ML20215C447

Rev 2 to Insp of Welds Through Paint

ML20215C447
Person / Time
Site:	Sequoyah
Issue date:	12/04/1986
From:	Bateman R, Rose J, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215C295	List: ML20215C292 ML20215C356 ML20215C394 ML20215C407 ML20215C432 ML20215C447
References
WP-02-SQN, WP-02-SQN-R02, WP-2-SQN, WP-2-SQN-R2, NUDOCS 8612150144
Download: ML20215C447 (27)

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EEY ELE'1EMT 17.O  ; .

.. J OFFICE OF UUCLEAR OPERATICMS (continued) .. .

This concern may be referring to structural welds i Structural up and finalwelds and piping have different code requiremnstead inspection. ents for fit of piping.

procedures for structural welds.No holdpoints are required by the TVA 17.7 s Concern No. EX-85-039-001 rod). regarding veld control (stubs and concern was not substantiated by the audit unused This procedures. of applicabl e

A surveillance verification of welder identification, program is maintained which included .

the procedure being used. the feature being welded and ..

Variables from the procedure ,(such as amperage) properly. are verified to assure that welders are using the procedu re thatandthe rod, welder is using hasrod.

the proper requested the properroper rod, was iss

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' TVA EMPLOYEE CONCERNS REPORT NUMBER: WP-02

, SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 2 4

TITLE: Inspection of Welds Through Paint l REASON FOR REVISION: N/A l

0 SWEC

SUMMARY

STATEMENT: N/A r

i PREPARATION PREPARED BY:

Original Signed By J. E. Rose 08-25-86

[ SIGNATURE DATE t

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[

REVIEWS PEER:

! Original Signed By R. M. Bateman 08-25-86 i SIGNATURE DATE i

TAS: TECHNICAL REV EW ONLY

< N ll lf SIGNATURE DATE CONCURRENCES I .

t Original Signed By CEG-H: L. E. Martin 09-12-86 SIGNATURE SRP:h.sNnir/U fh /2. d4ff:7 DATE / SIGNATUR [ /

DATE

APPROVED BY:

A '

b N/A ECSP M'ANAGdR DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

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WELDING PROJECT GENERIC ENPLOYEE CONCERN

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EVALUATION REPORT REPORT NUN 8ER: WP-02-SON R2 DATE 08-26-86

SUBJECT:

INSPECTION OF WELDS THROUGH PAINT s

CONCERNS CONSIDERED: WI-85-013-003 WI-85-041-006 WI-85-041-008 IN-85-458-001 PH-85-040-001 IN-85-767-003 NS-85-001-001 l IN-86-019-001 lR1 PREPARED BY . E. 15M.e b b , OC, WP REVIEWED B .

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REVIEWED BY . *- 8! 6' 85 '

, QA, WP Q 0 REVIEWED BY 9AL" d , CEG-H, WELDING

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77 l 1t ID,PROGRAMMANAGER APPROVED BY 3-Revision 1 to this report is being issuep to add an employee concern which

' has been evaluated and determined to involve isues previously evaluated.

! dispositioned, and closed by the WP.

Revision 2 to this report incorporates comments made by the Senior Review' Panel on 8/19/86.

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GENERIC EMPLOYEE CONCERN l

SUMMARY

SilEET

,,j Report Number: WP-02-SON R2 Report

Title:

INSPECTION OF WELDS THROUGH PAINT I. CONCERNS CONSIDERED: WI-85-013-003 WI-85-041-006 WI-85-041-008 ,

IN-85-458-001 PH-85-040-001 IN-85-767-003 l

NS-85-001-001

• IN-86-019-001 lR1 II. ISSUES INVOLVED

1. Specifications allow inspection of welds after coat'ing in violation of FSAR and AWS requirements after tests. demonstrated V '?

that adequate inspections could not be made.

2. There may have been/were welds inspected through. primer.

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3. Inspectors did not understand thickness provisions forprimer and --

could not have performed an adequate inspection.",,

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4. NRC involvement in approving procedure for inspecting welds

'through paint.

III. STATEMENT OF CONCERN / ISSUE VALIDITY Validity: Y ,N X , Substantiated: Y , N' X .

IV. EFFECT ON !!ARDWARE AND/OR PROGRAM None e

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WP SQN, R2 V. JUSTIFICATION OC and N0 procedures did not allow inspections at SQN to be made after priming for original construction. OC procedures specifically stated li welding inspections were to be done prior to priming. Nuclear Operations procedures repeat AWS and ASME Codes requirements for the I condition of weld surfaces prior to inspection. They do not specifically prohibit painting prior to welding inspections; they do _

infer it.

This has been historically interpreted as a prohibition of painting prior to visual inspection. NO procedures provide for PSI /ISI inspections after painting, but this is after initial installation inspections are performed prior to primer being l applied. The No procedures for in service inspection of previously lR2 coated welds are in accordance with ASME Section XI requirements.

• The audit and inspection verified the procedural commitment.

9 VI. RECOMMENDATION AND/OR CORRECTIVE ACTION NEEDED

• None n

,N X . s -i VII. REINSPECTION NEEDED: Y .

c VIII. ISSUE CLOSURE . .

'?I' . Close based on this report. - t s,:

IX. ATTACHMENTS I lR1

1. Text of Employee Concerns 1

2. Excerpts From Bechtel Audit - Key Elements 10.0 and 14.0 l "

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' GENERIC EMPLOYEE CONCERN

.;) Report Number: WP-02-SQN R2

v Report

Title:

INSPECTION OF WELDS THROUGH PAINT i

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- I. SCOPE OF EVALUATION

.This engineering analysis covers the following WBN concerns determined to have possible generic implications at SQN:

s WI-85-013-003 WI-85-041-006 WI-85-041-008 IN-85-458-001 '

PH-85-040-001 .

IN-85-767-003 l

I NS-85-001-001 [R1 IN-86-019-001 -

4 . .

II. ISSUES ADDRESSED BY CONCERNS e

Each concern was analyzed to determine the issues voiced by the concerned

'e I individuals. These issues are as follows: ,,

,h[. 1. Specifications allow inspection of welds after painting or coating

' ' C- with inorganic zine primer in violation of FSAR and AWS requirements after tests demonstrated that adequat's inspections t

could not be made.

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2. There may have been/were welds inspected through primer.

3. Inspectors did not understand thickness provisions for " primer and could not have performed an adequate inspection.

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4. NRC involvement in approving procedure for inspecting welds through

+ paint.

i III. CONCERN VALIDITY OR SUBSTANTIATION Review of the OC procedures used at SQN during construction specifically prohibited the practice of inspection of welds after painting. (See Section 4.c to SNP Inspection Instruction No. II-75, 4

" Visual Examination of Weld Joints.")

Y The Process Specification which allows this practice was initiated in

1982, one year after construction was completed. This specification was not applicable nor was it implemented at SQN.

