ML20215D892
| ML20215D892 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/10/1986 |
| From: | Bateman R, Martin L, Rose J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215D785 | List: |
| References | |
| WP-16-SQN, WP-16-SQN-R02, WP-16-SQN-R2, NUDOCS 8612170114 | |
| Download: ML20215D892 (51) | |
Text
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- n TVA EMPLOYEE CONCERNS REPORT NUMBER: WP-16-SQN P
' T' SPECIAL PROGRAM
's
' REPORT' TYPE: Welding Project REVISION NUMBER:
2 TITLE: Performance of Preweld Inspections J
REASON FOR REVISION: N/A l
SUMMARY
STATEMENT: N/A PREPARATION PREPARED BY:
Original Signed by R. M. Bateman 09-12-86 SIGNATURE DATE REVIEWS PEER:
Original Signed by J. E. Rose 09-12-86 SIGNATURE DATE llCh SIGNATURE DATE CONCURRENCES Original Signed by CEG-H; L. E. Martin 09-15-86 SRP: M m W 7ddWtil 12 - S-B(
SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
h (,fb l$~ Ybh N/A ECSP MANACdAl DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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}{ELDING PROJECT
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GENERIC EMPLOYEE CONCERN
. )...
EVALUATION REPORT
[
REPORT NUMBER:
WP-16-SON, R2 DATE 09-15-86
SUBJECT:
PERFORMANCE OF PREWELD INSPECTIONS CONCERNS CONSIDERED: SQM-5-001-001*.
5 SQM-5-001-002*d WBM-5-001-001 -
/
BEM-5-001-001-BEM-5-001-002-BFM-5-001-002-WI-85-030-007 -
IN-85-212-001-BFM-5-001-001*
]R2 WBM-5-001-002-l
- SPECIFICALLY INVESTIGATED BY NSRS IN REPORT I-85-768-SQN 3
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, OC, WP PREPARED B REVIEWED BY \\.N.
8hEt,
N/2[P)(,
, OC, WP REVIEWED By.
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, QA, WP G
G REVIEWED BY [
M
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, CEG-H, WELDING
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APPROVED BY
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, PROGRAM MANAGER v v v
Revision 1 was to update status of interim corrective action on NCO-CAR-86-001, DQA/0E-CAR-86-01, and SQ-CAR-86-03-01.
Revision 2 expanded discussion on SQN Construction Welding Surveillance 7
'g Program per NRC telecon on 09/02/86 and to include additional employee Q
concerns which have been evaluated and determined to involve issues previously evaluated, dispositioned and closed by the W.P.
00390 N
GENERIC EMPLOYEE CONCERN _
~
~I - --
1 WP-16-SON, R2_
Report Number:
PERFORMANCE OF PREWELD INSPECTIONS _
Report
Title:
CONCERNS CONSIDERED:
SQM-5-001-001*
SQM-5-001-002*
I.
WBM-5-001-001 BEM-5-001-001 BEM-5-001-002 BFM-5-001-002 WI-85-030-007 IN-85-212-001
)R2 BFM-5-001-001 l
WBM-5-001-002
- See NSRS Report I-85-768-SQN (Attached).
II.
ISSUES INVOLVED Do uncertified welder foremen perform preweld inspections?
1.
Is this a violation of IVA Quality Assurance requirements?
2.
Is this a violation of ANSI N45.2.5 requirements?
4 :, g.
~~
3.
STATEMENT OF CONCERN / ISSUE VALIDITY III.
Validity:
Y_ X
_,N_
_, Substantiated:
Y_
X
_,N EFFECT ON HARDWARE AND/OR PROGRAM IV.
None (Program has been revised).
V.
fllSIIFICATION Nuclear Procedural controls were adequate for construction ith J.
the Nuclear Operations QA Program.
- I RECOMMENDATION AND/0R CORRECTIVE ACTION NEEDED VI.
i rt).
None (Corrective action has been taken as described in th s repo
')
':i i.i REINSPECTION NEEDED: Y_
_, N _ X VII.
VIII.
ISSUE CLOSURE
- ,i; Based on completion cf required corrective action for Nuclear l
Operations.
Page 1 of 2
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00390
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y"6 WP-16-SQN, R2 c[
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_ ATTACHMENTS E b-II.*
e lR2 1.
Text of Employee Concerns 2.
NSRS Investigation Report - I-85-768-SQN
' ~"
3.
W. C. Drotleff's March 17,_1986, memo to R. B. Kelley (B27 860314 003) 4.
J. P. Vineyard's March 19, 1986, memo to J. W. Coan (B27'860319 002)
.3 Page 2 of 2 00390.
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GENERIC EMPLOYEE CONCERN y A,
~ '
Report Number:
WP-16-SON, R2 h:
Report
Title:
PERFORMANCE OF PREWELD INSPECTIONS 7
$k I.-
SCOPE OF EVALUATION V
This engineering analysis covers the-following WBN, BLN, and BFN concerns determined to have possible generic implications to SQN. The
({
Issues in'this report have also been investigated by NSRS on concerns f
'SQN-5-001-001-and SQN-5-001-002 in NSRS Report I-85-768-SQN dated s-February 1986. The information contained in this report expands on j
the evaluations performed in the NSRS report.
i 4
[
II.
ISSUES ADDRESSED BY CONCERNS L
i Each concern was analyzed to determine the issues voiced by the concerned individuals. The subject concerns are repeats of the SQN I-
-specific concerns. These issues were stated in the NSRS. report and are as follows:
1.
Do uncertified welder foremen perform preweld inspections?
2.
Is this a violation of the TVA Quality Assurance Program?
i 1
- 3. -Is this a violation of ANSI N45.2.5 requirements?
1 f
III. CONCERN VALIDITY OR SUBSTANTIATION N i The concerns relate to General Construction Specification G-29C, I
Process Specification 0.C.1.1 (a) which requires welder foremen to h:;
perform preweld inspections including fit-up inspections.
i NSRS Report I-85-768-SQN correctly concludes that the issues revolve around preweld inspections on structural and miscellaneous steel features. The report concludes that these preweld inspections are verificatiens only and that' final acceptance of welds on completed t:
ass %mblies is performed by qualified quality control inspectors.
(l These conclusions fall short of identifying all of the requirements applicable to these issues. This report will address these issues g
further as they specifically relate to compliance with ANSI N45.2.5, e
" Supplementary Quality Assurance Requirements for Installation,
{
Inspection, and Testing of Structural Concrete and Structural Steel During the Construction Phase of Nuclear Power Plants." ANSI N45.2.5 j
requires inspections to be performed to the extent necessary in j
connection with the feature's importance to safety.
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V Page 1 of 3 00390
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q-WP-16-SQN, R2 9,j;,
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-Review of SQN construction procedures. indicates that OC implemented ANSI N45.2.5 requirements during the construction era at SQN through a
-~
network of procedures for the erection of structural steel, miscellaneous steel, and hanger features. These procedures required.
final visual inspections of welds on these features to be performed by certified QC. inspectors. They also required a. rigorous surveillance program which verified individual elements such as fit-up inspections.
Detail Weld Procedure _ compliance, proper welder qualification
-practices, filler metal. control, and workmanship on a daily surveillance basis. These daily surveillances were delineated and documented in l
~
.accordance with the following Construction procedures:
SNP CP No. 3 l
issued 09-30-71, " Procurement, Storage Issue, and Control of Welding l
-Materials", SNP CP M-3, issued 01-24-72, " Welding Surveillance and Weld lR2 Procedure Assignment", SNP CP W-3, issued 01-31-77, " Weld Procedure l
l Assignment and Welding Surveillance", and Standard Operating Procedure l
No. 700, issued 04-25-77, " Weld Surveillance".
l Refer to the WP SQN Phase I Report (Section 4.0) for discussions of the l
OC Welding Program procedural assessment and a list of procedures reviewed.
lR2 WP has randomly reviewed the documentation generated per these site l
procedural requirements for various time frames during the construction l
era. This record review revealed welding surveillances were l
performed and documented as specified in site procedures. Additional l
documentation is available that was generated prior to the issuance (R2 of a site procedure mandating welding surveillance. This surveillance l
was adopted from the existing Browns Ferry QA Program. These methods of l
g.
()j;]j 3y welding surveillance were used throughout the construction era to assure l
compliance to ANSI N45.2.5 requirements. The provisions of Process l
Specification 0.C.1.1 (a) (originally issued 09-01-81) were not used l
for the construction era at SQN.
l Nuclear Operations is committed to perform modification activities in a manner equivalent to the original construction requirements. They did, however, fail to recognize their role in implementation of ANSI N45.2.5 requirements and did not implement a program to satisfy these requirements. This failure was recognized by Nuclear Operations in late 1985,and the noncompliance was documented on Corrective Action Reports NCO-CAR-86-001, DQA/0E-CAR-86-001, and SQ-CAR-86-03-01 in accordance with the Nuclear Quality Assurance Program. Interim corrective actions _
have been developed to assure compliance with these requirements.
These interim corrective actions include:
1.
A Division of Nuclear Quality Assurance (DNQA) directive for l
-certified QC inspectors to either perform 100 percent fit-up lR1 inspections or sample inspect welder and welder foreman checks l
which record fit up gaps for fillet holds.
l 2.
Revision of procedures to comply with the DNQA directive.
3.
Office of Engineering (OE) clarification of its position with regard to how documents such as ANSI N45.2.5 are incorporated into design a
output.
- 3 Page 2 of 3 00390
WP-16-SQN, R2 k
.f.
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OE performance of an engineering evaluation of fit-up gap practice
.4.
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.and conclusion that installation met design requirements.
p '-
OE (and others) random verification of fit-up conditions to 1
5.
substantiate the worst case assumption of the engineering
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evaluation.
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'These interim actions are being evaluated for additional program j
f
- Improvements and additional corrective actions will be implemented as t!
necessary, b
In summary, the issues considered in these concerns are not
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substantiated for the construction era at SQN but are substantiated for the Nuclear Operations era due to the following reasons:
SQN construction had a program in place which contained procedures p
i 1.
which adequately addressed the elements of ANSI N45.2.5.
Nuclear Operations has identified this issue as an area of 2.
noncompilance and has documented this noncompliance in accordance with QA program requirements. Corrective actions have been implemented which completely address this issue and confirm no effect on hardware.
The issues addressed in these concerns are closed based on completion of the. interim corrective actions for Nuclear Operations described above, g
1.; j part of which is contained in the following memoranda,
.jy t
i 1.
W. C. Drotleff's March 17, 1986 memo to R. B. Kelly (B27 860314 003) i h
2.
J. P. Vineyard's March 19, 1986 memo to J. W. Coan (B27 860319 002)
Additional corrective actions may be implemented based on the program l
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evaluation described above.
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00390 0
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(EMPLOYEE CONCERNS) 09/11/86
=O8:36:50 SD RD GD'_10 ------CONCERN-------
PRIORITY-ORG OTC EGG INSP (JClJT
_l S S,U E. P L AN T S
1 SR SOM-5-001-001 F
YWORDS:
INSPECTION. PROGRAM FIT-UP RESP PROB: WCDPW SECUOYAH - THE GENERAL CONST. SPEC. G-29C, PROCESS SPEC.
O.C.1.1 IS IN CONFLICT WITH THE TVA OUALITY ASSURANCE COMMITMENTS AS STATED BY THE TVA TOPICAL REPORT. TVA-TR75-1A. IN THAT PROCESS SPEC.
-0.C.I.1, SECTION 6.0 ALLOWS UNCERTIFIED WELDER FOREMEN, WHO HAVE DIRECT RESPONSIBILITY FOR THE INSTALLATION, TO PERFORM PRE-WELD INSPECTIONS.
NUCLEAR POWER CONCERN. Cl HAS NO FURTHER INFORMATION.
IR: l-85-768-SON STAT:
RC:
TECHNICAL COMMENTARY:
ISSUE CONSIDERED:1. UNCERTIFIED WELDER FOREMEN PERFORM PRE-WELD INSPECTION 2.
DOES THIS VIOLATE TVA OUALITY ASSURANCE REQUlHEMENTS?
CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
S 1
SR SOM-5-001-002 KEYWORDS:
INSPECTION PROGRAM FIT-UP RESP PROB: WCDPW SEQUOYAH - UNCERTIFIED WELDER FOREMEN ARE REQUIRED BY TVA TO PERFORM PREWEL INSPECTIONS ON INSTALLATIONS THEY ARE DIRECTLY RESPONSIBLE FOR WHICH IS A VIOLATION OF ANSI REOUIREMENTS. NUCLEAR POWER CONCERN. Cl HAS NO FURTHER IN-FORMATION.
IR: 1-85-768-SON STAT:
RC:
TECHNICAL COMMENTARY:
'SSUE CONSIDERED: UNCERTIFIED WELDER FOREMEN PERFORMING PRE-WELD INSPECTIO VIOLATE ANSI N45.2.5, REQUIREMENTS.
.eT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
W 1
SR WBM-5-001-001 PROB: WCDPW KEYWORDS:
INSPECTION PROGRAM FIT-UP WATTS BAR - THE GENERAL CONST. SPEC. G-29C. PROCESS SPEC. O.C.1.1 IS IN CONFLIC1' WITH THE TVA QUALITY ASSURANCE COMMITMENTS AS STATED BY THE TVA TOPICAL REPOR TVA-TR7f-1A. IN THAT PROCESS SPEC.
