ML20147D242

Forwards TVA Employee Concerns Special Program Rept, Heat Code as Re Matl Control. Info Provided by House Interior Committee Staff

ML20147D242
Person / Time
Site:	05000000, Sequoyah
Issue date:	09/26/1986
From:	Kammerer C NRC OFFICE OF CONGRESSIONAL AFFAIRS (OCA)
To:	Asselstine, Roberts, Zech NRC COMMISSION (OCM)
Shared Package
ML082310247	List: ML20147D242 ML20147D488
References
FOIA-87-726 NUDOCS 8801200106
Download: ML20147D242 (27)

Text

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3 j#* ""%o, UNITED STATES eq) p ' ^,

. NUCLEAR REGULATORY COMM;5SION 5yg

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WASHINGTON,0. C. 20555

'f September 26, 1986

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MEMORANDUM FOR: Chairman Zech Comissioner Roberts Comissioner Asselstine Comissioner Bernthal

' 1 Comissioner Carr

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arltqa Kamerer, Director FROM:

v(fice oTCongressional Affairs SUBJEC1:

INFORMATION FROM HOUSE INTERIOR COMMITTEE ON TVA Attached is a report from the TVA Employee Concerns Special Program concerning material ' control at the Sequoyah Nuclear Plant. This

'information is provided by House Interior Comittee staff.

Attachment:

As stated cc:

ED0 OGC OI OIA NRR IE RII 8801200106 880114 PDR FOIA

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TNA EXPLOYEE CONCERNS

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REVISION NUNSER: 0 sequoyah Nuclear Plant - Element REPOAT TfPE:

PAGE 1 0F 26 Heat Coda as Related to Material Control TIT 1.E:

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-? 17 B,c REASON FOR REVISIOf4: p a,l on Weo Fon 9 /'Z/M

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. pre PREPARATICN PREFARED BY:

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CATE SIGNATURE CCNCURRENCIS ctc u-S8P!

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REVISION NtJMBER:gggggy,,

SPECIAL PRCGRN1 ppGE2.CE26

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e t (SQN), Construction ptre000CTION endations contained in l

2 The evaluation of the Sequoyah Nuclear P anHe the Nuclear Safety Review Staff (N

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[thatasearch folicws:

"Therefore, it is NSRS's recommendatio that a history d

of documents / files / procedures be ma e soof th ted to include T.

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the following:

s generated.

(1) The purpose / reason' the Heat Number Sort wa l ented to (2) Those esnagement controls designed and imp em administer the program.

d to serve ar.d the (3) The function the program was designefunctio

, r... ith the avai'lable Sort printout)."

(4) The confidence OC management has A response to these recommendstions was p9 007) and was deemed NSRS lanned to t'anager of Construction (C01-85-052 - (QO1-85-07C9-054). tion of further satisf ac': cry by the Director of NSRS this matter further; however,,no indicathus loaving,the inves:!gati investiga: ion could be found,

) Employee Concerns T,ask Grou Also, a Watts Bar Nuclear Plant (WBN(ECTG) nueber MC 40703, performed at W3N an i

SCN.

.P_l. ant Sitas, includ ng ce*woY OF DEgegivgo Mc3' M fellowing cencerns, is *,hera d8F e

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o The perceived problam, as mat ods u e[ in :no Construe icn He eri MS-*

.poyar stercrecs 34':

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a lack of croci-.

n of preparty Ca d.ad W M is SOFT EIC9# 3 )' feh et eat (M rm i/A-:'5 inst 3113t!CG' Materials, at Ce r s t"2 C t!25 t,,

i IN-35-5AS-XC7 W:-85-C02-C02 r

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HEPORT NUM8ER:'

o TVA EMPLOYEE CONCERNS FOR SPECIAL PROGRAM REVISION NUNSEN:lNFORMAT ONLY

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PAGE 3.0F 26

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Nuclose Pcwect EX-65-013-001 IN-8 5-6 60-001 III. EVAL.U ATION t'ETH000t.CGY A.

Constrwetion:

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Reviewed expurgated files to',obtain additi,onal information.

1.

Reviewed upper-tier criteria to determine: the requirements governing the installation of pressure-retaining materials.

2.

Reviewed site procedures to determine how the upper-tier 3.

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criteria was implemented.

Conducted. interviews to detarmine the process used in the

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4.

verification of installed materials.

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Performed a random sample of pressure boundary-material installations and a review of the associated weld do 5.

d to decermine if the material installed was properly identifie and traceable to its certified Matorial Test Report (CMTR),

__uclear Dewer:

N B.

k 4, LATER IV.

_ SUM.YARY OF FINDINGS Conste;etion:

A.

A review of the ex;urgated files revealed no additional 1.

inf ormatien.

A review of the upper-hier criteria revealed the f:llcwirs:

2.

(75AR), Revision 3, does The Final Safety Analysis Re,cortrot centain a citar de a.

censtruction Record for Nuciaar Class I, II, and :::Oiscus siens with corso activities at SCN.

Standards and.datarials Ingsncaring Occua of tha ar:

Nac! car Engineerir7They state: "The a:elica'ela Cada of Roceed is si:u2-icn.

0 Adderoa for tne f 2 rication, ANSI 33:,7 (1959) and 197,irenents of '.'ucioar C'.as s I. II, ins: action, and test requ piping systae.s and tha:

a (TVA Class A, B, and C/0) and II to

.-avisien to the FSAR sec::en 3.2.2,5 is necessary Tha F3AR st:ted, clarify this situati:n."

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-FOR TVn EMPLOYEE CCNCERNS REVISICN NUMSER: t l

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SPECIAL PROGRAM ONL'T FAGE 4,CF 26 "Fabrication, inspection, and testrequirements Case 115, have been used in lieu of the applicable nuclear code cases for allpipin looes and the eressurizcr surae line831 Case 115 ac Section III as meeting 831.7,requir,ements."

pioing.

