ML20214G997
| ML20214G997 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 12/20/1985 |
| From: | Alexander M, Harwell E, Sauer R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082840729 | List: |
| References | |
| I-85-776-SQN, NUDOCS 8605290632 | |
| Download: ML20214G997 (16) | |
Text
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f TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. I-85-776-SQN EMPLOYEE CONCERNS:
XX-85-108-001 IX-85-108-002 i
SUBJECT:
SOCKET WELDS NOT INSPECTED i
I DATES OF INVESTIGATION:
NOVEMBER 18-26, 1985 LEAD
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u C-INVESTIGATOR:
C.
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/7[8I E.[.HARWELL DNfE /
J REVIEWED BY:
Ab N 7 8T M. W. ALEXANDER DATE APPROy,ED'BY:
/2-[20 [85
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R. C. SAUER DATE I
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BACKCROUND I
A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine.the validity of two expressed employee concerns as received by the Quality Technology Company (QTC)/ Employee. Response Team (ERT).
The concerns of record, as summarized on the Employee Concern Assignment Request Forms from QTC and. identified as IX-85-108-001 and XX-85-108-002, respectively, stated:
Sequoyah:
C/I states welds in Unit #1 accumulator rooms and/
or fan rooms were never inspected. Timeframe is nine or ten years ago. Welds on 2" stainless steel (socket welds) and hangers on the radius pipe in those areas.
C/I has no addi-tional info.
Sequoyah:
Programmatic breakdown on the weld inspection proc-ess.
Nine or ten years ago C/I states that some welds on 2" stainless steel socket welds were not inspected as required.
C/I has no additional info.
Since both concerns dealt with 2" stainless socket welds in the same timeframe, it is assumed that the two are related and will be addressed in a single investigation.
II.
SCOPE A.
The scope of this investigation was determined from the stated concerns of record to be that of two specific issues requiring investigation.
1.
The construction weld inspection program was inadequate nine or ten years ago and did not assure that all stainless steel socket welds were inspected as required.
2.
Specifically, welds on 2" stainless steel (socket welds) and hangers in unit 1 accumulator and/or fan rooms were not inspected by the construction organization nine or ten years ago.
JB. To accomplish the investigation, NSRS reviewed construction procedures and instructions related to weld inspection requirements and documentation at the time of interest of this concern (1975-76) and subsequent procedures and instructions. A review of mechanical drawings and flow diagrams for unit 1 was performed to determine what piping is present in the accumulator and fan rooms.
A review of weld map isometrics of those systems in the area of interest were performed to determine weld map numbers. A review of the weld report computer printouts was then performed for these weld maps.
A random review was performed of individual weld data sheets or computer data cards.
Interviews were conducted with personnel having knowledge of inspection requirements during the concern timeframe (such as inspectors, mechanical engineers, welding engineer, and a QC records clerk).
l 1
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SUMMARY
OF FINDINGS A.
Requirements and Commitments 1.
ANSI Standard D31.7 (1969) and 1970 Addendum - Nuclear Power Piping - Governed installation and inspection requirements for Sequoyah Safety Class A, B. C, and D piping systems.
2.
ANSI Standard B31.1 (1967) - Power Piping - Governed installation and inspection requirements for Sequoyah Safety Class G and H piping systems.
3.
10CFR50 Appendix B - Basis for QA program utilized at Sequoyah.
4 SNP FSAR Section 3.2.2, " System Quality Group Classification (Fluid Components)."
B.
Findings 1.
References 11, 12, and 13 define the governing codes and safety classifications for various structures, components, and systems at SQN.
From these guidelines, the drawings for various systens and structures identify the safety class (es) for design and installation.
2.
References 1 and 3 defined the welding and nondestructive testing (NDE) requirements for various safety classes and configurations. For each weld to be performed on a safety class system or structure, an attachment A fecm these procedures (which defined the appropriate welding and NDE requirements) was to be filled ut by a cognizant individual.
3.
Until 1977, all welding and subsequent NDE activities were documented on Attachment A (Weld History Record)) of reference 2.
4.
In 1977, Sequoyah instituted the use of a universal computer program to monitor inspection and test status during the construction of the plant. Every uniquely identified weld joint was entered into the program. At this same time, weld records were changed to computer cards for each required operation, such as fit-up, visual examination, liquid penetrant examination, etc.
