ML20205J771
| ML20205J771 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 02/17/1986 |
| From: | Brock L, Harwell E, Stevens W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340195 | List: |
| References | |
| I-85-768-SQN, NUDOCS 8602260408 | |
| Download: ML20205J771 (8) | |
Text
r-c TENNESSEE VALLEY AUTHORITY NUCLEAR SAlETY REVIEW STAFF NSRS INVESTIGATION REPORT NO.
I-85-768-SQN EMPLOYEE CONCERN:
SQM-5-001-001 SQM-5-001-002
SUBJECT:
UNCERTIFIED WELDER FOREMEN PERFORM PREWELD INSPECTIONS DATES OF INVESTICATION:
DECEMBER 30, 1985 - JANUARY 20, 1986
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INVESTIGATOR:
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REVIEWED BY:
L. E. BROCK DATE APPROVED BY:
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I. ' BACKGROUND -
A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of two expressed employee concerns as received by I
Quality Technology Company (QTC)/ Employee Response Team (ERT). The concerns of record, as summarized on the Employee Concern Assignment Request Forms from QTC and identified as SQM-5-001-001 and SQM-5-001-002, respectively. stated:
Sequoyah - The General Construction Specification G-29C, Process i
Specification O.C.1.1 is in conflict with the TVA Quality Assurance Commitments as stated by the TVA Topical Report, TVA-TR75-1A, in that process spec. 0.C.1.1, section 6.0 allows uncertified welder foremoni!J.
who have direct responsibility for installation, to perform pre-weld inspections, Nuclear Power Concern. CI has no further information.
i Sequoyah - Uncertified welder foremen are required by TVA to perform pre-weld inspections on incta11ations they are directly responsible fer, which is a violation of ANSI requirements. Nuclear Power Coccern. CI has no further information.
Since these two concerns deal with the same area, the investigation was done in such a manner that a single report covers both concerns..
II. Scope 1
A.
The scope of the investigation was determined from the stated concerns of record to be three specific issues requiring investigation:
1.
Do uncertified welder foremen perform pre-weld inspections?
2.
Is this a violation of the TVA quality assurance commitments?
s 3.
Is this a violation of ANSI requirements?
B.
In conducting this investigation, MSRS reviewed the AWS code, ANSI L
standard commitments, QA tier requirements, welding and inspection
. program requirements, and plant implementing instructions.- Several
- ,' people were interviewed who' had been associated wi(h defining welding and inspection requirements or had been responsible'.fo'r field A implementation.
_ gh III.
SUMMARY
OF FINDINGS '
A.
Requirements and Commitments 1.
Topical Report TVA-TR75-1A, Rev. 8. Section 17.2, "TVA Quality' Assurance Prograr. Program Applicable to Plant Operation."
2.
NUREC-0011, Safety Evaluation Report, dated March 1979, for Sequoyah Nuclear Plant finits 1 & 2 Docket Nos. 50-327 and
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50-328.
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Nuclear Quality Assurance Manual. Part II, Section 5.3,
" Maintenance and Modification Inspection Program."
4.
ANSI /AWS D.1.1, " Structural Welding Code - Steel."
B.
Findings 1.
The Sequoyah structural steel components were designed in accordance with the American Institute of Steel Construction I
(AISC) specification. This was acceptable to the NRC as stated in the Sequoyah Safety Evaluation Report (Ref. 14).
2.
The welding associated with the AISC specification, particularly" s
welded steel structures, is governed by the American Welding Society (AWS) Code D1.1 (Ref 16). This AWS Code requires that all completed welds be visually inspected:
" Visual inspection of welds may begin immediately after the completed welds have cooled to ambient temperature."
3.
The AWS Code states, "The Inspector shall, at suitable intervals, observe joint preparation, assembly practice, the welding techniques, and performance of each welder, welding operator, and tacker to maxe certain that the applicable requirements of this code are met."
4.
The AWS Code requires the inspector to verify the size, length, and location of all welds; that correct procedures are used; that welders are qualified; and that proper filler material is used. The AWS Code states that, "Other acceptance criteria, different from these specified in the code, may be used when approved by the Engineer." The engineer in this case is the design organization.
5.
