ML20215N437
| ML20215N437 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/25/1986 |
| From: | Czajkowski C, Schuster M BROOKHAVEN NATIONAL LABORATORY |
| To: | Liaw B NRC |
| Shared Package | |
| ML20214D842 | List: |
| References | |
| CON-FIN-A-3839 NUDOCS 8611050405 | |
| Download: ML20215N437 (6) | |
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- - liRoul'1(AVI N NAllONAl. I AliORAR >kY ASSOCIA1ED UNIVERSITilS. INC.
Up!on. long IMond. New York 11973 (516)282-Deportrncnt of Nac\c>at EnotgY F15 bbb'3349
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' April 25, 1986 Dr. B.D. Liav Engineering Branch Mail Stop P-ll32 U.S. Nuclear Regulatory Co==ission Washington, DC 20555
Subject:
Trip Report, Sequoyah Nuclear Power Plant, FIN A-3339, TVA Welding ,
l Concerns
Dear Dr. Liaw:
The SQN Expert Velding Consultant Team met with TVA and NRC personnel during the period of April 14 - 16, 1986, at the Sequoyah Nuclear Power Plant. The objectives of.this visit were:
- 1. In plant hands-on evaluation of support and piping welds previously
- inspected by 7VA, Bechtel and the NRC Inspection Van personnel.
- 2. Review as applicable velding concerns with TVA management, welding engineers, construction personnel, quality assurance representatives and inspection personnel.
- 3. Provide preliminary BNL Expert Welding Team input and recomunendations regarding SQN/TVA action plan and inspection activities to date.
SQN Ixpert Welding Team participants were Messrs. C.J. Czajkowski, M.H.
Schuster, W.D. Doty and C.E. Hartbower.
Coordination and NRC coverage was provided by D.E. Smith, Engineering Branch, DPL-1, Bethesda, MD.
The following trip activities are discussed in this trip report:
A. Entrance smeeting B. Tield evaluation of support and piping velds C. Interview of TVA personnel D. Exit ceeting E. Sur: ary conclusion n y. .n ~ c T M /l0564o5 ya .
Apr $ ) s l', 19H6 i
A. Entrance Hecting The entranec meeting was convened at approximately 10 a.m. The meet.
was attended monts #1.) by TVA personnel, NRC, and the Welding Team consultants (Att:
D. Smith, USNRC, Engineering Branch, Bethesda, MD., and C.J.Czajkowsh provided an overview of the Welding Team objectives and purpose for the si visit (as described in introduction).
L. Martin, TVA discusse Bar employee concern, program.d the status and current schedule of the Watt welding concern program at SQNHe also2 stated 1 and is not athat at this time the ecploys critical path item and tha;
. the final NRC in a report is in its short period final draf t condition and will be submitted to I of time.
April 15,1986 B.
Field Evaluation of Support /Pinine Welds In order to provide a more objective evaluation of SQN employee concer reinspection plan, and the SQN corrective actions and final report, the Weli ing Team was provided a tour of units 1 and II with access to reinspection TVA and the USNRC NDE Van personnel. sample lot structural com Personnel who participated in the tout were D. Smith, USNRC; Welding Team members, Hessrs. C.J. Czajkowski , M.H.
. Schuster, W.D. and S.P. Stangnolla Doty, C.E.
C.W. Hartbower; and TVA members, R.M. Jesse, J.H. Fox Hartmaker. ,
Weld and component identification was provided by TVA personnel. Pipin identification or "as-built" condition. isometrics and design documen piping Welding welds. Team members examined approximately 33 structural supports and figuration. Structural support velds were predominantly of fillet veld cor butt welds. Piping welds were Butt and fillet socket with emphasis on
' inspection reports will be accomplished. Weld anomalies were noted and c j
in possession of the TVA inspection reports.To date, the Welding Team is not l April 15,1986 C.
Interview of TVA Personnel welds,Upon completion of the field evaluation of piping and structural support the Welding (A tta chment II).
Team and USNRC representatives met with TVA personnel The purpose of this meeting was to give Welding Team members
, , p. * * *
- an opportunity tn discons and review previously identified welding concerns with welding engineering, quality control, quality assurance, and TVA manage-ment. Specifics such as inspection personnel experience, training requirc-ments, work assignments, wcld rod issue, weld rod control, wcIdcr testing ASME Section IX/AWS DI .1, maintenance of welder qualifications, welder tracking requirements were discussed at length with TVA personnel.
Weld inspection requirements such as pre-weld, in process and post-weld inspection, frequency of these inspections, verification of welder qualifica-
'tions during these inspections, inspection tools, receipt inspection require-cents, welding procedures, inspection procedures, weld documentation require-ments (traveler), manpower requirements, weld repair requirements both docu-mentation and in process were also verified by discussion with the TVA attendees. Methodology utilized for TVA saeple lot inspections and selection of welds and structural cocponents was provided by TVA personnel., It should be noted that TVA participants at this meeting were cooperative and forthright in their responses to the Welding Team cembers.
April 15,1986 D. Exit Meeting The Exit critique of the visit was convened at approxicatly 1600 hours0.0185 days <br />0.444 hours <br />0.00265 weeks <br />6.088e-4 months <br /> (Attachment III). D. Smith, USNRC, Materials Engineering, acted as the group spokesman.
The Welding Team requested:
- 1. Purchase order requirements, design specification and materials certifications fo'r steam generator structural supports.' Review of charpy V notch requirements will be performed upon receipt of the requested documents. .
- 2. List of all employee concerns related to SQN. The Welding Tema requests that these be provided on an ongoing basis until completion of this assignment.
- 5. SQN corrective actions resolution and rework schedule.
- 7. The Welding Team observed three structural supports with unwelded sections.
- 8. Provide independent reports / conclusions which have been or may be initiated in response to reinspection results.
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. i conclur. inns In r,eneral, Welding Tenm members did not express specific concern as a result of this SQN visit. There was some discussion regaiding NDE require-ments for ASME Section III, Code class III piping weld. The differences between other industry standards and Nuclear NDE/ inspection requirements was discussed at length.
If there are any questions, please contact the undersigned.
NN AM [oh Carl C A-o neski Milf'Mrd H. Schuster HHS:CJC/ad Attachments cc: Welding Team P. Cortland W. Kato W. Long D. Smith J. Weeks 4
. 4
. o (4/25/86 M:mo Attschment 1)
Attendance Roster Entrance Meeting 4/15/86 NAME AFFILIATION Robert Birchell SNP Compliance Glenn Kirk SQN W.D. Doty Consultant - Brookhaven National Laboratory C.E. Hartbower Consultant - Brookhaven National Laboratory D.E. Smith NRC/NRR/PWR-A Carl Czajkowski Brookhaven National Laboratory Milford Schuster Brookhaven National Laboratory John Fox DNE L.E. Martin DNP S. P. Stagnolia Nuclear Construction R.M. Jessee Nuclear Engineering Carl Hartmaker DNE Roger Field, Jr. SQN L.M. Nobles SQN David Humble Mech. Maint.
