ML20210E802

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Discusses Welding Procedures & Practices Re Use of Unqualified Welders & Welding Procedures That Affect Safety. Response Requested.Supporting Documentation Encl
ML20210E802
Person / Time
Site: Diablo Canyon, 05000000
Issue date: 12/02/1983
From: Vines I
HOWARD P. FOLEY CO.
To: Ruff A
NRC
Shared Package
ML16341D666 List: ... further results
References
FOIA-84-744 NUDOCS 8603280177
Download: ML20210E802 (19)
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Characterization:

Alleged deficiencies in H. P. Foley welding program including: (1)~the use of unqualified welders; (2) the use of unqualified welding procedure specifications; (3) gross'erros contained in welding procedures including nonconformance with industry codes; and (4) design errors. The nonconformance reports which document the substance of the allegations were prepared by the r

. alleger while an employee of the H. P. Foley Company.

Implied Significance to Plant Design, Construction or Operation:

The H. P. Foley Company performed safety-related welding on: electrical components; heating, ventilation, and air conditioning systems; and -

instrumentation tubing. Improper velding could cause equipment failure and attendant loss of design functions during normal operation or during design basis events, including seismic events.

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Assessment of Safety Significance: .

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The alleger provided the staff with a listing of wpecific weld procedute l

specifications and quality control procedures and copies of nonconformance reports to support his contentions. The staff approach to resolution of this issue was to examine how the H. P. Foley Company addressed the concerns and i 12.3 4

nonconformance reports issued by the alleger, and to independently assess the quality of the Foley welding program using the specific examples provided by the alleger, supplemented with additional investigation of related areas of

'the welding program.

Th"e alleger's stated concern was that the adequacy of safety-related welding performed by the H. P. Foley Company was indeterminate in that:

(1) Unqualified welders are used.

Staff Note: The alleger's concern regarding welder qualifications was vague and unspecific but appeared, from nonconformance report 8802-924, item 2 as supplied by the alleger, to be directed towards lack of formal l

welder training rather than lack of strict compliance with the.

qualification requirements of the applicable codes.

, (2) .Welding procedures are not adequately qualified. See QCP-5A, welding.

i. procedure specifications (WPS) 31, 32, 35. 36, and 86 and see comment sheets;for QCP-5A (Rev. 9).

. (3) Welding procedures QCP-5A (Rev. 3, 4, 5 and 9), QCP-5B (Rev. 3 and 4),

QCP-SC (Rev. 0), and QCP-SD (Rev. 0) contain gross errors and are not in accordance with the applicable codes. See NCR-8802-924, for example,

( relative to QCP-5A, Rev. 9.

l (4) As indicated in NCR-8802-924, item 9, there are design errors.

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The staff investigated the above stated concerns by: (1) conducting a thorough review of procedures specified by the alleger and associated procedures; (2) reviewing past NRC and NRC contractor (EG6G). inspection findings involving Foley weld quality; (3) interviewing, in private, over twenty responsible license and contractor personnel; (4) reviewing over 700 nonconformance .

re" ports issued by H. T. Foley; (5) reviewing qualification records for six welders;'and (6) examining veld quality on over 100 components located in the Unit 1 containment, cable spreading room, turbine building, control room, and 480 volt switchgear rooms.

The staff investigtion of the alleger's concerns found that:

(1) The alleger's assertion that welders were unqualified was not confirmed.

A staff review of qualifications for six welders found them in compliance with applicable codes with the exception of the minor deficiencies discussed below. A previous NRC investigation of Foley welder

. qualifications and procedure QCP-5 for AWS structural welding found that the procedure provides a system for qualifying and maintaining the qualifications of welders which was confirmed by a review of qualification records for seventeen welders (IE Report No. 50-275/83-13).

Further, the staff concludes that the Foley resolution of the alleger's nonconformance report No. 8802-942,- Rev. 2 properly dispositioned the apparent concern regarding inadequate welder training. Two minor-deficiencies were identified b'y the staff during review of this issue:

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(a) The welder qualification list indicated that welder "US" was qualified to limitation 1 whereas the welder qualification records

indicated that he was qualified to the more restrictive limitation 2.