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WP-02-SQN, R2 l

l A review of NO PSI /ISI NDE procedure (N-VT-1) indicates that welds in completed systems which have been originally installed, inspected, and documented to AWS requirements may be inspected without coating removal. l l This procedure is in accordance with ASME Section XI requirements l for in service inspection and applicable only to operational systems which lR2

- have been previously certified to have been constructed and inspected I in accordance with the constructional requirements. l Issue 4 has no relevancy because the NRC is an Enforcement Regulatory Agency which performs audits and surveillance inspections to ensure compliance with Procedures, Standards, and Regulatory Guides committed to by licenses. NRC reviews and approves the QA program descriptions to assure compliance with regulations. Specific implementing procedures must comply with NRC-approved QA program requirements. '

Compliance of detailed implementing procedures is accomplished through internal review required by the approved QA program. Verification of implementation is accomplished through NRC inspections and audits, not

. through formal approval. .

Insummary,thefourissuesconsideredintheseconcochs.are'not.

substantiated due to the following factors: -

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1. Procedures were and are in effect for OC and N0 respectively which provide for initial inspection of welds prior to painting.

.I,Oh The Bechtel audit established that those procedures were g

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effectively implemented for both OC and NO. I

3. NRC does not formally approve or disapprove specific construction practices. ...

The results of this analysis confirm that the correct program elements for the control of these activities were addressed and implemented at SQN by both OC and NO. Based upon the foregoing analysis, the issues addressed in the Employee Concerns are closed.

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'04/03/86 CEMPLOYEE CONCERNS) Page 1 of 3 07:52:17

-'09C STATUS RESP -0TC ,PPP CFR 'INSP TC ------CONCERN------- PROBLEM

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DO SR WI-85-013-OO3 WCDPW ID N .(WORDS: REINSPECTION PROGRAM PAINT CRITERIA X: W Y: C Z: N G2SC (CONSTRUCTION SPECIFICATION) ALLOWED WELDS TO BE INSPECTED AFTER PAINTIN'G -

FROM 1981 THROUGH THE END OF THE WELDING SAMPLING PROGRAM. THIS IS IN VIOLATION 4

OF AWS D1.1. CI HAS NO MORE INFORMATION. CNOTE: THIS ITEM IS CURRENTLY UNDER INVESTIGATION BY ERT. THE REVISDN WAS MADE TO SEPARATE THE ORIGINAL 003 CONCERN INTO TWO DISTINCT CONCERNS.)

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TECHNICAL COMMENTARY:

ISSUE CONSIDERED: INSPECTION OF WELDS THROUGH PAINT.

LUC STATUS RESP -QTC- PPP CFR INSP TC ------CONCERN------- PROBLEM ,

ID -

P3 SR WI-85-041-DO.S WCPTI XEYWORDS: REINSPECTION PROGRAM PAINT , , .X :

W Y: N 2: N AWS WELD INSPECTORCS) (UNKNOWN) DID NOT UNDERSTAND THE1"d.M'1L" PROVISION FOR INSPECTION OF COATED (CARBO-2INC PRIMER) WELDS AS CONTAINED IN REVISIONS OF SPECIFICATION G-ES

C. PROCEDURE

QCP-4.13, AND MEMORANDUM DATED NOVEMBER 1981.

INSPECTORCS) REFERRED TO CRITERIA AS "MILLIAMPS" AND THEREFORE COULD NOT HAVE

, IMPLEMENTED / INSPECTED FOR CONFORMANCE. CI HAS NO ADDITI'NAL\INFORMATION. O NUC

,PSWER DEPT. CONCERN. ,

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, .dd'IHNICAL COMMENTARY: -

ISSUE CONSIDERED: LACK OF UNDERSTANDING OF PAINT THICKNESS ~ MEASUREMENT FOR '

VISUAL WELD INSPECTION.

LOC STATUS RESP -QTC- PPP CFR INSP TC ------CONCERN------- PROBLEM ID F5 SR WI-85-041.-OO8 WCDPW XEYWORDS: REINSPECTION PROGRAM PAINT,

• X: W Y: N Z: N PROCESS SPECIFICATION H3.C.S.4 OF G-2SC PERMITTED INSPECTION OF AWS WELDS THROUGH COATING (CARBO-ZINC PRIMER) FOR ELEVEN MONTHS AFTER ENGINEERING EVALUATION / TEST SHOWED THAT WELD QUALITY (POROSITY,. CRACKS, ETC) COULD NOT BE INSPECTED THROUGH PAINT. NUC POWER DEPT. CONCERN. CI HAS NO ADDITIONAL j INFORMATION.

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TECHNICAL COMMENTARY:

ISSUE CONSIDERED: INSPECTION OF WELDS THROUGH PAINT. l L: g .

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Attachmtnt i l -

Page 2 of 3 l '04/03/86 (EMPLOYEE CONCERNS) 07:52:17 PROBLEM STATUS RESP -0TC- .PPP CFR 'INSP TC ------CONCERN-------

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ID l_l- f f DC --- --- ---- ---

IN-BS-958-OO1 WCDFW l

'r' ERT PS SR X: W Y: C Z: K i I(-(WORDS:REINSPECTION PROGRAM PAINT _

TVA USED IMPROPER INSPECTION CRITERI A FOR AWS WELDS - MEMD FROM XNOXVILLE-*

(POSSIBLY ENDES. 1980 OR 1981) ALLOWED INSPECTION THROUGH PAINT. INDIVIDUAL FROM XNOXVILLE CXNOWN) INVESTIGATED THIS, BUT RESULTS ARE UNXNOWN. CI HAS NO MORE INFORMATION. ,

TECHNICAL COMMENTARY: s ISSUE CONSIDERED: INSPECTION OF WELDS THROUGH PAINT. PROBLEM LOC STATUS RESP -0TC- PPP CFR INSP TC ------CONCERN-------

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------ ---- ----- --- --- ---- -- ID PS SR PH-BS-040-001 WCDPW -

X: W Y: C Z: N XEYWORDS: INSPECTION IMPLEMENTATION PAINT PRIOR-TO OA HANGERS WERE FREQUENTLY PAINTED BEFORE THE WELDS WERE: INSPECTED. AUX.

BUILDING, REACTOR BUILDING'#1, ELEV . 792 '-0" , & 74S'-O"..'. 1583. CONSTRUCTION DEPT. CONCERN. CI HAS NO FURTHER DETAILS. s3 TECHNICAL COMMENTARY: ,,

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r INSPECTION OF WELDS THROUGH PAINT.

PROBLEM

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. 7 C STATUS CONSIDERED

RESP -QTC- PPP CFR INSP TC ------CONCERN-------

s ._- so PB SR IN-SS-767-003 WCDPW XEYWORDS: REINSPECTION PROGRAM PAINT CRITERIA ' X: W Y: C 2: Y CI EXPRESSED CONCERN REGARDING THE INSPECTION OF PAINTED WELDS. CI FEELS NRC INVOLVED DUE TO HAVING APPROVED THE PROCEDURE OF INSPECTING WELDS THAT ARE PAINTED. DETAILS KNOWN TO OTC, WITHHELD DUE TO" CONFIDENTIALITY. CONSTRUCTION i DEPT CONCERN. CI HAS NO FURTHER INFORMATION.

