ML20198F434
| ML20198F434 | |
| Person / Time | |
|---|---|
| Issue date: | 11/13/1985 |
| From: | Burns T, Naidu K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20198F409 | List: |
| References | |
| REF-QA-99901022 99901022-85-01, 99901022-85-1, NUDOCS 8511140354 | |
| Download: ML20198F434 (8) | |
Text
O ORGANIZATION: HATCH INCORPORATED EL PAS 0, TEXAS REPORT INSPECTION INSPECTION NO.: 99901022/85-01 DATE(S): June 12-14, 1985 ON-SITE HOURS: 44 CORRESPONDENCE ADDRESS: Hatch Incorporated Mr. A. E. Hatch, President 1206 Myrtle Avenue El Paso, Texas 79901 ORGANIZATIONAL CONTACT: Mr. Edward Taylor TELEPHONE NUMBER: 915-542-1991 PRINCIPAL PRODUCT: Electrical Switchgear Panels and Main Control Boards.
NUCLEAR INDUSTRY ACTIVITY: Less than 1%.
n ASSIGNED INSPECTOR:
dNe n l t, /if K. R. Naidu OTHER INSPECTORS: J. C. Harper T. F. Burrs, Broo - ve tional Laboratory, (BNL)
APPROVED BY: st o' E. W. Merschof#,' Chief, RIS INSPECTION BASES AND SCOPE:
A. BASES: 10 CFR Part 21 and 10 CFR 50 Appendix B.
B. SCOPE: Evaluate the implementation of the Hatch Quality Assurance Program.
I l
i PLANT SITE APPLICABILITY: Dresden 2 and 3, 50-237, 50-249; Quad Cities 1 and 2, 50-254, 50-265; South Texas Project, 50-498. l 8511140354 851113 l l
PDR GA999 EMVHATCH 99901022 PDR
ORGANI7.ATION: HATCH INCORPORATED EL PAS 0, TEXAS REPORT INSPECTION l NO.: 99901022-85/01 RESULTS: PAGE 2 of 8 A. Inspection Issues Hatch Incorporated (HI) manufactured safety reiated electrical cabinets for Quad Cities 1/2 and Dresden 2/3 nuclear power stations, both of which are owned by Commonwealth Edison Company (CECO), Chicago. In May 1985, receipt inspections at Quad Cities identified discrepancies in weld documentation of Hatch supplied equipment. Specifically, personnel observed that the Gas Metal Arc Welding (GMAW) process was used to weld portions of the panels, however, the documents indicated that Shielded Metal Arc Welding (SMAW) was performed utilizing Welding Procedure Specifications (WPSs) qualified to American Welding Society (AWS) D-1.1. HI admitted to Ceco that unauthorized GMAW welds were performed on the cabinets without an approved WPSs. HI subsequently developed GMAW procedures which were approved by Sargent & Lundy, the Architect Engineer for CECO.
The purpose of this inspection was to determine the adequacy of the implementation of HI's quality assurance program.
B. Background Information Hatch Incorporated (HI) manufactures Main Generator Control Panels, Direct Current (DC) distribution panels, transfer feeder panels and various panels for installation at power plants, chemical plants and nuclear generating stations. HI also manufactured electrical panels for the Department of Energy for installation at test sites in Nevada.
C. Inspection Findings Nonconformances
- 1. 10 CFR 50 Appendix B Criterion IX states in part " Measures shall be established to assure that special processes, including welding, ... are controlled and accomplished using qualified procedures in accordance with applicable codes, standards specification, criteria and other special requirements."
The HI QC manual requires all welding activities associated with the construction of safety related panels to comply with AWS D-1.1.
The following were contrary to the above:
- a. Weld Procedure Specifications (WPSs) No. I and 2 were qualified to AWS D-1.1 (which addresses welding of base >
metals greater than 0.125 inches) to Weld 10-14 gauge sheet
ORGANIZATION: HATCH INCORPORATED EL PAS 0, TEXAS REPORT INSPECTION NO.: 99901022-85/01 RESULTS: PAGE 3 of 8 metal (thickness less than 0.125 inch) .instead of AWS D-1.3 which is pertinent to welding base metals less than 0.125 thick.
- b. For the Gas Metal Arc Welding process, AWS D-1.1 specifies that the maximum thickness permitted to be welded is that which is qualified by the Weld Procedure Specification (WPS).
Contrary to this specification, WPSs No. 3, 4 and 5 have been approved without specifying the weld thickness.
- c. AWS D-1.1, does not recognize welding nuts to sheet metal.
Contrary to this, WPS No. 6 has been qualified and approved to Weld ASTM A354 nuts to ASTM A366 sheet metal.