O.C.1.1.
SECTION 6.0 ALLOWS UNCERTIFIED WELDER FOREMEN, WHO HAVE DIRECT-RESPONSIBILITY FOR THE INSTALLATION, TO PERFORM PREWELS INSPECTIONS. NUCLEAR POWER CONCERN. Cl HAS NO FURTHER INFORMATION.
IR:
STAT:
RC:
TECHNICAL COMMENTARY:
INSPECTIONS?
. ISSUES CONSIDERED:1.DO UNCERTIFIED WELDER FOREMEN PERFORM PRE-WELD 2.lS THIS A VIOLATION OF TVA QUALITY ASSURANCE REQUIREMENTS? 3.lS THIS A VIOL-ATION OF ANSI N.45.2.5 REQUIREMENTS?
E w e,- - -
09/1b/86
-(EMPLOYEE CONCERNS)
~.", CAY ISSpE PLAAT' PRIORITY ORG QTC EGG INSP.SD RD GD 10 ------CONCERN-------
G8:36:50
~
D' 1
NSRS SR BEM-5-001-001
,7.
YWORDS:
.lNSPECTION PROGRAM FIT-UP RESP PROB: WCDPW y--
.$T BELLEFONTE -~THE: GENERAL'CONST'. SPEC. G-29C. PROCESS SPEC. O.CJ1.1 IS IN l
CONFLICT WITH THE TVA QUALITY ASSURANCE COMMITMENTS AS STATED BY T L
. REPORT.-TVA-TR75-1A. lN THAT PROCESS SPEC.
0.C.1.1.
SECTION 6.0 ALLOWS j
UNCERTIFIED WELDER FOREMEN. WHO HAVE DIRECT RESPONSIBILITY FOR THE
?
TO PERFORM PREWELD. INSPECTIONS. NUCLEAR POWER CONCERN. Cl HAS NO FURT j
INFORMATION.
STAT:
RC:
IR:
4 TECHNICAL COMMENTARY:
=lSSUES CONSIDERED:1. UNCERTIFIED WELDER FOREMEN PERFORM PRE-P 2.THIS IS A VIOLATION OF TVA QUALITY ASSURANCE REQUIREMENTS.
i 3.THIS IS A VOILATION OF ANSI N.45.2.5 REQUIREMENTS.
i
?^I 1882! ELAN { {R((R}(( gRg g}g {gg_ {NS{ Sg Rg gg {g ------CONCERN-------
B 1
NSRS SR BEM-5-001-002 f
I.
KEYWORDS:
INSPECTION PROGRAM FIT-UP RESP PROB: WCDPW BELLEFONTE - UNCERTIFIED WELDER FOREMEN ARE REQUIRED BY TVA TO PER
~ INSPECTIONS ON INSTALLATIONS THEY ARE DIRECTLY RESPONSIBLE FOR WHICH IS A VIOLATION OF ANSI REQUIREMENTS. NUCLEAR POWER CONCERN. Cl HAS NO FURTHER INFORMATION.
STAT:
RC:
IR:
TECHNICAL COMMENTARY:
INSPECTIONS.
Jh58UESCONSIDERED:1.UNCERTIFIEDWELDERFOREMENPERFORMPRE-WELDN45.2.5 REQ
- V.L 2.THIS IS A VIOLATION OF ANSI 4;f lON OF ANSI N.45.2.5 REQUIREMENTS?
SD RD GD 10 ------CONCERN-------
N F
_ CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP F
1 NSRS SR BFM-5-001-002 1
p KEYWORDS:
INSPECTION PROGRAM FIT-UP RESP PROB: WCDPW TO PERFORM PRE-FERRY - UNCERTIFIED WELDER FOREMEN ARE REQUIRED BY TVA WELD INSPECTIONS ON INSTALLATIONS THEY ARE DIRECTLY RESPONSIBLE FOR WH BROWN'S
~ VIOLATION OF ANSI REQUIREMENTS. NUCLEAR POWER CONCERN. Cl HAS NO FURTHE J
INFORMATION.
6:
STAT:
RC:
{
IR:
TECHNICAL COMMENTARY:
PERFORM PRE-WELD INSPECTIONS?
h ISSUES CONSIDERED:1.DO UNCERTIFIED WELDER FOREMENTVA QUALITY ASS 2.18 THIS A VIOLATION OF TlON OF ANSI N.45.2.5 REQUIREMENTS?
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Page J ot 4 (EMPLOYEE CONCERNS) 09/1,1/86 48:36:50
.. CAT ISSyE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10
CONCERN-------
W 1
DO SR Wi-85-030-007
~YWCRDS:
REINSPECTION PROGRAM PAINT PROB: WCDPW THE WBN FSAR COMMITS TVA TO THE REQUIREMENTS OF AWS D.1.1 FOR STRUCTURAL WELDING. CONTRARY TO THESE REQUIREMENTS, THE G-29C PROCESS SPECIFICATION WAS MODIFIED TO REFLECT LESS STRINGENT INSPECTION REQUIREMENTS (E.G.
VISUAL INSPECTION OF WELDS THROUGH PAINT (CARBO ZINC PRIMER) AND NO DOCUMENTED INSPECTION BY CERTIFIED VISUAL INSPECTORS (FIT-UP, IN-PROCESS) PRIOR TO FINAL INSPECTION.) Cl HAS NO ADDITIONAL INFORMATION. NUC. POWER DEPT. CONCERN.
1R:
STAT:
RC:
TECHNICAL COMMENTARY:
ISSUES CONSIDERED:
1.
INSPECTION OF WELDS THROUGH PAINT.
"~
2.
FITUP INSPECTIONS BY WELDER FOREMAN.
CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
W 1
NSRS P4 SR IN-85-212-001 KEYWORDS:
INSPECTION PROGRAM FIT-UP RESP PROB: WCDPW WELD FIT-UP INSPECTION WHICH WERE PERFORMED BY OC DURING 1978-1980 ON DUCT SUPPORTS IN REACTOR BUILDINGS #1 AND 2 ARE NOT BEING PERFORMED ON DUCT SUPPORTS PRESENTLY BEING INSTALLED IN REACTOR BLDG.
- 2.
Cl OUESTIONS WHY THESE FIT-UP INSPECTIONS WERE REOUIRED DURING 1978-1980 AND NOT REQUIRED AT PRESENT TIME.
CONSTR. DEPT. CONCERN. FURTHER INFORMATION AVAILABLE, WITHELD DUE TO CON-FIDENTIALITY.
IR: 1-85-444-WBN STAT:
RC:
TECHNICAL COMMENTARY:
SUE CONSIDERED: FIT-UP INSPECTIONS WERE DELETED FROM DUCT SUPPORTS.
-JAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
j
.\\
F 1
NSRS SR BFM-5-001-001 PROB: WCDPW KEYWORDS:
INSPECTION PROGRAM FIT-UP RESP BROWN'S FERRY - THE GENERAL CONST. SPEC. G-29C, PROCESS SPEC. O.C.1.1 IS IN
]
CONFLICT WITH THE TVA OVALITY ASSURANCE COMMITMENTS AS STATED BY THE TVA TOPICAL REPORT, TVA-TR75-1A, IN THAT PROCESS SPEC.
O.C.1.1.
SECTION 6.0 ALLOWS
)
UNCERTIFIED WELDER FOREMEN, WHO HAVE DIRECT RESPONSIBILITY FOR THE INSTALLATION,
]
TO PERFORM PRE-WELD INSPECTIONS. NUCLEAR POWER CONCERN. Cl HAS NO FURTHER
)
INFORMATION.,
' ~
i IR:
STAT:
RC:
TECHNICAL COMMENTARY:
i ISSUE CONSIDERED: 1.DO UNCERTIFIED WELDER FOREMEN PERFORM PRE-WELD INSPECTION?
]
2.lS THIS A VIOLATION OF TVA QUALITY ASSURANCE REQUIREMENTS?
4 i
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L-E Page 4 of 4 UI* '09'/11/86 (EMPLOYEE CONCERNS)
I' '.QAT 08:36:50
'k ISSUE PL. ANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
l W
1 SR WBM-5-001-002 W -i,.2,
~ '
NWORDS:
INSPECTION PROGRAM FIT-UP RESP PROB: WCDPW
-i I
SEQUOYAH - UNCERTIFIED WELDER FOREMEN ARE REQUIREO BY TVA TO PERFORM PREWELD INSPECTIONS ON INSTALLAllONS THEY ARE DIRECTLY RESPONSIBLE FOR WHICH IS A VIOLATION OF ANSI REQUIREMENTS. NUCLEAR POWER CONCERN. Cl HAS NO FURTHER INFORMATION.
IR:
STAT:
RC:
TECHNICAL COMMENTARY:
ISSUE CONSIDERED: UNCERTIFIED WELUER FOREMEN PERFORMING PRE-WELD INSPECTION IS A VIOLATION OF ANSl(N45.2.5) REQUIREMENTS.
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sd. 4 Attactment 2
.a tv s+ ssp eop.wp 5.es:
IU80 1 Of 9 4
t.L'NITED STATES GOVERN 31ENT e-M 617IOTdndMM
^
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TENNESSEE VALLEY AUTH,QPJTY,,
'~ -i TO: H. L. Abercrombie, Site Direct'or, Sequoyah Nuclear Plant FROM: K. W. Whitt Director of Nuclear Safety Review Staff, E3A8 C-K DATE:
((g j g ggpq
SUBJECT:
NUCLEAR SAFFTY. REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL Transmitted herein is NSRS Repor't No.
T-85-768-SON Subject UNCERTIFIED WELDER FOREME!T PERFORM PREhELD INSPECTIONS Concern No.
SO'4-5-001-001 and /f0W54iD'90027 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 W. D. Stevens at telephone _6231 N
. f sy-Recommend Reportability Determination:
Yes No I
/'
n Ers' tor, NSRS/ Designee
/
e WDS:JTH.
Attachment cc (Attdehment):
s.
W. C. Bibb, DFU T J.
J. W. Conn, W9C135 C-K.n W. T. Cottle, WBN
-~'
James P. Darling, DLN R. P. Denise, LP6N40A-C C. B. Kirk, SQU F. E. Laurent, CEO-WBN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Zeic Sliger, LP6N48A-C J.11. Sullivan, SQN j
Kent Therp, IOB-WBN
, ~J)93U
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page 2 og 9 r
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S2 : s. -TE!!!!ESSEE-VALLEY AUT!f0RITY. :
NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT No.
I-85-768-SQN EMPLOYEE CONCERN:
SQM-5-001-001 SQM-5-001-002 i
. ? ': -..
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~. -... - -..
SUBJECT:
~
UNCERTIFIED WELDER FOREMEN PERFORM PREWELD INSPECTIONS
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.t.!.! C..C.T...i."=.l'.1._v"rk_. r '.., _',. '.
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DATES OF' INVESTICATION:
DECEZLDER 30, 1985 - JANUARY 20, 1986 INVESTIGATOR:
v-E.[F.HARWELL
/
DATE
.. t h,
I'
- REVIEWED BY:
b Z!/4 b
~
'1
.L.' E. BRCCK DATE W
APPROVED BY:
I
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- w. D. STEvENS.
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Page 3 of 9 b '. -
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( '_
A Huclear Safety Review Staff (NSRS) investigation was. conducted to determine the validity of.two~ expressed employee concerns as roccived by.
' Quality Technology Company-(QTC)/ Employee Response Team (ERT).
The
~~
concerns of record, asfsummarized on the Employee Concern Assignment Request Forms from QTC and identified as SQM-5-001-001 and SQM-5-001-002, respectively, stated:
Sequoyah - The Cencral Constructicn Specification C-29C. Process Specification O.C.1.1 is in conflict with the TVA Quality Assurance Commitments as stated by the.TVA Topical Report, TVA-TR75-1A, in that process spec. 0.C.1.1, section 6.0 allows uncertified welder foremen,-.~
who have direct responsibility for installation, to perform pre-weld inspections;'Ndelear' Power Concern.
CI'h'as no'furtherfinformation.
Sequoyah - Uncertified welder foremen are required by TVA to perform pre-weld inspections on installations they are directly responsible
~for, which is a violation of ANSI requirements. Nuclear power
' ' ' ~~ Concern.
CI has no further information.
Since'these two. concerns deal with the same area, the investigation was done in such a manner that a single report covers both concerns.
II. SCOPE A.
The scope of the investigation was determined from the stated fy 6
concerns of record to be three specific issues requiring investigation:.._
- . n;.. _...
1.
Do uncertified welder foremen perform pre-weld inspections?
2.
Is this a violation of the TVA quality assurance cormitments?
- i..
3.
Is this a violation of ANSI requirements?
B.
In conducting this investigation, USRS reviewed *the AWS code, ANSI standard commitments, QA tier requirements, welding and inspection
, program requirements, and plant implementing instructions. Several people were interviewed who had ocen associated with defining welding and inspection requirements or had been responsible for fleid impicmentation.
g.1 -
s
' III.
