ML20207K731
| ML20207K731 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/19/1986 |
| From: | Howard J, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K654 | List: |
| References | |
| C010703-SQN, C010703-SQN-R04, C10703-SQN, C10703-SQN-R4, NUDOCS 8701090502 | |
| Download: ML20207K731 (12) | |
Text
_ _ _ _ _ _ _ _ _
i
- TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 4 (Final Report)
TITLE: Bending Equipment / Material PAGE 1 0F 11 REASON FOR REVISION:
To incorporate TAS and SRP comments. Revision i To incorporate additional SRP comments. Revision 2 To incorporate additional SRP comments. Revision 3 To incorporate Line Management response and finalize report. Revision 4 -
PREPARATION PREPARED BY:
L w- - lE b *0 G RE DATE REVIEWS PEER:
w V. w# 12-l8h6 g SIGNATURE 4) ATE hTAS*
- fd/
~~
s M8 '/i SIGNATURE DATE CONCURRENCES CEG- / 1 lA $ $b S wk lE ~1 ~ IC SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
f $ l$~SV"5 DATE N/A MANAGER OF NUCLEAR POWER DATE ECSPMANAj8R CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
1251T 10
(({$Ibb 7
(
- . s TVA EMPLOYEE CONCERNS REPORT NUNBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 2 0F 11 I. INTRODUCTION Five employee concerns relating to two basic issues were evaluated at Watts Bar Nuclear Plant (WBN), and as a result of the evaluations, the generic applicability of the issues was deemed pertinent to the Sequoyah Nuclear Plant (SQN) Quality Assurance Program. These two issues relate to the implementation of Division of Nuclear Engineering (DNE) process specifications (PS) for qualifying tubing bending tools and operations and procurement specifications used to purchase copper pressure tubing.
IN-85-707-002 IN-85-740-002 IN-85-740-003 IN-85-773-002 IN-85-831-001 No related site-specific concerns had been identified by SQN's Employee Concerns Program.
II.
SUMMARY
OF PERCEIVED PROBLEMS
- 1. Programmatic deficiencies resulting from inadequate implementation of DNE requirements concerning the qualification and control of bending equipment may allow questionable quality bends to be
. produced and damaged or defective bending equipment may remain undetected.
- 2. DNE procurement specifications may have been inadequate by not clearly specifying " Bending Quality" tubing in the copper tubing description.
III. RETHODOLOGY
- a. Discussions were held with responsible SQN Modifications and Additions engineers to determine which site procedures governed 4
tubing bendies and installation operations.
- b. Reviewed WBN Element Report C010703, " Bending Equipment / Material,"
to ascertain if WBN's bending equipment control methods were applicable to SQN's program.
- c. Reviewed SQN's Division Procedure Manual (DPM) N73M2 PS 4.M.2.1 (revision 7) for general bending requirements, tool requirements, qualification of bending processes and material requirements governing SQN's program.
TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 3 0F 11
- d. Reviewed addendum number 3 to PS 4.M.2.1 (revision 7) for code requirements for acceptable wall thickness of pipe or tube bends and revision to qualification tests for bending procedures. The addendum was dated January 7, 1986.
- e. Discussions were held with Office of Nuclear Power Quality Assurance (ONP QA) engineers, Modifications and Additions engineers, and Site Services engineers to ascertain methods being used to govern the control of bending equipment after initial qualification of that equipment.
- f. Reviewed Administrative Instruction AI-12. " Adverse Conditions and -
Corrective Actions," to establish controlling guidelines for identifying and correcting Conditions Adverse to Quality (CAQ).
- g. Reviewed historical file for Discrepancy Report (DR)
SQ-DR-85-04-045R, " Qualification of Tube Bendors," in order to evaluate program deficiencies previously identified by ONP QA.
- h. Reviewed memorandum from D. C. Craven, QA Supervisor, ONP to R. W. Olson, Modifications Manager, DNC, dated April 10, 1986 upgrading SQ-DR-85-04-045R to a CAR, SQ-CAR-86-04-017, as part of the problem history evaluation.