Richard Butler SQN-QA Robert W. Olson SQN Larry Alexander SQN 9
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(4/25/86 Memo Attachment 2)
Attendance Roster Interview Meeting 4/15/86 NAME AFFILIATION M.H. Schuster Brookhaven National Laboratory John H. Fox TVA Lawrence Warner TVA-ISI Dennis Allen TVA-ISI Brett McCreary TVA-QA Carl Czajkowski Brookhaven National Laboratory David E. Smith NRC Carl W. Hartmaker TVA-DNE S Stagnolia TVA-0C-WTC Roger Field, Jr. TVA-0E Robert M. Jessee TVA-DNE W.D. Doty Consultant - Brookhaven National Laboratory C.E. Hartbower Consultant - Brookhaven National Laboratory e
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, Attachment 10 TENNESSEE VALLEY AUTHORITY CH ATT A NOOG A TENNESSEE 37401 55 1573 Lookout Place AUG 01 B86 Director of Nuclear Reactor Regulation Attention: Mr. B. J.!Youndblood, Project Director PWR Project Directorate No. 4 Division of Pressurized Water Reactor (PWR)
Licensing A U.S. Nuclear Regulatory Cosumission Washington, D.C. 20555
Dear Mr. Youngblood:
In the Batter of the ) Docket Mos. 50-327 '
Tennessee Valley Authority ) 50-328 Please refer to your letter to 3. A. White dated June 10, 1986 which requestec additional infometion on the Sequoyah Buclear Plant Phase II Welding Project Beyorts. Enclosed is the response to your request.
If there are any questions, please get in touch with R. H. Shell at FTS 854-2668. -
Very truly yours, !
TENNESSEE VALLEY AUTHORITY 4,_
Al R. Cridley, D1 tor Buclear Safety Licensing l ancleennra l ec: U.s. auclear Regulatory Commission (anelosure) mesten II attention: Dr. J. Selson Crace, Regional Administrator 101 marketta street, uW, Buite 2900 Atlanta, Geor51a 30323 1
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, . ENCLOSURE SEQUOYAH NUCLEAR PLANT NELDING PROJECT REPORTS
- 1. In 2.0 APTECH ENGINEERING REPORT (Supplemental Information), Page 3, 8th line, it is stated that "In the case of the feedwater lug, no engineering evaluation was requested by the plant." Why was installing the alssing welds to drawing requirements chosen as the means of resolving 1 missing weld problem rather than performing an engineering evaluation as had been done with a very stellar problem? Demonstrate that code requirements were met without installing the alssing welds.
Response: leien alssing welds are identified during inspections, it is usually much easier to add the welds as required by the drawing (provided there is sufficient access) than to request engineering disposition to leave "as is." This was the case for feedwater lug FDH-203. However, when sufficient access does not permit welding,' engineering disposition and
". subsequent drawing changes are initiated. Yhis was the case for the Safety Injection Systes stanchion-to-pipe weld, '
1-SIN-17.
l In the case of 1-SIN-17, engineering gave preliminary approval to leave "as is" since cursory calculations showed that the actual weld provided was adequate for design loads.
Therehre, addition of the weld was not required.
Engletering will provi'de final calculations to demonstrate structural adequacy of the subject tupport when the drawing i is revised and reissued.
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- 2. The tera " separated weld" is used in 2.0 APTECM ENGINEERING REPORT '
(Supplemental Information), Page 3,12th line. Define the basis l for your assessment of this weld failure as being due to operating i transients and not having been due to poor veld quality or cracking l durlag fabrication.
Response: Slace no cracked welds have been found during the e reinspections, there is no reason to question tM quality of the construction welds. Conversely, there is not a readily identifiable basis for attributing the occurence to an operating transient. TVA deterstned this to be an isolated case since no other cracked welds or damaged supports were found in the same area and the cause is ladeterminate.
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- 3. In the APTECM ENGINEERING REPORT, the Table titled. "Not DESCRIPTIONS
- SEQUDYAN ILJCLEAR PLANT UN!T I". N0! Number $Q0201, under 01sposItIon and Additional Comments it is stated: ". . . clean weld area per SON-17, palat and re-enastne." Englain how code requirements were met with the esamination following painting.
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Ii. & E' Response: The note under NOI SQ0201 in the APTECH ENGINEERING REPORT is an editorial error. The Maintenance ins;ruction required that the subject weld be added, ceeaned, visual
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and PT examined, then painted. The inspection report shows that the weld passed final examination (visual and PT) on 12/9/85 and has not yet been painted.
- 4. In the APTECH ENGINEERING REPORT. Table 4-1 Ilsts 5 Licensing Event Reports concerned with welds. Provide the number of LERs evaluated in this search. Mere any failure analyses conducted of the welds covered by these LERs? If so, please provide them.
Response: There were 840 LERs evaluated in the search. A metallurgical failure analysis was done in conjunction with LER 80156. The failure analysis involved a vendor weld (seal water injection line to reactor coolant pump weld)..
- 5. Here there ever other than E7018 carbon / low alloy steel shleided metal !
, arc welding electrodes on the Sequoyah site, such as E8018C3?
Demonstrate that incorrect electrodes were not used on any weldsent.
1
Response
i A. Construction Phase
- Yes, small quantitles of E6010. E11018X and various other types of specialty maintenance electrodes were kept on site. These materials and their use were strictly controlled. Their uses were llalted to such things as construction plant (temporary construction facility) malatenance and construction; maintenance of construction equipment; hard facing of construction equipment cutting edges; crane boom repair; build up for hard facing of worn construction equipment; and the fabrication of construction jigs and fixtures.
In addition to the previously described maintenance materials, small quantitles of t.4018C3 and E7010Al materials were used on appropriate permanent plant features. The use of these materials was also strictly controlled in accordance with the construction Quality Assurance / Quality Control Program.
- Checks and balances were reflected in construction procedures to i
lasere the proper procurement, storage, and application of welding materials used for permanent plant construction. These included the -
recording and verification by QC Inspectors of filler materials by type of safety related pipewelds and a QC survelliance to spot check proper filler material application on all safety related welding. In addition 04 reviews of safety related pipeweld records included electrode type as a check point.
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, 8. Operation Phase Yes, like construction, small quantitles of various types of other electrodes are maintained for specialty welding and specialized maintenance appilcations. These include carbon steel coated electrodes other than E7018 which have not been used on safety related plant features. .These appilcations include maintenance of shop and shop equipment, fabrication of temporary jigs and fixtures, and noncritical maintenance of non-safety related balance of plant items.
These materials and their appitcations are strictly controlled in accordance with approved plant procedures.