SUMMARY
OF FINDINGS '
A.
Requirements and Commitments 1.
Topical Report TVA-TR75-I A, Rev. 8. Section 17.2, **TVA Quality Assurance Program, Program Applicable to Plant operation."
2.
UUREC-G0ll, Safety Evaluation Report, dated Harch 1979, for
/<
Sequoyah Nuclear Plant Units 1 & 2 Docket Nos. 50-327 and 50-328.
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Attachment.2 c'-
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4. 3. -
l Nuclear Quality Assurance Manua'1, part II, Section 5.3,,
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" Maintenance and Modification Inspection program."
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cer.e4a > ANSI /AWS:D;1.li " Structural Welding Code - Steel."
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.-B.~. Findings..-
~
rt.< :1.:z(The Sequoyah structural stee1' components were designed in accordance with the-American Institute of Steel Construction (AISC) specification,1This was acceptabic to the ITRC as stated
...c...in.the Sequoyah Safety Evaluation. Report (Ref. 14).
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2..rueThe-welding' associated with.the AISC specification. particularly -
.e
.. welded. steel. structures; is governed by the knerican. Welding.
...: Society"( AWS) Code -Dl:1"(Ref.16). -This AWS Code requires that all completed welds be visually inspected:
" Visual inspection of welds may'begin.immediately'after the' completed welds have cooled to ambient' temperature."
.. c.
3.-
The AWS Code states, "The Inspector shall, at suitable intervals, observe joint preparation, assembly practice, the
.._. welding. techniques, and. performance.of each welder, welding
- operator, and. tacker to make certain that the applicable requirements of this code are met."
4.-.The rd.~ Code requires the inspector to verify the size, length, 3'.' Ji
'((SE and location.cf,all. welds; that correct procedures are used;
~,that. welders are. qualified; and that proper filler material is-used.
The AWS Code states that, "Other acceptance criteria, different from these specified in the code, may be used when approved by the Engineer." The engineer in this case is the design organization.
-....... - m...
5.
References 4 and 5 require that all individuals performing QC
. inspections be qualified'and'their. qualifications be documented.
~
6.
oplant implementing procedures and instructions (References 1, 8, 4
,.,;and.10). require that inspectors: performing QC inspections be
- .qualif.i.ed.and certified. Reference.1 states, "QC inspection c-
~ ~ ".
shall be performed by qualified individuals.ot.her than those who performed or directly supervised - the activity.'bding inspected."
- q 7.
process Specification O.C.1.1 (Reference 6) was prepared and issued by the design organization as being their defined requirements for welded fabrication of steci structures in accordance with AISC specification, and the AWS Structural Welding Code.
Process Specification O.C.1.1 requires, as a minimum, the pre-weld and in-process welding activitics be verified by the welder and his foreman and be subject to a quality surveillance program which verifics that these acitivitics are being properly performed.
The post-welding (finished weld) inspections are performed by an AWS certified
,[']
inspector who is trained and qualified.
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process.0pecification~0;C.1.1 is not always invoked N., s '
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dockplani:; however "when 'it-is h6h
- invoked the inspection j
requirements become a negotiated agreement between the ofgsnization perfordiirig%he work'and QA as the means of meeting -
the interpreted, applicable code requirements.
'8.
A design engineer Individual E, knowledgeable with the AWS Code requirements and the process. specification,"said that the pre-weld and -in-process welding' verifications performed by the T
welder and the foreman were not QC inspections and were not required 'to be QC inspection hold points by the code.
Individual E said that the only QC inspections required by the l
code were' the final. weld" inspections performed by the' QC' - -*
1 L'
inspectors and verfication of compliance"via a surveillance program (which is implemented by QA/QC personnel).'
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This in'cotisistent with'the' code requirembnts ' verified'by the l
investigator in Findings 2, 3, and 4
{
9.
The investigator was advised in discussing with plant QA staff personnel that the welding surveillance program is accomplished
{
per the instn2ctions of QA Section Instruction-Letter 18:1,
)
Surveys" (Ref. 13).
10.
Reference 12, an inplant survey, identified a difficulty that the QA staff was/is having with meeting the inspection l
,[j)
..( '
requirements of process Specification 0.C.1.1.
-The specification allows for increasing the si::e of the fillet weld to compensate for a fit-up gap greater than 1/16 inch. Since QC acceptance is based solely on the final visual inspection, QA conton'ds tfiat it is impossible to determine if the fillet weld
~
size has been adjusted to compensate for fit-up gap in excess of 1/16 inch since a QC inspection at fit-up was not required.
Their (QA) recommendation was that craftsmen should note whether the weld fit-up gaps exceeded the 1/16 inch.
- r -
j IV.< CONCLUSIONS -AND REC 0!DtENDATIONS-I A.
Conclusion,s..
.,,g...
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n i 1.
The concerns of' record were not substantiated for the following reasons:
The pre-weld and in-process welding verification activities a.
'done by'the weldce foreman are not considered QC inspections and are not required to be-QC inspected by the governing codes.
b.
Since these in-process verifications, discussed in IV.A.1.a. are not QC inspections, only the final weld inspection and the surveillanec activities require a
,d qualified and certified inspector.
3 i
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Page 6 of 9
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c.
Since these in-process verifications, discussed Ih'
~ {';)# - ~~
-IV.A.1.a. do not require a special process (UDE
^^ ~~
inspections), individuals perf orming these activities do -
not have to be trained and certified per ANSI standards.
In fact, the AWS Dl.1 Structural Welding Code is an
~~
~
American National Standards Institute approved document.
d.
Although the lack of QC hold point inspections for pre-weld activities seems awkward compared to the ASME requirements, Process Specification O.C.1.1 meets the requirements of the AWS Structural Welding code and is consistent with the commitment to the NRC to design and fabricate structural components to the AISC specification.
B.
Recommendation USRS agrees with the recommendation made in QA.Inplant Survey Sa-85-A-005 that the craftsmen or foremen checking the fitup gap should note it in order that the QC inspector doing the final weld inspection will know what size fillet weld should be present.
Post Investination Findings Area Plan Procedure DPM U73M2 was revised on December 20, 1985, to tak'e exception to the preweld inspection activities of process specification O.C.1.2 by requiring these activities be done by a certified QC inspector for
'n all safety-related items. Per discussion with a Nuclear Service Welding s;}/
Engineer, P.S. O.C.1.1 should have been included, and a revision is presently being processed to take the same exception for this specification.
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' At ach:ent 2 Page 7 of 9 Y= ?
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DOCUMENTS REVIEWED IN INVESTICATION I-85-768-SQN
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AND REFERENCES 1.
Sequoyah. Nuclear Plant (SQN) Administrative Instruction AI-20 Rev. 10, dated November 21, 1984, " Inspection Program" 2.
SQN Modification and Additions Instruction M&AI-1, Rev. 9 dated August 5, 1985, " Control of Weld Documentation and Heat Treatment" 3.
SQN H&AI-11 Rev.11, dated September 4,1985, " Fabrication, Installation,"
and Documentation of Seismic Supports and Supports Attached to Seismic ' Category I Structures" 4.
Nuclear Quality Assurance Manual (NQAM), Part II, Section 5.3 dated'~
' July 30,1984, " Maintenance and Modification Inspection Progrmn" -
5.
TVA Topical Report TVA-TR75-1A, Rev. 8 Section 17.2.9, " Control of Special Processes," and Section 17.2.10
" Inspection" 6.
Area Plan DPM N73M2 Process Specification O.C.1.1, Rev. O, dated March 9,1983, " Specification for Welding of Structures Fabricated in Accordance with AISC Requirements for Buildings" L$[4'-
7.
Maintenance Instruction MI-6.21 Rev. 9, dated December 17, 1985,
" Repairs and Replacements of ASME Section II Components" u
8.
SQN? Technical Instruction TI-51, Rev. 29 Procedure No. N-VT-2..Rev. 2, dated July 1, 1982, " Visual Examinations of Welds" 9.
SQUP T-51, Rev. 29, Procedure No. N-VT-3, Rev. 4, dated April 23, 1985,
" Visual Examination of Weld Ends, Fit-ups, and' Dimensional Examination of Weld Joints"
?
10.
SQN Quality Accurance Section Instruction Letter No'.10.3, Rev. 2, F
dated March 16, 1982, " Inspection - Nondestructive Examination" SQi!"~ Quality Accurance Section Instruction Letter No. 10.4, Rev. 8, 11.
y dated November 12, 1985, " Inspections - QC Inspections" I
- R s
, 12. QA Inplant Survey Sa-85'-A-005, for period of August 19-23, 1985, j
"Special Processus - Welding" t
g-13.
SQN Quality Assurance Section Instruction Letter No. 18.1, Rev. 10, dated October 17, 1984, " Surveys" i
14.
NUREC-0011, Safety Evaluation Report, dated 1979, Sequoyah Nuclear Plant Units 1 and 2, Docket Nos. 50-327 and 50-328 s
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At t actuacn t 2 es;,
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Page 8 of 9
._15. *Sequoyah Cencral Design Criteria, SQU-DC-V-1.3.3.1, Rev. 4, dated g
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SePtembdr'4,'1984, " Additions After Hovember 14, 1979,-
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.Relinforced Concrete. Structural, and Miscellaneous Stoct
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16 ANSI /AWS'D1.1-1985,." Structural Welding Code - Steel " Hinth Edition, dated February 8, 1985, Section?6','" Inspection," and Section 8 "Worlenanship"
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Attachnent 2
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Page 9 of 9
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w EMt OYEE CONCERN A55IGwENT REiUEET
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TO: Direct r - NE 'i 5 TRANS GTTAL NUy. bet T50E17
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reesivec
- ne Erc '.oyee concern icentifisc
- below, anc nas assi r ec
- t. t e inexccter category anc.=riority:
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-Criority:
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Concern # SGM-5-001-002 i.-f 5 - 7 59-S/l Caregory:.
53 Confidentiality:
_YES
_NO (I&H) l Supervisor Notifie : X_YES ___NO NUCLEAR SAFETY RELATED YES -
Concern:
SEOUDYA-i
' UNCER"IFIED WELDER FOREMEN Ars: ru. QUIRED BY TVA TO PER ORYi PREWELD INSDECTIONS ON INSTALLATIONS THEY ARE DIRECTLY-RES:ONSIELE-.09
. W 1ICH IS A VIO_ATION OF ANSI REQUIREMENTS.
NUCLEAR POWER CONCERN.
-CI 5,AS NG :'URTHER I NFO Riv. AT I ON.
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us DEC 0-91985 MANAGER, ERT
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N5RS has assignec' renconsibility for inventigation of the above concern
-to E R~ __ _.
NSRS/E9T _
NBR5
_/___}2,45 OTnERS (53ECI,Y)
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R. B. Kelly, Di:ector of Quality Assurance, LP 4H'45A-C V. C. Drotlef f, Manager of Engineering, W12 A12 C-K ROM At tachmen t 3 with refe.rence Page 1 of 22
~
DATE March 17, 1986 CORRECTIVE ACTION REPORTS (CARS) DQA/0E-CAR-86-001 AND HCO-CAR-86-0
SUBJECT:
References:
- 1) R. J. Mullins me=orandum to R. W. Cantrell dated January 29,1986 (L16 860124 824)
- 2) NSRS Investigation Report I-85-768-SQN K. W. Whitt's memorandum to H. L. Abercrombie dated.
February 18, 1986
- 3) Your memorandum to J. A. Kirkebo, dated March 7, 1986 (L16 860307 800)
- 4) J. W. Cean's memorandum to L. E. Mart'in dated March 7,..
1986 (B27 860310 001)
Reference 1 and attached CAR DQA/0E-CAR-86-001 and reference 3 with attached CAR HCO-CAR-86-001 indicate that OE General Construction Specification G-29C was in noncompliance with Quality Assurance Program Topical Report commitments to ANSI N45.2.5, velding inspection personnel qualification requirements. This commitment appears in the portion of the topical report applicable to design and construction (Tables 17D-1 and 17D-
- 2) and in the portion applicabic to plant operation (Table 17D-3).
CAR SQ-
}
CAL-86-03-010 also attached to reference 3 is being handled by an v
evaluation described in reference 4.
I do not believe that G-29C is in noncompliauce with N45.2.5.
The CAR ref1'ects a difference of understanding concerning the role of C-29C in the engineering / construction / quality assurance process.
General Construction Specification G-29C is a key part of the OE effort to ensure the fune. tion and adequacy of all structures it designs. To accomplish this, it requirca a combination of inspectors and velding foremen to verify all work to ensure tW. it meets spec.ified workmanship standards. - OE also specifies all,of those preveld and postveld inspections required to ensure the fGnetion and integrity of design. These include the inspection requirements of N45.2.5 as appropriate based on the importance to safety.
These inspections are noted on the drawings and specifications for each individual feature on structures designed by OE.,We believe that the combination of velder foreman verifications plus the inspections specified on the drawings have been adequate to ensure the integrity of the designs constructed in the past.
OE is currently reviewing its policy for the type and detail of requirements to be included in its future design output documents.