(b) The qualification record for welder "M27" for limitation 5 does not 11dicate completion of an acceptable fracture test as required by

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the ASME Code Section IX, Subsection QW-452.4.

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(2) No significant deficiencies in the qualifications of QCP-5A procedure Nos. WPS-31, 32, 35, and 36 were identified by the staff. WPS-86 has been deleted from QCP-5A and the staff was informed that-it was never used. The staff concluded that the alleger's concerns over procedure qualifications were properly addressed in nonconformance report No. 8802-924 and associated correspondence. The following minor deficiencies were identified by the staff in the reviews of welding procedure qualifications for procedures contained in~other QCP's:

(a) The'velding procedure qualification rec,ords for QCP-SC, WP-RS-4 do not indicate performance of th'e macroetch test required by the AWS D1.4-79 code.

(b) The welding procedure qualification record for QCP-5D, MOS does not -

list the .ctual preheat used as required by the ASME Code Section IX, Subsection QW-201.

(c) Procedure QCP-5C does not place any restriction on the carbon equivalent of reinforcing steel welded in accordance with a qualified welding procedure as required by the AWS D1.4-79 code.

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. (3) No gross errors were identified in the welding procedures. The procedural concerns described in NCR 8802-924 were dealt with in a letter from the Quality Director to the alleger dated September 29, 1983, in nonconformance report Nos. 8802-942R2, - 938R2, -951, -940R1, and -941,

, and in Engineering Disposition Request Nos. 1337 and 1432. The staff.

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considers all of the concerns described in NCR 8802-924 to have been satisfactorily addressed by the licensee. A minor deficiency was identified by the staff during the procedure review regarding instructions from PG&E to the H. P. Foley Compaar to weld thin she'et metal to the requirements of the AWS DI.1-75 Code which is not intended for this application.

(4) The staff identified no design error associated with the alleger's.

specific concern. .

Staff Position The review of the alleger's conceres failed to identify significant welding program or hardware deficiencies or any instance in which the alleger's concerns were not addressed properly. The welds observed by the staff in installed components and structures, were judged adequate for their applications. -

The evaluation of the licensee's cohpliance with regulatory requirements and applicable industry codes and standards conducted during the investigation identified some deficiencies. These deficiencies are not considered significant enough to suggest that the integrity of safety-related components

< is in question, however..they must be addressed and satisfactorily resolved by the licensee.

I Action Required:

Ev'aluation of apparent deficiencies by the NRC staff for possible enforcement action and examination of licensee actions to resolve the identified deficiencies. This will be monitored through the routine inspection program.

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i; PROBLEM STATEMENT Allegation No(s): 101 ATS No(s): RV-83A_0073 BN(s):

This document lists (or directly references) each allegation or concern brought-to the attention of NRC personnel. The purpose of this statement sheet is to assure that ALL points raised by the alleger are covered.

  • If the problem statement is not clear as to who, 'what, where, when,- of- why regarding the issue, the commentary section" will amplify the statement. The~ commentary section will also-be used if .there is apparent conflicting information or if there is NO or-very little original information available which describes the concern (s). ( This*can occur if, for example, a one line concern

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was received in an interview).

PROBLEM STATEMENTS (use extra sheets as necessary)

ALLEGATION #- VERBATIM STATEMENT OR REFEPENCE i 101 Reference Howard P. Foley Company Interor'fice Communication dated 12/2/83 from confidentia' alleger (quality control inspector, to Albert Ruff, HRC. Also see blue binder of backup material provided by the same alleger.

COMMENTARY The referenced communication itemizes t h e u s e ,- in procedure Mo.

QCP-5A, of terms such as "maybe", "should be", "if necessary",

etc., without comment as to why such use is objectionable. This aspect of the original aproblem statement has not been specifically addressed although procedure SA was- reviewed and found satisfactory.

Date This Statement was Completed 3/9/84 . 'i ist Technical Reviewer Signature PROBLEM STATEMENT 5

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welder ' training.