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Since the aeplicable code requirements for the primary coolant loops are not defined and there is no clear distinguishing boundary between it and its branch lines,

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Chemical Ve';.7.e Control System (CVCS) and Safety Inj System (SIS). piping material included in this report ha been evaluated based upon the applicable Code of Reco ANSI B31.7 (1969) and 1970 Addenda including, the ANS 831,7c-1971 Addenda parsgraph 1-723, for matorials identification and certification, per SQN Construction Scecification NO. NZM-865, ?Fleid Fab 3, dated 4/12/77.

831.7, (1969), 1970 Addenda and The Code of Record, ANSI 1971 Addenda e paragraph 1-723, for material identi 1-723.1,3(a) states in and certification, paragraph. identification of pressure-ret il licable shall consist of marking the eaterial with the app part ".

heat code material specification and c/ade, heat nucher, or d __t_o of the material, *ard anv add!)iedal sarkico recuireof all facilitate teseeability

ial, tas:s and examinations. performed on tne cater identifies Alternatively, a marking syebol may be used which king the material scocificatien number and c br Certified with the Certified Materials Test Re: ort. *I54 Ma erials rest 44:ert ene sv-:vi _ars :-* cect."

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.EPORT NUMBER:

I i. EMPLOYEC CCNCERNS 1NF0k(TV3 SPECIAL PROGRAN REVISICN NUMBER !

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PAGE 5 0F 26 SQN is committed, in se: tion 3.1.2.1 of the FSAR, to the b.

requirements of 10 CFR-50 Appendix B, "Quality Assurance Criteria for Nuclear Powgr Plants and Fuel Reprocessing Plants", which states in driterion VIII, "Measures shall be established for the identification and centrol of materials, parts, and components, including partially fabricated assemblies. These measures shall assure that identification of the I

item is maintained by heat number; part numcer, serial number or other appropriate means, either, on the item or on records traevable to the item,'as required throughout fabrication, erection, installation, and use of the item. These identification and control measures shall-be designed to prevent the use of incorrect or defective eaterial, parts, and cempenents.",

3.

Review of site precedures:

Site Procedures used during the coratruction of S0.'J pertaining to carking and identification of receised a.

catarial, consistad of the following:

SNP Construction Procedure NO. M-7, "Erection and Occumentatian, Require, cents For Piping Systems Within The scope of the Quality Assurance Plan" (M-7), Revisica 0, dated 08/25/72 tnrcush Revision 15, dated 01/02/20.

SNP Inspection Instruction NO. 30, "Receipt Inspaction" (II-30), Revision 0, dated C5/C4/77 through Revision 7, datad C9/10/92.

SNP Constructica Procadure NO. P-34, "Maat Number Valida:!cn" (P-34), Revisien 0, da:sd 05/13/77 and Revisien (, dated 12/13/73.

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IPORT NUMBER:

Ts.. EPPLOYEE CONCERNS FOR SPECIAI. PROGRAM REVISION NUMBER:

INFORMATiON l ONLY PAGE,6 0F,26,

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SNP Inspection Instruction No, II-39, "Heat Code Transfer and ASTM Oasignator Transfer" through l.

(II-39), Revision 0, dated 05/04/77 Revision 2, dated 12/11/70.

SNP Construction Procedure No. P-31, "Identification and Marking of Permanent Material" (P-31), Revisica 0, dated 05/04/77 through Revision 2e dated 12/17/79.

A review of these procedures revealed

• that only one provided methods procedure. M-7, Revision 0, dated 08/25/72 for the material to be traced to the certification recerd_,

Later revisions of M-7 and additional as per the code.

associated procedures, were developed that required received materials to be marked, so that, at best, materials could. -

The only be traced back to the procurement contract.

precedures governing "heat number validation" upon material (i.e., P-31, 9-34, and II-39) do not contain a rece'ist e.ethod for material identification and barking traceable to the C.T R.

Site precedures used during construction of SQN pertainir.g 6.

to material identification / verification at installation, consisted of the following:

S.JP Construction Precedure No. M-7, "Erectien and Occumentation Requirementi Ecr Piping Systam.s Within The Scope of the Quality Assurance' Plan" (M-7), Revision 0, dated 09/25/72 through Revision 15, dated 01/02/90.

"Fitup and SNP Inspection Instruction NO. 74, Cleanliness" (II-74), Revisien 0, datad 02/14/777 thecu;h Revision 6, datad 07/23/92.

that only one A review of these peccadures revealed required ths procacure, M-7, Revision 0, ested 09/25/72, esterial certification to be on hard and be acceptsele.

Later revisicrs only required tho material to be listed en the Wold History tocord, unich was then certified to he in accordance with ac;1icatie deswings, codas, ard s;ocificatiens, by signa:ure.

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/ ORT Nur.8ER: -~~FOR TVA EMPLOYEE CONCERNS INFORt'. ATV3M SPECIAL PROGRAM REVISICN NUMBE :

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required Sita procedure II-74, Revision 0, dated 02/14/77, examination and, verification of acetotable grade, and ASME Classif testson, with the prov hich was

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material used shall have mar'c and/or heat nu r

- card.

Site procedure II-74, Revision 1, dated 05/12 h

terial esterial identification, with the provision t at m.a used shall have marw and/om heat number, card.

Site procedure II-74, Revision 3, dated 11/07/79, and subsequent revisions, required examination and verification that the coreonent identification wa i

seccified on the acelleable weld mao, with a provis on i

that piping material required heae nuicor verifiest en, which was cartified, by signature, on cata sheet or equivalent data card.

No sita procer'ure could be fcund to describe the heat num:er verification Note:

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cass.

.* l, No site procedure could de fdund Nota: severning tha accuracy of the informati:n or the use of the bNSP, only a Usar's Guide was fcund, describing nca information sr.culd he enc:ded.

