ML20215C432
| ML20215C432 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/04/1986 |
| From: | Bateman R, Rose J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215C295 | List: |
| References | |
| WP-01-SQN, WP-01-SQN-R03, WP-1-SQN, WP-1-SQN-R3, NUDOCS 8612150136 | |
| Download: ML20215C432 (23) | |
Text
,. .
?, ae TVA EMPLOYEE CONCERNS REPORT NUMBER: WP-01 SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 3 TITLE: ASME Welding Material Control, Traceability, Accountability, and Conditioning REASON FOR REVISION: N/A SWEC
SUMMARY
STATEMENT: N/A PREPARATION PREPARED BY:
Original Signed By J. E. Rose 09-12-86 SIGNATURE DATE REVIEWS PEER:
Original Signed By R. M. Bateman 09-12-86 SIGNATURE DATE TAS: TECHNICAL REVIJW ONLY
~
/bNapf /tlNf6 SIGNATURE DATE CONCURRENCES Original Signed By CEG-H: L. E. Martin _09-15-86 SRP: sux)p//) fi$b }Z- AV ${G SIGNATURE DATE SIGNATUR DATE
[
APPROVED BY:
N/A ECSP MhNAGE F DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
2242T '36 86 h27 21 KOCK 05 PDR P
l.
WELDING PROJECT GENERIC EMPLOYEE CONCERN ..
'V EVALUATION REPORT REPORT NUMBER: WP-01-SON, R3 DATE 09-15-86
SUBJECT:
ASME WELDING MATERIAL CONTROL, TRACEABILITY, r
ACCOUNTABILITY, AND CONDITIONING CONCERNS CONSIDERED: WI-85-053-004 IN-85-424-007 XX-85-068-006 IN-85-453-009 IN-85-441-003 IN-86-150-001 IN-85-234-001 IN-86-167-001 IN-85-424-001 WI-85-041-001 IN-85-426-001 IN-85-454-004 IN-85-352-002' IN-85-672-003 EX-85-039-001 EX-85-021-001 IN-85-337-002 IN-85-424-006
' IN-85-424-004 IN-85-424-007 lR1
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PREPARED BY *E . Gh.u 9/ IV R fn , OC, WP REVIEWED BY Id. ) *h l~2- 8J , OC, WP REVIEWED BY '
. .M 9[$!86'
, QA, WP O 6
-REVIEWED BY ((
/#7 9 2 , CEG-H, WELDING L. - / 7. f -
l { , PROGRAM MANAGER APPROVED BY ,
i Revision 1 was issued to include an additional Employee Concern which has j been evaluated and determined to involve issues previously evaluated, dispositioned, and closed by the WP.
Revision 2 included comments made by the Senior Review Panel on 8/19/86. .
Revision 3 added specific information on electrode control procedures and -
reinspection results per NRC telecon on 09/02/86.
00250
GENERIC EMPLOYEE CONCERN
SUMMARY
SHEET
.D
\,;L/ Report Numbor: WP-01-SON, R3 I Report
Title:
ASME WELDING MATERIAL CONTROL. TRACEABILITY, ACCOUNTABILITY, AND CONDITIONING I. CONCERNS CONSIDERED: WI-85-053-004-XX-85-068-006 .
IN-85-441-003 -
IN-85-234-001 IN-85-424-001r IN-85-426-001-IN-85-352-002-EX-85-039-001 - .
IN-85-337-002-IN-85-424-004-IN-85-424-007-IN-85-453-009 IN-86-150-001 -
IN-86-167-001-WI-85-041-001-IN-85-454-004-f i;fa IN-85-672-003-I S2 EX-85-021-001 IN-85-424-006-IN-85-424-007, lR1 II. ISSUES INVOLVED
- l. Wold Rod Control Program does not meet code requiremgnts (with regard to traceability). , ,
- 2. Returned welding material is possibly not accounted for
. adequately. l l
- 3. Possible lack of portable electrode holding ovens.
- 4. Possible collection of moisture in electrodes due to lack of portable eletrode holding ovens.
s III. STATEMENT OF CONCERN / ISSUE VALIDITY Validity: Y X ,N , Substantiated: Y .N X IV. EFFECT ON HARDWARE AND/OR PROGRAM
,None Page 1 of 2
)
WP-01-SQN, R3
. ., .g V. JUSTIFICATION
.. y) .,
Welding Electrode Control Programs meet code, standard, and regulatory requirements.
VI. RECOMMENDATION AND/OR CORRECTIVE ACTION NEEDED None VII. REINSPECTION NEEDED: Y ,N X .
s VIII. ISSUE CLOSURE Close based on this report.
IX. ATTACHMENTS I
- 1. Text of Employee Concerns lR1 1
- 2. Excerpt From Bechtel Audit - Key Elements 12.0 and 17.0
- ),4
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' )$'
Page 2 of 2 00250 i
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WP-01-SQN, R3 l' GENERIC EMPLOYEE CONCERN Report Number: WP-01-SON, R3 Report
Title:
ASME WELDING MATERIAL CONTROL, TRACEABILITY, ACCOUNTABILITY, AND CONDITIONING I. SCOPE OF EVALUATION This engineering analysis covers the following WBN concerns determined to have possible generic implications at SQN:
WI-85-053-004 XX-85-068-006 IN-85-441-003 IN-85-234-001 IN-85-424-001 IN-85-426-001 IN-85-352-002 EX-85-039-001 IN-85-337-002 IN-85-424-004 y IN-85-424-007 f ' M1 IN-85-453-009
' I#' IN-86-150-001 IN-86-167-001 WI-85-041-001 IN-85-454-004 IN-85-672-003 EX-85-021-001 IN-85-424-006 '
IN-85-424-007 lR1 II. ISSUES ADDRESSED BY CONCERNS Each concern was analyzed to determine the issues voiced by the concerned individuals. These issues are as follows:
- 1. The Weld Material Control Program does not meet code requirements.
