PLA-1436, Final Deficiency Rept Re Nonconformance of Bechtel Field Welding.Initially Reported on 821115.Training Sessions Conducted Re Welding QC Requirements & Procedures FP-G-24 & FP-W-1 Will Be Revised.Also Reported Per Part 21
| ML20079J708 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 12/15/1982 |
| From: | Curtis N PENNSYLVANIA POWER & LIGHT CO. |
| To: | Haynes R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| REF-PT21-82 10CFR-050.55E, 10CFR-50.55E, PLA-1436, NUDOCS 8212280323 | |
| Download: ML20079J708 (7) | |
Text
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@ Pennsylvania Power & Light Company
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Two North Ninth Street + Allentown, PA 18101 + 215 I 770LS151 (b ~ 33 $
Ncrman W. Curtis t
Vice President-Engineering & Construction-Nuclear 215 / 770-5381 December 15, 1982 e
Mr. R. C. Haynes Regional Administrator, Region I U.S. Nuclear Regulatory Commission 631 Park Avenua h
King of Prussia, PA 19406 e
SUSQUEHANNA STEAM EIECTRIC STATION FINAL REPORT OF A DEFICIENCa' INVOLV'NG t
E-VARIOUS WELDING DEFIClliiCIES FOUND ON UNIT 2 (8.1.2A #82-47)
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ERs 100450/100508 FILE 821-10 E
Dear Mr. Haynes:
g This letter serves to provide the Commission with a final reporc on a defi-i ciency involving various welding deficiencies found on Unit 2.
E This deficiency was originally reported by telephone to Mr. D. F. Johnson of NRC Region I on November 15, 1982 by Mr. Jason Saranga of PP&L. At that time, 5.
the condition was identified as "Potentially Reportable."
The attachment to this letter contains a description of the deficiency, its cause, an analysis of safety implications and the corrective actions taker and planned. This information is furnished pursuant to the provisions of 10CFR50.55(e).
Since the details of this report provide information relevant to the reporting requiremente of 10CFR21, this correspondence is considered to also discharge any formal responsibility PP&L may have in compliance thereto.
We trust the Commission will find this report to be satisfactory.
Very truly yours,
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N. W. Curtis Vice President-Engineering & Construction-Nuclear BMS:pvm Attachment
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1 December '15,11982
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. PLA-1436 era 100450/. Fils'821-10
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-100508 t
cc:' Mr. Richard C. DeYoung (15).
Director-Office'of Inspection & Enforcement U.S. Nuclear Regulatory Commission Wauhington, D.C.
20555 Mr. G. Mcdonald, Director Office of Management Information & Program Control-U.S.; Nuclear Fegulatory Commission' Washington, D.C.
20555 Mr. Gary Rhoads U.S. Nuclear Regulatory Commission
_P.O. Box 52 Shickshinny, PA
- 18655
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ATTACHMENT TO PLA-1436
.Page 1 of 5 SUBJECT' Inspection of Bechtel Field Welding, MCAR 1-80, Unit 2.
DESCRIPTION During construction of the Susquehanna project, a considerable percentage of the welding was done by Bechtel field personnel in accordance with American Welding Society Structural Welding Code AWS D1.1.
Welding
~
procedures used for this activity are included in project specification 8856-C-90.
Field welding covers several areas which can be grouped into two broad categories.
The first category includes the welding and fabrication which was orig-inally planned to be performed exclusively by Bechtel field personnel.
This category includes the following work items.
a.
Electrical racewsy supports per drawing 8856-E-53 b.
Instramentation supports per drawing 8856-JG-16 c.
Miscellaneous steel per specification 8856-C-16 d.
SQRT and jet impingement fixes per specification 8856-C-16 The second category includes those items which were fabricated and furnished by project vendors and subcontractors under various specifica-tions. However, due to subsequent design changes, Bechtel field personnel were required to make various modifications to these items.
