ML20215N428
| ML20215N428 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/31/1986 |
| From: | Czajkowski C, Schuster M BROOKHAVEN NATIONAL LABORATORY |
| To: | NRC |
| Shared Package | |
| ML20214D842 | List: |
| References | |
| NUDOCS 8611050393 | |
| Download: ML20215N428 (57) | |
Text
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TECHNICAL EVALUATION REPORT (TER)
RELATED TO THE WELDING CONCERN PROGRAM AT TVA'S SEQUOYAH UNITS 1 AND 2 AUGUST 1986 Carl J. Czajkowski Milford H. Schuster Department of Nuclear Energy Brookhaven National Laboratory Upton, new York 11973 p t \\ 6So313,
i TABLE OF CONTENTS Page EXECUTIVE
SUMMARY
v
1.0 INTRODUCTION
I I
1.1 Background.
2 1.2 Independent Audits.
1.3 Hardware Inspections and Corrective Actions.......
2 2.0 FORMATION OF THE EXPERT WELDING TEAM.
2 3.0 EVALUATION OF EMPLOYEE CONCERNS....
5 5
3.1 Category 1 - Welding Procedures.
3.2 Category 2 - Welding Qualification / Training..........
5 11 3.3 Category 3 - Welding Inspection.
3.4 Category 4 - Welding Design and Configuration.
23 25 3.5 Category 5 - Filler Metal Control.
3.6 Category 6 - Miscellaneous /One of a Kind...........
30 4.0 PROGRAMMATIC REVIEWS BY TVA CONTRACTORS..
32 32 4.1 Aptech Report.
4.2 Bechtel Audit.
33 5.0 HARDWARE INSPECTIONS (TVA AND USNRC).
35 5.1 TVA Reinspection.
35 5.2 NRC NDE Van Inspection.
37 5.3 Combined NRC and BNL Welding Team Audit.
37 6.0 DISCUSSION AND CONCLUSIONS..
38 6.1 Category 1 - Welding Procedures.
38 38 6.2 Category 2 - Welding Qualification / Testing.
6.3 Category 3 - Welding Inspection.
39 6.4 Category 4 - Welding Design and Configuration.
39 6.5 Category 5 - Filler Metal Control...............
40 6.6 Category 6 - Miscellaneous /One of a Kind..
40 REFERENCES........
42 LIST OF ATTACHMENTS..
43
-v-EXECUTIVE
SUMMARY
Specific concerns brought up by TVA employees indicated several areas of the TVA welding program at the Sequoyah Nuclear Units 1 and 2 (construction and operation) which, if accurate, question the adequacy of the program. This, coupled with the utility's review of various quality indicators (NRC inspec-tions, audit findings, etc.), suggested t' tat conditions existed in the TVA welding program which did not meet indust:y/ regulatory codes or standards.
The utility's approach to resolution of the Employee Concern Program was to evaluate the concerns with a three-way investigation. The first evaluation consisted of a review of a sample of documents from the plant which were com-pared to TVA's commitments to the USNRC.
In the utility's Phase I report, they believed that these commitments had been met with the exception of preweld inspections.
The second approach to the resolution of the Employee Concern Program by TVA was composed of two independent audits of the Sequoyah welding program. The first audit performed by Aptech Engineering consisted of an in-depth review of the two units' PSI /ISI programs. This audit, in general, concluded that the welding program contains the necessary controls to ensure a high quality of welds. An additional independent audit of the welding program at Sequoyah was performed by Bechtel Engineering.
The Bechtel team expended thirty auditor weeks (five-member team) and audited all aspects of the welding program (both construction and operations). This audit disclosed no findings relative to any employee concerns, but did observe that many TVA documents were ".... confus-ing, overlapping, repetitive and unclear".
The third segment of the TVA investigation consisted of a sample reinspection of 333 Class 3 piping welds, 15 spiral duct welds, and 403 structural joints by TVA inspectors. As a result of this reinspection, the utility concluded that all of the reinspected weld joints meet design requirements and that additional reinspections (by the utility) are not required.
The USNRC's evaluation of TVA's response to the Employee Concern Program consisted of reinspections at the plant (both the Region 1 NDE Van and a combined NRC and BNL Welding Team audit), and the formation of an expert welding team, under BNL contract, to review TVA's resolution of welding issues and to make recommendations on the adequacy of TVA's corrective action. This team consisted of five independent experts in the fields of welding /
naterials/ structural engineering.
The team evaluated the TVA investigation and responses to 117 concerns (either specific or generic) relative to the Sequoyah units. These evaluations found areas of the Sequoyah welding program which suffered programmatic breakdown. Various questions on these areas have been transmitted to the USNRC for forwarding to the utility.
Since there were these areas of " programmatic breakdown", it becomes necessary to address the question of the adequacy of the Sequoyah welding utilizing a hardware inspec-tion approach.
Three NRC inspections involving the Sequoyah units were performed. The first NRC inspection was performed during February 18-28, 1986.
This inspection included 417 inspector hours on site to evaluate TVA's reinspection
-vi-The second inspection took place in February 1986, by the NDE Van.
This involved the inspection of 40 pipe weldments (Class 3, either dye penetrant or magnetic particle inspection), 361 structural weldments visually inspected, and 46 piping welds (ANSI B31.7) visually inspected. This report concluded that "..... the NRC findings were representative of the types found by the licensee."
The third NRC reinspection took place in June-July 1986 and involved 30 pipe welds, 502 pipe support welds, 31 instrument tubing welds, 120 instrument support welds, 130 structural welds (electrical), 280 HVAC support welds, and 100 structural welds and generally concluded that the licensee complied with the governing codes and specifications for the welds examined.
A review of the evaluations and inspections performed to date have shown that the Sequoyah units have suffered some areas of " programmatic breakdown," but the hardware itself does not have any defects of great detriment or magni-tude.
This being the case, if questions posed to TVA are answered to th,e NRC's satisfaction, then the welds at the Sequoyah units are deemed " suitable for service."
The expert welding team has also sent separate summaries of their technical opinions of the exployee concern program for the Sequoyah units, which is also part of the TER.
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1.0 INTRODUCTION
1.1 Background
Various quality indicators (e.g., NRC inspections, audit findings, non-conformance reports, etc.), manifesting themselves during the construction of the TVA nuclear units, directed the utility toward possible existing condi-tions in their welding program which did not meet industry / regulatory codes or standards.
Specific concerns brought up by TVA employees also indicated several areas of the TVA welding program (both construction and operations) which, if accurate, additionally question specific practices at the various TVA units.
The NRC requested a meeting with TVA in order to discuss these welding program concerns and provide a listing of various comments and questions by the regulatory body on the adequacy of the TVA welding program. The utility evaluated these comments and presented a two phase plan to the NRC at a public meeting on January 7, 1986. These two phases would be applicable to each of TVA's nuclear plants and would involve:
Ensuring that the TVA welding program which is currently in effect adequately reflects the regulatory requirements and TVA's commitment to same.
Evaluation of the implementation of the TVA' welding program and verification that field weldments are adequate for service.
1 The first phase of the Action Plan is stated in Volume 1 of the Project Review Plan:
Review TVA commitments to NRC Verify that written program reflects commitments:
Determine that welding related commitments are reflected in design output.
- Determine that construction and nuclear operations programs, as l
applicable, reflect design output and quality requirements.
Assemble welding program quality indicators (including employee weld-l ing concerns) by type and plant.
Analyze and evaluate effect of quality indicators on programs.
Issue adequacy statement regrading written programs to implement /
control welding.
The Phase II program is broken into two parts:
Independent Audits Hardware Inspections and Corrective Actions I
4 -
1.2 Independent Audits This part of the program is to encompass an in-depth auditing of the utility's welding program.
It is to be approximately one month in duration accomplished by a five man audit team. The audit is to cover ASME and AWS, as well as non-ASME safety-related applications at the site.
1.3 Hardware Inspections and Corrective Actions A reinspection program was devised by TVA, with NRC concurrence, for selective structures of systems from six different groups. This program consists of in-spections of a minimum of 100 welds from each group. The six groups include:
1.
ASME Class 3 and ANSI B31.1 welds and attachment welds 2.
Supports associated with Group 1 (above) 3.
Cable tray / conduit supports 4.
Miscellaneous structures 5.
Butt welds on spiral welded ducting The pipe welds were to be' reinspected to ANSI B31.1 or B31.7 using both visual and nondestructive (surface only) examination and the structural welds exam-ined in accordance with NGIG-01 [4].
The results of these inspections and audits are described later in the TER and were documented in the " Tennessee Valley Authority Welding Project, Sequoyah Nuclear Plant, Phase 1 and Phase 2 Review and Program Results".
2.0 FORMATION OF THE EXPERT WELDING TEAM The excessive number of employee concerns expressed by TVA employee's regard-ing the utility nuclear units generated sufficient concern in the USNRC to form a triumvirate NRC team (NRR, I&E and Region II) manage the overall NRC t
staff activities including the TVA resolution to their welding concern program.
Part of the NRR responsibilities was to:
" Contract with Brookhaven National Laboratory (BNL) to constitute an expert team to review TVA's resolution of welding issues and to make recommendations on the adequacy of TVA's corrective actions, as appropriate."
The implemention of these responsibilites was realized in the form of two contracts to BNL entitled " Evaluation of Welding Concerns at TVA Operating Reactors," FIN A-3839, and " Evaluation of Concerns at TVA Near-Term Operating Licenses," FIN A-3836.
a.
The contract under FIN A-3839 is specific to this TER and has as its objec-tive: The formation of a panel of independent experts in the field of welding /
materials / structural engineering to evaluate the utility response and action plan for addressing the employee welding concerns. The work requirements for the contrpet are:
Task 1: Seouoyah Nuclear Power Station 1.
BNL will contact, issue and administer subcontracts to various welding /
structural engineering experts in order to form the welding team.
2.
BNL will coordinate the receipt and appropriate distribution of TVA's resolution of the welding concerns and various supporting documents to the team necessary to develop a comprehensive and informed evaluation of the TVA welding program.
3.
BNL will convene, coordinate and schedule team meetings as necessary to meet the program objectives.
4.
BNL will review and evaluate the TVA welding program as a full par' tic-ipant of the welding team.
5.
BNL will evaluate and categorize welding concerns received from TVA and distribute as necessary to the. team members.
6.
BNL will coordinate and schedule field inspections if necessary for team members to assess the program implementation and the structural integrity of affected components. The team is composed of experts in the various fields involved with welding. The welding team secretary is Carl J.
Czajkovski, a BNL Staff Research Engineer specialized in failure analy-sis, welding and metallurgical investigations. Every effort was made to verify that this team did not have a preconceived bias relative to the utility and the NEC.
Based on the above, the following list was proposed as the team of consultants:
William D. Doty An independent consultant, formerly a Technical Director of U.S. Steel's Research Center; author of several books and numerous papers; a Member of Welding Research Council and Pressure Vessel Research Committee.
Carl E. Hartbower An independent consultant, formerly Chief Welding Engineer at FRA, NRL; AWS Dl.1 member.
Paul E. Masters An independent consultant, formerly Chief Welding Engineer at American Bridges Co,;
advisory member to AWS Dl.1 Committee.
William H. Munse Professor Emeritus of Civil Engineering, University of Illinois; member of AWS & AISC Code Committees.
o Robert Stout Dean Emeritus Lehigh University, specialized in welded steel structures; author of several books and numerous technical papers on the subject.
More complete copies of the resumes of the welding team are listed as Attach-ments (1-6) to this TER.
Additionally, in April 1986, the BNL effort was enhanced by the addition of Mr. Milford H. Schuster (resume - Attachment 7), formerly of Long Island Lighting Company.
