ML20210F946
| ML20210F946 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/25/1986 |
| From: | Bateman R, Lewis J, Rose J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| XX-85-101-006-R02, XX-85-101-6-R2, NUDOCS 8702110194 | |
| Download: ML20210F946 (67) | |
Text
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11 REPORI NUMBER: 11-85-101-006 IVA EMPLOYEE CONCERNS SPECIAL PROGRAM o
REVISION NUMBERt 2
REPORI IIPE: Welding Project IIILE: Welder Cert 1[lcation iiis0N FOR REV5510N:
~
Editorial changes to Attachment 5
SUMMARY
SIATEllENI N/A PREPARATION PREPARED DY:
11-U_6-86 Orlainsi Signed _Dy R. M. Bateman DATE SIGNAIURE REVIEWS 1
PEER:
11-06-86 Orlainel Slgn,ed.,DY J. E. ((ose DAIE SIGNAIURE TAS:
DATE SIGNEIURE CONCURRENCES Original Signed By CEG-ll!
J. F. Lewis for LEM_ 11-25-86_
SRP:
SIGNAIURE*
DAIK SIUllATURE DATE 5PPROVED 1)Y:
DhIE MANAGER OF NUCLEAR POWER DAIE ECSP ffANAGER CONCURRENCE (FINAL REPORI ONLY)
- SRP Secretary's signaturo denotes SRP concurrences are in flies.
e 2247 8702110194 870205 PDR ADOCK 05000327 PDR p
i
EMPLOYEE CONCERN
SUMMARY
SHEET Report Number: XX-85-101-006 Report
Title:
Welders Certification I.
CONCERN CO.'JSIDERED: XX-85-101-006 II.
ISSUES INVOLVED Welder certification III.
SI AIENENT ON CONCERN / ISSUE VALIDITY Validity:
Y X M,N
, Substantiated:
Y X M,N This issue concerning welder continuity is valid, all other issues are not valid.
IV.
EFFECT LN llARDWARE AND/OR PROGRAM
~
None V.
JUSIIFICATION TVA's commentment for welder continuity is based on the requirements of.
the ANSI 31.1-0 Code. TVA's procedures reflected the requirements of the ASME Code,Section IX after August 6, 1974. The reconmended corrective action will resolve this problem.
VI.
RECOft1ENDATION AND/OR CORRECTIVE ACTION NEEDED Revise the FSAR to adopt ANSI B31.1 Code through June 1971 addenda to allow the use of later editions of ANSI B31.1 which refer welder continuity to the ASME Code,Section IX.
VII. REINSPECTION NEEDED:
Y
,N X
Page a 3158T i
Report Number:
XX-85-101-006 s
VIII. ISSUE CLOSURE Closure is based on FSAR revision IX.
AllACllMENIS A.
APPROVAL SilEET 1.
ERT report XX-85-101-006 2.
Text of employee concern 3.
Summary of SQN specific concerns reviewed by WP 4.
Program summarization of weld project (WP) evaluation 5.
Rebuttal of ERT report 6.
March 26, 1986 letter to M. R. Martin 7.
March 31, 1986 memorandum to'N. W. Whitt from R. G. Domer 8.
WP-Bechtel audit of SQN Key Elements 4.0, 5.0 and 17.0 Page am 3158f J
Attachment A I
WELDING PROJECT
_ SON SPECIFIC EMPLOYEE CONCdRNS_
DATE 11/6/86 __
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUBJECT:
SUMMARY
OF WP ENGINEERING EVALUATION CONCERN CONSIDEREDt. XK-85-101-006
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. DNC, WP PREPARED BY
_, DNC, WP
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. DQA, WP.
h REVIEVED BY d
C REVIEWED BY_ 'ltinuA/ $ $1rx) 11/2 c /WL FbA' 1/f n1_, CEG-N,, Welding d
, Program Manager APPROVED BY 4
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WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS e
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AIIACHENT 1 ERI REPORI XI-85-101-006 9
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.a' UNITED' STATES COVEntGtENT MemorandMm TENNESSEE VALLEY AUTHORITY -
1 To: 11. L. Abercrombie, Site Director, Sequoyah Nuclear Plant K. W. Whitt, Director of Nuclear Safety Review Staff', E3A8 C-K
,1 FROM:
MAR 0 71986 DATs:
!UBJECT: !!UCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSHITTAh-Transmitted herein is NSRS Report No.
XX-85-101-006 Subject WELDER CERTIFICATION Concern !!o.
XX-85-101-006 This report contains two Priority 1 [P1] recommendations which must be addressed.
The Pelority 3 [P3) recommendation will be looked at for
.0?%>
corrective action follow through by July 3.1986.
No response is required
.c-for this item. Should you have any questions, please contact W. D.
Stevens at telephone 6231.
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a Recommend Reportability Determination:'.Yes No X
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Irector, NSRS/Desigtieii~
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Attachment
.s cc (Attachment):
j W. C. Dibb, DFil l
W. T. Cottle, WDti, James P. Darling, DLU
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R. P. Denise, LP6N40A-C
- 0. O. Kirk, :::;:I D. R. Nichols, E10A14 C-K
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QTC/ERT, Watts Une Nuclear Plant i
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Eric S11ger, LP6N40A-C J.11. Sullivan, SQN 4581U I
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e NSRS Recommendation: XX-85-101-006 q-85-101-006-01:
" Welder certification
~-
Complete the following sequence of recommended actions in conjuncElon with and consistent with recommendations I-85-135-SQN-01 and I-85-135-SQN-02 in report I-86-135-SQN.
Completion of A and B below is considered Priority 1 (P-1).
Item C is dependent on the outcome of A and B.
Item D is Priority 3 (P-3).
A.
Identify the particular ASHE Section IK code year and addenda to qualify welders.
If different years were used, then identify when each was in effect.
~
B.
After completion of Q-85-101-006-01 review welder qualification records against the code in effect and determine which welders, if any, had periods of time when welder update (continuity) requirements were not being met.
.a': :~
f' C.
For any welders identified as unqualified in q-85-101-006-02, determine which welds were made during periods of disqualification.
For those welds identified, do a technical evaluation for acceptability..
D.
Update site construction specifications to be consistent wth SQN FSAR Section 3.2 commitments. This area covers design, fleid fabrication, 1-assembly, examination and testing of piping.. Evaluate piping' previously completed under the construction specifications for acceptability.
principnity prepared by P. R. Washer.
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QUALITY TECHNOLOGY
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COMPANY QQ P.O. BOX 600 Sweetwater. TN 37874 (615)365-4414 I
RAGE 1 OF 17, ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-101-006 CONCERN:
Seauoyah:
A welder perfortnad welds without having the ptoper certification.
INVESTIGATION PERFORMED BY:
G.
Pohlraann DETAILS PERSONNEL CONTACTED:
CONFIDENTIAL
- s...
(UMM DOCUMENTG REVIEWED:
A.
Sequoyan Nuclear Plant Drawings Flow t
1.
Dwg.
47W809-1, R/23
" Powerhouse Units 1 &
2 g
Diagrarn Chernical and Volurne Control Systern".
2.
Dwg.
47W830-1, R/16
" Auxiliary Building Reactor Building Unit i & 2 - Mechanical Flow Diagrarn Waste Disposal Syst ern".
3.
Dwg.
'47W560-6, R/40
" Reactor Building Units 1 &2 Mechaical Waste Disposal Sy s t ern".,
4.
Dwg.
1-RC-515-1W, R/0
" Reactor Building Unit 1 - Loop 1 Crossover Leg 2" Drain".
s.
5.
,Dwg.
1-RC-516-1W, R/0
" Reactor Bu'ilding Unit 1 - Loop 2 Crossover Leg 2" Drain".
" Reactor Building unit 1 - Loop 6.
Dwg.
1-RC-517-1W, R/0 3 Crossover Leg 2" Drain",.
. Reactor Building Unit 1 - Loop 7.
Dwg.
1-RC-518-1W, R/0 4 Crossover Leg 2" Drain".
8.
Dwg.
2-RC-515-1W, R/A
" Reactor Building Unit 2
A '.i x i l i n t y Reactor Coolant Loop '1 Crossover Leg 2"
.,;. 4 Drain".
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C PAGE 2 CF 17 s'
ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-101-006 DETAILS DOCUr.ENTS REVIEWED: (Continued)
A.
Seouoyah Nuclear Plant Drawings (Continued) 9.
Dw o.
2-RC-516-1W, R/A
" Reactor Building Unit 2
Auxiliary Reactor Coolant Loop 2
Crossover Leg 2"
Drain".
10.
Dwg.
2-RC-517-1W, R/A
" Reactor Building Unit 2
Auxiliary Reactor Coolant Loop 3
Crossover Leg 2"
Drain".
11 Dwg.
2-RC-518-1W, R/A
" Reactor Building Unit 2
Auxiliary Reactor Coolant Loop 4
Crossover Lug 2".
Drain".
Wald R/G "RS ctor Building Unit 1
12.
Dwg.
WD-28, History identification Waste Disposal".
13.
Dwg.
WD-29, R/4
" Reactor Building Unit 1
Weld h.c2p.N.
History identification Waste Disposal".
Weld c'
14.
Dwg.
WD-30, R/2
" Reactor Building Unit 1
t History identification Waste Disposal".
g B.
Watts Bar Nuclear Plant Drawings 1.
Dwg.
47W560-6, R/25
" Powerhouse Reactor Building Unit
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1 - Mechanical Waste Disposal System".
f' 47W560-18, R/19
" Powerhouse Reactor Building Unit 2.
Dwg.- Mechanical Waste Disposal System".
1 3.
Dwg.
47W560-28, R/3
" Powerhouse Reactor Building Unit
[
1 - Mechanical Waste Disposal Eystem','.
4.
~6 w' g.
47W560-29, R/2
" Powerhouse Reactor Building Unit 1 - Mechanical Waste Dispommi System". g C.
Procedures 1.
SNP Construction Procedure No.
- PSB, Rev 11, Dated 2-14-77 "Prepreation, Review, Handling, and Temporary Otorage of Quality Assurance Records" with Addendum 1,
dated 2-22-77.
2.
SNP Construction Procedure No.
P-8, Rev 12, Dated G-13-77
" Duality Assurance Records" with Addendum, i
.I Dated 0.-15-77.
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s PAGE 3 GF 17 ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-101-OO6 DETAILS DOCU.v.ENTS REVIEWED: (Continued)
C.
Procedures (Continued) 3.
SNP Construction Procedure No.
P-8, Rev 13 Dated 11-18-77,
" Quality Assurance Recorce" with Accendum 1,
Dated 1-30-78; Addendum 2, dated 10-11-78; and Addendum 3,
dated 10-3-78.
4.
SNP Construction Procedure No.
P-8, Rev 14, Dated 3-26-79 " Quality Assurance Records".
SNP Construction Procedure No.
W-2, Rev O, Dated 2-2-77 5.
" Welder and Welcing. Operator Performance Qualification".
G.
Construction Procedurm# No.
CONST QAP 17.01, Rev 2,
Dated 11-9-77 " Quality Assurance Records".
Duality Assurance Procedure No.
DEC-GAP 7.
Construction Dated 5-13-76 " Qualification of Welders and 2.09, Rev O,
,f.r.P 3l'.4@.
Welding Operators".
D.
SNP Design Criteria No. SQN-DC-V-3.0, Rev.
O, Dated 12-12-75 " General Design Criteria for the Classification g
of Piping, Pumps, Valves, and Vessels".
SNP Construction Specification No. NEM-865, Rev 3, Dated 4-12-77
" Field Fabrication, Assemoly Examination and 9.
Tests for Pipe and Duct Systems",
D.
SNP FJnal Safety Analysis Report Se~ction 3.2~.
E.
Standards / Codes t
l 1967.
1.
ANSI B31.1 S.
(Including 1970 Addenda).
2.
,AN,S I B31.7 - 1969f 1973.
3.
ASME Section IX, 1971 Edition m'nd Addergda through f
1974 Edi, tion and Addenda through 1976.
4.
1977 Edition and Addenda through 1979.
5.
ASME Section IX, 6.
F.
General Specification G-29M
" Process Specificction for
- Welding, Heat Treatment, Non-Destructive Examination, and
(
Allied Field Fabrication Operations".
Process Specification 1.M.1.2(a), Dated 2-24-75 " General 1
I 1.
WeldinD Procedur.e Specification"..
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'E[1T INVESTIGATION REPORT PAGE 4 OF 17 CDNCERN NU.'lDER XX-85-10*-006
~~
DETAILS DOCUMENTS REVIEWED: (Continuee)
F.