5.
From interviews with various knowledgeable personnel who worked at Sequoyah during construction, all safety class A, B, C, and D welds were required to be inspected and documented in accordance with procedures and instructions.
These individuals reported that class E and G socket welds were visually examined and logged but that no QA documentation was prepared.
6.
In order for a particular weld joint to be designated acceptable, a reference 2. Attachment A (Weld History Record),
and/or all weld record computer cards had to be completed, 2
l 1
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reviewed, and accepted by the QC Records Unit for storage as a permanent plant record in accordance with the requirements of references 7 and 9.
7.
Input to the universal program required that incomplete or missing inspection documentation be reconstructed if adequate supporting documentation was available or the item was reinspected in accordance with the requirements of reference 8.
8.
A review of the universal computer program printout for those piping systems within the unit 1 accumulator and fan rooms revealed that the above documentation system was utilized for class A, B, C, and D socket welds and that required socket weld inspections had been performed and the results were acceptable.
Class E cr G welds were not tracked en the computer program.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Ucither employee concern of record could be substantiated for the following reasons:
1.
The universal computer status system required '. hat all documentation be present before the system could be transferred to Nucicar power. Any safety class welds that were not examined prior to the utilization of the universal program would have been examined at a later date to meet QA record requirements.
2.
The construction instructions and procedures in place at the time of the concern did require inspecticns and documentation; therefore, an adequate program was in place. However, the use of the universal program provided a better method of determining the present status of any weld and what remained to be done.
Although the universal program provided a more positive means of preventing oversights, the old manual system could have provided the same assurance but by a much more laboricus method.
B.
The concerned individual (CI) may not have been aware of the changes made later in the weld documentation tracking program.
In addition, the CI may not have been aware that class E or C welds did not e
require the same level of inspection as class A, B, C, or D welds.
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DOCUMENTS REVIEWED IN INVESTICATION I-85-776-SQN AND REFERENCES 1.
SNP Construction Procedure M-3, Rev. 2, dated May 1, 1975, " Welding f
Surveillance and Weld Procedure Assignment" 2.
SNP Construction Procedure M-7, Rev.14, dated November 19, 1976,
" Erection and Documentation Requirements for Piping Systems" 3.
SNP Construction Procedure M-20. Rev. 3, dated December 15, 1975,
" Pipe Support Installation and Documentation" 4.
SNP Construction Procedure W-3, Rev. 3, dated December 4, 1978,
" Weld Procedure Assignment and Welding Surveillance" 5.
SNP Inspection Instruction No. 63, Rev.13, dated May 20, 1983, " Piping Inspection" 6.
SNP Inspection Instruction No. 66, Rev.16, dated March 1,1983,
" Inspection of Supports" 7.
SNP Construction Procedure No. P-8, Rev. 10, dated August 24, 1976,
" Quality Assurance Records"
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8.
SNP Construction Procedure No. P-8, Rev.16, dated February 17, 1983 4
9.
SNP Standard Operating Procedure No. 550, Rev. O, dated December 14, 1977, " Review of Qualiy Assurance Records" 10.
SNP Construction Procedure No. P-24, Rev. 4, dated March 28, 1980,
" Inspection and Test Status" 11.
SNP Final Safety Analysis Report, Section 3.0, Design Criteria -
Structures Components, Equipment, and Systems 12.
tte General Design Criteria, SQN-DC-V-3,0, Rev. O, dated December 12, 1975, " Classification of Piping, Pumps, Valves, and Vessels" 13.
SNP Construction Specification N2M-865, Rev. 3, dated April 12, 1977,
" Field Fabrication. Assembly Examination, and Tests for Pipe and Duct Systems" i
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EMPLOYEE CONCERN ASSIGNMENT REQUEST TO: Director - NSRS TRANSMITTAL NUMBER TSO175 ERT has received the Employee concern identified
- below, and has easigned the indicated category and priority:
Priority: 1 Concern # XX-85-108-OO2 7-?>$- T I - SGV Category: 33 Confidentiality:
_YES
_NO (I&H)
Supervisor Notified: ___YES _X_NO NUCLEAR SAFETY RELATED YES J
Concern:SEQUOYAH:
PROGRAMATIC BREAKDOWN ON THE WELD INSPECTION i
PROCESS.