Maintenance and modification procedures provide for the QC verification of proper filler material use for safety related applications. This verification provides indirect traceability to
-- heat / lot numbers. In addition, a QA surveillance program provides .
additional spot checking of proper electrode usage.
- 6. For the 8echtel Audit, what were'the total number of welders and laspectors in the populations from which the audit samples were taken?
Provide separate totals for the Office of Construction and Nuclear Operations.
8esponse: populations from which the 8echtel Audit Team selected are as follows:
Oreantration Walders Inspectors Construction approx. 3100 approx. ISO Nuclear Operations approx. 205 appron. 120
- 7. The TVA Aetaspections checked the relative magnettsa for all welds, austeettic and ferritic. leut was the procedure for this inspection method? Provide justification for different levels of magnettsa and their acceptance criteria, particularly " weakly magnetic".
i Response: The magnetic check for generic filler metal type (i.e.,
ferritic or austenttic) was performed by touching a small peranaeat magnet to the weId deaos!t afd noting hts judgement as to whether the deposit was strongly, weakly, or non-engnetic. The laspector also noted whether the base materials being joined were stainless or carbon steel.
Evaluation of correctness of filler metal was done by OE according to the following guidelines:
- 1. The correct weld metal for welds joining stainless steel to stataloss steel should be weakly magnetic or non-magnetic.
- 2. The correct veld metal for welds joining stainless steel to carbon steel should be weakly magnetic or non-magnetic.
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- 3. The correct weld metal for welds joining carbon steel to carbon steel should be strongly magnetlc.
The above guidelines are as contained in P.S.3.C.11.1 (RI).
The " weakly magnetic" category as a permissible condition for items 1 and 2 above reflects that the correct stainless steel weld metal used in these welds should appear non-angnetic or weakly magnetic depending on delta ferrite content and/or degree of base metal dilution.
4.
Cracks were not listed as one of the attributes in the tables of TVA Retnspection Report. Mere any cracks found during the TVA j
Reinspection? Also, porosity was not an attribute Ilsted in the structural welds table. leiat was the rejection rate for porosity in -
the structural welds in the TVA Reinspection?
Response: Both cracks and porosity were attributes that were checked in the reinspection effort. No cracks were found during the reinspection. Rejectable porosity was not found on any structural welds.
- 9. In 4.4.1. Page 8. Ilne 21, of the five welds which were ground, were the manufacturer's alalaum wall thickness requiraments encroached upon?
If so, to what entent?
Response: Only one weld (2CCF-68) of the five which were ground to reduce surface Indications had its manufacturer's alnlaus wall thickness encroached upon. This weld is in a 4-inch schedule 40 carbon steel pipe. The measured thickness locallred ground area is 0.198". This is 0.0094" less than the manufacturer's alnlaus wall requirement of 0.2074" but is more than twice the design einlaus wall of 0.08".
-, 10. In 4.4.1, Page 10, lies 1. the rough condition of welds found durlag the relaspection is discussed. Provide Information that justiftes the statement, "The indepth lavestigation of the welder and laspector qualification revealed no indications of inadequacy of the melder or Inspector capabilities.* telat was done to demonstrate that this level of workmanship by this welder and/or judgement by this inspector were not repeated elsewhere at Sequoyah?
Response': After proper removal of palat, both welds were inspectable by the penetrant method. The inspectors' certification flies were reviewed and both inspectors in question were found to have at least two years esperience at penetrant testing when the inspections were made. The welder was lattia ly certifled in May 1975 and had welded in nuclear applications off and on since that time. TVA determined that no further lavestigation of the inspectors' or welders' work was necessary.
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- 11. In 4.4.1, Page 11, in the table titled " PIPING WEl.05", the rejection rate when expressed in terms of the percentage of welds rejected is 567.
(184/333). Even allowing for some rejected welds counted more than once because of more than one rejectable attribute, the rejection rate is very high. 4) What is the root cause of this high rejection rate of originally inspected and accepted welds? b) Is there any basis for concluding that there is a connection between the employee concerns expressing doubt about inspectors capablittles or that harassment and intimidation of inspectors occurred? c) Nith respect to question a),
address in particular the attribute underfill, which has very specific code requirements. d) The arc strike / weld spatter rejection rate was 311. What is the root cause for this high rejection rate? e) What were the original inspection criteria for these ireld attributes? f) letat were the reinspection criteria for these attributes? g) What is the justification for elimination of inspecting arc strikes for cracks in G-29C?
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Response: The reinspection rejection rate on a per weld basis to Inspection requirements is 24% (80/333). The 184 arc l strikes and weld spatter indications were reportable but not rejectable. Base metal outside the weld area was not required to be examined by the construction code. The procedure used for the reinspection required base metal indications outside the weld to be reported.
Any reinspection effort will typically have a rejection rate of 5-10 percent. However, a reinspection such as this can have a rejection rate approaching 20-25 percent because of the circumstances under which the reinspection was made.
- a. Desat is the root cause of this high rejection rate of originally inspected and accepted welds?
Response: The root cause of the high discrepancy rate involves both psychological factors and a changing inspection philosophy l
la recent years. Inspectors performing this reinspection anticipated "second-gusssing" of their judgements by others. Becausethereisjudgementinvolvedinweld laspection close calls will inevitably become rejects under such conditions. It is unrealistic to expect the results of a reinspection performed under the degree of scrutiny involved here to yleid results comparable to those performed in the 1970-40 era. This does not imply inadequate laspection during construction. It does reflect a change in weld inspection philosophy and asthodology over the past 15 years and nost parttcularly in the past 2-3 years. Thesl9ntftcantchangeinvolves
. less reliance on the inspector s eyes and judgement of the weld as a whole, and more on quantitative measurement of every attribute on every increment of weld.
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To a lesser degree, the current discrepancy rate is a $
result of changes in acceptance criteria (see "d" below).
b.
Is there any basis for concluding that there is a connection between the employee concerns expressing doubt about inspectors i capabilities or that harassment and intialdation of inspectors -
occurred?
i Response: The program was working properly and Inspectors were ,
performing properly. We have no evidence that would I support the concerns about inspector capability and inspector harassment or intimidation. ,
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- c. With respect to questico a), address in particular the attribute l t
underfill, which has very specific code requirements.
