ML18033A555
| ML18033A555 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/25/1987 |
| From: | Brown W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 23300, 23300-V02-R04, 23300-V2-R4, NUDOCS 8902150038 | |
| Download: ML18033A555 (64) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG VOLTE2 ENGINEERING CATEGORY SUBCATEGORY REPORT 23300 ESSEN'I'IAL RAW COOLING WATER PIPING UPDATED TVA NUCLWWPOWER 3902150033 39(>20i'DR ADOCI< 050002 9
P PDC.I
ii 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:
SUBCATEGORY REPORT.FOR ENGINEERING TITLE:
ESSENTIAL RAW COOLING WATER PIPING REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 1 of 34 REASON FOR REVISION'.
2.
3.
Revised to incorporate SRP and TAS comments.
Revised to incorporate SRP and TAS comments.
Revised to incorporate SRP and TAS comments and add Attachment C
(References).
Revised to incorporate SRP and TAS comments.
PREPARATION SIGNATURE OATE V IEW OMMI GN TAS: r NA R
CEG-H:
SRP:
IGNATUR "87 GATE APPROVEO Y
C P
ANA 557 SRP Secretary's signature denotes SRP concurrences are in files.
0 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER '
Page ES-1 of 2 EXECUTIVE
SUMMARY
This subcategory report summarizes and evaluates the results of the Employee Concerns Special Program evaluation under Engineering Subcategory
- 23300, Essential Raw Cooling Water Piping.
It covers 11 issues related to two of TVA's nuclear plants, Watts Bar and Bellefonte.
The issues were derived from 23 employee concerns that cited perceived deficiencies or inadequacies in the design and construction of portions of the essential raw cooling water system piping.
With one exception, the employee concerns rel'ated to the quality of the cement mortar lining. added to this piping at Watts Bar and Bellefonte; the piping
.originally was unlined carbon steel.
Areas of concern were the quality of the lining installation, the ability of.the lining to resist erosion, and the completeness of quality assurance documentation.
Most of the employee
- concerns, and all of the potentially significant issues, were raised relative to Watts Bar.
At Watts Bar, several nonconforming condition reports were
- issued, as were two Nuclear Safety Review Staff reports covering several of the employee concerns.
The issues were not applicable to the Browns Ferry or Sequoyah plants, which do not have cement-mortar-lined piping.
Of the 11 issues evaluated, nine were found to require no corrective action.
For the remaining two issues, one corrective action was identified to remedy the negative findings for both.
These findings involve failure of the contractor responsible for lining installation at Watts 'Bar to document the required inspections and failure of TVA to discover this failure in a timely manner.
The corrective action resulted from the Employee Concerns Task Group evaluations.
The causes for the two negative findings were
" Inadequate Procedures"
- and, on a broader basis, "Lack of Management Attention."
These factors resulted in failure of several TVA organizations, including Engineerinq, to review the contractor's (jA program compliance.
Although this failure did not result in any technical adequacy problems, it allowed incomplete documentation of quality assurance activities.
The corrective action was:
Provide means for controlling subcontractor quality assurance activities.
This corrective action was primarily in an area outside design engineering activities.
Therefore, it was concluded that the engineering activities applicable to this subcategory did not represent a technical
- problem, but did indicate a programmatic problem involving Engineering, Construction, and guality Assurance organizations.
It should be pointed out that these difficulties appear to be confined to Watts Bar, because, in the same time frame
( 1982), the opportunity for similar difficulties was present at Bellefonte and none occurred.
- However, the specific corrective action was generic to all TVA plants.
The broader problem is being corrected by a combination of broad actions by TVA to improve organizational interfaces, procedures, and communications.
2858D-Rg
( 11/16/87)
TVA EMIPLOYEE CONCERNS SPECIAL PROGR&l REPORT'UMBER:
233OO REVISION NUMBER:
age ES-2 of' Improvements have been made in the TVA organization structure, with clearer assignment of responsibility and authority, consolidation of the nuclear organization, centralization of site activities; and improvements in management system programs and procedures, as outlined in the Corporate Nuclear Performance Plan.
These improvements should supplement the specific corrective action described in this report,to prevent a recurrence.
The causes identified and other evaluation results are being examined from a'ider perspective in t'e Engineering category evaluation.
28580-R8 (ll/16/87'
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 FRONT MATTER REV:
3 PAGE i OF viii Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA).
The ECSP and the organization which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1,
1986.
Concerns filed after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns.
Each of the concerns was a
formal, written description of a circumstance or circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concerns Special Program was to thoroughly investigate all'issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the
- NRC, and the general public.
The results of these investigations are communicated by four levels of ECSP reports:
- element, subcategory,
- category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart of Sequoyah Nuclear Plant's reactor unit 2.
An element consists of one or more closely related issues.
An issue is a potential problem identified by ECTG during the evaluation.process as having been raised in one or more concerns.
For efficient handling, what appeared to be similar concerns were grouped into elements early in the program, but issue definitions emerged from the evaluation process itself.
Consequently, some elements did include only one issue, but often the ECTG evaluation found more than one issue per element.
Subcateg'ory reports summarize the evaluation of a number of elements.
- However, the subcategory report does more than collect element level evaluations.
The subcategory level overview of element findings leads to an integration of information that cannot take place at the element level.
This integration of information reveals the extent to which problems overl'ap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three 'items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
Additionally, at. the end of each subcategory report will be a Subcategory Summary Table that includes the concern numbers; identifies other subcategories that share a concern; designates.
nuclear safety-related, safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
Either the Subcategory Summary Table or another attachment or a combination of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
TVA EMPLOYEE CONCERNS SPEi IAL PROGRAM REPORT NUMBER.",
,'23300 FRONT MATTER REV:
2 PAGE ii OF viii The subcategories are themselves summarized in a series of eight category reports.
Each category report reviews the major findings and collective significance of the subcategory reports.in, one of the fo11owing'reas:
management and personnel relations industrial safety construction material control operations quality assurance/quality control welding engineering, A separate repor.t on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing willibe, released by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the information coll.ected at the element level, the category, reports integrate'the i'nformation assembled i,n all the subcategory reports within the c~ategory, addressing particularly the underlying causes of those proble'ms that run across more than one subcate'gory.
A final report will integrate and assess~
the informati.on collected 'by,all, of the lower-level reports prepared for the
- ECSP, including the Inspectoc General's report.
For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennesaee Va11ey Authority Employe'e Concerns Task Group Program Manual.
The Manual spells out the program's objectives,
- scope, organization, and responsibilities.
Xt also specifies the procedures that were followed in the idve<tigation, reporting, and closeout of the issues raised by employee concerns.
TVA EMPLOYEE CONCERNS
'SPECIAL PROGRAM REPORT NUMBER:
23300 FRONT MATTER REV:
2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS~
classification of evaluated issues the evaluation of an issue leads to one of the. following determinations:
Class A:
Issue cannot be verified as factual Class B:
Issue is factually accurate, but what is described is not a
problem (i.e., not a condition requiring corrective action)
Class C:
Issue is factual and identifies a problem, but corrective action for the problem was initiated before the evaluation of the 'issue was undertaken Class D:
Issue is factual and presents a problem for which correcti've action has
- been, or is being, taken as a result of an evaluation Class E:
A problem, requiring corrective action, which was not identified by an employee
- concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
collective si nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern (see "employee concern")
corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in order to prevent recurrence.
criterion
( lural:
criteria) a basis for defining a performance, behavior; or quality which ONP imposes on itself (see also "requirement").
element or element re ort an optional level of ECSP report, below-the subcategory level, that deals with one or more issues.
em lo ee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, ineffi.cient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
TV)L EMPLOYEE CONCEFSS SPECTRAL PROGRAM REPORT NUMBER".23300 FRONT KNITTER REV:
2 PAGE iv OF viii grouping of employee concerns.
~findin s
inoludas both statements of faut~i an~d the~i judgments made about those facts during, the evaluation process; negative findings require corrective action.
issue a potential problem, as interpretedi by the ECTG during the evaluation
- process, raised in one or more concerns.
K-form (see "employee concern.")
evaluation judgment or decision may be based.,
root cause the underlying reason, for a problem>
~Terms essential to the. program but which require detailed definition have been defined in the ECTG Procedure Manual (e.g., gerieric,'pecific, nuclear safety-related, unreviewed safety-sigriificant question),
Cl
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 FRONT MATTER REV:
2 PAGE v OF viii Acronyms AI AISC ANS ANSI ASME ASTM AWS BFN BLN CAQ CAR CATD CCTS CEG-H CFR CX CMTR COC Administrative Instruction American Institute of Steel Construction As Low As Reasonably Achievable American Nuclear Society American National Standards Institute American Society of Mechanical,Engineers American Society for Testing and Materials American Welding, Society Browns Ferry Nuclear Plant Bellefonte Nuclear Plant Condition Adverse 'to Quality Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System Category Evaluation Group Head Code of Federal Regulati'ons Concerned Individual Certified Material Test Report Certificate of Conformance/Compliance DCR DNC Design Change Request Division of Nuclear Construction (see also: NU CON)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NVMBER:
23300 FRONT MATTER REV' PAGE yi OF viii DNE DNQA DNT DOE DPO DR ECN ECP ECP'-SR ECSP ECTG EEOC EMRT EN DES ERT FCR FSAR FY HCI HVAC INFO IRN Division of Nuclear Engineer'ing Division of Nuclear Quality As'surlance Division of Nuclear Training Department of Energy Division Personnel Officer Discrepancy Report or Deviatio'n Report Engineering Change lUotice Employee Concern.
Program Employee Concern Program-Site Representative l:.mployee Concern:
Slpecial Program Employee Concerns Task, Group Equal Employment Oplportunity Ciommission IEnvironmental Qualification'Emergency Medical Response
'Zeam IEngineering Design IEmployee
Response
Team or 'Emergencyi Response Team IField Change Request IFinal Safety Analysis Report IFiscal Year General Employee Trai'ning IHazardl Control, Instruction HeatingVentilating, Air Condi ti'.oning Installation Instruction Institute of Nuclear Power Operatlions Inspection Rejection Notice'
~
~
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 FRONT MATTER REV:
2 PAGE vii OF viii L/R M&AI MI
'MSPB MT NCR NDE NPP Labor Relations Staff Modifications and Additions Instruction Maintenance Instruction Merit Systems Protection Board Magnetic Particle Testing Nonconforming Condition Report Nondestructive Examination Nuclear Performance Plan NPS NQAM NRC NSB NSRS NU CON Non-plant Specific or Nuclear Procedures System Nuclear Quality Assurance Manual Nuclear Regulatory Commission Nuclear Services Branch Nuclear Safety Review Staff Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUMARC Nuclear Utility Management and Resources Committee OSHA Occupational Safety and Health. Administration (or Act)
ONP OMCP PHR PT QA QAP QC QCI Office of Nuclear Power Office of Morkers Compensation Program Personal History Record Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures
'Quality Control Quality Control Instruction
TVA EMPLOYEI.'C'ONCERNS Sl?ECTAL PROGRAM REPORT NUMBER:
23300 FROIG'ATTER REV:
2 PAGE viii OF viii QCP QTC Quality Control Procedure Quality Technology Company REF RT SQN SI SOP SRP SWEC TAS Reduction in Force Radi ograplhi c Tes t,ing Sequ,oyah INuclear Plant Surveillance Instruction Standard Operat:ing Pr ocedure Senior Review Panel.
Stone and Webster Engineering Corporation Technical Assistance St;aff TSL TVA TVTLC VT WBECSP WBN Tr'ades and Labor T'ennessee Valley Author;ity Tennessee Valley Trades and Labor; Council Ultr as on ic Tes tin g Visual Testing Watt:s IBar Employee Concern Special Program Watts IBar Nuclear Plant WorIc Request; or Work; Rules Woricplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 2 of 34 Section Executive Summary Pref ace ECSP Glossary of 'Report Terms Acronyms CONTENTS
~Pa e
ES-1 1
'Introduction 2
Summary of Issues/Generic Applicability 3
Evaluation Process 4
Findinqs 5
Corrective Actions 6
Causes 7
Coll'ective Significance Glossary Supplement for the Engineerina Category Attachments A
Emoloyee Concerns for Subcategory 23300 B
Summary of. Issues,
- Findings, and Corrective Actions for Subcategory 23300 C
References 3
4 22 23 27 32 B-l C-1 TABLES Table 1
Classification, of Findings and Corrective Actions 2
Findings Summary 3
Matrix of Elements,, Corrective Actions, and
- Causes, Paoe 29 30 31 28580-R 1 1 (11/16/87)
<0 Cl
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 3 of 34 l.
INTROOUCTION This subcategory report summarizes the results of the Employee Concerns Special Program (ECSP) evaluation under Engineering Subcategory
- 23300, Essential Raw Cooling Water (ERCW) Piping.
The employee concerns provide the basis for the evaluations and are listed by element number in Attachment A.
Of the 23 concerns in this subcategory, 20 were identified for Watts Bar (WBN)'nd three for Bellefonte (BLN). All 23 concerns related to a single subject, quality of. concrete pipe lining; therefore, only one element was established.
The overriding issue raised by the employee concerns (ECs) was whether the quality of the cement mortar lining applied to portions of ERCW system piping was adeauate.
The ERCW system provides cooling water to many safety-related components.
It must function under all plant operating conditions, including
~ shutdown following design basis accidents.
In the late 1970s, other TVA plants experienced corrosion and plugging problems in the carbon steel piping systems using Tennessee River water.
