ML20150D315
| ML20150D315 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/11/1988 |
| From: | NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20127A683 | List:
|
| References | |
| NUDOCS 8803230311 | |
| Download: ML20150D315 (11) | |
Text
}
J p no
![
o, UNITED STATES
{. ) 3 s, c NUCLEAR REGULATORY COMMISSION E
W ASHINGTON. D. C. 20555
\\.'.d
/
SAFETY EVALUATION BY THE OFFICE OF SPECIAL PROJECTS EMPLOYEE CONCERN ELEMENT REPORT 24300 "INADEQUATE DIESEL GENERATOR MARGINS" TENNESSEE VALLEY AUTHORITY SEOU0YAH NUCLEAR PLANT, UNITS 1 AND 2 00_CKET NOS 50-327 AND 50-328 I.
SU3 JECT Category:
Engineering (20,000)
Subcategory:
Diesel Cesign Margins (24300)
Element:
Inadequate Diesel Generator Margins (24300)
Employee Concern:
XX-85-122-006, 007 WI-85-1CO-002 I-85-132-SQN-01 XX-85-122-030, 031, 032 WI-85-100-010 The basis for Element Report 243C0, Revision 1, prepared January 5, 1987 is several employee concerns.
One concern states, "Diesel generator trargins are inadequate.
TVA has added diesel generators to Brcwns Ferry, Sequoyah and Watts Bar.
Each time a question is raised. TVA must conduct another study.
TVA adds diesel generators without upgrading licensing docurrents." Another concern states, "Inadequate raanagement of control of status listing of AC and DC electrical loads including i
diesel generator loads.
This involves inadequate control of, or preparation of, calculations for loads, and inadequate canagement and centrol of load
$a:
n'argins, including electrical loads and rnechanical loads (heet, SHP, etc.) that MO@
translate into electrical loads."
n8 08 II.
SLWARY OF ISSUE wo Of The errployee concern raises issues regarding the adequacy of diesel generators no and the adequacy of all TVA electrical calculations in general.
A TVA S$
evaluation panel revit cd the employee concerns.
Sargent and Lundy and Gilbert /Coronwealth assisted TVA in reviewini, the employee concerns.
The TVA gg panel fcund:
a) n. a.
a.
Licensing documnt:- describing the fif th diesel generator did not exist, b.
Documentation of diesel leeds and nargin did not exist.
j g
Electrical calculatiens were prepared infonully and not raintained.
o
4
. III. EVALUATION flRC and its consultant, SAIC, evaluated this concern.
The NRC evaluation of electrical calculations is presented in detail in the SER which addresses employee concern Element Report 21301.
The programatic inadequacy with regar d to preparation and control of calculation has been addressed in Elerrent Report 20502.
TVA has verified 1)1 diesel generator loads and has reanalyzed diesel loads and verified all calculational assumptions.
TVA has also ccmnitted to icentifying several long term loads that may be tripped to keep the long term loading within the diesel generator's steady state capability.
TVA presented this information to NRC during a March 26, 1987 reeting.
TVA has ccamitted to incorporate these operator actions into the operating procedures.
Currently, the calculation for the Unit 2 diesel generator operation assumes that Unit 1 is in cold shutdown.
The calculatien must be revised to address two urit operation in the future.
The review of the diesel generator loads and margins is being addressed in a separate SER cn electrical calculations.
!V.
CCNCLUS:0N Based en cur review, we find that the employee concern was valid and that the TVA's investigatien, evaluation and the corrective actions plan to resolve the coployee c~ ern as descriled in EN-243CO-SGN, Rev. 1, acceptable and believe that implen..otaticn of these corrective actions will close the issue for Unit 2 f
restart.
However, the calculation for cperating procedure for two unit operation should Le reviewed by TVA tefore the two unit operation is approved j
by NRC.
The NRC staff will issue a separate SER under electrical calculation 1
review to address the diesel generator loading cod margin issue.
o SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 & 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT HC-40206 "MATERIALS AS IT RELATES TO PURCHASING AND REQUISITION" I.
Subiect Category:
Haterials Control (40000)
Subcategory:
Purchasing and P,equisitioning (40200)
Element:
Haterials as it Relates to Purchasing and Requisition (40205)
Employee Concern:
WI-85-053-011 The basis for Element Report MC-40206, Rev. 2, dated Octcber 21, 1986 is Watts Bar Employee Concern WI-85-053-011 which states:
"Haterials are received at WBNP from other TVA sites with complete documentation, however, these other sites are not on the WBNP vcndor list.
This was also found during the June 1985 ASM2 survey.
Details known to QTC, withheld due to confidentiality.