The context of this issue gives the inference that the concerned individuals are referring to the everall traceability of welding materials from procurement until the materials are consumed in the final weld. ,_
- 2. Returned welding material is possibly not accounted for adequately.
- 3. Possibic lack of portable electrode holding ovens.
- 4. Possible collection of moisture in electrodes due to lack of
, p portable electrode holding ovens.
Page 1 of 5 00250
)
WP-01-SQN, R3 III. CONCERN. VALIDITY OR SUBSTANTIATION The original requirements for control of welding materials for SQN l were accomplished through the application of the requirements of l 10CFR50, Appendix B, Criterion VIII, ' Identification and Control of l Materials, Parts, and Components,' which states: Measures shall be l established for the identification and control of materials, parts, l
! and components, including partially fabricated assemblies. These l measures shall assure that identification of the item is maintained l by heat number, part number, serial number, or other appropriate l means, either on the item or records traceable to the item, ag lR2 required throughout fabrication, erection. Installation, and use of l '
the item. These identification and control measures shall be l designed to prevent the use of incorrect or defective material, l
, parts, and components.' The underlined portions of Criterion VIII l provided the basis for the use of a program 'which ensures that l specified materials are used.' It established the principle that l allows full material traceability or control programs 'which ensure l that specified materials are used' as acceptable methods of material l control. l 4
SNP Construction Procedure No. M-1, ' Procurement Storage, Issue, and ^~ l Control of Wolding Materials' issued September 30, 1971 utilized this l concept of a control procedure and established the basis for the use l of a procedure for welding material control for subsequent Office of l Q. : Construction (OC) activities at SQN. This procedure was issued l 4
concurrently with the start of permanent welding activities at SQN. lR2 ANSI N45.2-1971, ' Quality Assurance Program Requirements for Nuclear l Power Plants' further expanded the concept of control procedures in i i
Section 9, ' Identification and Control of Materials, Parts, and l Components.' This section states, in part, that 'Where physical l Identification is either impractical or insufficient, physical l separation, procedural control, or other appropriate means shall be 1 employed.' l As nuclear construction and quality assurance technology has advanced l these concepts have been better defined and OC has implemented the l provisions of ASME Boiler and Pressure Vessel Code (ASME B&PV) lR2
' Section III as the basis of its welding material control program. l The provisions of ASME B&PV Code,Section III have expanded the l concept of control procedures and specifically address welding l material control in NB-4122. "
l e
! Pressure Vessel Code,Section III. NB-4122 requirements for welding material control during nuclear construction. These requirements state in part:
Welding and brazing materials shall be identified and controlled so I ,
that they can be traced to each component and/or installation of a
., piping system, or else a control procedure shall be employed which ensures that specified materials are used.
The Office of Construction (OC) has used the underlined option which Page 2 of 5 00250
WP-01-SQN, R3 g specifies a " Control Procedure" since the inception of the QA program.
This procedure was implemented in SQN Site Procedure M-1 and later W-1 for OC Nuclear Operations (NO) procedures require full traceability to end use. This procedure is implemented in SQN Site Procedure M&AI-5 I for NO.' ,
Both OC and NO purchase welding electrodes to be used for permanent s construction and nuclear plant modifications in accordance with_ASME 4 B&PV Code Section III rules for Class I Construction. Both OC and N0 i procedures fully delineate the controls for electrode control from
' procurement to final consumption in the weld joint. The Con'struction Quality Assurance Program for Watts Bar and later plants has been reviewed by ASME and holds the appropriate ASME, Certificates of Authorization for Nuclear Construction. Elements of that program dealing with traceability of welding materials are essentially identical to the program used by OC at Sequoyah. The Nuclear Operations QA program fully complies with ASME Section III, NB-4122 by requiring full traceability of welding material to end use.- NRC.
INPO, and outside consultants have found this program to be acceptable.
r Program implementation has been independently verified through the
- Bechtel SQN Implementation Audit performed in January 1986. Key 1 Elements 12.0, "Use and Control of Welding Filler Metals," and 17.0, i
" Employee Concerns," comment regarding this issue: .
The statement in the concern shows a lack of understanding of the
{ Code. For example, ASME III, NB-4122 requires traceability of the weld filler metal but gives two methods to choose from. Either trace to each component or ensure the specified material is used by l
a control procedure. TVA's OC program required that all the material meet the standards, and therefore, did not require traceability to a component. .,
1 The audit established that the program has been and is being 4 effectively implemented though several suggestions were made for sbreamlining and condensing the NO program.
Implementation of the Electrode Control Program has also been addressed
- through the WP Sample Reinspection Program performed at SQN.
j' Each weld inspected by the reinspection team was checked magnetically for generic filler material-type. No noncompliances were observed in the reinspection.
i Both OC and N0 procedures specify electrode issuance requirements by j
use of the Materials Requisition. The requisition form contains the
> welders name and identification, the electrode type, size and
- quantity, the date of return, the control center attendant's signature, and the control number of the material being used. Welder certification cards are verified at time of electrode issue, and helpers are not allowed to withdraw electrodes at SQN for welders. l i , .l y'f Both OC and N0 procedures provide for verification that unused lR3
}
electrodes are returned to the Issue Center (OC) or Tool Room (NO) by l .