- 1. Reviewed memorandum from R. W. Olson to D. C. Craven dated September 26, 1986, responding with remedial corrective actions
.taken by Modifications in answer to CAR SQ-CAR-86-04-017 (RIMS S02 860926 942).
J. Reviewed Procurement Specification 47BM600, Revision 4, sheet 8 of 73, dated June 8, 1977, to determine DNE specifications for copper tubing.
1 K. Reviewed ASTM B88-83-A and ASTM B75 " Standard Specifications for copper tubing material to determine the type of tempers contained in each specification.
- 1. Discussions were held with SQN Mechanical Maintenance (MM) craft personnel to determine if difficulties had been encountered and/or documented during copper tubing bending operations.
- m. Reviewed Quality Technology Company (QTC) expurgated files and other investigation reports for any additional pertinent information.
m.- . . _ _. .. _ .. . _ _ - . _ _ -_ . _ _ _ _ _ _
TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 4 OF 11 a
IV.
SUMMARY
OF FINDINGS 4 .
- a. SQN Modifications and Additions engineers stated that tube bending operations were governed by DPM N73M2 PS 4.M.2.1.
-} b. Review of WBN Element Report C010703 verified.that WBN's
} controlling procedure, General Construction Specification (GCS)
M G-29 PS 4.M.2.1, was essentially the same as SQN's DPM N73M2 PS 4.M.2.1, and the same program deficiencies identified during WBN's
)] evaluation would be inherrent in SQN's controlling procedure.
In addition to the identified program deficiencies, WBN's procurement specifications for copper tubing were inadequate by not specifying " Bending Quality" in the description given in the Bill of Materials. "Nonbending Quality" material was supplied by vendors, but was in compliance with the specifications giver. in the procurement documents. Difficulties were encountered during i bending operations when "Nonbending Quality" material was used.
Cracks and breakage were inadvertantly attributed to " bad material or benders."
- c. Review of SQN DPM N73M2 PS 4.M.2.1, section 3.0, revealed that: "A I qualification test shall be performed whenever essential variables are changed. Two of the essential variables listed were equipment and material. The qualification test consists of bending three c samples. If the three samples are from a single heat, that heat is
, considered qualified. Qualification on three separate heats of
[ material qualifies the procedure for the material being bent.
Requalification is required whenever the equipment manufacturer or
~
[. model number is changed or the bending process is for any reason suspected of beir.g out of control. Tools used for bending shall be controlled in a manner appropriate to their application so as to ensure reproducibility of bend geometry. Tools used in bending stainless steel shall be used exclusively to bend stainless steel. ,
To alleviate the possibility of galling when bending stainless steel, it is recommended that tools and formers be chrome plated.
2 Copper received in the hard drawn condition may require annealing prior to cold bending in order to obtain acceptable bends."
- d. Review of addendum number 3 to PS 4.M.2.1 (revision 7) supplied the following: " Code Requirements for acceptable wall thickness of b pipe or tube bends are basically that the minimum wall thickness
- after tending shall not be less than the minimina calculated design f thickness for straight pipe or tube. Bending qualification test requirements were clarified to say: If the samples are one each from three different heats, the procedure is qualified for the
[ material being bent."
O l
TVA EMPLOYEE CONCERNS REPORT NUNBER: C010703-SQN
.SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 5 0F 11
- e. Discussions with ONP QA Engineers revealed that during routine surveillance of work associated with Modifications and Additions Workplan 11006, procedural discrepancies were identified and were documented on DR SQ-DR-85-04-045R as follows:
- 1. Tools used to bend stainless steel pipe were not segregated from tools used to bend other materials.
- 2. Not all bending tools (19 of 22) were properly and/or fully identified as listed in attachment B of PS 4.M.2.1.
- 3. Process Qualification Records (attachment A of PS 4.N.2.1) for bending pipe and tubing could not be located by plant personnel responsible for same.
