ML20205J795
| ML20205J795 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 01/31/1986 |
| From: | Alexander M, Breeding C, Sauer R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340195 | List: |
| References | |
| I-85-865-SQN, NUDOCS 8602260427 | |
| Download: ML20205J795 (8) | |
Text
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s TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-85-865-SQN EMPLOYEE CONCERN:
XX-85-120-003
SUBJECT:
IMPROPER PLACDIENT OF HEAT NUMBERS DATES OF INVESTIGATION:
DECEMBER 16, 1985 - JANUARY 7, 1986 INVESTIGATOR:
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C. L. BREEDING DATE
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REVIEWED BY:
M. W. ALEXANDER DATE
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APPROVED BY:
R. C. SAUER
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BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as KK-85-120-003, stated:
Sequoyah: Heat numbers have been placed on approximately 5 plates on the containment vessel when it was discovered there were no heat numbers on these plates. This was done without quality's knowledge and violated the QA
--procedure. CI has no further information. Construction
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Department Concern.
The ERT follow-up group was contacted for more information on the exact i
nature of this concern such as the unit and location within containment f
of this incident. ERT had extensive notes taken from the anonymous phone call, but the concern mentioned no specific unit. The Concerned Individual (CI) did say that he was working on putting plates on the containment vessel. He stated that these plates should have been heat treated, and they had no heat numbers. He stated that the foreman told the craf tsmen to put heat numbers on the material. The foreman later said the heat numbers were wrong and were to be changed. The CI stated that this i_s contrary to QA procedures and named the foreman (Individual E).
The Cli first came to work at TVA in 1976. This information from the ERT eliininated the initial construction of the containment vessels from the ir<restigation and indicated that the alleged discrepancy i
occurred at,a later date when modifications were made to the containment.
II.
SCOPE A.
The sccise of this investigation was determined from the stated concern of record and the additional information contained in ibe ERT fild notes to be one issue requiring investigation:
o Nameplates without proper heat numbers were attached to one of the containment vessels.
B.
In conducting this investigation NSRS reviewed quality assurance requirements documents and work documentation for activities within -
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the, scope of this concern. NSRS also interviewed the work foreman r
nam (43 by the CI and other cognizant TVA personnel.
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III.
SUMMARY
OF FINDINCS A.
Requirements and Commitments A
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1.
TVA Construction Specification N1M-865, " Field Fabrication, Assembly, Examination and Tests for Pipe and Duct Systems,"
Rev. 3, dated April-12,.1977 Addendum II, required that,
" Materials used for permanent attachments to Class A and B piping require CMTR's, heat number traceability, and identification."
2.
TVA Construction Specification N2G-P77, " Identification of Structures, Systems, and Components Covered by the Sequoyah Uuclear Plant Quality Assurance Program " Rev. 5, section 3.2.3.1, required that, " Quality Level I materials require:
(a) certified' material test reports (CMTRs); (b) traceability; and (c) inspection documentation.
The traceability of material is required from the mill heat number to installation."
3.
TVA Sequoyah Construction Procedure M-31, " Erection and Docu-mentation Requirements for Welded Attachments to Containment Vessels," Rev.1, required heat numbers to be stamped on material that attaches to the containment vessel.
4.
U.S. NRC Regulatory Guide 1.26 (Ref. 14) contains a " quality classification system related to specified national standards that may be used to determine quality standards acceptable to the Regulatory staff for satisfying General Design Criterion 1 (10CFR50) for other safety-related components containing radioactive material, water, or steam in water-cooled nuclear power plants." This regulatory guide endorses the ASME Boiler and Pressure Vessel Code,Section III, for use-in determining quality requirements of the containment vessels.
5.
ASME Boiler and Pressure Vessel Code,Section III, classifies the containment vessels as Class B and refers to Section VIII of the code for rules that "shall apply to the materials, design.
fabrication, inspection and testing, and certification of Class.
B vessels."
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6.
