ML18033A582
| ML18033A582 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 11/24/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 22300, 22300-V02-R03, 22300-V2-R3, NUDOCS 8902150226 | |
| Download: ML18033A582 (62) | |
Text
EMPLOYEE CONCERNS SPECIAL PROG VOLUME2 ENGINEERING CATEGORY SUBCATEGORY REPORT 22300 INSTRM8ENT SUPPORTS DESIGN UPDATED NUCLWQt PO%ER
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT TYPE:
SUBCATEGORY REPORT FOR ENGINEERING TITLE:
INSTRUMENT SUPPORTS OES IGN REPORT NUMBER:
22300 REVISION NUMBER:
3 Page 1 of 25 2.
3\\
Revised to incorporate initial SRP and TAS comments and latest element evaluation status.
Revised to incorporate additional SRP canments and BLN CAP.
Revised to.incorporate additional SRP and TAS ccmnents; revised Attachments A and B; added Attachment C (References).
io xZ-57 REVIEWS OA A:
APPROVEO 8
CONCURRENCE (FINAL REPORT ONLY)
SRP Secretary's signature denotes SRP concurrences are in files.
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER:
3 Page ES-1 of 2 EXECUTIVE
SUMMARY
Subcategory
- 22300, Instrument Supports
- Oesign, addresses five employee concerns about the design and installation of instruments and instrument line support connections.
The concerns cited perceived problems with torquing of connection bolts, failure of instrument tubing clamps, adequacy of instrument mounting brackets, and seismic qualification of locally mounted instruments.
The evaluation substantiated the claim that certain deficiencies exist at all four nuclear plants relative to the torquing of bolted connections for instrument line supports.
At the two nuclear plant sites (Sequoyah and Watts Bar) evaluated for the adequacy of instrument mounting brackets, it was determined that the structures were capable of withstanding the most severe loads in Engineering's design bases.
However, it also was determined that mounting brackets for safety-related instruments could be subjected to damaging abuse in areas of heavy traffic.
The evaluation found that documentation for the seismic qualification of locally mounted instruments at the Sequoyah plant was incomplete.
Walkdowns, document revisions, retorquing, inspections, and evaluations are necessary to resolve the findings.
The orincipal causes of the validated issues were ineffective communications, inattention of first-and second-line engineering supervision to the enqineerinq construction interface, and incomplete design detail.
- Further, TVA's incomplete attempts to perform its corrective actions committed to for element 223.3 reveal continued inattention to detail of first-and second-line supervision.
Beyond the specific issues related to design adequacy of instrument and instrument line supports, the oversights found in a number of TVA design output documents indicate broader deficiencies, in Engineering's attention to details.
The design of nuclear power plants requires addressing many items not generally considered in nonnuclear applications.
Accordingly, there is a
need for first-and second-line engineering supervision to be better trained in the special requirements of nuclear power plant design, particularly in the area of design documentation.
A review of the Nuclear Performance Plans (Ref. 4) by the evaluation team revealed that TVA's efforts will be beneficial to its nuclear program when fully implemented; Strengthening the Branch Chiefs'rganizations, increasing technical training, and adding the Engineering Assurance organization to perform technical audits are the principal enhancements related to this subcategory that are described in the NPPs.
27340-R28 (10/15'/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER",
23 0
REVISION. NUMBER:
Page ES-2 Of 2 The findings of this subcategory are combined with those of other subcategory reports and reassessed iri the Engineerinej chte'gor'y evaluation, which has assessed the broader issues identified and has'ssued the necessary correcti~e action tracking documents.
2734D-R27 (10/14/87}
D
Preface.
- Glossary, and Li.st of hcruoyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUMBER PhGES REVISED REhSON'OR CURRENT REVISION To clarify that, one or more attachments will help the reader find where a particular concern is evaluated
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TVh ENPLOTEB CONCERNS SPECZhL PBOGRhN REPORT NUNBER:
22300 FRONT KNITTER REV:
3 PdGB i OF viii Preface This subcategory report is one of a series of reports prepared foc the Employee Concerns Special Program (ECSP) of the Tennessee Valley huthority (TVh).
The ECSP and the acganizati,on which carried out the pcogram, the Employee Concerns Task, Group (ECTG), were established by TVh's Nanager of Nuclear Powec to evaluate and cepoct on those Office of Nuclear Power
<ONP) employee concecns filed before Febcuary 1,
1986.
Concerns filed after that date are handled by the ongoing ONP Emplayee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns.
'Each of the concerns was a
formal, written description of a circumstance oc circumstances that an employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concecns Special Program was to thoroughly investigate all issues presented in the concerns'and to ceport the results of those investigations in a form accessible to ONP employees, the NRC.
and the general public.
The results of these investigations are communicated by four levels of ECSP reports:
element.
subcategocy,
- category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restact of Sequoyah Nuclear Plant's reactor unit 2.
hn element consists of one oc more closely celated issues.
hn issue is a potential problem identified by ECTG during the evaluation pracess as having been raised in one or moce concecns.
Far efficient handling, what appeared to be similac,concecns were grouped into elements early in the program, but issue definitions emerged fcom the evaluation process itself.
Consequently, some elements did include only one issue, but often the KCTG evaluation found more than ane issue pec element.
Subcategory reports summarize the evaluation of a number of elements.
- However, the subcategory cepoct does moce than collect, element level evaluations.
The subcategocy level ovecview of element findings leads to an integration of information that cannot take place at the element level:
This integration of infocmation ceveals the eztent to which problems overlap more than one element and will therefore cequice corrective action for undeclying causes not fully apparent at, the element level.
To make the subcategocy reports easier to understand, three items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and
~ list of acronyms, hdditionally, at the end of each subcategocy report will be a Subcategory Summary Table that includes the concern numbers; identifies othec subcategories that share a concern; designates.nuclear safety-celated.
safety significant, oc non-safety celated concerns; designates generic applicability; and bciefly states each car(cern.'ither the Subcategory Summary Table oc anothec attachment oc a combination of the two will enable the ceadec to find the cepoct section oc sections in which the issue raised by the concern is evaluated.
TVh EHPLOTEE CONCEBNS SPECIhL PROGRiLlf BEPORT NUNSER:
'22300'RONT RITTER REV:
2 I
PhGE ii OF viii The subcategories are, themselves s'ummarized in a series of eight category repo'rts.
Each category report reviews the major findings and colldctive'ignificance of the subcategory reports in one.of the following areas:
management and personnel relations industrial safety construction material control operations quali ty assurance/duality,control welding engineering h separate report on employee concerns dlea(in'g ~lith specific contentions of intimidation, harassment, and wron)do'ing w(11 be released by the TVk Office of the Inspector General.
Just as the subcategory reports in/egrate the informatiori collected at the element level, the category reports iktlgrite'he informati,on assembled in all the subcategory reports within the category, addressing part'icularly'he, underlying causes of those problems that run across more tha'n aine subcategory.
h final report will integrate
.and assess the inforaiation collect'ed 'by'all of the lower level reports prepired for 'the
- ECSP, i.ncluding the Inspekto~'r General's report,.
For more detail on the methods by which ECQG employee concerns w'erd evaluated and reported, consult thl Tlsnneskee Vali<'~y iluthority EdpI,'oy$ e Concerns Task Group Program Nanual.,
The Nanual spells out the program's objectives,
- scope, organization, a6d kespodsibil'ities.
It alamo
'spelcidie's the procedures that were followed in,ithe'kvestigation, reportin'g, and closeout of the issues raised by esiployee concerns.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 FRONT MATTER REV:
2 PAGE iii OF viii ECSP GLOSSARY OF REPORT TERMS~
classification of evaluated issues the evaluation of an issue leads to one of the following determinations:
Class A:
Issue cannot be verified as factual'lass B:
Issue is factually accurate,,but what is described is not a
problem <i.e., not a condition requiring corrective action)
Class C:
Issue is factual and'dentifies 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, requiring corrective action, which was not identified by an employee
- concern, but was revealed during the ECTG evaluation of an issue raised by an employee concern.
collective si nificance an analysis which determines the importance and consequences of the findings in a particular ECSP report by putting those findings in the proper perspective.
concern
< see "employee, concern".)
corrective action steps taken to fiz specific deficiencies or discrepancies revealed'y a negative finding and,: when necessary, to correct causes in order to prevent recurrence.
criterion lural:
criteria a basis for defining, a performance,
- behavior, or quality which ONP imposes on itself <see also "requirement" ).
element or element re ort an optional level of ECSP report, below the subcategory level, that deals with. one or more issues.
em lo ee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or inappropriate; usually documented on a K-form or a form equivalent to the K-form.
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TVh EMPLOYEE CONCERNS SPECThL PROGRhlf REPORT BASER: '2300 FRONT KNITTER RPT:
2 PhGE iv OF viii evaluator(s) the individual(s) assigned the responsibility to assess a specific grouping of'mpiloyee concerns.
~findin s imnlades both statements of yaot and the jndtmants made abont those facts dluring the evaluation process; neIgative findings require corrective action.
issue a potential problem, as interprdted bIjr t'e ECTG during the evaluation
- process, rai,sed in one or more concerns.
K-toom (sae "demployea oonaesn" i evaluation judgment or decision may be based.
root cause the underlying reason for e problem.
>Terms essential to thai program but which require detailedl definition hisve been defined in the ECTG Procedure Nanual (e.gas generic,,
specific,,
nuclear'afety-relatedl, unreviewed,safety-significant question).
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAN dEPORT NUNBER:
22300 FRONT NATTER REV:
2 PAGE v OF viii
-hcronyms AI Administrative Instruction AISC American Institute of Steel Construction ANSI AMS BFN As Low As Reasonably Achievable American Nuclear Society American National Standards Institute American Society of Mechanical Engineers American Society for Testing and Materials American Melding Society Browns Ferry Nuclear Plant CAQ CAR CATD CCTS Bellefonte Nuclear Plant Condition Adverse to Quality Corrective Action Report Corrective Action Tracking Document Corporate Commitment Tracking System CEG-H Category Evaluation Group Head CFR CI CNTR COC OCR DNC Code of Federal Regulations Concerned Individual Certified Naterial Test Report Certificate of Conformance/Compliance Design Change Request Division of Nuclear Construction (see also NU CON)
TVd lBSPLOYEE CONCERNS SPECZhL PROGRhH REPORT NUNBER:
'22300'RONT
ÃhTTER REV:
2 j
PhGE vi OF viii ONE ONQh DOE DPO OR ECN ECP ECP-SR ECSP EEOC EQ Division of Nuclear Engineering Division of Nuclear Quality hssurance Divis.ion of Nuclear Training Department of Energy Division Personnel Officer Discrepancy Report or Deiriation Report
,Engineering Change Notice Employee Concerns Program Employee Concerns Program-Site Representatiire Employee Concerns Syecial Program Employee Concerns Task Group Equal Employment Oyyortunity Commission Environmental Qualification Emergency Hedical Response Team
~I EN OES Eng:ineer i'ng Des ign ERT FCR FShR GET HCI HVhc Employee
Response
Team or Eatergency Resyonse Team Field Change Request Final.Safety hnalys i,s Report:
Fiscal Tear General Employee 'Training Hasard Control Instruction Heating, Ventil.ating, hir Conditioning Installat,ion Instruction INPO IRN Institute of Nuclear Power Operations Inspect,ion Reject;[on Notice 0
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TVA ENPLOTEE CONCERNS SPECIAL PROGRAM ctEPORT NUllBER:
22300 FRONT NATTER.REV:
2 PAGE vii OF viii L/R H&AI NSPB NPP NPS Labor Relations Staff Nodifications and Additions Instruction Naintenance Instruction Merit Systems Protection Board Nagnetic Particle Testing Nonconforming Condition Report Nondestructive Examination Nuclear Performance Plan Non-plant Specific or Nuclear Procedures System NQAN 'uclear Quality Assurance Nanual NRC NSB NSQS NU CON Nuclear Regulatory Commission Nuclear Services Branch Nuclear Safety Review Staff Division of Nuclear Construction (obsolete abbreviation, see DNC)
NUNARC Nuclear Utility Nanagement and Resources Committee OSHA ONP OWCP PHR QAP QCI Occupational Safety and Health Administration (or hct)
Office of Nuclear Power Office of Morkers Compensation Program Personal History Record Liquid Penetrant Testing Quality Assurance Quality Assurance Procedures Quality Control Quality Control Instruction
TVk )NP1&XEE CONCERNS SPECLLL PRMRAN REPORT NUlQER".
'22300
'RONT NATTER REV:
2 PAGE vi i.i OF viii
- QCP, RIF Quality Control, Procedure Quality Technology Company Reduction in Force SQN SI SOP SRP SMEC TAS TEL TVTLC UT WBECSP VBN VR Radiographic Testing Sec[uoyah Nuclear.Plant Surve illance Ins tru ction Standard Operating Procedure Senior Revi.ew Panel Stone and 'Webster Engineering Corporation Technical hssistance StaEf Trades and Labor Tenriessee Val!Ley Authority Tennessee Val!Ley Tr'ades and Labor Council Ultrasonic Testing Visual Test,ing
'4/atts Bar Employee Concern Special Program Vatts Bar Nuclear Plant 1dork Request or 14ork Rules liforkplans
TVA EMPLOYEE CONCERNS SPECIAL 'PROGRAM REPORT.
NUMBER:
22300 REVISION NUMBER:
3 Page 2 of 25 Section Executive Summary Preface ECSP Glossary of Report Terms.
Acronyms CONTENTS
~Pa e
ES-1 1
Introduction 2.