General Specification G-29c1
" Process Specification for
- Welding, Heat Trea t raent, Non-Destructive Exarni na t ion, and Allied Field Fabrication Operations". (Cont, i nued )
2.
Process Specification 1.M.2.2(a), Dated 2-5-75 "Weldet-and Welding Operator Perfortnance Qualification" with Adcend urn 1,
Dated 6-2-76 and Addendurn 2 Dat ee 6-29-78.
3.
Per f ortnance Qualification Test GT-7-0-1-L(a),
Rev O,
Dateo 8-29-75.
4.
Perfortnance Quali ficat ion Test GT-7-0-3-L, Rev 1,
Dated 2-5-75.
5.
Perforrnance Qualification Test GTSM-7-5-0-3-H(a), Rev O, Dated 8-29-75.
G.
Perfortnance Qualification Test GTSM-7-5-0-3-H, Rev 2, j,,. y pMy Dated 2-5-75.
7.
Welding procedure Qualification Record No. GT18-0-1, g
t Dated 12-10-70.
8.
Welding Procedure Qualification Record No. GT18-0-1, Dated 5-28-74.
9.
Welding Procedure Qualification Record No. GT88-0-1, Dated 5-14-70.
10.
Welding procedure Qualification Record No. GT88-0-1, Dated 5-28-74.
11.
Welding Procedure Qualification Record No. GT88-0-1, Dated 3-6-78.
1, 12.
thil d ing Procedure' Qualification Recotd No. GTSM18-0-1, Dated G-2-70.
- S l
13.
Welding Procedure Qualification Record No. GTSM88-0-1, Dated 9-18-70.
14.
Detail Weld Procedure No. GT18-0-1,'firv 5 Dated 5-1-78.
15.
Detail Weld Procedure No.
GT10-0-1A, Rev 1,
Dated
. r..
7.2..
2-28-75.
16.
Detail Weld Procedure No.
GT88-0-1, Rev G,
Dated 2-23-79.
..Rev 4,..Datud...
17.
Detai1' Weld
.'. l '.1.* l?,%.. %'., is 2-28-75.: '
Procedure No..GTSM18-0-1,W)7M 6l:
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PAGE 5 OF 17 dRT INVESTIGATION REPORT
~ *-
. CONCERN NUMBER XX-85-101-OO6 j
DETAILS DOCUMENTS REVIEWED: (Continued) l F.
General Specification G-29M
" Process Specification for
- Welding, Heat Treatment, Non-Destructive Examination, and Allied Field Fabrication Operations". (Continued) 18.
Detail Weld Procedure No. GTEM88-0-1 Rev 4 Dated 2-28-75 1
SUMMARY
OF INVESTIGATION:
This concern is substantiated.
Walder qualification records were reviewed for the identified welder and were found not to comply with TVA/Sequoyah Nuclear Facility (SON) site procedures.
During the course of the investigation it was noted that the welder qualification program contained contradictory information and incomplete instructions, rendering the welder qualification proge,dm indeterminate.
This investigation started on 11-29-85 and concluded on 2-14-06.
hkh), FINDINGS:
3 The investigation included a review of the qualification records for ss individual 1.
See Attachment i for a list of records found in this individual's qualification file.
~
1.
Listed below are areas in the qualifiention records that were found to be questionable.
i i
A.
We1. ding Performance Qualification Records (WPQR) dated 5-11-77, 11-11-77,*11-29-77, and 9-29-781. Revocation of Welder Qualification memos dated 12-6-77, 8-8-78, and 8-G-79; and the Walder Qualificati'on Lists (Sheets 1 & 2 of 2) for individual 1
were not processed in accordance with SNP Construction Procedure No.
W-2, Rev O, Section 7 which states,1, " Attachments A, D,
G, and E shall be reviewed and stored in accordance with UNP CP P-8."
i NOTE:
Attachments A,
D, G,
and E I of Construction j
Procedure W-2 are the Welding Performance Qualification
- Record, Welder Qualification
- List, Revocation of Welder Qualification.
Memorandum, and Retention of Welder Performance Qualification 5
Memorandum respectively.
1.
CP P-8 Rev.
11, paragraph 6.D.1.a states in part,
(.p' A'.;
"...QA records resulting from construction procedures or inspection instructions shall be s_,
submitteo immediately after completion to the GCRU
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PAGE 6 CF 17 ERT $NVESTICATION REPORT l
CONCERN NUMBER XX-85-101-006 DETAILS
- FINDINGS (Continued)
I.
A.
1.
Continued for detailed review and spotoval.
Evidence of detailed :eview and approval shall be noted by the reviewer's initials on the record."
Contrary to initials of the QCRU this recuirement, there are no reviewei snown on the WPQR dated 5-11-77.
(Note p-8 ilev.
11 was in effect at the time of issuance of the noted WpOR.)
2.
CP p-8 Rev.
.12, paragraph
- 6. A. 2. F states "All-t'ecords forwarded to the CCRU for review and/or storape shall be:' stamoed with the "QA Record" stamp."
and paragraph
- 6. B.1 states in
- part,
"... detailed review and approval sna11 be noted by the reviewer's initials on the record. " Contrary -
these requirements, there are no "QA Record" to stamos or GCRU reviewers initials shown on the WPQR
@f. y,
fhZ1 dated 11-11-77.
(Note P-8 Rev.
12 was'in effect at the time,of
' issuaisce of the noted WpQR. )
Cp p-8 Rev.
13, paragraph 6.C.2 states in
- part, 3.
"Evicence of a detailed review and acceptance shall be noted by a "QA' Record Review" stamp and.the reviewet 's initials and date on the record."
Contrary to t'his 'requir'ement, tiiirre are no "QA Record Review" stamps ot' r.eviewer's init ials and -
date shown on the following records:
WPOR dated 11-29-77 a.
b.
WPQR dated 9-29-78 1
dated Revocation of Walder Qualification memo c.
12-6-77 dated Revocation of Walder dualification memo d.
8-8-78 Qualification List page 1 of 2
dated u.
Welder 5-77 through 5-78 (Note:
p-8 Rev.
13 was in effket at the time
.o f issuance for the noted records.)
D.
- WPQR, dated 11-11-77, contains the statement listed
[
below.
" Equivalent qualification being awarded based upon side bends of POT GT-SM-7-5-0-3-H passed satisfactory has maintained certific..ation of the GTd;rW.
..g.pp...:..s.2, -..;..,..w;.g ;.nyh,
.5-11-77. Weldet'
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pAGE 7 CF 17 ERT INVESTIGATICN REPORT CONCERN NUMBER XX-85-101-OO6 DETAILS FINDINGS: (Continuec)
I.
B.
Continued sortion of this test through 11-11-77.
PGT GT-SM-7-5-0-3-H revoked by letter dated 12-6-77 due to lack of SM welcing."
1.
ERT questioned TVA welding inspectors / engineers l
(indivicual 2,
3, and 4) as to how or why a
- record, tnat was signed on 11-11-77, could reference another document that was issued almost j
a month later (12-6-77).
Individual 2's immeciate "You guys don' t know (expletive 4
response was deleted), do ya' 7"., Individual 2 clarified this alleged lack of undhrstanding by explaining how the situation described above could happen, which by individual 2's own admission, was not an uncommon l
Individual 3 and 4 concurred with. individual event.
2's explanation of program functions.
The s'E_:qq explanation is as follows:
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a.
A welder would bring an
" Authorization for l
t Welders Test" memorandum (Reference Attachment D of SNp Construction procedure W-2 Rev 0) to I
the Welding Test Supervisor.
This memo would orovide some detailm* identifying the welder i
and identify which tests had been authorized by the Craft Superintendent.
The Test Supervisor would then assign a test
- number, complete *the requirsd information in the log book and administer the test.
Once the test was completed, the Test Supervisor would be resoonsible.for interpreting the mechanical results or accepting the NDE inspectors report of the radiographic (gamination.
If the test results.were found to be acceptable, the Test the Supervisor would then complete and sign t
" Authorization for Wdidern Test" memorandum
{
and return it to.the welder.
his document was considered to be advance notice to the l
Construction B'uperintendent of the welder's l
qualification and capabilities.
The Test Suoervisor would then "pe6cil-in" the required information on the Wp0R (including the date in the lower left hand corner of the form) and f*...
hand carry the WAGR to the Welding Engineering Supervisor's (WES) secretary for typing.
The WE9 would then review both documents (penciled-in and typed WpOR),
sign the typed Wp0R and discard the
" penciled-in"
. copy, t
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PAJE O OF 17 ERT ItWESTIGATIO.'J 3EPO3 r
(
CONCERN NUMBER XX-85-101-006 DETAILS v
FINDINGS: (Continued)
I.
B.
2, The conversations witn individuais 2, 3 & 4 t aiseo cuestions as to the validity of the suoject WPGR and the overall program.
s.
The entire process ( f t,*om comalet ion of the welder testing until final sign-off of the WPGR) would allegedly take no mote than one (1) week.
From the information found in the subject WpQR.
it can only be concluded that this one (1) week process took place one (1) montn after the w e l o u t*' s original oualification had expired or the information was added to.'the record after it was signed.
b.
Individuals 2 and 3 stated that the Welding Test Supet visor would issue a test number when the welder came in for cualification testino.
The test numbet* (taken in secuential gnddt-em (NEOr from a log book) identified the
- welder, the,
test to be taken, the test booth number ano -
s_-
other facts relative to the testing.
g e
The test numbers shown on WPQR's dated 5-11-77 (Test No. p)79), 11-11-77 (Test No. 6665L, and 11-29-77 (Test No.
59801_ for-inoivioual 1 do not agree with these statements.
This
~
information subst&ntiates the conclusions in item a above.
Individuals 2 & 3 have ' stated that all records c.
(i.e.:
the, log books from the test
- shop, Authori:ation for Welder Test
- memos, actual test
- results,
" pen 411ed-in" WPQRs) with the exception of the final 'WPOR, have been destroyed. These records, according to the TVA
~'
- procedures, are not c'dnsidered DA records. The of the.WPOR's or od the st aternents accuracy rnade by individuals 2, 3 and 4, could not be j
substantiated b'ased on the fact that there is no available objective evidence.
d.
Individual 2
stated that the date on the bottom of any WPGR " clearly" was the effective date of the welder's qualification and not the
(,
date that the authorized welding engineer signed the record.-
(Note:
The effective date as deset*1 bed by individual 2
is the date that the Test Supet*yisor aparoved the welder and. released him to, weld in the field.)..> y.
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ERT INVESTIGATION REPORT PAGE o CF 17 CONCERN N'JMBER XX-55-101-OCG i
DETAILG FINDINGS: (Continued)
I.
B.
2.
d.
Continued Construction procedure W-2, Rev 0 tequired the WpOR to be reviewoo and stored as a GA recore.
Division of Construction Procedure CONST DAp 17.01 Rev 2, paragraph G. 2. 4, states in part,
" Records
- shall, as a " minimum, contain the following information to be classified as an acceotable record of work and/or inspection performances D.
- Stamped, initialed, signed or otherwise authenticateo and dated by the responsib1'e inspector or data recorder uoon completion and...."
Contrary to the requirement.in CONST GAP 17.01.
WpOR dated 11-11-77 was not dated by is?d) the welding engineer who signed it. Therefore, the record was never properly completed.
/
u.
In an attempt to corrolate the welding sngineer's desetiption of the program with existing procedures, it was determined that procedure W-2 governs
" Welder and Welding Operator Performance Qualification" at the Seouoyah facility. (See SNP CP No.
W-2, Rev 0 Section 1,
Purcose-which
- states, "This i
procedure described the methods to be employed for testing and oualifying welders and welding operators at Seouoyah Nuclear Plant").
The engineers gave a more datalled description of the program functions than did t ocedure W-2.
de,termined that procedure
- However, it was DEC-QAp.
2.09 also applied to the
" Qualification of Welders and Welding Operators" at the **Gequoyah facility (see DEC-GCP 2.09,
- Rev O,
Cdver Page which states," Applies to:
All Nuclear. Plants Except Drownu Ferry" 'and Section 1.0 Purnese which
- states, "This-procedure assigns the responsibility and defines the sequence of actions to be accomplished in the qualification, certification and recertification of welders and welding operators.")
- s.,
~
, 9 -i e
- . #
- l
- T. *
- t.: ~ '.:. :'
': ':. - " W,
- ..: mi m::.',
4 h
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PAGE 10 DF 17 ERT INVESTIGATICN REPORT CONCERN NUMBER XX-85-101-006 DETAILS FINDINGS: (Continued)
Continued I.
B.
2.
e.
Pr'ocedure DEC-GAP 2.09 provides different requirements and responsibilities not only for set up the organizations responsible for test and
- approval, but also fot*
the different review and t* outing cycles of the WPQR.
