ML20140C371
| ML20140C371 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 03/12/1986 |
| From: | Alexander M, Slagle F, Stevens W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340275 | List: |
| References | |
| I-85-709-SQN, NUDOCS 8603250334 | |
| Download: ML20140C371 (9) | |
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i TENNESSEE VALLEY AUTHORITY 1
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT NO. I-85-709-SQN EMPLOYEE CONCERN No. XX-85-053-001
SUBJECT:
INADEQUATE PIPING AND CONDUIT SUPPORT INSPECTION DOCUMENTATION DATES OF INVESTIGATION:
OCTOBER 23 - NOVEMBER 5, 1985 3
h INVESTIGATOR:
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A M. W. ALEXANDER DATE' REVIEWED BY:
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rom A 3/./sq F. J. SLAGLE DATE APPROVED BY:
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M f////II W. D. STEVENS
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BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern as received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern, as summarized on the Employee Concern Assignment Request Form from QTC, stated:
Sequoyah - Documentation sampling plan for pipe supports and conduit supports was inadequate:
Plan allowed accepting system with only 10% of the documentation. Cases of missing documentation were
" evaluated" away. In cases where 10% of the documenta-tion was not found, inspections / tests were.only redone to the extent necessary to reach 10%.
The CI does not i
believe this was adequate, and might not have met NRC
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requirements. Unit 1--1978 to 1980--auxiliary, control and diesel generator buildings.
Further clarification was requested from the ERT follow-up group, but they could provide no additional information.
II.
SCOPE A.
The scope of the investigation was determined from the stated
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concern to.be that of four specific issues requiring investigation:
a 1.
The documentation sampling plan used by the construction organization to accept piping and conduit supports was inadequate because it allowed accepting systems with only 10 percent of the originally required documentation.
2.
Cases of missing documentation were " evaluated away."
3.
In cases where 10 percent of the documentation was not found, inspections and tests were redone only to the extent necessary to reach 10 percent.
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4._ This might not have. met.NRC requirements.
B.
NSRS reviewed procedures used by the Division of Construction to document the inspection and testing of conduit and piping supports and reviewed historical records of support installations and testing. NSRS also interviewed TVA personnel who were involved in the piping and conduit hanger programs at Sequoyah Nuclear Plant (SQN) in the 1978 to 1980 tbneframe and reviewed NRC inspection reports for this period. The scope of this investigation was limited to unit 1 only as stated in the employee concern.
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III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments 1.
10CFR50, Appendix B, " Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants" 2.
CONST-QAP 17.1, " Quality Assurance Records" 3.
TVA Topical Report TVA TR75-1 Section 17.1, " Quality Assurance Program for Design and Construction" B.
Findings i
1.
General To provide better records management and traceability, a.
the SQN construction organization, in the 1977 timeframe, converted their inspection and test status tracking methods to a computerized system (the UNIVERSAL computer program). UNIVERSAL also included unique identifiers for each piping and conduit support.
This required that all construction inspection and test records generated prior to.the UNIVERSAL program be reviewed to determine their acceptability as current input.
b.
The construction review of piping and conduit support" records was conducted in accordance with approved Division of Construction Standard Operating Procedure (SOP) 551, "Past Records Review and Engineering Evaluation" (Ref. 5).
For those previously conducted tests and inspections that met current requirements or for which equivalent inspections had been performed, a ---
plus (+) was indicated in the UNIVERSAL status sheets.
l If current interpretations of requirements differed from those in effect at the time of installation SOP 551 required an engineering evaluation as a basis for their acceptance and a dollar mark ($) was indicated in 4
UNIVERSAL. Section C.3_of SOP-551_ states:
i The evaluation and acceptance of current j
inspection requirements may be accomplished by determining those records that can be justified by engineering evaluation and the application of the policy statements listed in Attachment F.
Attachment F contains the following policy statement t
relative to expansion anchors:
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Expansion Anchors Some anchors are not traceable to a lot.
Where this condition exists, areas may be divided into lots, total number of anchors counted, and compared to the records of anchors tested in that area.