Welding for these two categories is performed and inspected in accordance with AWS Code D1.1 in conjunction with applicable design drawings and specifications. Monitoring and surveillance of field welding is the joint responsibility of the field welding organization and the respective discipline engineers.
Field quality control engineers perform final inspection and verification.
Inspection results are then documented on Quality Control Inspection Reports (QCIRs).
If no nonconformances are observed during the inspection, completed work is considered to be
" accepted" without any further action.
After Quality Control performs the final inspection and accepts the completed work, Bechtel Quality Assurance Engineers undertake a review of documentation and perform an inspection of the hardware on a sample basis.
It was at this point that the deficiency was discovered by the Quality Assurance organization.
Several nonconformances were observed by Quality Assurance (QA) in the field welding of various items, previously inspected and accepted by Quality Control.
For example, nonconformances were identified on:
instrumentation supports, SQRT fixes, beam stif feners attached to struc-tural steel in the containment diaphragm slab, equipment bases and the attachment of hinges to the reactor shield. After identification by Bechtel QA, the nonconforming items were then thoroughly re-inspected by either Quality Control or field engineering and at times both jointly.
Any nonconformances noted during such re-inspections were noted on
ATTACHMENT TO PLA-1436 "Page 2 of 5
- nonconformance reports and subsequently evaluated by Bechtel Project Engineering.
-Based on the results of the initial discovery of the nonconformances by Bechtel QA,.it was determined the scope of the problem should include all' field welded items. Bechtel QA issued MCAR l-80 on August 18, 1982 to bring management attention to the condition and obtain necessary correc-tive action. Subsequent investigation was to determine the root cause of
.the problem and provide corrective action (s) to prevent. recurrence.
CAUSE At the completion of the investigation into the causes of the problems with field welding inspection, Bechtel determined there were two reasons why ncnconformancee were not detseted en field welded items.
First, field engineering personnel did not perform monitoring, surveil-lance and inspection activity properly to identify all nonconforming welding. Second, Quality Control did not adequately verify if the welds wer'e in acccrdance with the code and design documents. Therefore, inp?cmentatioa of inspection activity is considered to be deficient.
SAFETY IMPLICATIONS Welding provides a structural connection between various safety and non-safety related structural elements in order to transmit design forces and moments. Weld dimensions are based on design loads or are governed by the minimum size requirements of the AISC Code.
For other than pressure piping, the American Welding Society (AWS) Code Dl.l. is used as a standard. Considering the importance of the structural function of the welds, it is necessary to ensure that existing welds meet design require-ments. Due to the weaknesses observed in the current inspection program (identified in MCAR 1-80) existing installations required additional inspection and evaluation to assure that all design requirements were met.
In addition, it was necessary to provide supplemental training to the field engineering and quality control organizations to ensure compre-hensive inspections were made.
Based on the available information, it has been concluded that the I
deficiencies discovered in the field welding inspection programs are reportable to the NRC under the provision of 10CFR50.55(e). This con-clusion is based on the following:
1.
The nonconformances described in various NCR's including those noted in MCAR 1-80 have been evaluated. These NCR's pertained to the field welding associated with SQRT fixes and equipment bases. Although the majority of the nonconformances are acceptable AS IS, in some cases, repair or rework is required to meet design conditions. Therefore, if these nonconformances had gone undetected, this could have affected safe operation of the plant.
ATTACHMENT TO PLA-1436 Page 3 of 5 2.
Nonconforming welds should have been identified by field engineering or QC personnel during their independent inspections.
Since this did not happen, it is indicative of weaknesses in implementation of Bechtel's QA program, which is considered to be significant.
EVALUATION / DISPOSITION OF THE NONCONFORMANCES Field welding has been performed in the following major applications.
For each application, the required corrective action is described below:
a.
Instrument supports A review by Quality Control of all Unit 11 instrunent support welds
('48 welds outside the wetwell and approximately 342 welds inside the wetwelli that were previously inspected and accepted, indicates that welding is adequate. No further action is required.
b.