Summary of Issues/Generic Applicability 3
Evaluation Process 4
Findings 5
Corrective Actions 6
Causes 7
Collective Significance Glossary Supplement for the Engineering Category 10 12 15 23 Attachments A
Employee Concerns for Subcategory 22300 B
Summary of Issues,
- Findings, and Corrective Actions for Subcategory 22300 C
References A-1 B-l C-1 TABLES Table 1
Classification of Findings and Corrective Actions 2
Findings Summary 3
Matrix of Elements, Corrective Actions, and Causes
~Pa e
17 19 20 27340-R28 (10/14/87) 4C 4
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TVA EMPLOYEE. CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER:
3 Page 3 of 25 1.
INTRODUCTION This subcategory report summarizes and evaluates the results of the ECSP element evaluations prepared under Engineering Subcategory
- 22300, Instrument Suoports Design.
Subcategory 22300 addresses concerns about the design and installation of instruments and instrument lines, along with their respective supports.
The concerns cited perceived problems with torquing of support connection bolts, adequacy of instrument mounting brackets, and seismic qualification of locally mounted instruments.
Five 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 concern app]icability 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 for the element and subcategory evaluations o
Section 4 summarizes, by element, the findings and identifies the negative findings that must be resolved o
Section 5 -- highlights the corrective actions required for resolution of the negative findings cited in Section 4 and relates them to element and to plant site 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 with which the concern is shared, the plant sites to which it could be applicable are noted, the concern is quoted as leceived by TVA, and is characterized as safety
- related, not safety related, or safety significant o
Attachment B -- contains a summary of the element-level evaluations.
Each issue is listed, by element number and plant, opposite its corresponding findings and corrective actions.
The reader may trace a concern from. Attachment A to an issue in Attachment 8 by using the element number and applicable plant.
The 2734D-R27 (10/14/87)
TVA EMPLOYEE CONCERlliS S'PECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBERS 3'age 4 of 25 reader may relate a corrective action description in Attachment B to causes and significance in Table 3 by. using the CATO number whiI.h
'ppears in Attachment B in parenthes'es at the end of the cordective action description o
Atta1chment C liists the references cited in -the text 2.
SUMMARY
OP ISSUES/GENERIC APPLICAGILIYY From the concerns, 12 issues were derived fdr this subCategory.
Some Of theSe issues were evaluated
)For more than one plant, resulting in a total of 31 issue evaluations.
Not all issues app'ly to every'l'ant because nOt all of the employee
- concerns, from which they originate',
appl~ y to every plant.
Applicability determinations of each concern, within~ each'lement,,
were made early in the program, as per ECTG procedure
'ECTG M. 1', Section 7.3, in cooperation wi.th TVA.
The criteria for making the appli cabi lity determinations are in ECTG pr ocedure ECTG M.l, Attachment, E.,
The criteria clearl'y limit 'the determinations of generic applicability to lbe based on circdmstahceh where there is "reasonable factual basis iInot merely speculation)"
fOr 'application to additional plants.
2.1
~Sussaar of Issues A synopsis of the issues, by e1lement, is pre~sented below as an overview.
For the unabridged text of th1e issues, see Attachment 8:
- 2. 1. 1 Instrument Line Support Connections -'lement 223.
1 Instrument line support installation requirements and restrictions, particularly thos1e app1lying to bolt insta'llation And torquing, are not adequately defined.
- 2. 1.2 Instrument Mounting Brackets - Element 223.2 Instrument-mounting brackets are not strong P no'ugh either to support instruments under design,co'nditions or to resist abusive treatment.
2.1.3 Local Instrument Seismic Qualification - Element 223.3 Locally mounted instrument instal'iation details are based on "good engineering judqment" without perform;ing seismic analyses or qua'iification.
2.1.4 Summarized'ubcategor y Issues The issue summa ies above deal with presumed'de'ficiericies
'or inadequacies in the design of the supports or mountings of ihstruments and instrument lines.
27340-R27 (10/14/87)
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 5 of 25 As the following sections show, portions of all of the above summarized, issues were found to be valid and require corrective action.
2.2 Oetermination of Generic A olicabilit The qeneric applicability assignments made are given below:
2.2.1 Element 223.1 Concerns IN-85-398-002 and IN-85-398-003 were evaluated at all four,plants.
Concern PH-85-054-001 was not evaluated at Browns Ferry (BFN) or Bellefonte (BLN) since the drawing series cited in the concern does not exist by number or subject for these plants.
2.2.2 Element 223.2 Concern IN-85-973-002 was evaluated at Sequoyah (SQN) and Watts Bar (WBN) only-and was established to be a plant maintenance issue.
The concern originated at and was specific to WBN.
SQN was also evaluated because it is a sister plant to WBN.
2.2.3 Element 223.3 Concern IN-85-886-N04 was evaluated at SQN only.
After evaluation at SQN, the concern was transferred to the Quality Assurance Category for evaluation and determination of generic applicability under Subcategory 80500.
3.
EVALUATION PROCESS This subcategory report is based on the information contained in the apolicable element evaluations prepared to address the specific employee concerns related to the issues broadly defined in Section 2.
The evaluation process consisted of the following steps:
3.1 Element 223.1 3.1.1 a.
Sequoyah e
Obtained and reviewed the notes on 47A050 series drawings.
and typical support drawings (both civil and electrical/instrumentation) for approved and qualified sizes, numbers,and types of clamps for instrument lines (Ref. 9).
b.
Co Oetermined that Unistrut clamp series P2008-P2102 or other manufacturer equivalent was used of SQN.
Oetermined clamp installation requirements.
27340-R30 (11/17/87)
TVA E;MPLOYEE CONCEIRNS SPECIAL PROGRAM REPORT NUMBER:,
,22300 REVISION NUMBER: 3 Page 6 of 25 d.
e.
Obtained and reviewed previous revisions.of above documents for evidence of changes in require'merits,'.
Reviewed ca'Iculations andi test'e'sulits. to er!sure that the design supports the drawings (Ref.
10').
Rev.iewed applicable
on these issues (Ref. 8).
ge 3.1.2 Reviewed TVA S(3N GC1G Report GCC-13-59 for Employee Concern PH-85-054-001 (Ref. 13).
Reviewed TVA corrective action, plans for CATDs 223 Ol SqN 01', 02,
'nd 03 (Ref. 14);
Watts Bar a.
b.
c ~
e.
3.1.3 a.
b.
C ~
Reviewed TVA memo.-
on the issues (Ref. 12).
Reviewed 47A050 series drawings to determine clamp installation requirements (Refw 9).
Reviewed applicable nonconformance reports (NCRs), significant condition reports (SCRs),
problem identification reports (PIRs)>>
etc.
(Ref.
- 8).
Reviewed calculations and test i es'ulnas ho 'ensurim that the design supports the drawing.; (Ref.
1IQ).
Reviewed C'onstruction Category Rep'ort CO17'203 (Ref.
13)',
Reviewed TVA corrective action plahs for CATOs 223 Ol WBN Ol and 0<?
(Refe 14).
Browr!s Ferry Perrermed a walkdown of selected areas of the reactor bui'IdinIi i) order to inspect typical instrument line supports (Ref. 11).
Reviewed applicable design critdrih aind 'project instructions (Ref. 6).
, Reviewed applicable nonconforman'ce reI>orts (N(Rs), significant condition reports (SCRs),
and problem identification reports (PIRs)
(Ref. 8).
0 d.
Reviewed typical design drawing and calculation (Ref. 9).
e.
Reviewed Construction Category Ri po'rt'CO'l73'03-'BFN (Ref'. 6).
27340-R27 (10/14/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 7 of 25 f.
Reviewed test report for Unistrut clamps (Ref. 10).
g.
Reviewed TVA corrective action plans for CATD 223 01 BFN 01 (Ref. 14).
3.1.4 Bel 1efonte a.
Reviewed typical design drawings and calculations (Ref. 9).
b.
Reviewed applicable design criteria and project instructions.
c.
Reviewed applicable nonconformance repor ts (NCRs), significant condition reports (SCRs),
and problem identification reports (PIRs)
(Ref. 8)..
d.
Performed a walkdown of selected areas of the Auxiliary Building, Control Building, and Reactor Building in order to inspect typical instrument line supports (Ref. 11).
e.
Reviewed Construction Category Report C017303-'BLN (Ref. 13).
f.
Reviewed test reports for instrument tubing clamps (Ref. 10).
g.
Reviewed the quality control procedures for instrument tubing installation (Ref. 13).
h.
Discussed the installation of tubing clamps with field engineers knowledgeable in the installation of these clamps (Ref. 11).
i.
Reviewed TVA corrective action plan for CATO 223 01 BLN 01 (Ref. 14).
3.2 Element 223.2 - Seouo ah and Watts Bar a.
Reviewed FSAR and, design criteria.for TVA's commitments to operating and seismi'c design requirements for Category I instrument supports (Ref,. 5).
b.
Obtained,and reviewed TVA drawing series 47W600 which shows instrument mounting brackets (Ref. 9).
Reviewed various revisions of applicable drawings for evidence of changes in engineering design requirements (Ref. 9).
d.
Reviewed seismic qualification test data, which support design, and performed calculations, as needed (Ref. 10).
e.
Reviewed TVA corrective action plans for CATDs 223 02 SQN 01 and WBN 01 (Ref. 14).
2734D-R27 (10/1 4/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM 3.3 Element 223.3 - S~e~uo yah REPORT. NUMBER:'2300 REVISION NUMBER:
3 Page 8 of 25 0
Reviewed Environmental Qualification (EQ) program commitments (general program for environmental qualification) in SQN Nudlehr
'erformance Plan,,
Volume II (Ref. 4).
b.
Obtained results of Seismic Qualification Review Team (SQRT) audit by INRC.
c.
Determined which instrumentation items were. covered by SQRT audit.
d.
Reviewed FSAR for SQN commitmeht 'foH ihst'rument seismic qua'lifications.
Reviewed Safety Evaluation Report (SER) in the same sections for result.
of NRC review.(Ref. 5).
e.
Reviewed SQN design criteria ahd other'commitments regarding qua'lification requirements (Ref. 6).
f.
Selected and reviewed appropriate samples of qualification documentaticin (Ref. 10).
g.
Obtained and reviewed drawings that sh<')w mounting details (Ref. 9).
h.
Reviewed TVA corrective action plan for CATO 223 03 SQN 01 (Ref. 14).
3.4 Subcateqo~r 22300 a.
Tabulated
- issues, findings, an8 cbrrieckive actions from the isle'merits'n a p'lant-by-plant arrangement (see Attachment B).
b.
Prepared other tables, as
- needed, to permit cottIpar ison and identification of common and uniqI>e issues,
- findings, and corrective actions among the four.plants..
Classified the findings and corrective actiohs from the element evaluations using the ECSP definitio'ns d.
On the basis of'CSP guidelinesI, Analyzed the causes and established the coillective significanre of 'tht'. f'indings fro'm the element evaluations.
e.
Evaluated defined corrective adti6ns to determine if additior>al actions are required as a resul't Of eau'ses found-in Step d.
f.
Provided additional,judlgment or information that may not be apparent at the element level.
2734D-R27 (10/1 4/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER:
3 Page 9 of 25 4.
FINDINGS The findings for each issue from the seven element evaluations for this subcategory are contained in Attachment 8, where they are listed by element number and by plant.
The findings for each element are summarized in the following subsections.
- 4. 1 Instrument Line Support Connections
- Element 223.
1 This element addressed the concern that the design guidance and instructions concerning instrument line support connections were inadequate and the implementation of these instructions produced undesired results.
In general, TVA guidance,.in this area was reasonably clear and technically adequate although some enhancements were necessary at all plants in the area of requirements for bolt tightening.
Other findings were that a number of unauthorized Unistrut clamps were in use (SgN, WBN, and BFN), that more specific designation was required with regard to clamp callouts on drawings (SgN),
and that some clamp damage resulted from the torquing of one-piece, one-bolt clamps to 6 ft-lb (WBN, BFN, and BLN).
Many of these items had prompted TVA corrective action before ECTG investigation.
4.2 Instrument Mountin Brackets - Element 223.2 This element was generally concerned with the degree to which instrument mounting brackets could withstand seismic or other severe design loads and withstand abusive treatment in heavy traffic areas.
The review of available documentation and the inspection of instrument mounting brackets confirmed that instrument mounting brackets at SON and WBN are adequate to meet their most severe specified design conditions.
Although these brackets are adequate to suoport the relatively light instruments, they are not substantial enough to withstand the abusive treatment (i.e., plant personnel stepping'n or bumoing into brackets) that is inevitable in heavy traffic areas of both olants.
4.3 Local Instrument Seismic Dualification - Element 223.3 This element was concerned with the extent to which engineering judgment was used, at SgN in the design of locally mounted instrument installation details without an accompanying seismic analysis or seismic qualification.
In
- general, TVA followed acceptable standard practice in this matter',
and items were installed in accord with standard TVA design guidance.
However, it was confirmed that documentation is'ot complete in many areas.
4.4 Summar of Subcate or Findin s A summary of the classified findings is provided, in Table 1.
Class A and 8
findings indicate there is no problem and that corrective action is not 27340-R27 (10/14/87)
TVA EMPLOYEE'ONCERNS
'SPECIAL PROGRAM REPORT, NUMBER: '2300 REVISION NUMBERS:
3 Page 10 of 25 required.
Class C 0, and E findings require correct"',ive actions.