In that acdition, ptocedute DEC-QAP 2.09 recuires the welders carry a
Walder Performance Qualification Certification card.
These requirements are different from those stated and ft'om those identified in procedure W-2.
These differences render the i
implementation of the Walder/ Welding Operators Gualification program indeterminate.
in C.
All welding and weld qualifications were being done
<n.
fM6b accordance with G-29. The process specifications under G-29 indicate that welding and welder qualification should be done in accordance with Section IX of the i
g
- However, these i
ASME'Boilei and pressure Vessel Code.
and process specifications do D2i state which code year addenda of Section IX apply.
A
'TVA engineer (individual 5) in Knoxville was contacted for clarification and stated there was no particular code year and addenda in effect. 'It rolled - meaning that as the code addenda became mandat~ory, TVA would incorporate those requirements.
Nowhere in the applicable B-29 orocess specifications is it stated what the ASME code incorporated. in and addenda are gr that they are year this fashion.
Without TVA knowing which code yeat'-
and addenda are under Section "a p'p l i c a b i u fot-qualification of welders be answered:
following types of questions cannot IX, the I
1.
All WPOR's listed in Att. 1 reference the use of j
filler metal with an*"F" No.
o f Z.
The 1974 sand later years and addendas of.Section IX do not recognize the "F" No. I designation.
2.
WpOR dated 5-11-77 indicates that the welder tested g3.
and qualified, using 6" XX-STG pipe, foi a range of 3/16" to max. WPQR dated 11-11-77 was issued based f*
5-11-77.
on the acceptance of the qualification on However, the WPQR dated 11-11-77 indicates that the l
then qualified to weld on a range.of welder was
~
. / ';-
.i;.
1/16" to 3/4".
,, gg.Q,.
,..q., y.. %
+ - -
l e
(-
(-
e e
e PAGE 11 0F 17 ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-101-OO6 DETAILS FINDINGS:
(Continuec)
I.
C.
2.
Continued Decending on the code year and addenda this may ot*
may not be acceptable.
(Reference GW-351 in both the 1974 and 1977 editions,of Section IX which states in part:
"The limits of thickness for which he will be quellfied are dependent upon the thickness of the weld he deposits with each welding process, in which the thickness shall be considered the test _ cocoon thickness as given in GW-452)."
In the weld that was deposited on 5-11-77.
tnis case, for initial cualification would be considered the test coupon thicknes'h.
D.
WpOR dated,9-29-78 indicates the material specification as A-106 to A-106.
This is carbon steel material.
The.
WPOR also indicates P
No.
8 to P No.
8.
P No.
B f.
(81Y0 designator is for steel alloy and austentic stainless steel material, not carbon steel.
s E.
Welder Qualification List,. Sheets 1 of 2 and 2 of 2 for individual *1 list the following test numbers:
Qualified'Date. Invalid Date i
Test Number 42602 GTSM-7-5-0-3H 5-11-77 11-11-77 l'1-11-77 8-4-78 24301.
GT-7-0-3-L
- 24200, GT-7-0-1-6(A) 11329-77 8-4-78 42600 GTSM-7-5-O-3-H(A) 9-29'78
'i7-25-79 WPOR's dat ed 5-11-77, 11-11-77, ~ 11-29-77, and 9-29-78 list teet numbers,5179,
- 6665, p980, and 0287 respectively.
1.
II.
The C'1 'made reference to two (2) specific welds within the Waste Disposal System (WDS).
With 'the CI's descript ion of the welded area and the help of. Watts Bar erfgineers familiar with the
- WDS, the area in question was located on the applicable WDS drawings.
Ho' wever, there is no information available at SON pertaining to the weld numbers.
A review of the drawings indicated that the particular' welds would be in a Class G line.
.v.
4~
A review of the requirements for the installation of Class G
Waste Disposal lines led to the following N.'..;~
.a.
a.
.c.
- +.
,.s J. '. s '.
. s..
.. ;.,,, 3 a.,
(:
(~
pAGE 12 OF 17 ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-101-006 DETAILS FINDINGS:
(Continuea)
II.
Continued A.
Section 11.2 " Liquid Waste Systems" of - the SON Final Safety Analysis Report (FSAR) refers to Section 3.2 of the FSAR
" Classification of Structures, Syst erns and Cornoonent s".
The review also identified SON Construction Specification N2M-865.
2.
Tables 3.2.2-1 and 3.2.2-2 of the FGAR Section
- 3. 2 descrios the " Summary of Codes and -Standards for-Cornoonent s of the Sequoyan Nuclear plant for-procurernent s prior.,to April 2,
197'3 and after Aatil 2, 1973."
(S'ee At t achtnents 2 & 3).
Both of these tables deal with the recuirements for the procurernent of pioing and other components.
2.
Table 3.2.2-3 (See At t achtnent 4) deals with h@OS Non-Nuclear Safety Classifications, however
,t%>
'%~
footnote
(*)
to Table 3.2.2-3 states
" Code Jurisaiction is applicable to the field fabrication, assembly, e x ar.11n at ion, and testing of
-s all piping systems except the prirnary coolant i
loops and the pressurizer surge line piping.
The piping design for the Sequoyah Nuclear plant is per ANSI B31.1 - 1967 power piping Code...".
- 3..
Construction Specification N2M-865.Section
- 5. 0, t'"
lists different requireme'nts for famid installation of piDing and duct syst erns.,
(See Attachtnant 5).
Section
- 5. 0 of N2M-865 clearly states "The following codes.
and standards novetn the installation and erection of TVA pipe and duct Requirernents 'for TVA Class A, B,
C&D sys t erns. ".
under this construction specification are different those committed to in..,Section 3.2 of the FSAR.
than I
B31.1 - 67 for the renewal of The requirements of ANSI B.
performance qualifications of welders are more stringent than those listed in Genei*al Construction Specification G-29M.
wwa 1.
ANSI B31.1-1967 paragraph 127.5.6 states perfortnance Requalification is required Benewal of performance qualification under either.of the following conditions:
- s.
. a n y,h. i;h5 h
- l.....;. ' *x %,,.
v :..
.. V
' [.
%... i. _....
e
(
=.
PAGE 13 CF 17 ERT INVESTIGATION REpDRT CONCERN NUMBER XX-65-101-006
'i DETAILS v
FINDINGS:
(Continued)
II.
B.
1.
Continued (1)
A welder has not used the specific within the essential variables given process in Section IX, ASME Boiler and pressure Vessel
- Code, to weld either-ferrous or nonferrous pressure piping materials for a
period of tnree monthe, or is reason to question his ability to (2)
If there make welds that meet the performance qualification requirements.
Renewal of qualific'ation under condition (1) need be made in only a single pipe wall thicknsus and may be made by either a test weld or a production weld checked ~ on the basis of acceptable radiography.
,c f.'.4 $b Construction Specification G-29M, Process 2.
General Specifica, tion 1.M.2.2(a), paragraph 4.1, states:
.c.,
' Renewal of Qualification 4.1 Cenewal of qualification of. a performance test shall be required under the following l
conditions:
Where the welde'r or welding operator has (a) not used the welding process (manual shielded metal m'r c, gas tungsten
- arc, etc.)
,to weld either ferrous or' nonferrous materials for a
period of l
three months lor
- more, except when employed on soms other welding
- process, the period may be extended to six months, ot-(b)
When there is specidic reasons to question the welder or welding operator 's l
ability te produce welds that meet. the specification requirements.
Henewal o f-qualificatio under (a) need be l
made in only a single test Joint (plate o t-
- s...
pipe) on any. thickness, position, or material
('
to reestablish the welder's or welding l
operator's qualification for any thickness, l
- position, or material for which he was previously qualified.
..l$.3
- 5,g. "...".{r
.t.*.
3.]
- ;. b i.:
.:: r.c.
.:.e. ;.
f M.~.} '*(."?:
l
7
(.-
(
'. =
e PAGE 14 CF 17 ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-101-OO6 DETAILS FINDINGS:
(Continued)
The areas noted as conflicting'are II.
1.
ANS1 B31.1-67 recuiten a welder who has not welded in a
specific process f o t' 3 months to have a
renewal of oualification.
G-29 allows a welder who has not used the welding. process for a period of 3
i rnonths or rnore, except when ernployed on some othat' to have the recualification period welding process, extenced to 6
rnonths before renewal of cualification.
2.
ANSI B31.1-67 states
" renewal of qualification...need be rnade in only a
single thickness and rnay be rnade by either a
pipe wall weld or a production weld checked on the basis test of acceptable radiography.
G-29 allows for the renewal of qualification to be made in only a
SME-single test Joint (plate or pipe) and G-29 does not em.
weld define by what means this particular further-would be checked (i.e.:
radiography or rnechanical
'N o s
tests).
reviewing the above infortnat ion, TVA's renewal of' A f t er-meet perforrnance qualification program does not welaer Table 3.2.2-3, the recuirernents of the FSAR Section 3.2, 8
Footnote (*) and additionally, the committnents under the FSAR for the
- design, field fabrication,
- assembly, and testing of pi~ ping systerns have not been ex arninat ion, roet in that existing constructio,n specifications have roodifled the requirements.
issued to
- Also, the dual process welding qualifications individual i on 5-11-77 and 94g9-78 do not cornply with the requi rernent s.
of ANSI B31.1-G7 for renewal of
'pei fortnance qualificat ions.
'~.
I III. During the evaluation of a computer printout identifying-all welds perforrned by individual i and applicable weld history the following questionable iterns were noted
- records, i dicates 'that individual i
printout A.
The cornput er When the weld history records for weld per'fortned weld A.
A were reviewed, there was no evidence indicating that weld A was performed by individur.1 1.
The weld history i
record indicates the cornplet ion of weld A
(
two-and-one-half years prior to individual l's s'
ernployrnent with TVA.
. g..:.....
n.
t..,
s.
~.. -,.
u
. x a...
=.c-j
C i
(
PAGE 15 OF 17 ERT INVESTIGATION REPORT CONCERN NUf1BER XX-05-10 -006 DETAILS FINDINGS (Continued)
III. (Continued)
B.
The Weld Qualification List indicates that individual 1
welded during the weeks ending 12-7-77 and 2-2-78.
There is no indication on the Wald Qualification List that individual 1 welded between the two dates.
This can be verified by individual l's medical records.
According to the medical records, individual was held off of work for over 30 days because of an injury.
- However, weld B and C operation checklists and weld history cards indicate that welds were rnade prior to week beatnnin.g 1-27-78, indicating that individual 1
welded and this informatibn.was not properly docurnant ed on the Welder Qualification List.
gg,g CONCLUSION:
'-a' This concern is substantiated.
This conclusion is based on the following deficiencies:
1.
Qualification records for individual i have not been reviewed in accordance with SNP Construction Procedure P-8.
2.
WPQR dated 11-11-77 contain's a staternent that a) was added after the record was's,igned, or; b) irnalies the record was back-dated to Maintain the welders cualifications.
3.
WPQR dated 11-11-77 and the. rest of the qualification records for individual 1,
contain information that could not be substantiated as accurate or corredt based on the fact that all supportinn evidence has been destroyed.
particular ASME 4.
TVA has not been able to identify the* qualify Section IX code year and addenda used to
- welders, therefore the welder qualifica, tion prograrn is indeterrainate.
- 5. -
FSAR Sect ion 3.2 defines committnents for the
- design, field fabrication, assernbly, exarninat ion and't' st ing of piping.
e These comrn i*t tne n t s have been modified by site construction specifications.
Therefore, the cornmittnant s for the SGN (lu facility are indeterminate.
6.
I n f orrna t i on (exarnpl e
- cornput er reports; weld history records / cards) pertaining to the doeurnenting of individual l's welding activities is inaccurate,. therefore rnaking the
- n.. ' w.c.2 : [; ;... n. g:..r,. : iw;..
- f.. ;
- ?.-
. records indeter minate.-
.a g. g.... a.
-9 m
c i
(
e s
PAGE 16 OF 17 ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-lO -006
, DETAILS OBSERVATIONS:
Listed below are observations noted during the course of the investigation.
1.
SNP Construction Procedure P-8 Rev 14 deletes the requirement for the Quality Control Records Unit (GCRU) personnel to initial and date their review of the general construction GA receras.
This is a
change from previous revisions of procecure P-8 whien required DCRU personnel to initial and date their review.
General construction records reviewed by the QCRU after the issuance of P-8 Rev 14 are tnerefore ihoeterminate as to their review status.
2.