- the individual welder. l .
}
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Page 3 of 5 i 00250
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WP-01-SQN, R3 The individual material withdrawals are logged by the individual l
,Q} welder's name and are Icgged back as the materials are returned. l lR3 I
Review of this log at the end of each shift provides verification l
that materials have been returned. Instances of non-return are l identified and investigated.
l The unused electrodes are required'to be returned to the control ,
center for reconditioning at specified intervals or at the end of the shift. The materials requisition forms are not classified as a QA record, and as such, are summarized on a daily its then discarded. .
Exchanging of electrodes between welders is not permitted and welders are made cognizant of the proper method of obtaining welding materials through craft training programs. Occurrences of this wculd be an intentional violation of procedure with the appropriate disciplinary action in order.
The accountability provisions of the electrode control program, QC l l
' inspections of safety-related welding and the attendent threat of adverse personnel actions on individuals for intentional procedural lR3 i
l violations make it very unlikely that an individual would elect to l l
' attempt the use of borrowed or moisture-laden electrodes.
Review of Electrode Control Procedure SNP-CP-W-1 for construction, indicates that portable electrode holding ovens were used from early on
- gJ in the construction of SQN until the completion of construction in 1981. After commercial operation began in 1981, Nuclear Operations
! C Procedure M&AI-5 deleted the requirement for use of portable electrode
! holding ovens and mandated the use of extended atmospheric exposure qualified electrodes (AWS D1.1, Section 4.5.2.2)
Implementation of these requirements by OC and NO is addressed through l
the independent Bechtel Audit of SQN conducted in January 1986. Key Elements 12.0 and 17.0 of the audit addressed "Use and C6ntrol of Welding Filler Metals," and " Employee Concerns" for OC and NO j respectively. The audit indicates that procedures were implemented
' correctly and that documentation generated as the result of this _.
Implementation was correctly prepared and is on file. This verified that adequate control of filler metals was and is being accomplished both during construction and operations.
l In addition, the issue of possible collection of moisture in welding materials, was addressed through tHb WP Sample Reinspection Program performed at SQN during January, 1986. The result of the reinspection was that indications of the possible effects of excessive moisture in covered welding materials (i.e., defects such as gross porosity and weld cracking) were not found.
j l
There were 15 mechanical welds out of 333 which were rejected for l
- surface porosity. This is a 4.51. reject rate. There were no lR3 structural welds rejected for porosity. Complete details of the l
reinspection results are contained in the SQN Phase II Report.
Page 4 of 5 -
l 00250
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WP-01-SQN, R3 1
', \ In summary, the issues considered in these concerns are not substantiated due to the following factors:
- 1. Procedures were and are in effect for OC and N0 which delineate the requirements for traceability and control of filler metals.
) have been endorsed by ASME through the ASME survey process.
- 3. The Bechtel SQN Implementation Audit established that these procedures were effectively implemented for both OC and NO.
- 4. The effect of noncompliance with these procedures was not found in-the WP Sample Reinspection Program.
The results of this evaluation confirm that the correct program elements for the control of these activities were addressed and implemented at SQN by both OC and NO. Based upon the foregoing analysis, these issues addressed in the Employee Concerns are closed.
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.q. Page 5 of 5
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00250 i
Attachment 1
.09/03/85 (EMPLOYEE CONCERNS) 14:00:32 PAGE 1 of 6 LOC STATUS RESP ' -OTC- PPP CFR INSP TC ------CONCERN-------
PROBLEM
- ~ -ID L1 SR WI-85-053-009 ., _WCPME,
! #" :b -
's 4WORDS: ELECTRODE PROGRAM CONTROL X: W Y: C 2: N WELD ROD CONTROL DOES NOT SATISFY CODE REQUIREMENTS. TVA ATTITUDE IS "ALL " ~
MATERIAL INFORMATION. IS CODE MATERIAL". CONSTRUCTION DEPT CONCERN. CI HAS NO FURTHER TECHNICAL COMMENTARY:
ISSUE CONSIDERED: WELD ELECTRODE TRACEABILITY.
LOC STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN-----
PROBLEM 550 ID NSRS L1 -
SR XX-BS-058-006 WCPME XEYWORDS: ELECTRODE PROGRAM CONTROL X: B Y: C '. 2: N BELLEFONTE - WELD ROD CONTROL DOES NOT SATISFY CODE REQUIREMENTS. TVA ATTITUDE IS "ALL MATERIAL IS CODE MATERIAL". CONSTRUCTION DEPT. CONCERN. CI HAS NO FURTHER*INFORMATION.
CINSF RPTH I-85-550-BLN)
TECHNICAL COMMENTARY:
ISSUE CONSIDERED: WELD ELECTRODE TRACEABILITY.
, ,4C STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN-------
,g.- ------ ---- ----- --- --- ---- --
PROBLEM 021 ERT L9 ID SR IN-BS-491-003 WCPME XEYWORDS: ELECTRODE PROGRAM ROD-OVEN ' X: W Y: C 2: N NO PORTABLE OF'THE SHIFT AND OVENSCANNOT ON WATTS BE USED.BAR. THE ROD SOMETIMES COLLECTS MOISTURE BY THE EN CINSP RPTM EX-85-021-001) *
, ,, i .
TECHNICAL COMMENTARY: '
ISSUE CONSIDERED: 1.LACKOFPORTABLEELECTRODEHOLDINGbUENS.
