ML20206C335
| ML20206C335 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/06/1987 |
| From: | Brown W, Halverson R, Kenzie L TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20206C172 | List: |
| References | |
| 80201-SQN, 80201-SQN-R05, 80201-SQN-R5, NUDOCS 8704130038 | |
| Download: ML20206C335 (92) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER
, y -
SPECIAL PROGRAM 80201-SQN
- 4 REVISION NUMBER:
REPORT TYPE 5 Element Report PAGE 1 0F 16 TITLE:
Inspection Criteria This report was revised to incorporate NRC comments.
REASON FOR REVISION:
Revision indicators are shown in the right margin of each affected page.
Note: Sequoyah Applicability Only PREPARATION PREPA Y: R. HALVERSON
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SIGNATURE REVIEWS PEER:
- 3-R f'S7 m 771 DATE
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, 4zn DATE
$1GNATURE l
CONCURRENCES CEG-B t, 3b/ 87 SRP : [2uu# 87 GNATURE* DATE SIGNATURE DATE o
APPROVE IN
! lD b N/A MANAGER OF NUCLEAR DATE
" ~ ECSP E!ANAGER 4 DATE POWER CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
- 8704130038 870406 i
REPORT NUMBER
,.1' TVA EMPLOYEE CONCERNS SPECIAL PROGRAM 80201-SQN
/W RifPORT TYPE:
Element Report- REVISION NUMBER:
5 TITLE: PAGE 2 OF 16 Inspection Criteria a.
1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction ,
The issues described in this Element Report were derived from employee concerns - generated as a result of the Watts Bar Employee Concern Special Program. The issues were determined to be applicable to the Sequoyah Nuclear Plant and were investigated and evaluated on that basis.
1.2 Description of Issues ,
4 The perceived issues reported by concerned employees are:
A. Vendor welds are substandard. (JAN-85-001 and JLH-85-005)
B. Quality Assurance (QA) Program Adequacy. (XX-85-050-001, XX ;.
050-003, XX-85-102-006, and XX-85-125-006) i 2.0
SUMMARY
2.1 ~ Summary of Charseterization of Issues The overall issues ~ raised by concerned employees suggest that certain vendor welds made by Southwestern Engineering Company (SECO) and National Valve and Manufacturing Company (NAVCO) are substandard. The adequacy of the QA program is questioned regarding installation of instrument compression fittings, . visual acceptance criteria which covers the American Society of Mechanical Engineers (ASME),Section II, and TVA's Procurement Program regarding replacement parts for safety related equipment.
j 2.2 Summary of Evaluation Process
} The _ Quality Assurance Category Evaluation Group (QACEG) Evaluation consisted of reviewing the appropriate requirements contained in documents such as: Appendix B to 10CFR50; TVA's Topical Report; Nuclear Quality Assurance Manual (NQAM); ASME Codes; Standards; Specifications; Procedures; Instructions; and Reports. In addition, l
discussions were held with cognizant personnel to gain additional l information to aid in this investig.ttion.
2.3 Summary of Findings The conclusions reached as a results of the QACEG Evaluation are:
.i' The issues of vendor welds being substandard are substantiated. A l
total of twenty-four welds made by SECO were identified as requiring l rework. Verification of repair work was performed by Quality Control L
l t
I TVA EMPLOYEE CONCERNS REPORT NUMBER:
r+'REbORT TYPE: SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
. TITLE: 5.
Inspection Criteria FAGE 3 0F.16 Inspectors and documented in a work plan. Three welds mede by NAVC0
. were also -identified as requiring rework. A maintenance. request was issued and the welds were repaired.
The issue of inadequate QA controls is partially substantiated. The QA Program controls for the installation- of instrumentation compression fittings are inadequate or nonexistent. The employee
- concerns regarding the visual examination procedure covering ASME Section II and TVA's Procurement Program allowing safety related parts to be purchased commercially are not substantiated.
2.4 Corrective Action Taken And The Results Achieved To Date Substandard welds made by NAVC0 and SECO have been satisfactorily repaired. Verification of repair work was performed by QC Inspection
, and documented. TVA QA performed a survey of other welds made by SECO with no additional adverse findings noted.
Corrective me'asures regarding instrument compression fitting installation activities included: inspection and noninspection personnel training; evaluate compression .. fitting inadequacies for.
] general applicability; and quality control inspection. Inadequate
- compression fitting installation was also reported to the NRC under i the rules of 10CFR50.55(e). TVA transmitted their final response to the NRC in July 1986.
3.0 LIST OF EVALUATORS 4 W. M. Akeley R. D. Halverson J. E. Mann 4.0 EVALUATION PROCESS
< 4.1 General Methods of Evaluation
, Methods of evaluations included reviewing the applicable TVA QA Program requirements and implementing procedures related to the issues. Documentation was reviewed and discussions were held with the appropriate cognizant personnel.
4.2 Specifics of Evaluation
- 4.2.1 Issue - Vendor welds are substandard Reviewed Employee Concern Files including the Confidential Files for any additional information. The Confidential Files
, TVA EMPLOYEE CONCERNS REPORT NUMBER:
.j ' REPORT TYPE: SPECIAL PROGRAM 80201-SQN
-Element Report REVISION NUMBER:
- TITLE : 5 Inspection Criteria PAGE 4 OF 16 contained additional information regarding the identification of the specific SECO and NAVC0 welds in question.
Reviewed Maintenance Request (MR) A-561926, dated 11/27/86, utilized in the repair of the NAVC0 welds and work plan 11777 which was utilized to repair the SECO welds. Procedures N-VT-3, Revision. 4, " Visual Examiniation"; N-VT-4, Revision 2,
" Liquid Penetrant Examination"; 10CFR50.55a " Codes and Standards"; ASME Section XI, Division I, IWA 4000, 1980 Edition, Winter 1981 addenda, " Rules for Inservice Inspection of Nuclear Power Plants Components"; and American National Standards Institute (ANSI)' B31.7, 1969 Edition, Sinsmer 1970 addenda were reviewed to determin'e the weld acceptance criteria.
Reviewed ASME Section XI Summary Report,- dated 1/20/86, indicating rework performed on NAVC0 welds and inspections conducted. Inspected the three NAVC0 Safety Injection Welds (315D, 315E, and 316A) as identified on Drawing A 7257, Revision 4, Piece Mark 151-134.
4.2.2 Issue - QA Program Adequacy This issue addresses three areas of TVA's Quality Assurance Program. The adequacy of the program is questioned regarding:
A. Installation of Instrument Compression Fittings.
B. Visual Acceptance Criteria for ASME Section II.
C. Procurement of safety related parts.
Installation of Instrument Compression Fittings Reviewed Employee Concern File including Confidential Files for any additional information pertaining to this concern.
NSRS Report I-85-329-SQN (Attachment B) had been issued documenting the investigation and findings of this concern.
This report was reviewed and its content re-evaluated.
Specifications, procedures, standards, codes, reports, and memorandums reviewed during this investigation are included in the NSRS Report " Documents Reviewed During Investigation I Construction Element Report C017304- 5 329-SQN and References".
SQN titled " Compression Fittings," was reviewed and the COCEG findings are consistant with the results of this evaluation.
Visual Acceptance Criteria for ASME Section II Reviewed Employee Concern Files including the Confidential File for any additional information pertaining to this concern. No additional information was available.
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. TVA EMPLOYEE CONCERNS REPORT NUMBER:
' SPECIAL PROGRAM
.< REPORT TYPE: 80201-SQN Element Report REVISION NUMBER:
TITLE: 5
_ Inspection Criteria PAGE 5 0F 16
, Reviewed ASME Section II', Parts A, B, and C, 1974 Edition and TVA Procedure - BF-16.4, Revision 0, " Material, Components, and Spare Parts Feceipt, Handling, Storage, Issuing, Return to Storeroom, and Transfer".
Held discussion with' a cognizant individual from Quality Assurance to' determine if TVA has ever established and-implemented a Visual Examination Procedure related to ASME Section II.
Procurement of Safety Related Parts Reviewed Employee Concern File including the Confidential File for any additional information pertaining to this concern. No additional information was available.
Reviewed Appendix B to 10CFR50; TVA Topical Report, TVA-TR75-1A/R8; Nuclear Quality Assurance Manual (NQAM) Part III, Section 2.1 " Procurement of. Materials, Components, Spare
- Parts, and Services"; Division of Purchasing Procurement
- Manual, Revision 6/21/83; Reg. Guide 1.123, " Quality Assurance 4
-Requirements for the Control of Procurement of Items and Services for Nuclear Power Plants"; and Sequoyah Nuclear Plant .
Standard Practice (SQA 45), Revision 21, " Quality Control of Material and Parts and Services". These documents were reviewed to determine the requirements and commitments for the procurement of items.
Held discussions with three cognizant personnel from Power Stores and Quality Assurance on the aspects of this concern.
l l
l 5.0 FINDINGS l
j 5.1 Findings on Issue - Vendor Welds are Substandard 5.1.1 Discussion QACEG investigation revealed that SECO supplied twenty-four non-safety tube bundles for Units 1 and 2 Moisture Seperator Reheaters (MSR). SECO installed the tube bundles in Unit I 5 and TVA installed the tube bundles in Unit 2.
As stated in an un-numbered NSRS "Onsite Employee Concern Impact Evaluation", a survey was performed by a QC Inspector, a SECO representative, and the cognizant engineer to identify the defective welds. In Unit 1, a total of 24 SECO welds were identified as requiring rework. SQN Work Plan 11777 was reviewed and affected welds were reworked. Verification of repair work was performed by QC Inspection and documented in l
l l
l l
, TVA EMPLOYEE CONCERNS REPORT NUMBER:
a, C REPORT TYPE:- SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
. TITLE : 5 Inspection Criteria PAGE 6 0F 16 the Work Plan. The. un-numbered NSRS evaluation "Onsite.
Employee concern Impact Evaluation"' indicated that the concerned employee was notified of the repair work and the employee was satisfied.
The three NAVC0 safety injection welds specified in this issue were identified as 315D, 315E, and 316A. The welds were located in Fan Room #1, Unit 1, near valve 1-63-649 at the ceiling above the ladder access opening. Several photographs were taken by TVA Quality Assurance personnel showing actual weld conditions. The welds were determined to be unacceptable in that they violated the visual acceptance requirements of.N-VT-3. Maintenance Request A-561926 was generated describing ,
the rework necessary to correct the identified conditions.
Corrective Action consisted of grinding areas identified as -
unacceptable and performing the necessary nondestructive examinations .( LP & UT) required for final acceptance in accordance with ANSI B31.7, 1969 Edition, Summer 1970 Addenda.
Work was completed on January 20, 1986, with ANI/ANII concurrence.
As part of the QACEG concern evaluation, an inspector from the TVA Quality Control group and a QACEG Investigator verified-weld identification and performed visual inspection of the three welds _ in question to further substantiate corrective action and the proper closure of the Maintenance Request.
This reverification concluded that all items were acceptable and that rework and reinspections were in accordance with the work instructions specified in the Maintenance Request.
5.1.2 Conclusion i
l This issue is substantiated in that the welds in question were determined to be visually unacceptable. Unacceptable SECO welds were properly identified and corrective action was accomplished in a satisfactory manner.
. NAVC0 welds, although visually unacceptable to the requirements of TVA's current procedure N-VT-3, did not require visual weld examination by the Fabrication Code, ANSI B31.7. TVA, although not required, elected to rework the NAVC0 welds in question to meet current visual weld acceptance 5 criteria. No further corrective action is required.
5.2 Findings on Issue - QA Program Adequacy A. Installation of instrument compression fittings B. Visual acceptance criteria for ASME Section II C. Procurement of safety related parts l
. - . . . _= . . _ . - - .
.- TVA EMPLOYEE CONCERNS REPORT NUMBER:
- q. .; - ' REPORT TYPE: SPECIAL PROGRAM 80201-SQN
' Element Report REVISION NUMBER:
TITLE : - 5 Inspection Criteria PAGE 7 0F 16 4
5.2.1 Discussion - Installation of instrument compression fittings An NSRS Investigation (I-85-329-SQN, dated 2/11/86) was conducted to determine the validity.of this issue as received by the Quality Technology Company (QTC)/ Employee Response Team (ERT) . This report was reviewed by QACEG, its contents re-evaluated, and the. report was found to be accurate and
- factual.
In. addition to this investigation, NSRS has conducted two previous investigations of matters closely related to the
, above concern of record. Those investigations resulted in
, specific recommendations from NSRS which were determined to be applicable to this issue. Those investigations are documented as follows:
Reference 1 NSRS Report No. R-85-02-SQN/WBN presents the results of a special review which was performed to investigate concerns expressed by Crawford Fitting Company. Those concerns involved potential misapplication of the Swagelock tube fittings on the Westinghouse designed i bottom-mounted incore instrumentation system seal tables.
'~
The report presents NSRS recommendation R-85-02-SQN-WBN-01 to NUC PR office-wide awareness bulletin on tube fitting maintenance activities.
Reference 2 NSRS Report No. IN-85-795-001; IN-85-795-002 presents the results of an investigation which was conducted regarding two employee concerns pertaining to Watts Bar.
Concern No. IN-85-795-001 stated that compression fittings on instrument tubing are not installed per -vendor instructions. The report contains evidence of potentially significant conditions adverse to- quality, and. NSRS recommendation Q-85-795-001-01 states that an evaluation of this situation should be conducted for generic applicability to all TVA plants.
Reference 1 presented NSRS' recommendation R-85-02-SQN-WBN-01 which addressed the need for increased awareness of the critical and somewhat delicate nature of compression tube fittings in general. The recommendation specifically encouraged NUC PR to i prepare and distribute to the nuclear plants an office-wide i . awareness bulletin or similar mechanism to achieve an increased awareness. This bulletin was issued September 20, 1985 to the nuclear plants with direction to take the following actions:
Issue the bulletin to employees whose work activities involve
, tube fittings.
t
,- TVA EMPLOYEE CONCERNS REPORT NUMBER:. l
' ~ REPORT TYPE: SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
~ TITLE: 5
. Inspection Criteria ? AGE 8 0F'16
, Incorporate the concerns and policy stated in the bulletin
, into permanent ~ hazard . control . instructions and plant' instructions as appropriate.
Coordinate with' the Nuclear _ Training Branch and implement.
training _for employees involved. in installation and
. maintenance of the tube fittings.
The text of the bulletin contains the following statements:
- "Sequoyah has initiated a training class on -tube fittings in cooperation with the Power Operations Training Center (POTC)."
"It is P&E (Nuclear) policy that compression-type tube fittings be installed consistent with manufacturer's instructions and that maintenance activities involving these fittings shall not degrade the integrity of these fittings.'
- Reference 2 presented NSRS' recommendation Q-85-795-001-01 which addressed evidence of a potentially significant condition adverse '
to . quality regarding compression fitting inadequacies at Watts Bar (WBN). The following actions were recommended and the results indicated:
t:
- a. WBN CONST should initiate an NCR documenting this condition as i ASME Significant. NCR WBN-6278R0 was initiated to document the safety significance of the inadequacy of quality assurance L controls on compression fitting installation for tubing connections. The NCR- states that installations were
' discovered at WBN which did not agree with the manufacturer's installation instruction. The condition was identified as "significant".
- b. The response to NSRS .should include the results of an i
evaluation. of this condition for generic applicability to all
- j. TVA plants. It was determined that this evaluation had n t j
been performed as of January 7, 1986. NCR WBN-6278R0 received an engineering review by OE in accordance with the requirements of OEP-17, paragraph 3.2; OE has not performed an evaluation for generic implications of the condition to l- Sequoyah and Browns Ferry.
- c. NCR WBN-6278R0 directed that Office of Engineering (OE) evaluate compression fitting installation to determine the need for possible TVA process specification revisions. As a result, OE developed a process specification 3.M.13.1 for installation and inspection of compression fitting joints in mechanical tubing systems. This specification is applicable j- to all TVA projects. Advance copies were distributed to all l
l .
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, TVA EMPLOYEE CONCERNS REPORT NUMBER:
., '. REPORT TYPE: SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE: .. 5 Inspection Criteria PAGE 9 0F 16 plant sit' on January 2,1986. SQN DCU will route a copy to the SQN Modifications Branch for review.
- d. NCR WBN-6278R0 directed that OE provide analyses for certain compression fitting connections to determine the acceptability of these installations although leak tightness is achieved.
These analyses were performed by TVA's Singleton Materials-Engineering Laboratory, and the results of the testing program-
~
are documented (Reference Attachment C). ~ The results provide technical information concerning the reliability and safety of compression fittings which may not have been installed with the manufacturer's recommendations but which achieve- leak tightness.
On August 19, 1985, the Power Operations Training Center (POIC) established an initial tube fitting training program in cooperation with SQN. This program is intended to provi'de individuals who install tube fittings with -the necessary information to properly install . tube fittings to ensure a leak-proof, mechanically sound tubing' connection. The course material covers the most commonly used brands of tube fittings.
10 CFR50, - Appendix B, Criterion II, requires that structures, systems, and components covered by the QA program be identified:.
Instrument sensing lines in safety-related systems have been identified in the QA programs for design and construction (Ref. Construction Specification N2G-877 " Identification of Structures, Systems, and Components covered by the Sequoyah Nuclear Plant QA Program") and for the operation phases of SQN (Ref. SQA-134, " Critical Structure, Systems, and Components List").
10CFR50, Appendix B, Criterion II, also requires that the QA program provide control over activities affecting the quality of the identified structures, systems, and components to an extent consistent with their importance to safety:
The procedure which provided programmatic QA controls of activities during the construction phase of SQN is identified in DEDC-QAP-2.0. However, lower-tier inspection procedures applicable to instrument sensing lines did not include provisions for quality control inspection of compression fitting installation activities.
The procedure which provides programmatic QA controls of maintenance activities during the operational phase of SQN is identified in NUC PR QA Manaual Part II, Section 2.1. However, lower-tier SQN instructions applicable to instrument sensing lines do not include provisions for quality control inspection of
s
, TVA EMPLOYEE CONCERNS REPORT NUMBER: -
, REPORT TYPE: SPECIAL PROGRAM 80201-SQN l
Element Report REVISION 1; UMBER: !
TITLE: 5 Inspection Criteria PAGE 10 0F 16 compression fitting installation or maintenance activities.
Repaired instrument sensing lines -are inspected by quality control personnel for cleanliness and leakage after reasse:nbly.
Lower-tier SQN instructions (MI-1.9, Revision 7, " Bottom Mounted Instrument - Thimble Tube Retraction and Reinsertion", and MI-1.10 Revision 3, "Incore Flux Thimble Cleaning and Lubrication")
applicable to instrument thimble tubes d_o include quality control hold point provisions for mechanical verification and signoff, as 1
well as cleanliness checks.
10CFR50, Appendix B, Critierion II, also requires that the QA program provide for indoctrination and . training of personnel performing activities affecting the quality of the identified structures, systems, and components as necessary to assure that suitable proficiency is achieved and maintained:
The programmatic training requirements applicable to the construction phase of SQN were established. The implementing doucument, QC-4, (" Quality control Instrumentation") containe_d modules' for quality control inspector certification but not modules for training of personnel involved in installation of compressica tube fittings. The inspector certification module I
for instrument lines and loops had not been implemented by the time SQN construction was completed.
2 The. programmatic training requirements applicable to the operational phase of SQN are established by NUC PR QA Manual, Part III, Section 6.1. Training requirements for training personnel are addressed in this procedure. The lower-tier SQN instruction AI-14 (" Plant Training Program") which implements this procedure addresses maintenance personnel training also, including personnel whose job function involves the installation of compression-type fittings on instrument sensing lines.
However, the courses listed for these personnel do not cover tube fittings even though the office-wide bulletin previously discussed directs plant management to " implement training for employees involved in installation and maintenance of tube
. fittings."
' Sequoyah Manuals SMI-1-68-20 and IMI-ll8 are examples of SQN maintenance instructions which involved compression-type fitting installation but do not specify personnel training requirements.
