ML18033B395

Welding-Related Employee Concerns Evaluations, Technical Rept

ML18033B395
Person / Time
Site:	Browns Ferry
Issue date:	12/31/1989
From:	CZAJKOWSKI C J, SCHUSTER M H BROOKHAVEN NATIONAL LABORATORY
To:	Office of Nuclear Reactor Regulation
Shared Package
ML18033B375	List: ML18033B395
References
CON-FIN-A-4001 MT-4001-1, NUDOCS 9006210280
Download: ML18033B395 (56)

Text

TECHNICAL REPORT MT-4001-1 BROMNS.FERRY MELDING RELATED EMPLOYEE CONCERN EVALUATIONS

, M.H.SCHUSTER C.J.CZAJKOMSKI DECEMBER)989 Nuclear Maste and Materials Technology Division Department of Nuclear Energy Brookhaven National Laboratory Associated Universities, Inc.Upton, Long Island, New York 11973 Prepared for Office of Nuclear Reactor Regulation U.S.Nuclear Regulatory'ommission Contract No.DE-AC02-76CH00016 NRC FIN A-4001 t VOOSa>OaSO VOO5SC PDR ADOCj(05000259 p (ted Q)

Ik l41 r gV'*1)

TABLE OF CONTENTS~Pa e 1.INTRODUCTION.

1.1 Background

......................2.PROGRAM TASKS.3~CONCERNS~~o~~~~~~~~~~~~~~~~~~~~~~~3.1 List of Concerns...................

3.2 Characterization

of Issues..............3.3 Description of Issues.................~~~~3.3.1 3.3.2 3.3.3 3.3.4 3.3.5 3.3.6 3.3.7 3.3.8 3.3.9 3.3.10 3.3.11 3.3.12 3.3.13 Control of Welding Filler Material......

Inspection of Welds Through Carbo-Zinc Primer Welder gualification and Continuity.

.....Availability of'Inspection Tools.......Inspector Training and Certification

.....Welder Training and Experience

........Surface Grinding of Welds...........Adequacy of Welding Equipment.

........Structural Steel Preweld Inspection.

.....Melder gualification

.............Meld Repair Not Meeting ASHE Code Requirements Structural Support Welds...........Meld Inspection Procedures

..........~~~~4.EVALUATION OF EMPLOYEE CONCERNS.4.1 Category 1-Melding Procedures.

.....4.2 Category 2-Melder gualification/Training

4.3 Category

3-Welding Inspection.

.....4.4 Category 4-Design and Configuration.

..4.5 Category 5-Filler Metal Control.....4.6 Category 6-Miscellaneous/One of a Kind.5.NRC STAFF INSPECTIONS

.~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~~7 8 10 13 14 15 16 5.1 Inspection Report Nos.: 50-259/86-34, and 50-296/86-34 (TORUS Modifications)

