ML20207K849
| ML20207K849 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/19/1986 |
| From: | Mcnutt G, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K654 | List: |
| References | |
| 212.2(B), 212.2(B)-R01, 212.2(B)-R1, IEB-79-14, NUDOCS 8701090541 | |
| Download: ML20207K849 (36) | |
Text
{{#Wiki_filter:,, = TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REPORT TYPE: SEQU0YAH ELEMENT REVISION NUMBER: 1 {- TITLE: PIPE SUPPORT PROGRAM NRC Bulletin 79-14 ABR Program PAGE 1 0F 35 REASON FOR REVISION: TVA comments incorporated. PREPARATION (.h PREPMARLA./LA,at 12/3/sc BY: v ' (jSIGNATURE' DATE REVIEWS (REVIEW COMMITTEE M 12 8 62 / SIliNATURE ' ' ' ~ j DATE d hs /3/$1b6 SIGNATURE DATE l CONCURRENCES 9/. tL. /2-4-9c l kDk EDO ~ O 27 3% kr /2-M-8 C SRP: SIGNATURE DATE G SIGNATURE
- DATE
- SRP Secretary's signature denotes SRP concurrences are in files.
APPROVED BY: Y bh' ' l$'l$'$ N/A ECSP MA (fER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) [
.3 TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 b PAGE 2 0F 35 1. CHARACTERIZATION OF ISSUES: Concerns: Issues:
- a. IN-85-027-001 a.
TVA program for implementing NRC IE "TVA program for implementing Bulletin 79-14 is inadequate. NRC Bulletin 79-14 inadequate. Design calculation documenta-b. Design calculations that address the tion is lacking." resolution of 79-14 program discrep-ancies lack proper documentation,
- b. SQN-86-002-02 "During the exit interview c.
Containment spray piping does not the CI stated that containment reflect "as-constructed" configuration spray line piping drawings and in terms of routing as well as weld weld map do not agree with the locations. as-builts. Alternate analysis was used instead of rigorous d. Containment spray piping was analyzed analysis, drawings were not using Alternate Analysis method corrected." instead of Rigorous Analysis method. -G#b 2. HAVE ISSUES BEEN IDENTIFIED IN ANOTHER SYSTEMATIC ANALYSIS? YES X NO Identified by Tennessee Valley Authority (TVA) l Date As shown below Documentation Identifiers: s o Corrective action report No. SQNCAR 8602009,(02/27/86) o Corrective action report No. SQNCAR 8606034,(06/11/86) o Generic concern task force report GPH-07-41 for employee concern # In-85-027-001, Rev.1, (04/28/86) l 3. DOCUMENT N05., TAG NOS., LOCATIONS OR OTHER SPECIFIC DESCRIPTIVE IDENTIFICATIONS STATED IN ELEMENT: o Nuclear Regulatory Commission (NRC) IE Bulletin 79-14 l o Containment spray piping drawings, weld map, and as-built drawings l h o Alternate Analysis and Rigorous Analysis calculations 0429D (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 3 0F 35 4. INTERVIEW FILES REVIEWED: I Review of interview files for concern No. IN-85-027-001 shows the following information: 4 o Employee concern assignment request from NSRS (06/8/85) o NSRS Report No. IN-85-027-002. This report is not relevant to the concerns discussed here. o File screening sheet (06/18/86) o Form G-A indicating generic applicability to all plants (02/3/86) o Form D, which is plant specific to WBNP (12/07/85) Review of interview files for concern No. SQN-86-002-02 shows the following information: o NRSR ECP Review Sheet G'1 o Form A, ECTG M-1, Attachment F, Page 2 of 2 4 o Standard Practice, Attachment B2, Page 9 o Standard Practice, Attachment B3, Page 10 and 11 ) 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT: See Appendix A. ~ 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS OR OTHER l APPLY OR CONTROL IN THIS AREA'l See Appendix A. 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED TO ELEMENT. See Appendix A. 0429D (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 4 0F 35 ,8. EVALUATION PROCESS: a. Reviewed Sequoyah (SQN) program for NRC IE Bulletin 79-14 inspections, identification, and resolution of discrepancies. b. Reviewed a sample of discrepancies identified in "a" (above) to verify the adequacy of resolution documentation. c. On a sample basis, reviewed design calculation input data and compared with as-built drawings for containment spray. d. Reviewed Alternate Analysis criteria to determine its application to containment spray piping. e. Investigated containment spray piping for type of analysis performed; i.e., Rigorous or Alternate. f. Reviewed design calculation performed by Alternate Analysis j method for applicability of the Alternate Analysis criteria, j i { 9. DISCUSSION, FINDINGS, AND CONCLUSIONS: l Chronology-NRC Issues IE Bulletin 79-14: 07/02/79 SQN claims equivalent program: 09/07/79 NRC audits SQN Unit 1 to verify compliance to IE Bulletin 79-14: 04/23 - 25/80 NRC issues COA confirming four-part program: 04/29/80 SQN issues MI-6.17 to implement IE Bulletin 79-14 Inspections: 04/29/80 NRC issues IAL after inspection completed 04/25/80: 05/21/80 Report of SQN inspections sent to NRC; TVA commits to additional Unit 1 inspections: 06/27/80 TVA issues plant-approved procedures MI-6.17A, MI-6.17C, and MI-6.18 to perform the additional inspections: 07/08/80 - 01/12/82 TVA essentially completes Unit 179-14 program: 12/80 TVA completes the remaining Unit 1 79-14 program: 07/15/82 TVA performs Unit 2 79-14 program, Phase I: 10/28/80 to 01/09/81 TVA performs Unit 2 79-14 progrem, Phase II; 02/23/81 to 03/06/81 NRC conducts an unannounced audit of 79-14 program for Unit 2: 06/02 - 04/81 NRC performs further inspections of 79-14 program for Unit 2: 08/06/81 to 09/15/81 0 04290 (12/03/86) 1 R
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 I PAGE 5 0F 35 TVA receives concern IN-85-027-001: 05/85 79-14 questions at Browns Ferry occasion SQN QA Survey: 12/85 and 02/86 SQNCAR 8602009 issued in response to QA Survey: 02/27/86 TVA investigation responds to CAR: 03/28/86'to 09/26/86 TVA receives concern SQN-86-002-02: 06/86 l SQNCAR 8606034 addresses further deficiencies: 06/11/86 TVA implements pipe support enhancerrcnt program to close both CARS: 05/02/86, to continue to completion beyond restart. Discussion: 9.1 ISSUES "a" AND "b" The NRC IE Bulletin 79-14, issued on July 2,1979 (App. A, 6.a), required a program to demonstrate, with a high I level of confidence, that the as-constructed safety-related piping system configuration agreed with the analyzed configuration. The essential elements to be examined for configuration verification were as follows: (,. o Pipe run geometry o Pipe support location, type, orientation, clearances (including floor and wall penetration) o Embedments (excluding those covered under NRC IE Bulletin 79-02) o Pipe attachments o Valve and valve operator locations and weights (excluding those covered in IE Bulletin 79-04) This verification that the seismic analysis applies to the actual configuration of safety-related piping systems was required of all power reactor licensees and construction permit holders unless verification to an equivalent degree I has taken place within a 12-month period prior to issuance of the NRC Bulletin. TVA's initial response on September 7, 1979 to the NRC regarding compliance with IE Bulletin 79-14 for