IR 05000400/1982003

IE Investigation Repts 50-400/82-03 & 50-401/82-03 on 811211-820226.Noncompliance Noted:Insp Records Did Not Reflect Correct Identity of Individuals Who Performed Weld Insp & Insps Performed by Uncertified Welders

ML20062A381
Person / Time
Site:	Harris
Issue date:	04/22/1982
From:	Alderson C, Vorse J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20062A354	List: IR 05000400/1982003 ML20062A353 ML20062A357 ML20062A362 ML20062A371
References
50-400-82-03, 50-400-82-3, 50-401-82-03, 50-401-82-3, NUDOCS 8208030706
Download: ML20062A381 (15)

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' UNITED STATES 4f #e NUCLEAR REGULATORY COMMISSION 8' 1 E REGION 11

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g 101 MARIETTA ST N.W., SUITE 3100

~[ ATLANTA, GEORGIA 303C3 g o@

'APR 2 e test INVESTIGATION REPORT N0. 50-400/82-03 and 50-401/82-03

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SUBJECT: Carolina Power and Light Company Shearon Harris Nuclear Plant Unit 1 Improper Welding Inspection Practices DATES OF INVESTIGATION: December 11, 1981 - February 26, 1982 INVESTIGATOR: _/ m O '/- / 9 f 2 -

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.' Vorse, Regional Investigator Date Signed

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forcement and Investigations Staff REVIEWED BY: A . L uu 4-2'4-8 CarlE/\Alderson, Director Date Signed Enforc6 dent and Investigations Staff f

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8208030706 820722 PDR ADOCK 05000400 G PDR

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i 1-1 A. INTRODUCTION On December 4, 1981, the NRC Resident Inspector assigned to Carolina Power and Light Company's Shearon Harris nuclear power plant, advised Region II that several personnel had complained to him tnat a welding inspector was not performing visual weld inspections properl The personnel who complained had no first hand knowledge; however, the rumor among the welders and welding inspectors was that if a hanger was located in an inaccessible area, the individual would not inspect the weld but would sign it off as acceptable. One

. complainant identified a specific hanger which was rumored to have not been properly inspected by the welding inspector. This hanger was inspected by the Resident Inspector and all welds appeared to be acceptable. Ilowever, the adjacent hanger had one weld which appeared to be rejectable. The Resident Inspector later learned the hanger welds had been inspected and accepted by the welding inspector in questio Based on the number of personnel who were complaining about the welding inspector's weld inspection practices and the potential impact on the welding inspection program, an investigation was initiated by Region II on December 11, 1981, under the authority provided by Section 161.c of the Atomic Energy Act of 1954, as amende B. SCOPE OF INVESTIGATION A review of the information supplied by the Resident Inspector disclosed one allegation to be addressed during the investigatio This was:

A welding inspector was signing off welds on hangers and pipes as acceptable when he had not visually inspected the During the course of the investigation, the Investigator held discussions with numerous current licensee and licensee contractor employees. Formal interviews were conducted with 59 individuals who were considered by the Investigator to have potential knowledge of the alleged acts or practices. The investigation also included an inspection of randomly selected hangers and pipes which had been l inspected by the particular welding inspector during the time frame the rumors began formin The investigation included a review of appropriate regulatory requirements, NRC records and licensee procedures and records including:

- 10 CFR 50, Appendix B

- Shearon Harris Quality Assurance Program Personnel Training and Qualification

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Visual Examination of Welds Procedure

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I-2 lii!s investigation was conducted by one investigator and two inspectors requiring a total of 42 man-hours of investigative and inspection activity on-sit CONCLUSIONS The allegation was substantiated in that the welding inspector had signed off weld inspections he had not personally performed; however, the welds had been inspected by inspector trainees who were working with the inspector. This results in two violations of NRC require-

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ments: Inspections were performed by uncertified welders; and Inspection records do not reflect the correct identity of the individuals who performed the inspection.