The following TVA forms within the Personal. History Record (PHR) for individual 1 indicate the wrong social security numberE(___ __ __30) - the O should be a 73.
e/P a)
TVA form TVA9880 dated 5-6-77 (Employee Status and
('5]' jab Information Record u.
b)
TVA form TVA9880A dated 5-6-77 (Appointment Affidavit g
and Conditions) c)
TVA ^ form 'TVA10539. dated 5-11-77 (Welding Performanew Qualification Record) d)
TVA form TVA9880 dated 5-26-77 e)
TVA form TVA95 dated 12-14-77 (t wo reports)
(Medical Evaluation For Return'To' Work) f)
TVA form TVA35 dated 12-27-77
~
g)
TVA form TVA95 dated 12-30-77 h)
TVA form TVA1444 dated 1-17-78 i)
TVA form TVA95 dated 1-19-78 J)
TVA form TVA95 dated 2-14-79 k)
TVA form TVA95 dated 2-16-79 1)
TVA form TVA95 dated 2-21-79 1,
m)
TVA form TVA95 dated 2-26-79 n)
TVA form TVA95 dated 3-1-79 Affidavit and donditions Report 3.
According to the Appointment (TVA form TVA3880A),
dated 11-1-79, found in the PHR of individual 1,
he was to begi*n work at Bellefonte Nuclear Project 11-6-79 as a steamfitter/ welder..
His appointment to BNP was contingent upon passing a TVA welding test. According to the Welding Test Authorization, dated 10-31-79, c.*
individual 1 failed to qualify.
Although not qualified as a
h%
- welder, individual 1 still received appointment to BNP r.s a
steamfitter/ welder.
(This per TVA form TVA9880 dated 11-06-79.)
SON personnel department stated that all records s.
(field files) pertaining to individual l's work activities at BNP were destroyed; "If the information does.not appear..in
- t hmSi:r l - 2.y
.,/.
his PHR, t hen hi s records are gone. " '. "_9. ~9.C *
,.g z,3 3 e
.e r
,,s.
i C
/
C.
PAGE 17 OF 17 ERT INVESTIGATION REPORT CONCERN NUMBER XX-85-10 -006 DETAILS OBSERVATIONS:
(Continued) 3.
Continued The only i n f ortnat i on relating to individual l's work activities at Bellefonte, is contained in TVA forrn TVA77 (Per sonnel Action
- Hourly TL) dated 4-21-80 which states under supervisots evaluation of service,
" welding on NB piping in reactor building #1."
\\
!?'*l*k s
e
^
's.
2'dO'b PREPARED BY: ___~ d b k
_DATE 4
REVIEWED BY __
N _____
_ [M DATE 6/M g
-/
.g
(..
/
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=
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, {^
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i
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.6 ATTACHMENT 1 1.
for individual lllh in the qualification flim
}
found of doeurnents
)
Liot B.y.gg..r_d_T 1 t 1_e_
Record E1LQ2r.li D.a._t_e.
Welding Per-fortnance Qualification t
Perforraance Qualification Record 5-11-77 Welding d
11-11-77 Perfortnance Qualification Recor of Welder Welding RaIrvocat ion 11-29-77
Subject:
Mernorandurn:
Weldei-12-6-77 Qualification of Revocat ion 3
Subject:
Mernorandurn :
G-0-78 Qualification Record Welding Pet-fortnance Qualification of Welder-Revocation 9-2d-78
Subject:
Mernorandura C-6-79 Qualification t 1 of 2 Welder-Qualification List Shee t 2 of 2 8
.g.,5 5-7 Welder Qualification List Shee q.
D M 9 9-79 s
W e
be g
e Wh.8J e
/*. g. *.
sd..
.... ; e.s _4.,.
.,...; ;. 9,...,,...
s.
-4 i.gw --
t r-' T.i. : l
.' ' ?,l
- l i,; u'\\. n.r V.
.O.
4.i a
.l
. SNP'
!.b' d,'
',I I*
[,
i
( ' y.
~
3
.: i i
f D
i.
a i
Table 3.2.2-1 e,e
~
I 1
E i
St
/
R PLANT f
' St20tARY OF CODES AND STANDARDS FOR COMPONENTS OF Ti!E SE0tfGYAtt NUCt.EA g
FOR PROCURE!!ENTS PRIOR TO APRIL 2, 19Q p
~
Code Cisssifications Croup D Croup C A
- Group B
{ Croup i
g D
Comnonen t.
ASHE Boiler and Pressure Pressure ASILE Boller and Pres-'.ASME Boiler and Pres-ASHE Boiler and Pres-Vessel Code, See Q.
Vessels sure Vessel Code, Sec-sure Code Section III, sure Vessel Code, Sec-tion III, Class A, Class C,-1968 Edition tion VIII, Division 1 Division 1 or Equivalent l
i 1968 Edition N
- ASHE Boiler and Pres-ASHE' Boiler and Pres-ASHE Boiler and Pressure 0-15 'Ps i g -
sure vessel Code, Sec-sure Vessel Code, Sec-Vessel Code,Section VIII, tion III, Class C, 1968 tion VIIT, Division 1 Division 1 Storage Tanks Edition
{
i
. o;
. Storage Tank Codes' Storage Tank Codes API-650, AWA D100 or
' ~
Atmospheric API-650, AWA D100 or API-650, AWA D100, or ANSI B941 4
Storage,, -
ANSI B 96.1.,
ANSI B96.1 Tanks
- e I
3 ANSI B31.1.0 ANSI B31.1.0 ANSI B31.1.0*
l i'
Piping ANSI.B31,1.0*
Draft ASHE Code for Pumps q,.
Pumps Drafi: ASME Code for Draft ASHE Code for Draf t ASHE Code for Valves Class'III or 9
f.-
Pumps and Valves Pumps and Valves Pumps and Valves Equivalent.
Class III Class II i
z 3
riass I HSS-SP-66, ANSI B16.'5' HSS'-SP-66, ANSI B16.5 HSS-SP-66, ANSI B16.5 MSS-SP-66, ANSI B16.5 y
g and Draft ASHE Code and Draft ASHE Code and Draft ASHE Code Valves g
for. Pumps and Valves - for Pumps and Valves for Pumps and Valves i
q}
Class III class II
. Class I D
Inspection and test requirements of AISI B31.7 l
- The piping has be n designed to ANSI B31.1.0 code re'quirements.have been use l cx loops and the pressurizer surge line. piping.
s.
5.
i
.s e.
i, l
t e
...... i t...., y c -
7.s :.........> un.. r. xs~
..,, s. h.wr.
.,..,,.n.
Ac///r8#
gg.g5'-/0/ - 0 0 6 (
/
SI:P
.l g
- s Table 3.2.2-2 ARDS FOR COMPONENTS
'~
ER
..c.
Su!2fAPJ OF CODES AlfD STANDPl. ANT FOR PR OF THE SEOUOYAH NUCLmEAR Code Classification Vessels V alves Pumos
- ASME Code, Scismic Pioint ASHE Code, Sec. III, TVA Catecorv Safety Claus Class AStE Code, See, III, Class 1 ANS N-18.2 ASME Code, Sec. III, A
Sec. III, C.l. ass 1.-...C. lass 1.
ASME Code, I
1 Class.1 ASME Code, Sec. III, ASME Code, Sec. III, Class 2 ASME Code.
Sec, III, Class 2 I
B Sec. III, Class 2 ASME code, 2a Class 2 ASME Code, Sec. III, ASME Code, Sec. III, Class 3 ASE Code, Sec. III, Class 3 I
C Sec. III, Class 3 ASME Code, 2b Class 3 ASME Code, Sec. III, SHE Code, Sec. III,
, Class 3 l
ASME Code, Sec. III, Class 3 I
D Sec. III, Class.3 ASliE Code, 3
Class 3 ANSI B31.1, Sec. VIII,.
Hanufac-B16.5, or Div. 1 ANSI, B31.1 turers
.HSS-SF-66 I
G Standards ANSI B31.1, j<.pi g'.
ANSI B31.1 B16.5, or HSS-SF-66 H
%/
t
?
J 3
I K
April 2, 1973uirements.
L.....
f code requirements prior toting ANSI B31.7. req MA, AFI',
~.,
ble 3.2.2-1 for listing oAStE Code,Section III as meeor s
- Refer to tab 31 Code Case 115 accepts code specific its saf ety-lasses G and K51s to be instaquali ine the
- Design engineers shall determNote that equipment. in V
i t
ctc.).
Category I structures j
related aspects.
,..ar...
4
- .eJ e
,og f;
.g 5
- b. : -
((f&.
.Y'-
. -l
f**4n<"
G,NcaNn-8.svw xc.
(~
I e
SNP g*
Table 3.2.2-3
- n -NUCLEAR SAFETY Ct.ASSITICATIONS_
Design for Code Seismic t.oadint
~~
'Ju ris d ic t !'o'n
- Ctsss
~~
l'intne Svstems Class II, ANSI B31.7 (19697 and Draf t ASME
- gte E
Puep and Valve Code for Nuclear Power (1968)
Class 111 ANSI B31.7 (1969) and Draf t ASHE He F
Purp and Valve Code..for Nuclear.fower (1968)
A!!SI B31.1.0 (1967)
Note 1 G
No te 1 A'!SI B31.1.0 (1967)
H No Section 1 ASHE Boiler and Pressure J
Vessel Code Note 1 E
Unclassified Note 1 Unclassified L
i' Yes ANSI B31.5 (1966)
It No e.7..
ANSI B3.3 (1966)
- W
- N Yes Steel, Spiral or Longitu-Round Duet, Q
dinal Welded Seam, AST!! A 211 and Duct Construction, 5"ACNA High Velocity Standards, Second Edition,1969, Erected to SQN-DC-V-13.8.,
No Round Duct. Steel, Spiral o Longitu-R dinal Locked or Welded Seam, StuCNA Duce Construction, Stand--
.. Hirh Velocity ards, Second Edition,.1969.
(Sheet Hetal and Air Condir.loning Centractors National Assoc.)
Yes Rectangular Duct, for Velocities over S
2000 fpm or Static Pressures Trem 2-to 10-Inch Unter Cauge S'!ACNA Hiah Veloe-.
Construction Scandards_, Second itv Duct Edition, 1969 Erected to SQN-DC-V,-13.8.
i No Rectangular Duct, for Veloc'ities Over T
2000 fpm or Static Pressures from 2-to 10-Inch Water Cauge, S?uCNA Hich Veloc_-
~
Construction Standards, Second.,
itv Duct Edition, 1969.
e
... s..
4
~
c 5 **.,;
t*
~
- s.
am.
- ... y, -
5 ~a '
b & C N 1 M G~nlT* b y t 2 0l'l- '
QbkW $~8 7-/d/. cog, (
j SNP
(
.n Table 3.2.2-3 (Continued) e
'0!:-50 CLEAR SAFETY CLASSIFICATIONS
)
Code..
Design for TVA Jurisdiction
- Seismic Loadine
.. - - ~,
Class _ -
- - =-.
pinine Svstems U
Rec: angular Duct, for Static Pressures
- Yes, Le lr.: 2-Inch Vater Cauge. S' TAC?fA low Velo-itv Duct Construction Standards,
~
Fourth Edition', 1969, Erected to 50::-DC 'l-13.8.
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' Rectangular Duct, for Static Pressures No Belou 2-Inch Water Cauge, SMACNA t.ow_
Valecit*. Duet Construction Standards, Tourth Edition, 1969.
- Code jurisdiction is applicable to the field fabrication, assembly, examina-tion. and testing of all piping systems except the primary coolanc loops and the pressurizer surge line piping. The piping design for.the Sequoyah Nuclear Plant is per ANSI B31.1.0-1967 Power Piping Code "and ANSI 331.5-1966 Re-frigeration Piping Code."
. Note 1:. All non-nuclear safety piping systems located inside seismic category I structures are seismically supported as necessary to prevent ur. acceptable interactions with safety,-related f,
structures, syste=s, or components.
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TIEI.D FABRICAT10tl, ASS EMBLY EXAHINATION, AND TESTS FOR PIPE Al DUCT SYSTEMS N2H-865 r.
4.5.2 c-37
" Testing and Balancing of Heating, Ventilating, and Air Conditioning Systems."
4.6 TVA Design Criteria 4.6.1 SQN-DC-V-3.0
" General Design criteria for the Classification of Piping, Pumps, Valves, and Vessels."
4.6.2 SQti-DC-V-3.2
" General Design Criteria for the Classification of Heating, Ventilating, and Air Conditiong Systems."
4_.7 ASIti A211 - Specification for Special Welded Steel or Iron Pipe 5.0 REOUIPR!EITIS FOR FIELD I!!STALLATI0tt OF PIPE AND DUCT SYSTE!!S The requirements pertaining to installation, testing, inspection, stamping, and certification shall be in accordance with the rules applicable to the TVA classification and type of component involved.