SQN was that the on-going design and construction verification program is equivalent to the requirements of this bulletin (App. A, 5.a). C 0429D (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 'PAGE 6 0F 35 In the exit interview on April 25, 1980, an NRC inspector cited several examples of pipe support installations that were accepted by the TVA construction inspections but did not meet the design drawing requirements. The NRC inspector i identified this situation as an infraction and stated that I the NRC would issue an Immediate Action Letter (IAL) l requiring additional inspections (App. A, 5.b). On April 29, 1980, NRC issued a Confirmation of Action (C0A) letter (App. A, 5.c) confirming a four-part program, for additional inspections, previously accepted by TVA in telephone conversation with the NRC. In this C0A, the NRC referred to its inspection of TVA's compliance with IE Bulletin 79-14. The NRC determined that TVA's program for verifying correct installation of piping supports had not been properly implemented in the systems inspected. Therefore, NRC directed TVA to take the following additional 3 actions: "1. Determine the cause of the problem in implementing your piping and support program, including the reasons for p," the failure of your quality assurance program to i i identify the problem. "2. Inspect a representative sample of pipe supports on j each safety-related system inside containment to verify proper installation. The percentage to be inspected a will be based on the findings from the determinations in paragraph 1 above and following discussions with this office. ~ "3. Select at least one isometric drawing from each of eight safety-related systems inside containment and verify that all requirements of Bulletin 79-14 are met. "4. Upon completion of the above, provide us with your i inspection findings, schedule for completion of the inspection of the remainder of the safety-related supports outside containment, and proposed corrective actions." On May 6,1980, TVA requested that the NRC- (App. A, 5.d) revise item number 3 of NRC's COA as follows, ir accordance with previous telephone discussions between the imC and TVA: Q j 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: '212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 <4 7 ~~ PAGE 7 0F 35 i- ? k " Select at least one isometric drawing from each of the I' eight safety-related systems inside containment and verify proper installation of pipe supports. Select at i least one isometric drawing from each of eight } safety-related systems outside containment and verify j that all the requirements of IE Bulletin 79-14 are il met. These eight system shall include the Residual ] Heat Removal (RHR), Auxiliary Feedwater (AFW), Safety Injection (SI), and Upper Head Injection (UHI) Systems." a 1 3 On April 29, 1980, SQN issued Revision 0 of Maintenance f Instruction MI-6.17, " Instruction for the Implementation of j NRC IE Bulletin 79-14" (App. A, 5.e), and inspections to this q instruction were authorized to begin. Unit 1 Inspection Program On June 27, 1980, TVA submitted to NRC (App.A, 5.f) a report of the inspections performed at SQN Unit 1 in response to the a J NRC C0A. The inspection program consisted of the following four_ activities, "a" and "b" inside containment and "c" and "d" outside containment: Inside Containment. The following inspections were performed inside containment: a. A detailed inspection using MI-6.17 was performed on ( all supports on one isometric each for the systems listed below: o Reactor Coolant (RC) { o Residual Heat Removal (RHR) o Safety Injection (SI) o Chemical and Volume Control (CVC) j o Auxillary Feedwater (AFW) f o Main Steam (MS) o Component Cooling (CC) o Main Feedwater (PFW) h { a 0429D (12/03/86) 4 I
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 8 0F 35 Also, for four additional systems, TVA elected to randomly select at least 20 supports per system and performed detailed inspections per MI-6.17. These systems were: o Upper-Head Injection (UHI) o Containment Spray (CS) o Steam Generator Blowdown (SG) o EssentiaI Raw Cooling Water (ERCW) b. In addition, walkdown inspections for 80 isometrics of 12 safety-related systems inside containment were performed to ensure that potential problem supports inside containment were discovered and corrected. These inspections were not per MI-6.17 but per an inspection summary sheet which had two-party sign off from ccnstruction and operations inspectors. These 80 isometrics for which the piping stress analysis was f, performed by TVA subcontractor Engineering Data Service (EDS) are referred to as 80 EDS isometrics. Outside Containment. The following inspections were performed outside containment: c. A detailed inspection using MI-6.17 was performed for all supports on one isometric each of the same 12 systems in item (a) plus the Fuel Pool Cooling System. d. The same portions of eight piping systems outside containment that received detailed pipe support inspection were inspected to the full extent of IE Bulletin 79-14 requirements, including pipe run geometry; support and restraint design, location, function, and clearance; embedments; pipe attachments; and valve and valve operator locations and weights. These eight systems included the RHR, SI, AFW, and UHI systems, among others. Additional Inspections for Unit 1. From the above inspections and the analyses performed (to justify the discrepancies found), TVA concluded that its program demonstrated that the piping and piping support systems at SQN Unit 1 are fundamentally sound and that low-power r operation of the unit would be unaffected by even the most severe discrepancies that could be found. 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 9 0F.35 TVA also committed to perform additional inspections to provide further assurance that the plant can be operated safely at full power. This inspection program consisted of the following: "A. Perform isometric walkdown inspections associated with the remaining safety-related systems inside containment. 1 J "B. Perform isometric walkdown inspections associated with the safety systems outside containment. "C. Inspect three supports on each side of rotating i equipment for proper clearance. "D. Perform a walkdown inspection of supports on piping 2-1/2 inches or larger that were analyzed with the alternate criteria method on the ERCW, component cooling, waste disposal, CVCS, fuel pool cooling, and fire protection systems in Class I structures. Systems not included are ice condenser glycol, {.) auxiliary boiler, primary water, and roof drain systems, since they perform no safety function. "E. Perform valve and material verifications on the eight isometrics inspected outside containment. "F. Perform valve and material input information L verifications on rigorously analyzed systems on a sample basis to consist of three valves for each s isometric and material verification at three welds i for each isometric. "G. Formal procedures will be written to ensure that discrepancies found are appropriately reviewed and Li technical specification action statements invoked, l if appropriate, within 48 hours from the time the ] design engineer performing the review is notified of the discrepancy. This is in accordance with 4 IE Bulletin 79-14." ] All of the above inspections, except item "D," were scheduled 3 to be completed before 30 effective full-power days fuel burnup on Unit 1. Item "D" was scheduled for completion before restart from the first refueling outage. TVA's a justification for delaying completion of item "D" was based on the inherent conservatism of the Alternate Analysis b criteria. 0429D (12/03/86)
/ TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 I PAGE 10 0F 35 To fullfil this inspection commitment, TVA developed the following maintenance instructions: a. MI-6.17A for rigorously analyzed piping (App. A, 5.g) b. MI-6.17C for alternately analyzed piping (App. A, 5.h) c. MI-6.18 for review of walkdown discrepancies (App. A, 5.1) The scope of MI-6.17A was to visually inspect all safety-related piping that was analyzed using Rigorous Analysis method. The scope of MI-6.17C was to visually inspect safety-related piping 2-1/2 inches and larger in diameter that was analyzed using the Alternate Analysis method. The following systems inside and outside of containment were included in this scope: o Essential Raw Cooling Water {f; o Component Cooling Water o Waste Disposal o Chemical and Volume Control o Spent Fuel Pit Cooling o Fire Protection The purpose of MI-6.18 was to provide proper documentation for the data obtained from these inspections; for the resolution of discrepancies found; and to assure that technical specification action statements are invoked, if appropriate, within the required time period (48 hours). Visual inspections were performed for the following elements: o Piping geometry in accordance with the isometric drawing o Interference between piping and other plant features such as equipment, structures, other piping, etc. 04290 (12/03/86) l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) i SPECIAL PROGRAM REVISION NUMBER: 1 >p PAGE 11 0F 35 o Installed location of valves; additional or missing valves f o Installed location of supports; additional or missing supports; type, size, orientation, and completeness of support installation o Type and thickness of pipe insulation, from the drawing ~ Detailed inspections were performed for the following elements: t o Three large valves per isometric for location and other I valve information such as valve number, manufacture, } etc. o Verification of pipe size, wall thickness, and pipe material at three locations o Clearances around the pipe for all welded-up structural supports for alternately analyzed piping (MI-6.17C) and j Q/n for all such supports between each rotating equipment-6 nozzle and the third vertical support from that nozzle for rigorously analyzed piping (MI-6.17A) h Using the above described instructions, TVA essentially completed its IE Bulletin 79-14 program for SQN Unit 1 by L December 1980. The results of this inspection program are discussed under the heading "Results of Inspection Program." p Unit 2 Inspection Program P l For SQN Unit 2, TVA responded to the IE Bulletin 79-14 in two programs: Phase I and Phase II. As a result of the Unit 1 IE Bulletin 79-14 sampling inspection, TVA decided to ) implement the Phase I inspection program to augment the on-going as-constructed inspection program. The Phase II program was implemented to verify the effectiveness of the Phase I program. These two programs were instituted by October 1980 (App. A, 5.j). Phase I. The Phase I program consisted of inspecting all rigorously analyzed safety-related piping (inside and outside containment) and alternately analyzed safety-related piping ) 2-1/2 inches and larger in diameter (inside and outside containment) for ERCW, CCS, WDS, CVCS, SFPCS, and FPS oiping systems. t 0429D (12/03/86) I L
e TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 r PAGE 12 0F 35 TVA developed the following procedures to perform the Phase I inspections: o Inspection of piping and supports - Isometric walkdown procedure No. SQN-80-04 (App. A, 5.k) for rigorously analyzed piping r o Walkdown inspection procedure No. SQN-80-09 (App. A, 5.1) for alternately analyzed piping ~ The extent of this inspection and the significant elements inspected are shown in the following tabulation: Item Type of Extent of Inspected Inspection Inspection Remarks Piping General 100% Measured if configuration (visual) discrepancy I noticed, and as-constructed data prepared (5 Locations of 100% Measured if components, (visual) discrepancy
- fittings, noticed valves, branch lines 4
Existence of 100% additional (visual) items such as l flanges, strain-ers, etc., not ) shown on the isometric j { Pipe wall 3 locations [ thickness, per inspection i material, and drawing [ and size (measured) i Insulation Type and presence of insulation l noted on drawing b i i 0429D (12/03/86) i (
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 I PAGE 13 0F 35 Item Type of Extent of Inspected Inspection Inspection Remarks Clearance from 100% adjacent piping, (measured) if structures, 1/2" or less sleeves away from piping Valves Valve type, 3 largest motor-tag number, operated manufacturer, valves in the valve model system number Orientation of 100% i the operator to (measured) be checked within +15'
- Location, 100%
Measured and additional (visual) type, tag ! ' (@ or missing number, etc., valves provided if discrepancy noticed Pipe Type, location, 100% Measured if Supports direction (visual) deviation noticed Rod and strut 100% size, spring (vlsual) size, snubber size, and any visible damage Clearance 100% Measured if around pipe (visual) discrepancy going through noticed wall and floor penetration J G 4 04290 (12/03/86) e- -,w,.s ,g4 .p
l TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 i PAGE 14 0F 35 L Item Type of Extent of v Inspected Inspection Inspection Remarks Clearance for 100% (visual) Gross clearances welded-up Measured.for measured to j structural supports Spec.G-43 support between limits rotating l equipment I nozzle or containment h per.etration and F third vertical ( support from f nozzle /penetra-tion Existence of 100% }- temporary sup-(visual) ports, addi- [ tional supports I h Support 100% f, . components, (visual) structural l members, welds L. Missing anchor 100% O bolts, damage (visual) to support In addition, Phase I required detailed documentation of all discrepancies, their assignment to the respective l-l organization for evaluation, and resolution of these }. discrepancies. The Phase I program commenced in October 1980 and the walkdown inspections were completed by January 1981 ( App. A, 7.x). i Phase II. The Phase 11 program was an audit to verify the f effectiveness of thL Phase I program in assuring compliance j with IE Bulletin 79-14 requirements. It consisted of, on an sample basis, 100 percent measured inspection of the items I ? l 04290 (12/03/86) I
