ML20209C456
| ML20209C456 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/23/1987 |
| From: | Bateman R, Joyce J, Rose J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20209C049 | List: |
| References | |
| WP-03-SQN, WP-03-SQN-R03, WP-3-SQN, WP-3-SQN-R3, NUDOCS 8702040274 | |
| Download: ML20209C456 (86) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER: WP-03-SQN SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 3 TITLE: Welders Performance Qualification Continuity REASON FOR REVISION: N/A SWEC
SUMMARY
STATEMENT: N/A PREPARATION PREPARED BY:
Original Signed By R. M. Bateman 9-12-86 SIGNATURE DATE REVIEWS PEER:
Original Signed By J. E. Rose 9-12-86 SIGNATURE DATE J
.A TAS T TECHNICAL REVIEW ONLY h' 7Afdd ni-er
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SIGNATURE DATE I
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l CONCURRENCES Original Signed By CEG-H:
L. E. Martin 9-12-86 SRP:.%,'u,,s> tulhtfo
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SIGHiTURE7/[
DATE l
APPROVED BY:
MU/d i-n n ECSP MANAGElf DATE /
MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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r te WELDING PROJECT GENERIC EMPLOYEE CONCERN EVALUATION REPORT REPORT NUMBER: WP-03-SON, R3 DATE 09-15-86
SUBJECT:
WELDER PERFORMANCE QUALIFICATION CONTINUITY CONCERN (S) CONSIDERED: IN-85-346-003 IN-85-352-001 EX-85-021-002 IN-85-835-002 IN-85-426-002 IN-85-532-005 PH-85-052-002 IN-85-778-001 PH-85-052-X03 IN-85-770-002 IN-85-627-036 IN-85-493-004 IN-85-940-X04 IN-85-424-011 IN-85-480-004 IN-85-815-001 lR1 EX-85-042-003 lR3 IN-85-113-003 J
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, PROGRAM MANAGER APPROVED BY Revision 1 included two additional Employee Concerns which were furnished to WP by the ECIG after orginal issue of this report. These Employee Concerns were analyzed and determined to involve issues previously evaluated, dispositioned, and closed by the WP.
Revision 2 to this report incorporates comments made by the Senior Review Panel on 8/19/86.
Revision 3 added results of Nuclear Operation review of welder certifications 8oNeeEnkOSkkE14$200N'pEevi!!hlyea$$a$ed$nhPk$-SQ 'kep $
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D GENERIC EMPLOYEE CONCERN
SUMMARY
SHEET Report Number: WP-03-SON R3 Report
Title:
WELDER PERFORMANCE QUALIFICATION CONTINUITY I.
CONCERNS CONSIDERED: IN-85-346-003 EX-85-021-002 IN-85-426-002 PH-85-052-002 PH-85-052-103 IN-85-627-036 IN-85-940-XO4 IN-85-480-004 EX-85-042-003 IN-85-113-003 IN-85-352-001 IN-85-835-002 IN-85-532-005 IN-85-778-001 IN-85-770-002 IN-85-493-004 IN-85-424-011 IN-85-815-001 lR1 lR3 In addition, SQN Specific Concerns XX-85-049-001 and XX-85-049-X03, and NSRS Investigation Report I-85-135-SQN are considered in this report because they address the same basic issues.
II.
ISSUES INVOLVED 1.
Welder Performance Qualification (WPQ) continuity records have been backdated.
l 2.
WPQ continuity records have been falsified.
3.
WPQ continuity. program is inadequate because there is no objective evidence to confirm actual process usage when WPQ continuity records are stamped by QC.
l 4.
WPQ continuity program is. inadequate because continuity may be maintained by running one weld bead.
5.
A one-position test plate is not sufficient to reinstate all WPQ J
test.
Page 1 of 2 01460 h ap.
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4
WP-03-SQN, R3 III. STATEMENT OF CONCERN / ISSUE VALIDITY Validity: Y
,N X
, Substantiated: Y
- X
,N
- Corrective actions are needed in the Nuclear Operations implementation of Welder Performance Qualification Continuity Program as discussed in NSRS Report I-85-135-SQN.
IV.
EFFECT ON HARDWARE AND/OR PROGRAM None V.
JUSTIFICATION:
See Issues 1 through 5 of WP Report WP-03-SQN.
All areas evaluated indicate that problems with Nuclear Operations (NO) welder continuity have been identified by QA Survey, and have been r
corrected.
(SQN-CAR-85-09-014 attached).
Corrective actions were in place prior to concern investigation. The Bechtel Audit verified that these corrective actions have been implemented for NO.
VI.
RECOMMENDATION AND/OR CORRECTIVE ACTION NEEDED Closure of NSRS recommendations I-85-135-SQN-01 and I-85-135-SQN-03.
VII. REINSPECTION NEEDED: Y
,N X
VIII. ISSUE CLOSURE By this report.
IX.
ATTACHMENTS 1.
SQN Specific Concerns - XX-85-049- 01 and XX-85-049-XO3 2.
NSRS Report - I-85-135-SQN 3.
SQN-CAR-85-09-014 1
4.
Text of Employee Concerns lR1 5.
Excerpts from Bechtel Audits Key Elements 3.0, 4.0, 5.0, l
and 17.0 lR3 t
l 6.
ERT Investigation Report - IN-85-770-002 l
l lR1 7.
ERT Investigation Report - IN-85-352-001 l
Page 2 of 2 01460 l
GENERIC EMPLOYEE CONCERN Report Number: WP-03-SON R3 Report
Title:
WELDER PERFORMANCE QUALIFICATION CONTINUITY I.
SCOPE OF EVALUATION This engineering analysis covers the following WBN concerns determined to have possible generic implications at SQN:
IN-85-346-003 EX-85-021-002 IN-85-426-002 PH-85-052-002 PH-85-052-XO3 IN-85-627-036 IN-85-940-X04 IN-85-480-004 EX-85-042-003 IN-85-113-003 IN-85-352-001 IN-85-835-002 IN-85-532-005 IN-85-778-001 IN-85-770-002 IN-85-493-004 IN-85-424-011 IN-85-815-001 lR1 lR3 In addition, SQN Specific Concerns XX-85-049-001 and XI-85-049-X03, and NSRS Investigation Report I-85-135-SQN are considered in this report because they address the same basic issues.
II.
ISSUE (S) ADDRESSED BY CONCERN Each concern was analyzed to determine the issues voiced by the concerned individuals. These issues are as follows:
i 1.
Welder Performance Qualification (WPQ) continuity records have been I
backdated.
2.
WPQ continuity records have been falsified.
3.
WPQ continuity program is inadequate because there is no objective evidence to confirm actual process usage when WPQ continuity records are stamped by QC.
4.
WPQ continuity program is inadequate because continuity may be maintained by running one weld bead.
5.
A one-position test plate is not sufficient to reinstate all WPQ test.
Page 1 of 4 01460
WP-03-SQN, R3
+
III. CONCERN VALIDITY OR SUBSTANTIATION Review of NSRS Report I-85-135-SQN gives a basis for determining the overall validity of Issues 1 and 2.
The report indicates that there was, in fact, a program implementation problem identified at SQN including welder performance qualification continuity. The report also indicates that this problem had been identified by Nuclear Operations (NO) in a QA Survey previous to the concern initiation and that corrective actions were initiated to correct observed deficiencies.
These corrective actions included a one hundred (100) percent review l
of all the active welder certification files.
l i
t From this review twenty eight (28) welder certifications were l
questionable. Twenty (20) of these were clerical errors and resolved l
based on supporting documentation. The remaining eight (8) required lR3 welders to be retested in accordance with ASME Section IX.
l Because all eight welders successfully passed the retest, no l
reinspections of their previous work was performed.
l While conducting their investigation, NSRS reviewed the certification l
and continuity records of approximately twenty five (25) welders.
l In their report they did not specify which welder records were l
surveyed or if they were welders who had previously been identified l
with documentation problems. The NSRS did report in their findings
[
that the random review revealed no indication of backdating or l
falsification. There were, however, indications of clerical errors lR3 and omissions in data entry and general laxity of program implementation.
l 4
They also reported that corrections were made by a responsible weld l
test representative to eliminate clerical errors based on supportive l
documentation.
l l
l There also appears to be no safety concern since all active welder l
performance qualification continuity records were either found l
to be corrected or readily restored to the requirements.
l Implementation of welder performance qualification and l
continuity activities were also addressed through the Bechtel l
SQN Implementation Audit conducted January 1986. Key Element l
3.0 " Initial Welder or Welding Operator Qualifications", concluded l
initial welder qualifications were performed in accordance with l
TVA approved procedures.
Key element 4.0 " Maintenance of Welder l
or Welding Operator Qualifications", concluded TVA welders l
demonstrated welding within certification expiration dates.
l Key Element 5.0 " Renewal of-Welder or Welding Operator l
Qualifications", concluded renewal within required ASME/AWS l
time frames.
In many cases TVA welders were given the original l
qualification test for renewal which exceeded ASME IX and AWS lR3 Dl.1 requirements for renewal.
Key Element 17.0 " Employee Concerns",
l did not substantiate employee concerns related to welder qualification l
continuity based on the audit of welder qualification l
records and supporting documentation. These key elements were l
evaluated for both OC and NO programs respectively The audit
[
consisted of a random sampling of thirty seven (37) welders which involved one hundred twenty four (124) welder qualification records Page 2 of 4 01460 I_-..
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WP-03-SQN, R3 for OC and twenty five welders involving one hundrad seven (107) l welder qualification records for NO.
No areas of noncompliance lR3 were noted in the audit.
The WP review of NSRS Report I-85-135-SQN and the results of Bechtel SQN l
Implementation Audit concluded that the technical requirements for both l
the program requirements and their implementation have been effectively lR2 met at SQN. No evidence of falsification of records was discovered in the l
WP review.
Issue 3 is a concern which relates to a former practice at WBN.
Nuclear Operations has completed a review of all welders whose qualifications were transferred from other sites. All identified lapses of continuity have been identified and corrective actions have been taken (S06 851206 800). SQN NO welders who have transferred qualifications have successfully passed a requalification test administered at SQN to provide a positive start for subsequent welder performance qualification continuity. SQN NO Procedure M&AI-5 also has been revised to provide a positive method of welder performance qualificatio'n continuity. These actions correct any welder qualification continuity deficiencies for SQN NO.
Issue 4 is addressed through both AWS and ASME rules. ASME B&PV Code,Section IX, paragraph QW 322 defines the conditions under which welder I
performance qualifications are affected.
AWS Dl.1, Section 5.30 states the same condition for welder performance continuity. Simply stated, use of the welding process for which the welder is qualified is basis for continuation of welder performance qualification. A minimum degree of usage is not specified nor required.
It was/is not normal practice at SQN to maintain welder continuity by running one weld bead although the applicable codes do not prohibit such. Normally, continuity is maintained by the welder making a production weld. The rare exceptions to this practice have generally been in maintaining qualifications of persons not involved in production welding (e.g., welder foremen). Therefore, the practice questioned in Issue 4 is acceptable.
Issue 5 is addressed in both AWS and ASME rules. ASME B&PV Code,Section IX, paragraph QW 322 specifically alllows the practice of reestablishment of all previous quellflations through the satisfactory passing of a one-position test. AWS Dl.1, Section 5.30 contains a similar provision, although it is less clearly defined. Therefore, the practice questioned in Issue 5 is acceptable.
In summary, the five issues considered in the subject concerns are dispositioned as follows:
1.
Welder Performance Qualification Continuity Records have not been backdated. This issue is not substantiated. This issue is closed by this report.
Page 3 of 4 01460 Q
WP-03-SQN, R3
- 2. ' Welder Performance Qualification Continuity Records have not been falsified. A detailed investigation of these issues was performed by NSRS and documented in NSRS Report I-85-135-SQN. Both these issues were not substantiated. The investigation did, however, discover that program implementation had been deficient and that NO had already taken steps to correct identified defielencies. The Bechtel SQN Implementation Audit conducted in January 1986 determined that both DC and N0 programs for these activities had been effectively implemented prior to the NO audit. Based upon this analysis, these issues are closed pending the completion of 2
the corrective actions regarding review of Welder Performance Qualification Records as outlined in NSRS Report I-85-135-SQN.
3.
The WPQ Continuity program is inadequate because there is no objective evidence to substantiate actual process usage when WPQ Continuity Records are stamped by QC.
This issue was not substantiated because it relates to a WBN practice. All welders who have transferred to SQN from other sites have successfully passed a requalification test administered at SQN. Implementation deficiencies discovered by SQN NO QA have had corrective actions initiated.
This issue is to be closed based on the above actions.
4.
Issues 4 and 5 are acceptable practices and are to be closed on that basis.
I IV.
CORRECTIVE ACTION l
Recommendations I-85-135-SQN-01 and I-85-135-SQN-03 are closed based on the Bechtel SQN Implementation Audit and pending completion of the SQN NO review of Welder Performance Qualification Records. No areas of noncompliance were noted.
I l
l Page 4 of 4 01460
-03/SM/SS (E:iPLCYEE CCilCERNS)
PAGE1 of 1 1;3: 59:y7 L,CC STATUS RESP
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CFR INSP TC ------CCriC ER!1-------
PROBLEM ID SR XX-85-035-001 WCPOW WORDS:
CERTIFICATIC' PROGRAM ELEC WELDERS X: S Y: C 2: N SEQUOYAH:
WELDER CERTIFICATIONS HAVE BEEN UPDATED FOR WELDERS WHO DID NOT'I1EE UPDATE REQUIRER 1ENTS OR EACKDATED TO GIVE THE APPEARANCE OF REQUIRE!!ENT COMPLIANCE.
ORDERED T1ANY UIOLATICNS TO PROCEDURES AND Et1PLOYEES ARE TOC AFRAID TO REFU CONSTUCTION DEPARTf1ENT CONCERN.
CI DECLINED TO PROVIDE FURTHER INFORT1ATION.
NO FOLLOW UP RECUIRED.
TECHNICAL COr1r1ENTARY:
LOC STATUS RESP
-QTC-PPP CFR INSP TC ------CONCERN-------
PROBLEM ID 502 NSRS A3 SR XX-SS-04S-XO3 WCPIF KEYWORDS:
CERTIFICATION Ir1PLEl1ENTATION FALSE NOf! SPEC X: S V: C 2: N SECUOYAH: WELDER CERTIFICATION CARD FALSIFIED. CONSTRUCTION DEPT CONCERN. CI HAS NO t10RE INFORT1ATION.
CINSF RPIN I-85-SOR-SCfD T'CHNICAL Cut 1r1ENTARY:
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- UNITES STATES COVERNMENT 67807dnd Mm TENNESSEE VALLEY AUTHORITY TO: H. L. Abercrombi Site Director Sequoyah Nuclear Plant FROH: K. W. Whitt, Di ector of Nuclear Safety Review Staff, E3A8 C-K
"^'S: EEB 18 Isg8
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSHITTAL Transmitted herein is NSRS Report No.
I-85-135-SON Subject WELDER CERTIFICATIONS UPDATED WITHOUT MEETING REOUIREMENTS Concern No.
PEE-3$4tul56513nd XX-85-049-x03 and associated prioritized recomendations 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 i
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
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pirector,NSRS/ Designee
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MDS:JTH D.
Attachme'nt ce (Attachment):
W. C. Bibb, SQN J. W. Coan, W9C135 C-K W. T. Cottle, WDN James P. Darling, BLN R. P. Denise, LP6N,40A-C C. B. Kirk, SQN F. E. Laurent, CEO-WBN W. E. Hason, E11C49 C-K--Review to confirm NSRS detemination of no fals D. R. Nichols. E10A14 C-K
,.h or.
QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C J. H. Sullivan. SON Kent Therp. IOB-WBN U
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Y TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT No. I-85-135-SQN EMPLOYEE CONCERN:
II-85-049-001 II-85-049-IO3
SUBJECT:
WELDER CERTIFICATIONS UPDATED WITHOUT MEETING REQUIRElENTS DATES OF INVESTIGATION:
NOVEMBER 26 - DECEMBER 12, 1985 INVESTIGATOR:
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E.[F.HARWELL DATE
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REVIEWED BY:
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L. E. BROCK DATE APPROVED BY:
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W. D. STEVENS DATE e
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Page 3 of 6 u
I.
BACKCROUND A Nuclear Saf y Review Staff (NSRS) investigation was conducted to determine the alidity 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 XX-85-049-001 and KI-85-049-XO3, 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 XX-85-049-001 had not been received from QTC/ERT when this investigation began on November 26, 1985, although the concern 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 o5 record which entailed determining three specific issues:
1.
Were welder certification / continuity records correct'.y 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 requirements of the ASME Code, the Nuclear Quality Assurance Manual (NQAM), Nuclear Power Welding Program Requirements, and audit and corrective action reports.
Several cognizant individuals were interviewed concerning the welder certification, continuity requirements, and recording.
NSRS also reviewed a 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
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Assurance Program, Program Applicable to Operation" l
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Page 4 cf 6 t
2.
NQAM.
art II, Section 6.1, " Welding" I
3.
ASME,Section II, " Welding,and Brazing Qualifications" B.
Findings
~.
1.
References 1 and 12 require personnel performing special processes (i.e., welding) tions to be documented.
to be qualified and their qualifica-2.
ASME Section II (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 II.
Reference 2 provides the requirements that the Division of Construction must follow.
4.
Sequoyah Nuclear Plant (SQH) utilizes references 7 and 8 to implement the requirements of the welding program.
S.
In the past, Nuclear Power has accepted construction welder performance qualification without retesting.
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
(
prac tice.
6.
In August 1985, an investigation of the welder certification and continuity program was started at SQN with the Plant QA Staff, Hechanical Maintenance, Hechanical 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 Modificab 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 corrected.
There were 10 welders whose certification papers were missing or there were gaps in their construction continuity records.
weld cards were pulled. and these welders were not allowed toTheir 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 ASHE Section II Code.
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Pag 3 5 ef 6 In di:%u231cn with a toolroom clerk (Individual H) who updates 9.
the er ntinuity records based on weld filler material draws, he indic,ted that some draws may be inadvertently lef t of f the welde certification print,out. Once the error or omission is 7
detected, the records are corrected for the timeframe for which they were missing.
The welder certification printout is l
presently done once a month. However, Individual H said they may start doing the printouts more often; and. therefore, l
errors could be detected sooner and corrected before a month's time elapses.
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 sitet 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 l
requirements and all safety-related welding was performed in accordance with an approved QA inspection program. Plant procedure H&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 or the welder retested.
2.
The concern that records may have been backdated in order to 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
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backdating. No evidence was found that indicated falsification of records had occurred.
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Pags 6 cf 6 e
3.
There appears to be no safety concern since all active welder f
recor s were either correct or readily restored to require.
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ments Also, all safety-related welding is' independently inspe ted 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 f
health and safety or the common defense and security.
(P2]
k 3.
I-85-135-SQN-03, Verification of Corrective Action Taken on g
S0-CAR-85-09-14 t
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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RESPCtlSILLE SUFERVISCR
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VlRIFICATICil - CCRRECTIVE ACTicri TAFEll AS DESCRIEID ADOVE Of wirH TDE F0tLCWif4 DEVIATICilS McJAfh m,
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Page 2 of 17 j
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. TACl!HEffr TO SQ-CAR-85-09-014 littra-The f ollowing are examplos of problems with wolder continuity and quaCorrective the t tona an determined f rom our murvey.
h that prograre an a whole and not just correction of the listed examples. nuc recurrence of almilar deficiencien tu unlikely.
in their continuity Certain weldurs had gaps (which exceeded three months) 1.
recorda:
Certifi-CAP Wolder cation Whero Cap Occurred 7/31/70 - 12/6/74 J. R. Canh ASHE 9/27/76 - 6/13/B0 tiefore Trannfer to Power W. W. Evann 12/30/81 - 4/28/82 Randy Cox 1/18/82 - li/31/tl2 b
At Watts liar Hnx Howard 12/27/H4 - 4/2H/Hi lieforu Trannt er to Power Itichntd Ntruly 7/25/72 - 11/1/74 f
At Sequoynh 11111 McEntyre 6/15/83 - 9/20/83 f.f Heforo Trnnaler to Power Roger Woodward 1/l/fl5 - 6/7/H5 f(
At Sequoynh Ted Smith
- (
Beforo Trannf or to Power Contlnutty records were updated for proccuses in which tho wolder van not l!ficatlon:
certifled or qualification tests were not on f Llc to verify qua 2.
Procennes Wolder SH Procennuu frnm 9/80 - 12/83 h,
l Jerry Phitilps SH Proccases from 7/79 - 5/84 E. Johnson quattrication tests were listed on continuity records, but were not on f x
l'afp 3.
Teny Volder h
CT-7-5 and SH-5-2 rA Richard Nicely f'
Qualification tests listed on continuity records even though-the Qu 4.
tions were invalidated:
.o S
Tunt/Datu Taken
- h Welder SM-5-n-l.
3-28-77 y
hobert Ward CT 0- 1-I.
6-1-79 f
4-16-74, dioyd Kirby SH-4-L 3 72. SH 8-3-L y
"Jillitm Smith CT-6 1-1.
11-7-75 e$
Ono CTA-8-5-X(1) was liuted twice.
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Waymond Pruutt test had been fa!!cd and the other qualifLcation had been revoked.9-21-76 5
and 9-21-76, respectively.
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g Page 2 of 1 i
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(Continued)
I Welder Tent /Date Taken
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donald Parton GT 0- }- L L2-20-74 3
4.arry Eustico SH-4-IF L 5-17-78 y
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vCliarlen Boarden SH B-l.
11-1-77
- Ted Smith
- GT1.1-1 6-15-17 i
- See Item 5 - GT1.1-1 was listed as CA.1.1-1 i
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- o the following L )_
5.
Inappropriate changen were made by engineers or clerkn perf ormance qus11fication records:
Changed from Welder Changed To g.";
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/ Phillip Dyrd SH-5-Ik }- L SM-5-0-3-il
- Walter Vinson*
SH-5-lb 3-1.
SM-5-l.
linroid Stnf ford GT-22-0-I-l.
GT-22 0-3-1.
i
,Ted Smitha*
CA1.1-1 GTI.1-1 f
- An AWS tent was changed to indicatu that an ASHE tent unu takon.
tis
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- lbreu changen of thln HamD Lypo were made to thin indlyldual'u recurd.
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- 6.
Uno continuity sheet contained cont 11cting entrica (Tom Russell, January 1984).
i 1.
One welder's records listed three different nocial uccurity numburn (Charten Ilearden).
The work documenta listed on vold rod lanuo cards for Homo weldern did not 8.
provide adequate documentation to verify that wolding had actually been il <
ie perIormed.
T l
Examples:
! i;ff Welder Rod lunno D.ite Work Ikwument i
W.
Hiednou 10/26/84 lini t 2 S1-156 f
12/10/04 Itit A-289434 Not in Filt a k
1/8/85 na A-254714 i
2 1
2/7/85 HM A-521104 i
3/26/65 tin A-295113 5
4/2/85
!!R A-52017] to Pi,p Water 5/1/85 MR A-291967 !!ot in files fL E. crutcher 2/7/85 Hg A-291768 cancelled 5/2/85 na A-563871 Not in Elles h
7/30/85 4
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Page 4 of 17 Pa y,.- I ol' I
't. Problems nimilar to items 1 and 2 wuru noted for noldering and/or bror.ingt Individual Problem Jerry Bookout Bra:Ing test was taken 2-2-82, but the continuity record contains entries for 7-17-81.
liarold Janow lost continuity f rors 11/4/77 - 8/11/78.
James Massengalo Continuity recrrd indicates that brazing was performed 11/7/83. but no qualifica-tion record was on file.
l.orenzo Phillips Continutty record indicaten that noldering wan purformed from 10/5/83 - 5/3/84, but the qunllflention for noldering una not received until 6/5/85.
Coleman Armstrosig Coittinuity nhuetu indicate that brazing una performed 1/14/85, but the brazing
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qualification test was not taken until 2/13/85.
~
Tomte Amon No performanco qualification test wou cn filo for Tust CA1.1-1 which was taken 8-10-83.
s liarold Staf ford Continuity records have entrics for brnzing frnm 10/4/83 - 8/8/84, but the qualification i
l test was not taken until 6/5/85.
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Page 5 of 17 g
l October 22, 1985 i @
R. W. Olson g
Hodifications Hansger g
i h
Subj ect: INITIAL RESPONSE TO CAR NO. 85-09-014 U
M We havo reviewed your initial response and havo found it,inadequato. Please reviso your initini response to address the following concerns
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Root Causo - A root cause must bo listed.
f Remedial Cortcetivo Action - Please indicato when all additional probicas found during your self audit woro or will be corrected l
l CAR Item 1
'r (A)
R. A. Nicoly's continuity record did contain a Sap which exceeded thros I
months (12/27/84 through 4/28/85). Picano indicato in your responso I,
that the record has now boon updated. (Sco Attachment 1.)~
f (D) Tod Smith'n continuity gap cxecods thrce months according to the records I
b (3/1/85 through 6/7/85). Those records contain wock onding dates. The wolder would have had to wold on 6/1/85 (a Saturday) to maintain
'+
i continuity. Picase reviso response accordingly.
CAR ttem 4 (A) Floyd Kirby's CT-6-1 test token 6/4/79 was failed subacquant to UT-6-1 (which was changed to GT-6-0-1-1,) taken 6/1/79. A lotter en file indi-5 cates that the failed test stands. A check of welder qualification I
recorda purformed 10/21/85 revealed that the f ailed test is no longer on 1,.
file.. (Sco Attachmont 2.) Picano revise response accordingly.
(B) Picano correct the response for W. J. Smith to indicato taking test
[
GT-6-0-1-1 on 6/23/77.
CAR Item 8 h
The wording of HR A-301942 states " weld practico for velders not required to
[
rcqualif y under the provisions of H&Al-5, steps 4. 3, 4.4, and 4.5."
The uss of this HR for maintaining continuity presents some potential probicsi areas e
l (listed below) which should be addressed:
(A) H&Al-5 does not describe this method for maintaining continuity.
L
( B) No instruction details how welding under this HR is to be documented
,h (i.e., will all velders be listed on thu HR alunn with the dato they vuldedf).
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(C) At what point in time will the HA be considered closed whero it can be
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f11ed as a completed record and provide evidence of wolding?
IE$E i{ j 095:)
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Page 6 of 17 R. W. O' son m
dl October 22, 1985 3
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Subject:
INITIAL RESPONSE TO CAR No. 85-09-014 s: j (O
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Your Recurreneo control - Recurrenco control monsures must be specified.
fy renponau only addressos the specific examples given with no indication of how you will ensure this does not happen again.
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Recommandations for recurrence control and remedial corrective actions:
T A plant instruction might be initiated to provido an acceptab!c This (A) method,to ensure that woldora maintain /updato their contin
{l continuity.
,ye-A cover 1ctter or similar type of documentation shculd be placed in 7~
The cover letter (B) those wclders' files whero probicms were reported.
f ~.
should ref erence this CAR and should includo an ovaluation of the
[:jf acceptability of any wolding previously performed in Nuclear Power ph:
during a time interval whero the vulder qualifications were questionab;e.
(14 Consideration might be given to requiring requalification testing for
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(C) any new solders who are assigned to perform wolding operations at
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Sequoyah.
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Per AI-12, utep 3.4.3.5. wo are given two calendar voska af ter tho inittui responne duc date to agree on the root couno and corrective action (n).
If i
reach narcoment on your responno by October 26, 1985, this CA:t i
wo connut h
will be cucalated to the oito director for resolution.
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dp D.$. Craven i
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l CAC:DI.C g
{3 i Attachments g
u This was prepared principally by'C. A. Crownover.
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h Page 10 of 17 ~ 8 L ' 1h!.M.i C.I. ! u ;it';:. I 1 e' I.ws a t ii*.s.,ecuo/21 lI. P. 't: i t ' (: l*: ;;re rt:'.U: T e */.e e g c, ; ..t;:,r, Crait IICIIC f~ V'I ~~ r i 141210 'y)l0
- JUP '813 i
Floyd Kirby I:ada;a ....o. ,,.. s.. o } ,Fakdla; Pro:::s e.T Hanual X ' S ci.it - Au t o r.a t t e N/A Ai. t v..: :..;,1_ .e ,1,, [ ,$' elder E. '.'u ld inr, U,s e r s t o r
- / A Woldin,; Procedure No.
GT-ll-0-1 ? l ( Dosition of test plato or pipo 6C t}ualifying for .nll P"'.it ion s p t .. + Hil. Spec.
- A-106 n To SA-106D P. No.
1 P. ?:o. I } 1 h P..n:;n slaali t t,od,1]I6" - "'A" Diaroter and/or chteknei.s _.2" x.154" Ii Electrodo or filler riotal typn In olac l'.70*J I - 1/3 7"
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'8 dacking ring or strip fl/A Consumablo ins. ort II/A iltacr U/^ Shtolding r.a: A Pur;;tnn cas II/A Plux type C;100VC PP.I.D p i fin i d t.I n e.ul T... e. p
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It e s u !. s p m }Y . butt f.C - 71 root y kp 't.C - 72 face u m o,g a v.i,uit 4C - 71 rent [(,' g g. 1 t 1 V-butt 6C - 74 (ac,* g u .o N/A N/A lI/A s 3 ,I ti/A !!/A !!/A \\ i
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' 'M M Te c No. q- -J 1 h a in.: 1.r.'s _E!A '*c c e r : s f y :ha: el.r statement.T in this r.'sor.1 are voirect and tiet thu tes t i.cid. j l,, j ucre previre d. . rete.sd and tes tsd in.ti:coritar.co. un th the requ a rco. nt a vi.cet t n IN j uf tl.as M::;: rods. {_frct.J/ l GlIn ~f.iPo o __ ui. . m... __. I (
- upervt irir Apprieval
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jk; 4 PW y icy h) 00963 0/30 ite,c3,,ne 3 Page 11 of 17 ~ [ CIN ER At._ A complete review of all velders' files has been completed. This revirv tdentified additional problems which had not been previously identtited U by the QA audit. All velders with continuity and/or testing from another s f(' ] nuclear plant have been retested. Corrections have been esade to documents to correct all identified prob 1ces. Additionally, a meeting was held at j Chattanooga NCO with representatives frora WBNP. SQN. and NCO to discuss existing velding programs. The conclusion was that the existing program ( was acceptable. All safety related welding perforroed by these individuals vas performed in accordance with approved QA inspection prograus and is constdered satisfactory. b ROOT CAUSE The review of the welder continuity program indicated many clortcal errors H in the recording of and transf or of information. Many of these errors [ } occurred during past years when requirements and practices were less [ p stringent than today's standards. Another contributing tactor that ratsed l
- C quentions was the interpretation of the mechanten of continuity updates.
L t Dif ferent urganisa tions updated records uning dif ferent mothuda, whir.h I counod uno urganization to question another's practicus. N i These factors caused confusion and raised questions as to the salldity of b T continuity records but did not identify any unqualified volders. i h j Rf2tEt)1 A! CORRECTIVE ACTION _ d i1 1. Welder b J'"R'.' Cash 3'j Hr. Cash was qualified by Construction on 7/10/70. Al hough signed N of f. periodic continuity records do not exist between H70 and 197'.. J Construction records certify that Mr. Cash wns eligible to draw rods on 12/6/74. The ASHE Codo dr.ea not require retention-..f these 9 .g records, but only updating of continuity. Hr. Cash's antinuity was - l maintained on a " running basic " 1.o., his eligthility estonded as f hn wolded. fir. Cash's wolding certification has been discontinued. 4 + 3 f Wehh.r - u. U.' 1%un dd Mr. I;vanu' n ta tun is nimilar to Mr. Cash'n. His ported of missing 'd continuity occurred in the early construction period 1976-1900 when j " running enn t inui ty" was main tained. Hr. Evans received additional kq testing in 1980 (SM) and 1982 (CT) which reestablinhed his continuity. h M Weider_- R. R'. Cox_ Mr. Cox's continuity yap occurred when an inadvertent entry was sude a r i nn hts continuity shee t. A January entry was made on a 19111 data
- e. hee t. Thin entry shculd have been for Jarua!r 1982.