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. Response: Seven of the 11 welds rejected for underflil involve
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sockolet branch connection fittings to pipe runs. These
)t fittings are proprietary products designed to provide j Integral reinforcement of the branch opening. Because of the configuration of the fittings themselves and the ;
geometry of the connectico as a whole, the correct weld }
size and configuration is not obvious. This is :
particularly so in the cases where there is little _2 difference in the size of the run pipe and branch ]
connection.
j The remaining four instances of underftll involved welds j joining members of unequal thickness (pipe to valve or j fitting). Here the reported underfill was with respect to g the edge of the thicker member. However, the weld =
thickness was greater than the ulnlaus pipe wall thickness. (Refer to llote 6 of Appendix 4.4.) j j
Me agree that the code requirements are espilcit with regard to underfill as applied to typical piping girth .
butt welds. Underfill in such welds has not historica11y j
~ been a problee and was not in this reinspection. :
J. The arc strike / weld spatter rejection rate was 311. i that is the i root cause for this high rejection rate?
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7 sponse: TVA procedures in use during the construction of Sequoyah i nuclear Plant prior to March 21. 1979 did not require the :
reporting of arc strikes unless a crack was present. The procedures used durthq the reinspection did require ]a reporting of arc strikes. The data slaply reflects the j procedure requirements in the two different tlae frames.
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Neld spatter has been prohibited by TVA inspecelon
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criteria since 1970. Neither the construction era nor current piping codes (ASME Section !!! and B31.1) address the condition. Although lumped with arc strikes as a discrepant condition..it was reported on only three piping welds.
- e. What were the original inspection criteria for these weld attributes?
Response: Please refer to lten "d" for response.
- f. mat were the reinspection criteria for these attributes?
Response: Soth arc strikes and weld spatter were treated as discrepant conditions during the reinspection,
- g. 2 4t is the justification for allalnation of Inspecting arc strikes for cracks in G-29C?
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Response Cracks have been and are presently prohibited in welds and
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adjacent base material in TVA inspection procedures. This prohibition includes cracks in arc strikes or anywhere else within the zone of laspection.
- 12. In 4.4.1, Page 11 and 4.2.1, page 13, in the tables titled " PIPING NELDS" and " STRUCTURAL IELD5" respectively, expressing weld rejection rates based upon the attribute inches is aisleading. There was only a finite nueer of welds laspected, and a quallfled craftsman shou'Id be capable of making welds which meet all of the attributes in all of the laches subaltted to inspection. For these tables, please rearrange the data as follows:
Nesponse:
P!PE WELOS NO. OF NELOS NO. OF WELDS WITH NO. OF NELDS TYPE OF MELD REINSPECTED REJECTED
- R.EPORTA8LE INDICAT10NS SY CODE SY CODE Sockst Nolds Office of Const. 204 78 0 Nuclear 0p5. 34 6 0 Outt Nelds Office of Const. 68 46 0 Nuclear ops. 22 6 0 Attachment to Pipe Mall Office of Const. 5 3 0 Nuclear Ops. 0 0 0 Total Melds . .
Office of Const. 277 127 0 Nuclear ops. 56 12 0 1
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STRUCTURAL WELOS
- NO. OF WELO NO. OF WELOS JOINTS NOT NO. OF WELDS WITH REPORTABLE MEETING TYPE OF WELD REINSPECTED IN0! CATIONS DESIGN REQUIREMENTS Fillet Welds Office of Const. 1080 160 0 Ituclear Ops. 148 21 0 Butt holds Office of Const. 50 4 0 Ituclear Ops. 0 0 0 Other (specify) - Flare I- ~
Office of Const. 92 24 0 Iluclear.0ps. 24 2 0~
- Neld Dints were evaluated not individual weld segments.
- 13. In the TVA Reinspection Report, a comparison is made between original inspection results and the reinspection results for piping welds. If such a comparison Can be made in a quantitative manner for structural l
welds, please present the data.
Response: The original inspection was made on an item basis rather I
than ladividual weld, consequently, we do not believe possible to make a meaningful weld-by-weld comparison between the reinspection results and the original laspection results for structural welds.
- 14. Referring to the Legend for Table 4.2, in the Final Resolution column, define the meaning of the letter codes la parentheses.
Response: The letter codes located within the parenthesis in the legend of the final Resolution of Table 4.2 denote various design sections within the Olvision of leuclear Engineering that had lead responsibility of the resolutions addressed 1 by the code of Al through A10.
IIES CSM - Iluclear Engineering Branch - Code Standards &
Materials Section CES M2 - Civil Engineering Branch Mechanical Analysis Section #2 l 50EP M3 - Sequoyah Engineering Project Mechanical Design
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Section #3 SOEP C3 - Seoucyah Engineering Project Civil Design Section
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- 15. There are some employee Concerns about various structures not -
being in accordance with the as-built drawings. Did the TVA ,
reinspection address this issue? If so, report the deviations from the as-built drawings found. Report the deviations in configuration as to p}
type of deviation, the rate of a type of deviation compared to the \j
, number in the reinspection population, and if such deviations resulted [p in not meeting code requirements. L;j n,
Response: ho. This reinspection program was not intended to address M deviations in configuration from as-built drawings. This ' O subject is being addressed by TVA's employee concerns 7{
program.
- 16. Table 4.3 shows that a total of 50 structures were reinspected in the i TVA reinspection program. However. Table 4.4 shows only 31 structures 6 as having been reinspected. Explain the discrepancy. j b
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-Response: Table 4.3 is correct for number of structures. Table 4.4 shows number of items or what was defined in Phase I as a
. package. An item may contain only one structure or a t number of structures. 3 -
To correct the Table 4.3..the title should read " NUMBER OF RE!IrSPECTED STRUCTURES".
There are 31 packages (itees) shown in Table 4.4. - 2 Tuo packages (No.10 and No. 30) are not reported in Table (j 4.4. Itee #10'was not reinspected and Item #30 is M reported in the Mechanical Reinspection (Table 4.2).
The resalning packages breakdown to the following number of f.j structures. ,
Items 2 thru 9) ~
12 ) t 14 thru 16) All contain one structure P 18 )
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23 thru 29) '
31 )
Ites 1- 2 structures Y; 11 - 2 structures ,1 13 - 3 structures W
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Attachmellt 1I ROBERT D. STOUT. Consultant 141 as r. u. . si ..i s.w. % e..isois September 8, 1986 (mse Phone: (215) 8614288 Home Phon.: (215) 866 0698 Mr. Carl J. Czajkowski
- Brookhaven National Laboratory Upton, N.Y. 11973
Dear Mr. Czajkowski:
This letter is a statement of my indi-vidual reactions as a member of the expert welding team formed by Brookhaven National Laboratory. This team was assigned to review the adequacy of the TVA welding pro-gram and the corrective actions taken by TVA in response '
to expressed employee concerns. The first segment of the work was to examine the program and employee concerns relevant to the Sequoyah Station. The committee embarked '
on a physical survey of the safety-related Class 3 piping welds and structural welds, and also considered 117 employee concerns pertaining to welding together with the TVA responses supplied.
. The physical survey did not raise any serious doubts about the quality and adequacy of the weldments based on visual examination. The fact that the station has been in operation for some six years without significant welding failures supports the adequacy of the welding.
