GAUGES Pressure gauges used for "Q" hydrostatic-test purposes are listed on the Master Index under "Special" status. This indicates that the gauge will be calibrated prior to issue and a calibration sticker affixed. When the gauge is returned, it will be calibrated again and the sticker removed while it is in the Calibration Facility.
Maximum calibration interval for these gauges when calibrated and
. issued is two weeks. These gauges are to be stored in the Calibration Facility in a segregated storage area.
4.0 SUPPCRTING MATERIALS
4.1 REFERENCES
4.1.1 Brown & Root Quality Assurance Manual, Section 13.
4.1.2 Brown & Root CPSES Construction Procedure, CP-CPM 2.1, " Calibration Personnel Requirements and Training" m
e CPM 13.1 Rev. 7 DCN #4 10/6/82
PROCEDURE EFFECTIVE BROWN & ROOT, INC. NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CPM 13.1 7 12/9/81 ,
1 of 1 FIGURE CPM-13.1-1 CALIBRATION STICKERS t,a BROWN & A007. Q/C CAUBRATED NO.
CATE -
Cut -
INSPECT -
$@NfkhVhb .-c;e eg.u f-4
'95d. b
- f' r:S c.;,*7:3. - %.
t r <a-
. ;[L ~ ,.
'C . 5,'
.,. , m ; .
J
PROCEDURE ! EFFECTIVE !
SROWN & ROOT, INC. NUMBER REVISION CATE PAGE l
l CPSES JOB 35-1195 CPM 13.1 7 ; 12/9/81 l 1 of 1 FIGURE CFM-13.1-2 ISSUE RECORD CARD l 0
b DESCRIPTION OF M&TE SERIAL NO.
O DATE ISSUED DATE RETURNED 2
INTENDED USE DEPT FOREMAN / SUPT.
LD 0 b DAY O NIGHT C LONG TERM CAL CHECK INIT.
v) .
PHONE EXT:
H BADGE # SIGNATURE RECORD ALL USE CF THIS .\tSTE (CT) BELOW - ITD1S INSTALLED.
TESTED CR INSPECFJ.
DAE I ITBI INSTALLED, TESTED OR INSPECED i VALUE l
l l
l e
- gD v
FROCEDURE EFFECTIVE BROWN & ROOT, INC. NUMBER REVISION DATE PAGE CPSES JOB 35-1195 CPM 13.1 7 12/9/81 1 Of 1 FIGURE CFM 13.1-3 CALIBRATION REPCRT P ROJC".7 : CPSE3 35-1195 ' UNIT: 112 PAGE 1 0F MEASURING TESTING DEV!CI:
i MODEL/ TYPE / SERIAL NO.
IDENTIFICATI0*l NUMBER MANUFACTURER W
DATE CALIBRATION DUE ACC1 RACY ALLOWED:
REFERE' ICE STA!!PARDIS)
ID NO. MAM"FACTURE9 CAL DUE TD NO. MANUFACTURE 9 CAL DUE ,
t i
6 I
CALIBRATION PROCEDURE / REVISION USED:
ENVIRONMENTAL CONDITIONS SATISFACTORY: TEMP HUMIDITY DATA AS RECEIVED DATA AFTER ADJU37 MENT NCHINAL IST RUN ERR 2ND RUN ERR M NAL I IST RUN ' ERR I 2ND RUN '
ERR I i I I I
I
}
l ! t i l l REMARKS I certify that the reasurements made above areG are notC within the tolerance specified for the item and verified repeatable. Next calibraticn due .
~
v cAusRATica IEc.:ncIAN CATE CAU S W ;GN M ERV UCR DATE 3
FROCEDURE EFFECT!YE BROWN & ROOT, INC. NUMBER REVISION DATE FAGE
-- CPSES JOB 35-1195 CFM 13.1 7 12/9/81 1 of 1 FIGURE COM 13.1-4 DEFICIENT M3TE EVALUATION REPORT
. (Per CP-CM*-I3.1)
REPLY DUE: f CCNTROL NO: CPSES 35-1195 ISSUE DATE:
NOTE: This report with reply should be returned to the Calibration Facility witMn five (5) working days frem date of issue as she.*n above.
' TO: COPY TO:
~
ITEM CESCRIPTION: IDENT. NO:
DATE LAST RECCROEC CliECX: __
DEFICIENCY: _-
SEE ATTACFED: .
Calibratior Report F SIGNAT4RE:
Issue Reeerd Cards "
3.Part Mero ELTE:
Other :
REPLY Per CP-CPM-13.1 a record of 111 items installed, ins;:ected or tested with this M&TE item since the last recorded check must be attached or included as
- a part of your reply to this deficiency.
C3NENTS: _
DATE: SNNATURE:
. ._...- - ..__ .. . ~ ..... .. . ... . --
QUALITY ENGINEERING REVIEd QUALITY ENGINEER: DATE:
CLOSED O nCa Is:uED C nCn i CATE:
-CC:MNT$:
s.
y by wep-C yw - se --
--y,, g. g.- y -7. - .pwe- ,69g v., g. < . = , , , g.p,g >g- ,.,m g--g-*q,p ,,-gyy.p--,y-,wp 9.,~ywyg ygg-yyyg,,..v.-yp. .-ce wv-
i PROCEDURE EFFECTIVE BROWN & ROOT, INC. NUMBER REVISION DATE PAGE CPSES i
JOB 35-1195 '
CPM 13.1 7 12/9/81 1 of 1 FIGURE CFM 13.1-5 RS, CT, M&TE PASTER INDEX 48 tee & 880f 1 e C,
~~
es. Cf. estt onette fums past s i r . .. .. . . . - . . .
pe0te4* Cta43 81 mfd.t97 CettesetICe teeff* Safte f actigt el Oef tll -_ .
4Ct*C ha f ve t moats _Cagte tufvt ei.tet takte st af38 34f t Cab __Saft 3st esse s cat 40Caf t:9 tit =f (3e.tx t aCCuestf teste 40 eteses s
.e e efetet=M Sfaegase
._ ~elf$_tt .re.
_. ._. l foe.,4 see Ce is. e e4. .ei. e7 onC i Jusf. .4. i 3 8 8f.4 44 LOSF 3eauG79 et 181 43
. -. 014 486 . 48 46 ..
TeseUE es t=CM to.ite F48 4416 4 *e CF 4684C79 44613 4 St.4eet 60sf teJamee . . .. as . . 00C .. It!.g 3 ..
ese .ett 89.t 8 te--. C0C . - 410Cfft - -. 4e613 t . Cf.eeeg famous setmC4 te* tis 848 6416 4.. CF 4Csf 2?Jamte as It!.t3 ese age es.es TCagUg estuC4 144 98tP48 4418 5 .4e ir attttt lectie t feef l 87 Bf.eeel el alttf188 e.l08 ets . - - - . #$e . e s.1 . - . . . .
70seut est*Cm OJ#.4 t eet og CF sf=49f t 7109 t Cf.eest
. . 6011 194Wtte . . - . -
et LtFf 68 ats.90C f It!.t 3 .
et3 GI6 eest e
! fgegut setstu 3713 . . . . . CF CCC. - t?.4ett .... toest 4- 87 4e#1 -
43Sf ifaaff s ee . 48 f t!.13 ,
est ett 48*Le fgeeug netgC8 eJ8*t t f A 94 CF 08 8 IlJU#ff 7087 I . .. CT*4ees .-
!*.4621 2 t Jue f f 48 It!*t a
.. es) ..
et t. 08 44 . . . . -. _ - - . . . . . . . . . - . ..
4111 98 CF eF S 34Jaefe 64 fee t C f.44 e f g TM eetatu !t 8 0 3 . . . . -
osfu CEftest.1= cite i
. et . . - ..
ste ..414 .89 9 l 70seut eetutz 43 3 .- _9e tr . aCfttt safee er .. Cf.coes ..
..48 03staat osmova.l It! t3 010 e%8 08 9 70seut set %C4 14.t10 #48 telt.e to CF 00C t esa ffg 4e483 i St.ete9 LGBT 24J4479 88 183 13 ela . . . . . . ele . . 88 44 -. - -. ..- . . . . . ...~
.~.
. I g 1 . (M _. . __
,u= ...
N.d*_*" ' L. . . I. .. M -
l i
t 1
I l
l u
' / m l
l l
. v
&W= 0 9 '.
I <%
h~ ~
. , . CS-) 5 8 /9 /}4 3
n During the time I was a welder, I probably made as many as two doz,en " plug welds"
.' on Quality hangers at the instructions of various supervisors. I testified about.
thesh welds before the hearing board.
I remember back in 1979, an occasion in which my foreman, told me, to weld a leg on a hanger that was not contained in the drawing in the dimensions needed. -I performed the welding without documentation at M instructions, and I was caught by QC. I knew what I had done was wrong. I reported this inciderit to CASE in an 'affadavh.
.. q
- j In 1982, instructed me accept the torquing of Hilti bolts without
' sign off in the traveler ' package. Later when I argued with@ bout it he denied ever having said it. old me that if I could not remember his instructions and did not trust him, he would replace me. I took this as a threat.
In 1982, I was told by N elpMinspect vendor welds on the deisel j
fb } generators. I told 6did not feel courfortable with the inspections and that I did not want to do them. M&old me to do the inspections, or "go
,, j
- l O.dhome". I reported this incident to CASE in an affadavit.
.l
,j After I testified before the ASLB hearing and before I was ROF'd*, I wrote a 4CRe on some large doors that were to be used in containment. I put hold tags on the doors because of improper welds I identified. gent word through6that I was to " buy off" on the doors or I would "be gene" I bought off on the doors.
On another occasion % told me to stop conducting inspections other than those I was assigned to conduct or that I would be fired. I was harassed, intimidated, and threatened after I testified. A short time later I was R0F'd.
I have read the foregoing statement consisting of 2 typed pages. I have made and initialed any necessary corrections and have signed my name in ink in the margin of each page. I swear that the foregoing statement is true and correct. Signed of September 165, 1983 at .
, -: s b Subscribed.and sworn $ before me this 15th day of Septemoer 1983 at Arlington,
- ^
r= n e
- ..A,-8v,f"-59 i
g
..e h % % %u. m .,6 4 2a;.6 ; i ;. s w ;.; ,;. _ w .w.; m ._,:: .,;; ug,.:..ga:,. 3 k ;i ..; . y. 4 3.. ;
'a+- " = -.=e.n
_ . __------u
'. y _ f f C Y ' $0$
$fffY
~
. h e 2nauinnma==ms
~
On September 15, 1983, a former Brown & Root, Inc., QC inspector at CPSES, was interviewed by NRC Investigator H. Brooks GRIFFIN in Arlington, Texas.
M recalled the following instances whichMcharacterized as intimidation and harassment as related to performinggwork.
1 following described incidents before the CPSES ASL8:
Msaid% testified to the (A) M stated that
$ supervisor, instructed' M o " buy ,
off" on a deficient hanger or he would ,"get someone who would." @
said refused, andNbelieved the hanger was accepted by another inspector.
(B) %said that in July 1982,~ cmplained toMsupervisor about a -
QC trainee improperly using liquid penetrant, but thatM (supra) told o_" forget about it." Msaid this discouragedM from; performing [hedduties. -
! (C)
M said that when'%orked as a welder,Mperformed numerous i
improper plug welds at the instruction of various supervisors- (not further identified).
(D) W stated that in 1979, a welding foreman instructedho weld i a leg on a hanger which was not authorized by the drawing, (E) Mstated that in 1982, Mimproperly instructedM to sign off on torquing on Hilti bolts without proper authorization, then %later denied having told % to do so.
(F) M said that in 1982, l instructedM.to inscect vendor welds on diesel generators whichM told him Mdid not know how to do.
{I g said thatm toleMthat if Meid net co the inspections that ,should "go hcme."
a
'I __
.- ~ , , -
- - - - --- . .~ - ---
7 52,191 y,
9 '
' ,*~~ .
-l r . f. ) * *'
Okay. Now at that time, were you qualifed -
gge 21-3 1 Q
2 as
- a welding.QC inspector?
1 3 A Yes.
4 Q What is tihe dif f erence between welding on ,
5 pipe supports and welding on skids and. supports for the 6 diesel generator that made you believe that you were 7 unqualified to inspect the welds on the diesel' generator ,
8 skids and supports?
9 A I was only qualified for Class V pipe supports II and III, which 10 or for -- actually, other than Class I, was what they called Q, I was qualified to do Class V --
11 12 IV, V and VI.
13 .
Also the diesel generators were vendor welds, 14 and it was' my understanding that they had been previously l
15 inspected prior to coming on site and were just a minimum 16 bought off as being able to make the trip, but I didn't 17 feel that I was capable of inspecting those, because they .
18 were vendor welds and because of the density and the --
19 I guess that would be the right word -- of the blueprints.
20 I was not familiar with that type of blueprints, and I wasn't 21 able to read them very well.
22 . Q Okay. I heard several different reasons for I think I heard three, 23 why you felt you weren't qualified.
24 and let me repeat these to you, s.eparate them out, and see 25 if you agree with me.
I
- t
- M8 9 ka r M* h T - " gi,. e6
- h4 . 6 4 M g h d *g '
p 4 e
_:=_m_ r= ~ ~** ~ ~' ~~ '
1 52,192 .
The first reason was that you were 1-4 1 I, II and III, 2 qualified to Class V, and other than Class 3 ,is that one reason?
d A Yes. .
5 Q Okay. And the second reason was because l
l, 6 these were vendor welds?
7 A Yes.
'.f l J
t 8 Q And the third reason was because you could j l' ,
dl 9 not read blueprints?
- h
. 10 MR. SOSNICK: I have to object, Counsel.
11 That,is not testimony.
12 MR. MIZUNO: Well; I' masking { if I'm 13 accurately summari=ing or not. If ,
doesn't agree --
14 THE WITNESS: No, it's not accurate.
l'
,i.
15 BY MR. MIZUNO:
j' .
16 Q Okay, then what is it?
,i.:
17 A I said I could not -- I was not familiar with
.h 18 the density -- I wasn't even sure if that was the right 19 word. The blueprints were very complex. I guess that's
[' ,.
20 They were very hard to read. That's the only thing
+[ right.
!!?' 21 I can say. I was not trained to read blueprints. I could
[ ,
L it i ' 22 read piping blueprints, very simple piping blueprints, and t 23 I was never asked when I went into QC if I could read i
So I didn't feel qualified for that reason j 24 blueprints.
, il '
i i-
'i , 25 also.
l t i i j l' -
V
!l i.
l ri .
h 2=::r g B v..g~.l.9.x..p;aa. - -- -
ny..,.,3.._ _ _ _ _ _ _ _
~
q - 1, ,
,.aT7l 52,192 PseI -
I' f
- 7. i.
9 !
g ti i
- k'd, .
1 The first reason was that you were e 21-4 I h II and III, I,
[ 2 qualified to Class V, and other than Class
! s 3 ,is that one reason?
- d A Yes. .
- 5 Q Okay. And the second reason was because 6 these were vendor welds?
Pi 7 A Yes. .
s
'. 4' - i m
. t, 8 Q And the third reason was because you could j
'l1. ,
..l7gj .
9 not read blueprints?
l I l'
.j 10 MR. SOSNICK: I have to object, Counsel.
u, i I Il That,isnotfll testimony.
i 12 MR. MIZUNO: Well; I' maskingfl[if I'm agree If}lll(doesn't
. 4.
13 accurately'summart ing or not. 14 THE WITNESS: No, it's not accurate.
.r 15 BY MR. MIZUNO:
>l,..'o
. ' ,,': q 16 Q Okay, then what is it?
' :7 l
~
ii
' 17 A I said I could not -- I was not familiar with p'
'l 18 the density -- I wasn't even sure if that was the right 19 word. The blueprints were very complex. I guess that's p j l , : ..
20 right. They were very hard to read. That's the only thing cc l l'lI l ; ,. 3
.l 21 I can say. I was not trained to read blueprints. I could
'! ; U 7 l i! 22 read piping blueprints, very simple piping blueprints, and
','l! [ L , 23 I was never asked when I went into QC if I could read
+
24 So I didn't feel qualified for that reason j *[ ,, j blueprints.
- f. . h 25 also.
! bb ,! , I i l! id. h - l ll! ^l i ;
.] u' .
i l
,s i l al '
,.tri
. L'*
- M; W'*'* * 'w' * * \ s}*.;. ., y a .;, ,,,,g a .sa r y. , , ,. :s.
y ... - - --- 1 -
.. l1
'a ' !
..]
52,193 q' 1 p
- I If t, .
hf 1 Q Okay. Let's start with hlueprints first. I
} ge 21-5 1
2 How do blueprints, other than their. complexity, who do , j 3 - blueprints for pipe supports differ from the blueprints d for the diesel generators? 5 .MR. SOSNICK: Counsel, I have to object 6 to this line of; questioning. I mean, I don't see all the 7 relevance of piping blueprints to allegations of 8 intimidation and harassment. 9 MR. MIZUNO: I believe that part of the l 10 measure of whether a person has been intimidated or not 11 is whether that person's belief is reasonable or not, and 12 I'm trying to ascertain whether belief that, 13 was unqualified to conduct the inspection of the welds 14 on' diesel generators was a reasonable one or not. 15 MR. SOSNICK: Well, Counsel', that is what 16 believed at that time. The testimony is what 17 believed at that time. Now we're here to discuss
< 18 allegations of intimidation and harassment, and you are 19 calking about blueprints. I think -- are we going to go 20 through every technical detail of every incident that 21 was mentioned during testimony?
22 MR. MIZUNO: I think they are two different 23 things. 24 One thing, you are talking.about the level 25 of detail that we're going to go into, and I would say yes. s - - - - - - - . E=' .~ i.s u s's Er s~~.~.= unsmNsus s '~ * '. ~~5 A~ ~ *= ~*'= >* '* m = ~~.* *As~*4 , . '. s *
. t L.a s s". .. .~ .a n...~~ , -.
- s. - e-.=;*.= . . .
} }%I - 52.194 () 1 il l ' b
,; f' 21-6 1 Second of all, the question is y). 2 beliefs. g
,4 Now we've established belief that j 3
,;1}} believed that was unqualified.
'fc -
d Now what I'm trying.co. establish is whether
- 3 .
1 belief was reasonable or not. They are two separate - 6
;; , [
f MR. SOSNICK: Well, maybe we. 7 1 if L MR. MIZUNO: Okay?
.f 8
r
. U(
- t.
MR. SOSNICK:' Go ahead. I'm sorry. i ii ti' 9 -l
- 1 MR. MIZUNO: Maybe we could set some i
.. '!p 30 II parameters here if we could just go off the record for i
.l . :.I I. ' "c one second and discuss this. Is that all right?
.; 12
!- MR. SOSUICK: Fine.
- l }I
'[
=
er k l 21 13 e c $ l e$
;i e
'h . 15 L <'- ;. :: j : I .3 : 16 v J '. ' li:s-s 17 3 18 5i 941 19 ' I $f l '!p 20
.u i'! 21
.I I
- 22
. x
,' :y n
? 2s I
* '%'t ,I
- 5. ' : 25
- i .l]
,1
'qi.
t t
. j tr l.
, t.
i hf $ EY0 Y Y ' ~ "
......-.-.--=-=--"""-~
. ~
. . , - ....._,~,. ~~..-
g , , - ' -
- w = 4 .1g'g g g g '
y U-
- !c t-C '- .
nf C, 52,195 }y;; yg l 8 s
;i' d
? P i; is '
, 9 5 . 'i 5 j zge 22-1 1 MR. MIZUNO: Back on the record., [, f t
- i 2 BY MR. MIZUNO: !
% g 1
3 Q What is the difference between welds that . .- j l si j j 4 are done by vendors versus welds which are done on site ,- ; 5 ; 5 that would make you unqualified to determine whether the i I I - vendor welds were acceptable or not?
.O j
7 MR. SOSNICK: Do you understand the question, . 8 J g 9 THE WITNESS: Yeah, I understand. I : j ' 10 It simply was not my job to inspect vendor - I
' 11 welds. I J
f ~ 12 MR. MIZUNO: That's not r e s'p'o n s iv e to my l 13 question. 14 THE WITNESS: That's the answer. That's 1 i 15 the only way I can answer it that I know of.
'I '
i 16 MR. MIZUNO: Okay. , I 17 BY MR. MIZUNO: lj 18 Q Did you communicate the fact that you felt -- ? l, ' l 19 okay, you did not communicate the fact that you felt 6
.1 . 20 unqualified to perform these veld inspections to people 1 %
21 who were higher than -- to supervisors higher than , 22 is that not true? 2 23 A He was as high as it went. I worked directly I ii
!. 24 for my superintendent, so I didn't have anybody higher ,
ij 25 to go to, except Mr. Tolson or somebody, which I would not I ' ( j '
.l' 8
1 kI.-..._.._-- _ . . . . . - . . - . . . - - . - ~ - , -- -~~--
n-- - - _ .= ~ . . -
- n. .w.--
--.-n ,
. . l'it .
' l '.
e i l' l i 22-21 have done. s . I i 2
.; Q What about Mr. Brandt? i 3 A Mr. Brandt was not even -- he was not even --
j 4 . i l Q He was not there? ! 5 A u '
-- over me at that time at all. '
l 1 i 6 { Q Okay. So the next highest person after I, 1 7 was Mr. Tolson? I 8 A Or Mr. Purdy. L I -- really, I'm not sure. . l
, I. . 9 ; i I Q Okay. Why don't you --
't-: ':
10 f
;fi A I don't believe Mr. Purdy -- 1 4
i 11 Q -- talk to people -- ! 3 t 12 A ? Sorry. Go ahead.
- 13 .
Q Why didn't you talk to people higher than 14
)
about your belief that you were unqualified 15 to conduct these welds?
' 4 I6 t A
In the first place, you just don't go over j
; 17 s your superintendent's head, unless you want to be kicks.ng 18 l
beer cans up the cow chute. You don't do that. He wasn't l l
- l. 19 just a foreman; he was a gold hat. And he was supposed I
)
a i 20 i
,, to know what he was doing. -
"4
. i E
.j
, 21 Q Well, you indicated, in talking about the 4 si $.
! !! 22 incident at the fab shop, that you talked to Mr. Brandt.
t, i ! 1, I ' 23 Why couldn't you }
' 3 I still don't understand why you j 24 ,
couldn't have gone up higher, since you did it in another I
, I.
25 case. k
. I ?
i l
!" l ! ;
i
- ~
t, ; i i
!! e 1 :
f'L , ink f.,g.,y, kkQM1 [s .j p ,? M M M W Q $ Q y. .
- I 52,197 6.' i!
V N
.e e
M* J l s
.:w ,, %)
When did I did it? I don't understand .i j :ge 22-3' 1 A , I 2 vhat you're referring there to. . ~-
.$u...
What was the basis for your belief that {p 3 Q -
.c i g4 '
h 4 going up higher tha ]wouldresult in you -- i u,j. '
% 5 what? -- kicking beer cans?
vr
>r be 6 A Being terminated is what I'm talking about.
tt 7 Q Being terminated. What was the basis for i al 8 that? l g d , 9 A Well, in the first place, who would I go to? 10 There was no one to go to except Ron Tolson or Gordon 1 ., - '. :J o L 11 Purdy, aad Gordon Purdy, he didn't have anything to do b I would g, 12 with our stuff. He was ASME. Ron Tolson, you just -- 13 y have had. to told that I was going to see - f n [j 14 Ron Tols,on about the same problem that I had just discussed it ., tj 15 with his. ; E5 16 Q And what's the problem with that? j3l
!. ]; i E $ 17 A He would have cold me the same thing he :
r 1 ,
- a d
l 1 18 already cold me. . e
?
g 19 Q Okay. And then you could have gone to j ia j[ 20 Mr. T o !.s o n . What would have prevented you from going to an 4 3 21 Mr. Tolson? i . 22 A I would have probably been fired.
.t 23 q And what is your basis for your belief : , ]. >
n i 24 t h a t, you would have been fired? 25 A 1 just believe.I would have been fired. { l 6i l 1 :
.I
_,,,,,,i,
; f f.Jhw 44* * ..'.I hb.h* ; .. . ,j,,;, A d g',jNJgA . . .,'.4.J. A . . , s '*. 4". .; ,- . *4 .
+ .b s . . .= . .. ... .6., . , , , . , , , , , , , , . ,
. - - - - - r; p ., ,
, , 1
[ 'i N C,, l ;
! a . ! !
).,
3 22-4
..g Q You have no basis? j 2 ,
[ A J He was nade at ne anyway, because I had told [, 3 1 hin that I did not want to.do the inspections on the diesel l . . I generators because I didn't feel qualified. . 5 . - Q But you told that coI You . ; O 4 didn't.tell that to Ron Tolson.
', j So how could Ron Tolson f 7
have been angry at you? 7 a , i A' No. was already angry at l 9
.ikE f ot me. So if I had gone to him and said, tj'l to "I want to go and a C
3
!' ~
]e talk with Ron Tolson about this problem, because I don't 11 )
t feel like you're doing anything about it," I feel like he j I 12 would. have fired ne. If not then, he would have fire'd ne ) 13 !4 l .- the next day or the next week or the next fifteen ninutes ' j 1s
,' . , , for anything he could find. :*
3 15 1
- MR. SOSNICK: May I ask a clarifying question. .i 4
16 " ( I think I can get your answer for you. 17 l MR. MIZUNO: Okay. I 18 3
': a
. MR. SOSNICK: Is it your t es ti:iony , 3 j.
that if you go over sonebody's head, you risk
'o ,
.', being fired? i 21 {
THE WITNESS: Yes. 22 2 o ,' , , MR. REYNOLDS: Objection. That's a leading 1 l 23 j
;i l .
I question, Counsel.
{
24 g MR, SOSNICK: i 8
- s. Just for purposes of 25 )*
ii-clarification; that's all. I ( 3
. I f ,a; .e ,
I i'
- i -i
- 9 h8 l
{l ) [ l a
. Y! .
t *
.~ a. . . ~ . a.a. . u... .. .
~,.w.:....c.~..=........~...- ........-....u..~......n-
. .- - - - - - - - .- - - * . ~ -
G.XVcEME1?MG?M U@wbr~K_ :%f, _ _ . . . . . . _ - - . . . . . . ~ . ~ - - 4131
- -7 . ., )
o1 for inspection of class 5 supports and he needed people to work on this. I l 2 knew that Brown & Root was going to lay off a lot of people the next week and that I had to find myself in another position before that time or I would 4 be out of a job. I explained this situation to and he indica-5 ted that he would get back to me in a few days. 6 Afteracoupleofdayshadpassed,I'contactedh the Site 7 Quality Assurance Supervisor; I just couldn't wait for ' to contact me. She put me in touch with the Site QA Manager. 8 L 9 discussed the pay range with me and then hired me on to work in group. 10 11 Q. What position didYhire you for?
- 12. A. He hired me as a,
' This was non-ASME work. -
14 Q. What training or certifications were required for this position? 15 A. At the time I went in, you didn't have to have any particular 16 training or certifications. I came in with welding experience and training. 17 I had also ccmpleted the classrocm hours for the ASME 1.evel II Visual. 18 Q. Did ' nquire i about your educational background prior to 19 hiring you? 20 A. No. 21 Q. Did you fill out any type of application for this position? 22 A. Yes. It was necessary for me to fill out an application because I 7.'t ' went from field to administrative pay. 24 Q. Did the application form require information about your educational background? 25+
.~...c. .....-......,,m, z .p ;gr.g g ,y, 3 g-- m y y n sra :
. ~___
l_ - e 4132 j 8-b A. 1 I don't recall, but I feel sure that it did. I can't remember the 2 exact words on the application form. 4 .--Qr: 1!svc you cycr indicated-tnt an applitatic,n o that you were a high
- 4' school graduate?
4 .
. 5 A. I have not. 1 6 Q. Did you know at the time you were hired what the requirements were j 7 for a Class D Visual Inspector? ;
l 8 A. At that time, no.
- 9 Q. Did anyone attempt to explain what the requirements were?
10 A. No. When I firs.t went into QC, I was given procedures to study that ! 11 would apply to my inspections. The first procedure they gave me was QI QAP 11.11-
; 12 1, Revision 0. ; h ' Q. Do you now know what' the' required qualifications are for a Class 0 14 Visual Inspector?
15 A. I do. In order to qualify as a Level D Visual Inspector, one must 16 have a high school education, an allotted amount of on the job training (0JT), 17 a limited Level II visual test, and a valid eye examination. . 18 Q. When hired you as a QC inspector, what qualifications 19 did he require? 20 A. He was aware of my welding experience. Without ever actually saying 21 anything, he waived the other requirements. At that time, the Class 5 hanger 22 program was new; there weren't even any tests made up for me to take. Q. Was anyone else hired into this program at that time? gg 27 A. Not at that time. There was one other inspector at the program and 25 he had already beert there a week. That was James Leigh. I do not know what O ,
,.,n l
' ' ~
'~l pEU"4CJ.WFEf'%%q.'.;.XlQLP9".
- u. . .. .u 0, . e ,;.& ... . . . . . . , . . . . . ..... u a ..
~a':"..J~~['
- u. AN""
. ... ~.> .a .g. ~. .> . . . - .. 3 3. . . _S. ...
4133 _g_ 24 [ his qualifications were. I do know that he was hired in at 2 . . .; .. , v.' w , % N % e..
- h Q. .Did you at any time take any training courses or obtain any certi-4 fications that would qualify you as a Level D Visual Inspector?
5 A. As I said before, when I first j.oined the QC program, there were no 6 tests or certifications required. At least, not to my knowledge. For approxi-7 mately three weeks I studied procedures, went around and observed inspections 8 with Clarence Bufkin, one of our supervisors, and perfonned a few inspections. g All of my inspections at- this time were under the direct supervision of Clar-10 enceBufEin. At the. end ,of those three weeks, I took a limited level II visual 11 test. This was a test that they had decided would be required. I also took 12 a. hilti bolt. installation test.
@ Q. Did you pass the tests?
14 A. Yes. The- first test we took was the limited level II. Each inspec-15 tor that took it was told to retake the practical section. We were told that 16 Mr. Maxwell, the Level III at the time, had found the coupons that we had in-17 spected (and rejected) and that he thought that they should have been accepted. 18 James Leigh, Larry Hite, and I had all rejected the coupons. The three of 19 us retook the practi, cal and passed. 20 Q. What happened after you completed the testing? 21 A. I went out and started inspecting on my own. 22 Q. What were you inspecting? 2 A. Class 4, 5, and 6 pipe supports. Q?? 2 Q. What other training courses have you taken at CPSES? 25 A. In , I took the CP-CPM 6.9 Procedural Training Course. G
%, .w. ....u=. .:.m,.zuxa.~=. .w:w=. :. =.c-~m.~
. , . . . . . . . . . .. .~ .. xw=w
- - ..- . . . .- =-. . . . .. .- - .- . - -
wmo,.-o,,. ee e . . mw, se e, w e
4134 Q o 1 I took this course in order to familiarize myself with the CPM 6.9. At that 2 time, this was a site construction procedure for almost everything you can name on. site. The class was required for QC people and also many of the craft 4 people. A memo was sent to me- by the QC secretary requesting that- I take this 5 course. Several others in my QC group took the course along with me. I have 6 attached the certificate of completion for' this course as Attachment H. t 7 Q. What other courses have you taken at CPSES? 8 A. I have also taken the required number of classroom hours and the 9 written test for both Magnetic Particle Inspection (PQYX 200 GT) and Liquid 10 Penetrant (PQYX 210 GT).. I have attached the certificates of completion for 11 these courses as Attachments I and J, respectively. 12 , Q.~Did these clas'sroodr hours and written tests qualify you to perform h magnetic. particle and-14mid penetrant inspections? 14 A. No. They only fulfilled part of the requirements for becoming an 15 inspector in either of these fields. I would still have to accumulate the l 16 required amount of OJT. I am unsure how many OJT hours are currently required 17 because they change the number periodically. As of this date. I have.approxi-18 mately 75 hours liquid penetrant time and approximately 8 hours of magnetic 19 particle time. At one time the penetrant requirements were only 120 hours, then 20 they changed to 150. I don't know how far I am from getting the full certi-
. 21 fications.
22 Q. Are the Magnetic Particle and Liquid Penetrant inspections used on the ASME or non-ASME side of the house? e 2 A. ASME. 25 Q. Why did you enroll in these courses if you were inspecting non-ASME
- O .
h a # T "
. 4 '* -
m* =wu.a.us:..u ausuu kw - . uu. Mpaa.a.G uA.a G.w.a. cw...w., , . .' ... . . ..s. .n s . un
......,..-.,.,-~.n, .- -~. -~ - , . - ~ ~ . - - . - - -
.,.n _ _- - - - ._ .- - -- 1 . 4135 h C.- 1 items?
- 2. A. Because I felt like if I got more certifications, my level as 3 an inspector would raise to a C and I would have a chance for a pay raise.