Hr. Cox was i -.d tested in September of 1981, which documerits the f act that this is 9-an erroneous entry. Ilowever Hr. Cox was recertified on 9/9/85. h h ik iA i + l
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- J I
Page 12 of 17 ~' Weider - H !!'. flownrd_ Hr. Iloward transferred from Dellefonte Nuclear Plant. Rellefonte maintained continuity on n " running basts" by extending has eligibility date. Rollefonto certified tha t Mr. Iloward van certified to draw rude on the date of his transfer. Hr. Itoward han reentablished his certification hy testing on 8/19/82 (CT) and 8/31/85 (SH). Walder - R'.'A.'Hicciv_ Hr. Nicely's records have been corrected based upon vold-rod issue card review. Weider 'H. P.'HeEntyre ,a 4 i h Mr. Mc!'ntyro's continuity question occurred in the early days of l conntruction whun continuity was maintained on a " running bania. ~ j Hr. McEntyre was certified to be oligibio to with.irnw roda un !!/1//I. Q Hr. McEntyro took addttional touting on 'l/16/1', ((;T) j by Conn truction. i and 4/9/75. which roostablishes hin certification. ^ Lf Welder 'R_.'!!. Wondwar_d_ j g Hr. Woodward's gap th continuity was previously addressed in 1 - a SQ-DR-84-09-114R. Update of Mr. Woodward's records in accordancu T j with the resolution of referenTed DR will clear this quention. 10/18/85. Hr. Woodward has reestablished his certification by testing on 3 [ Wolder w Ted Smith _ I T f Mr. Smith'n gap occurred when no entry was undo in the time llowever, the entry made on 6/7/85 vortflod period referenced. Hr. Smith's [ that Mr. Smith had maintained continuity through that day. continuity was maintained undet the construction program of updating Hr. Smith was terminated on 9/1/85 and will te on a weekly bants. rutented if reemployed. s. 2. Wolder ' Jerry Phillip_n_ W Jerry I'hillips' tont won minning f rom him file. A copy of the ]} SH-4-n-3-il tunt han been ncquired and placed in his filo. Weider - E. Johnnon E. JohnNon'n tent vnu missing f rom his file. Copics of the SH-$-1 f;; and SM-4-1 ten ts we're acquired and pl.sced in his file. 3 l i l 3. uelder - Rtchard flicely i R Hr. Haec1y's ataintues SM & CT qualifscation records cannot bo j' Ilin cortificottons became invalid in January 1981 and 3 loca ted. I 1 1 .2
}fi " y ) M Q 'y % g q)p ts g 74 i K. fr 6..yNti 4 ~ '~ ~ "" ! j f p%..r'M. W< tt : T .v., j 009G1 0 / " - ~ " I" Page 13 of 17 [ in I'lH l. porf orm welding ognin unt il retent ing he d11not Although Mr. Hirely's ntaintenn SH & GT prorennen have been revalidated, he has not used at sintenn sinco prior to retentsng When Mr. Nicely'n staintens stuel qualificattuna have k in 1983. been Incated and pinced in his qualificatson filo, he can f.e per the permitted to perform stainicas steel SH & GT solding, r ASHE Codo. All invalidated tests were removed from cont nutty sheets. 4 Welder - Ronald'Parto_n Mr. Parton's qualifiestion was revoked on 6/25/77 and no welding van performed utilizing this qualification until af ter recertif t-9/19/711 (CT) and 11/15/73 (SM). cation por ASME codo by retssting on 4 Weldor - Charlen Reardon_ Ilowuver, other ten ts t in t No copics of SH-4-in-L unis t in hin f oldor. woro takun and panned ntnce 1977 would,vpsniti/ hsin for thin tunt. Welder - R_ohor t Unrd_ Per ASME Codo, Robert Ward has renewed his prnvioun SH spsalifica t t in The SH-4-H tcat dated 10/4/ 7 7 by panning an SH-4-H test on 6/20/83. C and the SH-5-B-L test dated 3/28/79 are valid and will remain un his Hr. Ward did not perform welding in SH from the ~ continuity record. untti after date hin qualification van invalidated (7/27/111) requalification on 6/20/83. N 4 Ueider 'Floyd Kirby~ Mr. Kirby's GT-6-1 (CT-6-0-1-L) disqualified test was improperly f r Thin test han been remov.rd r placed on his continuity shcot for 1985.A copy of the f ailed tent has been h. l f rom his continuity sheet. i If placed in his file. WeIdur - W. J.* Soi t_h_ W. J. Smith did not veld SH f rom the dato of his invalidated qualif t-Por ASME Codo, on 6/21/85, his cation on 1/13/77 through 6/21/85. prevtuun SH tuntn were requalified by panning the SH-4-D-3-il tont. previoun GT-fs-0-1-L tont.wnn qualified by retent on 6/23/77. Tim (; ) P[ Wuider - Raymond Pruett_ i 1 indicate the GTA-S(.1)-i D Mr. Pruett's continuity records should not b Since f is no longer an appropriate qualification. ] test 9tnce it y be updated, it will to reooved f rom his 1.stest contenutty cannot continutty.uheet. Hr. Pruott han not performed GTA welding etnce Q l'd 3/J/77. ]L Weider - f.arry Puntice They were fir. Vumtice's qualifications were revoked on 1/26/fle.Weiding van not perf ormed reent.ibitehed by tests on 4/6/84 anil 4/11/84. }) 1/Jh/tl4.ind 4/6/tf 4 letween f g( tro 'U ~ Page 14 of 17 ,a Walder ' Tod Smith _ n_ Ted Smith's test descriptions were inaccurately changed. The urtgtnal l1 descriptions have been reestablished. Mr. Smith was terminated N/1/d). } J" Hr. Smith did not perforts CTA brating since his qualification van revoked on 4/15/78.
- p Welder - P.'R.*Byrd
[ L Hr. Byrd's test record had an inaccurate test procedure listed. L 1.e., test number SH-5-B-3-L which is a light-wall test. The m parameters identified indicated a heavy wall test, which he took. A chango to the parameters was made instead of changing the test = number to SM-5-B-3-H. This error has been corrected. [ 4 Wolders' R (Jalter Vihnon,' Tod Smith
- nnd liarold' S taf ford _
[i Hr. Vinnon's, Hr. Smith's and Hr. Staf ford'n test doncriptionn f woru inaccurately changed. The original demortpttunn hovu imun f< 1 I rnuntablished. Tod Smith'n test doacriptionn were inaccurately changsd. I Tho originnt descriptions have buon ruustahlinhud. i e ? f 6. The da tos on Mr. Russo11's records cannot be verifin1 to dutormano ) the coune of the conflicting entrios. Hownvor, etnce thn continutty i records indicate that he veldad both processes in November 1983, } per the ASHE Code, he should have welded either process by ( February 1984, for which there are acceptable entries. 7. C. F. Boarden's social security number hnd the last two digita reversed, a correction was mado. 8. In an af fort to oliminate potential problems such as Mr. Bludnue's ? I and Hr. Crutchor's, HRA3d1942 has boon written to allow woldurs to f perfo.m documented welding for the purpose of maintaining prof tetancy and continuity. 9. .lcrry lionkou t_ lirnz ing tenta nro workmanshlp quality tuntN. It in n0L uncommun to dentroy af ter purformance is mado. All nuch brazing performud 4 by tir nookout would havo occurred previous to 1981. Any problose 1 ' -) with Mr. Dookout's brating would have been identified and corrected Mr. Bookout will be retested before additional bra:Ing by now. ]i is performed. 'a Weldur - Harold Jan_ow N Hr. Janow should not have been permit ted to brane for SNP CONST 3 after 5/4/78. He hos not brated for SNP.Ht!C (R since being hired on 1/12/85 and will not brsas until a rotest is administured. Wolder .innen Han.sennale_ J.w.cn Mannengsle's brating record has ta en.icquired.ind. copy h.se been pl.sced in his continuity fitn. i ~
IMiGfdl 'i 1 i % 0 q 9.5
- )
0/J 1 .s Attactunent 3 [ Page 15 of 17 ~ Welder - 1.or nro phillip_n ) s.saanwe Hr. Phillips'-heaetng qualif teatton da ted 10/5/31 has txen piaced in his file. ^% m Weider ' Coleman Armstronit Mr. Armstrong nhould not have boon permitted to drnw brazing mtertai on 1/14/85 without having proper qualificatton documentation. Han tunt indscates a qualification date of 2/13/85. Hr. Armstrong han properly maintained continuity since. The toolroom attendants have boon instructed not to issue rods untti the proper documentation appears on the veld-rod issue card. Uolder y Tommie Amb's Hr. Amon' CA1.1-1 qualification han been acquired and placed in h: 1 file. Weldor - Harold Staffor_d_ Hr. Staf ford'n brasing and soldoring qualification teNin dated ~ 10/4/83 have been acquired and coptus 'hnve been placed in his filo. CONCf.tlS10!!_ T1:e review did not identify.any wolders who wore working in violation J ( of the applicable code. All sofoty relatud wolding performed.at SQN receives applicable nondestructive testing, which insurus that all wulds 1 are acceptablo. In soveral cases, weldors were directed to reestablish their certifications to insure all doubt had been removed concerning their qualifications. It should be noted that the code required continutty j update but does not specify a method. TVA's current method meets codo j requirements and is consintent with induntry practices. Host of the y discrepancies reported occurred in the past or vero clorien1 in naturo. j our current prograts is much improved and recurrencon oro not anticipated. 1 RECtJHRCHCE CONTROL i f 1l l Thu following actions havn boon takun en innure futurn probiumn of thle l nature do not recur. i;4 - 8) 1. A welding engincor position has boon added to tio Site Services stat f. 1 In addition to current QA audita. he will provilo a gunorn! nurveill.ince 1 f h(h[4[ k( 5 of the welding progrum on a periodic basis. b 2. Veiding continutty ef for ts are being m.stntained by toolroom personne. i who have g.stned exper tence in recent ger tods which reduces error s. , h g\\ 3. A merio han heon placed in anch active weldar'n filo nottnn review
- {d-(copy a t t.iched).
This memo documents that 411 (dentified def tetencias were currected whether reported by the wold-tent representattvce or Rtv'S **J the 8)A ntaff. SQ-CAR-85-09-014 lists only those specific deficieneten j i-g f to C whet identified by QA and does not necessarily include those duticiencten j (
- 1cm identified by the weld-test reprenant.ittvue.
9t1 stele 4 A ,I v y d i a mm.m
\\ . - ~, f .5 b h k t NN)b f 4 ; W?MI D ((! 3,. g) g.j .} Q/ i Page 16 of 17 ,1, -n-p g i f 4 Nuvistuna wv11 be tude to H&Al-5, clartlying responsth:11t tew and 61 l ( t requirements. Estimated completton d.:te 12/31/85. .ft{ I 5. A meeting of weld-tee t represent.itives f rom 54N, WRNP, BFNF,.ano 'ot.O w.in conducted to review requiremunts and,irnc ticien. 1.DA ICDI.--2/12/H 6 t .3 4 I O .s+ [ l i t 2 A e' L r l' E l 4 ,i 4 b9 i I I h A i 1 l k ah I I l a 1
.,f?$Nk[ %f ? . i.. " ; '.. N' '.T {; Y r Q.e,p&,.,. 4;. T/ <. 4:. - 2,l? $),.? (YY.>R' ,G , v :.
- % c '. f 4 gG'. > : s : 'O s '.
lo ;.. N u.,: ' !S- . " c o a y 7;... yy a ,f E*- l,. q,',; ' c 3. zk.N ; : s ( 1 ' ~ . l.. lt ti r!, A ' - <lT c,;., (.. '. ~. ' ,; x. a p ::.l. f J 1 . I. *-lln d Q:,'+,-- .... ~: : y k' ; '..,,e . k k. I' t h,, Y [d M '...,,.I, 1Ti ly~ -.W, t,0; 1, .j. ' c.,...... .~ 6 s, ,. s : ;.C... ;,-.-- .u. h , - ; 7. - 4 ~[ ~ r i J.: . -l., c : j .1 0 0 9 G 'l !-f- ~ 07J '. l Page 17 of 17 Ac tive Welders' Files 1 L. D. Alexander, Supervisor, Hocha i i n cal Hodifications, NUC PR, Sequoyah i Oc tober 23, 1985 t SEQUOYAll NUCLEAR PLANT - CAR-85 09 -014 A review of.itl ac tive volders' fil [ s Doug Fryu to iduntify and i:orre t dparaonnel and weld-t I f O iscropanctes rula ted to wolder rus tinot ty and wolder qualif ts:a tion e .i c h for apecific and generte correctiveanil all discrepancies Thin individu4t 's file vna ruviewad n-25/85. 1 f by 44 action of deficienciou identifiedIto equipmunt was required to have bcon pall welding porfo ual on safety related approved QA programs including the op erformud in accordanco with h propriate NDE. 1 n 2 i ? I i.DA t CDI. L. D. Alexander a P f3 h r '{/ s 1 6 L }2 1 a n t u 7 l I 1 l a Q
cistu9nunn a P:g3 1 of 6 09All/86 / (EMPLOYEE CONCERNS) '09:13:59
CONCERN-------
INSP SD RD GD 10 PAT ISSUE PLANT PRIOReT ORG OTC EG3 W I ERT A2 SR IN-85-346-003 KEYWORDS: CERTIFICATI N PROGRAM UPDATE PROB: WCDPW WELDER CERTIFICATIONS ARE UPDATED ON EVIDENCE OF ROD WITHDRAWL SLIPS. THE PRECESS MAY NOT HAVE BEEN USED.IN THE APPLICABLE TIME PERIOD, 90 DAY OR 180 DAY, DEPENDING ON ASME OR AWS. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION CONTINUITY. CAT ISSUE PLANT PRIORITY ORG QTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 ERT A2 SR EX-85-021-002 KEYWORDS: CERTIFICATION PROGRAM UPDATE PROB: WCDPW THERE IS NO METHOD / OBJECTIVE EVIDENCE TO VERIFY THAT A WELDER HAS USED A SPECIFIC PROCESS WHEN THEIR WELD CARDS ARE STAMPED /UP-DATED BY QC. NO FOLLOW-UP REGUIRED - NO ADDITIONAL INFORMATION AVAILABLE. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION CONTINUITY. CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 ERT A2 SR IN-85-426-002 KEYWORDS: CERTIFICATION PROGRAM UPDATE PROB: WCDPW UPDATING OF WELDER CERTIFICATIONS IS INADEOUATE IN THAT A WELDER IS ONLY REQUIRED TO PRESENT THEIR CARD FOR UPDATING AND SOMETIMES IS ASKED TO RUN A BEAD-NEVER A COMPLETE WELD. NO FOLLOW-UP. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION UPDATE.