At.achments to Containment Liner Plate An inspection of 133 welded attachments to the Unit 11 liner plate, selected at randon, was performed by Quality Control and all 133 were found to be acceptable. The inspection is documented on Field Inspection Report (FIR) #C-50-4541.
Therefore, no further acticn is
- required, c.
SQRT Design Fixes and Equipment Bases Since the issuance of MCAR 1-80, welding in these applications has been completely re-inspected by field engineering or jointly with Quality Control. Al nonconforming conditions were dispositioned in accordance with the established project procedures.
Some rework /
repair was required as a result.
On completion of required repair / rework, existing welds will meet the design requirements, d.
Eleatrical Raceway Supports For those electrical raceway supports which have been inspected and accepted, they will be reinspected at the time of area turnover.
In addition to the QC inspections discussed above, field engineering will also inspect all accessible welds prior to the final inspection by Quality Control.
e.
Jet Impingement Fixes Field engineering will re-inspect all accessible welds associated with this application. Any nonconformances noted will be documented on nonconformance reports and appropriate action will be taken.
f.
Miscellaneous Steel in Civil / Structural Applications This category includes items such as service platforms, seismic fixes for blockwalls, beam seats / brackets, beam fixes due to attachment,
ATTACHMENT TO PLA-1436 Page 4 of 5 etc.
Welding in this application, was visually spot checked (inspec-tion and evaluation) by a team of representatives from Bechtel Project Engineering and Bechtel Material & Quality Services. This team found that the weld quality was generally in compliance with AWS Dl.1 code. During the inspection, no porosity, cold laps, slag inclusions, or crator cracks were observed. Similarly, a dimensional check of the welds (i.e. spacing, location and length) was observed to be in compliance with the design intent. The areas found in noncompliance were judged to be adequate structurally. Therefore, no further inspection or investigation is required.
CORRECTIVE ACTIONS For all future inspection activities by Buchtel Quality Control and Bechtel Engineering the following actions have been and/or will be taken:
1.
Formal training was given to all Bechtel Quality Control Engineers certified in welding, Level I and Level II.
During this training, special instructior was given conterr.tng the AWS code, specifica-tions, procedures, acceptance criteria and final weld inspection.
Copies of the training records are available at the jobsite.
2.
Sechtel Field Engineering re-instructed applicsble foremen of their responsibilities to adhere to specified requirements. Additionally, training sessiens were held with cognizant craftsman to ensure that they are fully aware of the requirements which they are required to satisfy.
3.
Responsible Bechtel field engineers were instructed to perform thorough inspection of all AWS welding performed under their cogni-Applicable field engineers were given comprehensive training zance.
in September 1982 by the Field Welding group to ensure adequate and uniform inspection of AWS Welding from a dimensional and quality point of view. Field Welding Engineering will monitor the final inspections performed by respective discipline Field Engineers to ensure adequate inspection is being performed.
In addition, Field Welding Engineering will also increase in-process surveillance.
Bechtel field procedures FP-G-24 and FP-W-1 will be revised in December 1982 to more precisely define the inspection responsibili-ties of cognizant field engineers and field welding engineers.
CONCLUSIONS 1.
Complete inspection of the field welding in some of the applications, including the followup action performed to date, provides adequate assurance that the field welding in these appli~ cations meet design requirements.
An engineering evaluation, performed by Bechtel M&QS, of those welding applications not planned to be re-inspected was performed.
It was concluded from this evaluation that the types of departure
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ATTACHMENT TO PLA-1436 Page 5 of 5 from'the AWS Dl.1 Code and design drawings that were observed are not detrimental to the structure...Therefore..the welding is acceptable.
The training and future inspections planned provide adequate assur-ance that all applicable engineering requirements have been or will be met for all other work.
2.
The administrative controls, procedural changes and training sessions instituted since the discovery of the deficiencies will prevent a similar occurrence in the future.
3.
PP&L NQA will audit the Bechtel actions outlined above to assure effective implementation of the corrective actions.