- 4. Some existing tubing benders had not been qualified.
- 5. The governing site procedures do not specifically address the handling, storage, or the administration of the site's tube bending program requirements as set forth by PS 4.N.2.1 Conversations with Modifications and Additions engineers and Site Services engineers supported the findings voiced by the site QA engineers.
- f. The escalation of DR SQ-DR-85-04-045R to SQ-CAR-86-04-017 was in
.accordance with guidelines stipulated by Administrative Instruction AI-12.
- g. Program deficiencies as noted above in section 4.f. were verified to exist.
- h. The noted memorandum emphasized the fact that corrective actions
, had not been implemented in a timely manner and that the
" corrective actions required" fulfilled the criteria to upgrade the DR to a CAR.
- i. R. W. Olson's memorandum to D. C. Craven showed substantial program improvements had been made to implement upper tier requirements for personnel training and bender segregation, qualification, and identification. This evaluation took exception to section II, IR4 paragraphs 3 and 4 of the memorandum as follows:
- 1. By not being able to locate purchase documents for all benders currently in stock, qualifications for bends made by unknown
- benders are questionable.
. TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 6 0F 11
- 2. Testing for benders removed from existing and/or prior stock did not meet minimum criteria required by Process Specification 4.M.2.1 as noted in section III.d. above.
Qualification tests shall consist of bending three samples per heat of a product form which qualifies that one heat of material only, not all heats.
. 3. Two of the 58 benders tested damaged the tubing samples. No verification is performed which would detect damaged or defective equipment before use. No control existed to detect or document where benders were used in order to identify suspect tubing should problems be encountered with a particular -
bender. Steps should be taken to curtail use of the defective benders until evaluation of the defective bends by DNE is complete.
- 4. Pressure testing the 1/2-inch, 1-inch, and 1-1/2-inch diameter tubing bent by the defective hydraulic bender blocks does not meet DNE PS qualification criteria. No mention of the disposition for the defective radius and slide blocks was noted. It is suggested that the use of the defective hydraulic bender blocks be curtailed until DNE's evaluation of the defective bends is completed.
Subsequent conversations with SQN Modifications Supervisor provided l the following reasoning and clarifications to the corrective actions I to be taken by Modifications in response to CAR 86-04-017. These l supplemental clarifications address the exceptions taken to the IR4 original CAR response by the ECTG as noted above. As related below, I the additional response addresses each of the exceptions taken in l this element report. Each response below corresponds with the l paragraph of the same number in the noted exceptions shown above. I 1 The inability to locate purchase documents for all benders l is not considered a detriment to quality. As stated in a l previous response to CAR 86-04-017, a review of maintenance IR4 history records and discussions with plant personnel revealed I no record of plant failures (tube ruptures) attributable to l the use of nonqualified tube benders. l
- 2. Qualifications tests were performed in accordance with lR4 Work Request B130181 for two purposes: l
- a. To qualify new benders (received since July 1985) lR4 for use on current work. l
+ ,
TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 7 0F 11
- b. To provide an indication of the reliability of old lR4 benders. l Only new benders are to be used on CSSC tubing since none l of the old benders are to be color-coded orange for stainless- lR4 steel usage. l The new benders were qualified for use on one heat or all heats l according to the availability of multiple heats of materials. IR4 These benders have been tagged by toolroom personnel to I note limitations on bender use. l Each individual bender from old stock was used to bend one test I sample which was tested in accordance with DPM N73M2, Process l Specification (P.S.) 4.M.2.1. The successful completion of I these tests is considered an adequate indication of the lR4 acceptability of these benders. Since there were a large I number of tests run, many models were, in fact, qualified l for one heat, but few were qualified for all heats. I l
l Our interpretation of P.S. 4.M.2.1 is that the qualification I testing provides an indication of a vendor's model of bending i tools' ability to mass produce accept ale bends and is not I intended to be used as minimal requirements to assure continued l acceptability. Section 3.1.4 of Addendum No. 5 to lR4 P.S. 4.M.2.1 (R7) states, "Requalification is required l l whenever the bending process is for any reason suspected of l l
being out of control." Requalification in accordance with the I guidelines of this P.S. has no meaning as to the control of I an individual bender since the individual bender suspected of I making the " bad" bends is not required to be tested. l l 3. During the course of the qualification testing, at least one l lesson was learned by those involved: Visual inspection of bending l l equipment will not always indicats defective equipment! The two lR4 l benders that damaged the tubing appeared to have never been used, l while others with damaged radius blocks produced adequate bends.