If the records show 10 percent or more of the total anchors have been tested, this is considered satisfactory.
If less than 10 percent of the total was tested, then' additional tests should be performed to achieve the 10 percent minimum.
If the engineering evaluation concluded that insufficient evidence existed to establish inspection and test status, the feature was retested or nonconformed and dispositioned in accordance with other established procedures.
Presently, additional investigation and verification work is underway as the result of employee concerns XX-85-023-001 and SQP-5-005-001 through -007.
These verification programs and any subsequent corrective actions should provide a high confidence level that the existing installa-tions are adequate or identify any generic anchor problems which would then be covered in a further expanded effort.
2.
Conduit Supports a.
Construction records show that engineering evaluations were used as the basis for the acceptance of a significant number of conduit supports.
b.
Discussions with cognizant personnel reveal that a significant amount of rnchor bolt retesting to current'~~~
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requirements occurred at this time.
The status of these tests was indicated in UNIVERSAL as "*" with no indication
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of an engineering evaluation having been performed, c.
A random sampling of engineering evaluations indicates that a significant' number involved uses of the " policy state-
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ment" (10 percent sampling plan) as justification for acceptance of conduit support anchor bolts.
In some cases, sampling was used to accept conduit support welding. Most records showed that generally 50 percent or more of the required documentation was available for defined lots.
This was probably due to the extensive anchor bolt retesting early in the program. No instances were 'found where less than 10 percent was available, and no instances of retesting to obtain a minimum of 10 percent were found.
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NRC inspection reports of construction activities for the years of 1978, 1979, and 1980 were reviewed. No unresolved issues were found dealing with conduit supports relative to this employee concern, A Condition Adverse to Quality Report (SCR SQN CEB 8502 R2) e.
has been recently prepared stating that, " programmatic deficiencies have been identified with design and installa-tion of seismically designed conduit supports as shown on the 47A056 drawing series of typical supports." The Sequoyah Engineering Project has performed a preliminary evaluation of the identified deficiencies and has concluded that most of the problems can be resolved by field inspection, analysis, and/or testing. This effort, when complete, will provide a high confidence that the general-population of installed conduit supports are adequate or identify any areas for which corrective action may be required.
3.
Piping Supports a.
Piping support records were also reviewed for the UNIVERSAL i
program and the foregoing discussions generally apply.
However, piping supports have also been subjected to 1
several additional reinspection programs since conversion to the UNIVERSAL program:
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i (1) During 1979 and 1980, in response to NRC IE Bulletin 79-02, approximately 140 pipe support concrete anchors were randomly reinspected. One anchor failed to pass the inspection (failure rate less than 1 percent). T51s compared favorably with earlier construction testing (G-32 specifica-tion) of some 8000 anchors where the failure rate was also less than 1 percent.
(2) During 1980, in response to NRC IE Bull'etin 79-14, all safety-related piping 2-1/2 inches and larger was reinspected. This program included detailed i
inspecti_ons of_approximately 4500_ individual _ __
i piping supports for configuration, welding, and concrete suchors.
Fifteen deficiencies considered to be of serious safety concern were identified and corrected as a result of these inspections.
other deficiencies of a minor safety concern were reanalyzed or corrected.
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IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusions This employee concern was not substantiated; however, NSRS is aware of additional, current verification activities in this area.
Any corrective actions that may be identified in these additional verification activities shculd be implemented in an expeditious and thorough manner.
This employee concern is not substantiated for the following reasons:
1.
Conduit Supports a.
The 10 percent sampling criteria was applied only to anchor bolt testing and weld inspections.
It was not applied to any other tests or inspections. At the time of original installation, anchor bolts were tested in defined lots in accordance with construction procedures.
If an engineering evaluation was performed for UNIVERSAL, it too was based on a sample (10 percent) of a redefined lot. Test documentation showed that generally 50 percent or more was available for each new lot.
The current construction practice as defined in the G-32 specification stipulates a 5 percent sample size for large anchor bolt populations. With regard to j
welding tests it appeared that documentation problems were associated with lack of traceability of inspection records to a particular support. Since records showed that welding inspections had been performed and 50 percent or better traceability was generally present, it appears that welding on conduit supports is adequately documented.
b.