Interviews cenducted with persons who perforr.od inspecti f

and/or verifica: ions of matorial during tna cesstrue:icn o 4.

SQN revealed the follcwing:

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.EPORT NUMBER: i FOR T,n OKPLOYEE CONCERNS REVISION NUMBER:)

ONLT SPECIAL PROGRAM t

PAGE 8 0F 26 Interviewee A.

Interviewee was a Qual ty Control Record Reviewer in Interviewe-a said, "July 31, 1977, was the construction.

approximate date the weld review group was formed to input information that was available onsite into a computerized This contract information was used to develope a heat cede or bast sort printout for material received with pregram.

Material for SQN procured by Quality CMTRs, MTRs, o-COCs.

Engineering Branch Contracts by Knoxville and inspected at the factory were not always encoded because Knoxville received all of the CMTRs, C00s and other rolated The information encoded in the printout documentation.

consisted of the heat number, sometimes the class of raterial, if known, the 209 number, the contract number, and a description of the material.

Interviewee did not knew of a procedure governing the use of the printout or for its control, there was a Users Guide and other information compiled to aid in the encoding process. involved., When interviewee began working in.the QCRU grouo, part of the responsibility of the grouc ' as to review the weld cards w

When the cards were received they were checked (SNP-II-74).

All blanks were filled in or N/A, the for the folicwing.

welder was certified to the process used, the inspector was certified to the inspecticn procedure, and that b:th If the heat c:mponents' heat numbers were in the printout.

nunbors were in the printout it meant that there was either a C00 or CMTR or sece kind of documentation."

Curir.g the intersiew it was revealed Note:

there was sc a prcblem with some puoole not knowing the difference between a CMTR and a C00.

Interviewee said, "There was not a recuirteent fer the reviewar of the data card to eneck for class, si:t, ty:e or When the review of the cares was grade of the material.

complete the heat nuthers sere tnen written en the sold The heat code printout was up-dated, usually once a map.

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FAGE 9,0F 26, e

Interviewee 8 Interviewee was a Construction Welding Inspector from Interviewee said, "I do not.

December 76 until August 77.

remember very much about the program that was used at that time except that they rec 9eded the information, heat, numbers of the naterial welded together, on a data card.

They wrote the heat number down which was on the matorial and then wrote it down on the data card. Thoy verified the heat numbers against the printcut, but, I do not romumber if they were required to check to see-if it was the correct code class."

Interviewoe' C Interviewee worked in construction as a QC Welding Interviowee Inspector from January 1977 until April 1981.

An said, "There was a procedure used before SQN II-74 (M-7), where code walds were controlled on what was called It. contained'all inforeat' ion needed a Weld History Record.I think the information on the Wald to track the work.

They History Record was then transferred to the data card.

used the weld man to deternine what matorial was to be but there was not a requirement that they go back to the printout to see if what the fittars had was the correc code class.

printcut."

Interviewas 0 Incarviewee was a Ccnstruction Weldicg Inspector from 1977 Intarviewee said, "I vartfied the catarial was until 1992.

sort print:ut. S ma of the correct by checking tne heat materist had the cede class marked en it with a pink paint

stick, If we ceu!d no: find tna class in ene printout or if it wasn't earkad on tha ;1:e wo s;uld rely on the craf t to tell us if it was the rignt mactrial."

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REPORT NUNSER: I FOR WA EP.Pt.0YEE CCHIERNS INFORMATl0K

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$PECI AL PROGR A.'1 REVISICN SUMBER ONLY PAGE 10 0F 26 w

Interviewee E Interviewee was a QC Inspector from 1979 Until 1902 in Interviewee said, "I verified material by The question was asked, "If construction.

use of the II-74 data card."

the interviewee checked the class of the material befor signing the card?" Interviewee said, "No, I only wrote down I did not use the number of the material that.was used.

the printcut, I think Record Review checked this later because if we made a mistake they would send the card Interviewee stated again, "I didn't use the printout, I only checked the wel'd tnaps and filled out the back."

data card."

_!nterviewee E Interviewee was a C:nstruction Welding Inspector who said, "We verified heat numbers by checking to see that they were on the material being used, we then wrote this number down on the data card, QCRU reviewed the cards and I think they We checked to see if the number was in the printout.

(welding inspection) did not do any checking to see if the caterial was the correct cede class, I did not use the heat I only wrote dcwn the heat number that was l

sort print:ut.

Before we used the data cards we verified on the material.

esterial on a wald history recora under a dif ferent I do remen:er, eqe. case, where I fcund ser.e schedule 40 e.aterial with the same, hea; number as sche procedure.

80, but this was changed out,"

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P AGE 110F 26 a

Interviewee G from Interviewee was a Construction Welding Inspector id, "The March 1975 until December 1979, ' Inte b

I would leg the heat and/or heat number written en it.

Latar, we used nunber down on the Weld History Record.

The question material was tne h

was asked, "Did you check to see if t e id,

right class and type or grade?" Interviewee sawe i l with.a somettees the class was written'en the mater aI only "Inspectors h

If it was pink caint marker.

tha printout which was kept in the pipe s op.Sometimes it

!n the printout it wat considered good.

ll the would not be in the printeut and we wou card."

said.the material was good, I would sign the Interviewee H 1973 until Interviewee was a SCN P.ech5nical Engineer f ro1 knew of any Interviewee did not t additional 1979 in Construction.

official system or process used to verify tha d to ensure checks other than inspection, were per d

Interviewee stated, "That an employee who worksd in There d a CMTR.

of checking of material to see,1f it ha' inspectors callad was a printout in Welding and when thef it was in the in, the employee would look it up to see iif if it Ine

printout, Goed ceans it has a CMTR.

ugh cur was goed eatorial.

pregram changed as did the pr:ctdure thro This was due to roccgnizing a construction.

better control.

escarial used was,of the correct classtre ured this. My feelirg is tated on very goed an:

job Cesttsman, that took pride in d:ing the best possible."