TECHNICAL CbMMENTARY:

ISSUE CONSIDERED: 1. INSPECTION OF WELDS THROUGH PAINT.

2.NRC INVOLVEMENT IN APPROVING PROCEDURE FOR INSPECTING

! WELDS ~THROUGH PAINT.

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) Page 3 of 3 07/25/86 (EMPLOYEE CONCERNS) Page: 1 03:19:46 _.

CAT ISSUE PLANT PRIORITY ORG QIC EGG INSP SD RD GD 10 ------CONCERN---- J " -

WE SFB W 1 EGG 571 Y SR B NS-85-001-001 KEYWORDS: REINSPECTION PROGRAM PAINT PROB: WCDPV s

WELDS (AWS) INSPECTED SUBSEQUENT TO PROTECTIVE COATING (CARB0 ZING PRIMER)

APPLICATION; FINAL VISUAL WELD EXAMINATION OF STRUCTURAL VELDS IN CATEGORY I STRUCTURES, INCLUDING PIPE HANGERS, CABLE TRAY SUPPORTS AND DUCT SUPPORTS; L' NIT -

1&2 , .

IR: NS-85-001-001 V STAT: RC: EC-SPL-8 VP-02-SQN TECHNICAL COHHENTARY: '

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, 3 CAT ISSUE PLANT PRIORITY ORG* QTC EGG INSP SD RD GD'I6'.'.l----CONCERN------

l WE W 1 EGG 571 Y SR

,/.IN-86-019-001 1 L' g;p l KEYWORDS: REINSPECTION PROGRAM PAINT . g, PROB: WCDPW fyr. I t *

CI IS CONCERNED THAT WELDS WERE ACCEPTED THROUGH CARB0'-ZINC. INSPECTORS VERE R1 l DIRECTED VIA HEHO TO ACCEPT WELDS I!! ROUGH PAINT. CI COULD-NOT PROVIDE ANY l ADDITIONAL INFORMATION. UNIT 1. CONSTRUCTION DEPT. CONCERN.

l l IR: STAT: RC: EC-SPL-8 WR-02-SQN I

l TECilNICAL COMMENTARY.

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Attachment 2 Page 1 of 18 1

KEY ELDtENT NO. 1.0

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OFFICE OF CONSTRUCTION

( PREPARATION FOR AUDIT OF WELDING ACTIVITIES Prior to the start of the audit, the audit team developed an audit plan and Identified applicable documents, specific manuals, specifications and' ,

procedures which described and implemented the TVA welding activities. ,

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4 The audit team developed an audit checklist to address all elements identified in the TVA work plan in addition to analysis of employee concerns for significance and integration into the checklist.

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- i The audit team identified and selected a cross section of welded systems .!

from applicable TVA specifications. Welds were randomly selected from "-

drawings applicable to each individual system for programmakic audit.

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KEY ELD!DIT 2.0 *-

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OFFICE OF CONSTRUCTION -

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ADEQUACY _OF DESIGN OUTPUT DOCU!iENTS. *l.,, f

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For items selected for audit, drawings, welding procedures aqd sucporting y y records were reviewed and showed compliance with the TVA,proge'am and t,Np;p Procedures.

• OBSERVATION '

One observation was noted during the audit of the welding output documents. .

The TVA detailed welding procedures (DNP) did not show the rt&me of the key i

'organisational group. By showing the name.,of.the key unit,that is responsible for the welding control documents, any questions concerning the

j. welding documents could have been readily resolved.

l, KEY ELDIENT 3.0 i

OFFICE OF CONSTRUCTION INITIAL WELDER OR WELDING OPERATOR QUALIFICATIONS Based on audit of welder qualification records and supporting documentation, TVA welders were qualified in accordance with TVA programs and procedures. , . . . .

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. - Attachment 2 Page 2 of 18 KEY ELEMErlT 4.0 -

OFFICE OF CONSTRUCTION MAI!!TDIANCE OF WELDER OR WELDING OPERATOR QUALIFICATIC:IS Based on audit of welder maintenance records, TVA welders demonstrated welding'within and procedures.certification expiration dates' as required by TVA programs

. . . s KEY ELEMENT 5.0 OFFICE OF CONSTRUCTION .

RDIEWAL OF WELDER OR WELDING OPERATOR OUALIFICATIONS Based on audit of welder qualification records"and maintenance. records, TVA

• welders were requalified in accordance with TVA programs And/ procedures.

In many cases TVA welders were given the original qualification test. ~

for renewal which exceeded ASME IX,and AWS D1.1 requirements' fob,' renewal.

'h-KEY ELEMENT 6.0 - .j'< '

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OFFICE OF CONSTRUCTION -

'j .. INITIAL WELDING INSPECTION PERSONNEL QUALIFICATIO.V 1/.

Qualification / Certification records for. nondestructive examin'ation personnel (weld inspection) were reviewed for compliance with TVA NDE personnel March, 1983. procedtires covering a time span from January,1971 through qualification TVA personnel qualification procedures used for the qualification /

certification of NDE personnel complied with and referenced the applicable edit (on of SNT-TC-1A (American Society of Nondestructive-Testing).

Records evidencing qualifications and certifications, contained sufficient detail to confirm compliance with applicable codes, standards and specifications in effect during construction activities.

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Attachment 2

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' I KEY ELEMEflT 7.0 :  !

OFFICE OF CONSTRUCTION MAINTEllANCE OF WELDING IllSPECTION PERSO? RIEL QUALIFICATIC I .

Review of inspection personnel qualification records for completeness and '

recertification confirmed compliance with TVA procedures used for qualification certification of NDE personnel. Recertification of inspection personnel was accomplished as required by app.licable procedurcs. In many instances recertification of personnel was accomplished on a more frequert schedule than required by TVA procedures or industry standards, (SNT-TC-1A).

KEY ELEMENT 8.0 .

OFFICE OF CONSTRUCTION RENEWAL OF WELDING INSPECTION PERSO! RIEL QUALIFICATICN

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Renewal of all welding inspection personnel qualifications s, elected for auditindicatedcompliancewithreferencedTVAprogramsand' procedures. ,:r S *,

'0 S U "i KEY ELC4ENT 9.0 1,Oi

? ' ' W.h ' OFFICE OF CONSTRUCTION USE OF APPROPRIATE WELDING PROCEDURES',

Detailed welding procedures and qualification records applicable to the audit items were reviewed. Postueld heat treatment records were audited and.

showed compliance with the TVA program and procedures. '

KEY ELEMENT 10.0 OFFICE OF CONSTRUCTION

, USE OF APPROPRIATE INSPECTION PROCEDURES For items selected for audit, appropriape inspection procedures were

• Identified for use. Procedure review showed compliance with TVA program requirements and referenced codes and standards.

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'] KEY ELEMEllT 11.0 3 .

