ML18033A560
| ML18033A560 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 12/03/1987 |
| From: | Peters A TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 21200, 21200-V02-R03, 21200-V2-R3, NUDOCS 8902150071 | |
| Download: ML18033A560 (78) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG VOLTE 2 ENGINEERING CATEGORY SUBCATEGORY REPORT 21200 PIPE SUPPORT PROGMQvf UPDATED TVA NUCLEAR POWER i ~'l 8902i5007l
>$ 0>0(
PDR ADOCK 0 0002 P
I
'I J $ 1 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:
SUBCATEGORY REPORT FOR ENGINEERING TITLE:
PIPE SUPPORT PROGRAM REPORT NUMBER:
21200 REVISION NUMBER:
3 Page 1 of 26 AS N
OR R
N:
2.
3.
Revised to incorporate SRP and TAS comments, and CAPS.
Revised to incorporate additional SRP and TAS comments; added Attachment C (References).
Revised to incorporate SRP and TAS comments.
R AR N
/J X3 87 REVIEW COMMITTEE:
I R
W
/(- zs-Z7 AS:
S NA UR N
RRN o
&7 OA E
i CEG-H:
APPR VED S
AGR SRP Secretary's signature denotes SRP concurrences are in files.
~O I
'll 1
0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER:
3 ES-1 of 2 EXECUTIVE
SUMMARY
This subcategory report summarizes and assesses the results of eight element evaluations prepared for the Engineering Subcategory
- 21200, Pipe Support Program.
The element evaluations examine 26 issues related to TVA's four nuclear
- plants, Sequoyah, Watts Bar, Browns Ferry, and Bellefonte.
The issues were derived from a total of six employee concerns which cited perceived deficiencies in the Pipe Support Program, and were mainly related to design documentation and as-built verification problems.
Of the 26 issues evaluated, 20 were found to require no corrective action.
Corrective action plans have been established by TVA for the remaining six
- issues, and the evaluation team has concurred with each.
Of the six issues requi~ing corrective action, four are to resolve peripheral findings identified during the evaluations.
The remaining two corrective actions were initiated by TVA before Employee Concern Task Group (ECTG) evaluation.
The causes for the negative findings are diverse, with no single category of cause dominating.
The corrective actions for this subcategory that were judged to be significant are tb correct potential and actual interferences between piping and adjacent plant features designed by different groups at Watts Bar; ensure that all required stress analyses have been performed at Watts Bar; correct deficiencies of Bellefonte IE Bulletin 79-14 program procedural documents and void procedures CFB EP 21.30 and BLEP-08; correct the insufficient clearance of a Browns Ferry drywell purge system piping support to accommodate piping thermal movement; and provide a dedicated work force to complete the Browns Ferry 79-14 effort.
The corrective action requiring recreation of the numerous missing or destroyed pipe support calculations is judged to be significant even though no safety-related problem has been identified because it reflects a breakdown in TVA's engineering and (jA.programs.
Although the missing calculations problem has been addressed in detail in element evaluation 212.
1 for Watts Bar only, it is known that Sequoyah has experienced similar document retention problems and is currently regenerating and issuing pipe support calculations.
Browns Ferry and Bellefonte have not been evaluated specifically for this issue.
- However, the TVA essential calculation program discussed in subcateqory 24600 will identify and resolve problems regarding missing calculations for Bellefonte or Browns Ferry.
27300-Rll
( 10/19/87)
'TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'1'200 REVISION NUMBER:
3 ES-2 of 2 With the exception of potential interference Of piping with other plant features on Watts Bar and Bellefonte's 79-14 program,'VA's Pipe Support Program procedur'es were found to be. gener ally'dequat~e.
In addition, pro6leks associated with missing or destroyed Watts Bar c alculat'ions and the
(>missi'on'f one stress analysis on Watts Bar arose partly from a lack of monitoring the
'horoughness of implementatior> of the procedures.
~ The evaluation team believes that the failure to fully implement procedures would have been identified and corrected by an effective design review process and through a
more aggressive QA audit program.
The TYA Corporate Nuclear Performance Plan describes corrective actions for improving the design control process.
It includes organizational changes to clarify technical responsibilities for monitoring and controlling technical performance.
The changes, when properly implemented, should improve the YYA'ipe support program.
The disci,pline branch chiefs are to schedule and perform technical reviews on major systems throughout the design effort.
In
- addition, an organization known as Engineering Assurance has been establidhed,
~
and is responsib)e for technical audi<ts and providing feedback to engineering management on technical performance.
The causes identified and other evaluation results are being reexamined frlom a wider perspective in the Engineering category evaluation.
27300-R 1 0 (10/16/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 FRONT MATTER REV:
3 PAGE i OF viii Preface This subcategory report is one of a ser.ies 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 thaf an employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concerns Special Program was to thoroughly investigate al'1 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 those 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 Nucl'ear 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 simi lar 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.
Subcategory 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 overlap more than one element and will therefore require corrective action for underlying causes not fully apparent at the element lovel.
To make the subcategory reports easier Po understand, three items have been placed at the front of each report:
a preface, a glossary of the termino3ogy unique to FCSP 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 SPECIAL PROGRAM REPORT NUMBER:
21200 FRONT NATTER 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 i'n ~one o~f the"following areas:
management and personnel re!Lations industrial safety construction material control
,operations
'uality assurance/quality ciontro3.
welding engineering A separate report on employee concerns dealing with specific contentions of intimidation, harassmeint, and wrongdoing will be teleased
'by the TVA Office of the Inspector General.
Just as the subcategory reports integrate the infotmation collected at the element level, the category report.
integratei the iinfiormation assembled ih all the subcategory reports w'ithin the category>
addressing particularly the underlying causes of those problems that
~run acrossimore than one subcategory.
A.final report will integrete and assess the information collected by all of the lower level reports prepared.for the,ECSP, including, the Inspector General's report.
For more detail on the method,s by which ECTG,employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Program Nanual,.
The Manual spells out the program'is objectives,
- scope, organizatiion, and responsibilities.
It, also specifies the procedures that, were followed:in the investigation, reporting, and closeout of the issues, rai. ed by employee concerns.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 FRONT MATTER REV:
2 PAGE iii OF viii FCSP 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'lass 8:
Issue is factually accurate, but what is described is not a
problem (i.e., not a condition requiring corrective action) a 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 corrective action has
- been, or is being, taken as a result of an evaluation Class E:
A problem, requi'ring corrective action, which was not.identified by an emp]oyee
- concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
t 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 perspectives 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.
n~m io ee concern a formal, written description of a ciicnmstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM R'EPORT NUMBER:
21200 FRONT MATTER REV:
2 PAGE iv OF viii grouping of employee concerns.
~findin s
includes both statement.,
of fact and the judgment" made about those facts during the, evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during the evaluation
- process, raised, in one or more concerns'.
K-form (see "employee concern")
evaluation judgment or decision meiy be based,.
root cause the underlying reason for a problem.
=Terms essential to the programi but which require detailed definition have boen defined in the ECTG Procedure Manual (e.g.,
gAnerid, Specific',
nuclear safety-related, unreviewed safety-significant~quest.ion).
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM
'REPORT'UMBER:
21200 FRONT MATTER REV:
2 PAGE v OF viii Acronyms
'BLN Administrative Instruction American Institute of Steel Construction As Low As Reasonably Achievable American Nuclear Society American National Standards Institute American Society of Mechanical Fngineers American Society for,Testing and 'Materials Amer ican Welding Society Browns Ferry Nuclear Plant Bellefonte Nuclear Plant CAQ Condition Adverse to Quality CAR CATD'CTS Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System CEG -H Category Evaluation Group llead CFR CI CMTR'OC DCR DNC Code of Federal Regulations Concerned Individual Certified Material Test Report Certificate of Conformance/Compliance Design Change Request Divisi'on, of Nuclear Construction (see also NU CON)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 FRONT MA.TTER,'REV' PAGE vi OF viii DNE DNQA DNT DOE DPO Divi.ion of Nuclear Fngineering Divi.ion of Nuclear Quality Assurance Divi. ion of Nuclear Training Department of Fnergy Division Personnel Officer DR ECN ECP ECP-SR Discrepancy Report or Deviation Report Engineering Change Notice Employee Concerns Program Employee Concerns Program-Site Representative ECSP Employee Concerns Special Program ECTG EEOC EQ EMRT EN DES ERT FCR FSAR GET HCI HVAC INFO IRN Employee Concerns Task Group Equal Employment.Opportunity Commission Environmental Qualification Emergency Medical Response Team Fngineering De. ign Employee -Response Team or Fme'rgency
Response
Team Field Change Request Final Safety Analysis Report Fiscal Year General Empl.oyee Training, Har.ard Control Instruct<on Heating, Ventilating, Air Conditiioning Installation Instruct ion Inst,itute of Nuclear Power Operations Inspection Rejection Noti.ce
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 FRONT MATTER REV' PAGE vii OF viii L/R Labor Relations Staff MMI Modifications and Additions Instruction MI Maintenance Instruction MSPB Merit Systems Protection Board MT Magnetic Particle Testing NCR Nonconforming Condition Report NDE Nondestructive Examination NPP NPS NQAM NRC NSB NSRS NU CON NUMARC OSHA Nuclear Performance Plan 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)
Nuclear Utility Management and Resources Committee Occupational Safety and Health Administration (or Act)
ONP OWCP PHR PT QA QAP QCI Office of Nuclear Power Office of Workers Compensation Program Personal. History Record Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures Quality Control Quality Control Instruction
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
?1200 FRONT MATTER REV:
2 PAGE viii OF vii.i QCP QTC RIF Quality Control Procedure Quality Technology Company Reduction in Force RT SQN SI SOP SRP Radiographic Testing Sequoyah Nuclear Plant Surveillance Instruction Standard Operating Procedur'e Senior Review Panel SWEC TAS TSL TVA TVTLC UT VT WBECSP WBN WR Stone and Webster Fngineering Corporation, Technical As,sistance Staff Trades ancl Labor Tennessee Valley Authority Tennessee Valley Trade:
and l.abor Council Ultrasonic Testing Visual Te: ti'ng Matt,s Bar Employee Concern Special Program Watts Bar Nuclear Plant Work Request or Work, Rules Morkplans
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT 'NUMBER:
21200 REVISION NUMBER: 3 Page 2 of 26 Section Fxecutive Summary Preface ECSP Glossary of Report Terms
,Ac ronyms CONTENTS Paqe ES-1 1
Introduction 2
Summary of Issues/Generic Applicability 3
Evaluation Process Findinqs 5
Corrective Actions 6
Causes 7
Collective Signi,ficance Glossary Supplement for the Enqinrerinq Cateqory
~
3 14 17
~t.tachments A
Employee Concern for Subcateqory 21200 B
Summary of Issues,
- Findings, and Corrective Actions for Subcategory 21200 C
References B-1 C-1 TABLES Table 1
Classification of Findings and Corrective. Actions 2
Findings Summary 3
Matrix of Elements, Corrective Actions, and Causes
~Pa e
20 21 22 27300-R12 (11/19/87)
~Ci 0
1.
IN TROOUCT ION TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER' Page 3 of 26 This subcategory report summarizes and assesses the results of the Employee Concerns Special Program (ECSP) element evaluations prepared under Engineering Subcategory
- 21200, Pipe Support Program.
This subcategory covers those concerns related to the execution of the pipe support design documentation, and installation and as-built verification activities, but does not include those concerns related to technical aspects involving pipe supports.
These technical aspects of pipe supports are covered in subcategory reports
- 22000, 22100, and 25500.
In addition, several programmatic aspects related to this subcategory (particularly corrective actions) are covered in Subcategory Report 24600 and are cross-referenced in this report wherever appropriate.
The employee concerns provide the basis for the element evaluations and are listed by element number in Attachment A.
The plant location where the concern was originally identified and the applicability of the concern to other TVA nuclear plants are also identified.
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 the determination of generic applicability o
Section 3 -- outlines the process followed f'r the element and subcategory evaluations o
Section 4 -- summarizes, by element, the findinqs and identifies the negative findings that inust be resolved o
Section 5'- highlights the corrective actions required for resolution of the negative findings ci.ted in Section 4 and relates them to element and to plant site o
Section 6 -- identifies causes of the negative findings o
Section 7 -- assesses the significance of the negative findings o
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 category wi.th which the concern is shared; the plant sites to which it could be applicable are noted; and the concern is quoted as received by TVA, and is characterized as safety related, not safety re'lated, 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 findings and corrective actions.
The 0
27300-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REP'OR il NUMBER:
2120O REVISION NUMBER 3
Page 4 of 26 reader may trace a concern from Att'achment'A to 'an issu< in Attachment B by using the element number and applirab'le plant.
'Th' reader may relate a corrective action description in Attachment 8 to causes and significance in Table 3 by using the CATO number which appears in Attachment B in parentheses at the'nd of the correctiv'e action description.
The term "Peripheral finding" in the issue column refer<s to a
finding that occurred during the'ourse of,'ev'aluating a concern'u't did not, stem directly from an employee concern.
These-are classified as "E" in Tab'les 1
and 2 oF thi0 report o
Attachment C -- llists the references ci,ted in the text 2.
SUMMARY
OF ISSUES/GENERIC APPI. ICABILIYY The employee concerns listed in Attachment A'for each e'lement and plant have been examined and the potential problem>naware nf mandatory American National Standards Institute (AI'ISI) requirements Fjertai'nihg 'to doCument retention, as evidenced hy the destruction of pipe support calculations prepared by EOS Nuclear.,
Inc.