Attrchme:t 4 09/14/86 /(EMPLOYEE CONCERNS) "09:10:59 , CAT ISSUE PLANT PRIORI T ' ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 A4 SR PH-85-052-002 KEYWORDS: CERTIFICATI N IMPLEMENTATION SPECIFIC PROB: WCPOW CI'S WELDER RE-CERTIFICATIONS WERE BACK DATED. DETAILS KNOWN TO OTC, WITHHELD DUE TO CONFIDENTIALITY. NO FURTHER INFORMATION MAY BE RELEASED. CONST. DEPT CLNCERN. Cl HAS NO FURTHER INFORMATION. IR: PH-85-052-002 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP
CONCERN-------
SD RD GD 10 W l SR PH-85-052-X03 KEYWORDS: CERTIFICATION IMPLEMENTATION FALSE SPECIFIC PROB: WCPOW WELDER RECERTIFICATIONS HAVE BEEN FALSIFIED. DETAILS KNOWN TO OTC, WITHHELD DUE TO CONFIDENTIALITY. Cl HAS NO FURTHER INFORMATION. IR: IN-85-533-Xll STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG QTC EGG ____ SD RD GD 10 ------CONCERN------- INSP W I A4 SR IN-85-627-036 KEYWORDS: CERTIFICATION IMPLEMENTATION UPDATE PROB: WCPlF SOME WELDERS HAVE HAD THEIR RECERTIFICATION CARDS BACKDATED. CONSTRUCTION DEPT. CONCERN. Cl HAS NO FURTHER INFORMATION. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION UPDATE.
09/11/86 /(EMPLOYEE CONCERNS)
- 09:13:59 CAT ISSUE PLANT PRIORIT ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
W 1 SR IN-85-940-X04 KEYWORDS: CERTIFICATI N PROGRAM UPDATE PROB: WCDPW UNTIL RECENTLY, A WELDER COULD HAVE WELDING CERTIFICATIONS UPDATED BY MERELY HAVING THE CERTIFICATION CARD INITIALED BY AN INSPECTOR. THIS PRACTICE MAY NOT HAVE ASSURED THAT THE UPDATE WAS BASED ON OBJECTIVE EVIDENCE OF UTILIZATION CF THE REOUIRED PROCESS WITHIN THE SPECIFIED TIME PERIOD. CONSTRUCTION DEPARTMENT CONCERN. Cl HAS NO FURTHER INFORMATION. IR: STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE OVALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 ERT A4 SR IN-85-480-004 KEYWORDS: CERTIFICATION IMPLEMENTATION UPDATE PROB: WCPOW CELDER CERTIFICATION UPDATE IS INADE0VATE. PERSONNEL MAY WORK IN A POSITION THAT DOES NOT REOUIRE ANY WELDING FOR 5-6 YEARS BUT CERTIFICATIONS ARE CONTINUALLY UPDATED. WHEN THESE PERSONS RETURN TO WELDING NO TESTS ARE CONDUCTED. THEY JUST RUN STRINGERS TO UPDATE CERTIFICATIONS. IR: IN-85-170-002 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 ERT A4 SR EX-85-042-003 KEYWORDS: RECERTIFICATION PROGRAM SPECIFIC TES PL PROB: WCDPW j WELDERS ARE BEING REOUALIFIED ON CARBON PLATE WITH A CARBON BACKING STRIP. THE TEST PLATE IS SET AT 33 DEGREES FOR THE TEST AND THIS ONE TEST REOUALIFIES THE WELDER FOR EVERY PROCESS HE HAD BEFORE, INCLUDING PIPE. Cl DOES NOT FEEL THIS IS PROPER. CONSTR. DEPT. CONCERN. Cl HAS NO ADDITIONAL INFORMATION. i IR: EX-85-042-003 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE OUALIFICATION UPDATE. i i l [
Attcchment 4 i '#82 09/11/86 / (EMPLOYEE CONCERNS) '09:J3:59 i + CAT ISSUE PLANT PRIORIT ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- I W 1 ERT A2 SR IN-85-113-003 KEYWORDS: CERTIFICATI N IMPLEMENTATION UPDATE PROB: WCPIF WELDERS ONLY HAVE THEIR CERTIFICATION CARDS STAMPED EVERY 90 DAYS. WELDERS ARE 4 N4T REOUIRED TO BURN ROD AND HAVE IT INSPECTED IN ORDER TO MAINTAIN THEIR CERTIFICATION IR: IN-85-Il3-003 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED WELDER PERFORMANCE QUALITIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 ERT A2 SR IN-85-352-001 KEYWORDS: CERTIFICATION PROGRAM UPDATE PROB: WCDPW WELDER UPDATES CERTIFICATION BY GOING TO QC WELDING AND BURNING A ROD OR JUST S T R I K I NG AN AllC. NO WELD USING THE PROCESS IS DONE OR VERIFICATION THAT THE PROCESS HAS DEEN USLD ONCE DURING THE 90/180 DAY PERIOD IS REQUIRED. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED WELDER PERFORMANCE QUALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG IN$P SD RD GD 10 ------CONCERN------- W l A4 SR IN-85-835-002 KEYWORDS: CERTIFICATION PROGRAM UPDATE PROB: WCDPW WELDERS RE-CERTIFICATION CAN BE ACCOMPLlSHED BY SIMPLY HAVING ONES CARD STAMPED. NO PERFORMANCE TEST IS REOUIRED OR CONDUCTED IN THE PROCESS. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE OUALIFICATION UPDATE. l l i l i I _, _ _ ~ _ _ _ _ _ _ _ _,, _ _ -. _ _ _., _ _ _.... _ _... _ _,
l Attcchment 4 P, iga 5 cf 6 09/11/86 /(EMPLOYEE CONCERNS) '09613:59 . CAT ISSUE PLANT PRIORIT ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 ERT A4 SR IN'-85-532-005 KEYWORDS: CERTIFICATI N PROGRAM UPDATE PROB: WCDPW WELDERS ARE RE-CERTIFIED WITHOUT VERIFICATION THAT WELDERS HAVE PERFORMED SPECIFIC WELD TECHNIQUE. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDCR PERFORMANCE OUALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN---'--- W 1 A2 SR IN-85-778-001 KEYWORDS: CERTIFICATION IMPLEMENTATION UPDATE PROB: WCPlF WELDER CERTIFICATION HAVE BEEN IMPROPERLY UPDATED. NO FURTER DETAILS AVAILABLE. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG '.INSP SD RD GD 10 ------COflCERN------- W 1 A2 SR IN-85-770-002 KEYWORDG: CERTIFICATION IMPLEMENTATION SPECIFIC PROS: WCPIF UPDATE OF WELDER CERTIFICATION RECORDS ARE NOT PERFORMED IN ACCORDANCE WITH PROCEDURE, i fJ THAT ODJECTIVE EVIDENCE OF PROCESS USE IN PROCEEDING 90 DAY PERIOD IS NOT ODTAINED OR VERIFIED PRIOR TO UPDATE OF CERTIFICATIONS. WELDS HAV6 BEEN MADE BY UNCERTIFIED WELDERS. DETAILS KNOWN TO OTC. WITHELD DUE TO CONFIDENTIALITY. CONSTRUCTION DEPARTMENT CONCERN. IR: IN-85-710-002 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED 1. WELDER PERFORMANCE QUALIFICATION UPDATE.
- 2. WELDS HAVE BEEN MADE BY UNCERTIFIED WELDERS.
mg_mc ug tu P:g2 6 of 6 09/11/86 (EMPLOYEE CONCERNS) '09:12:59 . CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W ~1 ERT A2 SR IN-85-493-004 KEYWORDS: CERTIFICATION PROGRAM UPDATE PROB: Wan'W CELDER CERTIFICATION UPDATE IS INADEOUATE TO VERIFY THAT THE WELDER CAN C;NTINUE TO WELD A PARTICULAR PROCESS. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED: WELDER PERFORMANCE QUALIFICATION UPDATE. CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 ERT SR IN-85-424-011 KEYWORDS: CERTIFICATION PROGRAM UPDATE PROB: WCDPW WELDER CERTIFICATION UPDATING PROCESS IS INADEQUATE, AND BASING DISCIPLINARY ACTIONS ON FAILING TO COMPLY WITH THE PROCESS iS UNFAIR. CEG., WELDERS WHO Fall TO RENEW CERTS. ARE GIVEN TWO WEEKS OFF. BUT RECERTIFICATION CONSISTS ONLY OF GETTING CARD STAMPED--NO WELDING IS INVOLVED.) DETAILS OF SPECIFIC CASE KNOWN TO OTC-WITHHELD TO MAINTAIN CONFIDENTIALITY. CONSTRUCTION DEPARTMENT CONCERN. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED:
- 1. WELDER PERFORMANCE QUALIFICATION UPDATE.
- 2. DISCIPLINARY ACTION IS UNFAIR.
CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- W 1 A4 SR IN-85-815-001 KEYWORDS: CERTIFICATION lMPLEMENTATION UPDATE PROB: WCPlF RE-CERTIFICATION OF SOME WELDERS CONSISTS ONLY OF COMPLETING PAPERWORK. THESE EMPLOYEES DO NOT HAVE TO PROVE WELDING ABILITY. THIS IS DONE FOR SOME EMPLOYEES WHO HAVE NOT WELDED FOR YEARS. NO FURTHER DETAILS AVAILABLE. IR: IN-85-352-001 STAT: RC: TECHNICAL COMMENTARY: ISSUE CONSIDERED:WPO CONTINUITY PROGRAM IS INADEOUATE BECAUSE THERE IS NO OBJECTIVE EVIDENCE TO CONFIRM ACTUAL PROCESS USAGE WHEN WPO CONTINUITY RECORDS ARE STAMPED BY OC. l l l t'.- . ~. _ _ _... _,.. _ _ _ _ _, _ _ _ _ _ _ _........ _ _., _ _ _. _ _ _ _ _ _..
Attechsent 5 Pags 1 of 8 xEv Et.nenT wO. 1.0 e, OfTICE OF % ION C PREPARATION FOR AUDIT OF WELDING ACTIVIT!!$ ~ Prior to the start of the audit, the audit team deve n audit plan and procedures which described and implemented the TVA welding activitie ons and The audit team developed an audit checklist to addre'ss all ele identified in the TVA work plan in addition to analysis of e ments for significance and integration into the checklist. mployee concerns The audit team identified and selected a cross section of we from applicable TVA specifications. systems drawings applicable to each individual system for programmatic audit KEY ELDENT 2.0 OFFICE OF CONSTRUCTION ADE00ACY OF DESIGN OUTPUT DOCUIiEiHS For items selected for audit, drawings, welding procedures and suppo t records were reviewed and showed compliance with the TVA program and r ng j procedures. OBSERVATION One observation was noted during the audit of the welding output d ocuments. The TVA detailed welding procedures (DWP) did not show the name of th organizational group. By showing the name of the key unit that is e key welding documents could have been readily resolved. respo e KEY ELEMENT 3.0 OFFICE OF CONSTRUCTION _ INITIAL WELDER OR WELDING OPERATOR OUALIT: CATIONS l TVA welders were qualified in accordance with TVA ( porting documentation, t grams and procedures. 0031X l Page 3 of 11 l 1 1 1
- e
Atttchm:nt 5 Pcg2 2 of 8 9 g-V KEY ELEMENT 4.0_ ~ [\\ w. OFFICE OF CONSTRUCTION HAINTENANCE OF WELDER OR WELDING OPERAT Based on audit of welder maintenance records, TVA welders demo welding within certification expiration dates as required by TVA nstrated and procedures. pecgrams KEY ELEMENT 5.0 OFFICE OF CONSTRUCTION RENEWAL OF WELDER OR WELDING OPERATOR OUALI Based on audit of welder qualification records'and maintenance welders were requalified in accordance with TVA programs andrecords, TVA In many cases TVA welders were given the original qualification t procedures. renewal which exceed,ed ASME IX and AWS,D1.1 requirements for renewal est for KEY ELEMENT 6.0 OFFICE OF CONSTRUCTION INITIAL WELDING INSPECTION PERSONNEL OUALIFICATION 3 Qualification / Certification records for nondestructive examination per (weld inspection) were reviewed for compliance with TVA NDE pe qualification procedures covering a time span from January, 1971 thro rsonnel March, 1983. TVA personnel qualification procedures used for the qualification / certification of NDE personnel complied with and referenced the applica edition of SNT-TC-1A (American Society of Nondestructive-Tcsting) l Records evidencing qualifications and certifications contained specifications in effect during construction activities. de sufficient 1 l 0031X Page 4 of 11
Attcchment 5 i PsS2 3 of 8 's' i ~ . i ~ KEY EL MENT 17.0 OFFICE OF CONSTRUCTION DtPLOYEE CONCERNS 17.1 Concern No. XX-85-049-X03 and XX-85-101-006 regarding welder certification. This concern was not substantiated by the audit of a random sampling of 37 welders which involved 124 welder qualification records from 1970 to 1979. 17.2 Concern No. XX-85-69-001 and XX-85-069-X05 regarding welder certification and on-the-job training. This concern was not substantiated by the audit of a random sampling of 37 welders which involved 124 welder qualification records from 1970 to 1979. 17.3 Concern No. XX-85-108-001 and XX-85-108-002 inspections. regarding weld audit of a minimum of 14 inspection procedures.This concern cou 17.4 Concern No. IN-85-476-004 and WI-85-041-002 inspectors training program. regarding welding as evidenced by audit of training programs.This concern could not be subs g (. 17.5 Concern No. N1-85-053-004 and XX-85-68-006 satisfying code requirements. regarding weld rod control audit of a random sampling of 48 receiving documents and associate CHTR's which involved 83 heat and/or lot number, 8 types of weld metal covering the years 1972 to 1980. pounds of weld metal. Although'. audit finding, AF-01-01,This re 572,000 against Key Element No. 12 of this report'is documented against the TVA program. It involves details required by TVA procedures over and above that required by ASME filler metal specifications and had no impact on weld quality. The statement in the concern.shows a lack of understanding of the code. weld filler metal but gives two methods ~ to clase from.For to each component or ensure the specified material is used by a Either trace l control procedure. the standards and, therefore, did not require traceability to a i i component. 0031X. Page 10 of 11
'~ Attachsint 5 Pcg2 4 of 8 s p { .0 ~. ( OFFICE OF CONSTRUCTIO_N A, EMPt,0YEE CONCERNS (continued) i 17.6 Concern No. XX-85-054-001 regarding weld inspection by craft. This from the weld history records for the welds revie rs pulled well as by an additional random sampling of 13 inspecto n the audit as holdpoints were found to have been signed off by anyon rs. No certified inspectors. e other than Structural welds and piping have different cod s ead of piping. up and final inspection. procedures for structural welds.No holdpoints are required by the TVArements f 17.7 Concern No. EX-85-039-001 regarding weld control (stubs rod). This concern was not substantiated by the audit of ap li and unused procedures. A daily surveillance program was maintained which p cable included verification of welder identification welded and the procedure being used. the feature being (such as amperage) were verified to assure that weldVariables from the proc I the procedure properly. monitored to assure that the welder had requested the issued the proper rod, and was using the proper rod rod, was 300 surveillances a month were performed during years of peakA construction. P 0031X Page 11 of 11 P m__,-.-
j Psgs 5 of 8 KEY ELDENT NO.1.0 /
- W '* h OPERATIONS PREPARATIN IUt AUDIT OF WELDING ACTIVITIES Prior to the start of the audit, the audit team developed an audit plan a identified applicable documents, specific manuals, specifications and n
procedure which described and implemented the TVA welding activities The audit team developed an audit checklist to' address akl elements for significance and integration into the checklist. identified based on availability, eg:The audit team identified and selected a cro replaced fell under Nuclear Operations program for audit.only systems w randomly selected from drawings applicable to each individual system for Welds were programatic audit. KEY ELEMENT 2.0 NUCLEAR OPERATIONS ADEOUACY OF DESIGN OUTPUT DOCUMENTS ,I For items selected for au'dit, drawings, welding procedures and supportin i records were, reviewed and showed co4pliance with the TVA program and procedures. OBSERVATION One observation was noted during the audit of the welding output documents The TVA detailed welding procedures (DWP) did not show the name of t organizational group. By showing the name of the key unit that is welding documents could have been readily resolved. responsible KEY ELD (ENT NO. 3.0 NUCLEAR OPERATIONS INITIAL WELDER OR WELDING OPERATOR OUALIFICATIONS TVA weldets are qualified in accordance with TVA pro e on., es. 0031X 1 k Page 3 of 11 i Pcgs 6 of 8 s. [f N KEY ELEMENT NO. 4.0 ...e1*-" NUCLEAR OPERATIONS MAINTDIANCE OF WELDER OR WELDING OPE S Based on audit of welder maintenance records \\ welding within certification expiration dates as requiTVA welders demo and procedures. red by TVA programs KEY ELEMENT NO. 5.0 NUCLEAR OPERATIONS RENEWAL OF WELDER OR WELDING OPERATOR O welders are requalified in accordance with TVA pr i n enance records, TVA and procedures. KEY ELD!ENT f.0 NUCLEAR OPERATIONS _ INITIAL WELDING INSPECTION PERSONNEL OUAL All inspector qualification records (NDE, to include visual audited indicated compliance with TVA programs and procedures a examination) referenced codes and standards. n e OBSERVATION t TVA Form 6780 (as referenced in procedure qualification and certification does not clearly identify the 0202 14) used to document NDE recertification status of the individual. when individuals are actually certified in accordanc require:nents requirements of Procedure Certification Program for NDE Personnel.0202.14 (formerly N75C01) e specific , Qualification Program clarity and definition could-be improved by addi certification expiration date or recertification status as an e t ng either the 6780. Specific reference to Procedure n ry on Form 0202.14 on certific tion forms (6780) qualification, certification requirements and practic a employed. NDE personnel r each NDE method 0031X 9 p_... ~ - - ~ ~^
Attcchm:nt 5 d Pc82 7 of 8 ~ .4;" y ( KE7 Ett4Drr 17.0 L ~ ~~ 0FFICE OF NUCLEAR OPERATIONS 17.1 Concern No. XX-85-049-X03 and XX-85-101-006 certification. regarding welder This concern was not substantiated by the audit of a random sampling of 21, welders which inyolved.107 welder qualification records from 1972 to 1985. i 17.2 Concern No. XX-85-69-001 and XX-85-069-X05 regarding welder . v,. certification and on-the-job training. $if ' substantiated by the audit of a random sampling of 25 weld This concern was not ..y..,e J.t ' involved 107 welder qualification records from 1972 to 1985 ers which 17.3 Concern No. XX-85-108-001 and XX-85-108-002 inspections. regarding weld audit of a minimum of 14 inspection procedures.This concern cou ^ 17.4 ~ Concern No. IN-85-476-004 and WI-85-041-002 inspectors training program. regarding welding as evidenced by audit of training programs.This concern could not be substatiate .~ -17.5 Concern No. W1-85-053-004 and XX-85-68-006 f-satisfying code requirements. regarding weld rod control ~ audit of a random sampling of 25 receiving documents and associat s, 1:. weld metal covering the years 1976 to 1985.CMTR's which inv ,)E ji yy / 3li... approximately 19,000 pounds of weld filler metal.This represents The statement in the concern shows a lack of understanding of the 8, f - code. weld filler metal but gives two methods to chose from.For exa 1:5 to each component or ensure.the specified material is used by a Either trace ' v,, ; ; control procedure. the standards and, therefore, did not require traceability to aT
- .y;,;
- 'if.c h component.