l As stated in 2 above, none of the old benders are to be used IR4 on CSSC tubing.
- 4. Although pressure testing of the 1/2-inch, 1-inch, and 1-1/2-inch I diameter tubing bent by the defective hydraulic-bender blocks l does not meet P.S. 4.M.2.1 criteria, the successful completion lR4 is concluded to be more than adequate justification for the I acceptability of in-place bends. l'
r TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 8 0F 11 Since no control existed to detect or document where benders were l used, no method to trace back to the work in the field exists. 1 Discussions with plant personnel revealed that the benders have lR4 been used for tubing modifications before July 1985. At that I time, the bender pumps became inoperable and were not repaired I until the qualification-testing exercise began. l All existing bending shoes are being removed from use since no IR4 qualification records exist for them. l J. Review of DNE Procurement Specification 47BM600, revision 4, sheet 8 of 73 revealed copper tubing material was specified as: tubing - -
seamless copper, hard, ASTM B88, type K or ASTM B75, type 120 or 122, 20 foot lengths, in sizes shown.
j The procurement specification implies hard temper qualities are
- part of the ASTM B88 properties. This is a misnomer. Type K
- refers to wall thickness only, which is independent of temper l quality. Types 120 and 122 refer to the chemical analysis of the l copper tubing materials without reference to temper quality.
'4
- k. Review of the ASTM B88-83A specification indicated that annealed or I drawn copper water tubes suitable for general plumbing and similar 3 applications were manufactured to this standard and no mention of
} hard-drawn tempers was included. ASTM B75-84 specifies seamless I copper suitable for general engineering purposes, and is supplied I as annealed and drawn tempers., The drawn tempers (H-tempers) are j specified as drawn H-58 (general purpose), H-55 (light-drawn, i bending quality), and H-80 (hard-drawn). Drawn copper tubing as i specified in ASTM B88 is suitable for general plumbing and is most i conunonly used where there are no specific requirements for high strength. Hard-drawn temper as specified in ASTM B75 is used only where there is a need for a tube as strong as is commercially y ,
feasible. Tubing of this temper is not bending quality and will f, crack or break during bending operations. Hard temper tubing is suitable for straight runs only.
- 1. Discussion with Mechanical Maintenance personnel revealed that difficulties such as cracking and breaking had been encountered.
j when bending attempts were made utilizing some copper tubing 4 materials. No documentation for the problem could be obtained.
- m. No additional relevant information was obtained from QTC expurgated 5 files or other investigative reports.
1 1
l :
)
I
,' TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 9 0F 11 CONCLUSIONS A. SQN site implemented procedures governing maintenance and modifications activities were inadequate in implementing requirements specified in DPM N73M2 PS 4.M.2.1. The engineering evaluation or justification to hydrostatically test the worst-case sample bend to qualify past installations is a deviation from the design specifications and requires DNE approval in order to maintain the design basis for SQN related to bending activities.
It is suggested that SQN ensure that all deviations from the design requirements noted receive formal evaluation and approval from DNE. This referral to DNE should address the qualifications of the benders for all heats of a given product form and should also consider the WBN sample inspection program results for an evaluation related to the installed conditions of the bends at SQN. The defective benders require special evaluation by DNE and should be addressed.