The corrective, action class, defined in the G1cIsspry Supplement, iis identifikd 'in
'he table by the numera.l combined with the finding 'class'.
The summary of finciings by classification is, given in Table 2.
Where more than one corrective action is idlentifiedl in Table 1I for a single find.ing (e.g.
Element 223.2,,
Findling b), Table 2 counts only a sing1e class'ification.
Thus Table 2 identifies one findling for each tissue ev4lu'at4d.'f the 35 findilngs identified in Table 113'eqIjirie no corrective action.
Of the remaining 22 findings, ten had corrective actions initia'ted before the ECTG.evaluatiori, eight had new corrective actions identified, and four wer e findings for peripheral issues, identified ciuring the ECTG eva'luation and requiring corrective actions.
From this table, it can be seen thai: at Watts Bar, where all of the issues were originated, seven issues out of a total of ten were found to be valid and require corrective, action,,and six,of those seven had corrective action initiated before the ECTG ev'alcIation.
5.
CORRECTIVE ACTIONS The general areas of corrective action are described below f'r each element'eviewed for this subcategory.
Following this'<
a, summary discussion of the information presented in Taible 3.
5.1 Instrument Line S~uiort Connections - Flement 223.1 The instructions pertaining to instrument line sbppOrt connections and'th'e resulting installation were reviewed and considered adequate to satisfactorily meet the design intent and design servicel.
Hokev'er,, several correct,ive aIctions were requir'ed which are identified in Att'achmeht
'B.
Three principal mc!asi~res are being taken.
First, drawings pertinent'to'his subject are being revised to better specify approved 'Unistrut clamp types, while design documents applicable to this subject are being updateci to the latest requirements (WBN, BFN, and BLN).
- Second, corrective actions are under way to wa1k down dr inspect affected plants for nonconforming materials or installations t6 a<su're
'hat Unistrut bolts are properly tightened, qualified materials are used, and correct clamp types are installed (SQN, WBN, and BLN).
Finally, all unqualified or damaged support clamps ~vill be. replaced (SQN and WBN).
'Fo& BFN
'hese clamps will eilther be replaced or qualified by special analysis.
5.2 Instrument Mountin~Brackets - Element,223.2, Although the design strength of'ounting brackets to support instruments was found adequate, findlings about damage potential in heavy traffic areas revealed the need for corrective action at b'oth SQN 'and WBN.
For both plants, TVA plans,to (1) identify those safety related instruments that are susceptible to damage from traffic, (2) walk'own'he areas and inspect for damaged
- brackets, (3) devlelop stronger'n4tr'ument'mounting details.and
'r eplac'.e damaged instrument brackets and those potentially susceptiblI to damage.
27340-R27 (10/14/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 11 of 25 5.3 Local Instrument Seismic Qualification - Element,223.3 This element, which relates only to SQN, concerned the basis for the location and installation of local instruments and the extent or degree to which they were seismically qualified.
As noted above in the discussion of findings on this issue, engineering judgment is an acceptable basis for establishing proper qualification of instrumentation equipment, and the TVA practice in this regard is not considered unusual or inappropriate.
However, the review of this matter revealed certain situations where some level of documentation might have better explained the installation of certain types of instrumentation equipment.
TVA intends to (1) determine the seismic qualification basis for all seismic Category I Instruments, (2) review all safety-related instrument installations to verify that they are properly located and consistent with their seismic qualification, and (3) modify supports or replace instruhents as necessary to satisfy qualification requirements.
5.4 Summar of Subcate or Corrective Actions TVA corrective actions that have been implemented since the concerns were registered have revealed the need for a large number of documentation changes and only a very limited need for plant modifications.
The greatest field effort is related to the need to verify the torque values of support connection bolts.
Actual plant modifications are identified in Table 3 for Sequoyah, Watts Bar, and Browns Ferry.
Although many of these modifications could possibly have been eliminated by performing rigorous engineering analyses to demonstrate the adequacy of the specific installations, TVA has not generally elected to do so.
Table 2 identifies 22 findings that require corrective action.
The corrective
- actions, along with their finding/corrective action classifications, are summarized in Table 3.
The corrective action descriptions in Table 3 are a
condensation of the more detailed corrective action information provided in Attachment B.
The plant or plants to which a corrective action is applicable are 'shown in the Corrective Action Tracking Oocument (CATO) column, and are identified by the CATO number.
With respect to corrective actions, Table 3 shows that, of the three elements in this subcategory:
223.1, which applies to all plants, has 15 corrective action descriptions; 223.2, which applies to SQN and WBN, has three corrective action descriptions; and 223.3, which applies to only SQN, has one corrective action description.
The corrective action plans for Sequoyah, Watts Bar, Browns Ferry, and Bellefonte are found to be acceptable by the evaluation team to resolve the findings.
2734D-R27 (10/14/87)
TVA EMPLOYEE,CONCERNS SPECIAL,PROIGRAM REPORT NUMBER:'2300'EVISION NUMBER: 3 Page 12 of 25 6.
CAUSES Table 3 identifies one or more c,auses for each problem requirinq corrective action and is organized in three. major groups:
manag1ement effectiveness, design process effectiveness, and technical adequacy.
For each corrertive action descripti,on,,
the closest or most immediate reason for a result is identified.
However, in many instances 'it was observed that the prob'iem resulted from a canbination or chain of ca<>ses, each of which should be identified.
Therefore, more than, one caIuse is ider>tified for those corrective actions.
The causes for problems in the area of i'nstrument Supports design genera'll!r relate to canmunications and des,ign detali lS.
THe cireatest number of Causes fall in the area of management effectiveneSs.'etailed bases for selection of the specific causes are provided in Section 6.2 below.
6.1
~Ma or Groupie( s of Causes The engineering errOrS that OCCurrrad in the d1eSign Of inStrument line SuppdrtS were generally those of anission.
Pr.ocedur'es'th'at'did n'ot adequately define the technical design requirements and first-and second-line engineering supervisors who diIi not pay sufficient attention to the details of nuclear power plant design,.
This ied'o oversiqhts in both verifying the design and properly directing construction regarding the installation.
Errors in vendor catalog informat,ion were; beyond the contro'i of TVA'engin'eers.
Accordinqly, there are no higher level causes.
In many areas, the TVA dlesign process was sound.
iiowever, the desiqn bases for qualified instrument 1 ine clamps and their required bolt torquinq weire unclear; additiona'lly, the design bases for instrument mounting brackets did not address the need to consider abusive treatment in certain high traffic areas.
This led to design details not specifying qualified instrument line.
clamp types and required bolt torquing, and for local instrument seismic qualifications to have b1een perf'ormed using undocumented engineering judgment.
As-built reconciliation and verIification documentation for both instrument line supports and local instrument seisinic qualifications did not properly define and analyze the actual installed conf'igurat,ions.
The'cmbination of the above contrib1uted to some uncertainty regardinq the desiqn process for this area of review.
The extent to whiich management, including f'irst-and second-1 ine super'vi,sion, is engaged in thee design work was examined on the basis of the findings identified.
In many areas,,
superv'isory effectiveness was adequate.
- However, exceptions were noted in the areas of orgarrizati'onal definition, carlnunications, and supervisory familiarity with the rigorous requirements of nuclear power plant design.,
2734D-R28
( 10/14/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER:
3'age 13 of 25 6.2 Oetailed Bases for S ecific Causes The bases for identifying specific causes follow for each negative finding for which corrective actions are described in Tabl'e 3.
6.2.1 Instrument Line Support Connections
- Element 223.1 Provisions for torquing of support clamp bolts were not defined on the SgN construction
- drawings, indicating insufficient design detail and inccmplete communications with the field.
The. oversight was an error by Engineering.
Resolution of potential use of unauthorized clamps at SgN, as a
result of generic review of WBN SCR 6084-S, during the construction and operating phases of plant life was the resulted from unfocused responsibilities and insufficient ccmmunication between Regulatory Licensing, Power Stores, Operations, and Engineering.
Potential errors at SgN resulting from the broad range of clamp designations could have been prevented had Enqineering provided more design detail on the construction drawings.
This oversight was an error by Enqineering.
Confusing notes on the instrument support standard drawinq for WBN impaired communications of the design requirements to Construction.
This could have been prevented by first-and second-line supervision being more attentive in providing Construction with the information necessary to properly construct the instrument supports.
In addition, there was insufficient detail in the notes, potentially leadinq to the use of unqualified clamps.
Insufficient communication to Construction and incomplete design detail resulted from Engineering's failure 'to specify bolt torques for instrument line support clamps at WBN.
This oversight was an error by Engineering.
Oamage of instrument line clamps at WBN was originally caused by the vendor in specifying an inappropriate torque value for the P2008 series clamp.
Subsequent installation and quality control acceptance of such damaged clamps.by Construction personnel without feedback to Engineering are indicative of procedures not beinq followed and lack of proper careunications.
In addition, sample walkdowns by ONE have indicated that instrument lines were not installed in accordance with design requirements and that there were both insufficient documentation to audit the installation -adequacy and inaccurate as-built reconciliation.
27340-R28 (10/14/87)
TVA EMPLOYEE CONCERNS SPEC'IAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER 3'age 14 of 25 0
o Loose clamps at WBN are the result; of a lack of sufficient first-and second-line engineering supervision attention to design detail~
,in providing an adequate design basis for support of instrument lines.
o The need for verifying and correcting the torque values of all Unistrut type clamp bolts at BFN cou'Id have been prevented by greater attention from first-and second-line -engineering supervision to design detail. in providing adequate design bases,'.
This oversight wa.
an error by Engineering.
o The requirements for qualified instrument line clamp types at BFN were not communicated by Engineering to Plant Operations and Construction before November 27, 1985.
This omission was a result of lack of sufficient first-a'nd second-line engineering supervision attention to design detail in providing adequate desi,gn bases for
'upport of instrukent lines.
o Potential damage of instrument line clamps, ai:
BIFN and BLN originated from, an error by the vendor in specifying an inappropriate torque; value for the P2008 series clamps.
o Failure to fully specify qua'lified clamp types in the BFN dedigh criteria and to implement appropriate corrective actions to prevent recurrence arose from incomplete design bases and procedures resulting in lack of sufficient design detail.
This oversight could
'ave been prevented by additionhl atf'ention by first-and second-line engineering supervision to the unique aspects of nuclear plant design.
o Incorrect inspection requirements for supports on five instrument lines at BLN resulted from incomplete information being communicated to Construction and lack of information about the desi gn detai 1 provided by Engineering.
6.2.2 Instrument Mounting Br ackets - Element',223.2 In heavy traffic areas, the instrument mounting brackets at WBN and SQN were susceptible to inadvertent abusive treatment and damage from plant personnel'his was primarily caused by engineering design bases not considering bracket loads other than from the attached instruments.,
The problem could have been~
minimized if either Construction'or Operations had given feedback to Enaineerinq on the, bracket's susceptibility.
6.2.3 Local Instrument Seismic Qualification
-. Element 223.3 The indeterminancy of the seismic qualification of local instruments at SQN was driven by insufficient depth of design details defined by the Civil 27340-R28 (10/14/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER:
3 Page 15 of 25 Engineering Branch (CEB) and lack of adeauate communication of design details, actual furnished components, and installed configurations among the CEB and the Electrical Engineering Branch (EEB), which supplied the instruments, and Construction, which-installed them.
These were caused by lack of attention to detail by the first-and second-line supervision in each of the three involved groups.
The extent of the problems could not readily be established because of incomplete and incorrect as-built reconciliation.
7.
COLLECTIVE SIGNIFICANCE The evaluation team's judgment as to the significance of the corrective actions is indicated in the last three columns of Table 3.
Significance is rated in accordance with the types of changes that may be expected to tesult from the corrective action.
The corrective action plan descriptions for elements 223.
1 and 223.3 are judged to be individually significant from both licensing and technical standpoints to ensure the functional operabil,ity of Category I or Class I instruments and;instrument lines during a seismic event.
The corrective action plan descriptions for element 223.2 are judged to be individually significant only from a maintenance standpoint.
When all the findings and corrective action descriptions for all four nuclear plants are viewed collectively, the following overall conclusions emerge:
o Although the majority of problems identified may only require changes in design input or output documents, the extent of the evaluations to be performed (including plant walkdowns) indicates the difficulty in determining the acceptability of the as-built instruments, instrument lines, and their supports.
These evaluations must be performed before. any need for hardware changes can be known.
This is reflected in the number of potential changes identified in the last column of Table 3.
o Beyond the specific issues related to the design adequacy of instrumentation
- supports, there is the broader issue of Engineering's lack of attention to details.
The design of nuclear power plants requires the consideration of many unique items not generally considered in nonnuclear applications.
Accordingly, there is a need for first-and second-line engineering supervision to be better trained in the special requirements of nuclear power plant design.
Certain aspects of the broader issue regarding management's inattention to detail apparently continue to exist at TVA, as evidenced by its attempt to complete the corrective actions for SgN element 223.3.
Review of the corrective action completion notification. prepared by TVA revealed that TVA had not performed the corrective actions as defined,,in its corrective action plan. nor documented the engineering judgments made'as required by TVA policy
[805 861222 501].
27340-R28 (10/14/87)
TVA EMPLOYEE CONCERNS SPECIAL, PRO(iRAIN REPORT NUMBER'2300 i
REVISION NUMBER:
3 Page 16 of 25 To address the general p'c ogr ammatic issues of TVA's past difficulties in ~the nuclear area, the Corporate Nuclear PerfOrmance Plan (CNPP) (Ref. 4) was created.