OFFICE OF CollSTRUCTIC.'I USE OF APPROPRIATELY TRAI?IED A11D OUALIFIED PERSC!l?!EL -

Records of all certified personnel audited indicated that appropriat'e training had been administered and. qualifications were in accordance with TVA programs and procedures. .

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For personnel trained and qualified in visual examinations, actual copies of written examinations were maintained as evidence of training and qualification.

Training records of personnel not requiring certification were not '

maintained since they were classified as Duration of Construction (DOC)

. documents.

Classification as DOC documents was in accordance with TVA programs and procedures and referenced codes and standards.'

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KEY ELEMENT 12.0 .

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OFFICE OF CONSTRUCTION USE AND CONTROL OF WELDING FILLER METALS .

Audit Finding - AF-01-OC .

Certified material test reports (CMTR's) for welding filler metals did not comply with TVA project specifications. Deta,ils on,each package are identified in Attachment A.

• s In general, TVA procedures required criteria over and above ASME filler metal specifications and had no impact on weld quality. For example, a CMTR stated that heat treatment was done at ll50*F for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The TVA project .

specification required the heat treatment to be 1150*F for 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br />. A letter in the contract file from TVA addressed this deviatibn and gave permission to use as is.

However, the letter was not signed land did not identify manufacturer, heat or lot number. .;'..

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This finding indicates that the TVA procedures were not:followed although referenced code requirements were complied with. The data' reviewed during the audit strongly supports the conclusion that there was nd '

actual weld quality related to control of welding filler.Jnat.d, . . 1, ials. impact on the

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SU}DfARY OF FINDINGS FOR EI.EMENT 12.0 (Of fice of Construction) ',

(AF-01-OC)

Weld Filler Metal Pqoject SFA . -

Package Classification Specification Spec. Heat No. Lot No. Comments -

g referenced

) checklist) '

29. E 7018 PF 1012 rev. 2 5.1 422N1151 -

See comment 1.

30. E'70S-3 PF 1019 rev. 2 5.18 623389 See comment 2'& 3 .

34. E 7018 PF 1012 rev. 2 5.1 01W019 2241342 See comment 1.

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35. E 7018 PF 1012 rev. 2 5.1 412L7101 3034015 See comment 1.

36.- E 7018 PF 1012 rev. 2 5.1 402N8581 2443662 See comment 1. f

37. E 70S-3 PF 1019 rev. 2 - 5.18 431J5621 -

See comment 3.

38. , E 70S-3 , PF 1019 rev. 2 -

5.18 625537 -

See comment 3.  ;

.3 9. . E 7018 PF 1012* 5.1 411N0471 -

See comment 1.

40. E 7018 PF 1012' rev. 2 5.1 08R217 -

See comment 1.

46. .E 70S-3 ,PF 1019 rev. 2 5.18 421E9101 -

, See comments 2 & 3.

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48. E 70S-3 PF 10'9 rev. 4 5.18 4h2T7432 -

See comment"3.

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Comment (1): CMTR states heat treatment (h.c.) @ 1125' Fi 25* for 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The project spec. required the h.t. gg to be @ 1150' F for 10 hrs.

oo a "g os :r Commant (2): CMTR states h.c. @ 1150' F for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. The project spec. required the h.t. to be 1150* for 10 hrs. ,a

Ccmment (3): The project spec. and SFA 5.18 requires the ycild strength. CHTR did not state this information.

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• No rev. given on CMTR or receiving report. Assume rev.'.2 '

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. Attachment 2 Page 7 of 18

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. \, ). KEY ELEMENT 13.0 -

OFFICE OF CONSTRUCTION IN PROCESS CONTROL OF NELDING .

The inprocess control procedures for welding were identified for the items that were selected for the audit. TVA documents that controlled welding activities and operation checklists were revi,ewed. .The review eesults showed the' construction work was accomplished in accordance with the TVA welding program and procedures.

KEY ELEMDIT NO.14.0 ,

OFFICE OF CONSTRUCTION '

DOCUMENTATION OF TECHNICAL AND OUALITY ACTIVITIES

! t-Reference Key Elements 2.0 through 13.0, and 15.0 througNy 7 0,.

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KEY ELEMENT 15.0

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• 1 OFFICE OF CONSTRUCTION ,

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NONCONFORMANCES AND CORRECTIVE ACTIONS.

Review of nonconformances and corrective action reports for completion and

/ closure, confirmed compliances with TVA program and procedural requirements for this activity.

,. .e KEY ELEMENT.16.0 OFFICE OF CONSTRUCTION .

TRAINING PROGRAMS Training requirements for personnel not requiring certification were

," reviewed for compliance to the TVA program training manual and referenced procedures.

Since limited data was required to be retained on individual attendance and participaticn, verification of program existance and control within TVA was the primary objective accomplished by the audit element. .

For this training programs report for details.- requiring certification, reference Key Element 11.0 of ...' .

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Attachment 2 Page 8 of 18

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' KEY ELEMENT 17.0  ;

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NA OFFICE OF CONSTRUCTION EMPLOYEE CONCERNS '

17.1

' Concern No. XX-85-049-XO3 and XX-85-101-006 regarding welder certification.

This concern was not substantiated by bhe audit of a random sampling of 37 welders which involved 124 welder qualification records from 1970 to 1979.

17.2 '

Concern No. XX-85-69-001 and XX-85-069-X05 regarding welder certification and on-the-job training. This concern was not substantiated by the audit of a random sampling of 3,7 welders which involved 124 welder qualification records from 1970 to 1979.

17.3 , . . .

Concern No. XX-85-108-001 and XX-85-108-002 regardihg iteld inspections.

This concern could not be substanti'a'ed~hd t evidenced by auditofaminimumof14inspectionprocedures..Pffj,',

17.4 Concern No. IN-85-476-004 and WI-85-041-002 regardingkelding

' inspectors training program. This concern could not b6 substantiated as evidenced by audit of training programs. "

6E 5,), * **

.{j. f- 17.5

- Concern No. Wl-85-053-004 and XX-85-68-006 regardi'ng weld rod control

- satisfying code requirements. This concern was not substantiated by audit of a random sampling of 48 receiving documents and associated '

CMTR's which involved 83 heat and/or lot number, 8 types of weld metal covering, the years 1972 to 1980. This represents approximately

• 572,000 pounds of neld metal. Although audit finding, AF-01-01, against Key Element No. 12 of this report is document'ed against the TVA program, it involves details required by TVA procedures over and above that required by ASME filler metal specifications and had no impact on weld quality.

The statement in the concern. shows a lack of understanding of the code.

For example, ASME III, NB-4122 requires traceability of the weld filler metal but gives two methods to chose from. Either trace to each component or ensure the specified material is used by a control procedure. TVA's prograp required that all the material meet the standards and, therefore, did not require traceability to a component.