(CATD 10703-SQN-01 and 10703-SQN-02)
B. Procurement specifications for copper pressure tubing were inadequate by not specifying " Bending Quality" in the description supplied by the Bill of Materials. The vendor's interpretation of TVA's temper quality requirements resulted in shipment of ASTM B88
" Bending Quality" or ASTM-B75 (H-80) hard drawn "Nonbending Quality" material. Since hard copper tubing has been shown to break or crack during bending operations, and no rer7rts of copper tubing ruptures during construction hydrostatic testing or system operations have been documented, it is reasonable to assume no "hard" copper tubing is installed. DNE should revise the procurement specifications to clearly indicate the required temper quality (bending quality) tubing to provent any future acquisition of "nonbending quality" copper tubing.
(CATD 10703-SQN-03)
V. ROOT CAUSE
- 1. ONP failed to implement the requirements of DPM N73M2 PS 4.M.2.1 into their bending operation program procedure.
l
- 2. The Bill of Materials description for copper tubing requirements was not clear enough to preclude the acquisition of "Nonbending Quality" tubing. The term " Bending Quality" should have been part of the material description used to procure copper tubing. The '
technical review of the procurement specificctions was inadequate, since the interpretation of the requirements was left up to the supplying vendor.
I ._ _ _
. , TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 10 0F 11 VI. CORRECTIVE ACTION The following is the Line Management's response to corrective IR4 actions. l CATD 10703-SQN-01, Rev. 1 lR4
- 1. Formally requested assistance from site DNE to determine: IR4
- a. Acceptability of corrective actions taken in accordance lR4 with CAR 86-04-017. l
- b. Additional corrective actions that may be needed to ensure IR4 all related design basis are preserved, i
- 2. Assure that all defective benders; including radius, clamp and l slide blocks for hydraulic benders are segregated and restricted lR4 from use. l
- 3. Initiate any additional corrective action required by DNE. lR4 CATD 10703-SQN-02 lR4 A revision to MMU-5 will be issued requiring periodic visual l inspections of bending tools. Damaged tools will be tagged IR4 defective until verification of adequacy is determined. Benders l which cannot be proven acceptable will be destroyed. 1 CATD 10703-SQN-03 lR4 Material specifications for " Bill of Materials" and Power Stores l l will be clarified to ensure the procurement of " Bending Quality" lR4 I
tubing. l
\ .
These corrective actions are not restart items. IR4 VII. GENERIC APPLICABILITY The generic applicability determinations resulting from the WBN ECTG evaluation of the subject employee concerns were accurate related to inadequate: a) site implementing procedures for bending activities and, b) procurement specifications for copper pressure tubing materials.
f A
-.. ,, , . , . , . _ , . _ , , _ . , , . _ _ _ , _ _ - --w.,,,. y. -
TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 11 0F 11 Additionally, the potential exists for these conditions to be present at BLN
& BFN, as stated in the WBN ECTG Element Report C010703 Bending Equipment / Material.
l l
l VIII. ATTACHMENTS Attachment A Listing of concerns indicating Safety Relationship and Generic Applicability.
a P
9 a
e v - em+ w c-- -
- w. c , - - , . , , a, . ,.e,w--r--, - - - - - - ---- ,,- ,-r >
. . y, 4 ,
m
<m g.:
coinggg %
4lp.
.; . ATTACHMENT A
".Ill -B S-7 07-0 02 CO 10700 11 HDil
-T50070 - - - . - - - YYYH' REPORT
< 115 - TUBING CR CKED llHEli BEllT HITH HAHDU littDER. HAS LOCATED IN REACTOR DUILD
- IttG 2, THROUGH HATCH, UP SPIRAL STAI RCASE, 011 IST L AllDIHG-3/8" COPPdR TU -
BIltG . HAS BEEN REPLACED HITH ACCEPT ABLE.TUDING.
- .- CRACKED TUDING HADil'T
. BEEli INSPECTED AT TIME THAT IT HAS D
- - - ISCOVERED AllD FIXED. C/ I ' H AS 110 110R E DETAIL. It0T E : C/I HAS 110 MORE Ill FORMATIO!!. HE REPLACED CRACKED TUDI 11G 0 ft0RE. HHEHEVER HE FOUtID IT - KilotiS OF !!