- 2. MOISTURE CONTENT OF ELECTRODES.
LOC ) ' STATUS RESP -OTC- PPP CFR INSP TC ---
CONCERN------- PROBLEM l 021 ERT L9 ID 1
SR IN-8S-239-001 WCPME i KEYWORDS:
- ELECTRODE PROGRAM ROD-OVEN X: W Y: C 2: N
! WELD RODS ARE NOT REQUIRED TO BE XEPT IN ROD OVENS AFTER ISSUANCE TO STEA j CINSP WELDERS. -
RPTHTHE ROD CAN BE KEPT UNHEATED FOR 8 HOURS AT A TIME IN A LEATH EX-85-021-001)
( .._.
I TECHNICAL COMMENTARY:
l,-}SUECONSINERED: WELD ELECTRODE CONDITIONING.
O -
l .
.x
,109/03/86- Attachment 1 CEMPLOYEE CONCERNS) 14:06: 32 PAGE 2 of 6 LOC. . STATUS RESP -QTC ,PPP CFR INSP TC ------CONCERN------- PROBLEM l
-. 021 ERT L4 . ,_ ID
'A, ,
SR IN-85-924-001 .. WCPME,
.'j(WORDS:
j ELECTRODE PROGRAM ROD-OUEN '
X: W Y: C 2: N c NO.PORTABLEOVENSUSED/REQUIREDONWATTSBAR.THERODOFTENCOLLECTSMOISTORb' AND SHOULD NOT BE USED.
CINSP RPT# EX-85-021-001)
TECHNICAL COMMENTARY:
ISSUE CONSIDERED:_1. LACK OF PORTABLE ELECTRODE HOLDING OUENS. *
- 2. MOISTURE CONTENT OF ELECTRODES.
LOC STATUS RESP -QTC- PPP CFR INSP TC ------CONCERN----
PROBLEM 021 ERT L4 ID SR IN-85-425-001 WCPME XEYUORDS: ELECTRODE PROGRAM ROD-DVEN X: W Y: C 2: N PORTABLE SHIFT. NO FOLLOW-UP. OVENS ARE NOT REQUIRED. WELD ROD IS XEPT GUT OF OVEN FOR AN EN 1
CINSP.RPT# EX-BS-021-001) i :
l TECHNICAL COMMENTARY: l +
ISSUE CONSIDERED: LACK OF PORTABLE ELECTRODE HOLDING OUENS.
'S STATUS RESP -QTC- PPP CFR INSP TC.------CONCERN-------
gi;.C',
3 PROBLEM 021 ERT L4 in SR IN-85-352-DO2 WCPME XEYWORDS: ' ELECTRODE PROGRAM ROD-DVEN ' X: W Y: C 2: N NO PORTABLE OVENS ARE USED ON WATTS BAR. WELD ROD CAN BE XEPT DUT ENTIRE SHIFT AND RETURNED TO OVEN FOR LATER USE. '
.CINSP RPTH EX-85-021-OO1) ' - -
r, -
1 TECHNICAL COMMENTARY:
ISSUE LOC CONSIDERED: LACK OF PORTABLE ELECTRODE HOLDING OUENS.
STATUS RESP -QTC- PPP CFR INSP TC ------CONCERN-------
____. ______ ____ _____ ___ ___ ____ __ PROBLEM EGG L4 - to SR EX-BS-03S-001 WCPME KEYWORDS: ELECTRODE PROGRAM ROD-DUEN
^
~
e X: W - Y: C 2: N WBNP-THERE ARE NO PORTABLE OUENS FOR STORING WELD ROD AFTER I TO RETURNED, THE WELDER AND THE WELD ROD IS NOT ADEQUATELY ACCOUNTED FOR WHE I.E. ROD STUBS AND UNUSEO ROD.
FURTHER INFORMATION. CONST DEPT CONCERN CI HAS NO TECHNICAL COMMENTARY:
?cSUE CONSIDER:
- 3' 1. LACK UF PORTABLE ELECTRODE HOLDING OVENS.
- 2. ELECTRODE ACCOUNTABILITY INADEQUATE e..~,w --a v.-,., -- , , ,~ -p -
m , , - ,-_ .,-----ne
At t ac tunen t 1
- .Oy/03/a6 (EMPLOYEE CONCERNS)
- 14
- 00:32 PAGE 3 of 6 L
LOC STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN-------
PROBLEM ID J .. 021 ERT L4 SR 'IN-85-337-DO2
. . __WCPt1E.,
.) .
', sis WORDS : ELECTRODE PROGRAM ROD-OVEN
, X: W Y: C 2: N ie
[
CONTROL OF WELD ROD IS INSUFFICIENT. WELDERS CAN KEEP ROD OUT OVERNIGHT CND -
l DUEN). THERE ARE NO PORTABLE OVENS ON SITE SO WELD ROD IS XEPT OUT FOR AT LEAST
' 8 HR. SHIFT. UNUSED ROD AND STUBS ARE TURNED IN (TOSSED IN) AT END OF SHIFT BUT h NO COUNT IS MADE. WELDERS CERTIFICATION' BOOK IS NOT ALWAYS CHECKED BEFORE ISSUING ROD. WELDERS CAN AND DO GET ROD FROM OTHER WELDERS TO FINISH WELD.
f CINSP RPTM EX-BS-021-OO1)
TECHNICAL COMMENTARY: '
ISSUES CONSIDERED: 1. WELD ELECTRODE CONDITIONING. 2. WELD ELECTRODE ACCOUNT-ABILITY.