Instruction MI-1.9 involves the installation of compression-type fittings on the instrument thimble tubes and does not specify that "all personnel working on tube fittings should have had the tube fitting claas." However, even this instruction does not clearly establish the training as a requirement.
SQN management is committed to the training of these personnel (e.g., Mechanical Test Unit); however the applicable instructions
1 l
.- TVA EMPLOYEE CONCERNS REPORT NUMBER:
-T REPORT TYPE: . SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
' TITLE:- 5 Inspection Criteria .PAGE 11 0F 16 do not formalize the requirement. In addition, the NUC PR Quality -Inspector Training- Manual . establishes the training requirements for quality control inspector certification. These requirements' do- not include instruction in inspection of installation of compression-type fittings. -However, quality control inspection is required in MI-1.9 "to verify that the tube fittings are properly tightened." i 10CFR50, Appendix B, Criterion V, requires that activites- I affecting quality be prescribed by documented- instructions, '
procedures, or drawings.
The above paragraphs address several instructions and procedures applicable to activities affecting the quality of instrument sensing lines. In addition to.these documents, SQN engineering
~ drawings and construction specifications essentially prescribed the only requirements pertaining to instrument sensing line installation and quality requirements.
These documents contain very little specific instruction / guidance for compression-type fitting installation. However, this situation has improved with the development and distribution of Process Specification 3.M.13.1, Revision 0, dated December . 9, 1985, " Specification for installation and inspection of compression fitting joints in mechanical tubing systems."
NSRS Report I-85-329-SQN provided four recommendations regarding installation of compression fittings. They were, I-85-329-SQN-01,. evaluate compression fitting inadequacies of NCR WBN-6278 for generic applicability; I-85-329-SQN-02, provide Noninspection Personnel Training; I-85-329-SQN-03, provide Inspection Personnel Training;. and I-85-329-SQN-04, provide site requirements for Quality Control Inspections.
SQN response to I-85-329-SQN-01 indicated that NCR WBN 6278 was reviewed for generic applicability for all compression fitting installations within the scope of the Watts Bar QA Program. The response further stated that a Significant Condition Report (SCR)
SCR 6278-S R0 (identical to NCR WBN 6278) was issued. The SCR form goes into more detail, particularly in the generic condition area.
SQN response to I-85-329-SQN-02 indicated that plant maintenance personnel responsible for installation and maintenance of compression-type fittings attended a formal training course, "Given by the Nuclear Training Branch, Power Operations Training Center (POTC)." In addition, the plant QA Staff is working with plant management to determine if the training requirements need to be incorporated into the applicable plant procedures.
. TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE: SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE: 5 Inspection Criteria PAGE 12 0F 16 SQN response to I-85-329-SQN-03 states that the Quality Control (QC) inspectors attended the training course identified in the response to I-85-329-SQN-02 prior to being assigned verification activities for compression-type fittings. This training provides sufficient guidance for the QC inspectors to perform the required verification activities.
SQN response to I-85-329-SQN-04 states that plant QC inspectors are currently performing inspections on the compression fittings during maintenance and modifications when required by the appropriate work instructions. However, there is no upper-tier or site requirement to perform these inspections, and these activities will be included in SQN Work Instructions at the discretion of the QA Staff.
Inadequate Compression Fitting Installation was reported to the Nuclear Regulatory Commission under the rules of 10CFR50.55 (e) via NCR 6278. TVA transmitted their final response to NRC open items WBRD-50-390/85-43 and WBRD-50-391/85-42 on July 30, 1986 (L44 860730 816 Attachment C). This response included a description of TVA's evaluation process and the results. A sample inspection of compression fittings identified discrepancies in the following areas: tubing cuts not deburred; tubes not bottomed out inside the fittings; nuts were not properly tightened; and ferrules were either unidentifiable, missing, or reversed. The NRC, to date, has not formally 5 accepted this response and it is still an open issue.
TVA's corrective actions included a Laboratory Testing Program to determine the long term affect on installed instrument systems with the above noted discrepancies. Affected drawings, process specification, and instructions and procedures were, or are being revised to prevent recurrence of this problem.
5.2.2 Conclusion Critierion X of 10CFR50, Appendix B requires that a program for inspection of activities affecting quality be established and executed to verify conformance with the prescribed requirements for accomplishing the activity. The employee concern is substantiated because this investigation has revealed that quality assurance program controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10CFR50, Appendix B, relative to compression fitting installation. This condition existed during the construction phase and has existed in the operational phase of SQN.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
' _ REPORT TYPE: SPECIAL PROGRAM 80201-SQN Element Report' REVISION. NUMBER:
' TITLE:. 5 Inspection Criteria PAGE 13 OF 16' 5.2.3 Discussion - Visual Acceptance Criteria for ASME Section II Concern .of . record indicates the visual examination procedure which covers ASME Section II is very ' nonspecific. Based on review of pertinent documents and discussions with cognizant personnel, it was concluded by ' this investigation that TVA does not have a visual examination procedure that pertains to ASME Section II.
5.2.4 Conclusion
_This issue is not substantiated.- ASME Section II has no visual . examination requirements 'for a fabricator and/or installer.
5.2.5 Discussion - Procurement of safety related parts Concerned employee . states that the TVA System Procurement Manual allows procurement of IE, safety related NSSS and hold devices to be purchased commercially, and not through qualified suppliers because they are part of a larger component.
4 NOTE: The concern refers to " hold" devices. It is assumed j
that this is a misspelling and that the CI is referring to equipment used in Class IE application ( device as a whole which' requires qualification by the supplier or manfacturer.)
During the investigation, it was determined that there is no TVA System Procurement Manual as noted in the concern. There is a Division of Purchasing Procurement Manual, Revision June 21, 1983, which references the Nuclear Quality Assurance i
Manual for quality requirements. The governing directive is the Nuclear Quality Assurance Manual (NQAM), Part III, Section 2.1, " Procurement of Materials, Components, Spare Parts, and Services". Lower-tier documents are Sequoyah Nuclear Plant Standard Practice (SQA 45), Revision 21, June 23, 1986,
" Quality Control of Material and Parts and Services", and Watts Bar Nuclear Plant Administrative Instruction, AI-5.1, Revision 19, March 26, 1986, " Materials Procurement and Control." These directives require that:
Items which are QA Level I must be procured from suppliers who have a QA Program approved by Division of Quality l Assurance, Procurement Evaluation Branch (DQA PEB).
QA Level II items may require the supplier have an approved QA program which conforms to the original requirements.
- - . ~. - . .
1 . , ,
TVA EMPLOYEE CONCERNS REPORT' NUMBER:
f.' REPORT TYPE: SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE: 5
_ Inspection Criteria PAGE 14 0F 16 For QA Level II and III items that require a Certificate of-Conformance (C0C), the vendor shall be required to have a DQA PEB approved COC program that meets the requirements of NQAM Appendix E,- Attachment 6, Part III,1Section 2.1 (QA Requirements for a Certificate of Conformance Non-ASME Code Items and Small Products).
For all QA Level II and . III items, the vendor shall be required to furnish a completed copy of Appendix D (Changes / Substitutions for QA Level II and III Items), or the suppliers own certificate which ' provides. the information requested, when the item offered is not identical to the contract requirements.
Suppliers of equipment used in Class 1E application (device as a whole which requires qualification by supplier or manfacturer) to include electrical wire and cable shall be required to have a QA program which conforms to the applicable portions of ANSI N45.2 or 10CFR 50, Appendix B.
l L
Suppliers of commercial grade equipment that has been-qualified for Class 1E application of TVA (replacement equipment must be identical to equipment qualified) shall
, comply with the QA program requirements for a Certificate
+
of Conformance.
Suppliers of standard design, commercial grade replacement parts (subcomponent, assembly, or module) inside equipment used in a Class 1E application (device as a whole which g requires qualification), as a minimum shall attest to the in-kind replacement requirements of the contract by furnishing a completed copy of Appendix D i (Changes / Substitutions for QA Level II and III Items) or -
the supplier's own certificate which provides the j information requested when the item is not identical to the contract requirements.
It should be noted that the procurement of safety related piece parts is an open issue with the NRC as described in reports 50-327/86-61 and 50-328/86-61 and is a potential 5 enforcement finding (Attachment G).
. 5.2.6 Conclusion Based on review of the above documents and discussions with cognizant personnel, this concern, as written, cannot be substantiated. As noted in the Summary of Findings, adequate
. controls are in effect that preclude procurement of safety
!. related material from unapproved suppliers. It should be i
1 1
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.- TVA EMPLOYEE CONCERNS REPORT NUMBER:
'* 1RE1I ORT TYPE:
SPECIAL PROGRAM 80201-SQN-
. Element Report REVISION' NUMBER:
TITLE: 5 Inspection Criteria PAGE 15 0F 16 noted . that the concern refers to a specific case known . to Quality Technology Corporation (QTC) and withheld to maintain confidentiality. This case was unobtainable during the investigation therefore the details could not be verified.
5.3 Corrective Actions Substandard welds made by SECO. have been satisfactorily repaired.
Verification of repair work was performed by QC Inspection and documented in SQN Work Plan 11777. NAVC0 welds which were visually unacceptable to TVA's. Procedure N-VT-3 were reworked and documented on Maintenance Request A-561926. A Corrective Action Tracking Document.
(CATD) 80201-SQN-01 (Attachment D) was issued to the Office of Nuclear Power (ONP). The CATD identified that although the .SECO welds were repaired, there was no sample inspection performed on other welds made by.SECO. The SQN Site Director responded to this CATD on October 20, 1986. The response stated that SECO performed work at Sequoyah only once. Sequoyah Modifications requested that Sequoyah Quality Assurance perform a survey. This survey was conducted by Quality Assurance with the participation of a SECO representative, and documented- on In plant Survey Checklist 21-85-5-021.. Deficient welding was identified and corrected by TVA. The response went on to say, "It is therefore concluded that the inspection / review effort did include the majority of welding performed by SECO with repairs being completed accordingly; thus, no additional surveys are warrented".
QACEG concurs with this response and considers the issued closed.
Nuclear Safety Review Staff (NSRS) investigation of instrument compression fitting installation activities was documented in NSRS Report I-85-329-SQN. This report provided four recommendations which included: evaluate compression fitting inadequacies for general applicability; inspection and noninspection personnel training; and
. Quality Control Inspection. Inadequate compression fitting installation was also reported to the Nuclear Regulatory Commission under the rules of 10CFR50.55 (e) via NCR 6278. TVA transmitted their final response to the NRC on July 30, 1986.
These recent actions have been taken by SQN management and others to i
improve the controls in the area of compression fitting installation.
However, QACEG has issued a Corrective Action Tracking Document (CATD) 80201-SQN-02 (Attachment E) on September 12, 1986, which identifies the lack of training requirements in various procedures. The SQN Site Director responded on October 20, 1986, committing revision to
- Administrative Instruction (AI) 14 to in.lude reference to tube fitting class MTU-MKI-28.
QACEG also issued CATD 80201-SQN-03 (Attachment F) identifying that TVA's commitment to the NRC of developing Procedure MAI-29, 4
" Instrument Tube Fitting and Installation" and issuing it by August 15, 1986 has not been accomplished to date. The SQN Site
. TVA EMPLOYEE CONCERNS REPORT NUMBER:
J' REPORT TYPE: SPECIAL PROGRAM 80201-SQN.
Element Report REVISION NUMBER:
TITLE: 5 Inspection Criteria PAGE 16 0F 16 Director responded on January 24,' 1987 (RIMS S03 870123 802) indicating that the SQN Modification Group has the responsibility to initiate MAI-29 and the estimated completion date is March 9, 1987.
Attachment A, identified the concerns as potentially safety-significant or safety-related. QACEG evaluation concludes that only concerns JAN-85-001 and XX-85-050-001 were potentially safety-significant. However, corrective measures, as described -in this report, have and are being taken.
6.0 ATTACHMENTS A. Employee Concern Program System (ECPS) List of Employee Concern Information B. NSRS Report I-85-329-SQN C. Final Report for NRC Open Items WBRD-50-390/85-43, WBRD-50-391/85-42 D. CATD 80201-SQN-01 E.- CATD 80201-SQN-02 F. CATD 80201-SQN-03 G. Potential Enforcement Finding 50-327/86-61 and 50-328/86-61 i
i 1
I l
Attccluext A Pag 2 1 cf 2 PAGE' . - . 7~
REFERENCE - ECPS120J-ECPS121C TEllNESSEE VALLEY AUTHORITY RUH: TIME - 10:31:3?
- REQUEST OFFICE OF NUCLEAR P0HER RUll DATE - 03/04/8'.
FREQUENCY ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY
- ATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80201 BASIS.0F INSPECTION S
H I REi 3RT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN BT BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION
! CONCERN NUMBER CAY CAT D LOC --------- ------ ------------------------------------------=-___ ---
01 QA 80201 N SQN 1N N Y N OECP HELDING PERFORMED BY SECO (OUTSIDE CONTRACTOR) ON J Ati-85-0 01 HSR TUBE BUtIDLE REPLACEMENT MODIFICATI0H IS SUBSTA 2 NA NA SR HA NDARD, SLAG NOT REMOVED, PIPING NOT ALIGNED PROPE-
! RLY, HELDS NOT CLEANED UP, TUBING NOT INSTALLED PR OPERLY, ETC.
4 QA 80201 N SQN 1N N Y N DECP THIS CONCERN HAS NOT DOCUMENTED PER SQA166 BUT HAS JLH-85-005 01 BEEN INCLUDED IN THE EMPLOYEE CollCERN LOG. THREE 2 NA NA SS NA SAFETY INJECTION HELDS ON HAVC0 SPOOL PIECES DISP LAYED EXCESSIVE OVERLAP, ARC STRIKES, UtIDERCUT HEA i VE HIDTH, AND RUST. THESE HELDS HOULD NOT MEET.CU j RRENT ACCEPTANCE CRITERIA.
CD 17300 S SQN 1Y Y Y Y I-85-329-SQN QTC INADEQUATE QUALITY ASSURANCE CONTROLS'HERE APPLIED XX 050-00101 TO THE INSTALLATI0ll 0F INSTRUMENT TUBING COMPRESS T50096 2 SS SS SS SS ION FITTINGS AT SEQUOYAH. 110 FURTHER INFORMATION d
02 QA 80201 S SQN 1N N Y ll AVAILABLE. NO.FDLLOH UP REQUIRED.
2 NA NA SS NA 03 QA 80202 S SQN 1Y Y N Y 2 SS SS NA SS CO 17300 S BLil 1Y Y Y Y QTC INADEQUATE QUALITY ASSURANCE CONTROLS ARE APPLIED XX 050-00301 TO THE INSTALLATION OF INSTRUMEllT TUBING COMPRESSI T50096 2 SR SR SR SR ON FITTIllGS AT BELLAFONTE. NO FURTHER DETAILS AVA 02 QA 80201 S BLN 1N N Y ll ILABLE. NO FOLLOH UP REQUIRED.
2 NA IIA SR tlA l
03 QA 80202 S BLH 1Y Y N Y i 2 SR SR NA SR 1N N Y H QTC BROHN'S FERRY: THE VISUAL EXAMINATION PROCEDURE Hl..
XX 102-00601 QA 80201 S BFH ICH COVERS ASME SECTION II IS VERY t10N SPECIFIC.
T50172 2 ilA NA SR NA NUCLEAR P0HER DEPT. CollCERN. CI HAS NO ADDITIONAL 1Y Y ll Y INFORMATI0ll. NO FOLLOH UP REQUIRED.
i 02 QA 80202 S BFil 2 SR SR NA SR l
m
Attcchme3.t A Pa f2 PA$.E -
8 REFERENCE - ECPSI2DJ-ECPS121C TENNESSEEVALLEYAU1NRTS RUN TIME - 10:31:3-
- REQUEST OFFICE OF NUCLEAR PONER FREQUEllCY EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 03/04/8'.
OllP - ISSS - RilM EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY CATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80201 BASIS OF INSPECTION S
H 1 REPORT APPL SUB R PLT 2 SAF RELATED HISTORICAL CONCERN CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION CONCERil NUMBER CAT - - -
QA 80201 S HPS 1N N Y N QTC KNOXVILLE - THE TVA SYSTEM PROCUREMENT MANUAL ALLO XX 125-00601 HS PROCUREMENT OF IE, SAFETY RELATED, NSSS AND HOL T5022I 2 NA NA SS NA D DEVICES EQUIPMENT TO BE PURCHASED COMMERCIALLY, 1Y Y N Y NOT THROUGH QUALIFIED' SUPPLIERS, BECAUSE THEY ARE 02 QA 80202 S HPS PART OF A LARGER COMPollEllT. (NAMES / DETAILS TO THE, 2 SS SS NA SS SPECIFIC CASE ARE KN0 Hit TO QTC AND HITHHELD TO MA IllTAIN CONFIDENTI ALITY). ' NUCLEAR POWER CONCERN CI HAS NO MORE INFORMATION.
6 CONCERHS FOR CATEGORY QA SUBCATEGORY 80201.
S 9
e e
ATTACHMENT B , ,
ITO A es los4-ss) towww.s.es) t*NITED' STA rES COVERN3f ENT
~
TENNESSEE VALLEY AUTHORITY 2 )m07andum-
~
TO:
H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant ,
!' R. W. Cantrell, Manager of Engineering, W12A12 C-K
'FROM:
K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K DATE: ((g{$]986
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TR
.~
T-85-329-SON Transmitted herein is NSRS Report No.
TION _
Subject._OUALITY ASSURANCE CONTROLS / COMPRESS' ION FITTING IN XX-85-050-001 h
Ys&TTS nn Concern No. . f4 vir rm'er-r OLEn&R eg FULNT and associated prioritized recommendations for your ftn 1 ybti action / disposition.
$ ,. i it
-: 43 It is requested that you respond to this report and the attache .~ s.v <,s Q (q
- 28. 1986_. iShodit. ,,-i M ye any Priority 2 [P2] recommendations by February B-P
. i f (
Stevens_ at telephone 7 ; ; __
questions, please contact W. D. .,c.. .
. 4 Yes NMi , !
Recommend Reportability Determination:
- .- ... /;//
' iFeetor, NSRS/Desijinee
[
~
WDS:GDM Attachment l cc (Attachment):
- W. C. Bibb, SQN .
! W. T. Cottle, WBN i James P. Darling, BLN R. P. Denise, LP6N40A-C C. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant *
,J Eric Sliger, LP6N48A-C J. H. Sullivan, SQN l
455U
- .W n ..r. r.. s.. n.....tr c...
- -. nr .
~ '~ ~
- n- r. .
e _
TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY _ REVIEW STAFF NSRS I!NESTICATION REPORT NO. I-85-329-SQN
~
~
EMPLOYEE CONCERN:
XX-85-050-001
~
SUBJECT:
QUALITY ASSURANCE CONTROLS FOR COMPRESSION F INSTALLATION .
DATES OF SEPTEMBER 18 - OCTOBER 8, 1985 ItNESTICATION:
.: y
'v:)I A Id
-- Wd DATE INV STICATOR:
R. E. MCCLURE uM 4[7[ d INVESTIGATOR:
DATE W. R. SIMONDS ..
, ~ ... . . __ _,_.
2[d[g4 REVIEWED BY: _
[Mf DATE M. W. ALEXANDER L / Df& -
=' /d ArrR0vEn BT:
WU N-DATE l
W. D. STEVENS
/1 2Y m
~
s'
~
.}
I. BACKCP.0UND investigation was conducted tod by A Nuclear Safety Review Staff (NSRS) determineT).theThe validity of an the Quality Technology Company (QTC)/ Employee Response i ntTeam (ER concern of record, as summarized on the Employee Concern stated: Ass gnme Request Form from QTC and identified as II-85-050-001,
~
" Inadequate quality assurance controls were applied to the installation of instrument tubing compression fittings at Sequoyah."
In addition to this investigation, NSRS has conducted two previous investigations of matters closely related to the above con record.
NSRS which were determined to be applicable to this employee concern. .
Those investigations are documented as follows:
A.