This review plus the development of new procedures by your organization vill enatie the Office of Nuclear Power to cicar up any remaining misunderstandings about the roles of velding foreman verifications and quality assurance inspections.
In particular ve vould expect Nucicar Quality Assurance to specify all generic quality assurance inspections for i
velding to carry out TVA's commitments under the applicable topical report.
-[
OE vill continue Y
to specify the necessary inspection requi r ement s for velding.
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. at tactuacn t J with, reference
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'1 Page 2 of 22 f,.
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8 R. B. Kelly
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Eg March 17.,.1986....t.
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CORRECTIVE ' ACTION" REPORTS (CARS)"DQA70E-CAR-86' 001,' AND NCo-CAR-86-001
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To clarif y the curren. ' General' Cons truct' ion Specification' 'G-2' 9C, we,..
t are adding the following to sections _0.C.1.1 and 0.C.1.2 and 3.C.5.2:
~~
....... n 4...
This specification contains only ' technical requirements.
It doea not 'i@ edify 'a'6y.'hhe'1'e'h9hualitif asaur~a'nc'e' program Iequire-This spe' ifi'ch~ti' d~shall be implemented in connection ments.
c o
vith the requir.ed nucl. ear quality assurance program when it is used to fabricate 'an item requiring nuclear safety assurance.'
I will also revise section 6 of' O.'C.1.'1 and 0.C.1.2 an'd section 2 of 3.C.S.2 appropriately as follows to emphasize the scope of the requirements.
"Th'e' ~ verifications and/or~ irispections required by this~
specification are not a substitute for the inspections required by OE-approved drawings.
They also are not a substitute for the
'fequirement?s' of a ' nuclear quality assurance program. The
' requirements of the drawings'and quality assurance program,
.I including requirements for personnel certification, shall be "j
implemented.
Additionally'in 1981, the design an...d constrbetion portion of the Quality s.
Assurance Program Topical Report was revised
- to' take additional exception to ANSI N45.2.5.
This was identified as exception 4, "Does not perf orm fit-up inspection of structural velds on a 100 percent basis." NRC questioned this exception'in 1982. The OEDC program'for* veld fit-up inspection, which did not require fit-up inspection of all velds was determined to c6mply with ANSI N45.2.5 (see NEB 820716'272). The exception was deletsd'from the design'.and construction portion of the Quality Assurance. Program Topical Report.
See attached NEB 820716 272 for i.n. f ormation.
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.s Additional Backtround Information The identical perceived condition adverse to quality was identified as Employee Concerns SQN-5-001-001 and SQN-5-001-002. The concerns vere investigated by NSRS.
(See their report number I-85-768-SQN - Ref erence 2.)
They concluded the concerns were not substantiated b :use "the preveld and in process velding verificatica activities d6ne by the velder foreman are not considered QC inspections and are not required to be QC inspected by the governing codes."
(
Q.
096052.02
F
..I, o A'.tachment 3 with reference
' l Fage 3 of 22
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R..B. Kelly v -
~
March 17, 1986
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" ' r.m!!"r A r"".C" Y"IT.'"J ( C.!.*J.! ) ' D*C /C.. ':. "- f.' ** ' i.!T l' ' '-. I. "
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CORRECTIVE ACTION REPORTS (CARS) DQA/0E-CAR-86-001 AND HCO-CAR-86-001
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A very similar, perceived condition adverse.to quality as documented in these CARS has been evaluated previously by the former Office of Engineering, Design and. Construction..(OEDC). organization and the NRC.
That
)
perceiv,ed condition, adverse to quality vas.;that the OEDC Quality Assurance Program; did not..r.equire.conpliance.with ANSI N45.2.5,
!i required. veld. inspections.7: This commitment.vas..and is :in the design
)
and construction,portioni,of,the Quality. Assurance Program. Topical C
Report. The specified inspections and implementation vere found to be in accordance.vith ANSI.H45.2.5.
b The perceived f ailure to comply with ANSI N45.2.5 preveld inspection I
requirements in 1980 resulted from a concerned employee's perception that OEDC was in noncompliance with four requirements of ANSI H45.2.5 as committed to in the design and construction portion of the topical report.
An audit finding (BLN.W80-08-01) was issued to a previously completed audit to document.this concern.
The audit finding was considered significant, reportable, and generic to all. plants under construction.
... s.w s.
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As a result of evaluating this audit finding the OEDC method of specifying e'
and impicmenting velding inspection requirements were determined to be in compliance with ANSI H45.2.5.
The NRC agreed that it was in compliance with ANSI H45.2.5.
(The audit finding, final report to NRC, and NRC.
l closure.are documented in BQA 821022 006, A27 810622 023, and NE3 82-0903 220, g,es,pect.ively and,are, attached.for. information).
...-s.
Based on the foregoing discussion, I am-confident that the OE program and j
design. output documents, meet-all :applicabic. ANSI. N45.2.5 requirements f or l
veld,, inspection.
a c. c.
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W. C. DrotlefT I
JAR:WPJ:MP cc: RIMS, SL' 2'6" C-K '
h H. L. Abercrombie, Sequoyah ONP R. R. Hoesly, 9-113 SB-K R. W. Dibeler,11-142 SB-K R. O. Barnett, W9 D224 C-K L. E. Martin, LP 6N 47A-C N. R. Beasley, A10-BFN ENG C. C. Mason, MR 6N45B-C
/
W. C. Bibb, Browns Ferry J. A. Raulston, W10 C126 C-K
- 1 C. Bo nine, Jr.,12-108 SB-K T. W. Roberts, W5 D181 C-K W. R. Brown, 9-169 SB-K J. C..Standifer, P-104 SB-K J. W. Conn, W9 C135 C-K J. P. Vineyard, A8 Sequoyah ENG, W. T. Co t t l e, MR 6 N 46 B-C J. F. Weinhold, W12 B34 C-K J. P. Darling, ONP, Bellefonte W. P. -Joest, W9 B81 C-K Project Manager, 9-167 SB-K 5
- Please revise C-29C as indicated by Pav 1, 19R6 p
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n IEnto STATES covens.utxT y
c00124 824 uro u
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. with references
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~.Meptoran i.
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d JM 0 *c5 To R'.~4. Cantrell Manager of Engineering, W12 A12 C-X
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FR031
- R. J. M.ullin Director of Quality Assurance. LP AN ASA-C.
CT INatts i gy - ; -
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JAN 2 91986 Nne, i m:n
"^TE i c_.m....
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SL*DJ ECT:
CONDITION ADVERSE TO QUALITY (CAQ) - CENERAL CONSTRUCTION SPECIFIC ATIOUWits
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In accorda'nce with requirements'of the UQAM, part V, section 16.1 I Cc'-er s
'(ID-QAP-16.1-)..'the - atta'ched Correctiver ActiontReport.
I I
No. DQA/0E-CAR-86-001-requireseaction-by your: organization for:
,,,y s disposition. ;;Le J : i." ' C L ' o -
- f. m ;~ uents :;.
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The attached CAQ identifies apparent inadequacies in Cencral Construction Specification r;-29C. (process Specifications 0.C.1.1*, O.C.1.2, and
--bO(
3.C.S. 2 ). These inadequacies involve. welding. inspection requirements that allow inspections of safety-related welds by noncertified CD,.MC- -.
personnel. These inadequacies were. identified during the Welding
_g,vproject's Phase I Program Assessment for SQN Nuclear Operations.
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- ; u-RFC The Division of Quality Assurance (DQA) is assuming the role of
- .uel GO organization as specified by ID-QAP-16.1, paragraph 2.3.c, and 1 g
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requesting the Office of Engineering (OE) to take the following action as Q NAL hbM OSG Upon,t eceipt of this memorandum.. confirm in writing that the act ons DSG l
l requested.below.be taken or offor suitable alternatives.
- i h SSG }
Evaluate the attached CAQ h significance in accordance wit j j 1.
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- *" ' requirements of,.the. 0EcQA. program..If significant:
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a..+ Evaluate for reportability in accordance with 10 CFR 50. 356 dnd
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process as appropriate.
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J b.
Determine and document the cause of' t'he 'coEdItion.
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Specify corrective action to preclude recurrence.
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2.
Specify'the remedial corrective action.
DQA recommends the f olllbwing l
corrective action to resolve this matter.
l l% P Irn.
Establish and document in OE procedures more definitive cruecu l
7 a.
to be utilized by engineering design personnel'to determine'when to specify preweld inspections in design output documents for
)
safety-related structural items.
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. NEB MASTER FILE.
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Buy U.S. Sa:ines Bonds Rerularly on the Famil.%rr,* as Pls.,
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- ui'.h ref erences
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-CONDITION' ADVERSE TO-QUALITY-(CAQ)
GENERAL CONSTRUCTION SPECIFICATIOU -"
(c-29C)
--- e " 2.-
/..-.;
q....,......v :...
.4 b.
Revise OE proced_ures to provide a method for clearly identifying on design output documents (i.e., drawings, specifications).those..,-,g welds requiring weld inspections.
- .r_..
.:,... s. et, s.. >.
.s c
. u..:"::... t :
- m. :. ;....
4..
!,I c7* 7 Perform and document an engineering evaluation to detetuine if----~~......-
W,. structural-welds talready.. completed at. TVA.'s. nuclear facilities-are
.a.
. ::.. :. acceptable without having preweld inspections by, certified i.
inspection personnel, and if not, what corrective action is needed.
[
d;. ; Revise appropriate General. Cons cuction Specifications he.g.,
j.
G-29C) and. existing design drawings to correct any in:.dequacies.
. i....
u, erre:r.Pending OE's. conclusions.on this. subject..TVA's comm'itments to ANSI N45.2.5-1974 may require clarification in the TVA Topical Report (TVA-TR75-1A).
tr
, : i....
I Please: report yeur course. of action to DQA within 30 days of the date of I '
- Y... -
this. memorandum.
v.
j F. B. (Pete) Smith has been designated by me to coordinate the resolution of*this.CAQ.
If you have any questions or need, additional.infcruation.
please. call him at Chattanooga extension 5302.
- - - ~ ~
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- R.0d. Hullin
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JEL:FBS:DFJ:CCH
' " ~ ~ ' " " ~ " ~ ' - ~ ~ '
Attachment ce cc (Attachment):
t:
.W.
T. Cottle, OUP, Watts Bar H. L. Abercromble, ONP, Sequoyah J. P. Darling, OUP, Bellefonte W. C. Bibb, Browns Ferry R. W. Dibeler,11-142 SB-K C. Bonine, Jr.,12-108 SB-K L. E. Hartin, LP 6N 47A-C W. R. Drown, Jr., 9-16 7 SB-K C. C. Hason, HR 6N 458-C
_~
J. W. Conn, W9 C135 C-K 02681 l
l f,
(. ;)
.y l
l l
l i
/,ttachment 3 with references Page 6 of 22 x
FEB 6 1986' - EcB:ncu B05 '86 0 2 0 6 00
^
ze:
RIMS s' MR AN 72AJC
~
V [ cc.(Attachment):
R. O. Barnett, V9 D224 C-K
~
_. ~
"N.
R'. Be'asley, A10-BFN
~
J. V. Coan, V9 C135 C-K R. R. Hoesly, 9-113 SB-K jJ. A. Raulston, V10 C126 C-K - Please prepare a response from
-R. V. Cantrell to R. J. Mullin addressing r..:. -
.4
.this CAQ.
Plaafn nnta A we must
.?
.:e..... respond b March' 3, -1986, r porting our
.e -. :
-e. ~. 3. : -. y :* - ir.- '" course of ac vu.
If vut-ourse of action is not fully defined by that date we must
% r e n:...
c.w;:.. m v
- .give 'the schedule :for determining the
..w...
u n.:
s,. w m c ours e 'or ~ac t i o n. " -
'M
- " 2 ' ' '
- c. :.....
r..a. t n:.-
w
- ( :.. u :...a -
In preparing the response, please coordinate as necessary and, in a.
- particular, coordinate with J. V. Coan
't relative to the' conversation among Lawrence Martin, J. W. Coan, and me on
-... " D. : :' January 31,*1986, concerning OE tak.ing a much more definitive role in our definition of specifications for 3-inspection and test.
.')
Also note the request to evaluate the CAQ
~
for reportability in accordance with 50.55(e).
. ;, g. -
. e c.
- yr Please note that this CAR is identified in s
R. J. Mullin's February 4, 1986, memo to Those listed (L19 860203 862) as being required for restart on SQN.
--EGB T. V. Roberts W5 D181 C-K
~
J. C. Standifer, P-104 SB-K
.".'J.*P'.Vineyard, A8 SQN-ENG
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Page 7 of 22
.s,
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.e CORRECTIVE ACTICU REPORT
%m
- 7. )
N' Report No. 00A/OE-CAR-R6-001 Initiated.By D.
F.
Jacuith Date 1/1'!/85 Requested By (if applicable)
Significant /_,/ Yes f__/ Uo Assigned To Office of Entineerinst (CE)
ADVERSE CONDITION: OE drawings through reference to General Construction Specification C-29C for weld inspection requirements, allows noncertified personnel to perfot2 inspections of safety-related structural welding.