4 Q. Have you ever been certified as a Level II ASME Visual Inspector? 5 A. I never received the actual certifications to perform the inspections, 6 but I did complete the classroom hours required for the Level II ASME Visual. 7 I have attached the Notice of Completion (Attachment K) and the certificate 8 of completion (Attachment L) for these classroom hours. As the completion 9 fanns indicate, I took the Visual Testing (QVT-301-GT) in March,1978. 10 Q. Were you still working as.a substation attendant at this time? 11 A. Yes.
~
1 Q. What prompted you to take this course ? y 1' A. While I was working as a substation attendant in the Weloing Engineer-14 ing Department, I was sent to take the Level II Visual test by my superiors. My 15 supervisor,' told me that they wanted to see if people with mini-16 mal experience could pass the test. the corporate Level III at 17 the time, administered the test. He told us that it was the hardest test to 18 pass on the Comanche Peak site. I took the required number of classroom hours 19 (about three days), and then took the written test. I took a general, a speci-20 fic, and a practical. I had been involved in weld rod control and other re-21 lated items up to this point; mostly weld filler material. I passed the test 22 and received the training course completion certificate. g Q. What other requirements would you have hac to fulfill in order to 24 obtain the certification to perfonn the Level II Visual inspections? A. 0JT hours in the field; I am not sure how many were required. I did Y:$;3 -~mm.-- -
.a .a wm a ,w a . . . . . . . + . .x. _._.
. ~~ ~ . ~ . ~mn- q .; < .;;. . m m x~~~ ~ ' 3 ; c; ;
- . :.a.
z
. . . ,.n... a. ._. y ;,.s .. ,.: . n :. 3 . . , , . . . . . . . .
,. ~-- _ . - - . ----. ........ c = m +.e.. m w a - .. umn l' . 4136 tD
- s. c 1 not have any of the required 0JT hours at that time.
2 Q. Have you ever perfonned inspections under the training certificate? h A. .No. I have not used this certificate to perform any inspections. It 4 does not give me any additional authority to perfom inspections. The training 5 course served mostly to further my education and knowledge in the welding field. 6 Q. When you transferred to QC in July,1980, did you infom i 7 hat you had taken the Level II Visual training course? 8 A. Yes. 9 Q. Did this make a difference in your transfer into QC7 10 A. It would have made a difference in my pay, yes. 11 Q. In your pay only? 12 A. Yes,. I. think so At that time the only position open, I was told, A p;-y was. in the class 5. non-ASME program. The Level II Visual training was for 14 ASME work. 15 Q. Did 'the position in the class 5 hanger program require the Level 16 II ASME training? ' 17 A. As I stated. earlier, it did not. - 18 Q. If you desired to complete your certification for the Level II ASME 19 Visual Inspector in order to perfonn the inspections in the field, would 20 you have to go back and take the classroom hours again? 21 A. I would not have to take the classroom hours again, but I would have
, 22 to take the general, specific, and practical tests again. If you wait over 2 a certain period of time, I believe it is 60 or 90 days, between the 2 time you complete your classroom hours and the time you do your 0JT, then you 25 do have to retest. The same rule would apply to my Magnetic Particle and Liquid n
.,. g,; ~ , . y. .
. . . 3 -- .- 33 -. . , 7--.g- - _
4137 0 1 Penetrant hours. If I did complete my OJT for either the Mag Particle or Li-quid Penetrant, I would have to retake the tests before certification. Q. .Have you ever tried to take any of these tests over? 4 A. Yes. After I transferred into QC, I tried to take the Level II Visual 5 tests again. I was told tihat I did not have to retake the training hours. I 6 took the general test and passed it; I do'not recall what the score was. Some 7 time later, when I received my ASME training files, this test score was not in 8 the files. I have no idea what happened to it. Anyways, when I requested to 9 take my specific and practical over again, I was informed byI that 10 the superintendent, had said that they were not allowing non-11 ASME personnel to take the Level II Visual anymore, who had just 1- been made lead man over the class 5 group, had recently completed his Level 3 TP II test. I. did not understand why, a'fter I had passed my general, that I was 14 not allowed to complete the other two portions of the test. 15 Q. Would have been aware that you had completed the Level 16 II ASME Visual classroom training? 17 A. I don't think he would have. I made the statement to him once 18 that I had taken the test. I don't recall exactly what he said. I mentioned 19 it to him at the time he took his Level II and they wouldn't allow me to take 1 20 it. He said something to the effect that he didn't know anything about it 21 and that I should just talk withf%about it. 22 Q. Does .fiave any knowledge of your welding ability? A. No. I did not knowf until after I transferred into QC. 24 I don't believe' M~[ knows anything at all about my welding ability. Q. You stated that you began to perform inspections on Class 4, 5, and (6 1 . i 1 i m .7-n..y.. r.- .. y~...- p- y . .n.-- m ;r v- .. .m
......n..,~.-.~-n.
-,g.r.
s e p .~ mrm
.-Ar y ac.a w ..m... a,.. .<c.u.. n, u. . .: .. , g, ..
.... . . <. u . . . . . . . .
_ ; . z. ,
,e- .. .r.--
. . .- ~. . . t .. . a : .. .......a.s. w .-. . . . a - - .- ...
. .. .n
_ -- : ~:r_r-~ m-~_ - ~~'
.. -m. .....-.....z== = ~ vm;owmw- . w. .a.. : .. .= > ::..:.x I-
- 4138 l .
.h 1 6 pipe supports in July,1980. At this time. were you inspecting only pipe 2 supports?
3
& A. Yes.
4 Q. How long did you. inspect only pipe supports? 5 A. Until approximately June 10, 1981. 6 Q. What did you do then? 7 A. I was put on a program for inspection of vendor welds on diesel 8 generators. 9 Q. Why were you put to work on the diesel generators? 10 A. I was asked by to work on them because M_ 11 was the only person inspecting all four generators and he needed help. 12 Q. Had you ever inspected vendor welds before? - 1 A. This was the first time. . 14 Q. Did you have any difficulties with these inspections? 15 A. Yes. I had been used to working off a simple isometric blueprint 16 which showed the hanger location for piping. The blueprints for the generators 17 showed the pumps, piping, and everything on the generator. As I recall, there 18 were two blueprints for the skid and three for the supports. I had to start 19 with these blueprints and then refer to the typicals (the designs for the sup- {
\
20 ports), in order to find where thewelds and supports were even supposed to 21 be. 22 These generators were huge; they sat up on big concrete slab blocks and l then the generators themselves were probably 15 feet tall and 25 feet long. I 23. l 24 would estimate there to be approximately a hundred pipe supports on each gener-25 ator. The inspections were very complex and difficult to follow. I had never h . 99' _ .-- - - - -
4133 O
%)
I worked on anything like them before. 2 Q. Why were Brown & Root personnel performing inspections on vendor welds? A. 'The way I understood it, these generators had previously been inspec-4 ted before arriving on site. When they arrived from the vendor, thei were 5 supposed to be ready to be. installed and fired up. They needed reinspection. 6 Q. Why did they need to be reinspected? 7 A. They weren't any good; the vendor welds had undercut and porosity 8 and some of the welds and supports that existed on the design documentation 9 were not even there. So QC started a. program of reinspection on the four 10 diesel generators. I believe- the reinspection was done under the direction 11 of Mr. Tom Brandt. 12 Q. What did you do when you found that- the welds or supports did no't 1 confom to what the blueprints or typicals said? 14 A .. We were told to "as built" the welding symbols and conditions. We 15 . changed the typicals to reflect what the welds or supports actually were in-16 stead of what the typicals said they were supposed to be. Also, on the skid, 17 we "as built" on the blueprint itself, there were no typicals for that.- 18 Q. After you completed an inspection, what did you do with the blueprints 19 or typicals that you "as built"? 20 A. We turned them into engineering. 21 Q. What happened to them after you turned them into engineering? 22 A. I do not know exactly what happened to them after that. 2, ,, once told me tham a TUSI employee in engineering, had said that
\*
24 whatever we came up with on the "as built" diagrams would be accepted as an 25 end result. They wantedM and I to come up with what was actually on
@ 4 j.Tas..E..YJ.
.. S G.P wA G. r.i.!.!Ya".%%..".~5:".MWR"~*.!.m.+T.T
. . n. a-- .- . . . C.'.F. .P..W4.CI ' "l '- '".
-----u-~~ -- ""- 9 "? "" ".>.
" ~.'*
.
- U- "" - "
~ ' 1'.W1.
- ~ - >
s
- -.-.. --... .. . . . . . . - . - - . . . - - - . . ~ . . - . - . . . . - . - . - . . - . - ~ , . . ~ . . .
? .
~
1
& the generators themselves. They wanted to knew weld sizes, types, etc.
2 Q. Was a final inspection done on the diesel generators? t 3'Q A. I don't know, but I assume they were all reinspected. I rejected 4 almost all of the welds I inspected. I would change the diagrams and then 5 the millwright people would be sent in to do the repairs. After their work I 6 was completed, a final inspection was probably done. As far as I know, the 7 repairs and any final inspections were done according to the "as built" 8 diagrams I had done. 9 Q. Did you express to your supervisor that you were having trouble 10 with the blueprints and the inspections on the diesel generators? 11 A Oh..yes. Every day I told him that I wanted to be taken off the 12 generators, that f did not know what I was doing. told me 156 to do the best. I. could, not to worry about it,. and to take my time. He said 14 that if I had any problems, I should talk with about them. 15 Q. Did oversee your inspections? 16 A. No, I was working on my own. These generators were so huge and 17 complex that at times I couldn't even find Also, with only two of 18 us working on them, was very busy. There was very little time for him 19 to assist me. 20 Q. How long was it before you were.taken off the diesel generators? 21 A. About three or four weeks later, finally took me off 22 these inspections. Q. Af ter you stopped working on the diesel generators, what did you do? l21.,S Q 24 A. I went back to inspecting class 4, 5, and 6 pipe supports. I continued 25 to work only on pipe supports until approximately April,1982. O . T45'O'?.CGRM.~,*27.~".W~.? mC?E
- * ~ .M'U.'".,2.'."G.K' A . "' "R L~ ~ - - m :- - ' 7blT.'
' '~~ r:ORT?L'*.T".
m- ~': :-l '..
?' ?i 2:'C ".ni?L
. . w. . .:. : -- ~~ : :... .._. ; ,.
-:s.x;;u ceu:E , . _ . . . . .
. '
- W1 ,
G 'A s\ j SEER WRITEUP DOCUMENT CONTR0t./ ROUTE SHEET {- j
; Al1 ega of Subject tion Numbers AG Allegation -fu-23, A oj-24,
- A c .;c> A G -A7, As-2P, AqC-/op 4 7. p
, TRT Group _.
Author: c,f. /d c_ N
,Jj m ,,jgv g
i
' This sheet will be initialed by each reviewer.
~
SSER writeup and serves as a routing and review record,It stays with all revisions to the t work package when the writeup is published, it will be filed in the i Draf t Number , i Oraft 1 2 ' 3 4 5 Author Group Leader d.Ul d i \W)b a -
/ M /e/fo/g Tech. Editor / /M T 012.
~
/ '
l Wessman/Vietti / i
.J. Gaoliardo / ; T. lopolito /
e Revision Number i ' Final 1 2 3 4 5 l Author
- Tech. Editor i Group Leader
} J. Gagliardo T. Ippolito l l 9
Admi nis t ra tiv e Writeup integrated into SSER potential Violations to Region IV Workpackage File Complete . Workpackage Returned to Group Leader ,[ ?
. N
,\D)
~0!A-85-59 4s
..c _..
n . ['00 Un & n
- f. .:..t :
. A0-73, ETC.
t 1 I Requestor's 10: i DEDI,P.02
.i 3
; Author's Name:
Chet Poslusny Document Coments: l, t t
.)
i e
'l 1
i
.i
.t i
i a 4, i l i i i
. _ . . _ . . . . . - . - . _ _ . . _ . . . . . _ . . _ . . . . . _ . . . ~ . . . . _ . _ . . . . _ . . . _ - _ . _ . . _ . . . . . . . -_
- v. y ,. . + = --
__ 7_ _ ,_ ;,,_ U/
- C/ . , ,
I
- 1. ;
Draft 5 10/:'9/E4 AQ-23, etc.
.j -
SSER 4 1 1 1. Allegation Group: QA/QC No. 4
- 2. Allegation Number: AQ-23,AQ-24,AQ-26,AQ-27,AQ-28,AQ-108
- 3. Characterization: It is alleged that quality control inspectors are not qualified due, to inadequate training, that there was widespread cheating on certification exams, and that training records are a
, 1 26- incorrect. There were also allegations that a small group of quality control inspectors in the Design Change Verification Group (DCVG) and a group of quality control inspectors inspecting the 2500 class S hangers were inadequately trained. ,
4 Assessment of Safety Significance: The implied safety significance of these allegations is that the lack of training and qualifications of quality control inspectors could result in inadequate inspections of safety-related hardware, thus making the condition of the hardware i indeterminate.
\
i 7 . . . . -. _ ..,. ,_
,- -~~-------; ,
Q- " '~ 7 .. ,
, i f
a The NRC Technical Review leam (TRT) reviewed b Brown & Ront (B&R)
, procedures and 21 Texa!. Utilities Generating Company (TUGCO) f procedures to determine if they met the intent of ANSI N45.2.6-1978, i Regulatory Guide 1.58, Revision 1, and SNT-TC-IA-1980. The TRT also ; thoroughly reviewed the training and certification files for 102 QC i
personnel (13 Level I QC inspectors, 76 Level II QC inspectors, j 8 Level III QC inspectors, and 5 QC clerks). The TRT also l interviewed eight Level II QC inspe_ctors, the training coordinator { for ASME QC inspectors, and the training coordinator for the non-ASME QC inspectors. Of the 102 QC personnel whose training E records were examined, 79 were ASME certified. In addition, 37 of . the 79 ASME inspectors had non-ASME certifications for Hilti bolts. The TRT reviewed tests for Level II visual weld (VT) inspectors and Level I and Level II mechanical fabrication (MIFI) inspectors. e The ASME personnel training and certification program was j established by B&R procedure CP-QAP-2.1, a general personnel training 1
, and certification procedure, and the more specific B&R procedures QI-QAP-2.1-5, " Training and Certification of Mechanical Inspection Personnel," and QI-QAP-2.1-1, " Nondestructive Examination Personnel
{ Certification." These procedures were detailed and met or exceeded the requirements of ANSI N45.2.6, Regulatory Guide 1.58, and SNT-TC-1A. The requirements for each inspection discipline i and level were well defined, with inspector education level and
, experience specified for each level of inspection. There t
1 i
- - ' - * ~ ~ ~ ~ ' '~ ~' "'
; 3:; , - -
, ~ . .
. - . . m i g. wc. . .? : ~ - . ,, .
t I ( were outlines for certification and retertification which included detailed procedures for certification training.
.l Minimum on-the-job training (0J1) was also outlined for each inspec-tion discipline.
I i In the QC testing program there were two areas which were poorly defined in the B&R procedures. For certification testing the type of test monitoring (i.e., proctor) was not i t specifically defined, nor was there a specific program for l periodically establishing new tests, except when procedures were changed.
/ .c One other area of concern to the TRT was B&R's and TUEC's interpreta-tion of the applicable ANSI standard. ANSI N45.2.6, paragraph 3.5, I " Education and Experience Recommendations," delineates the education and experience recomendation for each level of inspector. The standard also states that other factors which may demonstrate capability in a given job are previous performance or satisfactory
. completion of capability testing. B&R and TUEC procedures quote the ANSI guidelines as their standard of inspector certification.
In practice, they do not follow these guidelines. Rather, their f I -
< ck j' system follows the exception to "the rule" by using "other ,.
*( * '
factors" as their nonnal method for qualification. p t .T^ 'r,1*f*" f
,i MD..!TQ'-
j" ,,... 1 I
. , _.. _ .. _ . .... . . .... . . .. _. , _ ... ..._ . . . _ . . , _ . . . _ _ _ . . _ ~ . . . . . . . . . .
=- --
j- ,-3 _ j . - l
~
l . ) i l
! ,A.
is ) The non-ASMF personnel training and certification program was governed by TUGC0 procedures CP-QP-2.1, " Training of Inspection Personnel," CP-QP-2.3, " Documentation within QA/QC I Personnel Qualification File," and TUGC0 Quality Instruc-tions QI-QP-2.1-1 through Ql-QP-2.1-19. Although, TUEC I j had committed to ANSI N45.2.6 and Regulatory Guide 1.58, the TRT has several concerns about the nonspecificity of their procedures and Quality Instructions:
, (1) There were no requirements for verification of education and 'i .j work experience.
(2) Personnel capabilities were loosely defined by levels (1, II, III). (3) The specific inspection disciplines were addressed in separate quality instructions and were administered by a cognizant quality g engineer in that discipline. There is no one individual who l controls the training ' programs. As a result, the overall quality program is rather fragmented. i 2 (4) Recertification could be acccmplished by a simple "yes" from
'i
'1 an inspector's supervisor. (5) There were no guidelines for using waivers for OJT, even though waivers were used frequently. l (6) The certification testing program had many problems, such as: I
! (a) No requirement for additional training
. , - , between a failed test and a retest.
2 U, 1
, . ~, ... . , . . .
, , . . my g. p - - y r - -'
l ., I
. 5
' .m (sJ ) (b) No tirne lirritatier on how soon an individual could retake a failed exam.
.(c) No assurance that the same test would not be given l consecutively.
(d) Two different scoring methods used to average the I. t i i results when two tests were taken. (e) No guideline on how or when a question could
) be disqualified on a test.
(f) No program for establishing new tests except t when procedures changed. j (g) No specific details on how tests should be i monitored. I j , (h) No limits on how many times an individual could be tested for a specific certification. The TRT identified the following specific problems which.fmphasized I 1 _ the overall weakness in the QA training._.and certification program. [. 2i
/
- D/ /.
) g. 2 1 j Of all the Brown & Root and TUEC training and certification '
- f. , "
records reviewed, 20% containtd no verification of education and/or ~ ' s ' I 1 past employment and work experience. In addition, there were several instances where verification took place after the individual was certified, as long as 2 years later, in one case. There was one j instance where an individual listed work experience on his resume that
, was false. After receiving correct information from individual's former y/ employer, B&R noted the fact but took no action against the person.
h
,_ _ ... .o-.~..~. v.m ,. 7 = = ' * * * ~ * ~ "******f***'****'***** * * * ' " ' ~ ' * " " * " ' ~ ~ ~-
~
- a. -
=;:mu.- ? -. x . n e = r v s. z n 2 - . -
1 ( There were ten instances where the results of a Browr. & Root Level I I certification test were recorded on the Level 11 certification. The
! time between the Level I test and the issuance of the Level II certification varied from 1 month to 6 months. Normal practice is to
.{ test individuals at each level of certification. The TRT was unable to i
etermine why these ten individuals were not tested in the normal way. There were six instances where, after failing a certification test, applicants were permitted to take the identical test; in some cases as
.t j soon as the next day. This occurred with both B&R and TUEC.
-\
4 There was one instance where a Brown & Root certification was issued D' but was not signed or dated. The explanation given was that this individual would not be used for inspections. There were two instances where white-out was used on certification examinations, contrary to CP-QP-2.3, paragraph 3.3.1(h).
.1 i
] During one certification examination, a TUEC QC inspector applicant was observed by two people leaving the testing area, going to his desk, reading something, then returning to the testing area. Even though his certification was subsequently voided, tests were supposed
'-! to be monitored and this one was not. This incident raised questions i
l about how closely the monitoring policy was being followed. There was i no apparent corrective action taken by TUEC in this case. !i !i I p_ _ Mee 4 % -+ NUMO %
* ' --- - M '_' M :
_________'1"~ 2--~--
.-. _._ _. .L 2: U ' .; . : . .:. .. : :Mr. : b L. . : .. ': : . . ..
i 1
, l' -
j Ng in reviewing B&W and TUEC recoros, there were sever: cases where the ,, _ , . l . j qualification of inspectors appeared to be questionable: }7
, One individual, who was a millwright prior to his transfer to QC, 1
j had no background in QC inspection or nondestructive examination (NDE). t He was issued a Level 11 certification for liquid penetrant (LP) d inspection work 4 months after his transfer to QC, and a Level II l certification for Magnetic Particle (MP) 7 months later.
^l-t ?! Another individual was a carpenter prior to his transfer to QC inspection and had no inspection background. Two months after his i
transfer to QC, he was issued Level II certifications for VT, MIFI and
> l mechanical equipment inspector (MIME). After 3 months, he was issued j
f. a Level II certification for LP. 1 3 A third individual was a laborer with no inspection background prior
'i j to entering QC. Four months after transfer to QC inspection, he was i issued Level II certifications for LP and VT.
l 1 1 i A person who had been an iron worker prior to his transfer to QC i had no experience in inspection. Less than 1 month after his transfer to QC inspection, he was issued Level II certification for VT
.1
! and MIFI.
I e
.y77-,.-~.~~.s~~~~~-~~~-~~'~"'"*
.w. ~ > .--r 'w'.r.+
. . .s -
- n. ,
l' i". " ' _ i_' '
'ul . ._.t. ._ i
{ 1 . IIQ
) Another person was a floorhand on e drilling rig prior to ertering QC and had no inspection background. Six months later he was issued a Level 11 certification for VT and seven months after i
j he entered QC inspection he was issued a Level 11 certification for LP. 1 s
. In another instance, a carpenter's helper was transferred to QC with no background in inspection. Seven months after the transfer, he was )
issued a level II certification for VT; and eight months after the i transfer to QC, he was issued Level II certification for PT and LP. I 1 An ANI liaison person with no background in inspection was also transferred to QC. One month after his transfer, he was issued a Level II certification for VT and two months after his transfer I 1 1 he was issued a Level II certification for MIFI. A laborer was hired into QC inspection with no work experience in QC inspection. Two months after his hire date, he was certified as a Level I inspector for Hilti bolts. A
! memo was sent to the QA manager requesting a waiver on the I-year experience requirement on the grounds that the individual had received sufficient OJT and had passed a test. The waiver was }
i i granted by the QA manager. It was subsequently discovered by B&R
! that this inspector's work was totally unacceptable and all of his inspection work had to be reinspected.
.' f-i i
I
.: w- - y: = =
. . . . . n- C .- -.
.._. _. :L:,. _ ;. ... 1
*I j( The requirements in QI-QAP-2.1 '., prevented an individual from taking the same examination consecutively and specified that i
i personnel who failed three consecutive examinations for the same certification were not eligible for qualification and certification in that inspection activity. The B&R practice of not retaining failed i examinations made it difficult to determine if an individual had i i failed three examinations or if he was retaking the same examination. l 1 With respect to the allegation that specifically questions the j qualifications of the QC inspector in the DCVG the TRT reviewed the I qualifications of five QC inspectors in that group. The TRT concluded that all inspectors were qualified, with the possible exception of
., an individual whose certification was limited.to document review verification only.
In reviewing the allegation concerning the inspection of 2500 class 5 l
; supports, the TRT reviewed the qualification for 19 inspectors t
j involved in that activity. Only one inspector, was found to have t i questionable qualifications, i In the TRT's review of craft personnel who transferred into QC inspection, five individuals were found to have questionable i j qualifications. I i c With the exception of the one case where TUEC identified an f
; individual cheating on a certification test, the TRT could not find t .... -_,; = c s ;::a:n' ~.=.: :. 2 . . : = .:.c:. L. - ~ ~ ~ :. r - ~- = ..
c
- L m:2: - ,.;:r
,_ y_ ..-...:....-.;
16 - ( , any docunentation that there was widespread cheating on certification examinations.
- 5. Conclusion and Staff Positions: Based on its review of the allegation concerning qualifications of inspectors assigned to the i DCVG, the TRT concludes that these inspectors were qualified for the task to which they were assigned. The allegation was not substantiated.
The TRT reviewed the allegation that specifically questioned the qualifications of inspection personnel inspecting some 2500 class 5 supports. TRT reviewed the qualification for 19 inspectors involved with this activity and. concluded that only 1 inspector had questionable qualifications. The staff position is that, although a small percentage of the inspectors were not qualified, the quality of some of the hardware may be suspect; therefore, the allegation has substance. With respect to the allegation concerning widespread cheating on QC I certification tests, the TRT could find no evidence or documentation I to substantiate this allegation, with the exception of l l the one case documented by TUEC. I r l Based on a TRT review of allegations concerning inspector qualifications, certification, and training in general,CQtheW&TRTg\\p
; concludes that the training and certification program for the ASME inspection personnel was adequate with the exceptions,already goted.
g !> Ru lN ua=.= -
- . c. .. x a -
- _ _ ._ 1 , _. - - - - - - - - -
h. In the non-ASML trainirag and certification program, the TRT found a lack of programmatic controls to assure that the program was achieving and maintaining requirements as set forth by 10 CFR 50, Appendix B. Problems areas were: (1) in the documentation for qualification including verification of education and experience; (2) in the training and certification program; (3) in the recertification program; and, (4) in the certification testing program. The TRT concludes that the deficiencies in procedural requirements and guidelines in the training and certification programs have j potential safety significance. The TRT does not infer that all TUEC and B&R inspectors are unqualified, but that identified inspection deficiencies, as .) enumerated in the electrical, civil, and structural SSERs, or lack of inspection thereof, indicate a root problem with inspection qualification that is directly traceable to their
" minimal requirement" inspection certification program.
l 4 l
} 6. Actions Required: A third party shall, before fuel load, evaluate B&R and TUEC's entire program for training and certification of QC 3 inspection personnel with emphasis on supporting documentation and 1
j certification testing. B&R and TUEC shall upgrade their program as required by third party findings. B&R and TUEC shall also review all inspector qualifications and in those instances where the inspector l does not meet the qualification requirements, B&R and TUEC shall take
- i. \
. ; .- . - -. . - - . z- . --
--.._--;7
-- ; ;.; - -- - - ~; _ -- ;- - - - -=3_---_____
s
. m w une .u.o ,.;,
,r b
f . ]; . 57 ,
' w e-yw 7
action to verify the acceptability of all ini;;ection performed by the unqualifiec inspector. i l
,/ h f' .
D I 1 1 l i l
\
/
v
"' *
- ww= * - - .- 4 . . ,. .. . ..-.., .,.. ,_, _,. ..
w
.~ yy, nb %.h%#'
an ,, .* \
- x. p . n 1 dklg' 32 f.
i', c, ,? - 13 - pr
'birY . sW '5 Y 'k'l~ f , h f,%Nf%f&
f, . .iy'k h ;'&? SEf
$,k..' f l?df.5.ilF*;'pl?:[gy.N'.;? 'Y
&v f %~: ?. _W .f'.
y ,__, f. .'..;.'".
& ..;3, A.q:;9'.-)+:~. -
,.%. g< . . ,3 .
-3. ,7 ;; .<
. . .y .paty. Q..._ ' , f p..'.;,;c.y. _
.. y.g . +. Q.,
.,,c,f. g
,(
w y ,..,. . . , - .,,. . 3 4
- *. 3 ,.$ .i.. ,.
...-. y e =
.S:,~;>4 i .. W Q g. . T , ., ;,
q.,.
.gf. ]. y ^ ~9
~
^
p
.ym - .
. :f. ..,Q. . x. , : .a i
. . .} ; < .h * ;' .. .:. .: '. . ' , y- .. .y
.. n r. g. .
; . ,,. ...+.,4 s.. ..u... . . ': ~ %,m k;,l,e . , . .- ..
q..... ? y r : s.
> . . . ve t
e; . .J
. u ,;. , u . ? . . , a. v;g-@4, qlif.gk ._ ' " ; . . . ;;- ! ^.
.<.t -
. ~ v. g +( ,w - .~ .
q s. , *- V :.y ,
. s t d '. y, ,
opp 7 - a
..c. . . . ,. .
;,f. T .7,
.f.
.. %v y g ;. h #.. Q. ,:/ . d. .. ,
, , . . y;, ; r- 4 .
.'%L y y . .
J :'w' .. g._b l .Q r%j:,1G . l l ' ' q i'.J r& ). ,( t
; .,/-
- q. -
s . .
- r. .p ...,,...,,e , ,- . .. _ .
* . ~ ., ; . y7;
- . . 9
.. .,g yV .
,...y
. ... . .. g. .
+ y,o
.Q~- ,
- ~ *
.&. 3.;p
\ lm g
- y. ' %.q . .. ' : . .
F.v . r;. w g-l r *. ; *% - .. . * ' ... .
,,j.,. . f,
& , ; .y.'
.e .
... _.. 3 . , ,
y- i
., v .
L
.. r . , '. n . : '. . .
, ~e, i
-r
. ~ ,;4 w ., <
- ~. .4 .
.. , : ~. ,;' . 7 l
} -[ .:- .y :.f;;.f_
. ;, +
[ ..c _
. ,9 _ : ^..
7 . ..
\. . ., 1 p ]
. f .
~
4 ~ i ,.: 3 _. l s,' st :. .. * .. ' :x
< g. :.
. . n.y .:; p .
c I'. : O.. .O. . I <'a . 7 -L.'
- my..L.y.
^
.7. ; . ..
1 's m . .. .. s ,. 2 8. Attachments: Noisc .
- 9. Reference Documen is: -
t
- 1. B&R proceduW.s: CP-QAP-2.1, CP-QAP-2.3, QI-QAP-2.1-1, QI-QAP-2.1-5
- 2. TUGC0 proceW.res: CP-QP-2.1, CP-QP-2.3, QI-QP-2.1-1 through 1.
; QI-QP-2.1-1.4 l
- 3. ANSI Na5.2..w , 978.
',/
l l l l.. . - . . _ . - - - . - - ~ ~~ ~ ' " ' ~ ~ ' * ' '
= "---- - -
l, . a
. - 14 .
4 Regulatory Guide 1.58, RevisionI 1. l S. Recommended practice SNT-TC-1A, " Personnel Qualification and Certification in Nondestructive Testing," dated 1980. I l 6. QA Personnel Certification and Training Files. 1
- 7. CPSES FSAR 17.1.2.
i I
; 8. Inspection Reports 82-11 and 80-15. ; 10. This statement prepared by: , V. Watson, TRT Date Technical Reviewer 1 )-
Reviewed by: H. Livermore Date I, Group Leader i b Approved by: V. Noonan Date { Project Director i : Ii !I 1 e\
\
\
1
\
\
t,) {.- 1
\
t
\ _._ -.- .- - . . . - . - . .-.- . . - -
--[ *tm *iI[ ' A__ e r . ---4
,f .... . ... 1 ..,
s .
- /
, ~
su d?k QC f 4' ' S S z g_ , i SSER AQW-5 CP3 9 [b2 % - L vM
~ As im M n <c~jLfr sr -O g e< Le w /c ,
- 1. Allecation Group:
Mechanical and Piping Category 27, p y W "' n&ww s c=
= : :- -
- 2. _A11ecation Number: .
AQW-5, AQW-11 AQW-16, AQW-17, AQW18, yAQW-19, and AQW-69.
\
- 3. C p
Characterization: It is alleged that the project visual h
-pere. inadecuately trained and improperly certified to perform the work required of them.
,/
~
4. _ Assessment of Safety Sionificance: . The allegations are of a very general nature and, except for two cases, did not specifically 5 identify the weld location, time, or welder's number. > The NRC - Technical Review Team (TRT), therefore, reviewed the Brown & Roo (B&R) and Texas Utilities Electric Ccmpany (TUEC) visual weld
}{'~'- gyining and certification program to determine if general conditions existed which could have led to the allegations.
Tne TRT found that both B&R and TUEC used basically pproach the same a in meeting their certification ccmmitments. ANSI N45.2.5-1978 (Qualification of Inspection, Examination and Testing or Personnel f Nuclear Pcwer Plants) as supplemented by NUREG .. e 12 the 6 provid d ' basis for estaolishing a unifcrm certification pregram . These standards established the minimum education and experience 1 FO!A-85-59 M-
. . . , m, ,
- - - = . . , . - . . . . . . - . . . . - - . - -
1 a recommendations for various levels of qualification, as well as the recommpdedtrainingrequirements. 5 e he TRT learned that visual weld inspectors must successfully complete yo t three parts of the program: a fomal classroom program, recommended reading, and a period of on-the-job training (0JT). The TRT found I that the time spent in the classroom and on 0JT during the program was documented. The TRT also learned that during the OJT period, each individual was l closely supervised at all times by a Level II inspector. The trainee 1 was not permitted to proceed toward certification until he had shown - 1 acceptable proficiency and knowledge of his work. An examination was d given upon completion of training. Failure to pass the examination h/ prohibited the individual from being certified to perform work at a g higher level. h ,i The TRT determined that both the B&R and TUEC training programs were l i covered by a number of procedures. B&R procedures CP-QAP-2.1, i i j QA-QAP-2.1-5, and TLP-1 covered the specifics of the training and f qualification and the delegation of the responsibilities involved in i ll the welder's inspection program. TUEC has similar procedures. These l' !' procedures effectively cover all of the Final Safety Analysis Report i
- m. (FSAR), ASME Code, and industry standard requirements.