5.2 Inspection

Report Nos.: 50-259/87-19, and 50-296/87-19 (TVA Phase I)....5.3 Inspection Report Nos.: 50-259/88-13, and 50-296/88-13 (TVA Phase II)....50-260/86-34

~~~~~~50-.260/87<<19

~~t~~~50-260/88-13 16 17 19 t 6.TVA WELDING PROJECT FINAL REPORT-VOLUME VIII.7.REFERENCES.

21 24

~s I E 4.~\

1.INTRODUCTION 1.1~Back round In October.1985, as the result of TVA employee concerns and other quality indicators alleging construction deficiencies the Nuclear Regulatory Commission (NRC)requested a meeting[I]with TVA to discuss welding concerns.A listing of TVA welding issues with questions and comments was also provided at this time by the NRC.After reviewing and assessing these welding issues, TVA concluded investigations, reviews, possible reinspections and changes were needed to assure the adequacy of the overall TVA welding program and the suitability for service of TVA weldments.

TVA then formed the Power and Engineering (Nuclear)Welding Project (WP)to review the TVA welding program, resolve welding issues and provide the corrective actions needed to assure all welding activities are completed in accordance with regulatory requirements and TVA commitments.

Two of the major efforts utilized to address the issues by the TVA Welding t Project are provided by the Browns Ferry Phase I (programmatic review)[1]and.Browns Ferry'Phase II (Hardware Inspections)

[2]reports.In addition, the TVA welding project final report[12]provides a summary for all the TVA Nuclear Power sites of the Welding Project activities, the Welding Project Plan and its execution, findings, root causes of deficiencies, and corrective actions.A.recurrence control plan for the TVA Nuclear Power Welding Program is also provided.TVA's responses to the employee concerns and other quality indicators was verified and evaluated by the NRC.Reinspections at the Browns Ferry Plant, documentation review, interviews with cognizant personnel are just some of the methods utilized by the NRC.

0 r~~t<<A l'IL S e TVA documented the following actions in the Browns Ferry Phase I and Phase II Weld Projects reports:[1,2]PHASE I: 1.Review of the FSAR and Project Unique Analysis Report (PUAR)to determine the welding related commitments.

2.Determination that welding related commitments are reflected in design output documents.

3.Assembling welding-related quality indicators by type..4.Review the welding related employee concerns and other welding related quality indicators for indications of programmatic deficiencies.

5..Determination of the adequacy of the OE program to produce documents'hat correctly depict and convey the welding commitments.

PHASE II: 1.Comprehensive review of specific and generic employee concerns.2.Independent audit by Bechtel Power Corporation (Bechtel)of the welding program implementation during construction and the current welding program implemented by Nuclear Operations.

3.Assessment by Aptech Engineering Service (Aptech)of weld quality using Preservice Inspection (PSI/ISI)data.4.Reinspection of welds at BFN by TVA inspectors overviewed by independent third party inspectors.

~~V1~tP p~~As part of their on-going review of TVA corrective actions and TVA response to the employee concerns, Brookhaven National Laboratory (BNL)was contracted by the NRC to provice technical expertise to assist the staff in resolving employee concerns regarding welding at the Browns Ferry Units.The contract under FIN 4001 Task Assignment 4 is specific to this technical evaluation report (TER)and provides the following work requirements:

1.Review and evaluate: a~a TVA's Browns Ferry Nuclear Site Specific Welding Subcategory Reports to include the original employee concerns and TVA's characterization and evaluation of these concerns and issues.b.Results of audits and inspections performed in Task Assignment No.2 and other NRC team inspection reports relating to welding at Browns Ferry Unit 2.c.Other available weld project evaluation reports.2.Prepare a TER.3.CONCERNS 63 Employee Concerns relating to the Browns Ferry Units were categorized by BNL into six groups.Five of these groups are considered to be essential elements for an effective welding program, with the programs end product a sound weld.Two concerns related to welding equipment were placed in the miscella-neous/one of a kind group.The input for the concern listing, categorization and evaluation came from the Employee Concerns Special Program, Volume 5, Welding Category, Subcategory Report 50100, Browns Ferry Nuclear Plant[10].The concerns were distributed among the group categories as follows:

1 r wl S sy I WELDING CONCERN CATEGORIZATION 1.Welding Procedures-2.Welder gualification/Training-3.Welding Inspection-4.Weld Design and Configuration-5.Filler Hetal Control-6.Miscellaneous/One of a Kind-1 Concerns ll Concerns 33 Concerns 0 Concerns 16 Concerns 2 Concerns li<<CONCERN NUMBER REPORT NUMBER RESPONDING TO CONCERN BRIEF DESCRIPTION OF CONCERNS 2850162005 EX-85-021-002-BFN IN-85-346-003-BFN IN-85-426-002-BFN IN-85-480-004-BFN IN-85-725-X14-BFN IN-85-725-X15-BFN EX-85-008-001-BFN IN-85-706'-001-BFN IN-86-158-006-BFN JLH-85-85-002-BFN HI-85-077-N17-BFN IN-85-458-001-BFN IN-86-019-001-BFN NS-85-001-001-BFN PH-85-040-001-BFN WI-85-013-003-BFN MI-85-030-007-BFN MI-85-030-007-BFN WI-85-030-008-BFN WI-85-041-006-BFN MI-85-041-008-BFN IN-85-007-001-BFN IN-85-134-002-BFN IN-85-406-003-BFN IN-85-476-004-BFN IN-85-981-001-BFN WP-25-BFN WP-03-BFN WP-03-BFN WP-03-BFN WP-03-BFN WP-03-BFN WP-03-BFN WP-07-BFN WP-07-BFN WP-07-BFN WP-24-BFN MP-03-BFN WP-02-BFN WP-02-BFN WP-02-BFN MP-02-BFN WP-02-BFN MP-02-BFN WP-02-BFN WP-02-BFN WP-02-BFN WP-02-BFN WP-04-BFN MP-04-BFN WP-04-BFN MP-06-BFN MP-06-BFN Repairs not to code Recertification/Dating Recertification/Dating Recertification/Dating Recertification/Dating Recertification/Dating Recertification/Dating Inexperienced Welders Inexperienced Welders Inexperienced Welders Muscle Shoals Welder Unqualified Welder BFN by NRC Inspection Through Paint Inspection Through Paint Inspection Through Paint Inspection Through Paint Inspection Through Paint Inspection Through Paint/Foreman Inspection Through Paint, No gC Inspection Through Paint Inspection Through Paint Inspection Through Paint No Inspection Tools No Inspection Tools No Inspection Tools Inadequate Training Inadequate Training I 1 t~'S CONCERN NUMBER REPORT NUMBER RESPONDING TO CONCERN BRIEF DESCRIPTION OF CONCERNS WI-85-041-002-BFN WI-85-081-007-BFN SQ-86-035-001-BFN SQ-86-035-002-BFN IN-85-282-002-BFN IN-85-299-003-BFN BE-85-001-001-BFN BE-85-001-002-BFN BF-85-001-001-BFN BF-85-001-002-BFN WB-85-001-001-BFN WB-85-001-002-BFN BF-85-019-001-BFN IN-85-406-002-BFN PH-85-012-X03-BFN XX-85-102-006-BFN XX-85-102-007-BFN XX-85-102-011-BFN EX-85-039-001-BFN IN-85-234-001-BFN IN-85-352-002-BFN IN-85-424-001-BFN IN-85-426-001-BFN IN-85-441-003-BFN IN-85-247-001-BFN IN-85-424-004-BFN IN-85-424-006-BFN IN-85-424-007-BFN IN-85-453-009-BFN IN-85-454-004-BFN IN-85-501-001-BFN WP-06-BFN WP-06-BFN MP-06-BFN WP-06-BFN WP-11-BFN WP-11-BFN WP-16-BFN WP-16-BFN WP-16-BFN WP-16-BFN WP-16-BFN MP-16-BFN WP-32-BFN WP-35-BFN WP-35-BFN MP-35-BFN WP-35-BFN MP-35-BFN WP-01-BFN WP-01-BFN WP-01-BFN WP-01-BFN WP-01-BFN WP-01-BFN WP-01-BFN MP-01-BFN MP-01-BFN MP-01-BFN MP-Ol-BFN WP-01-BFN WP-01-BFN Unquali.fied Inspectors Unqualified Inspectors Unqualified Inspectors Unqualified Inspectors Grinding of Welds Grinding of Welds/Shrinkage Foreman Performing Weld Inspection Foreman Performing Weld Inspection Foreman Performing Weld Inspection Foreman Performing Meld Inspection Foreman Performing Weld Inspection Foreman Performing Weld Inspection Hanger Welds Inadequate Prior to 1979, No Inspection Criteria Duct Work Inspections Visual Exam Inadequate Inspection Recording Requirements Inadequate Inspection Procedure No Portable Weld Rod Ovens No Portable Weld Rod Ovens No Portable Weld Rod Ovens No Portable Meld Rod Ovens No Portable Meld Rod Ovens No Portable Weld Rod Ovens Poor Quality Electrodes Meld Rod Issuance Questioned Weld Rod and Stub Control Weld Rod and Stub Control Welders Swapping Rod Welders Swapping Rod Uncontrolled Weld Rod in Building e V r9.S pl l+1~1 CONCERN NUHBER REPORT NUMBER RESPONDING TO CONCERN BRIEF DESCRIPTION OF CONCERNS IN-85-672-003-BFN IN-86-047-001-BFN MI-85-053-004-BFN MP-01-BFN WP-01-BFN WP-01-BFN Meld Rod Return Procedure Weld Rod Return Procedure Meld Rod Traceability IN-85-247-002-BFN IN-85-303-001-BFN WP-13-BFN MP-13-BFN Welding Machines Inadequate Welding Machines Inadequate

3.2 Characterization

of Issues TVA provides a description.of issues in their subcategory report 50100[10].The characterization of issues was derived from 63 employee concerns of t which 7 were specific to BFN, 49 specific to WBN, 3 specific to BLN, 3 specific to SAN and 1.:non plant specific.TVA then divided the employee concerns into 13 similar issues which were investigated by the Melding Project, guality Technology Company and/or the Nuclear Safety Review Staff.Each of these 13 issues was addressed by a Welding Project Evaluation Report[4]which was then.provided to the USNRC as a portion of the weld project effort[10].3.3 Descri tion of Issues (Melding Project Evaluation Reports)3.3.1 Control of Welding Filler Haterial 3.3.2 Inspection of Welds Through Carbo-Zinc Primer 3.3.3 Welder gualification and Continuity

3.3.4 Availability

of Inspection Tools 3.3.5 Inspector Training and Certification I f r S'>>4

3.3.7 Surface

Grinding of Welds 3.3.8 Adequacy of Welding Equipment 3.3.9 Structural Steel Preweld Inspection 3.3.10 Welder gualification 3.3.11 Meld Repair Not Meeting ASHE Code Requirements 3.3.12 Structural Support Melds 3.3.13 Weld Inspection Procedures 4.EVALUATION OF EMPLOYEE CONCERNS This secti'on of the report will list the employee concerns for each of the six BNL/NRC welding concern categories, a brief description of the concern and a TVA description of the issues as it applies to the welding concern category.A BNL evaluation of the concern/issue will also be included in this section.4.1 Cate or 1-Weldin Procedures One concern was found to be specific to this category 2850162005.

ISSUE: Weld repairs such as overlays, patches and Furmanite (viscous fluid sealant)not in accordance with the ASHE Code.TVA COMMENTS: Overlay welding is an acceptable.method of making temporary repairs to correct for intergranular stress corrosion cracking.TVA's plan for use of overlays was approved by the USNRC.

4 CV I IC Temporary mechanical and welded patches are used to contain leakage.They do not substitute for permanent repairs in accordance with applicable codes.This issue has been addressed by Weld Project Evaluation Report WP-25-BFN.Use of viscous fluid sealant is outside the scope of the Weld Project, and has been addressed by Subcategory 30800.BNL EVALUATION:

BNL is in concurrence with the use of temporary repairs (weld overlay, patches, etc.)as outlined in WP-25-BFN with appro-priate engineering review and concurrence is an acceptable practice.An example is weld overlays which are an integral part of the maintenance programs and under the normal controlled conditions for applying same, constitute an acceptable temporary fix in mitigation of IGSCC.Eleven concerns were addressed by WP-03-BFN, WP-07-BFN and WP-24-BFN.

The concerns, issues, and TVA evaluation was as follows: CONCERN ISSUES TVA COMMENTS JHL-85-002 Welders from Huscle Shoals may not have had the appropriate number of bend tests.All affected welders at BFN were qualified to the requirements of ASHE Section IX.This issue has been addressed by Weld Project Evaluation Report WP-24-BFN.

rI I jl e~a+/, I'll CONCERN ISSUES TVA COMMENTS IN-85-725-X14 IN-85-725-X15 The possibility exists that one welder could weld or complete a test plate for another welder.No one except the Meld Test Supervisor is allowed to enter the test booth while a welder is being tested.This issue has been addressed by Weld Project Evaluation Report MP-03-BFN.

HI-85-077-N17 Melding by a uncertified.welder.Initiated by USNRC.There have been isolated instances of welders operating outside their limits of qualification.

These instances were identified and corrected by the ongoing guality Assurance activities.

This issue has been addressed by Weld Project Evaluation Report WP-03-BFN.

EX-85-021-002 IN-85-346-003 IN-85-426-002 Inadequate basis for welders qualification continuity updates.The basis for qualification continuity updates satisfies requirements and parallels industry practice.This issue has been addressed by Meld Project Evaluation Report MP-03-BFN.

IN-85-480-004 Personnel whose duties do not require welding continue to have their qualification continuity updated.Continuation of supervisory personnel qualifications is an acceptable practice.This issue has been addressed by Weld Project Evaluation Report WP-03-BFN.

~~t 4f$S 1>>

CONCERN ISSUES TVA COHHENTS EX-85-008-001 IN-85-706-001 IN-86-158-006 gualification and experience of Subjourneymen.

Adequacy of TVA Welder Training Program.Subjouneymen are utilized in accordance with the applicable labor agreement and good management practices.

This issue has been addressed by Weld Project Evaluation Report WP-07-BFN.

Welders are tested and qualified.'in accordance with AWS Dl.l and ASHE Section IX.This issue has been addressed by Weld Project Evaluation Report WP-07-BFN.

BNL EVALUATION:

TVA Welding Project Evaluation Reports WP-03-BFN and WP-07-BFN adequately address all the issues identified by the concerns.This conclusion is based on the TVA commitment of requalification of welders as appropriate.

4.3 Cate or 3-Weldin Ins ecti'on Some 31 concerns were considered appropriate to this category.Weld Project Evaluation Reports WP-02-BFN, WP-06-BFN, WP-16-BFN, WP-32-BFN and MP-35-BFN provide TVA evaluations, concerns, and issues: CONCERN ISSUES TVA COHHENTS IN-85-007-001 IN-85-134-002 IN-85-406-003 Availability of inspection tools.Inspection tools were available throughout construction and operation.

10 J I W~p.'x tl I~tr' CONCERN ISSUES TVA COMMENTS This issue has been addressed by Weld Project Evaluation Report WP-04-BFN.

IN-85-476-004 IN-85-981-001 SQN-86-035-001 SQN-86-035-002 WI-85-041-002 WI-85-081-007 Qualification of Welding Inspectors.

Topical Report (TVA-TR-75-lA)not in compliance with ANSI N45.2.6.We3ding Inspectors are qualified in accordance with the Nuclear Quality'Assurance Manual.Welding Inspectors are qualified and certified using SNT-TC-IA,~as a guide, rather than ANSI N45.2.6.Appropriate exceptions are made in the Topical Report (TVA-TR-75-1A).

This issue has been addressed by Weld Project Evaluation Report WP-06-BFN.

Many welds and hangers are questionable with respect to adequacy.Original welds would not meet today'requirements.

This issue is factual in that some of the support welds do not meet the visual inspection criteria.This issue has been addressed by Weld Project Evaluation Report WP-32-BFN.

IN-85-406-002 PH-85-012-X03 XX-85-102-006 XX-85-102-007 XX-85-102-011 No specific inspection criteria prior to 1979.Welding and brazing inspection of safety related ductwork was deleted from the QA program.NDE Inspectors can only write a Notice of Inspec-tion for inservice related defects.Preservice defects can only be identified by a Maintenance Request.During initial construction, direct application of the codes provided all of the necessary inspection criteria.At the time of commitment to 10CFR50 Appendix B, a procedure system was in place and provided all of the necessary inspection criteria.HVAC at BFN was fabricated and erected using mechanical means.When welding modifi cations were specified, an'appropriate procedure for inspection was emplaced.11

~*'

CONCERN ISSUES TVA COMMENTS.This Notice of Indication is used to report defects identified within the defined scope of an inspec-tion, inservice or preservice.

The Maintenance Request is used to report observations identified outside the defined scope of an inspection.

This system is in compliance with the Nuclear guality Assurance Manual.This issue has been addressed by Weld Project Evaluation Report WP-35-BFN.