As of the writing of this TER, the team has had two group meetings (totaling 3-1/2 days of effort) and each member has been to the Sequoyah site for dis-cussions and weld inspections (Attachments 8 and 9).
Additionally, all infor-mation relative to the concerns has been sent and reviewed by the team. A three-day meeting was also held between Messrs. C. Czajkowski and M. Schuster (BNL), D. Smith (NRC/NRR) and C. Georgiev (NRC/I&E) on May 13-15, 1986. At this meeting, the concerns relating to Sequoyah Units 1 and 2 were categor-ized. The categorization was made in six groups:
1.
Welding Procedures 2.
Welder Qualification / Training 3.
Welding Inspection 4.
Weld Design and Configuration 5.
Filler Metal Control 6.
Miscellaneous /One of a Kind The first five groups were considered to be essential elements in any welding program which would be necessary to assure that a welding program was adequate to produce a sound weld as an end product. Into the six categories, all of the concerns (both generic and Sequoyah-specific) were divided. Ihe total input for the concern listing came from three sources:
1.
A Franklin Institute listing dated 3/21/86 (F).
2.
A list supplied by TVA as the " Concerns" applicable to the Sequoyah units (TI).
3.
The contents of Appendices 5.1 and 5.2 of the TVA Welding Project Phase II Report-Volume 3 (T2).
These three sources were cross-checked one against another and a total listing of concerns generated. The concerns were placed in the categories with these results:
O concerns 1.
Welding Procedures 2.
Welder Qualification / Training 27 concerns 3.
Welding In pection
- 48 concerns 4.
Weld Design and Configuration -
7 concerns 5.
Filler Metal Control
- 26 concerns 6.
Miscellaneous /One of a kind 9 concerns
This totals 117 concerns (either generic or specific) for the Sequoyah Nuclear Units. These concerns and the utility response to these concerns were evalu-ated in detail by the welding team and are contained in Section 3.0 of this TER.
There were 26 specific concerns relative to Sequoyah (T2) with the balance being Watts Bar concerns with possible generic implication for the Sequoyah units.
3.0 EVALUATION OF EMPLOYEE CONCERNS It had been previously determined (Section 2) that there were 117 em-ployee concerns considered applicable to the Sequoyah Units and that these had been divided into one of six categories. This section of the report will list the employee concerns for each of these categories, the reference for how the concern was determined (Franklin Institute Report (F), TVA original submittal (TI), Appendices 5.1 or 5.2 of final report (T2)), the TVA Report which an-swered the concerns, and a brief description of the concern. A welding team evaluation of the concern is also included in this section.
It should be noted that the exact number of concerns may dif fer from various reports and lists due to the continuous updating and overlapping of concerns (generic or specific). This TER has therefore listed all of the concerns that the BNL team consider to be Sequoyah applicable. Even though some differences may occur, it is believed that all major categories (fit up inspection, bad electrode, etc.) of the concern program have been evaluated.
3.1 Category 1 - Welding Procedures There were no concerns found to be specific for this category.
3.2 Category 2 - Welding Oualifications/ Training This category had 27 concerns associated with it, as listed on the following page.
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Report Number Concern Responding Brief Description Number Reference to Concern of Concerns EX-85-042-003 F,T2 WP-03, All positions based on WQ 2Q position EX-85-021-002 F,T1,T2 WP-03 No objectives evidence WQ IN-85-426-002 T1,T2 WP-03 Updating welder certs inadequate based on bead on plate IN-85-346-003 T1,T2 WP-03 Updating welder certs IN-85-480-004 F,T2 WP-03 Updating certs irregularity PH-85-052-002 F,T1,T2 WP-03 Updating and backdating of welder certs PH-85-052-X03 F,T1,T2 WP-03 Welder certs classified IN-85-352-001 T2 WP-03 Welder cert updating-just burned rod IN-85-424-Oll T2 WP-03 Welder cert updating-card stamped IN-85-493-004 T2 WP-03 Welder cert inadequate IN-85-532-005 T2 WP-03 Welder cert recertified without having used process IN-85-835-002 T2 WP-03 Welder recerts by stamping IN-85-778-001 T2 WP-03 Welder recerts updating IN-85-940-X04 T2 WP-03 Welder recerts updating IN-85-113-003 T2 WP-03 Welder recerts stamped every 90 days; no rod burning IN-85-770-002 T2 WP-03 Update on welder certs IN-85-627-036 T2 WP-03 Welder certified / backdating IN-85-706-001 F,T1,T2 WP-07 Welder insufficient welder training and exp.
XX-85-045-001 F,T2 WP-07 Insufficient welder training XX-85-049-001 F,T2 1-85-135-SQN Updating and backdating of welder certs XX-85-049-X03 F,T1,T2 1-85-135-SQN Welder certs classified XX-85-101-006 F,T1,T2 ERT XX-101-006 Welder performed welds without proper certs SQM-6-005-001 F,T2 I-86-ll5-SQN Welder passed though qualification falsified SQM-6-005-X02 F,T2 I-86-115-SQN Welder certs records falsified XX-85-088-003 T2 ERT XX-088-003 Alteration of welder certs by correction fluid XX-85-088-X04 F
ERT XX-85-088-X04 Correction fluid on welder certs XX-85-088-001 F,T2 ERT XX-088-X04 Welder certs altered (Knoxville) correction fluid
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3.2.1 Seventeen of the 27 concerns were answered by Welding Project Generic Employee Concern Evaluation Report WP-03.
This report addressed the following five issues:
Issue #1: Welder Performance Qualification (WPQ) continuity records have been backdated.
TVA Evaluation: Welder Performance Qualification Continuity Records have not e
been backdated. This issue is not substantiated. This issue is closed by this report.
Issue #2: WPQ continuity records have been falsified.
TVA Evaluation: Welder Performance Qualification Continuity Records have not been falsified. A detailed investigation of these issues was performed by NSRS and documented in NSRS Report I-85-135-SQN.
Both these issues were not substantiated. The investigation did, however, discover that program imple-mentation had been deficient and that NO had already taken steps to correct identified deficiencies. The Bechtel SQN Implementation Audit conducted in January 1986 determined that both OC and NO programs for these activitica had been effectively implemented prior to the NO audit. Based upon this analysis, j
these issues are closed pending the completion of the corrective actions regarding review of Welder Performance Qualification Records as outlined in NSRS Report I-85-135-SQN.
Issue #3: The WPQ continuity program is inadequate because there is no i
objective evidence to confirm actual process usage when WPQ continuity records are stamped by QC.
TVA Evaluation: This issue was not substantiated because it related to WBN practice. All welders who have transferred to SQN from other sites have successfully passed a requalification test administered at SQN.
Implementation deficiencies discovered by SQN, NO, QA have had corrective actions initiated. This issue to be closed based on the above actions.
Issue #4: The WPQ continuity program is inadequate because continuity can be maintained by running one weld bead.
Issue #5: A one-position test plate is not sufficient to reinstate all WPQ tests.
[
TVA Evaluation:
Issues 4 and 5 are acceptable practices and are to be closed on that basis.
i Expert Welding Team Evaluation ( All 5 Issues) i In general, the investigation (NSRS-I-85-135-SQN) appeared to adequately cover the essential bases for the TVA evaluations. There is a need for more information, however, on the status of corrective action implementation of ites I-85-135-SQN-02 from the NSRS report. The welding project report does not mention this item in its evaluations of the problem.
t 3.
I-85-135-SQN Corrective Action Backfit Evaluation "TVA formal corrective action processes such as corrective action reports, nonconformance reports, etc., should be evaluated to include a backfit evalua-tion provision to determine if the identified deficiency requires such action to provide substantial, additional protection for the public health and safety or the common defense and security."
3.2.2 WP-07 was used to address two employee concerns, IN-85-706-001 and XX-85-045-001. The issues involved in these concerns were:
1.
The TVA Welder Training Program is inadequate for nuclear construc-tion.
2.
Welder performance qualification tests do not test a welder's overall ability.
TVA Evaluation The utility felt that these concerns were unsubstantiated for the following reasons:
1.
There is no requirement relative to welder training programs.
2.
The base requirement for welder skill is the Welder Performance Qualification Test Program.
3.
The Welder Performance Qualification Test Program is outlined in both the OC and NO, QA programs.
4.
The Bechtel SQN Implementation Audit has established that these programs have been and are being effectively implementated by OC and NO.
5.
No indication of a generic welder skill problem was discovered by the SQN Reinspection Program.
Expert Welding Team The expert welding team agreed that sufficient investigation and followup had been perfomed by the utility. It was additionally agreed that there is no requirement for a welder training program by current codes or standards, since the " proof test" of a welder making a sound weld has always been his/her performance qualification test.
Additionally, the welder performance test was never intended as a gauge of a welder's overall ability; it is merely a method of determining the particular welder's ability to produce a " sound weld" with a specified procedure.
3.2.3 NSRS Investigation Report No. I-85-135-SQN was used to evaluate concerns XX-85-049-001, X03. The issues involved were:
Issue #1 - Sequoyah: Welder certifications have been updated for welders who did not meet update requirements or backdated to give appearance of requirement compliance.
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Issue #2 - Sequoyah: Welder certification card falsified. Construction Department concern. CI has no more information.
TVA Evaluation: The utility feels that although 1 above was substantiated, the two concerns can be closed out for the following reasons:
1.
The concern that the welder update (continuity) requirements were not being met was substantiated and had been identified recently in a QA audit finding. All active welder records have been properly updated by supporting documentation or the welder retested.
2.
The concern that records may have been backdated in order to give an appearance that the welder was qualified could not be substantiated.
There were some clerical-type errors where incorrect dates were entered on welders' records, but these were corrected when a review identified discrepancies between welder continuity record sheets and l
supportive documentation (i.e., welder performance qualification record). In addition, the toolroom clerk may have missed entering 4
weld filler material draws on a welder's record and correctly updated the continuity records later, but this is not considered backdating.
No evidence was found that indicated falsification of records had occurred.
3.
There appears to be no safety concern since all active welder records were either corrected or readily restored to requirements. Also, all safety-related welding is independently inspected per an approved QA program.
4.
Corrective Action Report SQN-CAR-85-09-14 (Ref. 13) did not address the consequences of the previous (nonactive) welder continuity program.
j Expert Welding Team i
The expert welding team agreed with the corrective actions and investigations associated with the welder falsification concern.
It did not, however, feel that sufficient information was presented on the eight welders identified in I-85-135-SQN (e.g.):
1.
Did they pass their retest the first time?
l 2.
Did TVA inspect any welds made by these welders while they were "out of certification?"
i 3.
How long were they out of certification?
4.
The eight welders found out of certification were out of all welders reviewed or just the twenty-five?
3.2.4 Concern XX-85-101-006 was investigated by ERT Report XX-101-006.
This report had as.its issue that a welder performed welds without having the proper certification.
The report substantiated the concern and had four i
j recoctmendations.
i
TVA Evalation Appendix 5.2 of the TVA Report states "WP has determined that this analysis missed the point of the concern. WP recommends this concern not be substantiated.....".
Expert Welding Team Before any evaluation can be made on this concern or report, more information is required from TVA on why the report and recommendations are dismissed.
3.2.5 NSRS Report No. I-86-115-SQN was writter. in response to concerns SQM-6-005-001,X02. The issues involved were:
1.
Whether a known welder was capable of making proper welds.
2.
Whether there was collusion to certify this welder resulting in falsified records.
TVA Evaluation:
1.
