IR 05000327/1987044

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Insp Repts 50-327/87-44 & 50-328/87-44 on 870622-26 & 0720- 24.Major Areas Inspected:Employee Concerns Task Group Final Element Repts in Categories of Welding & Matls Control
ML20235V245
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 09/23/1987
From: Fair J, Georgiev G, Hermann R
NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20235V238 List:
References
50-327-87-44, 50-328-87-44, NUDOCS 8710150062
Download: ML20235V245 (21)


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I ENCLOSURE s

i UNITED STATES NUCLEAR REGULATORY COMMISSION OFFICE OF SPECIAL PROJECTS TVA PROJECTS DIVISION Report Nos.:

50-327/87-44 and 50-328/87-44 Docket Nos.:

50-327 and 50-328 License Nos.:

DPR-77 and DPR-79 Licensee:

Tennessee Valley Authority Facility Name:

Sequoyah Nuclear Plant Units 1 and 2 Inspection Conducted:

June 22-26 and July 20-24, 1987 Inspectors:

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er Date George Geof'giev/ Team L (b;;'->(

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l Consultants:

M. Schuster, C. Czajkowski, W. Marini

D Approved by:

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D Robert A. Hermann, Branch Chief i

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.i.. PERSONS. CONTACTED.

1.1 Licensee Employees

C. Whittemore,.

.TVA Licensing R. D. Briggs, TVA, DNE

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J. W.-Kelly, TVA, DNE

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T..J.-Arnsy, TVA, DNQA

J. C. Brady, TVA, Maintenance

T. J. Akers.

TVA, Communications

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T. J. McGrath, TVA, ONP; T. Knight,-

TVA, Sequoyah

C. R. McWherter, TVA, ONP

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C. R. Brimer,.

TVA, DNE

E. R. Ennis TVA, Sequoyah

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J. R. Inger TVA,WBN/ECTG R. C. Wenney

~TVA, Sequoyah

G. B.-Kirk TVA,DNSL/SQN T. L. Howard.

TVA, DNQA i

L. G. Hebert-TVA, DNQA

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T.- A. Flippo TVA, DNQA J. T. LaPoint TVA, Sequoyah F. Lewis TVA, QA l

A. Verner TVA, QA R. Grimes TVA, ECTG

.J. Weishoupt TVA, ECTG S. Lock TVA, HCTTG W. Harris, Jr.

TVA, HCTTG G. Wade TVA, DNE D. Chatman TVA, Maintenance 1.2 NRC Resident Inspectors K. Jenison, Sr. Resident Inspector D. P. Loveless, Resident Inspector P. E. Harmon, Resident Inspector j

Attended Exit Interview at Sequoyah, July 23, 1987

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2.

INSPECTION SCOPE AND OBJECTIVES

i This special announced inspection was conducted at TVA's Sequoyah Nuclear l

Plant (SQN) site. The inspection was performed to review and evaluate four

- final element reports prepared for Sequoyah by)the Employee Concern Task Group (ECTG) in the categories of welding (WP Report and materials control (MC d

- Reports). The objective of the inspection was to determine the accuracy of the information' contained in these four reports and to determine the adequacy of

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TVA's conclusions and corrective actions.

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DISCUSSION j

During this inspection, the NRC team reviewed four element reports. Two of the reports were satisfactorily written and two required revision or additional-

written explanation to clarify, add details, or modify TVA's existing corrective actions. The four element reports and the associated NRC observations are as follows:

a.

WP-25-SQN, " Improper Weld Repairs"--TVA adequately addressed the issues raised by two employee concerns. No additional work or corrective action is required.

b.

MC-40503-SQN, " Valves (Test 70)"--TVA adequately addressed the issues raised by this employee-concern.

No additional work or corrective action are required.

c.

MC-40703-SQN, " Heat Code Traceability"--TVA adequately addressed the

issues raised by this employee concern. However,. the NRC team considered the proposed corrective actions in the small-bom piping materials area. to be inadequate.

Specifically, the acceptance of 2.5 percent of nodal points for small-bore piping based upon actual material properties and thicknesses is considered unacceptable.

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MC-40709-SQN, " Search for Defective Material"--TVA did not adequately address the issues raised by the employee concern for the following reasons:

TVA did not review all applicable suppliers identified in NRC

Bulletin 83-07. TVA must review all revisions to the safety-related supplier list for the applicable time frame, and ascertain that it has addressed all suppliers appearing on these revisions and on the attachments to NRC Bulletin 83-07.

Vendors not listed in the approved. vendor list have supplied

safety-related materials. TVA has not reviewed enough of those vendors to determine whether those unlisted vendors may have supplied fraudulent materials. TVA must review an adequate number of suppliers of piping, tubing, and fittings who do not appear on the safety-related suppliers' list to determine whether potentially fraudulent Ray Miller. Inc. material was procured through them.

Additional information is needed to confirm the validity of a statement made to TVA by Dravo Corporation personnel with reference to materials that Dravo procured from Ray Miller, Inc. TVA must obtain additional information from Dravo to ascertain that the material purchased by Dravo (as identified in NRC Bulletin 83-07) was not subsequently supplied to TVA.

