ML20205R460
| ML20205R460 | |
| Person / Time | |
|---|---|
| Issue date: | 03/30/1987 |
| From: | Abbate C, Stone J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20205R441 | List: |
| References | |
| REF-QA-99900762, REF-QA-99901018 NUDOCS 8704060354 | |
| Download: ML20205R460 (25) | |
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ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT INSPECTION INSPECTION REPORT 97 DATES: 02/03-04/97 ON STTC H0flRS?
NO.- 99900762/87-01 CORRESPONDENCE ADDRESS: Nuclear Energy Services ATTN: Mr. William J. Manion President d Shelter Rock Road Danbury, Connecticut 06810 ORGANIZATIONAL CONTACT: Mr. Craig Anderson TFIEPHONE MIPRFRt I?nO 746 G??6 NUCLEAR INDUSTRY ACTIVITY: Enaineering services for the nuclear power industry.
1 ASSIGNED INSPECTOR: b N. b Claudia M. Ablate, Special Projects Inspection d)at ]
Section(SPIS)
OTHER INSFECTOR(S): Patrick D. Milano, SPIS APPROVED BY: foa , [, W YJo/87 Jamef C. Stone, Acting Chief, SPIS, Vendor Progran Branch Date INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21, 10 Cid Part 50, Appendix B.
B. SCOPE: Review allegations concerning welding performed at the NES-Selamco facility in Greensboro, North Carolina. The welding and welding records involved in the allegations concern the fabrication of high density fuel storage racks for a number of plants and the reactor ravity pool seal fabricated for Connecticut Yankee (Haddan Neck).
PLANT SITE APPLICABILITY: Brunswick, North Anna 1 & 2, Beaver Valley 2, Trojan and Haddam Neck.
00 6 Eh1 PDR
ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION Mn - 000nn7A9/A7.01 RESULTS: PAGE 2 of 13 A. VIOLATIONS:
None.
B. NONCONFORMANCES:
None.
C. UNRESOLVED ITEMS:
None.
D. STATUS OF PREVIOUS INSPECTION FINDINGS:
- 1. (0 pen) Violation (85-01-01)
Contrary to the requirements of 10 CFR Part 21, Section 21.31, NES did not specify on purchase order No. N57605 that the provisions of 10 CFR Part 21 apply to Reno Machining Company who were to procure material to be used for fabricating clamps used in the steam generator no:zle dam assemblies.
This area was not reviewed during the inspection.
- 2. (0 pen) Nonconformance (85-01-02)
Contrary to 10 CFR Part 50, Appendix B, Criterion III, NES design calculation for the stear generator nozzle dam assembly did not encompass all aspects of the following: a) materials selection and suitability, b) diaphragm / seal sub-assembly stress analysis, c) all possible loading conditions (hydraulic, pneumatic, and seismic), di the correct subsection of the ASME III code per contractual commitments, and e) consideration for dimensional tolerances.
This area was not reviewed during this inspection.
- 3. (0 pen) Nonconformance (85-01-03)
Contrary to 1.0 CFR Part 50, Appendix B, Criterion XVI, NES Document No. ;09010 " Computer Code Documentation Control Procedure" did not have provisions for handling computer code error reports. Computer code error reports received from vendors
ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT IflSPECTION un - coonn'A9/97 01 RESULTS: PAGE 3 of 13 supplying computer code services were not promptly identified and corrective action to assure that conditions adverse to quality for past and present safety related components were not l
determined, documented and reported to appropriate levels of I management.
This area was not reviewed during this inspection.
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- 4. (0 pen) Nonconformance (85-01-04)
Contrary to 10 CFR Part 50, Appendix B, Criterion XVIII, NES had used Control Data Corporation's (CDC) services for computer codes used for safety related component analyses and had failed to comply with criteria in the aforementioned section of Appendix B by:
a) NES had not performed an audit of CDC to verify it's compliance with all aspects of the quality assurance program, b) NES did not have a planned audit of CDC scheduled, c) CDC was not on the NES approved vendor's list (dated 09-16-85).
This area was rot reviewed during this inspection.
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- 5. (0 pen) Unresolved Item (85-01-05)
Based upon observations made durino steam generator nozzle dam testina, questions were raised concerning the adequacy of test I equipment, procedure and classification of hardware. '
This area was not reviewed during this inspection.
E. INSPECTION FINDINGS AND OTHER COMMENTS:
- 1. Entrance and Exit Meetings An entrance meeting was conducted on February 3, 1987, at the Nuclear Energy Services (NES) office located in Danbury, Connecticut. The allegations involving the NES-Selamco facility in Greensboro, North Carolina and the inspection plan were discussed at that time. During the exit neeting on February 4, 1987, the inspection findings and observations were summarized.
'0RGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION ND - QQQn076?/R7-01 RESULTS: PAGE 4 of 13
- 2. Background Information This inspection was conducted as a result of allegations the Nuclear Regulatory Commission (NRC) received concerning the use of uncertified welders and possible falsification of welding records at the NES-Selamco facility in Greensboro, North Carolina between September 1982 and January 1983. The welding and records in question involved the fabrication of high density fuel storage racks (FSR) for a number of plants and the fabrication of the reactor cavity pool seal (RCPS) for Haddam Neck.