The concern that the welder in question was incapable of making proper welds was partially substantiated by virtue of the poor performance evaluation of work performed in the turbine building. The welder does make adequate welds in the shop.
2.
The concern that the welder was passed by collusion between engineering.and the general foreman resulting in falsified records could not be substantiated.
Expert Welding Team The concern appeared to have had adequate investigation and corrective action by TVA.
This concern appears to be a management problem and not a hardware or a safety issue.
3.2.6 The last three concerns in this category XX-85-088-001, 003 and X04 all involved the use of correction fluid in altering welding certifications.
TVA Evaluation:
XX-85-088-XO4 and 001 were substantiated by a QTC report (same number as concern). The investigation showed that no substantive information was obliterated.
Concern XX-85-008-003 was considered unsubstantiated by the investigation report.
Expert Welding Team The welding team agreed that -003 was unsubstantiated from the available data reviewed.
It should be noted that in the two cases of substantiation, no corrective action was considered necessary.
In the unsubstantiated case, the review was limited to only those "hard copies" available, a limited scope.3.3
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3.3 Category 3 - Welding Inspection There were a total of 48 concerns in this category.
Report Number Concern Responding to Brief Description Number -
Reference Concern of Concerns IN-85-282-002 T2 WP-11 Surface grinding PH-85-040-001 T2 WP-02 Inspection thru paint WI-85-013-003 T2 WP-02 Inspection thru paint WI-85-041-006 T2 WP-02 Inspection thru paint WI-85-041-008 T2 WP-02 Inspection thru paint IN-85-458-001 T2 WP-02 Inspection thru paint IN-85-767-003 T2 WP-02 Painted welds WI-85-030-008 WP-02 Inspection thru paint IN-85-406-003 T2 WP-04 No inspection tools IN-85-134-002 T2 WP-04 No tools IN-85-007-001 T2 WP-04 No tools IN-85-007-003 T2 WP-17 Vendor welds IN-85-657-001 T2 WP-17 Vendor welds IN-85-127-001 T2 WP-17 Bergen Patterson/ Vendor weld appearance GQM-5-001-001 T2 WP-16 Undersized socket welds WP-16 Preweld inspection by foreman SQM-5-001-002 T2 IN-85-212-001 T2 WP-16 Weld inspection IN-85-406-002 T2 WP-09 No inspection criteria PH-85-012-X03 F,T2 WP-05 Deleted HVAC XX-85-069-001 T1,T2 ERT Report NDE certs XX-85-069-002 ERT Report NDE certs XX-85-069-003 T1,T2 ERT Report NDE certs XX-85-069-006 ERT Report NDE certs XX-85-069-007 T2 ERT Report NDE certs XX-85-069-X13 T1 ERT Report NDE certs XX-85-069-003-R1 T2 I-85-738-SQN NDE certs XX-85-069-X05 T1,T2 I-85-738-SQN NDE certs XX-85-069-X07 T2 I-85-738-SQN NDE certs XX-85-108-001 T2 I-85-776-SQN No inspections performed XX-85-108-002 T2 I-85-776-SQN No inspections socket welds IN-85-001-005 F
I-85-753-WBN Vendor welds XX-85-054-001 T2 I-85-346-SQN QC inspector sign off XX-85-065-001 T2 I-85-750-SQN Remote inspection XX-85-083-001 T2 I-85-652-SQN Poor welding inspection XX-85-102-011 T2 I-85-735-SQN Different programs IN-85-981-001 F,T1,T2 WP-06 Poor training of inspector WI-85-041-002 F,T1,T2 WP-06 Inspector quals.
IN-85-476-004 F,T2 WP-06 Inspector quals.
SQM-6-008-001 F
Undersized socket welds WBM-5-001-002 T2 WP-16 Preweld inspection by foreman WI-85-081-007 T2 WP-06 Inspector not qualified
a s
3.3 (Cont'd)
Report Number Concern Responding to Brief Description Number Reference Concern of Concern XX-85-098-001 T2 WP-18 Laminated piping in Unit 2 NS-85-001-001 T2 WP-02 Inspection of welds thru paint IN-85-271-001 T2 WP-02 Surface gri.nding of welds WBM-5-001-001 T2 WP-16 Preweld inspections BEM-5-001-001 T2 WP-16 Preweld inspections BEM-5-001-002 T2 WP-16 Preweld inspections BFM-5-001-002 T2 WP-16 Preweld inspections 3.3.1 Nine of the concerns were responded to, by WP-02.
The issues involved in these nine concerns were:
1.
Specifications allow inspection of welds after painting or coating with inorganic zine primer in violation of FSAR and AWS requirements after tests demonstrated that adequate inspections could not be made.
2.
There may have been/were welds inspected through primer.
3.
Inspectors did not understand thickness provisions for primer and could not have performed an adequate inspection.
4.
NRC involvement in approving procedure for inspecting welds through paint.
TVA Evaluation The four issues were considered not substantiated for the following reasons:
1.
Procedures were and are in effect for OC and NO, respectively, which provided for initial inspection of welds prior to painting..
t 2.
The Bechtel audit established that those procedures were effectively implemented for both OC and NO.
3.
NRC does not formally approve or disapprove specific construction practices.
Expert Welding Team The team believed that sufficient investigation had been performed on these concerns due to the fact that inspection through paint was not allowed at SQN. The team agreed with the utility's findings.
i 3.3.2 Three concerns were addressed by WP-04.
The major issue of these th' ee r
concerns was:
l 1.
Welding inspection tools were not issued to welding inspectors.
_ 13 _
TVA Evaluation The utility considered these concerns unsubstantiated for the following reasons:
1.
Weld inspection tools were and are furnished to welding inspectors.
- 2. ~More sophisticated inspection tools were furnished to welding inspectors as they became commercially available and as the need for more percise verifications of weld attributes was identified through program improvements.
3.
Records were and are available which document the purchase and distribution of these tools.
Expert Welding Team It was felt that sufficient investigation was performed by the utility to close the item.
It was also deemed prudent that a definite number of available records should be reviewed by the I&E Audit Team (July 1986) to j" verify issuance of inspection tools. This could not be accomplished and should be reviewed at some later date by the NRC.
3.3.3 Three concerns were aimed at vendor welds and were addressed by WP-17-SQN.
The itssues involved were:
1.
Vendor velds are not of the same quality as TVA field welds.
2.
Vendor welds are not inspected in the field.
TVA Evaluation The utility investigated and substantiated these vendor welds and drew the
[
following conclusions:
l 1.
The employee concerns are substantiated as they relate to the observed general condition of vendor welds.
2.
A similar problem had been identified, reported, documented, and dispositioned in accordance with applicable QA program requirements at WBN.
Expert Welding Team fheteamwasinagreement that the investigation and follow up was adequate j
but felt that some additional information was required:
1.
Were B-P hangers rejected at receipt inspection or prat-facto as part of the concern investigation?
2.
What was the inspection criteria for the hangers at the plant?
At the vendor's shop?
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The above two questions are not in the scope of the EWT but would more ade-quately answer the issues raised.
3.3.4 Nine concerns were evaluated by WP-16-SQN.
The issues involved with these nine concerns are:
1.
Do uncertified welder foremen perform perform preweld inspections?
2.
Is this a violation of the TVA Quality Assurance Program?
3.
Ia this a violation of ANSI N45.2.5 requirements?
TVA Evaluation The issues considered in these concerns are not substantiated for the con-struction era at SQN but are substantiated for the Nuclear Operat*ons era due to the following reasons:
1.
SQN construction had a program in place which contained pro-cedures which adequately addressed the elements of ANSI N45.2.5.
2Property "ANSI code" (as page type) with input value "ANSI N45.2.5.</br></br>2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Nuclear Operations has identified this issue as an area of noncom-pliance 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.
' Expert Welding Team The team believed that since the utility has now committed to fit up inspections (NO) by certified QC inspectors that adequate corrective action has been implemented. The utility has not adequately answered the question for construction since-they did commit to N45.2.5.
This standard does state "This inspection shall include visual examinations of preparations..." in section 5.5 entitled " Welding." Additionally, Section 2.4, " Personnel Qual-ifications" requires that " personnel performing tests and inspections required l
by this standard shall be qualified in accordance with ANSI N45.2.6.
Per-I sonnel performing field inspection and testing activities shall be certified i
for Level I capability...". More information is required of the utility on this apparent violation of the ANSI standard for the construction phase of l
SQN. This instance might also be a possible violation of Criteria X and I of 10CFR50, Appendix B.
3.3.5 Concern IN-85-406-002 was answered by WP-09 7'.e concern expressed i
was:
i 1.
Prior to 1979, there was no specific 9,id 0. gection criteria for use j
by inspectica personnel.
TVA Evaluation This issue was not conaidered substantial for the following reasons:
l l
1.
Inspection procedures which delineated code and standard requirements 4
were in effect at SQN for OC.
2.
The Bechtel SQN Implementation Audit provides an independent veri-fication of the adequacy of these procedures.
Expert Welding Team The investigation and explanation by the utility adequately answered the concern.
3.3.6 Two concerns were related to spiral-welded pipe and had the following issues answered by WP-05-SQN.
1.
EGT piping is too close to wall for adequate access for welding.
2.
Welds should be welded and inspected from the inside of the pipe to assure adequacy.
3.
Welding and brazing inspection may have been/was deleted from the QA program without adequate justification.
TVA Evaluation Issues 1 and 2 were substantiated due to:
1.
It has been determined by direct inspection that there are areas of spiral weld duct which are not welded on the outside diameter because of the close proximity to walls and other barriers in similar systems.
2.
It has been determined by direct inspection that welds have been made and subsequently inspected on the inside diameter of the spiral weld pipe where there are corresponding areas which are not welded on the outside diameter.
Issue three was not substantiated because there was a program in place for welding inspection on duct work and duct supports doing construction at SQN.
Expert Welding Team The follow-through and investigation by the utility was adequate to close out these concerns.
3.3.7 Six concerns related to NDE inspectors were answered on an ERT inves-l tigation report which had the following issue:
l l
1.
Employees OJT (on the job training) records have been falsified.
TVA Evaluation l
Appendix 5.2 of the TVA final report, page 1 of 2, lists concerns XX-85-069-001, 001-R1, X05 and X07 as being closed by NSRS Report I-85-373-NPS with "No
falsification of records was substantiated. WP concurs with report recommen-dations." The ERT report addressed six concerns on OJT and determined that the concern was substantiated and had the following recommendations.
The results of this investigation clearly indicated both a programmatic break-down and falsification of records within the TVA NDE training / certification program. Based on these findings, the following is recommended:
1.
The turnover of this report to the Office of General Counsel (OCC) for investigation of legal wrong doing, and 2.
TVA issue an immediate stop work order against the certification of NDE inspectors until such time as the situation can be evaluated and corrective action taken.
Expert Welding Team No additional evaluation can be done until more information is received re-garding these recommendations.
The information needed is:
1.
Were any MT/PT/ Visual reinspections done on any of the " uncertified /
unqualified" inspectors?
2.
Volumetric examination was not really addressed. What is the impact on ISI/ PSI previously inspected welds? Did any " qualified" individu-als reinspect any " unqualified / uncertified" inspectors'previously accepted work?
3.3.8 Three additional concerns on NDE certification were addressed by NSRS Report I-85-738-SQN.
This report dealt with the following issue:
1.
Sequoyah: Very of ten, rejected items are accepted by someone other than a supervisor or a higher level (grade). To illustrate the point, CI stated that the supervisor will send another examiner /
inspector with less qualification and experience to reexamine the once rejected items and will get acceptance.
TVA Evaluation The utility found that the concerns were not substantiated based on the following:
1.