This is in conflict with quality assurance commitments (i.e., Tcpical Report, ANSI U45.2. ANSI U45.2.5) which require that inspections of safety-eciated structures, systems, and components must be performed by certifled QC inspection personnel independent of the job function.
Specifically: 1) C-29C. Process Specifications 0.C.1.1 and 0.C.1.2 requires the welding foreman to perfoes preweld inspections. 2) C-29C, Process Specification 3.C.S.2. paragraph 2.2 states that preweld visual inspections may be performed by noncertified personnel.
CAUSE (Root cause analysis required /_,/ Uot required /__/):
CORRECTIVE ACTIQU (1) Remedial corrective actions (s)
PROPOSED:
~4. l.n, Estimated Completion Date RESP SUPV. DATE (2) Action (s) to prevent recurrence COUCURRED:
/
Estimated Completion Date QA SUPV.
DATE APPROVAL: The resolution of the above described adverse condition is acceptable.
Recommended By PORC Chairman Date Approvcd By Site Director or Division Director Data completion - corrective action has been completed and is ready for verification by QA.
~
Responsible Supervisor Date Verification - corrective action taken as described above or with the following deviations.
1 y'/
Verified By QA Representative Date 02691-i Page of i
TVA 22C01 (OCC-2-7h)
. - with ref crences
,,,... sv.. p ies a ssi to* * u 5i
<,C nt T F.o sT.\\ T E s.G.o.g n s 3 g.T....
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~7 Me2230 rand um ' -
c-TENNESSEE VALLEY A11TIIORITY t
~
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TO.: sH. L,. Abercromb.ie..,, Sit.e.,Dir.e.c.t.o.r.,.S.equoyah' Nuclear Plant FROM: K. W. Whitt, Director of Nuclear Safety Review Staff E3A8 C-K DATE:
MB 1 C'oos SUBJECT!~ NUCLEAR..' SAFE.T.Y" REVIEW'STAEF'.INV. ESTICATION REPORT TRANSM g
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f ' t.
- a.i : :. - s...-
. Transmitted herein is NSRS, Repor;t No.
. :. i '.
T-85-768-SON
- n
.. - cc : t.u: ~; - r. *: - :. ~' :
..t' Subject UNCERTIFTED WELDER FOREMEN PERFORM PREWELD INSPECTIONS Concern No. __
SOM-5-001-001 nnd SOM-5-001-002'
.-..i :
' No response or corrective. action is required for this report.
It is b,cing transmitted to you for information purposes only.
Should you have any fques ti~onii,~p~ lea' FE con...
E...W. D. Stevens
-at telephone _6231 tac a,,
Reconsnend Reporta.bility Determinatio'ni~;
es No I
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g f
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y r.M'N E ERING WDS:JTH
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F. ; 1 C 'gg
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- Attachment cc (Attdehment):
' T WELDlHG PROJECT
~
t/
W. C. Bibb, DFN Noted
\\.4 Coen, gf4 J. W. Coan, W9Cl35 C-K (
, $ms W. T. Cot.tle, WBU
- 1 Jessee James P. Darling, BLU l.Pitzi R. P. Denice, LP6N40A-C
/ Stagnolia t
G. B. Kirk, SQN
,i F. E. Laurent, CEO-WDN g Prucitt
,-f,.Q gi, l
i D. R. Nichols, E10A14 C-K I
l QTC/ERT,'Natts Bar Nucicar Plant I
l Eric Silger, LP6N48A-C l
l J.11. Suilivan, SQN I Fd3 l
Kent Thorp. IOD-WBN i Toss 1
. 04930
- /
.J 9&
.g
Page 9 of 22 4
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{ t l' e '-y-TEN.N.E. SSEE VALL.E.Y._; AUT!!ORITY
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NUCLEAR SAFETY. REVIEW STAFF
~
NSRS INVESTIGATION REPORT NO.
I-85-768-SQN 1
EMPLOYEE CONCERN:
r......>..
,SQM-5-001-001 p.
SQM-5-001-002 i-_
' SUBJEC:
~ UNCERTIFIED ' WELDER FOREMEN PERFORM.PREWELD. INSPECTIONS s.+....
2.
- = u.ui a. m..u:u :s..
-t.....
ja..
DATES OF
':* " ~ ~ - * -
- INVESTICATION:
DECEMBER 30, 1985 - JANUARY 20, 1986
/
/,
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INVESTIGATOR:
/ j f&
E.[F.IIARWELL DATE
[
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S REVIEWED BY:
L. E. BROCK DATE t.u.i.. - TU,t.
4.
- ;,.: s.,
r APPROVED BY:
M V
W. D. STEVENS DATE 2..,.,
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._ uith references
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Page 10 of 22
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.I.
BACKGROUND a--
~
A Nuclear Safety Revie~wTola'f f""(NSRS) Tin'v'Estl'g's't' ion was conducted to
"' -' ~
determine the validity of two expressed employee concee' ns as received by _
Quality Technology Com'pahy (QTC)/ Employee Response Team (ERT).
The
~~
concerns of record, as summarized on the Employee Concern Assignment Request Forms.f rom QTC 'and identified as SQM-5-001-001 and SQM-5-001-002, respectively, stated:
s ha s Ot * ~.
Sequoyah - The Concral Construction Specification C-29C Process
~ Specification O.C.1.1 is in conflict with the TVA Quality Assurance Commitments as stated by the TVA Topical Report, TVA-TR75-1A, in that process spec. 0.C.1.1, section 6.0 allows uncertified welder, foremen, who have direct. responsibility' for. installation, to perform pre-weld c :"'
inspections Nuclear Power Concern.
CI has no further information.
Sequoyah - Uncertified welder foremen are required by TVA to perform pre-weld inspections on installations they are directly responsible
.for, which is a violation of ANSI requirements. ' Nuclear Power Concern. CI has no further information.
Since these two concerns. deal with the same area, the investigation was done in such a. manner..that.a single report covers both. concerns.a--------
II. SCOPE
,4 A.
The scope of the investigation was determined from the stated
- p concerns of. record,to..bc..thee.e.. specific issues requiring.------. --- -
investigation:
1.
Do uncertified welder foremen perform pre-weld inspections?
2.
Is this..a.vi.q.l.ation_of._the TVA quality assurance commitments?----
..n 3.
Is this a violation of ANSI
- requirements?
B.
In conducting this investigation, USRS reviewed the AWS code, ANSI standard commitments QA tier requirements, welding and inspection
, program requirements, and plant impicmenting instructions.
Several
' people were interviewed who had been associated with defining weld'.9; and inspection requirements or had been responsible for field implementation.
. t,
,' III. SUlUiARY OF FI! DIUCS -
A.
Requirements and Commitments 1.
Topical Report TVA-TR75-1A, Rev. 8. Section 17.2, "TVA Quality Assurance Program, Program Appiicable to Plant Operation."
g 2.
ITUREC-00ll, Safety Evaluation Report, dated Harch 1979 for i
Sequoyah Nuclear Plant Units 1 & 2. Docket Hos. 50-327 and 50-323.
f 1
. uith references A :y' Page 11 of 22 s:-
- ~
. n.,
Qg-3..
Nuclear Quality Assurarice Manual. Pat;t II, Section 5^3,
~,
" Maintenance and Modification Inspection Program."
~~'
...y a late m m e;v
.evte St.: : - y;;;;.
nve: 3 - :s:,.,:,:-.::.
wa4
.t*" ANSI /hhS D'.1.Td "StructhiairWelding: Code CSteel.";
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- .6..-
4 B.
' Findings:t
~
-1
- a.c,.
1.
The Sequoyah structural steel components were designed ha accordance with the American Institute of Steel Construction
.(AISC)
- s.
specification..This was acceptable to the URC as stated
.in the Sequoyah Safety Evaluation Report (Ref. 14).
..~...e....s v.
u.... n
- c.-
..-. : '..a.
- w; ' ' '
n.
2.' *
- The welding-associated
- with the AISC specification..partiedlarly.
v u.. welded. steel structures, is governed by the American Welding inti Society ( AWS) Code D1.1 (Ref~. 16).
This AWS' Code requires that all completed welds be visually inspected:
" Visual inspectica
.. of welds may.begin immediately' af ter the completed welds have ~
cooled to ambient temperature."
3.
The AWS Code states, "The Inspector shall, at suitable intervals, observe joint preparation, assembly practice, the
. welding -techniques, and performance of each welder, welding operator, and tacker to make certain that the applicable requirements of this code are met."
The AWS Code requ,y-mrpQ g
4.
ires the inspector to verify the size, length,
.*y and location of({q{ualified; and that proper fillyl welds; that' co
,];7 that welders are er material is used.
The AWS Code states that, "Other acceptance criteria, different from these specified in the code, may be used when approved by the Engineer." The engineer in this case is the design organization.
a-5.
References 4 and 5 require that all individuals performing QC inspections be qual.if, led'and their qualifications be documented.
6.
Plant implementing procedures and instructions (References 1, 8, and 10) r,. :
require that inspectors performing QC inspections be w.,. qualified and certified.
-Reference 1 states, "QC inspection shall be performed by qualified individuals other than those who performed or directly supervised the activity bping inspected."
s.I 7.
Process Specification 0.C.1.1 (Reference 6) was prepared and issued by the design organization as being their defined requirements for welded fabrication of steci structures in 5.:
accordance with AISC specification, and the AWS Structural Welding Code, process Specification 0. Col.1 requires, as a minimum, the pec-weld and in-process welding activitics be verified by the weldce and his foreman and be subject to a quality surveillance program which verifics that these acitivitics are being properly performed.
(finished weld)
The post-welding
< 10 inspections are performed by an AWS certified
.< _ y inspector who is trained and qualified.
/
7
n n u... u i.a e n c ; a u.n t et erences
,.i.,
page 12 of 22
., v, '
+
7-
~n Process Specification O.C.1.1 is not*.always invoked im 1 #
wor.kplans;chowevec; when it is not 16voked the inspection - -
, - ([-[j.
requirements become a negotiated agreement between the
~'
' \\;*'
4-
< organization. perf orming the work and QA as the means or meeting
))Ei interpreted, applicable code requirements.
~.
8.
A design engineer, Individual E, knowledgeable with the AWS Code
' requirements and..the process specification, said that the pre-weld and in-process welding verifications perfor.ned by the welder and the : foreman were not QC inspections and were not required to ~ be QC inspection hold points by the code.
' Individual E said that the only QC inspections required by the code -were thenfinal. weld inspections performed by the QC inspectors and verfication of compliance.via a: surveillance sprogram.(which is impicmented by QA/QC personnel).
m, v_..
..,...-....3._t,,
.y.
This in consistent vith the code requirements verified by the investigator in Findings 2, 3, and 4.
9.
The investigator was advised in discussing with plant QA staff b
Personnel that the welding surveillance program is accomplished L
per the. instructions of QA Section Instruction Letter 18.1,
,t \\
l'
" Surveys" :(Re f. 13 ).
7.f g (
Q'
,s l 10.
Reference 12, an inplant survey, identified a difficulty that
\\[iN the QA staff was/is having.with meeting the inspection f
.g.,
requirements of process Specification 0.C.1.1.
The
___gga specification allows for increasing the size of the fillet weld
- N(
-to compensate for a fit-up gap greater than 1/16 inch..Since QC acceptance is based solely on the final. visual inspection,_QA.
contends that it is impossible to determine if the fillet weld size has been adjusted to compensate for fit-up gap in ~ excess of
__1/16 inch since a QC inspection at fit-up was not required.
Their (QA) recommendation was.that craf tsmen should note whether the weld' fit-up. gaps exc'cediid the 1/16. inch..s jfa-hl,$;
,,,_ x.,J q a IV<. ' CONCLUSICUS AND REC 0!DIENDATIONS...
v, a
-- ((7 4u.
m...
A. _., Conclusions
, e,3
.a.
'?
1.
The concerns of record were not substantiated for the following reasons:
~
The pre-weld and in-process welding verification activitics a.
done by the welder foreman are not considered QC inspections and nec not required '.o bc QC inspected by the governing codes.
b.
Since these in-process verifications, discussed in IV.A.1.a. are not QC inspections, only the final weld
(,
inspection and the surveillance activities require a
\\{4/]
qualified and certified inspector.
1
,g%%........w..
.v A %.. & Cl et LHCC'a
..' g Page 13 of 22
?