NINE OR TEN YEARS AGO C/I STATES THAT SOME WELDS ON 2
l STAINLESS STEEL SOCKET WELDS WERE NOT INSPECTED AS REQUIRED.
CONST.
DEPT. CONCERN. C/I HAS NO ADDITIONAL INFO.
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NOY MANAGER,,d ERT DATE 1
NSRS has easigned responalbility for investigation of the above concern
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to:
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ERT ___
NSRS/ERT _____
NSRS _. /
OTHERS (SPECIFY)
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NSRS I
DATE 1
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WELDING PROJECT SON SPECIFIC EMPLOYEE CONCERNS DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMA'Y OF WP ENGINEERING EVALUATION R
CONCERN CONSIDERED: XX-85-108-002 PREPARED BY
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REVIEWEDBY,A2w*ze/
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FtB / # /i1 CEG-H, Welding APPROVED BY h - 7,M '
/I'f'06 Program Manager 6
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This pact. age.uo,our i c ea the acttune t al.en by the Welding Project (WP) to evaluate and d i s.p os,i t i on the s.ub i ec t SOll-spec i f i c employee concern which was previously evaluated by NSr.5/OTC/ERT and cummarized in WP Phace I and Phase II reports.
s The Welding Project analyzed each SOM-cpecific employee concern (Attachment 2) to determine the statement (s) being voiced by these individuals.
l These statement were then evaluated both individually and collectively to develop istues.
Each issue was then incorportated into the WP review activities of Phase I,
" '.rocedur al Accestment" and Phace II, " Procedural Implementation."
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Du) ring Phase I, each issue was analyzed against requirements of the applicable OA program, policies, NSRS/OTC/ERT Inveutigation Reports, and other relevant i
L information to determine if program elements were deficient when evaluated i
I against upper tier requirements.
Phase II consicted of a sample reinspection of hardware and independent program audit by Bechtel.
In each area analyzed by Bechtel, the auditors found no objective evidence to cubetantiate the employee concerns concidered. The following areas directly related to employee concern were inveutigated by the audit team:
0337I Page 1 of 3 I
h
1.
Welder qualification and attendant records 2.
Welder qualification and attendant on-the-job-training 3.
Welding inspections 4.
Welding inspectors training programs 5.
Weld material traceability 6.
Welding inspections by craft personnel i
i 7.
Weld material control 7:
l Each of these areas was investigated by the auditors for both construction and operations phases.
In all cases, there was no objective evidence to l
substantiate the employee concerns. The audit report concludes that both l
construction and operations 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.
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The results of the reinspection program at SQN also give another, additional verification of the Welding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the accuracy and implementation 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 analysis of SQN Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed components and systems, and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified
}
through the Employee 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 su= mary analysis of the WP evaluations and recommendations is included in.
1 a
Pg 3 f3 0337I 5
Page 1 of 3
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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 ERT 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.
XX-85-086-003 Box Anchor Design Substantiated by NSRS Report Deficiency.
I-85-560-SQN (Attachment 3).
WP concurs with report recommendations.
XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS 5"
Rejected NDE Items Report I-85-738-SQN (Attach-
[
ment 3).
WP concurs with i.
report recommendations.
SQM-5-001-001 Uncertified Wolder Foreman Substantiated by WP Evaluation i
SQM-5-001-002 Performing Preweld Report WP-16-SQN (Attachment WBM-5-001-002 Inspections 3).
Interim corrective (Also Listed in actions are being the Generic formulated.
Closure is f
Summary) based on these actions.
Additional corrective actions may be implemented.
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS f
Piece REPORT I-85-636-SQN (Attachment 3).
XX-85-069-001 Inadequate OJT-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for NO inadequate OJT-records was XX-85-069-X05 substantiated by NSRS Report XX-85-069-007 I-85-373-NPS (Attachment 3).
No falsification of records was substantiated.
WP con-curs with report recommon-dations.
05640
I Page 2 of 3 i
EMPI.0YEE CONCERN NUMBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was SQM-6-005-X02 Making Proper Welde substantiated; SQM-6-005-X02 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 This is an acceptable E316 Steels practice.