In addition,
(Ref. 4) to further define the programnatic aCti'onS to be taken for their facilities (BLN-is broadly addressed in the, CNPP).
'n
- general, TVA senior management has ident'ifi'ed'the need for strengthening its Engineering organization in response to the requirements of nuclear plant design.
The Engineering organization is'respo'nsible f'r 'the content and
'uality of the design documents and for ensuring that they conform. to sound engineeririg principles,
'licensing commitments,'nd Qua~lity Assurance ptograrh requirements.
This need for strengthening is based,,
in part, on. deficiencies in design process effectiveness, which ar'e partially illustrated by the cause discussion in Section 6.
This need is also partially based on past implementation of the TVA Quality Assurance program,.
Thus; the need for strengthening the Engineering organization, as.indicated by the
- NPPs, is accomplished primarily through additional trai'ning of the ONE personnel to the'equirements of that program and to basic management principles.
ONE Nuclear, Engineering Procedure NEP-5.2 and policy memo PM 87-35 clearly delineate the responsibility, authority, 'and accountability of the Project Enoineers and Branch Chiefs.'he. Project Ehgihedr is Hesponsible for work
- scope, budget, and schedule, and for ensuring that project work is executed according to plan and in conformance with the techn.ical direction of the Branch Chiefs and the requirements of the corporate.
QA program.
The, Branch Chiefs are responsible for staffing levels and qualifications of 'technical personnel on the projects, and for the technical inadequacy of'he engineering desiqn.
The Branch Chiefs are the final'techn'ical authority within ONE, and have the authority to stop work t,hat does'ot eon'form to established requirements.
In the past, Branch Chiefs'uthority or resources to fully administer technical reviews was limited.
Under ~the-restructured orqanization, the Branch Chief provides engineers ar>d technica'l direction fdr the Project Engineer; the Branch Chief also assesses the need for technical
- reviews, develops a document review, and approval matrix, and schedules reviews as required.
These programs have been start:ed but have not, as of thiS report
- revision, been fully implemented.
An independent audit on the effectiveness of the implementation of the total Quality Assurance program is instituted by Engineering management, as a
manaqement tool, to additionally ensure that management policy is being enforced.
This audit function is provided by the Engineering Assura'nce (EA)'rganization.
The findings of this subcategory are combined with t,hose of other subcategory reports and reassessed in the 'Engineering category evaluation, which has assessed the broader issues identified and:has issued the necessary corrective
'ction tracking documents.
27340-R28 (10/1 4/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 17 of 25 TABLE 1
CLASSIFICATION OF FINOINGS ANO CORRECTIVE ACTIONS Element 223. 1 Instrument Line Support Connections Issue/
~Findin **
Cl Finding/Corrective Action Class*
C3 01 C7 C6 06 C6 01 06 Cl E6 E3 C6 Cl C6 A
Cl
~
A C6 A
E3 E6 223.2 Instrument Mounting Bracket***
A A
01 Cl 06 C6 01 06 Cl C6 E6
- Explanation of classes is on the next page.
~ Oefined for each plant in Attachment B.
- ~ After evaluation of SqN and WBN, the evaluation team established that this is a plant maintenance issue and does not represent a safety concern.
Accordingly, a review of BFN and BLN, was not performed.
27340-R27 (10/14/87)
~ ~ '
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM Table 1 (Cont'dI)
REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 18 of'5 0
E1ement Finding/Cor'rective Issue/
Action Class*
223.3 Instrument Sei smic equal if'ication'~
a 96
'6 06
- Classification of Findinas and Corrective Actions A.
Issue not valid,.
No corrective action required.
B.
Issue valid but consequences acceptable.
No corrective action required.
C.
Issue valid.
Corrective action initiated Ibefore ECTG evaluation.
0.
Issue valid.
Corrective action taken as a result of ECTG evaluation.
E.
Peripheral issue uncovered during ECTG evaluation.
Corrective action required.
- Oefined for each plant,in Attachment B.
- 1. Hardware
- 2. Procedure
- 3. Oocumentation
- 4. Training
- 5. Analysis
'6. 'valuation
- 7. Other (inspection)
- Reviewed for SON only, reassi gned by TVA td Subc'ategory 80500 for other plants.
27340-R27-(10/1 4/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REYISION NUMBER: 3 Page 19 of 25 Classification of Findin s TABLE 2 FINDINGS
SUMMARY
Plant A.
Issue not valid.
No.corrective action required.
B.
Issue valid but, consequences..acceptable.
. No corrective action required.
5 3
2 3
13 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 evaluation.
Corrective action.
required.
2 6
1 1
5 2
1 2
1 1'0 Total 14 10 6
5 35 2734D-R27 (10/14/87)
IAIILE 3 HAINIXOf tLEHENIS, CDkkECIIVE ACTIONS, AND CAUSES SUDCAIECtxtV 22300 REVISIOII NWttERI 3 PACE 20 GF 25 CAUSES OF NEGATIVE FINOIHGSa I
I TEGINICAL HANA&LHENILIFECIIVEIIESS DESICN PROCESS EfFECIIVEkESS ADE ACT I
2 3
5 6
7 8
g 10 I
12 13 I!
IS 16 17 F INDI ND/
CORRECTIVE AC'IION ELOI CLASS.aa CORRECTIVE ACTION CATO frag-(
(Proto-(Inade-(
(lnade-(
(Engrg (Design aentcd laade-(Inade-(acres (quate (Un-(lnadc-(
(quate
( Lect (tudgat(/Crit organ-quate (quate (Not (coa-(t iacly(Lath (quate (lnadc-(As-bit(of
( not (coavat I(
(Iaa-(
I)-
(Prate-(Fol-(aunt-(Res of/of ttgt(Design(quate (Recon-(Design(Docu-( Not tion Ir uvres la~cd cation issues Attea Dates Calcs all.
Uctall canted Hct Insuf.
Vcrlf (Stds Docu (Not ueata-(Fol-tlon loved Engrg Vendor Error Error Slgalf I-cence of Corrective Actions' H
H 223. I Cl Tlghtcn originally Installed Unlstrut bolts oer ECNS
&SRO an4 67gl.
Sttk 02 E6 Replace all <<nauthor Ised elaaps, If any, utth approved claaps resulting froa Lhc long-tete torque inspect ton progr an Sttk 01 x
oa tas w
la
~
~
~ ~
v
~
!7AOSI, !7A052, an4!7&05!
series to caii out specific apprOvC4 Unittrut C leap 4cslgnatlons.
C3 Revise the notes for thc
!TAOSILser!cs-orcut ags-Lo---
rcduee the potent l ~I for confus1on.
Corrective action uas cocplctcdt Thcreioret aa CATO was gcncrate4.
(kttk)
C6 Pcrforn
~ randoa saaplc Inspection at kgk Lo vertfy-Lhat no unqualified aater lais
~erc used-.
.Corrective action uas cocplctcd.
Ihereforc, no CAID uas gencratc4.
(kgk)
A Respond to NCR kttk SNP 8230.
Correetl e ae< ioa uas coaplctcd. Thcrcfurc, no CAID aas generatedo (ktut)
AIAI-kelt doua all unit 1 lnstruaent line'supports aad resolve 'discrepancies.
ktut Ul ktlk 02 x
l P I P I
Defined la Lhe SIOSSat'j SupP
~ Caeat
~
~ a Defined Ia Table li 26070-R 12 7
IARLE 3 IQINIXuf tLLHENIS~ CURRECIIVE ACIIUNS~ ANO CAUSES SUNCAIEGORV 22300 REVISION htfg)ERt 3 I'ACE 21 CF 25 CAUSES CF NEGAVIVE FIN)INGSa I
HANAQHLNI EFILCIIVLNESS
)
2 3
a 5
6 7
I IEOINICAL Abf ACV OESIQI PROCESS ffFLCIIVENESS 8
g 10
))
12
)3 le 15 16 If F INOIhG/
CORRECII Vf AC)ION fLEH CLASS. ~'ORRECIIVE ACIluN CAIU IFrag-I I
IProce-Ilnadc-I Ilnade-I Ifngrg IOcslgnllnsuf.l Inentedllnade-I)nade-Idures Iquate Iun-lnadc-I Iquate I Lack IJudgntl/Crit IVerlf IStds IOrgan-Iquate Iquate Ihut ICon-'tieuly Lack quate Ilnadc-IAs-bltlof I riot ICoavaitlpocu-Ihot I
I Slgnifl-I cance of I Correctlvcl laa-I II-IProce-lfol-Inunl-IRes oflof Hgtlueslgnlquatc IRecon-IOesignlpocu-I Not Inenta-Ifo)-
IEngrg Ivendorl Actions' ion trn(
duces leuco cat ion Issues At)en dates Calcs cll.
Detail nented Het tiun lo ed Error frror 0
H H I C1 Rctorquc loosened bolts on instruncnt support clanps.
01, Cl Verify COrreCt tOrque Of all unistrut-type claep bolts.
06, C6 Pcrfons evaluation to. verify that correct unit)rut clanp types are Installed.
RFN Ul UFN ul x
I I
I I
IAI-IAI I
I I
I I
I IAI-Al I
I I
I AIPIPI 01 Replace el I Unlstrut P2008-P2020 ter tea clasp tyPcs ulth qualified oncS.
OFN ul x
E3 Revise Oeslgn Crltcri~
RFN-50-0)IO to refer to latest requlrcnents.
NFN Ol 223. 2 E6 lupi cnent correct lvc "actions to prcvcnt recurrence of concerns regardtng proper clanp types and bolt torquing.
Cy Provide QC reinspection for five Instrunent lines.
Rcvlsc drauings 58092$ 12 and SGttOV25-IO-)29 to ellnlnate Unlstrut P2008-P2020 series clanp.
Ol, Cl Hodlfy safety-rclatcd instrunent brackets that are susceptible to daeage.
NFN Ol ULN Ol BLN 01 SQN Ol huh Ul x
I I
I I
I I
I I
I I
I I
I I
I I
I x
I I
I I
I I
I I
I I
PI IAI-IAI IAIPI I
I I
I x
Defined in thc Glossary Supplenent.
~ a Defined in )able I.
260/O-R)2 IO/05/81
IANLL 3 IQIMIX UF ELENENIS, CONNECTIVE ACIIONS, ANO CAUSES SURCAIEGURV 22300 REVISION NQteER:
3 PAGE 22 UF 26 IMNALEHENI lffECIIVthESS I
2 3
6 6
6 CAUSES OF NEGAIIVE F INUINGSe 1EONICAL CV DESIGN PROCESS EffECIIVENESS ADE 7
9 IO II 12 13 II 16 16 FMIING/
'ORRECTIVE ACTION ELOI CLASS."
CORRECI IVE ACTION CATO I
(lnade-(
Frag-(
(Procc-Inade-(
(nentcd Inade-(!nude-(durcs (quate (Un-(Organ-quate (quate (Not (Con-(tinely (Iaa-(
II-(Proce-(Fol-(nuni- (Res of ltlon (trng inures Ilooded lcatlonllssuesl l<<adc-I IEngrg lOeslgn(lnsuf.(
(quate
( Lect'(tudgnt(/crit (verlf (stds Lack quate (Inade-(As-bit of of Hgt Design(quate (Recon-Design Atten Rates ICalcs Icll Uatatl Cobalt Not Nci noL Oocu-Docu-
~enta-1 Ion Not Fol-loved uentrd Engrg Vendor 6 Igni(l-cance of Corrective Ac I I n
1 II 1
U O6.
C6 Ident lfy safety-rc lated Instruuents counted on 11 I ~ -
~
I
~
I
~
'p Jane%
vla14% ~ 5 sw susceptible to danage tron traffic ~
SUN Ol NUN Ol E6 Evaluate s lnllar prob lens NUN Ol ba5cd on feedback Il'ou DNC and Plant Opcratlons.
P P
223. 3 Ident lty all safety-rcl ~ ted Instrueenis anu verity inat they'have been properly qualified.
Ol P
P IDIALS I
(12 8
I 2
I II I
~
Ocf inca in thc Glossary Supplenent.
~'efined In Table I.
eIn1n u1>
awe v=e a s 1IIIurInv
~v/vJI v
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 23 of 25 GLOSSARY SUPPLEMENT FOR THE ENGINEERING CATEGORY Causes of Ne ative Findin s - the causes for findings that require corrective action are categorized as follows:
1.
Fra mented or anization -.Lines of authority, responsibility, and accountabi ity were not clearly defined.
2.
3.
Inadequate aualit (0) trainin
- Personnel were not fully trained in the procedures established for. design process control and in the maintenance of design documents, including audits.
Inade uate rocedures
- Oesign and modification control methods and procedures were deficient in establishing requirements and did not ensure an effective design control program in some areas.
4.
Procedures not followed - Existing procedures controlling the design process were not u
y adhered to.
5.
Inade uate communications
- Communication, coordination, and cooperation were not u
y effective in supplying needed information within plants, between plants and organizations (e.g.,
Engineering, Construction, Licensing, and Operations)',
and between interorganizational disciplines and departments.
6.
Untimel resol'ution of issues
- Problems were not resolved in a
ime y manner, and their resolution was not aggressively pursued.
7.
Lack of manaoement attention - There was a lack of management attention in ensuring that programs required for an effective design process were established and implemented.
8.
Inade uate desi n bases
- Oesign bases were lacking, vague, or incomp ete or design execution and verification and for design change evaluation.
9.
Inade uate calculations - Oesign calculations were incomplete, used incorrect input or assumptions, or otherwise failed to fully demonstrate compliance with design requirements or support design output documents.
10.