References 4 and 5 require that all individuals performing QC inspections be qualified and their qualifications be documented.
6.
Plant impleuanting procedures and instructions (References 1, 8, and 10) require that inspectors performing QC inspections be qualified and certified.
Reference 1 states, "QC inspection
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shall be performed by qualified individuals other than those who performed or directly supervised the activity,b81'nt inspected."
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7.
Process Specification 0.C.1.1 (Reference 6) was prepared and 4
issued by the design organization as being their defined requirements for welded fabrication of steel structures in accordance with AISC specification, and the AWS Structural j
Welding code, process Specification 0.C.1.1 requires, as a j
minimum, the pre-weld and in-process welding activities be verified by the welder and his foreman and be subject to a quality surveillance program which verifies that these acitivities are being properly performed. The post-welding (finished weld) inspections are performed by an AWS certified 4
inspector who is trained and qualified.
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Process Specification O.C.1.1 is not'always invoked in workplans; however, when it is not invoked the inspection requirements become a negotiated agreement between the organization performing the work and QA as the means of meeting the interpreted, applicable code requirements.
8.
A design engineer Individual E, knowledgeable with the AWS Code requirements and the process specification, said that the pre-weld and in-process welding verifications performed by the welder and the foreman were not QC inspections and were not required to be QC inspection hold points by the code.
Individual E said that the only QC inspections required by the T-code were the finar weld inspections performed by the QC-inspectors and verfication of compliance via a surveillance program (which is implemented by QA/QC personnel).
This in consistent with the code requirements verified by the investigator in Findings 2, 3, and 4.
9.
The investigator was advised in discussing with plant QA staff personnel that the welding survelliance program is accomplished per the instructions of QA Section Instruction Letter 18.1,
" Surveys" (Ref. 13).
10.
Reference 12, an inplant survey, identified a difficulty that the QA staff was/is having with meeting the inspection requirements of Process Specification 0.C.1.1.
The specification allows for increasing the size of the fillet weld to compensate for a fit-up gap grea*.er than 1/16 inch.
Since QC acceptance is based solely on the final visual inspection, QA contends that it is impossible to determine if the fillet weld size has been adjusted to compensate for fit-up gap in excess of 1/16 inch since a QC inspection at fit-up was not required.
Their (QA) recommendation was that craftsmen should note whether the weld fit-up gaps exceeded the 1/16 inch.
g IV.
CONCLUSIONS AND RECOMMENDATIONS
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A.~ Conclusions
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' 1.
The concerns OE. record were not substantiated"for the following reasons:
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a.
The pre-weld and in-process welding verification activities done by the welder foremaa are not considered QC inspections and are not required to be QC inspected by the governing codes.
b.
Since these in-process verifications, discussed in IV.A.1.a are not QC inspections, only the final weld inspection and the surveillance activities require a qualified and certified inspector.
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c.
Since these in-process verifications, discussed in IV.A.1.a. do not require a special process (NDE inspections), individuals performing these activities do not have to be trained and certified per ANSI standards.
In fact, the AWS D1.1 Structural Welding Code is an American National Standards Institute approved document.
d.
Although the lack of QC hold point inspections for pre-weld activities seems awkward compared to the ASME requirements, Process Specification 0.C.1.1 meets the requirements of the AWS Structural Welding Code and is consistent with the commitment to the NRC to design and fabricate structural components to -the AISC specification.
B.
Recommendation NSRS agrees with the recommendation made in QA Inplant Survey Sa-85-A-005 that the craftsden or foremen checking the fitup gap should note it in order that the QC inspector doing the final weld inspection will know what size fillet weld should be present.
Post Investination Findinzs Area Plan Procedure DPM N73M2 was revised on December 10, 1985, to tak'e exception tc the preweld inspection activities of process specification O.C.1.2 by requiring these activitier be done by a certified QC inspector for all safety-related items. Per discussion with a Nuclear Service Welding Ensineer, P.S. 0.C.1.1 should have been included, and a revision is presently being processed to take the same exception for this specification.
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DOCUMENTS REVIEWED IN INVESTICATION I-85-768-SQN i
AND REFERENCES
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1.