V l
~
! -i
.si a_, A _,
e 'q+
-**WWPg**
'**PM* *8
*"*"-'-+4 "* T**
z_ __. .
~
2 .l l,. .. - .. -.. - - - .. -
/ -
j .
}
l i k The TRT reviewed the training and certification procedures in effect 4 during the period the allegations were to have occurred. In addition,
't i
the3fMDL _ T:- -Wane %@untinmar weld.Jnsectatesma_t_randon g , The TRT found that, in all cases, the education and
< experience levels appeared to be adequate to meet ANSI and procedural requirements.
, The TRT found that the amount of experience a potential inspector had u
.j in performing similar work for previous employers was a major factor i
~j in his advancement. The weight given to the amount and value of this i
j which was later confirmed by j an experienced inspector observing an individual's performance during j M the OJT training period. l i i In discussions with a B&R visual weld inspection supervisor, the TRT confirmed the centrol exercised over new inspectors. The supervisor g indicated that inspectors were given only tasks which they were capable of performing based on their experience and training. As a 1 l new inspector became more proficient, the scope of wodk was expanded. I l One alleger claimed that poor welding was being done on several 1 l systems. The TRT reviewed six pipe welds, chosen at randem, in the
! containment spray system. A TRT welding engineer visually inspected l
these welds. In addition, the TRT reviewed the weld data card (WDC) l 3 and associated documentation for two of the welds in detali. ihis
- review showed that the welds had been completed satisfactorily and had
( l received the necessary weld inspection. lI < t
. . - . - - - - - - - - - . - - - - - _ -- ' ~ ~ ' " *-
/
no
-4.
)
/
NRC Region IV.(RIV) investigated a series of allegations related to the training and qualification of nondestructive examination (NDE) inspectors and reported their findings in IR 82-10 and IR 82-11. f Although many of the items investigated by RIV related to NDE rather f than visual weld inspection, a number of the allegations were in areas i j similar to those being reviewed by the TRT. The TRT concurred with the RIV findings related to their review. i i 1 . 8 In 1982, an alleger was told to inspect certain vendor weTds on a l' diesel generator skid. The alleger did not " feel comfortable or i qualified" to do the inspectinn and expressed this opinion t Mo j s.upervisor.~gstated thatgwas told to do the work or "go home."
\ -
The TRT learned that at the-time of the inspection, the alleger was {; qualified only to review non-ASME pipe support welds. In addition, the alleger stated that g was not able to understand the vendor's shop fabrication drawing sufficiently to make a judgement on the welds involved. g ti - b
! m W gom me +o msg me A>A ""I '
It is possible that the alleger was not cualified to perform
~ %
an acceptable weld review because of M lack of expertise in understanding unfamiliar shcp drawings and becauseMwas asked to review what may have been unfamiliar welds. The TRT was unable to determine if threats were made to terminate the alleger if the
.-' inspection was not performed.
.% ,e-c+ . w w. ,
..% ..,em. ._. ._, ,- -..,e.. .y- eww__,w , . . . -w - , -- --
- 7 . . . . .
- O -
~
?*,%&ffD ~ T
- 5. Conclusion and Staff Positions: Since most of the allegations were insufficiently specific to allow detailed study, the allegations cannot be confirmed or denied. However, the system in place to control visual weld inspection is in accordance with all requirements and provides the degree of inspection required.
The TRT has concluded that the vendor welds the alleger was to inspect would not normally have been included in a B&R weld inspection \ g program. _ In addition, being asked to interpret unusual drawings would l also have made the alleger hesitant to prec this case th M i
/
inspector training program did not fail since the welds the allecer t was being asked to review were not those nomally encountered. ,
/
l The TRT concludes that B&R and TUEC visual weld inspector training and , certification programs produce visual weld inspectors who are / adequately trained and certified. Accordingly, these allegations have
/
neither safety significance nor generic implications. j
/
- 6. Actions Recuired: None. - - ,
I ms o m . f
- 8. Attachments: None. k
_-a VW _/ A &/- w r Af . Tlw C, f w/4 nd Am/ n 9 -r lm fAs
~
c~ 7 Og #
%put .
. . _ _ A 44 fQ ..d;.w. . .
. \
l f
/
/
/ 9. Reference Documents:
i l
- 1. ANSI N45.2.6-1978.
- 2. TUGC0 Procedure QI-QP-11.21-1.
f f 1
- 3. NUREG 1. 2.6.
- 4. TUGC0 Procedure CP-QP-11.21.
a
- 5. B&R Procedure TCP-1.
- 6. TUGC0 Procedure QI-QP-2.1-19.
- 7. B&R Procedure QI-QAP-2.1-5.
- 8. TUGC0 Procedure CP-QP2.1.
i
,9. B&R Procedure CP-QAP-2.1.
- 10. BhR ISO BRP-CT-1-SB-019, Rev. 6.
- 11. NRC IR 79-15.
- 12. NRC IR-82-10 and IR-82-11.
- 10. This statement prepared by:
R. Hubbard, Date i TRT Technical Reviewer I Reviewed by:
-, L. Snao, Da~2 Group Leader Acproved by:
V. Noonan, Da a Project Director I
- - - - - _ _ _ - - ~ ~ - -________-__1
. --.. -. _ . . ... m . y p 3. . % . . . .f-,.. .. . j j, .s s -/ .e*( I g 1C 0\ ] DCP3 - SSER AQW.5 O oreft 7 1/8/85 SSER 8G -T 0 9 na -. rwM
; . m su
- 1. Allegation Group,: Mechanical and Piping Category 27, , ,9 , ,, w J
, Unqualified Weld Inspector c, q 4hJm i
- 2. Allegation Number: AQW-5,JQW-11,AQW-16,AQW-17,AQW18,AQW-19, and AQW-69.
- 3. Characterization: It is alleged that:
(a) Weld inspectors were not qualified (AQW-5). (b) Vendor welds on diesel generator inspected by an unqualified individual (AQW 11 and AQW-16). O (c) QC inspections were inadequate (AQW-17). (d) EBASCO inspectors did not properly inspect welds (AQW-18). (e) Backfit inspection program was not completely implemented (AQW-19). (f) There was widespread use of lesser qualified mechanical / welding inspectors (AQW-69).
- 4. Assessment of Safety Significance: The allegations are of a very general nature and, except for two cases, did not specifically identify the weld location, time, or welder's number. The inspectors were apparently working on areas where non-ASME welding was occurring.
The Technical Review Team (TRT), therefore, reviewed the non-ASME' Brown & Root (B&R) visual weld inspector training and certification b program to determine if general conditions existed which could have led to the allegations. F01A-8sras g-7
. _ . . . . . . .. . .. . . . . . . .w ANSI N45.2.6-1978 (Qualification of Inspection, Examination and Testing Personnel for Nuclear Power Plants) and Regulatory Guide 1.58, Rev.1 provided the basis for establishing a uniform certification program. These' standards established the minimum education and experience recommendations for various levels of qualification, as well as the recomended training requirements.
The TRT learned that visual weld inspectors must successfully complete three parts of the program: a formal classroom program, recommended reading, and a period of on-the-job training (0JT). The TRT found that the time spent in the classroom and on OJT during the program was Q documented. The TRT also learned that during the OJT period, each individual was closely supervised at all times by a Level II inspector. The trainee was not permitted to proceed toward certification until he had shown acceptable proficiency and knowledge of his work. An examination was given upon completion of training. Failure to pass the examination - prohibited the individual from being certified to perform work at a higher level.
,~.
U .
. * * .' # ), $g,.%* * "' I g ,a% $/ -
m ~, _- _ _ . . _ _ . -_..._.......m I -
- I
)
i
; The TRT determined that the B&R training program was covered by a
. number of precedures. B&R procedureX CP-QAP-2.1M covered i the specifics of the training and qualification and the delegation of i i i the responsibilities involved in the welder's inspection program.
I td-#L6cT i These procedures effectively w .m. u.. J the Final Safety Analysis I r Report (FSAR) M and industry standard requirements. The TRT reviewed the training and certification procedures in effect l during the period the allegations were to have occurred. In addition, j the TRT chose 14 personnel files of -former weld inspectors at random to review. The TRT found that, in all cases, the education and experience levels appeared to be adequate to meet ANSI and procedural l I Q i requirements. The TRT found that the amount of experience a potential inspector had in performing similar work for previous employers was a major factor l i in his advancement. The weight given to the amount and value of this l experience was often a judgement decision which was later confirmed by j an experienced inspector observing an individual's performance during the 0JT training period. In discussions with a B&R visual weld inspection supervisor, the TRT confirmed the control exercised over new inspectors. The supervisor indicated that inspectors were given only tasks whi.ch they were O . __ _-..~'
**~'
_ __ - . . .T* .,-. .n> '
- l. ..
I i
- ! 'I~;
l capable of performing based on their experience and training. As a ^l
- hew inspector became more proficient, the scope of work was expanded.
1 t One alleger claimed that poor welding was being done on several systems. The TRT reviewed six pipe welds, chosen at random, in the containment spray system. A TRT welding engineer visually inspected these welds. In addition, the TRT reviewed the weld data card (WDC) and associated documentation for two of the welds in detail. This review showed that the welds had been completed satisfactorily and had 4 received the necessary weld inspection. .I NRC Region IV (RIV) investigated a series of allegations related to the training and qualification of nondestructive examination (NDE) e
! inspectors and reported their findings in IR 82-10 and IR 82-11.
Although many of the items investigated by RIV related to NDE rather than visual weld inspection, a number of the allegations were in areas l similar to those being reviewed by the TRT. The TRT concurred with i i the RIV findings related to their review. er was told to ins
.! In 1982, an alleg/4GW-il,40cu-4)
( pect certain vendor welds on a j diesel generator skid.n The alleger did not " feel comfortable or qualified" to do the inspection and expressed this opinion to N supervisor. M stated thatNas told to do the work or "go home." O .
, :.e , .
I 1 . S The TRT learned that the inspection was part of a program to evaluate
,the welding on a vendor furnished diesel generators skid. . NCR-M-80-0009 had been prepared on July 17, 1980 to cover the apparent
[ failure of the vendor to fabricate the skids to the ASME NF
, requirements. The disposition of the NCR stated in part "The fabrication records have been examined and there is insufficient documentation to claim NF equivalency. A program has been developed, however, to qualify the support and skid fabrication to AWS Dl.1-1975 l and the AISC Manual of Steel Construction, Seventh Edition." TUSI Procedure CP-QPil.ll was prepared to provide guidance during the reinspection.
O The alleger has indicated that M was given a copy of the procedure r Tue which would indicate that .erformed hM inspection work to the AWS Dl .1 requirements. The alleger was qualified to perform AWS visual weld inspections and did perform the inspection work and preparation l of as-built information for a period of a month.
- -r NTM It is possible that the alleger was not qualified to perform j an acceptable weld review because ofhlack of expertise in ww W ! # W ret 3 unfamiliar shop drawings,2-1 Mer:::[ ',,;; _;.. to
! rev d ~ '" t a :.;,; i;;r ; " 4 - ~ ' h. There is no indication that $ had not been properly trained to perform the work. The TRT I was unable to determine if threats were made to terminate the alleger
,3 Q if the inspection was not performed.
1 l . s - F l i -...... . . .... .- .. . -
+ , .,
- - : . . . _ . . . . ,- < < eu mu . - - . - -4 I
l QA/94 M 4% l 4 -z.3, n -z Y m ap-ze J 49-ioa. &,4c-es Ae=7, es A c
)J csvw n u=y ydlw&$mp .sia p k+a e y. .. n W
6fs nswa a*y"u+1'n". juo p ain w A A A & e /Sc nty, h ! v / > A w J. u S -ws 6&
~L sa sA:.~ds s P A p, nur 3 a M e) N Y *)s[a2/ A %t' m.>sd sa 3 mgo Ly yssda s ympw &p >a s s , u ad .
m s . i, 1 WTIll0Y WN O r $ P.. .be . 6 - e - . ,,,, ..,e _
i j . .- , I i h n TV CN Y W-S 40s so, net M ocr 29,igey do
$f a dg . & 4 h 46p6 hub. '
g E n% A s nudf
/ Art, f eug sco-/z a u.9v (1 asswam
_, & ~ 9 x,ner makaA w Tea 4 m & ~~e day" n Aa'y 30,/98/ w d eivyuds ,i d W' was Lild cu d ido Y g w now-H J acw-M n !l a). M M,,uc y
& W- 4 +gu-d2d ma U&~
~
M L unAn k '
- p ws sa A mhm. A rar u' d 4 a d >>y r @ p a k y s wasf s i!
i i I - I i l .. .
e,_~-_.-
-w - _ . _
.- %_;. _ _ _2 _. _ _ _.
5-
- 5. Conclusion and Staff Positions: Since most of the allegations were insufficiently specific to allow detailed study, the allegations cannot be ! confirmed or denied. However, the system in place to control visual weld inspection is in accordance with all requirements and provides the degree of inspection required.
The TRT has concluded that the alleger had been certified to perform visual AWS inspections. The reinspection of the skid was made to the same requirements and, therefore, should have been within the capabilities of the alleger. O The TRT concludes that B&R and TUEC visual weld inspector training and certification programs produce visual weld inspectors who are adequately trained and certified. Accordingly, these allegations have l neither safety significance nor generic implications.
- 6. Actions Reouired: None.
P
- 8. Attachments: None.
O .
I
-7'
- 9. Reference Documents:
i
- 1. ANSI N45.2.6-1978.
l 2. TUGC0 Procedure QI-QP-11.21-1. I 3. NUREG 1.2.6.
- 4. TUGC0 Procedure CP-QP-11.21.
- 5. B&R Procedure TCP-1.
- 6. TUGC0 Procedure QI-QP-2.1-19.
- 7. B&R Procedure QI-QAP-2.1-5.
- 8. TUGC0 Procedure CP-QP2.1.
- 9. B&R Procedure CP-QAP-2.1.
1 jQ
- 10. B&R ISO BRP-CT-1-SB-019, Rev. 6.
! 11. NRC IR 79-15.
l 12. NRC IR-82-10 and IR-82-11. I 13. Deposition of efore the ASLB, September 13, 1982, pp. 4131-4140
- 14. Deposition of before the ASLB, September 15, 1982,
, pp. 4845-4848.
- 10. This statement prepared by:
1 R. HuoDard Date j TRT Technical Reviewer i Reviewed by: L. Shao Da te Group Leader {: h Approved by: V. Noonan Date Project Director
.. . . ~ . . _ . . _ . _ . . . . . . . . _ . . . . . . . . _ _ . . . _ _ _ _ _ _ . . . _ . . _ . _ . . . _ . . . . . . ._
w,' - a .- _ 9a.____ ma x
s a yx .wa.reswc.rsm.;mwrsaiuur;a. ira .srum a.=.nc, m mm rs. .; :======== ,==r =-==7
.? Tl9 'r-3 ' WL* G -
- % Y V ~~ '? .
n
.. r' n
\ =
. Interview DCP11 - 1/25/85
, CONFIDENTIAL
.)
r v*-
'2 INTERVIEW WITH ON WEDNESDAY, JANUARY 9, 1985, ,j 4:00 P.M. T0 12:30 A.M., HOLIDAY INN, NORTH OF D/FW AIRPORT c
E v
-Y: -1 $ PRESENT AT INTERVIEW:
i x T k John Zudans b s Robert Masterson p Juanita Ellis Ernest Thompson d 3 Mr. Ellis Joseph Tapia w - N ^ h 5 CONCERNS DISCUSSED (PARTIAL LIST)-
~
1 fy AH-4.- This concern addressed a welder who was instructed to weld a leg on a i hanger which was not authorized by the hanger drawing. G (1) The TRT stated that an earlier phone conversation with
.v provided no further information to specifically locate x
y this hanger. The TRT reported that it researched the s
'y appropriate TUEC & B&R procedures and found that during @p..
fabrication of parts of an assembly the drawing and hanger
;&. package was not required at the hanger location. Also, a CMC l 4 was an authorized document to make a change to a hanger drawing Z
r . in the field. i ._. FO A-85-59..
. _4
mv =m~:::- l y . 1 l (2) said that was not really what meant. said M told to use a piece of scrap steel to increase the h length of the Q-material that was cut too short by the fab shop. h haidgpicked a piece off the floor without a heat number and against procedures transferrer' the heat number of the short j
*g A'
piece of material to this piece of scrap steel. sketched a D view of what this hanger looked like, but could not identify any
- 1 3 hanger number or location. This is what was commonly called a "counterfit anager." This hanger was discussed in the h AH This concerns a piece of scrap I-beam that was used in the s
*$ fabrication of a hanger.
(1) The TRT stated that during an earlier phone conversation, indicated that this hanger was in the south (a p yeard tunnel at elevation 820', but could not identify the J - 3c exact hanger. 1so said that according to a Region IV
@ inspector this hanger had been scrapped.
d . The TRT stated that it visited the south yard tunnel and found 9
$ hundreds of pipe hangers. The TRT also talked to the RIV 3
!6 'x inspector who remembered the incident, but could not state [ confidently without reviewing his notes whether the hanger had
- e. been removed. He did not have immediate access to his notes.
O P
?.*.
1 g ID 4 ' 3-The TRT reported that it reviewed the B&R and TUEC procedures _ . concerning use of non-Q material and found that if properly . -; signed off by QE a procedure existed to upgrade non-Q material
+
R to Q-material. The TRT also randomly checked a number of pipe supports and confirmed that the heat number on the piece of 4 y material matched the paperwork in the hanger package. a - 3 (2) said that what really happened was that he was told {& to find a piece of material that would fit a hanger because the ,). original piece was cut too short. He then transferred the heat s e number of the Q-material (short piece) to the non-Q piece of II scrap I-beam and welded it to the hanger. He called this a E.I g "counterfit hanger." He said he would be able to take the TRT to the hanger during the plant visit on Thursday, January 10, E ti 1985. He also said that Case Exhibit 666C contained a copy of ( . h the RIV inspectors notes on this hanger. (R. Masterson)
~~: .5 1
y AQH This concerns a QC inspector who was instructed to buy 5 @ off on a hanger or be fired, refused and thought the hanger was lit accepted by another inspector. _t! i?j a; (1) The TRT identified the hanger as TWX-039-714-A35R from the 9 y transcripts of hearing testimony. The TRT found a hanger inspection report signed off by about the time period whenMsaid this incident occurred. The TRT also found a notation is logbookthatMhadlistedthis ih hanger as being acceptable and satisfactory. The TRT also 6+* F _
== -
~-
ym. tere ,m.mm---w . 2 -
-:s: .y, ,
r /
'A C vy .
y , l
;jl s'earched the NCR log and found no NCR issued by for j this hanger, y .
n f (2) saidthat$recalledglogbookindicatedand y.c unsatisfactory inspection for this hanger and that the TRT
..a should rechack our copy of log book. h also said the h hanger inspection report referen ed by the TRT was the same one showedtohattheASLBhearings. _
contends that it is a h fraud and that it should be checked by handwriting experts. %_ M@ alsosaidthatg,;couldshowthehangertotheTRTduringthe m S' plant visit on January 10, 1985. (D. Hansen/R. Masterson)
?n
. 2., AQW-il, s i AQW This concerns vendor welds on the diesel generator skid supports inspected by an unqualified individual. j (1) The TRT reviewed NCR M-80-00009 concerning the vendor welds. It 4
.g was dispositioned that the welds should be expected to perform a . r-duties.
M N
, (2) %said that the drawings were very complicated to read and thatNwasn't familiar with many of the welding symbols. h w
$T.: complained to foreman that because ofMrouble reading the drawings, many mistakes might be made. His response was "do { the best you can." hsaid was on the job for about a
,7 month and feels the welds should be checked further. M h
y identified the diesel generator as MEDGEE-02. (R. Hubbard) Q,. W ku __ _ _
r,- ~~ . m. :, , , ., ., . :., e -w e- ~_ . :~ - _~~ . = :a w-m:1=gm
.~r c~7.c-~~m pn..
'I
-i
; . k.
~[ AW ~This concerns a QC trainee who improperly used liquid penetrant.g
. .6 (1) The TRT talked to the alleger in August 1984 and identified fI the QC trainee. The TRT reviewed QA Procedure CP-QP-2.4 which is 4 stated, "A trainee works along with a certified individual and G 11 9 does not independently conduct or interpret test results. Based f
-n
.h upon the description in the allegation, one would expect a
, ..y; j trainee to improperly use LP during the training period. The
.0 $ TRT concluded this was a normal part of training. $1 W
f (2) said the individual was not even a QC trainee but a
. .e
,k
, s boiler maker who was living with the Level II inspecting Fuel
. Pool Liner . Welds. According to 3theLevelIIlet Mapply the LP while he went somewhere else.hconducted an
' di (s erroneous test on may welds that were completely out of I l); procedures. When the Level II returned, he signed off the LP q h inspection report without reviewing any work or the results. y g saidMcould point out the welds during the plant visit. , ,fl (V. Ferrarini)
=
i a i
-1."5 @1 y AB This concerns a QC inspector who was improperly instructed to sign off on torquing of hilti bolts without authorization.
't '6 - (1) TheTRTtalkedtotheallegerinAugust1984andg, identified
',- the document that was signed off was the WFML. The TRT reviewed
- y. . . the applicable procedures and determined that the baseplate and
; hilti bolts usually are installed earlier than the actual pipe d-k -,.,,,,., ,,%. 7. < e . - , _ , . . ..y .%-..- -7, ,%_. _ . . . . _ - _ _ _
+ :vm""m ~~ x-
_[ ~ * : --- - ,.,
--,n .-n, .,
-=
p, C s support attaching to it. In this case, a hilti bolt inspection l a report is completed. When the hanger is eventually inst'lled this IR verifiying bolt spacing and torque seal application is used to sign off the hanger inspection report. (2) said that the hilti bolt inspection reports are not filed with the hanger package in the vault, but rather , separately. Mcontends that in order to save time and not j have to go to the vault for each hanger to verify ~ the hilti IR, H A
$ M)as told to assume the hilti IR was in the vault and to k, initial and date the WFML thatNreviewed it. This would then 1
allow the QC inspector performing the final hanger inspection, )e to check the WFML for verification of previous hilti bolt [ said more needed to be done by the NRC. (V. f inspections. k Ferrarini) h 4 Y R. Masterson g
,W E
TRT Member 12 ' Y D 9
$M
'Y G
E a
.j
*a,
*L 4
+
~
._____.__.___._...._m__,
s' g ' 10 i E DCP3 - SSER AQW-5 Draft 8 - 1/31/85 SSER
- 1. Allegation Group: Mechanical and Piping Category 27, Unqualified Weld Inspector
- 2. Allegation Number: AQW-5, AQW-11 AQW-16, AQW-17, AQW18, AQW-
\
q and AQW-69. i
- 3. Characterization: It is alleged that:
d I d f (a) Weld inspectors were not qualified (AQW-5). k u. W $5
/
Vendor welds on, diesel generatoQnspected by n unqualified v-individual (AQW 11 and AQW-16). h ' g (c) he < +$1 I QC inspections ^ were iriaifequate (AQW-17).k i (d)'*EBAS spectors did not properly inspe:t welds (AQW-18).
} .
(e) Backfit inspection program was not completely implemented
, (AQW-19).
& (f) There was widespread use of lesser quali fied mechanical / welding
-G l inspectors (AQW-69).
\ j j $ 4. Assessment of Safety significance: The allegations are of a very i
general nature and, except for two cases, did not specifically identify the weld location, time, or welder's number. nspecto h _j g de h apparently working on areas whern non-ASME welding was occurring N# ' he Technical Review Team (TRT), therefore, reviewed the non-ASME NS t Brown & Root (B&R) visual weld inspector training and certification
.! g program to determine if general conditions existed which could have I
j b led to the allegations. P31A%69 K-gs
*t- / + J
- 2 4* *
- b, I
l i : t - (ANSI N45.2.6-1978 (Qualification of Inspection, Examination and i I
. L ha
- g Testing Personnel for Nuclear Power Plants) and Regulatory Guide 1.58, j
i "W"he 40w
'Rev.1providedthe[asisforestablishingauniformcertification
{a c M-program. These standards established the minimum. education and experience recomendations for various levels of qualification, as
,' well as the recomended ining requirements .
/
c) j HoA 1 - The TR at visual weld inspectors must successfully complete three parts of the program: a fonnal classroom program, recomended i hc
] f g reading, and a period of on-the-job training (0JT). The TRT found hat the time spent the6)essroomandonOJTdurin the program was Yh ocumentf
, %A hhe TRT@o learned)that during the OJT period, each individt,al was
%h so% b<- LetR T closely supervised at all times by a Level II inspector. The trainee 6A% k'
/was not permitted to proc'eed toward certification until he had shown i
Nu W acceptable proficiency and knowledge of his work. An examination was 4dT given upon completion of training. Failure to pass the examination I j prohibited the individual from being certified to perform work at a i igher level. ALO . k dbaE he TRT determined th t the B&R training program was covered by a i l At4WAb W number of procedures. B&R procedure CP-QAP-2.1 covered the specifics p i of the training and qualification and the delegation of the responsi-bilities involved in the welder's insoection crocram. Mse roceduras i . sq uAe A% effectively flec the Fina afety alysi rt (F <.4 ~82
,and
[ .. N I ustry an r raq'Iaamnts. 4.s? - _. - - y ..g a
._m,., p, . . _ ,
g p3 *S Jr& l j 7 ' l ,.h N
- The TRT r iewed the (trainino and cer ficationo~rocedures)ineffect hringthe eriod the la11egations were to have occurre In addition, vb
( .the TRT chose [N) personnel fiTD of former weld inspectors at random www ma M v M $4 e.1? dr to review. The TRT found that, in all cases, theleducatiof( and hp l r1ence levelslopeared to be adeouate NS o; [ gJd?. requirements. L. 6 SA eMd by 3kR/TRT ?. rW- . - [ [_ @ hhat t e hmoun of experience a potential inspector
%L s b in performing similar forpreviousemployerswas[majorfactor d *- in his advancement, The weight given to the amount and value of this experience was often a judgement decision which was later confirmed by '
hiD an experienced inspector observing an individual's performance dur g th , raining perind UAMA
~
In discussions with kB&R visual weld inspection supervisorl the TRT P
@d A confinned the control exe'rcised over new inspectors. The supervisor c
i 6 ?3,,,-
$g, indicated that inspectors were given only tasks which they were ;c capable of performing based on their experience and training. As a wOd # ',2 .
Jg new inspector became more proficient, the scope of work was expanded. t
@0 Vj/S b l # #9 One alleger claimed that p or welding was being done on several systems. The TRT reviewed six pipe welds, chosen at random, in the l
f[ ntbmentspray . A TRT welding engineer visually inspected p s ? these welds. In addition, the TRT reviewed the weld data card (WDC) and associated documentation for two of the welds in detail. This .i review showed that the welds had been completed satisfactorily and had
.' g-received the necessary weld inspection.
V U
.,..-,._p. g _ . _ , ,* ,. ... . %%,, _. -
o_. . . , , , -
.awa w ~ + -
.a a_ .. ._2.. . . _
9 )I, ! J. .
;; NRC Region IV (RIV) investigated a series of allegations related to 1
the training and qualification of nondestructive examination (NDE) inspectors and reported their findings in IR 82-10 and IR 82-11. Mo 88 d'm ~ F * .l
- ke, m
~
than- u 1, eld knumber of the allegations were in u en
,- e o ,_sdedh r-to-those_be ba "viewbbythaT concurred w
$ dings related to their' review.
5g 8I , L. S A 5:ES N In 1982, an alleger was told to inspect certain vendor welds on a s diesel generator skid (AQW-11, AQW-16). n a .eVW;er did not " feel comfortable or qualified" to do the inspection
- i; opinion to supervisor.
6 $y' I The TRT learned that the inspection was part of a program to evaluate the welding on a vendor f'urnished diesel generators skid. NCR-M-80-0009 had been prepared on July 17, 1980 to cover the apparent failure of li - the vendor to fabricate the skids to the ASME NF requirements. The i disposition of the NCR stated in part "The fabrication records have c :i been examined and there is insufficient documentation to claim NF i equivalency. A program has been developed, however, to qualify the if support and skid fabrication to AWS D1.1-1975 and the AISC Manual of l Steel Construction, Seventh Edition." TUSI Procedure CP-QPil.ll was 1 prepared to provide guidance during the reinspection. l - o i i -- < ~
- , - , - . ~ , . ..
_4 . _.. .
C 5-The alleger has indicated that Mwas given a copy of the procedure which would indicate that@perfomed the inspection work to the AWS Dl.1 requirements. The alleger was qualified to perform AWS visual weld inspections and did perfom the inspection work and preparation of as-built information for a period of a month. N ssible that he alleger feltgwas not qualified to perform u)d\ \ g D w " % f acceptable weld review ck of experti
}
t% g E appeared to be unfamiliar shop drawings. There is no indicati mb, M h
'~
i had not booninrocerly trained to perfom the w e TRT t tu (c? - A _ b g 7, __ w as unable to detennine if threats were made to teminate the alleger } Lif the %paction was not oerfomed. ( " y% %. Y $ AQ/QC Category 4 w\-Q&@d corporate 7-allegations ,AQ-24,AQ-26,AQ-27, AQ-23 AQ-28 and AQ-108. The category covers a range of allegations claiming that QC inspector were not qualified due to inadequate training. A pr raninatic iew of ASME and non-ASME inspection training programs was conducted by the QA/QC TRT. Included were SNT-NDE inspectors as well as visual weld inspections. I ?. yhb 5A w p, Q [dingtothespecificallegationsrelatedtotheh. q .4 In re ield, d t
~
rev iewed a very narrow range of the site inspection l e f ht training program. The SSER conclusions reached should be reviewed accordingly.
. - . . . . , ... . - . . . . - . . - . . . - - . . . . . . . - . . . . . - . . . . ..-i L ,
= i P e TRT called the AQW-5 alleger on August 30, 1984 and October 29, 1984 to arrange for a meeting. The alleger declined to havi further discussions. Efforts are being made for a meeting with originator of ,
allegation AQW-17. A : letter sent to the AQW-18 and AQW-19 alleger on August 30, 1984 received no response. pw W e
,W kk A letter was also sent to the AQW 69 alleger on August 30, 1984 with
@V no response. A meeting was held with the originator of allegations ehpa
- d* AQW-11 and AQW-16 on January 9, 1985. The alleger continues to fc 'f[, maintain that because % ould not understand the vendor drawings E approved D/G skid welds that were unacceptable. fh'e { 44 a c W.
~' TAT do?
- 5. Conclusion and Staff Positions: Since most of the allegations were insufficiently specific to allow detailed study, the allegations cannot be confimed or denied. However, the system in place to control visual weld inspection is in accordance with all requirements and provides the degree of inspection required, s
f .
~
The TRT has concluded tha e alleger had been certified to perfom visual AWS inspe he reinspection of the skid was made to h e i me requirements and, therefore, should have been within the capabilities of the alleger. Q )
/
Vf < ty \ i
' ~
_ _ - _ 3
I i
- l
- 7-l The TRT concludes that B&R and TUEC visual weld inspector training and certification programs produce visual weld inspectors who are
' adequately trained and certified. Accordingly, these allegations have i neither safety significance nor generic implications. /
- 6. Actions Recuired: None.
-1 '
- 8. Attachments: None.
- 9. Reference Documents:
- 1. ANSI N45.2.6-1978.
- 2. TUGC0 Procedure QI-QP-11.21-1.
- 3. NUREG 1.2.6.
- 4. TUGC0 Procedure CP-QP-11.21.
- 5. B&R Procedure TCP-1.
- 6. TUGC0 Procedure QI-QP-2.1-19. .
- 7. B&R Procedure QI-QAP-2.1-5.
- 8. TUGC0 Procedure CP-QP2.1.
1
- 9. B&R Procedure CP-QAP-2.1.
- 10. B&R ISO BRP-CT-1-SB-019, Rev. 6.
- 11. NRC IR 79-15.
- 12. NRC IR-82-10 and IR-82-11.
4 4 I
, , . , - - , -----7,w,,---- , . -- - - - - -, , , , - , , - - - - -
~
N C- ! 13. Deposition of before the ASLB, September 13, 1982, l l I r pp. 4131-4140 t i4. Deposition of before the ASLB, September 15, 1982, I l o pp. 4845-4848. ; i i- 10. This statement prepared by: ' R. Hubbard Date TRT Technical' Reviewer Reviewed by: L. Shao Date Group Leader t
! Approved by:
i- V. Noonan Date l Project Director i i. i I [ h I i i I e-
. - =- . . . - . - -
. .. . . . . . - - . . . . . . . - . . . . . . . ~ - . - - . - . . .
t >
%hw*
OCP12 - sser aw-34, aw-35, aw-38 DRAFT 14 12-85 l" ,! S.EEE
- 1. ' Allegation Grouo:
Mechanical and Piping Category No. 1 Welding With Incorrect or Without Any Procedures.