Construction depth concern.
CI has no further information."
This concern was evcluated by TVA as potentially nuclear safety-related and potentially applicable to Sequoyah (generic).
II.
Sumary of Issue The problem defined by TVA is that other TVA sites are not on the approved vendors list for supplying materials to Sequoyah.
This literal interpretation of the concerned individual's (CI's) statement implies a precedural, rather than a hardware problem.
Since the CI stated that documentation for transferred materials was ccnplete, this analysis of the problem is prcoably accurate.
However, the underlying question of the adequacy of transferred material must also be addressed.
III. Evaluation TVA's investigation of the concern traced the criteria for their procure-ment QA program from 10 CFR 50 Appendix B through Regulatory Guide 1.123 and ANSI Standard N45.2.13 to Secuoyah Administraticn Instruction AI-11, vhich defines responsibility for receipt inspections.
TVA personnel performed employee interviews and reviewed Nonconformance Reports (NCRs) and audit reports to determine if problem: h?d been identified at Sequoych in materials supplied from other TVA sites.
The TVA evaluators concluded that although the TVA sites are not on the Acceptable Suppliers List (ASL),
a program is in place to ensure that adequate technical and QA require-ments cre act on items transferred frcm other TVA sites.
They also concluded that there was no evidence (NRCs, audit findings) of failure to
~
meet these requirements.
The TVA evaluators therefore concluded that no problem existed at Sequoyah and no corrective action is required.
IV.
Conclusion The NRC staff believes that TVA investigation of the concern was adequate, and their rese'ution of the concern as described in Element Report MC-40206 Rev. 2 is acceptable.
A recent NRC inspection of procurement at Sequoyah (September 15-19, 1986 and September 29 - October 3, 1986) determined that AI-11 was deficient in some respects and would, by itself, not necessarily ensure the quality of transferred materials.
However, no evidence of hardware deficiencies resulting from TVA plants not being on the ASL for previously transferred materials was identified during this inspection.
i
- u
, is,
e SEQUOYAH NUCLEAR POWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT MC-40301-SQN "VALVE SUBSTITUTION AS RELATED TO MATERIAL CONTROL" I. Subject Cate gory:
Materials Control (40000)
Subcategory:
Installation (40300)
Element:
Valve Substitution as Related to Material Control (40301)
Employee Concern:
EX-85-181-001 The basis for Element Report MC-40301-SON, Revision 2, dated October 31, 1936, is Employee Concern EX-85-181-001 which states:
"On valve inspection (Test 70), Quality Control (QC) verifies the proper valve by the mark number tag which is installed by the warehouse or vendor and is of ten just a paper or metal tag which can be recoved or replaced by anycne.
If the valve has been substituted from what the drawing lists, the bill of materials does not properly reflect the change.
No paperwork is provided to Watts Bar engineering to document that it is an acceptable replacement.
Many substitutes have come from Hartsville, Phipps Bend, and Yellow Creek are a different type than what the drawing calls for.
Check Unit 2, R1, Steam Generator Blowdown 4
System, as an example."
The pcrtion of the.above quota that is generically responded to by the Element Report is the segment of the quote as folicws:
"If the valve has... is an acceptable replacemant."
The remainder of the concern is addressed in Material Control Subcatagories, Purchasing and Requisitioning (MC-40200) and Material Identification (MC-40500), as stated by this Element Report.
This segmant of the concarn was evaluated by TVA as potentially nuclear safety-related and potentially generic to Se;uoyah.
II. _Suneary of Issue The issue defined by TVA is that valves may have been substituted fron what the drawing requires without documenting the substitution, and the bills of materials were not revised to show the change.
r>
2 III. Evaluation TVA personnel interviewed personnel involved with valve installation during the construction phase at SQN, reviewed construction procedures related to valve installation, reviewed a sample of the 47W drawings, and reviewed construction valve documentation for 200 valves to determine if valve substitution was a standard practical SQN during construction.
The TVA evaluation concluded that during the construction phase of SQN, the valve installation program maintained adequate control of valve substitu-tions.
The NRC inspector interviewed the Employee Concern Task Group (ECTG) investigator who wrote the Element Report on January 7, 1987.
The NRC inspector reviewed the ECTG documentation package wnich was collected during the TVA investigation. A pertinent fact, that was not ulearly pointed out in the Element Report, is that the Watts Bar valve installation program is different from the proigram at Sequoyah.
The prograr.1 at Sequoych is simpler and the r.nans of valve installation verification is more definitive.