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INSPECTION DETAILS i

The NRC team reviewed four element reports and the associated documentation relevant to those reports.

In addition, the NRC team interviewed informed TVA personnel to obtain pertinent information concerning the review and resolution of employee concerns associated with these four reports. Each of these reports is addressed below.

4.1 Element Report WP-25-SQN, " Improper Weld Repairs"

4.1.1 Documents Reviewed

Element Report WP-25-SQN

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Sequoyah Plan of Action report " Wall Degradation in Fluid Piping Caused by

Erosion and Other Specified Mechanism" Sequoyah Inspection Report " System 67 (ERCW) Localized Erosion Downstream

of Butterfly and Ball Valves Utilized in Throttling Service" Administrative Instruction AI-9, " Control of Temporary Alterations and Use

of the Temporary Alterations Order" Administrative Instruction AI-19, " Plant Modifications After Licensing" DNE calculations, " Essential Raw Cooling Water Corroded Piping Qualification" The document packages for Maintenance Requests A-117635, A-007982, A-232960

and A-285930.

The document packages for Work Plans 11249, 11250, 11304, 11505,

11731, and 11558 4.1.2 Discussion and Observations This element report addresses two employee concerns, XX-85-100-001 and

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2850162-005. The concerns involved temporary weld repairs using weld overlay

and patch plates which are not in accordance with the ASME Code. The report I

I states that weld overlays were used at the Browns Ferry Nuclear Power Plant and that the weld repair patches were used at Sequoyah. The NRC team reviewed only the information relevant to Sequoyah.

The review of the information contained in the documents referenced above revealed that on several occasions 12 patch plates were welded on the

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essential raw cooling water (ERCW) system. The details of those weld repairs follows:

In September 1983, a leak was observed at a tee located on the ERCW system. Maintenance Report MR-A-049430 was generated as a result of this observation. The repair was completed on October 4, 1983 by welding a carbon steel patch plate on the west side of the tee, located between 1-FCV-67-146 and 1-FCV-067-152.

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-4-In November 1983, another leak was observed on an elbow located on the ERCW system. MR-A-087982 was generated as a result of this observation.

The repair was completed on November 14, 1983 by welding a carbon steel patch plate on the elbow downstream of 0-VLV-067-551B.

A baseline ultrasonic testing (UT) program was developed to check the pipe wall thicknesses every 6 months on the ERCW system.

In February 1984, the UT measurement identified two pipe wall thinnings on a tee downstream of 1-FCR-067-147 and on a spool piece between 0-VLV-67-551A and 1-FCV-067-146.

MR-A-232980 and MR-A-232958 were generated as a result of this observation. The repairs were completed on April 9, 1984 by welding two carbon steel patch plates on the thin areas.

In August 1984, a leak was observed on a pipe on the north side of 2-FCV-067-146. MR-A-285930 was generated as a result of this observation.

The repair was completed on August 18, 1984 by welding a carbon steel patch plate on the pipe.

In September 1984, the UT measurement identified wall thinning on the south side of a pipe downstream of 0-FCV-067-146. Work Plan WP-11246 was generated as a result of this finding. The weld repair was completed on September 17, 1984 by welding a stainless steel patch plate on the thin area.

In September 1984, the UT measurement identified wall thinning on the inside radius of an elbow downstream of 0-VLY-067-5518 and on the top of spool piece between 0-VLV-067-551A and 1-FCV-067-146. WP 11250 was generated as a result of this finding. The repair was completed by welding two stainless steel patch plates on the thin areas.

In October 1984, a leak was observed on the south side of a tee between 1-FCV-067-146 and 0-FCV-067-152. WP-11304 was generated as a result of this observation. The repair was completed by welding a stainless steel patch plate on the leaking area.

In April 1985, the UT measurement identified wall thinning on the bottom of a saddle tee located on a 30-inch pipe at the 24-inch connection. WP-11558 was generated as a result of this finding. The repair was completed by welding a stainless steel patch plate at the bottom of the saddle tee.

Subsequent inspection of the internal surfaces of the pipe performed by an ISI level 3 inspector established that the pipe did not show any cavitation or wall thinning.

Therefore, the original UT measurements were found to be incorrect.

In April 1985, the UT measurements identified wall thinning on the south side of a tee between 1-FCV-067-146 and 0-FCV-067-152. WP-11505 was generated as a result of this finding. The tee was repaired by welding a stainless steel patch plate on the thin area.

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-5-In August 1985, a leak was observed on a 2-inch branch connection

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downstream of 2-FCV-067-146. WP-11731 was generated as a result of l

this finding.

The repair was completed by weldine a stainless steel I

patch plate over the leaking area.

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in late August 1985, TVA decided to replace all degraded pipe and to coat the internal surfaces of the pipe with Belzone coating. All existing patch plates were removed, except for the one installed under WP-11558.

This patch plate was not replaced because an inspection of the internal i

surfaces of the pipe by an ISI level 3 inspector established that the pipe j

did not show any signs of cavitation or wall thinning.