- 2. Allegation Numbers:
AW-34, AW-35, AW-38, and AQW-24
- 3. Characterization:
It is alleged that welding was done without procedures or with incorrect procedures; specifically:(1) Temporary supports were welded without a weld procedure specification or by an unqualified welder (AW-34),'(2) a scrapped piece of magnetized I-beam was welded for hanger repair (AW-35), and (3) welding repairs were perfonned out of procedure and without authorizing documentation on a tube steel structural member on a diesel generator (AW-38, AQW-2 .
- 4. Assessment of Safety Significance: .
AW-34 Allegation AW-34 concerns the welding of temporary supports withou weld procedure specification or by an unqualified welder. The TRT reviewed the requirements for temporary supports, and made walk inspections in both Unit I and Unit 2. In Unit 2, the TRT observed welding in progress where temporary supports were in use. During t observations, the TRT discussed the fabrication, inst llation, and fotA- 5 59 g Cma o-
2- l removal of temporary supports with Brown & Root's (B&R) Assistant Project Welding Engineer and Quality Control (QC) personnel. The TRT established that temporary supports are employed during construction to maintain the required positions and alignments of components during installation until designed supports are permanently installed. Such supports are essentially made up on the site by construction personnel from available materials which are assembled in a manner to provide the necessary support function. There are no written specifications or procedures for temporary supports. The American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code, 1974 Edition (including Addenda through Surinary 1974) and the American Welding Society (AWS) D1.1-75 Structural Welding Code do not address the subject of temporary supports except for temporary welds attaching to, and their removal from Code installations. The following requirements pertaining to temporary supports are found in B&R precedure CP-CPM-6.9E, Revision 7, paragraph 3.17, and reflect the requirements of revision 6 of Gibbs and Hill (G&H) 2323-MS-100, Piping Erection Specification: k
" Piping should be erected in its permanent hangers. If the permanent hangers are not installed, temporary hangers may be used. Piping may be temporarily supported from other piping provided adequate precautions are taken to prevent damage to the supporting pipe. Piping shall not
be supported by valves, pumps, or other equipment, and care shall be taken to ensure that pipe attaching to these items is adequately supported. Unattended pipe attached to equipment will not be temporarily supported by items which are readily removable, such as lumber, jack stands, chain falls, etc. Such piping shall be securely supported with hard supports which are rigidly attached to the pipe, such as a structural support secured to the pipe with all-thread rod, a pipe clamp suspended by rod, clamped-lashing, etc. To ensure proper alignment, piping should be run toward equipment instead of from equipment. Care shall be taken not to cold spring piping when connecting the equipment. When piping is connected to equipment, a minimum of two temporary or permanent supports shall be provided; when two supports cannot be provided, written direction from Site Engineering describing the
. deviation shall be obtained."
The TRT established in an interview with B&R's assistant project 1 l welding engineer, that B&R uses the following principles for installing temporary supports: (a) Temporary supports shall be located so as not to interfere with subsequent installation of permanent supports. The actual locations of temporary supports are not documented.
- b. No attachment weld is made to the component being supported. If the temporary support is anchored to a nearby permanent plant structure by welding, that attachment weld must be made using a welder and a weld procedure, both qualified to AWS D1.1 Structural Welding Code. The attachment weld is also subject to the require-ments of AWS DI.1, Paragraph 8.14, Temporary Welds,
- c. Whenever practical, welders qualified to AWS D1.1 are used to fabricate temporary supports. However, a welder who has been qualified for making only temporary welds as described in note (11)ofB&RCPSES 35-1195, Welder Qualification Matrix, may be used for the weld fabrication of temporary supports. Such a welder has a "T" suffixed to his welder's symbol. " Temporary" welders are not permitted to make attachment welds to components or permanent plant structure.
- d. A pre-qualified welding procedure for mild steel meeting the requirements of AWS 01.1 is used for weld fabrication of temporary supports and a weld filler material log for temporary welds is maintained.
- e. A QC inspection is performed in accordance with B&R QI-QAP-11.1-28, Paragraph 3.1.1.1 and to the requirements of each B&R hanger location (BRHL) isometric drawing to verify that permanent hangers are correctly located. Temporary hangers would be identified and documented as discrepancies requiring action for clearance before final acceptance of the isometric drawing '
installation. t
i B&R QC personnel, in an interview by the TRT, independently substantiated that the above principles (a) through (e) were followed for temporary supports. The TRT finds these principles adequate in conjunction with the quoted requirements of B&R CP-CPM-6.9E, paragraph 3.17. However, to ensure the safety of components and personnel, they should be controlled by written procedure. During a walk-through inspection of Unit 1 on July 16, 1984, the TRT did not observe any temporary supports. On the same day, during a walk-through inspection of Unit 2 north and south pump rooms at the reactor vessel level, three temporary supports were observed and visually examined by the TRT. Each temporary support was a relatively simple welded structure to satisfy the particular needs. None of these temporary supports required welding to permanent structure or components. The temporary supports conformed to CP-CPM-6.9E, paragraph 3.17, in that they offered good, rigid support and conditions were not damaging or hazardous to permanent installations or personnel. The alleger has refused an interview with the TRT to review its findings on his allegation AW-34. AW-35 Allegation AW-35 relates to the welding repair of a hanger using a scrap piece of I-beam which was magnetized. The alleger stated that he was subsequently informed by the NRC that the hanger had been removed. The TRT could not identify which NRC staff member had so
l infonned the alleger. TRT discussions further established that the hanger had not been identified to the Region IV staff. Its removal,
,therefore, could not be confirmed.
This allegation could not be meaningfully addressed until the hanger j was pointed out to the TRT by the alleger during a plant walk-through on January 10, 1985. The pipe line supported by this hanger was marked 4-CT-1-073-152GR. The B&R hanger log, which has the same identification number as the pipe line, was obtained; from the BRHL drawing and the location of the hanger, the TRT identified the hanger as CT-1-073-001-Y45R. From the final inspection report IR-MH5-1352 it was established that the hanger was non-nuclear, safety related, seismic category II, class 5. A B&R drawing identified Mark No. CT-1-073-001-Y45R, revision 2 established that weld fabrication was to the American National Standards Institute (ANSI) 831.1, Power Piping Code. Weld filler material logs (WFMLs) identified as CT-1-073-001-Y45R established that weld procedure specification (WPS) 11032, revision 7 was used with E7018 electrodes. The WFMLs established that the alleger had welded on the hanger on April 23, April 24, and June 2, 1980, additional welding was acccmplished by another welder on January 8, 1981. From drawing Mark No. CT-1-073-001-Y45R, the TRT detemined that the hanger was composed of a 1 inch thick base plate and four pieces of material having I-beam cross sections. Welds joining the hanSer pieces were specified as 3/16-inch and S/16-inch fillet welds.
The TRT review of final inspection report IR-MH5-1352 established that welds had been visually examined for slag, undercut, and porosity and
,for conformance to the drawing as specified by QI-QP-11.11-1, Revision
- 5. The welds were acceptable.
The TRT visually examined hanger CT-1-073-001-Y45R. All welds appeared to be fillet welds and were of acceptable quality. A 6-inch engineering scale was laid against each of the four hanger details. None of the details exhibited magnetic attraction for the scale when it was removed. The TRT notes that the welding of magnetized material is difficult because of arc instability and would probably result in a weld with unacceptable internal and surface defects. The I-beam materials of construction for non-nuclear, safety related, seismic category II supports are identified in B&R procedure CP-CPM-9.9, revision 8, as conforming to American Society for Testing Materials (ASTM) specifications A-36 and A-515, Grade 65 or to the equivalent ASME specificatiers. These materials are both plain' carbon steels and are commonly cut by the oxy-acetylene cutting process, a gas flame process which has no electromagnetic field and would, therefore, not cause magnetization of the steel. 'Since the material was alleged to be scrap, it may have been welded on previously. If this were the case, it would have been subjected to the electromagnetic field of the welding arc. However, plain carbon steel is welded every day in
industry without becoming magnetized. The most likely explanation is that arc blow, if encountered, was due to a poorly placed ground clamp to a welding or ground cable draped over or wrapped around the beam, or to welding into a corner.
~
The TRT could neither substantiate nor refute the allegation. AW-38, AQW-24 Allegations AW-38 and AQW-24 concern unauthorized welding repair of a base metal defect in an auxiliary support skid for a Delaval emergency diesel generator system in Unit 2. The allegation stated the incident occurred in August 1982. The TRT related the allegation to Texas Utilities Generating Company (TUGCO) nonconformance report (NCR) M-82-01207, no revision, dated August 6, 1982 and reported by the alleger. NCR M-82-01207 stated that during rework of the diesel generator support structure, the structural steel member (item G) referenced in NCR M-82-00902 dated July 8,1982, was damaged and the damage, a base metal discontinuity, was repaired by welding. However, the weld filler material used was not issued specifically for the repair, violating B&R procedure CP-CPM-6.98, Weld Filler Material
, Control.
The TRT reviewed the NCR history related to the Unit 2 support skids. NCR M-82-00581, no revision, reported on May 13, 1982 that both Unit 2 auxiliary skids, which should have been to ASME B&PV Code, Section III, NF, Component Supports, were not, in fact, NF. The NCR disposition, dated May 20, 1982, _ specified, in part, that accessible welds not
l 1
-9_
l meeting B&R CP-QP-11.11, revision 1, were reworked. (The TRT has not l been able to find the authorization to perfonn this rework). NCR M-82-00902, no revision, reported July 8, 1982 that linear indications had been found in item G, and interim dispositioned on July 19, 1982 for removal and replacement of item G. NCR M-82-01207, no revision, reported August 6, 1982, the previously described base metal repair by welding of item G with filler material not authorized for the repair. From the available NCR history, the TRT analyzed that the following chronological events occurred: (1) Weld repair of unacceptable vendor welds was conducted without NCR authorization. (2) During the time period of (1), linear indications were found in the base metal of item G and NCR reported. Item G was NCR dispositioned to be removed and replaced. (3) Prior to removal of item G, a base metal discontinuity in it was weld repaired without authorization, probably as an extension of the weld repair action in progress and noted in (1). This repair was the subject of NCR action for the use of unauthorized weld filler material. It is the TRT's opinion that not only was the filler material not authorized for weld repair of item G, but the weld was not authorized. The TRT, therefore, substantiated the allegation.
The TRT also determined that NCRs M-82-00581 and M-82-00902, by revision, were redispositioned to scrap both Unit 2 auxiliary support skids because of additional base metal linear indications. Region IV
'was advised of this action in TUGC0 letter TXX-4095 dated January 10, 1984 which also stated that replacements would be fabricated at the job site. (TRT members escorted by B&R personnel examined the scrappedcut-upskids.) The TRT reviewed the TUGC0 replacement design and determined, with respect to section properties of the steel structural members which replaced welded channel assemblies, that the i
design was equal to, or better, than Delaval's ASME B&PV Code, Section III, NF design. The TRT notes that there are some questionable documentation aspects which were found during its evaluation of this allegation:
- 1. No documentation was found which authorized repair by welding of accessible vendor welds in the Unit 2 auxiliary skids.
I
- 2. The weld repair of the base metal discontinuity in ite- G w :
reported almost 1 month after item G was NCR dispositioned for removal and replacement. i
- 3. There was a lapse of 12 to 15 months between the initial and revised dispositions of NCRs M-82-00581 and M-82-00902 which finally scrapped the skids.
e I
- 4. Documentation of weld repairs continued for almost 5 weeks after the disposition to scrap and replace the skids.
The implications of these docmentation aspects will be addressed by the TRT QA/QC group. The findings of the TRT for allegations AW-38 and AQW-24 were reviewed with the alleger in a meeting at the Granbury Inn at Granbury, Texas on March 5, 1985. The alleger accepted the technical evaluation and conclusions of the TRT. He expressed his primary concern relative to these allegations as harassment of crew members who were coerced into violating p,rocedural requirements.
- 5. Conclusions and Staff Position: Allegation AW-34 was substantiated by the TRT in that it was determined that temporary supports, other than attachment welds to components or permanent plant structure, are weld fabricated without a weld procedure specification and may be weld fabricated by a welder who is not performance qualified. However, there are no specified requirements to do so.
It is the TRT's position that the use of temporary supports must consider component safety. Safety significance and generic implications of temporary supports welded without procedures and controls are addressed in Mechanical and Piping Category 11, Allegation AP-13. Allegation AW-35 could be neither substantiated nor refuted. The TRT could not logically explain why a piece of plain carbon steel I-beam should be magnetized and concluded that arc blow, if encountered, was
-. ee - - -- . . + . . _ , ww , . , - . . .,w- . , - .-,-m -
( . . _. ._ - . _ . . _ . _ . . .. l .
- probably caused by a poorly located welding ground or poor welding i technique. The hanger final inspection report established that welds were visually examined and acceptable. The TRT, therefore, concludes that this allegation has neither safety significance nor generic
, implications. l i Allegations AW-38 and AQW-24 were substantiated in that the TRT could ) find no documentation authorizing the repair of a base metal defect in ! item G. However, the TRT notes that the allegation could have no j impact on safety because the skids have been scrapped and replacements j have been designed to provide equivalent or superior strength and t' stiffness.
- 6. Action Recuired: Actions required for temporary supports are as l stated for Mechanical and Piping Category 11, Allegation AP-13.
l
/
- 8. A ttachmen ts : None.
. - . . . . . . . ..- -. - - - ~ . - - . . - - - -~- -
a
~
- 9. Reference Documents:
- 1. NRC 01 Report 84-006 dated March 7, 1984 (includes testimony numerous interviews).
- 2. ASME B&PV Code,1974 Edition Including Summer 1974 Addenda, Section III Subsection NF, Component Supports.
- 3. AWS D1.1-75 Structural Welding Code.
- 4. B&R Procedure CP-CPM-6.9E, Pipe Fabrication and Installation, Revisions 0 and 7.
- 5. G&H 2323-MS-100, Piping Erection Specification.
- 6. B&R CPSES 35-1195, Welder Qualification Matrix.
- 7. B&R QI-QAP-11.1-28, Fabrication, Installation Inspections of ASME Component Supports, Class 1, 2, and 3.
- 8. B&R Inspection Report IR-MH5-1352.
- 9. B&R drawing, Mark No. CT-1-073-001-Y45R.
- 10. ANSI B31.1, Power Piping Code.
- 11. Weld Filler Material Logs, CT-1-073-001-Y45R.
- 12. B&R CP-CPM-9.9, NNS-Seismic Category II Supports.
- 13. ASTM A-36, Specification for Structural Steel.
- 14. ASTM A-515, Specification for Carbon Steel Plates for Pressure Vessels for Intermediate and Higher Temperature Service.
- 15. TUGC0 NCR M-82-01207.
- 16. TUGC0 NCR M-82-00902.
- 17. B&R CP-CPM-6.98, Weld Filler Material Control.
- 18. TUGC0 NCR M-82-00581.
- 19. B&R CP-QP-11.11, revision 1.
.-.. ..._,-o e m .,,_? .
. l ' ' ' ~
14
- 20. TUGC0 TXX-4095, Commanche Peak Steam Electric Station, Unit 2 Diesel Generator Auxiliary Skid, QA File: CP 82-06, SDAR-82, File No.10110, dated January 10, 1984
, 21. B&R WPS 11032, revision 7.
- 22. TUGC0 QI-QP-11.11-1, revision 5, Installation Inspections of NNS Seismic Category II Supports for Class V Piping.
- 10. This statement prepared by:
C. Richards Date TRT Technical Reviewer E. Thompson Date TRT Technical Reviewer Reviewed by: L. Shao Date Group Leader Approved by: V. Noonan Date Project Director 0 { l j e - s . - - _ _ _ _ . _ _ ~. - - - - -
.Q{ #t.' i j[
DCP3 - SSER AQW-5 s x Draft 10 - 3/18/85 ,
. n ti
,#~ .
SSER
- 1. Allecation Grouo: Mechanical and Piping Category 27 Unqualified Weld Inspector
- 2. A11ecation Number: AQW-5,AQW-11,AQW-16,AQW-17,AQW18,AQW-19, and AQW-69.
- 3. Characterization: It is alleged that:
/3Gw0-f,4 C W-l9 in 6-V) +Jsp&cxotLS g,y&tC6 AJd7~ QU P t 1 H 64)
&Qcv-lI,4(ptU-lG
\)6 n ocre to 6-c. c.t c N 7- m 3- O t &f &L G & N & (2 /4-MfL LU M IN S P6 CZ6A GY A b) ou Surt.t pt 60 w ci vt0044. ,
l A Ou) - I J A 5 ct.6-AwtLuCET Hot.0 PoiN T a.>4S Im przo p5<t L N (26L 6*t & B Y A. G) C g NT06 crof t A-Ow -l 8
& 6 A-5 to iN SP&crores orp acr pp.oacrz.t.y u n spe ct a., + u o s .
A- f.) e>J - &, 9 I ^>SP& croteS Ooo riot' HM& PGoPGA. 50 u t A:;te W4-c. f) A64 6 (2 0 0 MC1. b' t 0 SSW-SSm &*li' cA 5% St c,.ut m cwc 9 tr c3w - S , /kp w - t 9 Two A-c c s- o ef21 ere 7mpr wyme s= e s 4,. l-h --ij.1,2A..ds.
@. E vu%.,,,,;Q.-
/
., q m. , w -. .- , ,, . -- . e,
e l diITUNSS60 l ^} A'O & & V 'L-T 6 I U S fd'CE"' O U ' O U & h t, t., $ G A-7-t a t) Co N C C-12 N Gd tA) 6-L O r su G u O1 PG CZi c A) f,-e) C 7746 O T14<M C^^ 3 (23-L 4-TM TO OA)O5TI&NA M O u r:.1od o rud-l ,o S P& crt o N u.) 4 i cs+ us p-s ao oe c+ W 6 G-C4 P t V Qtto co & S , Sv6IGT Cf- 1pS PG Croft- Q u A t ni w r to Ai S 11 M IS fr00 % SS H IM Q A/O c c A:rG60 re4 4. Ou 2.t A> 4 T5 t 6- 12 tho ^' & con V G12S h-TI o N S ON A-uG US Y
~5 o, t 9 8 4 pvo O c-ro 6 cM- 29, l9 8 H' , At- f-L L &b M cp (4 Cp u) -S OG ci t NG0 ro 1-H W & G u (2 TI W OI 5 c., v S $I O N S ' L) t W ~l~ M N G $ L.& W W
$$g 7 T~D ~l~M0' O f* 0 ' U A~Y" < Of /**l ' 0S *~^'
fr (pu) -lCl cas $10 4 0 S r S CJ , 1 9 8 Y (2G Ct G-v C'-0 N O (284190NSG. D ACW ACW-16 In 1982, the alleger was told to inspect certain vendor welds on a diesel generator skid. Mold % supervisor" did not feel
" confident or qualified" to inspect the welds, stated that she was told to do the work or "go home".
The TRT learned that the inspection was part of a program to evaluate the welding on a vendor furnished diesel generator skid. NCR-M-80-0009 had been prepared on July 17, 1980 to cover the apparent failure of the vendor to fabricate the skids to the ASME NF requirements. The dispcsition of the NCR stated in part "The fabrication records have been examined and there is insufficient
. documentation to claim NF e i
i
. t *?
C-equivalency. A program had beem developed, however, to qualify the support and skid fabrication to AWS D1.1-1975 and the AISC Manual of Steel Construction, Seventh Edition." TUSI Procedure CP-QP11.11 was prepared to cover t ph 3.5 of the procedure provided instructions for conducting a visual inspection of the welds. The alleger was qualified as an AWS D1.1 visual weld inspector and was being asked to inspect welds to the same code. The TRT can find no evidence that the alleger was unqualified to perform the inspection. TUGC0 letter TXX-4095, dated January 10, 1984, advised the NRC that the skids would be scrapped and replacements fabricated at the job site. A meeting was held with the originatnr of allegations AQW-11 and AQW-16 on January 9, 1985. The alleger continues to maintain she was unqualified to perfonn the work &t/4t/ m ut.<64 St4e u;44 + (90M 4 fre) r% 4 2 S W 6'- C l'* 5 O W '2'
- St N C& T146- $6I 0 $
tu tfL& S c.rt.A-99&n Mr O GHLAl&d M A t C.% WM
@ no q SI& UtF-t & f C i m rra ,s g u e tati v a rue ucea w ~ ce gsi rn M eo w orv To 'rM 6 A> ILC 0* C6 O' ' N # T' A *' " ' '
j l ACW-lJ 0C tsu S p 5 @ k- umst=c IT L S Mt- 5 0 00 Y M'%r' A-h- C GM Liv &1 W Po r vr o p ,s page. pace _ e,p ere t.o s-Lo vat ruvr PsticocLm u uc, rue pscess tu wCcrioM. Tne Au 54 & R.- nLic cc.ptm M TMG
t.2 4 4 (UG L O t.u A S PoofE b6CouS6 N A-r& & wA s cem rug T W (20 a le M. a)14 IL & T146 5064.o t.U M 6 6-1 ou 4 ry, M 6 ,
. As $ b)(2 C (2s-grou H i es os crog uno a rove's n a nroo T)4 G ALLG 62 t% TlCN A-N C A &Go CTGO 4 1S f t v o rN G.5 iN I0. 29-IT CA n?-C TuLM ? ; I 9 *)9, A ce. ort c e 94 ro 41+d it640 rLT~ , A Q C. l M $ P& CAO(2 voo0LO Cg Am e p &
A- Lt N642 a> 6 co S 5-+n, ,4-p r&rt G-t n>p p.eet-L G 6 + 1V L-l M 65 I s & TlH1. 43-C C 6-f) r/HvC 6, TN4 1M C PGCZo/2-a) o v u n m n a ,e ru+ sw u Less s r e a <- ea v e-<c I M S 0 5cxloN T~rfs*v 6 L 612- {$611 Wit $7st .c C6 0 u tt0 c c.p- s a - % v esu Sns<. Li ucu ca.6c cruh u;<Ye Ac conerv49 A-co c.ovo rz. 7:46- s es
- w r w e s- co rt. eu rcknco. =nxL r+s
$u6 $ &4 uMT T14 0* $W a>Ovl40 (b 6~ IE.6 LG* f 6 d eo rt- co cr ua- ,,c,cic , _ro ru w s- !
esu rzence e y 7He 4<.lssest , ruc e>c ietpsa+ l M >$A.0 in ,4 00- Y-146 c> tLA 4 r A>44 i tus psw l W GtV Q1V /4- S 6<oN& Cf- 1CSGS-eh3d- AUT140vtA a-A-M *' l 1 0YY h YOLO*0W TO $*S'l W ( & ( W f j . u) 1 nt. ru& ewt.aseNat Cc iespeacrL as n 6 0rnttv & 14 6- L4n o (2Ecos L L 0 ~t'4 + cuotN- ev 0*f-- 1146- Mot 4 <v& Gu T' ccA-1m st) ~rN e- as 6 <^o tutv3: Srsa c t G A ,o o & LAvs c- tN c W
- us h-3 l A)M* T146 lb6&t ow $ irGS Gd2XD!C C onc cu ctv) r1W TN& Q C. t pf ps-c.ro12-m % I4k 6' MA0& i4 -N &YL LO'l i A'
___ _ . _ _ _ . . - - - ~ _ . _ . _ . . _ _ _ _ . _ _ _ _ _ _ , ._,_,,.,.ye. , . , _ , , , , . . . . . _ . , , _ _ _ , . . , _ ,.
~ .- 2.7 5
3 0 0 G.6411 G^> T w nor (2+ u A in t utit. G ru-af & . YlM S'W 4A 4 0yt&vI ous c.lf adew Ip.s 90wGs0
. (4ho #covo P-cc 6-1)TA-6 LG, Tin Tf27 concutze5 u,u n+ T-H-t S c o A> c t a c t.o As , Yt+s- rrt%- 1.s (Ld4+Y2 L PCs vM Q A- 1 m pu c,c.-r i o A>s c4 71+t S Y%-LL &G A-77o N TO DM T(Lr' QI4-l0 C, A-L c6-G nri on (-ho - 4 '2- o F M/P Ca-rd-4oq 43 f)dS c v2A.6 GS TlV6 T(LT suAcu m o+
A-LL 66 A-rl ahf 77h4 Y'" thed t.O dH' r)/N4 c~oH/2/r/on'3 i)U $ r&) 00(C/N 6 7?/d /H $7MC A-YZ 60 o f-Thl6 f /x> df21, 61C Go fir.S M26 66tMG s tl M d 76 /92/29 G
/r- /VJ66-77 HS tt) / 7'H- M Al-tla's GA-A-GptO - t S Tw& A-u.6-G d42 3 74Yd-D r>M-r 6-6 4 5 cc i10 $ psczr><t4 c cTt'tJ $ t & N -o As noSPd-crtotoS O f- c.od-L o rP 4 PYLem Tl44 pt cort L 6 V 64- u ) b H %- ) TM& to &<. 0 6fLS
%6- 0.20 ftICI N & I S' +GG-Y ort iv, o.-tL& 14 -6 o J6 TM-6 *t i TH4 rus-c r cz,4-1 o u M a s o r>&rt.vt.to12- To t.t> TN d T 1'? V T H A-T 6-0 M cb np$Qd-C.TLoM PCctZfouN d-C l
LA)6-fL d- f ivt ()LOy&n p> q 7 t; & C TO PrtA iv1 Mi<t 1 co e a-envec on ec+,vr (soe) pov - ,a-eus-
,osascrioo mo u. rusC enoee-ovaa-epZ ~ Q P -1 I,2I -t (2g-ep un aret esrt l'cr(L-v'tsom n m s ps-cruw s i.s rnert.6R>rts Appuc,a-a Le
(-bw C Prts vt t)d-S t ro S Tt20 c Vl o NS foft PGf2fccw '46 L __
s z.7
\/tS o 4L IN 5 PG C rt c M c> se- 80 P norcts.
M 060 C 6-C 0fI6 OSSC.AI(3&S t N O & TA-t C 1-N C
. A-C C & 9 Y A'<3 L & Cooc noms o F TH& a.) 5<-c
$ uits M 4 , u) 4 L C S t -a, s A uc cooe-o Cr ort. A rt car Awo o n444 C (4 YML Ac.rotu 5 Tics oc TH G- u.s 6 <-M totatCd pu5 Y 13 & sit G.Lt 6 D O Q C L C S & , T126-TL)G'C ~rilA l W\ NG S u P&tL vt soc Tocc T1-f& T7fF
*n447 G-6 6-S Co y up .s p g.e g t o n pg42so MD6L so&Yf4 TTZ A 1N 610 AWC C6-(2. P I Ft Gd lio y;J,6 $p6 m M 6 *t- 45 A A)&to TvGC M pt.c y 66 r T M G s s o c r-s c+ A Tc21- Ob4 7
/pc czrtsoP (2Ofi662 0 t'- Tbkt" TVOC T"YLA-l WINh f2(2CG W l5 26- Po rz r-eo s tu G A fpc (A YG-G O % bi
$ t 6-(TLC-ft- 5 &ivT TO T*K0 0121 G (U4-Yorf- Cf h-LL6-6A TLOU &QtJ) ~18 ch b&usrBC,t49Y tzsc.isuen oc, as-spe u s e ,
AQW-69 It is alleged that "eight B&R QC personnel may not have either high school dipolmas or General Education Development,(GED) certificates and, therefore, are not qualified to be inspectors." T N t$- 5 0 G M C I ~ C Tf- Q C. ( M S G6cTorf-- M M I A>C1 S A)9 CP U 44.-t ft CATt 6%! t$ b 0/)W $ 0-0 Isu WlOc CA-YSS 0 % d. A letter was sent to the AQW-69 alleger on August 30, 1984 with no response.
k$hI 7 ufw . - jy g 5, Co ncam e n t wo fmu. 9ertreova A 00) - S', A- CLO -l T TIM- S u6T& T of-- s y s Pd-c rot 7.- O u A-<.A f-I cw o N S IS fcco(2&SSc4 iN 9 4/QC cn-r"B o rcy 4-14-01.0 - t I , A-oco - i Q The TRT found no evidence that the alleger was not trained to perfom There is no safety inspection work on the diesel generator skid. significance to this allegation. A-(su) -I 9 The TRT determined that the QC inspector should have been present to verify that the weld sean he had inspected was the one being released AA>c W re&-m A-s tu &D C t 6*N , 'Th' G C. t MSP&c-Tort- m% MO mA4V H Wo (2- stu T u 0 6 c- M . c u T P> 0 T T H + u 1 M lMD PftGVICVS t cj 66ed Acc54rGo. r M 7t2.r cw
-- n 10SGGert)M Puo ovo S &"[ SIG M \ Ff M ( G IN M+
4 cr < o,o s . 6Ot.D-l8 a.) G 4C- 'l Wr ^'H {r34SCO 1# S P G-c.n c w (26650 N N 64 AND C 6 #T I FI H IU T1+& S/>rvt & iv1 M N G A 4-E TV6C t. m G G o y G-G S ' T7+& S 063-Ser o f T uGC 1 N $ 06 C To YL T (L A. w ti pso O guget f.4 cA.r t 00 lS A-90 tid-SS6-C 1rU Wpc.cATGG0Q Nr
- 6. Actions Recuired: None.
....m
( _g.
- 8. Attachments: None.
l -
- 9. Reference Documents:
- 1. ANSI N45.2.6-1978.
- 2. TUGC0 Procedure QI-QP-11.21-1.
- 3. NUREG 1.2.6.
- 4. TUGC0 Procedure CP-QP-11.21.
, 5. B&R Procedure TCP-1.
- 6. TUGC0 Procedure QI-QP-2.1-19.
- 7. B&R Procedure QI-QAP-2.1-5.
- 8. TUGC0 Procedure CP-QP2.1.
- 9. B&R Procedure CP-QAP-2.1.
- 10. B&R ISO BRP-CT-1-SB-019, Rev. 6.
-., 11. NRC IR 79-15.
w
- 12. NRC IR-82-10 and IR-82-11.
- 10. This statement prepared by:
R. Hubbard Date TRT Technical Reviewer Reviewed by: L. Shao Date Group Leader Approved by: V. Noonan Date Project Director
~,
I, ! i,- e DCP3 - SSER AQW-5 i s 1c xDraft 10 2[I - 3/18/85
)
s . I / I/) .SSER s I e 3 ~
- 1. Allegation Grouo: Mechanical and Piping Category 27, # ,
Unqualified Weld Inspector
. /
- 2. Allegation Number: AQW-5,AQW-11,AQW-16,AQW-17,AQW18,AQW-19, and AQW-69.
- 3. Characterization: It is alleged that:
(a) (AQW-5 and AQ eld inspectors were not qualified . (b) (AQW 11 and AQW-16) Vendor welds on diesel generator inspected by
~
an unqualified individual.. (c) (AQW-17) Improper release of hold point.
,1 (d) (AQW-18) EBASCO inspectors did not properly inspect welds.
(e) (AQW-69) Inspectors did not have proper educational backgrounds.
- 4. Assessment of Safety significance: It is alleged that:
AQW-5 " Weld inspectors not qualified." A0W-19 " Poor inspection occurred during the backfit program." [ QA/QC TRT reviewed a series of allegations related to QC inspector qualification and training. The results are included in QA/QC Category 4. Ah C d q Afgo #- g q , s_ m 4 7-r :^, s a n. - -n 3 . j0, o. )*'. b. p"' 1,.
- {d
- /o2
b, D ms e QA/Q TRT found that the tra ing and certification program for
' 'N ASME welders as adequate. QA/QC TRT also found a lack of prcgram-
/(
- matic control i enon-P.SEtrainingandcertificationprogramto j
. assure that the pro ra;n was achieving and maintaining requirements as i 50, Appendix B. The SSER Category 4 has requir#ed set forth in 10 B&R and TUEC to/ provide a hird party evaluation of the entire spection ning and certi cation programs. B&R and Et shall upgrade 3r procrams as recuired by
- A
- party findings.
During telephone conversations on' August 30, 1984 and October 29,
~
1984, the alleger of AQW-5 declined to have further discussions with the TRT. A letter sent to the originator of allegation AQW-19 on August 30, 1984 received no response. A0W A0W-16 In 1982, the alleger was told to inspect certain vendor welds on a diesel generator skid. MtoldM supervisor id not feel
" confident or qualified" to inspect the welds. tated that E was told to do the work or "go hcce".
The TRT learned that the inspection was part of a program to evaluate the welding on a vendor furnished diesel generator skid. NCR-M-80-0009 had been prepared on July 17, 1980 to cover the apparent failure of the vendor to fabricate the skids to the ASME NF requirements. The disposition of the NCR stated in part "The fabrication records have been examined and there is insufficient documentation to claim NF q _- _ S
,/
/ -.h v
-= _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
.s.- .
p c' } P-c,. , r equivalency. A program had beem developed, however, to qualify the -
~
support and skid fabrication to AWS D1.1-1975 and the AISC. Manual of Steel Construction, Seventh Edition." TUSI Procedure CP-QPil.11 was ; prepared to cover the reinspection program. l Paragraph 3.5 of the procedure provided instructions for conducting a
# visual inspection of the welds. " The alleger was qualified as an AWS D1.1 visual weld inspector'and was being asked to inspect welds to the same code. The TRT can find no k evidence that the alleger was unqualified to perfonn the inspection.