The alleger contacted Carolina Power and Light (CP&L) and expressed his concerns on February 8, 1983. CP&L subsequently notified NES-Selamco on February 9, 1983. NES-Selamco responded to the allegations by letter, dated February 24, 1983, and described the review performed by NES-Selamco and their conclusions based on the review. (The NES-Selamco response to the allegations is Appendix B of this report). Two of the allegations were substantiated by NES.
For these two items the cause was described and corrective action was taken. CP&L reviewed the NES-Selamco response and found both the response and corrective action acceptable.
NES-Selarco was closed in 1986 by the parent company NES and they have no plans to reopen the facility. The NES-Selarco records were transferred to the NES Danbury, Connecticut office where this inspection took place.
- 3. Allecations, Findings and Conclusions Allegation 1 - Uncertified welders performed work on fuel storage racks (FSR) for a number of plants and the Haddam Neck reactor cavity pool seal (RCPS).
Findings - The Welder Performance Qualification (WP01 records were reviewed for selected welders. The Welder and NDE travelers were also reviewed and did not list any welders who were not oualified by having an approved WPQ for the process and within the limits of the qualification. Thus, the available documents could not be utilized by the NRC inspectors to substantiate this allegatien.
NES-Selamco, however, substantiated the allegation through interviews with the employees. This is documented in the NES-Selarco response to the allegations (Appendix B to this report). As part of the NES-Selamco's corrective action, uncertified welders who did perforn
ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION un . aaann7so/pv_n1 RESULTS: PAGE 5 of 13 l
welding were given qualification tests after the fact and the welds in question were inspected and found acceptable per drawing and specification by NES-Selamco. Although the welds were not made by qualified welders, as required by the specification and the ASME Code,Section IX, NES-Selamco believed that in as much as the welders did pass the qualification test after the fact, and the welds were inspected and accepted, the integrity of the hardware is not in question.
Conclusion - The allegatien is substantiated.
Allegation 2 - Travelers and weldino records were not prepared and completed as required in that the entries were filled in after fabrication was completed.
Findings - The NES-Selamco response to this allegation stated that paperwork for work-in-process was caught up twn and three days af ter the fact by use of time cards etc., because it could not be accomplished on an everyday basis. The type of paperwork involved was not clarified in the allegation or the NES-Sclamco resporse and during the review of travelers and welding records the NRC inspectors could not deternine if the records reviewed were completed after the fact. The records which were reviewed contained the required information such as inspector's stamps, signatures, and dates.
Conclusion - Based on the review of the records, the inspectors were unable to draw a conclusion as to whether the allegation is substantiated or not.
Allegation 3 - Certified welders' stamps were used on documentation i for work performed by uncertified welders. {
Findings - As stated in Allegation 1, the Welder and NDE travelers were reviewed. Only welders who were certified vere listed on the records along with the appropriate stamps. Uncertified welders did not appear on the record sheets even though work was performed by them.
Conclusion - The available records could not be used to substantiate the allegation. However, NES-Selanco reviewed the allegation and in the NES-Selanco response to the allegations (Appendix B of this report) NES-Selamco substantiated the allegation.
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ORGANIZATION: NUCLEAR ENERGY SERVICES '
DANBURY, CONNECTICUT REPORT INSPECTION NO
- 44QOO76?/R7 01 RESULTS: PAGE 6 of 13 Allegation 4 - Welder certification practices were not in accordance with procedure in that the 6-G position was not held throughout the test, the practice of rolling the coupon on the table was used, and coupons from certified welders were used to certify other welders.
Findings - The welder certification records were reviewed. With regard to the first part of the allegation, no documentation was found to substantiate the allegation. Additionally, NES-Selanco asked welders qualified in the E-G position whether the position was held throughout the certification test. Ten welders signed a statement confirming that the 6-G position was held throughout the test (see Appendix B).
With regard to the second and third parts of the allegation, NES stated that a procedure for 6-G pipe test coupons was utilized where the root was welded in the 1-G position (rolling) by one welder, followed by the balance heing welded in the 6-G position by another welder. No written procedure outlining this method of qualification was available for review.
This process was also inadequately described on the WPQ. The summary of welders qualified should indicate that the welder was qualified in this manner and would be restricted from making open butt weld root passes. No evidence of welders, qualified by this procedure, making welds outside the appropriate range of variables was found.
Conclusion - The allegation is not substantiated based on the documents reviewed.
Allegation 5 - No quality control inspection or nondestructive testing (licuid penetrant test) was performed during the fabrication process although the documentation required it and indicated it had been performed.
Findings - The inspectors reviewed the travelers for the fabrication of FSRs and the RCPS. The cperation steps which recuired verification by quality control or manufacturing were properly stamped and dated. The welds which reouired liquid penetrant tests (PT) were also properly stamped and dated on the Welder and NDE travelers by a Level II PT inspector. In some cases, a Penetrant Certification was completed identifying the part tested, the material used, and the inspector's signature.
ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION wn - aconn7Aa/A7.n1 RESULTS: PAGE 7 of 13 Conclusion - Although the documentation was filled out properly, based en the after-the fact record review, the inspectors cannot determine whether the allegation is substantiated.
Allegation 6 - No control over the issuance of welding wire and rods; the established program was not being implemented.