~
- ...~p.
17.6 Concern No. XX-85-054-001 regarding weld inspection by craft N :' concern was not substantiated by the audit of 4 inspectors pulled This . from the weld history records for the welds reviewed in the audit as well as by an additional random.sampilng of 10 inspectors. holdpoints were found to have been signed off by anyone other than No certified inspectors. 0031X (_ u,; .s.: l Pace 10 of 11
Attcchaint 5 Pega 8 of 8 a ( KEY ELDENT 17.0 ....3--
- A.
CITICE OF NUCLEAR OPERATIONS (continued) This concern may be referring to structural welds instead of Structural welds and piping have different code requirements f piping. up and final inspection. procedures for structurh1 welds.No holdpoints are required by the TVA or fit 17.7 Concern No. EX-85-039-001 regarding weld control (stubs and rod). This concern was not substantiated by the audit of applic bl unused procedures. A surveillance program is maintained which includeda e verification of welder identification, the feature being welded a d the procedure being used. Variables from the procedure (such as n amperage) are verified to assure that welders are using the procedure properly. Welding rods, ovens and controls are monitored to assure that the welder has requested the proper rod, was issued the rod, and is using the proper rod. proper 0031X Og O O O gg
t-e + (. / s (' Attachm;nt 6 Page 1 of 24 QUALITY ~ ( . TECHNOLOGY 1 QlC T*"* ~ P.O. BOX 600~ Sweetwater, TN 37874 (615)3654414 -- ~ ERT INVESTIGATION REPORT PAGE 1 OF 5 CONCERN NO. EX-85-042-OO4, EX-85-042-OD5, IN-85-480-OO4, IN-85-627-037 CONCERN: Welder recertifications were falsified. See " Details" Below ~ INVESTIGATED PERFORMED BY: W. M. Kemp/R. L. Ahmed DETAILS Note: The concerns noted below have be.en investigated and the results transmitted on 10/15/85. These previously transmitted results also address the concerns noted above. 1 IN-85-770-OO2, IN-85-424-X13, IN-85-021-XOS, IN-86-167-OOS, IN-85-965-OO1, IN-85-612-XO7, IN-85-770-XO7, IN-86-167-XO6, ( WI-85-OO3-OO1, IN-85-778-XO7, (R-86-143-OO2 WI-85-OO3-XO2 Concern # IN-85-627-037 Concern: Some welders recortification cards have been falsified. Construction dept. concern. CI has no further information. Concern # EX-85-042-OO5 Concerns Welder certification updates were falsified. Concern # EX-85-042-OO4 Concern: Welding engineering department would sign a certification update that a welder was requalified eve ~n though the welder had not used that particular welding process during the past 90 days or that i the welder had not done a welder requalification test at the test lab. Concern # IN-85-480-OO4 Concern: Welder certi fication update is inadequate. Personnel may work in a position that does not cert i ficat ions require any welding for 5-6 years but are continually updated. When these persons return to welding no tests are conducted. They Just run stringers to update certifications. 4 m
( g Attachatnt 6 Page 2 of 24 ~ ERT INVESTIGATION REPORT pAGE 2 OF 5 CONCERN NOS. EX-85-042-004, EX-85-042-005, IN-85-480-OO4, IN-85-627,37 0 DETAILS, centinued ~~ ~ DOCUMENTS REVIEWED: ~ ~ -~~ ASME Section IX QW 320 AWS D1.1 Section 5 Welders Qualifications OCI 4.02 Revision 4 Welder Welding Operator performance Qualifications OAM 5.1 Welding Control Rev. 20
SUMMARY
OF INVESTIGATION: ( This' concern is substantiated. Based on the investigation of these concerns "Back Dating" of welder qualification was a common practice. "Back Dating" would be approved based upon someone (i.e., Foreman, QC Inspector O.C.) having knowledge that the welder had welded in that specific process. However, there was objective evidence, i. e., supporting documentation such no as weld
- number, item, work order or work package to support the Justification of "Back Dating" the welder qualification (Certification).
REQUIREMENTS: ASME Section IX, DW 322 stated that when a welder: a) "has not welded with a process during a period of three i months or more his qualifications for that process shall be expired except when he is welding with another process the period may be extended to six months." b) "...he has not welded with any process d'uring a period of 3 months I all his qualifications shall be expired including any which may extend beyond 3 months by virtue of (a) above." OW 322 goes on further to state that the " Renewal of Qualification for a specific welding process under (a) and b) above may be made (_ in a single test joint (plate or pipe) on any thickness, position or material to reestablish the welders or welding operation qualification for any thickness, position or material for the process for which he was previously qualified. i i . ~..-.
Attachnent 6 ( ( Pegn 3 ef 24 f ( ~ / ERT INVESTIGATION REPORT PAGE 3 OF 5 CONCERN NOS. EX-85-042-004, EX-85-042-005, IN-85-480-004, IN-85-627-037 DETAILS, continuea REQUIREMENTS, continued AWS D1.1 Section 5 st'ates: 5.30 Period of Effectiveness "The welder's quali fication as specified in this Code shall be considered as remaining in effect indefinitely unless (a) the welder is not engaged in a given process of welding for which the welder is qualified for a period exceeding six months or unless (2) there is some specific reason to _ question a welder's ability. In case (1), the requalification test need be made only in the 3/8 in (9.5 mm) thickness." 5.31 Records " Records of the test results shall be kept by the manufacturer or contractor and shall be available to those authori:ed to examine them." QAM 5.1 Para - 2.0 application states: 2.1 Scope "All welding shall be performed by qualified welders and weldir.g operators using qualified procedures and certified welding material in accordance w~ith the code." GCI 4.02, Para. 6.4.1.2 " Welders are requalified when any of the following oc' cur:" 6.4.1.2.1 "When they do not use any process for a period of three months." 6.4.1.2.2 "When they do not use a specific process for a period of six months." s
F Attaciunent 6 2' / Pcge 4 of 24 6. ERT INVESTIGATION REPORT pAGE 4 OF 5 ~~ CONCERN NOS. EX-85-042-004, EX-85-042-005, IN-85-480-OO4, IN-85-627-037 DETAILS, continued FINDINGS: ~ ~ During the course of this investigation, . two sets of welder . certifications were reviewed and the following information was provided Welder #1 On July 19, 1985 his Certification (welding card) expired. His certification was back datea on 8/2/85 by WQC to July 11, 1985. Welder #2 On July 8, 1985 the welder went to the test shop to renew his certification which expired on July 7, 1985. His card was back { dated to June 11, 1985. The Of fice of Construct ion's (OC) " welder's quali fication verification" records were reviewed (random sample). 13 cards were checked with 4 cards found to be back dated. i.e., Welder A - back dated on 11/28/84 to show 10/31/84 Welder B - back dated by WQC on 5/22/85 to 5/14/85 Welder C - back dated by WQC on 9/15/84 to 8/30/84 Welder D - back dated by WQC on 5/29/85 to 5/27/85 This was discussed with Mr. K. Hastings (WEU) and Mr. K. Kinser, (WEU); two forms were located. One form, (a WEU form), identified the welders numbers and the date that the qualifications were updated (back dated). The other form was from WQC to WEU which was a " certification up date log." The second form was discussed with Mr. K. Galloway WQC Supervisor who ctated that if .a welder's qualification was past the 3 month . limitation, a " verbal" concurrence between DC Inspectors, welding foreman or OC would be requested in order to" support the "back dating" ( (here up dating) of the welders certi fication. Although this took
- place, is no documented evidence i.e.,
weld number location or work _ crder to support the "back date" and to assure no we,lding was conducted during the time span when certification had expired and when it had been corrected. -m
{ ( + p Pcg2 5 of 24 ERT INVESTIGATION REPORT pAGE 5 0.0 5 CONCERN NOS. EX-85-042-004 EX-85-042-005, IN-85-480-004, IN-85-627-037 BE?EiCs-caniinu;;-------------------------------------- Nowhere in the procedures is "back dating" addressed.. If a welder' s qualification " expires"', p e t-Q 322 and AWS Section 5, he shall make "a single test Joint" per ASME IX WQ 322 and "A single test" per AWS D1.1. Welders and welding operators are cualified/ot-recua l i fi ed per ASME/AWS not certified. CONCLUSION: These concerns are substantiated. Back dating of welders' certification did take place without any procecural guidelines addressing this (practice.back dating of a welders certification. evidence which supports In addition, there is no documented the By "Back dating" qualifications for renewal without objective evidence to support the back dating, welding can be conducted by " expired" qual i ficat ions. OCI 4.02 Rev. 5 was issued 8/26/85 docurnenting the controls for maintaining welders qual i ficat ion. These controls utili=e specific inforraation i. e., reference documentation, however this does not correct the past indeterminate condition of objective evidence. "back.. dating" without p PREPARED BY:_____/,f_//g' j d2td _.j h_[_h /U ArE REVIEWED DY: M ___hM f Q Lima I" 4D.- 7 .w n _ A/w A $47' q cc ~ /l.sE6 S r
( ( / Prga 6 cf 24 ( RE UEST FOR REpORTABILITY EVALUATION 1. Request No. IN-85-627-037 ' ~ (ERT Concern No.) ID No., if repobed) I' 2. Identification of Item Involved:__ Welder Certification Falsification ,(Nomenclature, system, manuf.,SN, Model, etc.) 3. Description of problem (Attach related documents,
- photos, sketches,etc.)
~ Welder recertifications were Ta7sified. " ~ a 4 Reason for Reportability: (Use supplemental sheets if necessary) A. This design or construction d e fi ci ency, - were it to have remained uncorrected, could have affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant. .No Yes.X If Yes, Ekplain:_Recertifications were_ falsified. Method to recertify was not controlled which _would allow weldino activities to be conducted by unoualified welders. N9 -.m ~ B. This deficiency represents a sinnificant breakdown ,in any portion of the quality assurance program conducted in accordance with the requirements:of Appendix B.- id No Yes X If Yes, Explain: Violation-of ASME_AWS D1.11 l ANSI B31.1]_.10CFR50 Aooendix _ B VIII '~ l l d - _-- : -. : on
- n..
,.i .u-.. C. This deficiency represents a si nni ficant defic'iency in final design as approved and released for construction such that the .. design does not conform to'the' criteria bases stated in the! ' - - ~ safety analysis report or construction permit.
- 2.
i No _X Yes If Yes, Explain: l 1 \\ a _ g l ERT Form M
V / f Attachm:nt 6 ( Pago 7 cf 24 ~ REQUEST FOR REPORTABILITY EVALUATION D. This deftetency reot esents a sionificant deficiency in conutruction of or significant d arna c e to a structure, systern o t' ,connoonent which will teouire extensive evaluation. extensive r e c e r.l g n, or extensive repair to toeet the criterta anc hacen stated in the safa!rty analysis reoot t o n-consteuction cet ta t t or to otherwise establish the adecuacy of tne structure. Sy s t era, ~ or coraponent to pert forra its in' tended safety function. ~ No _X _ Yes._____ If Ves, Explain: 93 . E. This deficiency represents a si oni ficant deviation from the perfor mance specifications which will require extensive evaluation, extensive
- redesign, or extensive repair to establish the adequacy of the structure,
- system, or component to perform its intended safety function.
No X Yes __ I f Yes, Explain: ( IF ITEM 4A, AND AB OR AC OR 4D OR 4E ARE MARKED "YES", JMMEDIATELY HAND-CARRY THIS REQUEST AND SUPPORTING DOCUMENTATION TO NSRS. This Condition was Identified by: _1,,, @ ,h2Gb.,____ ERT Inves iga (qr), - Phone Ext. Y $W~ W %Y__ ERT Project Manager. Phone Ext. Acknow)edgmenlt of receipt by NSRS / .l_.- Date h _fM Time /%5.___ Sagned l l i 'ERT Form M i
? Attac4vacnt 6 s Page 8 ef 24 i. EMPLOYEE CONCERN ASSIGNMENT REQUEST TO: Director - NSRS TRANSMITTAL' NUMBER T50158 ERT has received the Employee concern identified
- below, and has assigned the indicated category and priority:
Priority: 1 Concern:.EX-85-042,005 Category: 88 Confidentiality YES NO (I&H) Supervisor Notified: X YES NO NUCLEAR SAFETY RELATED YES Concern: W. elder certification updates were f.alsified. CI has no further information. Constr. Dept. concern. No followup required. ) - o MANAGER, ERT 'DATE - NSRS has assigned responsibility for investigation of the above concern to: ERT / NSRS/ERT NSRS 2.//sp; p g OTilERS (SPECIFY) /)d,1 @Qu w I$l%?.( NSRS DATE ( U) h ( u-
( AttacInnent 6 ( / ( Pcg2 9 eif 24 s. ( EMPLOYEE CONCERN ASSIGNMENT REQUEST TO: Director - NSRS TRANSMITTAL NUMBER T50158 ERT has received the Employee concern identified below,.and h+s assigned the indicated category and priority: Priority: 1 Concern:,EX-85-042-004 Category: 7 Confidentiality YES NO '(I&H) Supervisor Notified: X YES NO NUCLEAR SAFETY RELATED YES Concern: Welding engineering dept.- would sign a certification update that a welder was requalified even though the welder had not used that particular welding process during the past 90 days or that the welder had not done a welder r_e_ qualification test at the test lab. Constr. Dept. concern. CI has no additional information. No followup required. s Yb NkV MANAGER, ERT DATE NSRS has assigned responsibility for investigation of the 'above concern to: ERT [ NSRS/ERT NSRS OTi!ERS (SPECIFY) $m hl4{?( (J) h
- w w.