Sequoyah Nuclear Plant (SQN) Administrative Instruction AI-20. Rev. 10, j
dated November 21, 1984, " Inspection Progra '
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SQN Modification and Additions Instruction M&A?,-1, Rev. 9, dated.
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-August 5, 1985, " Control of Weld Documentation and Heat Treatment" 3.
SQN M&AI-11, Rev.11 dated -September 4,1985, " Fabrication, Installation'^
and Documentation of Seismic Supports and Supports Attached to l
Seismic Category I Structures" i
i 4.
Nuclear Quality Assurance Manual (PQAM), Part II, Section 5.3 dated j
July 30,1984, " Maintenance and Modification Inspection Program" e
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TVA Topical Report TVA-TR75-1A, Rev. 8 Section 17.2.9
" Control of Special Processes," and Section 17.2.10. " Inspection"-
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6.
Area Plan DPM N73M2 Process Specification O.C.1.1, Rev. O, dated i
March 9, 1983, " Specification for Welding of Structures Fabricated
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in Accordance with AISC Requirements for Buildings" i
7.
Maintenance Instruction MI-6.21, Rev. 9, dated December 17, 1985, j
" Repairs and Replacements of ASME Section II Components" I
8.
SQNP Technical Instruction TI-51, Rev. 29, Procedure No. N-VT-2, Rev. 2, 4
dated July 1, 1982, " Visual Examinations of Welds" t
9.
SQNP T-51. Rev. 29, Procedure No. N-VT-3, Rev. 4, dated April 23, 1985, l
" Visual Examination of Weld Ends Fit-ups, and Dimensional
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4 Examination of Weld Joints" g
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SQN Quality Assurance Section Instruction Letter No. 10.3, Rev. 2 j
dated March 16,1982, " Inspection - Nondestructive Examination"
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SQE~huality Assurance Section Instruction Letter No. 1Q.4, Rev. 8, 11.
dated November 12, 1985, " Inspections - QC Inspections" tl 12.
QA Inplant Survey Sa-85-A-005, for period of August 19-23, 1985,
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"Special Process'es - Welding" l
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13.
SQN Quality Assurance Section Instruction Let'.or No.18.1, Rev.10, dated October 17, 1984, " Surveys" f
14.
NUREC-0011, safety Evaluation Report, dated 1979, Sequoyah Nuclear Plan *. Units 1 and 2 Docket Nos. 50-327 and 50-328
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Sequoyah General Design Criteria, SQN-DC-V-1.3.3.1, Rev. 4, dated September 4, 1984, " Additions After November 14, 1979, Reiinforced Concrete. Structural, and Miscellaneous Steel" 16.
ANSI /AWS D1.1-1985 " Structural Welding Code - Steel " Ninth Edition, dated February 8, 1985, Section 6 " Inspection," and Section 8
" Workmanship" 010SS
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i-TVA 63 (oS4 c5) (oP-WP 5 85)
(*NITED STATES GOVERNMENT MemorandMm TENNESSEE VALLEY AUTHORITY TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FRON: K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K gg g
DATE:
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSMITTAL Transmitted herein is NSRS Report No.
I-85-135-SON Subject WELDER CERTIFICATIONS UPDATED WITHOUT MEETING REQUIREMENTS V
/
Concern No.
XX-85-049-001 and XX-85-049-X03 and associated prioritized recommendations for your action / disposition.
This report contains one Priority 1 (P1] recommendation which must be addressed before startup.
It is requested that you respond to this report and the attached Priority 2 [P2] recommendation by April 17, 1986. The Priority 3 (P3] recommendation will be looked at for corrective action follow through by June 1. 1986. No response is required for this item.
Should you have any questions, please contact W. D. Stevens at telephone 6231-K Recommend Reportability Determination: Yes X
No a
w J' Director,NSRS/ Designee
(/
Y,s WDS:JTH Attachment P
ce (Attachment):
W. C. Bibb, SQN J. W. Coan, W9Cl35 C-K W. T. Cottle, WBN James P. Darling, BLN R. P. Denise, LP6N40A-C C. B. Kirk, SQN F. E. Laurent, CEO-WBN W. E. Mason, EllC49 C-K--Review to confirm NCRS determination of no falsifcation D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C J. H. Sullivan SQN Kent Therp, ICE-WBN U
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