Paragraph 3.12 defines the boundary of jurisdiction. When joining piping and components of different classifications or components.which have been manufactured under different code editions and addenda, the more restrictive requirements shall govern.
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The following codes and standards govern the installation and erection of TVA pipe and duct systems. In some cases design drawings and specifications may contain additional requirements applicable to a specific component or system.
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Design for TVA Seisctic Class Loadine Apolicable Codes and Stan'dards A
Yes 1.
ANSI B31.7 (1969) and 1970 Addenda, Class I*
B Yes 2.
ANSI B31.7 (1969) and 1970 Addenda, c' lass,II*
C/L***
Yes 3.
ANSI B31.7 (1969) and 1970 Addenda, Class III*
C Yes 4.
ANSI B31.1.0 (1967) issued July 26, 1967.
H Ho 5.
ANSI B31.1.0 (1967) issued July 26,'1967, with NDE of butt welds per ANSI B31.1.0C, 1972.**
.. J Ho 6.
ASME Boile'r and Pressure Vessel Code,Section I, 1968 Edition through Winter 1969 Addenda, inclusive.
K/L Yes/No 7.
Unclassified, to be specified on applicable drawings.
H/N Yes/No
.8.
ANSI B31.5 (1967), 1968 Addenda.
j
-Q Yes 9.
Round Duct,' Steel, Spiral, or Longitudinal Welded Seam, ASIM A 211, SHACNA Hieh Velocity Duct Construction Standards, Second Edition,1969, and AflSI B31.1.0 (1967).
R No 10.
Round Duct, Steel, Spiral, or Longitudinal Locked or Welded Seam, SHACNA High Velocity Duct Construction
,,I;d Standards, Second Edition, 1969, and ANSI B31.1.0
.h n
(1967).
x.
S/T Yes/No 11.
SHACNA High Velocity Duct Construction Standards, s
.Second Edition, 1969.
U/V Yes/No 12.
StfACNA Low Velocity Duct Constructioii' Standards, Fourth Edition, 1969.
D-General Construction Specification."G-29" contains process specifications which define and shall be used to meet the.TVA requirements for fabri--
cation in accordance with the ASME, AWS, ANSI, or other. codes or 6-
"G 37" shall be used for testing and standards referenced therein.
balancing heating, ventilating and air conditioning systems.
All welding used in construction of.TVA classes Q, R, S, T, U, and V shall be in accordance with G29H or G29C proc,edures.
s.
B31 Case 115-December 1973 - Acce' pts Rules of Section III of ASHE Eoiler and Pressure Vessel code as complying with the requirements of B31.7 - 1969 and applicable addenda for the respective class of constructioni. Use of portions of later edition and addenda of any code or standard listed in section 5.0
- or of portions of ASHE Section III must be approved by the Nuclear Standards and Haterials Section of DED-MEB. Approvals shall be issued as addenda to this specification.
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- Refer to memorandum R. H. Dunham to G. G. Stack dated February 23, 1973, Contract 69C60-64422.
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.- 3 REQUE FOR REpORTABILITY EVALUATION
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XX-85-101-006'
______ ___ _ ___ted) 1.
Request No.
(ID No.,
if repor (ERT Concern No.)
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2.
Identification of Item Involved:___
(Nomenclature, system, manuf.,SN, Model, etc.)
3.
Description of problem (Attach related documents,
- photos, sketches,etc.)
Welder qualification _re_ cords hav_e_not been comp _1p.tgdug.vigxp.d_and..ano.r_gynd_
i{ac_cordanc_e__with_approvedSQtlprocedures. Ov_efa.1,1 welde.r__quali_fisat. Lor ___
records are indeterminate.
(Use supplemental sheets *if necessary)
- 4., Reason for Reportabilitys
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constructio6
- deficiencyj-were it to have A.
This design or could have affected adversely the safety remained uncorrected, operations of the nuclear power plant c any time throughout of the expected lifetime of the plant.,
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Yes
_ 1f Yes, Euplain _
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No
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This deficiency represents a p_innificant breakdown in any portion of the quality assurance program conducted
- in L'
accordance with the requirements-of Appendix. -Bt l
Violation of Criterion IX No
'Yes X
If.Yes, Explain -
g deficiency in final
, deficiency' represents a pianificantfor constructicn such that
- the, C.
This approved and released design as conform to the crithria bases stated - in. the a design does not safety analysis report or construct. '.on permit. ~
i No _X Yes ____, If Yes, Explains f
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REDUEST FOR REPORTABILITY EVALUATION 1
U.
Thas deficiency t eot esents a
significant deficiency in construction of or significant damage to a structure, system e t-which will t eault e extenutve evalustjon.
eMtensave
, component extensivo repair to eneet the cratersa anc ba sets t e o e'.c i g n, o t-stated in t,he safety analysis t ecot t o t-consteuctton netmst on-to othotwise establish the adecuacy of tne structure.
- system, ot-component to pertform its intended safety function.
No X
Yes g____
If Yes, Explains I
M E.
This deficiency r,npresents a sinnificant deviation from the phrformance speci f icat ions'. which will require extensive _
evaluation, extensive
- redssign, or extensive repair to establish the adequacy of the structure,
- system, or component to perform its intended safety function.
- X Yes If Yes, Explain No
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IF ITEM 40, AND 4B OR 4C E AD E 4E ARE MARKED "YES",
Jit.dEDI ATELY HAND-CARRY _THIS REQUEST AND SUPPORTING OCUM"NTATION TO NSRS.
This Condition was Identified by:,.*,4t:4r ob u
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Acknowindgmen of receipt by NSRS T
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REQUEST FOR REpORTABILITY EVALUATIDN XX-85-101-006.
1.
Request No.
(ERT Concern No.)
(ID No.,
if reported) 2.
Identification of Item Involved:
_____________________f.,SN, system, manu (Nomenclature, Model, etc.)
3.
Description of problem (Attach related documents,
- photos, sketches,etc.)
Construction Specification (N2M-865) contradicts requirements listed in,fhe Final Safety Analysis Report, Section 3.2
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Reason for Reportabilitys (Use supplemental sheets if necessary)
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. deficiency," were.it to have A.
This design or const ruct ion'.
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.
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(.yM.q No X
Yes _____ If yes, E:4 plains s
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t nND B.
This deficiency represents a sinnificant breakdown in any portion of the quality assurance program conducted in 2d
- .'3 accordance with the requirements.of Appendix-B.'
Explains. Violation of Criterion III & 'V
- yes X
If yes, tro Construction specification lists different requirements for field fabricatior}.
assembly', examination, and testing for piping.
l.
q' DR in final C.
This deficiency represents a pianificant' deficiency 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 permik.
No _ X
_ Yes If yes, Explains _
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REQUEST FOR REPORTABILITY EVALUATION U.
This deficiency represents a
significant deficiency in construct ton of or significant damage to a streicture, system er component which will'recuire extensive eval u a t_lon.
extenssue
- teoessgn, or extensive tepair to meet the er1teraa and
- baser, stated in the safety analysis report or consteuction cetmat or to othetwsse establish the adecuacy of tne structure, s ys t era, ot* component to pectform its intended safety functic.,r.
No _X Yes _____ If Yes, Explain Q R_
E.
This deficiency represents a sinnificant deviation from the performance speciflemtions,which will require extensive evaluation, extensive rede' sign, or extensive repair-to.
establish the adequacy of the structure,
- system, or component to perform its intended safety function.
No X
Yes If Yes, Explains-
$5N
JMMEDIATELY-HAND-CARRY THIS REQUEST AND SUPPORTING DOCUME, IDN TO NSRS.
WM _)_dd_I_h__
This Condition was Identified by:
phone Ext.
ERT Inv{s,t:. gator l',
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ERT Project Manager
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Acknowledgment of receipt by NSRS j
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Attechm:nt 2 Ptga 1 cf 1 10/16./86 (EMPLOYEE. CONCERNS)
CAT ISSUE PLANT PRIORITY ORG QTC EGG INSP SD RD GD 10 ------CONCERN-------
- 13:01: 01 8
1 SR XX-85-101-006 PROB: WCPOW
(, 'WORDS:
QUALIFICATION CRAFTSMAN SPECIFIC A WELDER PERFORMED WELDS WITHOUT HAVING THE PROPER CERTIFICATION.
SEQUOYAH:
DETAILS XNOW TO OTC, WITHHELD DUE TO CONFIDENTIALITY.
CONSTRUCTION DEPT CONCERN.
Cl HAS NO FURTHER INFORMATION.
i IR: XX-85-101-006 STAT:
RC:
TECHNICAL COMMENTARY:
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PROGRAM SUMMARIZATION OF WELD PROJECf (WP) EVALUATION This packago summarfres the actions taken by the Welding Project (WP) to evaluate and disposition the subject SQN-specific employee concern which was previously evaluated by NSRS/91C/ERT and summarized in WP Phase I and Phase II reports.
The Welding Project analyzed each SQN-specific employee concern to determine the statement (s) being voiced by these individuals.
These statements were then evaluated both individually and collectively to develop issues.
Each issue was then incorporated into the WP review activities of Phase I,
" Procedural Assessment" and Phase II, " Procedural Implementation."
During Phase I, each issue was analyzed against requirements of the applicable policles, NSRS/QIC/ERT Investigation Reports, and other relevant information to determine if program elements were deficient when evaluated QA program, against upper-tier requirements.
Phase II consisted of a sample reinspection of hardware and independent program audit by Dochtol.
In each area analyzed by Bechtel, the auditors found no objective evidence to substantiate the employee concerns considered. The following areas directly related to employeo concerns were investigated by the audit team:
1.
Waldor qualification and attendant records Welder qualification and attendant on-the-job-training 2.
3.
Welding inspections 4.
Welding inspectors training programs 5.
Wald material traceability 6.
Welding inspections by craft personnel 7.
Wald material control Each of these areas was investigated by the auditors for both construction and there was no objective evidence to operations phasos.
In all cases, The audit report concludes that both substantiate the employee concerns.
construction and oporations phases have had and now have a functioning Welding Quality Assurance Program which meets code, standard, and regulatory requirements and that the employee concerns considered were found to be unsubstantiated and without technical merit.
3157T Page 1 of 2
Attacivnent 3 The results of the reinspection program at SQN also give another, additional verification of the Wolding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the accuracy and isnpinmentation of these programs through hardware inspections and attendant document reviews.
In all cases, the components and items were found to be acceptable upon initial reinspection or found to be acceptable after engineering analysis.
The Wp annlysis of SQN-Specific Employee Concerne supplemented by. Elia independant Dechtel nudit, reinspection of installed components anit system,,
and independent (NSRS) overview and investigations has not revealed any significant or ganeric inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified tiirough the Employne Concern Program. The Employee Concern Program has simply reiterated problems which have been or are.now being resolved through existing corrective action programs in the overall Nuclear Quality Assurance Program.
~
A summary analysis of the Wp evaluations and regommendations is included in Attachmont.
Page 2 of 2
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Page 2 of 3 d
EMPLOYEE WP ACTION CONCERN NUMBER ISSUE SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was substantiated; SQM-6-005-X02 SQM-6-005-X02 Making Proper Welds was not substantiated by NSRS Report I-86-115-SQN (Attach-ment 3).
WP concurs with report.
XX-85-013-001 E309 Electrode Used to Weld Thld is an acceptable E316 Steels practice. ERI investigated in ERT Report XI-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
1X-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
iSC2-XX-85-049-001 was r,dpa..
Welder Certifications XX-85-049-001 XX-85-049-XO3 Updated Without Meeting substantiated as it relates to Welder Continuity Require-Requirements monts. This had previously been identified by NO in an audit. XX-85-049-103 was not substantiated. Details and l
recommendations are given in NSRS Report I-85-135-SQN i
(Attachment 3).
WP concurs l
with I-85-135-SQN-01 through
-03 and recommends they be l
closed based on the l
WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and l
l 17.0 (Attachment 4).
Not substantiated by NSRS,
XX-85-054-001 QC Holdpoint Sign-Off Report I-85-346-SQN Violation (Attachment 3).
XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Report I-85-750-SQN Inspections (Attachment 3).
05640
~-
Page 3 of 3
.'!*.)
EMPLOYEE CONCERN NUNDER ISSUE VP ACTION XX-85-083-001 SQN Weld Inspections not as Not substantiated by NSRS Strict as WBN
~
Report I-85-652-SQN (Attachment 3).