D ,NSRS 4 DA'TE u.> W~ V
..e. t 7.. EMPL YEE CONCERN ASSIGNMENT REQUEST .t To: Director - NSR TRANSMITTAL NUMBER T50031 has received the Employee concern identified below, ERT assigned the indicated category and priority: and has Priority:3 Concern i IN-85-480-004 Category:33 confidentiality: YES NO (I & H) Supervisor Notified: X YES h10-. NUCLEAR SAFETY RELATED YES Concern: WELDER CERTIFICATION UPDATE IS INADEQUATE. PERSONNEL MAY WORK IN A POSITION THAT DOES NOT REQUIRE ANY WELDING FOR BUT CERTIFICATIONS ARE CONTINUALLY UPDATED. WHEN THESE PERSONS RETURN TO WELDING NO TESTS ARE CONDUCTED. TO UPDATE CERTIFICATIONS. THEY JUST RUN STRINGERS C Mh em. kh $b?K MANAGER, ERT,' 'DATE NSRS has assigned.responsibilty for investigation of the above concern to: i ~ ERT [ NSRS/ERT NSRS OTHERS (SPECIFY) f \\ c f& dabr SRS / /DATE s ..,-......s....,.y.
~ f,. j,, { y Attach:nent 6 f ( Page 11 cf 24 QUALITY y TECHNOLO tY P B 00 S w h 37.874 se ERT INVESTIGATION RE RT REV.1 PAGE 1 OF 6 / / ,/ s' CONCERN NO:, IN-8 5-7 70,QO 2, -IN-8 5-4 2 4-X13, -IN-8 5-0 21-X0 5,- 167-005 ~- -IN-85-965-001,-IN-85-612 X07,-IN-85-T70-X07,, 167-X06 f f - WI 85-0 03-001, -IN-85-778(X0 7, IN-8 6 'f4 3-00 2,,W1-85-003-X02 CONCERN: SEE DETAILS
- All listed concerns tracked
\\ under IN-85-770-002. INVESTIGATION PERFORMED BY: William M. Kemp,Jr./ Rana L. Ahmed DETAILS IN-85-770-002 Walders certification cards were falsified. IN-85-965-001 (A welders certification expired on a Wednes day,. This welder was (re-certifiedthenextWednesday. But the certification was back dated a prevent-the work preformed by the welder from being rejected. This was about 12/16/80. . IN-85-778-X07 Walder certification card falsified. - WI-85-003-X02 Walder certification cards falsified. ,IN-85'-021-X05 Walders certification cards were falsified / IN-8 6-14 3- 00 2 Walder's certification card was back.da.ted around 30 days af ter failed to have his card up dated. - IN-86-167-005 Concern that welder re quals (updates) have been back' dated. -IN-86-167-X06 Ider certification card has been falsified. I s
L ~ ,itaciunent ', f \\ Page 12 of 24 ((,ERTINVESTIGATION s EPORT,REV.1 PAGE 2 OF 6 CONCERN NO: IN-8 770-002, IN-85-424-X13, IN-85-021-X05, IN-86-167-005 IN-85-965-001, IN-85-612-X07, IN-85-770-XO7, IN-86-167-X06 WI-85-003-001, IN-85-778-X07, IN-86-143-002, WI-85-003-X02 - DETAILS, continued \\ IN-85-424-X13 Management personnel falsified welders certification card. ~ / IN-85-612-X07 Welder certification card falisified. -IN-85-770-X07 Welders (8) certification cards were falsified. WI-85-003-001 Welders certification card updated is incorrect (back dated). Time (- frame May 27-June 3, 1985. Welder performing duties in Turbine Building, Unit 2. Personnel Contacted: Confidential Documents Reviewed: ASME Section IX QW 320 AWS D1.1 Section 5 Welders Qualifications QCI 4.02 Revision 4 Welder Welding Operator Performance Qualification. QAM 5.1 Welding Control Rev. 20 L L 1 m
l" ( At tac tw:n t 6 \\ / \\ Pcgo 13 of 24 .RT INVESTIGATION RE ORT,REV.1 PAGE 3 OF 6 CONCERN NO: IN-85-77 -002, IN-85-424-Xk3, IN-85-021-X05, IN-86-167-005 IN-85-965-001, IN-85-612-X07, IN-85-770-X07, IN-86-167-XO6,, WI-85-003-001, IN-85-778-X07, IN-86-143-002, WI-85-003-X02 DETAILS, continued Summary of Investigation \\ These concerns are substantiated. B0 sed on the investigation of these concerns "Back Dating" of welder qualification was a common practice. "Back Dating" would be approved b2 sed upon someone (i.e.,
- Foreman, QC Inspectoror O.C.)
having knowledge that the welder had welded in that specific process.
- However, there was no objective
- evidence, i.e, supporting documentation such as weld number, item, work order or work package to support the justification of "Back Dating" the welder qualification (Certification).
The " Fa lsi fica tion " issues are to be act'd upon by the TVA Office of e G neral Counsel (OGC). 1 Requirement: (AMSESectionIX, QW 322 states that when a welder: a) "has not welded with a process during a period of three months or more his cualifications for that process shall be exoired except when he is welding with another process the period may be extended to six months." b) he has not welded with any process during a period of 3 months all his qualifications shall be exoired including any which
- may extend beyond 3 months by virtue of (a) above."
\\ I QW 322 goes on further to state that the " Renewal of Qualification for a specific welding process under (a) and (b) above may be made in a single test joint (plate or pipe) on any thickness, position or material to reestablish the welders or welding operation qualification for any thickness, position or material for the process for which he was previously aualified." l l AWS Dl.1 Section 5 states: l l 5.30 Period of Effectiveness "The welder's qualification as specified in this Code shall !l (, be considered as remaining in effect' indefinitely unless (a) l.
(- r / Pege 14 of 24 ERT INVESTIGATION RE) ORT,REV.1 PAGE 4 OP 6 CONCERN NO: IN-85-7 0-002, IN-85-424-X'13, IN-85-021-X05, IN-86-167-005 IN-85-965-001, IN-85-612-XO7, IN-85-770-X07, IU-86-167-X06. WI-85-003-001, IN-85-778-X07, IN-86-143-002, WI-85-003-X02 DETAILS, continued 5.30 continued i 'the welder is not engaged in a given process of welding for which the welder is quailfied for a period exceeding six months or unless (2) there is some specific reason to question a welder's ability. In case (1), the requalification test need be made only in the 3/8 in (9.5 mm) thickness." 5.31 Records " Records of the test results shall be kept by the manufacturer or contractor and shall be available to those authorized to examine them." QAM 5.1 Para 2.0 application states: f ML 2.1 Scope "All welding shall be preformed by qualified welders f( and welding operators using qualified procedures and certified weldino material in accordance with the code." QCI 4.02, Para. 6.4.1.2 " Welders are recualified when any of the following occur:" 6.4.1.2.1 "When they do not use any process for a period of three months." ~ 6.4.1.2.2 "When they do not use a specific process for a period of six months." Findings: During the course of this investigation, two welders were interviewed and the following information was provided: Walder i 1 I On July 19, 1985 his certificate (welding card) expired. His certificate was back dated on 8/2/85 by WQC to July 11, 1985. L{ alder !2 W On July 8, 1985 the welder went to the test shop to renew his certification which expired on July 7, 1985. His card was back dated to June 11, 1985. I e _-_,g
'i k F Prge 15 of 24 t. ERT INVESTIGATION RE ORT,REV.1 PAGE 5 OF 6 i CONCERN NO: IN-85-770-002, IN-85-424-X13, IN-85-021-X05, IN-86-167-005 IN-85-965-001, IN-85-612-XO7, IN-85-770-XO7, IN-86-167-X06 WI-85-003-001, IN-85-778-X07, IN-86-143-002, WI-85-003-X02 DETAILS, continued The office of Construction ~s (OC) " welder 's qualificati'on verification" was reviewed (random sample). 13 cards were checked and 4 cards were back dated. i.e, Welder A - back dated on 11/28/84 to show 10/31/84 Welder B - back dated by WQC on 5/22/85 to 5/14/85 Welder C - back dated by WQC on 9/15/84 to 8/30/84 Welder D - back dated by WQC on 5/29/85 to 5/27/85 This was discussed with (Confidential) (WEU) and (Confidential),(WEU); two forms were located. One form, (a WEU form), identified the welders numbers and the date that the qualifications were updated (back 1 q{(dated). The other form was from WQC to WEU which was a " certification p date log." The second form was discussed with (Confidential) who stated that if a wslders qualification was past the 3 month limitation, a " verbal" concurrence between QC Inspectors, welding foreman or OC would be requested in order to support the "back dating" (up dating) of the w21ders certification. Although this took
- place, there is no 3
documented evidence i.e., weld number, location or work order to support the "back date" and to assure no welding was conducted during the time span when certification had expired and when it had been corrected. Nowhere in the procedures is "back dating" addressed. In the procedures, if a welder 's qualification " expires", per 0 322 and AWS Ssetion 5, he shall make "a single test joint" per ASME IX 30"322 and,g,f "A single test" per AWS Dl.l. GW Walders and welding operators are qualified /or reoualified per ASME/AWS not certified. e hL G
( ( l'ah Lk of 24 C-RT INVESTIGATION REP RT,REV.1 PAGE 6 OF 6 CONCERN NO: IN-85-77 -002, IN-85-424-X13, IN-85-021-X05, IN-86-167-005 IN-85-96 -001, IN-85-612-X07, IN-85-770-XO7, IN-86-167-XO6 WI-85-003-001, IN-85-778-X07, IN-86-143-002, WI-85-003-X02 DETAILS, continue
== Conclusion:== i These concerns are substantiated. Back dating of welders ~ cartification did take place without any procedural guidelines cddressing this practice. In addition, there is no documented evidence which supports the back dating of a welders certification. By "Back dating" qualficiations for renewal with out objective evidence to support the back dating, welding can be conducted by " expired" qualfications. QCI 4.02 Rev. 5 was issued 8/26/85 documenting the. controls for maintaining welders qualification. These controls utilize specific information i.e., reference documentation, however this does not correct the past indeterminate condition of' "back dating" without objective evidence. The "falsificaton" issues are to be investigatedfevaluated by the OGC alative to the back dating of welders certifications. b 10 f23 lPA PREFORMED BY W )?1 , A vyDyo o^" I M/ 2/P% l REVIEWED BY 4 l DATE ef u"wece/ h y U k p& s9 a L U i 3
~ 'f Attaciunent 6 2" ' f * * *; g \\ Pcge 17 of 24 UEST FOR REPORTABILITY EVALUATION 1. Request No. IN-85 965-001 (ERT Cancern No.) (ID No., if reported) 2. Identification of Item Involved: Welders Certi ficatinn (Nomenclature, system, manuf., SN, Model, etc.) 3. Description of Problem (Attach related documents, photos, sketches, etc.) Welders certification cards were falsified (back dated). 4. Reason for Reportability: (Use supplemental sheets if necessary) A. This design or construction deficiency, were it to have remained uncorrected, could have af fected adversely the safety of operations of the nuclear power plant at any time.throughout the expected lifetire of the plant. NO YES X If Yes, Explain: There is no objective documentation i.e. weld number, work plan, or item which suoports time frame welder ( certs expi red. Welds could have been made by unavalified welders. AND B. This deficiency represents a significant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of Appendix B. No Yes X If Yes, Explain: ASME Section IX AWS Dl.1 Section 5 10CFR50 Appendix B, Criteria IX, II E C. This deficiency represents a sienificant deficiency in final design as approved and released for construction such that the design does not conform to the criteria bases stated in the safety analysis report or construction permit. No X Yes If Yes, Explain: E ERT Forn H l s
i s ca:;u i.; ut 3. . 4. ~ i /*' N Page 2 of 2 { QUEST FOR REPORTABILITY EVALUATION ?* D. This deficiency re resents a sienificant deficiency in construction of or sirnificant damage to a structure, system or component.which will require extensive evaluation, extensive redesign, or extensive repair to meet the criteria and bases stated in the safety analysis report or construction permit or to otherwise establish the adequacy of the structurg, system, or component to perform its intended safety function. No X Yes If Yes, Explain: r 0,,,R, E. This deficiency represents a sienificant d iation from performance specifiestions which will require extensive evaluation, extensive redesign, or extensive repair.to establish the adequacy of the structure, system, , or component to perform its intended safety function. . No X
- Yes, If Yes, Explain; _
( l IF ITEM 4A, AND 4B OR 4C OR 4D OR 4E ARE HARKED "YES", IMMEDIATELY HAND-CARRY THIS REQUEST AND SUPPORTING DOCUMENTATION TO NSRS. This Condition was Identified by: (/ g/ 3/,P W6[ ERT Group Manager Phone Ext., l ~ 04T/aa-L .a c-m v j ERT Project Manage Phone Ext. '. I i Acknow gme t of receipt by NSRS 3 Date /O,,f $ 7 Time / O M l Si L. ERT Form M O I k
r rvA es tas s-esi cor wp s as ( Attach 2ent 6 ,. L*Nt'TCD' STATES COVErtN.ilENT Paga 19 of 24 f \\ Memorandum x TENNESSEE VALLEY AUTHORITY TO: W. T. Cottle, jite Director, Watts Bhr Nuclear Plant FRoli: K. W. Whitt, Director of Nuclear Safety Review Staff. E3A8 C-K DATE: fb i 1
SUBJECT:
CORRECTIVE ACTION RESPONSE EVALUATION REPORT NO. : IN-85-770-002 SUBJECT WELDER CERTIFICATION CONCERN NO.: IN-85-770-002 (X) ACCEPT ( ) REJECT n ~ K. W. Whitt BFS:JTH y ec (Attaehment): J.W.Coan,W9C135C-K\\ R. P. Denise LP6N40A-C F. E. Laurent, CEO-WBN D. R. Nichols, E10A14C-K I OFFICE OF ENSNEERING QTC/ERT, CONST-WBN E. K. Sliger, LP6N48A g } }.p v Kent Therp, 10B-WBN WELDING P AQ)ECT I/ %e in Coon 4 Principally prepared by Bruce F. Siefken. I Sims g r-W Jessee i 4/f p _l Pitzt l/ s' _ WStagnolio. g GPrucirt4,,gv I I I I l I i l Fife l g I Tos: j (1433U G 9.... t c c..;... n.,..s. n.....r..r... ry g.... y g...:.. p..