Inade uate as-built reconciliation - Reconciliation -of design and licensing documents with p ant as-built condition was lacking or incomplete.
27340-R27 (10/14/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 24 of'5 11.
Lack of desi~n detail - Oetail in design output documents was insufficient to ensure compliahce with design requirements.
12.
Failure to document en>> ineerin
'u~d ments - Oocumentation jultifying,'ngsneersng judgments used sn the design process was lacking or incomplete.
13.
Oesi~ncr'iteria/commitments not met - Oesign criteria or lichnding commitments were not met.
14.
Insuff iciient verificathion docutlIentation - OocurrIentation (Q) 4as insuff~iciient to audit the adequacy of design and installatioh.
15.
Standards not f'ol'lowed - Code gr jinddstry'st'an3ards and practices were not complied with.
16.
Enoineerin~error - There were,eri.orb dr oversights in the assumptions, methodology, or jUdgients 'usd.d
'in 'th0 design prdce0s.
17.
Vendor error - Vendor design or supp'lie'd items 'were deficient. for the intended purpose.
Classification of'orrective Actions - corrective actions are classified as belonging to one or more of the following groups:
1.
Hardware
-. physical plant chang'es'.
Procedure - changed or generated a procedure 3.
Oocumentation
- affected OA recordls 4.
TraiIning - required personnel etiucation 5..
Anal sis - re uired desi n calcul ti ns tc
=resolv g,
a 0
> e e
6.
Evaluation - initial corrective, action plan indicated a need to evaTuate the issue before a definitive plan cou'Id be established.
Therefore, a'll hardware, procedure, etc, changes are not yet known 7.
Other - items not listed above Peripheral Findin~ Issue)
A negative f;inding that does not result directly evaluating an employee concern.,
By definition, peripheral findings (issues) require corrective act'ion.
27340-R27 (10/14/87) ll
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page 25 of 25 Si nificance of Corrective Actions - The evaluation team's judgment as to the significance of the corrective actions listed in Table 3 is indicated in the last 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 Oocumentation change (0) - this is a change to any design input or output document (e.g. drawing, specification, calculation, or procedure) that.-does not result in a significant reduction in design margin.
o Change in design margin (M) - This is a change in design interpretation (minimum requirements vs actual capability) that results in a significant (outside normal limits of.expected
'ccuracy) change in the design margin.
All designs include margins to allow for error and unforeseeable events.
Changes in design margins are a normal and acceptable part of the design and construction process as long as the.final design margins satisfy regulatory requirements and applicable codes and standards.
o Changq 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 design or design error.
If the change resulting from the corrective action is judged to be significant, either an "A" for actual or "P" for potential is entered into the appropriate column of Table 3.
Actual is distinguished from potential because corrective actions are not complete and, consequently, the scope of required changes may not be known.
Corrective actions are judged to be significant if the resultant changes affect the overall quality, performance, or margin of a safety-related structure,
- system, or component.
27340-R27
(,1 0/1 4'/87)
0 ll
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page,A-l of 2 ATTACHMENT A EMPLOYEE CONCERNS FOR SUBCATEGORY 22300 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, the concern is quoted as received by TVA and characterized as safety related, not safety related, or safety significant.
0107A-R38 (10/03/87)
CONCERn EEEIIEIII KOIIEI AIIAL'IUIENIA ENPLOYEE CONCLkNS FUk SOUCAILGORY 22300 PLANI APPL ICAUILI IY LOCAIIUN
~IIN wUN 8
N ULN CONCEkk UESCNIP IION>>
kEYISION NOjIUER: 3 PAGE A-2 OF ?
223.1 IN-85-398-003 V11 US U54 OUI IN-85-488-OU2 wuk wUN X
X "Uolts for Un)strut Clamps were not required to be torqued prior to 6-1-85, Unit ]).
Unit A2 bolts have an option to be torqued to 6 ft.
los.
Naif moon c)amps flatten during a 6 ft. lb. torque.
If torquinq jc ~ sn nnt jnn nn Elnjt >>4 nK~
srnl ~
Et K
t E II Et ai
~
a..I.
~
~
t vKVK~
VK~ unK ~ rat nKKJ nvan t Ia OII Vtl~ ~ Vll Vll Vll~ V r I ~
OIIU wIICll snoulo tne option be appliedl CI knows tnat this was not a proceuural iequ)rcment OA uniiS....O (SRiSSj "Ine notes on tne 4hWSU series drawinqs were really confusinq.to tne U.C. inSpeCtiOn perSOAne)r Nuen CnnfuSIOA EKISted betveen tne Sfae nuEjmer and type of Instrumentatio'n support clamps wnich were sl rant snla nu tna IEKA ravjar nt r s
a.. ~
~
~.. i...
Ii a
vt
~ v j KKIV vvu av ~
~ va
~lutva ollu WIIOV tJilc I, loIIIV tl44 l.4 I lcU IUE on the typical support drawinq...." '(Sk/SS)
"Inconsistent hanger torquing: until 6-I-85 no Instrumcntat)on nanger bolts were torqued.
From that date, bolts were required to be torqued to 6 ft.lo.
Inis amount of torque flattens half moon clamps and damaqeS c)amp noSe.
3-'4 montns
- aqo, hanqer inspecturS randomly Inspected unknown Inumocrj of bolts -and 4Lrx fa!led Iposs!Lily Uy0 tested).
CI questions corrective action for 10-20 tnousand not tea tI O ~
NCW USU
~ IOLCS (Car)y July 85 j perm) tS nojid-t IqntCA IAq theA turning 1/2 turn witn wrencn.
Uut tnis can leave tne tubinq luose.
(Uoth OnitS).
(EMiSSj 223.2 IN-85-9/3-UU2 wUN (snared witn 706UUJ X
X "Iypical InstruijEent mountiiiq brackets consisting of tnin gauge, perforated snectmcta)
(or similar material) are not strono I nouan to support tne Instruments (qenerlc for typical mounts).
Constant nK nnjnn jntn 1asnjnn snsjnrt sna r 1 ~ t Ean n
~ ~ ara
~
srl atr IE rt rn j
~ naut
~ CVK~ ~ n j v jv ~ ~ ~ a ~ ~ vllv a
~ vt ~ ~ ~ j vll
~III al vl VI nvl at
~ ~la ~ I causes damage to botn bracketS and inStrumentS.
CI could not provide sPecific instrument
- numbers,
)ocailons, etcrt but stated a) I such Insta) latlons snould be sub3ect to re-desiqn.
Ibis was reported to manager (known) but no action was.takcnr>>
(Sk/SS) 223.3 IN-85-886-NO4 wUN Ikeassianed to 80UUO for wdk, Ul:N and ULN)
NxC identified tne following concern related to IN-85-886-001 from review uf EEIC fIlo, "Un unit I, local instruEEECAtS were Installed uSinq
'Good Ejiq.
JuugE1ECnt'nd nO SeiSmiC analySiS WaS dOnern (Sk/SS)
Sx/NU/55 Ind)dates safety relatuut Aot safety rulalcu, ur safely s1lkiificant pur determinatiun criteria in LCIU PrugrOEEE Nanua)
A before evaluations
~
5 (U9/lb/8/]
and applied by
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page B-l of 12 ATTACHMENT B
SUMMARY
OF
- ISSUES, FINOINGS, ANO CORRECTIVE ACTIONS FOR SUBCATEGORY 22300 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 trace a concern from Attachment A to an issue in Attachment B by using the element number and applicable plant.
The reader may relate a corrective action description in Attachment B to causes and significance in Table 3 by 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 a employee concern.
These are classified as "E" in Tables 1
and 2 of this report.
0107A-R39
( 10/05/87)
Issues AI IACIpltNI 4 SUHNVuIT UI ISSut.S, fINUINIIS, ANU CUKKCCTIVt ACTIONS FUK SUUCATCGOKY 22300 F lnalngs kEVISIUN NUIIUtk: 3 itage 8-2 of I2 Corrective Actions 111*N11111111N111N Eleeent
?23. I
- instrument I.lne Support Connections
- 111111111111111*N 1 ~
TNC notCS On the 4IAOSU Sel Ies ara>>lngs for typical supports aescribing sizes,
- numbers, ana types of Instrument line, support connections were confusing to OC InspeCtion perSnnnel 54H a.
ine nOieS On ine 4/Aubu SerICS drawlngS are nOt COnfuSing for S4N instrument line support connections.
Un wUN where tne conCern
<<aS ralsea, IYA haa apprcaleately IUU nu'tes On Its alawlilg Seriec 548 Wac nn lv 56l ~
IheretOre, interpret~tiOn IS e'aSIur ana prvper
'lhln lsssstsht tt i lh t t tl ~
C
~ I I t
CUU
~ y w v lul
~ J il\\ll ~ ecov
~ C ot J4sl ~
54H a.
Hone required.
h Rnltc an@
theta lhth t I I
~
vv \\ t vl
~ ~ t ~ ~ v i%sit
~
~ Ilo \\ I ohllst were not torque4 before 06/Ul/86.
b ~ As stateil iil NCH SIIN Swr 83US, fnstrueent iine ciaaps 4i4 not nave specifiea torques before U2/83; no<<ever, tne TvA bolt tlgntenlng prograe under specification Ho. N2C-94b issued Ob/26/Ub establlsnes toruuc reoulreeents.
b ~,
IVA wiii tighten Originally lnStalle4 unlstrut OOlts for Instrument line claaes unaer-tne prograe aescribed In tngineerino I,'lianoe Nattot c hhgil ana 6/91 'his action >>ill assure adequate
~ lt
~
t I ~ t ~
II'tts ~ cnU is'I ~
vvl ~
~Isttol Iot IVII~
llhIP olill vci Inis ls a post-restart corrective action.
c, The bolts iicre over-torquca to 6 ft-lb. after 06/Ul/85 causing damage to clamps.
4 Eni tv warrant nf rlaenc fal led ran4oe inspection (possibly Uu visually examined I e.
The ne>> requireeent is for oolts to 'be hand-tlghtenea followea by a na1f-turn with wrencn.
This eay be Inaaequate.
- t. 'The torque requirements for Unit I h nca4 t
a nsh tssnth an II it 'J Ql \\
V ~ ~
~ OS OU ~
~ V ~
~llVtl Vl Vl~ ~ t C ~
c.
54N dia not specity a 6 ft-ib value ot torque for single-hole clamps on tne 4/Ausu series
- arawlngs, Tnus bolts were not overtorquea ana clamps were not"aaeagea becausL of torquing, a.
In a sampling program-reu@1ng Xrcecisposition cf-SCK S4N CEU 8612I a Iiigw percentage of clamps were founa iu have baits which turned at 1ess than ihe presently prescribed
- torque, althougtl the clamps coula support the tubing.
tioreOVer, tne bOlt tightening prOgrae undertaken by TVA to close uut tne above SCK aadresscs the Issue by assuring aaequate bolt installation to eeet design loaalngs for sels.-ic Category I ana i(bj lwstrualent-line supports.
e.
Tne new bult tightening requircavnt has been veriflea as part ot twe disposition tur sck s4N ctU 8612.
Urawing 4/AOSU-ll act ines tne reuuireeents, ana testS enSure the Installation's meeting tnu design requirements.
- f. Tne same dra~ing series (4/Ausuj aeflne's tne requirements tur-I>>lth llnltS fnerefcret Orsce
~ sse tos qiie reqvil cserlts were establisneu fur S4N, they wave been luentiflea for ootn un1is.
c.
None required.
Scc Corrccttvc Aciion b.h l
e.
None requlre4.
f.
None required.
24/40-8~6/8/j
0 ATTACNwtNI 0 bUHHARY N ISSUCS ~ F INUINUS, ANU CURRECTIVt ACTIONS FUR SUUCATCQlkY 2230U REVISION NUWUtk: 3 Page 8-3 of I2 Issues F indings Corrective Actions Element 223.l - SQN (Continued) g.
Not defined g.
'Tne documented evidence fOr the SQN response to wUN SCR 6084-5 dated I2/IS/Ub Identifying I/ types ot unautnorlzed Unistrut clamps Is being completed by TvA.
g.
A review of the NBN ScR 6084-S based on the SQN construction contract records recently Indicated that some of tne unauthor Ized clamps were also received at the SQN site.
IIowever, tne results of the samples taken in April l986 did not Identify any unauthorized clamps.
Therefore, tnere ls a high probability that the unauthorized clamps were not used for Category I Instrument piping.
Furthermor'e, under the long-term torque Inspection program (Engineering Change Notice 6690),
TVA will replace all unauthorized c)aays, lf any, <<1th approved clasps.
(CAIU SQN Ol) h.
Not def Ined
- n. A tew drawings In the 4/AUbl, 4/AUb2, and 4/AOb4 serIes nave a broad range of clamp callouts that need to be replaced with specific designations.
TVA has not completed corrective actions at this time.
TVA will rev1se those drawings ln the
- 47A051, 74AOb2, and 47A054 series with a broad range of Unistrut clamp callouts with the specific approved clamp designations.
(CATO SQN 03)
Ibis Is a post-restart corrective action.
l wBN The notes on the 47A050 series drawings for typical supports descrIblng sizes,
- numbers, and types of Instrument line support connections were confusing to QC Inspection personnel.
wUN a.
Tne 4/AUbU series drawings include approximately
)80 notes which were originally not arranged by subsect.
This condition could reSult in confusion and tne subsequent Installation of unqualified clamps.
NCR 6084, RO and Rl for wUN document tne existence of an unqualified Instrument line clamp for unit 2.