(EUS),
as well as othe'" diffic'ulties associated with calculation retrievability and their degre'e of completeness.
The specific concern was, evaluated only fur WBN, and it was found that management was awar e of ANSI requirements.
There was nn basis to evaluate the specific concern for any other plant since it pertains to management awareness of mandatory ANSI requirements.
2.2 NRC Dul'letin 79-14, ABR Pro~ram - Element 212.2 The TVA prbgram for implement,ing and documenting its 79-14 as-bui.lt reconciliation (ABR) program is inadequate; the, containment,spray piping system does not agree with as-builts,,
and was jnappropri.ately analyzed by the alternate analysis method rat,her than a rigorous analysis method.
This issue was eva'luated for all four plantsl.
2730D-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 5 of 26 2.3 Desi n Features in Pi e
Han er Pro rain - Element 212.3 The large number of field change requests (FCRs) required to facilitate pipe support construction indicates that inadeqiiacies in the design process exist, particularly with regard to work performed by Impell contract personnel.
This issue was not evaluated for SgN and BFN because construction of these plants was completed long 'before the concern was first documented at WBN.
Because the concern is directly related to FCR/construction phase activities, it is appl.icable only to-,
and was evaluated for, those plants (WBN and BLN) where construction is not yet completed.
2.4 Fre uentl Chan in Han ers - Element 212.4 Design changes to pipe supports (hangers) are excessive and are made for no apparent reason.
Some are changed back to original design.
This issue was evaluated only for the plant at which the concern originated (WBN) because the concern statement describes a detailed, site-specific condition.
In addition, because the concern was found not to be valid, no similar evaluation of other plants was deemed necessary.
2.5 Summar of Subcate or Issues The issue summaries above deal with perceived deficiencies in the pipe support prograin.
More specifically, one element is concerned with document retention
( 212. 1),
one deals with the adequacy of the.as-built reconciliation program (212.2),
and the remaining two pertain to perceived desiqn inadequacies reflected by the chanqe control process (212.3 and 212.4).
Each issue evaluated within the elenient evaluations is stated fully in, which also lists cor respondinq findinqs and corrective actions that are discussed in Sections 4 and b of this report.
3 ~
EVALUATION PROCESS This subcateqory report is based on the inforination contained in the applicable element evaluations prepared to address the specific employee concerns related to the issues broadly defined in Section 2.
The evaluation process is given below.
2730D-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER'1200 REVISION NUMBER; 3
Page 6 of 26 3.1 Element Evaluation Process The following steps were taken to prepare element evaluations.
- 3. 1.1 ao b.
Retention of Calculat'ion Records - Element 212.1 (WBN only)
Reviewed the applicable ANSI N45;2.9-1974 (Ref.
- 17) document retention requirements for lifetime,qual~,ity assurance records.
Reviewed 10 CFR 50 Quality Assura'nce criteria (Ref.
1I6) to deter!nine'he prescribecl division of document, retention responsibility between the applicant (TVA) and contractors (such as EDS).
c ~
d.
e.
Reviewed applicable portions of the WBN FSAR and TVA document retention procedure.s (Refs.,
18, 19,,
and 20) to ensure that, the above ANSI and 10 CFR
'50 requirements are adequately addressed.
Reviewed the personal services contract between TVA and EDS (Ref.
- 21) to deterrrline if t;he 10 CFR 50 division of responsibility requirements regardling document retention were properly addressed.
Held discussion with TVA EN DIES personnel, as required.
Evaluated a demonst:ration of TVA's microfilming. system during a
visit to the Knoxville off ice.
9
~
Reviewed a sample of 30 pipe s!jpport,ca',1culations,(Ref.
- 22) to verify that a Records and information Management System (RIHS) number exis,ts for each.
h.
- 3. 1.2 a.
Reviewed TVA's corrective ection plad for 'CATO 212 01 MBN 01 NRC Bulletin 79-14,,
ABR Proqram - Element 212.2 Reviewed program for NRC I!= Bulletin 79-14 inspections, identification, and resolution of discrepaincies (all plants)
(Refs.
1, 23 through 26, 3'll, 39 throuqh 42, 49 through 56, md 71 through 74).
h.
c ~
d ~
Reviewed a sample of discrenancies identified in the 79-14 program to verify the adequacy pf resolution documentation (WBN, BFN, and SON) (Ref s.
27, 2829, 30, 44, and
- 57).
Defined the boundaries of the containment spray system by comparison by TVA with similar systems for SQN (Ref.
43)
(BFN only).
Investigated containment; spray piping for type of analysis performed; i.e., rigorous or alternate (al'1 plants)
(Refs.
2, 3,
31 through 34, 44, 58,,
59, 60, 75, and 76).
27300-R12 (ll/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 7 of 26 e.
Reviewed available containment spray system design and fabrication isometrics for configuration of pipe routing and weld locations (WBN, SgN, and BFN only).
BLN construction was not complete; therefore, this step was not applicable (Refs.
35, 36, 37, 45, 46, 47, 48, and '61 through 70).
Reviewed TVA's. corrective action plans for CATO 212 02 WBN 01, 212 02 BFN Ol, and 212'2 BLN 01.
3 ~ 1.3 b.
Desiqn Features in Pipe Hanger Program - Element 212.3 Requested that TVA provide data related to the field change requests (FCRs) such as audit reports, meeting notes, sample drawings affected by FCRs, together with project processed FCRs, etc., to enable the evaluation team to assess the employee concern (WBN only).
Reviewed FCR statistics for Impel 1, Gi'lhert/Commonwealth Associates, and TVA-designed drawings, design review report, field change request study reports, meeting notes, and support drawings with FCRs (WBN only) (Refs.
77 through 87).
c ~
d.
e ~
- 3. 1.4 Reviewed various memoranda regardinq the TVA constructibi lity inspection group "OASES" program (Refs.
88 and 89)
(WBN only).
- Selected, a't random, a total of 75 support.:
15 for each design entity - Impel'1, Grinnel1, Gilbert/Commonwealth, TVA Civil Design Group (jobsite),
and TVC Civil Design Group (Knoxville) - involved in the design of BLN pipe supports.
This selection was made from ALN Pipe Hanqer Information System, PGM Z42091.
TVA was requested to provide pipe support drawings that are affected by FCRs, support modification requests (SMRs),
nonconformance reports
( NCRs), etc.,
tnqether with copies of approved
(BLN only)
(Ref. 90).
The evaluation team reviewed
The reasons for the drawinq changes were grouped into categories to facilitate arriving at conclusions regarding the validity of the concern.
The categories were Interference, Material Substitution, Tolerance, Drafting/Documentation,= Welding, Stress
'Frequently Changing Hangers - Element 212.4'WBN only)
Reviewed sprinq support design requirements (Refs.
96 and 97).
b.
Selected a sample of pipe support drawings -to,verify the reasons for their revisions (Ref. 98).
( 11/19/87)
liVA EMPLOYEE CONCERNS SIP EC IAI PROGRAM REPORT NUMBER:
21200 REVISION NUMBER:
3 Page 8 of 26 c.
Reviewed applicable procedures that al'I'ow changes to be made to pipe support designs (Refs.
91 through 95).
The following steps were taken to prepare subcategory evaluations.
a.
Tabulated
- issues, findings, and corrective actions from the. elem@ntl evaluations in a plant-by-plant.'rranqement (see At'tachment B)'.
b.
C, Prepared Tab'les 1,, 2, and 3 to permit comparison and identification'f common and uni(iue issues, findings,'nd corrective actions among the four plants.
Classified the findings and corrective actions from the element evaluations using the ECSP definitions.
d.
On the 'basis of ECSP guidelines,,analyized the collective significance and
- causes, of the findings from the, element evaluations.
e.
Evaluated defined corrective actions to determine if additional actions are required as a result of causes found in step d.
f.
Provided additional judgment or information that may-not be apparent at the element level.
4.
F INDINGS The findinqs from each of the eiqht element evaluations for this subcateqory
~
are contained in Attachment B.
lhe findings are listed by element number and hy plant.
The followinq subsections are a discussion of those findings.
4.,1 Retention of Calculation Records
- Element 212.
1'or Watts Bar, the TVA procedures,
- FSAR, and microf'i lming process were found to be adequate in acldressinq the document retention requirements of ANSI N45.2.9-1974, thus indicatii>q a hiqh level of awareness of these requirements on the part of TVA OE irianagement.
The peripheral findinq invo'Iving the inadvertent destruction of 'watts Bar pipe support calculation records prepared by EDS Nuclear, Inc.
(EDS) was a result i
of hreakdowns in conmuinication between TVA and EDS) as well as between the TVA contract administration eng.ineer and the TVA Civi.l Engineering Branch Cnief.
TVA committed to recreate, all destroyed or missing icailculatiohs.
2730D-R12 (ll/19/07)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 9 of 26 Because this situation is known to be a problem at
As SON is currently regenerating calculations, no further ECTG evaluation is necessary, because the necessary corrective action has already been identified.
The status of pipe support calculations at BFN and BLN is not known.
- However, any missing calculations will be identified through the implementation of the essential calculation program, which is tracked by the CATDs listed in Table 3
of Subcateqory Report 24600.
Therefore, no further evaluation or corrective action is required for this issue.
4.2 NRC Bulletin 79-14 ABR Pro ram - Element 212.2 For Watts Bar, both phases of the 79-14 program were found to be adequate.
Discrepancies noted during these two phases were well documented, with no major qeneric problems identified other than the potential interference of oipinq with other plant features.
The as-constructed piping configuration for the WBN containment spray system agrees with the as-designed configuration, includinq pipe support types and locations, as well as fitting welds.
With nne exception, the containment spr ay piping was analyzed by either rigorous or alternate methods as appropriate in accordance with the analysis method anplicahility criteria.
TVA was unable to provide evidence that the 8-inch overflow piping from the refueling water storage tank had been analyzed by either method.
TVA conmitted to perform this analysis and review other systems to ensure completeness of the stress analyses.
For Browns Ferry, only Phase I of the three-phase 79-14 program is complete.
The NRC issued notices of violations as a result of several inspections and audits.
In addition, the Nuclear Safety Review Staff (NSRS) has noted that discrepancy trackinq, scheduling,
- planning, and quality assurance (QA) involvement were not satisfactory durinq Phase I (Ref. 15).
The NSRS
- findinqs, as stated in the report, included:
o Issuance of support drawings or modifications without formal issuance of isometrics or load tables o
Inappropriate emphasis (bordering on employee intimidation) by TVA manaqement on avoiding hardware modifications, regardless of analytical results o
Lack ot basic technical training of piping analysts 2730D-R] 2 (11/19/87)
TVA EMPLOYEIE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER:
3 Page 10 of 26 o
Use of unqualified checkers o
Failure of guality Assurance (OA) to perform audits and surveillahce of.identified problem areas within piping analysis sections Resolution of discrepancies discovered during iPhasei I was found to he adequatel.y documented.
Oine support for the drywel1 purge syst;em piping was identified during Phase I
as, having a potential interfierence problem.
- However, EN DES in Knox,ville, was never informed.
Although rigorous analysi,s of Rrowns Ferry drywe11 spray headers was not originally required, this piping will be rigorously analyzed under Phase II of the 7'9-14 program because of a
chanqe in piping classification for this system.
The as-constructed configuration of the two Browns Ferry drywell spray headers matclhes the as-designed configuration with minor deviations.,
Because of a lack of.
available information, a similar verification ifor the spray, header in. the torus could not be made.
This verii.ication wiillibex'ncluded in the Long-Term Torus Integrity Program.
For Sequoyah unit 1, the 79-14 program for pipe supports is adequate in its current form as a result of substantial improvements made by TVA.
The 79-14 program for Sequoyah unit 2 was found to be adequately performed.
Resolution of discrepancies for the
'Sequoyah, 79-14 program is properly doc'umented, and calculations have been performed where required.
Within reasonab'le toler'ance, the as-constructed piping configuration and associated field welds for the Sequoyah containment spray system agree with the as-designed configuration including pipe support types and locations.
Most, of the Sequoyah containmhntl spray pipinq was analyzed by t'e rigorous method.
The small portion nf th'is pipinq analyzed by the alternate method was. eligible for, that, application.
For Bellefonte, the 79-14 proqram h'.s not begari ihipl'nmhnt'ed 'and is not requir' at its current stage of construction.
- However, a corrective action plan has been established to eliminate deficiencies in the applicable procedures.
4.3 Oesiqn. Features in P~ie Hanqer Pro ram - Element 212."'
study of FOR-related statistics for Watts Bar pipe support work did not indicate a siqnificant difference in quallity of work performed by Impell when comoared with similar work performed by TVA and Gilbert/Commonwealth.
FCR statistics cannot be used as the sole criterion for judging the quality.of desiqn work; various f actors beyond the control of the design originator may
,'ontribute to a high number of FCRs.
An informal constructib'ility group, referred to 'by TVA as OASES,,
made a posit,ive impact on reducing the number of FCRs and improving the qual',ity of design for WBN unit 2.
The FCRs
.and S'ARs for Bellefonte did not indicate a siqnificant lack of checking or other oroblems.
These chanqes ar>> part; of a, normal desiqn and installation process.
2730D-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM 4.4 Fre uentl Chan in Han ers - Element 212.4 REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 11 of 26 Twenty-eight randomly selected pipe supports (with revisions) from several Watts Bar safety-related systems were reviewed by the evaluation team.