ASME Boiler and Pressure Vessel Code,Section VIII, paragraph UG-6 Plate (b), states that, " Material not identified by mill test reports may be used for nonpressure parts such as skirts, baffles, and supporting lugs." A similar statement in this code in paragraph UG-55, " Lugs, for Platforum, Ladders, and Other Attachments to Vessel Walls," states, " Lugs or clips may be welded, brazed, riveted, or bolted to the outside or inside of the vessel to support ladders, platforum, piping, and attachment of insulating jackets. The material of the lugs or clips need not conform to the specifications for the materials to which they are attached or to a material specification permitted in this Division, but if attached to the vessel by welding shall be of weldable quality."
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B.
Findings 1.
Individual E was named by the CI as the foreman over the crew that was involved in the alleged incident. He currently works for TVA at Watts Bar as a steamfitter foreman and was contacted during this investigation. He was a foreman at Sequoyah for two years (1979 and 1980).
He remembered doing work in the summer of 1980 to install plates on the interior of the Sequoyah containment vessel that were used to mount piping hangers. He identified the location on the containment where this, work was done. The description of the event provided by the CI matched only this one area of work that Individual E had been foreman
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--- over.
2.
TVA drawing 47W2500-35 R14 " Mechanical Pipe Support Pads Containment Liner" (Ref. 19), details the location of steel plates that are welded to the unit 1 containment liner for support of piping hangers. There are more than 100 of these plates. The drawing indicated that in 1980 five pads were added to the containment liner. These pads were mark numbers 124, 125, 126, 127, and 128.
They were added by Workplan 8434 (Ref. 18) to support piping in the Ice Condenser System.
Individual E was the foreman over this work.
3.
Workplan 8434 is on file in the permanent records storage vault at Sequoyah and it was reviewed to determine the details of the work and inspections done to add the five plates to the containment vessel.
The work accomplished in Workplan 8434, the foreman involved, and the timing of the work matches the information given by the CI.
During the period Individual E was a foreman at Sequoyah, no other workplan was found that added five pads to the containment vessel. Pages 107 through 127 of Workplan 8434 contain the quality control (QC) -inspection records-for the
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welding of these plates to the containment vessel. The hea't~
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numbers for the plates from which the pads were cut are recorded on the record for each pad and signed off by a QC inspector or cognizant engineer.
i 4.
Although the TVA construction procedures (Refs. 1, 2, 3, and 16) required that heat numbers be attached to material used in containment vessel construction, the procedures used by Nuclear Power outage and plant maintenance organizations (Refs. 10, 21, 22, and 23) do not.
Individual H, a TVA representative to ASME, indicated this is an acceptable interpretation of the ASME Boiler and Pressure Vessel Code which covers containment vessels (Section III, Subsection B, and Section VIII, Part UC)
(Ref. 5).
However, Nuclear Power procedures do require that the heat numbers for such material be traceable to its source l
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material. The Sequoyah Quality control Staff indicated that traceability for nonpressure boundary materials is usually assured by noting the heat number on the materials list-(575) provided by the warehouse. Traceability for Workplan 8434 was verified by the QC inspectors and cognizant engineers when they signed the QC inspection reports, which was an additional verification (Ref. 18).
An individual who was accustomed to-working with the construction procedures might not be aware of, the different procedures used by the Nuclear Power organizations to ensure that proper materials were used.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusion This employee concern is not substantiated. The records of the work done to add five plates to the containment vessel in 1980 indicate that the heat numbers for the plates were checked by the quality control inspectors and documented in inspection reports. There was no requirement to add heat numbers to the plates welded to the containment vessel in Workplan 8434 and thus no requirement for QC inspection of heat number transfer. The differing requirements used in the construction of the containment vessels and what Nuclear Power used to add these pads are the results of acceptable interpretations of ASME Code requirements.
B.
Recommendations None 1
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DOCUMENTS REVIEWED IN INIESTIGATION I-85-865-SQN AND REFERENCES 1.
TVA SNP Construction Procedure No. M-31, " Erection and Documentation Requirements for Welded Attachments to Containment Vessels," Rev. 1 dated Feburary 24, 1977 2.