XX-85-098-001 Laminated Pipe in Unit 2 Mot safety-related. Not Condenser. Ihls lesue is substantiated by WP Evaluation also on the Generic Summary Report WP-18-SQN (Attachment 3):
XX-85-100-001 Improper Weld Repale on an Not substantiated by ERI Undetermined Number of Report X1-85-100-001, dated Welds 3/5/86 (Attachment 3).
XX-85-101-006 Welder Certification for ERI Report XX-85-101-006 the Construction Era (Attachment 3) with NSRS Recommendations indicates that this concern is sub-4 stant!sted. WP takes exceP-tion to this ERI Report based on subsequent information provided in Attachment 4.
WP exceptions, recommen-
[
dations, and basis for l
closure were discussed with NSRS as documented in Attach-ment 5.
WP recommends this concern not be substantiated and that it be closed based on the WP-Bechtel Implemen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachment 6).
XK-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS Notice of Indicatiens for Report I-85-735-SQN Preservice-Related Defects (Attachment 3).
XK-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS XX-85-108-002 Report I-85-776-SQN (Attachment 3).
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05640 l
4 Page 1 of 3
SUMMARY
OF SQN SPECIFIC EMPLOYEE CONCERNS REVIEWED BY WELDING PROJECT EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XX-85-088-003 Alterations to Welder Not substantiated by ERI Qualification Records in Report XX-85-088-003 of Knoxville 3/8/86 (Attachment 3).
XX-85-124-001 Burial of Electrode Stubs Not safety-related. No action required.
9 XX-85-086-003 Box Anchor Design Substantiated by NSRS Report I-85-560-SQN (Attachment 3).
Deficiency.
WP concurs with report recommendations.
XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS 1~ %
Rejected NDE Items Report I-85-738-SQN (Attach-
' ment 3)
WP concurs with f '
report recommendations.
SQM-5-001-001 Uncertified Welder Foreman Substantiated by WP Evaluation SQM-5-001-002 Performing Preweld Report WP-16-SQN (Attachment WBM-5-001-002 Inspections 3).
Interim corrective actions are being (Also Listed in formulated. Closure is the Generic
. based on these actions.
Summary)
Additional corrective actions
~
may be implemented.
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS REPORI I-85-636-SQN 1
Piece (Attachment 3).
XX-85-069-001 Inadequate OJI-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for N0 inadequate OJI-records was substantiated by NSRS Report,
XX-85-069-X05 I-85-373-NPS (Attachment 3).'
XX-85-069-007 No falsification of records was substantiated. WP cona curs with report recommen-dations.
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05640
XX-85-101-006 l
PREPARED BY F O S [ M O//h/,/FA 7 a.s. ovivls 7
. ECTG REVIEWED BY NI.E.
th, O 1/14
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, OC, WP rw bosfsl$
REVIEWED BY
, CEG-H, WELDING APPROVED BY PROGRAM MANAGER 3096T
Atttchment 5 XX-85-101-006 is based on Q1C's basis for substantiating employee concern XX-85-101-006 six (6) identified deficioncies, (see subject concern) the following provides a response to each specific deficiency:
The processing of welder qualification records (WQR) was not 1.
performed in accordance with Sequoyah Nuclear Plant (SQN)
Construction Procedures (CP) W-2, " Welder and Welding Operator Performance Qualification," and SQN CP P-8, " Review, Handling, and Temporary Storage of Quality Records." SQN CP W-2, revision 0, requirod the WQRs to be reviewed by Quality Control Records Unit (QCRU) and stored in accordance with SQN CP P-8, howeser no evidence SQN CP W-2, exists that the review of the WQRs was performed.
revision 1 (effective date July 31, 1981) deleted the requirement for SQN CP P-8 required retention of the WQRs and upon the QCRU review.
completion of the construction, these records would be transferred to the Division of Power Production. SQN CP P-8, revision 12 (effective 1986), clarified the American National Standards date June 13, Institute (ANSI) N45.2.9 definitions for record retention (duration of construction and life-of-plant), WPQs were classified as duration of construction records. Although the review of the WPQs was not i
performed (revision 1 of SNP CPW-2 deleted the requirement for QCRU review) the requirements of ANSI N45.2.9 were satisfied.
2a. WPQRs for welding technique GT-7-0-3-L was. issued concurrently with
_l or af ter the revocation memorandum (dated Decr4aber 6, 1977) for welding technique GT-SM-7-5-0-3-H with an effective date of 11, 1976. This qualification is based on the WPQR for November welding technique GT-SM-7-5-0-3-H which is comprised of two welding l
processed, gas tungsten arc welding (GT) and shielded metal arc The welder maintained the GT portion of the 4
welding (SM).
qualification through the usage of the GT portion of the welding technique, but the SM portion of the qualification was not maintained because of nonusage of the SM portion of the welding technique.
Based on the above, welding technique GT-SM-7-5-0-3-H was revoked according to memorandum dated December 6,1977 and the WPQR for welding technique GT-7-3-0-L was awarded with an effective date of November 11, 1977 based on the maintenance of the GT process of the The statement:
previously issued technique GT-SM-7-5-0-3-H.
" Equivalent qualification being awarded based upon satisfactory side bends of PQT GT-SM-7-5-0-3-H passed May 11, 1977. Welder has maintained certification of the GT portion of this test through i
PQT GT-SM-7-5-0-3-H revoked by letter dated 11, 1977.
November December 6,1977 because of lack of SM welding" on WPQR for welding technique GT-7-3-0-L is an explanation of the qualification.
i l
1 4
Page 1 of 3 f
3355T
2b. The TVA WPQR form has one (1) location to record the date. The date l
that was recorded on the WPQR form was the date the welder satisfactorily completed the performance test. The WPQR form is
" pencilled-in" in the weld test shop by the weld test shop supervisor and forwarded to engineering for typing, review, and engineering signature. The date on the WPQR form represents the welder qualification date and is the date that the welder qualification continuation is based. The Welders Qualification Record form in the American Society of Mechanical Engineers Code (ASME),Section IX (QW-484) has only one place to record the date and this form is used through the industry.
3.
The methodology for processing the WPQR dated 11-11-77 and the rest of the qualification records is explained in paragraphs 1, 2a, and 2b.
As the ERT report stated, the welder test shop log book,
" pencilled-in" WPQRs etc. are not available for review and procedurally were not considered QA records.
4.
Welder Performance Qualification (WPQ) may be performed to the edition and addenda of the ASME Code Section IX in affect at the time of the contract award or WPQs can be performed to the latest ndition and addenda in effect.
New editions and addendas become effective six (6) months after they are issued.
ASME Section IX editions and addendas issued after the start of construction were reviewed by TVA to determine if the later edition / addenda affected the requirements stated in General Specification G-29M, " Process Specification For Wolding, Heat Treatment, Non-Destructive Examination, and Allied Field Fabrication." Although some of the requirements of later editions and addendas were incorporated, not all of the later requirements were incorporated. TVA's WPQ program requirements are between the original edition of ASME Code Section IX in affect at the time of the contract award and the latest effective edition / addenda of ASME Section IX.
(Note: The acceptance criteria for welder performance bend test specimens has not changed from the 1968 Edition of Section IX through the current Edition.)
f 5.
lVA's welders continuity was based on a ninety (90) day usage until SQN CP M-2, " Welder And Welding Opeator Performance Qualification,"
l revision I was issued (effective date August 6, 1974). Revision 1 of said procedure adopted the option of continuing the welder's performance for a specific process which has not been used to six (6) l when the welder has been employed on some other welding process. The performance qualification extention to six (6) months was adopted the ASME Code,Section IX 1971 edition 1971 winter addenda. TVA's FSAR l
should be changed to reflect the ANSI B31.1 Code through the.ob-971 addenda. The addition of this addenda revises the introduction of ANSI B31.1.0-67 Code by modifying paragraph 3, column 2 to read:
"After code revisions are approved by ANSI they may be used by agreement between parties beginning with the date of issuance shown l
on the title page."
The 1973 edition of ANSI B31.1 Code and later editions refer welder qualification to the ASME Code Section IX.
Page 2 of 3 l
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i Computer printouts for systsa status wero used to irdic ts th3 6.
completion status of each weld within a system. This printout was not intended to be used as a welders history or to be a nermanent Quality Assurance (QA) record. The accuracy of this-priatout for welder identification is a moot point.
The Walder Qualification List (WQL) would indicate the latest usage by welding process for each welder. The WQL would show usage on a week-ending basis according to SQN CP W-2, " Welder and Weldirx3 Operator Performance Qualification." The purpose of the WQL is to document continuity of the welders qualification through the continuing usage of the welding process. Based on the usage date specified by QTC, the welders performance qualification was properly continued. Welding process usage not listed on the WQL did not affect this welders performance qualification continuity because of other process usage within the specific time frame required for welder continuity. Welding process usage not listed on the WQL can not improperly extend a welders continuity, but may prematurely retoke a welders qualification.
Based on the above responses, item five (5) is the only item that required further action, Recommended corrective action:
't 1.
Revise the FSAR as indicatei/in No. 5 above.
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WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS AIIACHMENI 6 MARCII 26, 1986 LETIER 10 MR. MARTIN
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.Harch 26, 1986 i.
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..H,r.LHartin:
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About two months or more ago I'got a call from a Mr. Pohlman of QTC requesting an Interview with regard to an employee concern. -A time for
,.". ' 5..,...the interview was set and the interview was held at my. office'.in-
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. Chattanooga. Mr. Pohlman arrived at the appointed time.wlth an associate
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.whose name I do not recall.
They had'wlth them.a' copy of,a Helder
'.. '.... Qual i fi ca t ion Re.. cord f.or. a 'we l de r.. f. rom Seg.i. soya,h.'.Co.n.s. t..ru. c..t i.od.'.
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.'.'~.. ',.,cfi n?que s t ioif ka' 'iniward,of" e qui, val un t qual l f. i gat t ori' fo'r.1 s i njl e proce s s.. '.,.
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(GT) ' Arc.Helding Certif.lc.ation. whi.ch,..was.,awar'de'd.ba.se'd.on2.l Q.3;r,%,.the.,~GT.,;.. lib.. ?.a..;DT-Sh l ~'ided.He tal. Ar.c. (SM) 'certl fi cation th,at :th,el". *. 3 ~....
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'*;<.,u;*." +weldef...'reviously'hel'd in.d,'whlgh.'hadiben'revo.ked.due. to.a..la.ck.b.f...',....'.
had p
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- J,H welding within the requrled time period..The'QTC e.mployees'a.lso had
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.......... ' cop i e s of the or i g i na l GT SH cer.t i fi ca t. ion. and th. e r'evo.ka.tio.n.not i ce fo. r. M 'i ~.
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that certification. All of these doc.uments w'e.re'.examin.e.d 'by me 'and. '.
q appeared to be in order and to have correct.datei, and appeared to me to
~be readily, traceable and ea.sily understood as to the relationshi,ps J
~ between all dates IIsted on all three documents.
I' asked what they perceivedtobetheproblemand[waspromptly, curtly,'andemphatically' told that these documents were obylously def,ective. ~ They Indicated to me that there.was no doubt 1n their minds that these records were in some (s.-
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way defective.
I then asked what their foundation for this belief was
.- based on.
They promptly told me that the' dates on the qualification forms were the dates those forms were slaned and since.the.second (GT-only qualification) form ref, erred,,.1#1 thin the body of the form, to a;-
date which was later than the form's slanature.date, then the. form was defective and invalid. At this point,1: attempted to correct their
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preconceived' notion 'that the form'.s'date was thel ate o,f.the signature d
being affixed to the typed copy of the. form and l' stead assured them that
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the form's date was.the date of the effective date of the action
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describedonthequalification. form,andihat.in'the. case'of Helder.
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. Qualification Records, the. signature at th.e' bottom of.the form'was not dated.
.I attempted to explain to them.that this. form.was;a.TVA-wide'for'm '..'
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'.;...a, and.that, to my recollection...had remaine,d relatively ' unchanged from..the
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.M.: M.N.'.t'.inIe?Ilhad.'f.l'r~s tl seeri? I tf(alidu. ; :.;.t 20' years'.ago).
.I,p,olnted out that of..the," ;,.....
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.a a);thedateofs[gnaturec
.~w... wo : dates. t ri iuestion relative.to. thl.s.:. matters.f,{2%L2.'bl.s.2%F-Q
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<.::i:-y %DQhMiElEtNedTeiMeNdho.L:lb:the: ef(etttye.:'date of/the./9 -95: ~ ~
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de s c.i.i. s.ed.' on".th.e' te s't.'.f.o.r.i.il,. thit.. da t.e(b..) was, f ar tm:g
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,than date(a).fromaQA' standpoint,andgivena'preprintd.TVA'wideform....
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- with a. space for one date only and.which 'the site wais unab.l.e'to' modify,.