NSRS Report No. R-85-02-SQNIWBN (Ref. 1) presents the results d of a special review which was performed to investigate concerns expresseT by the Crawford Fitting Company.
misapplication of the Swagelock tube fittings on the Westinghouse designed bottom-mounted incore instrumentation system seal tables.
h The report presents NSRS recommendation R-85-02-SQN/WBN-01 to NU for the preparation and distribution to the nuclear plants of an
.. I office-wide awareness bulletin on tube fitting maintenance activities.
B.
NSRS Report No IN-85-795-001; IN-85-795-002 (Ref. 2) prosents the
. results of an investigation which was conducted regarding Concern No. two employee concerns pertaining to Watts Bar. stated that compression fitti The report centains IN-85-795-001 are not installed per vendor instructions. lity. . .....
evidence of a potentially significant condition adverse to quadvaluat en-of
' -~
states that an and NSRS recommendation Q-85-795-601-01
~
f this situation should be conducted for generic applicability to all I
' TVA plants. .
l l
II. SCOPE l
A.
The scope of the investigation is defined by the concern of record.
Since previous NSRS investigations involved matters closely related to this concern, the results of those investigations were included as appropriate in the findings of this investigation.
i i
B.
Reviews of regulations, specifications, and other pertinent docu-f ments were performed to identify requirements, commitments, and l programmatic controls applicable to the concern of record.
Cognizant personnel were interviewed to help establish the manner in which compression-type fittings have been installed at SQN.
l 1
J i ,
III.
SUMMARY
OF FINDINGS A. Requirements and Commitments
Criterion II, " Quality Assurance Program" b.
Criterion V " Instructions, Procedures, and Drawings" c.
Criterion I, " Inspection" 2 Topical Report TVA-TR75-1, Revision 8 a.
Section 17.1~.2.3, " Indoctrination and Training" b.
Section 17.1.5, " Instructions, Procedures, and Drawings" .
c.
Section 17.2.2.3, " Indoctrination and Trainin~g" d.
Section 17.2.5, " Instructions, Procedures, and Drawings" ,
- e. Section 17.2.10. " Inspection" 3
, . I 3.
OEDC Quality Assurance Manual for Design and Construction
- C.7 a.
OEDC-Q AP-2.0, . " Quality Assurance Program,". Revision 1
- b. QAS-QAP-4.1, " Quality Assurance I".doctrination and Training," Revision 0 .
t c.
CONST-QAP-2.02, " Quality Assurance Items," Revision 0
- ~~~-
' d.
CONST-QAP-2.07, " Qualification / Certification. of-. Inspection,
~~
.,, Examination, and Testing Personnel," Revision 3
- e, COUST-QAP-10.01, "In'spection," Revision 2 4.
Sequoyah Nuclear Plant General Design Criteria No..SQN-DC-V-3.0, "The Classification of Piping, Pumps, Valves, and Vessels,"
~
Revision 1
- 5. Sequoyah Nuclear Plant Construction Specification No. N2M-865,
" Field Fabrication Assembly Examination, and Tests for Pipe Duct Systems," Revision 3
~6. Sequoyah Nuclear Plant Construction Specificati by the Sequoyah Nuclear Plant Quality Assurance Program."
Revision 5 ,
}
2
. . .. .. . .. - ~. .- ~ . - .
4
' . ,)
- ,?
I) 7.
HUC PR Nuclear Quality Assurance Manual 10/12/84
- a. Part II, Section 2.1, " Plant Maintenance," Revision b.
Part III, Section 6.1, " Selection and Training of Personnel 10/12/84 for Nuclear Power Plants," Revision RB . . Findings 1.
Reference 1 presented NSRS' recommendation R-85-02-SQN/WBN-01 i l E which addressed the need for increased and somewhat delicate nature of compression tube fittings in awareness of the cri The recommendation specifically encouraged tWC PR to general.
d prepare and distribute to the nuclear plants an offi
~
, 20, 1985 awareness.
This bulletin was issued September U
(Ref. 39), to the nuclear plants with direction to take the "
following actions: ,
o Issue the bulletin to employees whose work activities
. involve them with tube fittings.
l o
Incorporate the concerns and policy stated in the _ bulletin '
into permanent hazard control instructions and plant.
[ instructions as appropriate.
s y; i o Coordinate with the Nuclear Training Branch and implement j training for employees involved in installation and
. maintenance of the tube fittings.
! The text of the bulletin contains the following statements:
o Sequoyah has initiated a training class on tube fittings in - ,,
- cooperation with the POT,C. ,,_ . ..
o
- It is'P&E (Nuclear) policy that compression-type tube l
fittings be installed consistent with manufacturer's instructions and that maintenance activities involving these l ' fittings shall not degrade the integrity of these fittings.
2.
Reference 2 presented NSRS' recommendation Q-85-795-001-01 whi addressed evidence of a potentially significant condition adverse to quality regarding compression fitting inadequacies at The following actions were recommended and the Watts Bar (WBN).
' results indicated:
I a.
WBN CONST should initiate an NCR documenting this condition--
ASME Significant NCR WBN-6278R0 (Ref. 21) was initiated to
[
document the safety significance of the inadequacy of quality assurance controls on compression fittingThe NCR states that
} installation for tubing connections.
,f installations were discovered at WBN which did not agree The with the manufacturer's installation instructions.
condition was identified as "significant."
3
. - - - .. - - - - - . .. - ~ - -_ - -.. -. .-
'./
l b,
The response to NSRS should include the results of anL_
evaluation of this ' condition for generic applicability to all TVA plants--it wa's determined that this NCR evaluation WBN-6278R0 had not been performed as of January 7, 1986.
received an engineering review by OE in accordance with the l
requirements of OEP-17 (Ref. 36) but contrary to OEP-17, paragraph 3.2, OE has not performed an evaluation for generic implications of the condition to Sequoyah and
' Browns' Ferry.
- c. NCR WBN-6278RO directed that OE evaluate compression fitting..-
~ installation to determine the'need for possible TVA process-
___. As a result, OE developed a specification revisions.
process specification (Ref. 27) for installation and inspection of compression fitting joints in mechanicalThi tubing systems. Advance copies were distributed to all plant ,
projects. SQN DCU will route a copy to the sites on January 2,. 1986. '
SQN Modifications Branch for review.
d.
NCR WBN-6278R0 directed that OE provide analyses for certain compression fitting connections to determine the accept-ability of these installations although leak tightness is p .. reg achieved. These analyses were performed by Singleton Materials Engineering Laboratory, and the results of the The i ' i's/l testing program are documented in references 30 and 31.
results provide technical,information concerning the i reliability and safety of compression fittings which may be installed inconsistent with the ma'nufacturer's recommenda tions but which achieve eleak tightness, i
the Power Operations Training Center (POTC)
- 3. On August 19, 1985, )
i established an initial tube fitting training program (Ref. 28 - -.
i ,-
- , in cooperation with SQN...This.. program is intended to provide --
v individuals who install tube fittings with the-necessary
+
idformation to' properly install tube fittings to ensure The course a icak-proof, mechanically sound tubing connection.
- material ' cove'es'the most commonly used brands.. of tube fittings.
i 4.
10 CFR Part 50 Appendix B, Criterion II, requires that structures, systems, and components covered by the QA program be identified. Instrument sensing lines in safety-related systems
[ have been identified in the QA programs for design and construc-tion (paragraph III. A.6) and for the operation (Ref. 8.c) phases of SQN.
S. 10 CFR Part 50 Appendix B Criterion II, also requires that the QA program provido control over activities affecting the quality j of the identified structures, systems, and components to an extent consistent with their ir.portance to safety.
).
. .. , ..~ .- . _ _ . -- . .. - . .
~,
/
4 h f '.
The procedure which provided programmatic QA'identified controls oin-activities during the construction phase of SQN isHowever, lowe
~
paragraph III.A.3.a. did not include
!. applicable ~ to instrument . sensing lines '(Ref. 35)i fitting provisions'for quality control inspection of compress on .-
r i
installation activities.
The procedure which provides programmatic QAf controls SQN is of 4
maintenance activities during the operational phase oHowever, lower-tier SQN s
identified in paragraph III.A.7.a. d) dD not include provisions for quality ii f
control . in compression fitting installation or maintenance activ i t es.
. Repaired instrument sensing lines are inspected by bly. qual ty
!~ i ble Lower-tier SQN instructions applicable to instrum
. tubes (Refs. 8.e-f) do include quality control hold point ll as provisions for mechanical verification and signoff, as we
- 1. . .
?
cleanliness checks. the
- 6. 10 CFR part 50, Appendix B, Criterion ified II, also that t'
j .,,, performing- activities affecting the qt:ality of the id
! , suitable proficiency is achieved and maintained.
12 d.
The programmatic training requirements applicab
- The implementing document (Ref. 20) contained modules for for quality control inspector certificaticn but no modules l
5 training tube fittings.
of personnel involved in installation QN of compr i ment lines and loops had not been implemented by the time S construction was completed. ,_,,,_ .
The programmatic training requirements applicable toTraining the operational phase of SQN are established by III.A.7.b.
- requirements fo.e maintenance personnel are addressed in this 5
procedure. The' lower-tier SQN instruction (Ref. 8.a) which implements this procedure addresses maintena the installation.of compression-type fittings on instrum sensing lines.
do not cover tube fittings (e.g., Ref. 28) even th management to " implement training for employees involved in installation and maintenance of tube fittings."
D 5
ir.
, .o -
- References 8.b and 8.d are examplesReference.
of SQN mainten but do not specify personnel training requiremen,ts.
, 8.e involves the installation of compression-type fittings on the instrument thimble tubes and does specify that "all personnel working on tube fittings.should l t blish-have had 28). .However, even this instruction does-not clear y es a
, the training as a requirement.
SQN management is apparently committed to In addition, instructions do not formalize the requirement.
, reference 22 establishes the training These requirements requirementsfor do quality' not control inspector certification.
include instruction in inspection of installation of.However, qual compression-type fittings.is required in-referen.ce 8.e "to verify th '
are properly tightened."
10 CFR Part 50, Appendix B, Criterion V, requires that 7.
activities affecting quality be prescribed by documented 4
instructions, procedures, or drawings. . The above paragraphs address several instructions and procedures applicable to
, , .,) activities affecting the quality.of instrument sensing lines.
A f g/ In addition to these documents. SQN engineering drawings (e.g.,
[ Refs. 24.a-h) and constructio,n specifications (III. A.5 and 6) essentially prescribed the only requirements pertaining to ~
instrument sensing line erection and quality requirements until ,
recently. These documents contain very little specific instruction / guidance for compression-type fitting installation.
However, this situation has~ improved with the development and
- l. distribution of reference 27. -
tion of activities 4
- 8. ,C,riterion I requires that a program for inspec affecting quality be' established and executed .to verify conformance with the prescribed requirements for accomplishing
- the activity.' Refer to paragraph III.B.5 above for findings ,,
related to this requirement.
,' IV. CONCLUSIONS AND REC 0KMENDATIONS A. Conclusion
[
The employee concern is substantiated because this investigation has
, revealed that quality assurance controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10 CFR This50, i-
- Appendix B, relative to compression fitting installatio However, recent actions have been l f h i
s' the operational phase of SQN.taken by SQN management and ot controls in the area of the employee concern.
! 6 i
- . _.,. ._ . _ . ,.- _ _ .-~ . _ - ._ ,, ,. - _
o.-
l
)
B. Recommendations i Fittine Inadecuacies of_
1.
.I-85-329-SQN-01, Evaluate' Compress on NCR WBN-6278 for Generic Applicability 5 001-01 This recommendation is being reiterated from Q-85-79 -
(Ref. 2).since previously identified .in the original NSRS Specifically, bility reportth this recommendation as described in III.B.2.b.
NCR WBN-6278R0 has not been evaluated for generic applic -
to all TVA nuclear plants. However, the review for review.
September 9, 1985 (Ref. 38),did not include an evaluation required by OEP-17 (Ref. 36).in III.B.4-8 strongly indicate the f rmed by WBN-6278R0 to SQN, the final determination must l r
.be C
per oThe OE as described in OEP-17. ted-and WBN-6278R0 be evaluated for applicability .to all TVA nuc ea plants and that the result's of this evaluation The be documen response distributed as required by established [P2] procedures.t applicability evaluation was not performed.
3g 2.
I-85-329-SQN-02, Noninspection Personnel Training itted g.} e SQN management is apparently commto tra As described in III.B.6 l
of compression-type fittings.
instructions do not-formalize or clearly establish the personne NSRS recommends that SQN instruc-training as a requirement.tions applicable to the i inginst'allation of .
an compression-type fittings be revised to establish tra
- 39. n [P2) . . . . . .
personnel as a requirement as described in reference- .
3.
7-85-329-SQN-03, Inspection Personnel Training.'
be NSRS recommends that tr'aining on compression-type fittings .
developed and implemented for quality control S QN .'
f-inspection methodologies for verification of the i quality P2]o
~
safety-related applications of compression-type fitt ngs.
I-85-329-SQN-04, Ouality Control Inspection-4.
l ted NSRS recommends that requirements fitting be es
- conduct random sample inspections of compression-typeThes d in j installation activities.
to verify and document that these activities are performeInspectio I
accordance with prescribed requirements. i testing.
) performed af ter installation bUt prior to hydrostat c (P2]
l 7
i
\
)
h DOCUMENTS REVIEWED IN INVESTIGATION I-85-329-SQN AND REFERENCES f
- 1. Special Review of Manufacturer Identified Potential Misa Report No. R-85-02-SQN/WBN 2.
Compression Fittings on Instrument Tubing - NSRS Report No.
IN-85-795-001; IN-85-795-002 .-
- 3. Swagekoek Report on Imitation and Interchange - 1984 0202.15 and 0202.16. " Instrument Mechanics
- 4. NUC PR Area Plan Procedure
- Training" 5.
NUC PR DPM N77A12. " Requirements for Repair and/or Replacement of Nuclear Power Plant Process - Control Instrumentation" 6.
Swagelock " Gold Book" - Tube Fitting and Installation Manual 7.
Westinghouse Installation and Standards Manual, Instrumentation and '
Control Standards Section 3.0, " Pressurizer Sealed Reference Leg
' Level System," Revision 8/11/71
- ~* ,
- 8. Sequoyah Instruction Manuals
- a. AI-14, " Plant Training Program," R'evision 30 b.
SMI-1-68-20, " Repair Leak in Tubing Fitting 1-VLV-68-442A."
i i
Revision 1 .
c.
SQA-134, " Critical Structure, Systems, and Components ..
(CSSC) List,"
' . Revision 7 .
d.
IMI-11B, " Filling of Sealed Instrument Systems Backfilling, Venting, and/or Flushing of Instrument Sensing Lines," Revision 5 e.
MI-1.9, " Bottom Mou ted Instrument Thimble Tube Retraction and Reinsertion," Revision 7 f.
MI-1.10, "Incore Flux Thimble Cleaning and Lubrication," Revision 3 i
- 9. NUC PR Nuclear Quality Assurance Manual 10/12/84
- a. Part II, Section 2.1, " Plant Maintenance," Revision b.
Part III, Section 6.1, " Selection and Training of Personnel for l Nuclear Power Plants ," Revision 10/12/84 f
)
8
- i. '_
/
- . o <
- 10. OEDC Quality Assurance Manual for Design and Construction a.
OEDC-QAP-2.0, " Quality Assurance Program," Revision 1
- b. QAP-QAP-4.1, " Quality Assurance Indoctrination and Training,"
Revision 0 c.
CONST-QAP-2.02, " Quality Assurance Items," Revision 0
- d. CONST-QAP-2.07, " Qualification / Certification of Inspection, Examination, and Testing Personnel," Revision 3
- e. CONST-QAP 10.01, " Inspection," Revision 2
- 11. MEDS Search on CONST QA Training Requirements
- a. Criterion II, " Quality Assurance Program"
- b. Criterion V, " Instructions, Procedures, and Drawings"
- c. Criterion I, " Inspection" ,
i t for
- 13. . ANSI Standard N45.2-1971, " Quality Assurance Program Requ remen s
- h'jp Nuclear Power Plants"
- 14. ANSI Standard N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"
- 15. ANSI Standard N45.2.11-1974, " Quality, Assurance Requirements for the
' Design of Nuclear Power Plants" '
16.
ANSI Standard N45.2.6-1978, " Qualifications of Inspection, Examination, * ~~ ~-
and Testing Personnel for Nuclent Rower Plants" . .
- 17. Topical Rehort TVA-TR75-1; 17.1.2.3 ; 17.1.5 ; 17.2.2.3; 17.2.5 ; 17.2.10 Revision S . .
4
- 18. Sequoyah Nuclear Plant General-Design Celteria No. SQN-DC-V-3.0, "The Classification of Piping, Pumps, Valves, and Vessels," Revision 1
- 19. Sequoyah Nuclear Plant Construction Specifications
- a. N2M-865, " Field Fabrication, Assembly Examination, and Tests for Pipe and Duct Systems," Revision 3
- b. N2G-877, " Identification of Structures, Systems, and Components Covered by the Sequoyah Nuclear Plant Quality Assurance Program,"
Revision 5
l Instrumentation," Revision 2 9
- 1 l
I
,4 .
) No.
21.
WBNP-CONST ASME Significant Nonconforming Condition Report (NCR WBN-6278, Revision 0 22.
NUC PR Quality Control Inspector Training Manual
- 23. ANSI Standard B31.7-1969, " Nuclear Power Piping" Sequoyah Nuclear Plant Mechanical Instruments and Controls Drawings 1
24.
a.
'47B001-15 " Mechanical Branch Valve Connection seismic Support,"
Revision 2 -
b.
A1W6001133, " Mechanical Instruments and controls," Revision 8 c.
47W600-1, " Mechanical Instruments and.Controis," Revision 12 d.
47W813-1, " Flow Diagram Reactor Coolant System," Revision 25 i
e.
47W555-1, " Mechanical CVCS - Chemical Control and Makeup Pip ng, Revision 13 f.
47W600-24, " Mechanical Instruments and Controls," Revision 16 g g. 47W600-18. " Mechanical Instruments and Controls " Revision 6 h, 47W600-16, " Mechanical instruments and Controls," Revision 4
- 25. Swagelock Tube Fitting Catalog C-983
- 26. Parker CPI Catalog No. 4230, January 1977
- 27. Process Specification 3.M.13.1 (RO), " Specification for ,
w bing Systems," Ceneral Construction Specification G-29M, December 9, 1985 .. . . . _ _ , . _ ,
h 28.
MTU-MMT-28, " Initial Tube Fitting Training," Nuclear Train'.ng Branc ,
- Power Operations Training Center, Revision 1 5
- 29. SQN Corrective Action Tracking' Report, CATS No. 85219, May.23, 198 30.
Memorandum from W. M. Childress to R. M. Jessee, " 6278R1 Watts Bar- Nuclear Plant - ASME Significant Nonconformance Report (NCR)
Laboratory Testing," dated December 6,1985 (B46 851206 001) 31.
Memorandum from W. H. Childress to R. M. Jessee, " Watts 6278R1Bar - Nuclear Plant - ASME Significant Nonconformance Report (NCR) 17, 1985 f
Laboratory Testing - Supplemental Data," dated December (B46 851212 001)
- 32. Memorandum from H. G. Parris to G. Wadewitz, " Requests for15, 1985 (Col 85 l
f Investigation / Evaluation," dated August t
10 l
- ?
) j
- s ,
1 <
h (SQN) and 33.
Memorandum from James P. Darling to K. W. Whitt, "Sequoya f t r Watts Bar (WBN) Nuclear Plants - Special Review of Manu ac at tings ure -
Identified Potential Misapplication of Swaselock Tube Fit QN/WBN,"
Westinghouse Reactor Seal Tables - NSRS Report No. R-85-02-S dated May 6, 1985 (L44 850426 807) 34.
SQN Workplan Specification WP No.10721, February 1,1984 ification,
- 35. CONST-SNP Inspection Instruction No. 85,O " Installation V , .
Sampling Lines, Control Supply Headers and Signal Lines," R i i 2 36.