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..lPORT NUr.8ER: iMM*NLY O

TVA Er.PLOYEE CCSCERNS

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SPECIAL PROGRAM AEVISICN NUNS PAGE II 0F 26 Interviewee 1 Interviewee was a Mechanical Supervisor a Interviewee relied on the May 1977 until April 1979.

HNSP whenever a question of<matarial verification came NAVCO supplied pipe had unique serial or mark Some TVA loose material had TVA mark '

up.

numbers and is identified this "way; however, material numbars on it.

hought on I.Q.T. contracts did not have mark numbers, only heat numbers.

Interviewee _7' Interviewoo was a welding inspector at SQN from 1975 until 1979 and stated,""I was connectad.with the program shape, or form and correct class l

verification of material was not used, inspectors on y in some way, checEed to see if the material's heat number w

printout, I feel SQN is required to use used in any ecde systen.

code catarial and all Class' A cust have a CMTR A or eaterial must be up-graded, which requires a CMTR and an NCE, PT, minimuns."

Interviewoo K Interviewee was a Mechanical Engineer at $QN from 1973

'11 Interviewee statid, e."We 'found mate installed at SQN, that wa did not have CMTRs for and th through 1979.

manuf acturer suppliad them at a lator data. 'There were il cases where no CMTR coulc he obtained and this (Repla:ad with different eut ar.d ree.oved.

The venders startad sueslying CMTRs witn scme was cu:

eatorial no mattar how it was requestad.

SON has also matarial),

for estarial that they tay not have even received CM733L:esa Material, raf errad to as LM shoa:s received.

estarial was to be installed at what designa:ad una:Hewevar, ducir; construc:!cn it was learned these ceuld not be relied v:en for ac:uracy, due to Ic:stien.

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1. cice waranousing lack of control in issuing ra:er a.

to ;; becemirg involved in !sive of estarial,waraheusirg pars:n

1774, a;:c:simately Ce:amnar.

write tSo nsaded LM nurcer on pick up i like fittsng ar.

it ard issue it."

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SPECIAL PROGRAM REVISICN NUMBER:

PAGE 13 OF 26 f

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No site procedure was found

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Note:

describing the use of "Loose Material (LM) sheets or numeers.

Interviewee further stated, "SQN operated under the SQ.1, had a CMTR or MTR for a principle that if theye particular heat number, it was considered good for~any product or type piece of material that uas made cut of it.

There was a lot of material that was installed that SQN not have a CMTR for and interviewee contacted the manuf acturer to obtain a CMTR, if one could not be obtained,

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CMTR's'for Class A were not looked the material was cut out.

at as being unique to_the actual

• material that was received,"

Interviewee _L Intarviewee was part of a task force set up to correct heat The codes on weld documentation from 1977 through 1979.

foll'owir.g is, sur.tary of interviews *with this person.

If the wald documentation material ident'ifiest documentation the intarviewee was directad by supervisory

ersonnel to analyze and correct erroneous and discrepanc Intarviewee weld documentation / heat numbers, as required, statad, "Inspectors were used to reverify, discrecant heat If the heat nueber sculd not be read in tha field, the sucervisors inservettens Vers. to. change the weld codes.

co:umentation so that both dccumants would agree, with the information on the document with tne latest da:e."

Interviewee changed a;;r:<irataly tan to twenty discre:so:

Tr.ase were heac codes per day, from 1977 :nrcugh 1979.

lined thecush, initialed and dated by the intarvios:e,rsenal judg-ent ins:ect:rs infor-acien, or ;a based u:en, that tha heat cede numbor had been incteractly writtan, (e.g., character trans;0sition or emissico) based y:0n hcw c0de ac; eared in the H5NP.

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PAGE 15.OF 25 Interviewee expressed doubt that Note:

. _all the heat code numbers to be

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rechecked were actually field verified.

Interviewee stated, "When weld documentation was lost or could not be located the insee.ctors were requested to check the field installed material, if no i.dentifying markings were found, new documentation Uas constructed f ecm the best available infermation, obtained from the following:

N inspectors' memory, inspection log sdeets or Coeration Checklist."

No site procedure could be found Note:

describing or defining the function of the "Coeration Checklist."

Randem St-ela inviau 5.

A review of material identified on 16 TV'A S;N weld m[ps, consistir; of S for Unit 1 ar.d 3 f or Unit 2,'en Class " A

Systems (Chemical Volume Centrol System, installed.

with the proper certification was are as fellews:

T%e reviewed Wold Mao Orswi-es

,. Unit 2 Uni 1_

2-CVC-5CC-1W 1-CVC-5CO-1W 2-CVC-501-1W 1-CVC-5Cl-1W 2 ~VC-5C1-2W 1-CVC-501-2W --

2-CVC-5C2

• .W 1-CVC-5C2-iW 2-C'. C-50 2-IW 1-CVC-SC2-2W 2-C'.'C-5 C 3 -1W 1-CVC-5CJ-1W 2-CVO-500-!W 1-CVC-5C9-1W 2-SI-5CC-1W 1-S ~- 5C O-1W This ra situ was limitad to a trall tam:'.e of deswirls fo thr:u;5 2", TV A Class " A" pres sure teur:ary ca arials.

das us9d fcr -aticial identif t:a:.:n sh:wn on these c:tes, Tbg hea:

drsair;s r.are tatt.ated ar.d censis ted Of $ 9 raa idsntif irl 517 itins.

The ecnstructi:q -f;I? (: 1:4d 4-25-04) de:armica if thesa haa: c:t*s wara ;ra:aa:!c to

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f*r these hea" was revie.ed ::Fren refereccas listad in the k'.02 thair CF71s.