- d. One unqualified welder was permitted to perform welding.
- 2. Criterion V of 10 CFR 50 Appendix B states in part " Activities affecting quality shall be prescribed by documented instructions, procedures or drawings...shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished,
- a. Contrary to the above, Hatch Incorporcted (HI) did not establish a procedure to crimp lugs or define the acceptance criteria for inspecting the crimped connections.
- b. Contrary to the above, HI did not establish a procedure for automatically welding threaded studs to sheet metal to meet the requirements of Part 4, Section F of AWS D-1.1.
D. Other Inspection Findings and Comments
- 1. Review of Welding Procedures HI uses welding procedures to weld cabinets. These cabinets (or panels) are fabri ated from sheet steel, angic iron, flat bar and channel. Prequalified fillet weld configurations meeting AWS D-1.1 are used extensively. Seal, groove, and seam welds are used in selected sections of the cabinet. Threaded studs are auto-matically welded with a stud welding gun inside the cabinets to support sub-panel assemblies on which electric starters, con-tactors, relays, and other devices are mounted. HI used two WPSs to weld safety related cabinets intended for installation at Quad Cities. One of the cabinets successfully withstood a shake table test at Wyle Laboratories.
I
~
ORGANIZATION: HATCH INCORPORATED EL PAS 0, TEXAS REPORT INSPECTION N0.: 99901022-85/01 RESULTS: PAGE 4 of 8 When these cabinets arrived at Quad Cities, receipt inspections indentifed that the Gas Metal Arc Welding (GMAW) process was used to weld certain sections of the cabinet. HI's welding documentation indicated that the Shield Metal Arc Welding (SMAW) process was qualified to be used. The HI QA manager stated that GMAW was used without the supervisor's knowledge, and that QC failed to discover its unauthorized use. HI belatedly developed four WPSs (#3, 4, 5 and 6) to address GMAW. Sargent & Lundy, the Architect Engineer for Commonwealth Edison, approved these WPS in May, 1985.
- a. The NRC inspectors reviewed HI WPSs 1 and 2 which were prequalified to AWS D-1.1. AWS D-1.1 has specific require-ments regarding the variables that must be addressed in order that the WPSs be considered as "prequalified status".
These variables are addressed in Appendix E, Part A, titled
" Joint Welding Procedure Requirements" states in part "... Table
, El covers the mandatory requirements for according prequalified status to joint welding procedures (see 5.1.1). Table E2 covers the provision of the code that may be modified when the joint welding procedure is qualified by tests (see 5.2)...."
The review of WPS 1 and 2 indicated the following:
(1) The WPSs have been used to weld sheet metal (gauges 11-14) which are less than 0.125 inch thick. AWS D-1.1 paragraph 1.2.2 recommends the use of AWS D-1.3 for thickness less than 0.125". (gauge to inches relationship is 11 = 0.119, 12 = 0.104, 14 = .074).
< (2) For the Preheat /Interpass entry, the WPSs state "below 30 F". The WPSs would be in compliance to AWS D-1.1 paragraph 4.2 if the statement was revised to read "when the ambient temperature is below 32 F, the metals shall be preheated to 70 F before welding".
(3) The WPSs state that post weld heat treatment (PWHT) will be by natural cooling. The WPSs would be in k
e - - - - - -
o ORGANIZATION: HATCH INCORPORATED EL PASO, TEXAS REPORT INSPECTION NO.: 99901022-85/01 RESULTS: PAGE 5 of 8 compliance to AWS D-1.1 if the statement was "none" or "not applicable". FWHT is not required for welds on cabinets.
(4) The WPSs did not show the weld joint configuration.
Prequalified WPS should have one of the joint configurations illustrated in AWS D-1.1, Part C of section 2.
(5) The WPSs do not expressly state whether the weld progression was from upward to downward or vice versa in vertical welding. Instead, the WPS stated progression as " forehand". This description would not be applicable for the " flat", " horizontal" or
" overhead" positions of welding.
- b. The NRC inspectors reviewed HI WPSs 3, 4 and 5 for Gas Metal Arc Welding (GMAW) and determined that the following do not comply with the AWS D-1.1 code.
(1) The maximum thickness permitted to be welded was not specified. In GMAW the maximum thickness that can be welded should be specified by avalified WPSs.