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 15 0F 35 (discussed above) covered under the Phase I program. This inspection program was limited to rigerously analyzed seismic Category I piping regardless of size. A total of nine piping isometrics from different systems such as main steam, feedwater, safety injection, etc., were selected for this program. This inspection was conducted by an independent inspection team (from Teledyne) not involved in the Phase I i program. The Phase II program was basically a means to identify and correct any programmatic deficiencies in TVA's e Phase I program. F' TVA developed the following procedures to perform the Phase II program: l i c o " Procedure for the Implementation of NRC-01E Bulletin 79-14," Phase II (App. A, 5.m) e o " Discrepancy Evaluation Criteria, Phase II," (App. A, 5.n) i F A total of nine isometrics were randomly selected from eight safety related systems for the Phase II inspections. These eight systems and number of supports inspected are listed 0 i-below: System No. Supports Reactor Coolant 34 t Safety Injection 13 E Chemical and Volume Control 19 f Main Steam 21 Component Cooling 28 Main Feedwater 10 s Containment Spray 64 Essential Raw Cooling Water 17 fDT The discrepancies identified by Phase Il program inspections [ were categorized as follows: a. Nonsignificant: A deviation between as-built configuration and analysis requirements that would not cause the affected piping to exceed its qualification levels. + i t G t 0429D (12/03/86) L k
TVA EMPLOYEE CONCERNS' REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 16 0F 35 b. Significant: A deviation between as-built configuration and analysis requirements that could cause the affected piping to exceed its qualification level. c. Potential for loss of pressure boundary: A definite potential for loss of pressure boundary is an i engineering judgment by the piping analyst that [ indicates the discrepancy is likely to cause a pipe l break under design loading. TVA made the following commitment to the NRC (App. A, 5.n, paragraph 4.1.3) for Unit 2 IE Bulletin 79-14 program: "If TVA finds one condition not identified in phase I, following engineering evaluation, which would result in a pressure boundary failure endangering the safety of the plant or the health and safety of the public, we l will reevaluate the program and make recommendations as l to corrective action." Q Results of Inspection Program. The following subsections present the inspection findings of the IE Bulletin 79-14 Program for Unit 1 and for Unit 2, ] Phase I and Phase II. i t Unit 1, 79-14 Program. A total of 175 discrepancies were identified in the initial inspection under the instruction MI-6.17, which was conducted on a selected sample of piping systems. The expanded inspection program performed per instructions MI-6.17A and MI-6.17C resulted in a total of f 1,156 and 824 discrepancies respectively. I The evaluation team verified, on a sample basis (App.A 7.e), resolution of the MI-6.17 discrepancies and found it to be l adequately documented. The resolution included calculations, as observed, for discrepancies 06-03-80-02 and 05-24-80-09. The MI-6.17 walkdown inspections were completed by June 1980. Review of the " discrepancy logs" dated January 1983 and September 1986 for the discrepancies identified under the expanded inspection program (MI-6.17A and MI-6.17C) showed 'c that each discrepancy was clearly identified, a resolution was provided to correct it, and the status of completion of the required actions was indicated (App. A, 7.f). b. 1 04290 (12/03/86) L
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM p REVISION NUMBER: 1 [ PAGE 17 0F 35 The walkdown inspections for this expanded program were completed by October 1980 and July '1982 for MI-6.17A and MI-6.17C, respectively. In December 1985 and February 1986, the Quality Assurance staff, on a sample basis and using instruction MI-6.17, performed an in-plant survey for SQN Unit 1 (App. A, 5.0). This survey was occasioned by questions raised at Browns Ferry Nuclear Plant regarding the performance of the IE Bulletin 79-14 program. The purpose of this survey was to determine if the original IE Bulletin 79-14 program was adequately conducted and if corrective actions for the reported discrepancies were satisfactorily completed. The survey identified the following shortcomings: a. As-constructed pipe supports did not agree, in all cases, with the dimensions, weld size, and weld type shown on the drawings. b. Drawings were not corrected for discrepancies found in the Original 79-14 program. p" c. Additional drawing discrepancies were found in this survey that had not been identified in the original 79-14 program. d. There was no documentation to verify that the several discrepancies reported and corrected in the original 79-14 program were reinspected after maintenance or repai r. e. Not all supports inside containment were inspected for clearances between the support and pipe (reference 80 EDS isometrics for inside containment on Unit 1). f. A large number of supports were not inspected because they were declared inaccessible. As a result of this survey, Corrective Action Report (CAR) No. SQN CAR 8602009 was issued on February 27, 1986 (Section 2.0). It described the adverse condition as: " Contrary to the requirements of MI-6.17, the 79-14 hanger program does not appear to have been adequately conducted and corrective action for some reported discrepancies was not properly documented...." G 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 18 0F 35 It should be noted that this CAR does not find other elements of 79-14 program (such as piping geometry, valves, insulation, etc.) to be inadequately verified under the MI-6.17 instructions. Its focus is on pipe supports. TVA's investigation ( App. A, 5.p thru 5.x) in response to CAR 8602009 revealed that the MI-6.17A pipe support inspections, in most cases, were performed without detail support drawings. Consequently, some important aspects of this inspection - - such as clearances around pipe in welded-up structural supports, support locations, support ~ configurations, completeness of support installation, snubber size, etc. - - would have been difficult to verify. On June 11, 1986, a second corrective action report SQNCAR { 8606034 (Section 2.0) was issued which described the adverse condition as: " Specific concerns have been raised on the Unit 1 79-14 hanger program involving hardware installation... and documentation... discrepancies.... Corrective {l/ actions must address, in addition to correcting the listed examples, the identification and correction of similar problems." In May 1986, TVA began a pipe support enhancement inspection program to correct the CAR-identified deficiencies. This l program is being conducted under Special Maintenance Instruction SMI-1-317-24 ( App. A, 5.y). The purpose of