Findings - The inspectors reviewed NES-Selamco Quality Assurance Procedure N10, " Control of Special Processes and Tests," dated July 1981. Section 4.1.5 describes the weld filler material control procedures. According to the procedure, a request ticket, traveler, and weld procedure were needed before weld wire was issued. Once the wire was issued, the heat number was to be documented on the Welder and NDE traveler.
The Welder and NDE travelers which were reviewed by the inspectors had the appropriate heat numbers recorded and in some cases, the weld wire material certifications, including heat numbers, accompanied the final documentation packace sent to the customer from NES-Selamco. The heat numbers on the certifications correspended to those recorded on the Welder and NDE travelers.
Evidence that training sessions were also conducted, which included the weld wire issuance procedure, was available (see Allegation 9).
Conclusion - Althcugh procedure implementation cannot be deterrined, based on the records which were reviewed, the procedure was follcwed in that the heat nunbers were recorded where required and the allegation is not substantiated.
Allegation 7 - No welding procedures existed for the work perforned on the RCPS; the welder used only the traveler and drawings to perform the welding.
Findings - The inspectors reviewed the fabrication records for the RCPS. The traveler outlined what operation steps required welding and referenced a weld map number. The weld map is a drawing which identified weld location, size, and type, and the weld procedure specification (WPS) to be used. The WPS is a written welding procedure used to provide direction to the welder while raking welds.
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l ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION
n . ooonn w /n7_n1 PESULTS: PAGE P of 13 Additionally, the Welder and NDE travelers which were reviewed referenced the Procedure Qualification Record (PQR) for each weld.
The PQR is a document wnich records the welding data and test results of the procedure qualification process. The documentation available and specified to perform the welding for the RCPS was no different than that used for the welding on FSRs.
Conclusion - WPSs were identified on the weld maps, did exist at the time and were traceable thrcugh the weld maps listed on the Welder and NDE travelers. Based on this review, the allegation is not substantiated.
Allegatinn 8 - Welds on FSRs were metal irert gas (MIG) welds.
The results were unsatisfactory and the welds were washed over with a tungsten inert gas (TIG) weld to give them the appearance of an acceptable weld. (This washing is an unacceptable practice which causes cracks in the weld due to excessive heat.)
Findirgs - The allegation did not give specific examples to locate the actual welds on which this practice took place.
However, the NES-Selamco response to the allegation did admit to the process of repair and completing welds using the GTAW (TIG) process. The Welder and NDE travelers did not indicate the use of multi-processes to complete a specific weld, although both the GTAW and GMAW (MIG) were approved and allowed for the fabrication. ASME Section IX allows the use of multiple processes and procedures to complete a joint as long as the procedures are qualified, individually or in combination.
The term " wash," used b gun (electrode holder) y thetoalleger, was used wasmetal melt the weld taken to mean that the T without addition of filler material. 1his meaning of terminology was concurred in by NES.
The records did not reflect any multi-process combination welding and the alleger did not state that the welds were unacceptable during inspection.
Conclusion - It was impossible to confirm this allegation through the documentatinn reviewed. If the activity of " washing over" welds had occurred, it would not have been acceptable from 1) the standpoint that the GTAW procedure was not qualified without filler metal addition, and 2) Specification 9527-028-216-1 had requirements
ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION un . naann7 e int.n1 RESULTS- PAGE o of 13 _
restricting the heat input. However, NES did confirm that multiple processes were used on individual welds although the records did not indicate this.
Allegation 9 - Workers signed records signifying that they received training and instructions on hnw to fill out various records such as travelers or how to perform certain welds when in fact, ro training or instruction was received.
Findings - The NRC inspector reviewed training records for the NES-Selamco facility. The training records documented the department receiving the training, the date, time, subject, reference material, instructor, attendance list and a sumary of the training session. The inspector performed a review of records of trainino that occurred on October 7, 1982. The areas covered during the training were: travelers, NDE record sheets, welding procedures, weld wire issuance and material identification. Four employees sigred their names as being in attendance for the training.
Additional training also tonk place durino the allecation time frame which covered other areas of the QA program in addition to the ones noted above.
A 0A Manual and Program Seminar was held on March 24, 1983, for all employees of NES-Selamco. The seminar was conducted as part of the corrective action committed to by NES-Selamco in response to the allegations (see Appendix B).
Conclusions - The allegation is not substantiated in that the training records which were reviewed demonstrate that training was perforned during the time frame of the alleoation. The inspectors, however, cannot determine the adecuacy of the training from the records.
4 Other Findings During the inspection, the inspectors reviewed additional documen-tation. The following is a sumary of each of the additional areas which were reviewed. The areas do not address specific allegations but are included to illustrate other areas which pertain to the NES-Selamco fabrication process and were reviewed.
ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT PEPORT INSPECTION en . ooonn7A?/n7 n1 RESULTS* PAGE 10 of 13
- a. The WPSs and supporting PQRs were reviewed for conformance to specification requirements. The specification, 9527-028-216-1, " Specification for Spent Fuel Storage Racks for Brunswick 1 & 2," required that welding and qualifications be in accordance with AWS Section A3.0 and ASME Section IX.
The documentation package showing the WPSs that had been transmitted to and approved by CP&L indicated that two manual welding procedures were approved, WPS-001 and WPS-002.