Wh .. h', v - ' { '[ , Mechanical and Piping Category 1 (AW-30) (AQW-24) covered the "14(. .. resulting weld repairs on the' diesel generator skids. The TRT stated i M. f ? in the SSER that NCRs M-82-00581 and M-82-00902 by revision were y .-r S!E - redispositioned to scrap both Unit 2 auxiliary support skids because s v? - of additional base metal linear indications. g,.[.,' - 4 TUGC0 letter TXX-4095, dated January 10, 1984, advised the NRC that p b. , _ the skids would be scrapped and replacements fabricated at the job,
.f
. - site. i
- L*
!. n. ,=
. J' ,', A meeting was held with the originator of allegations AQW-11 and -[t m , . g.3. c 5 AQW-16 on January 9.1985?2iThe alleger continues to maintaingas
~?. . fk. .
.$,y , unqualified to perform the work.
.--.,t '
,U t -
.n,
,eb.[ "
.b ,g a (
gr ,.
** *
- N .- e '
.# { j? ,j $* e'as 6< ,g a 4
4
.. M,JJ7, It is alleged that a QC inspector bought off a seam before he ever saw the seam and it was not a good weld because water was coming through while the weld was being made.
The TRT reviewed a Region IV investigation of the allegation as reported in IR 79-15 dated July 2, 1979. The report identifies the welding as part of the installation of the stainless steel liners in the Unit I reactor containment building or in the comon fuel handling building.
~
The TRT reviewed the methods used to provide inspection of the liner welds prior to welding. The report stated that the reactor resident inspector discussed the
)
allegation with the QC inspector involved. According to the inspector the seam in question had been reviewed for cleanliness and weld fitup and documented. A piece of tape had been placed over the seam. m
&R procedure CCP-38, Stainless Steel Liner Erection, identifies t e g
c n11 ness and fitup QC hold point as item 5 in paragraph 3.4.1. The hold point is also identified on B&R stainless steel liner inspection
' O' /
- avelar. 'y '
sy 9 f a d
) he QC inspector gave authorization on the telephone to another r j j, inspector to release the hold point and allow the next step in the installation process to proceed.
M 4 . , , ,
f, he TRT determined that the QC inspector should have been present to
; verify that the weld seam he had inspected was the same one being ,
released. He should also have verified the seam had remained clean. y '
/[f e t Based on the information contained in Region IV IR 79-15, the as pl.
& p inspection had been performed and documented. g j (p v *gWyp Jh. m ale de+adned that B&R procedure CCP 1Apiueo%uate
,bg '
i na i.. .ci. ; wn. iur inspec ung tne cleaniines. ef the 'i er pht-c. The TRT can find no safety significance in the QC inspector's actions. W n S24. --<. 4=; tM ^?. '
,,1 .6.un vi on. .liev 6.un to tne TRT Y..... ~-
~
.i
%4 9gm' 4 xy Allegation AW-42 of Mechanical / Piping Category 43 describes the TRT CD evaluation of allegations that poor welding conditions existed during the installation of the liners.
Efforts are being made to arrange a meeting with the alleger. AQW-18 l The alleger stated that EBASCO inspectors often sign off inspections j I e of welding from the floor level when the welder is 15 feet or more l l above. ) i t ev--w-.-~~.-,,.. m,... ..e,#. , % ,ym . . .c e -
I
'., The TRT determined the EBASCO inspectors were employed by'TUEC to primarily do balance of' plant non-ASME inspection work. The EBASCO
< personnel were trained and certified in the same manner as a new TUEC l l inspector. The TRT therefore, reviewed the TUEC training program to determine if controls existed to prevent improper inspection. l [ 1 The TRT found that the QA/QC TRT reviewed a series of allegations related to QC inspector qualification and training. The results are included in QA/QC Category 4. During the QA/QC review a number of irregularities within the TUEC training program were found. As a result, the QA/QC TRT has required TUEC to provide a third party evaluation of the entire QC inspection training and certification programs. TUEC shall upgrade its program required by the third party findings, t . A letter sent to the originator of AQW-18 on August 30, 1984 received no response. - AQW-69 It is alleged that "eight B&R QC personnel may not have either high school dipolmas or General Education Development (GED) certificates and, therefore, are not qualified to be inspectors." l l
e The TRT found that the Region IV senior resident inspector (SRIC) k reviewed the allegation and reported the results in IR 82-10-11 dated f December 3, 1982. The SRIC found that of the eight persons identified by the alleger as not meeting the minimum education requirements, five were found to have documents verifying their high school graduation obtained by B&R from their respective schools. The remaining three had GED certificates on file in their personnel jackets. The SRIC found no basis to the allegatio' n.
, ~
J The TRT also found that the QA/QC TRT reviewed a series of allegatio related to QC inspector qualification and training. The results are included in QA/QC Category 4. The QA/QC TRT reviewed the training and certification records of 102 TUEC and B&R QC personnel and found that 20% contained no verification of education and/or past employment and work experience. 4 The QA/QC TRT concluded that a violation of B&R procedure CP-QAP-2.1, paragraph 3.1.2 had occurred. The procedure requires verification f i
,agplicants previous education and experience.
( / g/ WThe SSER Category 4 has required B&R and TUEC to review all inspect 4 qualifications and in those instances where the inspector does not l meet the qualification requirements, B&R and TUEC shall take action to verify the acceptability of all inspection perfomed by the unqual led nspectors. i
r i< [ ll f .
, A letter was sent to the AQW-69 alleger on August 30, 1984 with no 1
( response. r[, 4
- 5. Conclusion and Staff Positions: .
(AQW-5)(AQW-19)(AQW-18)(AQW-69) The TRT determined that allegationg, AQW-5, AqW-19, % and AQW-69,
%p.a.s-Tet -
covering inadequate QC -4M- certification, will be resolved
/t
'by TUEC's response to the QA/QC TRT SSER [ 0 h h
~
A0W-17 - The TRT detemined that the QC inspector should have t,een present t,o verify that the weld seam he had inspected was the one being releas(sd. He should have verified the seam had remained clean. Based on the infomation contained in Region IV IR 79-15, the inspection had been perfomed and documented. The TRT can find no safety significance in the QC inspector's actions. A0W-11 and ACW-16 The TRT found no evidence that the alleger was not trained to perfom inspection work on the diesel generator skid. There is no safety l significance to this allegation. l i
- 6. Actions Recuired: None. I i .
9 t 8. Attachments: None. l.
- 9. Reference Documents:
- 1. ANSI M45.2.6-1978.
- 2. TUGC0 Procedure QI-QP-11.21-1.
- 3. NUREG 1.2.6.
- 4. TUGC0 Procedure CP-QP-11.21.
- 5. B&R Procedure TCP-1.
- 6. TUGC0 Procedure QI-QP-2.1-19.
- 7. B&R Procedure QI-QAP-2.1-5.
- 8. TUGC0 Procedure CP-QP2.1.
- 9. B&R Procedure CP-QAP-2.1.
- 10. B&R ISO BRP-CT-1-SB-019, Rev. 6.
- 11. NRC IR 79-15.
- 12. NRC IR-82-10 and IR-82-11.
- 10. This statement prepared by:
R. Hubbard Date TRT Technical Reviewer e 4 Reviewed by: L. Shao Date Group Leader Approved by: Y. Noonan Date Project Director
'. C,
- g, DCP3 -
SSER AQW-5 Draft 10 - 3/18/85
,rm
',..: )
SSER ; l
- 1. Ai~ nation Grouo: Mechanical and Piping Category 27, Unqualified Weld Inspector !
- 2. Al*+;ation Number: AQW-5, AQW-11, AQW-16, AQW-17, AQW18, AQW-19, and AQW-69.
- 3. Cht 1:terization: It is alleged that:
(a' (ACW-5 and AQW-9) Weld inspectors were not qualified .
-\W
'AQW 11 and AQW-16) Vendor welds on diesel generator inspected by (b
A an unqualified individual. y f ~ v (c' 'AQW-1 7
. proper release o *
(d (ACW-18)EBASC ppectors did not properly inspect welds.
~
7 (e ,'AQW Q9 M etors did not have proper e b ational backgro *
# W Assessment of Safety Sionificance:
h li N ! ?! c i b j ?
- 4. it._' m ' ips d >h AQe-E " Weld insorcj; ors not qualified." /% h
_ " Poor inspection occurred during the backfit pr "! ( A h - 3 f.L W - h Thi 0.T found that the QA/QC TRT reviewed a series of allegations re's ed to QC inspector qualification and training. The results are in:'.ded in QA/QC Category 4. me, .i 3 n~ 1" n b N ft1.;ai .h n , 2',I,2,.
=['*-)w?
u.,
/ 'B ~~
C The QA/QC TRT found that the training and certification prcgram for AhMEwelderswasadequate. The QA/QC TRT also found a lack of program-matic. control in the non-AMSE training and certification program to assure that the program was achieving and maintaining requirements as set forth in 10 CFR 50, Appendix B. The SSER Category 4 has required B&R and TUEC to provide a third party evaluation of the entire QC inspection training and certification program:. B&R and TUEC shall upgrade their programs as required by the third party findings. ~ During telephone conversations on August 30, 1984 and October 29, e\~Q.g? 1984, the alleger of AQW-5 declined to- have further discussions with the TRT A iener sent to tne originator of allegati " n 3 u. Urust 30, 1984 received no resp .
~
ACW ACW-16 In 1982, the alleger was told to inspect certain vendor welds on a diesel generator skid. Mtoldgsupervisor did not feel
" confident or qualified" to inspect the welds.
statedthatM was told to do the work or "go heme". l The TRT learned that the inspection was part of a program to evaluate the welding on a vendor furnished diesel generator skid. NCR-M-80-CC09 had been prepared on July 17, 19S0 to cover the apparent l l ! failure of the vendor to fabricate the skids to the ASME NF t 1 requirements. The disposition of the NCR stated in part "The ! fabrication records have been examined and there is insufficient documentation to claim NF
)...- & o
- 3- l equivalency. A program had beem developed, however,'to qualify the s'upport and skid fabrication to AWS 01.1-1975 and the AISC Manual of' Steel Construction, Seventh Edition." TUSI Procedure CP-QPil.ll was ~
i preparedtocoverthereinspectionprogram.g
-faragraph 3.5 of the procedure provided instructions for conducting a visual inspection of the welds. ,
- The alleger was qualified as an AWS D1.1 visual weld inspector and was being asked to inspect welds to the same code. The TRT can find no l evidence that the alleger was unqualified to perfonn the inspection.
ll I and Piping Category:1 (AW-30) (AQW-24 .t..
._- resulting we d airs on the diesel generator skids. The -TRT stated the / ;
.v.3 in the SSER that NCRs. 581;andM52-000 7 y revision were j b-redispositioned to scrap both U au ' ry support skids because of additional base met linear indications. < letter TXX-4095, dated January 10, 1984, advised the NRC,th'at the skids would be scrapped and replacements fabricated t'the job s'- j site. ;,' _ 1<. L'.
; -~w
- t .
-a
" * ' ~
?-h: v% . . v ._
q' E q H A sieeting was held witEithe fginator &; d@.Er .s.
... of' allegations AQW-11.and
- .V . s: 2: cb _ ~ .
d .- n M h h -~ .J - 6 :-
' 'c- r - .#FAQW-16 on January 9,s1985.h' The alleger continues to maintain was my: .'. : y ;,
y en , , QYZ ~ '
+, x.
pg f o R j unqualified to perform the work.'. . _ pg-y'
..g.
{&
^
2l- .
-Jb e i h *, * . P .1* ,
Ih.
- T' .
a
- E ** - 8
l AQW-17 It is alleged that a QC inspector bought off a seam before he e'ver saw the seam and it was not a good weld because water was coming through while the weld was being made. 1 The TRT reviewed a Region IV investigation of the allegation as reported in IR 79-15 dated July 2, 1979. The report identifies the welding as part of the installation of the stainless steel liners in the Unit I reactor containment building or in the common fuel handling - building. \
,K The TRT reviewed the methods used h provide inspection of the liner N
N i \ , N' s.
! welds pr)or to welding... N y[ .gtf
,~ ) , g L.
.- h eg W WIa e
4 The report stated that the reactpr resident inspector discussed the allegation with[tlie'lic inspector involved / According to the inspector' the seam in question had been reviewed for cleanliness and weld fitup , and documentedFA piece of tape had been placed over the sea _mp s#,' 7 R7rocedure CCP-38, Stainless Steel Liner Erection, id 3fieg cleanliness and fitup QC hold point as item 5 in paragraph 3.4.1. Th'e , hold point is also identified on B&R stainless steel liner inspection traveier. - -
\ c, .t P -
O . The QC inspector gave authorization on the telephone to another inspector to release the hold point and allow the next step in the installation process to proceed. O e M
- - - - - , e-- ,-n+--, -.-ew e , a-w.,e, , . . -,,..e me,,, , ,m, 4g q- 4 em e n,ry +* ,y.*1p mer ,e#? *:
The TRT determined that the QC inspector should have been present to. v'erify that the weld seam he had inspected was the same one being released. He should also have verified the seam had remained clean. j Based T the information contained in Region IV IR 79-15, th Q inspectjort ad h heen-perfCnned ?nd dOcurer.ted. > A A
- The'lTRT\ also determined
'\ that B8,R procedure CCP-38 provj< fed adeq instructions for ins i
; \
l l
/ /l he J1ner pla/ tes./ e
/ TRTg,anfi,d,nosafe\pectngtheceaninessofcept
\ \
,t s,ignifican\ s actions.
The TRT is referring the QA implication of the allegation to the TRT QA/QC. Allegation AW-42 of Mechanical / Piping Category 43 describes the TRT evaluation of allegations that poor welding conditions existed during the installation of the liners. Efforts are being made to arrange a meeting with the alleger. ,
^
AQW-18 i
'D [
The alleger stated that EBASCO inspectors often si off inspections - of welding from the floor level when thh welder lis 15 feet or more above. % ,k D (c . S, bp I' i" 1, g sp g " s , m. m-m e-< = - *_ >-w,-**- o se -*w * = - -,,
-wef-- =<-wc.-9p,yWe- .- ey qqy,,%gymp , ,g g ey 7 = _ _
L* 3 '
, - 3
,The IRLdelennined CO inspectors-werempT6 fed by TUEC to ',
d
rimarily do balance of plant non-ASME inspection work. The EBASCO p\
personnel were trained and certified in the same manner as a new TUEC insp o [b
The TRT, therefore, reviewed the TUEC training program to determine if controls isex\ d to prevent improper inspectic CwO Th T"7 #ru'nef th reviewed a series of allegations related to QC inspector qualification and training. The results.are
\
included in QA/QC Category 4.A
\
r N f During the QA/QC review a number of irregularities within the TUEC
\
training program were found. 'As a result, the QA/QC TRT h'as required
\
, TUEC to provide a third party evaluation of the entire QC inspection
\
training and certification programs. TUEC shall upgrade its program
\
as required by the third party findings. 4 A letter sent to the originator of AQW-18 on August 30, 1984 received no response. 4 3 AQW-69 It is alleged that "eight B&R QC personnel may not have either high school dipolmas or General Education Development (GED) certificates and, therefore, are not qualified to be inspectors." e
. e
-- - -* .% =m e %_e -
eew M m s,_. *
- The TRT found that the Region IV senior resident inspector (SRIC) reviewed the allegation and reported the results in IR 82-10-11 dated December 3, 1982.
The SRIC found that of the eight persons identified by the alleger as notmeetingtheminimumeducatkonrequirements,fivewerefoundto have documents verifying their high school graduation obtained by B&R from their respective schools. The remaining three had GED certificates on file in their personnel jackets. The SRIC found no basis to the allegation. Th 'RT :1:: found ot th TRT ve a series of allegations related to QC inspector qualification and training. The results are included in QA/QC Categor T
,A b9 TheQA/QCTRTr{eviewedthetrainingandcertificationrecordsof102 /
w n < TUEC and B&R QC personnel and found that 20% contained no verification of education and/or past employment and work experience, s ( QC TRT concluded that a violation of B&R procedure CP-QAP-2.1, paragraph 3.1.2 had occurred. The procedure requires verification of Ta[ previous education and experience. , M SER-Categoty g has required B&R and TUEC tew all inspector
~ ~ .
qualifications and in those ins a s where4he inspector does not
,~ %
meet the qualifica requirements, B&R and TUEC shall take act@n to verjif ability of all inspection performed by the unqualified inspectors.
fiihy? d ',Y sf
?,7 - 8-
,?
2 g '
-3 ; ; .f A letter was sent to the AGW-69 alleger on August 30, 1984 with no response.
g' [ 5. Conclusion and Staff Positions: [ (AQW-5) (AQW-19) (AQW-18) (AQW-69) [ The TRT detemined that allegations AQW-5, AQW-19, AQW-18 and AQW-69, covering inadequate QC frispection and certification, will be resolved - by TUEC's response to the QA/QC NSSER Category 5. A0W-17 The TRT detemined that the QC inspector should have been present to verify that the weld seam he had inspected was the one being released.
* /
He.should have verified the seam had remained clean / Based on the
%?
infomation contained in RegionEAR-79-15, Je inspection L - . Q ormed and documented j he TRT can find no safety significance in the QC inspector's actions. { f/) da og.3 rd. < .I O n (,f % hb Nh A0W-11 and A0W-16 ' The TRT found no evidence that the alleger was not trained to perform inspection work on the diesel generator skid. There is no safety significance to this allegation.
- 6. Actions Recuired: None.
7 T- m_NW__ *"M_ s
- j
+: ,.:_ w _. . _,_,.mg,.mmu _ ~ . ,,
W "n f,j , h, } DCP3 - SSER AQW-5 _t Draft 10 a p - 3/18/85 Q
~
SSER
-; I -
_g
\, .
- 1. Allegation Group: Mechanical and Piping Category 27,
*2 -
Unqualified Weld Inspector 4 i T i j 2. Allegation Number: AQW-5,AQW-11,AQW-16,AQW-17,AQW18,AQW-19,
! Y l -.; and AQW-69. ).
N h 3. Characterization: It 's alleged that:
~1 j g (a) (AQW-5andAQW Weld inspectors were not qualified .
j } (b) T1& WW (AQW 11 and AQW-16) Vendor welds on diesel generator, inspected by
-4 ) I an unqualified individual.
k w pr ecWMC s&l m *## f lj ( (c) (AQW-17) Improper release 3 of hold point, ayA OC DA#N' (d) (AQW-18) EBASCO inspectors did not properly inspect welds.
] 1 (e) (AQW-69) Inspectors did not have proper educational backgrounds.
i j 4. Assessment of Safety Significance: ItcA(ARephat: .k A &-f fW!ffjj $ - t 9 44 w 10 A -5 "We linsp c s no lualifi .
@ All f'UIN #
A _ "P 1 spes occo ed du - Th TRT Tvuud R.:t
'* * *T' s Q g gpf*1 e QA/QC TRT reviewed a series of allegations j related to QC inspector qualification and training. The results are h
i; included in QA/QC Category 4. H, 1 a ' KD y J F0lA-85-59 q_ m #/
l 1 1 i .' . g
,LN.'D e
e C -49 (a. -
... . -- . _ _~_ ___.,- _ ._..__._.._. _ . _ . . _ _ _ + 1 E -- . _ _ . - . . ...
g . 7 N a . . . s' .. . . . - ... ~ . - - - ... . - -
-b , >
de w.- - . + + - me -* . - = . ww-e ....m...... _. . , . ..p A- ,
-ee e. e ehes ums w. e w - , , , , .,,.,,,.,p , ,
*c m .
* = * - . mwomem .oo ..,e w j * ~ * * * -M w - r 4+w -i f ll
_ _ .Too . 4u.zou srwo arue way so
; ... .lA).lW MS6n _I. Al 40 59vMG t NS PM
~ 0^26 l AL.usGAT1 w ccDC W ed w M 140 i Mo m
. . . ._ .M _M40_ C.M f/[A>J. W VT)
% . oat o MiqNA mfd \ NCPGotw w w wM 0M N .
O ott) & 0tL6 ..O< % (34sc ist fA-os M , Y g I O e
+W=e $ k es)E - s *9
. a .e h ;, h &D '- **' **.. "
6 % 9 &'[ 4 3- h y*d , 4 On g ,h ' fg m','j g , p w Q,
'(
= g 3 : v3 .. b ._,*i ~ a h' ' .:
~~ 2 ~ -
s .. W (s.-(* l' - 1X, ,aN The TRT found.that the training and certification g[amfor ASME welders ~ adequate. The QA/QC TRT also fo a lack of program- ~ Q # ~# y, / matic control in the no -AMSE training a Vcertification program to
' assure that the program was ac e ng and maintaining requirements as set forth in 10 CFR 50, endix B. e SSER Category 4 has required B&R and TUEC to rovide a third party evalua on of the entire QC
\
inspect training and certification programs. B&RN d TUEC shall rade their programs as required by the third party findin ss
~
- During telephone conversations on August 30, 1984-and.0ctober 29,
. 1984, the alleger of AQW-5 declined to have further discussions with the TRT. A letter sent to the originator of allegat{on AQW-19 on
~
l August 30, 1984 received no response.
- :.)), -
l ^
":)
3py yht WW 0 L $ AQW AQW-16 - t ... .
.1 ll
- In 1982, the alleger was told to inspect certain vendor welds on a
{ diesel generator skid. h told % supervisor did not feel
" confident or qualified" to inspect the welds.~ _
stated that % I was told to do the work or "go home". _. - [ , I)h)b _ m
- The TRT learned that the inspection was part of a p gram to evaluate E$.y the welding on a vendor furnished diesel generator skid... ,.
'S.5
~
. . .g 4
^ g**? .m.- X- NCR-M-80-0009 had been prepared on July 17. 1980 to cover;the1 apparent
% yp%K :; . v; ,
4
# Nailure of.the vendor.t D abricate"the skids'3 . fi,jp Q g:.uy;.
Lto the ASME h%Y NF.K;VAQ.. l%$2h,']:V W. :.* .?..'
- :.Qf,t"Thi.3 R*.
3 Y 3: .- T.'. in%df}.7 3 ~' requirements. The! disposition of the' NCR stated in p#%W d
'wf %, ..? , .
- v. a ar
$ 6 %: . - fabrication records haV(EsGWe'been examined.and there is
[ f
*y@ .
..R M.
$ < T%? ^y"-
y-
; * ' , documentation to claim NF. *W b -
. q. ..
l' i kif S.&,$N4?A w.,[-;;%t M:f,fh?ff.: O;d.'" , e . , l WW, IR?lNisSa . . b O.:. ,as.Q;f.' r,
9tg .
*' t y:t y
' equivalency. A program hid beem developed, however, to qualify the and the AISC Manual of support and skid fabrication to AWS D1.1-1975 !
I j
.- Steel Construction, Seventh Edition." TUSI Procedure CP-QP11.11 was l
' ' prepared to cover the reinspection progr k
f Paragraph 3.5 of the procedure provided instructions for conducting a s* visual inspection of the welds. The alleger was qualified as an AWS D1.1 visual weld inspector and was The TRT can find no being asked to inspect welds to the same code. evidence that the alleger was unqualified to perform the inspection. lf G - Mech ical and Piping Category 1 (AW-30) (AQW-24) covered the ~ b pai on
.e diesel gerator / skids. e.TRT stated y
resu ing weld 132-00581 an -8 00902 by r is n were in e SER hat NCRs
]k because I rap both Unf 2 auxili ry sup art skid r ispos oned to of additio al base metal 1 r indicatic
~
, e er TXX-4095, dated January 10, 1984, advised the HRC that i the skids would be scrapped and replacements fabricated at the job It site. .. - , , . ampj- --
i r< c =c.<,
.h v W AQW-11:and 2/- .3 -
74mw er, , w~ tor A meeting was held with the origina of allegations }q
,y . 31: . ' e. y . . Ce a pd9%W4 :
s.. k P,
& AQW-16 'on January 9,1985. The all.eger , continue
- c. ..
unqualifiedtoperform'the r llb f l kf, h _, 4u p w14 4 q q. upra ;&hhSh+p y ' 7
\ . i Y'
i, % ~ . 0.%% *
,d$.2:: ' , . ..' :% +
. wc T. # - ^ V3.~-
g ..
-i
~ - - - - - - , . . , _ _ _ _ _
t 3 . ~= ' ,: ;$m P,- e J
), 3f43 g5, 1
m -y% a es i b . p% p (JM*% A4 & 5 avv cc usW I W 'G\ l cy& C' 'weex" yMw rows'*' ~ 1 l gf W '
,p 6 WI h } i r sW ,. ""' a#
k alW # W'
.a ps & ggsp h ()w W a
e oaca # k W rpAA)U, 5
? uj @ l #
19 W# v s 1 pie a es & e 3 g ,y j. y *4 3 . - t 4 : ,. -
]
. rp;4's . 'k.e;.< :)isCJc *:0 2i*..
', y?. .~ . . . .
-l
?l <
. : ? - s. - -- .- ; 31.~ ,r . iJ, il 4
q s p . M 1 k, j . ( . t
] ~ . . - - = .
0 . 5. .. 4 m 1, . ... T
'sh i'.A "9
, *w. g .
4 d l5 "w su
![ I'i> '.Ya%.%'Of ry',,j Mf%%.@Tigg gzgMyspg* gMMWMS,)$Qs ** ' J'? ' < e.' . i'
4
.? ,
W w:x
._.../
$t.- . . .
.r -
. . g
.s' .
.g: -
=..,... . .
.I .
-r
. . -+. *.
- g t .i . ._. p .
.e,.
.f .
.. i w
.i
. ,*a ,
f.* #,' s "; s Q %'[ T i ,* U , ,, @
- I. .. s '"
I
..S.
' , . , +' '
; ' .'r ' . * * * ' ' .. ;.W ' 4? , .; 4
'.J.'" e....*. . '. 3
- .-)
r . 1
. ( *' . . .M . 6 ' T. _ *.h M O -1 D - D 'd *. e ' Y*d . - " *
'Y' h .
n .. [J
^
DU.VO % . b .$ O. J M ' *< N b8 h 'M e
* . b4 E ,' b* .
d [ .5 % . , ,, . * * -
*** 1* . .) .
e
*k. A , k ' . I [* %*
- om .% 9% *-* **m. s d
y
. % .mM.. .3 .O}$ p g% t . _ N.M c. _ . . . P. ' ..
s x!. i
's . -
p' ' N *
- i.* ,,Q .t. M.b '- Q t.g,. -
d..a . \'s.
#I**
r $ '*. .a ~a N. .'=. ,, s. 4 t [' 'N., 'a " ' h < s.~%*>-I g ' * -4T '.* M *&t. - .**P--..J *
.s.. U . .- 4* v.
- 9 y
!n d i g s r a *
..a. . %' r 3 j
uV %. _ *k%.dV #~,_h Q I r s =*
- .'.p
.h. .._ h4 . .A j '. ..
) v.i s'
=r .s d . .'~. ..e. .. .
.'" W.**t*, *. I*.' M." ?. t. 3.r.d, ,,'.,*;E%T* %.,(d. h. .M,' N. D $ *'Q '
. q~ t.0 '.. ' t.'s 3 h
.k .
%,,, 4* *=
;h'
.q . ' W .* Y , *a .A. k .'_ .? t' s , . .' .Z.y_Q,;,W.. e , . u_n f_ M...~.
.o Y, , ; %. _. W* .}
S , y , - Ar ,
- g. .3 e, .;,'.:_.. v. ,g .
.g - :; q (* 4, y 9,.2 ,--
A
*.o .%
'.L W . ,,, , t e . ,a *2 ,;
m* y #' .T = ,[,.: ., g* , g . .y * . , Q f % :." .' .2 -% , Y. I * ' ' .*'.!'T N'.
- T* h, ,'V N- *
- s '*
- c.
s i.a T c.N -; ..v,.2 v. .-g : ' e
- J.,o e 9 N t .q, .,- . ..
- A
. t'.,,,,.o '- ?.%
.%m r '.%.'>
.*
- W M.
- Zp*:..h**.'. y Q q . .'W 3 *Q % '. * ~
1 T' l ., l
. gA N,* * '*O '.N _
mg -.*. *, ,* 8.N *
*. I en,s ,A '
l *h st-l
.,p rs .x -
e e.
.a.- -
- .. . -~
3~; . .
- .~ :, x: . t , _.
,.: . ! . r,,
- s. . ,n
.x..- .
j w % '; . - =
.h ..v. *. ,. S **
! i, 1, ,e.. lI
.,g.
,.m
's g
-a %=
g 1*
,s
- w ~~~
i f. s .e.... ... . _. - s.. 9 G'.> . , 9.* t e G* l as-9
,, e m. . . . _---e m e m -g.a-sh4 * * " * **F"" ' ' * ' ' " **" '* ~ " ~ " * '
\
~ ,.
".3 " ~U'LY.Wdh L ' k ", -=4 s-.
. . - - g.. -,=.p,-.
. , e-.g.p-- . . . ,* . , ,,. - .. ' -@ w p ii n 3 .f ., y-.,* -
.a, g. ,b.g .,.* I ....I "[ I . . .
.1 S $ ske 1S=*g$.Lar %tae".%. .%. A,s ,ws n +a.-e a=4:, , ,:, ,~K ' ,2 s : W.' - J.,,.k,- % W.' '- %%.'& :- ' ~ ;> v u.sk.e, skJ.W ~.'.,*'s *% .2 ': W
. = - . -. -
.- -. , _ ~ . .
6 j . n n 4.s 9:i.. A $1 QLo -l]
\ Tr is accca.sc ww a Gc avus-ereit
~
- (25.t.6 M G- O no cc6suuucnf Mec o Potur on 3 h FU6-L 900L L IM Gel- t,U 6<-4 e,a / vtlov 7"(Mutestru IWG" W NCC6 $$ I NSf6C*I10$.)y V"H6 19 LLC &r6fl 5 -. .. ._ A LSO (L A.g yyy 60 71 % gy 6< e g))sGd FCC 4 OMG
'$ st
) 540 W W 04W)iM & . M iMr M- se.1 M iL,G- T*M G-g s
Y + $U 6'LC s&J M b 0-8 HCr /V1 h66'o . _ . .
' k hs(om.s _W n,$pgcrort.. l4 n C /nl005 T/6n-704 i
h . - - - - , W -) l.A 5 f* W CMo sQWO Wert%64 &{ $4 UC/ttsfef
- . - . . . - . . ---. . lW I$ '")9 1.C.64stFC TM ,14~)%
2 Ac.t. ort,ctn e'
. . - - - . . . W_M _. ll$*490R._13 . k .0.. . / A,?fS66Y'D!% t,0C to LG 5 .
f,4*. b M i A s4 f.JsVttVI. 4,1 6t.,0 $L W. . M T"044- IL C
- q. . . - . . . , , , ..
%. _ _.d@l-( d[ _. _. @ ___.Md01 7/ W N
. - . -- - -- -. =A bfMA . C.*0 0.2 L'*. .. Of _ W ._. $Y%49 00$$ [T1556t*
M
. . . . . . . - - _ . . ' lIN N ._ Sk W W-t%t > . .YflAQ LPQW A?*t- $tt WWM .
. . _ . . . . . .((?Y . $M/A!WS_ .3W W%
- . -. ._ A ctouamy m coyome rp6 sm ,eru- rsse k
? .
. . -. . Art . Au reenw. . Ar- n m ms-/ s sw
. -.. . . - . _ . _pC JNffde@ Weot4,4,f Musf. W 7:sd . _
,o
\ _ .
ffC.A? *>""~ 0" . M /DS/M Mo< '*<- W h . 7ML- W6LO M . Fert #<wt2"&t cosxx, {Z;L> h N W6 #N f y JI66 M 5+t- CP'J4f-6 s@toidif Ak c /J e e w A $t s '$9$c= 0 W /NffMyt- t,4y,g,,, .xfdM W W )$ 0 / P f/ W /l- M N'At<,/d /}/A l 0$ A-
- a.
- !q..
.i
*I
'8S E M4 dMbbMeth %3MM'ka11.N1.c4h.M F9MEmsMLSNsYdXMb55NUJyBaWMD/teMNdba/Ob Nh. ;h
~
.A gas.s 4% { dAQC3t' d*
'J i . . ,
,1 .
',.i
.a.
4
)
I et
- - - - - - - - . - - - - - - ~ - -
g.,;, -- .-
%- -~ .
. ' .,j Qa 'u . . ,
*:,y ' . . _ u . . _ . , .. .
,) i ~ . _ . , L. ,,
p.:* e > - %' . p~'. . O N ,.#g *.,f.,..'