At WBN and BLN, the solution to this problem for a portion of the piping (the 30-and 36-inch underground lines carrying river water to and from the plant) was to add a cement mortar lining.
This was done to detailed and demanding TVA specifications by outside contractors in 1982.
The lining work involved approximately 25,000 feet of piping.
Early in the work, the HBN contractor failed to meet several specification requirements.
These deviations were documented in TVA quality control (OC) inspectors'onconforminq condition reports (NCRs).
Many of the ECs dealt with Design Engineering dispositions of these NCRs, claiming that dispositions to "use-as-i s" resulted in an inferi or product.
The evaluations are summarized in the balance of this report, as follows:
o Section 2 -- summarizes, by element, the issues stated or implied in the employee concerns and addresses determination of generic applicability o
Section 3 -- outl.ines the process followed for the element and subcategory evaluations o
Section 4 summarizes, by element, the findings and identifies the negative findings that must be resolved, and cites documents on which findings are based o
Section 5 highlights the corrective actions required for resolution of the negative findings cited in Section 4 and relates them to element and to plant site 28580-Rll (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
Z3300 REVISION NUMBER.'
Page 4 of,34 o
Section 6 -- identifies causes of the negative findings o
Section 7 assesses the significance of the negative findihgs o
Attachment A -- l.ists, by elementeach employee concern evaluated; in the subcateq1ory.
The concern number is given along with notation of any other element or category with whic:h the concern is shared, the plant sites to which it co'uld be. applicable are noted, the concern is quoted as received by lVA, and is characterized as safety
- related, not safety related, or safety significant o
Attachment B -- contains a summary of the element-level evaluations.
Each, issue is listed, by element number and plant opposite its corresponding findinc1s and correct'ive actions.,
The reader may trace a concern from Attachment A to an issue in Attachment B by using the element number -and applicable plant,.
The reader may relate a corrective action description in 'Attachment B to causes and significance in Table 3 by usipg the CATO number that aopears in Attachment B in parentheses at the end of the corrective action description The term "Peripheral finding"'n the issue column refers to a
finding that occurred during the course of'valuating a concern'but did not stem directly from a employee concern.
These are classified
's "E"'in Tables 1
and 2 of this report o
Attachment C -- 1',ists the references cited in the text 2.
SUMMARy OF ISSUES/GENERIC APPLICABILITY The 23 employee concerns listed in Attachment A for each plant have bedn
- examined, and the potential problem~'aised by the concerns have been identified as 11 separate
- i. sues.
Summaries of the ll issues under element ievaluation 233. 1, Quality of Concrete i
Pine Lininn, follow::
o Matts Bar 1.
The original piping was improperly installed.
It leaked, requiring repair with cement morta1 linings 2.
The cement mortar lining is failing because of inadequate repairs and may cause damage or loss of funct'ion of safety-related components.
0 28580-R11
( 11/16/87]i
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 5 of 34 3.
The procedures used to install and repair the lining were inadequate; they were not the same as those used to line the samples used in the testing program.
4.
The lining contractor's quality assurance and inspection plans were inadequate, and the contractor failed to perform,.or to
- document, required inspections.
5.
TVA Design Engineering improperly dispositioned the numerous NCRs issued against the contractor's work, accepting most of the deficiencies on a "use as is" basis.
6.
TVA Design Engineering valued schedule over quality relative to the lining contractor's work and interfered with TVA site QC personnel in their monitoring of this work.
7.
TVA Nuclear Safety Review Staff (NSRS) improperly disposed of one of the employee concerns relative to the quality of the pipinq lining.
o Bel 1 efonte 8.
A oortion of the ERCW piping may not have been lined as reauired.
9.
Use of hand-lining of piping at bends may have resulted in inadequate lining integrity.
10.
Fewer TVA inspectors.
were used at BLH, comoared, with MBN, to monitor the lining contractor's work, resulting in the possibility of inadequate lining quality.
ll.
Quality assurance documentation may be inadequate because required inspections were documented by contractor personnel, rather Chan TVA personnel.
Each issue evaluated is stated fully in Attachment B.
This attachment also lists corresponding findings and corrective actions, which are discussed in Sections 4 and 5 of this report.
The ll issues summarized above cover a wide spectrum of activities, all related to a single process applied to a single.system.
Only four of the issues involve enqineering activities; three of them relate to contractor nerformance, three to quality control and assurance, and one to the handling of employee concerns.
I 2858D-R 1 1 (11/16/87)
rVA EMPLOYEE CONCERNS SIPEC,IAL PROGRAli REIPORT NUMBER:
233OO REVISION NIJMBER 4
Page 6 of 34 The concerns in Engineering Subcateqory 23300 were not considered gener'ic to the Prowns Ferry.
(BFN) or Sequoyah
(',SQN) plants, which do not have cement-mortar-lined piiping in their ERCW, or comparable, systems.
As the followina sections show, only two issues were found to be valid 'and to reauire corrective action.
These issues were in the area of quality aSsuranbe.
3..EVALUATION PROCESS This subcategory report was pr'epared to address the specific employee conCerns related to the issues broadlly defined in Section 2.
It is also based on the preliminary subcategory
- report, issued in July 1986 at the conclusion Of the oriqinal Watts Bar evaluation (Ref.. 38).
The evaluation process consisted of the following steps:
o Watts Bar Evaluation Reviewed employee concerns in deta'i 1 to identify common elements and issues.
b.
Reviewed documentatiOn of the technical basis for the i!iitial'ecision to provide cement mortar lining. for the steel pipe.
~
c.
Reviewed design drawings, specifications, and system descriptive clocuments to determine suitability, operating parameters, safety aspects, and component function and l~ocation.'.
Reviewed size,
- geometry, nd flow velocities of ERCW piping to determi,ne susceotibility to erosion.
Revieweid ERCW testinci orooram as documented in TVA Repor't CES-B, Irull Scale Tiastinq and Qualification of Cement Mort~Sr Lined Carbon Steel Pipe,,
and reviewed results to determine aool',ication requirements, durab'ility, and I,'ai lure anodes
'of
'ining.
f.
Revieweid NCRs and their disposition to cletermine:
o What problem areas (noncompliances) were formall y identified 0
o Whether the employee concei'ns were adequately.
cover~ed
~by~
the NCR dispositions o
whether the NCR dispositions were t,echnical,ly valid 28580-R 1 1 (11/16/87) 4l.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 7 of 34 g.
Interviewed TVA employees knowledgeable of the background of the ERCW pipe cement mortar lining history.
h.
Inspected a portion of lining to determine condition of lining and evidence of failed lining or failed repairs.
i.
Reviewed TVA and industry historical experience with concrete-mortar-lined pipe to determine failure frequency, failure modes, and effects.
j.
Reviewed procedures and inspection and audit reports ~elated to the ERCW pipe.
k.
Assessed the technical adequacy of the cement-mortar -lined ERCW pipe and whether or not the degree of uncertainty concerning quality of the pipe lining was. sufficient to pose a public health and safety risk.
o Bellefonte Evaluation a.
Reviewed WBN preliminary element evaluation 233.1, covering similar employee concerns at WBN.
b.
Reviewed BLN requirements drawings and specifications for completeness and c 1 ari ty.
c.
Reviewed BLN NCRs related to the subject piping.
d.
Reviewed BLN quality assurance (gA) audit reports covering the lininq contractor's. records.
o Suhcateaor Evaluation a.
Tabulated
- issues, findings, and corrective actions from the element evaluations in a plant-by-plant arrangement (see )'.
h.
Classified the findings and corrective actions using the ECSP definitions.
c.
Comoared the results of the WBN and BLN pipe-lining programs.
d.
On the basis of ECSP guidelines, analyzed the collective siqnificance and causes of the findings.
28580-R11 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPOR'I NUMBER;.
2'33()0 REVISION NUMBER:
4 Page 8 of 34 e.
Provided additional judgment or information that may not~ be apparent a't the individual plant review level.
4.
F INDINGS The findings for this subcategory are also contained in Attachment B.
'The findings are listed by element number and by plant.
The discussion and findings for element evaluatioh 233. 1, Ouality of. concrete Pipe Lining, are given in the fol'lowing subsections.
4.1 Original Pi oi~n Installation
'(WBN)'.
1.1 Discussion A problem arose in the late 1970s at ahother TVA plant using Tennessee River
~ater for cooling water services.
It was identified in Nuclear Power Exoerience, BWR volume (Ref. 28).
It consisted of a potential reduction in flow quantities due to corrosion and encrustation of the carbon steel piping interior.
At WBN, the oroblem was identified in NCR WBNNEB 8017 (Ref.
~1),~
first issued in late 1980,.
There is no indication in the NCR or related documentation that the WBi< piping was leaking.
Corrective action is virtu~ally
~
comolete at this time.
The specific, solution to the problem for the large buried ERCw piping at wBN was the applicatioh of a cement morr;ar lininq to the inside of the oip'inq.
- 4. l. 2 Finding The ERCW oioinq wa's lined with cement mortar to reduce friction loss from the.
corrosive effects of Tennessee River water',
and not because the carbon Steel pipinq leaked or was improoerly installed.,
4.2
.Lining inteoritv and Effect on ERCW S stem Operations (WBN)
- 4. 2. 1 Di scuss ion The issue raised in several concerns was that of the integrity of the ERCW oioinq cement mortar lininq.
Some concerns mentioned that portions of tthe linina had already come loose and were being transported throughout the system.
Other concerns related to the potentia'1 for the lining to failiati some time in the future.
The result could h0 e'ither a gradual or a sudden release of cement mortar particles or fragments that could plug piping or enuioment, deqradinq the system's capability to perform its safety-related coolinq function.
28580-Rll (ll/16/87)
II
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 9 of 34 The cement mortar lining of the buried portion of, the ERCW piping was installed between April and October 1982, in accordance with two TVA specifications (Refs.
2 and 27),
and inspected by TVA in accordance with a third TVA soecification (Ref. 3)..
The ERCW piping was flushed following completion of the l.ining process.
NCR 4419R (Ref.
16),
issued in November 1982, describes the collection of mortar debris at discharge points.
The pieces were character ized as:
"obviously unused mortar rather than failed lining.
. either lining which 'had been chipped out during normal repair operations
. [or].
. l.ining which had failed during the flushing of the system."
- The NCR described subsequent inspection of accessible sections of the lining.
Approximately 2 percent, 5 percent, and ll percent, respectively, of the total lenath of three of the four main headers were inspected.
Three small (less than 20 square inches) areas of mortar erosion were found, only one of which resulted in exposed pipe (approximately 2 square inches).
On this basis, the remainder of the piping was accepted as-is (Ref.
17).
As a result of the Watts Bar Employee Concerns Special
- Program, the ERCW
.piping lining quality question was again reviewed.
Two substantive Nuclear Safety Review Staff (NSRS) reports were issued, I-85-158-WBN and I-85-166-WBN (Refs.
22 and 23), covering 10 of the concerns.
Both reports contain the following statement relative to experience with the ERCW piping from 1982 throuah 1985:
"Review of maintenance requests revealed no problems resultinq from mortar lininq pieces cloaging ERCW components.
Interviews with site staff responsible for maintenance and operation confirmed this conclusion.
Maintenance personnel stated that mortar chips were found durinq the initial system restart after installation of the mortar lininq.
These pieces were debris resulting from the installation process.
Morta chips were flushed out the main discharge
- header, and none have been found since then."
Reoort I-A5-166-WBN contains this further statement:
"No failures of the strainers have been attributed to plugging by mortar chips."
These strainers were used durinq the initial flushing ooeration to entrap particulate material and are not included in the operational design.
It should be noted that the ERCW svstem is an ooen cooling system, in which the pumps take suction directly from the river.
All cement-mortar-lined piping is downstream of the ERCW pumps.
Therefore, these pumps are not subject to damage from cement mortar lininq particles as implied in five of the employee concerns.
I Experience with application of cement-mortar-1 ined piping in safety-related services is limited.
The evaluation team performed several reviews of backqround material to provide perspective on the potential safety problems 28580-R11 (11/16/87)
TVA 'EMPLOYEE CONCERNS SPECIAL PROGRAM ftEPORT'UMBFR:'23300 ftEVISION NUMBER:
4 Page 10 of 34 that could arise with this application.
These included a review of TVA's aualification testing program for cement-mortar-lined carbon steel
- pipe, a
review of previous nuclear power plant opeirat;ing experience with similar'ement-mortar-lined
- pipe, a review of potential water hammer effects, arid an evaluation of potential lining failure modhes iand effects on safe plant shutdown.
These reviews are described briefly in,the following subsection4.
Erosion of Pipe Lining.
One concern
( IN-85-589-001) raised the issue of'otential erosion of the piping, lining at iparticular,po,ints in the system where there are high localized flow velocities.
This concern is potentially valid, in that erosion was a problem in other portions of the ERCM system.
Furthermore, there have been occurrences of cement mortar lining erosion in service water lines in operating nuclear power plants (Ref. 32),.
The evaluation teams checked the size,
- geometry, and flow velocities of the. MBN ERCM buried headers and determinedl that tHe fIiathntial fOr 'erosiOn was quite low.
The piping is 'large, with no smal,l biranchI connections or severe changes in cross section, and the flow velocities in the s~ystem are low.
The 1986 inspection of the accessible portion of the pipe found no evidence of erosion at a 90'lbow (Ref. 35).
Oualification Testing Program.