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'.tliat'the clear and logical choice of the date to..re.cor.d.,.w.a.s't.he-effective date of the action described'on the record and.no; the date of l
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.the formalization of the record.
I further attempted to verbally " walk, ~.c.*
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' them through" the whole process of testing welders and recording the results of those tests.
I further showed them the Sequoyah Construction
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Procedures concerning the testing of welders and the preparation of test.
records; including the provision within those. procedures for the weld test supervisor to fill out what was a temporary notice-to the welder's g
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..,.' J'f.. foreman which gave permission to the,fcreran to employ the welder in t e
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.:. performance of welds using th.e newly-passed quallfication prior to the Issuance of the typed, signed final record of the test..I explained that. -
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'. 'If the.date recorded on the form had been the date of the form's
' signature, then these would exist a number.of welds with dates.of welding,
' i' which were prior to the recorded.date of qualification for the welder..I
.also pointed'out that'the welde'r's perlo'd for continuity welding begins with the'date he performed his qual'1fication ' test and if the date of.
signature was used, then the require'd period for continuity' welding could.
be exceeded by the amount of;1ag time.between performances of the test '
. eld and the procei; sing of the. paperwork.cThis period, as I told QCI w
.peop1.e, was typically.7-10 days, but.at.. peak. periods.may wel.1.have been
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.s I.also.poin.ted out..that,to my' knowledge,.,.
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.... considerably longer than that...
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I d.'"~~ N.' he'p'ra'ctice'of ditin'g theitest reco'r'd illh,2the'effectiv.e date of the
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.g;,%& ;tes t was.' uni:versally the' practice. the.
. d.now tri.IVA and.I..fel t that.It..
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ih.,f.i3%4.$aYiNMi.Iidli~dlis'Wy3 fa' @r$NaTT S PIW','.:.'.Othlflj,j.in' f act.,'. t. he Elk.dus try.'.s.. tin'dard; ii.ased oifla' conv'er
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l"'. -lwith Bechtel's weld 6r record ' auditor, YThe'Helder Qualification Test t
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, : record.f.orm.in the A5(IE Code (QH-484).has only one ifate sp. ace on 1t and
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This explanation was..
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..this for is used throughout the welding'In.dustry.
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very lengthy on my part.
I.gave them plen'ty of chances to iuestion what' l
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.I was was telling and showing.them and felt that I, h'ad le'f t'no stone,. '
unturnedinmyattempttoalifytheirsuspicionsrelativetothese 4 y.n.v Following this expla ation, they expressed to me-that I did not records.
I considered have any way of proving that Wha't I said was the truth.
this to be an accusal that'I was lying.to.them.
I agreed that I was f
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. Y. ' i,E unable to prove to them that the date.on the test form was the effuctive.
.T.date of the test and not the date of the signature, as this was not specifically spelled out in any procedure..Even af ter 1 pointed out that
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the date on the form was typed by the s'ecretary and not handwritten, as
. ' ' ' was the signature, the QTC employees continued.to insist that.the date on
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..the form was the dat.e the form had.been signed.
I stated that.'sl.nce.I.-
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.' had signed many of th'ese forins'l 'could say,for sure that simply was not true!
They indicated that'all QA'. rec 6rds should'have' dated signatures and that since the form.was a QA record and had,a s.lgnature and a date n
.then it followed that the date.was'the date of the signature, and that
.the only conclusion they could. draw was that these~wer.e defective.
...,'. At approximately' this'. point. in o'ur.discuts'.lons Twl.ilch.t.o this.. time ha'd, N
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...7.? seemed to me.to.h.a.ve.11.ttie;or'.no desi.re. to verify;.that:th.e record was,in.,. c:.:...
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'kakdNIcIk$Ej N *Cdy'por.Hfdl.i p6.Vionb IVed 'no'tIoii?.Nia t '.ibne. ani[e[oh f. oui deedIhai.'. N- ).[.d
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.:been committed with. regard.to~these. records..
,In.a' final attempt to make'
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i these two people' understand that these records wer,e( a.s 1.had represented I
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them.tobe,I'offeredto.t'ake.lthemtosee'.tw6dtherknovledgeableweldIng,*,s' :. [-
engineers who might be able to shed some additional light on.the
- f. subject..They agreed to discuss this with them when I explained.that.
both parties were at Sequoyah in the welding unit at'the time these records were generated and were. knowledgeable about these records.
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explained that one was a 50-4 in charge of welding inspectors at the time
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who.later became a welding unit supervisor and the other was in fact.the.
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' test supervisor of the test in question aiid issue'd the test numbers and filled out the original shop copy of,the. test report.
i further
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explained that both were now no' longer lIn Nuclear Power o Construction J-and should be more unblased than I was.
QCT's.. discussions,wlth these Individuals resulted.in the Investigators being. told exactly the'same... .
th.Ing about the dates and th4 forms that I,had told them.
Namely that the date on the form was the effective date of,the action expressed on
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'.the form, that the date.was supplied by the.pe.rson who took t.he action' explained on the form (14 eld Test. Supe.rvisor,'.o'r other pe.rsons' In the' case ".'
.ualification)'.and was supplied by that person to 7
,of' award of equivalent q
.the. secretary who typed it on'th'e f'orm;,and it.had'nothingiat'all to'do.
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i wi. th.the date which t..he. uni t supi.rvlior of h.ls de. si.gne.e -(n.ot th.,e' T.est.'.
Again',QTCjer, son.nel..,.,9';
J"'.b[.J.*! Supervisor)ac'tuallysignedtheI,inishedcopy',
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.. : -expressed.the.Ir. preconceived conclusion that this date.wa.s.the dat.e of../
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.m$.::..u*MeWere 's6rry)m.i.a.:t..th.ey]pe r.' son. al..l.y di d.n,o. t. l li.se..'.T.V.A's H.6]
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F.or.m 'but that was the forni tha t we h. ad 'to wo'rk'.wl. th 'an. d"t.h. a.'t.we. had done' '..".
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- th.e best job we could with that form and that these recofds. lh i ue.stion
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were.true, appeared to us.as knowledgeab1' aiid.reas.onable' engineers t'd.'be
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ac.ceptable and did not appear to us to have any; sign tha.t they were not..
. acceptable in any way and that.these conclust'ons were. easily reachable by...,.:..
any other knowledgeable. reasonable Individuals.
1 After this discussion and the departure of the QTC Investigators the i
three of us (TVA employe.es) discussed.these p,roceedings and it.was
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i 4.,,kk. i apparent to me that we all,relt. that these people were not knowledgeable,
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- - ' did.not appear to be reasonable,,did not appear.to be. attempting to determine.lf the records in question.were acceptable but, in fact, seemed
. to have the preconceived notion that the records were faulty and were dead set against accepting any reasonable. evidence contrary,to that
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notion.
It seemed to me tha.t we ;all felt that these Individuals were
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, attempting 'to create 'a positiori that our' entire welding quallfication.
program was totally flawed'and unheceptable, even though they had no evidence.that was the case.
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,At this point, I.wlil.attemp.t to'reconstructifrom my memory the general',.
nature of the 'three' documents'.whichwe.di scussed..'
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.' Document No..I was a'Perf.ormancs' Qual'lficatl'on Recor.d fo.r:the.Helder'.
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. showing the, accep.tabl.e, passing; of..a GT.-SH, performan.ce, test. on 5-il.-XX;..r,
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.. Document'No.' 2 was.'a revocation. noti.ce of[the tertlfication, from document :.
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No.'1.'due to. lack of welding sith SH process.l,.Thls document No.' 2'was',
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.. dated in the month af ter 180 days beyond the 'date of document: No. I and * -
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wasf somewhere near.12-16-XX (again, I. don' t 'remeinber the. year, Jand this. .
.date may v.ary by a few days)..This document'No.J.2 stated that the revocation was effective 11-11-XX (180 days'after document No. 1).
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Document No. 3 was an award of an equivalent qualification for-the GT portion of the GT-SM heavy wall.tes.t which was, des.cribed in document No.
3,.
I and revoked by document No. 2.
The body of the document stated that 1
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- ,[,1 this. document covered the granting of GT'only, light wallpipe test,
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equivalent to the GT. portion of a.GT-SH heavy wall pipe test passed i
5-11-XX and revoked by letter dated.12-16-XX (approximate date),
effective'Il-11-XX. Document No; 3 was' dated to show it being effective
'l l-I I -XX.
This date is consistent with the body of document No. 3 and
. '.. - the issue date and effective.date'of. document No. 2 and Is also "
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consistent wl'th the effectl N date of document No. 1; these facts are obylous to even the. casual observer and, had the,QTC personnel been knowledgeable, reasonable, and attempting.to. determine the_true validity.
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Ioftheemployeeconcern,'Itwould'have'beenobvioustothem.
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s The'. discussions I held with QTC's ' investigators lasted 'f rom, early in the. ' '
morning untt1 Nell past'.luri~ch time'..They er.e,vsry.,tr.ying and,
. ' ' -:,'[;.throughoutthem,IhadthedistinctimpressionthatIwas.dealingwith
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',. two' individuals whc! did not kno.w. eno. ugh.about wha.t'the.y were..
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nvet tfga fTn%e.t'o':
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Understand:
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djode,1 t[s I.on,,E i,o.ji d ',no t. s e erii,tp,'nie.' to, h.e, w1 i1.1.ng'," to fa
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, ". '.. '.. input,'and who'.were obylously attempting to. escalate'an acceptable set'of'.
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- self-explanatory'. records into a conddmnation of.'.TVA's enti,r.e welder
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,.. p These Individualsiere unhble,to ai:ce6t 'the facli,
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... qualification program.
that welder performance qualification is governed by a " rolling code,".
.ASME Section IX, and who drew the erronlous conclusion,'that since TVA did not qualify their welders to a particular year and addenda of the code, that our entird program was faulty. Anyone who has a working
' knowledge of the code's position on code revisions and welder pp6 -
', ' qualification knows this.to be. the casefthe accepts the codes. stated l,
position that welders are quallfled under whatever rules are in effect at.
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- '.,,.' '. -the time that, the welders are tested and 'that thelr. qualifications remain,.*l
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., as they were when the tests were performed no matter what changes the 1
These individ,uals were code may undergo after the date of testing.,
unable to accept that posttion even tho' ugh that posttion Is' accepted throughout the welding industry.
ReadingofQTC'[sreportonthisconcern,;
shows thelr. lack of. knowledge about.this vital point. -
Also, and, to me, most important k., one determines from reading t, heir report that the dates on the welder qualification records are the dates o'f the signatures on the. records. ITHIS.ISABSOLUTELYFALSE,'and'It'was;.
.the entire point that we were attempting'to convey to them during an from i eading the.lF -
., ex. tended and apparently vain discussions. 'Fu'rtherg
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i report, we can[ conclude.'thht we,tol.d:them:th.e da'tes,wer.e s.lgnat~ure ".,,
',. dates--nothing Is ' f artt 3r from the truth! -
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lit ch they hk'vi're,hedainth.e'l.'r4spoIt are 'n.6t'Vh11d.and / ~..... -
f t.6'Anh. ih,,..s. s.3he concI.Utlons$.
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(.. sed..on' incgrre. c. t;. logic a. nd.misconcep,tions;of.t.h.e. re.quir.ements. and '
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.the facts'.
The report contains statements which ar,e.'not true'and, to my.-
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.. knowledge, does not contain the docuinents in.qu.e.s. tion ><hich:woui.d.a.liow 7
th'ereaderto'drawshisownconclusionbased'on.the'evid. enc.e".[jhe. report.l. '.,
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also uses the numbering system employed.for uniquely identifying. test
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I, r.eports and applies. flawed logic to attempt to s'ow'that some."
h hankle-pankle took place. What this number ~ sequence shows, in fact, is
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d that the situation is exactly as we stated to TC, i.e.M(1)'t at the f f.z-.
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dates on the test record were not the dat he records were effective, and (2) that document No. 3,,t.he GT. equivalent test, was awarded at or 4
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.aboutthetimedocunentNo./(thecrigl.naltest'.srevocationletter)was'
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,- Issue,jd and was effective at the date stated on.the bottom of the form and substantiated withl.n the form's body.'
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When I agreed to discuss this matter wit.h.QTC,.I had not previously had
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anysignificantcontact}with,themandwasnotpredisposedto.assumethat they were not fulli on,'the 'Op-and-up,' and.were not attempting to use knowledge'able people t'oldo unblased investigations and to reach reasonable and valid conclusions.
During my' discussion on.this. matter it
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.became apparent to me that all was not'right' wlth' this.opeia. tion. Upon' reflection, I have been forced to conclude,thatlI..was, dealing.with people -
-.'.~.,Jwho were not.sufficiently'tralndd'an'd knowledgeable,and'who seemed t.o'me.
the.r..thap 'the', co' rect conc'.lu.s ton In thl's.