IN-85-282-002 Surface grinding of welds.Shrinkage of stainless steel butt joints.Surface grinding and shrinkage.

Surface grinding of welds is provided for by the ASHE,'ANSI and AWS codes.Some shrinkage is inherent in girth butt welded joints in stainless steels.Heat input during welding is controlled by adherence to approved welding procedures.

This issue has been addressed by Weld Project Evaluation Report WP-11-BFN.

r BEM-85-001-001 BEH-85-001-002 BFH'-85-001-001 BFH-85-001-002 WBH-85-001-001 WBH-85-001-002 WI-85-030-007 Foremen perform preweld inspections, which is not in accordance with the Topical Report (TVA-TR-75-1A), ANSI N45.2.5 and AWS D1.1.AWS Dl.l allows preweld activity examinations to be on a sampling basis.Browns Ferry procedures and specifications mandated surveillance programs of all welding activities.

Practice at Browns Ferry does not violate the TVA Topical Report (TVA-TR-75-IA) or ANSI N45.2.5.12 4 4~r1++)I~I'Ek

~~,~CONCERN ISSUES TVA COMHENTS IN-85-458-001 IN-86-019-001 NS-85-001-001 PH-85-040-001 WI-85-013-003 WI-85-030-007 WI-85-030-008 WI-85-041-006 WI-85-041-008 The Process Specification permitted inspection of AWS welds through coating of carbo-zinc primer.Thousands of welds may have been inspected through primer.There is no documentation to show which welds were involved.Inspectors did not under-stand the coating thickness limit for inspecting primed welds.This issue has been addressed by MeldProject Evaluation Report WP-16-BFN.

'The Process Specification in question was site unique for Watts Bar, and was never implemented at Browns Ferry.The BFN specifications and procedures meet the requirements of ANSI/AWS Dl.l.This issue has been addressed by Meld Project Evaluation Report WP-02-BFN.

BNL EVALUATION:

BNL, after careful consideration of the issues identified, consider the concerns with one exception to be acceptably addressed.

It is, however, not clear in the Weld Project response to concern BFN-85-019-001 what the scope of the problem is and what corrective actions are planned.BNL cannot at this time with the information at hand provide constructive comment.We are in concurrence with TVA that in order to come to an intelligent conclusion, additional weld evaluation data is needed.4.4 Cate or 4-Desi n and Confi uration There were no concerns found to be specific for this category.13 P y'4 4.5 Cate or 5-Filler Hetal Control Sixteen filler metal control concerns comprising four issues were addressed by the Weld Project Employee Concern Evaluation Report WP-01-BFN.

The concerns, issues, Weld Project Evaluation Report, and TVA response is as follows: CONCERN ISSUES TVA COHHENTS EX-85-039-001 IN-85-234-001 IN-85-352-002 IN-85-424-001 IN-85-426-001 IN-85-441-003 Lack of portable rod ovens to protect coated electrodes from moisture absorption.

The Browns Ferry program for control of welding filler material meets the requirements of ANSI/AWS Dl.l Section 4, ASHE Section III NB-4000 and ASHE Section XI IWB-4000.IN-85-424-004 IN-85-424-006 IN-85-424-007 IN-85-453-009 IN-85-454-004 IN-85-501-001 IN-85-672-003 IN-85-047-001 IN-85-053-004 Inadequate control of weld rod.Administrative practices for return of filler material.The Browns Ferry program for control of welding filler material meets the requirements of ANSI/AWS Dl.1 Section 4, ASHE Section III NB-4000 and ASHE Section XI IWB-4000.IN-85-247-001 Poor quality E7018 electrodes.

The quality of the electrodes purchased meets the requirements of ASHE Section II and III.These issues have been addressed by Weld Project EvaluationReportWP-Ol-BFN.

BNL EVALUATION:

BNL provides the following comments: "Why do we want to use portable ovens in.the field, and what is the potential effect if we don't7" The primary reason for use of weld rod ovens is to prevent moisture pickup on the weld rod, which could cause hydrogen delayed cracking of carbon and alloy steels.Notoriously, this type of cracking will make 14 8 h~E're g, P pE'4 I~I Ak 1leal~A'44 e itself known visually from a few'inutes to a few days after the weld is made.The results of the reinspection and PSI/ISI programs showed no evidence of cracked welds being found, so this is probably not a problem at BFN.Portable rod ovens are used at BFN for E-80XX, E-90XX, E-100XX, and E-110XX electrodes which are used when welding alloy steels.7018 electrodes with a concentricity problem was identified at Watts Bar and were returned to the manufacturer.

Welding materials used at BFN are: "purchased in accordance with the ASME Boiler and Pressure Vessel Code,Section II, Part C, SFA Specifications and the additional requirements of ASME Section III, Subsection NB.Tests must be performed in accordance with SFA specifications on each heat and lot number of weld filler material manufactured to assure acceptability for use.t BNL believes that the utility did an adequate job of answering the concerns., 4.6 Cate or 6-Miscellaneous One of a Kind There were a total of two concerns in this category: CONCERN ISSUES TVA COMMENTS IN-85-247-002 IN-85-303-001 Suitability of welding equipment.

The Lincoln IDEALARC TIG 300 welding machine was used at Browns Ferry.This machine features remote current adjustment, soft start, and current output range of two through 375 amperes.This issue has been addressed by Weld Project EvaluationReportWP-13-BFN.