~.
c.A ~,.'.Since these. in-process verification =. discussed in n.1
(~^
gy,],V.p.1.~p,'.,,p Inot.Jequire,a' specitil process -(UDE
( -......tnsp.ec tio,n,s.{., individuals {per,fo rging-the s e ac t ivitie" s dm ' with references Page 12 of 22 \\,, ? u. .1.. process Specification O.C.1.1 is not.always invoked kn. 4 {' wor,kplans;c howevec; when it:-is-not idvoked the inspection "- ( ( requirements become a negotiated agreement between the -~ N. ' f~ . organization. perf orming the work and OA as the means of meeting 4 n [EEe interpreted, applicable code requirements. A design engineer. Individual E, knowledgeable with the AWS Code 8. ' requirements ande.the process specification, said that the pre-weld and in-process welding verifications performed by the welder and the : foreman were not QC inspections and were not required to be QC inspection hold points by the code. ' Individual E said that the only QC inspections required by the ' code were thenfinal. weld inspections performed by the QC ' inspectors and verfication of compliance.via.a: surveillance iprogram (which is implemented by QA/QC personnel). e re.. v... - - t.- ':.na..- .. r.,, ~ This in consistent with the code requirements verified by the. investigator in Findings 2, 3, and 4. 9. The investigator was advised in discussing with plant QA staff g personnel that the welding surveillance program is accomplished t per the. instructions of QA Section Instruction Letter 18.1, ,t ' { " Surveys":(Ref. 13). S.( ef [ ,s f 10. Reference 12, an inplant survey, identified a difficulty that \\),*- .the QA staff was/is having.with meeting the inspection ,N requirements of process Specification 0.C.1.1. The [ ---gga specification allows for increasing the size of the fillet weld
- i to compensate for a fit-up gap greater than 1/16 inch..Since QC 8
g acceptance is based solely on the final. visual inspection,_OA contends that it is impossible to determine if the fillet weld size has been adjusted to compensate for fit-up gap in excess of 1/16 inch since a QC inspection at fit-up was not required. Their (QA) recommendation was.that craftsmen should. note whether the weld' fit-up. gaps exc' ecd'ed the 1/16. inch. s M, /.~J,l.. ,,s,1;r. u.a44.-9 m ' IV. CONCLUSIONS A!!D REC 0!DIENDATIO!!S...... -- ypnY -..........s s... A. Conclusions .s 1. The concerns or record were not substantiated for the fellowing .easons: The pre-weld and in-process welding verification activities l a. t f done by the welder foreman are not considered QC inspections and are not required to be QC inspected by the { governing codes. j i b. Since these in-process verifications, discussed in I i
F . w.,. e m. > u u. a r et er r.ac es Page 14 of 22 r .\\. * '~~ ~ r-if)sEN[,],EVIWED;,Ii;[,}jhe TICATION :1 85 '758 .)
- * * * "~ ~ ' * ** * "? ' gir, [,
. '.. [ ra ' ^ ^ -S 7,e. _ un.c :: ~~ Y. *u :' ' ' ' - - ~ ~ n. . AND,
REFERENCES:
..a
- 1
- 1.
Sequoyah Nuclear Plant (SQN) Administr ti dated November. r-21, 1984, a " Inspection Progran"ve Instruction 'A~I-20, Rev. a:. 10
- s. 2.
s SQN Modificatio'h"and Additions InstEuc'tl5 ~~ August 5, ;1985, " Control of '.,Jeld Documn M&AI-1, Rev. 9, dated 5.~.' ; en t.a tion _.and-Hea t-Trea tmen E" 3. SQN M&AI-11..Re... ~
- v. 11 ?-da ted Sep tember...'.~.-
4, Seismic
- Category I Structures"and Documentation of S upports Attached to 4.
Nuclear Quality Assu'rance Ma'nu[1 (NQAM).... ~. - - 1..= v.c July 30, 1984, " Maintenance and Modification InspectiPart II, Section . dated 5. TVA Topical Report TVA-TR75-1A, Rev on Program". Special Processes," and Section 17 2 10Section 17.2.9, " Control of .8 " Inspection" ...u.. ~ 6. Area P[an b'PM N73H2 Process Specificati March 9, 1983, " Specification for Weldin on 0.C.1.1, Rev. O, dated . :in Accordance with 'AISC Requirements. for Buildings"g .og., \\pf. * \\yn
- 7.,. Maintenance Instruction,MI-6 21
.b ~ " Repairs and Replacements of ASME S, Rev. 9, dated December ~~ .a ection XI components"17, 1985, 8. SQNP Technical Instruction TI-51 dated July 1, 1982, " Visual Examinatio, Rev. 29, Procedure No. g ns of Welds" i 9. SQNP T-51 Rev. 29 Procedure No " Visual Examination of Weld Ends. N-VT-3, Rev. 4, dated April Examination of Weld Joints" . Fit-ups, and Dimensional 23, 1985, 10. SQN Quality Assurance Se'etion Instru ti dated March c 16, 1982, " Inspection on Letter No. 10.3, Rev. 2, SQN 'uality Assurance Section Instru ti-Nondestructive Exam 11. Q dated November c 12, 1985. "Inspectionson Letter No. 10,. 4, Rev. 8, a;'. - QC Inspections" , 12. ~ QA Inplant Survey Sa-85-A-005, for period of A "Special Processes - Welding" ugust 19-23, 1985, g 13. SQN Quality Assurance Section Instructi i dated October 17, 1984, " Surveys" on Letter No. 18.1, Rev. 10 14, HUREC-0011, Safety Evaluation Report Plant Units 1 and 2 Docket Hos. 50 327, dated 1979, Sequoyah Nuclear P and 50-328 f,. i., 'A E / I g
~ .,..s...u.. s a miie5e5eacci 4Q.c,.. e.,,.- Page 15 of 22 L;* 15,. 1Sequoyah Ceneral Decir,n Criteri~i SQti-DC-V-1.3.3.1, Rev. 4, dated September 4, 1984, " Additions Af ter trovember 14
- 1979,
' Relinfocced Concrete, Structural, and Miscellaneous Steel". ~. e_. --~ k,. -1 ~...1.,. .s. s - Q~~j) ? 16. ?^ ~ ANSI / AWS D1.1-19F,5, St'cuEtu'ral' Welding
- CBd^e' ~ Steel," Ninth Edition, dated February 8, 1985, Section 6 "Incpection." and Section 8,
~ 4 4-
- Workmanship"
'"
- t 1* '-
f r,. g.- 0105S. 3. 4,- - -..4 .... J 1.,., ; ;; ; g... .~ '-s~ ,s .w. : ' ;.. -a,. -;, -. 5 ... c,., % --~6 ... ; ;. ;,,,,.t.,:,, ...-s. ~
- 8 *T. 01. *.
6.
- i. c..,y,y.,.,
+ " J.' l < P... .,4 - a i I ,..s-5- ...y s. a, t i t A .*'E, g 1 p y m A ~..;.) v. s. ql h 6
r L16 860307 800 klemorand um TFNNESSEE VALLEY AUTHORITY y., .: 3.,.. ,g,-
- ~ ~..
z_, 3 m,l_..TJ - J. A. Kirkebo. Director of Enginedr.cr ind T s I nical Ocevices. W12 A8,C X . ;IRO.%I Rf B. 'KEIy'['.Direc tk.. 6f ubb'[aNY.u.u.l.iY..y. AsSur'ir[e.e.~ LP..'iN 4 5 A'- r. ev a ~ .~ DATC
- . with references -
Page 16 of 22
SUBJECT:
SUBHITTAL OF NCO-CAR-86-001 A!!D SQ-CAR-86-03-010 FOR RECONSIDERATION Attached are copies of CARS HCO-CAR-86-001 and SQ-CAR-86-03-010 which are associated with the structural weld issue described in DQA/0E-CAR-86-001. 1 - These are being submitted for your reconsideration in accordance with the telecon on March 6 among you, L. E. Martin, and myself. R. B. Kelly i Jr.L: KC Attachment.s cc (Attachments): RIliS. MR AN 72A-C .) O' 0256 r, i t l i 1 1 t.* . g), I ( ' N\\ \\ ~ huar f.* S. Sawin ne Rnnale Rrnrilauriv asn ih.' Pass.s.nli.%,,in er Pin" L
c i..... t7 n< 7 e,. y '. , CORRECTIVE ACTICH ' REPORT .t.. Report tio.,NCO-CAR-PA-001 knitiate[5[ 0. F. Januith _ Date l'/53756 3,. 8. *_..._. i. L
- e...
. s, .. v.;., t. : - _.,,, ; ;.cj,,., : a ;...., Requested By (if applicable) C. J. Pit:1 ~~ Significant /jp Yes /_) No Assigned To _ _Mr.chanical Branch trUC OVCS i ADVERSE CotIDITION: DPH N13H2. Process Specification 0.C.l.1 is inadequat.e in that it allows the welder foreman to perfor:n preweld inspections *on CSSC structural items. This does not agree with our com;nitments (i.e., . Topical Report. ANSI, N45.2.5 and N18. 7 ).which require',use.of certified QC t.intpection. personnel, litdependent. of. the job function. -(Ref erence,- Weiding Proicet - Nuclear Operations - Phase I - SON Proeran Assessment) .. w.
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. ~. ;. ~ av -CAUSE (Root cause analysis required M/.. Not required L /):DPM N73M2 was not properly reviewed to ensure ccmpliance with AN,SI N45.2.5-1974 CORRECTIVE ACTION (1) Romodial corrective actions (s) PROPOSED: DPM N73112 has been revised to require use of certified QC inspectors to perform preveld inspections on CSSC S M /J 2c 8/. Estimated Completion Date 3/14/86 RESP ~SUPV. DATE structural items. (2) Action (s) to prevent recurrence CONCUP-ED Future PHPs which reference OE C-specs, will be more ,) thoroughly reviewed by INC SVCS 6 DQA to ensure As / Estimated Completion Date N/A 4 hUPV.- DAYE conoliance with OA_ commitments. APPROVAL: The resolution of the above described adverse condition is acceptable. Recottsnended By N/A M/A PORC Chairman Date Approved By Site Director or Division Director Date Completion - corrective action has been completed and ic ready for vocification by QA. Responsiblo Supervisor Date Verification - corrective act. ion takern as describcd above or with thn following deviation 1. l M orifled By i QA Rel're se n t a t ive Dato 0241K TVA 22C01 (CEpC-2-7'a)
[FLT. I CM i YH IMO N0].. ~" Attacinent 3 with ref crences PECUESTED BY (IF APPLICAELE) I'ne 18 or 22 s GttlFICMM) .7 7" ( lacts cnE
- YES, No AsSicneD To P A> o /.m. 4JAL,ta.. us
~ A&U.SE C00lTICti: GA.M. '7.dM. 2 h if u ;. '-, h -m-s ~~ ~ ~' ] n-. J'L&=A* Qe+L g Q p, g /- J ,, x W h Y.7 b-W me ) ^ud?.Z '. 'M p&g&g<.*. .s* w ^ %)* M_p w *. M_ y l M M M s ,,84 : 4. Co.:::-+. ac; - -~p A>- -v2 /.,.4e'.2 7, M /%. ~ R P F 0 544 9 39 3
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r 'R'00T W p.5. t, c.;,7 e CAllSE (CAuS.E.ANALY, SIS RECOIRED d. NOT RECUIRED C:
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... m y........r. .. m... ..... i.:...:...:.*..........:.; t 1.1 u:.. CORTEGhE AGICtl G) REMSIAL CCRRECTIVE ACTIONS (SY ~ N hs & ~" 'EST! MATED CCMPLETICil DATE e M (2) ACTICil(S) TO PREVEl(T RECURRENCE O W w cr c: k [g '.. , n :. : - [. .._.. i..8.. s.:..: m g g ~. g APPFINAL THE RESCLLrTICN CF THE ASOVE DESCRIBE 5 ADVERSE CCffDITICU IS ACCEP RECCPMENDED BY ~ PORC c1%1FiWI CATE ,( ., FCR SIGillFICANT PLAT 1T CARS CNLY) .gpFgOygD.sy .....-.s ....-...:-..r PLT SUPT OR VGR, TECH SUPPCRT DATE CCf9LETICfl - CCRRECT!VE ACTICN WAs coWLETED cli._ 2 0 is' prinY tor' ~- 4 VERITICATIO!! BY TQt. s. RESPCitsiELE SUPERVISCR DATE s VERIFICATIO:L - CCnPECTIVE ACTICH TAKEN As DESCRIBED A50VE CR 'dlDi THE l FC4.LCWillG DEV!ATICIS VERITIED BY / DidC g C1.0S ED BY_ )} ~ FQE SUPERV.150;t __ DATF. (',.