,.*'v, - - * .*
, . 4 . 1
} ..
s=} . R-:% s
~sW..*:_*f R ', ~. = f~ _
,. ~ . '.. . .
.1 9 . . .. .. t.. ..
..r :. . . . . ~ . :a J -.. . * . . ,
,.. .~,. ..
n.. .. 7 ... .. -;,,- 4 . .., . . . .g ;. - .,n
-5
'. 4
.[ , g .m s S.g -*
T.
.'.~ ..* , ,
e ..
- 4,
- s. . .
.s .; . m .
, s .
.M w. , ,' , .-
,WJ.. : .s.S voi .NN .%. 3 . . i.* ' . . .". ..: . ..g. C. r-: . ;p r \ .
1 s. ~
'?.D k'.*#d O.? '.k t i
5 s, P. ; *W , t*.*D f .\'
.4
? T. ,
$o *':<*a' N._.t k
.<% .' _h\_*.M.g_2_*d_ ' 4- .h [\. _ ._- W @ W. , .4 t.%#,.' ** .*A * *. M a . ,-. 5 '.
~. ..
- n< <
' . ' .> . k' $@lh*>,_ , .'.htN N'C'J,%3( , . .Mk _,_ ' . 'R-.N.'
~
d t . O ~ D l'#,',%., - 1 T, .0 . W.s-7'e -M - 6 '. s h *, w -4 h ...[v, A tet i'.: . ? . k --- .
- s. .
A.
~< }
w b.) QQG. . , .
*,s 6
.%.y M,. y .3 *-L%, * . .~.. s.
- S , . G n
-r . v'
\, _ . . - ..- ',
./.. ._...'s'... . , .. .
.+. i -
.- - *; rp I , . 4 y.; . -. , . - - *-.c- ~. -
.j -
--_u_,., -
**'e , .f ,
w:.
* ~ **
M, , b.,,, ,. #.* . T- - y .,
.1 ....-,___._._.= , .g ..g.~..,e. .. . . . ..
,e p. .s= e
. e ,,
e 3$,-
.P ,t 4
. . - .y. . , . _ - - . .
}q . -?. ' . :.
-D' e m .W. - se eb e45 .ebe,em M-2
.3 - - ^ . , - e . t S
.'w
,g . . . . . . .
.s.
9 . . : . .. . .d)' .
- -n. . . . .
es g h.
+q.. . ..
.=f
's 7.
Y
.i k
.g
.*o
[ . i .=, , w- hm ,m-e w ee em-* eAa
- g.y>
g,.4
. .%p
.. A .N'W...-W*:"i'- T, e,'
- --...., e ...->:..s -.c.. . .-
,, o* .&_5s _ . '****'c'-r. .,
> &&W$
$'". 7
YO# W%h,b w 4Y .}N. ame . . e* &.'eEA *&;f
* 'A'.% WA, . . . - - N I N * ' U N b '#*
***A W *'*' '
*%' 6 '
'f
- n ~ nm. , m - - --mm _ _ =. . -c m-xs :-- x .: . _ . . .- . -
.a s
t
?
,3 o
. e4'*:
p. b J 0 G h & 91 W M4 /A. / W ffff W/4/M YMC wo%d l'& a M 7W renn NALC 4ddz' N .
./ M fford!2 #pse CC vA 6 rAhu' W - Yht' YW C4Hl;l?/t.4 a,a/ 7>@- 77)./J w&J!stAtJth YMd' a
h W /f 1454&fl4L/N6 M QA /Mff/WW
. .. _ . . f f~ Y' W W hh Ws ku - -- .-- . . .. _.. -- -- -. YW. . N - N O*- YMM A#*4 8 .. ..M MN - dV/M
.h -.-.
- kMGWGA'S ..W 6bd A st.)G;6d/W4 w/ 7~ Yow 4
}A - - . . . - - .
., W3M: OGNN6. W /NC7'73 MAL!~7'nt) dt '7)*6 b A' & r
',9 W A+16.- 65fNG /7)ht<75 yes AMfstes se <, $. 34 ' 5. - - - - - . . . - . _. . .. .
't h
- .1
. - . . - _ . /W W M ._ N/ Y .-.7H6..M M % .,
p . - .
- ' , . .y T m
~
. N, ~ cRr.
N.
=.--_ -
^4 y
. x. , ~,e .:
9-
.s D _--, _
kT n ', 4 ,. ' ,A ,, 7 , 'h
^
*....,,-~1**
4). y ~. . . . . . - - - - Tb
- 2. ,, . _ . . _ . . _ . _ __. _ _ . . . . _ . _ . - . . . _ _ . _ - . . _ _ . _ . . . . - - --
/ '
.P<
' C' , l .
..e 4%
y [
.l .- . . - . . - . -~. .. - - . .._ _ . .-. .. .
I."h W .*%;.s . . .
' lA 9".,
. '4 . .
.$, . *h :
g s s 4' 4 .
/~
$h # M - 9 "b,rd S. wesais47"%sG's,4sh e45ObME,4Mke.,s.shuQ.hW31 i.4*dMUE*m.?.3LQWJ tei,{KKEE.I4Ji}.{.'Jil.W ~
.s :
% NAQW-17 It is alleged that a QC inspector bought off a seam before he- i
( ,, ges.or-wevs en ;
\ eve w the seam and it was not a good weld because water was coming throu while the weld was being made.
d The TRT rev1 ed a Region IV investigation of the allegation a reported in IR 9-15 dated July 2, 1979. The report identi es the j welding as part o the installation of the stainless ste liners in il the Unit I reactor c ntainment building or in the c on fuel handling
?
building. j he TR rev,tewed thp s h t y 1de c1 o tb@er__ _.
- s pHor t 1 ding.
a j
~
The report stated that the rea or r ident "W y
/[br ector discussed the e !l f allegation with the QC inspectornvolv . According to the inspector the seam in question had been7eviewed for cleanliness and weld fitup f and documented. pieceof/apehadbeenplakdovertheseam.
[ 0 j B&R procedure CCP-38, ainless Steel Liner Erectio identifies the
.1 .y cleanliness and fit QC hold point as item 5 in parag ph 3.4.1. The 1 I S 4
hold point is alsar/ identified on B&R stainless steel line inspection
/ traveler. /d
- ,) HAM W The QC in pector gave authorization on the telephone to another
._ L d~
.i
[ inspec or to release the hold point and allow the next step in the ins allation process to proceed. W a
*;. ~
4
.]2 :;w; m a ga; w n m.acu on:... pap 9 m g u qa.:.a4.u w y.y9 4 a u;5;
VuQ wu wq
- n=#'s a , , g agg y , j , ,... , ._
m %M.m. PO' ( e v . i
' nw
. #g s Y b
; e .
a n 1 n 4 S h 1 I t
"M c 'f 7
4 I
?
4 e/s r d
; 34 2
4 9 t ,
<J k%J ;46%linfinsliQ{,{d M?Q;f;5.;Qi3Gsfj.,,j,.j];;.] ,_j;,, . ,,g .
.fiMMI5Er"is5Addel+b . ,
a 3' . u l'l q , The RT determined that the QC inspector should have been resent to
, fq.ue ;1 , verify hat the weld seam he had inspected was the sa one being k m
1
, released. He should also have verified the seam d remain.ed clean.
; I F
, Based on the nfomation contained in Region IR 79-15, the ,.J l
i p inspection had en perforred and documen d. 2 eTCpC
; The TRT also detennine that B&R p cedure CCP-38 provided adequate j
instructions for inspecti th cleanliness of the liner plates. k TRT can find no safety sign cance in the QC inspector's actions. , 1 i s The TRT is referring he QA implica on of the allegation to the TRT , l 1
/ QA/QC. $G&-
p) i 3
$ g Allegation -42 of Mechanical / Piping Category 3 describes the TRT 4 V' evaluati of allegations that poor welding condi ons existed during 3 the i ta11ation of the liners. ? .~
2
$ fforts are being made to arrange a meeting with the allege .
.2 J M Q ,; The alleger stated th EBAS inspectors often si off inspections of welding from the floor vel when the welder i 15 feet or more a f above.
.e 1
( d' '
\
2 6 3
.d v ?,1 d.NidbaAiGC,654LiJAZJiLis.o26WMGMged?d;;,4;,o.g;.: 24gg ga43,;,,A,44,_c g;,g,,h;a;_jgg
-m m wsv:,.,av_ m .a-- m _ d . . 1 , 4 a a 9 _
~
{, f(4M[. b (., N ( 1, 6wsM@'~ 3e ll&r
^
Occum W Y OowR 4<L g s/0 *
~
~
g mw a w a Oitcustw petsws - e
. :f-m
$i a .
, =g 4
I* g s L b . 9 M
.,5 T
6 6 be
'[1
'ki s
+
e U GJ, 5%m p f M
.%= , ,
'h se E
-; r, bMN6Ms+hMAWdNUV.dhAJ.ACC,MJiQd}L-l4ggp]L,ms.:igs1,6. ,g,4;;g,;;,,g,,,
4 l t . . . 1 i
. o .
/ 's
,t ,
i v
. ?:~. - . ~.-- . ~_,,,-
s .
. 4 .:. .
.sx,
.(._ , .. . . -
j >
-4 G . .2 k'-gx W .i *.R.'~13.Jv.*. E.2.>[_. o '
~:'
c
.T . .. w. .e. m . .. . . /.: *
. c..w... .d.4 . ,_.e o _ .s..* .
- r. * ..
.,e- . *:-,
~
2 . -
. s.. .,.s---.,s.8.,.
=*I'".*.L' .'
- p
. . . s ., _ r . ,,-t, : , .
, .* ,a
.. s- ._. .
---b.-+ - .
[ D IG " I O'
- f. . ,* x ', g n * ,.
.'..'..i - - * *.. F .' ,s .
--.1 .
" ,'k % .. y .ps,; . v*
S. s
, q .r .- . ~ ,c.
. 3
-.o .. .
.o,
.=,.. . ..,.
..+ '
*. Q
/7, ', ; \ ' ,,*
- l r
c, * %'= $. . . f.' M i #. ' a. ' D I',Q ry, . ,- ?. r *, ,, i .] I
,n s e
?._..3 ". .~i h ;c %
~4QI- .'.%,
t637 --'.%*.'*,e. .-.u G. ?. . . t . . S. .* *.
- B e
'Nss "c . ' 't..- 71.M
. - -[ 'c*. '.'s' . .J.h &W G .-.(.. . __yM'.. s. .*/~ %
. * ?. . , ._ .' 1 s. a., .. 1' 3 9
fI.J t . 3.' .N ~k.1' A'-M4 Mt),3Ob h. - NT *l'_S . - . E < *i 2 *. "l 3* " i
. m ., y p
. }. * - *
. +v.b. ..
he 4 <J-
.. . .t), . . e 3 4au. o n L.
a
. ..,,...m a
..y
.T c... t. ~ ..-
~
's.- ..s. . .
% . .- s . .
p;
; . w ,.
.s., *
.. . .f,
.T. %., . '.A>- y p.
4 $
, . - w
.e....
, s
. ; . s. . -.
t,. e-
,g.,_..a ..%.
.. . .. i + ,- . .- .
. ' ' 'J T o ; .' *' '
.*if ' ,3 - . , . .E A.,' , ,, ,.
2 - [' ,. L ..
~ . -.
~ , .. . . - . .
,n.,=-.. . .a ..
. .wa.
.. .s..p.
. . , s.
- e.
u~ y
.__w,.,-e.,........
n .. :.. d . g, ,. , . ; ,t 6 e.
.6' ,
.<.- c-
~ -
. - r .- , . -
t s P ' t, a,.* '. c e. .i e . : s g ,i .yu. a
] .. t. ,. . .
- x. .
.. . .., . +, . s.
... n .
.x .2 2
.. ; * .. .. e. - .
,a f 3, ,
! 's
\
s v' 5
, . .s ,r. . -
=."*'4 '. ==
, . ' , . , , , t .
- a.
._ f. . , .~ ' , . 3 _
>. %'_.,,.~< U. .
t '.,6 -, . , , - 3',
.y , - - - - y.. -
-www-i m s 3 ' -
,, F- -
V','W e#" -*8 " T E 8,' e * * , m .__, p p S 3.),fa . .th .. .b'h . .-
- A eA. a h dI5. 4 "
' N-
' *' 7* '
,;i, L ,.. '- - 3.c g .,.- - - - , - - - _ _ _ . m .. me c_ , , ,m ye_ _ _. ._ _ __._,; g; , -
m l e a
.+
1%@u2 - I 8 @
'T W iv ces 04- s m W Cenec no tos erores cc:rew sia n -or-e s uspr-ezr os CG e.2 G1 D Ih 4 W 7%5~ f*-l.00tt. ( so01 e,o %d-ro
- "TN6 cvG4-o Of2.f /w4 ,,o ortac, A>o tC p:qnpr- cyt m ort.G psev& %,
v . - 'TW6 Tr>5c N U)^'t Topdrtotior't. reco W u . --. - .. -. W ... M.- $6Mt O.' . IviP&CTLow (b'st.4 ovvW6C g.o 0+t 6- )5 .
.----... 9 otoyan . ,s y . ru sc ,-v pre 1m ru m os ems oe..At*,vr._(6o P)_ usp-Myn6 ivcpsenau wert.s:i G . . ~
y . - . . ..TuSC Ate coeurw . Cp I ~ Cp P -1 I . 2.1 - t (flooai>eorerenri
?
.m'
. pow atcu,s e. .wsowe.rw s) is nurvems mac.ssex
' ~
! .hw__ fut4Vs C04-S_.I10.5 7~ tLocTI do'! fest. (M11.46!2+*t t UG
? .
(/ lit)R. LUM _INipsc-TTad . c(- d c[ t.uc4AC, , 79,f. ,.
+ 6tocdo r.M& -pSS c ru t$ Gd ... ) o _06-Tos s t- TNG o4cceprnet4 W
H . .. . . . .. .
.~
.-------. ' LhNC$5"$ONL..Dh. . . {&h$*C Q1\hl0 $.h , LQh*( fD hh h h-k - . - . M cow Fst.owrwu MJo .ovuse canstsn.crsnurzc.r x --.....o' rue wm es1na e n snc er<.a o w urcs ,, u c 7- ( m- A. et ot & (Mrs**se-pg)b -
W - vISvM iMikmLA4d 64aT146 iNfPCC%'ott. o
.: rye rose- v2 "<-
ys 7 ruotyee
- . . .hta& 70 tM i F .
tac 4 50 t m Grto nt 'S f .-
.. ... . ...M l'O.6C _ T~rtMHUIN& TUPtMAf0fL yo Lp %
l . M2Y T3 W r* f 6 M to u ySpscon., porttowo5s wan5-4K'*%I N6!) & M) C Gwrif-t GM iu 7%4 [,4 tvt 5 aM MM- j M s4. U90 T~bM M 9L oycf.6 o YN 6- (20$ut.t-1 01 4- vttr G A/oc 0ytov4 (but sw <:8. v*s- tucr-e
- vtt,w u tv<- Ato4x*m os (2cygm no q A/pc - .n 64e44,o q Y, Acpttfrt- $GA.ir Tt, -r%5- e rt./(,tio+ vert o# . ,4ue(ATt* -
a.<,w-1e ou 40ousr- 5o,1wt acisuon no ,eowaasi f w. x - a un_ . ,_.,, _ . , _ , , ,a
a
- b. -
The TRT determined the EBASCO inspectors were employed by TUEC to
,. prihrily do balance of plant non-ASME inspection work. Th BASCO person 1 were trained and certified in the same manner s a new TUEC 1 -inspector.
,9 .{ TheTRT,tjerefor reviewebtige TUEC tr ni g program to determine if controls existed to
/ / imp \ roper ins ction.
vent W'
. L/
t v i.' The TRT found that the QA/ TRT r viewed a series of allegations A '- h related to QC inspector quali ation and training. The results are included in QA/QC Category . E d During the QA/QC revi a number of ir gularities wi hin the TUEC O / \ training hrogram w e f'dund. -a\ 1 2 d-
;(s/ X As a/resNYt,e QA/Q TRT has /equired 7, EC to ro de . thir/ \ d pa y-evaluat on e eftire QC inspection h /
/ TUEC shal upgrade itsl program l,} tra in and. e tification p ogry/
as requi by th dd party findings.
, A1 ter sent to the originator of AQW-18 on August 30,19 received y
response.
- {
1 AQW-69
. It is alleged that "eight B&R QC personnel may not have either high school dipolmas or General Education Development (GED) certificates and, therefore, are not qualified to be inspectors."
O
.n.--,n. -- + --,,g .. -g
.1 4 ~. . .
4 i a The TRT found that the Region IV senior resident inspector (SRIC) k reviewed the allegation and reported the results in IR 82-10-11 dated
; December 3, 1982. ,f The SRIC found that of the eight persons identified by the alleger as not meeting the minimum education requirements, five were found to ] have documents verifying their high school graduation obtained by B&R h from their respective schools. The remaining three had GED certificates 2
i on file in their personnel jackets. The SRIC found no basis to the 4 W allegation. M w d d.,r "f g T ttX ~ @ N8 N TM TT,7.Lv Twund Jmi. .... e/QC T^J reviewed a series of allegations
^
4 i related to QC inspector qualification and training. The results are
@ included in QA/QC Category 4.
r g . 4 a l T b A/QC TRT reviewed the training and certification records of ,102 1 - TUEC an R QC
- g. \ personnel and found that 20% contained no .
j verification g of education ahd or past employment and work experience l. /
?.. . ,
d The QA/QC TRT concluded that a violation ofcedure B&RCP-QAP-2.1, pro / 1 paragraph 3.1.2 had occurre The procedure ,re' quires verification of i ., an applicants previous education an experbnce. 3 U The SSER Category 4 has requir B&R and TUE to review all inspector qualifications and in thos'e instances where the inspector does not
\
l
;' meet the qualificatJon/ requirements, B&R and TUEC shal ake action to c2 ( verify the acceptability of all inspection perfomed by the unqualified y inspectors.
ae
.m
$de1 N b's .A L .uL. s Y'w> t.1 h asY K.E ' a !f.bN '& ' $
o.JY & 's l&'&*)i ' $&hjyj jY), 2.he 26.&p y, . _ , ',
v _ . . . _ _ . g s 4 P' N.i ki n f^ QW - f'
. ' TIM (
c t v Sc &W e i
/ /
$ lf Y ' j i
' %l- N
~
lU (, M, b E e.$
.i
'1
'N n
e e m s 74%*.# g
+. ,4 e-1 1 .
a. v e d
-1 p. . .Y m
3 W tw c. 5 w#
-l .
. .t dj
- v. .
i' i.1 e al
/
4 w i
*q
.71
' 1 1.
Gs.,5GkM.eGsahav v e .dsa.'..stGda -,'n , hOu *.ec.1%. a , % w Gs;;.u- .. :.. ..;u '. 4 s' . x.- . slug.wa, a.a,..r. . < , .: . ..
r y p A' letter' was sent to the AQW-69 alleger on August 30, 1984 with'no
. response. -
i l l S. Conclusion and Staff Positions: (AQW-5)(AQW-19)(AQW-18)(AQW-69) The TRT determined that allegations AQW-5, AQW-19, AQW-18 and AQW-69, covering inedecuate QC inspection and certification, will be resolved by TUEC's response to the QA/QC W SSER Category 5. i AQW-17 . The TRT detennined. that the QC inspector should have been present to
; verify that the wel,d seam he had inspected was the one being releaseddp48 .",7
([. He rheMd have :ri'*ed the : -- "d e-?%:d 010:n. h:ed :- +5e %wd") gy (. g , ,. j p,e_. u - - --
' in Region tv in is-15, 0.c ir.:;::: tier h:d beer.
l ';v - 'ng (4 \
- MW 60V 6 perfor=d =ad dec..n% ied. ThevnWG TRT canMn06- A- ruwww find no safety significarce % in Qt P" rte. ws4d 1**"> @ IteC0ad C.c4**3
- IM g vot
.,df- the QC inspecto actions.
nu AQW-11 and AQW-16
,t. The TRT.found no evidence that'the alleger was not trained to perfonn a-
- inspection work on the diesel generator skid. There is.no safety p'. . ,
significance to this allegation. .g,- %,,. ,_
.'T- l ,
'5. ;- Q,i.y .f.t. . ,ff t , ,
'D, . .
. Actions Required: None.
Q,.fqfsy,'M ."
; .J 6. < -l 3 (,t.- i qi d to
, .y; -
],g.4 y.yp '
. . - r y
- p?'r [
~ .
. a s
$ Y. " ..A~l d 'f, ,
t* I-n'** lg . = , , &-
J . a: .
~
?
- 9-i l
I [ Attachments: None.
\y 8. l
. l F
- 9. Reference Documents:
3
- 1. ANSI N45.2.6-1978.
A 2. TUGC0 Procedure QI-QP-11.21-1. t p 3. NUREG 1.2.6.
? 4. TUGC0 Procedure CP-QP-11.21.
t
) 1
- 5. B&R Procedure TCP-1.
f 6. TUGC0 Procedure QI-QP-2.1-19. 9 l 7. B&R Procedure QI-QAP-2.1-5. i. 0 4
- 8. TUGC0 Procedure CP-QP2.1.
- 9. B&R Procedure CP-QAP-2.1.
4
$ 10. B&R ISO BRP-CT-1-SB-019, Rev. 6.
3 il 11. NRC IR 79-15.
- 4 C 12. NRC IR-82-10 and IR-82-11.
4 C 3 y y 10. This statement prepared by: 5 R. Hubbard Date TRT Technical Reviewer 3 i:, v.'
't .
'; Reviewed by: !T L. Shao Date N Group Leader \w i9 k Approved by: V. Noonan Date l:f: Project Director
.h
' L A.eehnm. M w t. A . m % .e u suw .am*&.wi.unwwwie s - . gwA, u;;.mu.;.;;.4 in'ia+ m w ar. m.ra
- s. wi. c 3. w n; c..a. ,
~ . , _ . . . . _ - -
R p
., * .. w..
2 h~ . , ~ P 1 p- ,l C.
% yp3 SSM A*
~
K () W
?! . .
E,
' 9
- Ss&rl
%w
.la kLC664TIdA) $rteop:ygcintck t! ftpt& C (W} Z.7 h
w L)h COMlGI0'C IU 4 +C I USP6-(AD M
,.a 2
y 2, A<essonw %su s Acow -C, ytow-t I, 40cv -lG,
- . . . . . . .-. .. -. MU) ~l 7, A GLU -l 8, A QW -l 9 w0 A OW - 69 e -
g_ ..,. - . -.. .
^
. . . . ..b* .
Gis m isa=nors f- . . . . . . . . . . . -. :-;.... L. 7~. 1 S . ML &6 6 0 YW; n.
. . . .. . . . - . ....-(0b(}$ QU) ~S)(AGW ~l9 ) Lu 9( 0 tMS PGc 70 d WW d T . . . . . _ . . - . . - . _ . _ _ . - . ., . . A> oT Q04(,f4i6-0, f
fi (S].._ 5W~~) $ AQl]~l(*) l}H2064 U>&< O5 oV 7"M6
.ht 656(. G 60644rort. u.> Gil.& IyoSPGCt-E'O
{ . .. : ' . lf Gif.%' 'N .. j _ y ' ysu q,op.;pj Sc gy 9;y;yypyc,
.'Y A@tD~l]) IM A20 011 &LGAdE cd Acto RM'I' h . . . . . .-
**h b- ...L. .
fb.h {.#Cth-!&.{6 ASCO I NS PG c>r"0rfd pt D A.20 7
~
frte9dft In)$ PW e,08-4.,0$ . h .
. .-. k 0.. A QW~&4) lM.SP W Q'25 06 O!O tUOT W0
!.i _ ffleP641. ED 0 CAT /0 n)A<-. 64C.C&1200A>0Sr W 1 g
~~
L . - . . . . . . [ 1 t - p9 e'- 1 4 4 . F01A-85-59 i,.
*4
-/5
-_.-._-ww.,.__--
. _ _ _ _ . _.g pg . , , _ . . , . _
. 7__ , _ - ........m. - __ - ....a-
. m.e m_ ._.
T*~f} ?.;f4 M .x.;.
- ~.;~' . '
q.).Q f
] T"' '
4, Q &Ssms,or C+f
- t *.
Zr iS Ancs cc >-w>cr
'ww wtpeeroses ,osr- c o m a cco
~
. 4ea)- s' 1%u)-I 9 " Psois i,utpa erzou crcuiuwe ,,
$uit.wc rx& i6xe<<icir Sko& m .
>:a
.72dr ritr Euwe ryw rs'& GHoc
'- .. . .._. [ /M M[N 8 O #M m .,
5.,B (dscArse ro G)C wiso crst ouwamau
~
. _ .7 M , u l Isvc. w fac ip G4/6C C4rCooky 4',
a soc.caaw -ra-mw lly,. . ..- 7 Aid- coa /dc 7777 Fouvs & rx4
-l%
.-rr25mmGAd conne c'4r7a0 9/z o & m e 1
$u. . .-. . . ...-._
.. fc/L.MneS asc<o* 1 d)M . ActCouG-rs; ,
M. '
. .tn r W6G =* r ptso s=oviw n cx4
%, s. . cF 17wgiemarre
/ cournoc i>v n 5 M .
10op ,4dn16 rtzawhos nw cs /znaroeac fitsdise) cv ASSux6 . raw >-M.6 /2wsm wM /Waistiws m svawrstwc6
.? /Yr-poix4nnx r1 M S G-r* Sett r H ,10 ,co cmta 4#ri ~'
790 SS&L C,ar 4 a s-1 ,ecce.ux ss
' 8/it 6,w rose rv pianos- se. rw-ra
,, fo fy 6u,uu m cue reac- s.or7as"
- W GC nu.ffserzs>v mwss idus cer.rs/wo<a< breems. 4/4
;4 w 7 *u c e S & c a. u s 4,c u s we-x fit 6 ddM-ur .t 4d A6poid&B 99 YA!-e M W-4 t 411sy f w /t4 4 G tj u m a i r w a n e c ~ s crN /d-o ci I Q t G3f' s Ccr 2-7,/ 981/' ws ice.ce n t en sipa) r sea.iw ro
; ye cr737m .,. 7:r:cr .?.wm =m= . , , , :m--
~ ~~&~?5~% *DRs R.f % ,Y "-~ .,' f _M ;g _ < F >
~~
\ *TW$ nrQ [' ?_W6l.Y ' ^ ^ ^ '
~~-tt1E%%929m&A~ ~~~~~ ~~~l 6 ,
; M W '*A"f Q"WJ Sf 'Q [
, ? ? ..
- s :;.% .
- = A'1,, .
.f,i,.$ , * . s
- 7-n . .; ,
xm ,
.w..
...",p[c.,
>j I
Fd
;*- rS ?
Sn'
~
4 c 5- TrC% SSmx q'c ru 6 cruc.m nort- o& AttW
, j .. -
A OuJ ~l 9 cnv Au cr 30, t 9 B Y t%ci 00% ^) o
*, (
...n s'
sy f Q., .
..w i s .A r 4-
- wr 4 me. . .em o. .ame 4 em . e.
. w%
. L.
. ~
-t' 4,. . - - . . -
-4
.[
m.h J'*Aa,%)
-W
, }l . . . . . . . .
, .Q
.n
. ~. ;
,4M _: .
v e- 4 J
^g:y . --. .. .-....-.:-a,
$.k
# ., W - . . .. .. . _ ... .
#,9 .. . ,-._. .
'q-g Q';f .. . . _ . __. _. ** 4- -
L . . . . . . &
.&.. m . -
'l - a
< +9_9
$ ** th '
e;O t '.n.
*.% ... . . . ...e, .. .. .
f
.". 4
~"'
.+
..4, s- ;-
s f. .. . *
'S; ?). bj:j h .3 >
9
..jy.
- - ~
. . .'.? '
a -
*j"",4
*T q .
.v.
.d.
r 0 I t t & O
.- 1 Ib _ . i ts e t - * '
M n' Th&S' M M'dN5.*.k Nb , ***# L 5
- 7
_ C; hetU ll kOfO-l G 1W t 9 B *!- , thb u.ec blk & coyuh M dd 44 eb h
+A q
w.
> P-f]QD>g/ et.- w wpv
>1 A mt " Id w w -? . n e A
' j#7
._.._.. _ _..-_. . M- - J
. . . _ . . -. ._ pi., D l t.MJbb/.* ._.^ W wY s
h $ s Y u) $ ou - bM' _.s' g ._ _. _ _ . . .~ - e. i The TRT learned that the inspection was part of a program to evaluate
'k - , :
i . .,, ; the welding on a vendor f'urnished diesel generators skid. NCR-M-80-0009
- !'-],[ ,j .
had been prepa td.on July 17, 1980 to cover the apparent failure of 1 b
. ---l the vendor to fabricate the skids to the ASME NF requirements. The
).
disposition of the NCR stated in part "The fabrication records have
,1 been examined and there is insufficient documentation to claim NF i equivalency.
'~
A program has been developed, however, to qualify the support and skid fabrication to AWS D1.1-1975 and the AISC Manual of I Steel Construction, Seventh Edition." TUSI Procedure CP-QP11.11 was prepared to provide guidance during the reinspection.
.... ., ~~~~;* ..- . . . . . . . . .
~ * *~ . . .-
gg gp g.. . N A44544 - g/41 90*Lu,A.WC ve"-f # Y "- f;. NS Of.I vs $UAL WM IN5fW W L.l,. . . . Om in+ num wat' Aso, PW y... c& M ~ Got er QW Gek r+- ^ OM') ' w}hEll.-cnm*~ v: .
*m.
.2:
g, . n- . . . . . .
, , , , . , . ,g -. =__-_ y-- -
3 , ;, .
.p,
T . ,
/
[ IC-
'i.
l
~ht6- -[1tX f<>ovo Ax> 9h OG-M E w M N
. LU.Abtst. u)M trJr ritAta.icM 00 (bM M
.'; . I U (() f< MA" U. W C.
Ee (C i fif W& l'.c g g.-atfA. 7" M - 4 09 f , 0 A-tsc J7Hu Io,i T o Y ih 400ts6-o TK6- eit.c M 'rt44 Sf'#S uso M
- i. . . . 8 6- :Sc./ 40pcM.. m 26 puu eiv1&AXS r-% t$17< M
~7t> 6 L rs,-
~
.. A T". c..T P 5 ,.
s j^ ' i h.. Inds;A*M to5r-5 )$6-<-e astvid M cuc iHW euc Act&Gnr~ toot A$a> ~td Aw 40to oN
$g ;
. . .- .. .. . . . ... .KS. 3. e ;l 9 8 C ' ' V14- AUGC'fA C'*%WUOd f0
% ~
1 ..
. ov %tu YMt 0. Y u) $$ 0 0 & U A<.t Gf0*d ,, W f W -
~
.- . .. . l.' .
vid6 I12iA W .-. cod 5iL : l
' ~.
. . - . . . . .. '- . : L -
g J I 5.
~ ~
g
,i 9
.r
. 1 i ,
l " i.; b
'i "l,_. -
Uf si
-...-..~-,
- s. P __ ___
. _. , ._ . . .-. = _- __-w-__.,=,_-=-. --
yd va ger i ..
- g. : ,
? .- l
,. M:i y
.1 f k(D(1) -/ 2
* & /.S / k t:d G 6 d 7Mx}7 A- (?C /Nf/5CrCil
.Y -
/Jou64r c49 A Sd m 4Sfort.& n+ SecM
'hl $4u) Y'NC f & AM /7 w Al W A
.$,55, . 6000 wsus 66cosd 60nrsrl wM c-eni4G W 7~/ptfD w /H c6 v1AG t06<d cuN /36'->A4 MACS, @4 .. 7~#6. 77CZ~ /2dV/d*060 A- (286/0D $
- fk -.
1.tw wA .. .
. .IAlt/GSTt G Ah7~/.0fu Cf 7%'& Attd'6477dN #S /E&At/f70d W
m /AJ !?..?9?/(.C&T60 2-2-99. 7lh5 /26A7/df~
- ?$f
. . .. ./06v77855. v7h5 uJM/A 'd A-S PMtJ~ CF 7W6-Jh.f744,6 Arrow of 7M 3rnfec6ff Sr$5c (w6#1 jh.
/AJ 7W& .O/// 7" /' Wrt c'et.??~A-/D#1&x7~
&. . . . . 80//0/A/S . 6d /N W6. 42frrMJo# fo 66, h % U0 u /'6 ff(l .
