ML20205J777
| ML20205J777 | |
| 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-85-135-SQN, NUDOCS 8602260409 | |
| Download: ML20205J777 (7) | |
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TENNESSEE VALLEY AUTHORITY-NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. I-85-135-SQN EMPLOYEE CONCERN: XX-85-049-001 XX-85-049-XO3
SUBJECT:
WELDER CERTIFICATIONS UPDATED WITHOUT MEETING REQUIREMENTS DATES OF INVESTICATION:
NOVEMBER 26 - DECEMBER 12, 1985 INVESTIGATOR:
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BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of two expressed employee concerns as received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concerns of record as summarized on the QTC computer printout and identified as KK-85-049-001 and XX-85-049-X03, respectively, stated:
Sequoyah: Welder certifications have been updated for welders who did not meet update requirements or backdated to give appearance of requirement compliance.
Sequoyah: Walder certification card falsified.
Construction Dept Concern. ' CI has no more information.
The K-form for XI-85-049-001 had not been received from QTC/ERT whsn this investigation began on November 26, 1985, although the concorr was received by them on July 12, 1985. NSRS requested that QTC/ERT provide the K-form so the investigation could proceed. On January 24, 1986, the K-form was received the concern and was exactly as described by the above statement of the employee concern which was obtained from the summary on QTC computer printout.
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 A.
The scope of the investigation is defined by the concerns of record which entailed determining three specific issues:
1.
Were welder certification / continuity records correctly maintainted?
2.
Was there any evidence that records were backdated or falsified?
3.
Are there any safety implications?
B.
In conducting this investigation NSRS reviewed the requircments of the ASME Code, the Nuclear Quality Assurance Manual (NQAM), Nuclear Power Welding Program Requirements, and audit and cor?entive action reports. Several cognizant individuals were interviewed concerning the welder certification, continuity requirements, and recording.
NSRS also reviewed 4 random sample of approximately 25 welder certification and continuity records.
III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments 1.
TVA Topical Report, TVA-TR75-1A, Section 17.2, " Quality Assurance Program, Program Applicable to Operation" 1
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2.
NQAM, Part II, Section 6.1, " Welding" 3.
ASME,Section IX, " Welding and Brazing Qualifications" B.
Findings 1.
References 1 and 12 require personnel performing special processes (i.e., welding) to be qualified and their qualifica-tions to be documented.
2.
ASME Section IX (Ref. 4) provides requirements to the power industry for qualifying welders and guidance on how to continue to maintain their qualification (continuity).
3.
Nuclear Power has defined in reference 3 how to meet the requirements of ASME Section IX.
Reference 2 provides the requirements that the Division of Construction must follow.
4.
Sequoyah Nuclear Plant (SQN) utilizes references 7 and 8 to implement the requirements of the welding program.
5.
In the past, Nuclear Power has accepted construction welder performance qualification without rotesting. However, because of the welder certification questions recently raised at Watts Bar (Ref. 10), the SQN Site Director issued a memorandum (Ref. 9) to site management directing them to discontinue this practice.
6.
In August 1985, an investigation of the welder certification and continuity program was started at SQN with the Plant QA Staff, Mechanical Maintenance, Mechanical Modification, and Hartford Inspector being involved (Refs. 6, 10, and 11).
7.
As a result of this investigation, a corrective action report (Ref. 13) was issued identifying problems found.
8.
A copy of a memorandum from Individual F, Mechanical Modifica-tions Supervisor, to Active Welder's Files, dated October 23, 1985, was placed in each welder's files indicating that all
- active welder's files were reviewed by QA surveillance personnel and weld-test representatives and discrepancies cberected.
There were 10 welders whose certification papers were missing or there were gaps in 'their construction continuity records.
Their weld cards were pulled, and these welders were not allowed to weld until qualification requirements were met.
Two welders' qualification test records were obtained and placed in their files. These two did not have a continuity problem. The remaining eight whose continuity records could not be obtained were retested in accordance with the renewal requirements of the ASME Section IX Code.
2
e 9.
In discussion with a toolroom clerk (Individual H) who updates the continuity records based on weld filler material draws, he indicated that some. draws may be inadvertently left off the welder certification printout.
Once the error or omission is detected, the records are corrected for the timeframe for which they were missing.
The welder certification printout is presently done once a month. However, Individual H said they may start doing the printouts more often; and, therefore, errors could be detected sooner and corrected before a month's time elepses.
10.
A proposed corrective. action response was received from the responsible supervisor and concurred with by QA on October 25,,
1985. The response identified several root causes for the problems found. One main cause was clerical errors in the recording of and transfer of information. Another contributing factor was the different methods of updating continuity by the various organizations, such as the different construction sites and Nuclear Power. These methods have changed over the years and are much more stringent by today's standards. The CAR response conclusion was that no safety concern existed since all active welders were brought into compliance with requirements and all safety-related welding was performed in accordance with an approved QA inspection program. Plant procedure M&AI-5 has been revised to clarify the responsibilities and method utilized to maintain continuity.
11.
A random review by NSRS of welder certification files revealed that corrections had been made and initialed by a responsible weld-test representative. However, no indications of backdating or falsification were found.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusion 1.