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i I DETAILS OF INVESTIGATION i

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d CAROLINA POWER AND LIGHT

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SHEAR 0N HARRIS NUCLEAR PLANT DECEMBER 14, 1981 - JANUARY 22, 1982 i

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l A. INDIVIDUALS CONTACTED l The following individuals were contacted during the course of the investigatio Carolina Power and Light (CP&L)

G. A. DeBarres, QA Weld Inspector

. K. A. Douglas, QA Weld Monitor R. L. Faulkner, QA Weld Control and Surveillance S. M. Freeman, QA Weld Inspector A. B. Giles, QA Technician J. C. McDonnell, QA Weld Inspector A. Lucas, Senior Resident Engineer E. W. Mercer, QA Weld Inspector S. W. Montastle, QA Weld Inspector R. M. Parsons, Site Manager

W. H. Pere, QA Weld Inspector K. B. Stanley, QA Weld Inspector R. B. Strickland, Mechanical Inspector G. G. Tingen, QA Weld Inspector T. Wait, QA Welding Supervisor Daniels Construction Company

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Crew P-21: Reactor Auxiliary Building (RAB)

R. V. McLeod, General Foreman ,

W. W. Burton, Pipe-Fitter Helper R. J. Carr, Welding Foreman J. F. Goodsell, Welder B. W. Nguyen, Welder K. M. Norton, Welder J. A. Owens, Welder G. S. Peck, Pipefitter R. D. Symank, Welder M. D. Warlick, Welder Crew P-35 (RAB)

W. T. Bohan, Foreman D. L. Cauble, Welder R. W. George, Pipe-Fitter W. J. Jenkins, Welder T. R. Merideth, Welder l M. D. Tatham, Welder i J. C. Woznick, Welder

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II-2 Crew P-17 (RAB)

D. E. Bradford, Pipe-Fitter C. A. Brigman, Foreman R. L. Grant, Pipe-Fitter T. M. Lazafame, Pipe-Fitter W. H. Martin, Welder J. E. Newsome, Welder J. B. Starnes, Pipe-Fitter Helper -

- L. L. Whitehead, Pipe-Fitter S. J. Whitlock, Fitter Crew P-14 (Waste Process)

R. A. Gardner, Foreman W. C. Lynch, Welder T. Smith, Welder W. B. Surber, Welder Crew P-20 (Waste Process)

J. A. Brincheck, Welding Supervisor K. T. Davis, Pipe-Fitter Helper J. D. Foster, Pipe-Fitter D. P. Freeman, Welder C. F. Green, Jr. , Welder J. W. Kilgore, Pipe-Fitter Helper J. F. Lynch, Pipe-Fitter D. C. Martin, Welder D. M. Shargots, Welder R. R. Stone, Pipe-Fitter N. C. Sulton, Welder G. G. Wilbon, Welder Daniels Technical Services, Ltd.

l D. A. Sands, QA Welding Inspector B. L. Holcombe, QA Welding Engineer Nuclear Regulatory Commission (NRC)

G. F. Maxwell, Resident Inspector

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II-3 ALLEGATION Occasionally, a welding inspector, Individual A, did not visually inspect welds on seismic hangers and piping. However, he signed documentation showing that he ha BACKGROUND The Resident Inspector at Shearon Harris nuclear site expressed

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concerns about certain workers approaching him and complaining about a welding inspector, Individual A. Several workers stated they were hearing other workers saying that Individual A was not looking at some welds he was signing off as acceptable. One individual stated to the Resident Inspector that if a weld was located in a difficult to access location, Individual A would not acquire the appropriate scaffolding to allow him to have access to the weld to be inspected. The Resident Inspector was further informed that he could find an unacceptable weld on seismic cate-gory 1 pipe hanger numbered A-3-236-1-CC-H-46 The Resident Inspector looked at the welds on that hanger and found no rejectable weld However, on an adjacent hanger, No. A-3-236-1-CC-H-342 the Resident Inspector found what was, in his opinion, a rejectable wel It was later determined by the resident inspector that this weld had been inspected by Individual A. Three additional hangers were looked at by the Resident Inspector and no rejectable welds were note INTERVIEWS OF WELDING INSPECTORS Eight weld inspectors including a supervisor, as well as four other personnel involved in the QA weld inspection program were interviewed by the Investigator. One individual stated he had heard rumors that Individual A " inspected from the floor". Two individuals

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stated they heard rumors that Individual A sometimes shined his flashlight on hangers from the floor but did not go up and visually check the welds. Five individuals stated they were aware that

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Individual A had a very bad case of arthritis during the summer months of 1981 and were surprised when they saw him up on the scaffolding. Two welding inspectors, Individuals B and C, stated i

they inspected welds before they (the inspectors) were certified.

l Individuals B and C provided the Investigator with signed statements I which contained the following information in essence:

Individual B started work as a welding inspector trainee beginning sometime in September 198 Initially, he was under the direct supervision and received on-the-job-training from Individual A. Individual A showed him what to look for -