Previously rejected items have been accepted by a second examiner who was a certified Level III examiner. On each occurrence the examiner would note on the NOI and the corresponding data sheet the basis for acceptance of the item which, in effect, voided the NOI.
This pro-cess does not appear to violate any specific regulatory requirement or ASME rule applicable to the ISI program.
d a
2.
Previously rejected items have been accepted by Level II NDE exam-iners who were designated as Acting NDE Unit Supervisor. The accep-tances occurred when Part III of the associated NOI was completed by the acting supervisor. This process does not appear to violate any specific regulatory requirements or ASME rule applicable to the ISI program.
3.
One NOI was found to have part III closed without documenting that all of the corrective action had been completed for the affected item. This occurrence is a failure to meet the intent of existing program requirements (reference 6c). This NOI does not clearly fit the CI's description; however, no other examples could be found which support the stated concern.
Expert Welding Team Response appears adequate if the follow up and corrective action is completed (TVA Evaluation 3).
It should be noted that the procedures for handling NOI's had misleading and insufficient information to make the handling of NOIs consistent. This ap-pears to be a symptomatic condition in many TVA procedures. The confusing and misleading procedures were also discussed by the TVA sponsored Bechtel Audit performed at SQN.
3.3.9 Two concerns regarding lack of inspections of socket welds were evalu-ated in Report I-85-776-SQN which dealt with the following issues:
1.
Sequoyah: C/I states welds in Unit #1 accumulator rooms and/or fan rooms were never inspected. Time frame is nine or ten years ago.
Welds on 2" stainless steel (socket welds) and hangers on the radius pipe in those areas. C/I has no additional information.
2.
Sequoyah: Programmatic breakdown on the weld inspection process.
Nine or ten years ago C/I states that some welds on 2" stainless steel socket welds were not inspected as required. C/I has no additional information.
TVA Evaluation The utility determined that the concerns were unsubstantiated for the follow-ing reasons:
1.
The universal computer status system required that all documentation be present before the system could be trasferred to Nuclear Power.
Any safety class welds that were not examined prior to the utiliza-tion of the universal program would have been examined at a later date to meet QA record requirements.
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2.
The construction instructions and procedures in place at the time of the concern did require inspections and documentation; therefore, an adequate program was in place. However, the use of the universal program provided a better method of determining the present status of any weld and what remained to be done. Although the universal pro-2 gram provided a more positive means of preventing oversights, the old manual system could have provided the same assurance but by a much i
more laborious method.
Expert Welding Team It was felt that the concerns were unsubstantiated and that the utility's programmatic close out of the items satisfactory.
3.3.10 Concern IN-85-001-005 was addressed by NSRS Report I-85-753-WBN which had as its issue:
1.
Vendor welds were bought off even though they exhibited " shoddy workmanship."
TVA Evaulation The concerns were substantiated and an engineering disposition of the affected parts was "use as is."
Expert Welding Team Utility response was adequate. Will be reviewed for WBN Project.
3.3.11 Employee concern XX-85-054-001 was addressed by NSRS Report I 346-SQN which had as its issue:
1.
Sequoyah: QC holdpoints are signed off by craftsmen (craft known) performing the work. Personal friendship between inspectors and craf t allow this to occur without being reported. Time frame is between 1979 to 1984. No specific provided."
1 TVA Evaluation i
The utility felt that the concern was unsubstantiated for the following:
1.
The individual identified by the concerned individual as having knowledge concerning this problem did not acknowledge seeing any craft personnel signing any QA documentation or know of any instances I
where it occurred.
I 2.
The weld documentation system with all its crosschecks and reviews would have a high probability of not allowing the si,off of a QC F
holdpoint by an unqualified individual.
3.
None of the people interviewed knew of any instance where a craf tsman signed o,ff on a QC holdpoint.
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1 4.
Since inspections were performed by the next available inspector, assurance of getting a particular inspector (personal friend) could not happen with any degree of certainty.
i Expert Welding Team The team believed that the investigation and closeout by utility was satisfactory.
3.3.12 Concern XX-85-065-001 was handled by NSRS Report I-85-750-SQN.
This concern had as its major issues:
1.
Inspectors made inadequate visual inspection of suspended, rigid ERCW pipe supports in the auxiliary building at the 669' elevation i
during the February / March 1984 time frame.
2.
Visual inspections must be performed at close proximity to verify specific mandatory inspection attributes (particulars) on the inspec-tion checklist.
TVA Evaluation The utility felt that this concern was unsubstantiated for the following reasons:
1.
The two inspectors named by the CI did not work together on ERCW hanger inspections.
2.
The two inspectors who did not work together said it was impossible to do an adequate inspection remotely and recognized that it would be l
a violation of procedures to do so.
Both said that it was not worth jeopardizing their jobs to do a poor inspection since they were not being pressured to meet a particular quota of inspections each day.
3.
The reexamination of ERCW pipe hangers conducted during this investigation did not identify any major problems.
4.
A plant QA staff manager said that he had not heard of an incident such as this employee concern and would have been notified if it had been reported to a supervisor.
5.
The onsite ANII said he witnessed the two individuals performing inspections and did not believe they would do anything other than a i
proper inspection.
Expert Welding Team The team agreed with the utility's findings but also observed that the number of reportable defects found on the reinspection showed an overall " sloppiness" in the original inspection sequence.
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3.3.13 Concern XX-85-083-001 was answered with Report I-85-652-SQN.
This had as its major issues:
1.
Were Sequoyah welds properly inspected?
2.
Were Watts Bar welds excessively inspected resulting in unjustified welding cost?
TVA Evaluation The utility felt that the concern was unsubstantiated for the following reasons:
la.
The allegation that Sequoyah welds may not have been properly in-spected could not be substantiated because these welds were in-spected under an inspection of QC program which met the QA and Code requirements applicable to construction activities at Sequoyah.
Ib.
The allegation that Watts Bar welds were excessively inspected could not be substantiated because these welds were inspected under an inspection and QC program which met the ASME Code requirements applicable to Watts Bar.
Since Watts Bar is an ASME Code stamped plant, the independent third party (ANI) verification of inspections performed by TVA personnel could be construed as a more strict inspection program.
In addition, Watts Bar has been subjected to many reinspections to resolve possible safety concerns and to satisfy NRC inquiries. These, also, could be construed as a n. ore strict inspection program.
2.
A comparision of the overall welding inspection and documentation requirements between two nuclear plants of different ages, different codes of record, and code plant versus non-code plant cannot be described succinctly and, if done, differences will be observed.
These differences would not necessarily indicate that one inspection l
program is better than the other or that the weld integrity of one plant is better than the other.
Expert Welding Team The team believed that:
1 1.
Programmatically the NSRS report does answer the question that the quantity of inspections between the two plants was similar. Previous reports, however, give rise to the speculation that the quality of these initial inspections may have left something to be desired at SQN.
2.
WBN welding cannot be evaluated at this time.
The team will evaluate this issue at a later date for the WBN program.
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I 3.3.14 Concern XX-85-102-011 was evaluated by report I-85-735-SQN.which had as its two specific issues:
1.
NDE inspectors report service-related defects only on Notices of Indication (NOI).
2.
Preservice defects are reported only on a Maintenance Request (MR).
TVA Evaluation 1.
The concern of record could not be substantiated because this investigation revealed that NOIs are prepared for both preservice and inservice defects found within the area of scope for ASME Section XI examinations.
Expert Welding Team The team agreed with the programmatic closecut of the concern by the utility.
3.3.1.5 Four concerns were addressed by WP-06-SQN, involving the following issues:
1.
Prior to 1981, an inadequate Welding Inspection Training and Certification Program allowed welding inspectors to complete their training in two weeks.
2.
The Training / Qualification Program for AWS welding inspectors is questionable because the inspectors only have two months DJT which is not documented.
3.
The Topical Report has been " bastardized" regarding TVA compliance with ANSI N45.2.6.
4Property "ANSI code" (as page type) with input value "ANSI N45.2.6.</br></br>4" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Welding inspectors are not qualified. They should be welders before becoming welding inspectors.
TVA Evaluation The utility felt that the concerns were unsubstantiated for SQN (WP-06-SQN) for the following reasons:
1.
A program was in place during the construction era which adequately addressed the applicable requirements for training, qualification, and certification of both visual welding and nondestructive testing personnel.
l 1
2.
The Bechtel-SQN Implementation Audit established that this program l
adequately addressed the code and standard requirements of the con-struction era and confirmed that the. program was effectively imple-mented for that era. The part of Issue 4 which states "they (welding inspectors) should be welders prior to becoming welding inpectors" should be dismissed. This is not an essential element of any train-ing, qualification, and certification program. It is simply a state-ment of personal opinion.
Expert Welding Team j
The team essentially agreed on the evaluation for SQN only.
It should be noted that in a previous ERT report for these concerns that it was substan-tiated for the WBN units.
3.3.16 Concern XX-85-098-001 was addressed by WP-18-SQN.
This concern has as i
its major issue:
Laminations in pipe prevented making a good butt weld in Unit 2 1.
condenser.
TVA Evaluation The utility wrote that the issue voiced in this concern is valid but not substantiated.
It has been determined not to be detrimental for the following reasons:
1.
ASME Class 1 rules state that weld prep laminations one inch and less in length are acceptable material conditions which do not require weld repair. Those greater than one inch are allowed to be weld repaired after grinding to a specified depth.
2.
Condensers are constructed to requirements less stringent than ASME Class I which do not address laminations as injurious defects.
4 3.
Laminations are commonly occurring discontinuities in wrought steel products and are not prohibited by materials specifications.
4.
The effect of a lamination in a pipe subjected to internal pressure is of no concern.
5.
Laminations pose no problem to weld joint integrity.
j Expert Welding Team The team agreed that the resolution was adequate and satisfactory, even though the item (not safety-related) did not necessarily fall into the scope of its review.
3.3.17 Concerns IN-85-271-001 and IN-85-282-002 were answered by WP-11-SQN 1
and had as its major issue:
1.
Crinding of welds may mask surface defects.
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TVA Evaluation 1.
The issue considered in this concern is not substantiated due to i
the fact that grinding is an acceptable practice.
Expert Welding Team Satisfactory closeout of this concern.
3.4 Category 4 - Welding Design and Configuration There were seven concerns that fall into this category.
Report Number i
Concern Responding Brief Description Number Reference to Concern of Concern EX-85-039-003 T1,T2 WP-15 Box hanger poor weld design IN-85-613-001 T1,T2 WP-15 Thermal stress pipe / hanger weld XX-85-086-002 T1,T2 WP-15 BNL wrong design for box hanger l
XX-85-086-003 TI,F WP-15 Weld design for box hanger
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i IN-85-405-001 T2 WP-15 Hanger over-designed l
XX-85-068-007 T1,T2 I-85-636-SQN No stamped spool falsified piece XX-85-100-001 T1,T2 ERT XX-85-100-001 Improper weld repair 3.4.1 Five of the concerns were responded to by WP-15-SQN which had as its issues:
1.
Box anchor drawings have a typical detail which shows a weld configuration which limits pipe movement.
2.
There is a possibility of fatigue in service in process piping to box anchor connections due to lack of provisions for expansion.
3.
There is a possibility of fatigue in service and material degradation due to continuous welding using large disseter electrodes and excessive amperage.
1 4.
There is a possibility of thermal stresses degrading piping where large (half-inch to one-inch) fillet welds on box anchcrs attach to process piping.
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TVA Evaluation The utility considers the concerns unsubstantiated for the following reasons:
1.
Engineering evaluations and tests relative to expansion and large welds have determined that their effect is not detrimental to process piping.