15 P I r CI g1'4 4 Iu k~, II I BNL is in concurrence with the TVA technical response in Meld Project Report WP-13-BFN.

It should also be noted WP-13-BFN states Browns Ferry did not use the types of welding equipment addressed by the issues.The concerns originated at Watts Bar Nuclear Plant, and were generical)y applied to Browns Ferry Nuclear Plant.5.NRC STAFF INSPECTIONS NRC Staff Program Reviews and Inspections as a result of TVA Melding Concerns by the Office of Special Projects (OSP), Region II, Office of Nuclear Reactor Regulation (NRR)with technical support provided by Brookhaven National Laboratory and NRC contracted consultants has been an on-going effort since early 1986.The character of these reviews and inspections was one of daily exchanges of inspection findings between the various team members.These discussions provided additional

'insight'nto potential program or hardware weaknesses to the team members participating in the various discipline t inspections.

BNL participated in all of the NRC inspections listed[4,5,6]in this report." The evaluations and comments provided in this task section are the result of this"hands on" participation in addition to review of NRC/TVA communications and inspection reports.5.1 Ins ection Re ort Nos.: 50-259 86-34 50-260 86-34 and 50-296 86-34 (TORUS MODIFICATIONS)

This inspection was conducted by th'e USNRC Region II with special emphasis in the areas of modifications inside the TORUS including review of management controls, engineering drawings, work procedures and work plans.Completed welds were also inspected for adequacy and compliance with applicable code and regulatory requirements.

One violation was identified which dealt with welder qualification records lacking thickness range information.

TVA, through an ASHE Section IX Code Interpretation, provided a satisfactory response to the violation.

16 k P t v~'j.~<iR>>~k CI Ai~9 Wtl' BNL EVALUATION:

In general, the inspected welds were found to comply with governing code, specification and regulatory requirements.

No new or significant issues were identified as a result of this inspection.

In addition, the TORUS Hodification Program[4]did not exhibit any of the earlier quality, inspection or welding problems identified with the original construction employee concern issues.5.2 Ins ection Re ort Nos: 50-259 87-19 50-260 87-19 and 50-296 87-19 (TVA Phase I)The objective of this inspection was to review and assess the adequacy and validity of the information reported in TVA's Phase I Report.4 The NRC inspection team selected some 52 FSAR commitment packages, nondestructive examination specifications, NDE procedures, personnel t qualification records and engineering calculations for review.'rk The executive summary of the NRC inspection report provides the following inspection team conclusions: "The NRC team noted no significant deviations from the results reported in TVA's Phase I report.The approach outlined in the report contained the elements needed to determine whether TVA's licensing commitments have been properly translated into the governing specifications and drawings.Several program weaknesses were identified as a result of the NRC team review as follows: "(I)TVA had performed very few reviews to determine how licensing commitments were translated into the design documents before 1981.The sample selection for TVA's Phase II inspection

'effort must include an adequate number of pre-1981 fabricated welds to provide the basis required to make those determinations.

17 I

(~)The NRC team found it hard to trace the origin of the allowable values used for the structural component welding calculations.

The engineering calculations must show clearly the origin of the allowable stress values used in the individual calculations.

(3)The NRC team identified several instances in which the drawings did not provide a traceable path to verify that the design output documents accurately reflect the commitments TVA made in the plants Final Safety Analysis Report (FSAR)to meet the applicable construction codes.TVA's Phase II report must identify those items and provide adequate discussions about whether or not the installed hardware meets the requirements of the applicable construction codes.(4)The NRC team identified several instances in which the FSAR commitments were not reflected in the actual application.

TVA's Phase II report must identify those cases and indicate clearly whether the hardware is deficient or whether the FSAR must be revise'd'to reflect actual field conditions.

(5)The NRC team found that the Phase I report included very few or no examples for certain welding activities, such as welding on I/2-inch instrument pipe and welding on.-heating, ventilation, and air-conditioning supports.The sample selection for TVA's Phase II inspection effort must include an adequate number of I/2-inch pipe and HVAC support welds to provide the required basis to assess these two areas." BNL EVALUATION:

BNL reviewers are in concurrence with the inspection team conclusions.

TVA in the Phase II Browns Ferry Welding Project Report Section 5.0 Response[2]adequately addresses the Phase I program weak points with appropriate corrective actions.18