The NRC inspector cross-checked the conclusion of the Report by inspecting a sample of safety-related valves and verified them to be as indicated on plant drawings, and by checking the output of several programs which were perforced by independent TVA groups or contractors which could indicate improper valve substitutions.
No indications refuted the Report findings.
IV. Conclusions The NRC staff believes that the TVA investigation of the portion of the concern addressed in the subject report was adequate, and that their resolution of the concern as described in Element Report MC-40201-SQN, Revision 2, is acceptable.
.a SECUOYAH NUCLEAR PCWER PLANT, UNITS 1 AND 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CONCERNS ELEMENT REPORT MC-40302-SCN "VALVE (CRACKED)
AS RELATED TO MATERIAL CONTROL" I. Subject Category: Materials Control (40000)
Subcategory:
Installation (40300)
Element:
Valve (Cracked) as Related to Mr.terial Control (40302)
Employee Concern:
PH-85-035-002 The basis for Element Report MC-40302-SQN, Revision 4, dated December 5, 1986, is Watts Bar Employee Concern PH-85-035-002 which states:
"The 3" SS valve located on the top of the pressurizer in Unit 1/ system 68 has a laminatien crack running thrcugh the valve body into the weld
- ene on weld upstream frcm valve "
This ccncern was cvaluated by TVA as potentially nuclear safety-related and potentially applicable to Sequcyah.
II. Su mary of ls y The perceived problem that this report addresses is that one of the 3-inch valves in the top of the Unit 2 pressurizer at Sequoyah (SCN) was previously installed in the same area in Unit 1 at Watts Bar hurJear (EES), anuat one of these valves at WBN is alleged to have a crack or lamination in the valve body that runs into the weld area.
The subject valve was identified during the evaluation at WBN to be serial number 19S3-3, manufactured hy Target Rock Corporaticn.
III. Evaluation TVA persennel visually examined spare valva (52 rial Nutter 1955-10) for cracks or laminations and ncne were found.
This valve was then placed in service replacing the subject valve (Scrial Number 1983-3).
The subject valve received a visual inspection of the interior and exterice of the valve bocy by a TVA nondestructive examination (NCE) Level II inspector.
No indicationJ of cracks or laminations were fcund in the weld areas.
- Mcwever, there was an elliptical shaped indication on the interior surface of th*
outlet side of the valve body adjacent to the indicator tube.
This was further evalucted by a Level III NDE irispector and determin::d not to be a crack, but the specific nature of the indication and the valve's suitability for service was n0t deternined by this inspection (note:
this valve eas ne 1
b
1
.t,>
2 longer installed). The indication identified was also present in the valves that were examined at WBN.
The indications in the valves at WBN were evaluated and determined to be inherent to the manufacturing process and not detricental to the safe operation of the valves.
The inspections performed by TVA were documented on work requests.
The TVA evaluation concluced that the indication found in the valve is not in the weld area as stated in the perceived problem, and this indication is inherent of the manufacturing process for these valves and not a crack or lamination.
Therefore the concern is not valid.
The TVA evaluation also concluded that there was no c/iterica to determine the acceptability of this particular value for use, and this needed to be addressed by lir.e manage-ment.
The NRC inspector contacted the Employee Concerns Task Grcup (ECTG) about the concern.
The ECTG stated that the spare valve (serial 1935-10) installed in Unit 2 at Sequoyah had no such indication from the manufac-turing process due to the fact that Target Rock had changed its process in the two-year span separating the valves' construction.
Target Rock repre-sentati.es had inspected the subject valves at the site.
ECTG personnel had also been present during the valve inspections.
Target Rock is providing a letter regarding the possible presence of the indications, which will become a part of the purchase order spe:ification for future receipt inspecticns of procured valves of the subject valves' type.
IV. Cenclusions The NRC staff believes that TVA investigation of the concern was adequate and thtir resolution of the concern as described in Element Rept.-
MC-40302-SON, Revision 4, is acceptable.
.b ?
SEQUOYAH NUC'. EAR POWER PLANT, UNITS 1 ANO 2 SAFETY EVALUATION REPORT FOR EMPLOYEE CCNCERNS ELEMENT REPORT MC-40307-SON "SCRAPPED MATERIAL AS RELATED TO MATERIAL CONTRCL" I. Sub_iect Category:
Materials Control (40000)
Subcategory:
Installation (40300)
Elem nt:
Scrapped Material as Related to Material Control (40307)
Employee Concern:
SQP-5-004-003 Part of the basis for Element Report MC-40307-50N, Revision 2, dated October 31, 1986, is Employee Concern SQP-5-004-003 which states:
"SEQUOYAH:
New material has been ordered scrapped by a supervisor and later retrieved by a different gecup.