Office"o'f Engineering OEP-17. " Corrective Action," Rev s on
, l 37.
Memorandum from Guenter Wadewitz to K. W. Whitt, " Watts 5 Bar Nuc ear Plant - Request f or Investigation / Evaluation," October 1,198 l Plant 38.
Memorandum from Guenter Wadewitz,to J. W. Co'an, dated"September Watts Bar 9, Nuc ear
- ASME Significant Nonconf ormance Report 6278RO,"
1985 Awareness 39.
Memorandum from W. T. Cottle to Those listed, " Tube Fitting 20, 1985 (L29 85 and Initial Training," dated September 4
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vv a u e u . x ,si t*1!!TED STATES GOVCRNMENT TENNESSEE VALLEY AUTHORITY
- i. C7HOTdndum
' Review Group (NMRG),
To :R. K. Seiberling, Manager of Nuclear Manager s l Plant LP 6N 38A-C FROM
- H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuc ear 5..;o..o(
DATE : April 18, 1986 I-85-329-SQN, SL*BJECT: NUCLEAR SAFETY REVIEW STAFF to R. W. Cantrell and me
References:
- 1. Memorandum from K. W. Whitt13,1986, " Nuclear Safety Review Staf f dated February Investigation Report Transmittal" 2.
Memorandum from J. P. Vineyard to H. B. Rankin dated March 28,1986, "Sequoyah Nuclear Plant -- Potential (copy Generic Condition Evaluation" (B25 860328 005) attached)
~
- 3. Memorandum February from John' A. Raulston to Those list (B45 860225 259) (copy attached) v5
..d
.my' Attached is my response to NSRS Report No. I-85-329-SQN.
QR.wh H. L. Abercrombie
- s PRW:GBK:RCB:DR Attachments I cc (Attach.renq),:
j Employee Concern Files, RES, ONP, SB-2, Sequoyah -j J. L. Hamilton, QA, O&PS-3, Sequoyah ' r n,i 3 ,
T. L. Hughes, ONP, O&PS-3, Sequoyah '
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l L. L. McCormick, ONP, SB-2, Sequoyah / Pc5 3 '
COORDINATED:
QA/JLHamilton, Regulatory Engineering /LLMcCorn?
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NUCLEAR SAFETY REVIEW STAFF
} REPORT NO. I-85-329-SQN NSRS REPORT NO. I-85-329-SON _
Concern
" Inadequate quality assurance controls were applied to the installation of instrument tubing compression fittings at Sequoyah."
Conclusion The employee concern is substantiated because this investigation has revealed that quality assurance controls for SQN were nonexistant or inadequate to comply with the applicable criteria ofThis 10 CFR 50, Appendix condition existed B, relative to compression fitting installation.
during the construction phase and has existed in the operational phase of SQN.
However, recent actions have been taken by SQN management and others as described above to improve the controls in the area of the employee concern.
Recommendations
("33 1. I-85-329-SQN-01, Evaluate Comoression Fitting Inadecuacies of NCR WBN-6278 for Generic Aeolicability_
,..J This recommendation is being reiterated from Q-85-795-001-01 pre-viously identified in the original NSRS report (Ref. 2) . since the
. actions taken by P&E (N_uclear) did not completely address this Specifically, NCR recommendation as described in III.B.2.b.
WBN-6278R0 has not been evaluated for generic applicability to all TVA nuclear plants. The NCR was transmitted to OE on September 9, 1985 (Ref. 38), for review. However,,the review did not include an evaluation for generic applicability as required by OEP-17 (Ref. 36). Although the findings presented in III.B.4-8fstrongly indicate the applicability of NCR WBN-6278R0 to SQN, the final determination must be performed by OE as described in OEP-17.
Therefore, NSRS recommends that NCR WBN-6278R0 be evaluated for applicability to all TVA nuclear plants and that the results of this evaluation be documented and distributed as required by estab-lished procedures. The response to NSRS 'should include a statement of why the generic applicability evaluation was not performed. (P2)
- 2. I-85-329-SQN-02, Noninspection Personnel Training I
As described in III.B.6, SQN management is apparently com=itted to training personnel involved in installation and maintenance of l compression-type fittings. However, several applicable SQN instructions do not formalize or clearly establish the personnel training as a requirement. NSRS recommends that SQN instructions
) applicable to the installation and maintenance of compression-type
', fittings be revised to establish training of personnel as a require-ment as described in reference 39 (P2)
{
.- , ~-, ._ . _ _ . - _ . . - - - - . - _ -- _ _ _ - - -
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- 3. I-85-329-SQN-3, Inspection Personnel Training NSRS recommends that training on- compression-type fittings be developed and implemented for quality control inspectors hat SQN.
This training should provide specific instruction on the inspection methodologies for verification of the quality of (P2) saf ety-related applications of compression-type fittings.
- 4. I-85-329-SQN-04, Ouality Control Inspection NSRS recommends that requirements be established and implemented in applicable SQN instructions that quality control inspectors conduct random sample inspections of compression-type fitting installation activities. These inspections should be designed to verify and document that these activities are performed in accordance with prescribed requirements. Inspections could be (P2) performed af ter installation but prior to hydrostatic testing.
SON Response to I-85-329-SQN-01 NCR WLN-6278R1 was transmitted to SQN Engineering Project (SQEP' by reference 3. A request was made to perform a review and determine applicability to SQN by reference 2. The NCR was then forwarded to the
.sf SQN Regulatory Engineering Section for distribution to the appropriate site sections and inclusion in the operating experience review (OER)
" program for any generic applicability. It appears that the need for a generic review of NCR WBN-6278R0 was inadvertently overlooked in September 1985.
SON Response to I-85-329-SON-02 i
The plant maintenance personnel responsible for installation and main-tenance of compression-type fittings attended a formal training course, MTU-MMI-28 " Initial Tube Fitting Training," given In by addition, the Nuclear Training the plant Branch, Power Operations Training Center (POTC) .
Quality Assurance Staf f is working with plant management to determine if the training requirements need to be incorporated into the applicable plant procedures. .
SON Resoonse to I-85-329-SON-03 The SQN quality control (QC) inspectors attended the training course identified in the response to I-85-329-SQN-02 prior to being assigned This training verification activities for compression-type fittings.
provides suf ficient guidance for the QC inspectors to perform the required verification activities.
J U _ .
I SON Response to I-85-329-SQN-04_
h ired The plant QC inspectors are currently performing inspe ivities by the appropriate work instructions.or site requirement i f the to perform th will be included in SQN work instructions at the discret on o Quality Assurance Staf f.
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' Chattanooga, Tennessee l
JUL 3 0 B3S WBRD-50-390/85 43 l J.
WBRD-50-391/85 42 l
U.S. Nuclear Regulatory Conrnission l
Region II Dr. J. Nelson Crace, Regional Administrator l
' Attention: suite 2900
. 101 Marietta Street, NW,
' Atlanta, Georgia 30323
Dear Dr. Crace:
2 - QUESTIONABLE COMPRESSION 90/85 43, WBRD-50-391/85 42 -
WATTS BAR WUCLEAR FLANT (WBN) - UNITS 1 AND
[ FITTINCS OW INSTRUMENTATION TUBINC - WBRD '
PITAL REPOR_T NRC-Region II Inspector as The subject deficiency was initially 24, 1985, reported to with 10 CrR in accordance 50.55(e) 24, 1985, and Al Ignatonis on September Previous interim reports wereissubmitted Enclosed on October our final report.
WBN 6278.
v January 31 and March 31, 1986.
d with Morris Branch on
=c .
Delay in substittal of this report was discusse July 17, 1986.
i h J. A. Mcdonald at N If there are any questions, please get in touch w t (615)'365-E527. Very truly yours, N TENb SS E V t,J.tY AUTHORITY
/
N /'
- E. L. Cridley Director
' Nuclear Safet and Licensing
' O -
Rnclosure cc (Enclosure):
Mr. James Taylor Director Office of Inspection and Enforcement
, U.S. Duclear Regulatory Consalssion Washington, D.C. 20555 .
I ,
Records Center Institute of Nuclear Power Operations 11D0 Circle 75 Parkvay, suite 1500 Atlanta, Coorgia 30339 -
RMI:ITP:1CP E. A. Padde, 9-16s SB-K ec (tnelosure): Eaulston, W10 C126 C-K EDt3A Ar 72Ad J. A.
KRC Resident Inspector, Watts Bar C W. Cantrell, BR IN 76B-C E. E. Ennis, Watts Bar ONP Cuenter Wadewitz, Watts bar EU Co!
R. B. Kelly, LP AN 45A-C J. A. Mcdonald, site Lie, WBN-OhT b.c. LSO, LP SN 106B-C COORDIEATED: DNE/Prahl WBW/ rickey 0958b N
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. EECLOSURE WATTS BAR NUCLEAR PLAET UNITS 1 AKD 2 TUBIWC '
QUESTIOMABLE COMPRESSION WBRD-50-390/85-43, WBRD-50-391/85 42 FITTIMOS ON WCR 6278 IOCFR50.55(e)
TINAL REPORT _
Descrirtion of DefielencI program (employee concerns TVA has identified through its employee h concernugh WCR 6278 RO, that variou I5-85-795 001 and 002) and, subsequently tThese rot in compression accordance fittings with fitting are compression fitting installations were no III tubing connections d tions. on various manuf acturer's installation recournen aused f or insttwnent-r llation in accordance with systems throughout the plant. compression fittings.
fitting joints include manuf acturer's recournendations. fittings as well as Im As a result of these employee concerns, a samp f omed and 60 fittings used in instrument or sampling lines was pergeneral categories:
i discrepancies identified which f all in the follow ngt bottooed out inside the l s were either
- q tubing cuts were not deburred; tubes were nofittings; n J unidentifiable, missing, or reversed. t site procedures and inadequately T
,' attributed to inadequate or nonaxistenThis resulted from inadequate specifica trained construction craf tsmen.
, 3 of requirements. ,
Af ter this sample inspection was comple e t d, WBN maintenance personnelinclud k d reducers with N identified an additional category which was thenThis cat 6278.
N Iwerial-Eastaan "Hi-Seal" nuts and ferrules as a mThese installations are no instrument panel isolation valves. (It should be noted that these type with manuf acturer's reconnandations. d ) The cause of this installations are not in the ASME code boun ary.rror in TVA drawings which C t an tube end reducers.
partleular condition was detemined to be an eallowed the 5_afety Iess11c st lent dations during In general, without adherence to manufacturers' recoernenl which wo installation, compression fittings may not totally testing. ThisseaAll testing" closed-e leaking connections.
tubing receives hydrostatic or pneumatic pressuref the initial seal of the the eltahmtes any concern with the adequacy However, o potential long-term concerns existed compression fittings.
adequacy of the seal due to vibration induceEither of these cituations Also, had during a seismic event.
allowing the vibretions to loosen the fi ttings and develop a leak.t d during pres burrs in instrumentation tubing would not be
" crud" and detec e an eventual flow restriction.i
?
and could lead to an accumulation of Tube leakage or flow restriction could cause errorst in question and the type of varying degrees depending on the insttvmensuch instrumentation e p robl em .
a d t
~ ' - - - - - - - _ _
"w% aan "Hi-Seal" nuts and f errules, TVA has determined throug -
tensile and vibration tests and analysis that fittings with this type discrepancy are functionally reliable and all existing installations are i
acceptable as-is, lq type problems in revision O of NCR 6278. TVA has
- To prevent recurrence of the ding.
revised construction Specification G-09, " Processd Specification f or W Heat Treatment, Operations," to detail the requirements for installation, remake anThese requirements 3 h inspection of compression fittings. (NU CON) Quality Control Procedure N E}
into the Division of Nuclear Constructions' M QCP 3.13-6, " Installation and Inspection of Tubing Instrument l Tube Fitting InstallerI.ines " as well9 as Quality Control Instruction (QCI) 3.13, "Mechanica trained Perf ormance Certification," to which applicable EUd CON craf t have 9 b and certified.
personnel will be controlled by MAI-29 " Instrument Tube Fitting an Installation" which is scheduled to be issued by August 15,1r.86. 1 i
- r To prevent a recurrence of the type problem identified by revision ify1use of th s $
N NCE TVA has revised its applicable drawings through ECN 6313 to spec it is to be of tube end reducers rude by the same manuf acturer as the fitting
.~J mated with.
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_'M em o r a n OSP TO F..
- . Abercrombie, Si:e Director, Secuoyah Nuclear Plan:
l TROM -W. R. 3 osn, Jr., Program Manager, E=ployee Concerns ~ask Croup, Wa :s Ea Nuclear Plan: ONP DA.. -
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SUBJECT:
SEQUOYAF. NUC'IAE 802C.-SQN, Pl./Ji!-EMPl.0YEI AND 80203-SQN-QUA1.!!Y ASSURANCE CONCERNS TASR GROUP CA EGORY-CORRECTIVE 80101-SQN, ACTION P' /J:S -
A:: ached are cepics of ISCP Corree:ive Action Tracking Documents (CACD)
Nos.
80101-SQN-31, 80201-SQN-01, 80201-SQN-02, 80201-SQN-03, 80203-SQN-01, and 80203-SQN-C2 along with the Corrective Ac: ion Plan responses concerning :he subject elemen: reports.
he Quali:y Assurance Catego y Group Head into heirconcurs appropriatewith yourelemen: co::ective action plans and has incorperated :he:
repert.
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c: (A::ach=ent): f K2.MS, MR AN 72A-C E. C. Denny, DSC-?, Secuoyah ON?
A. Ta-ser, QA O&?S-3, Secuoyah M. U. Rudclphi, ICTO 31dg. , *Jat s Iz ON? i i- J. I. Karr,103 ::siler sic, Jat:s la ONP \
R. K. Maxen. 103 ::sile #7, .ar:s 3ar \ '
- 7. C. Price, 5-2;2 53-K l
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W. R. Brown, Program Manager, Employee Concerns Tast Group, ONP, Watts Bar Nuclear Plant' FR031 H. L. Abercrombie, Site Director, ONP, O&PS-4 Sequoyah Nuclear Plant DATr . October 20, 1986 stBJECT: SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 802.01 SQN R1 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated September 12, 1986, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report 80201-SQN - Inspection Criteria (Sequoyah)" (I25 860916 991)
I acknowledge receipt of your element report and in accordance with your request (see reference), Element Report 802.01 SQN R1 has been reviewed for applicable corrective action.
By this memorandum I am endorsing the site line organization CAPS and
, attaching these CAPS for your review and concurrence in response to your "i-Q CATD 80201-SQN-1 and CAID 80201-SQN-2. These CAPS are not restart J requirements.
If you agree with the proposed CAPS, ple.ase sign the ECTG concurrence space 4 below item 9 on the CAP tracking checklists and return the CAP tracking cheeklists. .
i
! ul M/'//M 9
H. L. Abercrombie .g RCD:JDS:JB:CS Attachments P. E C E P/ E D l cc (Attachments):
RIMS, MR 4N 721-C [G 22 $3 A. G. Debbage, ONP, ECTG Building, VBN EmNeyw .~.e .:!"ns Tesk 0181T . _A
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ECSP CORRECTIVE
Action Trackinc Document
, (CATD) 1.
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(' INITIATION
. ,7, *
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1.
IbediateCorrectiveActionRequired:' l -
/Y/ Yes /-/ No
- 2. , Stop Work Recom:nended: /~/ Yes /X/- No
- 3. CATD No. 80201-SON-1 4. INITIATION DATE 9/12/86 S. PISPONSIBLE ORGANIZATION: Office of Nuclear Power
- 6. , PROBLEM DESCRIPTION: /X/ QR /;/ HQR
~ ' Vendor velds, identified in.this Element Report (Concern JAN 001 an:i JLH-85-005 ) were made by National Valve and Manufacturine Comnanv (NAVCO) and Sentrv Eouiement Corocration (SECO) were sub-
, standard and recuired rework. Corrective Actions for these welds did no: include a sample insnection of other velds produced by NAVC0 or SECO.
- , / /ATTACllMENTS
- 7. PPIPAPID BY: NAME R. D. Halverson EE DATE: 9//r:/RT,
- 8. CONCURPINCE: CEG-H WW //'lA - /- DATE: 9-/ Z 4(.,
- 9. APPROV/J : ECTG PROGRAM MGR: ' DATE:
. CORPICTIVE ACTION i
- 10. PROPOSED CORPICTIVE ACTION PLAN: Te /STW_4bM t i r,) '
9 ,
'/M ATTACHMENTS
- 11. PROPOSED BY: DIRECTOR /MOR:
12.
-.l.1/thn/~7/h ff/4'//'r D/.TE : A'///7/4 CONCURP2NCE: CEG-H d6k.e/& DATE: 2 M SRP: 6' /
DATE:
ECTG PROGRAM MGR: DATE:
VERIPICATION AND CLOSEOUT
- 13. Approved corrective actions have been verified as satisfactorily implemented. .
.. SIGNATURE TITLE :: ATE
w-
- f. .- ,
Page 1 of 2
' *"'9 l
Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Number ///,4/ f430'E/!/
Lead Organization Responsible for Corrective fetion Plan CORRECTIVE ACTION PLAN (CAP) *
- 1. Does this report require corrective action? Yes No x (If yes, describe corrective action to be taken, if no, provide justification)
Scc- .M1ACH M EA W ' T
- 2. Identify any Similar item / instances and corrective action taken.
M E4C 7At/s /'cA% xM.:m N &sw su* 4.L'M ~7Erz deci o
- 3. Will corrective action preclude recurrence of findings? Yes >( No
- 4. Does this report contain findings that are conditions adverse to cuality (CAQ) as defined by AI-12 or NEP 9.1? . ,.- Yes No >-
,.f 5. If a CAQ condition exists, what CAQ document was initiated? "/#
- 6. Which site section/ organization is responsible for corrective action?
c.o w n,G Ama (k~rrwis er t.urnt) cwm>c dy firr .12c7mJ-
- 7. Is corrective action required for restart! Yes No -K (This determination is to be made using the " Criteria for Determination of Restart Items" in accordance with the Nuclear Performance Plan, Volume 2.)
- 8. P2 zone number for restart corrective action? Zone -
- 9. Estimate completion date for corrective action.
Completed By Approved By
/'/ MeI ate /#-/-f'4 h) />h, Date in-2 5M ECTG Concurrence G S M /4---- Date 2.-/W i1 SRP Concurrence '
Date CAP CLOSURE
- 10. Was your corrective action initiated and completed in accordance with step 1? Yes No
- 11. If step 10 is no, describe the corrective action taken.
- 12. Is the corrective action implementation complete? Yes No
- 13. Is the corrective action documentation closed? Yes No
- 14.
- What documents were used to implement the corrective action?
Completed By: Date Verified By: Date ECTG Closure: Date Continued on back page e
- ' A'ttcchm:nt T s .,
I
Reference:
ECTG Report CAT D 80201-SQN-1 (T25 80916 991)
In reference to the ECTG report effort, it should be noted that both concerns investigated (JAN-8-001 and JLH-85-005) were:
i
- 1. Specific to a referenced location job or 2.
Investigated reported his by the site concern. manager for whom the concerned individual 3.
The response. concerned individual in both cases was satisfied with the Additional comments are provided for each concern.
Cencern JAN-85-001 Contrary to the investigator's report, SECO does not reference Sentry Equipment Corporation but references work performed by Southwestern Engiaeering Company (SECO).
SECO has performed work at Sequoyah.only once, with that occurring between September 1985 and November 1985. The concern was received Novemb'er 26, 1985. Sequoyah Modifications requested that Sequoyah QA perform a survey on the referenced work.
This was accomplished by QA and documented on an in-plant-survey
,. J checklist (21-85-5-021). Additionally, a SECO QA representative returned to Sequoyah to participate in the evaluation. Deficient
.?'h '
welding was corrected by IVA and a warranty claim was submitted for
- processing.