Ill -8 5-7 4 0'-0 02 CO 10700 N HBil
. TS0199 YYYY HS REPORT ALL HAllD BENDERS ARE THE " IMPERIAL" BRAllD, AllD ALL BEllD THE SAME. THESE
, BEllDERS HORK OK FOR STAIllLESS STEEL '~
PER BUT THEY CRACK AllD " EGG SHAPE" C0P TUDING.
CI DECLIllED TO PROVIDE'~~
^
FURTHER INFORMATI0tt.
.--ill -8 5-7 4 0-0 0 3 - CD EPT. CollC ERil . ., - CollSTRUCTI0lt D T50199 1070011 HBil YYYY HS REPORT . . . _
'. HAND .MADE TUBIt!G BEHDERS USED TO BEli D RADIATION MONITORIllG TUBItto'(I". All
. D 1 1/2") DAMAGE TUBIllG. BEHDERS LO.
. .' , CATED 729' 0F TURBIllE BUILDING (14" 77 1~~
- ' ' . AllD 20" RADIUS).- TUDIltG LOCATED Ill u..
c, ' .v.._ ..t
~ . . . q . n- ~ , y.,. .G "~q
- .- f i -
I- .': i.ADDITIDHAL EQUIPMENT DUILDIltGi -GO I r
, .; ; ^ H CRAllE BAY DOOR OF UNIT 2, aTAKE RIG -~
.~ ~ : ' J HT HAND DOOR, LOOK BEHIIID HIltG HALL
~ '.. --
- HEAR OR DEHIllD S0llE STAIRS.' - CollSTRU --
CTION DEPT. CONCERil. - CI DECLIllED T .'_
Ill 773-002
. ~
CO 0 PROVIDE FURTHER INFORMATI0ll.
T50081 ,. .
10700 H HDH .YYYY _
- Ils
~ . - -
, c
. = - - -
REPORT
~
.-.ETHERCOPPER TUBIllG BREAKS OR SQUEEZ HHEll BEllDIHG 90
, ., E - - , --
- ~
. MATERIAL OR
..u.~.,-.. - . _.
BENDER
,HATION IS
- DEFECTIVE. - H0 NORE II FOR .
AVAILADLE.O Ill ~85-831-001 T50086 . e r. CD,- a 10700 N HBit ~Y Y Y'Y
~ ~ ' 'N
- . ,=.. ~ m ~ . - n u;Q- : j ;T,_*@(.'. j;. : -~
. :' ; . ~ ~- m .~ .. .
2.'. . ' ' M*. C.e[. 3 ep.I.-i.. . R EP OR T . ' i . ^~ r~ . * -
- 'llS '; COPPER INST *RUMEllTATI0ll'TUBIllG IS-Cott 2 --
~ T '2 - , , - G ..-;'~~'.
.~ae - V ..'.THE SISTENTLY " BREAKING" HHEtt BEtti USIllG W
.,y N.-
- , W- ;.J L=ct: ' ._.-c=g .,... . -..- _; d '
. :. 3. 7 .: . ~. . - 2. MECHAllICAL (HAtID-OPERATED) B EllD -
E ~ J~-ING TOOLS; ' BECAUSE OF THE C0tISISTE!!C
-- ~ ~ -- -- . . . .
.Y-AT HHICH THE " BREAKAGE" OCCURS,THE ~
RE IS A C0ilCERH THAT THE "COOD" BE!!
a
'* . S 11AY VIOLATE 111HIf1UM !!ALL OR OTHERtl
NG MAY BE THE CONDITIOH OF THE BEllDI j -(HO SPECIFICS GIVEH)-
-. ? -
m
.e- *A^ "
ee _
++.
g %=-%.mWh*'
--.,w
~^
~~".......
~ ~
~~
_