As a result of this discr'epancy, TvA deleted any reference to unqualif'led Clamp typeS In tne appliCable deSign drawings.
TvA also inspected a random sample of 378 clamp supports for unit 2 and found no unqualified clamps.
Tnerefore, TVA concluded that there ls 95 percent confidenCe tnat 9b percent or more of tne qualifIed c)amp types nave been Installed on unit 2 supports.
I.or unit I, TVA Inspected a random Sample of PU/ clamp supports and found no unqualified c lamps.
lherefore, TYA concluded tnat this Item Is not applicable to unit I.
wUN a.
Prior to ECTO evaluation, wSN revised notes on 47A05U series drawings and performed a random sample inspection to verify that no unqualified materials were used.
Tnerefore, no further corrective actions are required.
I 24/40-8
( IO/05/8/)
Issues ATTACIWCHI 8 SUMMART Ut ISSUf5, FIHUIHGSt ANU CURkiCTIVi ACTIONS FUk SUUCATiGOkT 22300 Findings RfVl'SIUH HUM1tfk1 3 Page 8-4 ot I2 CorrectIve Actions Element 223.I - <<BN (I;ontfnued) b.
Bolts for Instrument line clamps were not torqued before 06/Ul/Ub.
- b. Bolt tiqntening requirements were aaaca via fCN 2904.to the 4/AUSU series dra~ings In 02/83 In response to NN
<<UH S<<P 823U.
A revie<< of 'construction proceaures used priOr tO 02/83.aeterminea that ftnal aursenntatfon naeesl on adequate Installation requfretents existed for all hnlstsesn CnvsnneCtasosss CXCCpi fos Consault dnsd Insstrldlsent line
-clamps fIndifeed before 1980.
A TvA evaluation concluaea indi inere is 95 percent confiaence that less, than b
.percent of tne conauit dna Instrument line clamp bolts finalized before l98U may not be fully tlqntenea.
b.
I'rior to fCTG evaluation, bolt tiqhtening requirements were added to 4/AUSU series arawlngS and InStallatiOnS made prfOr tO lllBII as a aual
~ atan h
Scanll t
Ic
~
~
s vs s s ca
~ slu ~ \\ u vJ Jscsts
~
~ ~ ssl tss Yos
~ s J acceptability.
Therefore, no further correciive aciions are requirea.
C.
The bOltS were OVer-tOrqued tO 6 ft-Ib after 06/Ol/85 caucfnn damage to clamps.
Cc Uy observing actual installations, TTA confirmed that tns ns ~ Inss nf nna nl ann n
~ It I
s ~ s c cu..v svs vsu
~ ~ y vt vs s vts ~ svv ~ vsse=vulva s saifslso loss lollvt I cvvQ serfes or equIvdlent) to 6 ft-Ib admdgea them.
Ibis was corrected uy revising the tightening requirements io "i/2 turn past hanatlgnt" as specftfca by Note l66 of arawlnq 41AUSU-IJ3, In response to plk <<UH CfU UO39.
In addition, lvA is refnspectlng ana repairinq any aama'gea one-piecet one-bolt clamps ln accoraance with <<ork plan N<<334P-2 for unit I ana PIR ldIH CEU 8639 for unit 2.
c.
To close out PIR <<UN CfB 8639, TVA will walk do<<n aii One-pieCe, one-boii insirumeni iine support clamps and will replace any damaged ciamps found during the walkdo<<n.
For unit I, the action Is beInq Implemented ana trackea as a part of NCR w-334-p.
For unit 2 the actino fs; betllg feplesssentoa osln trackea by Plk wBN CFB 8639.
(CATO wBN 02) n Fos'tv norront nf c I anne fat lan J r
~
vs str vs
~ vv random inspection (possibly UU V ISuaf Iy CXdmlrlesv) ~
'v ~
TVA OISCOVCrea-Problems-with thle IOStalldtfalnl Of Instrumentation ana Instrument lines and, on IO/25/85, plaCed an aamfnistratlVe onOia On tniS aCtiVlty until the necessary corrective actions cuuld be determined, HCR <<-334-P, kU foi <<UN specit'ies alscrepancies founa with documentation on fnstrIJIent lines and their SuPPOrtS.
To better unaerstana the extent of the nrohlems a randem cdmplo nf 601 nit I.c.sppoutc wac Inspectea by TVA. t leven cladPs or bolts were founa to bc loose.ol damaged.
Rcinspcctlun dnu rctorqulng of bolts for all unit I instrument line clamps are being Performed in dCCOrdanCe with WOrk Plan N<<334P-2.
d.
To ciose oui iiCR w-334-P, TVA wiii walk ao<<n all unit I Instrument line supports and will resolve all discrepancies found during the walkdo<<ns.
Details of the walkao<<n requirements are given fn TVA memos (l3d ll9 186 Ik2l, 8604nll llll/I ann 09 Il (826 8609l) 052J)
(CATD <<BH Ol)
)
e.
Ihe new requIrement fs for bolts to be hand-ttghtono{l folld<<oa bM a half-turn
<<Ith wrencn.
This may be, Inaaequate.
- e. Laboratory tests, uescribea fn TTA memo (st /9U1IU ooIJ, estdoffstt'tne clamp loda cdpdcft!Cs,.e: tne basis ot-tigntenlng values similar to those given ln Note 166 ot drd<<fng 4/AUBU-Id/.
incse tigntening values proviae adequate clamp loda CapaCftfeS dna preClude cldmP damage.
e.
Hone required.
~
f.
The torque requfremcnts for Unit I
are different fron tnose for Unit 2.
ud Ihll-llllllhi<<I I
- f. Ine bolt tiqhteninq requirements.
Oiven In terms ot ndnatlght plus turn-ot-tne-nut, <<cre estdbllshea in U2/83 fffCCt>VC Ub/UI/Ub tns So requirements Were replaced witn torque values fur t<<u hole clamps.
for One P1CCC On -bu t ddmPS llu t lghtCklflg I'Cqusressent-
<<as hanatfgut plus I/2 turn with the option to-turquc to b f't ib, ln U4/86, lne OPtiandl turque vdiue fOr one-ptece, one-bolt clamps wds aelct<<d to avoid clamp admdqe.
tacll ot tile above luhs wds dct inca 'ln drd<<inq series 4/AUbU wnic plicable to both units I
dna 2.
f.
Hone required.
issues AlIACNKtNI B SUNKAKr ut IS>uk',
F INUINUS, ANU CukktCIIVt ACIIuNS IUK SUBCAltUUKT 22300 Findings ktVISION NUKBtk: 3 Page B-D ot I2 Corrective Actions tlement 223.l - NM a.
Bolts for instrument line clamps were not torqued before 06/UI/Bb.
NN
- a. As identified in Ntk BtN Uwp Uaub, Dolt-tightening requIrements for instrument line clamps for unIts I, 2, and 3 were nOt SpeCitie4 DetOre U2/Bd.
Ueneral Construction Specification U-D3, k4, issued In Ol/B4 defined torquing requirements.
- however, these tightening requirements 4o not accurately simulate the tightening ValueS uSed ln the laDOratOry teStS whien eStabliShed the clamp load capacities.
IVA has not completed the requIred cprrectsve action tor Nck NN dwl'BU> to determine the a4equacy or bolt tightness tor Instrument line clamps Installed Detore Ol/U4.
The recoomended metno4 or determining tne adequacy or instrument pIping and tuning clamp bolt tSghtness given Sn Oeslgn Criteria BIN-Du-UIIU by shaking the pipe adjacent to tne support may be adequate for tubing, but may not De adequate for piping and has not been substantiate4 Dy UNt.
Current IYA corrective actions do not include an evaluation ot qualitle4 clamp type use and correct bolt-tightening Installation Dase4 on as-built lntormatlon.
Since II/2//UD, UNt has Issued individual support 4etall drawings.
A UNt revie~ ot 394 individual support detail drawings revealed that l4 drawings speclry the use ot Unistrut clamps.
Ol'hese 74 drawings, UNE found that 66 drawings specIty proper bolt-tIgntenlng requirements, Dut that U drawings 4o not specity tnem.
a.
Verify or correct Installed torque values of all Unistrut-type clamps for Class I
Instrument tubing and small nore piping.
Torque values wil I De verlfIed against appropriate loa4 rating test intormation.
write a CAI)K to address concernS relating to the completeness ot the corrective action in NCk BFN BKP 8305, Rl.
'erify or correct installed clamp types ot all Unlstrut-type clamps Sor Class I
Instrument tubing and small bore pipIng.
Clamp types will De verrired against qualItied clamp types which have load rating test intormation.
Clamps which do not have load rating test information will be replaced or qualitied by special analysis.
(CATO BFN Ol) b.
Ihe bolts were over -torque4 to b ft-Ib after 06/Ol/Bb causing damage to clamps.
I c.
Forty percent of clamps failed random Inspection (possibly BU'Isua I ly examined).
b, c
Ine design documents 414 not prohlolt the use of one-piece, one-bolt clamps (unistrut p2wB-p2UBU serlesJ for units I, 2, and 3.
Thus, this clamp type, which Is susceptlDIe to damage trom overtorquing, may have been used.
Unistrut Corporation's design bolt torque for I/4-Incn-diameter clamp bolts (lnclu4lng Dolts tor p2uoB-P202U series clamps)
Is 6 ft-lb.
Torquing of bolts for PBWB-PBU2U series clamps to b tt-lb will cause 4amage to the clamps.
Ukt has not evaluated the as-Duilt usage or this clamp type for installations prior to I I/2//Ub~
Project Instruction Bltp Pl Bb-29 requires a sample Inspection ot D4 small Dore pipe supports In or4er to addreSS the ISSueS Ot SCK UIN CtU USBU.
ThiS inSpeCtiOn was not completed since the engineering evaluation ot the lnitSal Inspection results snowed pipe stresses larger than the allowaole values.
b.
Replace al I installed UnlStrut PBUUB-P202U serIes or similar clamps with qualified clamp types.
(CAIU Bl'N UIJ I
c.
See Corrective Action "a."
24/4U-M
( IU/Ub/Ul)
issues ATTACIOiLNT 8 SUHHAkY Uf ISSUES, FINUINUS, ANU CUHHICTIVE ACTIONS FUR SUUCATLUUHY 2/300 Finuings.
HE VISION NUNUEH: 3 Page 8-6 of )7.
Currectlve Actions E)ement ?23.1 - UFN (Continued) d.
The new requirement ls for bolts tu oe hand-tightened folio>>ed by a half-turn W'Ito WrenChr This may Oe in>>neqrr>>te e.
Tne torque requirements for eacn unit are different.
- u. Since ))/2//N, UNL liaS been Issuing Individual suppurt detail ura>>ings.
A revle>> by UNE uf 394 individual crrirrrrri n I 11
.r
-I I..
I>>
~
rr rt %rrr ~ ir~ 4>> ~ ~Irl>>
~ eve4 Iud I'I ui 4>>IIIg'hrvnac specified tne use uf Unistrut c)ampS.
Uf these 14 dra>>ings, one ura>>ing specifiuu tile use of Unlstrut P2UUU-P?02U series clamps.
This ur4>>ing specified a
Dolt-tightening requirement uf "finger tight pius I/O turn."
The evaluat)un tlram I nnslderc tills lu Ire>>n acceptable bolt-tightening requlrLicnt b<<cause It p oper ry slerurates rile labilratufy Iesl.conditions uefined In TVA memo H. U. Lane to T. d. Nurtnern, Jr., (Ol/)0/29) 4nu USLu for escabl lsiiing tne ciamp aiiu>>4bie ioaos.
. e. Uoll,-tlqhtening requirements fur Instrument line c)aiiys w'ere nut specified oefore u)/U4.
Since 0)/84I genera)
Do)t-tlqntenlng requirements h4ve been uefineo in Oeneral Consti'oct)on Sprclf li'at inn Cr-8 1, Hg fur unite 1 ~ 2 ~ and 3.
Since ))/77/US, tnese requirunents fur Instrument line ci4mps iiave beeli spcclf led uli Indivlduai supporl des Ign dra>> lngs.
o.
None required.
e.
None required.
f.
Not defined DLN
- f. In addltiunl. during the Investigation, the evaluatlun teain fuuno that tnLre are nu design criteria or uther ueSIun dneumentS Wnleh !dr nt Ifu>>li nuali fled IOStrrrIIrent line c)amp types and require that only tnese qualified
'c ~ ruOP tyPUS VL u>>eiut I ul un I cs I ~
c ~ 4IIu J ~
IilelLIul LI for supports Insta)leo befure II/2//85, unqualified cialnps couid nave been used.
fur supports lnstaiied after ))/2//US, tne use of qualified clamp types nas been verified Dy UNL on tne oasis of 4 review uf Individual Support uetal I dr4>>lnus.
ULN-f.
Hevlse Uesiun Criteria UF¹50-dl)0 to refer to current qua)if ication and evaluation rrlt er.l >>
IITlplekrenl liie Curi Lcc lve 4c I lunS rLqullLu IU prevent recurrence of concerns regarding proper ciamp types and proper c)amp Doit tightness.
(CATU UFN, 0))
Ul N a.
Uo)ts for instrument ilne ciainps were not torqueo before Oo/U)/UD.
4 ~ UOlt tiglllLning rLqulfeiltLnls ill:fe added lo tile SII80828
,ur4>>inqs un U2-2>-UO.