TVA Construction Specification N1M-865, " Field Fabrication, Assembly, Examination, and Tests for Pipe and Duct Systems," Rev. 3, dated April 12, 1977 3.
TVA CUnstruction Specification N2G-877, " Identification of Structures.
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Systems, and Components Covered by the Sequoyah Nuclear Plant Quality Assurance Program," Rev. 5 7
4.
10CFR50.55A, " Codes and Standards" 5.
ASME Boiler and Pressure Vessel Code Section XI, Article IWA-7000, IWA-4000, and Section III and Section VIII 6.
10CFR Part 50, " Licensing of Production and Utilization Facilities,"
Appendix A, Ceneral Desigr. Criterion 1, " Quality Standards and Records" i
7.
ANSI B31.1-1971 ADDENDA, " Power Piping" 8.
ANSI B31.7, " Nuclear Power Piping" 9.
NQAM Part II, Section 2.3, Revision August 20, 1984, " Repairs and Replacements of ASME Section XI Components" 10.
SNP Modifications and Additions Instructions M&AI-1, " Control of Weld Documentation and Heat Treatment," Rev. 9, dated August 5, 1985
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11.
Construction Specification N2M-865, " Field Fabrication. Assembly, ~~
Examination, and Tests for Pipe and Duct Systems" 12.
Division of Nuclear Power, Division Procedures Manual, N76A10, Revised September 28, 1984, " Purchase Specifications for CSSC Metallic Wire and Cable Used Inside Primary Containment, Welding and Brazing Materials, Valve Parts, and Pump Parts" 13.
Sequoyah Nuclear Plant Standard Practice SQA162, " Purchase Specifications for CSSC Materials," Rev. O, dated October 9, 1985 i
14.
Regulatory Guide 1.26, Rev. 1, dated September 1974, "Qualit/ Croup Classifications and Standards for Water, Steam, and Radioactive-Waste-Containing Components of Nuclear Power Plants" 5
m 15.
Sequoyah Nuclear Plant Design Criteria Manual SQN-DC-V-3.0, " General Design Criteria for the Classification of Piping, Pumps, Valves, and Vessels" 16.
SNP Construction Procedure No. P-34 " Heat Number Validation," revised December 13, 1978 17.
Sequoyah FSAR Chapter 3 18.
Workplan 8434 - start date Feburary 15, 1980, finish date May.23, 1980 19.
TVA Sequoyah Nuclear Plant drawing 47W2500-35, Rev. 14. " Mechanical Pipe Support Pads Containment Liner" 20.
TVA Sequoyah Nuclear Plcnt drawing 45ECB15. Rev. 16 21.
SNP Standard Practice SQM1, "Sequoyah Nuclear Plant Maintenance Program "
Rev. 2, dated July 29, 1985 22.
SNP Administrative Instruction AI-11. " Receipt Inspection, Nonconforming Items, QA Level / Description Changes and Substitutions," Rev. 33, dated August 6, 1985 23.
SNP Administrative Instruction AI-19 (Part IV), " Plant Modifications:
After Licensing," Rev. 11, dated July 26, 1985
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TV A 61(05-9-65) (OAWP 5 85)
UNITED STATES GOVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY TO: Those Listed FROM:
K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K
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FEB 181986
SUBJECT:
TRANSMITTAL OF ACCEPTED FINAL REPORTS
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The attached final reports covering the following concerns have been issued by NSRS without corrective action and are. transmitted for your infomation.
EX-85-054-002 EX-85-148-001 IN-85-474-001 IN-85-533-X11 IN-85-545-XO9 IN-85-768-XO6 IN-85-768-X07 IN-85-9 79-O'12 6
PH-85-052-XO3 s
N K.
W. Whitt 1,
H. L. Abercrombie, WBN W. C. Iribb, BFN W. T. Cottle, WBN
%g,
James P. Darling BLN
..g R. P. Denise, LP6N40A-C D
D. R. Nichols, E10A14C-K Scott Schum, QTC/ERT-WBN Eric Sliger, LP6N48A-C BFS:GDM Attachments 0500U f
E r