this program is to verify that the installed configuration of pipe supports is compatible with the as-analyzed configuration. It also provides for enhancement of the support condition through concurrent or subsequent performance of minor maintenance and through disposition of discrepancies. The scope of this program is to inspect all supports inside containment: o For 80 EDS isometrics o The supports previously identified as inaccessible TVA does not plan ( App. A, 5.q) to reinspect supports that were inspected for IE Bulletin 79-14 in accordance with plant-approved instructions (such as MI-6.17A) which did not require the use of detail support drawings. TVA's rationale G 0429D (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUM5dR: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 p PAGE 19 0F 35 for this position is that the restraint direction is indicated on the isometric, and a properly trained inspector can determine whether the required pipe restraint is provided by the support without the use of the detail drawing. The isometric is the governing drawing since the detail drawing is made from the information on the isometric drawings and the load tables, etc. The sample of the W package (MI-6.17A related inspection package) discrepancies revealed 14 incorrect restraint directions and 55 incorrect gap discrepancies among the supports that could have those discrepancies. The resulting discrepancy rates are 3.3 percent for restraint direction and 12.8 percent for gap, or a combined 16.1 percent for both. This rate indicates that the 79-14 inspectors performing the W package inspections were sufficiently trained to detect problems in restraint direction and in the related condition of incorrect gap. TVA also demonstrated that the nine supports identified as discrepant per the QA audit ( App. A, 5.0) were reviewed for their design adequacy and were found to be adequate (App. A, a 5.z). The evaluation team has reviewed TVA's rationale for not reinspecting the supports that were previously inspected under the plant-approved procedures without the use of detail support drawings. The following observations are made: a. The inspectors performing support inspections under l instruction MI-6.17A verified clearances around the pipe for supports with such design features. For example, the clearances are clearly noted on the walkdown isometrics 47K454-57, R1 (Pkg. #219W), l 47K431-56 R3 (Pkg. #27W), 47K450-201, R3 (Pkg. #127W), 47K450-203, R4 (Pkg. #161W), and 47K406-97, R1 (Pkg. #92W). b. The size of a pipe support component such as a snubber cannot be verified if a detail support drawing is not used for support inspections. However, TVA is in the process of verifying sizes for all snubbers (App. A, l 5.q, paragraph 4.4) under the instruction SMI-0-317-28 (App.A,5.aa). Therefore, this aspect of the support inspected under MI-6.17A without detail support drawings will be addressed. h 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 20 0F 35 c. Support configurations (including welds) that differ from the as-designed configurations would not be identified in an inspection walkdown where detail support drawings are not used. The critical aspect of a pipe support configuration is the welding between its various components. TVA's welding program has demonstrated that welding, in general, is acceptable. Af ter its inspection of pipe support welding, the NRC concluded (App. A, 5.bb, paragraph 2.0 "c") that ... the inspected welding activities were found to comply with the applicable specifications. Most of the identified weld deficiencies have been identified and evaluated as a result of the TVA reinspection effort. The deficient welds were determined to be adequate for the intended application...." With this critical aspect of pipe support configuration l being adequately addressed by TVA's Welding Program, the other aspects of the support configuration h~,. verification, if not performed, present very small risk of pipe support design inadequacies. The evaluation team is of the opinion that the significant attributes of a pipe support installation - - such as clearances, location, type, function, etc., - - have been verified by SQN for the inspection performed under MI-6.17A and under other programs performed subsequently. Therefore, reinspections of these supports under the pipe support enhancement program would not yield significantly different results. Unit 2, 79-14 Program. The inspection program for Unit 2 was performed in two phases. k.- 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 3.- PAGE 21 0F 35 Phase I. The Phase I inspection identified 2,064 discrepancies. They were categorized as follows: a. Construction Scope Discrepancies: A total of 589 discrepancies were of this category and were resolved by construction engineering and/or craftsmen. I b. Engineering Scope Discrepancies: The remaining 1,475 discrepancies were assigned to EN DES for resolution. Out of these, 727 discrepancies were piping related and 748 were pipe support related. Phase II. The Phase II inspections reported 658 discrepancies. The reason for this high number of discrepancies is that the inspectors were instructed to use neither acceptance criteria nor judgment to dismiss any deviation between the design document and the as-constructed condition. Of the 658 discrepancies, 296 were resolved by EN DES onsite engineers using existing acceptance criteria such as general S' construction specifications and other design documents. EN DES onsite engineers determined that of the remaining 362 discrepancies, 59 were also identified by Phase I inspections. These were already reviewed and evaluations made under the Phase I program. A " Discrepancy Report" (App. A, 5.n, Attachment 3) was written for each of the remaining 303 discrepancies and forwarded to EN DES Knoxville for further evaluation and resolution. EN DES evaluated and categorized these discrepancies as follows: o Nonsignificant o Significant o Potential for loss of pressure boundary TVA's review of the 303 discrepancies found that 298 were insignificant, 5 significant, and none had potential for loss of pressure boundary. 