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Page 10 of 11

Attachment 2

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Page 9 of 18

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KEY ELEMENT 17.0 -

OFFICE OF CONSTRUCTION EMPLOYEE CONCERNS -

, (continued) 17.6 Concern No. XX-85-054-001 regarding weld inspection by craft. This concern was not substantiated by the pudit of 13 inspgetors pulled from the weld history records for the welds reviewed in the audit as well as by an additional random sampling of 13 inspectors. No holdpoints certified were found to have been signed off by anyone other than inspectors. .

This concern may be referring to structural welds instead of piping.

Structural up and final welds inspection. and piping have different code requirements for fit.

procedures.for structural welds. No holdpoints are required,by the TVA

. j f' 17.7 Concern No. EX-85-039-001 rod). regardingweldcontrolistubs'andunused procedures. This concern was not substantiated by the audit of applicable A daily surveillance program was maintained which included verification of welder identification, tihe feature being welded and the procedure being used. Variables fromthe procedure ,

d. (such as amperage) were verified to assure that welders were using

' '3b ( .

the procedure properly.' 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.' Appro::imately - '"~

ge 300 surveillances a month were performed during years'of peak construction. *

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KEY ELD!ENT NO. 1.0  : ,' .

L.-, NUCLEAR OPERATIONS PREPARATION FOR AUDIT OF WELDING ACTIVITIES '. _

Prior to the start of' the audit, the audit team developed an audit pl' an and identified applicable documents, specific manuals, specifications and peacedure which described and implemented the TVA welding activities.

The audit' team developed an audit checklist to' address all ele'ments identified in the TVA work plan in addition to analysis of employee concerns I for significance and integration into the checklist. j The audit team identified and selected a cross section of. welded. systems based on availability, eg: only systems which had been modified, repaired or replaced fell under Nucleae Operations program for audit. Welds were randomly selected from drawings applicable to each individual system for

-.' programmatic audit. . ; :)-

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3 Y' t KEY ELD!DTI 2.0 N. i

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NUCLEAR OPERATIONS *E f/ ,

8 ADEOUACY OF DESIGN OUTPUT DOCUMDITS

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[('- For items selected for audit, drawings, welding procedures:and supporting

( records were reviewed and showed compliance with the TVA program and procedures. '

. I i

OBSERVATION '

One observation was noted during the audit of the welding [utput documents.

The TVA detailed welding procedures (DWP) did*not show the name of the key organizational group. By showing *the name of the key unit that is responsible for the welding control documents, any questions concerning the u '

welding documents could have been readily resolved.

• VEY ELEMETT NO. 3.0 NUCLEAR DPERATIONS INITIAL WELDER OR WELDING OPERATOR QUALIFICATIONS  !

Based on audit of welder qualification records and supporting documentation., . . .

TVA welders are qualified in accordance with TVA programs and procedures.

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_ _ - _ _ _. - _ _ - _ _ _ _ _ - _ _ . - _ _ _ _ _ _ - _ _ _ _ - - - - _ _ _ _ _______n____--____-_________--

. . . . . . .. . ._ . . ~ .  !

Attachment 2 Page 11 of 18

( KEY ELEME!!T FIO. 4.0 NUCLEAR OPERATIONS MAINTEllANCE OF WELDER OR WELDING OPERATOR OUALIFICATICMS Based on audit of welder maintenance records, TVA welders demonstrated welding and within certification expiration dates as required by TVA programs procedures. -

KEY ELEMENT NO. 5.0 NUCLEAR OPERATIONS RENE'4AL OF WELDER OR WELDING OPERATOR OUALIFICATIONS

.g Based on audit of welder qualification records and maintenance records, TVA welders are requalified in accordance with TVA programs and p,rocedures.

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KEY ELEMENT 6.0 . s .q '-)'

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NUCLEAR OPERATIONS **

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INITIAL WELDIllG INSPECTION PERSONNEL OUALIFICATIO?!S fl(s t ... ".

[ All inspector qualification records (NDE, to include visual: e.tamination)

(' U;"', audited indicated compliance with TVA programs and procedures and the referenced codes and standards. .

I' :

OBSERVATION TVA Form 6780 (as referenced in procedure 0202.14) used to document NDE qualification and certification does not clearly identify the recertification status of the individual. Additionally, certification

• - authority is referenced as being in compliance with TVA program, requirements

when individuals are actually certified in accordance with the specific ,,,.

requirements of Procedure 0202.14 (formerly N75C01), Qualification Certification Program for NDE Personnel. ,

Program clarity and definition could be improved by adding either the-certification expiration date or recertIfication status as an entry on Form 6780. Specific reference to Procedure 0202.14 on certification forms (6780) would provide for direct reference and compliance with TVA NDE personnel qualification, employed.

certification requirements and practices for each NDE method -

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Attachment 2

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f KEY ELE 4ENT 7.0 NUCLEAR OPERATIOf!S

. [( -

MAIllTEMAf!CE OF WELDIFIC IllSPECTIOff .

. PERSOFINEL QUALIFICATIONS --

• All welding inspection personnel qualification records audited were in s compliance with TVA programs and procedures and the referenced codes and standards. -

, The observation detailed in 6.0, " Initial Welding Inspection Personnel Qualifications" is also applicable to this element with no changes or deletions.

KEY ELDIENT 8.0 .I- '

NUCLEAR OPERATIONS ,., *} '

REffEMAL OF WELDIt!G INSPECTION PERSONNEL QUALIFICATICH (1:

For all records of personnel audited, renewal of welding inspection personnel qualifications are in compliance with TVA programs a,nd procedures. , ,

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, KEY ELDIENT 9.0 .-

,  !!UCLEAR OPERATIONS '

,, USE OF APPROPRIATE WELDING PROCEDURES -

, Welding procedures and heat treating procedures were audited against the referenced Nuclear Operations docunents and found to be in c6'mpliance.

, KEY ELDIDIT 10.0 NUCLEAR OPERATIONS USE OF APPROPRIATE INSPECTIO!! PROCEDURES For all items audited, applicable inspecelon procedures were identified for use as referenced in TVA program and procedures.

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,: KEY ELEME?IT 11.0 . .

NUCLEAR OPERATIO!!S USE OF APPROPRIATELY TRAINED A?ID OUALIFIED PERSO RTEL Personnel Recuirino Certification:

By review of personnel training records and governing TVA training procedures, use of appropriately trained and qualified personnel was verified.

Personnel ?Iot Recuiring Certification:

Training records for personnel not requiring certifications were reviewed to TVA program procedures, (General Employee Training -- GET-4). , ,

OBSERVATION .'

, Procedure AI-14 (Plant Training Program) Revision'.31 and . Area *. Ian 0202.04

,c Revision 0 require retraining on a biennial basis for genitralf. employee GET-4 Instructions to QA/QC. ,

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A review of training records for general employee training GET-4; revealed 4 out of 12 individuals were overdue for retraining.

• 't .19 W

'lgg?p~ Procedure AI-14 and Area Plan 0202.04 do not provide for any penalty or

,g restriction of activity for failure to comply with the retraining time frame.

'. Recommendation - Subject plant training program AI-14 shod 1 be evaluated to determine need for retraining time frame and provide for restrictions or t- deletion of the requirement. '

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' KEY ELEMENT 12.0 .