This could represent a lack of control regarding scrapped material."
The Nuclear Safety Review Staff (NSRS) obtained additional infomaticn frcm the Employee Response Team follow-up group, which further specified the concern to be that the concerned individual (CI) had noticed new fittings still in the manufacturer's plastic bags, in a garbage pile next to a warehouse in November 19SS.
These fittings were picked up by someone from another plant organization the following m ek.
The C1 assumes that the fittings were later used somewhere in the plant but is unsure what happened to these fittings af ter they were picked up/ retrieved frx1 the garbage pile.
Additionally, the Elemnt Report identified five Watts 3ar concerns which were made generic to Sequoych; the concerns were IN-85-291-001, IN-8S-339-002, IN-85-624-C03, PH-85-C03-C09, and WI-35-091-014.
The report sumari:ed the combined cor.cerns (SQN and WSN) as folicws:
"The perceived prcblem, as statad in the concerns that this recort addresses, is that material tha,t hcd been scrapped was retrieved frcn the scrap pile and used in permanent plant installaticns."
)
These cencerns were evaluated by TVA as potentially nuclear safety-relcted and both potentially and specifically applicable to Sequoyah.
II.
Sumary of Issue The problem defined by TVA is sumarily stated in the last quote above.
The specific Watts Bar material (from WBN ccncern descriptiens) supposcdly used after being scrapped, included:
general scrap, valves, snubbers, pipe, and hanger material.
The specific Sequoyah concern is stated above.
In all of the concerns, no specific end use was identified for the wap material.
The scrap material was not identified as being scfety-related.
if
2 The use of non-safety-related material in a safety-related application, the use of safety-related material in the wrong application, and the use of safety-related material that had degraded in improper storage would be tne primary regulatory considerations.
Due to the Watts Bar concerns which were made generic to Sequoyah, the time frame for consideration in the Element Report was assumed from construction to the tiec of the investigation (1986).
III. Evaluation The Sequoyah specific cencern (SQP-S-004-003) was addressed by NSRS Report I-86-164-SQN as noted in the Element Report.
The concern was recent encugh that the actual events could be reconstructed.
The scrapped material was not utilized in the plant.
The Element Report recognized that NSRS Report should have identified corrective action which was specified in the Element Report.
The Element Report identified that there were no procedural controls for scrap during the construction phase and that some problems exist in currant procedures.
The Element Report appears to have adequately covered the area of concern for current site activities.
The Employee Concern Task Group (ECTG) that generated the report utilized persennel observation, interviews, and program review to evaluate the concern.
Via the site staff, ECTG obtained correc-tive action on prcgram atic scrap material problems.
As stated in the
)
report, these problems had not caused scrap to be misused.
The Element Report utilized interviews as the means of evaluating scrap use during the construction period.
With regard to interviews of TVA construc-tion perscnnel, the report states:
"During the construction phase of Sequoyah (SQN). material was en occasion scrapped by mistake, its traceability maintained, and therefore retrieved for installation at a later titt Hcwever, no spec'ific items could be identified."
The report did not state the number or types of personnel interviewed by
- ECTG, The NRC staff ret with the ECTG investigator on January 7, 1997, to discuss the subject Element Report. The SRC inspector reviewed the supportive evaluation package for the report.
The NRC inspector determined that r.isuse of scrap material during the construction period was probably the most difficult part of the concern to resolve, and aside frcm destructive sampling or nendestructive saroling of material, the interview method was the most useful tool available.
i
,j o o
3 From the discussion with tha ECTG investigator and review of support documentation, the NRC inspector determined more information en the ECTG interviews with TVA personnel regarding scrap use during plant construction.
The interview results appear satisfactory with the possible exception of the small number of TVA Quality Control (QC) inspectors interviewed. This over-sight appeared to be one of personnel availability at the time of tr.e ECTG evaluation.
QC inspectors are, and were responsible for verification of material at installation.
The ECTG investigator had interviewed mainly engineering staff who, under tha TVA system, were responsible for material release.
The NRC inspector interviewed three additional construction peric? QC inspectors during January 8 and 9, 1987, at Sequoyah.
The QC inspectors interviewed correborated the results of the Element Report.
Two were emphatic about scrap not being used and the third could not remcmber any specific misuse of scrap.
Although there were no precedures during construction regarding reuse of scrap, the QC inspectors stated that it was and is, common knculedge as to what is required for safety-related installa-tions.
IV. Cerclusion The NRC staff believes that TVA investigation of the concern was adequate and that their resolution of the concern as described in Element Report MC-40207-SQN, Nevistor. 2, is acceptable.
1
.