0429D (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 22 0F 35 Of the five discrepancies found to be significant, four had already been identified in Phase I and resolution had been addressed. (Apparently the onsite EN DES engineers overlooked the previous identification.) The one significant i and unresolved discrepancy was the f ailure to set a spring near a steam generator nozzle. A comparison of Phase I and Phase II inspection findings shows no new discrepancies with potential for loss of i pressure boundary. The evaluation team reviewed a sample of 11 discrepancy reports ( App. A, 7.k) identified by Phase II inspections. This review found clear documentation for the description of discrepancy; its categorization as significant, nonsignificant, or having a potential for loss of pressure boundary; resolution of discrepancy; and basis for engineering judgment. The overall assessment of TVA's IE Bulletin 79-14 program is fo, sunned up in the generic task force report "GPM-07-41" (Section 2.0) as follows: " Implementation adequacy, for the SQN 79-14 program, will be resolved by SQN-CAR-86-002-009. " Design calculations do exist for major discrepancies identified by the 79-14 orogram. In the majority of cases formal design calculations were not necessary and in those cases the design engineers provided evaluational comments based on technical judgment. " Design calculations or design engineers evaluational comments are documented in program packages in accordance with MI-6.17 and II-DS. l "The procedural mechanisms in place for SQN are acceptable." j The evaluation team concurs with this assessment. t a i 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER:- 1 (~ PAGE 23 0F 35 The NRC has arrived at the same assessment for TVA's IE Bulletin 79-14 program for Unit 2, as indicated in NRC letters to TVA ( App. A, 5.cc and dd). NRC conducted an unannounced inspection during June 2-4, 1981 and found that all inspections for IE Bulletin 79-14 program for Unit 2 were completed and approximately 87 percent of the required modifications were completed. NRC sampled four completed pipe supports for detail inspection and did not find any violations or deviations. Further inspection performed by NRC during August 6 - September 5,1981 included review by Region II piping specialists of TVA's IE Bulletin 79-14 program for Unit 2. On the basis of TVA's final report (App. A, 5.ee) and NRC's inspections, this bulletin was considered closed for Unit 2.. 9.2 ISSUES "c" AND "d" t The containment spray system at SQN consists of two containment spray headers and two RHR spray headers. The (V,"a piping extending from the refueling water storage tank to the containment spray headers and from the RHR heat exchangers to the RHR spray headers is also considered part of the containment spray system. The issue "c" raises a concern that the as-constructed piping configuration for this system does not agree with the as-designed configuration. To investigate the validity of this concern, the evaluation team reviewed all four spray headers and associated piping inside containment (four l isometrics) for an overall check of piping configuration and pipe support types and locations (three supports per isometric). A detailed check was performed on one inside containment and two outside containment isometries to ascertain piping configurations and types and locations of all pipe supports. The above review was performed using the following as-constructed isometrics and the corresponding as-designed isometrics: h 04290 (12/03/86)
s TVA EMPLOYEE CONCERNS REPORT-NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 f PAGE 24 0F 35 1 Design Calculation Design Isometric _ As-Constructed Isometric 0600104-01-01 0600102-01-01 A-7206,A-7207,A-7208(Unit 1) A-7481, A-7482, A-7483 (Unit 2) N2-72-01A 47K437-50 A-7204 (Unit 1) A-7479(Unit,2) N2-72-03A 47K437-51 A-7210 (Unit 1) A-7485 (Unit 2) Piping configuration was verified by) comparing the computer input data (from the piping analyses with the piping configuration of the as-constructed isometrics. Pipe support types and locations were verified by comparing the as-constructed and as-designed support detail drawings with the input data from the piping analyses. Ten as-constructed l isometrics and 59 pipe support detail drawings were reviewed. All 10 as-constructed isometrics were reviewed for presence of field welds as the CI's reference to " weld map" was interpreted te mean the lecations of such welds. It U should be noted that field wel') locations are not shown on the design isometrics. The only field welds that can be verified for locations are the welds for fittings (albows, tees, etc.), which were verified by comparing their locations with a fitting shown in the design isometric. The concern expressed in issue "d", that the containment spray piping was analyzed using Alternate Analysis method instead of Rigorous Analysis method, was investigated by the evaluation team as follows: Using TVA's list of rigorous analyses for the containment a. spray system, the boundaries of each analysis were identified on the flow diagram ( App. A, 5.ff) of this system. b. The portion of this system that was not analyzed by Rigorous Analysis method was reviewed to identify if Alternate Analysis method was used. c. Where Alternate Analysis method was used, it was examined if the analyzed piping meets the applicability of performing such analysis. O 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM ^ REVISION NUMBER: 1 PAGE 25 0F 35 The evaluation team identified two drain lines and two minimum flow pump recirculation lines of 2-inch diameter that were analyzed using Alternate Analysis method. The remaining piping greater than 1-inch-diameter was analyzed by Rigorous Analysis method. Further review of the design calculation for the 2-inch diameter lines determined that they are low energy lines and are thus eligible for Alternate Analysis method ( App. A, 6.d and 6.e). Alternate Analysis criteria also specify that 1-inch-diameter and smaller piping with operating temperatures below 650 F may be analyzed by Alternate Analysis method. The 1-inch diameter and smaller piping of the containment spray system was found to meet the temperature criteria. Findings: a. Unit 1. TVA's initial response to the NRC IE Bulletin 79-14 for SQN Unit 1 inadequately inspected pipe supports. To make these inspections satisfactory, TVA implemented additional plant-approved procedures such as MI-6.17, MI-6.17A, and ' g MI-6.17C. The Quality Assurance survey performed in February 1986 for Unit 1 IE Bulletin 79-14 program identified further discrepancies. The survey found that a large number of supports were not inspected because they were inaccessible and that inspections were performed without.using plant-approved procedures, i Two corrective action reports have been issued as a result of the QA survey. i TVA has undertaken a pipe support enhancement program to resolve these corrective action reports. Unit 2. TVA's program for SQN Unit 2 compliance with NRC IE Bulletin 79-14 comprises a Phase I and a Phase II. This program has been adequately performed per the respective i procedures. b. Resolution of discrepancies for the NRC IE Bulletin 79-14 program is properly documented, and calculations have been performed where required. O 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 g t PAGE 26 0F 35 c. Within reasonable tolerance, the as-constructed piping configuration for the containment spray system agrees with the as-designed configuration including pipe support types and locations. The field welds are appropriately shown in the as-constructed drawings, d. Most of the containment spray piping is analyzed by Rigorous Analysis method. The small portion of it that is analyzed by Alternate Analysis method is eligible for that application.