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The current long-range plans provide that each of the existing three

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component cooling system (CCS) heat exchangers be replaced with two plate-type heat exchangers. This will require the installation of 6 new heat exchangers. The following Engineering Change Notices (ECN) have been written for this modification:

ECN 6474, heat exchanger C; ECN 6486 heat exchanger A; ECN 6429, heat exchanger B; ECN 6656, bypass; ECN; 6788 and ECN 6789, header changeouts After this modification is completed, the need to throttle using butterfly valves will be eliminated which, in turn, will eliminate the pipe cavitation problems associated with the discharge from the CCS heat l

exchangers.

The NRC team's review of the information pertaining to this issue confirmed that TVA has used reinforcement patches as temporary repairs to ASME Class 3 and ANSI Standard 831.1 pipe fabricated systems in cases of leakage or where pipe wall thinning has been identified by UT.

In all cases, the work was performed and controlled in accordance with the requirements of the governing maintenance and modification procedures (AI-9 and AI-19) using either MRs or WPs. The work was also reviewed by the authorized nuclear inservice inspector (ANII).

The ANII had indicated on the written documentation that temporary

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t repairs such as patch plates fall outside the jurisdiction of the ASME Code Section XI. Therefore, the concern that TVA makes weld repairs that are not in accordance with the ASME Code was substantiated. However, in all cases, the repairs were performed by welders and welding procedures qualified in accordance with the requirements of ASME Code Section IX and the work was J'

documented in accordance with the TVA's ASME Section XI Repair and Replacement Program; thus, the plant's safety operation and performance was never compromised.

4.1.3 Conclusions Patch plate welds were used to repair the ERCW system from September 1983 l

through August 1985. These repairs fall outside the jurisdiction of ASME Code Section XI; thus, the concern that TVA makes repairs that are not in accordance

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with the ASME Code was substantiated. However, the NRC team concluded that the safe operation and performance of the plant was not at any time compromised because the repairs were performed in accordance with the TVA's ASME Code l

Section XI Repair and Replacement Program.

TVA has also replaced most of the

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patch plates and the three CCS heat exchangers will be replaced with six l

plate-type heat exchangers.

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4.2.' Element Report MC-40503-SQN, " Valves (Test 70)

4.2.1 Documents Reviewed MC-40503-SQN report TVA MI-6.21, Rev. 11

.TVA SQA45, Rev. 26

TVA.SQA162, Rev. 5, App. 2 TVA MI-6.20. Rev. 11 TVA AI-19 (Part IV). Rev. 18

TVA SQO28, Rev. 2

Valve Data Sheet 47VD600, sh. 1

Valve Data Sheet 47VD406-1, sh. 1

Valve Data Sheet 47VD450-20, sh. 10

. Purchase Order 81PE4-320035

Bill of-Material.478M406-8, Rev. O

Bill of Material 47BM454-1, sh. 12, Rev. 1 4.2.2 Discussion and Observations Oneconcern(EX-85-181-001) evaluated in this element report questions the adequacy of valve installation inspections performed under " Test 70" by quality control (QC) inspectors. The element report defines the following two issues:

"Are mark number tags essential for valve identification at installation?"

"If valve mark number tags were to be removed or replaced (switched),

are procedures in place to ensure that the correct valves are installed?"

The' Employee Concerns Task Group (ECTG) evaluator concluded that valve mark number tags are not used by Office of Nuclear Power personnel to identify valves at installations at Sequoyah.

The review of Element Report MC-40503-SQN, Rev. 3 and the documents listed above, and conversations with licensee personnel at Sequoyah revealed the following:

During the original procurement phase of the project, the TVA Department

of Nuclear Engineering (DNE) had utilized " mark numbers" to identify the j

various.like items contained on Bill of Material drawings for the purpose

of tabulating the quantities of the purchased items.

For valves, the mark numbers and quantities were then entered on the

i Valve Data Sheet, which identified all applicable technical requirements for each individual type of valve appearing on the Bill of Material.

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this way, several Valve Data Sheets could be attached to a purchase order form to facilitate ordering.

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When these bulk quantities were received, mark number tags were attached in order to identify the Bill of Material to which they ~ pertained.

It should be noted that these mark number tags were attached in addition to f

the required permanent nameplates and/or code data plates.

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Currently, such small quantities of valves are being purchased for a

specificpurpose(i.e.,systemmodificationordirectreplacement)-that the technical requirements can be listed in the body of the purchase order without the need for attaching a Valve Data Sheet..Therefore, there is no longer a need to assign a mark number'to these items, and such a number i

is no longer being.used to identify valves in either purchasing, receiving, warehousing, or installation tasks.

A review of applicable procedures reveals that there is no requirement i

for, or even mention of, mark number tags during either procurement or installation.

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4.2.3 Conclusions There is no need for valve mark number tags in order to ensure that the correct type of valve is installed in the specified location.

The NRC inspectors concluded that TVA's investigation and resolution of the concern were adequate.