A ma,'jor question with regard to the use,of, cement-mortar-1>ned pipe for the ERCM system is its fierformance under seismic
- events, as well as underwater hammer event,s.
TVA conducted tests in 1981 of 18-inch-and 30-inch-diameter cement-mortar-1lined pipe and of' 30-incn elbow, similar to that used at MBN, as documentedI'in TVA Report CEB-S, Full Scale Testinq and Qualification of Cement Mortar Lined Carbon Steel Pipe (Ref> 29).
The test results linclude a cyclic bearing,test at, loads, uo, to 1'ips
(-a 12-kio initial load is sufficient to produce local deformation of 3.4 inches and a 1.8-inch permanent ovalling) and a torsion t'est at loads uo to 60 kios.
The tests concluded that the cement mortar lining is, qualified to resist the desian earthquake and other design loadings at
',TVA faci'lities and that the induced stresses,
- strains, and deformation pr'oduced by the design earthquake around acceleration are w<ill below those encountered in the qualificatiOn testing program.
potential Mater Hammer Effec'ts.
Certain trar>sient system operating conaitions, such as system startup.with the piping part~ally air-Filled, can lead to severe hydraulic events in the process of refi 1'ling the system with water.
These are referred to as
'"water ha'mmer;"
Such eveints can produce substantial shock waves, which, in turn, can'resul't in high, suddenly applied loads to the system IPiping.
These loads can be more 'severe than seismic loaas in certain situations.
With ERCW piping, 'if'portions of the lining were to be severely cracked and not bonded to the piping, those portions could be dislndaed.
28580-Rl 1 (1 l/16/f37) 4l
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 11 of 34 The qeometry of ERG< piping, which has a discharge point well above the buried Dipinq headers, is such as to virtually assure that water hammers would not occur in this piping (Ref. 24).
Preoperational testing of the ERCll system included a specific test to attempt to induce water hammer.
This test revealed no water hammer effects on the buried ERCW piping (Ref. 36).
Linino Failure Modes and Effects Anal sis.
Potential lining failure modes are identified in the seismic qualification test report (Ref. 29).
The two major failure modes are spalling, in which a number of small fragments are produced at a sinale location, and collapse, in which one or more relatively large mortar sections are dislodged.
For unbonded mortar, which is more likely to he oresent at repaired
- areas, collapse i,s unlikely in the absence of a seismic or water hammer event.
This unlikelihood results from an arching effect in which the surrounding mortar keeps the repaired area in place.
Therefore, collaose is likely to be sudden at several locations simultaneously or to not occur at a'll.
In any event, this failure mode is of little concern because larqe pieces of cement mortar are likely to remain near their original locations because of the density of the material and the low water-flow velocities (approximately 7 feet per second maximum) in the system.
Small fragment failures are more likely to result from long'-term effects:
for
- examole, oiping flexure caused by temperature changes or. by corrosion behind the lining (Ref. 20).
In such cases, the failures would likely be gradual; larqe oarticles would settle, and'articles small enough to be carried by the flow stream would flow through to the discharge or would accumulate at such locations as heat exchanger tube sheets or nonflowing branch pioe lines.
These accumulations should be detected by normal maintenance and surveillance ODerations.
In response to NSRS Investigation Report I-85-166-MBN, TVA has committed to a periodic inspection of the heat exchangers to confirm that the cement mortar liner is not deteriorating during plant operation.
The ERCM system consists of two redundant trains, one of which is normally in a standby mode.
For the event sequences described
- above, even if the ooeratinq train were to sustain a random failure and lose function, the standby train would be available to accomplish the safe shutdown.
Fragments, if-produced in the standby train, would tend to settle out before the system was olaced in ooeration.
Therefore, a lower concentration of small fragments would be carried by the flow stream, and component loss due to plugging would he unlikely.
Comoonents in the flow stream include heat exchangers and valves.
There are no pumps downstream of the lined pipe.
Partial clogging of heat exchanaers would result in only minimal loss of efficiency.
Small oarticles would have minimal effect on open valves.
Mater samples removed from diesel generator and component cooling water heat exchangers. contained rust flakes and small pebbles, but no mortar
.chips.
2858D-Rl 1 (11/16/87)
TVA EMPLOYEE CONCERNS SIPECIAL PROGRAM REIPORT NUMBER: '3390',
REVIS ION NIJMBER!
4 Page 12 of 34 Nuclear Power Plaint Exiperience with Cemen't-'Mortar'-Lined Piping.
In a r'eview'f the PWR and the BWR volumes of "Nuclear Power Experlenice," only one case was noted of signif icant cement-mortar-lining failur'e due to cracking.
It was at Indian Point L'Init 1 in 1964 (details of t:his failure were not available),
(Ref. 32).
Other minor fai'lures were attiributablie to localized ex osion.
None of these cases were catastrophic or resulted in a chal'lenge to plant safety.
It is important t:o note that cenient mortar continues to cure and gain streng'th
'any years after installation.
Piping Lining Inspection.
One evaluator participated in the. inspection of a ttbI',-,,;,,;i
... p This inspection, based on a special maintenance iinstruction (Ref. 26)., covered the accessible portion (approximately 40 feet 'long) of discharge header A,
a 36-inch-diameter line.
The first, portion of the inspection was performed by WBN mechanical. maintenance personnel using a video camera in the piping and TV monitors on the surface.
The inspectors noted and marked anomalous indications in the lining.
The evaluator, after monitoring the TV examination, entered the piping aind inspected the lining, including one particular indication identified earlier.
lhis indication, approximatdlyl l-l/2 inches in diameter, on the top of the piping, consisted of an irregular indentation with rust discoloration, There were othier similar1ly discolored areas in the vicinity.
The evaluator concluded that; these indications may have resulted fry>m incomple1 e cleaning of this poi tion of the piping before
'he linina was ajiplied, resulting in inclusion of rust particles in the ceme'nt
'ortar.
These iridications appeared to be stabilized.
Otlher indications consisted primiari,ly of narrow filled cracks and birush marks at hand-repaired areas.
In qeneral, the condition of the lininq appeared to be good, with no indication of det:erioration having occurred in the riiearly' years since the lining was applied.
Ongoing Inspections.
TVA has comnitted to an ongoing program as Follows:
o Yearly inspections of niortar-lined pipe samples that are submerged in the Tennessee River at TVA's Singletion Materials Engineering L'abor atory.
If tests indicate 'signific'ant. dearadation of the l.ininq TVA will investigate the condit'ion of the cement-moir tar-lined ERCW pipe at WBNi; iThe NRC found this program acceptable in t,he Watts Bar Safety Ewal'uation Report (Ref. 31,).,
o Visual inspection from-the access points,to the first eibow in botlh directions to identify and report'on',defects.
(This inspection has been performed, as described above.)
2858D-,R11 (1'1/16/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 13 of 34 o
Periodic inspection of heat exchangers to determine if there is a
buildup of cement mortar particles (Refs.
25 and 40).
4.2.2 Finding There is no substantive evidence that the cement mortar lining is failing.
Although a large quantity of mortar material was flushed from the system after the lining was installed, this residue was believed to be from the lining
- process, mainly material removed from areas that required repair.
Even if there were substantial lining failure, there would be no loss of safety-related functions, because of system redundancy and because failed lining particles could be expected to settle before startup of the standby loop.
4.3 Linin Installation Procedures (WBN) 4.3.1 Oiscussion One concern
( IN-85-529-001) stated that there were differences betweeh the lining procedures used at WBN and. the TVA qualification,testing program.
A second concern (WI-85-040-002) stated that an "inadequate procedure" was used.
The TVA test report for the qualification program (Ref.
- 29) states the following:
"The qualification program was performed on full-size cement-mortar lined pipe specimens.
The lining procedure used was that of a standard
.commercial lining firm.
'lo unusual lininq practice or precise research laboratory testing control procedure was used during lining.
- Thus, the lined pipes.tested should be representative of commercially lined pipe.
On the basis of the test data and observed oerformance, a conventional, comnercially oroduced cement-mortar lined pipe is fully adequate for its intended function in a seismically qualified Category I raw service water pipeline."
The pipe lining tested included machine-troweled and hand-troweled sections.
The WBN instal'lation was more rigorously controlled than a conventional, commercially produced cement-mortar-lined pipe because of additional layers of inspection provided in the specifications (Refs.
2 and 27).
4.3.2 Finding The procedures used to install and repair the lining were adequate and in accordance with standard industry practice.,
The procedures were similar to those used for lining the samples used in the TVA testing and qualification program.
28580-R12 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER",.
4 Page 14 of 34 4.4 Contractor Inspection and Oocumentation.(WBN 4.4. 1 Oiscussion The concerns t,hat touch on this subject specifically state that the contractor's inspection criteria and plan were inadequate and that the contractor failed to perform or document reguired inspections.
The latter issue was the subject of NCR 4270R, Revision 2 (Ref. 18).
Unfortynately, this addition to the NCR was issued several months after completion of the contractor's work.
A subsequent TVA QA audit of 'the. c'ontractor's records (Ref. 21) clearly confirmed that the contracto'r had an acceptable program plan, but that it,ivas poorly implemented, resulting in fai lure to maintai n records of inspections.
Because there is no documentation, no conclusion can be drawn as to whether or not the contractor i,nspected the work.
It is possible that many of the required inspections were no't made.
This subject is discussed further in paragraph 4.5..1.
4.4.2 Finding The lining contractor's quality assurance and inspection plans were adequate.
How'ever, the contractor fai'led to,document results of many of the required inspections.
Therefore, it cannot be ascertained whether the required'nspections were performed.
Lining adequacy, in the absence of this documentation, is based tin the evaluation described in Section 4.2.
4 ~ 5 Oisposition of NCRs
('ABN)
- 4. 5.
1 Discussion Issues raised by several concerns are the nume'rou's deficiencies in the lining contractor's performance of the work and 'the apparently indiscriminate aoolicatinn of'use-as-is" disoositions by Enoineering Oesign.
Several NLRs were issued during an approximately 6-mon'th'peirio'a,. including 4117R,
- 4133R, 4163R, 4270R (incluiding revisions),
and 4357R (Refs. 46, 8;
9, 12, 14; and 18).
Most of the specific problem areas',
and all of the areas raised in the
- ECs, were covered by NCR 41 17R.
The techlniCal problems covered by thi0 NCR
'ero sufficient to Irequire a stop-work order until they were resolved.
The other NCRs were, for the ~ost part, concernS related to work in progress, with several of the original nonconformances recurring, although at a substantially reduced rate.
Several TVA engineering memoranda were 'issued to dispositidn these NCRs (Refs.
5, 7, ll, 13, 15; and 19).,
The three specific issues identif'ied in the NCRs related to the ti~chnical
- auality, and their dispos,itions are discussed below.
28580-Rl 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 15 of 34 Inadequate Mortar Thickness (IN-85-877-001 Engineering Design revised the soecification to allow a greater tolerance in the mortar thickness.
The basic reauirements for the lining process are found in American Water Works Association (AWWA) Standard C602-76, Cement Mortar Lining of Water Pipelines-In Place (Ref. 30).
In accordance with this standard, a nominal lining thickness of 3/8 inch was specified by TVA, with a tolerance resulting in a
minimum allowable thickness of 5/16 inch.
- However, the 3/8-inch nominal value in the standard is based on "old" pipe.
A 1/4-inch, nominal value is recommended for "new" pipe (or 3/16-inch minimum).
Inspection of the piping prior to lining (Ref.
5) showed that the condition more closely matched that of "new" pipe.
Therefore TVA Specification N3M-921, Cement Mortar Lining of the'ERCW System (Ref. 27),
was revised to.specify the minimum acceptable thickness of 1/4 inch.
This change provided the justification for the "use-as-is" disposition of those lined sections listed in the NCRs as having lininq thicknesses between 1/4 and 5/16 inch.
Low Humidit Durin Curin of Pipe Lining.
One of the apparent problems with the pipe ining contractor's work described by TVA gC inspectors was control of humidity in the piping sections (Refs.
4, 6,
and 8).
The specification reauired maintaining at least 90 percent relative humidity in the lined pipe sections for a minimum 4-day curing period.
Humidity control is important to proper curinq of the pipe lining to prevent r api d surface drying that could result in cracks in the mortar lining.
Humidity measurements were to be made four times each day during the curing process.
The pipe lining contractor had considerable difficulty maintaining the required humidity level in the lined sections because of'he humidity measurement process itself.
End caps had to be removed from the piping sections to gain access for the measurement.
This action resulted in a drop in humidity during the oeriod the end caps were removed.
To determine actual humidity conditions during the curina process, a
continuous humidity monitor was installed in a newly lined pipe.
It was determined that adequate humidity could be maintained in the piping sections by procedural controls (Ref. 5).
Accordingly, the humidity measurement requirement was deleted, and procedural controls for maintaining humidity were closely monitored thereafter.
Because an acceptable curing orocess is demonstrated by the absence of cracks, inspection of piping sections after curing can show whether the curing process is acceptable.
This was the basis for the "use-as-is" disposition of this.NCR item.
Low Compressive Stren th.
TVA Specification N3M-921 requires sampling of cement mortar and preparation of test specimens for determining the comoressive strength of the material after 14 days.
NCR 4133R, Revision 1
{Ref. 6), item 5.F, describes test results on a sample for which the minimum strenqth was 6,266 psi, compared'ith a specified.minimum of 8,000 psi.