I[I NUCLE 7R OPERATIONS USE AND CONTROL OF WELDING FILLER METALS

• OBSERVATICN .

The site co'ntrolling procedure for " Receipt Inspection" is unnecessarily long and confusing (reference AI-ll, Revision 38, 66 pages). Extractions are for example:

s "2.5.2

As part of the receipt inspection of Level I items, Level II substituted items, or Level II items to which Part 21 applies, ,

either purchased by NUC PR or EN DES and shipped from the vendor to -

NUC PR, the QC inspector shall review and verify manufacturing

• documentation and material certifications of physical properties as follows: ~

• a.

Manufacturino Documentation--Assurance that.the'it'em received was fabricated, tested, and inspected priori to, shipment in accordancewithapplicablecode,specificati6pjjpu' contract, and/or drawings. chase r

'; b. 'L. j i Physical Procerties--Assurance that physicaItproperties conform ot?,. S t. to the specified requirements and that chemical'cnd physical,,

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? test reports, if required, meet the requirements,."

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,4 [5 Anotherand worded controlling organized. procedure, power stores SIL-8, "QA Records," is poorly Personnel can infer four places fo' rCMTR's to be filed. For example: ,

J.

The receivi'ng report (IVA 209), packing list w/rel'ated documents, .

SQA45 (Attachment 11), TVA 2652 (Purchase Request),-Quality .

Assurance Certifications, changed QA Level Assignments, Material Receipt Inspection Report (AI-ll, Attachment 1), ECN Material Receipt Inspection Report AI-11, Attachment 5), AI-ll, Attachment 16, NCI Tag (TVA 7830), Recommended Disposition of Nonconforming Items (AI-ll, Attachment 10), OSSD or D (TVA 210), TVA'9640, and TVA 5050 are filed in the procurement document. folder or attached to the TVA Form 575 or attached to the procurement document or filed under procurement document number."

Yet another controlling document, N73M2

• Process Specification for Welding, Heat Treatment and Allied Field Operations" requires that CMTR's shall be

- apprcved from materials by the metallurgy power stores.and standards group prior to release of welding .

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. KEY ELDIEtIT 12.0  ; ,

l(k FJUCLEAR OPERATIOflS USE AND COrlTROL OF WELDIllG FILLER METALS

-(continued)

Too many controlling procedures are required to be used simultaneously to do the job of control of welding filler material effectively. This puts the program and the people trying to enforce the,, program in a vulnerable position. * *

• The material receipt inspection report (Attachment 1 of AI-ll) refers'to an item on a shipping ticket or a contract document. It does not list what is -

being inspected, such as weld filler metal with heat number. One document ,

ties to another before either gives the complete information.

The program could be condensed and simplified'to be more functional and less vulnerable to error and misinterpretation by the users...+ *j'i'

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- ') KEY ELD 1Et!T 13.0 .

(. NUCLEAR OPERATIOtJS IllPROCESS COPITROL OF WELDIt!G ,

Auditing covered the TVA documents that controlled the welding operations.

The audit results confirmed compliance with the inprocess control of the referenced TVA documents.

. . . s KEY ELEMENT NO. 14.0

• NUCLEAR OPERATIONS .

DOCUMENTATION OF TECIGIICAL AND OUALITY ACTIVITIES

), .. ,-

Reference Key Elements 2.0 through 13.0 and 15'.0 through 17.0..

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11 NUCLEAR OPERATIONS -

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• NONCONFORMANCES AND CORRECTIVE ACTIONS ;/.

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l, *" y closure, confirmed compliances with TVA program and procedural requirements It., .h ;. ;L for-this activity. '

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N KEY ELC4ENT 16.0

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• TRAINING PROGRAMS ,

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f!'[h' i,c., , to the welding program were revleued for compliance to the TVA program.

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' , .;t W i 7 W. , ' Reference Key Element No. 11. '

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KEY ELEMENT 17.0  ; -

(~ OFFICE OP NUCLEAR OPERATIONS .

.. ~.

17.1 Concern No. XX-85-049-X03 and XX-85-101-006 regarding welder certification. This concern was not substantiated by the audit of a random sampling of 25 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 t,o 1985.

17.3 Concern No. 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. g (* e

- t' ,.

17.4 Concern No. IN-85-476-004 and WI-85-041-002 regafdiYh$ welding inspectors training program. This concern could not'be.substatiated as evidenced by audit of training programs. S  ;/.

's psy 17.5 Concern No. Wl-85-053-004 and XX-85-68-006 regarding ge,1d rod control ny? , satisfying code requirements. This concern was not,, substantiated by i'.~ ' ., audit of a random sampling of 25 receiving documents and associated CMTR's which involved 25 heat and/or lot number, 6' different types of -

weld metal covering the years 1976 to .1985. This represents approximately 19,000 pounds of weld filler metal.

The statement in the concern shows a lack of understanding of the code. For example, ASME III, NB-4122 requires traceability of the weld filler metal but gives two methods to chose from. Either trace to each component or ensure. the specified material is used by a

, 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 concern was not substantiated by the audit of 4 inspectors pulled from the weld history records for the welds reviewed in the au'dit as well as by an additional random sampling of 10 inspectors. No holdpoints were found to have been signed off by anyone other than certified inspectors.

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r Attachment 2 Page 18 of 18

,g KEY ELE!!EllT 17.0 .

OFFICE OP FJUCLEAR OPERATIO?!S .

(continued)

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. !Jo holdpoints are required by the TVA s

procedures for structural welds. *

• 17.7 Concern flo. EX-85-039-001 regarding weld . control (stubs and unused rod). This concern was not substantiated by the audit of applicable 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 amperage) are verified to assure that welders are using the procedure

- properly. Welding rods, ovens and controls are monitored to assure that the welder has requested the proper rod, was: Issued the proper rod, and is using the proper rod. ,

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. TVA EMPLOYEE CONCERNS REPORT NUMBER: WP-09 SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUNBER: 1 l

TITLE: Weld Inspection Criteria Used For SQN Construction REASON FOR REVISION: N/A l

l SWEC

SUMMARY

STATEMENT: N/A PREPARATION PREPARED BY:

Original Sinned By R. M. Bateman 08-25-86 SIGNATURE DATE REVIEWS PEER:

Orlainal Signed By J. E. Rose 08-25-86 SIGNATURE DATE TAS: TECHNICAL REVIEW ONLY

$//

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kSIGNATURE

//lM fd DATE CONCURRENCES i

Origian1 Signed By CEG-H: L. E. Martin 09-03-86 SRP: M M* 4 8S SIGNATURE DATE G SIGNATURE

• DATE APPROVED BY:

$4 /

h DATE N/A MANAGER OF NUCLEAR POWER DATE l ECSP MAiAG1R l CONCURRENCE (FINAL REPORT ONLY)

• SRP Secretary's signature denotes SRP concurrences are in files.

l 2242T gg (G

s WELDING PROJECT GENERIC EMPLOYEE CONCERN L ,.)