No attempt was made to analyze the documents pertaining to the programmatic aspects of the TVA operation beyond the extensive discussions among the committee and NRC representatives. The examination of l
the employee conogns and the responses of TVA did not reveal any evidence of gross departures from accepted practices. The chief weaknesses seem to be associated '
with an overelaborated program which has suffered from the failure of management to maintain careful control of it.
l In summary my conclusions are as I follows:
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- 1. The class 3 welded construction at the Sequoyah Station appears from the reinspection reports of TVA and NRC to be of acceptable quality. The visual inspection by the team supported this view.
2..No employee concerns were confirmed which threaten the safety of the plant.
- 3. TVA must restore full confidence in their man-agement of the welding program.
- 4. There were no inadequacies revealed in the welded construction which would prevent resumption of' operation of the Sequoyah Station.
Very truly yours, k b Robert D. Stout 9
- - - - -- y ~r --, * - + ---,,---m y w
-* e- , - - w e- -- - --
e Attachment 12 (813) 642 6074 PAUL E. MASTERS we 6o.=a c=a.=c e.ma 1951 PALACo GRANDE PARKWAY CAPE COH AL, FLORIDA 33904 September 13, 1986 Mr. Carl J. Czajkowski Department of Nuclear Energy Brookhaven National Laboratory Upton, New York 11793
Subject:
Position Statement - Contract Number 225771-5 It is the writer's opinion that the Technical Evaluation Report (TER) relative to the welding concern program at TVA's Sequoyah units 1 and 2, dated August, 1986 and edited by Carl J. Czajkowski, properely reflects the concensus of the Expert Team's evaluation of the utility's response and action plan for addressing the employee welding concerns.
During this evaluation it was quite evident that there was poor over-all management by TVA. They appear to treat each site as an entity.
Their documents, which are innumerable, were confusing, overlapping, repetitive, unclear and lacked continuity with regard to each other and to revisions. This certainly results in a lack of understanding by all I
craf t personnel and their supervisors. This a,1so appears to create con-fusion in the control by NRC in monitoring TVA's work. This situation adds to the public's already poor opinion of the control and safety of nuclear power plants. in the recent meeting with NRC this was quite evident by the discussions within the NRC group relative to the TVA situation.
The writer seriously questions, the use of TVA's Visual Weld Accept-Criteria for Structural welding, NCIG-01, for the reinspection or for Initial welding. The document correctly states in its introduction l
I paragraph 1.1.1.1 of AWS D1.1 and that it was a new paragraph in the I 1985 edition. Also included is part of the Commentary on this paragraph, i but fails to include the statement in the preceeding paragraph to the
! effect that any modifications of the Code deemed necessary by the auth-orities should be clearly referenced in the construction agreement be-tween the owner and the contractor, in this case, TVA's, the Justifica-tion for NCIG-01 is being applied many years after the original spec-ifications were written. ,
~
it is ludicrous to use a lower weld quality requirement, NCIG-01, than the original, DI.1, as the criterion to reinspect questionable welding. Further Justification of acceptance of undersize welds, lack of specified number of welds, etc., by engineering reevaluation shows poor original design work by specifying over welding or a reduction of the safety factor for the connection. Again adding to the public's poor opinion of nuclear power projects.
l l
Psga 2 PAUL E. M ASTERS Position Statement Continued During the Teams on-site visit to the Sequoyah plant on Feb. 26-28, 1986 it was the writer's opinion that the weld quality was good. How-ever it must be realized that this did not include weld size, length, etc.,
as we did not have these requirements when viewing the welds.
The writer cannot make a statement relative to the start-up of the Sequoyah units as that must be based on the acceptance of the eng-Ineering reevaluation judgement and the acceptance of a lesser weld quality requirement used in the reevaluation and weld reinspection results.
w s -
,_ _ ?deA Paul E. Masters
1
. . l Attachment 13 l l
W. H. Munse 1208 Devonshire Dr.
Champaign, IL 61821 October 1, 1986 Mr. Carl J. Czaykowski Materials Technology Div.
Brockhaven National Laboratcry Upton, New Ycrk 11973 Welding Ccncern Program at TVA's Sequoyah Plants
Dear Mr. Czaykowski:
This letter report is in answer to your request to the expert welding team for individual evaluation of the Weld Evaluation Program at the Sequoyah Nuclear Plants.
Your Technical Evaluation Repcrt of August 1986 includes the expert welding team's evaluations cf the detailed Employed Concerns. relative to the Sequcyah Units. In ' addition, I shculd like to cffer the fcilowing comments and analysis concerning various aspects of the overall Welding Program. These ccaments relate to the empicyee concerns as well as to a variety of cther questions, analyses and reports.
- 1. Evaluation cf Ccnstruction Welding and Inspection. Both the Aptech and Bechtel audits inycived only an examination of the welding and inspec-tien documentatien for SQN and not an examinatica cf the actual welds.
Based on these studies the Welding Program concludes that (a) "the welding prcgram for the TVA Sequcyah Nuclear Plant is being effectively implemented and that the installed hardware is suitable for service," and, (b) "that TVA had an effective program related to welding and NDE." However, there are many questions raised in these audits that lead cne to question these conclusions. Fcr example, it is indicated in the Aptech repcrt that the welding and inspecticn programs shculd provide quality welds, if properly implemented. But, were they properly implemented?
An examination of the data on the weld reinspections at SQN shows the existence of numercus welds with rejectable attributes (See Tables 4.2 and 4.3 of the Vcl. III report) even though less stringent requirements were empicyed in the reinspecticn than had originally been specified. This certainly does not indicate that the original designs and specifications had been pecperly implemented.
In ancther pceticr of the Aptech repcrt it is noted that 46,430 hours0.00498 days <br />0.119 hours <br />7.109788e-4 weeks <br />1.63615e-4 months <br /> of operation at SQN 1 and 2 had not identified any welds which are not of sufficient quality fcr their intended service. This may be true (cr
o, 2
operating-service conditions but does not cover the maximum design leadings for which the plants are designed; the cperating ccnditions shculd not be expected to produce any problems in the welds since they would not stress the welds to the magnitude that would be reached by the application
- cf the maximum design loads.
In the Bechtel repcrt it is cbserved that, "Many cf the referenced implementing procedures in the NQAM were found to be excessively 1cng, ambigucus, and do not give clear and concise instructicns to personnel to perform their activity." Again, with such conditions existing it is hard to see hcw the welding and inspection personnel cculd prcperly perform their functions. ,
Another evaluaticn which relates to the TVA welding and inspection can be found in the QAE-80-Z report. Although this report applies specifically to the Watts Bar Plants, much of it is of a general nature and no doubt generically applicable or appropriate to the Sequoyah Plants toc. Many reccamendaticns are made, including the tc11cwing:
' (a) Disciplinary action should be taken against welders who bypass holdpoints.
(b) Responsibility for meeting QA/QC requirements should be emphasized.
(c) A CONST qualificaticn/ certification program for visual weld inspection should be established.