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II-4 regarding acceptability and when to reject a weld. After about 2 months, Individual B began inspecting welds by himself, particularly in areas which were relatively inaccessible and high up. Individual A remained on the floor signing off the weld inspection documentation and provided Individual B with a sticker showing the weld had been inspected. Individual B placed the stickers on the hangers on which he had inspected

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welds. Individual B estimated that he had inspected welds by

. himself on approximately 50-75 hangers most of which were on the 90ft. and 236ft. elevations in the Reactor Auxiliary Building. Although he inspected the welds prior to being certified in January 1980, Individual B had no misgivings about those welds he accepte In fact, he believes he was on the conservative side and inspected all welds in accordance with AWS D1.1-75 Standard Individual C began his on-the-job-training with Individual A in October 1981 for pipe hanger welding inspection. Indivi-dual C estimates that he spent 3-weeks, 40 hours4.62963e-4 days <br />0.0111 hours <br />6.613757e-5 weeks <br />1.522e-5 months <br /> per week with Individual A and, although he could not recall how many hangers they inspected, he estimates ht.alone inspected about 75% of the welds. That is, those welds which were difficult to get to because of the need to climb scaffolds or physically difficult to get t When he rejected welds the first several times, Individual A climbed the scaffold, looked at the welds and agreed they were rejectable. Thereafter, Individual C rejected and accepted welds without Individual A looking at them. Individual A always signed the weld inspection fonns (Weld Data Report (WDR QA 34 and traveler)) as well as the weld inspection sticke Individual C estimates that he inspected welds on about 100 hangers by himself before he was certifie In all of these situations, Individual A signed the documentatio Like Individual B, Individual C had no reservations about the welds he had accepted. He also inspected the welds according to AWS D1.1-75 standard INTERVIEWS OF CRAFT PERSONNEL i Forty-two Craft personnel comprised of welding foremen, welders,

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pipe-fitters, and pipe-fitter helpers were interviewed by the Investigator. Twenty-seven individuals had no knowledge of Individual A and could provide no pertinent information. Three individuals stated they heard rumors that. Individual A would inspect from the floor and shine his flashlight on the welds. Five

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individuals stated they observed Individual A performing inspections on welds which were high up and difficult to get to. One welder, l

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Individual D stated that Individual A accepted welds without looking ,

at them. A signed statement was provided to the Investigator by 's

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Individual D which contained the following information in essence: ,

Sometime in the late spring or early summer, Individual D was assigned to assist IndGidual A,in locating and providing

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access for. inspection of welds'on piping. This transpired o,n ,

a Saturday with no one else in the general area. The pipes

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Individual A remained on the floor and Individual D climbed the scaffolds and ladders, placing stickers on pipes signify \ A ing the welds had been inspected. Individual A signed off the

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paperwork. Individual D estimates that this activity took

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place on approximately 100 welds, all non-safety Category 6 '

and 7. Individual 0 expressed concerns to co-workers and '.

opined that this was the source of all the subsequent talk going around the plant about Individual A not inspecting the welds. Individual D thought Individuals E and F may'have knowledge about similar occurrence ~

Individual E was interviewed and stated he had no first hand knowledge about improper welding inspection. Individual E only acknowledged hearing rumors that Individual A had welders put stickers on pipes for him. Individual F was interviewed by the Investigator and he

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provided a signed statement containing the following information'in essence:

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IndividualF,apipefitterhelper,estimateshhassisted Individual A in locating welds approximately 500 times. Most of the welds were easily h cessible and were looked at by Individual A. On one cccasion, however, in September 1981, Individual A glanced at two category T (non-safety related) 3 l

welds which were located approximately 20 ft. above hi '

l These were off the "MY column" and " column 2" of the East-West Hallway of the waste process area. Individual A signed the; inspection sheet and handed the carbon copy to Individual F for the craft records. He also gave Individual F two filled -

out stickers instructing him to place them by the weld "

However, Individual F did not do so because there was no t scaffolding or ladder available, so he took the stickers

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hom Individual F was later requested by the Resident ,

Inspector to provide him with the stickers. Only one was '

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still available and this was given to the Reiident Inspector by Individual F. This same sticker was late; provided to the Investigator. The sticker bears the initials of Individual \

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II-6 Based on the information provided by Individual D regarding Indivi-dual A's not inspecting welds on a Saturday when no others were in the indicated area, a foreman, Individual G was asked to provide the names of craft personnel who assisted Individual A on Saturday Individual G provided those names to the Investigator. They were:

Individuals H, I, J, K, L and These personnel were interviewe Individuals H, I, J and M stated they ob' served Individual A inspect welds from scaffolds and ladders on Saturdays and he always appeared to be inspecting carefull Individual K stated he observed Indivi-dual A inspect the welds although he seemed reluctant to go hig *