ERT investigated in ERT Report XX-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
XX-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
XX-85-049-001 Welder Certifications XX-85-049-001 was
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XX-85-049-X03 Updated Without Meeting substantiated as it relates Requirements to Welder Continuity Require-ments. This had previously been identified by NO in an audit. XX-85-049-X03 was not substantiated. Details and recommendations are given in NSRS Report I-85-135-SQN (Attachment 3).
WP concurs with I-85-135-SQN-01 through
-03 and recommends they be closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).
XX-85-054-001 QC Holdpoint Sign-Off Not substantiated by NSRS Violation Report I-85-346-SQN (Attachment 3).
XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Inspections Report I-85-750-SQN (Attachment 3).
05640
Dage 3 of 3
~e EMPLOYEE CONCERN NUMBER ISSUE WP 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 Not safety-related. Not Condenser.
This issue is substantiated by WP Evaluation also on the Generic Summary Report WP-18-SQN (Attachment 3).
XX-85-100-001 Improper Wold Repair on an Not substantiated by ERT Undetermined Number of Report XX-85-100-001, dated Welds 3/5/86 (Attachment 3).
XX-85-101-006 Welder Certification for ERT Report XX-85-101-006 the Construction Era (Attachment 3) with NSRS Recommendations indicates
("" '
that this concern is sub-stantiated.
WP takes excep-tion to this ERT Report based on subsequent information provided in Attachment 4.
WP exceptions, recommen-dations, and basis for closure were discussed with NSRS as documented in Attach-ment 5.
WP recommends this concern not be substantiated 5
and that it be closed based on the WP-Bechtel Impicmen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachment 6).
XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS Notice of Indications for Report I-85-735-SQN Preservice-Related Defects (Attachment 3).
XX-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS XX-85-108-002 Report I-85-776-SQN (Attachment 3).
(W 05640
f rage i ut a 11/04/86 (EMPLOYEE CONCERNS)
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11:28:22 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10
CONCERN-----
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P7 SR XX-85-108-002 i
WORDS:
INSPECTION IMPLEMENTATION NONSPECIFIC PROB: WCPIF SEOUOYAH: PROGRAMATIC BREAKDOWN ON THE WELD INSPECTION PROCESS. NINE OR TEN YEAHS AGO C/l STATES THAT SOME WELDS ON 2"
STAINLESS STEEL SOCKET WELDS WERE NOT INSPECTED AS REQUIRED.
CONST. DEPT. CONCERN.
C/l HAS NO ADDITIONAL INFO.
IR: 1-85-776-SON STAT:
RC:
TECHNICAL COMMENTARY:
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WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS ATTACHMENT 3 NSRS REPORT I-85-776-SQN
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L*NITED STATES GOVERN?.!ENT
\\f' Memorandum TENNESSEE VALLEY AUTHORITY TO H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FROM
- K. W. Whitt, Director of Nuclear Safety Review Staff. E3A8 C-K
'.M P Q '7 *Qpi?
J DATE
- ~-
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL Transmitted herein is USRS Report No.
I-85-776-SON Subject SOCKET WELDS NOT INSPECTED Conceen No.
XX-a5-108-001 and xi.-r53 rive-vvs No response or corrective action is required for this report.
It is being transmitted to you for information purposes only.
Should you have any questions, please contact R. C. Sauer at telephone 2277 (r -
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l Reco:: mend Reportability Determination: Yes No I
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1 rector, NSRS/ Designee RCS:JTH j
Attachment
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f ec (Attachment):
Jim W. Conn, WBN P-104 SB-K R. P. Denise, LP6N35A-C R. J. Griffin, SQN E-18 G. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C li J. H. Sullivan, SQN W. F. Willis, E12B16 C-K (4)
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TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW ST/tFF NSRS INVESTIGATION REPORT No. I-85-776-SQN EMPLOYEE CONCERNS:
XX-85-108-001 XX-85-108-002
SUBJECT:
SOCKET WELDS NOT INSPECTED
^
DATES OF INVESTIGATION:
NOVEMBER 18-26, 1985
/
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/78I INVESTIGATOR:
.M./
/
f E. (f. HARWELL DNfE /
REVIEWED BY:
/7[/7/87 M. W. ALEXANDER DATE APPROV,ED BY:
/2-[Zo[83 R. C. SAUER DATE Asc5296T3Q XR
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I' I.