The 28580-Rl 1 (11/16/87)
'TVA EMPLOYEE CONCERNS SPECIAIL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 16 of 34 TVA Engineering disposition of'his item inCluded a statistical analysis
~of
~
the data for all cement-mortar-material kombrelssive'e'sts in accord5nch with American Concrete Institute standard ACI 214-77, Standard Recommended Pra'ctice'or.
Evaluation of'Strength Test Results of Concrete (Ref. 33).
This ahalysis indicated that: the average strength of samples was '9,150 psi, and that all deviations, including the above case, fell within the tolerances of acceptable standard practice.
This formed the basiS for Ithis "us'e-as-is" dispositio~n (Refs.
7 and 15),.
refers to the disposition ot NZFM7UR, Kevision 2 (Ref.
18).
The issue here appears to be that the contractor's records of inspection were inadequate for the areas from which nonconforming lining was removed, prior to making repairs.
The contractua'l responsibility for performing these inspections was the contractor's,, itself a point of di'sagrei'erne'nt'betwe'en Engineering Oesi~gn
~
and site QC.
When the TVA QA audit of the contractor's records (Ref.
21)~ was
~
performed, it was clear that this critical inspection had not beqn well documented by the contractor.
This audit was not performed until May 1983, nearly 6 months after the contractor's wOrk was Completed.
The eventual disposition of the audit findings was "use-as-is'" (ref. 39) and relied on analysis for suitability of service as discussed in Section 4.2.
It appears that, given the sensitivity of the division of inspection responsibility issue mentioned
- above, TVA QA/QC.would ensure that the
~
contractor was documenting its inspections in accordance with the contract (Ref.
2);;
Had TVA done so, the need for an after-the-fact disposition of an NCR would have been avoided.
Another important aspect of this issue was identified in iCR 4270R.
The is made that, as a result of the contractor being.responsib'ie for repair inspection (Ref.
13), the auality of the'lininq "cannot be determined.~'oncept was carried through into the NSRS Report I-85-166-WBN (Ref. 23).
report entitled
"'NSRS Perceptions of Watts Bar Status" (Ref.. 4O), issukd early
- 1986, NSRS repeated its claim that the status of the lining was
~
"indeterminate."
claim ar ea This
,in 4.5.2 Finding The disposition by Oesign Engineering of nonconforming condition reports (NCRs) covering the technical requirements for the cement, mortar lining was appropriate and adequately documented.
- However, one NCR subject, not in
~
Oesign Engineering's area of responsibility',
was not dispositioned in a timely manner.
No quality assurance audit of the WBN lining contractoi' record's of required inspections.
was performed unti.l seVeral months after the work'wa's completed.
0 28580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 17 of 34 4.6 Qualit Sacrificed for Schedule and Interference with Site QC
':lBN 4.6.
1 Discussion Concern IN-85-442-112 claims that Design Engineering "valued schedule over quality" in both its issuance and monitoring of the pipe lining.contract.
No direct evidence was found to substantiate this concern.
Concern IN-85-442-X12 states that Design Engineering prevented site QC from monitoring the lining repair areas.
QC was therefore unable to confirm that bad mortar was chipped all the way to bare metal, and could not effectively participate in an audit of the contractor, as discussed in Section 4.2.
As 'discussed previously, the lining contractor was. responsible for inspection of repair areas prior to relining.
This was not a hold point in accordance wi,th the contract.
There were two hold points for TVA inspection established by the contract, both related to inspections prior to initial lining of pipe sections.
However, there was no evidence that Design Engineering prevented QC from monitoring the contractor's repair work 'other than the fact that the hold point -was not included in the contract, nor was it added after the original problems were identified.
A statement supporting Design Engineering's contention was included in the memo (Ref.
- 10) dispositioning NCR 4270R, stating that Construction "may at your discretion continue to perform surveillance inspections on the repair procedures employed."
4.6.2 Fi'nding No objective evidence divas found that Desiqn Engineering was unduly influenced by schedule considerations either, in awarding the lining contract or in dispositioninq NCRs relative to the work (see Section 4.5 above).
It was also found that Design Enaineerina encouraged, rather than discouraged, sit Quality Control's efforts to monitor the contractor's work.
4.7 NSRS Disposition of Emplo ee Concerns (WBN) 4.7.
1
,Discussion Concern 'AI-85-098-001 relates to the handling of another concern in the "Nuclear Safety Update,"
10/11/85, published by the NSRS (Ref. 34).
The claim is made that the NSRS did not identify the basic problem associated with the ERCM piping lining.
2858D-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM PEP!ORT NUMBLR:
23300 ftEVISION NUMBER:
4 Page 18 of 34 The specific NSRS report deailing with CI>ncerrI III-85-415-002 was I-85-158-WBN (Ref. Z2).
This. 1-1/Z page report was IonderIseIi i'nto three sentences ar!d, with the concern, appeared in "Nuclear Safety Update,"
as follows:
"Concern:
The essential raw booli!ig &at'er '(ERCW). lines (intake at pump house) are concrete
- lined, and 'are deteriorating.
This cau. es continual i'.ailure of ERCW system'a!e fo pluigging of strainers by concrete chips.
"Results:
A review of maintehance
- requests, hew water samp'les, and'nterviews found that pieces of mortar chips were seen duri!ng th5 initial system rest:art,
- but, tlI!eye weire a res'ult of the installation process.
1'he mortar chips were flushed out and no others have been seen since.
No mortar chips
~vere four>d in the water sample's whic".h
'ere
- taken, and no failures of the strainers have been attrjibktecl tl plugging by mortar ch'ips.
.( IN-85-415-002)"
The issues identifieal in the NSRS report are discussed in Section 4.2'..
'This report documents interviews with knowledgeable personnel.
and discusses lining'eterioration;
- however, the report does'not a'ddr'ess the concern that there have been continual. fai'lures of the ERCW system due to strainer plugg'ing'.
4.7.2 Finding A publ i shed summary aif an NSRS di sposi t i on of one of the employee concerns was excessively brief and could lead tihe reader.
to bel ieve that the
'ISRS investigation was not sufficiently thorougn.
However, it was alwavs int'ended
'hat the full investigation reoorts would be
-naa!e avaIlaole io interes ed parties (Ref. 43).
The full NSRS ~eport, for this particular concern was detailed enough to show the emplloyee that the'riivestigation was suffikiehtly thorouah.
0 4.8 Co!r!piete!ness of the Linin~Process
'(BL'N)
Concern BNP gCP-10.35-8-24 requires further xamination.
The term "protective coating" was used by the concerned indiv!idual (C'I).
Normally tllle term "lining" is used to describe a material applied to the insi'de of pioing and'protective coat:ing" is used to describe'he I xt'erior'of certain piping, sucn as that which is bI~ried underground.
The buried portion of the I=RCW piping is provided with such an external coating.,
- However, because there are'o other employee concerns that relate to protect'ivd cbatIng on any piping system and the lining of the FRCW piping was the subject of many concerns, the evaluat'ion team concluded t;hat the use of the teirm "priotI.ctive coating" by the CI resulted from unfamiliarity with! the distinction between the t,erms des!cribed
- above, and that the term "'lining" was'n'tended.
'8580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 19 of 34 The term "section" of piping, as applied to the actual ERCW pipe lining
- process, referred to lengths of approximately 1000 feet.
These lengths were bounded by short sections removed from the piping to provide access for the contractor's lining operations.
Because of the terminology problem mentioned in the previous paragraph, it was assumed that it was not the CI's intent to claim such an extensive omission of lining.
Therefore, this investigation decided, that the concern might apply to any portion of the lining, regardless of length.
The specific scope and description of the lining contractor's activities are contained in two TVA specifications (Refs.
50 and 51).
These specifications require several levels of inspection of completed
- work, as follows:
o Primary inspection responsibility was assigned to the contractor's inspectors.
o TVA inspectors iver e assigned to moni'tor the work of the contractor's inspectors and to perform independent inspections.
o The TVA Project Manager for lining activities inspected each section of pipe after it had been lined and each closure piece after it had been repaired and hand lined.
One possible origin of the concern is the difficulty in completing those=
portions of the lining covering final closure welds in the pioe sections removed for access to the buried oiping.
At WBN, an accessibility problem prevented hand lining of these final closure weld areas.
- However, at BL'N, provisions were made to maintain access even to these
A final report (Ref.
52) issued by TVA relative to Ra'ymond International's performance of the lining work at BLN stated that "the application of the cement mortar lining was performed in a very satisfactory
- manner, and TVA CONST was well. pleased with the cooperation given by the contractor's field personnel."
4.8.2 Finding In view of the multiple levels of inspection provided, the thoroughness in planning the accessibility for lining operations, and the satisfactory performance of the contractor, it is highly unlikely -that any of the required lining was not completed.
28580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT'UMBER:'
23'30O REVISION NUMBER:
4 Page 20 of 34 4.9 Lining Inteqri~t at Chanoes in Direiction BL~N 4.9.
1 Discussion The concern questions the quality of lining a't piping "bends."
In practice, no pipe bends were used to changle piping: direiction
- Instead, welded dlbbws were used.
The main issue of this concern appears to be the quality of'and - rather than machine - application of'he cement mortar lining.
Because it is'impr.actical to machine line all piping, the short sections of piping welds must b0 hland lined after piping is reinstalled.
Host areas to be repaired (usually fbr excessive cracking or for lining that is too thin) must be hand lined after substandard lining is removed.
Therefore, hand lining must be as capable of producing quality lining as is machine lining, and,, in fact, it is.
Machine lining primarily has economic advantages, but also produces a more-uniform thickness and a better surface f'inish.
Hand lining can-be of high quality because the craf'tsman is able to observe and Con'trO1 the process during application.
The concern specif ically mentions the use of lhand lining at changes irr piping direction, implying that', machine. lining at such locations was not practicable.
The TVA final report on the contractor's work,, referenced
- above, contains the following item in a list of problems encountered":
"Linin~Pipe Elbows - The mechanical trowels on the lining rhachine were not designed to operate at pioe e'lbows; therefore, it was necessary to app'iy the lining 'to'pipe 'elbows with the:mechanical trowels removed from the lining machin~e.
Once the ilining was
'pplied, then the elbows were hand-Finished."
It may be seen from the above thatat elbows[
o~nly.he finisning, not the application, was performed manual lii, in ~contrast'o the statement contained iris'he concern.
.4.9.2 Finding At elbows, only the finish'ing, not the app1lication, was'performed mandalliy, in contrast to the statemeht contained in 5he~conceirn.
- However, hand lining is an acceptable method for producing quality lining and is used fo)r repairs and for other lining where machine application is impract'ical.
2858D'<<R 1 1 (11/18/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 21 of 34 4.10 Inspection Ade uac BLN 4.10.
1 Discussion The CI points out that more TVA inspectors were employed at WBH than at BLN for similar work.
The CI indicates that WBN experienced "quality problems,"
which is a reasonably correct statement, as indicated in the WBN review.
The CI is concerned that, with less TVA inspection, BLN would be expected to have a relatively greater number of problems than WBN.
As indicated in Section 1, different contractors applied the ERCW lining at WBH and BLN.
At WBN, significant technical problems arose shortly after the lining work began, to the extent that a stop-work order had to be issued until the problems were resolved.
Numerous NCRs (see Section 4.5) were issued throughout the performance of contractor's work.
Although the primary inspection responsibility was the contractor's, as it was at BLN, it is evident that the contractor failed to perform. the required inspections.
Therefore, a greater burden of inspection fell on TVA at WBN.
As described in Section 4.8, the contractor's performance at BLN was satisfactory.
Review of the referenced final TVA report shows that only three NCRs (Refs.
54 and 55), covering minor issues, were issued during the course of the BLN l.ining work.
Considering the above, the difference in number of TVA inspectors employed at WBN and at BLN appears to indicate not a cause of difficulty at BLH, but better contractor performance at that plant.
~ewer TVA 'inspectors were needed at BLN than at WBH because contractor performance was 'better at BLN.
4.11
(}A Documentation Adequac (BLH) 4.11.1 Discussion As indicated previously, the contractors had orime responsibility for performing and documenting required inspections (Ref. 51).
The CI appears to be indicating that this self-inspection arrangement may have contributed to a
lack of quality assurance of the contractor's work at BLN.
The contractor gA programs at WBN and SLN were conceptually identical.
At WBH, the contractor's QA program was characterized by TVA gA as "a well-conceived documented program [which was] poorly implemented."
No 2858D-R12 (11/16/87)
TVA EIMPLOYEE CONCERNS SPECIAL PROGRAM Ri.PORT NUMBER:
23300 REVISION NUMBER:
4 Page 22 of 34 auditing of the
'NBN contractor's documentat~ion of h'is 'work was performed until several months after the work was completed.
Most of the required inspections
[
were found to be undocumented.,
In contrast, TVA au~dited the BLN. contractor while the work was being performed.
The TVA Quality Assurance Audit Report (Ref.
- 53) found that "no deficiencies. were observed."
It appears that the inspection/documentatio'n v'cwork at BLN did not compromise the QA requirements applicable to the lining activities.
- 4. 1.1.2 Finding Quality assurance documentation iprovidedl bye the contractor at BLN was found to be, adequate.
Documentation responsibility 'wat a0si'gned to the contractor by TVA.
Audits performed during the BLN linin'g activities found no documentation deficiencies.
4.12 Summa g The classified findings are summarized-in Table l.
Class A and 8 findings indicate that there is no problem arid that co&redtive action is not required.
Class C, 0, and E findings require cot'recti've'action.