~)I rJ I' e 5.3'Ins ection Re ort Nos.: 50-259 88-13 50-260 88-13 and 50-296 88-13 (TVA Phase II)The inspection effort focused primarily on the information contained in the TVA Meld Project Phase II Report.The inspection encompassed (1)review of open items from the April Phase I NRC team inspection; (2)structural welding;(3)pipe, spiral duct and instrument welding;(4)non-destructive examination; (5)review of engineering calculations; and (6)review of operating experience as related to welding problems.The NRC inspection team reviewed some 171 component document packages and performed field inspection verifications of some 166 components and individual welds.The NRC welding team noted"no significant deviations from the results reported in TVA's Phase II Report," and that the NRC's findings are in general agreement with the TVA's welding project Phase II Report.The NRC inspection team, as'result of the inspection, noted six areas which TVA must address.The six areas which required improvement as provided t by the welding team inspection report were:!"(1)Data accumulated during the United Engineers and Constructors (UEKC)Cable Tray Support Interim gualification Malkdown indicated that the walkdown did not verify or document weld size, length, or location for welds connecting the support to the supporting structure or for welds connecting support members together.TVA needs to justify why weld size, length, and location are not needed to determine suitability for service of cable tray supports.(2)Data accumulated during the Electrical Conduit and Conduit Support Walkdown indicated that the walkdown verified weld length and location but not weld size.TVA needs to justify why weld size is not needed to determine suitability for service of conduit support.(3)Three of the heating, ventilation and air conditioning (HVAC)supports inspected by the NRC team were found to have one or more deviant weld conditions.

The supports were inspected by Stone and Webster Engineering Corporation (SWEC)for work performed under the 19 p f"~%1 as 4g,

'~~1 4 , t scope of the BFN HVAC supports reevaluation program.TVA needs to increase its quality assurance surveillance in this area to ensure that SWEC properly implements the welding inspection requirements of the HVAC program.(4)Six mechanical weld configurations were incorrectly reported in the Phase II Report, two welds were incorrectly documented, and one weld was rejectable for excessive weld reinforcement.

In addition, the material thickness data were not reported for a number of emergency equipment cooling water (EECW)welds.TVA needs to revise its Phase II Report to reflect the actual weld conditions.

(5)Two welds, TRHRS-2-13 and TRHRS-3-18, were found to have indications of microbiologically induced corrosion (HIC).TVA needs to evaluate the effects of HIC on these welds.(6)Approximately one third of the engineering packages reviewed contained one or more mathematical inaccuracies.

TVA stated that a"large turnover of calculation preparers and checkers has taken place during the preparation of these calculations.

TVA needs to review this finding for generic applicability to its ongoing BFN calculation program and ensure that engineering calculations are properly prepared and checked and that they are mathematically accurate." TVA in subsequent communications

[7,8,9]with the NRC staff addressed the Phase II program deficiencies.

The communications provided technical responses, procedural changes, training recommendations, and other corrective actions such as:the implementation of special programs outside the scope of the TVA Welding project.BNL EVALUATION:

BNL is in concurrence with the NRC staff inspection findings and conclusions.

TVA's efforts and responses[7,8,9]met all the Welding Project Phase II t.[2]requirements and commitments.

No new or significant employee concern issues were identified as a result of the Phase II[2]effort.20

~p'i(~+J<~g 6.TVA WELDING PROJECT FINAL REPORT VOLUME VIII The TVA Welding Project final report summarizes the following recom-mendations and actions:~Weld project activities as related to the safety related welding program adequacy assessment.

~The Weld Project Plan execution.

~The findings and root cause of deficiencies.

~Corrective actions.~A recurrence control plan for the TVA.~Nuclear power welding program.V"1 This Welding Project Report Volume VIII provides a summary which applies to the Sequoyah NPS, Browns Ferry NPS, Bellefonte NPS, and the Watts Bar NPS.In addition, the evaluation and commentary of program implementation for the Sequoyah NPS and Browns Ferry NPS are provided basically as one subject.It should be noted that BNL's review and comments relative to this report are directed towards the issues identified as pertinent to the Browns Ferry NPS.BNL under contract with the NRC provided a technical evaluation report[13]related to the welding concern program for TVA's Sequoyah Units 1 and 2 in August of 1986.TVA Summar of Corrective Actions TVA in Section 5.0 of the Melding Project Final Report Volume'VII[ll]provides the following summary of corrective actions which are the result of TVA Welding Program Assessment:

21 f.CW Hardware Welds or weldments determined to be deviant from applicable licensing requirements have been or will be dispositioned by one of the following methods: Rework or repair to meet applicable licensing requirements.