F1 Storial cc:a s, tV A Racel'/ing Reports (TV A-2C9 5), con;ait 8

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quan;ittes and d::urenta:! n Pacst sed, wara cc:aine

REFORT NUMSER:,,,,..... #

TVA EMPLOYEE CONCZRNS AnOR REVISIC$ NUMBER:m/0ON PAGE IS OF 26

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In some cases the TVA-209 reference was in error, omitted or did not Note:

contain the material documentation.

i A revi2w of the TVA-209s and their attached docu revealed:

Class " A" and "B" or lesser material was received withid

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to distinguish between classes.

Material with identical heat codes was 2.

or pressure class).

)

Some material was.ident;fied by a Loose Material (LM Nuecer (e.g., NAVC0 Pipbig), and some was not (e.g.

3.

LM numbers are not Caeitol Pipe & Steel Products).

il unique to the heat number / code, pressure class. mate discriptien or product form, and in most cases are not ref erencad en the CMTR,' filed with the TVA-209.

identifying it as Some matarial had addittenal markings 4.

acceptacle for Class "A" use.

h Therefore, a comprahansive walkdown of the piping on t e i as Unit raf arenced drawings was perfcereo by Medificat cif any, aedit personnel to determine what,

~

e.

tne installad ma:arial.

he heat Results of this walkdcan differed significan:1y' fren ttr.eraf e:de information on the 'Aald Paes;of the weld doc d

inf:rrati:n cor:aring the doeurantad ra:arial idantificationweld docum This review, ::msisting Of wi:n tha; en adjacan f r:m tha ;icir.g systems walk:0wn.

657. of the do:uranted '*4!ds reveale: :na:

573 wald decurents,-atarial iden;tf t:sti:n discre:anc:as (e.g.,

with walk::wn con:atra:

r aat nur:ars, dis agree-en:illigible an: ries, en ald irce-cla a 00:u en:s).

cc:.r.ents, disagreerant be:waan adj acant.al:

inf:r-a::en,

!s crasen: Ad as rt:rattatatiza

!!s; :/ ata-:las he i>4r, i us-Tha f:'.'.:

iri of sere :f tra firciras of ints evaluat::n:

c -:rtaarnve in naturi.

I

a c:nsisare:

ru:

1

?

)

l I,

8 1

~

E N =isca$2 %.- -

_..e REFORT nut'aER:

TlON TVA EMPt.0YEE CCNCERNS WO 0

SPECIAL. PROGRAM RE'/ISIC4 nut'8ER

/

PAGE L6,OF 26 Examole A:

identification of '-

"CMC" is used as the heat code for material ld num'cer one of the components on the weld document for we"CNC" is listed 2CX-0114 A 1, on weld mao 2-CVC-501-2W,HNS d

l t'achine Co.

material descriptions, manuf actured by Coloniarather, it is the "CMC" is not a heat cede:

for C_olonial nanuf acturer's identification ecde 'and stands

However, Machine Ccepany.

Exa-ole B.:

ling 2" 60003 socket weld (S/W) coup "CCI" is a heat cede for a(epig.), Schedule (Sch) 160 Bo "A" and "S".

are two entries in the HNSP, one each for Cla ived The CMTR fi el d with this on 10-2-75, en TW204 #75-7922 t ant TVA-209 identified the fittings as having been Liquid, Pene tested and as IA clear Class I-P/A Class "A"; heweverf.no the CMTR, special identif t:ation ear'<ings ' ware denoted onThe ea:erial id truceable to the fittings.

1. 76-1379. The as Clas s "5" was received on S-21-75, on 7/ A-209 Nuclear C.WR filed witn this TVA-209 identified the i

car't.ings were denoted on tne CMTR,A;;roxi-ately h

One example of wai:<dewn :erf ort.ed for this evaluatieg.installa:ic 01256 and 2-CX-01257.

e O

f I

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f e

a m n o e

.l "hlO TVA EMPLOYEE CCNCERNS REPORT NUMBER:

f SPECIAL PROCRAN WOR REVISION NUMBER.

ONL PAGE 17,OF 26 Examulv C:

i

/

"CZC" is a heat code for 1"X3/4" 6000# in'serts, A182 F304, for both Sch 160 bore and a special 0.375 inch bore. The HNSP f

l revealed three references to TVA-209s, one for Class "A" and two for Class "B".

The traterial identified in the HNSP as Class " A" was received on 9-17-75 on TVA-209 #76-2235. The CMTR filed with this TVA-209 identified the fittings as having a special bored inside diameter (IO) of 0.375 inch, as having be,en Liquid Renetrant tested and as Nuclear Class I-TVA Class A; however, no special identification markings were denoted on the CMTR, traceable to the fittings 3 The natorial identified in the HNSP as Class "B" was received on 3-17-75 on TVA-209:

1. 75-5643 and #75-5674 The CMTR's filed with the se TVA-209:

identified the fittings as having a Sch 160 bore and as Nuclear Class II; again, no special identification markings wore denoted on the CMTRs traceable to the fittings. Apcroximately 10 of these "CIC" fittings are installed, per the weld document'atten for the reference weld map '.* swings; however, the walkdown perforced for this evaluation identified only two.

Note:

The FS AR in paragraph 3.2.2.1 states in :: art,

... Branch piping 3/8-inch inside diameter or smaller, or protected by a 3/9-inch diameter or smaller orifice, is exempted fron Class A..."

The use of the 3/8-inch dianeter or scaller orifice is not ccnstst:ntly iden,.ified on the weld documents for caterial identifica:icn.

An examole of installation is Wald Mac 1-CVC-io:-:W: weld num ers 1-CX-02:4 3 a nd 1-CX--3 214 4 1.

Those. eld doeurents d:,

not denote :his fittir7 as having a special 1/3-i.:n bere, as recu! red by the weld eso.