The corrective action
- class, defined in the Glossary Supplement, is identified in the table by the numeral combined with the finding class.or'examp'le,'he designation 03 in Table 1 indicates that the evaluated issue wa0 found to be valid (finding Class 0) and that a corrective action inkolvidg documentation requirements must be taken (corrective act',ion Class 3}.
~
Findings are summarized by classification i~n 7able
'2. 'f the ll findings identified by a classification in Table 1, nine require no corrective action.
The other two findings resulted in new corrective actions.
Both of these findings resulted from issues originating a't
!~1BN,',
i(i 5.
CORRECTIVE ACTIONS Table 2 identifies two find'ings that require Corrective action.
- However, the second finding -covers an issu<~ that is the subset of the much broader first finding.
Therefore, only one corrective~ ac~tion is requii'ed for the two issues.
CATO 233 Ql
<<fBN 01 described the required corrective action as fol lows:
"The contractor for installing the ERCM piping cement mortar lining failed to document required inSpeCtionS. 'his failure waS covered in NCR 4270R, R2.
Action on this NCR.las not taken in a timely manner.
Fo'liow-up action is requ'ired to prevent recurrence of such problems."
28580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 23 of 34 The detailed corrective action description is provided in Attachment B.
The purpose of the corrective action was:
. to provide a means of controlling gA.
. contractor activities
. at TVA nuclear power plants and for providing a
means of notifying the Nuclear guality Audit and Evaluation Branch (NgAKB) of onsite contractor activities."
This corrective action is also summarized in Table 3, along with its corresponding finding/corrective action classification.
This corrective action is identified as applicable only to WBN.
- However, the corrective action taken was generic to all four plants.
From the Finding/Corrective Action Classification column of Table 3, it can be seen that the single corrective action identified requires action involving documentation requirements.
The evaluation team found the corrective action plan to be acceptable to resolve the findings.
Other corrective actions, at a much broader level, have been initiated by TVA to address issues that underlie the specific issues covered in this report.
These actions are discussed briefly in the following two sections on causes and collective significance.
6.
CAUSES Table 3 identifies "Inadequate Procedures" and "Lack of Management Attention" as the causes of the problem described in Sections 4.4 and 4.5.
However, this is an oversimplification of a complex problem to which there appear to have been many contributing factors.
Several of these factors were in areas beyond the scope of the Engineering category.
At the most immediate level, the factors that appear to have contributed to the problem were as follows:
o Contractor unfamiliarity with performance of work under a gA program.
The contractor tended to perform the work in the manner to which it was accustomed, i.e., with minimal paperwork.
The list of previous work submitted with the contractor's proposal did not include any oerformed on nuclear power plants (Ref. 37).
o Schedule pressures on contractor and TVA construction personnel.
Lining of approximately five miles of piping, involving complex logistics, had to be completed within approximately three months, according to the contract (Ref. 2).
28580-R11 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:'
23300 REVISION NUMBEFI 4
Page 24 of 34 I
Focus on more direct quaiiity drobletns.
As indicated in Section 4.5, numerous NCRs were issued covering 'abroad
'spe'ctrum of contractor nonconformances to specification technical requiremi.nts.
These NCRs required substantial effort by construlction and engineering personnel throughout the contractor's work.
Howeve~,
the NCR that recommended auditing the contractor~'s ~inspection records was nbt
'ssued until the work was virtlually cdmplete (Ref.
12)
As indicated in Section 4.4, the contractor's QA program plang based On TVA's contract gA requirements, was not the cause of the problem.
What appear to have been missing were TVA procedures to assure implementation of nontechnical specification requirements,.
Praicedures for the following were inadeq~iatia or nonexistent:
o Defining interorganizational responsibilities anal communications methods o
Scheduling and initiating audits of documentation o
Informing concerned personnel of contractor capabilities and qualifications, to assist planning of contractor survei llande The TVA contract (fief. 2), in.the "Special Conditions" section, contains the following relevant provisions:
"Technical gn(sineer.
The Technical Engineer shalt he..., Chief, hecnan>cMacn(i>nearing Branch...
(i<noxvil'le]...
He will (aI represent TYA in matters concerning the amount, quality, acceotability, and fitness of the work and materials to be furnished under tfie contract, and (b) answer all questions which may arise as to measurement of'
'uantities and the fulfillment of the technical requirements of the specifications.
Communications
~elative to the teclhnical matters should be directed to him." (page 1)
"Project ManaiIer..
The Pr'oject:
Mtanager shall be....
LABW site]i, gino'nnan represent pvn, in tine,in.",paction of materi ails, procedures, and quality of work at the construction site.,"
(page 1)
"Ins ection of Installlation.
Inspection at the c'ite and of installation ws be the duty o7 the IMrorect Manager who shalll have access to 'th5 wbrk't all times and shall be given every facility for making unhampered inspection."
(page 2)
"Access to Work Areas and Contractor'si Records.
The Engineer and his ass>stants or otner autK>rizeat agents or T7~sha1ll at all t'Imes have access to all places where work is being done ta provide services under 28580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 25 of 34 this specification, and they shall have full facilities for unrestricted inspection of such work.
The Engineer and his assistants or other authorized agents of TVA shall also have access, at all times, to the Contractor's records and files for material provided under this specification for the purpose of conducting quality assurance audits and inspections."
(page 5)
"Qualit Assurance Pro ram Manual Submittal.
The Contractor's Quality Assurance Manua shal be submitted in accordance with appendix E to TVA for review and acceptance by.the TVA Oivision of Engineering Oesign Quality Assurance Branch.
After award of contract, the program and manual shall be available for review and accessible to audit throughout the life of the contract.
The Contractor shall, during the life of the
- contract, submit all proposed changes of his Quality Assurance Program to the Quality Assurance Branch for review and approval prior to implementing the change.
All revisions to the Quality Assurance Program shall be identified by the TVA project name and contract number."
(page 6)
Appendix B to the.above contract, covering QA requirements, provides further amplification of the above in Section 14.0, Quality Assurance
- Records, and Section 15.0, Audits.
These records are clearly defined as a deliverable product under the contract.
From the above quotations, it is clear that there was a definition of division of responsibility between Engineering in Knoxville and the Project Manager
( a member of the Construction organization).
The Project Manaqer was responsible for reviewing all contractors'ctivities at the site related to "quality of work."
These would appear to include maintenance of required documentation while it remained at the site.
Although it would be expected that the Project Manager would utilize Construction QC Dersonnel to orovide this review, it appears that there were no procedures for reviewing the software portion of the work of onsite contractors.
It appears that Construction QC did not understand this to be its responsibility, as it recommended a
QA audit of the contractor's documentation (Ref.
12).
From the corrective actions that were taken, it appears that TVA did not have adequate means for informing QA personnel responsible for performing audits that there was a need for their services on a particular activity at a
particular time.
The Nuclear Quality Audit and Evaluation Branch has been established to evaluate site contractors'ualifications in order to determine how closely the contractors'ctivities should be monitored and to schedule appropriate audits.
28580-Rll (11/16/87)
TVA EMPLOYEE COhlCERNS SPECIAL PROGRPiM RIEPORT NUMBER:
23300 RIEVI SION NUMBER',:
4 Page 26 oF 34 From the quotation.;, it may also be seen that the Engineering contract requirements, relative to documentation requirements and provisions for following the contractor's activities, were reasonably complete and cleai.,
except for.the specific responsibilities of'he Project Manager.
On a broader. basis,,
the underlying cause of'he "Inadequate Procedures" divas a
"Lack of Management Attentionm to QA in general.
This alppears to have b0en the case within the engineering organization, as well as at higher leVelS o'f TVA management.
Within the engineering organization, there appears td have been adequate front-end consideration of QA, but it, does not appear that anyi followup activities were attempted in this area.
The falct that no audit of the contractor's records was made until several imonths after the work 'waS completed gives ample evidence of the lack of attention paid to this aspect of'the work.
The following, is a brief review of other subcategory replorts thait proVide information relative to the foregoing discussion of causies.
o 20400 Einiiineering Or cianization and Oper tin PrOcedures (Ref: 61')
~neer e
ament
'26600TWrrgantzat.rona trufture ts,sue g covers a
Tack of effectivle communication and interface control....
between EN-01ES and other divisions."'ommunication and interface problems were found to exist between EN OES and other omega'niz'ation's
('not including Construction).
" Inadequate Procedures" and "Laci: of Management Attention" were among the problem causes idtentified in this subcateqory report.
o 70600 alanagement Techniques (qef;
- 62) - Under the generarl findings, ir; rs stated
- that, management technrque tn OitP...
rras marred by a
1 aclr of clearly established lines of authority, by poor communications'ith'mployees, by an absence of teamwork based on shared beliefs and information.
Uinder element 70604, Faulty Communication, it was found that "ONP managers need improvement; in communication Skills arid should ble helci accountab'le for communication responsibilities."'nder element
- 70605, Lack of Commitment tb Qua1Iitg, 'it 'was found that
""qbality'ssurance'equirements
.were not well definIad or effectively communicated to the line resoonsible for the work, and the responsibility of the QA organization was not clearly established."
Also, "the lack of ac'ceptance'ases resultecl in QC inspectors, const1rudtibn engineers, and QA personnel all trying to determine acceptability.'"
'The c'auSe Of these problems was that "TVA repeatedly app'lied its management experience drawn from,its design and construction of fossi 1 and 'hydro'ower plants to its nuclear program,"'ailing to recognize the "'managerial chial'lenges unique to the nuclear industry" 28580-R12 (11/16/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 27 of 34 o
80100, Uualit Assurance Management and Polic (Ref.
63
- This report, in the Qua ity ssurance Qua ity ontro
- category, inc udes findings of significant deficiencies in several
- areas, including gA organization and
- training, and audits of construction activities.
It also provides historical perspective relative to TVA gA program development.
For
- example, the TVA gA program has undergone three major changes in direction since the subject contract was issued.
The first, creation of the Office of guality Assurance, occurred during the late stages of the
.performance of this contract work.
(This major reorganization may have been another factor contributing to the failure to monitor contractor gA program compliance.)
7.
COLL CTIVE SIGNIFICANCE The evaluation team's judgment as to the significance of the corrective action listed in Table 3 is indicated in the last. three columns of the table.
Significance is rated in accordance with the type of changes that are expected to result from the corrective action.
The 23 concerns expressed in the subcategory Essential Raw Cooling Water Piping resulted in two issues requiring a single corrective action as a direct result of the employee concern program.
No additional corrective actions were required other than those implemented before the ECTG effort.
Table 3 shows that the single corrective action.required in this subcateqory resulted in document changes.
The changes were procedu'ral and organizational in nature.
The corrective action was considered significant because ii should prevent failures of contractor gA documentation activities, such as those that occurred at Watts Bar.
Most of the employee concerns (21 of 23) raised issues in the areas of technical adequacy or design process effectiveness.
None of these required corrective action.
Only three of the employee concerns raised issues related to contractor inspection and documentation.
This is the area for which corrective action was necessary.
The evaluation team considers it significant that the employees',
erception is that an actual quality problem, as opposed to a paperwork problem, sti l exists for the ERCW cement mortar lining.
The evaluation team also feels it is significant, to note the sharply contrasting experience at the Watts Bar and Bellefonte plants in the area of contractor gA documentation.
With virtually identical engineering specifications and contractor and TVA gA program plans, and with closely overlapping time frames for similar work scopes, opposite results occurred.
At Bellefonte, not only did the contractor provide proper OA documentation, but TVA audited the contr actor's documentation in a timely manner.
Tnis level of performance indicates that the TVA corporate and, site procedures in place 28580-R12 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM RI=PORT NUMBER:
23800 Rl=VISION NUMBERS '
4 i
Page 28 of 34 at that time were capable of producing, although not assuring, desired results.
As indicated in Section 6, these procedures were far from complete, which created a potential for such different responses.
It is possible that a'ore positive attitude toward QA existed at.
BLN at that time.
It also appears that the factors mentioned at the beginning of Sect,ion 6 contractor inexperience, schedule pressures, and focus on numerous technical problems were relatively less signif'icant at BLN than at NBN.
- However, the evaluation
'eam considers that these conjectures relate to issues primarily outside the scope of, the engineering category originating at higher levels in the ~TVA organization.
These issue.;
appear to be a subset of the broader issues that have resulted in the significant organizational and procedural changes that TVA has made since these problems occurred in 1982.
The TVA Corporate Nuclear Performance Plan (CNPP) describes improvemerits in TVA QA organization and procedures (Ref. 60).
Improvements have been made in the TVA organizational structure, with clearer assignment of responsibility'nd authority, consolidation of the nuclear organizat'ion, centralization of site activities, and improvements in management system programs and procedures.
No mention's made in the CNPP of the soecific changes to the TVA NQAM described in Attachment B to this report.
However, reference is, made, in, this section to two of the QA functional groups affected by the changes, the Nuclear Quality Audit and EvaluatiOn Branch and the Site Quality ManagerS.
The concluding sentence of this CNPP section states that the aetio'ns will h'elp assure ".
. that lines of responsibility and authority for nuclear QA/QC activities are clearly defined These actions should greatly r6duCe the probability of recurrence of those problems as described in, this report.'he results of thi;- subcategory evaluation are being combined
~vith the other subcategory evaluations and collectively reasSes'sed in the Engineering category evaluation.
28580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 P age, 29 of 34 TABLE 1
CLASSIFICATION OF FINOINGS ANO CORRECTIVE ACTIONS Element Issue/
~Findin **
Finding/Corrective Action Class" W
N 8
N BLN N
233.