LOC STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN------- EROBLEM ID 021 ERT L2 SR IN-BS-424-OO4 WCPME KEYWORDS: ELECTRODE IMPLEMENTATION CONTROL X: W Y: C 2: N OA TRAINING CLASS, G-S-85, INFORMED CRAFT THAT STEAMFITTERS COULD WITHDRAW AND CONTROL WELD ROD IF THEY HAD A WELDER SIGNED WELD SLIP AND THE WELDERS CARD.
, CINSF RPT# EX-BS-021-001) 7.CHNICAL COMMENTARY:
l D
'c,JE CONSIDERED: ELECTRODE CONTROL.
'd5C STATUS RESP -0TC- PPP CFR INSP TC -- CONCERN------- PROBLEM ID 021 ERT L2. SR IN-BS-424-OO7 WCPME KEYWORDS: ELECTRODE IMPLEMENTATION CONTROL '
~ X: W Y: C 2: N LACK OF WELD ROD CONTROL: WELDERSGET.ADDITIONALRODFROMbTHERWELDERSRATHER
[p THAN GOING BACK TO THE ROD ROOM FOR MORE. SITE POLICY ALLOWS LEAVING ROD WITH OTHER WELDERS, OR LETTIN: SUB-JOURNEYMEN CHECX-OUT ROD AND RETURN ROD. (CAN ALSO LEAVE ROD IN TOOL BOXES). THE ROD ROOM DOES NOT COUNT ROD WHEN.IT IS ISSUED, AND DOES NOT REQUIRE ACCOUNTING FOR ROD STUBS. OCCASSIONALLY, WELDERS ARE REPRIMANDED FOR NOT TURNING IN ROD WITHDRAWAL SLIPS, EVEN THOUGH THE ROD SLIP REALLY DOES NOT ACCOUNT FOR ANYTHING. CI HAS NO MORE INFORMATION.
CINSF RPTM EX-BS-021-001) -
! TECHNICAL COMMENTARY: '
a ISSUES CONSIDERED: 1. ELECTRODE CONTROL. 2. ELECTRODE ACCOUNTABILITY.
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/ . # .51 l
S I M' ,
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Attachment 1
,Q9/03/86 (EMPLOYEE CONCERNS) 14:08:32 PAGE 4 of 6 LOC STATUS RESP -0TC- PPP CFR INSP TC ------CONCERN-------
PROBLEM 10 021 ERT L2
) ~ SR lIN-85-953-OOS. . _ ,_ W C P M E ..
(WORDS: ELECTRODE IMPLEMENTATION CONTROL X: W Y: C 2: N WELDERS FREQUENTLY GIVE WELD ROD TO OTHER WELDERS
j> >
(INSP RPTH EX-85-021-OO1)-
TECHNICAL COMMENTARY:
ISSUE CONSIDERED: ELECTRODE CONTROL.
LOC STATUS RESP -0TC- PPP CFR INSP TC
CONCERN------- PROBLEM to 021 L2 SR IN-85-1SO-OO1 WCPME KEYWORDS: ELECTRODE IMPLEMENTATION CONTROL TRACE X: W Y: C- 2: N I
THERE IS NO PROGRAM FOR MATERIAL TRACEABLITY OF WELDING ROD AT WBNP WH5N WELDING ROD IS DRAWN, IT COULD BE USED ANY PLACE IN THE PLANT. MATERIAL .
1 TRACEABILITY IS NOT EVEN ATTEMPTED. CONSTRUCTION DEPT CONCERN. CI HAS NO FURTHER'INFORMATION. 2 CINSF RPT# EX-BS-021-OO1)
TECHNICAL COMMENTARY:
ISSUE CONSIDERED: ELECTRODE TRACEABILITY.
STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN------- PROBLEM c[.- 9C - ------ ---- ----- --- --- ---- --
ID
- O21 L2 SR IN-85-167-001 WCPME XEYWORDS: ELECTRODE IMPLEMENTATION CONTROL TRACE X: W Y: C 2: N CI~IS CONCERNED THAT THERE IS NO TRACEABILITY-OF WELD RODS TO ACTUAL JOB PERFORMED. CI HAS NO ADDITIONAL INFORMATION. CONST DEPT CONCERN.
CINSF RPTM EX-85-021-OO1) J )-
3: - -
c TECHNICAL COMMENTARY: i ,
. m- -
ISSUE CONSIDERED: ELECTRODE TRACEABILITY. ! .
, LOC l STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN------- PROBLEM yo L 021 L2 SR WI-85-041-OO1 WCPME f!
KEYWORDS: ELECTRODE PROGRAM CONTROL TRACE -
X: W - Y: C 2: N WELD CAWS & ASME) FILLER MATERIAL (ROD) CONTROL RECORDS / DOCUMENTATION IS INADEQUATE FOR AWS WELDS ROD SLIPS ARE NOT RETAINED AS RECORDS AND DO NOT IDENTIFY HEAT / LOT NUMBERS AND LOCATION OF USE; FOR ASME WELDS, ROD SLIPS DO NOT IDENTIFY HEAT / LOT NUMBERS AND LCOATION OF USE CI HAS NO FURTHER INFORMATION.
CINSF RPTH EX-8S-021-OO1)
~
TECHNICAL CQMMENTARY: .
/
' ?f,' CONSIDERED: ELECTRODE TRACEABILITY h t.+
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e
Attachment 1
.'03/0,3/E5 .