. . .. 16 u/Ld//26 . ,
7724~ .f/ 6146<266.. YJ46 /716MDS bki . . . -. . . - . - . . - 7'*N6 . ..h . -.h7]dCh W ft(Mt66 l//().Sf6Crzow e#- M '.;h?.h. . ... d-/X20ft~. 40 5-6 0f.#tr810/2 70 UJC4d/DGi m
.%s
. . 7M42P- 7-N6 N 2:-T v Q.
lc
^7~/J&
,peur f269072.f~ S7375d
' $ /4.7.ShI5 Q~ Oft,. $/$60Jf6*$ W $6&GA7//Al
.$. .$l ,
-S 62 t,p / 7t/ 7N& G C / W r / 6 c 7 c it- t b v'0 4. e 6 *n ,
3? k&ceMM)G 70 7Md thffdcred 7N& S&*G+s1 [ecJ.Qpg /D f66 SY4u) /h%20 dcMX) /fdf//d4354 iCoA-4$.. Ct&Avu4.6if A/>$ to444 4770/ #Xdd DecusGordd. f.) A f/GC6 OG TA#d ,W C dd&x! ft.Mst:7 cyd*t-99 nsJm.
.;kf Wif.fstoc6cdit6- C4'*/-38 , fr/p.wt.6-1f f7004-
,}{f (_,J e dVl-cad c7Mu) / C6v7241GS YN& CtdMcewHf
/4WG ft 72/i" $st' / /d& Ps/.07 Ad /Vfn1 5
/Al h4rt. 3, % /, 7"N' -6 //ccc fosv7' /S A 4 S-c
/ GdW77Cr 96 0N $//2 S r4 sNcs-ff S r 5 6 <-
3'
.,I u,s.- arcm. -, +.,...w.me . . . m .c. . . .. u. . . . . . - mem . - . ,. .., . .s. . . : z. A: - ;an;m=a
' h )*( h *
{fg h' ff ,' -
'. ['
,N1
,2 f *
~ 'A, ,
~
.c,
~ "^
. 774 6 Gc insssercit ese sporporu+4rre>v
.s 70 Art >O r#dd /N.ff M /f- CD 7N6- 724&t>%ffvv0 Yd l0.Y ff6Ld%:fG 7A/6 M0ld #6/AJ7 AWD Atletu TNG u
.?
O &yr S769 /o rM6 /p1rnic4rios Mzo c.srr
, & f/fCCW* '
?5M
'gtf.3 . . .
W p7?T Q&rf**rJP09 W YM6 --- h5 .
. . . . - Q C n u.r # 6 c r o re. S/ Hut.e p 6 nsw p,ce;e r h[
. l-f
. . . . . . .. roheruy mkr rne- wm I uS/6c!t%d al4:1 r#6- FY>w!6 o46 65i44 /?/-te41ft),
s==, we m AL$ . & ft 4 u w e t so A h w & v64t /tr 5*) rN6- f% p,qt.n w - fAj$C- CW 7NCf /A//dA%**fAby*/ ht)
- e$e
. -. s l - - - -
.,--. 558 ~ DFAJM/UM *M
_ano.sm. smes a macusaeaes,
# . /N
/ U ,G / C _ C7%$$ -
$ m a $
/AAJD Ge.gorH' 2 9 / {
- p L.- - e '
y
***eee**6 + ese . e - -.w e,,,,, ,.
. &l60cred .Cc/i38 j/ary/Md MW instniard
'4:h v% .. ... . /*b d iN3/6e7~s44 7N6 Ct.49'd,/NFff cet- yswd- uA>04
+ N?-. . . $4?"6-3 s 7N6 7722 ' C#9L' r*sA/4 stA9 fQ m sinin cues in ru oc o.wma mi,
. $,^i
- . . 7~/6 rnr. /1 itscowouc 'rN6 cs saucwrrw
. o
- 7 N d M l d dn4 W o w or M 7'/t.7* GA/gc ,
p$ Alc564new Aa/42 @ #5as*svion. freu
- k.
"s lGr5&ot9 43 C+roudo-3 7yc- ??trmuerow Of* A4.4GG Alr/eN1 7 ~#M.7~ /hort t. u d <.4 / 4 6
~ n m$ Y
'f hbe/$$f$h ffl$ hOhlhh W lh
~
.) 0/ 'rfd d/46tz f .
S /9e'estr-S # rZ d rJ & tn'4 rr/st d f Yd Acemt 4 tildd'r'IN4 su/ rH- rN-6 A-kB;&frd- . I A s j + 7
.i<
jv
- e. . % . D 4 h 4. 4I'e's,'e
_ -'* # 64 h %=dsw[ b ' **
- eI E dh_+. _ *.t'.5.~s 3 s'. s ..j . (_ , ,t'* ', ! E 4 * } yIe {*
A s% q ..~ b
,-,-.._._-----..,...m..- ...._-,-m.. . , . ~ . . m-
-.m x .m m em MW .. .
.m w.f .
GM - I
.9
'J 4 e
'; =((
. l. I oS PScro M cG 'r&O St G M W s US PG2xtM cf.- e.o &< o ah & W W 6- G L c o rt. L59 ccc
~;
l vJMtv T >+4- vu & t <0 E(L tS I .(* fc 6 7 o K. m N..O A4 0 V6.
'"-".b; .. . . . . . .- . . - . . . 'T -l'6 .TYlT %w t10Ec y-Hssr lecece
- l.h ... .n.us 96-cro tt-s weu w picy 56 rose. rs
?f . . - . -. P n,sw1 w q 00 eac+vcl e+ <*s or vou nents
. i M.s Gscrtbp .uso.4Y. vus sea co pearonse Q %
tp&rts rrzA,w pro pwp cg.rt y,,c, s.n so rg.s (m t
. ..gq
!~IfE lY i M Al D'vt A -5 % . NGu) 'T~v 5C s yui QS-e to K- .
- 1
- p. l &
A; - . - . . .
- , : 't06C - 't1GL 4'IU)ll4. Qit.c Gr<44%1 y .06-Y6YZws s N6 IG .
\ '
.h .-
.. L W . & I-5.... N tST&n _TO P vt.6 c W . U*1 Ate M
'M . s u spc.c.r to w , . l (f'.
" ~ ~ ~~
g g g . s,
' L.% . . 'rfl V t<%- Vi 54U &n A S GA I &f ci AU.54 A >'l !)U f
?
m., (2.stA r60 7'o Q C . ;pjpc-e.rort Gosuft cs vroo
, 5,,v.
r%IO T11AtN1A%. TM4- (2GCotX5 Ar25 t a ca u.0 to i, h )
- 1 Curt, soc, rus BA/Cc tzset.w ror />vinetst
y w outssuuutmer an ms tu ws r v s c y . T'rt.# suiv G Pvt.o6 W usG45- Ccouo. As-n
- ; (74soer rt46- Q4/pcrrtr y A J l2 5. e o ire s n Tv FC 70 9tzeytO5 p3- T 4-irt e 94 9 i v4t. OA-TIo u o(- TH 6 Cutt vt 6 Q C. tN.sPC-c% M'
' rib 4-I UIN G ANO C Gr! TI F1 cart G H (%G r(Ast t .
W TO 5-C. S P4U> VP 6 ft.Adi I rf fdesw x- _ - 1 m . .,m
.., ,._ .. _ . . . . . . . . ~ 'sx .%.n. j .
. +,% g .
;. ;m
- q..
C v.- *1 +
.%....g.i
- 1
*i 45 &QUl40 $y T H 7 %-1rf.J) fy
. f i o oma s.
l l
'l 4 c 6. rrt M . $6nJT 1D Ti4& CruCat MA ror1- Qf l
; AQLp ~l o ou.kt 30,19 8t{ (25O 50 cca
-,1b
. M O. (E6-W0%fC*
* *;'J? .
7;g' _ . ....,_..._..e. .. ,
...,.-'ck., 4 . -
pf ;j., . . _ . . . , . . ...f... s . . . . . . y .* * , p . ,. g$ . ._ __. . . . . . . . . _ _ _ . _ . _ . _ , _ . .
.f . . .
p
.. m.-
' [,, ..t4q /3
';T
~
r, .. . .. ... .%..y.._. . _+
'{ .
,3 -
3,a ;.g 3
.- . _ - ?. : . . . - - _ .
.. . g
*- e, . . .
f;g31 ..'
.X -*
-.: "d. -
41 O g( J' 4;*1
- f. %
5
.b l'
.1 2, ,
g5 M-
**si
- (
\ ,
e
' 1 i- \+ g. gj g .P -g[ . g %d g y 5 %*%# ,- #18
- 8 . - 'E - ' # b d- -'I iO$ .'e I O#'______
U"
-DJ
N7 "_mnamsgupwww. ' _ u swe.m %ww < s.~> v ,,. w a vws . eees %. . ,y_ -.-c__ -
%, g g .
W g, >+
*..*s
- g is -
.e ..=>p .m.;; e . . j-f
[?.4 . 9 m e
, 149u)-G 9 .
b Oc #swsua /x9 nor Aws sm
. A,h Jeb'6Al SC6006 ()//&c>wM o% 66wCc+%44-60ccs$rs+0M- Ddt/5a#41&*s*'~ h30.,)cozerm
.. .-4 MQ
~'s'i 3
- . _ . - - .$#.2N./ W M '
=.
. . .....--..y.~.-........ . :. .....-..- . ..
?, .-
A. ,' .
.rowia.....sfe-wwa /suwa (see)
. . . . . . . . ... . /VAfs4 dw56 YMG s96&G4P'%o 4x4 /6 IGM W ./Y R U U fS .. />t/ ) fE 82-/0,l62~// 47W N:h .
a .1.-'
. I2-1-e2,. - . . - . . . - . . . -
?.':4p ; D 6 $/f/C ./@ U/14 W .0 A~ V"f4'0 &l6 ^"Y" t;
.q. .
.~ . . . . . - . . . h . N? l .
b
$ . .. . .. - -- . ..-..f3 L /V6 7~. M56-Y)A G 7146 .M/M'* runt
- .:9 w , ,
- . . . .... f) 0) ,,
YY
- .. .- AUW8. W h $ $dCO!W W UW)jJNb l} 7726ft Al t&H 96600c 6dMGCresw f.k . . .
06nowde.6y Mz & cerw74 /.% 1 T'.1
-. _ if41#c-eriu& D.MsetJ . 7;tt d /k ns
- v x 4
/
f l .-#/ld JM) '7N4/4 fM.Wwiv C< ;7~4 C u 9-f,
? .. 7 ~ M . S A / C f c o / W A yj $4r// 95 Mf
.i pu c6><-ruo,
'(
l 9
- e em q
- .T V.f r*~R.Fis un.u ?.a x wn?n?.T.**J'.W.woa4ww _ **'7 a .u,u.. .1. a. r . .., . a*TD. .;,,. - . . , .
.h -
e - 8-
~13. Deposition of efore the ASLB, September 13, 1982, pp. 4131-4140
~14. Deposition of before the ASLB, September 15, 1982, f
pp. 4845-4848. 1 i 10. This statement prepared by:
- R. Hubbard Date
+ TRT Technical Reviewer 1 e. Reviewed by: f L. Shao Date f Group Leader Approved by: V. Noonan Date Project Director e c 4-s a
- 3
*n, 1 : :; -
b.. ,, F ~,; i :.- .
&4 E . ?.: *i D ' * *\ - . . . _ _
. _ . ? .-- w : ,w.n m m .c,..vn. w.. ~ . - m.- ~ .,.~.a + . . . . . , n ~, .. .__
* $ "s 1
.id) ',
.:x
- x,
~. .
c
.v M 6' 772 7 /34-4 0 foo rw] V'd#'Y Cr~ A d* y G#lg c Y129"' /2001da)0+9 4 .fdet/Sf # 4 cts-6 AtMst.f
~
$64A2Y6t? Cr0 &C /pf/Getc?f. G4)4t >LesW&
And Yl&W441K4, y$$sc /f.5fllLart Aatfc" wCd.y4gef IN $A $6 d44640y $t
<v J ..
.-. ..... . 7196- &Al $ C W blUdod V'N6' 77M'G420 yrjs.c
~:'.- 's .- . ._ A'NU . C&C'lC4it-oo $5dexd[ g7-/62 2 n." 4
... .-. --. . 19'WD. _ $ C- $5%/h),uG<, je%D feu/n rM-*
5 E d N . . f. h t T M r'A) 3 r1 suo t/'Ert.///o$r2Ou & 440C4ttDo
$Y . .- .- ---- .-
"$ . :L:
. Quo si2 P4 67- srnSt.cyinavr m ws>tc f) . . . ._ f>d/Nhd.Es .
~}
. . ..--- ..- .. . V**Lif . $AfGd W. W L0000 j
W
& . . . . . . - - . ; ~....MC6' ) .'1//bl W W .8l/2 hfd W "
' *'* O_._9j4# .2d-}k EiI,4 Aixo etot?>Wses
~ lY .
.m{$,; . '
- 71 $6~./@ d&dtM6' /$4f00/XoT t/&t./N&
OtC.AA/ W W A260!ouJ fooA 'n:in
'. _ M/) FW#0W/
...~
. 7246 sad +%Jhd AMO!'t+0 /M
- 2
. 900 7f.)d L* Cr0 /260/ OR) AfL /AJ// M
. c ., b$ YY hh V _y grosc .rm rwe w " om'y
.: gg6. gify'46/4 / de- m ipffr-e7uu
$6+f4cr?k M G9 cdt1 uscuAl/4'M
~w19 Cent, A 4 Grid +f. wad .T3#%~ 7v pdd AGlu~ M Aas< e4 ou Aus 50, i G8y' wiw poisswG ,
6me grDe (Bk p,e e,[ s * " . 3' p a g ,4gy O 8 S E. .e T"w 4 g ,+.A $ g a
. . s ,
9.9. ,4 .. . m
. ., y.;,
.u
..m
.. t . .
S, lowccuriopt Avo lr'tw Arr77ws:
~
(Aes-rJ(now t r)(sev-se.)(~s au-c 9)
- _I rM6- rre.r ps rsrsnia.ere ysmr pus 4><.rns.t
~:s
.gi ASr.o .-r, Apw -/ 9, 4pw-se sw 490 -47
- p. dov6tzwg iRAodpu,4rd p c. s.o.r/6c7zeo o s
# - Awid. c6rtr>4asnno anns <xa i.es /!+.rbwre
$,$ t . .
. ...'. J 8f- .72/6C). /ZA:ffe4ff Cro 7Mf 9A/Nf yQ .. ..
., . 77t7 3s512 Cn r y C
- .wJ
- n. .
- s. _..
M.4 L. . Aba)- I'? ?. . YN+ yrtr Mrs**wav &> rnsv-JM6 i.;'$. t
.. . ... L.- *: $C Dvr## cred .rsoute. Mnu6 6o&e Y N
- h . . . - . . . + ;' ' . . . . Sswm tdNne isrecerse wied v:ss4 -
m..,.8s ,
+: s'*~*.0*s Mi>os m swro. A rxeuce.
D..n.3
.- Al.]o. A/Mu6 ' ycM/45e 7 N.6. [ & nson Meet.C
.f.k . .. .; . . ../dfrM*/PVd C(M, if4:f&C QU Qaid /XAn**fW
- ll ..
c etr p w re ..i o i C W /2s:6 f sit ?9-/ r*
.i.. Y#e iaf#ccries Noc coow sd' erAm*de M l 46e useurse. 7N G nfr 6wou p oo no
\Q) S m >y hewine***uc# /iv rs.c p; c ( i>>196 cross igem-s.
'M. ,
- .q
..w.-
lQ L' A$w- // ) (4pa> -/6) ! ' *. 7%c- rter >cou ao no Snss,uce YMGr
.h 72t.6 gttemdM wk/ ,co-r -71s%wdd n i o h fv& iN)h &bh fN I J;7/d-f64 6 M' Sp/0- 7M dk.6- iT
/Lio f>W&%f fig uip wsuce H n/ tr n a c.s >< n n .
P =
- =
r .
, , s .n . .. .. . ; ,. .u me; .- . . . . . . . . , o a. , .4 .- . . . ,
, . .y . . . . . . .,.. . .s.
n _ .. ._
%. 2+ m z. s' . /s
'E&'bl,y$ l[. $!* '
1 r ,p>,.iy 2 ,
.r r #. ,;i '
I 4
*.ey e s . s 'lv y:h. .
5, .a. g- . Mf;g. ,
1e
' 2 2^
- 6. Actions Required: None.
/
- 1 A '
l 8. Attachments: None. l
- 9. Reference Documents:
- 1. ANSI N45.2.6-1978.
- 2. TUGC0 Precedure QI-QP-11.21-1.
- 3. NUREG 1.2.6.
- 4. TUGC0 Procedure CP-QP-11.21.
; 5. B&R Procedure TCP-1.
-..t J .' .
s6. TUGC0 Procedure QI-QP-2.1-19.
.L
,, 7. B&R Procedure QI-QAP-2.1-5.
'8. TUGC0 Procedure CP-QP2.1.
- 9. B&R Procedure CP-QAP-2.1.
':. 10. B&R ISO BRP-CT-1-SB-019', Rev. 6.
.y.
, 11. NRC IR 79-15.
a,.: l WJ 12. NRC IR-82-10 and IR-82-11. > l ,%.):\ ,v 1.g. . . e
'*.L.,, '
.,^
Jdd,i . ...
. ;F;y 'y __
y.: 3;'s , _ 5 -t. - c'
.,,S' **
2,.. '
, .< ' c4.. .+
;.,6 y.- .
.T.
s..
*l'. ,
+'.
- 5__, i;_l r' ,
- bh
-
- 1*Y* UE Av .
7 g. . ; ^ Dfd-l
\
~
. n: . .
... J . . .' i 55 I 0 GW
- e 4 5 4 U $dbm W' W 5 sy wi. m hRC Inspection Report 79-15 reported an investigstion of
% f-Lc :31y ,. ,3,3. t:
wmu . . . - y a series of six interrelated allegations concerEng the
.yY;'"3' . .,
welding of the stainless steel liner system in the fuel handling facility spent fue7 storage pools. The allega , 5 tions, simply stated, indicated that welding cond'i'tions
., were very poor; that welders were unqualified; tha.t- O_C }
inspections were inadecuate_; that welding procedures were . not followed; and that at least one weld seam was largely. rust and concrete. The investigation indicated that the .p [ allegitions concerning#p'c or welding conditions were sub-
. ~
stantial y true and that some of the welds might well be of relative low strength.The allegation about unquali- '
" fied welders was found not to be the ase'in a technical 4; sense, since each welder had passed the necessary tests.
i It was apparent that the alleger meant that the welders a i were not competent in his opinion. The matter of QC inspections and welding out of procedure could neither be substantiated nor refuted since it was .iust one person's word with no other confirmation. In any case, the matter ., was considered to be unimportant since the welds in question were seal welds rather than strength welds and [ not of any safety significance.
..q A.38.c. (Stewart) NRC Investigation Report 79-22 related to allegations by a forter Comanche peak employee which appeared in a news article of the University of Texas at )
FO!A-85-59 ./7
- - ~. . - . . - . -
COMANCHE PEAK STEAM ELECTRIC S ATICN ,\ T- S t :-s Es GENERATING 00. NONCONFORMANCE REPORT (NOR) fi 4g3,'00009 R." e
-/
ITEM /CCM PON Ef fT TAGdO NUMSER m2 NO.
, UNIT l STAUCTURE/ SYSTEM f LOOATICN CA ELEVATION l
I l N/A l 1 DG/2900 DG Aux. Skids C?1 v 04:: c. ,,i CG 51dg. 310'6" l 1 NONOONFCAMING CONDITICN Gi Suoports for ASME Class 3 piping and comocnents are considered and fabricated by 5 the Vender Transamerica Delaval as Non-NF. o E Tne supports should be NF as specified in the applicable Gibbs & Hill specification. E 9 9 m C'. 1 3.3 REFERENCE DOCUMENT. 2323- 5 -34 pgy ,,,, REPORTED BY: 7 ,gITc;T, 80 i Greg Brown CATE: f..l CE REVIEW / APPROVAL: f 1/0 i PL DEPARTMENT 0 ACTION A00REsSEE 3 7 u.--4tt/Moehlman Eneineering CISPOSITION: I 5XX REPAIR USE As tS SCPAP REWCRK i i, l d us See Attached. e U) I E Request temporarf waiver. The physical work is complete, waiver will allow ecuipment' o
@ te be started for testing.
z 9 U I
/ >.
i,/ _
~
7 .h D-CE REVIEW APDRCVAL: [ ' /
/J 4 l w .
0 ' O!SPOSITiCN VERIFICATIOWUSURE: W i gg7g;
~
- y ; ,
COWENTS: Rev. 5 issued to recues: temporary waiver.
/ ;
i 8. F0(A-85-59M J
NCR M-80-0000s, R.5 CISPOSITION: Partial Disocsition: , Millwrignts to remove the oaint from :ne welds on Auxiliary equioment skic, per Engineering's oirection and prepare welds for welc inspection.
~
Interim Disposition: The weld inspection is in progress in accordance wtih CP-QP-11.11, R.1. Welds that do not meet the acceptance criteria of this procedure shall be repaired in accordance with Weld Procedure 10046. Interim Disposition: Rework of some vendor supplied supports is necessary for proper alignment. CMC's will be issued by Engineering and approved by the Vendor. Rework will be performed by the millwrights in accordance with these CMC's. All welding shall be per site welding procedure 10046. Final Disposition: Evaluation of the subject condition is separated into a consideration of design and a consideration of fabrication. The Vendor, Transamerica Delaval has performed an analysis that shows that the worst case stresses fall within the allowables of the ASME Code. This portion of the nonconforming condition is therefore dispositioned "use as is". The fabrication records have been examined and there is insufficent documentation to claim NF - equivalency. A program has been developed however to qualify the support and skid fabrication to AWS D1.1-1975 and the AISC Manual of Steel Construction, Seventh Edition. I All accessible welds were inspected to CP-CP,11.11, R.1. The inspection results fell into two areas: those that had problems such as undersi:e, undercut, etc, and l welded channel box sections where penetration was either lacking or unverifiable. Welds of the first type were reworked as required, re-inspected, and found to be acceptable. For those welds in the latter group, the Vendor, Transamerica Celaval ran an analysis of the welded channel box sections. The analysis showed the adequacy of the welded sections and their suitability for the worst case loading conditions. Based on this, the welded channel box secticns are acceptable as is. Inaccessible welds can be neither accepted or rejected by inspection. These welds do not constitute a majority of the welds and are dispersed throughout the skid. Based on this and the fact that the Transamerica Delaval supplied skid stress analysis yielded a maximum stress value of 0.37, the integrity of these welds does not have a major impact on the overall structural integrity of the skid. Consequently, the inaccessible welcs may be usec as is. The following supporting cocumentation is attached: 1. Weic Procecures, 2. Welder Qualifications, 3. Material Certifications. t i _ -em
_-___--_______-_\ f :
+
+
DCP1 - SSER Category 26 Oraft 5 - SSER
- 1. Allegation Group: Mechanical and Piping Category No. 26, Use of Unqualified Welders
- 2. Allecation Number: AQW-2, AQW-3, and AQW-4
- 3. Characterization: It is alleged that:
(a) Welders used by Brown & Root (B&R) were unqualified (AQW-2). (b) Unqualified helpers are being used for safety-related welding (AQW-3). (c) Unqualified welders were being used (AQW-4).
- 4. Assessment of Safety Significance: NRC Region IV (RIV) investigated this allegation and reported the results in Inspection Report (IR) 50-445/79-11, 79-15, 79-22, and 79-20. The NRC Technical Review Team (TRT) reviewed the allegations and the RIV responses, focusing '
attention on verifying the existence of an acceptable B&R welders qualification program. The TRT interviewed B&R personnel and the alleger regarding both i current and past procedures for qualifying welders. The TRT found ; that B&R's Welder Qualification Program required that new and rehired welders prove that they were capable of performing the work which would be required of them at CPSES prior to being allowed to work onsite. The program required all welders to pass one or more standard , I welder qualification tests. y= 3A C :
=Q
;?/ .
1 "k % Yl 5U*hN*CA.'s.*' {' && , ys,~ ~' -%ll,{ 'ghkl*] r}p 'Q'y , s ' ,e ,;,,ye , t_y 4 3,f_7.(( Qc}
-__ __ - ~%, ,ym m - m .-- -. ,,., y ~., r .. g c~ . .my y, ,
%t-l .. ..
T These tests were performed at the Welder Qualification and Training Center (WQTC). Supervisors at WQTC stated that testing of the new welders was done correctly and according to specific procedures. The .
. new welder's test coupon from each qualification test had to meet required mechanical properties tests. Upon successful completion of each standard welder qualification test, the welder was certified to j
make those welds which were in accordance with a specified group of
-; essential variables. ?
i L The welders qualification matrix and the welders qualification log ensured that only a properly qualified welder performed a specified
~
rj weld. These documents, revisec and reissued on a weekly basis, listed 2 all currently qualified welders by name and symbol number and i described the extent of each welder's qualifications. These documents [ , also included a listing of the current welding procedure specifications and standard tests. The craft foreman verified that the welders were qualified to perform the required work by reviewing these welder qualification logs. The TRT reviewed the qualification program by selecting a sample weld, 2 'f FW 3-A, which is shown on 180 BRP-CT-1-RB-016-3 (containment spray), 9 and reviewing all of the documentation associated with it. The weld J filler material log showed that four welders worked on the original weld and on the two repairs that followed. Welding extended over a period of several months. The weld filler material log also identified the welding procedures that were used.
,n eb#.d y a6 % f 9' *ek p. P85 I "M J. * '
NN
- eme # % 1 ef M b > d* 1 J '.h' d * # W. M W. . '
N f . - 6 7 d l The' TRT reviewed the welders perfomance qualification record for the I week preceding the date each weld was made, and found that the record showed each of the welds was made during the relevant period. The TRT also found that the procedure used for each weld qualified the weld which was made, and welders were correctly selected based on qualifications shown in the appropriate welders qualification matrix. The TRT then reviewed the performance qualification test results for each of the' welders, and found that the weld procedures followed in the qualifying tests corresponded with those on the perfomance qualification test results.
- 5. Conclusion and Staff Positions: The TRT concludes that the B&R welders qualification program is in accordance with the B&R Quality Assurance program, which is based on the ASME Code Section IX requirements. The TRT is also in agreement with the results of the l Region IV inspection which concluded that the existing welder's qualification program is acceptable.
Accordingly, these allegatiores have neither safety significance nor generic implications.
- 6. Actions Required: 'None, l- .
- 8. Attachments: : None sp. J., ,
.3 ,-.<.y.,
.. _ . ,.,_____._.&. , , . _ .s 4 .- , . . . , m. -, % , , . ,, , .. . 7, , ,.f - . -. .r,
---------._--._m.,.. . . , _ _ _ _ __ .- ..~ _.--
t :.. ew,wess ->emse.,msn-o.wasar.; -- - - -
.-w **aw.-&v .v..TW%YWn F 'wW-' w % '9 M P W M A;&.1,4
. -! -y;,= ^ '
IF s
,h.
j
, j n
- i T9- 6
%.1, hf.;I.
~ J.',.s. ..
p -9 e
? 4~ xo-2 wat 4 4+~
; A 5 a6A +w9= a, m
& A' a
w ML .. abc. spew-z Afm. 1
$N h '
& k OGO .5
]$$
ed Apw.-V m&m m.,y,
;y .~ - . . , .---.-h,a.,.
'I*N
. , .3,
,m '
~ '
cQ
'O e N *
- . d.
..p[z ,
y' h .:
-.v;, , . . y. ,, . - ,
.py s -
- e e
o>
,ng , op- .
%: . .i
. y s. . .. . . ..e
, . . . .4. . m , .".n g-- .
~ ' #
*-,.S.,=-.
..t..,,: ._- ..
+ ." e, t *
,*. 9, , , .'t,...,
..' r .
.--~*L<,2..<.,,.
_..--......T7.._.--~...:'
%x.ez! -wn a, . - . . . - . -,
74 . .- , . . 2Wj ,
..g . s . .. _ ._.. . . .. . . _ . . . .
s .
- @'is
+vr-e wh -
- ?*.;
= ..
_ }: . f..w
. a,
,0 v+? ,1 en a Gj w g
. ,i ., ,
.'$:*7.,'
6;Q , w!, I.D.. . - a 's -i o,v ,
.1 >s e',
e,* eN$ m.
; v.. *w ,.
- s. c eI 4 -
** yY 4"1
.,T Y* -
OW MT,--'_ Mea gi 4 _.QWdf g ,
am.e- -= _ _ w e% v
. . ~ , ', .
p 9. Reference Documents:
, 1. irs 79-22, 79-15, 79-11, 79-20 and WDC 630321.
- 2. NDT Radiographic Report, RT 12378.
4.; 3. VT Thickness Report No. 0439.
- 4. Weld Filler Material Log No. 630321.
- 5. Weld Data Card No. 493.
Ik 6. Weld Filler Material Log No. 493. 2
- 3 7. Performance Qualification Tests BHI-88021-RF, APL-88021-RF, D
+ BJI-88021-RF, and AZC-88021-RF.
? 8. Welders Qualification Matrix for July 22, 1984 through July 31, 1984.
A T 9. Welders Performance Qualification Records for the weeks of
+
.c July 18, 1980, August 27, 1979, and March 17, 1980.
. r:.
f 10. Performance documents as follows: s M.( (a) ASME Section IX Code jd (b) B&R Procedure WES-031 2 U (c) 150 BRP-CT-1RB-016-3. s'( 10. This statement prepared by: 7/31/84 It R. Hubbard Date fjj TRT Technical Reviewer 'S . 4 'I-Reviewed by: i@; L. C. Shao Date 14 Group Leader 12. l Approved by: ! V. Noonan Date l Project Director
.I;.
I s }* e > \ ' Mw in ,n ka#G:,. . Ev2.b .i,. , ~: ";. . s . .%, w. .::: a ;;.;w.. ,. . _'- ' ~ ~..ui t;,axu2;:.3;i-G ;. <,a.J:.;;; . ,: .,G.k W M M ; .:. :,
6 k a r-
= .
p= ' -
,pp- ,r
*.
- n .e y4
. . p _- .
. ,1
'/.c= - 79 ' ,
'f .I . \
QWI In Reply Refer To: , . j chet No. 5 t 79-15 . 50-44 Rpt. 79-15 . [. t,
. l i
. Texas U'tilities Generating Cvny .
ATTN: Mr. R. J. Gary,. Executive Vice . 4 President and General Manager ' l 2001 Bryan Tower - . Dallas, Texas 75201
~
.. .' : . j
\ n
.m . Gentlemen:
t -
~
This refers to the investigation conducted by Massrs. R. G. Taylor and ! W. A. Crossman of our, staff on May 29 through June 4, 1979, of activities I authorized'by NRC Construction Permits No. CPPR-126 and 127 for the Comanche } Peak facility, Units N .o1 and 2, concerning allegations by a former Comancha . Peak employee.
~ .
{I The investigation and our f4ndings are discussed in the enclosed investigation
- i
,, report. r ~.- -
l No items .of noncompliance or deviations were identified. - -
.f .. ~ Even though no items of noncompliance with NRC requirements were identified j during this investigatioc, we did find that the allegations were essentially ;
true. We also noted during this investigation that a thread of continuity i existed ,between this investigation and others recently conducted relative to ,q ,i e alleged problems with site management sud quality control in certain areas of construction. Although we feel that the major organizational changes you
.made in' January 1978 have strengthened the QA/QC program at Comanche Peak, we :
cannot ignore the fact that we are continuing to receive allagations concerni.ng : construction practices. Taken individually.these allegations, some of which I have been substantiated, 'do not appear to have any significant adverse impact ' on the conformance of your plant to NRC commitments. However, as we discussed in our meeting with you and Mr. Pikar, in our office on June 22, 1979, when : these allegations are taken collectively, there appears to be a 1aorale proble=t j
. which is evidenced by several of the allegers and any be attributable, in' part, to communication problems ,between the werkers and supervision. In our '
J3 ina 22 seating, you indicated that you would look into these apparent , connunication problems along with the adequacy of QA/QC indoctrination of ' plant supervision and ' workers and taka appropriate action to correct any weaknesses that you detect in these areas. We ' intend to follow this matter ; i;.n.ly 'ci ; L q ; i W ic. . t
.~. e. p.. .RH,,,MR, ,,,,,,,Qsg, ,,
WACrossman, ,, .,,,,,,,N WC le g... Taylor /nh .W ou .................... .................... ...................... . Ev..e.t. .t..u. .. .. . . . . . . . . . . . . . . . . . . . . . ..............
.- e. , . . ... 7../..t...(.7. 9... .. .. 7. ./. . .D. .. . 7. 7. ./.9.. ..... . . 7. 9. . . . 7 . ../1. ../. 7. 9... . . . . . . . . . . . .
sac soam nai (s.w wm * .....a -=-"- - = .