A review of the fabrication and assembly travelers verified that these were the only two WPSs utilized on the job.
WPS-001 was a procedure for the GTAW process for welding P8 to P8 base material (austenitic stainless) utilizing a F6/A8 filler rod of ER308. The WPS indicated that the procedure was supported by PQR 08081602B. This PQR had been prepared in May 1980 to support a similar procedure, WPS No. SW-001.
Sheet 1 on the form was dated December 15, 1981, while sheet 2, showing the test results, was dated May 21, 1980. Sheet I had a later date because it was retyped prior to submittal to CP&L.
No essential variables were changed in this retype which would require a performance of a new qualification. However, a copy of the original WPS, SW-001, Revision N/C, dated April 1,1980, required the electrical variables to be 45-120 amps and 16-20 volts DC. WPS-001 dated December 15, 1981, had these variables as25-200 amps, 9-16 volts and the POR showed the test was done at 45-90 amps,16-17 volts. While the electrical characteristics are non-essential variables and section QW-?IO of the ASME Ccde allows changes in noressential variables to suit production, this change was a significant percentage change in the range of amperage and voltage from the original.
WPS-00?, dated December 15, 1981. was for the GMAW process for welding P8 to P8 base material with ER308 weld wire utilizinq low voltage short circuit transfer. This procedure was supported by PQR No. 8082601, Revision E, dated May 1980, which was for an older WPS, SW-002. In this case, however, the PQR was retyped and dated Pecember 15, 1981 and the original PQR was not available for review. A question arose as to the actual variables and if they were changed in the retyping of the POR.
This was raised because a review of original WPS SU-002, dated April 1, 1980, showed the required voltage to be 18-?6 volts DC and amperage to be 90-180 amps. The contact tube to work distance were required to be 1/2" to 1". These variables
ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION mn . ooonn7e/97_n1 RESULTS: PAGE 11 of 13 appear high for this type of transfer. The retyped POR did indicete that these values in the test were lower.
- b. Specification 9527-028-216-1 states in section 2.7.1.5.1 that the welding process should restrict the heat input to the stainless steel by proper selection of voltage, head width, electrode size, interpass temperature and travel speed. No addendums or revised WPSs were prepared for the production welding to place restrictions on variables or changes in technique to reflect this requirement.
The specification also required the manufacturer to select welding processes and filler metal to ensure a 5 to 20%
ferrite content in the deposited weld metal. The available material certificates of conformance for the weld wire indicated that it contained 8 to 9% ferrite. Since GMAW welding tends to reduce ferrite by nitrogen pickup and base metal dilution, a test utilizing the proposed processes and base metal should have been done and the deposited weld metal tested to ensure the minimum ferrite content was met. No in-process measurements of ferrite were conducted during fabrication,
- c. Several items of note were recognized with the preparation of the WPQs. First, the laboratory test number for the appropriate guided bend or radiographic test was not recorded. Rather, the contract number with the test lab, Law Engineering Test, was recorded. This led to creat difficulty in tracing specific tests to the actual performance test. Second, an NES consultant, who was brought in to correct welding problems, had rodified the WP0 forms. The changes on the retyped forms added or changed data on variables which were missina or not the same on the criainal documents.
Examples of this were (a) changing backing from " argon" to "none," (bl changing backing from "none" to " welded both sides," and (c) changing positions qualified from "2-G and 3-G" (plate) to "l-G." While the position chance was an appropriate correction since the actual test had only been in the 1-G (flat) position, the statement of a 3/8" plate coupon being welded from both sides without substantiating documentation was not logical for that thickness. Finally, one WPr) for welder No. W-1, dated February 21, 1983, did not indicate the transfer mode for the GMAW process.
9 ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION en . ooonn7so/97_n1 RESULTS: PAGE 12 of 13 In summary, none of the changes disqualified the welders from the type of production welding performed except for the welder No. W-1 who's WP0 indicated qualification in the flat, horizontal, and vertical positions for plate groove and fillet welds when he was only qualified in the flat position. However, the retyping of quality documents appears to have not been adequately controlled.
- d. Audits of NES-Selanco by Northeast Utilities, dated November 4, 1982, Stone and Webster, dated November 4, 1982 and CP&L, dated April 8, 1983, were reviewed. The CP&L audit considered the NES-Selamco QA program unsatisfactory pending resolution of the nonconformances which were identified by CP&L. CP&L also reviewed the NES-Selamco corrective action in response to the allegations and found the actions being satisfactorily implemented. Evidence of customer audits which reviewed the specifics of the welding process and qualifications, however, was not found,
- e. During the review of the RCPS records, it was noted that GMAW was specified for use in " Procedure for Pre-Installation Assembly and Testing of RCPS," Document 80A7303, dated January 3, 1983, Revision 0. However, the weld maps used during the fabrication of the RCPS list VPSs which used GMAW and GTAW.
The Welder and NDE travelers indicated that GTAW was in fact used for some welds on the RCPS. NES employees could not identify why GTAW was used instead of GMAW uhich was specified for use in the procedure,
- f. Internal project audits performed by NES-Selamco for two manufacturing jobs were reviewed by the NRC inspectors. One project audit for the Beaver Valley racks, dated January 1,1984 and three project audits for the North Anna racks, dated March 21, 1983, June 6, 1983, and November 22, 1983 were reviewed.