Justification of acceptance of discrepant conditions by analytical demonstration that these conditions had no effect on the suitability-for-service of the weld or component.

~Justifiable exceptions to the FSAR.-The method of, treatment of discrepant conditions was determined both by the nature of the discrepancy and the provisions of the governing code or standard.Pro rammatic The WP assessment of the welding program also disclosed the need for improvements in several of the programmatic aspects of the TVA welding program such as design output, site procedures, welding-related training, and communication.

Recommendations made by the WP for these improvements are'ummarized below: Indoctrinate and provide ongoing training to engineers, designers, supervisors, craft, and managers in the programmatic aspects of the TVA welding program.Provide necessary action to improve communication among supervisors, engineers, inspectors, and craftsmen as individuals and as groups.Improve FSARs,.specifications, procedures, and drawings to ensure that all technical requirements are included in a clear and concise manner.22 J rfg"

~The TVA trending program should be evaluated and revised, as necessary, so that it is effective in stimulating effective preventive actions for recurring nonconformances.

e Incorporate verification of weld configuration (size, length, and location)as appropriate during walkdowns, inspections, design modifications, etc.TVA also provides the following corporate commitments in Enclosure 2 of the report: "(1)TVA will consolidate the TVA nuclear welding program into corporate standards to provide a unified program by January 15, 1990.A single welding program will be established for construction, modifications,'maintenance, engineering, and quality assurance which includes applicable central staffs and all sites.This single welding program will address the Melding Project Final Report, the Welding Project plant specific Phase I and II Report recommen-dations, quality assurance program requirements, essential program elements, and line organization monitoring requirements.

Weld Program Coordination Team (MPCT)concurrence for this program will be obtained.Implementing procedures will be developed and issued separately in accordance with the TVA Corporate Standards program.(2)Nuclear guality Assurance (NgA)and WPCT will develop and conduct a Program Modification Effectiveness Evaluation (PHEE)six months after implementation of the corporate standard.This evaluation will be a formal, structured, and in-depth evaluation involving all organizations and locations which are associated with the TVA nuclear welding program." CONCLUSION:

TVA appears to have addressed all...the welding issues with appropriate corrective actions and aggressive corporate commitments which, if properly implemented, should provide a good welding program.23 4 C 0 , r$rf 4 TVA's actions provide assurance the five essential elements (welding procedures, welder qualification/training, welding inspection, weld design and configuration and filler metal control)needed to produce a sound weld have been properly addressed.

7.REFERENCES 1.Browns Ferry Phase I review.2.Browns Ferry Phase II review.3.Welding Project (WP)Employee Concern Evaluation Reports.MP-Ol-BFN-Control of Welding Filler Material at Browns Ferry Nuclear Plant.WP-02-BFN-Inspection of Welds Through.Carbo-Zinc Primer at Browns Ferry Nuclear Plant.WP-03-BFN-Welder gualification and Continuity at Browns Ferry Nuclear Plant.WP-04-BFN-Inspection Tools Browns Ferry Nuclear Plant.WP-06-BFN-Inspector Training and Certification at Browns Ferry Nuclear Plant.WP-07-BFN-Welder Training and Experience at Browns Ferry Nuclear Plant.WP-11-BFN-Surface Grinding of Welds at'Browns Ferry Nuclear Plant.WP-13-BFN-Welding Equipment 24 I 1'L1 1 4 4't\)Q, z rt WP-16-BFN-Structural Steel Preweld Inspections at Browns Ferry Nuclear Plant.WP-24-BFN-Welder gualification at Browns Ferry Nuclear Plant.WP-25-BFN-Meld Repairs Not Heeting ASHE Code Requirements at Browns Ferry Nuclear Plant.WP-32-BFN-Adequacy of Structural Support Welds at Browns Ferry Nuclear Plant.MP-35-BFN-Weld Inspection Procedures at Browns Ferry Nuclear Plant.4.NRC Region II Inspection Report Nos.50-259/86-34, 50-260/86-34 and 50-296/86-34

-10/6-10/86

-(TORUS Hodifications).

5.NRC Special Projects Welding Team Inspection Report Nos.50-259/87-19, 50-260/87-19 and 50-296/87-19

-4/20-24/87 (TVA Phase I).6.NRC Special Projects Welding Team Inspection Report Nos.50-259/88-13, 50-260/88-13 and 50-296/88-13

-5/16-27 and 6/6-10/88 (TVA Phase II).7.Request for additional information Phase II Welding Project Report (TAC 62262)4/19/88.8.Response to request for additional information

-Phase II Welding Project Report (TAC 62252)6/24/88.9.Response to weld project inspection items.NRC Inspection Report Nos.50-259/88-13, 50-260/88-13 and 50-296/88-13

-10/3/88.

h)f~tl

'0.TVA Employee Concerns Special Program, Volume 5 Welding Category, Subcategory Report 50100 Browns Ferry Nuclear Plant.ll.TVA Welding Project Final Report, Volume VIII-8/25/89.12.TVA Nuclear Performance Plan, Volume III, Rev.1, Section 6.0, Plant Welding Program.13.Technical Evaluation Report (TER)Related to the Welding Concern Program at TVA's Sequoyah Units I and II, Brookhaven National Laboratory, August 1986.26

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