CEMPLOYEE CONCERNS) PAGE 5 of 6 14:08:32
. LOC STATUS RESP -0,TC- ,PPP CFR INSP TC ------CONCERN------
. PROBLEM 1D r- . 021 ERT L2, SR lIN-OS.-454-OO4 . " ,,., _ W C P M E.,,
I
\J<r)WORDS: ELECTRODE IMPLEMENTATION CONTROL X: W Y: C 2: N WELDERS FREQUENTLY GET ROD FROM EACH OTHER INSTEAD OF WITHDRAWING FOR ROD TOC 51-(INSF RPTM EX-OS-021-001)
TECHNICAL COMMENTARY:
ISSUE CONSIDERED: ELECTRODE CONTROL.
LOC STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN-------
PROBLEM ID L2 SR IN-BS-672-OO3 ~ WCPME XEYWORDS: ELECTRODE IMPLEMENTATION CONTROL X: W Y: C 2: N 4
~
AT. SHIFT END, WELD ROD SLIPS ARE TURNED IN. THE SLIPS ARES. CHECKED THEN THROWN AWAY. IF THE ISSUE ROOM DETERMINES AT A LATER DATE THAT A WELDER DID NOT CONFORM TO " TURN IN" PROCEDURES, IT IS HIS WORD AGAINST THEIRS AND HE GETS THE WARNING LETTER.'THESE LETTERS HAVE BEEN ISSUED WITHOUT PROOF OF WRONGDOING. CONSTRUCTION DEPT. CONCERN.
TECHNICAL COMMENTARY:
ISSUE CONSIDERED: ELECTRODE ACCOUNTABILITY.
, ("cDC STATUS RESP -OTC- PPP CFR INSP TC ------CONCERN------- PROBLEM 4
Sfty - ------ ---- ----- --- --- ---- --
ID J O21 ERT L2 SR EX-BS-021-OO1 WCPME XEYWORDS: ELECTRODE IMPLEMENTATION CONTROL ACCOUNT X: W Y: C 2: N WELD ROD ISSUE AND ACCOUNTABILITY IS INADEDUATE. ROD SLIPS DO NOT REFERENCE WHERE ROD WAS USED; WORK PACKAGES DO NOT REFERENCE ROD ISSUE SLIPS; THERE IS NO ROD STUB ACCOUNTABLITY; EXCESSIVE WELD ROD. LAYING AROUND ON-FLOORS, ETC., IN BUILDINGCS). C/I STATED THAT ON ONE OCCASION, HE/SHE NOTICED SEVERAL RODS LAYING '
UNDER THE WINDOW OF THE ISSUE STATION IN THE AUX. BLDG., ELEU. 713. APPARENTLY THERE WAS NO ONE AT THE ISSUE STATION WHEN 3RD SHIFT WAS READY TO RETURN UN-USED ROD. NO ADDITIONAL INFORMATION AVAILABLE - NO FOLLOW-UP REOUIRED.
CINSP.RPT#-EX-85-021-OO1) -
TECHNICAL COMMENTARY: I MULTIPLE CONCERN--ISSUES CONSIDERED: 1. WELD ELECTRODE TRACEABILIT.Y.
C. ELECTRODE CONTROL.
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Attachment 1
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Page 6 of 6
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'ed . . ) 07/25/86 (EMPLOYEE CONCERNS) 03:40:42 CAT ISSUE PLANT PRIORITY ORG QTC EGG INSP SD RD GD IO ------CONCERN- . --- . .
WE SFB W 2 EGG L2 533 Y SR B IN-85-424-005 KEYWORDS: ELECTRODE CONTROL PROGRAM PROB: WSPME NO ACCOUNTABILITY OF WELD ROD DURING ISSUANCE OR RETURN OF UNUSED ROD AN3 STC35.
IR: EX-05-021-001 V STAT: RC: WP-01-SQN TECHNICAL COMMENTARY: -
CAT ISSUE PLANT PRIORITY ORG QIC EGG INSP SD RD GD IO"------CONCERN------
- l. WE SFB W 1 EGG L2 531 Y SR B IN-85-424-007
-1 l KEYWORDS: ELECTRODE CONTROL IMPLEHENTATION PROB: WCPME I
l l LACK OF WELD ROD CONTROL: WELDERS GET ADDITIONAL ROD FROM OTHER WELDERS RATHER
'M..* 'l THAN GOING BACK TO THE ROD ROOM FOR MORE. SITE POLICY ALLOWS LEAYING ROD WITH
- n 9 R1 l OTHER WELDERS, OR LETTING SUB-JOURNEYMEN CHECK-0UT ROD AND RETURN ROD. (CAN i'" l ,ALSO LEAVE ROD IN TOOL BOXES). THE ROD ROOM DOES NOT COUNT ROD WHEN IT IS
? , : l ISSUED. AND DOES NOT REQUIRE ACCOUNTING FOR R0B STUBS. OCCASIONALLY, WELDERS
,; l ARE REPRIMANDED FOR NOT TURNING IN ROD WITHDRAWAL SLIPS, EVEN THOUGH THE ROD
( l. SLIP REALLY DOES NOT ACCOUNT FOR ANYTHING. CI HAS NO MORE INFORMATION.
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~ IR: EX-85-021-001 V STAT: RC: EC-SPL-1,WP-01-SQN
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l TECHNICAL COMMENTARY: '
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. KEY ELEMENT 12.0. ~
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OFFICE OF CONSTRUCTION USE AND CONTROL OF WELDIMG FILLER METALS .