It is therefore concluded that the inspection / review effort did include the majority of welding performed by SECO with repairs being completed '
accordingly; thus, no additonal surveys are warranted. s c\
Concern JLH-85-005 i
(
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The review of this concern included a discussion with an individual , t (L. G. Herbert) who was the cognizant construction inspector during the time that NAVC0 piping was received onsite at Sequoyah. He stated that $' y.[ '
a similar concern was expressed in 1976 to the visual adequacy of NAVC0 welds. I This potential worse-case basis. concern was satisfied by reviewing radiography film of the '
The effort concluded that although the t welds were not ground flush or at least smooth, as was the TVA practice, 4 ,
the welds were satisfactory (passed X-ray criteria). Reference memorandum from L. G. Herbert to J. L. Hamilton,_ dated May 29, 1986.
.' f \
u _ _ _ _ _
Sequoyah has recently completed a study on welding which was performed '
by contractors, TVA weld project personnel, ANIS, QA organi::ations, and others.
TVA and contract suppliers.This effort included a review of field welds performed both The conclusion reached by these parties was that Sequoyah welding practices..were acceptable. Reference Welding Task Force Report L44 860207 800 and later revisions., .
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- . Many of the NAVC0 welds have been inspected as part of the in-service-inspection program required by Section XI of the ASME Code. Others will
') be inspected as the program (SI-ll4) continues through the plant life.
These inspections have yielded no evidence of an abnormal rejection rate
! in NAVCD welding.
Based upon these efforts, it is concluded that no justification exists for additional surveys, t
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- 10-1-86 0212M e
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UNITED states covEnNMENT ISmOTdndMM TENNESSEE VALLEY AUTHORITY y
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John L. Hamilton, Jr. , Supervisor, Quality Engineering / Quality Control, -
ONP, Sequoyah Nuclear Plant FROM 4 Leo G. Hebert, Quality Assurance Evaluator, DNQA, WBN, ONP, DATE : May 29, 1986
SUBJECT:
WELD RADkOGRAPH REVIEW ,
1
. b This memorandum is in response to our conversation on April 17 and P.ay 23, ,
1986 regarding a review of weld radiographs at NAVC0 Corporation, Pittsburgh, Pennsylvania.
In early 1976, March / April, verbal concerns were expressed by the craf t welders at Sequoyah Nuclear Plant in regards to the poor visual appearance of NAVC0 spool piece welds; yet the Construction Quality Control inspectors
.were rejecting welds that appeared. to have a higher standard of quality.
Arrangements were made with Mr. Robert Jackson, of NAVC0 for me to review radiographs at th,eir facility. A walk-through, utili:ing construction management, was made; welds were selected on a worse-case basis; and -
photographs were taken to allow 1AVCO personnel to understand our concern.
v I made a trip to Pittsburgh, Pennsylvania and reviewed the radiographs of the selected welds; even though the welds did have a poor visual appearance, all radiographs reviewed did meet the appropriate quality standards. For
' record purposes,. it should be noted that at the time of this action, I was a certified Level III in RT, PT, MI and UT in accordance with SNT-TC-1A. t t
I am certain that correspondence was written concerning this situation and the visit to NAVCO, but due to organizational changes and the time frame ,
[
involved, I do not know if it could be retrieved.
l If I can be of further assistance, please do not hesitate to call me at '
Knoxville extension 6863 or Watts Bar extension 3516.
i P
SQN SITE / g i QUAUTY MANAGE.TS OFFICE ,f/]/, %/,, _f Leo G. Hebert L
LCH:FC J'JN 0 2'86 :
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Action Tracking Document i (CATD) s f l INITIATION _ .
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Ic: mediate Corrective Action Required: /Y/- Yes
- 1. / / No
- 2. Stop Work Recocenended: // Yes /I/ No
- 4. - INITIATION DATE 9/12 /86
- 3. CATD No. 80201-SON-2
- 5. PISPONSI3LE ORGANIZATION: Office of Nuclear Power
- 6. PROBLEM DESCRIPTION: /I/ QR /;/ NQR Concern XX-85-050-001 (Findines Section) indentities the lack of soecific trainine renuirements in the followinc documents:
OC-4 Rerision 2. "Ouality Control Instrumentation" -- No modules for trainine.
AI-14 Eevision 30. " Plant Traininc Procram".. ~ Courses listed do not include tube fittines.
MI's' S P.1- 1 -6 8- 20 . Revision 1. and IMI-118. Revision 5. -- Do not so ec ifiv oersonnel trainine reoutrements.
NUC PR Cualitv Insnector Trainine Manual -- No instructions in inspection of installation of comoression tvee fittines.
- , / / ATTACHMENTS
~~'
- 7. PPI?APID BY: NAME R. D. Halverson & DATE: 9//1/JW DATE: %/ 2- P(o
- 8. CONCUPJ'INCE: CEG-P. '/ -('Z //V/
DATE:
1 .. 9. APPROVAL: ECTG PROGRAM MGR:
CORRECTIVE ACTION .
I
- 10. PROPOSED CORPICTIVE ACTION Pl.AN: .SEF A-inoL=e i
, . . ., , /X/ ATTACH $1ENTS
- 11. PROPOSED BY: DIRECTOR / MGR: /htaN//4'F/n# D ATE:/s~////K
- 12. CONCUEFISCE: CEG-11 //f L # 1 6 DATE: 2-/7-T)
S RP.: # / DATE:
ECTG PROG E$i MGR: DATE:
l VERITICATION AND C1.CSEOUT
- 13. Approved coriective actions have'been verified as sat.zia:torily
] implemented.
l TITLC LAIE SIGNATUFI.
fa L
6,... Pego 1 of 2 i l'
\ Corrective Action Plan of Employee Concern Investigation Tracking Checklist I # l ECTG Report /CATD Number (A19[#/. // ft%/ - O C o N JT .
l Lead Organization Responsible for Corrective Action Plan .
CORRECTIVE ACTION PLAN (CAP) Yes V No
- 1. Does this report require corrective action?
(If yes, describe corrective action to be taken, if no, provide justification)
/serioJ -.; AT-M-2.. Identify any Similar item / instances and corrective action taken.
Mg e.www co.wemas sa .r:.um 'n"sreM,-.
/s-m ninsm Mc, 14wh,w cJwhJ w c'ms /
o No
- 3. Will corrective action preclude recurrence of findings? Yes AC
- 4. Does this report contain findings that are conditions adverse to No k-cuality (CAQ) as defined by AI-12 or NEP 9.1? ..,.- Ies
.," 5. If a CAQ condition exists, what CAQ cheument was initiated? 4/,4-
- 6. Which site section/ organization is responsible for corrective action?
.Te e7p c-./~ & AEwpe.J cd sff'W 55;7 ~7P-rMc
/
No Jc Is corrective action required for restart? Yes 7.
(This determination is to be made using the " Criteria for Determination of :
Restart Items" in accordance with the Nuclear Performance Plan, Volume 2.) '
- 8. P2 :ene number for restart corrective action? Zone
///A7 Estimate completion date ,for corrective action. ///A 9.
e' aw- Date /e-/-S4 Completed By -/ d Date /d -# - N, Approved By X k1//dm 2-d-T7 Date ECTG Concurrence "// f W //f L Date SRP Concurrence v '
CAP CLOSURE
- 10. Was your corrective action initiated and completed in accordance with No
- Yes step 1?
- 11. If step 10 is no, describe the corrective action taken.
Yes No
- 12. Is the corrective action implementation complete? _
No Yes
- 13. Is the corrective action documentation closed?
14 Vhat documents were used to implement the corrective action?
Completed By: Date Verified By: Date ECTG Closure: Date b
U .
Continued on back page
.-*Referenca: CATO 80201-3QM-2 '
I All' instrumentation attached to the RC3 is restricted by special 3/8-inch transition couplings, thus restricting the amount of leakage to that which the charging system is capable of normally making up. All instrumentation attached to other systems important to safe operation of the plant are provided in redundancy (Trains A and B). Based upon these facts. I conclude that a break in the line or a defective tube-fitting would not create an unsafe nuclear operating condition.
Sequoyah safety procedure (AI-3) requires personnel working on systems or system components to obtain appropriate hold orders on clearances.
In addition, a recent study completed by Singleton Laboratory (F01 851211 601) in response to employee concerns at Watts Bar Nuclear Plaat concluded that improperly installed fittings would not be a problem if they did not leak and that leaking fittings would be repaired before an unsafe condition would exist.
It is therefore concluded that if existing procedures are followed, the potential for personnel injury is minimum.
Appendix B of 10CFR50 requires procedures.and inspection programs be established and executed for work on safety-related equipment. The level of detail is not stated. Sequoyah performs all C33C work in accordance with written procedures (specifically work requests and Ff5 workplans) which appear to meet criterian V requirements. The level of detail is determined by the complexity of the task which may generate
~
specific instructions such as MI's, SMI's, etc. Additionally, all of the work documents are reviewed by QA for adequacy and adherance to
~
applicable requirements including the establishment of QC hold points which seems to meet Criterian X requirements.
" It should be noted that neither Criterian V or X specifically states the j
- 1evel of detail of instructions or that specific QC hold points be
' established. These determinations are the responsibility of the utility in accordance with applicable codes, etc. I therefore conclude that Sequoyah is in compliance with these requirements. -
In response to the specific problems addressed by the investigators, the following comments are provided:
- 1. QC 4 is an instruction utilized by the Construction organization during the construction phase of the plant. It has not been used a:
Sequoyah for several years and never by Nuclear Operations.
Therefore, no corrective action is required.
s I. AI-14 does not list all courses required or taught at Sequoyah. Tho original intent of this instruction was to address minimum training requirements for employees at Sequoyah. Additional requirements were implemented through the initiative of plant supervisors in response to conditions adverse to quality, and other directives such as the referenced memorandum from W. T. Cottle. These requirements were initiated administratively by momorandum as was the case in the
. .. W. T. Cottle memorandum. AI-14 is currently being revised with
- ( additional reference to tube-fitting class MTU-MMT-28 referenced.
The estimated completion date is December 3, 1986, per discussion
) with Doug Bateson, Sequoyah Training Officer.
i t
! 3. Personnel training requirements are not placed in procedures on a l general basis. Reference to AI-14 or section requirements are i sufficient to address this. Therefore, no revisions are necessary, n
[. 4 The QA supervisor (John L. Hamilton) for engineers and inspectors I responsible for review of work documents and inspection activities I has directed his representatives to insure that requirements are l placed in maintenance requests and workplans to use only qualified, trained, maintenance personnel for tube-fitting installation and that inspectors assigned to the related inspection activities are trained in tube-fitting practices. Approximately ten QC inspectors have attended MTU-MMT-28 to date. The mechanical inspector training class will be revised to include tube-fitting inspection criteria
'and additional inspectors certified as they return to the Power Operations Training Center for recertification.
DA:GDL 10-1-86 021cM
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[ ) Page 42 of 62
(/ Rev. 50 Appendix H PLANT INSTRUCTION REVISION REQUEST ROtTIING
- 1. 44t&Sf-- / /
, Originator's Supv./Date Approved Responsible Supervisor /Date Approved
- 2. Administrative Services - Date Received .
Approved I.
N" Adm Svs, WPU Supv J, . -
- 3. SI Scheduler (sis Only)- Date Reviewed Approved g Plant Instruction Revision Request (To be fill d out by originator of
. revision request and routed to appropriate section supervisor.)
. Ta'* .
Originntor A YomW/t Date N ~{~S(*
Instruction No. MZ /
1 Tit 1e /YM/*WS Y&7~s--~~
v Page Numbers Affected 7 , 28
- i
,, MATS # CATS # CAR # .
i 7..
THIS REVISION IMPLEMENTS SCURCE DOCLHENT:
. .. (NQAM, Area Program, etc.)
Summary description of Revision (If possible, marked up pages on latast J revision should be attacJ hd ). 44 RC#e 27J"4Nc:f [e h rJ--
t~ En Tc/ne~ hvr?ad Mm-ns Y m o r.r *A "
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s re Mk%) WMac M/ddhem Aw CM*/Mcz2 I
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t Reason for Revision: d~d/~~ 8 M /d D/ -MA) E w erd. XX - ?.i"-0 O - 6 c) /
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SQNP
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AI-14
~
Page 28 of 50 .
Revision 33
. . _ j II. TRAINING OUTLINES (continued) !
.- F. SPECIALIZED TRAINING (continued) l Those portions dealing with the SQN response are discussed
~
in greater detail. Addionally, the plant's Implementing ,
Procedures are addressed and summarized during the training.
Sufficient training must be given to those individuals who are designated in the Implementing Procedures as being re-sponsible for performing various functions during an emer-gency.
f '
- d. ,
designated alternate shall be responsible for administering
. this training.
. 'e. ' DOCUMENTATION- A training roster will be completed and provided to the SQN Training Office for all persons successfully complet-
, .s..,. s ing REP training.
. f. RETRAINING- Annually 3 TRAIN Code - REP t
- 6. HEALTH PHYSICS SCIENTIFIC AIDE AND TECHNICIAN OUALITYING PROGRAM.
e ,
- s. PURPOSE- The objective of these HP training programs is to
. ; ensure a fully qualified HP staff is maintained to assist in the safe operation of TVA's Nuclear Plants. In achieving this objective, TVA complies with NRC regulations.
. c. REFERENCE- PMP 0202.12
- d. RESPONSIDILITY- The HP section supervisor for coordinating the training required for the HP staff and ensuring staff (
members maintain appropriate qualifications.
- e. DOCUMENTATION- The associated training documentation will be maintained at the POTC as described in the HP administrative .
section instruction letter (HP ASIL) -3. !
- f. This training program is completely described in HP ASIL -3.
- f. Caerrm , Lsrnw dunm, cr c-M gw kwe ,wwM re n.w men?
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- SQNP AI-14 I Page 3 of 50 Revision 33 D. RESPONSIBILITIES (continued) 4 (continued)
- f (e) Ensuring that all temporary and service personnel
,. $ under their cognizance are trained to the extent necessary to asure safe execution of their duties f( (for unescorted access, see Appendix B).
r f (f) Reviewing the Plant Training Office computer status j' Y program printout of plant personnel issued to the -
- It section and report to the Training Offjcj yngrgors
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(_'& %,gd n ,,<< wo o c . ,4 a. vncam san # 7wma .
1 L ,; 7. The Nuclear Training Branch is responsible for the development and update of the courses in the GET program through the utili-
- =ation of information provided by the plants, the DNQA Quality y Systems Branch, and other ONP personnel. This responsibility includes ensuring that the course material is in compliance with the various regulatory guidelines which are applicable.
I '
I 8. When revisions occur to courses under the responsibility of 7 the Plant Training Office, Attachment 4 shall be completed.
g Any revisions shall be reviewed by the plant Training Officer and the responsible site supervisor for completeness, accuracy, and applicability to Sequoyah Nuclear Plant. When a review discloses discrepancies between the course and Sequoyah plant procedures, the Plant Training Office will initiate .a formal
.. revision request form. ,
- 9. The supervisors of the sections below listed shall be respon-sible for providing plant specific information for GET training y packets and instructors for the other designated courses. They shall also notify the Training Officer when revisions to docu-ments or plant procedures covered in this training indicate the
, possible need for revision of GET courses and/or retraining of plant personnel in a particular subject. For all other courses, designated supervisors shall be responsible for the development and maintenance of complete training packets. Each training packet will have as a minimum a training outline, audiovisual aids where appropriate, and written examination covering the j g- material. Approval of the p chets shall be the collaterial re-sponsibility of the Training Officer and the supervisor of the i -
1
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c = co starts cm.cas.yEs' S08 870123 802
,dM,9 7d n d um TENNESSEE VALLEY AUTHORITY
}
W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP.
Watts Bar N" clear Plant vnn.y H. L. Abercrorabie, Site Director ONP, O&PS-4 Sequoyah Nuclear Plant DATE . January 24, 1987
SUBJECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 802.01 SQN R3 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated January 15, 1987, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report f0201-SQN - Inspection Criteria (Sequoyah)"
(T25 860115 915)
I acknowledge receipt of your element report and in accordance with your request (see reference), Element Report 802.01 SQN R3, Corrective Action Tracking Document (CATD) No. 80201-SQN-03 has been reviewed for applicable corrective action.
By way of this memorandum I am endorsing the site line organization CAP,
- t. returning your CATD No. 80201-SQN-03, and attaching the CAP for your
. :s
) review / concurrence. This CAP is not a restart requirement.
If you agree with the proposed CAP, please sign the ECTG concurrenec space below item 9 on the CAP tracking checklist and rett: ; the CAP tracking checkli s t. ,
N
/ k f H. L. Abercrombie RCD:JDS:JB:CS P.COEIVED Attachments I R4 72A-C (S02 870121 952) M b b7 0571T E:nmm 0.ms *aw Gr.*uc WP'!
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'l A'TACHMENT. F 1
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- ECSP CORRECTIVE Action Tracking Document
- I
- 2.
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!.-. (CATD)
'f '
jt ,-- , jp INITIATION .
- 4 ~): .',, ; 1. Immediate Corrective Action Required: /X/ Yes // No
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-Stop Work Recommended: // Yes /I/ No CATD No. 80201-SON-03 4
- i . ;
- 5. INITIATION DATE 1/8/87 E .
RESPONSIBLE ORGANIZATION: Office of Nuclear Power
- ?.. ?. I 6.
. PROBLEM DESCRIPTION: /X/ QR /~/NQR C 'l - r)
[: , 's
- t ,1, As identified in this Element Resort. Attachment C (L44 860730
- t 816). TVA committed
- o the NRC that " work on cocoression fittings
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- i. ,
- which would be done bv ooerations eersonnel will be controlled bv MAI-29. ' Instrument Tube Fitting and Installation' which is
\
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5 h scheduled to be issued bv August 15. 1986." To date. no evidence a
exists that this procedure has been issued.
i ', I: *
A / // ATTACHMENTS 2 7.' PREPARED BY: NAME R. D. Halverson N:b C.
DATE: 1/8/87
.i k 8.hCONCURRENCE:I CEG-E #A C/ d E //V/ v '
. DATE: 1/8/87
}- ,
9.' I'. APPROVAL: ECTG PROGR;_4 MGR: (/) & i e ta v u 4.DATE: ///4/F7 1 .s .-
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CORRECTIVE ACTION ,I .' 'J; ,
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.10. l PROPOSED CORRECTIVE ACTION PLAN:
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- 66 4' 4., DATE: / ,2N">
l 12.'; PROPOSED BY:, , DIRECTOR /MGR:b/ 4---- --
CONCURRENCEi..;CEG-H M DATE: 849-77
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DATE:
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[' VERIFICATION AND CLOSEOUT '$>
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Approved implemented. '
corrective actions have been verified as satisfactorily r, ' .
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SIGNATURE.
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,. . Standard Practice Page 8 SQA166 Revision 8 Attachment A Page 1 of 2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Numbee 488,C//T Lead Organization Responsible for Corrective Action Plan Initiation Date CCRRECTIVE ACTICN PLAN (CAP)
- 1. Does this report require corrective action? Yes / No (If yes,.
<&-~ describe 6C Wcorrective action
/ ~71, W to be taken, if no, provide justification) s-WHer) fM cm.-ux77va' kW '
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- 2. Identify any similar item / instances and corrective action taken.
ac ^ /?J. W
- 3. Will corrective action preclude recurrence of findings? Yes # No
- 4. Does this report contain as defined by AI-12 or NEP 9.17 findings that are conditions adverse to cualitv (CAQ)
- 5. IF a CAQ condition exists, what CAO document was initiated?
^
YES No D gjk _
._6..Which site section/organi:atic s responsible for corrective action?
- 7. Is corrective action required for restart? Yes No V (This determination is to be made using Attachment C of SQA166.) i
- 8. P2 zone number for restart corrective action? Zone /# '
- 9. Estimate completion date for correction action.
Completed By Approved By
/If M '
Date /- Z/~8 7 ~
'W4, / /) h Date /- 7. /- 5~' ?
ECTG Concurrence Mh/Cs V Date ___ 2-8 "7--t"~7
- 4
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Standard Practice Page 9 SQA166 Revision 8 ATTACF2CT A Page 2 of 2
~
CAP CLCSURE
- 10. Was your corra:tive action initiated and completed in accordance with step Yes No
- 11. If step 10 is no, describe the corrective action taken.