1 equality of Concrete Pipe Lining a
b c
d ef 9
A, A
A A
A A
03 A
03 8
C2
- Classification of Findin s
and Corrective Actions A.
issue not valid.
No corrective action required.
B.
Issue valid but consequences acceptable.
No corrective action required.
C.
Issue valid.
Corrective action initiated before ECTG evaluation.
0.
Issue valid.
Corrective action taken as a result of ECTG evaluation.
E.
Peripheral issue uncovered during ECTG evaluation.
Corrective action required.
"*Oefined for each plant, in Attachment B.
- 1. Hardware
- 2. Procedure
- 3. Oocumentation
- 4. Training
- 5. Analysis
- 6. Evaluation
- 7. Other 28580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
, 23'30()
REVISION NUMBEf(:
4 Page 30 of 34 Classification of Findi~ns TABL'E 2'INDINGS
SUMMARY
Issue not valid.
No corrective action required.
B.
Issue valid but consequences acceptable.
No corrective action required.
C.
Issue valid.
Corrective action initiated before
~ECTG evaluation.
D.
Issue valid.
Corrective action taken as a result of ECTG evaluation.,
3 4
7 1
0 1
0 2
0 E.
Peripheral issue uncovered during ECTG evaluat,ion.
Corrective action required.
Tot,al 0
0 0
0 28580-R 1 1 (11/16/87)
Cl
0 IAatt 3 Mikla Uf LLLHLNIS. Cbkkflllvt ACIIUNS, Ahd CAUSES SUBLAILGUNV 233UO RfVISION NNIERt PAGE 3l UF 3t HahautHthl tf Ital lrtht'A CAUSES OF NEGATIVE F INDINGS ~
I I
TECHNICAL UtSIGN PROCESS Ef FECT IVENESS AOE ACV I
2 3
a S
6
)
O g
10 II l2 l3 ld IS 16 ly F IhUING/
CORRECTIVE ACTION flot CLASS aa CORRECIIVE ACIION LAIU lfrag I
I lyrae" llnade I I
I I
llnadc I lfngrg IOeslgnllns<<
I lnentedllnade-llnade-Inures Iquate Iun-I Ilnade I
lquate I Lack IJudgntl(rlt/ IVerlf IStds IOrgan-Iquate Iquate lhut ICun-ltleelyll<<k Iquate llnade-IAs-bit!
of I not IConnltlDocu-lhot lite-I tl-IProce-IFol-Inuni-Ines oflof Hgtlbeslgnlquate lkecon-IOeslgnlbocu-I Not Inenta-Ifol tlon trn dures loved catiun Issues Attrn Bases Calcs cll.
Detail nented Het tlon loved I Slgnifl-I cance of I Correctlre Ifngrg IVendorl Actions'rror Error D
H ll I 233. I O3 Prorlde neans for controlling NBh Ol suocontractor quality I
assurance actiriiies I
I I
I I
I I
I I
I I
I I
I I
IAI-Defined in the Glossary Sup@learnt.
~ a Defined In Table I.
2861D-Rl
( II/Ib/By)
TVA EMPLOYEE CONCERNS SPECIAL PRO'GRAM REPORT NUMBER:'
23'30O REVISION NUMBER:
4 Page 32 of 34 GLOSSARY SUPPLEMENI FOR
'THE ENGINEERING CATEGORY Causes action 2.
3.
4 ~
5.
0 ~
ai're categIor ized als follows:
Fracrmented organization - Linies of authority, responsibility, anI8 accountaibi lity were niot clearly defined.
Inadecluateuali~t (O) trainincI
-" F'erponnel were not fully trthinI>d 'in
'he procedures estabTished 7or design process control and in iIhe maintenance of design documents, including audits.
Inadeguate~riocedures
- Design and modification control inethocls and procedures were deficient i'n establishing requirements and dici not ensure an effective design control progr am in some areas.
Procedures not followed - Existing procedures control1ling the design process were notMuTTy adhered to.
Inadequate communications. - Communication, coordination, and cooperation were not Mu Ty effectiv'e in supplying needed in within plants, between plants and organizations (e.gae Engi Construction, Licensing, and Operations),
and beitween interorganizationall disciplines and deoartments.
formatioh neerihg,'ntime~1 resolution of issues
- Problems were not resolved in 'a timidly'anner, ancMtieir resolution was not aggressively, pursued.
7.
3.
Lack of management attention - There was a lack of management attention in ensuring tnat programs required for an effective design process wer:e established arid implementeda lnadeouate de:ion bases
- Oesign ba es. strewldcking, vague, or rncompete 7or rfesrgn execution and veriification and for design change evaluation.
9w Inadequate ca'Iculations
- Design'a'lciLjlatio'ns 'were incomplete, used incorrect input or assumptions, br 'otHerwise failed 'to fully demonstrate complialnce with design requirements or support design output, documents.
10.
Inadequate as-built reconciliatifIrn - RecrIrnc'ili'ation of desiqn and Trcen:srng oocuments wiittr~pant as-built r:onditiori was lackirlg or incomplete.
0 28580-R 1 1 (11/16/87) '
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page 33 of 34 11.
Lack of desi n detail - Detail in design output documents was
>nsu resent to ensure compliance with design requirements.
- 12. Failure to document en ineerin ud ments - Documentation justifying eng>neering gu gments use
>n t e essgn process was lacking or incomplete.
- 13. Desi n criteria/commitments not met - Design criteria or licensing commitments were not met.
- 14. Insufficient verification documentation
- Documentation (g) was insufficient to audit the adequacy o
design and installation.
- 15. Standards-not followed - Code or industry standards and practices were not comp se with.
assumptions, methodology, or judgments used in the design process.
17.
Vendor error - Vendor design or supplied items were deficient for the Classification of Corrective Actions - corrective actions are classified as belonging to one or more of the following groups:
1.
Hardware - physical plant changes 2.
Procedure
- changed or generated' procedure 3.
Documentation - affected gA records 4.
~Trainin
- required personnel education
~Anal sis - required design calculations, etcst to reso'Ive 6.
Evaluation - initial corrective action plan indicated a need to
~eva uate the issue before a definitive plan could be established.
Therefore, all hardware, procedure, etc.,
changes are not yet known 7.
Other - items not listed above 28580-R 1 1 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
2J306 REVISION NUMBER:
age 34 of 34 Peri heral Findi~n (I,ssue) - A negative'fi'ndi'ng, 'that does not result directly rom an emp oyee concern but that was unco~vered~during the process of evaluating an employee concer n.,
By def inition, peripheral findings (issues) require corrective action.
Si nificance of Corrective Actions - The evaluation team's judgment as to the signs icance Mo the corrective actions listed iri Table 3 is indicated in the last three columns of the table,.
Signii.icance is,rated. in accordance with the type or type." oF changes that may be expected to result from the corrective action.
Changes are categorized as:
o Oocumentation change (0) - This is a change to any design input or output document (e.g.,
drawing, sp4cifikat'ion', CalCulation, or procedure) that does not result in a significant reduction in design margin.
o Change in design margin (M) - This is a change in design interpretation (mini>num requirement vs actual capability) that results in a significant (out,side normal limits of expected accuracy) change in the design margin.
All designs include margins to allow for error and unforeseeable events.
Chan(ies in design margins are a normal and acceptable part of the design a(id bonstruction process as lion) a~s the'inal design margins satisfy regulatory requirements and applicable codes and standards.
o Change of hardware (Hl) - This is a ohysical change o an existing plant; structure or component that results from a change in the dhsign
- basis, or that is required to cori ecti an initially inadequate~
de~sign or design error If the change resulting from the corrective action is judqed to be significant, either an "A" for actual or "P" for potential is entei ed'into 'the appropriate column of Table 3.
Actual is distinguished from potential because corrective actions are not complete
- and, consequently, the scope oi r~quired changes may not be known.
.Corrective actions are judged to be significant if the resultant changes, affect the overallI quality, performance, or margin of a safety-related structure,
- system, or component.
0 4l 28580-R11 (11/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER: 4 Page A-1'f 5
,ATTACHMENT A EMPLOYEE CONCERNS FOR SUBCATEGORY 23300 Attachment A -- lists,.by element, each employee concern evaluated in the subcategory.
The concern number is given. along with notation of any other element or cateqory with which the concern is shared, the plant sites to which it could be applicable are noted, the concern is quoted as received by TVA and characterized as safety related, not safety related, or safety significant.
0107A-R56 (11/16/87)
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2dd. 1 Kl-Ub-Uqu-UU2 Kl-US-Ugu-UUl wUti WVli "LKcw CVIDVIit mvrtar lining was installed utilizing an inadequate procedure a inspection plan.wh(ch resulted in bad workxIanship,a a
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Subsequent flaking of repaired areas has resulted in repeated failures uf pumps <<ssoclated wlih the piping systeIx."
(sK)
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CONCEKN EL(HE~ 5 IIUUIIFN PLANI LUClllIUM Al IACtltk.hf A tIIPLUYtt cubit>>hs FUR sUULAltuvk'f 433UU APPLILIIutLIIY 1lld lIUN bl'h biN CvtlctKrl UEsLKIPI IUK>>
Kev is Ion Number 4
PAGE A-3 OF 5 2S3.1 IN-Ub-44(-Xle (Co>>L'd)
IN-Ub-.4gv-UUZ IN-U5-Wg-yUI IN-Ub-bug-UUl IN-85 bead-UU3 (shared <<itrr 24bUU)
HUN Hdtl HUN HUN HUN "l.KCH pipe iS nvw losing its cearent murtar lining because design e>>gi>>curing In Knoxville valued scnedvle over quality in ltreir lssvo>>ce ond mvnitoring uf lne pipe lining contract.
Itrey allowed the CuntraCtvr to enter tne pipe - wniCh nad been Sealed to enSure pruper cuf'irlg - before curing time was up.
they allowed tne contractor to uo w>>alever rework he wonted to and prevented ivA r)C frora monitoring to see Lnot bad mvrtor was cnippeu all the way down to bare aretal.
As a result raven of ttre rework was nothing but cosmetic cover-up.
tlc cv>>4rloined to engineering b wrote NClts, but engineering gave 'dish rog'ispusiliv>>s ('don'L wvrry about it - that's the contractor's problem'].
Co>>tractor did nut inspect his own work per contract pruvisiuns.
Sile UC requested to participate in audit of contractor:
Uesig>> tng wvuldn't allow LIIIS, a>>u Said that lhe whole problem was the site Llc department but; cvnLractor's work was so bad that some SeitiunS ot pipe were rewurked IVVX.
HuCtr ut tne mvrtar lini>>g was t lusneu inLu tne nuluing ponu uuring sys(tern) flush.
tIC tras since ubServeu trIOL all repoir polcnes rroVe been tlushed out of at least orr<<
SeCtlv>>.
4C daily lvg (Nay-Aug.
19UZ] nos Information on related octivil.ies, IIIeetlrrgs o>>d concerns."
(sK)
"LeIIIV>>t murlor 11>>er ut tKl;H piping.
IIISIruper Curing a placing teaSIeroture.
tn.K's processed wiln disposition to use as is rs specs cno>>geu."
(SK)
"LKLH II>>es, wit>> cuncrete/(yruut) ll>>er,'ere nul. installed in accvruuICe <<itn prvr.euvreS uSed to teSt/quality lining prucess.
As o
- result,
'Ii>>er Is toiling, ond pieces ore clugging strainers ond adVerSely OtteCting reliable VperaLIVn Ot tKCH prmrpS."
(SK)
"Cv>>crete/gvnnite liner ot carbon steel EKilt line was installed to preV<<nt adVerSe imp>>Ct upun SyStera OperatiOn due LO SCaling Of CarbOn steel line.
Ci is concerned lnal tne lining wi11 weor through and foil ol fItl.ingS and otner areas of cnanging t luw direction or pressure."
(SK)
"Eraerge>>cy Kaw Lvvli>>g Hater'tKUH) Intake li>>es were improperly irlstolled by trre svbco>>tractor.
Several Nonconforma>>ce reports were
~ritten, oil ut >>nicn coare boCk diSpvSiLioned as
'No signiticant prvblear.'l disagrees witrr these dispositiuns."
(sK) sK/Nv/ss i>>dicotes solely r violed, rrvt solely reloleu. vr solely sig>>il iro>>t lier delerrainoliun crilerio irr Ltre ECIG Prugrola alo>>vol o>>d opplivd by TVA rretoce evoluolivrrs.
2//VU-> (11/lb/tt/)
CU!lCEKN kLENENT NUNUEK Al I ALlll'LL,NT A tl+LUYLL I.'VL!(.Lit!LBFOK 5UUCAIEGUKY 88]UU VLAIII t(VVLItnUILI I Y isiS( iuii ii(i Sii il ii Sl ~
.CUNCEKN UEUCKIPTIUN*
Kevision Number:
4 PAGE A-4 OF 5 QS.
1 IN-85-b]U-VU4 (Cont'JJ (st!ared witn dabuU)
IN-85-NU-VU>
Iu ui I I
~ /viz
~ \\ ~
VV S i<< VVV NUN MUN
~ I ~
M>>II "Lutttraitur (xnv>>nJ lor tne linlpg installation on tl!e Elxergettcy kaw Cuuling ilater (tKCM) intake line was required by contract, to xtaintain apprupriate ducu(xentatlun relative tu work performed.