Un the bnsis of 4 revie>> of cunstructlun Inspectiun recurds
'(qC Inspection status, Computer I'rlnt-uut UINJANU4, 05/)5/8/) I it >>as determined tnat, five lin~s accepteu oefure tnis date.nave not been rr knspertru 4 ~
Perfurm a>>a)hdu>>n uf Instrument tilbilig lines UIK-LLPC-OOUA-NI -OUUU-N, -008C-N,
-UUUU-N, and
-UUUE-N to determine>>hetner one-piece, one-hole clamps (Mark No. N-64) were used.
(CATU ULN 0))
Al IACKKENI 0 SIPuuurt Ut lbbUtb~ t INUINGb~ ANU CUKKLLIlVL AC I IONIC tUK SUHCAILGUKY "li.'JUO REVISION NOKSLK: 3 Page U-/ ot IZ issues I. In41nqS Corrective Actions tlement i!I!3.I - ULN (Contlnuea) b.
Ihe bolts were over-torquea to b ft-lb
- b. Iorqulng ot one-piece, one-oolt (Unistrut PzUUU series) atter Ub/Ul/Uo causing 4amage to clamps.
tubing clamps to b tt-Io aamaqes them.
Iwo details on the UelletOnte drawingS allO~ tne uSe Ot theSe ClampS (ara>>lngs DGUU9i!o-IU-Ir ana ouuu9zo-IU-I6).
Ihelr bolts are required to oe torquea to b to / ft-los (arawlng DGUUVLD-IU-Ui.').
Ious, tne potential tor over-torquing I'i.'UUU series clamps erlsts at ULN; ho~ever, on the Dasis ot 4lscussions with knowleaqaDle IYA engineers and tield walkaownS, it aPPears that TVA haS uSed other, approved metho4$ ot secul lng the tuDlng to Its supports.
b.
KeviSe drawinqS 5G80925-IO-II and DGUUND-IU-129 to eliminate the use of Hark Ho. H-64 clamps.
(CATO BLN Ol) c.
Forty peicent of clamps failea ranaom InspectIon '(poss IDIy UU visual ly erramined).
d.
Ihe new requirement is tor bolts to De hand-tIghtened fOI IOwe4 by a halt-turn
= with wrench.
This may be Inaaequate.
e.
Ihe torque requirements for each unit are aitferent.
c.
Hanaom Inspections ot Installed tubing clamps have not Deen pertorme4 at DLN Decause no problems requiring resolution via ranaom reinspectlonS nave been ldentlt le4.
A4dltlena 1 ly, field >>a lkdO>>nS Dy the evdluation team have not revedlea any discrepancies.
d.
Ihe halt-turn method ot tIqhtenlng tubing clamp bolts ls not usea at ULN.
As specltlea on arawtng DGKU9LD-IU-Ul bolts are to be tlqhtene4 using specitled torque values.
e.
Iorque requirements are given on ara>>lng oouU96-IU-Uz dnd are identicdl tor botn ULtl units.
c.
None required.
d.
Hone require4.
e.
None requirea.
>>0>>>>>>>>w>>>>liki1>>I>>t t lement ZZ3.2
- instrument Haunting Uracket ww>>1>>*11>>$ 0*1IO>>N>>
SI)N a.
Instrument mo'untlng brackets are not
- a. Ueslgn Criteria SQN-UC-v-10.3 and IU.4 articulate the strong enouqh to support Instruments.
requIrements for instrument mounting brackets at E'EN.
Uased on review of drawings, plant walkdowns ana pertormlnq a sample calculdtion It was determined that tne mounting Drackets are aaequate to meet the/r most severe design conal tions.
S4N a.
None requlrea.
D.
ln heavy traffic areas, the brackets are susceptiDle to abusive treatment which causes 4amaqe to bracketS ana instruments.
- b. In heaVy trattiC areaS, the ISSue that the braCketS are susceptIble to aousive treatment resulting in damage to brackets ana instruments is valid as aocumentea In wUN NCK bi!9b, KO, for similar Installations at wdN.
b.
TVA UNE will compile a list ot satety-relatea instruments mounted on light-qage brackets similar to those Iaentif led in the element report.
UNL will laentify locations of the instruments and consider their susceptaolllty in view ot the Z4/40-9
( IO/Ub/U/)
I c
Issues ATTACIUItNI 8 SUIUVIHT Ut ISSUBS, FINUINUS, ANU CUKHBCTIVL ACTIONS FUH SUBCATEGOHT 72300 Findings REVISION NUHUtH: 3 Page 8-8 of 12 Corrective Actions EleIrent 223.2 - SI)N (Continued) general traffic pattern.
They wlII also develop and obtain approval for a field walkdown procedure.
Subsequently, they will perform tne walkdown and identify any deficiencies.
As a result, TVA will initiate corrective action for each deficiency and develop stronger aountInq dntdl Ic fni i.nnlavlnn thn Incti.i innnt brackets.
(CATO SI)N Ul) c.
All such installations snould be re4esigned.
wBN a.
InstruIN.nt counting brackets are not strong enougn to support instruments.
b.
In neavy traffic areas, tne orackets dre SusCeptlble tO ilbuslve treatment wnlcn causes damage to brackets and Instrueents.
- c. If tne walkdown discloses damaged bracketst tney should be strengtnened or protecte4.
NUN
- a. UeSlgn Criteria WB-UC-40-2/, UI. I, and 31.2 artiCulate tne requirenents for instrueeni oountlnq brackets dt wUN.
Laboratory testing (wyle test report 4280/-I, UU//6//4) and TVA Calculation 84l 860429 902 conflro tndt the edunting braCketS dre adequate tO eeet their eOSt severe design conditions.
- b. In neavy traffic areas, the issue tnat the brackets are SuSCepilble iu abuSive treatment reSulting ln dimdge tO brackets dnd Instrueents ls valid as documented In NCRs 678/ and 629b.
However, this Is a plant maintenance issue for Improved plant edlntunance of tne selsolc Instrueent installation.
Tnls issue is being addressed bv TVA bv tne aotlun nlanc attached td TVA Inc@Os frOA Curtis to Inose Listed (Ul/UU/Ub and U3/26/Ub),
and the 1
v..
c nvU i.JUt i vnc
\\
~ vbul 4 v ~
UI nb vc vl avd vcJvi lhls Is a post-restart corrective action, c.
See Corrective Action "bi" wUN a.
None required.
b.
TVA will enSure that the aCtlOn planS cofAIIItted to ue perforlned in the attaclvnent "C" to the Instrueent Proj<<ct Final Heport dre cIrnPIeted.
1hese included satisfactory c)osures of NCHs 6296 (Unit I) and 628/ (Unit 2).
NCH 6287 Rl (0//08/861 wds revised to provide a disposition of bracket repldcsiiBnt ds a plant eiuldncecnent wBN-ONC will track NCR 628/ to coepletlon ano closure by lneans of Iracklng and Reporting of Open Iteuls (TROI).
In.addi tlont TVA wilI Inspect Instrueent counting brackets for erlstlnq or pnteilt ial Artuilting braCket 4/image duI'ifiq PerfOradnCe Ot a Planned field WalkdOwn oi Instrueentation TVA wiii cake an assessIIIent of any damage dnd, If
- required, UNL/Cf8 will redesign and renldce tne brackets.
TVA will Issue LCNs for the work and track their v lncnvnc II'ATIIvuu AlI 24740~/US/8/)
0 issues Al IACIPItNI U blpuuutt Ur lbbutb, I INUINA, ANU CUHKECIIVt ACIlulls I UK bUKAltUUKVZZNU F indlngS RtVISION NUNdtk: 3 Page 5-9 ot IZ Corrective Actions tlement 223.2 - NUN (Continued)
C.
Al I such lnstal latlons should be redeslgned.
d.
Not defined
- c. As dOcumented ln the disposition of NCNs 6296 and 6ZU/,
construction or plant Operations, or both, will replace thOSe I/O-lnCh braCketS Shewn On detail Ulg Of draWlng 4/wbUU-Iv with the more rugged I/4-inch bracket sho~n on detail 8321 Of drawing 4/W6UU-3ZI and draWlng 4/AU61-l6 to enhance plant maintenance.
- d. lr similar problems are identtt>ed on the basis of appropriate teedback trom UNU and I'lant Uperatlons, UNt ShOuld evaluate tnose problems ln the same fashion as discussed in finding "c" above.
URN c.
See Corrective Action "b."
d.
See Correction Action b."
BIN (Not to be evaluated)
(Not to be evaluated)
ULN BLN t0$1iSi00**OAiON*$
t lement. 2Z3.3
- instrument Seismic Qual i 1 ication 110100**1**%*0**0%
SQN a.
Local instruments were installed
'ased on "Uood Engineering Judgment."
SQN transmitters
( I-pl-I-U and I-pi-I-Zb accordance witn the s gn raw, w
a.
A sample lnspectlon ot tnree Instruments was pertormed to determine the extent and acceptability of seismic qualltlcatlon at S4N.
Ine local panel-mounted pressure C) were installed ln SQN a.
TYA wi II obtain a list of s4N Units I and 2 safety-related Instruments from Sequoyah Critical structure,
- Systems, and Coayonents (cSSC) List.
Ihe list will be evaluated documented evidence judgment wnlch is ln industry-wide.
Curr InduStry are to juSt documentation.
Uase applic4t(
ot good e ring inspection as well a a seismic gral to.th englneerln qua I gt'F"h]dqpua (I)gb~ar+
t regula n
~roc pg I ptab ~e~
y such Judgment with teehnlea des gn, ver ty as-s, is and c
by the evaluation
- team, tne temperature switch has now been determined to De adequate.
qualification documentation of al I Unit 2 satety-related instruments'required for sate
- ShutdOwn, tO mitigate eOre damage, Or tO prevent releases ln excess ot IUCFRIUU limits (FSAK Chapter IS events) before 24/4D-M (IO/Ub/U/)
issues
(
Elenent 223.3 - SON (Continued)
ATIACIPIENT 8 SueNIY UF ISSUES, FINUINOS. AND CORRECTlVE ACTIONS FOR SUNCATEGORY 22300 FindIngs REVISION NUII8ER: 3 Page 8-IU of 12 Corrective Actions n
~.
Uni~
a A I other Unit 2 sa)ety-'relat s
ueents and al I Unit I'a)ty-re)at est ufnents wilI be subjected tp he Shffse sb{4h%sn Search and field ins c~gprg+
a ter Unit 2 restart.
lesesv ptPL~IIIY2 I e OI t OCLIvltles H ~ I I be perfpetf%hfofbfamgst rt of Unit I.
lee f(pill fnspeebfpI of pl be perforeeo fn according withppqEjdge approved by Plant Operation'\\Review
.ofunittee (PORC I or generi pItpcedureYtKatgover walkdowns, t
s
~ ss c
eLs $4pa I
lep e
sue VLyo esVte f p os~olsLQ o ees
~ J ~
spe procedu s~r ised 4g 1)glity Assurance (TIA).
Atcolyi4jonh re to quaiity repori (CN)R) w>$ IQCAni Qd corrective actions w II ro r each IncoInp)et y
cu e r
onconforfn!ng 1nstallatl n.
n adgihNn, TVA indicated that other pe ign ch h
u Its have resulted in ti folio a
fons that would pr"el-Oe.~- -nw e Vpb
-el-e-:
o TVA design T+an@c nt, CE8-Ol 12l(0$ WeISfn(c Ue gn, Review
. and Contro beep.~eye tly revised (OS/86 I to A
rhstv'en t!re sel sole des n
wyljje's to ensure adseguane sei foe
<<gorguol icae pone of Instrufnents dIta(L g In~i I t Tons.
SON seisolc revie ygPgFss 8fhtl(8sIIufnents is in accordance 3( Xljp-Dl gl.$3.
o Revlslon 2 of
'I h f ffI'heine Procedure SI}EP-3 Sped
/
and current revisio 3 (+/8/ r~pi e I
walkdowns before I
Ig'bb eng!neerlng-chan e
~
~s.'his procedure provld rPtpf t identify poteniia in probiefIIs 1n the design of Itffng detail for future installat Ion of instrueents.
(CATO 4IIN 01)
I II 24/4D-Ub/8/)
issues ATTACNNLNT B 6UNHAKV Ul'SSUt',S, FINUINBS, ANU CUHKtCTIVL ACTIONS FUK SUBCATLUUKY ??300 F lndingS REVISION NUBBER: 3 Page B-ll of I?
Corrective Actions E)ement 223.3 - S(1N (Continued)
THIS ITE"I PAR(@LL%!S/)8%9:
'k(K
~'dequate.
on ons.
ed that ln
, the not be b.
No seismic analysis was done for b.
Tne local panels where both pressure transmitters were different types of insta) )ation of local mounted were qualified by testing ano/ur analysis.
The instruments.
as-bul lt lnstal)ation of local field-mounted temperature swltcn 1-1'S-30-)03 lacked seismic analysis or other evaluation at the start ot tnis report investigation as indicated ln finding a. above.
1ne design mount)ng bracket ot the Foxboro transmitter shown on alternate Section Al-Al of Oeta1)
B)9, Orawing 4/w600-)9 ls more flexible than tne qualified approximately I-lncn deep bracket.
The evaluation team performed a quallficat1on calculation for alternate Section Al-Al and determined that this detail ls adequate.
b.
See Corrective Action "a."
c.
No se1smic analysis was done for local instruments.
- c. Instruments may be acceptably qual)fico to meet seismic requirement by analysis, testing, a combination of both, or similarity.
Both pressure transmitters,
)-PT-1-30 and I-PT-I-?BC, were seismlca I ly qua I ifled by testing.