~ , twa o.se.e m { / L'fiiTED BTATES GOVERN 3 TENT Page 20 of 24 Memorandum { TENNESSEE VALLEY AUTH0RITY TO K. W. Whitt. Dir tor of Nuclear Safety Review Staff E3A8 C-K Frost W. T. Cottle, Site Director Watts Bar Nuclear Plant NUC PR ' 31 jcgg DATE stBJECT: WATTS BAR NUCLEAR PLANT - RESPONSE TO EMPLOYEE CONCERN INVESTIGATION REPORT - TRANSMITTAL ~* .vo 'c. : .._-.lransmitted herein is Construction's response to recommendation 8 '} } Q-85-770-002-01 contained in investigtion report number IN-85-770-002 1 i covering the following employee concerns: IN-85-770-002, IN-85-965-001, c ' ~" WI-85-003-001, IN-85-424-X13. IN-85-612-X07. IN-85-778-XO7, ! p pg IN-85-021-X05, IN-85-770-X07. IN-86-143-002 IN-86-167-005, IN-86-167-X06 WI-85-003-X02. The response appears to be consistent with your recommendation with additional information provided in Non Conformance Report (NCR) numbee 6277 and accepted response to investigation report number IN-85-113-003. kheresultsofConstruction'sreinspectionprogramhavenotbeenfully evaluated because NCR 6562 must be dispositioned for some welds found to --be out of specification. Upon receipt of your acceptance of this
- ~
response, I will request the scheduled date when Construction expects to ~have all described activities documented and sampling results evaluated and accepted. Additionally, the above concerns cannot be closed until satisfactory completion of the Department of Energy Weld Evaluation Project (DOE-WEP). Although none of the concerns implicated the WBN-NUC PR program, the program was evaluated. See memorandum from E. R. Ennis to K. W. Whitt, dated November 7, 1985 (T16 851107 916) regarding concern,IN-85-113-003. My staff has discussed this response with your Mr. H. A. Harrison and i obtained informal acceptance. Ifyouhaveanyquestions,'pleasecontactW.L.ByrdorJ.R.hngerat ~ 3774, Watts Bar Nuclear Plant NUC PR. I_ W. f. Cottl6 WLB:JRI:HC Attachment This memorandum was principally prepared by J. R. Inger. i i l r l e Bu r l '. 7. 7a: in ne Ra nds R.'"* ' "" ~ Dn' *rs!! C- : ~ D!- *
['~ / a *. Page 21 cf 24 {mployceConcernIN-85-770-002(ctal) C0NCERN: Recommendations Q-85-770-002-01 " Backdating Welder Certification Card" - WBN Construction -- should issue an NCR to document and obtain resolution for the indeterminate condition of welds performed by welders whose qualifications had expired by virtue of not updating certification cards on schedule or from actual non-performance of processes. A suggested resolution is to evaluate the results of a proposed welding program review for which extensive reexamination of welds /weldments is planned to be performed. i
RESPONSE
Stop Work Order 25 was issued August 23, 1985, which identified i the welder certification program at WBN to have some aspects of concern with respect to adequacy and accuracy of records. NCR 6277 was issued August 26, 1985, to document and obtain resolution for the indeterminate condition. An in-depth review of the welder initial certi-fication program as well as the recerti'fication program has been perforced to assure compliance to ASME and AWS requirements. Tne conclusion of this review is that both programs as delineated in con-e j struction procedures meet or exceeds ASME and AKS requirements; however, a ( breakdown in the implementation of the recertification program did occur. Watts Bar site procedures controlling welder certificatica maintenance were revised effective August 26,19SS, and all welding engineering and inspection personnel have been retrained to ensure that all personnel involved with welding activities are thoroughly familiar with requirements. A total of 567 welders possessed active. welder certifications at the time Stop Work Order 25 was issued. All welder certifications older than 90 days ~ were withdrawn. Thirty of these welders had received initial certification tests within 90 days prior to the stop work order; therefore, were considered acceptable. ( A renewal qualification test program was initiated August 2'8', 1985, for the 537 welders whose certification maintenance was questionable. 'Ihe tests were performed in accordance with ASME Boiler and PV Code, Section IX and ANS D.1.1 as applicable. A total welders had one or more coupons re.of.1008 tests were administered and 120 jected. In order to assure no weld quality has been compromised, 'IVA has identified all welding performed by these welders on ASME code items. A statistical sampling reinspection program is currently in progress on this group of welds in accordance with NCIG-02. In addition, all other welds on ASME systems identified to have been welded during the time frame in question have been identified. All welds made by a welder who showed a lapse in continuity (after the lapse occurred) will also be subjected to a statistical sampling reinspection program. 'Ihe reinspection { program and results are currently scheduled for completion in January,19S6. e e O v. ,7. m, ,wn ,n,.. n-,. ,--.....,,,.,-,.-n ,.-,,,.-n
e. ( Attaclunent 6 Page 22 cf 24 '2 g ( , Employee Concer IN-85-770-002 (et al) A seperate program is currently in progress to review the total welding" ~ program at WBN which includes an extensive reexamination of welds /weldsents by a third party agency. 'Ihe results of the reinspection / program review will be evaluated to assure weld /weldment integrity at WBN has not been compromised. Principally prepared by Kenneth Hasting, extension 3395 e 4 \\ e . O 1 e O
\\ s
- , 9 g;,n 2,
'NITED STATES COVSBNMENT NCSIOYdndMM TENNESSEE VALLEY AUTIIORITY s E. R. Ennis, Plant M nager, Watts Bar Nuclear Plant TO( K. W. Whitt, Direct r of Nuclear Safety Review Staff. E318 C-K FROM
- --NOV4 1985 DATE NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSHITTAL
SUBJECT:
i Transmitted herein is NSRS Report No. IN-85-770-002 i Subject WELDER CERTIFICATION t b Concern No. IN-85-770-002 and associated recommendations for your action / disposition. It is requested that you respond to tiils report and the attached recommendations by November 25, 1985 Should you have any William M. Kemo at telephone 365 4414 questions, please contact Recommend Reportability Determination: Yes X No ( Original signed by M. S. Kidd Director, NSRS/ Designee MAH:JTH Attachment cc (Attachment): H. H. Culver, W12A19 C-K QTC/ERT, Watts Bar Nuclear Plant W. F. Willis, E12B16 C-K (4) _ Copy and Return-- K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K To : f From: I DEte: IN-85-770-002 I hereby acknowledge receipt of NSRS Report No. Subject WELDER CERTIFICATION for action / disposition. C-f Date Signature .,f Ruv U.S. Savines Bonds Recularly on the Payroll Savings Plan ~
(/ ~ j* - ( Attactucnt 6 Page 24 cf 24 ~~ s** NSRS RECOMMENDATIONS Concern: IN-85-770-002 (et al) g BREsmmsedat190s 9:85:ZZ9:092:91 :_"Bashdatics tJeidet_Gettificatige_Gatd" - WBN Construction should issue an NCR to document and obtain resolution for the ind3 terminate condition of welds performed by welders whose' qualifications had C:tpired by virtue of not updating certi fication cards on schedule or f rom cctual noncerformance of processes. A suggested resolution is to evaluate the results of a proposed welding crogram review f or which e:: tensive ree:: amination of welds /weldments is planned to b3 performed. / ( Prepared by: 4/V d e --. Harrisdn M. A e e G 9 e E o o e 4 L t h
i Attachmint 7 ( / Page 1 of 17 s,. QUALIT ( TECHNOLOGY gg COpPANY P.O. BOX 600 Sweetwater, TN 37874 (615)365-4414 ERT INVESTIGATION REPORT Page 1 of 5 Concern Nos.: EX-8 5-04 2-002 / I N-8 5 - 6 0 0 - 0 0 6.- IN-85-310-006-IN-85-627-036. Concern: Welders ~ some form of punishment.must ensuta..their o n recertifications or receive administered, including back dating some certificationsThe recertification' p properly See " Details" below. Investigation Performed by: W. M. Kemp Details: Note: The following concerns have been investigated and the reported. These previously completed investigations resolves the findings concerns noted above: /lLdd-9&IN-85-503-001: IN-85-778-001;- IN-85-612-006-IN-85-493-004;s IN-85-770-003;- IN-85-346-003-IN-85-532-004;- IN-85-532-005;- IN-85-543-002-EX-85-021-002;: IN-85-424-Oll;/ IN-85-540-001 IN-85-426-002;. Q 85-815-00T e IN-85-835-002-h IN-85-352-001 Concern No.: EX-85-042-002 Concern: Welders have to keep their own records. certification
- update, If they miss the Supervisor did not keep.the qualification record updatedtheir superviso letter.
1 Concern No.: IN-85-310-006 Concern: Welders that have period not used a' process during the 3 month updating their certifications.are asked to do a quic~k partial weld using the process before Concern No.: IN-85-600-006 Concern: Card is presented to welding engineer and they look at aC {pr)intoutandthenstampcard. A follows: i B) domputer have current cards and he thinks they have not welded in theSeveral Foreme they are certified in, in several years. processes O
1 -( ( AttacIncnt 7 I' \\ Page 2 of 17 ( ERT INVESTIGATION R ORT Page 2 of 5 Concern Nos.: EX-8 042-002 IN-85-600-006 IN-85-310-006 ~ IN-85-627-036 Details: Concern No.: IN-85-627-036 Concern: Construction Dept.Some welders have had-bheir rec rtification cards backdated. concern. CI has no further information.' Reference Documents: Quality Assurance Manual 5.1 (ASME) Welding Control Quality Qualificationcontrol Instructions 4.02 Welder / Welding Operator Performance G-29 Project Specification Manual
- 1. fi. 2. 2 Welder / Welding Operator Performance Qualification WBN-85-0108-200 Jan. 8, 1985 Letter May 24, WBN-84-0123-201 Jan. 23,1984 Welder Certification / Update 1984 (StopWorkAuthority125 Findings: These concerns are substant'iated.
This investigation was conducted to determine the availability of documented evidence to support the welders qualification renewal program. The following deficiencies were noted: 1) QAM 5.1 (ASME), G-29 PSM 1.M.2. 2 and QCI qualification tests.the responsibilities for the test 4.02 are discrepant in identifying shop and For example, QAM 5.1 states that the construction engineer designates the engineer
- who, is to supervise the test shop and perform qualificatlon testing.
OCI 4.02 states the Welding Engineering Unit will be responsible for the test shop and qualification be responsible for the testiwhile G-29 PSM 1.M.2.2 states that the shall shop'and qualification testing. 2) During the investigation it was stated by a welding "We do not engineer qualify welders to Section IX only to G-29."
- However, QAM 5.1 (ASME) refers to the
" code", QCI 4.02 that welder qualification is in accordance with ASMEre IX. Section 9 e
r f' Attachm nt 7 i ( \\ Pigs 3 cf 17 s. ( ERT INVESTIGATION RE ORT page 3 of 5 Concern Nos.: EX-8 042-002 IN-85-600-006 IN-85-310-006 IN-85-627-036 Details: 3) A random selection of related NCR's (#4868,
- 5194, 4508R,
- 5304, 5303, 5065, 5034, 4577R)~from 1981 to 1984 concerning expired welder qualiffcation determined that the root was never evaluated or determined.
cause 4) There is no documented evidence per QCI* 4.02, paragraph 6.4.1.2 and QAM 5.1-(2.4) as to the verification of welders welding to a specific process to support their renewal of certification. The only evidence is if someone in QC saw or knows that the welder has performed an in process weld justifying his renewal. Ho~ wever, no documentation is
- thus, available to support QC's claim that this took place.
5) During the investigation the following incident was observed: A welder came to the test shop to update his welding (' ~ certification. The welder was advised by a welding engineer to go to the test booth. After 2 or 3 minutes the welder came back to 'the office and gave his card to the weld engineer in the test shop 'ffice who stamped and initialed o his card. It may be noted that both of the welding engineers were busy at that time with the ERT investigator. The welding engineer did not observe or verify the welders process per QCI 4.02, paragragh 6.1.5.1, 6.1.5.2, 6.1.3.1, 6.1.3.2. There was no weld filler metal to theobservation of the welder taking any test booth (QCI .4.02, paragraph 6.1.1.3) or the welder bringing any hot metal to prove the process in the test booth (QCI 4.02 paragraph 6.1.5.3.1). It was also stated by the welding engineer that they do not observe all the welders all of the time (only 70%). 6) If no one in QC has seen or has knowledge of the welder using a process in a 3 month period, the welder goes to'the weld test shop to " burn a rod". On a plate to the process he is qualifying for with or without verification of position current and material. The welder has now welded to a process, within a 3 month period and his certification is renewed with no more documentation than a signature on a certification card. Stop Work Authority 525 was issued to stop all weld activities August 23, 1985. on (, has been initiated and is in process:The following corrective action by management O
(/ Attseincnt 7 ( / Page 4 cf 17 ~, { ERT INVESTIGATION R ORT Page 4 of 5 Concern Nos.: EX-8 -042-002 IN-85-600-006 IN-85-310-006 ~ IN-85-627-036 Details: 1) Recertifying approximately 536 welders except which had been certified within 90 days previous to the for 30 welders work order being issued. stop 2) QCI 4.02 Weider and Welding Operator Performance instruction, has been revised to include controls and specific evidence for welders performance, objective verification and renewal of certification. 3) TVA Form 10204A (OC-8-85), Welding Material Requisition, Will be revised to include the statement: "I certify that on this date this welder used the. above welding process on (feature)." "The weld material requisition shall be kept for the life of construction and will be inputted into the computerized welder-welding operator listing on a daily basis." 4) Quality Training Program Manual 3-3 and QAM 5.1' will be revised to reflect the program for the control certification. of welder's With the initiation of these controls by problems management future should be eliminated, however, past problems welders qualification must still be evaluated. on which was dated _May 24, Memorandums WBN-84-0123-201, WBN-8 1984, all state: 1) "If the welders certification expire. because of failure ~to have them updated the folloeing s will be taken actions First Offence - Two Week Suspension Second Offence - Termination" 2) "The welder ~would be held responsible" 3) "Each welder is responsible" 4) " Alteration of penalty for welders who fail to update certification" l S y
( ( Attactsngnt 7 \\ ' Paga 5 cf 17 t ( ERT INVESTIGATION REP RT Page 5 of 5 Concern Nos.: EX-85 042-002 IN-85-600-006 IN-85-310-006 IN-85-627-036 Details: The requirements per QAM 5.1 Rev. 20 states that for welder welding operator qualification maintenance, the responsibility .for this -' control is.,with Engineering / Unit Welding Quality Control." ~ the " Welding QCI 4.02 Rev 3 states that the Welding Engineering Unit is responsible to control verification and renewal of qualifications. ASME IX, QW 300.2 states that the manufacturer (TVA) is responsible for welder qualification. ASME Section III, Subsections NB, NC, and ND states that the manufacturer or installer shall maintain records of qualification of welders. AWS ( D1.1 states that welder qualification requirements shall be controlled by the manufacturer & installer. From these requirements and the performance of this investigation the following items are noted: 1) Responsibility of control of welder qualification l (renewal) was not retained by management (per applicable requirements) but was directed to craft (welders). ~ t 2) There was no system or control to identity welders whose qualifications were up for renewal. 5
- 3)
Memos circumvented procedure requirement and commitments for control of welders qualifications. I Based on the findings in the investigation, this concern is Substantiated. It is noted.that TVA-has initiated corrective action to resolve this con.cern, however the. impact of past welder qualification problems must be evaluated.. ) e,vWy!rwxseaA ed dde<Ma: \\ aaQJe Prepared by_ h c%//f'[#2 f, f (eviewedby_ 8Mb hh)'. / date - s M pff'
y W-f~ Attach ent 7 ( I N Pag 2 6 cf 17 i R JUEST FOR REpORTABILITY EVALUATION 1. Request No. IN-85-627-036 *nthers (ERT Concern No.) (ID No., if reported) 2. Identification of Item Involved:__,t[eygy _nERGiff ten - -( Nomencl at ure, system, manuf.,SN, Model, etc.) 3. Description of problem (Attach related documents,
- photos, sketches,etc.)
,yelders must_ ensure the_ir own ecertification or_ receive _some_forn of,,__ _ Punishment,_._,_T_h_e recertip cation _,rocess is not oroneriv_ adni,n,1.s, tg3 q,[ ingindjng o back datine. 4 Reason for Reportability: (Use supplemental uneets if necessary) A. This design or construction. deficiency,- were it to have remained uncorrected, could h' ave affected adversely the safety of operations of the nuclear power plant at any time throughout the expected lifetime of the plant. No __ Y e s ,,_X._ I f Y e s, E:,pl ai n Back d.g_qing qf._qng11Lica,tiens,,,,__ _,nd maint,e, nance of_,gual_ip cations _v,as not controlle,d__in a manneg g2_as UIt. a elding activities were conducted bv aualified velders w AND -f "
- B.