A Nultcu!ttvraance Kepurt was written, and dispositioned
'use as is'fter trie cuntractur t~ice tailed to produce Lite reuulrld documeritatiuii "
(5KJ "Inspectiun Criteria lur t!((Urge!(Cy Maw Cooling Mater lines was nut v
~ s aUI>>tuilLCI
!ak J
'>>V ipi run Lt'Um ltttuxe p(X((p t(uuSe Lu bulldiiig IS I I!ted Wilt> CunCrete.
- CunCrete Could break uft and tne Pieces Cuulu b<<Come StuCk in PuinuSI valves, et<."
(>K)
IN-85-84b-UUC IN-UU-U/]-f!UI (Shared witn (4bbU]
MUN MUN "tmergenCy Ila>> Cuuli>>g Mater (tKCM] db" dia((later lineS naVe a
'grOut'!ns r
Tlsis ns I siist! >I si !c ~ c I ns
~ I
~ c I t-..
~
~ it.. I..~..... ~
s.....
~
~ ~
I
~
~ <<cvc
~ Vi
<< I ~ v
~
~ Iie ~
<<0 lsli<<e ~
~ os Uces ailu I UU!Isi 0 ol grouL to cause damage/failure tu Intake puopsl tl!is could be a
sssl ety, Iialurd io nuclear uperat Iuns.v (Ukj "ltib LLKM line was accepted by Knuxvllle Engln<<ering even though Hatts Uar L]A tound and duce((tented tn<< folio>>lnu nonconfurmances:
( lg81/Ig82)
IN-Ub-145-UU(
Iu uu 1s u svsv
~ ~I VV
~ VV VV<<
(snared >>iui 151UU)
M(IN L Iii
~II/II Lijsi tint eius t svln tnlrl/ss cc I 1! ~ s. rl Z. Lliier did nut bund to pipe.
d ~ 4ruuL>>as AUL slainte lneu at lUok liumldlty (ends ol pipe wLft.'mproperly.covered during curing).
4s 1.incr naS Cr~CkS.
b.
5L'rect(S guittg.,into KU Is( are currently being clugg<<d witli Cl!ipped gruut."
(N)
"Concrete lining is coming apart In EKLM liries.
Mttat is being dune]"
Is 5k]-
"lhe intake lI!(es Lrum itic pumping Station were gruuteu uuck in 1881/lgd~.
Soaie ul tiiis grout is falling louse,
>>liiC!i coulJ da(xage or st!ip tne pueps.
. GI stated that '!iunks ol concrete 6" ur. 8" in dia(I(uter are in tne intake line Irtx!I tne puap stdtiun Cuucretl'ebris tiaS been eiiteririg aux. bulldirig at ]3]'nd datiiaging ttie rfly valVes.."
I 5K) bk/NU/bs los!isa!
.I Iv!"!.t I, !.
I c.l.!y! ! iiei!~
r
-!ULy sist ilicatit snsr u Le!min'tiultcriter!u-!n tine ECIUVrugrmu a(at: <<1
".:8 ";I!!Id by TVA beture I.valuatiu(IS.
CUNCCHtl ELEIIENT IIUlldtK rtnttt LILRIlue AlIACtMtttf A tttptuYtt CU>>tc.K>>5 Fud sultCAttGUKY Z33UU APPL It>>dlt I II CUKCLKN Ut,SCHlt'1 (UH>>
Revision tlweer:
4 PAGE A-5 OF 5
Z33.1 (N-Ub-ZSZ-uu\\
(Cont'd)
KUN l>>e repa(l U>> L>>e LKCM t Ine violat<<d prucedureS a>>d was accepted e>>t irely by NCKs.
Uue tu Lhe shoddy wurkniansh tp Involv<<d, CI teels t>>e t.KGK t l>>e s>>uuld be evalu>>ted tur safe tu>>ctiun.
1UUz."
(SK)
UNP-4CP-)u.d>-U-C>
ULN Uhr-t)LP-lu.35-U-z4 "Cl wurried about integrity ot tKCK ceaxnt oertar lining aL bends w>>ere eertar
>>as applied by hand" (SS)
"Ct Lu>>Cerned about a section ut tHCK pipe t>>aL way nuL be cuvered wit>> specit led protective cuating."
(SS) ttl-Ub-ug/-NUZ Kutl "NKC iue>>titled L>>e tulluwi>>g co>>cern free review ot the t)lC file, MIUrtdl w>>S Wet atld suvlC waS flaking ol t the newly \\ ined EHCM pipe."
(N) sH/Nu/55 i>>dlcates satety related, nut satety related, ur sat<<ty sig>>il ica>>t per detenu(nation criteria in the ECiG Program ea>>ual a>>d applied by 1VA oefore evaluations.
Z//OU-5 (11/1b/U/)
i Cl
~
I Cl k
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION 'NUMBER: 4 Page B-1 of 5
ATTACHMENT B
SUMMARY
OF ISSUES,
- FINOINGS, AND CORRECTIVE ACTIONS FOR SUBCATEGORY 23300 Attachment 8 -- contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findinqs and corrective actions.
The reader may trace a concern from Attachment A to an issue in Attachment B by using the element number and aoolicable ol ant.
The reader, may relate a corrective action description in Attachment B to causes and significance in Table 3 by using the CATO number which appears in.Attachment B in parentheses at the end of the corrective action descriotion.
01 07A-R56
(.11/16/87)
Issues AITACIIIENT 8 SON!ARY OF
- ISSuES, FINUINGS, ANO CORRECTIVE ACTIONS FOR SOUCAIEGOkY 23300 F lnd!ngs REVISION NUNER:
4-Page 8-2 of 5 Corrective Actions
- nnnnnnanntinnt*nn*
Element 233.1
>> Ijuailty of Concrete Pipe Lining nnnann>nnnnanatnnn SIIN (Not to be evaluati ill SQN a.
Ori inai i'i in insiaiiation Concern IN-Ub-Igb-004 suggests that the reaSOn the Original Stet I nille t'ellllifed a cement liner was becauSu the LNCM pipe tt ia>>r>>>>a>>
t il
~
~ 1-. 4 -i Wva r>>Vie vyve iy iuttai tz4 an4 teaie4
~
The pipe was repaired with spray-on grout (cement-mortar iincrj.
b.
Linin Inte rit and Effects on fkCM 5 stem oera ion Twalve conraras add>>est th to>>!>>it quality aspects-of the cement-mortar Tining and note perceived and potentiai effects on ERCM system operation and components.
These concerns state that the EkCM line is cement-mortar lined:
that the lining is failing; that repairs maria tO tha lininn arii COSmeatii resulting In pieces of mortar lodging in pumps,
- valves, and sti'ainers causing loss of flow'nd/or damage
!.o components; and that much of the.lining was flushed into the holding puno.
In
- addition, one concern states that the 1inlng Wi I! Waai'hi Oiunti anil fai I at fittings and other areas of changing f )ow dlrectlmi ur pressure,
- a. Uri Inal Vi in Installctiun he RLW.p p nq waS ined with cetvint mortar tO reduct friction loss from the corrosive el fects of Tennessee ktvar v ttvr tint ha>> JI ta tl r rl >>
r ~
t t t>>
t i
a
~
~
~
~
~
~
u>>v
~
\\
\\ vl uvil atev
~ y iy In'jj icQnitt ur was Imprope'riy !nstallud.
b.
L inin Inte rit and Effects un LNCM 5 stein 0 eration here 1S nO SubStant.Ve ev.
e!!Ce that the ct" nt m r!ar lining is falling.
Althougli a large quantity of mortar tinatei ial was flusiied from itic sysieia afier thte I ining was installed, this was believed tu oe residue from the iining process, mainiy materiai removed from areas that required repair.
Even if there were substantial lining failure, there would be no loss of safety-related functions because of SvStrtit redundanCv and iieraiiae failed lining particles could be expected to settle vvtv~ v atvs vuy vf tvv Stvll4uy Ivvye haf>>ra ct zr ~ ia I'ha rt ii~
1 MUN a.
None required.
b.
None required.
hatt'tti tii Iiivi a tvvv iv lvil
Issues AII>a.k Itiil 8 SUF&AHY Ui'bSUtb, F INUIHub, RHU COkktCIIVE Ai.'TIOHS IUk bUUChIEtiukY 23300 F iwui>>gs HEV I SION BONER:
Page 8-3 of b Corrective Actions K Iement 239. I - HBH (Continued) c.
Llnin Installation Procedures Concerns IN-Bb-b28-Uul and HI-Bb-040-002 discuss the pruceuural aspects of the lining iwstallatiun.
These concerns state that twe procedures used to install and repair the lining were inadequate and were nut the same as used to test/qualify tlute lining.
This resulted in poor ~orkmanship aiwi NCks.
- c. t inin Iusta I lat low I'ruceeiurus he procedures used to iwstaTT a<<J repair the lining wel e adequate awd iw accurda>>ee with Standard industry practice.
Ihe pruceuurus used at wBH were similar tu those used for lining thu samples in the IVA testing anu qualification prugrmw.
c.
None required.
d.
Contractor lns ection awd Uocume<<tatiuw Concerns MI-BS-U40-0UL, IN-Bb-442-x)2, IN-Bb-b3U-UU4, and IN-Bb-b30-UUb re late to the adequacy and conduct of the lining contractor's quality assurance prugram.
The COnCernS State that the lining contractor's inspection criteria and plan were inadequate, the co<<tractor did not inspect worK per the contract provisions, and that tnu documentation of the inspection was inadequate.
- d. Contractor lns ectiow awd Uucuiuentatiun d
he in wg contractor s qua ity assurance awd iwspectiuw plans were adequate.
- however, the contractor failed to document results of many uf thu required Inspections.
Therefore, it cannot be aSCertained that the required inspectioris were performed.
Cur
.IR A d.P an:
Curr ciive acscgjl~es described ie idee-ais, 03/I (Bl (kef.-g g h s been taken by 1VA to precl de the rR I'en of problems similar to th gesolIIbed~pv Initially, this action cdhSIKteIFWlb issuance of a qualit atigfc9 (Hhf, 02 pfpYQe s;.4)ciao of control ling OA
~
~
~ co tlgc(()T'gghti s
at TVA nuclear p
w plants and r providing a au.ans of i t fylng Qi5 Qc)ear Quality Audit awd Evalua i
nc1pgll)All]8) of onsite contractor c
itic&a ~.
subsequentl n (I3 of(@~<.tIIe tiuallty Hotlce was I po te&geiba)im into the TVA Nuclear II a ssilrante 'ual (NI)AM),
in Part 3, Se i n12.1 tippy.'
the specific addit o
tip FAN re as fo1 lows i t~daÃa u
H.ans lor iw hiS',QQ.y al ity fhnager (Silff) nowcunfj'..ai4ua agreemewts mad ring pre-ur ustawai d
- meetings, such s schedule covwi tments, as cni aid to sc ei >ling of audit 24830-g
( 11/Ib/Bl)
Issues Allitli<<L<<t 8 SUtetANY'bp lssUts, I'INUlttbS, Atiu L.VIINLLIIVLACIIUNS fvti SUUCAILVUKY caJUV I iisdiirgs lt8VISIUtt ttgrkitN:
4 Page 8-4 vt 5 Cvrrective Actions Eleaent 233.1 -
IDUN (Continued) n Ilrcnnc It ines na ls ~ ssr
~
J vu u
ue ~ us ns nu Loncerns IN-uo-sa(-xl(, tN-ub-igv-vugg, IN-85-OJV-UUJ, IN-85-OJV-UV4s IN-85-811-001, arid IN-Uv-%J%-vvl cia iia that Ueslun tnglrieerinv iiuprvpLrly dispositioned NCNs 'related tu Liie contr artorss tsistallativn Lst I
liiii g.
itic ConCernS State tnat tiie NCNs were dispos(tluiied iiSi: as-Is" >>iliivui prvper Just(f(cation.
Ihe ttCNS wire issued due to fat lure tiy tiie contractor to follow curing proceuures.
viulatiun of specification requireaILIILS, arid tailure tn slnrseeusenr s a<<sstrasi tssLssuri I ~.eeL 1
~ Uis"vsiliiiiivi tii.its iie o spvs lion by design Lngl>>vering vi nviIL'vnturaiing cvndtttvn repurls (NUNs] Luvering Liie t<<Liinlral rLquirLaILnLS tur ttie CeaiL>>t eurtar lininu uvre appropriate anu adequately uvcuaILIIL<<u.
Itv>>aver, vne tiCN sais Is s r tnsi Its 0 stall fus ~ Ivs
~ r sn s ar.,~ vt responsibility, was nut ulspusillvveu iii a tlreely aia ines
~
esv qva e Ity ueusue ailCie auu s t us Lne NUN 1 liiliiij cunti aclvr'S records ut requir<<d i>>spect lviIS waS pertvraIL'u until several aariitlls atter tii<<wvrx>>as crxiipletLJ.
activi
~
4/
ILp gt t
aw I h they Ie lI fh g'+ye contruped by t I o -itbtvirgggt for jhe fort(r~~
~IL(dr,. apprvpf Hte J5ICLIIIL~dguua.nt s d Lwi s v tslunrst ltt'lsLLHftrxt ssee's~~
<II<<
before beginning work.
I <<drls v's r rsl scuse rsl I luce
~ v
~ Mu v ~
ssus
~ v ~ r e.