It appears that all engineering evaluations were performed in accordance with approved procedures, and no evidence was found of missing documentation being
. _. _ _ - _. _ _ _. _ _._.___" evaluated away" without following. approved. procedures. __ _ ____.____
c.
No evidence of retesting or reinspecting to meet the 10 percent minimum criteria was found.
d.
No evidence that NRC requirements were not met in this process was found.
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Piping Supports 1
The above conclusions relative to conduit hangers also apply to piping hangers.
In addition, recent detailed reinspections of piping supports to meet NRC requirements have provided added assurance that piping supports have been properly installed.
3 B.
Recommendations None
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t DOCUMENTS REVIEWED IN NSRS INVESTICATION I-85-709-SQL AND REFERENCES i
1.
NRC Inspection and Enforcement Bulletin 79-14. " Seismic Analysis for As-Built Safety-Related Piping Systems," dated July 1, 1979 NRC Inspection and Enforcement Bulletin 79-02 R2, " Pipe Support Base 2.
Plant Designs Using Concrete Expansion Anchor Bolts " dated November 8, 1979 3.
SQN Maintenance Instruction MI-6.17
" Instructions for the Implementa-tion of NRC IE Bulletin 79-14" 4.
TVA Division of Engineering Design, Civil Engineering Support Branch Report No. CEB-84 (undated, not issued), "Sequoyah Nuclear Plant -
Report on IE Bulletin 79-14 Inspection / Evaluation Programs" 5.
TVA Division of Construction Standard Operating Procedure (SOP) 551 RS, "Part Records Review and Engineering Evaluations" 6.
TVA Division of Construction Standard Operating Procedure (SOP) 102, R4
" Conduit Hanger Installations" 7.
SQN CONST piping and conduit support inspection records contained in the UNIVERSAL computer program 8.
SNP Construction Procedure P-24. Revision 4. " Inspection and Test Status"
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SNP Construction Procedure C-8, Revision 4. " Expansion Anchor Installa-tion. Testing, and Documentation" 10.
Letter from L. M. Mills (TVA) to J. P. O'Reilly (NRC), "Sequoyah Nuclear Plant Units 1 and 2 - NRC-IE Bulletin 79 Final Inspection, Reports," dated April 3, 1981 (A27 810403 011) 11.
Letter from L. M. Mills (TVA) to J. P. O'Reilly (NRC), "S'equoyah Nuclear Plant Units 1 and 2 - NRC-OIE Region II Letter RII:LM Inspection Report - Additional Information on IE Bulletin 79-02," dated I
January 2, 1980 __ __ _
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SNP Construction Procedure P-30, Revision 5 " Fabrication and Installa-tion of Seismic Supports" i
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NRC inspection reports for 1977-1979 14.
Condition Adverse to Quality Report, SCR SQN CEB 8502 R2, preliminary
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telecopied to plant on November 14, 1985 7
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N UNITED STATES GOVERN 5!ENT Memorandum TENNESSEE VALLEY AU'1 IORITY TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FROM: K. W. Whitt, Director of Nuclear Safety Review Staff. E3A8 C-K MAR 131986 DATE:
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSMITTAL Transmitted herein is NSRS Report No.
I-85-709-SON i
Subject INADEOUATE PIPING / CONDUIT SUPPORT INSPECTION DOCUMENTATION Concern No.
XI-85-053-001 No response or corrective action is required for this report.
It is being transmitted to you for information purposes only.
Should you have any questions, p12ase contact W. D. Stevens at telephone 6231 Recommend Reportability Determination: Yes No X
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' I frector, NSES/Desi nce
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WDS:GDM Attatament cc (Attachment):
W. C. Bibb, BFN W. T. Cottle,_WBN __--________..___..
James P. Darling, BLN R. P. Denise, LP6N40A-C G. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C J. H. Sullivan, SQN 3-ITY S597U
_ Buy U.S. Savings Bonds Regularly on the Payroll Savings Plan
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