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Audit Findine - AF-01-OC
, , Certified comply withmaterial test reports TVA project (CMTR's) for welding filler metals did not specifications.
identified in Attachment A. Deta,ils on, each package are s
In general,' TVA procedures required criteria over and above ASME filler metal specifications and had no impact on weld quality.
.' stated that heat treatment was done at ll50*F for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.For example, a CITR specification required the heat treatment to be 1150*F for la hours.The TVA project A letter in theto permission contract use as file is. from TVA addressed this deviation and gave
- identify manufacturer, heat or lot number.However, the letter was not ~ signed and did not
-This finding indicates that the TVA procedures were not followed although referenced code requirements were complied with. The date.
the audit strongly supports the. conclusion that there was no impact en thereviewed during actual weld quality related to control of welding filler materials.
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SUMMARY
OF FINDINGS FOR ELEMENT 12.0 (Office of Construction) ',*
(AF-01-0C) *
, Weld .
Filler Metal Project SFA P'ackage Classification Speci fica tion Spec.
(As referenced Heat No. Lot No. Comments
)n checklist)
- 29. E 7018 PF 1012 rev. 2 5.1 422N1151 -
See comment 1.
- 30. E:70S-3 PF 1019 rev. 2 5.18 623389 -
See comment 2?& 3
- 34. E 7018 PF 1012 rev. 2 5.1 01U019 2241342 See comment 1.
- 35. E 7018 PF 1012 rev. 2 5.1 412L7101 3034015 See comment 1.
36.
E 7018 PF 1012 rev. 2 5.1
- - 402N85d1 2443662 See comment 1.
- 37. E 70S-3 _
PF 1019' rev. 2 ; 5.18 431J5621 -
See comment 3.
- 38. E 70S-3 , PF 1019 rev. 2 5.18 625537 -
See Lem ent 3.
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.3 9. E 7018 PF 1012* 5.1 411N0471 -
See comment 1.
- 40. E 7018 PF 1012'rev. 2 5.1 08R2I7 See comment.1.
- 46. .E 70S-3 PF 1019 rev. 2
5.18 421E9101 -
, see comments 2 & 3.
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48.
E 70S-3 -
PF 1019 rev. 4 5.18 422T7432 See comment 3.
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Comment (1): CMTR states heat treatment (h.t.) @ 1125' Fi 25* fer 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. The project spec. required the h.t. EE to be @ 1150' Fifor 10 hrs. -
Comment (2): CMTR states h.t. @ 1150' F for 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.
,rd The project spec. required the h.t. to be 1150' for.10 hrs.)
o3 mn Comment (3): Theprojectspec.andSFA5.18requirestheyettdstrength, cnTn did 'not state this information.
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023 No rev. given on Cl!TR'or receiving report. Assume rev.1,2 .
Attachment 2 Page 3 of 8
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Krl ELE!ENT 17.0 -
\" OFFICE OF CONSTRUCTION D!?LOYEE CCNCERNS -
17.1 Concern No. XX-85-049-XO3 and XX-85-101-006regardire selder certification. This concern was not substantiated by the audit of a random sampling of 37 welders which involved 124 welder qualification records from 1970 to 1979. '
17.2 '
Concern No. XX-85-69-001 and XX-85-069-X05 regarding welder certification and on-the-job training. This concern was not substantiated by the audit of a random sampling of 37 welders which involved 124 welder qualification records from 1970 to 1979. ,
17.3
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Concern No. XX-85-108-001 and XX-85-108-002 regarding weld inspections.
audit of a minimum of 14 inspection procedures.This concern could not be t
17.4 Concern No. IN-85-476-004.and WI-85-041-002 regarding welding inspectors training program.
f:; as evidenced by audit of training programs.This concern could not be substantiated
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.17.5 Concern No. W1-85-053-004 and XX-85-68-006 regarding weld rod control (i,jF I {g' . J' '
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satisfying code requirements.
This concern was not substantiated by 1- ,, {C audit of a random sampling of 48 receiving documents and associated -
' U[ . CMTR's which involved 83 heat and/or lot number, 8 types of weld metal covering the ytars 1972 to 1980. ~
i ' 3a 572',000 pounds of ueld metal. Although This represents approximately
[j' against Key Element No. audit finding, AF-01-01
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- .q 12 of this report is documented against the TVA program,
!_ it involves details required by TVA procegures over and
-d" - above l impact that required on weld quality. by ASXE filler metal specifications and had no
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code.statement in the concern.shows a lack of understanding of the j { ;: " For example, ASME III, NB-4122 requires traceability of the
- weld filler metal but gives two methods to chose from.
n
' Either trace
, , q to each procedure.
control component or ensure the specified material is used by a
'l TVA's program required that all the material meet ij 2 the standards component. and, therefore, did not require traceability to a
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9 KEY ELFl4ENT 17.0
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OFFICE OF CONSTRUCTION EMPf.OYEE CONCERNS (continued)
-17.6 Concern No. XX-85-054-001 regarding weld inspection by craft concern was not substantiated by the pudit of 13 inspectorsThis pulled from the weld history records for the welds reviewed in the as audit well as by an additional random sampling of 13 inspectoYstro '^
i holdpoints were found to have been signed off;by anyoneanother th L
certified inspectors.
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Stsuctural up and final inspection. ' welds and piping have different p ng., code re r fit t procedures for structural welds.No holdpoints are required by'the TVA
- 17.7 Concern No ' EX-85-039-001
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4 rod). regarding weld' control (stubs and unused procedurca.- This ccacern was not substantiated by the ' audit of applicable AJdaily surveillance program was maintained which welded and the procedure being used. included. verification of w .