JSWA4M,AA-M GM '
.iame d 4 4 5 m 14 **- 44 &i b444i.hA44 AE-h+* Eh d+ ACah 4-%-WdiAA 4 +4+*1 Ar*h6- *A= -'
-h hE-4-~4We M-*A JamAA h-hl_h -A s h A4-ha
?.. , e 5 9 1
- f 4
l 1 i { 4 t 4 4 r I !. i f 1 4 i 8 5 ! [ f 4 l l i ! i 1 i . 1 5 3 f t 1 I L . I l 1 i
-t i
3 1 i } i ( i 5 I i i e ! l l-s I l 1 4 6 a 1
. l
' [- ) - %
j Tazas Utilities Cenarating Compazzy ; In accordance with Section 2.790 of the NBC's " Rules of Practica," Part 2, ! Title 10, Code of Paderal Esgulations, a copy of this lattar and the enclosed l investigation report will be placed in the NBC's Public Document Room. If the report contains any infornation that you believe to be proprietary, it is necaseary that you submit a written application to this offica, within 20 days ) of the data of this latter, requesting that such information be withheld from public disclosure. The application unast include a full statement of the reasons why it is e1=4==d that the information is proprietary. The application should be prepared so that any proprietary information identified is ecce=4a=A in an [.j enclosure to the app 1tration, sines the' application without the enclosure will ; I also be placed in the Public Document Ecom. If we do not hear frca you in this i regard within the specified period, the report will be placed in the Publie ll
. Document Room.
Should you have any questions conearning this' investigation, we will be plassed ! to discuss them with you. - 1 I Sineersly, ll
. I Original s6ned by j W . C. Seidie' ' -: - ;
~
; W. C. Seidla, Chiaf -
_ }
.Baseter Construction and ,
Ma-da==dng Support Branch
Enclosure:
~
IE Investigation Report No. 50-445/79-15 ' , 50-445/79-15 i,
. i I
ec: w/ enclosure _
' Texas Utilities Genarsting Company .
- - i
~
I ATTN Mr. H. C. Scissidt, Project Manager . . 2001 Bryan Tower , nallas, Texas 73201 , bec to DAC:ADM " bec to Reproduction Unit - - 6 for distribution P M / for distribution MS k 76 - AD/RCI (Reinmuth)
- Central Files -
IE Files - PDR l ,
~
- Standards Development- LPDR -
j ELD- - TIC -s - NRR (9 Cys Q/ NSIC - . - MIPC : bec distributed by RIVb/ 2 ? Texas Dept. of Health Resources
!{
. l 1
jl
. I i
*.e. .e-a-. t 6 _-_. &avr 1.s n +s e 4 #e . + - . _ w - -
, e-: - s -
sM _
U. S. NUCLEAR RIGULATORY CCIOf1SSION OFFICE OF INS?ECTION AND ENFORCEMENT REGION IV Report No. 50-445/79-15; 50-446/79-13 Docket No. 50-445; 50-446 Category A2 Licensee: Texas Utilities Generating Conpany 2001 Bryan Tower Dallas, Texas 75201 - Facility Name: Comanche Peak, Units 1 & 2 Investigation at: Comanche Peak Steam Electric Station, Glen Rose, Texas Investigation conducted: May 29 through June 4, 1979 Inspectors: r-^ 2/[79 R. G. Taylor, Reactor Resident Inspector, Project Sections Date Wd= ~ W. A. Crossman, Chief, Projects Section c/zi/7 Date Approved: ;;; (e/Z/[7 IJ. A. Crossman, Chief, Projects Section Date Investigation Su::n::atv: Investigation on May 29 through June 4,1979 (Report No. 50-445/79-15; 50-466/79-15) Areas Investigated: Special investigation of allegation received regarding improper and potentially very poor welding of inter-plate seams in the Unit 1 Refueling Pool, spent fuel pools, and transfer canal of the cocoon facility Fuel Handling Building. The investigation involved twenty-eight inspector-hours 4 by the Reactor Resident Inspector (RRI) and the Chief, Projects Section. Results: The allegations were neither specifically confirmed nor refuted. The allegations, if confirmed, would have no safety significance. No items of noncompliance or deviations were identified.
& ci bdInn_ yin"'1
- - . ~
, . - . . - .-. .-. - =. - ..-
INTRODUCTION Comanche Peak Steam Electric Station (CPSES), Units 1 and 2 are under construction in Somervell County, Texas, near the town of Glen Rose, Texas. Texas Utilities Generating Company is the Construction Permit holder with Brown and Root, Inc. as the constructor and Gibbs and Hill, Inc. as the Archite,ct/ Engineer. REASON FOR THE INVESTIGATION The Region IV Reactor Construction and Engineering Support Branch received a telephone call from a former CPSES employee who reported several allegations indicating a potential breakdown in the CPSES Quality Assurance program and a possible threat to the health and safety of the public. The substance of the allegations also appeared in an edition of the Fort Worth Star-Telegram published on May 30, 1979.
SUMMARY
OF FACTS The Region IV Reactor Construction and Engineering Support Branch received a telephone call on May 25, 1979, from a party who identified himself as a former CPSES employee who had worked as a Boilermaker welder. The call was taken jointly by the Branch Chief and the Section Chiefs of the Projects Section and the Engineering Support Section who in turn provided the infor-nation to the assigned Resident Reactor Inspector at CPSES on May 29, 1979. The allegations were reviewed with the alleger in an interview which took
- ' - place on May 30, 1979, at his home. Each of the following allegations relate i to welding of stainless steel liners in the Unit 1 Reactor Containment Building
- or in the common Fuel Handling Building
, 1. Allegation No. 1 1I l Welding and weld repairs on the liners were difficult because water from concreting activities had run down the leak chase channels and out past the backing strip into the weld area. Welds finally completed were very poor; some welds had been slugged with weld rod and others were so thin that if buffed a second time with 120 grit, they would not have passed PT (Penetrant Test).
, 2. Allegation No. 2 l l There are problems with the gate guide (refers to a gate in the Reactor Containment separating the refueling pool from a small storage pool and the transfer canal). 1/The statements above are the allegations as received. Clarifications obtained from the alleger during the interview of May 30, 1979, are indicated by parenthesis. I r r_s : , , - - . ~
._,.g_ .._,n.,.-, ----n,c.
- a. The gate guide between the large and small pool was welded in the shop. When the gate guide was installed in the pit, the end bevel was cut off so it could be fit-up. When the guide was installed, it was not rebeveled and where a fillet veld of 3/8" was required, only 3/16" fillet weld was made.
- b. The gate guide had to be welded to both sides of the liner. When welding the back side, the welder had to crawl down between the rebar to get to the weld. The position was so crowded that the welder could not make a good weld. Also, the welder couldn't see what he was welding very well.
- c. Six inches of the chase " channels were left off the gate guide and added after the gate guide was installed. The rebar was so thick in the areas where welding was performed that "you could hardly get your finger through, much less the welding torch." Consequently, the welds were not made properly.
- 3. Allegation No. 3 Welders have no experience. They spend as much as 80 hours trying to make a test weld. They finally learn how to make a weld that will pass the qualifying test and then when they get into the field they don't know what they' re doing. ,
- 4. Allegation No. 4
. There is " lots" of QC coverup. QC is " buying-off" on welds over the phone.
) One QC inspector bought off a seam before he ever saw the seam and it was not a good weld because water was coming through while the weld was being
)
(The buy-off involved was joint preparation and cleanliness prepar-made.
.. ~ atory to welding).
- 5. Allegation No. 5
'o Brown and Root is not following procedures in welding the liner plate.
(The procedures referred to are welding procedures and specifically refer to use of a down-hand welding technique being used versus the procedurally required up-hand technique).
- 6. Allegation No. 6 Some of the top seams 18" above water level on the fuel pool had backing strips tack welded to the liner plate. There are places where the plate did not cover the backing strip. He would not guarantee the veld. The weld was probably 60% rust, air, concrete, etc.
3...w.--, - . . . . - . , _+ _ . . - ,..-,_.,-%w.- . - , - - - , . . . . - _ .
I .. CONCLUSIONS Review of the CPSES Final Safety Analysis Report, ProjectSpec5ficationsand Engineering Drawings, as they pertain to the liner fabrication and installation, have led to the following conclusions relative to each allegation stated in the Summary of Facts above. To better understand these conclusions, the following considerations are necessary: The liner systems are not installed to prevent or mitigate the conse-quences of any of the postulated design basis accidents, but rather are installed to prevent an excessive burden on the liquid waste collection and disposal system and to allow the wall and floor area to be more easily decontaminated af ter pool usage. The liners as a functioning element are, therefore, not considered safety related 3 and are not normally included in the NRC inspection program. The liners, as passive elements and parts of the building structure, are usually classified into seismic Category I since if one or more - of the liner plates were to become detached from the wall, serious damage could be done to stored fuel assemblies. The plates are, therefore, secured to the concrete supporting structure with a system of weld studs attached to the back of the plate and embedded into the concrete. The weld stud system is not a factor in these allegations.
- 1. Allegation No. 1 f
The RRI, based on the interview with the alleger and with other welders, has become reasonably sure that there were difficulties encountered by the welders with water, moisture and in some instances with concrete on the weld surfaces and that in some instances, the welds may not be com-
- pletely sound internally. These welds, however, serve no strength purpose and need only to be smooth and leak free, factors which are established by visual inspection, dye penetrant examinations, and by vacuum box tests
, of the joint after it is complete. The allegation, while probably true,
- ., has'no safety consequence.
I
- 2. Allegations No. 2.a, b, & c f These collective allegations, while probably true in a substantial sense, l
also have no safety consequence. The weld joints in question only need r to be smooth and leak free in the case of a. and b. and leak free in the case of c. The welds do not serve to lend strength to the structure.
- 3. Allegation No. 3 The project specifications for all welding, including the pool liners, require that welders be qualified under the requirements of the American Society of Mechancial Engineers, Boiler and Pressure Vessel Code, Section IX or a comparable requirement such as those of the American Welding l
l
,,y... ..
, _ , - . , . y .- y._.... ~ . _ . . . ,
Society. Section IX of the ASME requires that a welder must perform a weld process involved and the as-welded coupon must pass specified ' tests when complete. No time limits are specified or implied as a requirement in Section IX for making the qualification test coupon weld. The RRI has verified previously that the site welder qualification pro-gram is in full compliance with Section IX.
- 4. Allegation No. 4 The RRI examined the circumstances surrounding the specific portion of the allegation and discussed the matter with the QC inspector directly involved. It appears that this man, on occasion, was depending on the inspections performed by a fellow inspector and so recorded on the appropriate weld data card. The joint was covered over with tape after it had been inspected for cleanliness and fit-up and the inspector re-leased it over the phone based on the record card entries. Water in the leak chase channels appears to have been a constant problem. The QC inspector may have made a judgement error in not re-examining the joint, but not withstanding, the joint had been inspected and found satisfactory at that time. The RRI did not investigate the alleged " lots" of QC coverup because of the lack of specifics.
- 5. Allegation No. 5 As noted in the Summary of Tacts, the general allegation of failing to follow procedures was subsequently refined in the interview with the alleger to relate specifically to an occasion where the alleger was directed by his supervision to weld down-hand rather than up-hand as required by the welding procedures. ASME Section IX indicates that such l
a change is in the category of a non-essential variable and, therefore, is not a prohibited change in the procedure, if recorded. It appears
- that the change was not recorded. Interviews with other welders on the
' same activity failed to reveal any similar experiences and supervision has
- denied directing the alleger to perform out-of procedure. The RRI, there-fore, has no mechanism by which to confirm the allegation. Again, assuming that the alleger did weld down-hand instead of up-hand for whatever reason, the consequences of such an action are essentially meaningless as related to a weld, since such a change has no effect on the finished weld of the
- type involved.
- 6. Allegation No. 6 The particular welds in question are even less consequential than the other seam welds in a functional sense. These welds, which are above the water
- line in the pools, do not need to be leak free, just smooth for the purposes of easy decontamination. The allegation, while perhaps true, has no conse-quence.
.,--%~-..
.m- w re-w --w o . = W
- y-,neo,www-+= ,----etw+e,M*-- '
, - - - =--m-+--nd - 9*%at -- *"F J --------
1
- 1
\ . DETAILS
- 1. Persons Contacted . . .
A11eger The alleger, hereafter identified as Individual "A," is a former e=ployee of Brown and Root, Inc. (the site general contractor). The person iden-tified himself as a former welder assigned to the millwright / boilermaker unit of the construction force. Principal Licensee Emplovee Site Quality Assurance Supervisor ~ Brown and Root, Inc. Project Construction Manager Millwright / Boilermaker Superintendent Individual "B." a welder currently working as a pipefitter but who was a Boilermaker Individual "C," a welder currently working as a pipefitter but who was a Boilermaker Individual "D," a quality control inspector who was assigned to inspection of pool liners
- 2. Background of Allegations, Individual "A" contacted the Region IV office at approximately 9:25 a.m.
on Friday, May 25, 1979, to express concerns about the welding activities
-._ which had taken place on the spent fuel pools, cask loading pool and the transfer canal in the common Fuel Handling Building for both Units as well as that work accomplished in the Unit i refueling pool and temporary storage pool installed in the Reactor Containment Building.
- The RRI was notified of these allegations on Tuesday, May 29, 1979, (May 28 a holiday) and initiated an immediate investigation. The first point of contact was the licensee's site Quality Assurance supervisor who inforned the RRI that he was aware of the allegations, since his company had been apprised of them by a newspaper reporter employed by the Fort Worth Star-Telegram.
The site supervisor also informed the RRI that another welder, Individual "B," had expressed similar concerns to the Project Construction Manager on May 23, 1979, and that concerns had been forwarded to site Quality Assurance for investigation. The RRI was provided an informal memorandum giving the results of the investigation dated May 23, 1979.
;6-
Individual "A" also contacted the Project Construction Manager on May 24, 1979, and expressed essentially the same concerns as those expressed by Individual "B" and which in turn he expressed to the Region IV office on May 25, 1979. It appears that Individual "A" and his supervision, up through the Project Construction Manager, had reached a substantial point of disagreement and Individual "A" voluntarily terminated his employment at the site as of May 24, 1979. The voluntary termination is a matter of record in Individual "A's" employment file.
- 3. Investigation The RRI initiated the site phase of the investigation by extensively reviewing the CPSES Final Safety Analysis Report in order to ascertain the safety classification of the various pools and pool liners involved in the allegation and to review the functional descriptions. Reference to Section 3.2, " Classification of Structures, Components and Systems,"
in the FSAR does not indicate the liners as being safety related although the buildings in which they exist are shown to be in seismic Category I. Paragraph 3.8.3.7.1 provided a commitment to test the liner seams via a vacuum box for leak tightness and briefly described a leak chase system behind the liner seams. Paragraph 3.8.4.1.3 provided a brief additional description of the function of the liners. Figures 9.3-9 and 11.2-4 revealed that the extensive leak chase system has lead-out piping which leads to a building sump and hence into the liquid radioactive waste collection and disposal system. The RRI then obtained Project Specification 2323-SS-18, Revision 3,
" Stainless Steel Liners," to ascertain what requirements the design engineer had established for the liners. The RRI noted the following significant items from the specification:
- a. The design engineer invoked the general quality assurance requirements of 10 CFR 50, Appendix B on the fabrication and installation work.
- b. , The design engineer provided three full pages of detail requirements
, relative to the system of studs to be welded to the reverse or concrete backed side of the liners.
c.- The design engineer made reference to the inter plate seam welds only by requiring that the welding procedures and welders be qualified to ASME, Section IX. Criteria for finished welds require that, " Surfaces of all welds shall be smooth and free of any irregularities such as serrations, ridges, crevices, or pinholes which may make it subsequently difficult to achieve an effective washdown of the liner surface." Under testing the design engineer provided the following, "All seam welds shall also be tested by vacuum box for leak tightness for their entire lenth." No other quality requirements were imposed on the seam welds. _7_
- d. The RRI then obtained the design engineer's drawings S-0831 through S-0834, SI-0560, MI-0581, all of which provide details of liner fabrication and installation. In addition, the RRI obtained vendor design detail drawings for the gate guide installed in the Containment Building between the refueling pool and the temporary storage pool.
These drawings, taken collectively, showed that the design engineer had designed a system wherein the liner plates and the gate guide would be supported by and anchored to the surrounding concrete walls
- by a very extensive system of "T" headed studs welded to the concrete sides of the plates and gate guide frane. The seam welds are entirely from plate-to-plate and provide no attachment into the basic building structure.
The RRI concluded on the basis of the above information that the liner system had been designed such that resistance to seismic effect was vested in the "T" headed stud installation and that the seam welds were necessary only to provide a very low leakage path for the pool water and that what leakage might occur would be drained to an appropriately designed method of disposal. The RRI interviewed Individual "A" on May 30, 1979, in conjunction with the Region IV Reactor Construction and Engineering Branch, Projects Section Chief, in order to gain additional information relative to each of the allegations received over the telephone on May 25, 1979. The additional information and clarifications were as noted in the Summary of Facts included in this report. In addition, Individual "A" acknowledged that he had only very recently become aware that the stud system existed for holding the plates in place and was, in fact, unaware that the leak ' chase channels were piped to,a collection point for controlled collection } and disposal of any leakage which might occur.
'- The RRI interviewed Individual "B" in the presence of the licensee's site QA supervisor, also on May 30, 1979. (This arrangment was allowed since
! Individual "B" only came to the attention of the RRI through the assistance l of the licensee's representative.) The allegations of Individual "A" were l reviewed in detail with Individual "B" who essentially confirmed Allegations 1, 3 and 6, but indicated he had not worked in the Allegation 2 area and further indicated that he had no complaints about lack of effective QC nor had he been instructed not to follcw welding procedures.
- The RRI interviewed Individual "C" on May 31, 1979, with the same results I as those obtained in the interview with Individual "B." Individual "C" indicated that he perhaps was one of the persons referred to by Individual I "A" in Allegation 3. He also indicated that he had very limited welding l experience before coming to work at CPSES and none in "Heliare" weld process.
He was given some forty hours of very informal training and then used fifty-two ' hours to make his weld test coupon, a duration that he now considers to be excessive. He now thinks that he is a good welder. I L.__.__.__.___ _ . . - ,. . -
===_
The RRI interviewed Individual "D" on May 30, 1979, and again June 1, 1979, to develop any facts relative to the specific allegation of " buying-off" joints over the phone. Individual "D" categorically denied that he, or to his knowledge any other QC inspector assigned to this work area, had ever
" bought-off" a designated inspection point without making the required inspection. On June 1, 1979, Individual "D" indicated that there had been very few occasions when he had given consent to the welders to weld up a seam that, by the inspection reports, had been previously inspected for fit-up and cleanliness. He also indicated that he and others haa repeatedly stopped work on welding of seams where it came to their attention that water or moisture was interfering with good welding.
The RRI interviewed the Boilermaker Superintendent on June 4,1979, relative to his knowledge and/or participation in any of the allegations. He cate-gorically denied ever directing welders to make welds where water or moisture was present, but acknowledged that it was a constant problem. He indicated that he finally received engineering permission to drill holes through the liner at the ends of the leak chase channels so that air could be blown through to dry out the channels and that this action helped a great deal. He indicated that he had continuely attempted to impress the welders with the importance of making good seam welds.
- 4. RRI's Assessment of the Liners The RRI observed some of the welding work on the refueling pool in the Unit No. 1 containment during the latter part of 1978 and the early part of 1979 incidental to making inspection of other activities in the same work area.
The welding appeared to be normal and the dye penetrant examinations appeared to be properly accomplished. The finished surfaces examined have been uni-formily smooth and appear sound. The RRI also' examined some unfinished areas in the Unit 2 spent fuel pool and can appreciate the difficulties that may be encountered in removing some of the concrete laitance fron the vertical weld i joint areas. i i _g_ r__..._._. ._ . . .__ __ . _ _ ._...,_ _..
u=:Teo siairs nu:staa ascuwATen, co rwss o=
'* *!! INSoECTION t. ENFORCEMENT - STATISTICAL DATA s (n"?2a*. ig73 &
"::n.
.A.s h ,.*;*f :a b-h m? ' *
- h ;NQsCToms) D"T *1-- PRiucip AL IN5esCTEC I,*U .:.
~
^M -e' " %
' C . T.t t f f *.O.'* I.g;3 .:.; D.W t i gs_f ~ , CO .
- ,ap i- ..,v s s-R E viEwE R t' U -m - - h::
T **
= e f.: im Ateon T 4:o. oAft$iN iNvtStsic:5r R t Gio:. [T e-* F RO?J CONDUCTING 7 -. " 19 74 ACTIVITY l"**
. ,3'
! !O !5 'O D h IL l' I3 I Cil Ol SI 21 O 17 lo I .
,. i e-tp - is is u u oo Y v ,' .
8 0',. 0ta.517.0 6sv*N:0uCTi I 71 Ol 1! C I TO L
- 7 14 25 30 g.. . ~ i1I i i TIIIIIil I io I o! el o! cl 7 !91
^
u M 00 Y Y pg;- .isas;n s* ev y R ES10f t:7 INSPECT 0 h en 1 C RtGIO*dAL 08FICE STAFF 3 C PERFORMANCE APPRAl$AL TEAM
+ +, a r : : A; ,- . . c; .;,ref t , .;st;< o :t Ep O,,tvi
. sh. I?;$PECTION OTHER C ,
05 0 */ANAGt*JENT AUOff 03 C h*ATL AOCT 13 C IMPORT ' 14 CuiRy sc2 ** 5a s tT* c5 C L*=4A0af>ENT VsSif 10 C PLANT SEC. I 15._ s *J C .*.0.0 *NT C7 C $8103AL 11 O INVEN'. VE Plf pffs my:.vESTIGAtl0N g5T. ALSO CatCE
*4 *. I *. 8 0 8 C E *.* I *.T CI C VENO 34 y 12 C sMIP'.1ENTiEXPCs1T g stocu s!
, I :=;t s u ,e, , o n c, ; g t ., , a r, ; , ef A s ,* - ANNOUNCED 2 C UNAN*JOUNCEO iH / A1~
'" ?" " 3 0 WEE KE NQ/MQLID AY l - - 1 2 CCFF SMtFT t :H /((QAY $HIFT
, .p s T ,.s . i v J.* ; y. s. .*is e. TiUa. iC> E C A Crif Sa x ou vi 4 - y
' s -* M 1
( y 7(a gc:0*. AL DEF*C8 (f TTEm 3 , Rest anEO TO MOS FOR ACTtON 4 O REGION LETTER & MOS FOR ACTIOP.
! 9;.s.s-t 9 . c . i. I 5
- a *
- a
- 3 8 *. :.,8 *:V (OpetCK 04! ROx OMvs l g 'ki /
, l*1#'J a aP 2 C C.M* **ti A :CE 3 C CEV.ATION 4 C NONCO*.17LIAfsOE & CEVlatl0N L F.7 ;,8 t ?E:.T C0.*.8 E n gagg %g tp. 3 g 40 41
,f..**. !s > ;;s *.Q q;Q',*si AN l iT1*.*b lN L E TTE R TO LiCEN5f E.
, nott I 01 ol emanci 2 v .neu.s.t
.v . ,R s susmfTeo Y,ooo g CITf D 8744s Os moes:onspLsasca
' 47 4.1
.
- Vf.*318 QS 'Ji:AT!CN t*!*.*$ ?. LITTER TO LIOFN3f f l 1 ni es CFFi:1 ALLY 0465T50 FaoM f f Vf TutRECORD l 44 45
, C 1,rr.,'?t!P 08 u:E *.!!! !V ENT E l l [
' .4t ::.5't * *a r. .t ;
f 1 *; *:0?..Rc**J "'*.! . ENCCR INo 8 e, 2 C ROUTINE (No Feel 3 C ROUTINE (Feel 4 O ROU'INE ff ee Reducedt 0 ju c ,, .Tra. t : n g ia,rcRvar ON 0 5 YES a R f!:i , . . 7 U .!*?i & *.* -i s0 WT TR A A3VITTAL CATE FOR INSPECTIO*! OR stivf 5TIGATIO .
,k
! Hi OR LE?u > t$5vFO T*; LiCEN5f t REPORT SENT TO MCS FOR ACTION IMMEDIATE A TICN LETTER I C T3 51 ** 63 04'E 65
! l ! i l'i Il I IIIIII I II III I MM C O Y Y i :.* O C v v M #A 0 0 Y Y SURJECT Of sNv ESTIGATION LCMECA ONE SCx oNLvi 6&67
.f.
'vP! a :: :56 : 4:1 TYPEt 0 0* R 20 c5 MISC
' ? * *. *.* t * *.. . C'J !
- 5 / 800w & E 05 0 11 *1 eNT cvf RE XPCS.'RF 15 C CR8 TIC ALITY 21g EDUIP F A? LURE f iC2 C ID 'IC. A. C it
- t ?*L5u*! c? "; 12 C EX1. 0VE RE XPOSURE 1C C LO53/THE87 22. ALLEGATION /
13 C ExC1$5 RAD LEVELS 17 C MUF YC M*L AIN T
$ 133 0 H.1 *A5170 V%8157 A* EA CS C 18 0 T R ANSPORT ATION 230 PUBLfC INTE9EST C9 0 14 C EXCES$ CONC LEVELS ,
l Oa :" LC4.M08 101:*FPt*ER ' AC'.L'I' D.?.*ACI 10 0 19 C CONTAM/LE Ast4NG 24C $A80TAGt SOURCE 250 ABNCRMAL OCOUR k 23 C ENVIRONMENTAL l EVENT 28C OTHER ME A ,,C
- T EMS ENTRits I
sa n L 7 !a0: On: .0. r.ss e.vlsT REsaRREo sV REGi:N: C , =,L . . , ,)c1;- !, .
. l l l
~ 7C 75 e NOTE: SLCCKS K TO N A*U57 51 V l0A?f a .5 E*.*O*0EME:47 t,ET*ER.NCTICE.ORDEs tS3VED: l l l l l l l VERIFIED 8v IE:MOS
, M U D D Y Y WHENIVER ENTRIES ARE f 76 MADE IN 8LC0K$ T, U l 1 6 Ano y V Civit Pt'.4 L TV 13* Jt 77 te W OATE ;H ENTimtD :*sTO CC?.** UTER FILE WO/YRI 1III I AO y' ,,. y y arsfess q.
wwtto statss =uctsam as culatonv comssiO= 8 2 * * ';*{ .~ I : INS 71: TION Cs ENFORCEMENT - STATISTICAL DATA stat "n.
*::t:! ,,,,,
! $ s: .. v s.: ef h ; M e g U .it No.e4pt TORisi F5Tav(.; >Rm i A.,lr3, @ vior
, M i HEvitnER M '* S t s & Ad v.a. isru.r.W 1 '~' ".'" l
>*f,;; ;.@.41 f v 8 *.0 0: 6 '" p - s e I'd i d
- d o r f* * " . CO. g t pA.5.: 00;e.i' .Nw'. A E G 4As REPORT NQ. DATES at.O sNv1ST.st& R IGior. {
I;;;.; . . F MO:.: CONOU* TING L
. 78 l ;ist
' AcilVITY i
l rs f r. lr k l,'= l > ll kl (cj l pl *,l 9 l O l7 l0 l A g l ~ ** ~.F, * ! 15 18 r.t 1.: oo y v f
; 08 L. f'.Sk NO !8v 'QDUCT) I d 01119i TO 4 2- H 25 30 9 '
mi ol 61ci t l7191 A."A. Iiit i IIl l l i i lI M t.3 0 0 Y Y 8
- - - .as s A > ra 1,v
, g ,gg,;,,L e,,,,E STAF F ISIOENT mS'iCTOR
~3 C PERFORuANCE APPRAISAL TEAJA v a r , s ; - *.v *
- t ? . :v * ** THECM CM tC? ON'.Vi OTHER lT3*T~~
4 INS *ECTION I CJ C MATL ACCT. 13 C luPORT 14 UIRY C! CS ** MANAGEMENT AUDIT 10 C PLAT:T SEC. I1 VESTIGATION
'C2 2 SAFtw CS C U AN AGEMENT vi$r.
' ;7 i e . C i *.T 07 C S7ECI AL 11 O INVENT. V E RIF. , inwest. ALso C>ecs l C4 ~ 17. 8 0 * ;E '.' E NT C3 VEND J*R 12 C SHIP?.:ENT/ EXPORT g OLOCK Si
, ,1 e s s ;-
- 0 4 : ' v!S?a
- AT10N r. A R TN*.-
, ANNQUNCED 2 C UN ANNOUfdCED
- 7. n "W ' F-r trjjDiv SHIFT 2COFFSMtFT 3 C w!E KENO /MOLID AY 6 h:
p . a s 6 0 * ". m i a at *G-T.0:: ?.3Tisi; ATION 4 CHECK V.E RUE OY.Yi A Qi ,
- t ** ! ? '
_ 7- s *, DN A'. Cat:CI LETTER 3 O REFERHf D TO MOS FOR ACTION 4 C REGIO's LETTER & NOS rOR ACTION
,i .se *
- y e . e s trig AT.O.a si.:3iNGS f HFCE OP:t 80x ONL 5 e
( lJSg / It *M.t a t 2 7 NONCOMPLIAN*1 3 C CEvlATION 4 0 NONCOMPLIANCE & CEVIATION L . t Ts * . s '?! ?.T O. site:.:EHELD 1 233 40 de
** I .U'?tth P Of NO::CO*/PLIA?lC1 ITT!?S IN LETTER TO LiOI*:StE- motg. Cma=ct uvst at susu'TTto CN 756 WestNavam #RtveCusLv l 42 43 Cff to rTtu C8 NomCO=seuas.C4 ini i is o88 *iALLv etttTso FRom
. Nu".*S!* 0f O!v:ATC*: TEV* lN LETTEP TO LICENSEE: I v i 01 Te44RtComo 44 45 C,
., ,=.g*f ggm Os LtCEN!!E EVEf4TS ; l l l ,
14 c.SsE;T'3:. F EE .
# 4 C ROUTINT IFu RoomsO 12 ?;ON AOwTiNEivf EDOR (No Fun 2 C ROUTINE (No F.et 3 C ROUTINE (Fut O {4; co.4 TINTS 2 7500 INFCauAitON 07 YES l l a !* */.: . "J F $ e.* T*i R OR RFDDRT Tm A.*.SVITTAL CATE FOR 1*0PECTION CR t*tvf STiG ATIO!. .
a r IItMEDIATE ACT:ON LETTER l g l' ai 08 Lt"!F is$dEO TO LICINSEE REPORY $1NT TQ N05 FOR ACTION 59 ao DaTE 65 s' 51 54 I l i l*I I l lu uIIIIII O O Y Y I II III i it. E L O y y
. L C y y I
i SutJ&CT Os irevEST6G ATION ICHECK Ohi BQ A 04Lys 4,r.k57 a *
- v'4 4 10 08 8* 20 t*3 TYt E S 10 CFR 20 40S MISO 11 C INT. OVE R EXPOSU R E IS C CRifiCALITY 21C UiP. F AILUR E
- lC' ** i'.* E 5 '. AL O'. f R e x805U A f CS C 22 LLEGATIO:4 Ex*1R?.A'. L4EF1xPCSy*E 07 C 12 C EXT. OVEhExkOSURE 16 C LOSS / THEFT 4 COM*.AINT i
$ lC2 05 C 13 C EXCESS R AD. LEVE LS 17 C MVF
,02 C sg.g43f TC usalST APIA 23C PV8LiC it.TEREST 08 C to C EXCESS CON" LEVELS 18 C TRANSPORTATION iCA C LOSS 08 8 A lLIT' 240 SABOT 4GI !
'CS C FAL8f*'y *A*.*A*I 10 3 19 C CONT AM/LE AKING SOURCE 250 A8 NORMAL OCCUR 20 C ENVIRONMENTAL EvfNT 2SC OTHER g NEAOvamTE75EP.TRi&S ,
T IMC3 ACT:0N ON I':S* INVEST RIFERRED 8v REGION b i
; ........-..~. Iii .
- 70 75 ,
L' O ATE -05 E'i C9CE"ENT 8 LETTE R, NOTS E.ORDERISSJED: l l l l l l l 4 FlEO BY BE C3 M M O D v Y WHENEVER ENTRiiS ARE
, MADE 1N BLOOKS T.O ANO V V !Ciw eL *1'.-LT v tS$v!D g IIill I
. _ ,, _ TERE =tN,O _ ,ER., _ vR, M M , Y - =ER_E
+ . s..
INVESTIGATION PLAN IE Investigation Report No. 50-445/79-15; 50 446/79-15 ) Licensee: Texas Utilities Generating Company . Location: Glen Rose, Texas Facili ty: Comanche Peak, Units 1 & 2 Type of Licensee: E, PWR,1150 S'e Type of Investigation: Allegationt - Dates of Investigation: Ny 29 - June 4,1979 Dates of Previous Investigation: May 15-18, 1979 Investigators : R. G. Taylor & W. A. Crossman SCOPE OF INVESTIGATION 099014B - investigate seven allegations by former Brown & Root Boilermaker welder ? L Reactor Inspector s/soh9 Date W= Approved r/ch Date
*r T y**wv -
w -,y-g9 y*%e ,,e --9p e &T'wi p te 6 -#g** eye, _s;. t T *
- s f * * **}}