Individual L stated he assisted Individual A with approximately 100 weld inspections. On one occasion, Individual A shined his flashlight from a distance and accepted one weld. This, according to Individual L, was on code 6 and 7 non-safety related piping, located high off the floo F. INTERVIEW 0F INDIVIDUAL A (WELDING INSPECTOR)

Individual A was interviewed at Shearon Harris on December 17, 1981 and he provided a signed statement containing the following infor-mation in substance:

Regarding signing off welds that he did not actually look at, but which were inspected by trainees, Individual A explained that he was always within close proximity to them. When questioned by the Investigator as to whether or not he remained at floor level while the trainee inspected welds high on the scaffolds, Individual A declined to state where his exact physical location was except that he was in the "immediate vicinity". Individual A explained that sometime around April 1981, EBASCO began sending revisions requiring reinspection of some pipe hangers. Subsequently, for about a 3 month period, Individual A went out and looked at the respective hangers. No welds had to be inspected but he did have to verify the hanger ( was physically present. Therefore, Individual A would often l

shine his flashlight on the hanger while standing on the floor to ensure the hanger was present and in its proper locatio He would then sign off the revised drawing and give to whoever was assisting him, a sticker indicating the date the hanger was

" inspected" to the latest revision. The assistant would then i place the sticker somewhere on the hanger. Individual A believes l this may have been misconstrued by others in the vicinity that he was signing off welds without actually looking at them. In fact, none of the welds on the hanger required any inspectio Individual A estimates that he inspected approximately 100 hangers in this manner. Individual A denied having not inspected welds on pipes or hangers, but signing them off as acceptable.

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II-7 G. WELD INSPECTIONS BY NRC Based on the statements, made by several individuals, that Individual A signed off pipe welds without inspecting them, the Region II Engineer-ing Inspection Branch was reqcested to conduct an inspection of randomly sampled welds on hangers and pipes. It was further requested that they draw samples from:

Areas which were relatively difficult to access;

- Welds which were inspected on Saturdays; and Welds which were inspected during the April-September 1981 time fram The results of the reinspection.of welds conducted by NRC inspectors are documented in NRC Inspection Report Nos. 50-400/82-01 and 50-400/82-06. A summary of that inspection is included herewith as Enclosure 1. Two violations were identified by the inspectors and they are discussed in the referenced inspection repor H. REVIEW 0F LICENSEE PROCEDURES The probicm of uncertified individuals performing inspections and the inspection reports for those inspections being signed off by a certified inspector was discussed with the CP&L Site Manager and Senior Resident Engineer. They stated that such actions were permissible in accordance with licensee procedure CQA-1, " Personnel Training and Qualification".

A review of that procedure disclosed that Paragraph 7.1 contains the following:

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" Emphasis will be on firsthand experience gained through actual l performance of processes, tests examinations, and inspection As the inspector in training develops proficiency, he may be 3 allowed to perform certain functions with minimal supervision; he>.vever, he will not be permitted to " sign-off" hold points in verification of quality requirements for work activities."

In response to the Investigator's comments regarding the inspecticn records being signed by an inspector who had not actually inspected the weld, the licensee's site management representatives stated that the certified inspector was accepting responsibility for the welds, therefore the inspector would only permit the trainees to accomplish the inspection when he believed they were qualifie . .-

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II-8 The licensee's procedure and implementation of the procedure is inconsistent with the requirements of ANSI N45.2.6-1973 which the licensee committed to follow in that the trainees had not been certified to perform the inspections in question; that is, no

" certificate of qualification" meeting the requirements of Section 2.2.4 of the Standard had been completed for the individual The licensee's procedure is also inconsistent with Criterion 17 of Appendix B to 10 CFR 50, which requires that inspection records

. identify the inspector who perfonned the inspection. An inspector cannot " accept responsibility" for an inspection that he did not personally perfor I. FINDINGS The allegation was substantiated in that the welding inspector

.igned inspection records indicating that he had inspected welds and found them acceptable when, in fact, he had not personally inspected the welds. This action results in two violations of NRC requirements. These are: The inspection records did not identify the individuals (B and C) who had actually performed the inspections as required by 10 CFR 50, Appendix B, Criterion XVII and Section 1.8.5.17 of the PSAR; and The inspections were perfonned by individuals (B and C)

who were not certified to perform the inspections in accord-ance with ANSI N45.2.6-1973 as required by 10 CFR 50, Appendix B, Criterion II and Section 1.4.9(1.58) of the PSA These violations appear to be the direct result of inadequacies in licensee procedure CQA-1 (Rev. 4), " Personnel Training and Qualifica-tion" or the licensee's interpretation of that procedure as discussed in Paragraph H abov m ,