The field salid:wn revoa*.id :nis fit-ing is a 2"X3/4" S/S reducing insert sts.;ed "0;C".

Another aus.:la is Wald Pap 2-CVC-SCO-1W: weld euder 2-CX-012 5 5 identifies the material as a 2"X3/4" redu:irg i stert wi-n the hest ecde "CNC" whi:n has caen lined thecun, initialed and tated, and changeo to "0;C".

Adjacant Weld ru-:ce -CX-C1:!6 identifie s the.a:erial as a ;"X2/4" ep:.31 ft:a inser:, witn heat cc:e "C C".

~

':..;..: y 't..v... _. _:.. _.,. v:,,, _. _

REPCRT teBER:

\\08

7 -

TyA Et*PLOYEE CCNCERNS CNd SPECIAL PROGRAM REVISICN NUMBER.

/,

e PAGE 18 CF 26-f.'

Eramole O_:

CO-1W ~

"CCF" appears on the marked up copy of W I

"CCF" is not listed in the HNSP.

is 2-CX-01020 and 2-CX-01C21 were reviewed to determ documented as installed.

insert with t e heat code h

4-16-73) denotes a 2"X3/4" 4000#Adj acent weld docum denotes a 3/S".special rest, with the beat, code "CNC".

"CNC",

Weld number 2-CX-01021 has been cut out and reinstalled 2 additional Note:

times, creating weld documents for (2-CX-01021 1) and (2-CX-01021 2).

3/4" Wald documen,. #, or 2-CX-01021 1, (d:.ted-5-11-79) denote s a "CvC" this heat gede ta a

a M

, aM, CMW as I red hc to "CCV".

M) d"oti' "

Wald document for MX-010212, (jatad l

• " h at cede,CCV".

S/S (flow restric, r) Wit

.e 2"X 3 / 4" inser:

no identificatien, tar W as The field wal'<down revealed tha:

were on this fittir.g.

The heat cede for the.fittin9 Note' was initially identified as "CNC", later changed to "CVC",

and then changed again to "CCV";

- i e ld '* 5 I'4 d C'*"

f ns.4ever, th revealed a identif!:3t! n rar<ings.

-E t a-a l. 43 0C00.1 and 3000d ;educif 9, 3 hast ceco for 2"x3/4" r o s c o c :'. i e a / -

,, q"..~, 1 3 %~ egd for sen 150 and Sen 4C, i ns.

rm

++e for e *mer. atertal de scrin o t

7,,;,.h es in tre HNSPs7=-sa75, to:n were r"*iv

-re he.

C a 3133

-o ~V- M ? 5 "#f3 3,

'~' '

' ',S d' w "~, ;r e s s TV.*.- 10 0 s r h u l e d th i c a: a r t a,. t e b c

3. -

',~~

sc:C;f reduc,.P?,.nserts, e.c.,4o u roa,ss havirg been 4

1 C.M I S o,,,

[*C

,,. y yo 8 ~

E*2AI act: rant tesIId End SI n;;;;3 ro s:acist i:om:if tes: :n urur95 "ar'

.4 r,

c,,p, traccacia to the fitt!rl5' e

REPORT NUM8ER:

pgg TVA EMPLOYEE CCWCERNS "k

fg.gy,g SPECIAL PRCGRAM CMLT.

REVISION NUMBER:

PAGE 9.OF 25.

Approximately 3 of these fittirsgs were installed per the weld documentation.

Examples of installation are:

Weld Mao 2-CVC-500-1W; weld number 2-CX-01059 and adjacent weld number 2-CX-01050 both identify the material as a special

{

reducing insert, with heat code "CNC".

weld number 2-CX-01158 and adjacant wald Weld Map 2-CVC-502-1W:

number 2-CX-01159 both identify the material as a reducing insert (special 3/8" 10. flow restrictor)~ with heat code "CNC".

Wold Mao 2-CVC-503-1W; weld number'2-CX-41245A and adjacent" both identify the matarial as a 2"X3/4 weld nunbar 2-CX-012458 reducing insert, with heat ccde "CNC".

No documentation could be found Nota:

showing any 2"X3/4" '600C#

reducing inserts, with a sencial

~

3 /8" bore _, with 'the heat coce "CNC", as having been received, teamele I:

is a heat ecde for 2"-60CC#, S/W, 45' ell, ASTM "SAH0Y" The kNSP contains four entries for this haat ceca; two for Class " A", one for Class,"B", and one witn no Class.

A192-F304.

received on The Class " A" entrias ref erence TVA-2Q9 #76-0!99, A review of the documentation filed with tnis 7-21-75.

TVA-LC3. revealed there ware CMTRs filed with it that identified the fittings as NUCLEAR CLASS 2, inscoctsd also as NUCLEAR CLAS3 1, having been Liquid Penetran S4H0Y and havieg sceci!!c -arkings, "(L) 2" 6C004 WOG A'.3 F304 Cna of :ne CMTRs also ref srenced T/A-IC3, #75-7Ci7.

PT5".

1. 75-7CS7 revealad :ha: this -starisi was A reviaw of TVA-003. The CNTR s f!!ec witn tha T/4-209 received on 6-5-75.

idantifitd tna fittings as NUCLEAR CLa23 2 and havir; scecific 3:W:Y" Cne of the CP.TR's

.ea r< irg s, "(L) 2" (C00d WO3 A13 27 304 the f ellcwing carewrittan no:stien, c:n:sirad "5 3:E;I3 L' TH HEAT.'.0 S4H0Y SHAL'. !!

V;:ta:E0 TO CL233 A.

THE UNICUE..E AT No i.-4LL SE CE3:GNATE0 A5 S4WOYPT.