(such the as amperage) procedure properly. were verified to assure.that welders gwere usinVar k ,%# Welding rods, ovens'and controls were
'J, monitored to assure that the welder had requested the proper rod. was issued the proper rod, and was using the pedper rod. .
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M 300 surveillances a month were perform e ~d during years of peakAppro:cimately
.t construction. '..
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1 s s Attachmtnt 2 Page 5 of B
. 3 KEY ELE'4EMT 12.0- .
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NUCLEAR OPERATIONS USE AND CCNTROL OF WELDING PILLER METALS _
CBSERVATICN ~ ~
The site controlling procedure for " Receipt Inspection" is unnecessaril y longfor are and confusing (reference AI-ll, Revision 38, 66 pages). Extractions example:
"2.5.2 As;part of the receipt inspection of Level I items, Lebel II substituted items, or Level II items to which Part 21 applies, either purchased by NUC PR or EN DES and shipped from the vendor to NUC PR, the QC inspector shall review and verify manufacturing documentation and material certifications of' physical properties as follows:
'i a.
Manufacturino Documentation--Assurance that the item received was fabricated, tested, and inspected prior to shipment in y accordance with applicable code, specification, purchase p_
e contract, and/or drawings. ,
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/N' Phvsical Procerties-Assurance that physical prcperties conform to the specified requirements and that chemical and physical p j'h."i test reports, if required, meet the requirements."
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,%$ Another worded and controlling organized. procedure, power stores SIL-8, "QA Records," is poorly D ;. .,
filed. For example: Personnel can infer four places for,CMTR's to be ,-
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, ij ;%p F 'The receiving report (TVA 209), packing list w/related documents, .
l Qt h; SQA45 (Attachment 11), TVA 2652 (Purchase Request), Quality
}iljp$$q . Assurance Certifications, changed QA Level Assignme, pes, Material Receipt Inspection Report (AI-ll, Attachmenti1), ECU Material}]p7;g C A Receipt Inspection Report AI-ll,' ttachment 5), AI-11, Attachment 1lM d 3%.; . 16, NCI Tag (TVA 7830), Recommended Disposition of. Honconforming }'Q1b + Items (AI-ll, Attachment 10), OSSD or D'(TVA 210), TVA 9640, and i jlf j TVA 5050 are filed in the procurement document folder or attached ' lh* jd 7 to the TVA Form 575 or attached to the procurement document or [I Mg 7. filed under procurement document number.": i i i. . }.:. Li 'I F j t< O')
, f. !; } , Yet another controlling document, N73M2 " Process Specification for Wei ,
t ; j .'y 6 ; Heat Treatment and Allied Field Operatiotw" requires that CMTR's shall be y D @ l materials from pouer stores. approved by the metallurgy and standards group prior to r 8 ,., '.s e+.'n , . 3
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FE'I ELES!Ef!T 12.0 , u
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g NUCLEAR OPERATIC?IS USE AflD CO?! TROL OF t1ELDIllG FILLER METALS (continued) " ' Too many controlling procedures are required to be used simultaneousl y to do
. the job of control of welding filler material effectively .
program and position. the people trying to enforce the program in a vulnerableThis puts the
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s The materihl receipt inspection report (Attachment 1 of AI-ll) refers to an
;
- item on a shipping ticket or a contract document.
4 being inspected, such as weld filler metal with heat number.It does not list what is ties to another before either gives the complete information. One document ai. . The program could be condensed and simplified 'to be more functional and lass..
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vulnerable to error and misinterpretation by the users.
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Attachment 2 Page 7 of 8 j ( . KEY ELEME?rr 17.0 OFFICE OF NUCLEAR OPERATIO;IS
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.17.1 Concern No. XX-85-049-X03 and XX-85-101-006 certification. regarding welder
. This concern was not substantiated by the audit of a random from records sampling 1972 of to 25 welders which inyolved.107 welder qualification 1985, 17.2 s Concern No. XX-85-69-001 and XX-85-069-X05 regarding welder certification and on-the-job training. This concern was not substantiated by the audit of a random sampling of 25 welders which involved 107 welder qualification records from 1972 to 1985.
17.3 .. Concern No. XX-85-108-001 and XX-85-108-002 regardiEg weld inspections.
. audit of a minimum of 14 inspection' procedures.This concern could not 17.4 Concern No. IN-85-476-004 and WI-85-041-002 regarding welding inspectors training program.
as evidenced.by audit of training programs.This concern could not be substatiated 17.5 g? Concern No. W1-85-053-004 cnd XX-85-68-006 regarding ueld rod control satisfying code requirements. (yf$ audit of a random sampling of 25 receiving documents and associated ( Z; ,
- CMTR's which involved 25 heat and/or lot number, 6 different types of weld metal covering the years 1976 to 1985. This represents . --
approximately 19,000 pounds of weld filler metal. 4 The statement in the concern shows a lack of understanding of the code. For example, ASME III, NB-4122 requires traceability of the
- weld filler metal but gives two methods to chose from.' Either trace to each procedure.
control component or ensure. the specified material is used by a the standards and, therefore, did not require traceability to aTVA's component. O If. 17.6 Concern No. XX-85-054-001 regarding weld inspection by craft. i ~ r. This
,3 - concern was not substantiated by the audit of 4 inspectors pulled
~(- from the weld history records for the welds reviewed in the audit as g,4 well as by an additional random sqppling of 10 inspectors. No '
holdpoints were found to have been signed off by anyone other than i! . 1, p;.p;:,:;, certified inspectors. , d.j.1p' .J9 /.
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