Al 1 revisions were found to have valid reasons
- and, in the majority of cases, were necessitated by either FCRs or ECNs.
4.5 Summar of Subcate or Findin s
The findings are summarized in Table 1.
Class A and B findings indicate there is no problem and that corrective action is not required.
Class C, 0, and E
Findings require corrective actions.
Of the 26 findings identified by a classification in Table 1,
20 require no corrective action and two had corrective action initiated before ECTG evaluations.
Four peripheral findings uncovered during the ECTG evaluation require corrective action.
Findings are summarized by classification in Table 2.
Where more than one finding/corrective action is identified in Table 1 for a single finding (e.g.,
element 212.2, Finding f), Table 2 counts only the single classification which has the greater impact on the Employee Concerns Program.
Therefore, Table 2 identifies only one finding/corrective action for each issue evaluated.
CORRECTIVE ACTIONS Table 1 identifies six findings that require corrective action.
The detailed corrective action descriptions are provided in Attachment B.
A condensation of this information by element, with the applicable plant identified in parentheses, foll.ows:
.o 212. 1, Retention of Calculation Records - Per SCRMBNCEB8531 Rl:
Review all WBN calculations for basic completeness.
Ensure that all MBN calculations are in the Records and Information management System.(RIMS).
- Prepare, issue, and document calculations for all missing and incomplete calculation packages and those not meeting requirements of the two actions above.
(MBN) o 212.2, NRC Bulletin 79-14, ABR Pro ram Implement a program to correct all:potential interferences between piping and adjacent plant features for unit l.
A WBN procedure was scheduled to be issued on July 9, 1987 which should prevent recurrence in both units.
(WBN) 2730D-R12 (11/19/87)
TVA IEMPLO',(EE CONCIERNS SPIECIAL PROGRAM REPORT NUMBER:
21250 RE'VISION NUMBER:
3 Page 12 of 26 Initiate piping stress analysis and pipe support, design work for the 8-inch overflow piping coming from the refueling water storage tank (applicable to both units)
Also review other seismic Category I sy!stem dr awirlqs to ensure that stress ana'lyses have been performed.WBN)
'evise current procedure CEB 80-76, and void procedures CEB EP2'l.30 and BLEP-08 and replace them with,new ones.
(BLN)
Remove the affected unit 2 pipe 'suppo'rt (H87 at elevation 629 feet 9 inche;s) and a similar uhit 3 pipe support.
(BF'N)'rovide a dedicated work force to complete the 79-14 effort.
A task perforimance contract has been let to effect a timely
'ompletion.
(BFN)
These corrective actions are also summarized in Table 3, along with their corresponding finding/correct,ive action clasSifichtibns. 'he table shows the plant or plants to which a corrective aetio'n is appliicable, in the Corrective Action Tracking Document (CATD) column, where the applicable plant is identified by the CATD number.
From the Finding/Corrective Action C1lassificIation co~lumn of Table 3, it, can be seen that the six corrective actions identified ihvolve the 'regeneration ance documentation of destroyed or missiog calculations, the implementation of a
program to correct potential interferences coupled with the issuance of a new procedure, piping stres!'nalysis for a system that was previously overlooked, and comPletion of Brown!a Ferry' 79-'l4 Program,'r)d
'one involves a PiPe support with a theirmal Iinterference problein.
An,hdd'itiondl 'cot'rective action plan will eliminate procedural deficiiencies in Bellefonte's 79-14 program.
Finally, with respect to corrective actions,~ Table 3'howS t'hat, of the four elements in this subcategory, two (2'12.3 and 212.4) require no corrective act'ion.
The element requirinq the largest, number of corrective actions i'
212.2, NRC Bulletin 79-114 ABR Pirogram, which has five.
Al 1 four correct i ve action pl ans i ssued hy TVA, coverinq a total of six corrective actions,,
were found to be acceptable by the evaluation team to'eso 1 ve the findings.
Additional corrective actions required to retol've'th'e QA-li elated aspects of the problems outlined in this Pipe Support, Program sljbeategory are established in Subcategory Report 24600.
Those programmhti'c Nor'redtive 'actions that pertain to this Pipe Support Program subcategory are~ summarized as follows:
o 205. 1, Calculation Preparation, Updatin<I and Records Retention Requirements
- The TVA Essential Calc'ulgtidn'Pr5 r'am ~ECP) take g
~irs s
ep Tn correcting past d
fei iCnecie
.s. Calculations are being 2730D-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 13 of 26 reviewed for unverified assumptions, reasonable method/approach, etc.,
and are monitored in calculation logs in accordance with engineering procedures.
Each engineering discipline is to provide a
detailed schedule for the post-restart, long-term completion of the ECP (all plants).
o 205.3 Calculation Record Retention A lower-tier procedure will be written to supplement the nuclear engineering procedures (NEP) that control calculation records (all plants).
This procedure will be a site-specific engineering project administrative instruction that will address the following topics in more detai l.
Collection, filing, and storage requirements for completed or approved calcul ations Schedule requirements for the routine microfilming of approved calculations Definition of a final calculation The Corporate Nuclear Performance Plan (CNPP) points out that the responsibility of engineering for each nuclear plant has now been assigned to a nroject engineer who ensures that technical direction provided by the chief discipline enqineers is followed for project work.
The project engineer is also responsible for assuring that design changes are reviewed and approved by enqineerinq personnel for compliance with technical specifications and other requlatory requirements arid commitments.
It was also noted in the CNPP that TVA's nuclear gA activities were not performed under a consistent set of programs and procedures, and that TVA's nuclear OA qroups did not report to a high level of management within TVA, thereby diminishing the visibility and importance of these activities to
~anaqement.
TVA has since reorqanized the reporting relationships so that all quality assurance and quality control functions now report to the Director of Nuclear Quality Assurance who reports to the Manager of.Nuclear Power.
The discipline branch chiefs are responsible for conducting technical reviews of the design parameters of the major plant systems to evaluate the quality, technical accuracy and adequacy, and the economy of the products and services for which they are responsible.
These reviews are scheduled by the branch chief when an area in the. design nears completion and before it is approved for use.
The CNPP also discusses the establishment of an Eng'ineeri,ng Assurance (EA) organization.
It is the responsibility of EA to assure that the Nuclear Ouality Assurance Program is applied to TVA nuclear engineering and design 2730D-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
2120O REVISION NUMBER:'3
,'age 14 of 26 activities.
The various functions perfo~eld 5y EA',include conducting program audits at regular intervals, conducting in-depth technical audits,'nd
'eviewing ancl approving documents used to procure engineering services from t he QA point of vi ew,.
The reorganization outlined in the CNPP, coupled with the corrective actions for the negative findings with.in this 'Pipe Support, Program subcategory, should rectify the prolblems,related to management of the design process and related QA activities, and should prevent the possilbi lity of recurrence.
6.
CAUSES Table 3 also identifies the causes of 'each problem requiring corrective action.
The most important cause of the corrective actions for the Bellefonte and Browns Ferry 79-'l4 programs is identified using the judgment of the'valuation team.
For the other corrective actions, it Was felt that the problem was t: he result of a combination of causes, each of which should be identified.
For element 212. 1, the required correctiAIe action is broad based in its overall scope.
Because this e'lement covers, calculations that were destroyed, misidentified in the Records and Information Management System (RllMS), 'or l
otherwise acknowledged to be incomp'lete, the evaluation team indicated in Table 3 that three of the 17 possible causes contributed to the overall problem.
The immediate causes of this problem are
" Inadequate Communication and "Lack of Management Attention."
"Inadequate Q-Training," while not the immediate cause, is equally important.
i'he three causes are further desckibed below:
Causes for eflement 212;1 as indicated in Table 3 are:
o "Inadequate Communication" - TVA authorized the disposal of the EDS-originated calculations on the basis of the erroneous assumption that TVA would have continue'd hcc6s4 to EDS'icrofilmed records.
The problem was compounded by the apparent misunderstanding between the TVA Civil Branch chief and a
TVA contract administraticin engineer that TVA already had copies of the essential calculation documents in its possession.
273OD-R12 (1'I/19/B7)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 15 of 26 o
"Lack of Management Attention" - In addition to the incidents of inadequate communication mentioned
- records, nor did it provide for regularly scheduled turnover of completed calculations to TVA for processing and lifetime storage.
Without such provisions, the intent of ANSI N45.2.9-1974 requirements could not be achieved.
In addition, TVA management's failure to question the lack of periodic, detailed QA audits of EDS during the life of the contract may be inconsistent with the intent of 10 CFR 50 licensing requi rements.
These problems occurred even though TVA management was aware of the ANSI document retention requirements.
"Inadequate Q-Training" - Section XVIII of 10 CFR 50 Appendix B
states that it is QA's responsibility to conduct periodic audits to verify compliance with and the effectiveness of all aspects of the quality assurance program.
TVA could have exercised greater control over the calculation retention issue by scheduling more frequent audits to ensure that documented calculations existed as requi red and were being prepared,
- retained, and turned over to TVA according to ANSI N45.2.9-1974 requirements.
Additional training of personnel, supervisors, branch chiefs, and managers regarding document retention requirements and audits to verify implementation of these requi rements would also have been beneficial.
For element 212.2, the most important cause for the first corrective action, which is associated with potential interferences between piping and adjacent plant features at Watts Bar, is " Inadequate Procedures."
These potential interferences were the most frequent discrepancy found in the Watts Bar 79-14 inspection program and can be attributed to the fact that existing procedures lacked the proper controls to prevent such problems.
The other two causes
("Lack of Design Detai 1" and
" Insufficient Verification Documentation" ) cited in Table 3 for this corrective action are largely the result of "Inadequate Procedures."
0 The second Watts Bar corrective action for element 212.2 deals with the omission of pipinq stress analysis and pipe support desi'gn work for an 8-inch pioe.
The evaluation team has concluded that this problem primarily reflects a breakdown of TVA's engineering
- program, in which Engineering failed to assure that all work included in its scope of responsibility was completed.
The third.corrective action for element 212.2 pertains to a Browns Ferry pipe support with inadequate clearance for accommodating a.design basis accident pipe movement.
TVA has issued a corrective action plan to remove this support.
The evaluation team believes that TVA field 'personnel should have informed EN DES (DNE) in Knoxville of this discovery.
Since this was not done, the evaluation team has cited "Inadequate Communication" as an important
- cause, in addition to three other causes.
2730D-R12
( 11/19/87)
TVA EMPLOYEIE C:ONCERNS SPEC'IAL PROGRAM REPORT NUMBER
'1'200 REVISION NUMBER 3
'age 16 of 26 The fourth corrective act.ion required for element,212.2 pertains to dedicatin a work force responsible f.or completing Browns Ferry's.79-14 programs The delayed completion resulted from the many problems encountered in the implementation and scheduling of this program, due to manpower limitations and the low priority given to the effort.
'he fifth corrective action required for element 212.2 pertains to el,imination of procedural deficiencies in Bellefonte's 79-14 progiram.
"Inadequate Procedures" is the only cause cited for this element on Bellefonte.
Causes for element, 212.2 as indicated, in Table 3 ar':
o "Inadequate P'rocedures"
- The problem of potential, interferences between piping and adjacent plant features at Watts Bar necessitated the development of a new procedure t:hat t;ranscends the activities of individual design groups in 'orderi to cover those interference problems that, wi~re not detected during the design process.
The BLN procedures were not complete and are to be revised and updated bef'ore implementat,ion.
o "Inadeqiiate Communication" - During a 79-14 inspect,ion walkdown performed Iby TVA at Browns Ferfy, it was noted that a drywell purge system pipe supiport had pipel cllearahce's tha't were inadequate to accommodate a Design Basis Accident pipe movement.,
It was late!
discovered that no design drawing existed for that support,,
thus preventing further iinvestigation
~of
~ the possible discrepancy.,
In spite of'his, the individualls'e'sphns'ible for'he 79-14 activity failed to. inf'orim the engineering organization in Knoxville of this important finding.
o "Untimely Resolution of Issues"
- This cause also was ci'ted f'or'th'e same incident of inadequate icorenunicabion mentioned above.
o
" Inadequate Calcu'llations" - The stress analysis of an Grinch i
overflow piping system coming from a refueling water storage Itahk
'at'atts Bar was never per formed.
o "Inadequate As-bu;ilt,Reconciliation" - The erroneous omission of stress analysis for the 8-inch overFlow piping at Watts Ba!r was di.scovered by the evaluation teain during preparation of ielementi evaluation 2'12.2.
Also,, the Browns Ferry pipe support, with insufficient pipe clearance (discus;sed above in the Inadlequate Commuinication section) was never brouqht to the att;entinn of tthe Knoxvil'le engineering organization.
T'e BFN 79-14 program is not yet completed.
o "Lack, of Design Detail" - Potential inteirferences between piping and adjacent plant features at Watts Bar were not completely accounted for during the design proce.s.
0 27300-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 17 of. 26 o
"Insufficient Verification Documentation"
- Watts Bar piping design and analysis documentation was insufficient to audit the adequacy of design and installation because potenti.al interferences between piping and adjacent plant features were not completely accounted for.
- Also, no stress analysis documentation exists for the aforementioned B-inch overflow piping system at Watts Bar.
o "Engineering Error" - The originator of the previously mentioned Browns Ferry drywell purge system pipe support design failed to consider the Design Basis Accident pipe movement.
ln summary, the three causes related to missing and destroyed calculations are all within the "management effectiveness" portion of Table 3.