U7CEACE TE37 TO PE L:0V!O FE.;ETRATE (0:0) CN ALL

/ CI!3:3LI SURFACES NS 0E AND CUT ;E1.

i

$ CE.h, -).Nn[t'p'

'

• I's *.%;y *l_.l,jS.

f 3.. p.., j' ;,~4 pe{o.j MtC REPORT Nur8ER:

TVA EMPLOYEE CCNCERNS f'

0;u.i 1

)

SPECIAL PROGRAM REVISICN NUP.BER s

PAGE 20,0F 26 Note: Engineers' and. Inspector's names omitted in this quotation.

S4H0Y PTS is in the HNSP; however f

Note:

S4H0Y PT is not.

weld

]

An example of installation is Weld Man 1-CVC-503-1W:

I and adjacent weld number 1-CX-02162 2.

number 1-CX-02151 2 Wold documents for these welds denote this fitting as a 2" The field walkdown 6CCO# 45' Ell, with heat code "S4H0Y".

~

revealed this fitting is "S4H0Y".

The msnuf acturer of this fitting,'when contacted q

the following:

1. "S4HO" denotas the heat nueter of the fitting identifying its chemical and physical analysis.

2. "Y" denotes the heat treatment received by a ) articular batch of fittings.

1

3. Had the fitting been Liquic Penetrant tasted it wculd have been stas:ed, "PTA*, "P7a", etc, idencifyirq the technician who performed the test lity

4. The markir.gs on the fittings do not provide traceabi r.

to its CMTR.

1 i

i i

1

vw w

1. Cd5N.O.],v,v : <.-

REPORT h7M3ER:

• Jif'. ",IA A b. m (

s

T7A EMPLOTE! CONCIPJIS W

SPECIAL PROGRAM RE7ISION NUMBER:

W.

PAGE 21.0F 26 r

Another era.1ple is Veld Map' 2-C7C-502-1 1

1 below).

Veld Document Veld Document 2-CI-01143B 1 2-CI-01143C

^

i Cocponent l

Component I

l Co ponent I

Component l

i Identiftettioni i

I Identifiestfon i

Identifiestion I

~

i l Identifiestion I

l 1

I i

i l

1 I

S4HDY I

BVX13F 1

i BVX24X l

S4HDT-P2B 1

i I

i I

1 1

l 1

l L

1 l

I i

_I i

1 I

1 I

L 1

1

_I 45' E11 1

i 2" Stoe I

l L

I 45' 211 l_

I I

L I

i I

1 l

I I

1 I

i I

I I

I i

I I

i I

l I!91d N61k 0W I i

I! ele VS11'0W l l *dentification I J Titla Vils334 l I Identifics ! n l i

SACY??

L I Idar. tift:stion l l Untble to Reed L t

sauY?;

(

Tigu-o 1 e

h

RE' 1T twneun g IlU" REVI,SION NUMSEp: ggpC7.M LOYEE CONCERNS

\\

TVA L ONLY SPECIAL PROGRAM PAGE 22.0F 26 i

i i

Examole_C:

W A182 F304.

2" 6000# 90' Ell $/

13-76,

"$4 MAR" is a haat code for a From a referencs in the HNSP, TVA-209 #76-5529, dated 2-A review of the CMTR filed with this TVA 209 the revoaled no NUCLEAR CLASS, ked the specific was found.

l weld number 2-CX-01250 revealed the heat code Wold Map 2-CVC-503-1W:

material identification to be 2" 6CCCP 90* with tne d the material

"$4 MAR", ad jacent weld nutber 2-CX-01251 revealeL A182 with the hea l

identification to be 2" 60C0# 908 "S4HXM".

i to be The field walkdown revealed the material identificat on "S4 MAR PTA".

Eremote1[:

"AX" ac; ears on the marked up' copy of Weld Mao 1-CVC-5 "Ax" is not liacad, is identified as a 2" 4000# S/W 90* oli.

No CMTR could be f

by this natarial description, in the HNSP.

l fcund for this material.

d ficatien revealed the raterial i ent:

d "S4XNAX" Weld nunber 1-CX-01091 2 to ha 2" Sch 160, 90* s11 A132 with :Pe heat co eliasd d

" A4" this was lined tnreugh, initialed and dattd, and ensnSa which wt>

Adiacent weld cu.:ber 1-CX-02C92 2 revealed theEll, A132 wi I

2" 6000# 908 to "AX".

ratarial identifica icn to be heat ccee " AX".

ft:a*,ien to la The field walkdcwn revealad the e.2:arial identi "S4xNAX-PTA".

Exarola I:

"MS963" accatrs on ths racked uo cecy of Weld Mao 2-SI-100

",4 The HNSP rava21s one I

pt;s.

as 1 1/2" Sen 150 S.S. A375 TP 304" A" ref erencing TVA-109 575-533 5.

entry identified as Ciss:

34 Urdotirnined Guant!"/ Cf this This 7/A-209 revoalid *na:The CMTR filed wita *nis TVA-!O9 tid spa:ift:

catarial was esceiva.

r,ct revcal tha tvantity that.as tested c:e anyes;arial h es*arial, t

6......

l ie

.4 Er.PLOYEE CONCERNS g4pois un -

ONLT

$PECIAL PROGRAM REVISICN NUMSER:

PAG.E 23 0F 26 Examole 1:

c d Map During the Weld Document Review perfo 02113 and 1-CX-02116 could not be found.locatad o L

had been "whited out".

~

These were the only two weld documents of the 573 reviewed that could not be Note:

located; however, during the search for these documents Lt was learned that a document audit was not performed verifying their existence, prior tu the system transfers to Nuclear Power, Exa-cle X:

"class Chafae Ofscreenneier

"B" Incensistancies in denoting changes from Class " A" for Class "A" were discovered durint the weld esp reviewTVA flew Diagram 1

27, "Ficw Disgram Raactor Coolant System", and 47W3 ma:arial installations.

l Systom",

Ravision 27, "Flow Diagram Chemical ar.d Volume controlo wara reviewed.o de: ermine the accurata Class changes.