Saare as d.
dbove I ~
UCS I II cll IOLLI In
~ ALLI tvsILS ailv nter erence.w th S te Concern IN-85L442-X12 expresses crltlcisiu of the actions and 'attituues nt 0 sinn kng(n>>
s rtnn tn Knvxvtlte The conceril states thaL Uesign LAginces lng valued schLuiile ovLl quality, prevented IVA IIC frvai monitor(rig the cvntracturss repair work, anu lould not allvw sile IIL to part ic ipate In an audiL vt. the roiitrdCLOI I ~ Uesi n t'n lneerin Attlluue arid inlertereni'e with Site C
t.
Itvne requlrerf.
ttu obJeCl ve ev idence was fvuiid trial Ues gn trig n<<er ng
>>as unduly llitluented by sc<<ovule cvnsidarativns in eittier awarding ttie lininu cuntract or in dlspvsitioniriu tICKs relative tu tne>>urk (see I lnuing "e" above).
It WaL tsssesssl thai Iieet
~ ssl teses I ~ ss sss lese ~
s
~srnssra s ~ sl I'elis ~ r I ~sai ~
discouraged, Sile lluallty Cvntrul's efturts to Iixrnitur LiiL CoiiLraCtur S
Wur k 24UUU-g
( II/
issues ni lilllh'R.NI d bUNsu<Y Ul'bbULb, FIHUiilbb, ANU LUKKEUIIVE ACIIUNb I UK SUuCAIEUUkY C33UU t Ilid>>igs kEVISIUN HUKSEk:
4 Page 8-5 of 5 Corrective Actions Element 833. 1 - NUN (Conti>>ued) g.
NSKS Dis usition ot Eu lu ee Cu>>turns Concern NI-85-UgU-UUI is critical of the NSKS's dispositiun ot Cuncern IN-Ub-4lb-UOZ as reported in the "Nuclear Safety Update" dated lU/11/Ub.
lhe concern states t>>at tne problem was not identified, a>>d tnat Investigaturs must nut have interviewed personnel k>>uwledgeaule of theproblem.'.
NSKb Uis ositiu>> ut tu lu <<e Luis.<<r>>s pub Is>>ed Sumuary 0 a>> Hbkb d>spds it lun Ot une Ot t>>e eiuployee cu>>cer>>s was excessively brief a>>d could lead the reader Lo believe thut t>>e Hb>>b investigation was ho't sufticie>>Lly thuroug>>.
- However, IL was always intended Lnat the full i>>vestigatiu>> reports wuuld be made availaule tu Interested partieS.
1>>e full Nbkb rupurt fur Lnis particular cuncer>>
was detailed e>>ough to snuw t>>e empluyee Lhut tn<< inveSLigatiu>>
was suflicie>>tly tnuruugh.
g.
None required.
(Not Lo oe evaluated)
BLN a.
A portion of tne LKCK pipi>>g may not have been lined as requirL'd.
UFN Ih View uf Lne multiple levels ut i>>sp<<ctiuh pruvided, Lhe 'LhuruughheSS in plan>>ing L>>e accessibility for \\ ining uperatiuns, and the SatisfaCtury perforiua>>Ce Ot the cu>>tractor, it is nighly u>>litely that any ut Lhe required lining was nut ceupleLed.
UFN ULN Nunc required.
b.
Use of hand lining ot pipi>>g at bends may have resulted in inadequate lining integrity.
c.
Fewer TVA inspectors were used ut dLH, coupared to MBN, to monitor the lining contractor's woru, resulti>>q in the possibility of inadequaLe lining quality.
d.
(Iuality assurance doceuentatiun may ue inadequ~te because required inspectio>>s were documented by co>>tractur persoi>>iel, ratner tnan lVA person>><>ly Lne finis>>i>>g, nut Lhv application, was pertoruied ma>>ually, in cu>>trast tu the Staieuu.'nt cuntai>>ed i>> tnu co>>cern.
- However, na>>d lining is a>>
acceptable ulethud fur pruduCI>>g quolity lining and iS used for repairs, a>>d fur uther lining where macni>>e applicatiun is iiupractical.
c.
)VA i>>spectiu>> at ULH was tuu>>d Lu ue adequate.
I>>e difference uetwuen t>>e >>uueer ut'VA i>>spectors employed at KUN and ULN did>>ot cdusL dift icUlty at ULN, out resulted from better cu>>tractur performa>>Ce at that plant..
- d. quality Assurance ducuuu:ntatiu>>
provided by the co>>tractor at ULN was found Lu be adequate.
Uucwuu>>tatiun respo>>siu(I(ty was assigned Lo thu contractor by lvA.
AuditS Performed during tne ULN li>>ing activities fou>>d
>>O duCuuu.'>>Latiun detiCie>>CieS.
b.
None required.
c.
None required.
d.
None required.
24830-9
('ll/lo/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page C-1 of 4 ATTACHMENT C REFERENCES Watts Bar 2.
3.
4 ~
5.
6.
7.
8.
9.
WBNP NCR WBNNEB 8017, Raw Water Piping Corrosion, 10/30/80 EHEB 801230 476],
EMEB 840403 014],
[B44 860113 008]
TVA Purchase Requisition
- 830267, Cement Mortar Lining of Piping For Essential Raw Cooling Water (ERCW) 'System, 10/28/81; includes TVA Specification
- 5225, same title TVA Quality Control Procedure WBNP-QLP 2.20, Cement Mortar - Lined Pipe Inspection, Rev.
1, (06/04/82)
WBNP NCR'117R, Noncompliance with Specification N3M-921 Rev.
0 and WBNP QCP 2.20, Rev.
0,
[WBN 820513 101], (05/13/82)
TVA memo Standifer to Wadewitz, Division of Engineering Design's Disposition of NCR 4117R,
[CEB 820604 017], (06/04/82)
WBNP NCR 4133R, Rev.
1, Noncompliance with Specifications H3M-921, Rev.
0, and WBNP QCP 2.20, Rev. 0,
)WBH 820621 123], (06/18/82)
TVA memo Standifer to Wadewitz, Division of Engineering Design's Disposition of HCR 4133R, Rev.
1, (CEB 820621 123], (06/18/82)
WBHP NCR 4163R, Noncompliance with Specification H3M-921 Rev.
1 and WBNP QCP 2.20, Rev.
1,
[WBN 820622 100], (06/22/82)
WBNP HCR 4270R, Noncompliance with Specification H3M-921,
[WBH 820810 103], (08/09/82) 10.
TVA memo Standifer to Wadewitz, Division of Engineering Design's Disposition of NCR 4270R,
[MEB 821008 003], (10/07/82) ll.
TVA memo Raulston to Mills, forwarding
( Interim) Report Ho.
3 on HCRs 4117R,
- 4133R, 4163R and 4270R,
[NEB 821020 270],
( 10/20/82) 12.
WBNP HCR 4270R Rev.
1, Noncompliance with Specification H3M-921,
[WBN 821013 100],
( 10/12/82) 13.
TVA memo Standifer to Wadewitz, NCR 4270R Rev.
1,
~MEB 821119 042],
( 11/19/82) 14.
WBNP NCR 4357R, Noncompliance with Specification H3M-921 Rev.
1 and WBNP QCP 2.20 Rev.
1,
[WBN 821012 101], (10/08/82) 37240-R4 (11/16/87)
TVA EMPLOYEE CONCEFNS SPECIAL PROGRAM REPORT NUMBER:,
23l306 REVISION NUMBER':
'4
'age C-2 of 4
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
27.
28.
TVA memo Standifer to Wadewitz, Divisibn 'of 'Engineering Desi'gn's
'isposition of NCR 4357R,
[CEB 821206 015], (12/06/82)
WBNIP NCR 4419R, ERCW Piping Mortar Lining Quality,
[WBN 821109 180],~
(.11/05/82)
TVA memo Standifer to Wadewitz, DivisiOn of Engineering Desi'gn's
'isposition of NCR 4419R,,
[MEB~ 821217 012], '(l2/17/82)
WBNP NCR 4270R, Rev2, Noncompliance with Specification N3M-921,
[WBN 830118 104], (01/18/83)
TVA memo Standifer to Wadewitz, Divisibn 'of 'Engineering.Design's Disposition of NCR 4270R Rev.
~1 a'nd ~Rev.
2,
[MEB 830308 031],
(03/07/83)
TVA letter to
- NRC, Kammer to Adensam, Integrity of,. Cement Mortar Lining, [A27 840615 007], (06/l5/84)
TVA Quality Assurance Audit Ref)orat, Audit'3V-49, May 3-6,
- 1983, Ameron, Incorporated, Pipe Lin>ng~ Division,
[OQA 830729 508],
(07/29/83)
NSRS Invest igation Fieport 1-85-158-WBN,, covering Fmployee Concern IN-85-415-002,
[no RIMS number'], '(07/05/8'5)
'SRS Invest i g at i on Report I 166-WBN,, covering 9
Emo 1 oyee
- Concerns,
[no.NIMS number],
(12/li2/85)
<11~, Yard, Mechanical, Essential Raw Cooling Water, Revisions 17, 5,,
14, 7,
9, 24,
- 116, 8,
7, ll,.and 1
respectively TVA meirho Brown to Cottle, responding to NSRS report I-85-166-WBN,
[no RIMS number],
(02/21/86)
WBNP Specia'I Maintenance Instruction SMI-67.2, Insoection of Mortar-Lined ERCW Discharge Lines (NON CSSC),
(04/18/86)
TVA Construction SpeciFication N3I4l-921<, Cement Mor tar Lining ofl the
'ssential Raw Cooling Water SySteiin, 'Rey.
1,
[ESB 831028 204],
( 11/28/82)
Nuc'lear Power Experience, BWR Volume 2,Section VII.C, -oage 20,'tem 83 (04/76)
Cl 37240-R4 (11/16/87-)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
23300 REVISION NUMBER:
4 Page C-3 of 4 29.
TVA Report CES-B, "Full Scale Testing and gualification of Cement Mortar Lined Carbon Steel Pipe," Rev.
0,
[CEB 820405 001], (04/05/82) 30.
American Water Works Association Standard C602-76, "Cement Mortar Lininq of Hater Pi pelines - In Place,"
1976 Edition 31.
US NRC Safety Evaluation Report, Watts Bar Nuclear Plant, Supplement 4,
page 19-2,)no RIMS number]
32.
Nuclear Power Experience, PWR Volume 2,Section VI.F, page 7,
item 17, (07/80) 33.
ACI 214-77, "Standard Recommended Practice for Evaluation of Strength Test Results of Concrete,"
1977 Edition 34.
TVA NSRS publication "Nuclear Safety Update,"
(10/11/85) 35.
TVA memo Bounds to Ennis, WBNP-Inspection of Mortar-Lined Essential Raw Cooling Hater (ERCW) Oischarge
- Lines,
[T13 860717 961],
(08/08/86) 36.
WBN Preoperational Test Oata Package, Test Number TVA-18C, ERCW Flow Balance (08/05/83) 37.
- Ameron, Inc. Pioe Lining Oivision, attachment to prooosal for pro,ject 53-830267, Relevant Experience
( 12/30/81)
~reliminary Subcateqory
~eoort
- 233, "Essential Raw Cooli ni:.later Pioinn," Zev. 2, (07/29/86)
TVA letter Costner to Ameron, Inc., Closeout of Vendor Audit 83V--'9,
~OOA 40504 507], (05/04/84) 40.
TVA memo Chandley to Standifer, TVA Corporate
Response
to NSRS Perceptions of Watts Bar Status,
[844 860228 018], (02/28/86) 41.
TVA letter TCAB-339, '!cNut t to Parkinson
( Becntel), Corrective Action Plan for CATO 233 01 WBN Ol (03/18/87)
<2.
TVA Ouality Notice, NOAH, Part III, Section
- 2. 1, Rev.
0 (12/"0/86) 43.
TVA Emplovee Concerns Task Group Procedure ECTG:1. 1, Program Descriotion, Rev.
4 (05/ll/87)
References 44 thrnuoh 49 not used 37240-R4 (11/16/87)
rVA EtlPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
'23300 REVISION NUMBER:,
'4 Page C-4 of 4 Bellefonte 50.
51.
52.
33.
TVA BLN Construction Specificatiori N4M-924, Rev.
1, Cement MOrtar Lining of the Essential Raw Cooling Watcher System
[ESB 830Zll 204],
(03/09/83)
TVA BLN Procurement Specification
- 5337, Rev. 0, Cement Mortar Lining of Piping for Essential Raw Cooling Water (ERCW) System (attcichmen't to reauis"',tion number 50-831050),'(04/20/82)
TVA memo, D. Nixon and D. Norris to QCR'U Contract Files, Bellefbnte Nuclear P'lant - Cement Mortar Lining'of'RCW Piping - Contractt 82K50-831050-Raymond Internatio~nal B<>ilders, Inc. - Final Report,
[BLN 830223 502],
(02/2',3/83)
TVA BLN Quality Assurance Audit Report BN-S-82-01, Raymond International Builders, Inc.
[BQA '82100'8 002], "(10/08/82) 54.
[BLN 820827 '109],'09/02/82) 55.
0,
[BLN 821110. 110], (ll/16/82)
References 56 through 59 not used General 60.
TVA Corporate Nuclear Performance
- Plan, Rev.
4, (03/87) 61.
ECSP Subcategory Report
- 20400, Fngineering Organization and Operating Procedures, Rev.
2., (10/17/87)
Cl 62.
63.
ECSP Subcategory Report
- 70600, Management Techniques, Rev.
4,~
(02/27/87)
ECSP Subcategory Report
- 80100, Qua,lity Assurance Management aindi Policy, Rev.
0, (06/15/87) 3724D-R4 (11/16/87) li