The distribution of causes for the TVA 79-14 program shows a total of four within the "management effectiveness"
- portion, seven within "design process effectiveness,"
and one within "technical adequacy."
7.
COLLECTIVE SIGNIFICANCE The six concerns expressed in this subcategory resulted in four issues requiring six corrective actions.
Four corrective actions of the total of six
.vere for peripheral findings uncovered during the ECTG evaluation.
The Pipe Support Program of TVA was found to be generally adequate in terms of its established procedures.
With two <<xceptions (potential interference of oiping with other plant features at Watts Bar, where
~ new procedure was
- ssued, and Bellefonte' 79-14 program, where niinor procedural deficiencies need to be eliminated),
the evaluation teatn did not find any instances in which the probleins associated with the concerns in this subcategory could have been prevented or minimized by enhancements to the procedures.
With few exceptions, the pipe support program was found to be technically adequate.
- However, the five findings associated with the 79-14 program in element 212.2 are judged to be significant by the evaluation team.
The two findings associated with piping interferences at Watts Bar and the pipe support with insufficient clearance at Browns Ferry that might have resulted in stress allowables being exceeded are judged to be significant.
The third finding judqed to be significant deals with the 0-inch refuelinq water piping at Watts Bar for which no stress analysis or support design work was performed.
Although this error is an inadvertent omission of required analysis, it raises the possibility that other piping systems of a similar nature might also have been over looked.
The corrective action plan for CATO 212 02 WBN 01 requires review of other safety-related systems to resolve this question.
2730D-R12 (11/19/87)
TVA EMPLOYEE CONCI.:RNS SPI=C IAL PRIOGRAM REPORT NUMBER:
21260
'EVISIOf'l NUMBER: 3 Paige 18 of 26 The fourth and fifth findings judged to be pbtelntially significant involve elimination of procedural deficienicies associatiedi with Bellefonte's 79-14
- program, and completion of Browns Ferry's 79-14 program.
The remaining corrective action discussed ini thisi suibcategory report is judged not to be safety signif'icant by thie evaluation iteyn.
The question of missirig and destroyed calculations has been addressed by a sampling program that i
demonstrated the adequacy of the affected pipe supports.
- However, even though.
no safety-related p~oblem has been identif'ied as
- such, the violations of document retention requirements are significant, because they reflect a
breakdown in TVA's Enqineering and QA prograims.
In conclusion, although all but one of the specific issues were found to be invalid, four of the six findinqs 'noted within this subcateqory as requiring corrective action were ir elated to peiripheral findings uncovered during ECTGi evaluation, with corrective action beinq required for each.
The rernaininq two
- issues, which were found to be valid, are the only ones that: were specific to the element (Bellefonte and Browns Ferry 79-14, program inadequacies).
The evaluation of four elements grouped within this pipe support program subcategory did not lead to any collective significance in t: he overall
- sense, although the effectiveness of'oth management and supervision at the design group level should be ques,tioned.
On the other hand, the observed procedural deficiencies are. fair ly typical to any nuclear project's 79-14 program, particularly in view of the multiphase aspects that are essential to assure a
thorough as-built review.
Tive problems associated with the snissiriq and destroyed calculations were attributed primarily to poor communicat,ion and lack of attention to the proper implementation of document; rietent ion requ'irelmehts by Ehgi'nedring and management personnel The key to a successful pipe support program from a management point of view is the assiqnment to des'ign group lead -positions of individuals who fully appreciate the need fair coordination and thorough documentation, as we'l as two-wiay communication with Field,(or office) counterparts,
- vendors, and the discipline chief's office.
It is obvious that the best procedures possible cannot guarantee a successful enqineering effort~
unless the engineering supervision perf'orms its role effectively.
In addition, there was a breakdown in the QA program caused by not conducting a more aggressive audit program to ensure that all aspects of the documentation retention requirements with respect, to vendors were being satisified.
While it is not the:responsibility of QA to duplicate the Engineering organization's efforts, management must require that periodic QA audit reports be issued on an established schedule and must carefully revieiw the results of these reports to ensure the effectiveness of the audits.
Within 'the limited scope of the Pipe Support;, Program subcatieqory the 27300-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 19 of 26 evaluation team does not consider it appropriate to analyze the QA breakdowns any further, other than to state the observed occurrence.
The important question of the interface between management and 'QA, and the extent of individual responsibilities in preventinq such problems, are addressed in Subcategory Report 24600.
In addition to QA audits, the Civil Engineering Branch Chief' office should conduct its own periodic technical audits and reviews.
These will provide the needed assurance that the design work is adequate from an engineering point of view.
These observations pertaininq to the proper roles of management and QA (including the discipline chief engineers) are also discussed in TVA's Corporate Nuclear Performance Plan (CNPP).
The results of this subcategory evaluation are being combined with the other subcategory evaluations and reassessed for the Engineering. category in a single report.
27300-R12 (11/19/87)
TVA EMPI OYEE CONCERNS
,SPECIAL PROGRAM
,'REPORT NUMBER:
21200 IREVISION NUMBFR: 3 Page 20 of 26 TABL'E 1
CLASSIFICATION OF FINDINGS AND CORRFCTIVE A'CTIONS Element 212.1 Retention of Gal cu1i ation Recor ds Issue/
FIi~ndin **
F indi ng/Co rr'ec t i ve Action Class'".
A E3 212.2 NRC Bulletin 79-14, ABR Program 212.3 Design Features in Pipe Hanger Program a
b c
d ef a
b c
A A
A A-A A
A EB E'l E2 A
A A
C6 A
A A
El C2 A
~
A A
212.4 Frequently Changing Hangers a
+
A'Classification of Findi~n.; anrl Correct'ive Actions A.
Issue not valid.
No corrective action required.
R.
Issue valid hut consequences aicceptah.le.
No corrective action required.
C.
Issue valid.
Corrective actioin initiated before ECTG evaluation.
0.
Issue valid.
Corrective act.ion taken as a result of ECTG evaluation.
E.
Peripheral issue uncovered during ECTG evaluation.
Corrective action required.
- Defined in Attachrrent B.
- l. Hardware
- 2. Procedure
- 3. Documentation
- 4. Training
- 5. Analysis
- 6. Evailuhti'on
- 7. Other 2730D-.R12 (11/19/87)
0 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM TABLE 2 F INOINGS.
SUMMARY
REPORT NUMBER:
21200 REVISION NUMBER:
3 Page 21 of 26 Plant Classification of Findin s A.
Issue not valid.
No corrective action required.
9 3
4 Total 20 B.
Issue valid but consequences acceptable.
0 0
0 0
No corrective action requi'red.
0 C..
Issue valid.
Corrective action initiated before ECTG evaluation.
D.
Issue valid.
Corrective action taken.
as a result of, ECTG evaluation.
E.
Peripheral issue uncovered during ECTG'valuation.
Corrective action renui red.
0 0
1 1
0 0
0 0
0 3
1
'0 Total 4
12 5
5 26 2730D-R12 (11/19/87)
TABLE 3 HAIRIX UF ELEHENIS, CORRECTIVE ACTIONS, ANU CAUSES SUCCATEGCRT 21200 REVISION NUHBER:
3 PAGE 22 OF 26 CAUSES OF NEGATIVE FINDINGS a I
TECHNICAL HANAGEHENT LffELIlVEhESS DESlGN PROCESS EffECIIVENESS AUE ACT I
2 4
6 6
y 8
9 10 11 12 13 14 16 16 Iy 212.1 E3 212. 2 El E2 ES F INDIIx't/
CORRECTIVE 4CTION ELEH CLASS. ~t COkRECTIVE ACTIUN Per SCRNBNCEBBS3l R1 I I) Review all calculations fol'asic cotplctcne$ 5
- 2) Ensure that all calculations are In Records and lnforaation Hanageawnt Systea IRIHS)
'tl tt
~
~
t ~ vvat c ~ tvtuv ~
aww docuaent calculat ions for ~ 11 aISSing and inCoaol etc calculation packaues and those not aeetin9
.. ~
~
~
t 1
~
~ vvu ~ ~ 4 wwtt w
~
4 tv c awv w
lactlcaent a provraa to correct all potent l~ I interferences between piping Jtwt tolawwflt wlwnt fwtttutec for unit l.
HBN procedure NBEP tP 43o20 ku wl I I De issued on Oy/Og/61 which Should prevent recurrence in wwtw sttt Inltlatc plplfl9 5tt'c5$
analysis and pipe support design work for tne 8-inch overflow oipino coalnu frow the refueling water storage t4Ai Iappiicaule to.both units).
4lso revle>> other selsalc Category 1 systea draw'Ings to ensure tha't stres5 analyses nave oeen perfor~~.
CATO MBN Ol wuh Ul woh Ot x
I I
I x
I I
I I
I I
I I
I I
I I
I I
I I
I V
I.
I Ii I
I I
I I
I I
I I
I 1
I I
I I
I I
I I
I I
)
1 I
I t
I I
I I
I I
I I
I I
I I
I I
I I
)
)
I-I-
I I
I I
I I
I
)
I I
I I
I I
I I
I l
I I
I I
I I
I I
I I
I I
I I
I I
I I
I I
I I
.I I
)frag-I I
IProce-llnade-I I
I I
I!nadc-I IEngrg IOesign)lnsuf.I Iwented)!nade-Ilnade-Idures
)quate IUn-I Ilnade-I Iquate I l.ack IJudgatICrlt/ IVerlf IStds
)Organ-)quate
)quate
)hot
,ICoa-Itiwely)Lack
)quate Ilnade-I4s-bltI of I not Icoaralt)Oocu-
)Not Itta-I fl-IProce-Ifol-
)aunt-
)Res of)of Hgt)Design)quate Ikecon-)Design)Docu-I Not Iaenta-IFol-tion tr dures lowed cation issues Atten Bases Calcs cil Detail aented Het t Ion lowed I Signlfl-I cancc of I
I I Corrective)
IEn9r9 )Vendor) Actions+
Error Error 0
H H I I
I I
I I
IAIPIPI IIPIPIPI I
I I
I I
I I
I i i I
I I
I I
1 I
I I
I IPI I
I I
I
)
I I
I I
I I
I I
I I
I I
I I
I I
t t
II Oel tned In tne GtuSSary Suttpleacnt.
~ ~
Oe>>ned in Table I.
2)3UU-ko t 1 1/IJ/6/1
Ian mIJJIX uf EitmhJS ~ Luh VL 4(IIUhS ~ Wiu CauSLS SDOLatLJRJa(V 2 IZIJII RIVISIJfh h atk; rauE 23 Gf Za LOSES 1JF htigaIIVE fihulhuS v
I I
ltahtufrJENI EffLLVIVEhESS I
IEOJJJIE4L I
OESIuu IROCESS EFFECIIJJERESS LJJE aCV I
F IJJOIICI/
CORRECVIVE ACVION ELEN CLRSS
~ a CORRLCIIVE JJCVIOH CRIU I
2 3
a 5
6 2
8 9
10 II 12 13 I~
16 16 lf I
lfra9-I I
)Proc<<-llnaEJC-I I
I I
linaJJ<<-I IEnqrq IDeslqnllnsut.l I Ssqnstl-In<<ntcdl toad<<-) lnaae lour<<s )quate l0n-I llnadc I
lqu'tc I Lack IJud9nt)Crit/ Ivcrit IStos
) canc<< ot Idrqan-)quate
)quate
)Not ICon-
)tlag<<lyltack
)quate linaoe-las-nit) of I not lcofnaitlpocu- )hot I COrrettiv<<l Jl J
V JP
-Jf I-J I-Jges IJ't RgtJfeslg Je l
Jeec
-Jfleslg Jltd -
J Rel J
I -Jf 1.
Jt s f Jf d
J Ic\\
l d
I e
t\\
I slit e
el
'l. Util td Rt ll I
d I E
R II RJ E I lhe proposed corrective action 15 to dclctc tnc subject unit Z support NBZ
~nd support H33 In unit 3.
C6 PrOVIde a dediCated rnrkfOrCe tO CO<<fplete tne 29-le effort. i task perfolvaanCC contract has been let to effect a tinely coaptation.
C2 Current procedure CEB 80-26 will be revised and procedures CEB EP Z1.30 and BLEP-08 rill be voided and will be replaced rith ner procedures
~
ofh Ol Bfh Ol BLR OI I
I totals
)
)
I I
I I
I I
I I
I I
I I
I I
I I
I I
I I
I )3 I 'I I
I I
C I
P I C I
'I I
I I
I I
I I
I
I I
I I
I I
I I
I I
I I
I I
I
.I I
I
)PI I
I I
I I
I I
I I
~
Defined ln the Glossary Suppleccnt.
Defined ln table I.
21350-R6 I II/19/82)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBFR:
2120O REVISION NUMBER: 3 Page 24 o>f 26 GLOSSARY SUPPLEMENT FOR THE ENiGINIEERING CAT'EGORY Causes of Neqative Findin~s - the causes for fin'dings that're'quire corrective action are categorized as follows:
Fraqmented orqainization
'- Lines of authority, responsibility, and accountabi1 i ty were not clearly defineld.
2.
3.
4.
5.
7.
Inadequate~ualithf (Q) train~ini
- Personnel were not fully trained in the procedures established for design process control and in the maintenance of design documents, including. audits.
s
~lnade uate procedures
- Design and modifica'I:ion control methods andi procedures were deficient in establ IshincI requiirements and did not ensure an effective design control program in some areas.
Procedures not followed - Existing procedures controlling the des'ign process were not fully adhered. to.