4.3 Element Report MC-40703-SQN, " Heat Code Traceability"

-i 4.3.1 Documents Reviewed Element Report MC-40703-SQN, Rev. 2 I

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Executive report on test code traceability at Sequoyah Nuclear Plant (SQN)

Sequoyah Piping Materials List

Class A System Modification List

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Element Report MC-40705-SQN Employee Concern Program Investigation Report related to NRC open allegation (R11-84-A-0187)

CAR-086-052

CAR-086-055

CAR-086-064 Employee Concerns IN-85-660-001, IN 85-545-XO7, EX-85-023-001, WI-85-008-002 and XX-85-027-X02 HCTTG Materials Traceability for Piping Systems SQN Report B25870225-036 Attachment I - Unit 1/ Unit II Large/Small Bore Installation Weld Maps and

Weld Data Packages TVA Purchase Requisition No. 92165 (NAVCO)

TVA Systems Materials Specification

ANSI Standard B31.1-B31.7-ASME Code Section III as applicable

SQN Document Control Procedure AI-7

HCTGG Audit Report

i Calculation RIMS B45 870415 803

Calculation RIMS B41 870416 016 Calculation B29 870409 001

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" Stress Indices for ANSI Standard B16.11 Socket-Welding Fitting," ORNL-TM-4929, August 1975 Design Criteria SON-DC-V-13.3 and SQN-DC-V-13.3.1

Calculation RIMS B41 870420 009

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Calculation RIMS B41 870420 010

Calculation RIMS B41 870418 001

4.3.2 Discussion and Observations This element report addressed five employee concerns. Three of the concerns, IN-85-545-X07, WI-85-008-002, and XX-85-027-X02, related to a lack of credibility of methods used during construction to be certain that properly certified materials have been installed during construction.

The other two concerns, EX-85-023-001 and IN-85-660-001, related to a lack of credibility of methods used during plant modification performed after the plant was placed in operation.

TVA designated an Employee Concern Task Group on July 1, 1986 to investigate these concerns. The results of this investigation were documented in TVA

Element Report No. MC-40703-SQN. This report identified more than 200 possible discrepancies between Sequoyah Units 1 and 2 on safety-related piping (98 at Unit 1 and 110 at Unit 2).

TVA (Division of Nuclear Engineering) then assembled a new investigative uni.t.

the Heat Code Traceability Task Group (HCTTG) to evaluate and resolve the issues raised by the ECTG. This report (B25870225-036) reduced the 208 original discrepancies to a total of 7 items of noncompliance (missing weld records, and with its expanded single scope identified an additional 17 items of missing weld identification).

These investigations led to the issuance of three Corrective Action Reports (CARS)--SQ-CAR-86-052, SQ-CAR-85-055, and SQ-CAR-86-064--which document the -

proposed applicable ccrrective actions to the discrepancies and program deficiencies.

As a result of disagreements between members of the ECTG and the HCTTG regarding the proposed TVA corrective actions to resolve the employee concerns, independent experts assessed the issues. The report documenting the findings of consultants Kelly and Landers was issued on April 21, 1987.

This report partially stated:

The current, as-analyzed stress values of TVA Class A small bore piping have been reviewed.

The nodal points which exceeded 60 percent of either code allowable stress or actual allowable stress were tabulated.

There were approximately 2600 nodal points used for the small bore piping analysis of TVA Class A piping.

Two and one-half percent of the nedal points had stress ratios which were not capable of meeting the 40-percent reduction on the code allowable stress.

Similarly,1.8 percent of the nodal poiints had stress ratios which were not capable of meeting the 40-percent reduction on the actual allowable stress.

The report also partially concluded:

In summary, the material control problem is limited to small bore piping. This report demonstrates that there is no technical difference

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In conclusion, the engineering evaluations demonstrate that the installed small bore pipe and fittings i

comply with ANSI B31.7c Code requirements when the-40 percent allowable stress reduction factor is used in lieu of NDE. Thus, plant safety is assured.

This reduction in allowable stress refers to paragraph 1-724 in ANSI B31.7c-1971 which states in part:

Unless otherwise required by the Design Specification, and provided all other applicable requirements of this division (1-274) are met, the non-destructive examination requirements of this division do not apply to:

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Non-pressure-retaining material:

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Seamless pipe and tube, seamless forged socket welding fittings, and seamless wrought butt welding fittings 2-inch nominal pipe size and smaller provided that:

The pipe, tube and fittings are made of P number 1 or P number 8 a.

materials that meet all requirements of one or more of the standard materials specifications listed in Tables 1-724 and A-1.

thedesignstressintensityvalues(S of Table A-1 used in the design analysis are multiplied by a fTc) tor of 0.60.

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NOTE: The major difference between the small-bore pipe material requirements of Class A, B and C materials is the application of non-destructive _ testing to Class A materials.

The three previously mentioned Corrective Action Reports (SQ-CAR-86-052,86-055, and 86-064) document the result and corrective actions associated with the various discrepancies noted in the three (ECTG, HCTTG, and consultants Kelly and Landers) reviews performed at Sequoyah. The three CARS were not

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officially closed by TVA at the time of this inspection.