2.
Continuous welding with large diameter electrodes is the optimum method of welding of box anchors.
Expert Welding Team The team felt that more information was required on issues 2-4 as follows:
2.
More information is required on possibility of " fatigue in service" for hangers. This was not addressed.
3.
The answer to this issue is somewhat misleading / erroneous due to the fact that the use of larger diameter electrodes generally results in a greater heat input to the weldment.
4.
This appears to be a Bellefonte specific issue. More information is needed to determine if the mockups had any bearing on SQN work.
The one installed box anchor at SQN (Issue #1) did not have this problem due to special handling, while the other seven hangers had the drawing changed.
This issue appears closed.
3.4.2 Concern XX-85-068-007 was answered by NSRS Report I-85-636-SQN and had the following issues associated with it:
1.
TVA may have manufactured an ASME Section XI spool piece.
2.
TVA replaced a DRAVO spool piece with TVA manufactured spool piece.
3.
The code nameplate was moved from the DRAVO piece to the TVA piece.
4.
TVA inspector may have been aware of switch but did not report it.
l TVA Evaluation l
The utility felt that the concern was not substantiated for the following reasons:
1.
No evidence of DRAVO spool piece could be found at Sequoyah, and no record of their purchase was found.
2.
Even though TVA does manufacture spool pieces for repair, replace-ment, or modification of plant piping systems, there could have been no exchange with DRAVO.
4 -
3.
Code nameplates are not required at Sequoyah; therefore, the concern about any removal attachment is not valid. No evidence of such activity was found in this investigation.
4.
Inspection personnel at Sequoyah are familiar with the fact that nameplates are not required. There would, therefore, be no reason for an inspector to report an activity that did not violate a re-quirement or procedure.
Expert Welding Team It was felt that this report adequately addressed the concern and closed it out.
3.4.3 The last concern in this category XX-85-100-001 was addressed by an ERT report. This concern had as its major issue:
1.
An undetermined number of welds may have been repaired improperly.
TVA Evaluation The utility felt the concern was not substantiated because insufficient evidence was found to substantiate the occurrence.
Expert Welding Team Utility response was sufficient to close out concern.
3.5 Category 5 - Filler Metal Control This category has 26 concerns associated with it, as listed on the following page.
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Report Number Concern Responding Brief Description Number Reference to Concern of Concern EX-85-039-001 T1,T2,F WP-01-SQN No portable rod ovens l
IN-85-424-001 TI,T2,F WP-01-SQN No portable rod ovens IN-85-234-001 T1,T2,F WP-01-SQN No' portable rod ovens IN-85-426-001 T1,T2,F WP-01-SQN No portable rod ovens IN-85-441-003 T1,T2,F WP-01-SQN No portable rod ovens IN-85-352-002 T1,T2,F WP-01-SQN No portable rod ovens WI-85-053-004 T1,T2,F WP-01-SQN Weld rod does not meet code XX-85-068-006 T1,T2,F WP-01-SQN Weld rod control not code complying IN-85-337-002 T2 WP-01-SQN Weld rod control, exchange among welders IN-85-424-004 T2 WP-01-SQN Improper issue weld material IN-85-424-007 T2 WP-01-SQN Lack of weld rod control IN-85-424-006 T2 WP-01-SQN Weld material accountability IN-85-454-004 T2 WP-01-SQN Weld material accountability IN-85-453-009 T2 WP-01-SQN Weld material accountability WI-85-041-001 T2 WP-01-SQN Weld material accountability IN-86-150-001 T2 WP-01-SQN Weld material accountability EX-85-021-001 T2 WP-01-SQN Weld material accountability IN-85-167-001 T2 WP-01-SQN Weld material accountability IN-85-672-001 T2 WP-01-SQN Weld material accountability IN-86-158-006 T2 WP-14 Weld material accountability IN-85-411-002 T1,T2 WP-12 Bad ARCO weld rod IN-85-247-001 T1,T2 WP-12 Poor 7018 electrode IN-85-600-001 T1,T2 WP-12 Hobart poor 7018 electrode IN-86-047-001 T1,T2 WP-14 No weld rod stub control l
XX-85-013-001 T1,T2 ERT XX-85-013-001 309 used for 316 SS pipe XX-85-041-001 T1,T2 NSRS I-85-756-SQN Wrong weld rod CS to SS 3.5.1 Nineteen concerns were addressed by WP-01-SQN which had as its major issues:
1.
The Weld Material Control Program does not meet code requirements.
The context of this issue gives the inference that the concerned individuals are referring to the overall traceability of welding materials from procurement until the materials are consumed in the final weld.
2.
Returned welding material is possibly not accounted for adequately.
3.
Possible lack of portable electrode holding ovens.
l 4.
Possible collection of moisture in electrodes due to lack of portable electrode ovens.
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i TVA Evaluation The utility considers these concerns unsubstantiated for SQN for the following reasons:
1.
Procedures were and are in effect 'for OC and NO which delineate the requirements for traceability and control of filler metals.
2.
The provisions of these procedures reflect ASME B&PV Code rules and have been endorsed by ASME through the ASME survey process.
3.
The Bechtel SQN Implementation Audit established that these procedures were effectively implemented for both OC and NO.
4.
The effect of noncompliance with these procedures was not found in the WP Sample Reinspection Program.
Expert Welding Team The team had some comments / questions regarding the answer to the concerns:
1.
The statements regarding traceability of material were adequate.
It did appear that they had some progam conflicts, but this would not effect the hardware.
2.
The issue regarding returned welding material was not addressed in WP-01-SQN.
3.
For SQN (specific) this appears acceptable, but, were holding ovens issued at SQN between 1969-1974 (beginning construction phase)?
Contradictory information received after the SQN site audit questions the completeness of this response.
4.
This issue is only partially answered by the issuance of portable rod ovens. The accountability of returned rod (possibly left in a gang box or a glider over night) has a great influence on the rods moisture content.
3.5.2 Two concerns were addressed by WP-14-SQN. The issues addressed by these concerns were:
1.
A system is needed which will provide the welder a receipt which can prove welding material was correctly returned to the rod issue centers.
2.
TVA does not allow apprentices to weld.
I TVA Evaluation The utility felt that the concerns be closed since the issues have no quality i
or technical basis.
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i Expert Welding Team The team felt that:
1.
This issue was raised in WP-01-SQN as being "non-anwsered" in the report. This report also "non-answered" the concern.
2.
This answer appears valid, but the team needs a copy of the concern for close out.
3.5.3 Three concerns were evaluated by WP-12-SQN which had the following issues considered:
1.
E7018 electrodes are of poor quality.
2.
Poor quality contributes to pinholes and porosity.
3.
E7018 3/32-inch electrodes are of poor quality.
4.
Electrode core wire is not centered and flux flakes off.
TVA Evaluation The utility felt that these concerns were not substantiated because:
1.
Electrode operability is a subjective judgement and cannot be measured quantitatively.
2.
The specific cases discussed in the concerns were WBN occurrences.
3.
A search of historic data on this subject by WP for SQN revealed no objective evidence of problems with these or other coated electrodes.
4.
The reinspection effort did not reveal any evidence of electrode quality problems.
Expert Welding Team The team believed that the utility did an adequate job in answering these
- oncerns and had the following comments
1.
E7018 (if purchased to the correct codes and standards) is acceptable even though some welders may have a period of adjustment to different manufacturers' electrodes.
2.
If the concentricity problem had occurred at SQN, it would have been impossible to locate all the electrode due to the electrode control procedures for the construction phase of SQN.
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B 3.5.4 Concern XX-85-013-001 was addressed by a ERT report which had as its major issue:
1.
309 weld rod was used to weld 316 stainless pipe at Sequoyah Unit 1.
TVA Evaluation The utility determined:
Based on the findings in this investigation, a change from E308 to E309 (same A&F designation) is not a violation of the code or procedure. The concern as stated may be true. However, the change from 308 to 309 filler metal has no impact to weld quality. This concern is closed.
Expert Welding Team Utility response is acceptable 3.5.5 The last concern in this category XX-85-041-001 was answered by report I-85-756-SQN and had as its primary issue:
1.
At Sequoyah, a weld was made in '79 or '80 in diesel generator building, unit 1, using the wrong type rod to weld carbon steel pipe to stainless steel pipe. A cover pass using the correct rod was run over the existing seld.
Construction Dept. concern. CI has no more information.
TVA Evaluation The utility felt that the concern was unsubstantiated because:
1 1.
The concern of record could not be substantiated because all thewelds examined were found to be free of any defects which could be noted on l
the surface. All the welds were approximately the same physical l
size; therefore, not allowing the detection of any extra filler metal which might have been added to conceal a defective weld.
I 2.
If the first pass weld was made with E308, the veld would not have been pleasing in appearance, but would have bonded to both the carbon steel and the stainless. The second pass with the correct electrode (E309) would have remelted some of the first pass and provided a smoother region of bonding.
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3.
With the rigid support being located adjacent to the weld, there is no reason to expect the weld would experience stresses to cause a fatigue failure.
Also, if the instrument tube weld should develop a crack, it would be restrained from separating and creating a significant leak.
4.
All the welds appeared to be sound and were free of any detectable defects after several years of operation.
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Expert Welding Team The team believed that the investigation into the problem was adequate.
3.6 Category 6 - Miscellaneous /One of a Kind There were a total of 9 concerns in this category.
Report Number Concern Responding Brief Description Number References to Concern of Concern IN-85-192-002 T2 WP-08 Unpainted welds IN-85-273-001 T1,T2 WP-08 Hanger welds not painted IN-85-451-001 T2 WP-08 Weld not painted EX-85-059-001 T2 WP-08 WI-85-030-001 F,T1 WP-10 Welding + NDE corrective action not implemented WI-85-030-010 T2 WP-10 Weld program study IN-85-303-001 F,T1,T2 WP-13 No remote switches on welding machines IN-85-247-002 F,T1,T2 WP-13 Only 2 setting on welding machines XX-85-010-001 F
SQN-nut to, baseplate welding plus chipped concrete 3.6.1 WP-08-SQN addressed four of the concerns which had as their major issues:
I 1.
Welds over six feet of the floor have not been painted in the Reactor and Auxiliary Buildings.
2.
Unpainted welds are in evidence on conduit and piping supports in the Reactor Building.
3.
Hanger welds should be painted as soon as they are finalized by QC.
4.
Rust causes welds to be weakened.
5.
Sandblasting removes metal from welds.
TVA Evaluation The utility resolved these issues as follows:
Issues 1, 2, 3, and 4 closed pending completion of protective coating reinspection and resultant corrective action under SQN-CAR-86-01-001.
Issue 5 is closed because the practice to sandblasting is an accepted practice in preparation of metals for painting.
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Expert Welding Team The team felt these were effectively closed out by the utility even though the concerns were not really welding issues.
3.6.2 Two concerns were addressed by WP-10-SQN which were considered with:
The corrective actions specified in Report Number QAE-80-2, " Review and 1
Evaluation of the OEDC Welding and NDE Program," dated September 8, 1980, may not have been implemented.
TVA Evaluation The utility felt this concern is substantiated and has closed the item because QAE-80-2 was not intended to be implemented at SQN and no impact on SQN hard-ware could be identified.
Expert Welding Team Although not SQN-applicable, many of the recommendations in QAE-80-2 encompass
" concern areas" at SQN and will be evaluated in greater detail for WBN.
3.6.3 Two concerns were addressed by WP-13-SQN which had the following issues associated with them:
1.
Welding machines (grid packs) do not have suitable control settings for welding with 3/32-E7018 electrodes.
2.
This unsuitability leads to porosity and pinholes in completed welds.