~Inade nate communications
- Communication, coordination, and cooperation were not fully effective in supplying needed information within plants, between -plants and organizations (e.,g.,
Engineering, Construct'ion, Licensing, and Operations),
and between interorganizational disciplines and departments.
Untimely resolutiion of issues
- Problems were not resolved in a
~t>me y manner, and t,he>r re:olution was noti aogressively pursued.
Lack of management aittention - There was a lack of management attention in ensurinq that proqrams requ'ired for an effective design process were established and implementedi Inadequate desiqn bases
- Oesiqn bases were lacking, vague, or incomplete for design execution and verification and for design chanqe evaluation.
-9.
10.
Inadequate calculations
- Oesign calculations were incomplete, used incorrect input or assiimptions, or otherwise failed to fully demonstrate compliance with design requirements or support deSign output documients.
~Inade cate as-t>oil t reconciliation - Reconciliiation of design and licensing documents.with plant as-built condition.was lacking or incomp 1 et ie.
27300-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page 25 of 26 11.
Lack of desiqn detail - Detail in design output documents was insufficient to ensure compliance with design requirements.
12.
Failure to document en ineerin
'ud ments - Documentation justifying engineering judgments used in the design process was lacking or
'ncomplete.
13.
Desiqn criteria/commitments not met - Design criteria or licensing
. commitments were not met.
14.
Insufficient verification documentation
- Documentation (g) was insu scient to audit the adequacy of design and installation.
15.
Standards not followed - Code or industry standards and practices were not complied with.
16.
En ineerinq error - There were errors or oversights in the assumptions, methodology, or judgments used in the design process.
17..
Vendor error - Vendor design or supplied items were deficient for the intended purpose.
Classification of Corrective Actions - corrective actions are classified as belonging to one or more of the ollowing groups:
1.
Hardware - physical plant changes 2.
Procedure
- changed or generated a procedure 3.
Documentation - affected gA records 4.
~Trainin
- required personnel education 5.
~Anal sis - required desiqn calculations, etcis to resolve 6.
Evaluation - initial corrective action plan indicated a need to evaluate 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 Peripheral Findin
( Issue) -
A negative finding that does not result directly rom an emp oyee concern ut that was uncovered during the process of evaluating an employee concern.
By definition, peripheral findings (issues) require corrective action.
2730D-R12
( 11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORl" NUMBER:
21'200 REVISION NUMBER: 3 Page 26 of.26 Si nificance of Corrective Actions - The evaluat,ion team's judgment as -to the significance of the corrective actions listed in Table 3 is indicated in the'ast three columns of the table.
Significance is rated in accordance with the type or types of changes that may be expected to result from the corrective action.
Changes are categorized as:
o Documentation change (D) - This is a change to any design input or output document (e.g., drawing, speicificationcalculation,,
or procedure) that does not result
<<n a signif'icant reduction in design margin.
o Change in design margin (M) - This is a change in design interpretation (minimuim requirement vs actual capability') that results in a significant (outside norrrial limits of expected
~
accuracy) change in the design margin.
All designs include margins to allow for error and unforeseeable events.
Changes in design
'argins are a normall aind acceptable part of the des,ign and construction process as long as the final des.ign margins satisfy regulatory requirements and applicable codes and standards.
o Change of hardware (H) - This is a physical change to an existing plant structure or component that -results from a change in the design basis, or that is required to correct an initially inadequate
'esign or design err.or.
If the change resulting tFrom the corrective action is judged to be siqnificant, either an "A" for actual or "P" for potential is entered into the appropriate column of Table 3Actual is distinguished from potential bec'au>e
'orrective actions are not complete and, consequently, the scope of required chanqes may not be known.
Corrective actions are, judged to be significant'f the resultant changes af Feet the. overall quality, performance, or mar.gin of a
safety-related structure,,
- system, nr component.
2730D-R12 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
21200 REVISION NUMBER: 3 Page A-.l o.f 2 ATTACHMENT A EMPLOYEE CONCERNS FOR SUBCATEGORY 21200 Attachment A -- lists, by element, each employee concern evaluated in the subcategory.
The concern's number is given, along with notation of any other element or category with which the concern is shared; the plant sites to which it could be applicable are noted; and the concern is quoted as received by TVA, and characterized as safety related, not safety related, or safety sianificant.
0107A-R57
'( l l/19/87)
CONCERN
<LE<rh<
i<<<<<<
AlTflt.}ENI A k tPLUYEL LUNCLRNS FUR SUBCATLGURY zlzuu PLANT rtPPL It<<OILI I Y LUCATION 5}IH }t}ttt BF N ULN CONCERN UESCRIPTION* REVISIUN t}U}BER} 3 pAGE A-2 UF 2 212. I IN-}}b-110-UU4 (shared with 2UbUU) I}Utl "l.ack of awareness by TvA 0E tttnagement (names given) of requirements to document the load carrying capabilities of pipe supports for future reference. TVA }}tnagement ignorant of requirements of ANSI N45.2.9 lor retention of design calculations as permanent plant records." (sR) 212.z IN-}}b-U27-uul Sl}N-}}b-UU2-UZ }tUN "TVA program for impl'ementing NRC Bulletin 7g-l4 inadequate. Oesign calculation documentation is lacking." (SR) "uuring the exit interview, the CI stated that containment spray line pipitrg drawingS and weld map do not agree with the as-built,s. Alternate analysis was 'used instead of rigorous analvsis, drawinas were not corrected." ISS) 2lz.~ IN-Ub-Ib3-uuz IH-}}U-}tbl-UUZ "ueSign featureS in pipe hanger design are nOt COmp}ete, checked, or rgsearcired. TVA lras contracted two engineering firms to walk down dieas prior 'to designing pipe hangers. Contrary to this, Cl stated th<tt a large percentage of design document's at WBH are inadequately Cheeked and resoarehod }hie ina<ten<<aCv ic eVidenCed hv tho larno r<nrr<t<er of Fl.R's required to facilitate construction of the items. JpeC ~ f <C < QflCC< ns CXp< CSSCd OVC< thC qua < 1ty Ol l<rn<pC I << Mnt< ol t personnel work on hangers in SyStem o2, B3 and 12. Construction uepartment concern." (SRI Large nu<r<ber of FCR's are generated due to lack of thorough final r<incte<<rtxt<ilit<< incnortinn Iknl 2 I2 ~ 4 IH-}}~-io4-Uuz aU}i rru<tuer<r ry cnang<ng nanyers rvr nu appar enr re<rsvr< wntcn causes a severe waste of material and money. Concern is generic to Units I z As an exa<np}e: a spring hanger size 11 is selected for a certain t<a<<ner ciX rr<OnthS later it <<i 1 I t<e charmed tn cizo 17 an<t a <<ear later tu size 14, and fOllowing year it will go back to size 11 <<.n < aga 1ii. 1<ivt sn/hu/>5 Indicates safety related, nut safety related, or satvty siyrrit icant pur'eteri<tittatiun criteria tn %1<e MTG Pr9gtarn fl<aflud+and applird wy }V<< hefore ev<rlr<<rtiuns. ~ < < }s</U< ~
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 21200 REVISION NUMBER' Page B-1 of 19 ATTACHMENT 8
SUMMARY
OF
- ISSUES, FINOINGS, AND CORRECTIVE ACTIONS FOR SUBCATEGORY 21200 Attachment B -- contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and corrective actions. The reader may tr ace a concern from Attachment A to an issue in Attachment 8 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 using the CATO number which appears in Attachment 8 in parentheses at the end of the corrective action description. The term "Peripheral finding" in the issue column refers to a finding that occurred during the course of evaluating a concern but did not stem directly from an employee concern. These are classified as "E" in Tables 1 and 2 of this report. 0 0107A-R58 ( 11/20/87)
AITACINENT 8 SUIVO<KY Ut'SSULS, Fll<VINGS, ANU CURkfC) IVE,ACTIONS FUK SUULATEliUKY 2I2OU REVISION NUHBER: 3 Page 8-2 of )9 Issues Findings Corrective Actions
- aaaa*aa*a*
Element 2)2.1 - Retention of Calculation kecorus
- aaaaaaaaaaataateaaa SQN (N/Aj kBN a.
TVA UE Hdnagemunt is unaware uf the mandatory ANSI requiremenCsalur slnrs>>iientdt!DD and rs t<anl.ion of design calculations as permanent
- pidAC, records'.
The following issue wds discovered dsarlno tne eValudtion tedlll 5 investigation of the stated Concern: t ~ Ka a>>le<sue ~ vv ~ \\ v e v ~ s ~ D< c ea eavt >>>>1>>a ~ I at irma nrs sadrsast by EOS Nuclear, Inc. anu later destrOyed by TVA fall within the category of Lifetime Quality Assurance
- Recurds, as described in SOCtinA 2 2 I Of At&I h48.2.9-)914
~ This destruction of calculations is dA 1 ilustratloii Of TVA Hsdisagv<a>AC'5 )ace of awareness of tnese ANSI requirements. wbh a. Ine evaluation tean< Compared TVA's applicable procedures ICN ufb-LV l.i4, Fi 3.U3, EP b.)4, and UEP-loj and FSr<n (Section ll-2) against, the requiren<entS of ANSI t14b.2.9-)g/4, dnd determined tliat they provide sufficient ~ sd Ca 1 sa Cuues' ne5 rs A<4 Ice<<<a IICS The teal<1 iloted s hu<<ever, that noiie of tlie 'procedures or applicable ..t ~.. a.'a'.,v l...s k. >> v.>>I a>>ant at iua I iat in<a nf Vu 4 tv<<a vs vs<a s ann ~ ss\\ suuau u ~ ~ <I ~ vavaavv v a ~ typical exan<pleS Of liletime quality aSSuranCe reCOrdS. t<evartne)us5, the degree of con<pleteness of the proceuuras died F5<<k is'a positive indication of TVA GE rlandgement'5 high leVel Of aWareneSS Of ANSI require<nentS <A tiiis reyafat. )s1 ddvls,ioA, a sdlbple uf 30 calcu)at IVAs wdS revie<<vo tu dSCertdin that each one has d Hdndge<<<ent anu engineering uata System (rlEUSj nuaiber, thus siglsilyinu that all calcu)ations within the sample were processed fur <biCrofilining Dy the originating 1 >> st ~ e.n us guess>>va u ~ ~ D I vn Handle<<<anc <<ds aware ut the iikbt requircircnts aiiv aid C<AISIder the pipe Support Ca)CulatiOnS prepareu by EUB tO be essential Lifeci<<a: quality Assurance
- kecords, Dut fa!!eu cu verily tndt they had the originalS, copies.
or biiCrofilins iii tiieir POSSeSsion, prior tO dutnbriZ)ng ~~.... ~ ~ ~ . r<sv TS v ea >I ~satin>> taJI>> <aJ>> Lssa sr vaaas Oa v lv'as uj vuu ~ lv I Vv avaa ~ u ~ ~ conc)uded tndt che inadvertent destruction of sane of these ca)cu)dclons <<45 dn isoldted incident, caused primarily t<y Dredku<<wns in co<iinunications between TVA and
- tUJ, as <<<<ll as between the Tvtt contract administration engender danu tilI IVD L<VlI fAasineering Us'anrli I'hlef Tv<<'5 co<<<4it<<mot cv recreate ciie oestroyeu and inissing Cd)Cu)dtluns IS uutlineu in ltS NOnCOnfurrnanCe Kepbrt ti14KI WUd Lcd o<lt<, kl, dnd bignifiCant Conuition Keport
( SLKI kbli Lf8 b>4 I s K I. Si)N {N/Aj WUN a. None required. D, sivrsuusasus>>eau>>a saaPua v t ~IJ Il u avvvu v s. ~ . r>> J ~ t I'<<<'llI uktacnvk4 I>s NCK action was completed Dy Nove<aber 3U, lgU4 (u<emorandum from K. 0. Uarnetc to J. Ca Stdndifer I'.FK K41)3O O03j and determined thac all unit 2 supports -wl)1 be reviewed by TVA as a pasrl. Of that unit,'S deSign prOCeSS.
- ThuS, dCCeptdoility-of theSe suppOrtS will 02
- enSured, Signs
~ 'n 0'ldll,i>>P Kee'urt {~CAI SCRKUNCEU853) kl was issueo on January l4, lgU6 to tdke corrective action for-all n<iss)ng pipe supports, in addition tO the destroyed EuS calculations, for i<nit I This cnrrective action Is ds fo))ows: 223OU- /lg/Dfj
n I Is gnMI.H I I) >~euuIY ut I'ut > ~ I Iwulliub~ iINU lVKKtlI I VL IIC I Iuhb FVK SVIII.IIItuvKYZI/Iiu IIEVISIVN hUMdtII. 3 Page 8-3 of 19 Issues I. IIIUinys Correct lvd Actions Element 212.1 - NBN (Continued) 1. Review all calculations for basic completeness. 2. Ensure that all calculations are in Records and lntormation Management System (RIMS). 3.
- Prepare, issue, and document calculations for all missing and incomplete calculation packages and thoSe not meeting requirementS Of l.
and 2. above. The above corrective action will be implemented by the Hanger and Analysis Update Program and will be conpleted prIor to UnIt I fuel load. The above TVA COInIIitIIIent iS per itS corrective action plan (CAP) (TI.A8-212, 02/25/Bl). (CATU 212 Ul NBN Vl) The evaluation team concurs with this I,KP. Element 212.1 - BFN (N/A) BLN (N/A) dFN (N/AI 8LN (N/A) 8FN (N/A) (N/A) ~ 22369-ll (II/Ig/Ul)
Issues AIIACttHENI B SUlbViKY VF ISSUES, F INUINUS, ANU CURREC1IVE ACflUNS I'Uit SUKCAftUUKV 212UU Findings Corrective Actions REVISION NUHBER: 3 Page B-4 of 19 11*11111111*11111* Element 212.2 - NRC ttul letin 19-14, WK Prugrditr 111111111*1 '11111 St)N a. TVA program for implementing tlKC Il. Bulletin 19-14 is inadequate. SqN
- d. U>>it I.