The results of the four audits identified minor findings. An overall NES Internal Audit, dated February 8, 1984, was also reviewed and stated that the internal audit and project audits in 1983 indicated the QA program at NES-Selamco was sufficient.
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ORGANIZATION: NUCLEAR ENERGY SERVICES DANBURY, CONNECTICUT REPORT INSPECTION "n - coonn7so/o7_n1 P F9111 TS
- PAGE 13 os 13 F. PERSONS CONTACTED:
- B. Ashby, Quality Assurance Manager
- C Anderson, Director of Quality Assurance
- M. Alling, Quality Assurance Engineer R. Smith, Engineer
- A. Uziel, Vice President Engineered Products
- W. Manion, President
- G. Hamiltor, Executive Vice President
- Attended exit meeting.
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l' . ALLEGATION: Welder Qualification practices were not in accordance with procedure in that 6-G position was not held through out test.
The practice of " rolling on the table" was used to get welders to pass and Ed Tilley. filled out paperwork to indicate 6-G position.
NES/SELAMCO REPLY: All welders qualifications performed in the 6-G position were welded and maintained in the required position as noted in the ASME B. and P.V. Code,Section IX, QW-461.3 (45 deg. + 5 deg. Exhibit #1-1) . Every welder at NES/Selamco that runs a 6-G Qualification Test utilizes a Test / Support Fixture (Exhibit #1-2) to maintain the proper position. Each test after it is set-up and tacked is verified by Quality Control (Exhibit #1-3).
All welders that are currently employed by NES/Selamco and certified in a 6-G position were asked if all previous 6-G Qualification Tests were maintained at a 45 degree angle for the entire test. All welders certified that each and every test was properly maintained (Exhibit #1-4).
The statement made by Mr. Edwards that test pipes were welded by rolling on a table in lieu of a 6-G position is a partial and misleading statement. Mr. Edwards was asked by his supervisor to run several root passes in some 6-G Qualification Tests in lieu of using a backing ring. He was told to Tig weld the root in the flat position to expedite the process. This process of using a Tig root in lieu of a backing ring for 6-G Mig Qualifications is an acceptable practice and is documented on the NES/Selamco Traveler used for the Welders Qualification and on the Welders Qualification Records (Exhibits #1-5A thru #1-5F).
CONCLUSION: Based on the results of our investigation into the allegation and the actual facts of the situation, we find no error in procedure and no further action is warranted.
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- 2. ALLEGATION
- When Bob Edwards went to work, only three people had stamps. -They were Ed Tilley, Roger Johnson, and Ken Mabe. However, l- other people did welding. Possession of stamps meant a welder was a
certified; however other welders worked on. racks. Bob Edwards and Scott Sellars did some of the welding on Carolina Power &' Light Racks. After welding, other welder's stamps were used on the documentation.
NES/SELAMCO REPLY: When Bob Edwards started his employment at l
- NES/Selasco, four people had welders stamps in the plant-including
! Ed Tilley,' Roger Johnson, Ken Mabe, and John Faircloth. They were ..
I the only welders in the entire plant. . Bob Edwards was the first of eight welders hired to man a site construction program for NES/Selamco (Exhibit 2-1 list of new welder hire dates) . Betwean October- 1982 and January 1983 NES/Selamco has spent 1,874 hours0.0101 days <br />0.243 hours <br />0.00145 weeks <br />3.32557e-4 months <br /> of welding time
- on programs which did not require qualified welders.' These programs included ratchet wheels for Siemens Allis, oiler and alcohol injectors l
- for Limitorque, racks / carts for Convatec Squibb, rack R & D program for Nuclear Energy Services, in-house tools and fixturing for the North Anna Fuel Rack Program for.VEPCO, and assembly tools and
' fixturing for the Reactor Cavity Pool Seal Installation Program.
Several of the new hire welders were utilized as they became avail-able to the shop.
We have confirmed through Scott Sellars that he and Bob Edwards did '
perform tig welding on the Carolina Power & Light Fuel Racks.
The tig welding included parts of weld joints 1, 2, 3, 4, 5, 6,-21 and 22 as indicated on weld maps of the Shop Traveler (Exhibit 2-2
- pgs. 43, 44, 45, & 49). Welding operations that Scott Sellars,
- Bob Edwards and Ken Mabe worked to were steps 30.2, 30.3, 30.4, 30.5 i and 30.8B. Bob Edwards, Scott Sellars and Ken Mabe performed tack welding operations of the -19 gussets for weld-joint #6 per traveler
! operation 30.4. Weld complete operations on joints 1 thru:7 per traveler operation 30.5 were performed by Ken Mabe (W-2) and _
! Roger Johnson (W-3). ' Scott Sellars and Bob Edwards performed fit-up i and tackweld operations only on weld joints 1 thru 7. Fit-up. .