BACKCROUND g.
A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of two. expressed employee concerns as received by the Quality Technology Company (QTC)/ Employee Response Team (ERT)'
The concerns of record, as summarized on the Employee Concern Assignment Request Forms from QTC and identified as XX-85-108-001 and IX-85-108-002, respectively, stated:
Sequoyah:
C/I states welds in Unit.(11 accumulator rooms and/
or fan rooms were never inspected. Timeframe is nine or ten years ago.
Welds on 2" stainless steel (socket welds) and hangers on the radius pipe in those areas.
C/I has no addi-tional info.
Sequoyah:
Programmatic breakdown on the weld inspection proc-ess.
Nine or ten years ago C/I states that some welds on 2" stainless steel socket. welds were not inspected as required.
C/I has no additional info.
p Since both concerns dealt with 2" stainless socket welds in the same timeframe, it is assumed that the two are related and will be addressed in a single investigation.
II.
SCOPE A.
The scope of this investigation was determined from the stated i
[.
concerns of record to be that of two specific issues requiring
(
investigation.
1.
The construction weld inspection program was inadequate nine or i.
ten years ago and did not assure that all stainless steel socket g
welds were inspected as required.
t l
2.
Specifically, welds on 2" stainless steel (socket welds) and hangers in unit 1 accumulator and/or fan rooms were not l
inspected by the construction organization nine or ten years ago.
\\
,B.
To accomplish the investigation, NSRS reviewed construction procedures and instructions related to weld inspection requirements (j
and documentation at the time of interest of this concern (1975-76) ji-and subsequent procedures and instructions. A review of mechanical drawings and flow diagrams. for unit 1 was performed to determine what piping is present in the accumulator and fan rooms. A review of weld map isometrics of those systems in the area of interest were performed to determine weld map numbers. A review of the weld I
report computer printouts was then performed for these weld maps. A random review was performed.of individual weld data sheets or
}
computer data cards.
Interviews were conducted with personnel having knowledge of inspection requirements during the concern timeframe (such as inspectors, mechanical engineers, welding engineer, and a QC records clerk).
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SUMMARY
OF FINDINGS
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A.
Requirements and Commitments 1.
ANSI Standard B31.7 (1969) and'1970 Addendum - Nuclear Power Piping - Coverned installation and inspection requirements for Sequoyah Safety Class A B, C, and D piping systems.
2.
ANSI Standard B31.1 (1967) - Power Piping - Coverned installation and inspection requirements for Sequoyah Safety Class C and H piping systems.
3.
10CFR50 Appendix B - Basis for QA program utilized at Sequoyah.
4 SNP FSAR Section 3.2.2, " System Quality Group Classification i
(Fluid Components)."
a
~
B.
Findings 1.
References 11, 12, and 13 define the governing codes and safety
+
I classifications for various structures, components, and systems at SQN.
From these guidelines, the drawings for various systems l
and structures identify the safety class (es) for design and installation.
)
2.
References 1 and 3 defined the welding and nondestructive testing (NDE) requirements for various safety classes and configurations. For each weld to be performed on a safety class system or structure, an attachment A from these procedures (which defined the appropriate welding and NDE requirements) was 4 to be filled out by a cognizant individual.
3.
Until 1977, all welding and subsequent NDE activities were documented on Attachment A (Weld History Record)) of reference 2.
1 4
In 1977, Sequoyah instituted the use of a universal computer program to monitor inspection and test status during the l
construction of the plant.
Every uniquely identified wald joint j
was entered into the program. At this same time, weld records f
were changed to computer cards for each required operation, such 2
as fit-up, visual examination. Tiquid penetrant examination, etc.
f S.
From interviews with various knowledgeable personnel who worked at Sequoyah during construction, all safety class A, B C, and D welds were required to be inspected and documented in accordance with proceduros and instructions. Thesa individuals reported that class E and G socket welds were vibJally OXamined and l
logged but that no QA documentation was prepared.
f 6.