== Conclusions:== a. The concern that TVA's program for implementing NRC Bulletin 79-14 is inadequate was valid for the initial stages of the Unit 1 program. However, this program has been substantially improved and the concern is no longer valid. The concern is not valid for SQN Unit 2 because its Phase I and Phase II programs satisfy the requirements of IE Bulletin 79-14. b. The concern that design calculation documentation is lacking is not valid. Discrepancies resulting from IE Bulletin 79-14 -{lt< inspections are properly documented and calculations are provided wherever necessary. c. The concern that the containment spray piping and weld map do not agree with as-builts is not valid. d. The concern that Alternate Analysis method was used instead of Rigorous Analysis method is not valid since the Alternate Analysis was performed only where allowable by criteria. 10. CdRRECTIVEACTI,0h No corrective action is required. i 1 i 04290 (12/03/86) l l
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 I ( PAGE 27 0F 35 [ APPENDIX A i 5. DOCUMENTS REVIEWED RELATED TO THE ELEMENT: ? 3 a. TVA letter to NRC (Initial response to NRC IE Bulletin { 79-14), (Doc #A27 790907 010), (09/07/79) I b. NRC letter to TVA,
Subject:
Notice of Violation, (Doc. #A02 800523 010), (05/21/80) c. NRC letter to TVA,
Subject:
Confirmation of Action, (Doc. # NEB 80 0519 265), (04/29/80) d. TVA letter to NRC,
Subject:
Confirmation of Action for IE Bulletin 79-14, (Doc. #A27 80050 016), (05/06/80) p
- i e.
Maintenance Instruction MI-6.17 " Instructions for the Implementation of NRC IE Bulletin 79-14," Rev. 2, (05/13/80), f Rev. O, (04/29/80) b b f. TVA letter to NRC,
Subject:
Additional Information on infraction, (Doc. # NEB 80 0702 266), (06/27/80) I[f g. Maintenance Instruction MI-6.17A " Instructions for the Implementation of Isometric Walkdown," Rev. 3, (01/02/81), [ Rev. O, (07/08/80) I h. Maintenance Instruction MI-6.17C " Procedure for the f Implementation of NRC IE Bulletin 79-14 requirements for Unit } l Alternately analyzed safety related piping, 2-1/2 diameter and larger." Rev. 1, (8/20/82), Rev. 0, (01/12/82) t i. Maintenance Instruction MI-6.18 " Instructions for review of isometric walkdown discrepancies, Technical Specification application and initiation of EN DES recormiended corrective action." (Sampling program, i.e., Bulletin 79-14), Rev. O, (7/21/80) I j. Memo from R. O. Barnett to R. W. Cantrell,
Subject:
Seq uoyah Nuclear Plant Unit 2 - Program Plan for IE Bulletin 79-14, (Doc. Control # CEB 801020 003), (10/20/80) ? = 04290 (12/03/86) l
d TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 i' PAGE 28 0F 35 i Appendix A (Cont'd) j k. Inspection of Piping and Supports - Isometric Walkdown i Procedure No. SQN-80-04, SQN Unit 2. Phase I, (10/20/80) j 1. Walkdown inspection procedure No. SQN-80-09 for Alternately Analyzed Piping, (10/20/80) Inspect' ion Procedure Phase II, SQN Unit 2, " Procedure for the [ m. L Implementation of NRC-01E Bulletin 79-14" Rev.1, (03/06/81), Rev. O, (02/20/81) n. Procedure for the Implementation of NRC-01E Bulletin 79-14 L " Discrepancy Evaluation Criteria Phase II", Rev. 2, [ (05/21/8':), Rev. 0, (02/20/81) I o. Compliance visits, Audits, and Inspections - Inplant Survey [ Check List No. 21-86-S-005, 79-14 Hanger Review Program, (02/28/86) p p. Memo from H. L. Abercrombie to W. E. Andrews,
Subject:
l I V Corrective Action Report (CAR) CAR-86-02-009 Hanger Deficiencies, (Doc. Control #S01860721936), (07/23/86) i j q. Memo from H. L. Abercrombie to W. E. Andrews,
Subject:
Corrective Action Report (CAR) SQN CAR-86-02-009 Hanger b Deficiencies, (Doc. Control #S00 860926 803), (09/26/86) V ( r. Memo from D. C. Craven to H. L. Abercrombie,
Subject:
Escalation of Corrective Action Report (CAR) J{ SQ-CAR-86-02-009, (Doc. Control #S08 860527 832), (05/27/86) s. Memo from D. C. Craven to R. W. Olson,
Subject:
Initial Response to SQ-CAR-86-02-009, (04/02/86) I t. Memo from R. W. Olson to D. C. Craven,
Subject:
Initial Response to SQ-CAR-86-02-009, Deficiencies in 79-14 Hanger Program,(03/28/86) u. Memo from W. E. Andrews to L. D. Alexander,
Subject:
r SQ-CAR-86-02-009, (06/12/86) 6, v. Memo from R. W. Olson to W. E. Andrews,
Subject:
Corrective l Action Report No. SQ-CAR-86-02-009-79-14 Hanger Program, (07/08/86) O f 04290 (12/03/86)
8 + TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 29 0F 35 Appendix A (Cont'd) w. Handwritten note from Mike Stitt to Doug (Craven), (07/15/86) x. Memo from R. W. Olson to D. C. Craven,
Subject:
Corrective L Action Report (CAR) No. SQ-CAR M -009-79-14 Hanger i Prtvam, (07/16/86) i i y. Special Maintenance Instruction, SMI-1-317-24, " Pipe Supports Enhancement Inspections EDS Isometric Drawings for Inside Containment and Supports Previously Identified as Inaccessible" Unit 1, Rev. 0, (5/2/86) z. Memo from J. P. Vineyard to H. B. Rankin,
Subject:
Review of Nine Reinspections of 79-14 Hanger Inspections, (Doc. Control
- 825 860213 001), (02/13/86) aa.