(d) The Welding Engineering Units should supply personnel with information on weld sequencing.
(e) Ccmplete welding procedure specifications shculd be at the fcreman's station.
(f) All necessary tecls, gauges, and instruments necessary to determine weld acceptance shculd be made more readily available.
4 (g) Mere surveillance checks shculd be made en in process welding l
operations.
(h) A standardized system for continuity of welders' qualification and welding procedure / performance qualification crcss-reference should be developed.
(1) A ccmplete rework cf distribution, centrol, content and utilizaticn cf G-29 specifications should be made. G-29 needs to be at work stations.
' (j ) Appecximately 50 percent cf the site welding engineers have insufficient backgrcund, experience and education to perform as
. qualified welding engineers.
}
9 -
3 (k)
Welding engineers spend the majcrity of their time as Technical unit supervisce to the welding welding inspecticn inspectcrs because of inexperienced perscnnel.
(1) i There is failure by craf ts to Tcllow instructicn in work packages and other documents, and to bypass holdpoints.
(m)
Inspectica perscnnel are not always pecvided with the basic tecls needed to perform the inspection functions.
(n)
With the excepticn of the apprentice prcgram, OJT for welders is not provided.
(c)
Nuclear projects are constantly cited by NRC fcr the lack cf control of filler material.
(p)
Quality some levels type cn civil structural drawings are confusing and need of resolution.
(q)
Redundancy in QCI and G-29 cn NDE procedures should be eliminated.
With such questions being raised and so many reccamendations being made, it is difficult to imagine that the welding and inspection programs are being or have been properly implemented.
- Finally, it is noted that the Aptech and Bechtel Audits involved only reviews and cf V, of PTrecords, and the TVA's reinspection is primarily through paint and NT peccedures.
Little has been dcne to provide a volumetric evaluation (reinspection), cf the Class 1 and 2 Sequoyah welds.
Thisect.
Proj appears to be one of the majcr shcrtccmings of the Welding Evaluaticn
- In fact there has been no indication of a systematic re-exami-nation of the radiographs for such welds.
- 2. Specifications.
AWS D1.1 Ccde. A second area cf concern is the application of the As a member cf the AWS Structural Welding Ccamittee the writer has considered the Structural Welding Code to provide minimum requirements.
j have interpreted the Code in the broadest sense and have provide stringent requirements than in D1.1 Ccmparison of G-29 to DI.1 and NCIG-01 to D 1.1) Code.(see Table A cf Vol. II fcr th There is less safety provided by G-29 and NCIG-01 than is pecvided by the D1.1 Ccde. The D1.1 Code is used primarily for buildings and bridges. In view of the
, critical nature of a failure at a nuclear plant, cne would generally assume that the provisions for a nuclear plant would be more stringent rather than less stringent than for buildings.
Justirication given rce the relaxatien of requirements.Furthermore, there has been no sc of the 1985 AWS Code it is indicated that, "when modifications areIn the ecmmentary
- approved, evaluation cf suit-ability fcr service using modern fracture mechanics evidence is recognized techniques,asa ahistcry cf satisfactory service, cc experimental i
I
a;
- 1 1
4 suitable basis fcr alternate acceptance criteria for welds." This type cf justificaticn Tcr modification has not been clearly demonstrated in the documents available to date.
A second precedure that has been used to justify the use of welds that fail to satisfy the D1.1 is to make an engineering check to establish suitability fcr service. Such a procedure using NCIG-01, since it is a relaxation cf the D1.1 Code, will provide a structure that is not as safe as if the welds met the D1.1 requirements. The necessity to use such a procedure also suggests that the original design may have been peor er overly conservative, both cf which indicate pccr engineering.
3 Summary and Conclusions. Frcm the TER it is shown that the Sequoyah units have suffered scme areas of pecgrammatic breakdown but the hardware itself does not appear to have defects of great detriment er magnitude.
However, f urther study cf this questien would seem desirable. The evalu-ation of the Employee Ccncerns indicates that many have not been substantiated, nor have they all bden shown to be groundless or false.
In NSRS report No. I-85-373-NPS interviews with 17 NDE inspectcrs concerning OJT, it is indicated that scat inspectors expressed concerns to varying degrees with regard to the validity of scme of the claimed OJT; falsification of records and favoritism are reported. Thus, the concern ever OJT was basically substantiated. In addition, it is indicated that scme inspectcra didn't feel they were qualified for some cf their tasks.
The ERT investigations report en OJT also indicates both a program-
' matic breakdown and falsification of records within the TVA NDE training /
certificaticn program. Again, a substantiation of the OJT concern.
' Based on the various studies and evaluations made to date it appears that there are a number of shcrtccmings in the TVA program.
(a) Inadequate training at all levels.
(b) Pccr reccrd keeping and control in welding and inspection.
(c) Many peccedures are excessively 1cng, ambiguous, and dc not give clear and concise instructions to personnel to perform their activities. There are many cverlapping dccuments.
(d) There is excessive redundancy f1 the various weld related construction documents, the various weld related inspection instructicas, the varicus weld related standard operating procedures, and in the various design, construction and inspection specifications and codes. This causes confusion.
(e) There are so many dccuments for a project that relate to welding and inspection that it is essentially impossible for the pcracnnel to be aware of all the requirements to which they shculd be working.
J r 5
These are all shcrtccmings that can be corrected. However, the fact that they have existed raises questiens as to the quality of the welded nuclear structures.
The Weld Evaluation Program was designed te establish a high level cf confidence in all welds at the Sequcyah Nuclear plant. However, with the relaxations in specifications needed fcr weld acceptance, and the need to use an extra engineering check of suitability fcr service does not help tc instill a high level cf confidence in the welding.
In the reinspection program the welds were generally rated as average er better. Hcwever, in 345 piping welds 9 were rated unacceptable as to the quality cf weld workmanship. In 7368 inches of structural welds reinspected (in 1394 welds), 1040 inches were fcund with indications, 10.38 percent were undersize and 9 joints had welds cmitted. Again, although mcst welds appear visually to be of average cr gccd structural quality (this was also the writer's general cbservation frcm a personal examination of a limited number cf welds), the number cf indications repcrted is cf such a magnitude that the desired high level of confidence in the welding and inspection does not appear to have been achieved. Acceptance has been achieved only by emplcying specificaticns less stringent than originally specified, and thrcugh the application of "an engineering evaluation,"
with little indication of what this evaluation entailed. A greater confi-dence in such acceptance criteria might be pcssible if scme quantitative measures were presented to such questiens as, what percentage the welds were undersize (per the criginal specified size), and frcm the engineering evaluation, what is the magnitude cf understress in the actual welds (based on the maximum allowable design stresses).
Frcm the above discussion it should be evident that the writer believes further analysis and justification of the Sequoyah welding and inspection would be desirable to demonstrate whether cr not the welding at the Sequoyah plants is cf a quality to satisfy the desired Ccce and Specification design requirements.