I tackweld and weld complete operations for. weld joints 21land 22 per l traveler operation 30.8B were performed by Roger Johnson (W-3) and Scott Sellars. Bob Edwards did not weld on weld joints 21' and 22.
l The welding of joints 1 thru 7 occurred br* w :n 10-26 and 11-4 of 1982 as indicated on the Welder and N.D.E. D$t3rd heet. Welding of joints 21 and 22 occurred on 11-8 and 11-9 'l 52 At the time the welding
- was performed neither Bob. Edwards not 0 c o t. . Ce;11ars were qualified per l ASME Section IX for the GTAW process. Bob Edwards ~and Scott Sellars-l- did complete weld test coupons for this process on December 6, 1982
! with satisfactory results as indicated on Law Engineering & Testing.
l Company's Test Feport #CHS 479. (Exhibit 2-3 & 2-4). Both weld. test coupons were done on pipe and welded in the 6G position.
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Further investigation has found that welder qualifications for Ken Mabe (W-2)'and Roger Johnson (W-3) in the GMAW process are not per-ASME Section IX requirements (Q.W. 304) (Exhibits' 2-5 & 2-6) .
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GMAW by the >
l~ short are transfer mode requires bend test instead of radiography for qualifications. Roger Johnson has already requalified to the'6G position in the GMAW process. (Exhibit'2-7). A non-conformance report will be-issued as a result of this' finding and submitted to_ Carolina l
Power & Light for disposition. Ken Mabe will.be retested with bend
- test results required.
In response t'o Bob Edwards' allegation that "after welding, other welder's stamps were used on the documentation", we have confirmed through interviews that Roger Johnson and Ken Mabe did perform the welding operations as indicated on the Welder
& N.D.E. Record Sheets. The participation by Sellars and Edwards
'does not appear on the record sheets since they had not.yet been issued welders stamps (Exhibit 2-8).
. CONCLUSION: Af ter a thorough review of this incident we have -
made the following determinations as to the cause and corrective i measures required to preclude recurrence of this situation:
Cause: Prior to the fourth quarter of 1982 NES/Selamco's total employ was 21 people. At this time the Q.A./Q.C. staff was adequate.
During the last quarter of 1982 NES/Selamco experienced a sudden growth in-it's welding crew (tripled) as the backlog of work began to build rapidly.
NES/Selarco's total employ doubled with no additions made to the Q.A./Q.C. staff resulting in inadequate coverage. This condition was compounded by management using the floor supervision as a direct labor force to maintain scheduling'. As a result, training and supervision of new hires on the floor was inadequate along with Q.A./Q.C. coverage. In addition, paperwork for work-in-process was caught-up two and three days after the fact by use of time cards, etc., because it could not be accomplished on an everyday basis. New hires could not be expected to distinguish the difference between work requiring qualified or non-qualified welders nor should that be their prime responsibility. The primary cause was a: failure by management to ensure that welders were properly qualified before releasing them for production work and a failure by the supervisor to ensure that all welders used on the work were properly qualified.
A secondary cause was the absense of adequate Quality Assurance overchecks to identify the situations at the time of occurrence.
i CORRECTIVE ACTION: In order to preclude reccurence of this incident, 1
NES/Selamco will take the following action:
- The Quality Assurance Manager and Welding Supervisor have been issued letters of warning that under no circumstances shall '
work proceed without complete verlification of welder qualifi-
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cations.
- A formalQuality Assurance training seminar will be conducted l ,
for all employees to review the precepts and implementation of_the NES/Selamco Quality Assurance Program. This seminar will be conducted by March 31, 1983.
- NES/Selamco will immediately hire a full time Weld and N.D.E.
Inspector. The Inspector's responsibilities will include all N.D.E. and Weld Inspection duties, continual surveillance and monitoring of all welding activities on the floor, issuance of weld wire and verification of welder qualifications for all work-in-process.
Corrective Action Continued ~
- In order to document monitoring of welding activities on the floor, the Weld inspector will complete on a daily basis the
" Welding Verification Checklist" (Exhibit 2-9). This daily l checklist shall be maintained in a notebook by the Quality l Department for a period of not less than one year, after which j the checklists may be destroyed or maintained in the archives at the discretion of the Quality Assurance Manager.
- During the week of February 21, 1983, Mr. Walter Sperko will perform a complete audit of all NES/Selamco Welding Qualfications.
Mr..Sperko is our consultant Weld Engineer and is a member of the ASME Subcommittee for Section IX. This audit will be used to completely update all welders qualifications. In addition to this initial audit we will have our consultant perform follow-up audits on a minimum schedule of every ninty (90) days to insure that all procedures and qualifications are being properly main-tained. -
- With the services of our consultant Weld Engineer, NES/Selamco is revising its welders qualification matrix to make it simpler for personnel to understand. This revised matrix will be com-pleted by March 11, 1983.
Additionally, please note that the welds in question were inspected 4
and found acceptable per drawing and specification requirements.
In as much as the welders did pass the qualification test, we believe that the integrity of the hardware is not in question.
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- 3. ALLEGATION: Welding on Carolina Power & Light Racks was done with
-mig process after fit-up which was done with tig. The results were unsatisfactory and they were washed with a tig pass to look good.
The welder stayed up most of the night to get the welds to look good enough to pass visual inspection. . Bob Edwards helped, but he was not certified at the time. Carolina Power & Light's Inspector apparently saw unsatisfactory welds and would not accept them.