3.
All GTAW equipment should have remote (high frequency are starting) switches so that tungsten inclusions can be avoided.
TVA Evaluation The utility closed out these issues based on the following:
1.
There is no industry standard which mandates the use of specific welding equipment for specific jobs.
2.
Equipment in use has sufficient control features to produce welds within the required criteria.
u 3.
Alternate techniques can be used to compensate for the lack of sophisticated features on multiple operator-type equipment and still produce acceptable quality welds.
4.
The WP reinspection did not discover any indications of a generic problem with welding equipment.
5.
There is no effect on hardware due to these issues.
~.
Expert Welding Team The team determined that:
1.
The welding machines described in the report appear to have suffi-cient settings for current ranges of typical welding procedures.
2.
If the machine was unsuitable, porosity or pinholing could be a prob-les and should have been picked up on the reinspection program.
3.
The high frequency arc start is a beneficial addition to GTAW weld-ing, but is not essential in making a good quality welded connection.
3.6.4 The last concern, XX-85-010-001, is not a welding issue but should be a hanger installation concern.
4.0 PROGRAMMATIC REVIEWS BY TVA CONTRACTORS In addition to the NSRS, QTC and WP reviews, TVA placed a contract with Aptech Engineering Services to perform a review of the SQN, PSI /ISI programs, as well as with Bechtel Engineering to perform an in-depth audit of their QA/ welding program for both construction and operations.
J I
4.1 Aptech Report The review by Aptech Engineering Services was made in addition to the other TVA activities relative to the SQN welding concerns. The review covered welds subject to the ASME Section XI program for Class 1 and 2 piping, as well as Class 1, 2 and 3 component supports.
The review was performed using a two-pronged approach; first was the evalua-tion of the preservice and inservice inspection results, and second was the review of the operating experience of the two plants.
There were 1101 welds (both Class 1 and 2) examined during the SQN-PSI program out of a total number of 2618 Class 1 and 2 piping welds on the two units.
Therefore, 42.1% of the total number of Class 1 and 2 piping welds were examined by the PSI program. Additionally, a total of 61 integrally welded attachments were subjected to the SQN-PSI program out of a total of 146 l
(41.8%). Less than 10% of the welds in the PSI program were examined by pene-l trant examination with the more than 90% of the welds examined volumetrically (ultrasonic testing).
The Aptech review of the SQN-PSI program uncovered only one significant NOI (Notice of Indications) reported.
(Significant NOI refers to an indication which is unacceptable to ASME Section XI and requires repair and reinspec-tion.)
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The SQN-ISI program (to date of Aptech Review) had inspected a total of 456 1
piping / socket welds (predominantly repeats of PSI welds), 90 hanger integral attachments, and 100% of all Class 1, 2 and 3 hangers for SQN 1 and 2 (over 3,100 ISI inspections).
The total number of 27 NOIs were reported for Units 1 and 2.
Of this total, 12 were significant NOIs (Unit 1) and 5 significant NOIs (Unit 2).
The operational history of the two plants showed that for 24,445 critical re-actor hours of service (Unit 1), only 5 LERs were written relating to welds.
(Licensing Event Reports (LERs) are written to USNRC to report failures on operating nucler plants). No failures were attributed to poor quality field welds.
Unit 2 has 21,985 critical reactor hours of service and has had no LERs relating to welds.
Based upon their review, Aptech Engineering came to the following conclusions:
The welding program contains the necessary controls to ensure high quality welds (after the 1974 AEC audit).
SNP evaluated the quality of welds made prior to the 1974 audit through reinspection and repair where required. Those welds made prior to the 1974 audit.can now be considered to be satisfactory despite a breakdown in the QA program.
The rate of significant indications detected during the preservice
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and inservice inspections is less than 5% with greater than 95%
confidence.
No Licensee Event Reports have been generated which relate to poor quality field welds.
BNL Evaluation Although the Aptech findings give an optimistic prognosis for the plant, it must be remembered that this review only encompassed a paperwork review of the PSI and ISI programs and did not attempt to answer any employee concerns. The review did not require any physical reinspections of hardware and relieu on documentation provided by TVA.
I 4.2 Bechtel Audit A Bechtel audit team (five-member team) spent 30 auditor weeks reviewing records to determine the prior and current effectiveness of the TVA Welding Program (both construction and operations).
The scope of the audit included 17 key elements for review:
1.
Implementation of technical and welding program requirements 2.
Adequacy'of design output documents
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Initial welder or welding operator qualifications 4.
Maintenance of welder or welding operator qualifications 5.
Renewal of welder or welding operator qualifications 6.
Initial welding inspection personnel qualifications 7.
Maintenance of welding inspection personnel qualifications 8.
Renewal of welding inspection personnel qualifications 9.
Use of appropriate welding procedures 10.
Use of appropriate inspection procedures 11.
Use of appropriately trained and qualified personnel 12.
Use and control of welding filler materials 13.
In-process control of welding 14.
Documentation of the above activities i
15.
Nonconformances and corrective actions 16.
Training programs adequacy 17.
Additional areas of concern as determined by a review of employee concerns.
The audit revealed one audit finding and four observations, none of which in-dicated a need for weld reinspections. The audit report also had no findings or observations relating to any employee concerns.
An observation of the auditors was that many TVA documents were confusing, overlapping, repetitive and unclear.
The Bechtel audit team also had this general observation:
It is significant to the audit team that procedures were in place beginning in 1972 to provide the craf t supervisors with quality assurance documents (procedures). The audit verified that by procedure, craft supervisors signed and returned a transmittal letter to indicate receipt of procedures and that an effective quality program was in place and complied with.
From the nature of the concerns analyzed, it appears that there was a lack of understanding by the craft personnel of how the Sequoyah Quality Assurance System functioned, and this lack of understanding j
is the initiator of many of the employee concerns.
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This audit found no discrepancies which would indicate the need for weld reinspections. It must be remembered that this audit occurred after TVA has updated some of their records as part of the Enployee Concern Program.
Additionally, the reinspection of a sample of. welds at the Sequoyah Units to a less conservative inspection criteria (NGIG-01) did show a significant enough amount of rejectable structural attributes to assume that the original construction left something to be desired in meeting original code specifications.
5.0 HARDWARE INSPECTIONS (TVA AND NRC)
With the concurrence of the NRC staff, the utility had committed to do a rein-spection on both Class 3 piping welds and structural members. Additionally, the NRC NDE van inspection of many welds during a February 18-28, 1986, visit to the Sequoyah Units, and the combined NRC and BKL Welding Team has done a
" cradle to grave" audit at SQN Units 1 and 2.
5.1 TVA Reinspection The TVA reinspection program sample consisted of 333 Class 3 piping welds in 7 systems (4604 linear inches) and 15 welds in spiral weld duct, as well as 403 l
Joints for 50 structures, totaling 7,369 linear inches of structural welds.
I All of these welds were examined visually.
In addition to the above, 304 piping welds were examined by either NT or PT (f rom the 333 pipe welds total).
5.1.1 Results of the Reinspection Of the 304 piping welds receiving MT or PT, 296 were accepted on the first 1
inspection (97.4%). All of the eight initially rejected welds were finally i
i accepted as follows:
1.
One accepted to ASME III after cleaning 2.
Two accepted to ASME XI i
i 3.
Three welds accepted to ASME III after filing or grinding + Re-NDE i
4.
Two welds accepted to ASME XI after filing or grinding + Re-NDE No weld repair by rewelding was required on any of the eight welds.
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The 33 piping weld sample (304 of which had the MT or PT done) was visually i
inspected for 14 attributes. The inspection disclosed 184 rejectable welds out of the original 333 population (55.3%). The attributes inspected were:
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Attribute Rejected Welds Contour / Transition 16 Offset / Alignment 2
Undercut 2
Reinforcement 7
Weld Spatter / Arc Strike 104 Weld Location 0
Weld Size 13 Weld Metal / Base Metal 0
Weld Convexity 0
Incomplete Fusion 5
Weld Overlap 8
Underfilled 12 Surface Porosity 15 Surface Slag 0
184 All of the visually reinspected and rejected piping welds were eventually accepted to code requirments either by initial evaluation of engineering or after surface conditioning and reinspection. No cracks were reported on any inspections.
The fifteen spiral duct welds were all accepted on initial reinspection.
The structural welds were examined for 7 attributes and had 1,194 inches rejected out of 7,369 inches inspected (16.2%). These rejects break down as follows:
Size 765 Incomplete Fusion 18 Overlap 3
Craters 7
i Profile 370 Undercut 31 Correct Filler Metal Type 0
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Additionally, nine weld joints were identified during the reinspection as having missing welds.
In all cases (rejected welds / missing welds), the evaluation by TVA Office of Engineering accepted the welds "as is."
l As a result of the TVA Reinspection, the utility concluded:
THE RESULTS OF THE REINSPECTION AND ENGINEERING EVALUATION OF THE REPORTABLE IMPERFECTIONS CONFIRM THAT THE REINSPECTED WELD JOIhTS MEET DESIGN REQUIREMENTS, AND ADDITIONAL REINSPECTIONS ARE NOT REQUIRED.
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5.2 NRC NDE Van Inspection During February 18-28, 1986, the NRC NDE Van conducted an independent measurement inspection at the Sequoyah Units. Four USNRC representatives o
expanded 308 on-site and 24 off-site hours on the inspection. The scope of the inspection included:
27 pipe weldsents - Dye penetrant inspection 13 pipe weldments - Magnetic particle inspected 361 structural weldments and 9 structures (several welds each) were visually examined to NCIG-01 with paint intact 46 piping weldments usually inspected to ANSI B31.7 with paint removed The report stated that:
"There were several instances during this inspection where the NRC results differed from the licensee.
In some instances, welds were rejected by the licensee but accepted by the NRC inspector; these differences were attributed to very conservative calls made by the licensee and to limitations present when inspecting welds which are painted. Conversely, some welds were accepted by the. licensee but rejected by the NRC inspector. The inspector concluded, however, that the differences identified were not indicative of inadequate licensee programs and the NRC findings were representative of the types found by the lincensee."
5.3 Combined NRC and BNL Welding Team Audit A combined NRC and BNL Welding Team audit was conducted at the Sequoyah site during June 2-6, June 16-20 and July 7-11, 1986. There were eight auditors performing various " cradle to grave" hardware and paperwork investigations at the site.
This audit had as its main objectives:
1.
verification of the effectiveness of the TVA program to review, address, and close out NRC inspection program issues, 2.
verification of the effectiveness of the TVA program to investigate and close out employee concerns, and 3.
confirmation that the reinspection program carried out by TVA was performed in accordance with their commitments.
This audit encompassed 30 pipe welds, 502 pipe support welds, 31 instrument tubing welds, 120 instrument support welds, 130 structural welds (electrical),
280 HVAC support welds, 100 structural welds and associated paperwork.
o There were some irregularities found during the audit with most of the hardware discrepancies having been previously identified as a result of the TVA reinspection effort. The report concludes that, in general, the inspected welds were found to comply with the governing codes and specifications.
6.0 DISCUSSIONS AND CONCLUSIONS During the review of the welding concern issues for Sequoyah Units 1 and 2, many items of conflicting evidence came to light. There were many disparities between the WP, NSRS, QTC reports and the results of the Bechtel report and Aptech survey. These disparities appeared to be primarily programmatic in content and could be either isolated instances of program transgressions or problems endemic to the entire welding program at the Sequoyah Units.
J In order to determine the TVA welding program effectiveness, it is.necessary to review the six categories of concerns from both a programmatic approach and then a hardware-oriented approach.