Very truly yours,
- b. L uws4.,,1 W. H. Munse Prcresscr Emeritus cf Civil Engineering WHM/jh
( e Attachment 14 s
September 16, 1986 Mr. Carl Czajkowski Brookhaven National Lab.
- Upton, Long Island New York 11973
Dear Carl,
Enclosed please find an Executive Summary of my views re-garding the adequacy of the TVA SQN Welding Concern Program and the adequacy of TVA's corrective actions in the areas of Welder Certification and Welding Inspection.
I consider these issues to be unresolved by TVA and because these issues potentially adversely affect the safety of the plantr startup should be delayed until TVA has adequately ad-dressed both issues. TVA's denial of documented facts by NSRS/
QTC/ERT should be flatly rejected; additional test and evalu-
,l ation is required to give reasonable assurance that the plant is safe for operation.
l I recommend the following additions to the TVA Weld Evalu-ation Program (WEP) as a MINIMUM requirement for assuring ac-ceptable Safety Related Welds at SQN:
With documented programmatic and implementation failures in visual weld inspection and a high probability of unqualified NDE inspectors at the time of construction and PSI inspections, i before restart of SQN weld quality in Class 1 and Class 2 piping welds should be verified by the following:
- (1) For inspectors who served at SQN during construction and/or in the PSI but are no longer employed by TVA, make an
, independent audit of personnel records to determine compliance l with SNT-TC-1A recommended practice for NDE Level II Certifi-cation of inspectors.
i (2) For inspectors still employed by TVA, test each NDE in-spector using hands-on weld samples (EG&G is using such samples J,
in their current WEP inspector-qualification program; such test-ing will give no assurance that the inspector was qualified at
, the time of construction or PSI but will at least verify that the inspector is currently qualified).
(3) Verify the quality of the radiography as used in the RT of safety related welds by re-examination of film by an inde-
, pendent team of radiographic experts. The assessment of quality i
should include determining if the films have the required identi-fication, are free of artifacts, have the correct penetrameters i and quality level, and have correct station markers. Additionally, l the verification examination should reassess the weld quality and related documentation to assure that all indications were properly
- interpreted and that all rejectable indications were corrected.
Sincerel ours, l A a=y y:w4s w ,s,
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.t"W '. "' '
SER/TER ATTACHMENT September 15, 1986 MEM00RANDUM FOR: C. J. Czajkowski Department of Nuc Energy Brookhaven National Lab.
Upton, Long Is' land 11973 FROM: C. E. Hartbower Consulting Welding Engineer Fair Oaks, CA 95628
SUBJECT:
REVIEW AND EVALUATION OF TVA's REASSESSMENT OF WELD QUALITY AT SEQUOYAH UNITS 1 & 2,-
EXECUTIVE
SUMMARY
OF FINDINGS.
STATEMENT OF PURPOSE
'The Welding Team was under contract to Brookhaven National Laboratory to independently review TVA's resolution of the issues raised.by the numerous welding-related employee concerns at the Sequoyah Nuclear Power Station (SQN) and to make recommendations on the adequacy of TVA's corrective actions, as appropriate.
As a team, our collective findings are encapsulated by Mr.
Czajkowski in his Technical Evaluation Report (TER) under the heading EXPERT WELDING TEAM as applied to each of six categories of employee concerns. The findings do not always represent a consensus opinion. I see two issue categories as requiring 'ampli-fication and further resolution prior to restart of SQN Units 1 & 2; viz., WELDING INSPECTION (40 employee concerns) and WELDER CERTIFICATION / TRAINING (27 employee concerns).
The following memorandum report constitutes an Executive Summary of my findings acting independently as a welding expert.
WELDER CERTIFICATION ,
Several reports address the employee concerns on matters re-lating to welder certification / training, including ERT Investi- :
gation Report of 9/26/85, QTC/ERT Investigation Report of 2/28/86 and NSRS' Report I-85-135-SQN. The following findings may impact the safety of SQN and in my opinion require further consideration by TVA before restart of SQN. Quoting from the NSRS report:
In the past, Nuclear Power has accepted construction welder performance qualification without retesting.
The SQN Site Director issued a memorandum (Abercrombie to listed reci 29, 1985, subject Welders Certification)pients Augdirecting site management to discontinue 1
the practice (of accepting construction welder perform-ance qualification without testing).
l COMMENT: Construction was completed at SQN prior to Aug 1985 and,
! therefore, the corrective action was too late to benefit this plant.
{
l There appears to be no safety concern since all active I
welder records were either correct or readily restored to requirements. Also all safety-related welding is in-l f
i l . ._ . . _ . . . .....
a ~
page 2 of 5 dependently inspected per an approved QA program.
COMMENT: Safety may in fact be a concern because construction was completed prior to implementation of a proper welder certi-fica. tion program, and the efficacy of NDE inspection may have been. limited as a means to verify the quality of safety-related welds by a programmatic breakdown and falsification of records within the TVA NDE training / certification program.
If one or more un SRWs), say C1 1 and/ orqualified welders C1 2 piping, andworked if the on safety-relatd particular welds welds made by an unqualified welder were tested by an unqualified NDE inspector, potentially dangerous flaws could be in the plant today.
NRC welding team inspectors (6/2-6/6/86, 6[16-6/20/86 and '
7/7-7/11/86 at SQN) confirmed a number of weld deficiencies that had been previously identified and evaluated by TVA in their WEP.
reinspection effort. Many of these weld deficiencies provide additional evidence of unqualified welders at SQN. Furthermore, i the fact that on reinspection there were NCIG-01 rejectable welds inspite of the relaxed acceptance criteria of NCIG-01, welds that in construction had been made to AWS D1.1 acceptance criteria, provides additional evidence of unqualified welders at SQN (as well as unqualified inspectors during construction and PSI).
When the provisions of the TVA QA program that required welder performance qualification testing were relaxed and the work force perceived a loosening of control / standards, workmanship could have suffered. Welder skills, performance and pride in workman-ship constitute the first line of defense against flawed welds; the second is the welding inspector who observes the day-by-day performance of each weldere If the welding inspector is to be effective, he or she must be adequately trained / experienced and operate with the full support of management.
WELDING INSPECTION I believe that before restart of SQN TVA should resolve point by point the findings of three NSRS/QTC/ERT Investigation Reports which concluded that certain employee concerns regarding weld inspection are substantiated.