EVALUATION REPORT REPORT NUMBER: WP-09-SON, R1 DATE 08-26-86

SUBJECT:

WELD INSPECTION CRITERIA USED FOR SON CONSTRUCTION CONCERN CONSIDERED: IN-85-406-002 PREPARED BY N. oM '25 % , OC, WP

, REVIEWED BY k- n_ -

$2MB(a , OC, WP REVIEWED BY . L M , QA, WP 3.-

o6 REVIEWED BY-

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d , CEG-H, WELDING APPROVED BY , .

PROGRAM MANAGER

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• Revision.1 expanded on weld inspection procedures available prior to 1979 to incorporate conunents made by the Senior Review Panel on 8/19/86 s

4 00280

GENERIC EMPLOYEE CONCERN

SUMMARY

SHEET

'N Report Number: WP-09-SON, R1 Report

Title:

WELD INSPECTION CRITERIA USED FOR SON CONSTRUCTION

~

I. CONCERNS CONSIDERED: IN-85-406-002 II. ISSUES INVOLVED Prior to 1979, there was no specific weld inspection criteria for use by inspection personnel.

III. STATEMENT OF CONCERN / ISSUE VALIDITY

.,- Validity: Y ,N X , Substantiated: Y ,N X IV. EFFECT ON HARDWARE AND/0R PROGRAM None V. JUSTIFICATION There was inspection criteria available.

([h VI. RECOMMENDATION AND/OR CORRECTIVE ACTION NEEDED

- None .

VII. REINSPECTION NEEDED: Y ,N X .

, VIII. ISSUE CLOSURE ,,

By this report.

II. ATTACHMENTS

1. Text of The Employee Concern

2. Excerpt From Bechtel Audit - Key Element 10.0 e

9 Page 1 of 1 00280

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GENERIC EMPLOYEE CONCERN Report Number: WP-09-SON. R1 s

4 ,

Report

Title:

WELD INSPECTION CRITERIA USED FOR SON CONSTRUCTION I. SCOPE OF EVALUATION This engineering analysis covers WBN Employee Concern Number IN-85-406-002 which was deemed to have possible generic implications at SQN.

~

II. ISSUES ADDRESSED BY CONCERN (S)

The subject concern was analyzed to determine the issue voiced by the concerned individual (s). This issue is as follows:

Prior to 1979, there was no specific weld inspection criteria for use by inspection personnel.

III. CONCERN VALIDITY OR SUBSTANTIATION The base requirement for inspection procedures comes from Criteria V and X of 10 CFR 50, Appendix B, and ANSI N45.2. The principle of inspection procedures is a basic and integral part of the TVA Quality Assurance Program. The SQN Division of Construction Quality Assurance ,

Program included the requirement for procedural control of quality j

@,, affecting/ quality assuring activities in SNP Construction Procedure No. P-1, " Preparation of Construction Procedures and Inspection Instructions," which was originally issued on December 16, 1971.

l Inspection procedures were generated in accordance with the provisions i of this document and were issued for use at SQN. ,

General Construction Specification G-29 was first formally transmitted j i

I

! to the implementing organizations on July 22, 1971. This specification l contained the weld inspection acceptance criteria and technical lR1 ,

documentation requirements. l ,

The' Division of Construction (now OC) at SQN originally conveyed the l requirements in site implementing procedures. These procedures were l l oriented by engineering discipline responsible for the feature. The l  !

2

> documentation requirements were specified in checklist format and the l '

appropriate G-29 process specification was referenced for the acceptance [

. l criteria. ,

I

1. SNP-M-3 issued 1/24/72 " Welding Surveillance and Weld Procedure l Assignment" lR1 l

2. SNP-M-7 issued 8/25/72 " Erection and Documentation Requirements l for QA Piping Systems" l 1

' 3. SNP-C-2 issued 12/12/71 " Erection and Inspection of Structural l .

g Steel" l l>

l

4. SNP-M-20 issued 11/14/74 " Pipe Support Installation and l Documentation" l~ .

Page 1 of 3 e I 00280

l WP-09-SQN, R1

?

t) 5. SNP-E3 issued 12/6/74 " Installation and Inspection of Seismic l Supports for Conduit and Lighting Fixtures" l

' l

6. SNP-IS. issued 5/1/75 " Fabrication, Installation, and Inspection of l Seismic Instrumentation Line Supports and Wall-Mounted Panels" l I

lR1

7. SNP-M-23 issued 3/31/75 " Fabrication, Installation, and Inspection l of Heating, Ventilating, and Air-Conditioning Duet Supports" l l

8. SNP-M-27 issued 5/28/76 " Fabrication. Installation, and l Cleanliness Requirements,for Heating Ventilating, and , l h

Air-Conditioning Duct Systems" l 1

Restructure of the Site Quality Assurance Procedures in 197, resulted in the l

[

following specific Inspection Instructions conveying the welding inspection lR1 criteria by the type of inspection being performed: , , _ l I i

1. SNP-II-74 issued 2/14/77 " Fit-Up and Cleanliness Inspection" l l

l

2. SNP-II-75 issued 1/31/77 " Visual Examination of Welded Joints"

- l

3. SNP-II-76 issued 3/16/77 " Liquid Penetrant Inspection" l l

4. SNP-II-77 issued 3/16/77 " Magnetic Particle Inspection" l l

1 j 5. SNP-II-78 issued 2/22/77 " Ultrasonic Examination" l I

6. SNP-II-79 issued 4/22/77 " Radiographic Examination" l j

This network of procedures provided the basis for welding inspection activities at SQN during construction. The Welding Project has reviewed these procedures and determined that the necessary detail was present and that the requirements were accurately presented.

Overviews by the TVA QA organization and by NRC inspectors were routinely performed during the construction of Sequoyah Nuclear Plant. (These overviews have continued during the operstional phase.)

Procedural deficiencies noted by overviews were tracked, corrected, and closed during the appropriate timeframe.

In addition, the Bechtel SQN Implementation Audit performed in January 1986 directly examined the adequacytof inspection procedures and their implementation in Key Element 10.0, "Use of Appropriate Inspection Procedures" (attached). The audit indicated that the review of the inspection procedures showed compliance with TVA program reqairements and referenced codes and standards.

In summary, the issue considered in the concern is not substantiated due to the following factors:

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1. Inspection procedures which delineated code and standard t_,

requirements were in effect at SQN for OC.