In order for a particular weld joint to be designated acceptabic, a reference 2, Attachment A (Weld History Record),
and/or all weld record computer cards had to be completed, s-2 1
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reviewed, and accepted by the QC Records Unit for storage as a permanent plant record in accordance with the requirements of references 7 and 9.
7 Input to the universal program required that incomplete or missing inspection documentation be reconstructed if adequate supporting documentation was available or the item was reinspected in accordance with the requirements of, reference 8.
8.
A review of the universal computer program printout for those piping systems within the unit 1 accu =ulator and fan rooms revealed that the above documentation system was utilized for class A. B, C, and D socket welds and that required socket weld inspections had been performed and the results were acceptable.
Class E or G welds were not tracked on the computer program.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Neither employee concern of record could be substantiated for the following reasons:
1.
The universal computer status system required that all documentation be present before the system could be transferred to Nuclear Power. Any safety class welds that were not examined prior to the utilization of the universal program would have been examined at a later date to meet QA record requirements.
(
2.
The construction instructions and procedures in place at the time of the concern did require inspections and documentation; therefore, an adequate program was in place. However, the use of the universal program provided a better method of determining the present status of any weld and what remained to be done.
Although the universal program provided a more positive means of preventing oversights, the old manual system could have provided the same assurance but by a much more laborious method.
B.
The concerned individual (CI) may not have been aware of the changes made later in the weld documentation tracking program.
In addition, the CI may not have been aware that class E or G welds did not require the same level of inspection as class A, B, C, or D welds.
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DOCUMENTS REVIEWED IN INVESTICATION I-85-776-SQN AND REFERENCES 1.
SNP Construction Procedure M-3, Rev.
2, dated May 1, 1975, " Welding Surveillance and Weld Procedure Assignment" 2.
SNP Construction Procedure M-7, Rev. 14 dated November 19, 1976,
" Erection and Documentation Requirements for Piping Systems" 3.
SNP Construction Procedure M-20 Rev. 3, dated December 15, 1975,
" Pipe Support Installation and Documentation" 4.
SNP Construction Procedure W-3, Rev. 3, dated December 4,
- 1978,
" Weld Procedure Assignment and Welding Surveillance" 5.
SNP Inspection Instruction No. 63, Rev. 13, dated May 20, 1983, " Piping Inspection" 6.
SNP Inspection Instruction No. 66, Rev. 16 dated March 1, 1983,
" Inspection of Supports" 7.
SNP Construction Procedure No. P-8, Rev. 10 dated August 24, 1976,
" Quality Assurance Records" s
8.
SNP Construction Procedure No. P-8, Rev. 16. dated February 17,
(,
1983 9.
SNP Standard Operating Procedure No. 550, Rev. O, dated December 14, 1977, " Review of Qualiy Assurance Records" 10.
SNP Construction Procedure No. P-24 Rev. 4, dated March 28, 1980,
" Inspection and Test Status" 11.
SNP Final Safety Analysis Report, Section 3.0, Design Criteria -
Structures Components, Equipment, and Systems 12.
'SNP Ceneral Design Criteria, SQN-DC-V-3.0, Rev. O, dated December 12, 1975, " Classification of Piping, Pumps, Valves, and Vessels" ll 13.
SNP Construction Specification N2M-865, Rev. 3, dated April 12, 1977, lj
" Field Fabrication, Assembly Examination, and Tests for Pipe and
'6 Duct Systems" 8
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t EMPLOYEE CONCERN ASSIGNMENT REQUEST J
TO: Director - NSRS TRANSMITTAL NUMBER T50175 ERT has received the Employee concern identified
- below, and has amalgned the indicated category and priority:
Priority: 1 Concern # XX-85-108-OO2
~.T-ss-7Y1 - scM 4
Category: 33 Confidentiality:
_YES
_NO (I&H)
J Supervisor Notified: ___YES _X_NO NUCLEAR SAFETY RELATED YES j
Concern:SEQUOYAH:
PROGRAMATIC BREAKDOWN ON THE WELD INSPECTION PROCESS.
NINE OR TEN YEARS AGO C/I STATES THAT SOME WELDS ON 2
g STAINLESS STEEL SOCKET WELDS WERE NOT INSPECTED AS REQUIRED.
CONST.