The concern that the welder update (continuity) requirements were not being met was substantiated and had been' identified recently in a QA audit finding. All active welder records have
" ~ ' been properly updated by supporting documentation er the welder retested.
%s 2t t
The concern that~ records may have been backdated in order to 2.
give an appearance that the welder was qualified could not be substantiated. There were some clerical-type errors where-incorrect dates were entered on welders' records, but these were corrected when a review identified discrepancies between welder continuity record sheets and supportive documentation.
(i.e., welder performance qualification record). In addition, the toolroom clerk may have missed entering weld filler material draws on a welder's record and correctly updated the continuity records later, but this is not considered backdating. No evidence was found that indicated falsification of records had occurred.
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3.
There appears to be no safety concern since all active welder records were either correct or readily restored to require-ments. Also, all safety-related welding is independently inspected per an approved QA program.
4.
Corrective Action Report SQN-CAR-85-09-14 (Ref. 13) did not address the consequences of the previous (nonactive) welder continuity program.
B.
Recommendations 1.
I-85-135-SQN-01, Evaluation of Previous Welder Continuity Records A sample of previous nonactive welder records should be performed to gain adequate confidence that welder certifications were maintained and that no safety implication currently exists.
[Pl}
2.
I-85-135-SQN-02, Corrective Action Backfit Evaluation TVA formal corrective action processes such as corrective action reports, nonconformance reports, etc., should be evaluated to include a backfit evaluation provision to determine if the identified deficiency requires such action to provide substantial, additional protection for the public health and safety or the common defense and security.
[P2]
3.
I-85-135-SQN-03, Verification of Corrective Action Taken on S0-CAR-85-09-14 To assure that all documentation problems have been resolved and all corrective actions have been completed or implemented, the plant QA staff will perform another indepth audit of the welder certification and continuity program in the next few months. This verification (audit) will allow satisfactory resolution of the CAR.
This is an NSRS tracking item only.
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DOCUMENTS REVIEWED IN INVESTICATION No. I-85-135-SQN AND REFERENCES 1.
NQAM, Part II, Section 6.1, dated October 12, 1984, " Welding" 2.
General Construction Specification C-29 Process Specification 1.M.2.2 (Revision 2), dated February 10, 1983, " Welder and Welding Operator Performance Qualification" 3.
Area Plan, DPM No. N73M2, dated August 28, 1984, " Process Specification '
for Welding, Heat Treatment, and Allied Field Operations" 4.
ASME Section IX, 1983 Edition, Winter 83 Addenda, " Welding and Brazing Qualifications," Section QW-320. " Retest and Renewal of Qualification" 5.
SQN Construction Procedure No. W-2, Revision 1, dated July 6, 1981,
" Welder and Welding Operator Performance Qualification" 6.
Compliance Visits, Audits, and Inspections - Inplant Survey Checklist No. Sa-85-S-007, dated September 22, 1985, Survey
Title:
Welder Qualifications and continuity 7.
SQN Standard Practice SQM 17. Revision 2, dated May 17, 1984, " General Welding Requirements for Nuclear Plants - DPM N73M2" 8.
~SQN Modification and Additions Instruction, M&AI-5, Revision 8, dated October 7, 1985, "Weiding Material Control Procedure" 9.
Memorandum from H. L. Abercrombie to Those listed dated August 29, 1985, " Welders' Certifications" (S02 850828 979) 10.
Memorandum from David H. Tullis to Boyd M. Patterson dated September 13, 1985, "Sequoyah Nuclear Plant - Welder Continuity Program" 11.
John G-l-Brady's notes of September 3,1985, concerning survey conducted by Doug Frye and himself to review the welder continulty program at S.QN and determine if any problems existed 12.
TVA Topical Report TR75-1A, Revision 8. Section 17.2.9, " Control of Special Processes" 13.
Corrective Action Report SQN-CAR-85-09-14, cated September 12, 1985 14.
Random (approximately 25) welder certification files 0046W 5
TvA'60 cos-s-esi coawp s-as UNITED STATES COVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant R. W. Cantrell, Manager of Engineering, W12A12 C-K FROM: K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K
((g { } jQ86 DATE:
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL Transmitted herein is NSRS Report No.
I-85-329-SON Subject OUALITY ASSURANCE CONTROLS / COMPRESSION FITTING INSTALLATION Concern No.
XX-85-050-001 and associated prioritized recommendations for your action / disposition.
It is requested that you respond to this report and the attached four Priority 2 [P2] recommendations by February 28, 1986. Should you have any questions, please contact W. D. Stevens at telephone 6231.
i Recommend Reportability Determination: Yes No X
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[ irector, NSRS/ Designee WDS:CDM Attachment cc (Attachment):
W. C. Bibb, SQN W. T. Cottle, WBN James P. Darling, BLN R. P. Denise, LP6N40A-C C. B. Kirk, SQN D. R. Nichols, E10A14 C-K I
QTC/ERT, Watts Bar Nuclear Plant Eric Sliger,_.P6N48A-C A L
l J. H. Sullivan, SQN p455U L
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