Two minoY deficiencies were identified by the staff during review of this issue:

(a) The ' welder qualification list indicated that selder "US" was qualified to limitation 1 whereas the welder qualification records indicated that he was qualified to the more restrictive limitation 2. -

(b) The qualification record for welder "M27" for limitation 5 does not indicate completion of an acceptable fracture test as required by the ASME Code Section IX, Subsection QW-452.4.

correspondence.. The following minor identified deficiencies were by qualifications for the staff in the reviews of procedures welding -procedure contained in other QCP's:

(a)

  • The welding procedure qualification records for QCP-5C, WP-RS-4 do not indicate performance of the macroetch test required by the AWS D1.4-79 code.

, (b) The welding procedure qualification record for QCP-SD, MOS does not list the actual preheat used as required by the ASME Code Section IX, Subsection QW-201.

(c) Procedure QCP-SC does not place any restriction on the carbon equivalent of reinforcing steel welded in accordance with 4 qualified welding procedure as required by the AWS D1.4-79 code.

addressed by -the licensee. An apparent minor deficiency wa's identified by the staff during the procedure review regarding instructions .from PG&E to the H.P. Foley Company to weld thin sheet metal to the requirements of the AWS D1.1-75 Code which is not intended for this application.

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    • C Fa'm 38 ALLE2ATlHN DATA F3RM u.s. NUCL A3 REGULATORY COMMISSION

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RECEIVING OFFICE

1. Facilitylles) Involved: IN I ttf more th n 3, or it k &g[ l f f 0 g p g, ~) {

poneric. write GENERIC) f

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2. Functional Areals) Involved:

(Check ppropriate boat ): operations _

onsite health and safety construction offsite health and safety

_ safeguards ._ _ emergency preparedness

_ other tspecityl 3.

Description:

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4. Source of A!!egation:

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5. Date A!!egation Received:
6. Name of individual triest two initi.i and int n mel - IA> -

Receiving Allegation:

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C 1 Open,.if foUowup actions are pending or in progress

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'2. Remarks:

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WGibs*G PMcGh uRE $Ft. sflu jyJ_e Initial Assessnient of Significance: er jufsp,. 7,,; r-1, rsa etre o,s e, re ;r RG1kn CR'LW ALk- rFr L Ar2 Ii :." 1/*%Cu/f.rAC Wea'NG C.saLb Rc tJL u t- n c 'sta.7/

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ATS No. RV-84-A-007 BN No.

Characterization:

Changes from Interim "As Built" Drawings to Final Drawing - Inadequate Control has been exercised over the transition from Interim Drawings to Final Drawings of the station as actually constructed. ~

[n w.Assessment of Safety Significance A face value assessment on the part of the staff indicates this issue is not of major significance in terms of public health and safety or management breakdown. Also, this issue appears to be a restatement of concerns identified and examined in allegation 61. The issue is a known issue and 2s being responsibly handled.

Staff Position The issues of concern here do not appear to represent any new significant management or quality performance issues which have not been previously addressed.

Action Required y g pb4ff This issue will be turned over to PG&E for =~1"* '--

The licensee will be ,

required to provide a written response to their findings and corrective actions.

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I' ' - additional quality control personnel. These personnel were -

certified to a certain level by Cataract based on experience and verified by an investigative service. However, the resumes

, of the individuals, in some cases, did not support the i certifications in some areas. This problem was identified by --

licensee Quality Assurance Audit No. 83043A, performed in February 1983, and further documented on Nonconformance Report No. 8802-824, dated March 17, 1983. Currently the' licensee, ,

the H. P. Foley Company, and Cataract Engineering Company are

resolving the problem by verifying past employment of the personnel in question. In the interim, personnel with a
  • potential resume problem are not being used in the field as
quality control inspectors. This nonconformance report (NCR l

. No.'8802-024) also notes that between December 7,1982 and .

March 10, 1983, Level I inspection did not require a Level II co-signature, and further notes that, "This nonconformance encompasses both H. P. Foley direct inspection personnel and sub-contracted, Cataract Engineering Company personnel." The 4

resolution of these licensee audit findings will be examined l during a future inspection. (50-275/83-13-01)

No items of noncompliance or deviations were identified.

i e. Concern: The concern was expressed or implied that as a result

< of increased construction activity starting in September 1982 l and the accelerated hiring of craft personnel, welders hired j- during this period might not be properly certified.