This review revealed the following:

h r"

The 1" sucaly llaa to the "Cxcess Le:dewn Heat Exc f rom the "Loep Numeer 3 Cold Leg "3"

at the 1.

1 C:1d Leg, upstream of valve 66-571; hewaver, when l

centinus: ton of this line is follewad en to 47'4"d9-1, "A"

to Revision 27, ener& is another charga f rom Class Class "3" notad, de*nstraam of.*alve $3-579 r9 N2:a cued c s en 47 wit 3-t.. aavisien a, 3rd note nu-:a j

8 I

2.

states, fecn

r 47W007-1, Ravisien 27.(3/2" I.0, Flew Restr j

C'. ass A to Class 3 pipe "-ese ceswirls wnere the i no clear statement of Class ch&B9a is mace.

e 4

e

.m..

\\

+=suo m _ _

REPORT NUM3ER:

" ~,g TVA EMPLOYEE CCNCERNS REVI$ICN NUMPERl.

44 g38l 1

SPECIAL PROGRAM t

04 PAGE 24 0F 25 G >

=

being Consequently, this has'resulted in the pip and l t which whose failure could cause a loss of reactor coo an d cooldown, would not permit an orderly reactor shutdow l makevo

~

systam..

~,

Eramele L:

~

l weld esos as "8VK24H", "BVM13Z", and "$VK24C" appear o'n severa The field heat cedes for 2" Sch 160 A376 TP304 S/S pipe.f actory carking h

walkdown revealed tha, in most ekses, t e The following are TVA paint stick earkings have been removed,between those tha examples of discrepancies that exist s

read and the weld documentation, 50 1 TVA Weld Map 1-CVC-503-1W; weld document 1-CX-02:

ith the heat identifies this material as, A376 2" Sch 150 pipe identifies this material as, A375 2" Sch 160 pipe with theT code "9VM132".

tick and heat cede "SVX24C" marked on the pipe with a paint s "9VX24C".

factory earkings "SVM131" etched en the pipe.

weld docu-ent 1-GX-0211tA identif 34-13 with the hea TV A Wald map 1-CVC-$02-2W:this catorial as, 2" Sc Adjacent weld document 3 with the hea:

this caterial as 2" Sch 150 S/S cide LM 34 cede "BVX24H".

initia:ad and I

datad, ard changed to "BVX24H".ccde "BVM13Z" (Tact:ry Mark).

this caterial to have hoa:

j 3.

.juelese Powor:

LATER CO.!CUJ3*t'il:

e e

-~.

a',

TV6 _dPLOYEE CCNCERNS REVISICN NUM8ER UV *ONyy.

e SPECIAL PROGRAM O

DAGE 75 CF,26,

~

licable Code of Record for Construetlon:

A, or does it define the The FSAR does not clearly define the accNuclea applicable Code of Record for the pr marSQN is committed by its i

e of Nuclear Class pressurizer surge line piping; however, Code of Record and to CFR 50 Appendix 8 to the ushich is m The' Piping Components, the identification of w llation, and use.

throughout their fabrication, erection, instainitial issue of h

site procedures, with the exception of t eSNP-u es to ensure these

' ~

commitments were mot.

l identificationf the significance of The individuals involved in the materia verification process lacked an understanding oPiping Comp l

d to why, or the manner in which, Nuclear C assAlthough a be identified. verify the identification of the instal eliance upon "if methcd was. developed, except the reheat codes / numb it was in the HNS?"', "been used before, ob rs are not unique code /nu:ber.

material"; however, since heat codes cum ei l description, they

/

Nuclear Class, Pressure Class or mate

fication, l

f ' Record and to CFR 50 Appendix The Nuclear Class Piping Cceconents during their with tne requirements of the Code o e for identification and control of these 'e This,non-complianco fabrication, erection, installation, and use.

itability has resultad in the receipt,be traced to the CMTR, attesting to it for the Nuclear anc/or Pressure Class in wh that canno:

Flyel**r Pew *fJ S.

LATER e

G l

t k

en v

, p.,

503 i

TVA EMPLOYEE CCNCERNS RE70RT NUMBER:

ggf 0NdO g3 SPECIAL PROGRM OM REVISICN nut'.8ER.

PAGE 26 CF 26 V.

ROOT CAUSE

~~ - - - - -

A.

Censtruction:

TVA personnel responsible for the adequacy and accuracy of site procedures, nor matar,tal manufacturers, either were not cognizant of or did not have full appreciation of the code of Record and 10 CFA 50 Appendix 9 requirements regarding maintenance and control of fiuclear Class Piping Coc;onents.

i-

.8.

Nuclear pewer:

1.ATER VI.

CORRECTIVE AC~ICN:

A.

Construct!,n:

To be provided by line erge.ril.:stion..

B.

Nuclear Ecwer:

LATER VII. GE';E4!C A83L!CABILITY:

A.

Cers traction:

cetermined generic to the sacuoyah tiuelear Plan: Makerial Idantificati:n Verifica:ien Pr: gram and Ma:arial Mar.2fseturers' r.2:arial Identifiestien Marking Progran for fluelear C! ass Piping Conponents, i.e., Nuclear Class I, II, III, an:/Or TVA Clas s A, S.

C/0.

The generic a:elicab!!ity of W3N-ICTG re:::rt r.urbar. MO 40703 romains valid for all 4:nar TVA Nuclear plan S!:es: h waver, it rus: 'ce revised ':: include the Material Manufac urers' Macarial Iden-i'icati:n Mar'<iel Pro; sm for.Nucisar Clas s Pi:1..i C:. ::. ants.

m e 3.

N'J C 101 P" IC'A 8! 8* !

LATER G

e