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3 with refcrences Attachment ~. .,G,.. ' '. ) Pa.ge 19 of 22 4 ..*s .. -.......... ~. .t.,
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..v. ... ~. = a. 4--.... -.- -.- } ....i'...*.,. 'N 3.,...,.,. f P. R. W 11pp e, nyp, pop 9 tr-V."'Oi s on' ONP r%3 - 2 7 3 s quoyah*'~ ' '- '" -'- " - ' - ~ ~ - - ~. - --~~_--% , ~ -... OC Uf37tcT 0:t or,,g3 q,,3 777,g. Jub l act. ~.. -. ~.....c.,.:...- .:;;.. _~ _,.m M---- A-~ ~ '- ~ ~ ~ ~ ' ' ~ ~ " ~~ [ Ef!4ctiV4 Chia dite, FebYtt&Yy 48,19%, 'a Visudi insp4ction prior to b ldi ( f t s.aup) vt il im pur/nmud by rhe QA 8ta H en 311 A'.85 01.1 Waids waisted to e ng .n1 - a r-cssc sh e ** *<velsn 3
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c.,/ejoaj 1 g,., J.,,,,, Any workplans or liR/t(Rs which have been previousl to incorporate this requirement Instructions which reference ILU-il for hanger inspeccions vill not norma require revision since the QA Staff is responsible for incorporating the i j vequirenants into this procedure. this revf nion to P.lAl-ll vill be impler.ented without the normal ten (10)Upon day graco period. me.n..ted i.n accordanco with the requirements of N-VT-2 as descr ) ,.,O,, If you have any q~ uestions concerning this policy or its implementation ric Contact D. C. Craven (6539) of the QA Staff. , please Q 4 l -.A p-7 g.-.. K. L.' Mertynbie DCCaRJZ This vae prepared principally.by J. I. Hamilton.. ...~..~..~.-------! . 3 W f .. ~. .. - ~ * -.. -... - - - .n.. s*% o / R I i
r mr B27 '860310 001 .cM.. im o ra n. d um Tzxxtsses vattsy AurnoniTv ,g.. .#. with refcrences 1,- w: 1.. ' E. Ma r t i n, Watts, Bar Employee Concern Task Croup,p"[BNP'0 MONP. 22 9 ^~ o 1 + 'l ..s '.. u. M OM , J. *W..Coan, Project. Manager, Velding Project, V9 C135 C-K DATE March 7,1986 PLAN 70R EVALUATION OF FIIUP G P PRACTICES OF SQN MODIFICATIONS P SL'BJ ECT: The following"s tep's"kr'e"necessary.:to subs taidiite the AssEmpi: ions'had'e in e 7 I.the eval'ultio6','df'.fitup practices of SQN modifications personnel included as Attachment 1. ~' ' .m ";1.' Thi Velding Project - m-. u : e. m. (WP) vill reviev the results of. the, previously ' ~ccupleted 'SQN reinspection f or information relevant to this issue. 2. SQEP personnel have revi ed modifications'made to civil features since plant operation (February 29, 1980) in order to, determine the fitup ' '7 requirements as required by notes on the civil drawings (reference ' memorandum f rom Vineyard to Coan dated February 14,1986,.B25 860214 003). In response to.a memoundum from Rankin to Vineyard dated ' February 7,1986 (S03 A60207 905) a review of all the drawing revision " produced a list of 107 types of structural en=x es. This was done to identify the significance of velding done by Nuctear Power.
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3. A person f rom HEB vith velding, noudestructive examination, and AWS code familiarity and a person from SQEP familiar with the design of,the involved vill conduct a plant inspection of about 10 typic i structures structures at SQN. This inspection vill verify to the extent possible .the fitup gap practices identified by modifications are a vorre case. 4. SQ modifications personnel vill review electrode uponge records to verify the electrode size assumptions of attachment 1,. a d Si O n.s: n.
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[ j g E W ERING] g s'.3 k ' J. F. Coan PAQ j', ' 'M y$ g f DJ E:MP \\ VELD.W3 PP.OJECT 3 cc: RIMS, SL 26 C-K I i Mc i R. C. Domer, W12 A6 C-K I NM J. F. Weinhold, W12 53h C-K I y VI Jes:e-3);., I ht:! g [ I 5:a p oho i J. P. Vineyard, OE, DSC-A, Sequoyah (Attn. ~&*C'" M18 xc: . g C. N. Johnse 4 I '910/86 - JVC:MP I l N d e (Attachment): I i i J. P. Vineyard, OE, DSC-A, Sequoyah ( Attn. C. N. Johnso:t ) I r -- Per telecen on this date with Charlie Johnsen, please ^ t' ' i I l oss 4 Famki: p e,. u u _c Design Serrices Manager su=marizing findings on above items and effect en st ....r.uc t.ure s a..t SU. Please provide me a copy of.a.11 correspondence on this
M L a ttim e n t i '.J1 Lin f ci O T CCC etl ) Page 21 of 22 . o $*..'*s- .y; ~ 3.. mg ~ " EVALUATION OF TITUP PRACTICES .. OF SQN H0DIFICATIONS PERSONNEL -h~ 4.., ..c;. :
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.......-.--..--.-.-~.--------.--.,r:va On February 24, 1986, the following personnel attended a meeting at discuss modifications personnel's fitup practice for fillet v{1 ding SQN to structeral steel., ' : ' ~, Larry Alexander SQN - Modifications Cary Pitz1 No na. Larry Ka tcham :... : ? < wa. SQ EP '.. L :'wM i M" R. A. Montgomery WP ^;' Carl Batmaker WP John D. White OE D. J. Etzler .. c. OE. s....::--. 3: Dan Mickler CC The following at:sunptions result from discussions with SQN~ modifications personnel. ~ A. Standar'd shop practice vas toreject.fitup.[apswhichexceededthe electrode core diameter. B. i Virtually all velding, based on review of veld material use records for i[-.,r,, past years,,vas accomplished using 3/32" or 1/8" diameter electrodes.- I k.# ~ C. Based on A and B, I will aesume that the identified concern is that fitup gaps of 1/8" were acceptable without increasing the fillet veld leg size as required by AWS D1.1, paragraph 3.3.1, and TVA General Construction Specification C-29C, Process Specification 1.C.1.2, Paragraph 7.1 D. For the..following discussion, 3/16".specified fillet veld with a craf t1 vill assume.a.vorse case situation of a fitup gap of 1/8". -TC? The following discussion supports a conclusion that the fillet veld integrity as a result of the craf t workmanship policy re bas not been compromised. . fitup'i[ap~it SQ N',7 1. The Visual Weld Acceptance Criteria (WAC) is a document the Nuclear Construction Issues Group (NCIG) and approved for use bydeveloped by NRC. criteria which when followed assuresThe VVAC establishes guidelines for fina the velds vill meet the design requirements of AISC. For a 3/16" specified fillet veld the actual veld f abricated can have an effective area 25I less than that to VVAC. 'specified and still be acceptable 0.099 in /inThe v ld area thus could be 3/16" x 0.707 x 1" x 75: e = s-a ( i' 096062.04
n L G.J t tmicIll ) Wiban cICru!!CES e, Page 22 of 22 8'
- 2..Withfthe veld con'dition' in assumption D an effective veld area of A,099
)~~ I in /in could be schievek with on,1y 5/64"-depth of penetration ~into the base material. This depth of penetration"is easily achievable with the ~ TL/ ~ E7018 electrodes and direct current reverse polarity which are used -almost exclusively for structural velding at SQN. AWS D1.1 ~ acknowledge s this penetration as evidenced by square groove butt joint ... detail B-PIC which specifies 'a nominal. root ~ opening of 1/8" in 1/4" tbick material. This joint detail provides an effective threat of 1/8" ~ which is much greater than the 5/64" depth of' penetration necessary. ^ 3. We have visually reexamined many structural velds at SQN, WBH and BFN, and; h, ave. identified several. structures in which velds were missing and undersize.... In all cases the structures were analyzed and demonstrated to meet design requirements. Since the fitup gap concern is less significant than missing velds. I consider that more serious velding discrepancies have been analyzed and shovn to not affect plant safety. 4. Most of the modifications performed at SQN have been in cable tray supports, conduit supports, duct. supports,.and pipe supports which are primarily made of square tubing. In most instances, metal to metal -- fitup is achieved because fitup gaps vould make assembly of the structures more dif ficult. 5. This practice has been used only by modifications at SQu and TVA does not intend to adopt this as a standard practice. t z u -..,.. s. \\,... ) s. e e e 8 * *
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Adf e 5. e p o. / :b ' U. :t.ih ,..) N ( 096062.04
B27 '86-0Il[0 0P ~ Rudd .g. Uj T TES covEnNMENT iM e m o r d n d p..m....... . snusssss vittsy Aurnoniry T ~, ..t... t. s q.2 e. w, n t,..,, e.. ..,c.., . Attnehment"4 s g,,, 'f 'J. ht Coan,. Project,. Manager, r Welding 3 Project. :V9 C135.C-K. .Page,*f or 9 .s e.; e te::. ec o. u, n r t,. : :t. r: : r. reverer g w :s. -o.. '.nJ. P.. Vineyard,- Project. Manager, Sequoyah Engineering Proj ect, OE, DSC-A,_, FROM ..JSequoyah Nucicar Plant.. s. ' t March 19,1986 v.. DATE r.1 L. u'
SUBJECT:
FITUP GAP PRACTICES OF SQN.H0DIFICATIONS PERSOUNEL.
References:
(1) Your memorandum to L. E. Martin dated March 7,1986 CSM No..L.. m t._n w.,(B27. 86 031a. 001),. At tachment..i1... m.... ..t' ".. MAR.2 t 10SfL,... u ;. u.. n. m 4... J. ' '..~ : m DAT2 ?f*D -- '(2).. :D. -J. Etzler.'s memorandum to the OE-NEB Files dated March ACTION RE'!D m 19,1986, " Evaluation of Fitup Gap Practices of Sequoyah ' ~ ~ ' uclear ant SQNL ModMentions Personnel - Mant DATF. C"'* Inspection" (B45 8603 19 261),.'sttachment f2 I , INFO CM Y ' CER M 6 WP~8 This memorandtim is for the purpose of evaluating and consolidating the ~~ JCW Y- ..information gathered by several groups at TVA working together to resolve p;2 u._ _ __ _ the question of fitup gaps af ter February 29, 1980 (Unit 1 initial operation).,.:A conclusion is drawn at the end of this memorandum which y"" v ... representa plie. combined opinion of Off. ice of Engineering as relates to this ' subj ect. '*.'9 / I .. i.n.[,% \\ _.'- The format.fS11ovs that of Reference (1). ..2MM 1. SQEP has reviewed the results of the SQN reinspection for fitup practices of SQN modifications personnel and the following is the results of that review: Thereinspectionofmodificationsdidnotrecordanydataj. relevant to fitup gaps. Apparently the modifications gaps were accepable. The few cases of gaps recorded during re' inspection were for const'ruction and were found to be acceptabic in that the "as-built" installation met ' design requirements.
- 2. 'As requested in Reference (1), a list of 107 types of structural changes since Unit 1 initial operation have been identifed.