NRC Findinas: The specific concern that welders hired since t

September 1982 might not be properly certified was not l substantiated, however an apparent item of noncompliance with welder certification was identified during this examination and

. is detailed below.

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To address this concern the inspectors examined H. P. Foley's

.. Quality Control Procedure for Welder and Brazer Qualifications and the Qualifications,of Welding and Brazing Procedures (QCP-5, Revision 8, dated 1/28/82) and determined that the

. procedure provides a system for qualifying welders and maintaining a continuous record of qualification status of all welders. The procedure references and appears to comply with the latest edition of the AWS D1.1, Structural Welding Code, for documenting test results and describes the steps necessary to qualify a procedure and a welder in accordance with Code requirements. ,

! An' examination of the qualification records for seventeen l welders (ironworkers, pipefitters, and electrical welders) established that all of the welders certified since September 1982 had been properly certified and monitored in accordance with requirements of QCP-5. However, the inspector noted that one electrical welder (symbol "JX"), initially certified on l

February 27, 1980 to an AWS D1.1 Shield Metal Arc Welding (SMAW) Process, had last been monitored by Quality Control on Ck 1 .

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-9 s July 27, 1982. H. P. Foley procedural requirements specify -

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that Quality C'ontrol must perform process monitoring for AWS D1.1 welding every six months for each welder to assure that welder qualifications do not lapse. This welder was found to be included in the H. P. Foley Active Welder's List and was performing work as a qualified welder as of March 31, 1983. '

H. P. Foley procedure QCP-6 states in paragraph 6.4 that, "A

  • list of qualified welders and brazers shall be maintained by the Quality Control Department. The list shall be revised t whenever there is a change in status." In paragraph 5.1, the ' '

procedure states that, " Welder qualification shall be effective providing the welder has used the process qualified for within the .following time periods: 6 months for welders qualified under Appendix "B", "C", "E", and "G"; or 3 months for welders qualified under Appendix "I"." Appendix C of the procedure describes the steps necessary to qualify a welder to the AWS DI.1, Structural Welding Code, latest revision, for groove welds of unlimited thickness. Successful completion of this qualification test also qualifies the welder for welding fillet welds on material of unlimited thickness. i QCP-5 further states in paragraph 5.1.1 that, "The Quality Control Department shall monitor each welder for each process qualified within the time period above to ensure that the jg welder's qualifications do not lapse." This welder's (symbol "JX") qualifications had effectively lapsed on January 27,

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1983. The failure to assure that welder qualification is maintained in accordance with procedural and code requirements is considered an apparent item of noncompliance with 10 CFR 50, Appendix B, Criterion V, " Instructions, Procedures, and Drawings." (50-275/83-13-02) (50-323/83-10-02) f.

Concern: The concern was expressed that the final typed ,i -

' version of Nonconformance Report (NCR) No. 8802-819, dated March 4,1983, varied substantially from the original rough draft of the NCR. This NCR documents a situation where, on j Ma'rch 2, 1983, H. P. Foley Quality Control Inspectors, assigned .

'to attend weld rod ovens in'the Fuel Handling Building, left j

the site before assuring that all weld rod was returned. On l this d.sy (March 2, 1983), the site was evacuated due to inclement weather and det'eriorating road conditions.

l NRC Findings: This concern was not substantiated.

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To address this concern,'the inspectors examined the final typed copy and earlier revisions of Nonconformance Report No.

i 8802-819. This examination did not identify any substantial

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change in the sentence structure or wording which could  !

reasonably be interpreted as changing the intent, meaning or i

description of the nonconforming condition or of the recommended disposition. During this examination of the i

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nonconformance report and related data, the inspector noted that Inspection Report (IR) No. 8802-1344, written by a H. P.

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personnel, the NRC did perform a nationwide survey on this subject in June 1981'. The survey results were inconclusive. '

The ratio of inspector to craft varied anywhere from 1:1.7 l (WNP-2) to 1:26 (Palo Verde). In addition to the ~ contractor QA/QC organizations, the licensee maintains their own QA/QC .