6.1 Category 1 - Welding Procedures a.
Programmatically - There were no concerns specific to this category and there is verification that procedures governing this work were in effect during construction and operations.
b.
Hardware - The materials of construction for SQN 1 and 2 were not unique and had been welded by the normal methods of metal joining (SMAW, GTAW, CMAW, etc.).
That these procedures were adequate to produce sound welds is evident from the operating history of the two units.
1 6.2 Category 2 - Welder Qualification / Testing Programmatically, this category had a significant number of concerns associated with it.
The methods of updating a welder's certifications was questioned and was the largest single area for all the concerns voiced. There is no doubt that there were instances where procedural violations probably occurred (as in the case of the eight welders who had to be retested), but what is the potential hardware effect?
If the problem of uncertified / unqualified welders welding on critical systems l
of the Sequoyah units were all pervasive, then the reinspections done by both l
the utility and the USNRC would have had a relatively high reject rate. If one reanalyzes the visual rejects on piping welds (TVA reinspection) 184/333 1
welds, it can be seen that if " welder attributable defects" are extracted, e.g., undercut, incomplete fusion, weld overlaps, underfill and surface porosity, the reject rate for poor welding becomes 42 out of 333 welds (13%).
This number may be considered high, but if one takes into account that these
" rejects" were all able to be accepted by engineering without rewelding, the amount of significance one can place in the 13% value becomes insignificant.
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l Note: Arc strikes and spatter have not been included since they may have been caused by adjacent welding operations (above or below the area of interest).
Ihe reject rate of " welder attributable defects" or the structural welds, e.g., incomplete fusion, overlaps, craters, undercut becomes 59 inches out of i
7369, or 0.8%; not excessively high at all.
Additionally, these reinspected welds (Class 3 piping and structural welds) i are the safety-related welds least inspected on the nuclear plant and would exhibit the most defects if an "all pervasive" welder qualification problem were in existence.
The apparent good quality of the welds covered under ASME Section XI deter-i mined in the Aptech report also lends credence to the supposition that these i
concerns on welder certification are most probably isolated occurrences at SQN.
6.3 Category 3 - Welding Inspection i
Many of the same arguments used in ttt previous category can apply to the i
inspection of welds and the qualification of personnel performing same. The Bechtel audit verified that inspection procedures and training procedures were in effect at SQN, which programmatically should satisfy the welding program requirements.
It can be successfully argued that there may have been an overall sloppiness in initial inspections done by TVA personnel, especially when one looks at the amount of rejectable welds for size and profile on both the piping and struc-tural welds. Both of these items are inspection / inspector intensive.
This overall " sloppiness" in inspection (during construction) was emphasized by the TVA reinspection. This reinspection was performed using the less 4
conservative standard NC1G-01 in lieu of the original construction standard i
AWS DI.l.
The initially high reject rates recorded on this reinspection are a clear indication that TVA had not performed their original inspections to the 1
original acceptance code (AWS D1.1).
Even though there was a reasonably large number of rejects, none were signif-icant enough to warrant repair by welding and were all accepted by engineer-ing. One must also take into account that on a well publicized reinspection, i
many " defects" may come to' light that would normally be considered nonrelevant during a regular inspection.
l 6.4 Category 4 - Welding Design and Configuration l
This category contained only seven concerns, five of which related to the same l
box hanger design. Although some information is still outstanding from TVA on the design issue, none of the requested information would indicate an exten-i sive problem. The other two concerns f rom this category were found to be unsubstantiated by the utility and at best wculd only indicate a limited instance of programmatic breakdown.
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i 6.5 Category 5 - Filler Metal Control j
The question of no portable rod ovens at SQN was the single largest item of concern. Return of weld rod at the end of the shift would also be allied with 4
j this concern. The Bechtel audit verified that procedures were in effect to i
control the issuance and use of filler material, so programmatically a system was in effect.
l l
Before one can analyze the extent of the problem, the question must be asked; "Why do we want to use portable ovens in the field, and what is the potential effect if we don't?"
i The primary reason for use of weld rod ovens is to prevent moisture pickup on j
the weld rod, which could cause hydrogen delayed cracking. Notoriously, this i
type of cracking will make itself known visually from a few minutes to a few days after the weld is made. The results of the reinspection and PSI /ISI pro-i grams showed no evidence of cracked welds being found, so this is probably not j
a problem at SQN.
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6.6 Category 6 - Miscellaneous /One of a Kind i
i Of the nine concerns in this category, only four were directly related to
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welding. Two of these dealt with control adjustments on welding machines which, if substantiated, would have caused defects that would have been ob-served on.the reinspection program. They were not.
The other two concerns j
were of a programmatic and not a hardware-specific nature.
A response (Attachment 10) to the first set of questions sent to TVA from the NRC was received August 1, 1986. The responses from the utility confirm the fact that there were programs, procedures or inspection plans in effect which outlined the necessary steps to provide a " sound weld" as an end product to i
construction. This does not mean that programmatic transgressions did not occur, but that a system was in effect to localize these transgressions and j
prevent system-wide quality problems.
The supposition that the SQN units did not suffer from "all pervasive" qual-i ity/ welding problems is substantiated by the utility's reinspection program
)
which revealed i
}k piping welds (Attachment 10) rejected by Code t
No structural weld joints which did not meet design requirements 1
l Since there has been presented evidence that some programmatic breakdowns probably occurred, it appears that an evaluation of the units' " suitability
{
for service" must rely essentially on the large number of hardware reinspections that have been performed to date. This being the case, the following conclusions can be drawn:
1.
There is evidence that many of the confusing / misleading TVA proce-dures may have led to programmatic errors in the SQN welding pro-l gram. The expert welding team questions on these have been trans-j mitted to the NRC for forwarding to the utility.
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2.
The reinspection of various welds by the utility and NDE Van have not discovered defects of any great detriment or magnitude.
3.
Since the combined NRC and BKL Welding Team audit did not show additional problem areas or concerns; if and the questions addressed to TVA are answered to the satisfaction of the USNRC, then there is no evidence to assume that the welds at the Sequoyah Units are not
" suitable for service."
These conclusions are those of the BNL members of the welding, team.
These conclusions have been drawn after discussions with the other members of the team, TVA meetings and site inspections and audits.
Each of the other members of the team have been requested to submit their own summaries of their opinions regarding the TVA Employee Concern Program. These are part of this TER (Attachments 11-15).
I t
REFERENCES 1.
Tennessee Valley Authority, " Welding Project Review Plan," Volume 1.
2.
Proceedings, "NSRS Public Meeting on TVA Welding Issues," January 7, 1986, Bethesda, MD.
3.
Memorandum, B.D. Liaw to B. J. Youngblood, dated March 3, 1986.
4.
Visual Weld Acceptable Criteria for Structural Welding at Nuclear Power Plants, NGIC-01, Rev.2, 5/7/85.
5.
Tennessee Valley Authority Welding Project Sequoyah Nuclear Plant Phase 1 and 2 Review and Program Results.
6.
Memorandum, H. Denton, J. Taylor and J. Nelson Grace to W. J. Dircks dated 12/5/85.
Subject:
NRC Plan for Dealing with Welding Issues at TVA Watts Bar Site.
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. LIST OF ATTACHMENTS ATTACHMENT I Professional Qualifications of Carl J. Czajkowski ATTACHMENT 2 Biographical Sketch of William D. Doty ATTACHMENT 3 Biographical Sketch of Carl E. Hartbower ATTACHMENT 4 Biographical Sketch of Paul E. Masters ATTACHMENT 5 Biographical Sketch of William H. Munse ATTACHMENT 6 Biographical St. etch of Robert D. Stout ATTACHMENT 7 Resume of Milford H. Schuster ATTACHMENT 8 Trip Report to SQN (3/18/86)
ATTACHMENT 9 Trip Report to SQN (4/25/86)
ATTACHMENT 10 TVA Letter Response to NRC Questions (8/1/86)
ATTACHMENT 11 Summary of R.D. Stout ATTACHMEMT 12 Summary of P.E. Masters ATTACHMENT 13 Summary of W.H. Munse ATTACHMENT 14 Summary of C.E. Hartbower ATTACHMENT 15 Summary of W.D. Doty (not yet available)
e PROFESSIONAL QUALIFICATIONS of CARL J. CZAJKOWSKI I am currently a Research Engineer at Brookhaven National Laboratory (BNL),
where I have been employed since 1980. I am in t,he Materials Technology Division of the Department of Nuclear Energy. My current duties are providing technical assistance (both field and laboratory) to the United States Nuclear Regulatory Commission (USNRC) in the areas of metallurgy and failure analysis related to nuclear power plants. Failure analyses performed on both radio-active and non-radioactive components in my current position have included the following material systems: austenitic stainless steels, ferritic and marten-sitic low alloy steels, inconel, aluminum and martensitic stainless steel. I have performed vendor audits for the Inspection and Enforcement Division of the NRC in the capacity of Technical Specialist in the aforementioned areas of expertise. I have performed a third party investigation of allegations pertaining to potential welding and quality control improprieties at a nuclear construction site. Additionally, I have testified as the NRC Technical Specialist for welding at hearings for a second nuclear plant.
Prior to my employment at BNL, I was employed for five years by the Long Island Lighting Company (LILCO). My job title from September 1977 to February 1980 was Chief Welding Supervisor at the Shoreham Nuclear Power Station. My duties in this position included supervisory responsibility for all velding problems or major welding efforts for the utility, as well as ordering and maintenance of equipment / gases / electrodes to support a 400 welder work force at the site. Additional responsibilities included conducting training sessions for supervisory and manual personnel on industry codes, standards and welding inspection, as well as administering the weld test booth for qualifi-cation testing. Subsequent to my promotion to Chief Welding Supervisor, I was employed by LILCO as a Quality Assurance Engineer (both home office and Shorehan site). This position was held by me from February 1975 to September 1977. The duties of this position encompassed preparation and review of LILCO's QA manual and procedures, reviewing A/E and NSSS quality programs, evaluating and surveying vendor activities, and performing field audits and surveillance of mechanical contractors' (Shorehan site) welding and nonde-structive testing practices.
I also held the job title Quality Assurance Engineer while employed by Ebasco Services, Inc. from September 1973 to February 1975. This position's duties included review of procurement specifications and dravicgs for inclusion of quality requirements, preparation of quality plans for surveillance of safety-related component fabrication in vendors' shops, conducting interdepartmental audits of engineering and design disciplines, in addition to QA evaluation of vendors, including review of documented quality programs and source evalua-tion.
=_
Professional Qualifications of Carl J. Czajkowski Page Two Prior to my employment at Ebasco Services, I held the job title QC Materials Engineer for United Nuclear Corporation from April 1972 to August 1973. This position's responsibilities included review of material purchase orders for compliance with contract requirements monitoring of the test-overcheck program for ferrous and non-ferrous material, establishing materials receiving inspec-tions instructions and audit participation, as needed.
My academic qualifications include a B.S. in Metallurgical Engineering from the University of Missouri at Rolla in 1971, and an M.S. in Metallurgical Engineering from the Polytechnic Institute of New York in 1982. I am a member i
of the American Society for Metals and the American Welding Society. I am the author or co-author of approximately fifteen publications in the area of failure analysis on reactor components.
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l BIOGRAPHICAL SKETCH of WILLIAM D. DOTY W. D. Doty received his B. Met. E., M. Met.
E., and Ph.D. (Metallurgy) degrees from Rensselaer Polytechnic Institute, where he also served as a Research Fellow. His graduate research was recognized through a national award from the American Welding Society.