DEPT. CONCERN. C/I HAS NO ADDITIONAL INFO.
g gfUELb~LNbf N COD N
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1 1
1 Y
j MANAGER,/
Z ERT DATE
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NSRS has assigned responsibility for investigation of the above concern to:
ERT ___
NSRS/ERT _____
h NSRS
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OTHERS (SPECIFY)
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NSRS g
DATE
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's TVA EMPLOYEE CONCERNS REPORT NUMBER: XX-85-013-001 i
SPECIAL PROGRAM y
REPORT TYPE: Wolding Project REVISION NUMBER: 1 TITLE: Wold Filler Material REASON FOR REVISION: N/A t
/
5WEC
SUMMARY
STATEMENT: N/A
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t PREPARATION PREPARED BY:
Original Signed By R. M. Bateman 11-06-86 SIGNAIURE DATE (y
REVIEWS PEER:
Original Signed By J. E. Rose 11-06-86 SIGNATURE DATE hkTECHNICACREVIEWONLY TA Offdad ukhd/
yy SIGNATURE DATE CONCURRENCES Ori 'nal Sianed By CEG- : J. FT Lewis for LEM 11-25-86 SRP: ad N I2 2-8d SIGNATURE DATE
(/
SIGNATURE
- DATE 1
APPROVED BY:
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N (/k h l2&?S0 N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) l 1
)
I
- SRP Secretary's signaturo denotes SRP concurrences are in files.
2242T L
WELDING PROJECT g
s' SQN SPECIFIC EMPl.0YEE CONCERNS e
DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
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SUMMARY
OF WP ENGINEERING EVALUATION
!)il CONCERN CONSIDERED: XX-85-013-001 V
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llf(af 80
, DNC, WP
,i eREeARED BY e_> i aEvrEWED BY d.E.Oru n/4/s,co
, DNC. We REVIEWED BY Mr.
//!f# #5
, DQA, WP v
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REVIEWED BY dinue/ k,Ns/w$ ///15/r/, F O B L >I m
. CEG-H, Weldina r
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/a m, program nanager Area 0vED BY e
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Thi s - package nuitar.ari n e the :ctior : tal.eii b f the Welding Project (WP) to evaluate and dicpocition the subject SON-specific employee concern which was
[
previously evaluated by ?!SRS/GTC/ERT and summarized in WP Phase I and Phase II
_ reports.
The Welding ProJoct analyzed each SON-specific employee concern (Attachment C)
-to determine the statement (s) being voiced by thece individuals.
These statement were then evaluated both individually and collectively to develop issues.
Each issue was then incorportated into the WP review activities of Phase I,
,edural Assessment" and Phase II, " Procedural Implementation."
i, During Phase I, each issue was analyzed against requirements of the applicable OA program, policies, NSRS/OTC/ERT Investigation Reports, and other relevant
-information to determine if program elements were deficient'when evaluated against upper tier requirements.
Phase II consisted of a sample reinspection of hardware and independent program audit by Bechtcl.
In each area analy:cd by Bechtel, the auditors found no objective evidence to I substantiate the employee concerns considered. The following areas directly t
. related to employee concern were investigated by the audit team:
i r
0".7,I Page 1 of 3 i
J+r, i
3 I' l
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i 1.
Welder qualification and attendant records 2.
Welder qualification and attendant on-the-job-training 3.
Welding inspections 4.
Welding inspectors training programs f
5.
Weld material traceability 6.
Welding inspections by craf t personnel i
i h'
7.
Weld material control h)
Each of these areas was investigated by the auditors for both construction and i
operations phases. In all cases, there was no objective evidence to I
t.
substantiate the employee concerns. The audit report concludes that both construction and operations phases have had and now have a functioning Welding
]
Quali.ty Assurance Program which meets code, standard, and regulatory
\\
requirements and that the employee concerns considered were found to be unsubstantiated and without technical merit.
Ie Page 2 of 3 j
0337I 1
1
The results of the reinspection program at SQN also give another, additional
'r I
verification of the Welding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the j
accuracy and implementation 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 analysis of SQN Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed components and systems, ij and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified I-l through the Employee Concern Program. The Employee Concern Program has simply j
reiterated problems which have been or are now being resolved through existing i
-}
corrective action programs in the overall Nuclear Quality Assurance Program.
l I
,i l
A summary analysis of the WP evaluations and recommendations is included in.