2. The Bechtel SQN Implementation Audit provides an independent verification of the adequacy of these procedures.

Based upon the foregoing analysis, the issue addressed in this Employee Concern is closed. ,

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- . Attachment 1 E'/18/86 CEMPLOYEE CONCERNS) PAGE 1 of 1 ,

l ")S:01

% ) STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN------- PROBLEM

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10 EGSG 00 SR IN-85-408-OO2 WCDPW KEYWOROS: INSPECTION PROGRAM CRITERIA X: W Y: C 2: N PRIOR TO 1979 THERE WAS NO SPECIFIC WELD INSPECTION CRITERIA FOR USE BY INIPECTION PERSONNEL. IT IS BELIEVED THAT THIS PROBLEM WAS URLID TVA SYSTEM WIDE-ALL FLANTS.

s TECHNICAL COMMENTARY:

ISSUE CONSIDERED: WELO INSPECTION CRITERIA USED FOR SON CONSTRUCTION

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' Attachment 2 Page 1 of 1

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KEY ELEMENT 7.0

' 'l OFFICE OF CONSTRUCTION MAINTENANCE OF WELDING INSPECTICN PERSONNEL QUALIFICATION -

Review of inspection personnel qualification records for completeness and recertification confirmed compliance with TVA procedures used for

- qualification certification of NDE personnel. Recertification of inspection ,

personnel was accomplished as required by applicable procedures. In many instances re:'rtification o of personnel was accomplished on a more frequent schedule than required by TVA procedures or industry standards', (SNT-TC-1A).

KEY ELEMENT 8.0 .

OFFICE OF CONSTRUCTION RENEWAL OF WELDING INSPECTION PERSONNEL QUALIFICATICN Renewal of all welding inspection personnel qualifications selected for audit indicated compliance with referenced TVA programs and procedures.

KEY ELEMENT 9.0 N,$^ ~ OFFICE OE CONSTRUCTION' k * *

., JJSE OF APPROPRIATE WELDING PROCEDURES

, Detailed welding procedures and qualification records applicable to the audit items were reviewed. Postweld heat treatment records were audited and-

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l -i;.'hshowed compliance with the TVA program and procedures. ,,

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KEY ELEMENT 10.0

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' OFFICE OF CONSTRUCTION USE OF APPROPRIATE INSPECTION PROCEDURES For items selected for audit, appropriate inspection procedures were identified for use. Procedure review showed compliance with TVA program requirements and referenced codes and standards.

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. . CONSTRUCTION CATEGORY E Es lestro .3 ECTG WRITEE'S GUIDE ELEMENT REPORT FORMAT l 1

1.0 Issue I. Introduction Characterization II. Summary of Perceived Problem i

2.0 Summary IV. Summary of Findings  !

Conclusions (Portion) 3.0 Evaluators Cover Sheet Information l

4.0 Evaluation III. Evaluation Process Nethodology 5.0 Findings IV. Summary of Findings 6.0 Root Cause V. Root Cause (Collective Significance)** ** Overall Root Cause will not be considered at this report level.

7.0 Attachments / VIII. Attachments List of Concerns Other items included VI. Corrective Actions in Construction Element (To be provided by Reports line orgainzations)

VII. Generic Applicability 1905T

. . NATERIALS CONTROL EIelestro 3 ECTG WRITER'S GUIDE ELEMENT REPORT FORMAT 1.0 Issue I. Introduction Characterization II. Summary of Perceived Problem 2.0 Summary IV. Summary of Findings Conclusicas (Portion) 3.0 Evaluators Cover Sheet Information 4.0 Evaluation III. Evaluation Process Nethodology S.0 Findings IV. Summary of Findings 6.0 Root Cause V. Root Cause (Collective Significance)** ** Overall Root Cause will not be considered at this report level.

7.0 Attachments / VIII. Attachments List of Concerns Other items included VI. Corrective Actions in Element (To be provided by Reports line organizations)

VII. Generic Applicability 190ST

Enc 1csuro 3 ECTG WRITER'S GUIDE NSRS/ERT* WELD PROJECT (WP) REPORTS NOTES / COMMENTS 1.0 Issue Background Info Issues Addressed Characterization (Section I) By Concerns (Sectier. -)

2.0 List Of Concerns Background Info Scope of Evaluation (Section I) (Section I and Att-1) 3.0 Evaluators Coversheet Coversheet 4.0 Evaluation Scope Not Delineated As Part Process (Section II) Of The WP Reports however it is addressed as part of the Weld Projects Program Manual i

t i 5.0 Findings Findings Validity or (Section III) Substantiation (Section III) 6.0 Root Cause** Conclusion and Validity or *** Note that reconweendations are not included in element reports under the current ECTG program, and Conclusion Recommendations Substantiation ** Overall Root Cause will (Section IV)*** (Section III) not be considered at this report level.

• The Weld Project has endorsed a number of ERT Reports and general issue level reports as adequately addressing the concerns at this level for SQN.

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Enclosure 4 Page 1 of 2 EMPLOYEE SEQUOYAH CONCERN ELEMENT REPORT NUMBER ISSUE Construction 11106 XX-85-053-002 (EN 22400)* Hanger Inspection (Initial) XX-85-053-001 (QA 80504)* Documentation

• Database subcategory as shown in 9/26/86 printout.

Material Control 40709 XX-85-027-XO4 Material Personnel -

(Initiel) Search for Defection Material Material Control 40302 PH-85-035-002 Valve (Cracked) as (Final) Related to Material NOTE: Initial report transmitted 9/29/86.

Welding WP-01-SQN, R3 WI-85-053-004 (WE 50300)* ASME Welding Material (Final) XX-85-068-006 (WE 50300)* Control, Traceability, IN-85-441-003 (WE 50300)* Accountability, and IN-85-234-001 (WE 50300)* Conditioning IN-85-424-001 (WE 50300)*

IN-85-426-001 (WE 50300)*

IN-85-352-002 (WE 50300)*

EX-85-039-001 (WE 50300)*

IN-85-337-002 (WE 50300)*

IN-85-424-004 (WE 50300)*

IN-85-424-007 (WE 50300)*

IN-85-453-009 (WE 50300)*

IN-86-150-001 (WE 50300)*

IN-86-167-001 (WE 50300)*

WI-85-041-001 (WE 50300)*

IN-85-454-004 (WE 50300)*

IN-85-672-003 (WE 50100)*

EX-85-021-001 (WE 50300)*

l IN-85-424-006 (WE 50300)*

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• Data base subcategory as shown in 9/26/86 printout.

NOTE: Initial report transmitted 9/17/86.

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Enclosure 4 Page 2 of 2 EMPLOYEE SEQUOYAH CONCERN ELEMENT REPORT NUMBER ISSUE Welding WP-02-SQN, R2 WI-85-013-003 (WE 50700)* Inspection of Welds (Final) WI-85-041-006 (WE 50700)* 1hrough Paint WI-85-041-008 (WE 50700)*

IN-85-458-001 (WE 50700)*

PH-85-040-001 (WE 50600)*

IN-85-767-003 (WE 50700)*

NS-85-001-001 (WE 50700)*

IN-86-019-001 (WE 50700)*

• Data base subcategory as shown in 9/26/86 printout.

NOTE: Initial report transmitted 9/15/86.

Welding WP-09-SQN, R1 IN-85-406-002 (QA 80206)* Weld Inspection (Final) Criteria Used for SQN Construction

• Concern IN-85-406-002 and Element QA 80206 added after 9/26/86 printout.

NOTE: Initial report transmitted 9/3/86.

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