TVA also performed additional reviews in this area in order to verify the

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accuracy of the employee concerns and to assess the possible effect on the safety of the Sequoyah plant. These reviews were performed by Bechtel, Structural Integrity Associates, and Aptech Engineering. The highlights of these reviews are summarized below.

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Bechtel Audit The purpose of this audit was:

To verify, by examination of objective evidence, compliance with those aspects of the TVA Quality Assurance Program associated with materials.

Audit to address program applied both during the construction phase and j

the operations phase.

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This audit concluded that TVA had generally complied with the connected quality programs and applicable implementing procedures for material control for both construction and operations. The exceptions to this compliance were 5 Audit Findings (2 for construction, 3 for operations) and 6 Audit Observations (5 for construction, I for operations).

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I With regard to programmatic deficiencies, the Bechtel audit did state:

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l The findings of this audit do not reveal a deficiency in programmatic controls. However, there were instances of implementation errors (i.e.,

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incompletely recorded heat numbers, heat numbers recorded on items or documentation partially illegible, etc.) which can create traceability questions requiring laborious' and costly research and investigation efforts.

Structural Integrity Associates (SIA) Evaluation

.The three tasks assigned to SIA by TVA for its investigation were:

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Survey the available documentation and industry personnel involved in the

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construction of other light water reactors built during the same time frame as Sequoyah to determine the codes and standards invoked for design

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and construction of those plants and to present the methods used by other utilities for materials control and maintenance of traceability during plant construction.

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Obtain a knowledgeable, independent interpretation of the traceability

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requirements of the various construction codes along with an historical

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background of traceability and marking requirements.

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By survey of the available data bases, determine whether any component

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service failure has ever been attributed to improperly documented

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material or resulting from a traceability flaw.

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This report summarized:

...that materials traceability, although not a code requirement, has been important to plant owners.

Traceability of materials has generally been

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maintained to a high degree although not 100%.

Even though a small fraction of material of questionable or incomplete pedigree is known.to have been installed and placed in service, no failures

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attributable to such material have been reported. The methods used by TVA in' the design, procurement, and construction of piping systems for the Sequoyah units appear to have been typical of the day. The heat code traceability questions raised by the Nuclear Safety Review Staff report are not unique. Those questions relative to Sequoyah do not appear to present an unresolved issue.

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Aptech Report

1 This report encompassed a review of nuclear material manufacturers programs, policies, and practices, as well as nondestructive examination versus nuclear classes. This report concluded:

For absolute and unquestionable traceability, the procurement document, the heat cod (. number, and the manufacturer must be known.

Also, if any NDE was performed by someone other than the manufacturer, a separate document was generated showing the NDE method performed and the identity of the material.

The rejection rate of NDE performed on small bore fittings manufactured by forging or machining was less than one percent.

Even today, there are no markings put on small seamless piping products to indicate the class unless the purchasing document actually requires this to be done. All manufacturers that were contacted have marked the NDE performed on the material since 1980. Prior to that time, some did and.

some did not. We believe that NAVC0 and the material manufacturers procedures and QA programs met the NAVC0 requirements of both ANSI B31.7 and ASME III.

At the time of the NRC team inspection, all of the previously mentioned audits, reviews, and inspections had been completed and for the most part been documented in Final Report B25-870225-038, " Materials Traceability for Piping systems Sequoyah Nuclear Plant," January 1987.

During the inspection, the NRC team reviewed the documentation identified above, reviewed TVA's evaluation of and corrective actions for the identified deficiencies, and interviewed informed TVA personnel to obtain pertinent information.

In addition, the NRC team selected for review a sample of small and large-bore piping materials which TVA had reviewed previously.

See Tables 1 and 2 for details. The sample was selected as a result of information provided in the following documents:

TVA Executive Report on heat code traceability issues, dated April 21,

1987 HCTTG Final Report, " Materials Traceability for Piping Systems, Sequoyah Nuclear Plant," dated January 1987 Piping isometrics (TVA Class A, B, and C)

Employee concerns

ECTG Reports, Elemen'. Reports, CARS, etc TVA HCTTG Research Reports (e.g., TVA spool breakdowns; TVA Class A, B, and C spool modifications; field verification; and configuration

reports)

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TVA material control procedures:

(1) loose material (LM), (2) vendo-

supplied material (NAVCO, Westinghouse, etc.) (3) mark, piece, and L,

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number, and (4) description (diameter, heat number, and schedule)

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'In general, the results of the NRC team's review of TVA installation documentation was consistent with the HCTTG report.

It should be noted, however, that the HCTTG report was issued in January 1987. The HCTTG report represented a sample. of the large-bore and small-bore Class A systems.

Since January, HCTTG has completed a review of all large bore Class A isometrics and identified 60 modifications to 7 systems. Of the 60 modifications, all but 4 were done on vendor-supplied spools (e.g., flange rotation, elbow alignment, etc.). The' remaining 4 modifications were completed using materials supplied by the Sequoyah plant. Material is traceable for all of the modifications, but in one case the Class A NDE requirements could not.be verified. TVA has completed an ultrasonic examination of this material and the results are acceptable. The additional review of the Class.A large-bore modifications does not change the extent of the problem as identified by the HCTTG January report.