(
1 l
- E 0337I s
i 1
Page 1 of 3 1
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 ERT 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.
XX-85-086-003 Box Anchor Design Substantiated by NSRS Report Deficiency.
I-85-560-SQN (Attachment 3).
WP concurs with report recommendations.
XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS Rejected NDE Items Report I-85-738-SQN (Attach-
, g,,,,
ment 3).
WP concurs with
{py; report recommendations.
9 Ii.
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 (Also Listed in actions are being the Generic formulated. Closure is Summary) based on these actions.
Additional corrective actions y
may be implemented.
r-I t
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS Piece REPORT I-85-636-SQN g
(Attachment 3).
XX-85-069-001 Inadequate OJT-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for NO inadequate OJT-records was XX-85-069-X05 substantiated by NSRS Report XX-35-069-007 I-85-373-NPS (Attachment 3).
No falsification of records was substantiated. WP con-curs with report recommen-
.. ?
N dations.
05640
Attachment :
Page 2 of :
/
EMPLOYEE CONCERN NUMBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was SQM-6-005-X02 Haking Proper Welds substantiated; SQM-6-005-X02 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 This is an acceptable E316 Steels practice.
ERT investigated in ERT Report XX-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
XX-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
Jin XX-85-049-001 Welder Certifications XX-85-049-001 was XX-85-049-X03 Updated Without Meeting substantiated as it relates Requirements to Welder Continuity Require-ments. This had previously been identified by NO in an audit. XX-85-049-X03 was not substantiated. Details and recommendations are given in NSRS Report I-85-135-SQN (Attachment 3).
WP concurs with I-85-135-SQN-01 through
-03 and recommends they be closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).
XX-85-054-001 QC Holdpoint Sign-Off Not substantiated by NSRS Violation Report I-85-346-SQN (Attachment 3).
i XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Inspections Report I-85-750-SQN (Attachment 3).
y.;
l 05640
Attachmen*.
Page 3 of 3
/
EMPLOYEE I
CONCERN NUMBER ISSUE WP ACTION t
I XX-85-083-001 SQN Weld Inspections not as Not substantiated by NSRS f
Strict as WBN Report I-85-652-SQN (Attachment 3).
[I:
XX-85-098-001 Laminated Pipe in Unit 2 Not safety-related. Not b.
Condenser. This issue is substantiated by WP Evaluation
)
also on the Generic Summary Report WP-18-SQN (Attachment y;
3).
XI-85-100-001 Improper Weld Repair on an Not substantiated by ERT
{r+
Undetermined Number of Report XX-85-100-001, dated d
Welds 3/5/86 (Attachment 3),
dV q
II-85-101-006 Welder Certification for ERT Report XI-85-101-006
%(
the Construction Era (Attachment 3) with NSRS Recommendations indicates that this concern is sub-i
.i(E;4
'C #
stantiated. WP takes excep-tion to this ERT Report based l
on subsequent information J
provided in Attachment 4.
WP exceptions, recommen-dations, and basis for closure were discussed with NSRS as documented in Attach-ment 5.
WP recommends this concern not be substantiated
[y and that it be closed based on the WP-Bechtel Implemen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachment 6).
)
XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS 9
Notice of Indications for Report I-85-735-SQN
$2 Preservice-Related Defects (Attachment 3).
I j
XX-85-108-001 Socket Welds hot Inspected Not substantiated by NSRS XX-85-108-002 Report I-85-776-SQN (Attachment 3).
4 fp, 3.?)
05640 h
i.o.. i oi.
10/16/86 (EMPLOYEE CONCERNS) 12:52: 43 CAT lSSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 - - - - - - C O N C E R fJ - - - - - - -
g',
S 1
SR XX-85-013-001 ncYWORDS:
ELECTRODE IMPLEMENTATION CONTROL PROB: WCPME 309 WELO ROD WAS USED TO WELD 316 STAINLESS PIPE AT SEOUOYAH UNIT 1 IR: XX-85-013-001 STAT:
RC:
TECHNICAL COMMENTARY:
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WEl. DING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS ATTACHMENT 3 ERT REPORT XX-85-013-001
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