  • organization which provides for surveillance and audit of
contractor activities. Furthermore, the licensee maintains a  !

l- staff of personnel, assigned to each .of the Resident .

Electrical, Hechanical, Civil and Startup Engineers, who also provide for inspection and overview of the work performed by i

site contractors. These personnel further increase the ,

inspector /cr~ aft ratio.

The inspector considers that a substantial conclusion i

regarding the -adequacy of the inspector-to-craft ratio at Diablo Canyon during'this period cannot be establish-d with certainty.

No items,of noncompliance or deviations were identified.

6. Additional NRC Inspections l

During the course of interviewing individuals referenced in the testimony of the former Quality Control Manager and the Assistant Quality Control Manager, the NRC inspectors became concerned that methods used by the H. P. Foley Company for recertifying welder or

, welding operators might not meet the' intent of the ASME Code. This

. report identifies a similar problem wherein a welder was not recertified within the time limits specified by the AWS Code, as well as, contractor procedural requirements. This item is the subject of NRC enforcement action and is addressed in paragraph Se of this. report. This new NRC concern deals with the methods employed by H. P. Foley to recertify welders or welding operators.

The 1980 Edition of ASME Boiler and Pressure Vessel Code,Section IX, " Welding and. Brazing", Subarticle QW-322, " Renewal of Qualifications", states thap, " Renewal of qualification of a performance qualification is required: (a) when a welder or welding operator has not used the specific process, i.e. , metal-are, gas, submerged arc, etc., for a period of three months or more; except when employed on some other welding process, the period may be extended to six months; or (b) when there is a specific reason to question his' ability to make welds that meet the specification.

Renewal of qualification for *a specific welding process under (a) above may be made in only a single test joint (plate or pipe) on any thickness, position, o' r material to re-establish the welder's or welding operator's qualification for any thickness, position, or '

material'for which he was prevously qualified."

A review of forty H. P. Foley welder certifications determined that all welders were certified or recertified in accordance with H. P.

Foley's Quality Control Procedure, QCP-5 " Welder and Brazer Qualifications and.the Qualification of Welding and Brazing Procedures." However, the inspector noted that one welder, (symbol

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k S-4, recertified on February 19, 1983, to'an ASME Welding Procedure

  • Specification'(WPS) No. M-03, a Gas Tungsten Arc Welding (GTAW) process), apparently was recertified by having the welder strike an ,

are with the nonconsumable tungsten electrode long enough for the l H. P. Foley Quality Control Inspector to take amperage and voltage I readings and record these readings on an In-Process Welding I Inspection Report. The report also indicates that no weld rod was

  • issued during this time. The signature of the Quality Control Inspector on the In-Process Welding Inspection Report apparently  !

accepts the recertification of the welder to the particular welding process. This particular welder was found to be on the H. P. Foley' Active Welders List, dated April 27, 1983. The NRC inspectors are  ;

aware that this particular individual did not perform welding af ter j this certification. A review of employer payroll and weld rod withdrawal records indicated that this welder had been promoted to Foreman on January 18, 1983 and had not performed welding since that date. However, it is of concern that he had been placed on the-Active Velder'.s List and was considered ready and able to perform welding based on the re-certification of February 19, 1983. j For those welders that were re-certified and had not used a welding process for 3 months or more, the inspectors observed that the In-Process Welding Inspection Report fails to indicate whether the welders were recertified b! making a test joint (on a plate or pipe) i' or by in process welding in accordance with the Code. Thus, the inspector is concerned that the discrepant welder requalification process described above, may have been used to recertify welders currently appearing on the Active Welders List.

.e' _

It appears that measures were not established to assure that recertification of welders was accomplished in accordance with the l Code and the requirements of 10 CFR 50, Appendix B, Criteria IX, l " Control of Special Processes". This is an apparent item of noncompliance (50-275/83-13-04 and 50-323/F3-10-04) . -

7. Unresolved Items Unresolved it ems are matters about which more information is required in order to ascertain whether they are acceptable items, or items of noncompliance, or deviations. An unresolved item was identifled during this inspec, tion and is discussed in paragraph Sg
of this report.

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