This deficiency represents a sionificant breakdown in any portion of the quality assurance program conducted in accordance with the requirements of Appendix B.* No Yes X __ If Yes, Explain: Violates if) CFR Aope_ndix_R Criteria I, VIII, XVII ASME D1.1 OR C. This g de ficiency represent s a pi nni fi ca__n_t, de ficiency in final design as approved and released for construction such that
- the, design does not conform to the criteria bases stated in the -
safety analysis report or construction permit. No _,X _ Yes If Yes, Explain: ( D., R.____
- 0thers EX-85-042-002, IN-85-600-006, IN-85-310-006 ERT Form M
f ~ ( / k Pagn 7 cf 17 ( h R QUEST FOR REPORTABILITY EVALUATION D. rhis defsciency reot esentr. a significant deficiency in conutruction of or significant daraane to a structure, syste'd or c osa c o n e n t which will reouire extensive evaluation. extensive ' rec e7.i gn, or ext ens i ve t'epai r to raeet the criteria anc ha s.s er, stated in the safety analysis recort or c..nstruction c e rta n t or to otherwsse establish the adecuacy of tne structure. sys t ern, ~ or coraponeret to per t'forra its intended safety f u n c t i v r.. ~ No.,_.x_ Yes._ ___ If,fes, Exp1ain:
- Q_R, E.
This deficiency represents a sinnificant deviation from the performance specifications which will require ewtensive evaluation, extensive
- redesign, or ewtensive repair to establish the adequacy of the structure,
- system, or component to perform its intended safety function.
No X Yes _ If Yes, Explain: ( IF ITEM 4A, AND 4B OR 4C OR 4D QR 4E ARE MARKED "YES", JMMEDIATELY HAND-CARRY THIS REQUEST AND SUPPORTING DOCUMENTATION TO NSRS. O This Condition was Identified by: __fC _ v_l4t'/Or MO d I ERT Investig9 oi Phone Ext. O N M ____T1mfa4v ERT Project Manager Phone Ext. e / Acknowi ndgraent of receipt by NSRS / b b ~ n _7a_ Date L Time M Si ncd / l L r .ERT Form M k
s. k'~ .\\L laClimerit I k Page 8 of 17 ( EMPLOYEE CONCERN ASSIGNMENT REQUEST ~ TO: D1 rector - NSRS TRANSMITTAL NUMBER T50210 ERT has received the Employee concern identified
- below, and has assigned the indicated category and priority:
Priority: 1 Concern # IN-8S-310-OO6 Category: 33 ~~'onfidentiality:
- _YES,
- NO CI&H)
C Supervisor Notified: __YES _X_NO NUCLEAR SAFETY RELATED YES Concern: WELDERS THAT HAVE NOT USED A PROCESS DURING THE 3 HONTH PERIOD ARE ASKED TO DO A QUICK PARTIAL WELD USING THE PROCESS BEFORE UPDATING THEIR CERTIFICATION. (DETAILS KNOWN TO QTC. BUT WITHHELD FOR CONFIDENTIALITY). WBNP BOTH UNITS. CONSTRUCTION DEPT. CONCERN. CI HAS NO FURTHER INFORMATION. 2 '~5
- g.,,., 2. E. - U 2
P h ,f;. _g y NOV 3 0_1985 MANAGER, ERT DATE NSRS hea esaigned responsibility for investigation of the above concern to: ERT __ NSRS/ERT _____ NSRS ______ l OTilERS (SPECIFY) &xx----.]-.,$h N we:2& i HSRS -~I (WM# DATE O
-{ {' AttacIncnt 7 Pcga 9 of 17 i C ERT INVESTIGATION REPORT Page 1 of 6 i CONCERN NO: MWK -5 IN-85-503-001. - IN-85-778-001, -IN-85-612-006 'IN-85-493-004, 'IN-85-770-003, uIN-85-346-003 -IN-85-532-004, 'IN-85-532-OO5, 'IN-85-543-OO2. VEX-85-021-002, 'IN-85-424-011 -IN-85-540-001, 'IN-85-426-002, 'IN-85-815-001. IN-85-835-002, IN-85-352-001 - g g j 7 N .,, CONCERN See ** DETAILS" Below INVESTIGATION i PERFORMED BY: William Kemp Rana Ahmed t Thin report contains the findings derived from a generic investigation of the concerns listed below:
- IN-85-503-001 CONCERN:
Individual (name known) in concerned individual's ( (hereafter CI) crew was given 2 weeks off for failing to have welding card updated by weld engineering. Individual had performed required welds but was out sick on the day update was required. Other individuals in CI's crew who had failed to get their cards updated received no disciplinary action or had i received only an oral warning. 4
- IN-85-778-001 CONCERN:
Welder certifications have been improperly. updated. No further details available. l
- IN-85-612-006 I
CONCERN: Welder certification, update is inadequate and not enforced per an established set of criteria.. Weldern given time i off without pay for failure to update certifications. i j .V IN-85-493-004 i CONCERN: Welder certification update la inadequate to verify that the welder can continue to weld a particular process.
- IN-85-346-003
(, CONCERN: Welder certifications are updated on evidence of rod withdrawai slips. The process may not have been used in the applicable time period, 90 day or/80 day, depending on ASME or AWS. ( w. e _._,,my-.,.-vwm--e----* - - '- " ~~~"" ' " -
^ (# (* Attac!acnt 7 i . - ;.1 * ( Page 10 of 17 t ERT INVESTIGATION EPORT Page 2 of 6 CONCERN: See " DETAILS" below gg___g___________________________________________________________
- IN-85-532-OO4 CONCERN:
Memo issued by management that provides direction that ,, is contrary to the established procedure for .. weld er
- 7.-
re-certification..,(Author of memo known to QTC)
- IN-85-532-OO3 CONCERN:
Welders are recertified without verificstion that weiders have performed specific weld technique.
- IN-85-543-OO2 CONCERN:
Weider certification update procedure is inadequate. Welders can be off work over 90 days and not be required to je re-test upon returning to work.
- EX-85-021-OO2 CONCERN:
There is no method / objective evidence to verify that welder has used a a specific process when their weld cards are stamped / updated by QC.
- IN-85-540-OO1 CONCERN:
Inadequate welder certification update. Welder is " punished" if he/she forgets to update on time yet the update is a formality. There is no verification the process was used the 90 day period. during Employees are kept updated even though th'ey do not weld for years at a time.
- IN-85-426-OO2
~ CONCERN: Updating of wolder certifications is inadequato in that welder is only required t'o present thdir card for updating a and sometimes is asked to run a b'end - never a completo.
- IN-85-815-OO1 CONCERN:
Re-cortification of some welders consists only of completing paperwork. These employees do not have to provo welding ability. This is dono for some employees who have not ( welded for years. . s_ i D o.
o i ( f \\ Page 11 cf 17 5 ERT INVESTIGATION EPORT Page 3 of 6 CONCERN: See " DETAILS" page 1& 2 g 7______________________________________________________________
- IN-85-835-CO2 CONCERN:
Welders recertification can be accomplished by simply having, ones card stamped. No performance test is required or . conducted in the process.
- IN-85-352-OO1 CONCERN:
Welder updates certifiestion by going to DC Welding.and burning a rod or Just striking an arc. No weld using the process is done or verifiestion that the process had been used once during the 90/180 day period is required.
- IN-85-424-011 CONCERN:
Welder certification updating process is inadequate. and basing disciplinsry actions on failing to comply with the process is unfair (e.g. welders who fail to renew certificates are
- -(,
given two weeks off, but recertification consists only of getting card stamped no welding is involved). IN-85-770-OO3 CONCERN: Individuals possessing invalid welder certifications. Personnel Contacted: Confidential Reference Documents: Quality Annurance Manual 5.1 (A5ME) Welding Control Quality Control Instructions' 4.02 Walder/ Welding Operator Performance Qualification G29 Pro)cet Specification M'anua.1'i.'H.2.2 Wolder/ Welding Operator ~ Performance Qualification IN-85-113-OO3 WBN-85 0108 200 Jan. 8, 1985 Letter Hay 24, 1984 Welder Certification / Update WBN-84 0123 201 Jan. 23, 1984 ERT Investigation Reports WI-85-055-OO1 AND WI-85-056-OO1 Stop Work Authority #25 ~~ This investigation was conducted to determine the availability of documented evidence to support the welders qualification of program a welders quellfication. renewal 6
r- /' Attach:ent 7 k Piga 13 cf 17 e 1
- .e.
s ERT INVESTIGATION EpORT page 5 of 6 CONCERN: See " DETAILS" page 1& 2 6E-- E----------------------------------------------------------- 6) If no one in QC has seen or has knowledge of the welder using a process in a 3 month period, the welder goes to the weld test shop to " burn
- a. yod" on a plate to the
. process he is qualifying for with 'or without verification of
- position, current and material.
The welder has now 7.- welded to q process within a 3 month period and his certification
- is renewed with no more documentation,than a
signature on a certification card. Stop Work Authority #25 was issued to stop all weld activities on August 23. 1985. The following corrective action by management has been initiated and is in process. Reference ERT Investigation Reports WI-85-055-OO1/ WI-85-OS6-OO1 - on Stop Work Authority #25. 1)c-Re-certifing approximately 536 welders except for 30 welders which had been certified within 90 days previous to the stop work order being issued. ( 2) QCI 4.02 Welder and Welding Operator performance Instruction, has been revised to include controls and specific objective evidence for welders preformance, verification and revowal of certification. 3) TVA Form 10204A (OC-8-85), Welding Material Requisition, will be revised to include the statement: "I certify that on this date this welder use the.above welding process on ______________________(feature)."' The material requisition shall be kept for the life of ~ constru,ction and will be inputted into the computeri=ed welder-welding operator listing on a daily basis. 4) Quality, Training program, Hanual 3-3 and QAM 5.1 will be revised to reficct the program for-the control of welder's certification. With the initiation of these controls by management, this should eliminate future problems however past problems on welders qualification must still be evaluated. Hemorandums WBN-84-0123-201, WBN-85-0108-2OO and a memorandum which was dated May 24, 1984, all state: f 1) "If the welders certification expire because of failure to g,( have them updated the following actions will be taken" "First Offence - Two week auspension" "Second Offence Termination" \\ e B G b
a. '( .(' Attachm:nt 7 e t.' Page 14 cf 17 s ERT INVESTIGATION EPORT Page 6 of 6 CONCERN: See " DETAILS" page 1&2 7-------------------------------------------------. 2) "The welder would be held responsible" 3) "Each welder is responsible" g .4) " Alteration of penalty for welders" who fail to ypdate the certification 7.-
- However, the requirements per QAM S.1 Rev.
20 states that for welder welding operator qualification maintenance, the responalbility for this control is with the " Welding Engineering Unit / Welding Quality Control." OCI 4.02 Rev. 3 states that the Welding Engineering Unit is responsible to control verification and renewal of qualifications. ASME IX, CW 300.2 states that the manufacturer (TVA) is f' responsibility for welder qualification. AJ( ASME Section III, Subsections NB, NC, and ND states that the manufactuer or installer shall maintain records of qualification of welders. AWS D1.1 states that welder qualification requirements shall be controlled by the manufacturer & installer. From these requirements and the performance of this ' investigation the following items are noted. 1) Responsibility for control of welder quellfication (rennwal) was not, retained by management (per applicable requirements) but was directed to craft (welders).- 2) There was no syatem o'r co'ntrol to identify welders whose qualifications were up for renewal. 3) Homos surcomvented proc dure requirements and commitments for ~ control of weldera qualifications. Based on the findings in the investigation, this concern is substantiated. It is noted that TVA has initiated corrective action to resolve this concern, however the impact of pant welder qualification problems must be evaluated. ( O / . J4. S U/d&Cd$ q %. Prepared by -- M M.-- M - r~ J ed 4 4 Reviewed by _ M... [ k gea Aceosweeetslo}-2 n ~+ fesu u d. ( w h WY' w srn3 oss %.sA A-
P.1;;u 13 ut L7 /
- ..a' REQUEST FOR REPORTABILITY EVALUATION t
1. Request No. N-85-426-002 (ER: Concern No.) (ID No., if reported) 2. Identification'of Item Involved: Welding (Nomanclature, system, manuf., SN, Model, etc.) 3. Description of Problem (Attach related. documents, photos, sketches, etc.) ~ Updating of welder's certification was conducted without obiective documentation evidence 4. Reason for Reportability: (Use supplemental sheets if necessary) - A. This design or construction deficiency, were it to have remained uncorrected, could have affected adversely the safety of operations /., -u. of the nuclear power plant at any tima throughout the expected lifetice of the plant. No YES X If Yes, Explain: Without ob.iective documented evidence to support renewal of certification,weldinQ certification is indet'arminate.. AND B. This deficiency represents a sienificant breakdown in any portion of the quality assurance program conducted in accordance with the requiracants e,, of Appendix B. No Yes X If Yes, Explain: 10CFR50 Aooendix 50 Criteria IX . ANSI N45.2 ' ~ - OR C. This deficiency represents a sienificant deficiency in final design as approved and released for construction such that the design does not l confor:n to the criteria bases stated in the safety analysis report or construction permit. i I No 'X Yes If Yes, Explain: t OR ERT Forn H e g..
- I
~ (* Attachmnt 7 Pago 16 of 17 d 8 d Page 2 2-of REQUEST FOR REPORTABILITY EVALUATION D. This deficiency represents a sienificant deficiency in construction of or sienificant damage to a structure, system or component.which will require extensive evaluation, extensive redesign, or extensive repair'to meet the criteria and bases. stated in the safety analy, sis report or 'Eonstruction permit or to otherwise esi:ablish' the adequacy of the str6cture, systemit or component to perform its intended safety function. s.. No X Yes If Yes, Explain: 2 Th5.s deficiency represents a _sienificYnt deviation from performance __.., E. specifications which will require extensive evaluation, extensive redesign., ', or extensive repair to establish the adequacy of the structure, system. ...or cocponent to perform its intended safety function. I No X Yes .If.Yes, Explain;, b. IF ITEM 4A, AND 4B OR 4C OR 4D OR 4E ARE MARKED "YES", IMMEDIATEkh MAND-CARRY THIS REQUEST AND SUPPORTDIG DOCUMENTATION TO HSRS. This Condition was Identified by:, .3df-uug,c/ ./ 1 ERT Group Manager Phone Ext.' W $ ) ,e ~'
- ]n up,p, ERT Project Manager Phone Ext.
Acknowledgc:en of receipt by NSRS ~ ~ w Date.70 $W Tice /Wl Sis / // nea L ERT Forn H I h -,._,r----, ,--_.,,.r. ...,--,._--,.n
F ( {' / Page 17 ef 17 , oso-Ef?LOYII CONCI?ll ASSIC :: CIT REQUEST TO: Director - NS T7_utsur.u. IEf3E?. T-50065 E3T has received the E=playee concers identified belev, and has assigned the indicated estegory and prioriry: Priority: 1 Concern f IN-85-426-002 Category: 33 Confidenti,1:7: TES NO (I&E) Supervisor Notifiad: X TIS 'NO NUCLI11 SAsr a " C'ID Vee Concer.*.: Updating of Welder Certifications is inadequate in that a welder is only required to present their card for updating and sometimes is asked to run a bead-never a complete weld. No follow-up. ~p3 r Y b
- <# y -
e t ( i NMd 7/N/W e VAII PutAGI?., En N,SRS has assigned responsibili:7 for investi;;ation of the above cencers to: / l NSaS/En NSaS [ OTHERS (S?ECI?T) &f/WY -7blk'~ 7 / DATI up g
- .L 1
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