IYA's initial response to the ttKL regarding ~curt>p lane< wttn IE ttulletin 19-14 for St)N was that tlie wiguinu deSiun and verification prugrdri trieetS ttie requirerrtentS ut the bulletin (1VA letter to tiRC, t)9/01/19 ~ . I I is>siss> ~ I ~ ~ is> s rl IIIII ~ ss. h W h ~ ts li I ACVC hf LIlcl IIvIvl viva ~ Isle Ilhs I IlvWvVe~ ~ v ~ Ivv vvvvv ~ inadequately inspected, pipe supportS (NRC letter to
- 1VA, Ub/LI/BU [AU2 BUU623 Ulujj.
1o make theSe.inspections SdtiStdCturyl 1VA itrtplertrented additional plant-approved prOCedul Ls ~ SUCII ds Hl 6 11> Hl b I/A~ dlid Hl 6 1lC ~ thdt ~ ~ Ih ~I ~ I III i IS l > ii siss hC as>sr \\ ~IC ~ I ~ 'I shC Wtl lht> ~ vqu ~ ~ vu vuv ~ v ~ vssv ~ hv ~ h v I v vpvv v ~ satisfied ttKC rL>quirertrents. lne quality tissurdnce survey (kef. 101) perfurmau in February Igdb fur Unit 1 IE Bulletin 19-14 program idesst ifis>sl fs ~I'tnl I'iscrenancies ltio surv'ov fLt>Jnla ttiat, 'a large nuiiber of supports were not inspected becauSe tliuy wer C IAdccessible dinv thiat iilsi>CCt.tni'is WCrC perfurrrred wittiout using plant-approved procedures. iwu CurreCtiVu actiOn re)tOrtS, SKNChK 8602009 (U2/21/bti) and >t)htttK ttbubU34 (Oo/ll/B6), have oeen issued as a resu ft uf Hte qA -Su> Veys lvti hds urtdLrrtdaett d pipe support enhdncenient progrdtit (Kef. I) tu resolve these Lorrect,ive action reports. llhit d. None required. spiidsu I, )trL r'lidsis I prugS alii COns iSted Of iinspeCt)lig a) 1-riguruuSly andiyted Safety-related piping (inSide and outside cutttdirrrr>crit) and at ternately arralyzed Sa(uty-relatL>d piping 2-1/2 inCheS and larger in dianieter (ittsirte dr>J uutsiue cuntainttent1 iur EKLlt, I'CS,
- KUS,
< VL'6 SFPL>t artsd FPS pipiiisg systL>>sic ~ dccL>rding to prucLdures sqtt-ud-tt4 atilt sqh-bu-UJ (Kefs. 53 and 64). 223bU- ~'/19/U/)
Issues >il I>iCt>He h I SuHH> >tv Vt Ibaui.S, FihulhbS, >ihu t.uNNII.TIYI. At.'Ilvt>S Fu> >UBC>ilt.uuNY elzuU Findings Corrective Actions Nt.YISION NUNB Page 8-5 of )9 Element 212.2 - St)N (Continued] b. Uesign calculations that address tne resolution of 19-14 prograin discrep-ancies lack proper documentation. Phase Il. Ine Vtyase II program was an audit to verify Lhte e leslireaess i the Phase i yreyrah i'sseriay cumt>liance with It. Bulletin 79-Ia requirements INefs. 55 and bb). It consisted of, un a sample basis, IUU percent measured inspection ot the items (discussed above) covered under the Phase I program. The inSpeCtion program was limited to rigorously analyzed seismic Category I piping regardless of size. A total of nine piping iso>iietrics from different Systems, such as main stea>it, feedwater, Safety injection, etC., were Selected foi this program. The inspection was conducted by an indepeiident inspection team (frow Teledyne) not involved in the Phase I program. The Piiase Il program was basically a means to identify and correct any prograt>h>atic deficieiicies in 1'YA's Phase I program. The evaluation team and the NNC nave concluded that this program hds been adequately performed per the respective procedures (Nefs. 99 and 100). ba NeSOlutiOn uf diSCrePanCieS fOr tne NRC IE Bulletin 19-14 b. HOne required. prograui Is properly docuinented, and calculations tiave been performed where required. c. Containment spray piping does not reflect as-constructed" configuration in terms of routing as well as weld locations. d. Containment spray pipiiig was analyzed using Alternate Analysis method instead of Nigorous Analysis method. c. The ds-constructed piping configuration for the containment Spray SySte~ agreeS witn the aS-designed configuration including pipe support types and locations witnin tne dcceptance tolerance established by TYA fur the Stttt 79-14 program. The field welds are appropriately shotyn in the as-conStruCted drawings.
- d. Host ut the containmeiit spray piping is analyzed bt/
Ni'gorous Analysis metttod. The small portion of it ttiat is analyzed oy Alternate >i>>alysis metnod is eligible For that. appl icat'Iun. c. Hone required. d. Hone required. 22360-11 ( I I/ I9/B/)
Issues AIIACIINthl 8 sul4ekY VF lssuts, F INUINus, AND cukktcTI YE AcTIUNs FUR ~uucnrtuukV 212uu Findings Corrective Actions REVISION NUNUER: 3 Page 8-6 of 19 Element 212.2 - WBN INN NUN a. The TVA program for implementing NNC Inspection and tnforcement (It) dulletin 19-14 is inadequate. a. IVA's approach to implementing the NRC IE Uulletin 19-14 prograra consisted of two phases, nally, Phase I and Phase Il. The Pnase I prugrmu (Performed per procedure EH UES-SEP 82-ldl reuulred inspection of all rigorously analyzed seismic category I piping regardless of size and all Cat ei.or v I a it ernatel v analyzed piping 2-1/2 inches in diameter and larger. Visual'nspections were performed for piping routing, presence ol concentrated masses (valves), f,ittin'gs, ~elded attacluneiits, and branch lines; pipe support types, In'c tions eris ntatiun component sizes and setting. In addition, clearances ao3acent to the pipe, within tne pipe suppurts, and with iri thc penets at Ions were measur 'hu Phase ll program (performed per procedure EN UtS-SEP 82-zbl Was an audit of the Phase I program tO verify its effectiveness in ensuring compliance <<ith tlie NRC IE pollution I9-14. This program consisted of 100 percent measured inspection of a representative sample of piping iSOmetriCS and.aSSOciated piPe SuppertS fOr all the aspects cuvered under the Phase I program. Tnis inspection was performed by an independent team (from Teledyne) nst aSSOCiated WIth the PhaSe I program. IVA's similar Phase I/l'hase Il approach to imp(ement'ng the NkC IE dulletin 19-14 on Sequoyah'Unit 2 was found adequate oy the NkC. (This is acknowledged in hRC lett=rS tu IVn dated 0)/16/81 and IU/08/81, ripnrtS. 50-S28/81-2) [ale nu2 810117 003J and 50-321/81-32 ~ tNINS oui 81)VT9 014j, resPectively.) a. None required. 223uu-11~9/>>1 j
~ ~ AI I AC<<'ri<.h I u >a~'b<<>utb, F Ihuil, n<<U <.UH<<t.ill vt A<.llu<<s FvN SUBCnltbu~v zlcuv RCVISIUN NUN: 3 Page B-l of 19 Issues I inuings Corrective Actions F.lement 212.2 - MBN IContinued) b. UeSign CalCulatiOnS that audreSS tne resolution of 79-14 progra<<< discrep-ancies lack proper documentation.
- b. << tutal u< Iv,lou d>screpancies was recorded as a
result uf tne pnase I program inspection ((.FB u4-U4). A tutal ot I,Udu piping discrepancies and 22U pipe support discrepancies resulted In <<<od<f Ication wol'K th<<t cons)sted of notching insulatiun or structural steel, reluCating COnuuitS and inStrument
- lineS, n<aking repairS to pipe supports, and rerouting approximately 13 segments of piping.
initially, all discrepancies were evaluated inuivioually. Uiscrepai<cies whose resolution resulted in an isometric drawing change were tnen evaluated for th'eir cumulative effects on the piping analysis. In addition, an input check was performed for all insulation weights ahu phys>cal valve data used in the piping analysis to verify that the latest available information was used. As a result oF the Phase I progra<<< discrepancy reSulutiun, a2b analySiS iSOmetriCS and apprOXiu<ately I,kud pipe support drawings were.correcteo to rut lect tne "as-cunstructeo" configurations, ano seven piping analysis problems were reanalyzed. Lhu discrepancies found uuring the Phase I program inspection were properly documenteu and forwarded to the appropriate groups for their resolutions. The resulutiuns of these discrepancies was adequately docu<<<enteu anu the engineering dudgments were stated on the resolut,ion for<<<. Ihese 3uag<<<ents were reasonable. b. None required. 2236U-ll ( 11/lg/Bl)
Issues ATTACNNtNT U BUNVKY UF
- ISSUED, F INUINUS, ANU CURRECTIVE ACTIONS FUK SUUCATEUUKY 212UU Findings Corrective Actions REVISION NUNBER: 3 Page 8-8 of 19 Element 212.2 - MliN (Continued) c.
Containment spray piping drawings do not reflect "as-constructed" confiauration in terms ot routing and weld lOCatiOnS. Ihe phase II pruyraui inspection of nine piping isometrics and associated pipe supports resulted in 57y deviations (CEU U3-31). Sixty-seven of the 57y deviations were classified oy TVA as Phase II discrepancies. The renutning oevtations were either acceptable per TVA Criteria Or they were already identified by PhaSe I inane etituI NdrIe Of the b7 diSCrePanCieS WaS SuCh that there was a definite potential for loss of pressure ~...... ~ .. ~ e..... t i Fir ice<< i eee neia vcc ckeeeetf ir ant vvUIIUVIJ ~ vv lice 4 1 eec ~ Vi~ ~ ~ evveee vetiv veev icier r V ~ ~ ~ ~ ~ ~ The une significant discrepancy,was a localized stress problem due to.a welded lug attachment. Ihe PhaSe II discrepancies and their resolutions were documented. eeee ~ ei4 t.a<< ic Of the t e<<e ~it<< Of the PhaSe I I nrOI) ~ am inspection described
- above, no major generic problems
<<1th tne.piping systems were identified. The d>screpancies in tlte area.of support location and pipe, yeumetry (the twO aSpeCtS ViSually Verified in VnaSe I nreoeeermeeet I re insinnificant and did not imbact the final ana yses. c. The contatnnent spray system consists of two containment spray headers and two residual heat removal (HHR) spray headers. The evaluation team reviewed the two containment spray heauers and associated piping inside and o !side a:ntainment-to-c!teck-theaters! 1 giping configuration and pipe suppOrt typeS and locations. The ,piping configuration,was verifiedwy comparing the geotetry and overall lengths ol' reasonable sample of design isometrics witn their is-constructed isometric I'niinterpart<<pipe SeuppOrt i<<teat ien<<and types ~ verifieo by coiipartiig the as-constructed support detail urdtelngs tO tfte design ISOnetfiCS (three SuppM'tS per isometric). c. None required. 223eu~iiiy787)
Nfl>N.>we.t>t u 5u>"t>QY ut lb'ut', f I
- 8',
t u LU>IKICl I VI. ACT IUttg fuk SU8C>tltuukY.'I/ud HlvisIUt< ttut:
3 Page 8-9 of lg Issues F l>>ulngs Corrective Actions Element 2)2.2 - N8N (Continued) d.
Containment spray piping was analyzed uSing the Alternate Analysis method inStead of'the Rigorous Analysis method.
Tt>u results indicate that witnin acceptable tolerance, tne as-constructed piping configuration tor the cuntain>>>cut spray system agrees witn the as-designed configuration, including pipe support types and locations.
There iS one Unit 2 design ISO>netrlc (47w437-2uu, Hevision l3) that is not identical to its corresponding as-constructed Isometric The design Isometric is a mirror image (opposite hand) of the as-constructed isometric.
The design isometriC shows Unit I piping cunfiguration; however, note 24 of the drawing states that this isometric is opposite hand for Unit 2 ~
Thus, the as-cunstructed Iso>netric and pipe support drawings are in agreement The issue of opposite hand drawtngS iS addreSSed in N8N Element 204 '
'n addition, tne as-constructed piping iSOmetricS were reviewed for the presence of field welds as the CI's reference tu "weld map" was interpreted to mean the location of such welds.
8ecause field weld locations are nOt SnOwn On the deSign iSOmetriCS, the Only field WeldS that can be verified for locations are welds for fittings (elbows, tees, etc.).
'These welds were verified by comparing tneir locations in the as-constructed iSOmetriCs with a fitting Shown in the design iSOmetriCS.
The field weldS Were fOund tO be appropriately shown on the as-constructed isometrics.
- d. Using TVA's computer list of rigorous analyses, the evaluation team was able to determine which portions of the contain>>ant Spray SyStem were analyzed by the kiyorous Analysis u>etnoa.