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i ENCLOSURE 1 Followup on Regional Request Certain pipe welds and a random sample of difficult access welds on seismic supports inspected by a certain welding inspector during a particular time frame

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were reviewed by inspectors from the Materials and Processes Sectio . The following seismic Category I welds were re-examined by Region II inspectors during the week of January 19-22, 1982:

COMPONENT ID/ WELD N SYSTEM ITEM INSPECTED CS-H-1790 Chemical and Volume Centrol Seismic Hanger CX-H-1623 Chilled Water Return Seismic Hanger CC-H-469 Component Cooling Seismic Hanger BD-H-144 Blowdown Seismic Hanger BR-H-731 Baron Recycle Seismic Hanger CS-H-137 Chemical and Volume Control Seismic Hanger RM-H-366 Reactor Make-up Water Seismic Hanger SI-H-1018 Safety Injection Seismic Hanger SF-H-704 Spent Fuel Pool Cooling and Cleanup Seismic Hanger CC-H-800 Component Cooling Seismic Hanger CT-H-205 Containment Spray Seismic Hanger SW-H-2343 Service Water Seismic Hanger

• CC-H-342 Component Cooling Seismic Hanger

• NOTE: This hanger was alleged to be unacceptabl In addition to the above welos, the inspectors also inspected the following welds j on the laundry and hot shower taak #591-4B, that were alleged to be rejectabl ISOMETRIC WELD JOINT SYSTEM 1-WL-1095 FW-3708 Waste Liquid 1-WL-1092 FW-3702 Waste Liquid 1-WL-1090 FW-3697 Waste Liquid Discrepancies noted as a result of the NRC reinspection are as follows: The inside of the box frame windows for hanger CC-H-469 had not been welde A review of the records for this hanger revealed that the weld inspector had mistakenly referenced a field change that would have deleted these welds if the hanger had been designed for a twelve inch pipe or smaller. Hanger CC-H-469, however, was designed for two 18-inch pipe ~

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Enclosure 1 2 Field pipe welds FW-3708, FW-3702, and FW-3697, located on the top of the laundry and hot shower tank, had small arc strikes on the base metal adja-cent to the field welds. Carolina Power and Light Company (CP&L) procedure NDEP-601 for visual examination of welds, paragraph 9.11, states that " weld and adjacent base metal shall be free of visible arc strikes, weld spatter and mishandling marks",

~ In addition to the above pipe field welds, arc strikes and weld spatter were i

noted on vendor welds between the above field welds and the tank. The weld inspector had not reported this condition as required by paragraph 19.9 of CP&L's Quality Assurance Program for Radioactive Waste Management Syste The three examples noted above were reported as a violation of 10 CFR 50, Appendix B, Criterion V and was assigned number 50-400/82-01-03, Failure to Follow Procedures / Instructions for Visual Examination of Welds and Reporting of Discrepancie As a result of the reinspections conducted during January, the Region II inspectors concluded that the samples taken were representative of the more difficult inspections the inspector in question had made on seismic supports. Although one item of noncompliance was found, the NRC inspectors concluded that this was an oversight by the welding inspector. When reading the instructions he apparently failed to see that the field change had size limitation The NRC inspectors found inspection stickers with the individual in question's name on supports that were very high and difficult to reac This indicated that the weld inspector had made the inspections since all of the reinspected supports were examined during the period that the weld inspector was working alone. As for the reinspection of the three pipe welds that were examined by the inspector in question, two discrepancies were noted in this area and reported abov The Region II inspection concluded that a larger sample of pipe welds; particularity Non-ASME welds inspected by this individual would need to be reinspected on a subsequent inspection. An inspector follow-up item 400/82-01-05, Inspection of Pipe Welds was open to track this proble . During the week of February 23-26, 1982 the Non-ASME welds listed below were re-examined by Region II. The safety significance cf this non-ASME pipe is established by section 1.8 of the Harris FSAR, which ccmmits to Regulatory Guide 1.143. The Guide identified the radioact tve waste management systems as an activity important to safety and requires inspection in accordance with ANSI B31.1. CP&L procedure NDEP-601, Revision 0, conforms with the requirements of ANSI B31.1 and is the procedure used by CP&L for visual inspection of the Waste Processing Syste .