- 12. Is the correc:ive action implementation complete? Yes No 13, Is the correc:ive action documentation closed? Yes No
- 14. What documents were used to implement the correctivt action?
Completed By:
Verified By: Date ECTG Closure:
Date Date (Step No.)
Description j'% '
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- ,,...no.. - .c STATES COVERp!ENT h6 S02 861203 994 1
nOhdndum TENNESSEE VALLEY AUTHORITY
- R. C. Der.ney, Employee Concerns Special Project Manager, ONP, DSC-P, Sequoyah Nuclear Plant
INITIATION R3ference: Memorandum from V. R. Brown to H. L. Abercrombie dated November 12, 1986, "Sequoyah Nuclear Plant (SQN) - Employee
- Concerns Task Group (ECTG) Element Report C017304-SQN -
Construction Category - Corrective Action Plan (CAP)
Rejection I,ransmittal" ,(T25 861112 993) l In accordance with the revised ECTG element report, I provide the ?fI[N0~#
cdditional response:
- 1. A memorandum (S02 861202 827) was transmitted to DNE requesting *their evaluation of NCR/SCR 6278. 's' "'t*-
- 2. A procedure will be written defining requirements for installation of .
!.+.
tube fittings at Sequoyah. .
- 3. Retraining requirements will'be established on a frequency of one '
year for Modifications personnel and two years for Maintenance
- personnel. .
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LDA:GDL cc: RIMS, MR 4N 72A-C This was prepared principally by L. D. Alexander.
COORDINATION: Rick Collins, DNE; B. M. Patterson, ' Maintenance 0293M f
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Buv U.S. Savines Bonds Recularly on the Payroll Savines Plan l
L Standard Practice Page 8 SQA166 Revision.8 I'-m . .-
,i -
Attachment A *
/
Page 1 of 2 .
Corrective Action Plan of Employee Concern Investigation Tracking Checklist EC G Report /CATD Number / ~) 3 , C 4 S PA) [C 7/ -
Lead Organization Responsible for Corrective Act on Plan Co A> s"T Initiation Date //-/ 3 .f6 CCRFICTIVE ACTIC:I PLAN (CAP)
- 1. Does this report require corrective action? Yes *>< No (If yes, describe corrective action to be taken,'If no, provide justification)
- 112= ne,-o S02 8Y/205 W .
- s. bs4 A e-A om- st</ - <
2- scV] A /*)?sts- Ato o+ sos I
- 2. ~
Identify any similar item / instances and corrective action taken. '-- ---- -~
' d~fi'C - SD2<df fo g f( Av2 94G *
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- 3. Will corrective action preclude recurrence of findings? Yes X. No
- 4. Does this report contain findings that are conditions adverse to cuality (CAQ) as defined by AI-12 or NEP 9.17 .YES No k
, 6. Which site section/organicacica is responsible for corrective action?
ba A %tmem. s - -
- 7. Is corrective actica required for restart? Yes No X (This determination is to be made using Attach =ent C of SQA166.)
- 8. P2 cene nu..ber for restart corrective action? Zone
~
- 9. Esti= ate completion date for correction action. 5-9-97 .
Completed By .
/// / b d - Date /'2 - P / 4 Approved By 2it./ gf # Date / 2_- M(
ECTG Cencurrence #hMA Date 2-(-7-7 ~7
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Page 9 SQA166 a Revision 8 '
- AT AC*-CCC A Page 2 of 2 l
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CAP CLCSURE ,
~
- 10. Was your cor:ective action initiated and completed in accordance wi:h step l?
Yes !!o
- 11. If step 10 is no, describe the corrective action taken.
- 12. Is the corrective action implementatica ecmplete?- Yes' llo 13..Is the corrective action documentation closed?
Yes . IIo
- 14. What documents were used to implement 'the corrective action =
Completed By: '"
Date i Verified By:, ,
Date EC G Closure: Date t
i (Sten llo.)
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' .Memorand um TENNESSEE VALLEY AUTHORITY -
VOI : D. V. V11 son, Project Engineer, Sequoyah Engineering Project, DNE, DSC-E, Sequoyah Nuclear Plant FROM : R. W. Olson, Modifications Manager, DNC, SB-2 Sequoyah Nuclear Plant DATE : DEC 0 21986
SUBJECT:
WAITS BAP NUCLEAR PLANT - OC NCR 6278 RO, R1 (SCR 6278 - SRO) AND ECTG REPORT 173.04 SQN R2 (TUBE FIITINGS)
References:
'l. Memorandum from J. A. Raulston to Those listed.
dated February 25, 1986, " Potential Generic Condition Evaluation" (B45 860225 259) t
.2. Memorandum from V. C. Drotleff to K. V. Whitt dated April 7, 1986, "NSRS Report No. I-85-329-SQN, Finding I-85-329-SQN-01, Evaluate Compression Fitting
~
. Inadequacies of NCR WBN-6278 for Generic Applicability' - %I-85-050-001" (B05 860404 002) .
s
-"- Although there seems to be some confusion and procedural variances in the
. , . . . processing of the subject NCR/SCR, a DNE evaluation is required to
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satisfactorily resolve this. employee concern. This item has been discussed among Larry Alexander of the Modifications Group and Rick.
Collins and Adrian Smith of DNE, Sequoyah.
!I request that you perform the requested evaluation and coordinate any corrective action with Larry Alexander (6862). The Modifications Group -
. willsupportlyouasrequired.
Your prompt attention will be appreciated.
l h/ /2/u~
R. W. Olson .
fLDA:GDL cc: RIMS, MR 4N 72A-C This was prepared principally by Larry D. Alexanded. . , . ,n.
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r CORFICTIVE ACTION RESPONSE EVAI.tATION REPORT NO: T-d'd'dd 7-8 9 SuSJECT: 0A C UTROL5 oe COM ? 0Esitou FITTINGS IrJSTAl L ATioN CONCERN NO: YY-lS"$fCE'ON)
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BRE3ECT DNE qa l805 969+04 CD & % L 3 M-SGW-01
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'r ,,a e ,' ,s UN n'c0 . 1 3o Memorandum unst m muum _ momn y
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J. M. Sullivan, Supervisor. Esgulatory Engineering, ONP. 55-2. Sequoyah Nuclear Plant. i /
FROM :
- 1. W. Olson/ Modificat.ioni Manager, ONP. SB-2. Sequoyah Nuclear Plant DATc : MAY 2 01986 st'nJ Ecy: WATTS BAR NUCLEAR Pl. ANT - NCR 6278 R1 - COMPRESSION FITTINGS FOR TUBING COMMECTIONS AND TUBE-END REDUCERS l
Reference:
Transmittal from Regulatory Engineering Section to me dated Apell 21, 1986 (attached) ,
The generic issues have been previously included as part of the employee concern program with physical testing being performed at Singleton Materials Engineering 1,abnentories. This study addressed the issues listed as Deficiency I including the development of a new General Construction Specification (G-29 Ps 3M13.1 Addenda). ,
i Deficiency II addresses a mismatch of valve fittings and tube fittings. It m should be noted that the bill of materials states ". . .or, equal." DME Engineer. 'im Staub, has ueen reque. d by Operations to buy only Der.gon i t
- valves with Parker fittings in the tut .' e . The general rule of thumb by the fleid was to install matching fitti i 1 by using the "or equal" statement.
9 Since Sequoyah has been through cola hydros, hot functional testing. ;
y preoperational testing, and years of service, it is concluded that incerrect installations have been identified and corrected. Additionally, all current Sequoyah employees working with tube fittings have been trained by MMT-28.
This training was presented by the Power Operations Training Center in O which emphasis was placed on not mismatching fittings.
~
It is therefore concluded that no addition. 1 corrective action is required by the Office of Nuclear Power.
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LDA:ATR Attachment cc: RIM,S, MR 4N 72A-C ( Attachment)g This was prepared principally by 1.. D. Alexan ed.
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L*N.ITED STATES COVERN. MENT Memorandum TENNESSEE val. LEY AUTHORITY B05 '86 0 4 0 4 002' T"
- K. W. Whitt, Director of Nuclear Safety Review Staff, E3 A8 C-t
(/
W"" W. C. Drotleff, Director of Nuclear Engineering, V12 A12 C-K ,
DATE : April 7, 1986 860411TO169 StwncT: NSRS REPORT NO. I-85-329-SQN, FINDING I-85-329-SQN-01, " EVALUATE COMPRESSION FITTING INADEQUACIES OF NCR WBN-6278 FOR GENERIC APPLICABILITY" l
Reference:
Your memorandum to H. L. Abercrombie and R. W. Cantrell dated ;
February 13,1986 ( c, :; ec)
\
In the reference memorandum under Section IV, " Conclusions and Reconsnendations," you addr esed f ouc recomundations. They were I-85-329-SQN-01 Evaluate Compression Fitting Inadequacies of NCR VBN-6278 for generic applicability; I-85-329-SQN-02, Noninspection Personnel Training; I-85-329-SQN-03, Inspection Personnel Training, and I-85-329-SQN-04, Quality Control Inspection. The only recommendation which involves the Division of Nucloar Engineering is I-85-329-SQN-01. DNE has reviewed this recommendation h-r. the following comment: ,
When NCR WBN-6278 RO was issued by the Office of Construction, they (OC) .
were not yet following ebe intent of naragraph 4.5.1.2 of OEP-17. Since then, the Office of Construction started following paragraph 4.5.1.2 of OEP-17, and NCR WBN-6278 R1 along with SCR 6278-S R0 (identical to NCR 2 WBN-6278 R1) was issued. The SCR form goes into more detail, particularily in the generic cor.dition area than the NCR
- fora which was used for NCR VBN-6278 RO. ..
i The " generic block" on NCR WBN-6278 R0 had been markod "yes" and was justified by saying "this condition is applicable to all compression fitting installations within.the scope of the WB QA program."
f sd DNE did not review NCR WBN-6278 RO for generic applicability because OC had already indicated it was. However, since NCR WLN-6778 R1 and SCR w
} 6278-S R0 have been issued. DNE has issued a generic memorandum dated February 25, 1986 (B45 860225 259).
f ,
OEP-17 was revised on March 28, 1986, to require assessment of the generic \ t 3 implications of NCRs/SCRs/ CARS initiated by Construction or Operations / and /'.
referred to DME for disposition. # .fg.1 4 tI Originni " "' 'D / C "- Morris G. lierr. don O ',/
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JFV:WDD:MBP ' ' {\ cc:, RIMS, SL26 C-K . J. A. Raulston, V10 C126 C-K J. C. Standifer, P-10a SB-K ' J. F. Weinhold, W12 B34 C-K n h w ROC 0f0 M L W. D. DeFord. W12 B32 C-K R. G. Ilome r . Ul 2 AS E-K OE01 - 1685E
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EXPERIENCE REVIEW APRJ.1'86
- EVALUATION FORM TO: [O $ th , bdS RETURN TO REGUI.ATORY ---
ENGINEERING SECTION
/ !'! ~:b' UPON COMPLETION '. .a . , ,
a.7 i FROM: Supervisor, Regulatc ry Engineering Section ,. n - ( DATE: / h -.
SUBJECT:
OPERATING EXPERIENCE REVIEW
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Item No. @ h 8 // Priority: Significant
' Normal'
References:
Please review and evaluate the attached Operating Experience Review information. [@ . , Check the appropriate disposition statement listed below supplying the necess m' Can and return this transmittal form to Regulatory Engineering with : M01_.d>yd of the transmittal date for normal experience items or twenty (20) dar > for significant experience items. This information has also been forwarded to
" . o: w r groups listed above. Coordinate your response with them as applicable, T'.. r coordinc*.e any necessary due date extensions with RES prior to the response .
E, becc.ning overdue. ; b, ' Disposition Statements N
, 1. I have reviewed the subject information and no action is necessary because:
( ) a. This item is already covered by instruction U () b. This information is not applicable to SNP because of a difference in design. Explain: 1 D
- ( ) c. Other (Explain) l O
- 2. I have reviewed the subject information and the following action is required.
A due date of should be placed in the OER database ,. / ' for completion of this action. [/ -w
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l ' SQA26 ' Attachment 3 ' Rev. 7 e
- 3. This OER item is 10CTR50.49 related: Yes No (If yes, the IQ Coordinator will initial showing that this response has been coordinated ~.
' with him). s I Reviewer Data
$ Section Supervisor Date .
Disposition statessent reviewed and concurred with: = a t Regulatory Engineering Date INTO ONLY TO: M 4 b . b cA. k f J
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NOTE: i A copy'oflall completed Attachment 3 forms which are 20CDt50.49 related j shall be sent to the Site EQ Coordinator.
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TENNESSEE VAU,EY AUTHORTrY A 005 B25 '86 0328 70 : E. B. Rank nager, Design Services, ONP, DSC-E, Sequoyah Wuclear Plant J FROM : J. P. Tisbeyard, Project Manager, Sequoyah Engineering Prc, ject, CE, DSC-A, 8eguayah Nuclear Plant DATE a MAR 281986 st'nJ ECT: SEQUCTAE NUCLEAR PLANT - POTENTIAL CENERIC CONDITION ETALUATION Please review Vatts Bar nonconformance report (NCR) OC NCR6278R1 and i determina applicability to Sequoyah per the attached memorandum from 1 John A. Raulston to Those listed dated February 25,1986 (B45 860225 259). n
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1 U J. P. Vineyars I (M.f.i E . - BB:JCW *It Attachment
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. RinS, SL 26 C-K John A. Raulston, W10 C126 C-K
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morgo . s Memo , .._ .. ~ .. m 845 '86 u e e p a9 > TO : Those listed IROM 3 John A. aulston, Chie f Nuclear Engineer, W10 C126 C-K DATE : FEB 251986 suaJECT: POTENTIAL CENERIC CONDITION EVALUATION The attached document, OC NCR 6278R1, describes a condition adverse to quality which was identified at Watts Bar Nuclear Plant. Please examine the attached to determine if this co'ndition' exists in your are's of responsibility. The bottom portion of this form should be completed and this memorandum returned to me within two weeks of the above date. Should this condition be found to exist in your area of. responsibility, the generation of a problem identification report or a significant condition report per CEP-17 is required within two weeks of the above date.- Original 01.t.ed DF sage John F. Cox, i- , John A. Raulston
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,. N. R. Beseley, A10-BFN ,
._ , , _ g_, ,, e R. R. Hoesly, 9-113 SB-K _ g- . .
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. {J. P. Vineyard,- -AS Sequoyah, OE,
_ . . . . . . . . . . . . DSC-A 7 y LCK:AH , g ,, f .
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Attachment ccr RIMS, SL 26 C-K Joyce Lane, BF IN 773-C . N#c _L _ . ' . E. C. Beasley, W12 334 C-K , I
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~f-l We have examined our activities in the area of concern and i found that the conditions ,
- s. Does not exist / /
- b. Does exist / / PIR/SCR No.
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Review performed by Date .. xc: R.IMS , SL 26 C-K E. C. Beasley, W12 334 C-K Joyce Lane, BR IN 773-C , E26053.35 Buy U.S. Savings Bonds Regularly on ths Payroll Savings Plan , . _,.
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{,TO TENNESSEE VAEEY !.lTTHORTT B45 Those listed '860225 259 ; TROM John A. Rauls ton, Chief Nuclesr Engineer, W10 C126 C-K t "" * . FEB 251986 sunJECT: POTENTIAL CENERIC C3fDITION EVALUATION ,
- The attached document, which was identified at Watts Bar Nuclear Plant.OC NCR 6278R1,y descr determine if this condition exists in your area of rePlease examine the attach portion of this form should be con
- pleted and this sponsibility.
memorandu The bottom vittin two weeks of the above date. m returned to me ( your area of responsistlity, the generation of a problem a sIgnificant n ide tifiShould cation report 01 in t above dates condition Original report per OEP-17 is required within two weeks of th Gl.z.ed Dr e John F. Cox. sagP John A. Rauls ton - N. R. Beasley, AIO-BFN /. p.ajf*g t ( - R. R. Hoes 17 , 9-113 SB-K
. P. Vineyard, AB Sequoysh, -0E, DSC-A g_,, ,,
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At tachme nt cc: ', g,,
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,f Joyce Lane, BF IN 77B-C E. C. 3easley, W12 334 C-K '
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TO : AdcessionNo. A L) *
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R.Nuclear W. Olson, Modifications Plant Manager, DNC, SB-2 '
. Sequoyah .c.u FROM: -
D.Project, W. Wilson, Project Engineer, Sequoyah Engineerin g
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DATE: December 4, DNE, 1986 DSC-E, Sequoyah Nuclear Plant 4 se _.'
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. i'3 We foundhave that theexamined condition:our activities in the area ancernof and
Reference:
S0. 660520 941
. a.
Does not exist /X/ B05 860404 002 i SO2 861202 827 b. Does exist // PIR/SCR No. Review performed by __ <C Date ll- /-86 e xc: h)) ' RM. SL 26 C-K E. C. Beas ley, W12 B34 C-K Joyce Lane, BR IN 775-C
) E26053.35
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'UNTTY.D STATES COVERNMENT Mem67andum rzetssrs vittzr turnoairr
!. O B26 '86 0 20 6~t)17 I
- J. C. Standifer, Project Manager, Watta Bar Engineering Project, P-104 SB-E (3)
FROM : euenter Wadewitz, Project Manager, Watta Bar Nuclear Plant OC DATr. : February 5, 1986 - si:rur:cT: WATTS BAR NUCLEAR PLANT - ASME SICMIFICANT NONCONFORMANCE REPORT 6278 R1 s Attached for your review and approval of disposition is NCR 6278 R1 which we consider to be significant. Please approve and return with attached forn(s) for our documen ion purposes. JA . f Cuenter Wadewit/ [ JES :CHR y. gy - s l TR5;QASMES.CR '-- l , . t .} chment i LAttachment): g ;. .nC l RIMS, MR!iN72 A-C l , R. W. Dibeler, 11-142 SB-K J g--j y aa . T. W. Hayes, NLU-WBN OC __!._tcs~~ . . ,, a-t - R. C. McKay, PMO-WBN OC - i- 9 _',i_ ' *
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J. W. Habee, 366 sPB-K '-c >
.y B. F. Painter, CSO-WBN OC 3 c. , . , y-C. E. Roberts, W11C114 C-K J. W. Self, N-S Croup-WBN OC QF ' ,e =
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T~'M.,-- I B. J. Thomas, QMO-WBN OC , d s47_- D. W. Wilson, DSM, WBN-NUC PR --.'- ! F - +TG e QA-Sitei WBN OC NRC Resident Inspector, WBN-NUC PR ZhT E'"
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02/06/86 - JCS:MCH DATE REC' @ JAR cc (Attach ==nt): O RIMS, SL 26 C-K ACTION REQ' - JFC J. G. Lane, BR IN 77B-C DATE DUE
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4 OF FICE OF CONSTRUCTDON NONCONFomastNG CONO T10M RtPORT
- 18. NCR No.:_ 6278
_ Re,. 1 1A. o w __2 v.etaned or Newt headwaenwe: IC. .
- Instrumentation Tubing Connection Integrity {
- 10. PtAMT Va trP U 2 I' 10 UNIT: I-es.,, g g <:
b I 17. 3YETEM- Vm + ne ASME Code Seetions NC 36;sI. & .1 5 10. Ashst CDOE: EY Om 1H. CONTRACT k.: sui
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- 11. IM4T1ATING UNIT _
MSB-B - Deficiency : 11 VgNDOR [ Compressio fittings for tubing connections have NAME N/f/ _\ been disco ed with installations which do not ADORE 33 #^^ ^ agree with the manufacturer's installation instructions. These discrepancies ara as N W'N. l follows:
- a. Tube cuts not deburred
- l d) $ } )
' b. Tube oat ';ottooed out in fitting (See attached courinuation page ~
. Acew.ni Came: res- ?