The inspector apparently saw the tig passes being applied to the welds. ,
NES/SELAMCO REPLY: NES/Selamco can confirm that some weld joints
- were fit-up and tackwelded using the tig welding process and then welded complete using the mig process. We find no problem with this condition as both the mig and tig procedures were approved for use on these weld joints.
The two PWR Spent Fuel Racks were rejected by Carolina Power & Light's Inspector, Mr. William H.,Sidberry, Jr., for 1/4" x 3" long fillet welds which were undersize in length to 2 1/2". This condition was documented on Rejection Notice S-00344 (Exhibit 3-1). Both the mig and tig welding processes were used to rework the welds to the required. length. The tig process was used where practical to min-imize additional splatter and clean-up time. Weld filler material
- was used as per the tig welding procedure requirements. The welders used for the reworking process were Mr. Ed Tilley and Mr. Ken Mabe as documented on the Welder & N.D.E. Record Sheet. Because of the criticality of the shipment, Mr. Sidberry(CP&L) stayed into the night (11
- 00 PM) to observe all rework activities. The Welders Qualifications for Mr. Tilley and Mr. Mabe were verified at that time. Mr. Bob Edwards was not used for any rework of the welds in question.
CONCLUSION: As a result of our investigation into this allegation, we have made the following determination. It would seem that'Mr.
Edwards, by his use of the terminology "apparently" in this allegation, has drawn several conclusions from his observations made in the plant during Carolina Power & Light's final inspection of the Racks prior to shipment. As Mr. Edwards was not involved in this process, it is obvious that his allegation is based on speculation rather than fact.
All rework was performed in accordance with applicable procedures and witnessed by the Carolina Power & Light Inspector. Mr. Edwards' allegation has no factual basis. .
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4 Liquid penetrant inspections on surfaces that-were later
~4. ALLEGATION:
covered with other assemblies, making them inaccessible were never done even though the documents indicate LP was performed. The Traveler was filled out after everything was finished, NES/SELAMCO REPLY: NES/Selamco's Procedure for Control of In-process Inspections and Test are as described in Section N-14 of the Quality Assurance Manual (Exhibit 4-1). A complete review of the drawings and specification requirements confirms that only 50% of all' welds required liquid penetrant examination. Additionally, the only in-accessible welds on the program are the single bevel weld joints joining the -12 bearing housing to the -22 bottom plate which are covered by the -23 foot at final assembly. The Manufacturing Plan
& Quality Record (Traveler) defines which welds actually received Liquid Penetrant Inspection. (See Exhibits 4-2 & 4-3). We have confirmed with Mr. Bob Hypes that these inspections were performed as indicated on the Travelers and in complete compliance with Section N-14 of the Quality Assurance' Manual and the applicable drawings and specifications. Mr. Hypes is available to discuss this allegation
! with whomever it may concern.
1 CONCLUSION: As a result of our investigation, and based on the reputation and past performance of Mr. Hypes as our Level II N.D.E. Inspector, we conclude that this allegation has no validity and no further action is warranted.
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%. ALLEGATION: Filler metal control was inadequate. There was a log book for signing out rod but they.never signed rod out. If Bob Edwards needed rod and nobody was around, he just went up and got it.
1 NES/SELAMCO REPLY: Weld wire control at NES/Selamco is accomplished as described, in Procedure N-10 of the Quality Assurance Manual (Exhibit 5-1). Weld wire is issued to welders who have a Traveler, and Weld Procedure, and completed " Request for Weld Wire" slip signed by supervisor, and who are qualified to the applicable process and material.
The Log Book for Weld wire issuance as referred to'by Mr. Edwards in this allegation, is non-existent in the NES/Selamco system.
There has never been a Log Book used for signing out filler material.
In addition, Mr. Edwards is well aware of the Procedure for checking out Weld wire at NES/Selamco as this was a part of his training received during his employ (Exhibit 5-2).
It should also be noted that during the time frame in question, NES/Selamco's Quality System had been audited by Stone & Webster Engineering Corporation, and Northeast Utilities with no findings or comments noted in the " Weld Wire Control or Issuance" System.
(See attached Exhibits 5-3, 5-4, 5-5). NES/Selamco's Weld wire room is controlled and operated by the Quality Department and Weld filler material is kept under lock and key.
CONCLUSION: As a result of our investigation into this allegation, we conclude that it has no factual basis. No further action is warranted.
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- 6. ' ALLEGATION: After Bob Edwards finally became certified, Ed Tilley used his coupons to certify other people who were going to Connecticut Yankee to install a Reactor Cavity Pool Seal. Also, Bob Edwards' stamp was used in the shop fabrication of the Pool even though he did not do all the welding. The following welders did weld on it: Bob Edwards, l Scott Sellars, John Faircloth, John Gibson, Ken Kittrell, Roger Johnson, I
Tommy Cain, Bill Pilson, and Chuck Robinson. Some were not qualified.
NES/SELAMCO REPLY:
A. All weld test coupons welded at NES/Selamco are sent to Law Engineering and Testing Company in Charlotte, North Carolina and are steel stamp indentified prior to being sent out for testing. All weld test coupons /
specimens are retained at Law Engineering for a minimal period and discarded. It would be impossible for the same test coupons to be used for more than one indivdual since they are retained by Law Engineering and, in most cases, cut up for bend tests. Also, Bob Edwards did not weld coupons for other welders at NES/Selamco. All welders welded their own weld test coupons and have so certified in writing (Exhibit 6-1).