- ISSUES, FINUINBS, ANU CUkklCTIVE AlTIUNS FVK SUBCHIEBURY 212UO F indings Corrective Actions kEVISION NUHBEK: 3 Page B-IO of 19 Element 212.2 - MBN (Continued) e.
- e. All piping shuwn on tne COntainnient Spray syStem flow diagrdm (drawing 47H812-), Revision 21) was verifie'd as being appropridtely analyzed by the kigorous or Alternate Analysis methods with one exception.
- 7) consists of three phases.
- However, TYA has issued policy a~norandum PM Ub-10 (Ref.
- complete, but the ma3ority of the Phase II work has not yet begun.
- 15) identified the lack of adequate tracking of diSCrepanCieS, ineffeCtive Scheduling and control, lack of an overall plan to provide final response to this
- bulletin, anu lack of IIA involvenent in this program.
- iiowever, since the two drywell spray headers are covered under tne Itd 79-)4,programma ano the spray heaoer in the torus is cover>>db ululer lho I TTIP wllirh ini')utlos lho IER 7v 14 requirvilielbtSt tne aS-CunStruCted CunfiguratianS <<ill be reconcileu with tile as-designed conbigurab,ions.
- f. Tne Pnase I inspuctiun walkouwn fur drywell purge system piping support H-U7 siiows potential for interference outweeii the pipe and tiiu support framing.
- ISSUES, FINU)NGS, ANU CORRECTIVt'. ACTIOHS Fbk SUBCATEGORY 2)200 REVISION-NUHBER: 3 Page 8-14 of 19 Issues Findings Corrective Actions El'ement 212.2 -
- 4. iiu procedure for Phase II has been referenced for BYllefonte.
- 10. 1-8 will be'ssued and training complete by iiovemoer 30, 1987; also this procedure will replace CEB-EP 21.30 ano supersede BLEP-OB.
- b. ttu uesign calculations tu resolve aiscrepancies iuentifieu by tne It Uulletin 79-14 program have been go<<crated as the progra>>t has not been implemented.
- c. Ine cuntatn>>ient spray (ttS) system is rigorously analyzed witlt the erception of small portions of piping which are alternately analyzed or qualified by Ctd Ul-bb (ttef. Itt3).
- u. Installation ot the containi>>ent spray syste>>t (Keactor 8ui lding spray
- 1 1 1 1 1 1 1 1**1 1 1 1 1*1 Element 212.3
- 1**11111111111 Hanger Prugrmg SI)N (N/A)
- 72) cited in the statement of concern.
- However, any nllalitatiVe I Valuat iun nf Imriell'c IJocinn ttnrk mlalst
- FCNs, due tu changing f.ield conditions.
- ISSUES, F ltiulht'S, tdlu CUXKECTIYL ACTIUNS FVK SUUCATEtsUKY 212UO Findings Corrective Actions REVISIVtt tiUHUEK: 3 Page 8-1U of lg Element 2I2e3 - RUN (Continued) c.
- d. ILK StdtistiCs CannOt oe uSed aS the Sole criterion for 3udging tne quality of design work; valiauS faCtorS
- ChangeS, ChdngeS Dy.Other disciplines, interterence with reinforcing oar, etcet may contribute to a tiigil number oi ICKs.
- cnecking, and four were modified because oi differences between assumed oeslyil dnd t letd
- checking, wnich is not significant.
- 041411 ~ 100***i*14 SQN (N/A)
- a. Ihe evaluation team reviewed 28 (Ref. gU) ranoomly selected pipe supports (with revisions) from several safety-related SystemS.
- NaweVer, nO inStanCe WaS fOund Where a
- design, as
- ECNs, and Nonconformance deports (NCks].
- systems, interference in the field, utilization of material avai laule, anu piping systems not installed as per deSign drawingS.
- Support, and Fabrication of Piping Systems,"
- 1. 14, R10 "Engineering Recor'ds - Retention and Storage,"
- 5. 14, R4 "Vendor Documents - Handling and Disposition," (03/28/85) 20.
- Packages, TTB 022, TTB 068:
- N3-67-24A/R5, dated 01/28/86 o
- R21,
- 1015, TTB 192),
- Ounham, Manaqer of Fngineering Oesign to Those List, "Program to Resolve NRC IE Bulletin 743-14,"
- E55, Rev.
- E56, Rev.
- E57, Rev.
- E55, issued ll/08/68
- E56, Rev.
- E57, Rev.
- E32, Rev.
- E56, Rev.
- number3, (04/29/80)
- Piping, 2 -1/2 Diameter and Larger," Rev.
- R16, "Engineering Change Notices (ECNs) Before Licensing - Handling,"
- Notes,
- Notes,
- Notes,
- Notes,
- Notes,
- R16,
Response
to Item 41 of the Bulletin," (RFI
LA27 7'90831'21j, (08/31/79) 40. General Construct:ion Specification G-43; "Supbor't and Installation of Piping Systems in Category I Structures," (TTB 2), (B42 850712 505], RO, (08/20/76), RB, (08/08/85) 41. Memo from R H.
(RFI 1172), [CEB 79'1004 018j, (10/04/79) 42. Memo from R,. H. Ounham, 'ianager of Engineering Oesign to Those Listeel, "Program to Resolve NRC IE Bulletin 79 Supplement," (RF I 1188), lCEB 791219 003], (12/19/79) 43. Telecon. between TVA and i3echtel, IQi4 833, (03'/31/87) 44 'Sstefa CROSH EECW EECW EECW HPCI HPCI Discrepancy Number 080780- 01 8:30-02 042815 101,1 80- 01 81901 1027-1 Uniit Oe,~cription of Piscrepan~c Piping and support Configiiration devi ation NI) axial restraining by a restraint Psping configuration deviation Seismic supports will fail under dIasign load Incomplete hanger, installation Oamaged (failed) pipe support 0 3856D-R2 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 21200 REVISION NUMBER: 3 Page C-7 of 15 Discrepancy ~Ss tern Number Unit Description of Discrepancy RCW RHR RHR RWCU RWCU FW CS FPC 052086-02 325-01 121780-72 093080-04 121080-03 092980-02 1213-04 201-01 HPCI 101480-04 2 MS 220-07 1 RBCCW 523-02 1 RBCCW 091580-02 2 RC I C 121980-05 3 RCIC 1217-06 1 Pipe whip restraint acts as vertical restraint Spring hammer with insufficient travel Piping and support configuration deviation Piping configuration deviation Piping configuration deviation Additional restraints and deleted gravity supports, Missing pipe supports Snubber ineffective Piping configuration deviation Missing pipe supports Missing pipe supports Piping configuration deviation Pipe support weld not per design Spring hanger bottomed out 45. Pittsburg-Des Moines Steel Company Erection Drawings: Uni.t 1
A
F 1
03 Unit. 2
C
C2
Cl Unit 3 E55, Rev. C2
84 E57, Rev. 84 46. 47. 48. 49, 50. MMI 99 Data Cover Sheet and Drawing Configuration Checklist for Unit 2 Orywell Spray Header System," [no RIMS number], (09/28/80) Civil Engineer inq Branch Report CEB-84-20, "Stress Intensification Factors for Drowns ferry, Sequoyah, Watts Bar, Bellefonte," (TT8-259-6), [CEB 840906 002j, (09/06/84) Drawing 47W452-224, "Nl-274-3R Isometric Torus Analyses of RHR System Pen. X-210 A and 8, X-211 A and 8," Rl, (04/26/84) Maintenance Instruction MI-6.17, "Instructions for the Implementation of NRC IE Bulletin 79-14," Rev. 2 (05/13/80), Rev. 0, (RfI 516), [no RIMS
Maintenance Instruction MI-6.17A, "Instructions for the Implementation of Isometric Walkdown," Rev. 3, (Ol/02/81), (RFI 631), Rev. 0, [no RIMS number j, (07/08/80) 38560-R2 (11/19/87)
'lVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUIMBER: 21200 REV IS I'ON NUMBER: 3 Page C-8 of 15 51. Maintenance Instruction MI-6. 17C, "Procedure for the Implementation of NRC IE Bulletin 7'9-14 f<equi rements For Unit 1 Alternately Ana'lyzed Safety Related
1, (RFI 631), (08/20/82, Rev. 0, [no RIllS number], (01/12/82) 52. Maintenance Instruction MI-6.18, "Instructions. for Review of Isometrir Walkdown DiscrepanciesTech'nical Specification Application and Initiation of EN f)ES Recommended Corrective'c'tion," (sampling program, i.e.; Bulletin 79-14), Rev. 0, (RFI 631),'ho 'RIMS 'nurhber], (07/21/80) 53. Inspection of Piping and 'Supports - IsOmetrhc Walkdbwn Procedure No. SON-80-04, SQN Unit 2, Phase I, (RFI 732), [SWP 801024 001], (10/20/86) 54. Walkdown Inspectidn Procedure SQN-80-09 for Alteznately Analyzed Piping, (RFI 732), [SWP 801024 001], ( 10/20/80) 55. Inspection Procedure Phase II, SQN Unit 2, "Pr'ocedure 'for the Implementation of NRC-OIE Bulletin 79-14,'" Rey'. l, (RFI 531), [CEB 810225 005], (03/06/81), f<ev. 0, (02/20/81) 56. Procedure for the Implementation of NRC-OIE Bulletin 79-14, "Discrepancy Evaluation Criter'ia Phase II," Rev. 2, (RFI'32)'CEB 810225 005], (05/21/81), Rev. 0, (02/20/81) 57. RF I SQN-663, (10/I?8/86) 58. Flow Diaqram, Drawing 47W812-1,, Rev. 12, '(RFI '698), [no f<IMS number], (06/11/85) 59. CFB 76-5, Alternate analysis, criteria of Watts'<hr Itive:le<Sr-Plant, R3, f CEB 830613 026 ], (06/13/83) (Binder 36A) 60. CER 80-5, Alternate analysis criteria of Seguoyah Nuclear Plant, Rl, (RFI 559), [no RIMS number], (06/24/75) 61. Desiqn isometric drawinqs by EDS Nuclear '(nbw Imfiell), (RFI 698),, [no'IMS number]: 0600102>>01-01, 0600102-01-02, 0600102-01-03, 0600102-01-04, Rev. 913 IRev. '914 Rev. '911 IRev. 911 62. TVA - SQN isometriic drawings [no RI4lS number], drawings reviewed at jobsite: 47K406-57, Rev. 5 47K406-58, Rev. 3 47K435-50, Rev. 5 3856D-R2 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 21200 REVISION NUMBER: 3 Page C-9 of 15 47K435-51, Rev. 3 47K435-53, Rev. 6 47K437-50, Rev. 4 47K437-51, Rev. 5 47K437-52, Rev. 3 47K437-53, Rev. 3 47K437-54, Rev. 2 47K437-55, Rev. 1 63. As-constructed drawings by National Valve and Manufacturing Co., TVA Contract 71C33-92615, (RFI 698), [no RIMS number]: A-7479, Rev. 2 A-7481, Rev..F2 A-7482, Rev. F4C A-7483, Rev. R2 A-7485, Rev. F4B A-7204, A-7206, 8-7207, A'-7208, A-7210, Rev. 5 Rev. 3 Rev. 5 Rev. 3 Rev. 6 64. As-designed support detail drawings by Chicago Bridge & Iron Company for the problem 0600104-01-01, (RFI 606), [no RIMS number j: CB&I 69-5545-74, CB&I 69-5545-75, CB&I 69-5545-87, CB&I 69-5546-309 CB&I 69-5545-310 CB&I 69-5545-311 CB&! 69-5545-312 CB&I 69-5545-305 CB&I 69-5545-307 CB&I 69-'5545-308 CB&I 69-5545-313 CB&I 69-5545-314 Rev. 901 Rev. 906 Rev. 903 Rev. 1 Rev. 2 Rev. 2 Rev. 1 Rev. 4 Rev. 1 Rev. 2 Rev. 1 Rev. 2 65. As-constructed and/or as-designed support detail drawings by Basic Engineers for the problem 0600104-01-01, (RF I 606), [no RIMS number]: DWG. REV. DWG. REV. DWG.P REV. 1'-H21-1 1-K21-'2 1-H21-3 1-H21-4 1-H21-5 1-H21-6 2 2 2 2 6' 1-K21-7 1-H21-14 1-H21-15 1-H21-16 1-H21-17 1-H21-18 4 4 4 4 5 ~ 7 1-H21-30 1-H21-31 1-H21-32 1-H21-33 1 2 1 1 3856D-R2 (11/19/87)