. Also, since January, additional certified material test reports (CMTRs) and other plant documentation have been located which were not available in January

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1987 when the HCTTG report was issued. A list of all Class A piping modifications was prepared by TVA HCTTG personnel and is now available.

A factor contributing to the field-installed traceability problems on reinspection was the fact that TVA had previously instituted a paint-removal requirement for its systems in contact with coolant above a set temperature.

Thus, markings of heat numbers had been removed from many of the piping systems, making reinspection of little value.

It was also possible that the personnel requested to. produce various documentation during the original ECTG review, may not have been the appropriate personnel required for performing the task. One item reviewed by the NRC team was found in TVA Element Report MC-40705-SQN (Rev. 2, February 1987) on page 4 of 15, wherein ECTG investigators requested CMTRs for 11 heat numbers. Only 4 were obtained from the existing Document Control Unit (DCU) at the time. A second search by the DCU produced 4 additional (total of 8) CMTRs.

The NRC team requested CMTRs for the same 11 heat numbers and received CMTRs or the appropriate objective evidence of updated heat number change for all of the requested heat numbers.

This indicates that the retrieval systems and personnel involved in the traceability effort had been improved since the review efforts began.

In general, the TVA Heat Code Traceability Task Group effort was found to be in accordance with the information provided in both the applicable TVA review reports.

Problems appear to be adequately bounded; the major problem area consist of TVA Class B and C material that was installed in TVA Class A systems. Listed below are the sununary results of the interviews that the NRC team conducted with cognizant TVA personnel.

TVA Quality Assurance Specialist An interview with a TVA quality assurance (QA) specialist was conducted.

j The specialist was the QA lead for a TVA HCTTG audit team. The TVA HCTTG j

audit was extensive and included review of all nonconformance reports for

- - - _ - - _ _ _ _ _ _ - _ _.

i

'

-13-

.

Sequoyah, previous audits, and plant procedures; TVA consultants Kelly and

Landers provided input. The specialist's comments were all positive in

!

respect to the HCTTG program and the results of the HCTTG efforts. The audit results confirmed that the HCTTG report adequately bounded and identified the major heat code traceability problems.

TVA ECTG Personnel.

  • The NRC team interviewed.two ECTG reviewers. Discussion of material control and material traceability items predominated. The two ECTG

reviewers felt that TVA had not clearly defined the code requirements for material traceability, and that this lack of definition resulted in

' procedural confusion and possible improper implementation of the program.

,

TVA HCTTG Personnel i

Coments from HCTTG personnel with respect to the HCTTG program were all positive.. Personnel interviewed were qualified for their jobs and-l exhibited a dedicated attitude toward the requirements of the HCTTG One of the HCTTG persons interviewed had also been a QC l

program.

l inspector during plant construction; when interviewed by ECTG personnel the individual indicated that the ECTG report did not give an accurate account of the interview: The ECTG report gives the impression that 20 or so plant records a day were changed for heat code traceability reasons.

The HCTTG person stated that 20 or so records a day were corrected for l

various reasons, one of which was heat code traceability.

j i

Summary The review of the documentation listed above and the results of the interviews conducted with well informed TVA personnel revealed that, in general, TVA The performed an extensive review of the heat code traceability issue.

information contained in the element reports'was found to accurately scope and review the identified issues. However, several inadequacies were

identified during the NRC team reviews of supporting engineering calculations which are identified as follows:

The review of the supporting pipe calculations identified that TVA has (1)

not performed minimum wall calculations for pipe schedules other than

,

schedule 160. TVA needs to perform those calculations to ascertain that j

'

a pressure problem is not present.

The acceptance of 2-1/2 percent of nodal points for small-bore piping, (2)

based upon the use of actual material properties and thicknesses is not

,

i TVA needs to review those nodal points again and upgrade them, either by performing the additional NDE, or by adding more supports l

acceptable.

{

to reduce the loads, or by replacing the piping.

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(3) TVA Design Criteria for Detailed Analysis of Category I Piping Systems, SQN-DC-V-13.3, Rev. 3 provides the loading conditions and stress limits for Category I piping systems in Table 3.1-1.

Footnote 3 of this table states that the allowable stress levels are given in ANSI B31.1-1967.

TVA's calculations of the allowable stresses for small-bore piping used ASME Section III, Appendix.I allowables which do not meet the criteria l

in SQN-DC-V-13.3.

4.3.3 Conclusions TVA has adequately addressed the employee concerns identified in this element report.

However,_ TVA needs to improve its corrective actions in small-bore piping area in order to ensure a safe startup and safe operation of the plant in the future.