These changes have been broken down into ten general categories by SQEP Cbl JAR Engineering personnel as follova: Uf 1. Pipe Supports 2. Heating 6 Vent Supports M MNE CD RFC 3. Electrical Supports 4. Miscellaneous Stect O HGC 5. Cable Tray Supports LA 6. Heavy Equipment Modifications f\\J NAL 7. Pool Liners OSG [' ? 8. Containment Vessel & Penetrations ,. y DSG 9. Pipe Rupture Protective Devices SSG 10. NSSS Supports V C g{ C GR_ Un j'( NEB MASTER Fil.Y OC.67A.06
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,,,eg.,. 'EC '"~ - ~~ . March 19, ~ 1986 . t r.. v u. Pre c r. i. cts *. see .-e: :r..r:- - FITUP.- GAP. PRACTICES OF SQN H0DIFICATIONS PERSONNEL SQN,,, Civil Engineering. personnel.have adv.ised that Items.1 through 6 require no special fitup instructions for initial installation. ' Item 7 ~ requires initial..fitup but was done prior.to. initial startup. These welds were full (penetration, velds and will not be included in this ',' study. Item 8 required ASME velding for attachments to. the pressure .... boundary and again vill.not-be included in this study. Items 9;and'10,. 'lt' quire fitup inspection during, initial construction.;;None of these.. re ess'were initially buil,t,during the_ time: frame covered here..:- ~ ' ~" ..,,...g. . g. 3.,, ;.,. ..It should be noted here that a report by OE, attached to Ref erence 1, .ohows a worse case fitup situation which would give an effective throat of acceptable dimensions. SQEP Civil Engineering personnel have ,,, endo,rsed this evaluation of ef f ective, throat. (See steps 3 & 4 below .t:.(CEi.just,ificat,io.n that, this is the worse case.) .s 5 : :.m v-
- 3.. ;D. J.. Etzler (OE), Larry Katcham (EQEP), Larry Alexsader (SQN-0MMM) and
,,. Bryan, Turner,,(,SQN-OHMH) co.nducted, a, plant search at.SNP on 3/6/86 for random fitup gaps used on fillet velds. The results of this search '{g53,,,("*'". J y, is attachment (2). Final conclusions of this report say: "I conclude (c.jp ,, that the majority of the structures involve designs which are easily fabricated and have relatively easy fitup. The physical inspection results support the earlier statements by(NO) personnel that their i practice was..to reject. fitups. in excess of the electrode -core diameter." 4.. SQN modifications personnel., reported the,amoun.t of ;e.lectrode, size. consumption as,follov,s:. :. :.., tr Electrode Size 3/32 ins. 1/8 ins. 5/32 ins. " " ' ' ' " ~ 1984 5,455 lbs. 2,350 lbs. 0 lbs. '.... 1985 '3,950 lbs. 5,180 lbs. 100 lbs. -.y ... g. :. r. Tofal percentage of electrodes greater than 1/8" is.59%. It is doubtful that the 5/32 in. rod was used for AISC velding. It is very doubtful that the root gap would have exceeded 1/8 inch. .a m. 9 ib' _.q..-
p . }, ' '; p. i Page 3 of 9 3.. - = r,- %.3c T .l; ~J.- W.'Coan-y p'~ Ma rch19. - 1986'
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FITUP GAP PRACTICES OF SQN MODIFICATI0HS PERSONNEL ..u.. Other factdr~s should be considered 'h'ere. ' Weld met'al is approximately ~ 10-16% ' stronger than specified yield str'ength. The allowable load is limited by code t; 'the lesser of;;the capacities proven by tests for fillet l velds parallel'to; stress and tho,se transverse!to stress. -The fillet velds transverse to stress are:at least 40% stronger than those parallel to st ess.' * ' * ""; ' W'
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" * ' - ' ' ~ = - . w. .< m ir:....... ru.r., cur.t-,,: :::... r r r.. :r. - A review of the four steps necessary to substantiate the. assumptions made - in the evaluation of fitup practices of 'SQN modifications personnel indicates that these assumptions were valid. The velding reinspection program found no fitup errors. ' A review of drawings and welds rs: quired for modifications to the features identified in 2 above shows that no modification made during the time frame from February 29, 1980, to present -would require special_fitup. The attachment to Reference 1 indicates an eff ective throat in the " worse case" condition greater than the design value for these fillet welds. This " worse case" condition was supported by 4 ~information r in-3 and 4 above. Given that this is the worre case, $N .any qualified fi weld equal to the specified leg size would yield an y $9 acceptable throac imension and resulting acceptable design strength. An Jadditional;1/16" of leg size equal. to each 1/16" oversized fitup gap would 'only be,a conservative addition in'this'~ case. The overwhelming majority of welds for modifications'during'ths 2 previous years as shown in 4 above were made with core diameters equal to or less than 1/8". Weld gaps greater than this core diameter would be much more dif ficult to make and welders indicated they rejected"these conditions. -;c Based on all this information, I b'elieve no further inves.tigation of weldi,ng. inspection practice as relates to fitup needs to be performed at Sequoyah. -HZUA'- ./ J. P. Vineyard' T' ( 1.K:MP Attachments Revievers Initials /Date cc (Attachments):
- RIMS, SL 26 C-K L. Katcha,
/M.M2/ V. A. Bianco, OE, DSC-A, Sequoyah D. J. Et ler 6 / 25-3//f R. O. Barnett, W9 D224 C-K J. W. Conn 2'i4,.J/rs,_, R. C. Domer, W12 AS C-K J. A. Raulston <//7L-J/l'o 5); W. C. Drotleff, W12 A12 C-K e p. fem rq CCL' 3/M ' I. '.- - C. N. Johnson, OE, DSC-A, Sequoyah g, c., w e m S u d.3/36 --- L. Ka tchan, 5-121 SB-K J. A. Kirkebo, W12 A8 C-K L. E. Martin, 10B - Watts.B. B. B. Rankin, ONP, DSC-E, Seq vah -- This also responds to itens J. A. Raul ston, W10 C126 C-K
- 1 and,f3 in 7our menorandum inac
o .ed Page 4 of 9 .,.e e 1 s7,- f' ..s ~ .), mdLI ;- ~ " r ; 0. i;.- EVALUATION OF FITUP PRACTICES OF SQN MODIFICATIONS PERSONNEL r c.,. On February 24, 1986, the following personnel attended a meeting at SQH to discuss. modifications. personnel's fitup practice for fillet velding structural steel.,
- . ". ". A L L L. :-) c0t-e U.-
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"C. . Larry Alexander SQN - Modifications .: : " : Gary Pitzi ra - 30 n:. Larry Katcham SQEP R. A. Montgomery WP ~~ Carl Hatmaker WP +* John D. White OE D. J. Etzler OE Dan Mickler OC "5 The: following assumptions result from discussions with SQN modifications ,, personnel. - A'. Standard shop practice was to reject fitup gaps which exceeded the ,'l:) electrode core diameter. 9 B. Virtually all velding, based on -review of veld material use records for
- - - past years, was accomplished using 3/32" or 1/8" diameter electrodes.
r .u-. C. Based on A and B, I will assume that the identified concern is that fitup gaps of 1/8" were acceptable without increasing the fillet veld leg' size as required by AWS D1.1, paragraph 3.3.1, and TVA General "" C'onstinction Specification G-29C.. Process Specification 1.C.1.2, ~ Paragr.,aph 7. 1 i.. D., For the following discussion,' I will assume a worse case situation of a 3/16" specified fillet veld with a craf t fitup gap of 1/8". The following discussion supports a conclusion that the fillet veld integrity as a result of the craf t workmanship policy re. fitup gap at SQi! has not been compromised. 1. The Visual Weld Acceptance Criteria (VWAC) is a document developed by the Nuclear Construction Issues Group (NCIG) and approved for use by NRC. The VVAC establishes guidelines for final visual veld acceptance criteria which when followed assures the velds vill meet the design requirements of AISC. For a 3/16" specified fillet veld the actual veld f abricated can have an ef fective area 25% less than that specified and still be acceptable ..g.. 'U. to VWAC. The veld area thus could be 3/16" x 0.707 X 1" x 75% = 2 Eg ;' O.099 in /in
R m a t t a c na.e n t.. .g,., Pane 5 of 9 r .,g f na = ~ ~j - 2. With the veld condition in assumption D an effective veld area of 0.099 in /in could be achifvedWITh onif'-5/64"idep'th of penetration into the I 2 base material. Thi's depth of jenedation'is' easily achievable with the. ~ _d E7018 electrodes and direct current reverse polarity which are used L almost exclusively for structural velding at SQN. AWS DI.1 C acknowledges this penetration as evidenced by square groove butt joint =5 ' detail'B-Plc which specifies'a nominal ~ root opening of 1/8" in 1/4" q a thick material. This joint detail provides 'an effective throat of 1/8" which is much greater than the 5/64" depth of penetration necessary. M_ 3. We. have visually reexamined"many strdetural" velds at SQN, VEN and BFN, and have identified several structures in which velds were undersize. i In all cases the structures vere analyzed and demonstrated to meet 6 design requirements. Since the fitup gap concern is no more significant than undersize' velds, I consider that velding discrepancies 4 similar to the fitup gap concern have been analyzed and shown to not JEE affect plant safety. d-il 4. Itost of the modifications performed at SQN have been in cable tray - supports, conduit support's, duct' supports, and pipe supports which are primarily made of square tubing. In nost instances, metal to metal fitup is achieved because fitup gaps vould make assembly of the structures more' difficult. g ( 5. This practice has been used only by modifications at SQN and TVA does 'I J not intend to adopt this as a standard practice. .s., m J B = .c = Prepared / /f/ L 3//8/b
- D/ J. Etzler a
U - E Reviewed M 7//T/$ s' J. D. White
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.: :. s u:. = Approved 93/
- f-C. E. Robert / /
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- .9; u,p.ho stirEs CovEnunE"'
B45 '860319 261 .Mefnprandum QA.Recedi TENNESSEE VALLEY AUTHORITY 4 n . Nuclear Engineering: Branch Filca r ent t : t:: c f.
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D. h Etz.ler,. Metallurgical Engineer,.1W9'. B82 C-K ':t.:.. ~. ' FROM t . e. : v.? : - - MAR.19,1986. t, .DATE c. :..
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SUBJECT:
EVALUATIO!!.0F.FITUP; GAP PRACTICES OF.SEQUOYAH NUCLEAR PLANT (SQN)~ MODIFICATIONS PERSONNEL - PLANT INSPECTION 1... .., ty.; s. :. t:- ,. ;.. z 1.0 .,,Da t e,, Time,.,and..P. lac e s....., e v.:c......... :. ;. ...t...
- r --
. Jjarch 6,.19,86.,.SQN
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.g. ~ 2.0 Requested by: ' Bob Olsen 3.0 .'In. Attendance "of Walkdcun Inspection Were:
- Bryan Turner SQH Modifications MOD /M, SB-2, Sequoyah
, Gary Pitz'1 No LP SS 139D-C .s Larry Katcham SQEP 6111 MIB-K 'h Roger Field SQEP 6121 MIB-K J) D. J.}.,E,t z l,e r,,, ,OE-NEB W9 B82 C-K 4.0 Purpose of Meeting: 4.1 "Ihe purpose of the meeting was to conduct an inspection of several SQN structures fabricated by mods personnel for evidence of the fitup gaps used on fillet welds. 5.D Come nts : '5.1 We vere guided through the plant by Bryan Turner and Roger Field directing us to structures representative 'of Work performed by modifications. 5.2 We looked at approximately 30 structures', 10 of which were chosen for detail fitup gap inspection.- The majority of' the structures were rejected for detail fitup inspection because they j consist of two or three straight sections of 2-inch square tube, or unistrut material, or a short section of square tube velded to an existing structure. This type of structure is so easily fabricated that it would require extra work to provide other than metal-to metal fit. 5.3 Several methods were used to measure the present gap. Note that the present gap is not an accurate measure of the fitup prior to 'D.. welding, but it is the only indicator available. .~ rj 5.3.1 khen members were not welded all around. I could directly J1 measure the existing gap. This was possible on 6 items. / of 096073.04
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m._ _Hucicar Engineering Branch Files ~ v , MAR"19 N 6 ain-EVALUATION OF FITUP CAP PRACTICES OF-SEQUOYAH NUCLEAR PLAIE (SQN) ? [ HODIFICATIONS PERSONNEL - PLA!E INSPECTION .[ t L :. u :,. w v. a
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T '5.3.2 Where short sections of square tube were welded to other } members, I could look inside the square tube and, detect the relative root gaps. This was possible on 3 items. 5.3.3 .I discovered. that on size-on-size square tube, "T" connections, an indirect measurement technique is sometimes possible. Figure 1 attached is necessary to describe this technique. Please note that this technique only provides an indicator of the maximum existing gap. k 6.0
Conclusions:
I e 6.1 I examined 10 structures dhich involved 13 separate connections and 32 welds. Four connections had gaps of between 1/16 inch and 1/8 inch, 7 connections had gaps of 1/16 inch or less, and 2 connections had metal-to-metal contact. The structures and results are tabulated in Figure 2.
- p..lf 6. '2 N ne of 'the structures consisted of square tube construction with
.s# the maxir.s being 6 x 6 and the minimum being 3 x 3; 1 structure ( consisted of a wide flange sitting on plate; two were plates ~ f), welded to a -square tube; and one consisted of angles velded to g square tube. 6.3 Based on the observations. of typical work perfomed by L modifications since 1980, I conc 1' de"that the majority of the u f s tructures involve designs which are easily f abricated and have relatively easy fitup.' The physical inspection results supports 'the earlier statements by.NO personnel.that their. practice was.to reject :fitups in excess of the-electrode core diameter. NO reported that for 1984 and 1985 about 1.5 percent of the electrodes purchased (250 pounds out of a total of 16,585 pounds) were 5/32 inch. The remainder of the electrodes were 3/32 inch and 1/8 inch. 6 I i ' n./ / - iC7< A / 'D J. Etzler [LC cc (Attachments): JAR:Sils - '1AR 191986' DJE:Sils A t tachme nt s Attachments C cc (Attachments): John A. Rauls ton, W10 C126 C-K RDIS, SL 26 C-K J. P. Vineyard, OE, DSC -A, S equoyah 096073.04 h ; I
Attachtent
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Page 8 of 9 ..>~ e / /'. - - FIGURE 1 s s-i --9 i A ) .INTE R 5 E( TI N G
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.\\h . M ' r'P y, .% ~ * " '.J b'???..N'fk,('k.,;R_X/f]LYkB_ jiN@Piaf - I [bb*?.- g [;') TRkot CH M G M BE.R ~ I ^ k ( t 1 1. Place, straightedge along fusion line of flare bevel on intersecting member side of weld. 2. Place another straightedge across surface of through member. 3. The height of straightedge 1 above straight edge 2 can be an indicator of existing gap. 4. If the reinforcement of the flare bevel weld on the intersecting member just covers the cut edge of the square tube this could be a very good indicator of the existing gap. This method can only indicate that the existing gap does not exceed the resulting gap measurement. l .') l 96073.04 l l
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SUMMARY
OF FITUP CAPS MEASURED l v' How Item Sueoort Mark Welds Type Structue Gao Measured 1 2 ERCH 346A 1 Pipe Support - ST/ST 0 Direct 2 CCH 1007 2 ' Pipe Support - PL/WF < 1/16" Direct 3 ERCWH 232A 1 Pipe Support - PL/ST 4.1/16" Direct 4 Valve Room 2 Pipe Support - ST/ Angle <1/16" Direct Aux Fdwtr Sup. 5 2AFDH 250 2 Pipe Support - PL/PL 0 Direct 6' ~ 47A450-3-78 2 Pipe Support - ST/ST 1/16-1/18" Direct ,7 ERCWH264 2 Pipe Support - PL/ST < 1/16" Direct i 8 1-67-11568 4 Pipe Support - ST/ST 1/16-1/18" Direct .w 9 10-9 2 Pipe Support - PL/ST < 1/16" Direct
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4 Pipa Support - ST/ST 1/16-1/18" Direct _ j,Tj f 4 Pipe Support - ST/PL 41/16" Direct 10 10-10 2 Pipe Support - ST/ST 41/18" Indirect 4 Pipe Support - ST/ST <1/16" Direct Abbreviations: t u ST - Square Tube PL - Plate WF - Wide F.lange f f k.' f,) U s.3-096073.04 1:, s .}}