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'.to-be attempting to reach.s.ome 9 r
_Also, upon reflection, I have. concluded.that although I drew
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reejl.1n no9_ eept.ng.;my. opinion :t'.myse1ff and.I lf/.that'hhsi:
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'.[Cf;t[.c$., embarrassment,l,I apologize.fbut.am qlti.c.k.to po.l.ri,t. odt 'thit.the ' report.. ' -
bares out my opinion of. th.e apparent, qual.lficatlons 'of QTC's
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,. Investigators.
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J' When I was first' told of the coriclusion ' drawn',In this report.(last week)..-
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.'.I requested to present.my version of these discussions to the.Interes,ted.
parties.
I was given that opportunity' yesterday and am most appreciative'
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for that.
I met with Joe Rose and Jim Coan of the Helding Project in l
' Knoxville and with the responsible NSRS representative. They listened to 7
, my reiteration of this. discussion which was.as I.previously.have reported
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. ',to you in this report. They were most; receptive of my position.and
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recommended that the corrective actions which HSRS had previously proposed based solely on the QTC report'be. set aside and a new' position
'be drafted.
They readily recognized thi errors,In QT,C's. report when I
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was able to convey to them what I had said to QTC, and they were able.to rely on something other than what'QTC, reported that I and my co.l.l.e2gues
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z had said.
It is unfortunate that I do not have before me the repo.rt or th.e documents in question but, on such'.short not' ice,'I.was una'ble to obtain a i
copy of it and feel certain that.the reco.rds.;ln question will,remai.n in order to'."girotect confidentiality.'". It' occurs 'to' unobtainable to TV
.,,... me that the report conta'l.iis other. majo..r 'errefs, 'which,l'~am u.nable to
.Since it has.been discounted; I expect that any,
. recall from memory.
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n further disection on my part.is wasted effort--something w.e already have.
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' t s-chttoo much of.,.il~ appreciate the oppor.tunity.to;;give you my thougli
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An.lt.his matter and request that shculd.this.repor,t not. full.y satisfy you 1
,that you will give me the. opportunity to discuss it with you.... Unt.11 the'.
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..;!91,',
10th of April, I,can b'e reache'd ht-Bellefonte.Constr,ction,by caII,1.ng u
, Chattanooga, 3274, extention 171.or 172., '
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'.Another major; contention of.the.QTC report'is that.the Helder'Testi '
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Records they reviewed did not show evidence of a "QA Record Review" as required by procedurd and therefore were' faulty.
The records they' reviewed obviously were obtained from the Helder's Personal History
. Record because of the nature of the other records..they reviewed such as
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copy of the records which were sent to the employee's personnel file and were not reviewing the QA record copy.of the. test report. The QA record *
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copies of all welder tests are stored on microf.llm and.show the iequired -.
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evidence of "QA RePord Revi'es."..These records were audited by Bechtel in the Sequoyah Phase II audit and were found to be in complete compliance I
~with all procedural requirements. This. conclusion further p:oints out the-nature of the quality of QTC's report on. this. matter. '.
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WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS I
ATTACHMENT 7 MARCH 31, 1986 MEMORAN30i'.4 TO K. W. WHITT FRON R. G. DOMER J
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'. TENNESSEE VALLEY AUTHORITY K. W. Whitt, Director of Nuclear Safety Review Staff, E3 18 C-K J
R. G. Domer, Hanager of Project Engineering, W12 A5 C-K FROM March 31, 1986 DATE SEQUOYAH NUCLEAR. Pl. ANT--EMPLOYEE CONCERN xx-85-101-006, StlBJECT:
REPORT XX-85-101-006 In accordance with assigned responsibilties the Welding Project (WP) has reviewed the subject concern, the investigation report and the 1
recommendations.
The WP has s'1so made a detailed review of the recently completed independent (Bechtel) audit of the Sequoyah Welding program.
That audit specifically addressed the issues raised in this concern.
The following recommendations and basis for close out were discussed with H. A. Harrison on March 24, 1986.
I Recommended Actions A. B. and C The WP recommends that the three priority I recommended actions, A, B, and C have essentially been accomplished by the Bechtet audit which addressed kN.h welders qualification, maintenance / continuity update and renewal.
While the audit activities were not exactly identical to the recommendations the audit activities were sufficiently comprehensive to provide confidence that It the welding program being implemented was meeting TVA's comunitments..
i is recommended that actions A, B, and C be closed out.
3 Recommended Act ion D It is recommended that the consistency review of construction documents and
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the FSAR has been accomplished for welding by.the WP as part of its Phase 1 That report stated that, the WP has evaluated the welding program program.
and associated quality assurance program elements related to welding (hereinnfter referred to as the welding quality assurance program) utilized by construction during the construction era.
This program adequately addresses the regulatory commitments in place during the construction era at Sequoyah tiuclear Plant.
An, integrated system of corporate level specifications and site implementing procedures was designed (1) to assure commitments and regulatory requirements were satisfied and (2) to that verify that the necessary welding quality was achieved at the plant.
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WP recommends that action D be clo' sed out as regards field welding and related activities.
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2 K. W. Whitt Harch 31, 1986 EllPLOYEE C0tiCERll II-85-101-006, REPORT II-85-101-006 If itSRS concurs with the close out of these open items please respond to If there are the SQtt site director with a
- copy to the WP project manager.
any questions or comments please telephone J. W. Coan at extension 4420.
y R. C. Domer JWC:llJB
- 11. L. Abercrombie, OllP, O&PS-4 Sequoyah cc:
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W. C. Drotieff, W12 A12 C-K L. E. Ilartin, 10B-WBil OtlP J. F. Weinhold, W12 B34 C-K J. W. Conn, W9 C135 C-K D. W. Wilson, OE, DSC-A Sequoyah
- Reviewers Initial /Date YR J. W. Conn JS r fa.:;
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KEY ELEMENIS 4.0, 5.0, AND 17.0 9
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OFFICE OF CONSTRUCTION MAIllTDIANCE OF WELDER OR WELDING OPERATOR OUA Based on audit of welder maintenance records, TVA welders demonstrated welding within certification expiration dates as required by IVA programs and procedures.
KEY ELEMENT 5.0 OFFICE OF CONSTRUCTION RDJEWAL OF WELDER OR WELDING OPERATOR OUALIFICATIONS Based on audit of welder qualification records'and maintenance records welders were requalified in accordance with TVA programs and procedures. TVA In many cases TVA welders were given the original qualification test for renewal which exceed,ed ASME IX and AWS,D1.1 requirements for renewal.
KEY ELD 4DTT 6.0
_ INITIAL HELDIN fl ECTI Sf OUALIFICATIO.'t Qualification / Certification records for nondestructive examination personnel (weld inspection) were reviewed for compliance with TVA NDE personnel qualification procedures covering a time span from January, 1971 through March, 1983.
T TVA personnel qualification procedures used for the qualification /
i edition of Stir-TC-1A (American Society of Nondestructive Records evidencing qualifications and certLE1 cations contained sufficient detail to confirm compliance with applicable codes, standards and specifications in effect during construction activities.
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KEY ELEMENT 17.0_
i OFFICE OF CONSTRUCTION EMPLOYEE CONCERNS-l 17.1 Concern No. XX-85-049-XO3 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 quellflcation q
records from 1970 to 1979.
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Concern No. XX-85-69-001 and XX-85-069-X05 regarding welder certification and on-the-job training. This concern was not.
t involved 124 welder quellfication records from 1970 to 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 co 17.4 l
Concern No. IN-85-476-004 and HI-85-041-002regarding welding i
Inspectors training program." This concern could not be substantiated bbfhI3 as evidenced by audit of training programs.
17.5 Concern No. W1-85-053-004 and XX-85-68-006 regarding unld rod control' audit of a random samp11ng of 48 receivlng docume CHIR'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 rep 572,000 d
against Key Element No.12 of this report la documented against the TVA program, it involves details required by TVA procedures over and t
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 chose from.Fo to each component or ensure the specified material is used by aElther tr control procedure.
the standards and, therefore, did not require traceability to a component.
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(continued) 17.6 Concern No. XX-85-054-001 regarding weld inspection by craft concern was not substantiated by the gudit of 13. Inspectors pulled This from the weld history records for the welds reviewed in the audit a well as by an additional random sampling of 13 inspectors.
s holdpoints were found to have been signed off by anyone other than No certified inspectors.
This concern may be referring to structural welds instead of piping
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Structural welds and piping have different code requirements for fit up and final inspection.
procedures for structural welds.No holdpoints are esquired by the TVA 17.7 Concern No. EX-85-039-001 regarding weld control (stubs and unused' rod).
This concern was not substantiated by the audit of applicable procedures.
A daily surveillance program was maintained which welded and the procedure being used. Included verification of w Vailables from the procedure '
the procedure properly.(such as amperage) were verified to assure th
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Welding rods, ovens and controls were monitored to assure that the welder had requested the proper rod, was issued the proper rod, and was using the proper rod.
300 surveillances a month were performed during years of peakApproximately construction.
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HAINTDfANCE OF WELDER OR WELDING OPERATOR OU 4
Based on audit of welder maintenance records, TVA welders demonstrated welding within certification expiration dates as required by TVA pro and procedures.
grams KEY ELEMENT NO. 5.0 NUCLEAR OPERATIONS RDIEWAL OF WELDER OR WELDING OPERATOR OUALIFICATIONg Based on audit of welder qualification records 'and maintenance records welders are requillfied in accordance with TVA programs and procedures
. TVA KEY ELDIENT 6d NUCLEAR OPERATIONS INITIAL HELDING INSPECTION PERSONNEL OUALIFICATICNS C
All inspector qualification records (NDE, to include visual examination) audited indicated compliance with TVA programs and procedures and the referenced codes and standards.
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TVA Form 6780 (as referenced in procedure 0202.14)
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qualification and" certification does not clearly identify theused to document NDE..
recertification status of the individual.
o Additionally, certification when Individuals are actually certified in accordance requirements of Procedure i-Certification Program for NDE Personnel.0202.14 (formerly N75C01), Qualification Program clarity and definition could be improved by adding either the certification expiration date or recertification status as an entry on l'or 6780.
Specific reference to Procedure n
0202.14 would provide for direct reference and compliance with TVA NDE person ce qualification. certification requirements and practices for each NDS met onnel employed.
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L OFFICE OF flUCI. EAR OPERATIO IS 17.1 Concern No. XX-85-049-X03 and XX-85 101-006 regarding welder certification.
This concern was isot substantiated by the audit of a random sampling of 2J, welders which inyolved.107 welder qualification records from 1972 to 1985.
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 25 welders which involved 107 welder qualification records from 1972 to 1985.
17.3 Concern tio. XX-85-108-001 and XX-85-108-002 regarding weld inspections.
This concern could not be substantiated as evidenced by audit of a minimum of 14 inspection procedures.
17.4 Concern !!o. 111-85-476-004 and WI-85-041-002 regarding welding inspectors training program. This concern could not be substatlated as evidenced by audit of training programs.
17.5 Concern tJo. W1-85-053-004 and XX-85-68-006
.n satisfying code requirements.
regarding ueld rod control This concern was not substantiated by 4'dA audit of a random sampling of 25 receiving documents and associated CUTR's which involved 25 heat and/or lot number, 6 different types of weld metal covering the years 1976 to 1985. This represents appro:cimately 19,000 pounds of weld filler metal.
The statement in the concern shows a lack of understanding of the code.
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to each component or ensure. the specified material is,used by a i
's control procedure.
TVA's program required that all the material meet the standards and, therefore, did not require traceability to a component.
17.6 Concern No. XX-85-054-001 regarding weld inspection by craft. This L
concern was not substantiated by the audit of 4 inspectors pulled from the weld history records for the welds revleued in the audit as well as by an additional random sampling of 10 Inspectors.
Ho holdpoints were found to have been signed off by anyone other than certifled inspectors.
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This concern may be referring to structural welds instead of piping.
Structural welds and piping have different code requirements for fit up and final inspection. No holdpoints are. required by the TVA procedures for structural welds.
17.7 Concern No. EX-85-039-001 regarding weld control (stubs and unused rod). This concern was not substantiated by the audit of appilcable procedures. A surveillance program is maintained which included verification of welder identification, the feature being welded and, the procedure being used. Variables from the procedure (such as i
amperage) are verified to assure that welders are using the procedure' properly.
Welding rods, evens and controls are monitored to assure that the welder has requested th' proper rod, was issued the proper s
rod, and is using the proper rod.
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