4.4 Element Report MC-40709-SQN, Rev. 2, " Search for Defective Material"

'

4.4.1 Documents Reviewed IEB 83-07, July 22, 1983 l

IEB 83-07, Suppl. 1, October 26, 1983 IEB 83-07, Suppl. 2, December 9, 1983 TVA Response to IEB 83-07, March 22, 1984 Element Report MC-40709-SQN, Rev. 2, May 12, 1987 Dravo letter to TVA, September 2, 1983 TVA Sequoyah Approved Vendor List, Rev. 7, November 8, 1979 (QAS-791108-801)

TVA Sequoyah Approved Vendor List, Rev. 2, October 4, 1978 (QAS-781004-808)

Hajoca Corporation letter to TVA, May 10, 1976

TVA Memo L54-830215-803

TVA Memo LO3-870427-800 TVA Memo LO3-870428-802 TVA Memo T25-870410-819 TVA Memo L53-830216-962 TVA Memo 00A-830825-702

"

TVA Memo MEB-840320-259 i

TVA Memo 0QA-840210-703 l

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TVA Memo L16-840314-808 TVA Memo L16-830223-806 4.4.2 Discussion and Observations This element report addresses the actions taken by TVA as a result of NRC

,

Bulletin 83-07, "Apparently Fraudulent Products Sold by Ray Miller, Inc.," and

the adequacy of TVA's response to NRC regarding such actions.

The element j

report addresses Sequoyah's specific concern XX-85-027-X04.

The perceived l

problem is that (1) materials personnel at Sequoyah were not given an opportunity to verify whether or not defective material had been received on site from a certain manufacturer and (2) a report to TVA at Knoxville that the material was not on site was made without input from materials personnel.

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A review of this element report and the documents listed above, in addition to an interview with the ECTG reviewers and conversations.with other licensee-personnel,. revealed the following:

  • -

.The scope of TVA's original search for. possible suppliers of Ray Miller,

Inc. material was limited to those companies appearing on the list of.'

vendors approved to supply safety-related material to TVA nuclear sites.

Letters were sent to several of the approved vendors asking them to-

research their files to determine whether they had, in fact,. received and

'l shipped Ray Miller, Inc. material to TVA. All companies that were sent i

these letters responded that either (1) they had never purchased material J

from Ray Miller, Inc. or (2) they had never supplied Ray Miller, Inc.

I material'.to TVA, or (3) the material supplied to TVA that could potentially have'been from. Ray Miller, Inc..was not used in a safety-related application.

,

The research of the remaining potential suppliers who were identified

was performed by reviewing all of the purchase orders issued by TVA to these suppliers for delivery to a TVA nuclear facility. The results of.

this search revealed a number of instances in which Ray Miller, Inc.

l material had been supplied; however, all of this material had been i

purchased as non-safety'related and had been designated for a particular

)

non-safet) related location.

In addition, all direct TVA purchase orders to Ray Miller, Inc. for delivery to.any TVA nuclear facility were researched. Several of'these purchases were found to apply to Watts Bar, Browns Ferry, and Sequoyah; however, in only two instances had-this material been installed in safety-related systems at Sequoyah, and in both of those instances, the l

purchases and shipments had not been made within the 1975 to 1979 time

'

period identified in the NRC Bulletin 83-07.

Although the above actions appear to be extensive, a number of areas were identified'during this incpection which require additional clarification and/or action.. These areas are discussed below:

(1) TVA's decision to research only material suppliers who appear on the safety related supplier list may have been inadequate for the following reasons:

Although Ray Miller, Inc. did not appear on the safety-related supplier list, in two instances safety-related material had been purchased directly from Ray Miller, Inc.

q L

Although Hajoca Corporation does not appear on the safety-related

"

I supplier list, evidence of at least four purchase orders for safety f

related material was presented to the NRC team during this inspection.

I The four contracts were: 624117, 536036, 827923-2, and 820260-4.

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(2)

In response to TVA's-letter of inquiry, the Dravo Corporation of Marietta, Ohio stated ~ in a letter dated September 2,1983, "We have researched our records and have found no evidence of materials being supplied by Ray Miller, Inc..to Dravo Pipe Fabrication Division directly or indirectly through subtier suppliers.".However, information contained in Attachment 1 of NRC Bulletin 83-07 indicates that several shipments of pipe, tubing, and pipe fittings were sold to the Dravo Corporation by Ray-Miller, Inc. during the 1975 through 1979 time period. Although-these shipments were not shipped to the Marietta, Ohio location, they were-delivered to two other Dravo plants elsewhere in Ohio. Therefore, a question exists about the end-use of this material and,' ultimately,'the accuracy of Dravo's response to TVA's letter of inquiry is in. question.

(3)

Documentation is not currently available to ensure that TVA's review of the safety-related suppliers list resulted in a comprehensive search of all possible suppliers of potentially fraudulent Ray Miller, Inc.

material.

During this' inspection, the NRC team compared TVA's safety-related suppliers list with identified recipients of Ray Miller, Inc.

material listed in Attachment 1 of NRC Bulletin 83-07. This review uncovered five suppliers who appeared on both lists and for whom no documented evidence of any TVA review is currently available.

(4)

The review of TVA's official March 22, 1984 response to the NRC Bulletin reveals that TVA has not reported the results of its search in a format consistent with that requested by the NRC Bulletin 83-07.

4.4.3 Conclusions Additional information is needed to complete the review of this item.

The NRC team concluded that TVA has not adequately investigated and addressed the issue identified in this element report.