B. Bob Edwards' stamp was used in the fabrication of the Pool Seal as he did perform welding on the hardware along with others. Mr. Edwards' weld stamp on the " Welder & N.D.E. Record Sheet" (Exhibit 6-2, Shop Traveler) indicates velding performed by him per specific oper-ations (Ref. operations 70, 80 & 100). We have confirmed through interviewing K. Kittrell, T. Cain, B. Pilson, C. Robinson and J. Gibson that these employees had not welded on the Reactor Cavity Pool Seal during its fabrication at NES/Selamco. They did however, weld on fixture components, tooling, etc. and did grinding and clean-up work on the Pool Seal. We have confirmed through interviewing that S. Sellars and J. Faircloth did perform mig welding on the Pool Seal per operations 70 & 80 of the Shop Traveler on weld joints 1 & 2. l There was no indication of this welding on the " Welder and N.D.E. Record Sheets" since they did not have welder stamps. 4 This welding was performed during the week of 12-21 thru 12-24 of 1982.
Mr. Sellars had taken his weld test on 12-21-82, but NES/Selamco had not received results of the test from Law Engineering & Testing Co.
until 1-3-83. Mr. Faircloth was tested on 1-7-83 for the GMAW process with test lab results received at NES/Selamco on 1-14-83. Both men are now qualified per the requirements at ASME Section IX, as the test results for the above referenced coupons were satisfactory (Exhibits 6-3
& 6-4), however their qualifications were not received prior to the performance of the work during the week of 12-21-82.
Further investigation has revealed that Ed Tilley's GMAW 2G & 3G qualifications are not per ASME Section IX. The short Arc transfer mode requires bend test instead of radiography for welder's performance qualifications (Exhibit 6-5). Ed Tilley is qualified to weld in the IG and IF positions in the GMAW-Short Arc process, as he qualified the procedure (Exhibit 6-6). Our records indicate that Ed Tilley welded in the 2F position on the Reactor Cavity Pool Seal. (Exhibit 6-2 Welder & NDE Record Sheet). A non-conformance report will be issued as a result of this finding and submitted to Northeast Utilities for final disposition. Ed Tilley will be retested in the 2G & 3G positions with bend test results required (Ref. QW-304).
CONCLUSION: After a thorough review of this incident we have made the following determinations as to the cause and corrective measures re--
quired to preclude recurrence of this situation:
Cause: Prior to the fourth quarter of 1982 NES/Selamco's total employ was 21 people. At this time the Q.A./Q.C. staff was adequate. During the last quarter of 1982 NES/Selamco experienced a sudden growth in it's welding crew (tripled) as the backlog of work began to build rapidly.
NES/Selamco's total employ doubled with no additions made to the Q.A./Q.C.
staff resulting in inadequate coverage. This condition was compounded by management using the floor supervision as a direct labor force to maintain scheduling. As a result, training and supervision of new hires on the floor was ina,dequate along with Q.A./Q.C. coverage. In addition, paper-work for work-in-process was caught-up two and three days after the fact by use of time cards, etc., beenuse it could not be accomplished on an everyday basis. New hires could not be expected to distinguish the dif ference between work requiring qualified or non-qualified welders, nor should that be their prime responsibility. The primary cause was a failure by management to ensure that welders were properly qualified before releasing them for production work and a failure by the supervisor to ensure that all welders used on the work were properly qualified.
A secondary cause was the absense of adequate Quality Assurance overchecks to identify the situations at the time of occurrence.
CORRECTIVE ACTION: In order to preclude reccurrence of this incident, NES/Selamco will take the following action:
- The Quality Assurance Manager and Welding Supervisor have been issued letters of warning that under no circumstances shall work proceed without complete verification of welder qualifications.
- A formal Quality Assurance training seminar will be conducted for all employees to review the precepts and implementation of the NES/Selamco Quality Assurance Program. This seminar will be conducted by March 31, 1983.
- NES/Selamco will immediately hire a full time Weld and N.D.E.
Inspector. The Inspector's responsibilities will include all N.D.E. and Weld Inspection duties, continual surveillance and monitoring of all welding activities on the floor, issuance of weld wire and verification of welder qualifications for all work-in-process.
- In order to document monitoring of welding activities on the floor, the Weld Inspector will complete on a daily basis the
' " Welding Verification Checklist" (Exhibit 6-7). This daily checklist shall be maintained in a notebook by the Quality Department for a period of not less than one year, after which the checklists may be destroyed or maintained in the archives at the discretion of the Quality Assurance Manager.
- During the week of February 21, 1983. Mr. Walter Sperko will perform a complete audit of all NES/Selamco Welding Qualifi-cations. Mr. Sperko is our consultant Weld Engineer and is a member of the ASME Subcommittee for Section IX. This audit will be used to completely update all welders qualifications.
In addition to this initial audit we will have our consultant perform follow-up audits on a minimum schedule of every ninty (90) days to insure that all procedures and qualifications are being properly maintained.
- With the services of our consultant Weld Engineer, NES/Selamco is revising its welders qualification matrix to make it' simpler for. personnel to understand. .This revised matrix will be
- completed by March 11, 1983.
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