A Nuclear Safety Review Staff (NSRS) investigation was con-ducted to determine the validity of an expressed employee concern which stated:
Sequoyah. Many employees are certified but are not qualified. They do not have enough on-the-job training (0JT) even though it is documented that they do have enough OJT. The concern existed from 1980 to present. '
Details known to QTC, withheld to maintain confiden-tiality. NUC PR concern. ,
NSRS notes that "...it should be recognized that a differentia-tion can be made between work-time experience, which is what OJT as used in this report is really referring to, and the proper usage of the term OJT which denotes a dedicated, organized, com-prehencive and documented system of formal training on actuual work activity and equipment.
r pago 3 of 5 The report (NSRS Investigation Report I-85-373-NPS on Docu-mentation of Required CJT for NDE Personnel Certification.by C. L. Wilson and M. P. Mills dated 1/31/86, 27 pages) determined that NDE management in TVA early on took a very loose inter-pretation of OJT requirements, and many of the individ-uals who trained under that policy and were subsequently promoted have continued and extended that practice...
A followup investigation by NUC PR will be required to remedy the findings documented herein.
Inspection personnel in both QC and.ISI have been placed in a difficult position by a policy which has been orig-inated and promulgated by individuals who are now more than two levels of supervision above them...
It is crucial to. understand that there is a direct con-nection between the personnel practices of the NDE groups and the safety of the plant. This is because the inspec-tors can only do their critical jobs well when they see that strict completion of technical training requirements, independence and rigorous adherence to procedures are cul-tivated and rewarded rather than compomised...
... sufficient certification discrepancies were noted to mandate an extended evaluation by NUC PR of the TVA NDE certification program and resultant inspection activities.
... This followup investigation should begin with Sequoyah Nuclear Plant. NSRS considers this a startup. issue for SQN.
Another report, an investigation of nondestructive examination (NDE) certifications at the Sequoyah Nuclear Plant (SQN) and the Power Operations Training Center (POTC), was written at the same time as the NSRS report. This investigation, by QTC, was to de-termine if NDE certifications.had been falsified (QTC/ERT Inves-tigation Re dated 1/31/86, port by M. P. Mills on Falsification of OJT Records 7pages).
The results of this investigation clearly indicate both a programmatic breakdown and falsification of records with-in the TVA NDE training / certification program. Based on these findings, the following is recommended:
- 1. The turn over of this report to the Office of General Counsel 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.
The third report, QTC/ERT Investigation Report by R. W. Jones dated 2/28/86, 28 pages, dealt with a number of generic concerns that :
Inspectors are generally untrained or not adequately train-ed, are unqualified, lack knowledge of weld-acceptance cri-teria and do not follow procedures.
Training, both classroom.and on-the-job is inadequate, certi-fication tests are described as a joke, do not receive the required minimum training. The above concerns encompass all inspector training, qualifications and testing.
l
o s
-J . %
PUCu 4 of 5 This investigation was performed from July through October
.1985 The generic concerns listed above were substantiated. The find-ing that inspector training was inadequate, both in.the class-room and on-the-job, is most damaging in the case of ultrasonic testing; it is common knowledge that this discipline requires special training and hands-on testing to assure qualified per-sonnel.
Because there are SUBSTANTIATED employee concerns with regard to welding inspection and inspector training / qualification, I be-lieve that all TVA inspections are sus pect including visual, NDE MT, PT and RT and, inparticular, the ultrasonic testing (UT) done in construction and in preservice inspection (PSI).
~
For UT in-spectors, there is no way that work-time experience can be substi-tuted for the " dedicated, organized, comprehensive and documented system of formal training" which the Nuclear Safety Review Staff found lacking in the TVA program.
APTECH reported in their " Evaluation of the Welds at SQN" AES 8511598AQ-1, Jan 1986, that Slightly under 10% of the field welds were inspected (in the PSI) by penetrant (PT). The remaining 90% were in-spected ultrasonically (UT), which is a more rigorous vol-umetric examination than PT, which is primarily a surface examination. The lack of significant numbers of NOIs from the PSI is a strong indi,cator that the quality of the welds is high.
COMMENT: If TVA UT inspections are suspect, then it is a fallacy to assume that the lack of significant numbers of NOIs is an in-dicator of high quality in ,the SQN welds.
Likewise, in the TVA WEP reinspection of 333 piping welds and 1394 structural welds, I take little comfort in the low rejection rate (discounting weld spatter and are strikes) considering (1) the high indication rate in Office of Construction (OC) piping welds by visual examination (a 38 to 68% indication rate) see SER Table 1A, p10, (2) the OC piping welds would have been rejected if the indica-tions had been detected during construction (ASME Section III vsSection XI),
(3) the reportable indications in OC structural welds should have been detected during construction.
(4) at the time of construction, the applicable code for the structural welds was AWS D1.1-72; for purposes of WEP reinspec-tion the accept / reject criteria were based on NCIG-01 which in some respects is much less stringent the AWS D1.1, therefore, if the visual inspectors had been well trained and diligent. TVA at the time of construction should have had a significantly higher rejection rate than found in the WEP reinspection based on HCIG-01.
f'
%l *e t
pago 5 of 5 There is additional evidence of unqualified, unmotivated inspections. There was a high incidence of weld spatter and are strikes discovered in the WEP reinspections. During con-struction, at various times TVA Specifications (P.S.3.C.5.2.
and P.S.3.C.5 4 after 2/13/81) called for removal of spatter and arc strikes. Furthermore, wherever there was to be UT in-spection, removal of weld spatter and are strikes should have been routine in preparation for inspection. There can be little doubt that much of the spatter and are strikes occurred during construction and yet inspection did not call for its removal.
There is another consideration, viz., I question whether the cracking that sometimes attends an are strike can effectively /
reliably be detected without first grinding the are strike smooth and flush. Wherever this was not done and followed by PT inspection, there is a possibility of undetected cracking.
With evidence that TVA failed to provide consistently reli-able welding inspection during construction and in the PSI in-spection, all safety related welds are subject to question ex-cept those verified by NRC welding team WEP reinspections. The NRC welding team noted a number of weld discrepancies, most of which were previously identified and evaluated as a result of the TVA WEP reinspection effort. This verification of TVA find-ings by NRC indicates that TVA inspection was effective in ident-ifying weld deficiencies in the recent WEP reinspections but con-firmed ineptness in earlier inspections. Futhermore, the earlier volumetric inspections by.TVA that are suspect were omitted from the WEP reinspection program. '
Some of the additional irregularities not found in the TVA WEP reinspections but found by the NRC welding team raise additinal questions about the qualifications of the TVA inspectors /inspec-tion program during construction. A number of welds were found by the NRC welding team which deviated from the requirements of the applicable design drawings; TVA inspection should have found these discrepancies in construction or in PSI. One structural platform was inspected by NRC; the TVA inspectors during con-struction could not have verified conformance to design because there were no weld details on the desgn drawings. Also the NRC welding team found that in some cases the drawing / Specifications failed to specify the Quality Level for inspection; thus, during construction the TVA inspectors had no way to know whether Quality Level 1 or 2 was intended by the designer. These discrepancies are not insignificant and should have been discovered by TVA in-spection during construction, in PSI or in the WEP reinspection. ,
( 74 NM
_