>- '.ncy 1 - There are no requirements to verify. the
- integrity o
- ing joints which were not subjected to hy,drostatic or pneumat '
testing. Responsible Organ 4 ration- TEU /OE
,O D.e. /- E -84^_ - M ' A Dem _!'id-
- 2. Ininstor ' '
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to.cn niod ==s Desas s.6o i Deficien::y I - VEN OC and NUC PR shall establish measures for documented train-ing of their respective cra.f t personnel involved with compression fitting ins tallation. Inspect drain connections to the closed drain system which do l
- not require hydrostatic testing and are subjected to potentially radioactive j service. These inspections shall be in .tecordance with the anufacturer's
- /-M14 Aaproved Oste !-T- O n . .,
n O oin.,cs Conie ar) 4 ($ As Detaned inb 3 Cents.t b oral
% Ret. met to Deep Pro,ect ' seien (DPol: J. L. De ris Aserosas Dass /- PM Respenste. har _ /*
Mr A O ov., ts in as
- 5. O A. o.i.ii.d in sect n 3 Det.
OPO S. Acoro ed Corwcwn Mer=wed and Accoowd SY: Authorved t.ucsew inspector Dats
- 7. Appro=ed Corweisen C.wsdeted, aws larm Rew.# From Noncentormeng 5:asus Acerowd Gy Date Dee.
Rewic-- P h .duar K ,,, O No ::,, sCR N C 7P .f di p o.,,/ fV! (. ,,n.c,,,CAo c.-w.-d esiv R= M { . d SA -- TTA B thr=* tist; .a.et 3 l l
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Page L of 1 LOP i.op scaccatomaans Asa stamcAs; 6278 m w e, e P *.i CDesmos aptaT CORTusuAT10e PAst y g g asammcs ,
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s lA Description continued: -
- c. Mut not completely covering threads
- d. Missing ferrule
- e. Reversed ferrule
- f. Daidentifiable ferrule DeficimeyyII: ,
Engineering drawings 47W600 serie,s and 47BM600 series specify the use of either an Imperial-Eastman (I-E) 783-FSS or a s Parker Hannafin CPI TRBZ-SS 1/2 to 1/4 inch tube and reducer (Mk 28A), but should specify only the use of.I-E reducer. The reducer connects to a Dragon panel isolation valve (Mki) with an I-E fitting. The Parker tube end reducer is a hard material which is machined for a Parker ferrule and is not
- designed to be used with the I-E ferrule. Because of the -
hardness and the machined groove, the I-E ferrule does not seat properly on the tube end reducer and presents a blowout " hazard. Apparenti Cause continued: Deficit.cy II: Error in the 47BM600 drawings allowing the use of inconpatible fittings. . 3 Correc, tion Method' continued: Deficiency I: , instructions to verify proper tube deburring, tightening require =ents, and ferrule type and orientation. . All sys'tems subjected to hydrostatic testing or pneumatic testing have been . verified with leak tight joints which indicat e adequate joint makeup for pressure retention. However, OE shall provide vibrational analysis for connections - in which the tube is not bottomed out in the fitting, nuts not properly tightened, ferrules reversed, and deburring was not ' performed to determine the acceptability of such installations although leak tightness is achieved. i rvasw,s w 3. ,3
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Attac hent B Page 1 of 1 LOP W m nenouns meetaeresmuss Ass sesERCART teegmes aErtKT CummeATIce Past Mh 6278 Hetts Rar llue Plant
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3 Correction Method contintaed: Deficiency I: l OE to evaluate compression fitting installation to determine ! the need for possibla TVA process specification revisions. Deficiency II: . Correct drawings to specify the use of only Imperial-Eastman 78FTSS tube end reducer. Inspect panels and replace Parkar ' reducers with Imperial Eastman reducers. s..
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5 i:ime sum === 802*861202 897~ Y TENNESSEE VALLEY AUTHORITY Memorandum 3 '70 : D. W. Wilsea Project Engineer, sequoyah Engineering Project DNI, DSC-I, Sequoyah Nuclear Plant R. W. Olson, Rodifications Manager, DNC, 88-2, sequoyah Nuclear Plant f F30N : Det DEC 0 21986 SU5J8CT: WATTS BAR NUCLEAR FIEfT - OC NCE 6278 10. El (8CE 6278 - 8R0) AND I REPORT 173.04 SQN R2 (TUBE FITTINGS) References 1. Nemorandum from J. A. Raulston to These listed dated February 25, 1986, " Potential Generis Condition Evaluation" (845 860225 259) ;
- 2. Hannorandum from W. C. Drotlett to R. W. Whitt dated < =
Apell 7,1**6, "NSrt Report No. I-85-329-8QN, Findias I-85-329-SQN-01, ' Evaluate Compression Fittin8 - ~
- Inadequacies of NCE WBN-6278 for Generic Applicability' - II-85-050-001" (805 840404 002) i.
Although there seems to be some confusion and procedural variances in the processing of the subject NCE/SCE, a DNE evaluation is required This ites has beento l- satisfactorily resolve this employee concern. discussed among i,arry Alexander of the Modifications Group and Rick
- Collins and Adrian Salth of DNE, Sequoyah.
I request that you perform the requested evaluation Theand coordinateGroup Modifications any corrective action with Larry Alexander (6862). __
' will support you as required. -
Your prompt attention will be appreciated. bb R. W. Olson ,
/
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cc: _EIMS. MR_4N 721-C , ;:, r.,_l y (f; This was prepared principally by Larry D. Alexander. , e Y p 0292M
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ATTACHMENT G , ek '
%, UNITED STATES '
. / NUCLEAR REGULATORY COMMISSION W ASHING TON, D. C. 20555 g.I - )Itr ,1 November 14, 19J6
.)[, .
- Docket Nos.: 50-327 - -
and 50-328 Tennessee Valley Authority ATTN: Mr. C. C. Mason Acting Manager of Nuclear Power 6N 38A Lookout Place - 1101 Market Place Chattanooga, Tennessee 37402-2801 Gentlemen: ' This refers to the inspection performed by Messrs. E. T. Baker, J. C. Harper, and J. J. Petrosino of the Vendor Program Branch and Mr. S. R. Stein of the Reactor Construction Programs Branch on September 15-19 and September 26 thru October 3, 1986, at the Sequoyah Nuclear Plant, Units 1 and 2. The inspection related to activities authorized by NRC License Nos. DPR-77 and DPR-79.- Our findings were discussed with Mr. H. L. Abercrombie and others of your staff at the conclusion of the inspection and were the subject of the October 21, 1986 letter from J. M. Taylor to S. A. White. The purpose of this inspection was to review Tennessee Valley Authority's (TVA) corrective action to Nuclear Safety Review Staff (NSRS) Reports R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS. The inspection included a review of contracts for original and replacement equipment, maintenance requests, quality assurance program requirements, site procurement procedures and practices, and associated documentation. The findings in the areas of procurement of safety-related equip-ment, record storage and retrieval, and receipt inspection indicate a failure to take adeouate corrective action to these previously identified concerns. In particular, your program has allowed previously qualified equipment (seismic and environmental) to be degraded by purchasing replacement components and parts as commercial grade, without documentation of its qualification, and without adequate dedication of the items by TVA. In addition, retrieval of quality assurance records for installed equipment was extremely difficult and in some instances, where the equipment did not have a unique plant identification number, the c records could not be retrieved. .Further, in some cases receipt inspectors have not been provided with adequate instructions to enable them to perform meaningful inspections. These deficiencies have been classified as a single Potential Enforcement Finding (50-327, 328/86-61-01) concerning failure to take adequate corrective action. I I i
~ ~ ~ - - ..
November 14, 1936 Tennessee Valley Authority The Potential Enforcement Finding Youriscorrective being referred to the NRC Region II offi action for Sequoyah for their review and appropriate action.and assessment of the applicab , , , TVA facilities should not await further NRC action. . Should you have any questions on this matter, we would be, pleased to discuss them with you. Sincerely, , Brian K. Grimes, Director
. Division of Quality Assurance, Vendor
, and Technical Training Center Programs Office of Inspection and Enforcement
Enclosure:
- 1. Potential Enforcement Finding 50-327, 328/86-61-01 *
, 2. Inspection Report No. 50-327, 328/86-61 cc w/ enclosures:
H. L. Abercrombie, Sequoyah Nuclear Plant Site Director Post Office Box 2000 Soddy-Daisy, Tennessee 37379 P. R, Wallace, Plant Manager Post Office Box 2000 37339 Soddy-Daisy, Tennessee J. A. Kirkebo, Director Nuclear Engineering Tennessee Valley Authority 400 West Summit Hill Drive, W12 A12 Knoxville, Tennessee 37902 R. L. Gridley, Director Huclear Safety and Licensing Tennessee Valley Authority SN 157B Lookout Place Chattanooga, Tennessee 37402-2801 M. R. Harding, Site Licensing Manager i
~~iennessee Valley Authority SN 157B Lookout Place N Chattanooga, Tennessee 37402-2801
POTENTIAL ENFORCEMENT FINDING Docket Nos.: 50-327/328 Tennessee Valley Authority License Nos.: OPR-77/79 1101 Market Place 37402-2801 Chattanooga,. Tennessee . . . 50-327, 328/86-61-01_ Potential Enforcement Findino As a result of the inspection conducted) on Septem Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix the following Potential Enforcement finding was identified. 10 CFR Appendix..B. Criterion XVI, states, in part, d"noncon- Measures lfunc- sha lished to assure that conditions adverse to quality, tsuch as failures, ma tions, deficiencies, deviations, defective material and equipmen , an forr.1ances are promptly identified and corrected." f Contrary to the above, TVA has failed to correct deficiencies f quality assur-in the ar procurement of safety-related equipment, storage and i h were retrieyal o d ance records, and receipt inspection of safety-rela R-85-07-NPS. I
Report No.: 50-327/86-61 and 50-328/86-61 Tennessee Valley Authority Licensee: 6N 38A Lookout Place 1101 Market Street 37402-2801 Chattanooga, TN License Nos.: DP.R.-77 and DPR-79 50-327 and 50-328 Docket Nos. Sequoyah Nuclear Station Units 1 and 2 Facility Name: September 15-19 and September 29 bctober 3,1986 Inspection Conducted: V 5^ d Date Inspectors: E. Baker, Tea % der -
\ ^
/ ff N Lu/ A ' d .l Specialist Mte
,.U. 9. /etrosino, Quality Assurance
' h 8 $
Date 9 . R. Stein, Electrical Engineer
/
?'
d /.
/k YlJ. C. Harper, Metallurgical Engineer
,.Ygt ,- Date nrj Date Approved by: .
,~ Reactive Inspection E. W. Merstnoff, C ogram Branch l Section, Vendor
SUMMARY
s t the l This was an announced reactive inspection which was co f TVA's corrective Scope: Sequoyah Nuclear Station to determine the Staff Reports o i effectiveness rement and action for problems identified in Nuclear Safety Rev ew R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS concerning ts of the pas record storage practices.for replacement of safety-related electr residual heat removal, control air, and emergency powerTVA's ipment review of systems; a sample of procurement actions ident selected during a plant walk-through; , Stores receiving inspection practices. One Potential Enforcement Finding was identified. t ' Results: L
- _ _ - _~
. ~ .-.-.-. . .- . - . -
4 REPORT DETAILS
,1. Persons Contacted:
Licensee Employees . . .
*H. L. Abercrombie, Site Director
*W. E. Andrews, Site Quality Manager
*J. Blankenship, Information Office Manager
- 1. D. Brewer. Control Shift Operator R. Bruce, Program and Standards Section Supervisor
*R.
H. Buchholz, Office of Nuclear Projects (0NP). Site Representative
*S. K. Chapman, Electrical Maintenance General Foreman M. Crane, Site Services Procurement Supervisor
*D. C.. Craven, Quality Assurance Manager
*M.
R.' Harding, Site Licensing ManagerR. Jenkins, Division of N
*Z. M. Kabiri, Site Services Manager
*J. W. Kelly, EA Engineer G. Kirk TVA Compliance Engineering Supervisor
. T. Kontovich, Electrical Maintenance
*J. E. Law, Chief Quality Systems Branch
*A. S Lehr, Instrument Maintenance Group Engineer.
*M. R. Matthews, Restart Task Force
*B. Patterson, Maintenance Superintendent G. W. Petty Materials Officer H. L. Pope, QC Supervisor
*M. A. Purcell, Licensing Engineer
-*B. Schofield, Licensing Engineer
*J. R. Staley, Power Stores Supervisor C. Stutz, QA Engineer
*P. R. Wallace, Plant Manager
*J. R. Watson, QA Engineer
*W. J. Wilburn, Site Maintenance E
*L. R. J. Wheeler, Wherter, Materials Materials and Manager Procurement *C. Services 5taf. Chief The inspectors also contacted or interviewed other licensei s from the operations, training, maintenance, and technical staff.
i Other Organizations R. V. Matheison, Westinghouse Site Representative NRC
*P. E. Harmon, Pesident Inspector
*K. M. Jenison, Senior Resident Inspector
*D. P. Loveless, Resident Inspector
*E. W. Merschoff, Chief, Reactive Inspection Section ,
- attended exit meeting t
- e
.n,,..~-,,,,-- - . . . . - - , _ . _ , - _ _ , . _ . ~ . - - . , ,_ _ - - - _ . - - . . . . - - - , - - - _ _ - . . - , . _ - -- ,--
- 2. Exit Interview The inspection scope and findings were summarized and discussed with those individuals identified in paragraph 1, above. The team members described the areas inspected and discussed the inspection findines listed below. The licensee did not identify as proprietary any of the materials inspection.provided to or reviewed by the inspectors during this
- 3. Licensee Action on previous Enforcement Matters This subject was not addressed in this inspection.
- 4. Unresolved Issues No unresolved issues were identified during the inspection.
- 5. Background TVA's Nuclhar Safety Review Staff (NSRS) performed in-depth audits of TVA's procurement system and records retention system. The results of these audits are documented in reports I-83-13-NPS dated June 17, 1983, R-84-17-NPS dated March 8, 1985 and R-85-07-NPS dated July 5, 1985. These reports high-lighted programatic problems found. deficiencies without providing specific examples of the One of the more significant findings related to the use of components purchased " commercial grade" and used in safety-related systems without any additional determination by TVA of the components' qualifications for use in safety-related applications. Another significant finding dealt with a timely themanner.
difficulty or inability to retrieve quality assurance records in TVA took corrective action in response to these findings to improve their procurenent and record storage programs to prevent similar problems from recurring. However, these corrective acticns did not appear to installed of address the effect past procurement practices may have had on the quality equipment. 1 This inspection was conducted to determine how procurement practices for i original and replacement components and parts affected the original quali- , fication or design requirements of safety-related equipment installed in the plant or if record storage practices prevent determining whether or not the qualification of equipment has been adversely affected. The inspection utilized three separate methods for selecting equipment for detailed review: a. A sample of electrical, mechanical, and instrumentation components was selected during a plant walk-through for a review of the related procurement documents. Equipment was selected based on problems identified during previous inspections of licensees and vendors. Problems this sample.noted in paragraph 6.b.7 were identified for an item from 3 I
- b. A computer listing of maintenance requests (MRs) initiated during the time peried 1980 to 1984 was obtained for selected systems and MRs were selected from these lists for follow-up based on whether or not a safety-related coriponent was replaced. Problems noted in
. paragraphs 6.b.1, 6.b.6, 6.b.9, 7.a. and 7.b were identified for items drawn ,from this sample.
- c. TVA began an effort in July 1986 to evaluate th.e , seismic qualifica-tions for a sample of Class 1E devices that had been f.eplaced. From a total of approximately 125,000 MRs, they identified 238 MRs under which Class IE devices had been replaced. At the time of this inspec-tion TVA was in the process of determining the ' status of seismic qualification for a sample of 50 MRs which represented Class IE replacement devices supplied directly from stock. This inspection reviewed several MRs from the 238 that were not part of TVA's sample of 50. Problems noted in paragraphs 6.b.2, 6.b.3, 6.b.4, and 6.b.5 were -identified for items drawn from this sample.
- 6. Review of Procurement
- a. Program Review The team review ad Part III, Section 2.1, " Procurement," of the Operating Quality Assurance Manual; SQA-45, " Quality control of i Materials, Parts, and Services," Sequoyah's site specific require-ments for procurement; and Sequoyah's Administrative Instruction AI-11, " Receipt Inspect. ion, Handling, and Storage of QA Materials, Substitutions and QA Level / Descriptions Changes."
' A review of the definitions section of SQA-45 shows that TVA accu-rately reflected the NRC's intent for the terms " basic component,"
" Class IE," and " commercial grade item," terms commonly used when discussing procurement. Three other definitions of interest to the team were, " Level I Quality Assurance Material," and " Level II Quality Assurance Material," commonly referred to as QA Level I and QA Level II, and " Critical Structures, Systems, and Components (CSSC)." A significant part of the problems discovered during this inspection stem from the definitions given for QA Level I and QA Level II and their use. TVA's definitions for these terms are as follows:
Level I Quality Assurance Material--(1) Those CSSC materials, components, and spare parts which are a part of and whose failure would violate the reactor coolant pressure boundary; (2) those other CSSC items that cannot be bought by industrial standards and reference part number; (3) certain items that must be specifically bought as Level I as required by Attachment 21 (reference DP N76A10) of this standard practice, and (4) electrical equipment defined as Class 1E. l 4
y , I Level II Quality Assurance--CSSC materials, components, and spare parts that can be purchased by positive identifica-tion, provided that these items are not GA Level I. QA Level II permits in-kind replacement of items when the specified industry. code or standard provides positive identification. Positive identification is established for an item by usina one of the following methods: '
- a. Documentation supplied with the origina1 eqqipment and/or from nameplate / tag information attached to the equipment.
b. The item's description as specified by the engineering drawing bill of material, provided no special process is performed due to drawing notes, etc. *
- c. The item's description as specified in the procurement
. technical specification.
,d .
The item's noun name and part number when supplied by the original supplier, manufacturer, ~or vendor. { These definitions are atypical of what is normal . industry practice in that they describe what equipment falls into each category rather i than describing the quality assurance requirements applicable to each
- category. Appendices to Attachment 20, " Specification of QA Program Requirements for Nuclear Power Requisitions," of SOA-45 contain the actual quality assuranc~e requirements. These appendices are written for particular categories of equipment, e.g., Appendix 1, "ASME Section III Materials;" Appendix 2, "ASME Section III Valves;"
Appendix 5, " Class 1E Materials and Equipment;" Appendix 8, "Non-ASME Code Items Which Have Unique Nuclear Requirements." A note which is pertinent to the findings of this inspection appears under the title of Appendix 8 as listed on page 250 of the 7/12/82 version of SQA-45. The note reads as follows:
... Used for procurement of QA Levels I and II [10 CFR 21 Applicable] basic components which have unique nuclear requirements, including Seismic Category I Application and equipment used in Class 1E application [ device as a
' whole which requires qualification by supplier or manufacturer) which are not ASME Section III Code." A cursory reading of this note by someone not familiar with TVA's interpretation of the phrases "10 CFR 21 Applicable," " Seismic Category I Application," and " Class 1E application," would lead one to believe that electrical and non-ASME mechanical equipment that was reouired to operate during and after a seismic event would be subject to the requirements of Appendix 8. However, as the next two paragraphs show, this is not the case. 5 L
When TVA procedures discuss requirements for Seismic Category I aprlication and Class IE application, they are not necessarily referring to the specific pieces of equipment which must function during or af ter a seismic event. The statement, " device as a whole which requires qualification by the supplier or manufacturer," appears in the note quoted above. As explained by TVA personnel during the inspection and as can be seen from the examples cited in paragraph 6.b. below, TVA personnel interpreted this to mean that seismic and IE qualification was only applicable 'to t5e assembly qualified and supplied by the manufacturer. Therefore, if a "whole device" (e.g., motor control center, diesel generator set) was replaced, seismic qualification of the replacement was required. However, if a subcompenent of the whole device was replaced (e.g., relay, circuit breaker, air starter motor) seismic qualification was not required for the replacement, regardless of whether or not the replacement had to function during or af ter a seismic event. The reason given for this practice was that TVA was ordering replacements by part number and was receiving an "in-kind" or "like-for-like" part. This practice was not adequate to assure a qualified part, however, because the procurements were made 0A Level II, no documentation required, which amounted to commercial grade and provided no assurance that the replacements were in fact "like-for-like." The procurement of safety-related equipment requiring seismic and ' environmental qualification as QA Level II occurred because of two problems. The second statement in.the definition QA Level I and the definition of QA Level II allow items which can be identified by a unique manufacturer's part number and are produced to industry standards to be procured as OA Level II regardless of the safety. function of the item or the industry standard invoked. The other problem is that rather than basing quality reouirements solely on the. importance of the item being procured, TVA based quality requirements on whether or not 10 CFR 21 was judged applicable to _ the item. This problem was compounded by the fact that the form for determining Part 21 applicability, Attachment 11 to SQA-45, was biased towards not imposing Part 21 on anything less than a whole device. Therefore, a piece of equipment which was originally supplied by the manufacturer as seismically qualified could be replaced by a commercial grade item without appropriate engineering analysis because TVA's procedures allowed the equipment to be classified as QA Level II, Part 21 Not Applicable. Paragraph 10.3 of ANSI N45.2.13 states that equipment may be accepted by source verification, receiving inspection, supplier certificate of conformance, post installation testing, or a combination thereof. As the examples in paragraph 6.b. show, TVA chose to accept equipment based on receiving inspection and post installation testing. The receiving inspection performed by TVA during the time period 1980-1984 consisted only of a check for shipping damage and cleanliness, and a comparison of the part number on the item to the ordered part number. Functional testing is performed after installation and assures that the piece of equipment will function during normal operation. However, receipt inspection and functional testing in-situ cannot 6
z ,
, ..r l
validate the ability of a piece of equipment to function during or af ter a seismic event or exposure to a harsh environment. The other methods of acceptance available to TVA were source verification ar.d supplier certificate of conformance. The " source verifict. tion required" block and the " documentation required" block were marked N/A for all QA Level II procurements reviewed, although some manu-facturers submitted certificates of conformance (C of Cs) anyway. However, in order to take credit for C of Cs, paragraph 10.2 of ANSI N45.2.13 requires that the purchaser have a means 'of v'erifying the
',' 5 validity of the C of C.