(2) The WPSs do not state the position in which welding was performed to qualify the WPSs. Paragraph 5.5.2.3 (11) considers a change in the position in which i welding is done to be an essential change.
l
[ (3) The WPSs incorrectly address the weld progression j and do not meet paragraph 5.5.2.3(15).
l l c. Items a(1) and b(1) above were identified as nonconformances 1.a. and 1.b., respectively,
- d. The NRC inspectors reviewed WPS #6 which was qualified to l weld a ASTM A354 nut to ASTM A366 sheet metal. AWS D-1.1 l does not recognize welding nuts to sheet metal.
- e. Threaded studs were welded to cabinets with an automatic l
Nelson Stud gun without a written procedure. Section 4, Part F of the AWS D-1.1 specifies the requirements for stud welding and provides acceptance criteria for inspections.
The inspectors informed HI that failure to establish a procedure to perform safety related welding was an item of l
a ORGdNIZATION: HATCH INCORPORATED EL PAS 0, TEXAS REFORT INSPECTION N0.: 99901022-85/01 RESULTS: PAGE 6 of 8 nonconformance contrary to Criterion V of 10 CFR Appendix B.
- 2. Review of Welder Qualification Records
- a. 125 Volt DC Distribution Panels The above panels are intended for installation in the South Texas Nuclear Power Station. From the review of shop travelers and production drawings, the inspectors determined that six welders performed welding on the cabinets. Review of the welder qualification records indicated that El Paso Testing Laboratories (EPTL) certified the welders in 1977.
Five of the six certifications were acceptable. One welder was qualified to weld with an E-6010 type electrode. Records indicate that he welded with an E-7018 type electrode. This is not acceptable per Paragraph 5.16.3 of AWS D-1.1, which states "A welder who is qualified for SMAW with an electrode identified in the following table shall be considered quali-fied to weld or tack weld with any other electrode in the same group designation and with any electrode listed in a numerically lower group designation."
Group Designation AWS Electrode Classification F4 EXX15, EXX16, EXX18 F3 EXX10, EXX11 F2 EXX12, EXX13, EXX14 Nonconformance 1.d. was identified in this area.
- b. Transfer Stations and Transfer Feeder Panels The above panels are intended for installation in Dresden Units 2 and 3 and Quad Cities. The inspectors determined from review of the shop traveler and production drawings that two welders performed welding on the panels. Review of the welder qualification records indicated that EPTL certified the welders. The certifications, dated August 1977, indicated that a Manual Shielded Metal Arc Process was used to weld 3/8" thick metal plates to A-36, with a 1/8" diameter 7018 type electrode in the 1G, 2G and 3G positions. The certifications were considered acceptable.
c ORGANIZATION: HATCH INCORPORATED EL PASO, TEXAS REPORT INSPECTION NO.: 99901022-85/01 RESULTS: PAGE 7 of 8
- 3. Shop Tour The inspectors toured the shop area where electrical components were being wired. No work was in process that was intended for nuclear power plants.
The inspectors observed that there was no procedure to perform electrical lug crimping and no inspection criteria was established for an inspection. The inspectors informed the HI QA manager that failure to establish a procedure for safety-related crimping was an item of nonconformance to 10 CFR Appendix B Criterion V.
- 4. Review of Audits Performed on Hatch The inspectors reviewed the following audits performed on H I'.
- a. Representatives of Bechtel Power Corporation (Bechtel),
San Francisco, audited HI during July 25-27, 1984 to evaluate the implementation of HI's quality assurance program relative to the panels fabricated for South Texas Nuclear olant. The audit identified two deficiencies, procurement of material from an unapproved source and non-adherence to ANSI 45.2.6 by using a level II inspector to document in-process inspections. Bechtel reaudited HI on November 29, 1984, verified the corrective action taken and closed the audit findings.
- b. Representatives of Commonwealth Edison Company, Chicago, Illinois audited Hatch Incorporated (HI) during November 14-16, 1984. The purpose of the audit was to evaluate the implementation of the HI QA program relative to the manufacture of Transfer Stations and Transfer Feeder Assemblies for Dresden i Station Units 2 and 3 and Quad Cities Units 1 and 2, as specified in Specification T-3307. The audit identified three findings. Documents indicate that HI took adequate corrective action. However, CECO had not completely closed all the audit findings.
1 L __._ ________
~
1 I
l
^ ' "
0RG5NIZATION: HATCH INCORPORATED EL PAS 0, TEXAS i REPORT' INSPECTION NO.: '99901022-85/01 RESULTS: PAGE 8 of 8 l l
i E. Persons Contacted: j A. E. Hatch President E. Taylor Quality Control Manager F. Exit Interview: .
At the conclusion of the inspection, the inspectors met with the persons identified in Section E and discussed the scope and findings of the inspection.
1 h
_ . , _ _ _ _ _ _ _ _ . - . . - _ ._