Dr. Doty joined the United States Steel Corpor-ation in 1947, and served in various research and supervisory positions at their Technical Center; from 1958 to 1966 as Chief of the Bar, Plate and Forged Products Division; from 1966 to 1973 as Research Consultant, Steel Products Development; from 1973 to 1983 as Senior Research Consultant, Product Engineering; and from 1983 to 1985 as Senior Metallurgical and Product Consultant.
Dr. Doty is widely known for his research and publications in welding and steel product development, and is co-author of an authoritative book on the "Weldability of Steels." In 1966, he received the Spraragen Award of the American Welding Society; in 1973 he was elected a Fellow by the American i
Society for Metals; in 1975 he was elected an Honorary Member by the American Welding Society; and in 1984 he was elected a Fellow by the American Society of Mechanical Engineers and was that Society's recipient of the J. Hall Taylor Medal. His technical committee activities have been many and varied. He is a member of the Main Committee of the ASME Boiler and Pressure Vessel Committee, and from 1967 to 1973 he served as Chairman of the Pressure Vessel Research Committee, and is currently a member of the PVRC Executive Committee. He is a member of ASM, AWS, British Welding Institute, AIME, ASME and Sigma Xi, and is a Registered Professional Engineer it the State of Pennsylvania.
4 BIOGRAPHICAL SKETCH of CARL E. HARTBOWER Mr. Carl E. Hartbower, retired from the Federal Service, will be available as a consultant starting in June 1982. Having served the Bridge Division of the Federal Highway Administration as their Principal Welding Engineer for almost nine years, he has been in a unique position to observe the welding-related problems that exist in the Interstate Bridge System.
Mr. Hartbower is a Registered Professional Engineer in Massachusetts (mechan-ical engineering) and in California (metallurgical engineering).
Fellow of the American Society for Metals (1979) "in recognition of contributions to the metallurgy and engineering of large-scale welded structures, to the use of fracture mechanics in modern bridge design and fabrication, and to the advance of nondestructive testing techniques and inspection."
FHWA Administrators Award in 1979 "in recognition of his outstanding contribution in fostering the Fracture Control Plan and for leadership in the safety problems attendant to the fabrication of major bridges."
Fellow of the Welding Institute (British).
Life member of the American Welding Society.
Member of the American Society for Testing and Materials; Chairman of Task Group E24.03.03 (precrack Charpy test methods).
Pioneering research (1) in development of the Navy's explosion bulge test (1940s), (2) on the welding of titanium alloys (1950s), (3) in development of the precrack Charpy test (1950s), and (4) on acoustic emission (1960s).
Navy Civil Engineer Corps Awards (1951 and 1952) for research papers on the explosion bulge test.
Spraragen Award for the best research paper published by the American Welding Society in 1968 (paper on acoustic emission); Mr. Hartbower's research on acoustic emission published by NATO in AGARDograph 176 (January 1974) and in AGARDograph 201 (Ocober 1975).
Exchange Scientist - in April 1961 the U.S. was visited by Professor N. N. Rykalin of the Baykov Institute, Academician B. Ye. Paton of the Paton Institute, and Professor N. O. Okerblom of the Leningrad Polytech-nic Institute. In exchange, the National Academy of Sciences selected Mr. Hartbower as one of three welding authorities to visit industrial and educational centers in the Soviet Union (see WELDING ENGINEER, p64 July 1962 and WELDING RESEARCH ABROAD, Vol. VIII, No. 2, Feb.1962).
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Biographical Sketch of Carl E. Hartbower Page Two In 1971, Mr. Hartbower revisited the USSR by personal invitation from the Soviety Academy of Sciences.
Commander, Navy Civil Engineer Corps, USNR, RETIRED. Life Member of the Naval Reserve Association and Member of the Naval Institute.
Elder in the Presbyterian Church.
Mr. Hartbower has BS (1943) and ME (1958) degrees from Worcester Polytechnic Institutq; was previously employed by the Naval Gun Factory (Welding Engineer, 1943-45), Naval Research Laboratory (Physical Metallurgist, 1945-52), Water-town Arsenal Laboratories (Chief of Metals Joining Branch (1952-61), and Aerojet General Corp. (Associate Scientist (1962-73). He has published over 50 papers.
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BIOGRAPHICAL SKETCH of i
WILLIAM H. MUNSE W. H. Munse is a Professor Emeritus of Civil Engineering at the University of Illinois, Urbana, Illinois, where he received a B.S. degree in Civil Engineer-ing in 1942. While an undergraduate student, he served as an Engineer for the city of Champaign, Illinois, and as a student assistant in Civil Engineering.
After spending nine months as a structural draftsman at the American Bridge Company, he returned to the University of Illinois in 1943 as an instructor and research assistant and received an M.S. degree in Civil Engineering the following year. Upon completion of a tour of duty as an officer in the U.S.
Navy, he served as a Research Engineer at Lehigh University for one year and then returned to the University of Illinois, where he has been on the profes-sional staff since 1947.
Professor Munse's area of specialization has been the basic engineering be-havior of metals and metal structures. He has made numerous contributions through his research on the static, fatigue, and brittle behavior of riveted, bolted and welded construction, and in the engineering application of the results of this research into the classroom, and in the translation of the research results into materials and designs specifications. This latter achievement has been made possible through his membership on the design spec-ification committees of the American Institute of Steel Construction, the American Welding Society, the Research Council on Riveted and Bolted Strue-tural Joints, and the American Railway Engineering Asociation, and on materi-als committees of the American Society for Testing and Materials. In addition, he has contributed to many national and international committees concerned with the behavior of metals and metal structures, serving as U.S.A.
delegate to the fatigue commission of the International Institute of Welding and the fatigue and fracture commission of the International Ship Structure Committee.
The results of Professor Munse's research have been presented in many national and international journals and reports. He is author or co-author of more than 140 publications, author of the Welding Research Council book on Fatigue of Welded Steel Structures, and author of chapters in several other books and handbooks.
In addition, Professor Munse has served as a consultant or advisor to many industrial and governmental agencies on problema involving the properties and behavior of metal stuctures. Included have been the development of design specifications for the Corps of Engineers, the evaluation of the fatigue resistance and the development of fatigue design provisions for such organiza-tions as the Chicago Bridge and Iron Company, the U.S. Steel Company, the ACF Company, the Association of American Railroads, and the U.S. Navy; and as-sisted in the evaluation of failures of bridges, railroad cars, buildings, a water tank, and an off-shore drilling rig. He has served also in an advisory consulting capacity to a number of other industrial and governmental organiza-l tions on structural and materials problems.
Biograp'hical Sketch of William H. Munse Page Two Professor Munse is an Honorary Member of the American Society of Civil Engi-neers, as well as a member of a number of other technical and professional engineering societies, including ASTM, AREA, AWS and TRB. In addition, he has served on many of the technical and professional committees of these organiza-tions. Has has been awarded the ASCE's Walter L. Huber Civil Engineering Research Frize and the Adam's Memorial Membership of the American Welding Society in recognition of his research on the behavior of metals and metal structures. In 1976 he was recognized by the Japan Welding Society on their 50th Anniversary with their Distinguished Service Award.
In May 1983 the Structural Division of the American Society of Civil Engineers honored Professor Munse with a symposium on the " Behavior of Metal Structures" and, in October 1984, he was elevated to Honorary Membership by the Society.
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of ROBERT D. STOUT i
Dr. Robert D. Stout is internationally known for his work in welding and has won several awards for his accomplishments in this field. He has been on the Department of Metallurgy and Materials Engineering faculty at Lehigh Univer-sity since 1939. He was Chairman of the Department from 1956 until 1960, when he was named. Dean of the Graduate School, and served until his retirement in 1980.
A native of Reading, Pennsylvania, he came to Lehigh from Carpenter Steel Co.,
where he was a metallurgist.
In recognition of his contributions to education and engineering, Dr. Stout has received several national honors.
In 1945, he was awarded the Lincoln Gold Medal for " conspicuous advancement of the science of welding". In 1952, he was presented the Stoughton Award by the American Society for Metals (ASM) for " outstanding contributions to the teaching of metallurgical engineering",
and in 1972 he received the ASM's A. E. White Award for distinguished teaching.
In 1960, he was selected to deliver the Adams Lecture to the American Welding Society (AWS). He receiv.ed the Spraragen Award for the best research paper published in the Welding Journal in 1963; the National Meritorious Certificate of the AWS in 1965; the R. D. Thomas Award in 1973 for service to interna-tional cooperation in velding; and the Charles H. Jennings Award for an out-standing research paper in 1974.
In 1962, Dr. Stout received the R. R. and E. C. Hillman Award at Lehigh, presented annually to "the member of the Lehigh faculty who has done the most toward advancing the interests of the University".
The David Ford MacFarland Award, presented annually "in recognition of achievements in the field of metallurgy which reflect credit upon Alma Mater,"
was conferred upon him in 1959 by the Pennsylvania State University chapter of the ASM.
Since 1955, Dr. Stout has served as one of the official American representa-tives to the International Institute of Welding, participating in the commis-sion to study the behavior of metals subjected to velding. He has attended international meetings of the Institute and delivered the 1970 Houdremont Lecture to that organization. He was a member of the materials advisory board of the National Academy of Sciences from 1964 to 1968, and a member of the Pipeline Safety Standards Advisory Commitee from 1968-71.
A graduate of Pennsylvania State University in 1935, he received his M.S. in 1941 and the Ph.D. in 1944, both from Lehigh. In 1967, he received the honorary degree, Doctor of Science, from Albright College.
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r Biographical Sketch of Robert D. Stout Page Two He has authored more than 125 articles which have appeared in leading tech-nical journals, and is author of the book "Weldability of Steels" published in 1953 and revised in 1971. He has served as a metallurgical consultant to over 50 companies.
Dr. Stout was National President of the AWS in 1972-73. He has served as chairman of several committees of that organization. He also has been Chair-man of the University Research Committee of the Welding Research Council. He is a member of the Society of Sigma Xi, national research honorary society, and Tau Beta Pi, national engineering honorary society, and is a Fellow of the ASM.
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e RESUME NAME:
Milford H. Schuster TITLE: Research Engineer FIELD OF EXPERTISE: Welding, metallurgy, nuclear power plant construction, nondestructive testing, failure analysis EDUCATION:
Specialized training in welding, welding metallurgy, physical metallurgy, reactor materials, ASME Sections I, II, III, V, VIII, IX and XI, electron beam welding, personnel management, engineering assurance, IMSI, C.E. BWR Training Program, ASNT-TC-1A, Level II MT, PT, UT, radiography, ANSI B31.1, pipe welding, quality control, quality assurance, machining.
EXPERIENCE:
1986-Pres.
Brookhaven National Laboratory (Materials Technology Division),
Technical Consultant to USNRC-NRR and I&E Divisions, Failure Analysis.
1980-1986 Long Island Lighting Co. - Welding / Materials Specialist Consultant, Chief Welding Supervisor, Shoreham Nuclear Power Station.
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1979-1980 EBASCO Services Corporation - Welding Specialist, Commission DE Federal, DE Elecricidad, Laguna Verde Nuclear Power Station, Mexico.
1978-1979 Daniel International Corporation - Project Welding Superin-tendent, Enrico Fermi Nuclear Power Station.
1976-1978 Courter and Company - Piping Supervisor, Welding Supervisor, Shoreham Nuclear Power Station.
1971-1976 Self employed - Welding consultant, Brookhaven National Labor-atory; Partner auto parts business.
1956-1971 Brookhaven National Laboratory - Materials and Welding Technical Specialist.
1952-1956 USAF - Aircraft Fabricators Inc., Metals Processing Specialist, Welding instructor.
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