Tne function of tne tiansm)tters was acceptab)e during anu after seismic testing, according to documented information provided by TVA; Temperature SwltCn I-TS-30-)03 (Fenwa)
NOuel )BU03-7) waS 3udged selsmica) ly qualified by TVA in )975 based on similarity tu anutner temperature swltcn (Fenwa)
Node)
I/00?-40) tested by Ueneral Lluctric.
A IBB? test report by Kyle Labs indicated that tnu function of the temperature swltcn was acceptable during and after seismic testing.
Tne test results indicate adequate SelSmiC qualifieatiOn fOr temperature SwitCh FenWa) Nude 1 IUU?3-7.
Since Fenwal Houel )0003-/ ls tne same ln form, fit, and function as Node l IUU?3-7, temperature switch I-T6-30-103 ls seismically qua)if leu by similarity.
c.
See Corrective Action "a."
24740-8
()0/05/8/I
issues ATTACHHCNT B SUWQRT UF ISSUES, FINUINGS, ANU CURRECTIVL Ai.'TIONS FUR SUBCATFGORY 22300 FInoings
~ REVISION NUMBER: 3 Page B-IB of I2 Corrective Actions Eleeent 223.3 - HBN (Mot to be evaluatee ln this subcategory)
BFN (Not to be evaluateo In this subcategory)
(Not to be evaluateo ln tnls subcategory)
HBM BFM BLM uBN BFN BLM 2g/go ubia) j
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page C-1 of 6 ATTACHMENT C REFERENCES l.
Element Report 223.1, "Instrument Line Support Connections" for Sequoyah, Rev.
1 (12/31/86) 2.
Element Report 223.2, "Instrument Mounting Brackets" for Seouoyah, Rev.
1 (04/13/87) 3.
Element Report 223.3, "Local Instrument Seismic Qualification" for
- Sequoyah, Rev.
2 (05/14/87) 4.
TVA Nuclear Performance Plan:
Revised Corporate Nuclear Performance
- Plan, Volume 1, Rev.
4 (03/87)
Revised Sequoyah Nuclear Performance
- Plan, Volume 2 (03/87)
Browns Ferry Nuclear Performance
- Plan, Volume 3 (09/86)
Watts Bar Nuclear Performance
- Plan, Volume 4 (03/87) 5.
Licensing Oocuments:
NRC' NUREG-0011, Safety Evaluation Report'elated to operation of Sequoyah Nuclear Plant Units 1
and 2, (03/79)
SQN FSAR update through Amendment 3, Section
- 3. 10, "Seismic Oesiqn of Category I Instrumentation and Electrical Equipment" WBN FSAR through Amendment 54, Oated 01/09/85 Section
- 3. 10, "Seismic Oesign of Category I Instrumentation and Electrical Equipment," including Table 3.10.4 6.
Oesign Criteria:
TVA SQN, "Oesign Criteria for Mechanical Auxiliary Instrumentation Room Panels,"
SQN-OC-V-10.3, Rev.
0 TVA SQN, "Oesign Criteria for Mechanical Local Panel for Class I
Equipment,"
SQN-OC-V-10.4, Rev.
0 Oesign Criteria WB-OC-40-27, "Mechanical Local Panels for Class I
Equipment,"
Rev.
1 Oesign Criteria WB-OC-40-31. 1, "Seismically Qualifying Mechanical and
.Electrical Equipment Oevices,"
Rev.
0 38070-R3
( 10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM Rl:PORT NUMBER:
22300 REVISION i'iUMBER: 3 Page C-2 of 6 Design Criteria WB-OC-40-31.2, "Seismic Qualification of Category I Fluid System Components and Electrical: or MechaniCal Equipment," Rev.
2 Design Criteria BFN-50-0710, "Field Inspdction of Instrument Lines,"
Rev.
0 ('i 1/07/80) 7.
Gal cul at i ons:
"Seismic Analysis of Instrumentatioh R'ack Fbame of Drawing 47W352',"
(06/29/72)
"Temperature Switch Mount Evaluation,"
(B25~ 861031 800]
"NRC WBN SWP 8230 Eval'uation," Rev.
1, (826 850305 076], (03/05/85)
Calculation 841 860429 902 8.
Conditions Adverse to guality:
NCR WBN SWP 8230 (SWP 821208 033],
( 12/06/82)
0
[IBWP 830216 006], (02/15/83)
NCR 6084 Rev.
0
[C24, 850606 100], (05/23/85)
NCR 6296 Rev. 0, "Transmitter Mounting Brackets,"
(09/03/85)
NCR,6084,,
Rev.
1
[IB26 851220 011],
( 12/10/85)
1 [841 851213 007],
( 12/13/85)
['841 860401 019],',(03/19/86)
0 [841 8511'l2 016],
( ll/12/85)
CA@ Engineerinq Report for SCR SqN CESAR 8612~
('06/03/86) 9.
Drawings:
~Seauo ah 47A050-47A051-1 (Rev.
2 through
- 7) Mechanical Hanger Drawing General Notes 1A (Rev.
0) 2 (Rev.
1 throuqh,.6) 2A through 23A (Revisions as of 08/24/86)
Series (Revisions as of 08/24/86) 'Mechanical Seismic Supports - Instrument Sensing Lines 38070 R3 (10/08/87)
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page C-3 of 6 47A052-47A054-Series (Revisions as of 08/24/86)
Mechanical Seismic Supports - Radiation Monitoring and Sampling Series (Revisions as of 08/24/86) Mechanical Seismic Supports - Control Air Lines 478601 18 (Rev.
- 52) Mechanical Instrument Tabulation 478601 21 (Rev.
- 52) Mechanical Instrument Tabulation 478601 21 (Rev.
- 53) Mechanical Instrument Tabulation 47W352 -
3 (Rev.
- 0) Mechanical Instrument and Controls Panel-Seismic Test 47W600.-
Watts Bar 47A061 Series (Revisions as of 09/20/86) Mechanical Instrument and Controls Series Sheets 1 through 16 (All Rev.
0) 47W600 -
19 (Rev.
5) 321 (Rev.
1) 47B2650 - 340 (Rev.
- 0) Mechanical RPV Sensinq Lines Pipe Supports Be 1 1ef onte 5GB0925-I0-02 (Rev.
- 14) General Installation Notes
( Includinq Bolt Torque Values)
-05 (Rev.6)
Channel Nuts and Bolts Assemblies
-10 (VOIOED on 03/14/83)
Tube Anchor Assemblies
-17 (Rev.
4), Tube Guide Assemblies
-129 (Rev.
- 1) Notes for Heat-Traced Tubing
-130 (Rev.
- 2) Support Oetails for Heat-Traced Tubing 38070-R3
( 10/08/87)
~,
c 10.
Test Reports:
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM Rl.:PORT NUMBER:
02350 RI..VISION NUM'BEA,: 3 Page C-4 of 6 0
Wyle Laboratories Test Report No. 42377-1, l'Seismic Simulation. Test Program on Instrumentation Rack," (Ill/I08/72)
Action Environmental T'esting Corp. Tes't Report No. T3-1091, "Seismic Vibration Test, of E10 Serie;s T'ransmitters,"
(12/73)
Wyle Laboratories Report No. 42807-il, "Seismici Simu'iation Test Program on an Instrumentation Rack,'" [no RIMS number'],
(08/26/74)
Myle Laboratories Report No. 17509-1, i"Qualification Plan for Fenwal Temperature Switches,"
Rev.
C, (05/07/82)
Instrument
'Tube Clamp Load Testing,
[B46 85041'1.002], '(04/12/85)
Instrument
'I'ube Clamp Load Testing
~ Additilna'1 7esting,
[846 850814 002], (08/16/85) 11.
Malkdowns and Trip Reports:
Walkdown in the Sequoyah Unit 1 Reactor and'Auxiliary Buildings, by the evaluation team on 09/18/86 Sequoyah Trip Re'port for September l9 hnd 20,
- 1986, IOM 563 Letter BLT-150, Browns Ferry Trip Rkpokt by'N.'.'hah'nd R.
G. Roberts
'n 03/03/87-03/06/87 (03/19/87) l Bellefonte 'Trip Report of 05/12/87-05/15/87, Bi T-232, (06/04/87-)
12.
TVA Memos and Letters:
TVA letter to Wolfe and Mlann Manufacturing
- Company, from F.
W. Chandler to 0.
M. Sa'iisbury on
'TYRE cont~act P2C33-92800 transmitting approval of'yle Laboratories Test Report No. 42807-1, (11/19/74)
TVA memo from F.
W. Chandler to R.
Ci. Oomer with attached, "GE Seismic Test Results,
- 225A6290, on Fenwal Slitkh 17002-'40',"
(06/24/75)
TVA memo from IR. 0. Lane to T. B. Ncirtiiern, Jr, "Watts Bar Nuclear Plant - Testing of Uni.strut Clamps," )SME'90710 001], (07/10/79)
TVA memo, from,lF. H. Coleman to CEB. files, "Seismic Qualificatidn of Foxboro Ser ies E10 Transmitters" for'BN Contract 828973,
[CEB 8109'03 252]% (09/03/81) 3807D-R3 (10/08/87) 0
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REPORT NUMBER:
22300 REVISION NUMBER: 3 Page C-5 of 6 13.
TVA memo from G. Wadewitz to J.
W.
Coan transmitting NCR 6287, Rev. 0,
[B26 850906 003], (09/05/85)
TVA memo from G. Wadewitz to J.
W.
Coan transmitting NCR 6296, Rev.
0,
[826 850912 009], (09/10/85)
TVA memo from J.
W.
Coan -to G. Wadewitz transmitting NCR 6287, Rev.
0,
[826 850923 009], (09/19/85)
TVA memo from J.
W.
Coan to G. Wadewitz transmitting NCR 6296, Rev.
0,
[B26 851021 005], (09/21/85)
TVA memo from R. B. Barnett to J.,P.
[B41 851009 001], (10/09/85)
TVA memo from J.
C. Standifer to G...Wadewi.tz, "WBN Non-ASME Significant NCR 6084 Rl and SCR 6084-S RO," [826 860121 128], (01/21/86)
TVA memo from R. 0. Barnett to J.
P. Vineyard, "SQN SCR SQN CEB 8612 Specific Bolt Tightening Instructions,"
[841 860220 005], (02/19/86)
TVA memo from R.
W. Cantrell to Those Listed, "ONE Interim Order-Suoplement to NEP-3. 1," [805 861222 501],
( 12/22/86)
Miscellaneous:
Construction Category Element Report C017303-BLN, Instrument Line Clamps, (10/16/86)
Appendix F of Sequoyah Nuclear Plant Quality Assurance
- Manual, "Design Criteria for 'Qual,ification of Seismic Class I and Class II Mechanical and Electrical Equipment,"
Rev.
2, (Ol/24/83)
TVA Design Interface Document CEB-DI 121.03, Rev.
1, "Seismic Design,
- Review, and Control," (05/16/86)
Project Instruction BFEP PI 86-29, "Procedure for Sampling of Class I
Small Bore Piping," Rev. 0,
[B22 861010 301], (10/10/86)
General Construction Specification G-53, "ASME Section III and Non-ASME Section III ( Including AISC, ANSI/ASME B31. 1, and ANSI B31.5) Bolting Material," Rev.
4, (01/12/84)
TVA SQN Construction Specification N2C-946, "Requirements for Tightening of Non-high Strength Bolts in Friction-type Connections,"
Rev.
0 TVA SQN ECN 6690 - Bolt Torque Requirements,[B25
'860515 515]
38070-R3 (10/08/87)
TVA EMPLOYEE CONCERNS
,SPECIAL PROGRAM REPORT NUMBER:'2300 REVISION NUMBERS:,3 Page C-6 of 6 TVA SQN GCTG Report GCC-13-59, (06/06/86)
Workpplans NW334P-1 and NW334P-2 describing the action plan to resolve the problems associated with clamp installat;ion and bolt torquing, (no RIMS number],
(01/08/86) and [no RIMS number] (02/07/86)
Quality Control Procedure 4.3-,
" Instrumerit Tub'in) Ihstallation," Rev.
0, (BLN 810105 389]., (05/01/79)
Quality Control Procedure 4.3, "Instrument Tubing Instal.lation," Rev.
13,
[C20 860612 461],, (06/25/85)
Quality Control Inspection Status, Computer Print-out BINJAN84, {no RIMS number],
(05/15/87)
Vendor Drawing, Fenwal Or awing 18003-7, Rev,i 8/7 (06/21/68)
Westinghouse Topical Report WCAP-8541,'eiSmic and Environmental Testing of Foxboro =Transmitters,'"
(07/75) 14.
Correct'ive Action Tracking Documents and Corrective Action Plans:
CATO 233 01 SQN Ol (10/24/86) and CAP (01/1'P/87)
CATO'33 01 SON 02 (10/24/86) and CAP (01/12/87)
CATO 233 01 SQN,03 (10/24/86) and CAP'(01/12/87)
CATO 233 01 WBN 01 (02/07/87) and CAP (04/09/87)
CATO 233 01 WBN 02 (02/05/87) and CAP (04/09/87)
CATO 233 01 BFN 01 {04/16/87) and CAP (06/27/87)
CATO 233 Ol BLN 01 (06/18/87) and CAP,(08/ll/87)
CATO 233 02 SQN 01 (04/11/87) and CAP (03/25/87)
CATO 233 02 WBN 01 (01/30/87) and CAP (04/09/8/)
CATO.233 03 SQN 01
( ll/20/86) arid CA'P (12'/03/86) 4l 38070-R4 (10/14/87) 0