The means pennitted by paragraph 10.2 are audits of the supplier or independent inspections or tests.- While TVA performed independent inspections and tests,.these tests could not be used to validate a C of C for seismic or environmental quali-fication since they only involved functional testing during normal = operating conditions. TVA also performed audits of the suppliers of most of the equipment for which documentation packages were reviewed. However, a review of those audits indicates that the programs reviewed were the nuclear quality assurance programs and not the comercial grade programs. Based on previous NRC vendor inspection experience, if the nuclear quality assurance. program is not invoked in the i procurement document, the items being procured are us'uall ~ manufactured under the nuclear quality assurance program.y Therefore, not i 4 a C of C received based on a contract which invoked the comercial grade quality program can only be considered valid.if the commercial grade program has been audited and'found acceptable.
- b. Procurement Implementation The following describes the results of the review of MRs, procurement documents, receipt inspection records, and other associated document-ation for selected equipment. ,
1) Steam Generator Level Solenoid Valve (2-LSV-003-174): MR A-593379 was issued on 12/2/85 to replace the coils in this ASCO solenoid valve (model 206-381-2RVU) which provides a control function for the Main Steam Isolation Valves. The valve being worked on, S/N 49243J-90, was an environmentally and seismically qualified valve, purchased under contract 80KJ3-00827551, which had imposed 10 CFR Part 21 and an i Appendix B quality assurance program on the manufacturer.
~
The valve location is the West Valve Room, a harsh environ-ment. Because of this, the maintenance was being controlled under the Qualified Maintenance Data System (QMOS) and the MR was marked "QMD5" and "10 CFR 50.49 Device." As stated above, the original scope of work was to replace the coils in this valve. However, because the craftsman could not remove the coil subassembly with the tools supplied for the ,iob, the whole valve was replaced with another fully qualified valve, S/N 84146N-8. l 7 i t j
_ __ _ _ . ~ _ . .
.. l l
I If the craftsman had not encountered difficulty installing the replacement coils, the qualification of the original valve would have been indeterminate since the coils were procured as pieceparts, QA Level II, no documentation required, and no review of the effect of the commercial *
' grade- coils on the seismic and environmental qualification of the original valve was made.
- 2) Reactor Trip Bypass Breaker B (2-BKRC-099'-KH/311-G):
The undervoltage trip attachment (UVTA) 'on this Westinghouse DB-50 breaker was replaced under MR A-101112 on June 24, 1985. The UVTA withdrawn from stock was one of 22 UVTAs purchased under contract 84P64-343921 in November 1983. The contract identified the UVTAs as QA level II, and did not impose QA, 10CFR21, seismic or documentation requirements on the supplier. However,- the supplier (Westinghouse) modified the original bid
;and self-imposed QA and 10CFR21 requirements. The microfilmed scontract file at Sequoyah includes *a Certificate of Qualification
~ from Westinghouse for ten UVTAs, but only four of the ten listed correspond to the UVTAs delivered under contract 84P64-343921 and the UVTA installed on this breaker is not one of them. As there is no documentation to support qualification of the UVTA,,
the qualification of the breaker assembly is indeterminate.
, 3) d Normal Feed Breaker to Reactor Vent Board 28-8 (2-BDC-201-JQ-B):
The Reactor Vent Board 2B-B t u Jriginally purchased with the 480V motor control centers under contract 71C2-54752, dated May 5, 1971. The contract required a cuality assurance program and seismic testing and qualification for the safety-related motor control centers listed on the contract. The seismic test report, dated March 1972, also documented successful separate testing of internal components, including a circuit interrupter of the type specified for the motor control center feed breakers. On December 26, 1978, Purchase Requisition 272924 was issued to procure a replacement for the Reactor Vent Board 2B-B normal feed breaker and two additional overload trip units. The purchase requisition and contract classified the items as QA level II, did not impose QA requirements on the supplier, did not require any quality documentation from the supplier, and determined that 10CFR21 was not applicable to this procurement. The receiving inspection consisted of a comparison of nameplate data to the purchase documents. One of the two overload trip units was withdrawn from stock on September 8,1979, and installed on the normal feed breaker for the Reactor Vent Board 28-B under MR 00226. As there is no documented evidence of qualification for the trip unit, it renders the qualification of the feed breaker and the safety-i related motor control center it services indeterminate. l { 8 ,' i
- . . . - - , _ . ~ _ _ - . - - -- _ . . - - . _ - - - _ - - . . - .
- 4) Auxiliary Relay in 6.9kV Shutdown Logic Relay Cabinet 2A-A (2-PNLB-202-SC-A):
This safety-related logic cabinet was originally purchased in June 1972 under contract 72C02-83403, which required a full OA program and seismic qualification. Contract 78P15-24576, dated September 29, 1979, purchased as QA level II, 15 relays of various styles without imposing QA,10CFR21, . seismic, or quality documentation requirements on the supplier. - One of the replacement relays was withdrawn from stock and installed in the 6.9kV Shutdown Logic Relay Cabinet 2A-A under MR A-019533 on May 28, 1982. As there is no documented tvidence of qualification for the relay, it renders the cuali-fleation of the safety-related relay cabinet indeterminate. Duri.m research of the contract files for this panel, the origi-nal se:smic report and additional correspondence was found to 1ndicate problems with the seismic testing of two types of relays, in' cluding the type of relay replaced under MR A-019533. Although a letter from TVA indicates acceptance of additional seismic testing of the relays, the report documenting the additional testing could not be located in the document control system during the three week period over which the inspection was ' conducted but was later obtained from an engineer who had retained a personal copy. '
- 5) Boric Acid Transfer Pump Motor (2-MTRB-62-230-A):
The original pump ano motor assembly was supplied under the NSSS contract with Westinghouse. The applicable Westinghouse speci-fication (677123 Rev.0) imposed seismic requirements for the assembly and required the supplier to provide documented proof of compliance to those requirements. Westinghouse provided Quality Release 11358-1, dated January 9,1974, as documentation that the boric acid transfer pump and motor assembly met the requirements of Specification 677123, Rev.0. A replacement pump motor was purchased on January 13, 1982 under contract 82P64-323717. Although TVA classifies the motor as Class 1E, the contract identified the purcha'se as OA level II l and did not impose QA, seismic,10CFR21, or documentation requirements on the vendor. A motor different than ordered was supplied. A TVA substitution evaluation form (SQNP AI-11 Attachment 10, Appendix A Rev.10) was completed on August 9, 1982, but the engineering concurrence for Class 1E substitutions was marked as not applicable. On January 13, 1983, the replace-t ment motor was installed. As there is no documentation to l support qualification of the pump motor, the qualification of the pump motor assembly is indeterminate. 9 1
, . l
- 6) Diesel Generators: !
The diesel generators were procured under contract 71C61-92652 from Bruce-GM which required manufacturing under a 10 CFR 50, Appendix B cuality assurance program and seismic qualification of all equipment. Under RD-579489, dated 6/6/77, to contract 73Z23-65906, TVA procured replacement air starter motors from Ingersoll Rand as QA Level II, no documentation required. TVA has replaced these air starter motors numerous times either with motors procured from Ingersoll Rand or rebuilt by Sequoyah plant personnel. As there is no documentation to support qualification of the replacement or rebuilt air starter motors, the qualifi-cation of the air starter motors and the diesel generators in which they are installed is indeterminate.
- 7) Shutdown Board 2A-A Logic Relay Panel (2-BDA-202-CO-A):
Items selected by the inspection team during the plant walkdown
;.. included two Agastat time delay relays from this safety-related Class IE panel. These were Agastat model number 7012PD relays.
- serial numbers (S/Ns) 81031110 and 80362242, and are in the control logic circuits for the essential raw cooling water and the component cooling water systems. The markings on these two relays indicate that they were not manufactured as qualified i Class IE components since the model number is not proceeded by an "E." This was subsequently confirmed with the relay manu-facturer, Amerace Corp. When contacted after completion of the inspection, Amerace Corp. indicated that the relays, S/Ns 80362242 and 81031110, were manufactured commercial grade during the thirty-sixth week of 1980 and the third week of 1981, respectively.
Although requested during the first week of the inspection, TVA was unable to identify or produce the procurement documents for these relays. However, since these relays are not uniquely identified by TVA as Class 1E devices, the inspection team assumes that they were procured as piece parts, QA Level II, without the imposition of QA or documentation requirements on the supplier. As there is no documentation to support qualification of the relays and the vendor's records indicate that they were not supplied as qualified devices, the qualification of the relays and shutdown board in which they are installed is indeterminate. 8) Containment Isolation Valve (2-FCV-32-103): This air operated globe valve is required to close on a Class B isolation signal and is listed in Table 9.3.1-2 of the FSAR as a seismic category I valve. This valve was chosen during the walk-through by the team to trace the procurement chain from an installed condition back to the documentation, and was also included in the sample of items for which the maintenance history 10
was reviewed. The valve was ordered as an ASME Class 2 valve, seismically qualified, under contract 73C34-83577, dated 3/15/73, from Masoneilan International Inc. The serial number of the installed valve, N00137-21-4, traces back to a valve data package for valve PCV-32-103. However, a valve data ordering sheet could not be located for either PCV-32-103 or FCV-32-103 under contract 73C34-83577. A review of the maintenance history for 'this valke indicates that the valve failed its local _ leak rate test and was recaired under MR A-081518, dated 8/1/83. The MR indicates that tne soft rubber seat had been damaged in service and was replaced. The seat was procured QA Level II, no documentation required, under contract 79P14-278023 along with two other items. Because the seat was classified as QA Level II, the receipt inspection did not include characteristics such as material type, cure date, durometer standard, estimated. shelf life and storage conditions.
. all of which should be verified for this type of material.
- 9) Control Valve (2-FSV-32-1031):
This ASCO solenoid valve, model 206-380-2RVU, serves a control function for air operated containment isolation valve 2-FCV-32-103 and is listed in Table 9.3.1-2 of the FSAR as a seismic category I valve. This valve was chosen during the . walk-through by the team to try to trace from the installed condition back through the procurement chain to the documentation. The valve (serial number 68337K), was purchased under contract 82PKI-330545, dated 4/8/82, from Mills & Lupton Supply Co. as OA Level II, no docu-mentation required. Also purchased as QA Level II under this contract were replacement coils and repair kits for this model
,, valve. Although no documentation was requested and the receipt inspection report for the valve had the " Certifying Document No."
block marked "N/A," a Certificate of Compliance for the valve certifying its compliance to IEEE-323 and IEEE-344 was in the contract file. .
- c. Conclusions Drawn from Insoection Findinos 10 CFR .50, Appendix B, Criterion XVI requires that conditions adverse to quality be promptly identified and corrected. However, although NSRS Report R-84-17-NPS, dated March 12, 1985, pointed out that TVA was using commercial grade items as basic components without deter-mining the effect on the safety function of the component or system in which it was installed, TVA has not initiated an effort to identify
' equipment which may be in nonconformance with seismic or environmental qualification requirements as a result of this practice. Sequoyah personnel have started a review of Class IE replacement devices
' for seismic qualification. However, the effect of using commercial grade piece parts on seismically and environmentally qualified devices had not been considered at the time of the inspection.
11
g , The method used by TVA to identify their sample of 50 devices resulted in the majority of the sample being instrumentation items such as level, pressure, or temperature switches. TVA's selection process started with equipment identification numbers that were categorized as Class IE, 10 CFR 50.49, or had a safety train designation. However, TVA's program only identifies "those devices qualified as a whole" as Class 1E and does not consider components or parts within a device as being Class 1E or affecting the qualification of the device. As a result, many safety-related electrical items'sdch as circuit breakers,
~
relays, and solenoid coils are not classified as 1E and therefore were not included in TVA's original sample. - TVA management stated that they intended to look at the 238 MRs iden-tified as involving Class 1E device replacements rather than only the sample of 50 as originally intended. This would still not account for the piece part replacements for safety-related electrical or mechanical equipment which comprise the majority of the replacements performed. The concerns identified above constitute examples which support Poten'tial Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective Action to Previously Identified NSRS Procurement Findings.
- 7. Record Retrievability At the start of the inspection approximately 30 components were identified by the inspectors during a plant walk-through to determine if the installed hardware was traceable back,to the required procurement documents. This was in addition to the equipment documentation requested as a result of the review of MRs.
In addition to examples 7.a and 7.b below, which involve record retrieva-bility, paragraphs 6.b.2), 6.b.4), 6.b.7), and 6.b.8) above provide examples of record retrievability in addition to procurement problems. a) Residual Heat Removal Isolation Valve (2-FCV-74-1): MR A-10737, for the fabrication and installation of sixteen 1-3/4" x 8" bonnet studs, was issued 8/20/83. Although no procurement deficiencies were noted, a record retrieval or accuracy problem was identified. The MR required a visual examination of the studs. Inspection report R-0686, dated 8/20/83, referenced visual inspektion procedure N-VT-1, Revision 4. During the course of the inspection this revision of the procedure was requested, but TVA was unable to produce i t, b) Residual Heat Removal (RHR) Pump Motor (2-PMP-74-10): MR A-080564, dated 3/15/83, requested that the 2A-A RHR pump motor shaf t material be verified. The method chosen to identify the shaf t l- material was the application of a copper sulfate solution, which in l- combination with visual observation, can be used in making a quali-i tative decision as to whether the material is* carbon steel or stainless l steel. Sequoyah Nuclear Power personnel performed the test and deter-mined that the material was stainless steel. 12
When TVA couldthe inspector not producerequested it. As athe procedure for performing the test, minimum, there should have been written instructions concerning the strength of the copper sulfate solution, the length of time between application and evaluation, temperature cation, of the material and evaluation prior to application, method of appli-criteria. Several completed Power Stores material receipt inspection packages that were ready to be micro-fisched were reviewed
- The review revealed that some packages for safety-related components did not contain the required objective evidence of acceptability,1.e., manufacturer's Certificate sheets. of Conformances and the component functional test data Discussions with Division of Nuclear Engineering (DNE) personnel determined that separate organizational files of these documents were kept by DNE. Therefore, several areas would have to be researched before the required objective evidence of acceptability for an item was available. ,
As an' example, package #839407, for eight nuclear grade Agastat time delay.' relays (Models E7012/E7022) procured by DNE, contained a closed OC inspection report that accepted the relays based on a handwritten note from DNE stating that DNE intended to accept the manufacturer's C of Cs. The required manufacturer's functional test data sheets were not in this package, but TVA personnel stated that the test data sheets were in a DNE file. When asked how the equipment,was controlled or tracked until DNE approved the C of Cs, Sequoyah personnel stated that no additionel system existed.controls were placed on the equipment and no tracking If DNE eventually decided that the C of Cs were not acceptable, the equipment may have already been installed. Similar examples were found in package 838674 for four nuclear grade Foxboro differential pressure transmitters, and package 836394 for Atwood and Morrill ASME Section III diesel generator plug valves. The lack of objective evidence of acceptability in the closed procure-ment and receipt the following inspectica packages appears to have been caused by items. reports.) (:tems a) and b) were addressed in the NSRS a) Failure to establish a procedure, including acceptance criteria, for closed package review to ensure that the necessary documents are included in each package. b) Lack of adequate TVA organizational coordination, communication l
- and/or procedures to provide one central focal point for review and storage of quality related documents.
c) Failure to establish a tracking system to assure receipt inspec-tion packages eventually contain all necessary documentation or - a reference to where the documentation is located, d) Failure to adequately review and approve the completed QC inspection reports by the QC inspectors immediate management. I l 13 i i
./ ,
o g. 10 CFR 50, Appendix B,~ Criterion XVII requires that records be identi-fiable and retrievable. ANSI N45.2.9, paragraph 6.2, requires that records ~be retrievable without undue delay. However, records for installed equipment which do not have a unique plant identification number (i.e., piece parts) could not be identified or retrieved during the three week period between the time the inspection started and the exit interview. Additionally, certain records could not be located through the record retrieval system and were lo.cated only by contacting an engineer in the Division of Nuclear Engineerin'g whd had a personal copy. This problem was previously identified in NSRS Reports I-83-13-75 and R-85-07-NPS and provides an additional example of TVA's failure to take adequate corrective action to NSRS findings. The concerns identified above contributed to Potential Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective Action to Previously - Identified NSRS Procurement Findings.
- 8. Receiot Inspection Receipt inspection packages for both past and present procurements and the associated versions of Administrative Instruction AI-11, " Receipt Inspection, Handling, and Storage of QA Materials, Substitutions, and ,
OA Level / Description Changes," were reviewed. AI-11, Attachment 1,
" Materials Receipt Inspection Report," is a listing of types of inspec-tions such as shipping damage, markings, cleanliness, dimensional, electrical insulation, etc. , with three check-off columns, "Yes," "No,"
and "N/A." Paragraph 2.4 of AI-11 states that the inspector is respon-sible for determining which of the twenty inspection requirements apply. , Paragraph 2.4.1 of AI-11 states that if any inspections in addition to the twenty listed are needed, the originator of the purchase request is responsible for preparing appropriate inspection instructions. However, AI-11 does not contain or reference any detailed inspection or test procedures which would tell receipt inspectors what dimensions or any other characteristic to check, what tools or equipment should be used, or what the acceptance criteria are. The inspection report does not provide any space for recording the results of any inspections other than "Yes,"
"No," and "N/A."
! 10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedt.res and include appropriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished. Contrary to the above, Sequoyah has not established detailed receipt inspection procedures which provide appropriate guidance to the receipt inspectors. This lack of instructions contributed to the probicm discussed in Section 7 of this report concerning closing of incomplete receipt inspection folders without a tracking system to assure that C of I Cs are eventually approved. l This problem was previously identified in NSRS Report R-84-1-17-NPS and provides an additional example of TVA's failure to take adequate corrective action to NSRS findings. The concerns identified above contributed to Potential Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective Action to Previously Identified NSRS Findings. 14 __ ._ .__ _ - _ _ _ _ -}}