TVA EMPLOYEE: CONCERNS SPECIAL PROGRAM REPORT NUMBER: 21,200 REVISION NUMBER-3 Page C-10 of 15 66. As constructed and/or.as-desiigned support detail drawings by Basic Engineers for the problem PN2-72-01A, (RFI 532), fno RIMS number]: DWG., REV. O'WIG. REV. DW(i. REV. 2-H21-409 2-H21-410 2-H21'-.411 1 2-l.l21-41 2 3 2-H21-41 5 1 1 ,'2-HI21-413 1 4 2-l 121-414 1 67. As-constructed and/or as-designied support detail drawings by Basic Enqineers for the problem 8N2-72-03A, (RF I 604), Lno RIMS number]: DWG. 2-H2!1-41 6i 2-H21-417 2-H21-41 8 2-H21-419 2<<H21-420 2-H21-421 2-H21-422', 2-H21-423 903 1 2 1 2 2 2 3 2-l l21-424 2-H21-42'5 2-H21-426 ',2-H'i21-42'7 2-l',121-4 28 2-HI21-42'9 2-H21-430 2-HI21-431 1 ' 1 ll 1 1 ll. 2 2i-H21-432 2'-H21-433 2i-H21-434 2-H21-436 2'-H21-437 2i-H21-438 2'-K21-439 REV. DWIG. R'EV. DW(1. REV. 4 1 1' 1 1 1 1 2 68. EDS piping analysis calculation 0600104-01-01 (inside containment), (RFI 698), [no RIMS number], (10/19/79) 69. TVA piping analysis calculation N2'-72-01A (outside containment), (RF I 532), fno RIMS number], (06/06/81) 70.. TVA pipinq analysis calculation N2'-72-03A (outSide containment), (RF I 604), -[no RIMS number ], (04/24/80) 71. Civil Enqineerinq IBranch Report CEB 80-76, "Bellefonte Nuclear Plant Units 1 and 2 Progir am P',lan for IE Bu'lletin 79-14," no revision (RFI 1515, TTB 314), [CEB 820114 CI27'], '(08/19/81) 72. Civil Enqineering Branch Report CEB-EP 21,30, Reviewing Revisions to Pipinq System Drawings for Possible Rigorous Reanalysis - Verifying that Rigorous Analysis or Reanalysis is Applicable to As-Constructed Configuration," TTIB 420-3, f842 851113 50(tl], R2, (11'/1,3/85) 73. Engineering Procedure BLEP-08, "Verification of AS-Constructed Input Information for Non-R,igorous Seismic Analyse's of Safety-Related Pi pi'ng Systems," TTB 420-.3, LB42 850411 500], Rl, (04/24/85) 74. General Construction Specification G-43, '"Support and Installation of Piping Systems in Category I Structures," (TTB 2)< [B42 850712 505], RO, (08/20/76), R8, (08/08/85) 3856D-R2 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 21200 REVISION NUMBER: 3 Page C-11 of 15 75. Design Criteria Diagram Reactor Building Spray System 32BW0615-NS-Ol, TTB 341-3, R16 (10/19/85) 76. Piping Isometric Drawings, TTB 341-3, TTB 368-3, and TTB 383-4 1AW1416-NS-A2 Rl 1AW1416-NS-A3 RO lAW2416-NS-Al RO 1AW0416-NS-Cl R4 1AW0416-NS-01 R5 1AW0416-NS-El R4 1RW1415-NS-Fl Rl 1RW1415-NS-F2 R 1 1RW2415-NS-Fl Rl 1RW2415-NS-F2 Rl 1RW1415-NS-Kl Rl 1RW1415-NS-K2 RO 1RW2415-NS-Kl Rl 1RW241 5-N S-K2 R 1 lAW1416-NS-Ll RO 1AW1416-NS-Ml RO 1AW2416-NS-Ml RO 1AW1412-ND-Al R6 lAW2412-ND-Al R8 1AW1412-ND-A2 R 1 1AW241 2-ND-A2 Rl 1AW0416-NS-A2 R3 77. WB-DC-40-31.3, "Detailed Design Criteria for the Assignment of Responsibility for Analysis, Support, and Fabrication of Piping Systems," IESB 841012 201 3, (10/04/84) 78. Enqineering Procedure EN DES-EP 4.02,
[ESB 840719 206], (07/23/84) 79. Enqineering Procedure EN DES-EP 4.03, Rll, "Field Change Requests Initiated by Construction," t.ECB 841203 502], (ll/21/84) 80. Field Change Requests (FCRs) and associated drawings: Affected Drawing Number Revision 47A406-2-35, R3 47A406-12-60, R2'2-2CVC-R54, R2 2-63-490, R902 2-62A-2810 R902 2-63-020, R902 2-62A-713, R902 2-63-250, R903 2-62A-364, R903 2-63-016, R902 62-2CVC-R214, R903 62-2CVC-R117, R903 62-2CVC-R217, R903 FCR Number H-13324 H-13652 H-13835 H-13884 H-13924 H-14315 H-14584 H-13673 H-13621 H-13586 H-13664 ,H>>13608 H-13607 System Number 62 62 62 63 62 63 62 63 62 63 62 62 62 RIMS Number C24 850410'13 . C24 850618 305 C24 850528 338 C24 850523 342 C24 850528 343 B26 850910 069 826 850916 111 C24 850624 300 N/A C24 850618 303 C24 850523 330 C24 850604 317 C24 850416 329 3856D-R2 (11/19/87)
TVA 'EMPLOYEE CONCEIRNS .'iPEC IAL PROGRAM REPORT NUMBER; 21200 ~ FIEVISION NUMBER: 3 Page C-1'? of 15 Affected Drawing Number Revi.'ion FCR System Number Nj>mberu R IMS Number 62-2CVC-R45, R904 2-,63-309, R903 47A435-14-56, Ft902 62-2CVC-R'175, R902 2-63-350, R903 62-2CVC-RI?48, FI902 2-63-352, R902 H-13594 Hl-1:3529 H-13379 H-13349 H-13277 .H-13266 H-13184 62 63 62 63 62 I 631 N/A C24 850614 31:3 C24 850405 347 C24 850318 419 C24 850325 300 C24 850606 320 C24 850308 331 81. Watts Bar Nuclear Plant - Piping Analysis and 'Hanger Design Meet,ing
[C24 850327 600], (0.'3/26/85) 82. Watts Bar Nuclear Plant - Piping Analysis and Hanger Design Meeting
[C24 850409 600], (04/09/85) 83. Watts Bar Nuclear Plant - Piping Analysis and Hanger Design Meeting.
[C24 850508 601]; (05/07/85) 84. Watts Bar Nuclear Plant - Piping Analysis and Hanger Design Meeting
[C24 850522 600], (05/22/85) 85. Watts Bar Nuclear Plant - Piping Analysis and Hanger Design Meeting
[C24 850723 600], (07/23/85) 86. Memo, from V. R. Defender (CEB) to CEB files, subject: WBN - Design review of unit 2'ipe support callculatiolas,'841'>0>09 005], (05/09/85) 87. Number of FCRs and Suplport Designs for Systems 01, 03 62, 63, 72, and 74 for Impell, TVA and Gilbert/Commonwealth,, (RFI 047), (05/06/86) 88. Constructibility Program (OASES) IOM 1723, '(08/17/87) 89. Watts Bar Nuclear Plant - Space Reservation for Support [C24 850328 006 and C24 850430 005], (03/28/85) and (04/30/85) 90. Field Change Request:s (FCRs), Support Mod'fication Requests (SMRs) Nonconformance Repor'ts (NCRs), et;c. FCR/SMR/NCR Number FCR C-0144 FCR C<<126;I FCR C-1889 FCR K-4180 FCR H-3454 Affected Drawing INumber~R ev i s ion 1KC-PIPHG-1702, RO 1RI;-MPHG-4133F, Rl 1VC-bl!PHG-0005F, Rl 1RI=-I IPHG-339Ii, Ro 1WID-MIPHG-0086, Rl R, IMS Number C20 8505(?2 902 INone INone BLN 831025 610 BLN 830331 587 Date 04/03/85 09/11/85 03/05/86 10/20/83 03/28/83 I0 3856D-R2 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 21200 REVISION NUMBER: 3 Page C-13 of 15 FCR/SMR/NCR Number FCR H-1553 FCR H-1185 FCR H-1206 FCR H-742 FCR C-0082 NCR-3555 SMR-15898 SMR-881 SMR-1924 SMR-12436 SMR-10490 SMR-6823 SMR-6412 S'MR-12775 SMR-8978 SMR-6522 SMR-1098 SMR-7996 SMR-563 SMR-1290 SMR-12893 SMR-6887 SMR-7236 SMR-1908 SMR-14886 SMR-12765 SMR-7956 SMR-14347 BNC-8091 Affected Drawing Number, Revision ORF-MPHG-5833, RO ONM-MPHG-0459, Rl ONM-MPHG-0459, Rl 2RK-MPHG-0128, R4 2RK-MPHG-0128, R6 1WO-MP HG-0086, R2 2NK-MPHG-1643, RO 1CA-MPHG-0050-1, RO 1CA-MPHG-0050-2, RI 2NO-MPHG-0065, R2 2CF-MPHG-0285, RO 1KE-MPHG-0781, R2 1KE-MPHG-0781, Rl 1NL-MPHG-0136, Rl ONM-MPHG-0903, RO 1R K-MPHG-001 3, R2 1RK-MPHG-0013; RO 2VE-MPHG-4018, R2 2VE-MPHG-4018, RO 2VE-MPHG-4018, Rl 2VE-MPHG-4018, R4 1WD-MPHG-0006, R2 1WO-flPHG-0006, R3 1WD-MPHG-0006, RO 1WO-MPHG-0006, R6 1WD-MPHG-0006, R5 1WO-MPHG-0006, R4 2RK-MPHG-0079, R3 2RK-flPHG-0079, R2 RIMS Number BLN 860417 306 BLN 810901 588 BLN 810910 598 BLN 810410 596 'C20 850425 904 BLN 841205 107 None None None None None None None None None None None None None None None None Hone None None None None None MEB 821119 158 Date ll/26/85 08/26/81 08/31/81 04/06/81 03/28/85 12/03/84 05/25/84 08/16/78 02/14/84 07/09/82 12/19/81 01/26/81 11/05/80 08/30/82'8/28/81 12/15/80 09/27/78 06/04/81 06/20/78 ll/01/78 09/22/82 02/05/81 03/16/81 02/24/79 09/07/83 08/20/82 06/02/81 06/03/83 11/22/82 91. iqineering Procedures EN DES-EP 4.02 for engineering change notices =CNs) befo're licensing - handling (TTB-2), (ESB 840719 206),
')7/23/84), RO, (09/04/73) 92. ~qineering Procedures EN DES-ED 4.03, for field change requests (FCRs) equested by construction, (TTB-2) [ECB 84 1203 502), Rll, (ll/21/84), RO 39/28/73) k 93. ffice of Engineering (OEP) - 11 for change control, (TTB-2),'no RIMS umber], RO, (04/26/85) 3856O 72 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL IPROGRAM REPOR1 NUMBER ". 21200 REVISION NUMBER: 3 Page C-14 of 1IS 94. Watts Bar Engineering Project (WII3EP) EP 43.03, for Field Change Requests, (TTB-2) [no RIMS number],, RO, (09/27/85) '95. WBEP-EP 43.02, for Engineering Change Notices, (TTB-2), [no RIMS number], RO, (09/27/85) q6. American National Standard ANSI/MSS SP-58, 1975 Edition 97. Pipe Supoort Design Manual, Volume 3, Section 7.8, (T'1B-2),, [no RIMS number], R2 (0!6/12/85) 98. Pipe support drawings: 67-lERCW-R212/903 1-10A-309/907 47A4SO-2'1-128/3 47A437-3-1/3 47A427-8-38/1 47A464-4-2/2 47A060-62-27/2 1-63-349/906 1-01A-380/910 47A400-6-266/2 47A437-4-I62/Il 63-1515-V132/1 1-63-404/904'-74-11/907 47A540-4-'17/1 47A060 77~5/~1 67A400-1/3 47A060-74-'1'/1 47A400-21/4 47A400-6-)48'/3i 47A465-2-38/1 '7A060-'70-27/3 47A060-3-23/2 47i>437-2-22/1 2-;$ 0-804/901 47A060-26-42/1 47A400-12/2 '1-63-'347/901 99. HRC letter to TVA, Suhject: Report Ho. .i0-'328/81-27 (NRC inspection of Unit 2 IE Bulletin 79-14 proqram compTetion), (Rl'I '735), [A02 910717 00:3]; (07/16/81) 100. HRC letter to TVA, Suhiect: Report Hos.'1)'/327/81-32 and ;0-328/81-42 (Closure nf IE Bulletin 79-'14 F'r Unit 2), (RFI /3b), iA02;311019 014J, (10/18/81) 101. Comnliance vis'its, Audits, and Insoectiohs I-Iinpilant Survey Check List 21-86-S-005, 79-'14 Ha'nger Review Program (RF I 551), [no RIMS nu!mber], (02/28/86) 102. Memo from W. C., Orotle Ff, 0'irector of Nuclear Engineering, and R. R. Kelley; Dir!ector of Nuclear Quality Assurance', to Those Listed,'Policy Memo PM 86-10 (OHE) - IEngineering Assurance Chiarter and Responsihilities,"'RF I 1285), [001 860702 002], (07/03/86) 103. Civil Enqineerinq Branch Report CEB 81-56 (BLN), "Qualification of Smklli Line Attachments to ASME Class 2 and 3 Piping," TTB 368-2,, ['CEB 840202 003], (02/02/84) 104. Civil Enqineering Branch Repor't C'EB 76-.11 (BLH), "Bellefonte Nuclear'lant Alternate Criteria for Piping Analysi,s and Support,," TTB 327-5,'CEB 840106 027], (ll/78), R2, (01/02/84) 3856O-R2 (11/19/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER: 21200 REVISION NUMBER: 3 Page C-15 of 15 105. Memorandum with attachment from WBN FCR Hanger Review Team to D. B. Bowen and R. A. Pedde, [C02 85031.9 101], (03/19/85); attachment: FCR study by Office of Construction (01/85) 106. Memo.from Guenter Wadewitz to W. H. Thompson, WBN - Request for Investigation/Evaluation, (TTB-2), (RF I WBN-343), [no RIMS number], ( 11/06/85) 3856D-R2 (11/19/87)
I ~, ~ ++AC g 4 4 iP}}