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TABLE 1.

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i-SMALL BORE PIPING MATERIALS REVIEWED Weld Map Item #/ Type Coments 2-CVC-500-_1W :

37/ Red. Cplg

. Note 1 2-CVC-500-1WL

'15/ Pipe Materials Traceable

"

2-CVC-500-1W.

17/ Pipe 2-CVC-5012W'

27/Cp19 Note 1

"'

2-CVC-501-2W 07/Cpig

"

2-CVC-502-1W 04/ Pipe

"

2-CVC-502-2W 40/Cpig

- 2-SI-500-1W--

08/ Pipe-Materials Traceable

"

2-SI-500-1W 29/ Ell

"

2-SI-512-4W Tank to pipe weld

"

2-SI-512-4W Pipe to Tee weld

"

2-SI-512-4W Pipe to E1 weld

"

2-SI-510-2W Pipe to El weld

"

-1-CVC-501-1W 02/ Pipe

"

1-CVC-501-1W 14/Cpig i

"

1-CVC-501-2W 03/ Ell

.

'l

"

1-CVC-501-2W 05/Cplg 1-CVC-501-2W 14/ Pipe Note 2

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1-CVC-501-2W 13/ Ell Materials Traceable

"

1-CVC-501-2W 15/ Ell

"

1-CVC-501-2W 18/ Pipe i

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SMALL BORE PIPING MATERIAL REVIEWED

.(Continued)

Weld Map Item #/ Type Comments 1-CVC-501-2W 29/ Ell Materials Traceable 1-CVC-500-1W 07/ Pipe Note 2 1-CVC-501-2W 23/Cpig Materials Traceable i

1-CVC 501-1W 5/ Ell Materials Traceable

"

1-CVC-501-1W 8/E11

"

1-CVC-501-1W 14/Cp1g

"

1-CVC-501-1W 18/ Ell 1-CVC-501-1W 22/ Red. Insert Note 3 1-CVC-501-1W 23/ Pipe Material Traceable

"

1-SI-512-4W Pipe /El weld

"

1-SI-512-4W Pipe /El weld

"

1-SI-510-2W Pipe /El weld

"

1-SI-510-2W Pipe /El weld

"

1-SI-510-2W Pipe /El weld

"

2-CVC-502-2W 33 Pipe /Cpig weld 2-CVC-502-2W 34 Pipe /Cp1g weld Note 1 2-CVC-502-2W 35 Pipe /Cpig weld Note 4 2-CVC-502-2W 36 Pipe /Cpig weld Note 1 1-SI-255 Pipe Material Traceable

"

1-CVC-501-1W LM34-13

"

ERCW 101 47W450-290, 557

"

2-CVC-502-2W 183035 Notes:

1.

CAR-86-055 issued.

2.

Class B material installed.

Subsequently cutout and replaced by Class A material. NCR-M-12 issued.

3.

Size of reducing insert verified when additional RT performed.

4.

Class B installed instead of Class A.

Additional PT performed.

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U TABLE 2 LARGE BORE PIPING MATERIALS REVIEWED TWeld Map Spool-Piece Comments L.

'A7200!

'1-RHR-62 Materials Traceable -

A7201 1-RHR-76'

Note'1

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. A7255 1-SI-93 Materials Traceable

"

L

' A7255 1-SI-99.

'

J, y

"

H A7256 1-SI-123'

"

~ A7256-1-SI-127

"

A7257 1-51-136

"

. A7262 1-RC-12

,

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- A7265 1-CVC-111

"

A7269 1-CVC-174

"

. A7269 1-CVC-177

"

A7280 1-RC-44

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A7281-1-RC-48 A7202 1-RHR-88 Material Traceable A7263 1-RC-19 Note 2 A7267 1-CVC-1 Materials Traceable t

A7269 1-CVC-166

]

"

"

A7255 1-SI-103 i

"

A7255 1-S1-94

"

A7202 1-RHR-88

"

A7100 1-MS-18A, 18 l

"

A7108 1-FD-86, 85

"

A7548 LM40-198

"

ERCW 101 47W450-285

.A7456 2-RHR-62

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LARGE BORE PIPING MATERIAL REVIEWED (Continued)

1

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Weld Map'

Spool Piece Comments A7457 2-RHR-75 Material Traceable

"

A7540 2-SI-172 l _.

"

A7541.

2-SI-171

"

A7543 2-SI-145-

"

A7543 2 SI-144

"

A7543 2-SI-141

"

A7554 2-CVC-176

"

A7554-2-CVC-176, BXM17A

"

A7548 TVA Spool..BXN6K

.A7548 TVA Spool, M2415 Note 3 A7548 2-RC-19 Material Traceable

,

"

A7547 2-RC14

~'

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A7552 2-CVC-147

,

"

A7554 TVA Spool, BXM17A

"

A7400 2-MS-24A, 24, 7 t

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Notes:

j 1.-

Documentation do not provide correct spool identification.

2.

CAR-086-055 issued.

TVA modification.

3.

CAR-086-055 issued. Additional UT performed.

)

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