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Up Topic Welding Industry / Technical Discussions / Problem with NRC
- - By Rick Hoople (*) Date 02-07-2009 19:42
Our company is building a crane for a nuclear power plant that will be governed by the NRC. My question is that we had a vended part come in that needed to be removed from a truck, and it had no lifting lugs to do so. We welded some on and that's when all hell broke loose. It turnes out that we didn't use their specified wire for weld joints to add this item which will be totally removed when not needed. The wire used was a material compatable wire, but not their wire. Could this become a pissing contest or is there really a concern with this? Material is A36, wire recomended for joints is TM771 with a C25 mix. What was used for the lugs was ESAB 86 wire, which is a 70 series wire with
90 -10 Arg. Co2 mix. HELP!
Parent - - By CWI555 (*****) Date 02-07-2009 20:50
Im afraid your in trouble. It doesn't matter if the material was legal or not. If that crane is a 10CFR appendix B item then your in violation of the required CFR quality program.
Pissing contest is going to be the least of it.
Parent - - By Rick Hoople (*) Date 02-07-2009 22:01 Edited 02-08-2009 00:01
Thanx Gerald,
I was afraid of that. The welder involved may have an issue here. Although I'm not sure if it is in fact a 10CFR crane. It is however going to be used for core removals.
Parent - - By CWI555 (*****) Date 02-07-2009 22:50
Well my name is Gerald :)

As for if it's a 10CFR item, utilization for core/core barrel removal is definitely going to put it in that category. Failure of that item during core removal could have severe consequences for nuclear safety. You may as well have made a weld on the reactor vessel without a WPS/PQR/WQR.

I advise you to review 10CFR to understand what it is you'll need to do to fix it. As a minimum, the repair areas will require a quality program that satisfies the 18 points covered by the part B appendix. I would consider bringing in the company that made the piece to do the repairs if they already have this in place. I would also suggest interfacing with the NRC and end user ANI to get their input before doing anything. I would also find out which engineer had the lack of foresight to put lifting lugs on the thing to begin with, and re-calibrate all persons including him or her that had a hand in putting you in this position. Best case scenario you will be allowed to repair etc. Worst case scenario you can be required to 86 the piece in question. Your pretty much at the mercy of the end user and the NRC and what mood their in. Strongly advise putting your best oil tongue out their for the interface with them.

Regards,
Gerald
Parent - - By Rick Hoople (*) Date 02-08-2009 00:01
My humble apologies for the wong name here Gerald, and thanx a bunch for your input.
Parent - - By CWI555 (*****) Date 02-08-2009 00:42
no apology necessary. Was just a friendly reminder. :-)
Parent - - By Rick Hoople (*) Date 02-08-2009 07:04 Edited 02-08-2009 10:47
Without appearing to ignorant. What does CFR stand for?
Parent - - By CWI555 (*****) Date 02-08-2009 14:35
Code of Federal Regulations.
Parent - - By Rick Hoople (*) Date 02-08-2009 17:08 Edited 02-08-2009 17:15
Thanx! This is information I should of had available to me. The part did have lifting eyes on it at one time, but when we got it they were cut off. Truck came in unanounced and put some in the position of MOVE IT NOW mode. The worst part about the whole thing now I find out is the part was stress releived, compounding the the problem we now have. I need to get my hands on that 10CFR just to see how deep in dodo we really are. I don't think a well oiled tongue will suffice on this one.
Parent - By CWI555 (*****) Date 02-08-2009 21:51
You have to understand that 10 CFR appendix B covers the quality assurance program and the minimum elements thereof. This is mandated by United States Federal Code. In other words it has the force of law. Anyone knowingly found to be subverting those requirements runs the risk of going to jail at worst and fined at best.

It's not something you can wave a wand and make it go away. The intended use of this item puts you squarely within those bounds. In order for it to have been built to begin with, it should have the quality program in place somewhere in the chain. Under no circumstance should you try to make it go away. Get the right people on the phone, in your shop, etc and do it every bit above board.

Appendix B also only covers the quality program. Digging into the relevant Nuclear regulatory commission mandates will unveil many other requirements for this item as well.
The bottom line is you need an expert ideally former NRC or Hartford ANI to guide you through the minefield you've found yourself in.
I cannot caution enough not to screw with this in the dark, you wouldn't be the first to have gone to jail for just trying to get it done in these circumstances.

Regards,
Gerald
Parent - - By G.S.Crisi (****) Date 02-08-2009 19:11
Many times questions regarding welding of cranes' booms or traveling cranes beams have been posted on this Forum. Based on my own experience from my days of erector engineer I've always recommended not to do anything before contacting the crane manufacturer and ask for his instructions. It's a matter of responsibility.
If you make a weld on the structural parts of a crane on your own and something happens afterwards, as was the unfortunate Rick's case, the responsibility will be yours.
Giovanni S. Crisi
Sao Paulo - Brazil
Parent - By Superflux (****) Date 02-08-2009 20:41
Sounds like the easiest way out would be to weld on the lugs (per qualified procedure) send them back to heat treaters and then the lugs can be removed at your convenience when the part returns to your shop.
I feel your pain...I was fired back in 1991 over a weld-on lug incident that failed during the lift. No collateral damage, it just broke off as soon as the rig put a bind on it (Quenched & Tempered steel part) same senario, "hurry up!! git lug eye on'er and git truck outta here! (I hated that foreman anyway, he was a neanderthal)". I was just the welder and "did what I was told", but someone's head was going to roll since there were so many on lookers.
The lesson learned is that every weld I make IS MY WELD and I don't touch nothing with out all info available now.
When it comes to proper rigging practices, even a 100 ton solid steel sphere can be lifted safely with out weld-on attachments. The weld on a lug trick, as we did often in the mines is just a fast way to cheat and often begging for mishaps.
Parent - - By Joseph P. Kane (****) Date 02-08-2009 20:50
Rick

Listen to Gerald on this one.  Someone could go to jail!

Joe Kane
Parent - - By Superflux (****) Date 02-08-2009 21:01
Ditto that!
Best start getting the RFI and NCR well written and documented.
If you do this "by the book",  worst case scenario is the company bought that crane part. When managers try to "fudge the paper" is when you've got some SERIOUS problems!
You don't "F" with the feds and the NRC!
Parent - By Rick Hoople (*) Date 02-09-2009 00:54 Edited 02-09-2009 01:05
I will try to keep everyone posted as to what we all encounter in this. Big lesson learned for every one here, and yes, you don't "F" with the Fed or NRC.
Parent - - By MBSims (****) Date 02-09-2009 02:49
Jail?  Based on what was described, there may have been a failure to follow proper procedures or a violation of quality assurance program requirements, which may result in a Notice of Violation.  But this does not sound like someone tried to cover it up or falsified information.  You guys are getting a bit carried away with the suggestion that "jail" might result on this event.
Parent - - By Superflux (****) Date 02-09-2009 12:27
Sure, here in this forum it all sounds on the up and up. Out there in the real world, I've seen owners, inspectors and managers try to bury bigger screw-ups than this.
Parent - By 803056 (*****) Date 02-09-2009 16:42
When you are working on nuclear components and the feds are involved, the easiest way to find yourself in a jam is to try to cover your tracks.

Admit mistakes were made and work with the powers to be to address them.

What happens in the commercial sector has no bearing on what happens in the nuclear industry. Any regulations that are included in the CFR has federal enforcement. That isn't anything to take lightly.

Best regards - Al
Up Topic Welding Industry / Technical Discussions / Problem with NRC

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