Spectal Maintenance Instruction, Collection of Name Plate Data for Mechanical Snubbers, Units 1 and 2, SMI-0-317-28, R0,(04/15/86) h' s bb. NRC letter to TVA,
Subject:
Report Nos. 50-327/86-33 and 50-328/86-33, (NRC Welding Team Inspection Report)(08/26/86) cc. NRC letter to TVA,
Subject:
Report No. 50-328/81-27 (NRC inspection of Unit 2 IE Bulletin 79-14 program completion), (07/16/81) j dd. NRC letter to TVA,
Subject:
Report Nos. 50-327/81-32 and { 50-328/81-42 (Clouser of IE Bulletin 79-14 for Unit 2), i (10/18/81) ~ v ee. TVA letter to NRC,
Subject:
Office of Inspection and Enforcement Bulletin 79 RII: JP0 50-328 - Sequoyah Nuclear Plant Unit 2, (Final Response to IE Bulletin 79-14), l (A27 810709 005), (07/09/81) ff. Flow Diagram, Drawing No. 47W812-1, Rev. 12 (06/11/85) gg. SNP Construction Procedure No. P-47, Addendum No.1 " Pipe and Pipe Hanger Analysis Drawing Walkdown Inspection," Rev.1, S (01/30/81), Rev. O, (10/27/80) 1, (01/17/81) ping and Supports, Rev. O, (10/27 hh. SNP Inspection Instruction No. D5 " Pi Walkdown Procedure" Rev. G [. 04290 (12/03/86)
..~ -i TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER:' 1 ( PAGE 30 0F 35 Appendix A (Cont'd) 11. Discrepancy Resolution Procedure, SQN-80-01, Rev. 1, (07/18/80) jf. Isometric Walkdown Procedure, SQN-80-02, Rev.1, (07/18/80) kk. Guidelines for evaluating 79-14 pipe configuration data packages, SQN No. 80-03, SQN Unit 1,(07/10/80) 11. Sequoyah Nuclear Plant Unit 2, Program Plan for I.E. Bulletin 79-14(PhaseI),(10/20/80) mm. Sequoyah Engineering Procedure SQEP-20, " Procedure for Processing, Evaluating, and Resolving Discrepancies found during Inspections per SMI-1-317-24, Rev. 0, (6/5/86) nn. Memo from C. R. Brimer to W. E. Andrews,
Subject:
Corrective Action Report - (CAR) SQ-CAR-86-034, (Doc. Control #S01 860715 926), (07/15/86) oo. Memo from M. N. Sprouse to G. H. Kimmons,
Subject:
Seq uoyah Nuclear Plant Unit 1 and Implications for all Nuclear Plants - NRC OIE Bulletin 79 Inspection Findings, (Doc. Control
- CEB 800703 029), (07/03/80) pp.
SNP Inspection Instruction No. 63, " Piping Inspection," R4, (08/22/78) qq. Sequoyah Nuclear Performance Plan - Draft of Volume II, R1, (07/14/86) rr. Design isometric drawings by EDS Nuclear (NOW impell): 0600102-01-01, Rev. 913 0600102-01-02, Rev. 914 0600102-01-03, Rev. 911 0600102-01-04, Rev. 911 h 04290 (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 31 0F 35 APPENDIX A (Cont'd) ss. TVA - SQN isometric drawings: 47K406-57, Rev. 5 47K406-58, Rev. 3 47K435-50, Rev. 5 47K435-51, Rev. 3 47K435-53, Rev. 6 47K437-50, Rev. 4 47K437-51, Rev. 5 47K437-52, Rev. 3 47K437-53, Rev. 3 47K437-54, Rev. 2 47K437-55, Rev. I tt. As-constructed drawings by National Valve and Manufacturing Co., TVA Contract #71C33-92615: g"?j A-7479, Rev. 2 A-7204, Rev. 5 W A-7481, Rev. F2 A-7206, Rev. 3 A-7482, Rev. F4C A-7207, Rev. 5 A-7483, Rev. R2 A-7208, Rev. 3 A-7485, Rev. F4B A-7210, Rev. 6 uu. As-designed support detail drawings by Chicago Bridge & Iron Company for the problem #0600104-01-01: CB&I 69-5545-74, Rev. 901 l CB&I 69-5545-75, Rev. 906 l CB&I 69-5545-87, Rev. 903 CB&I 69-5546-309 Rev.1 CB&I 69-5545-310 Rev. 2 CB&I 69-5545-311 Rev. 2 l i CB&I 69-5545-312 Rev. 1 l CB&I 69-5545-305 Rev. 4 CB&I 69-5545-307 Rev.1 CB&I 69-5545-308 Rev. 2 CB&I 69-5545-313 Rev.1 CB&I 69-5545-314 Rev. 2 l $ i 0429D (12/03/86) {
TVA EMPLOYEE CONCERNS REP 3RT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 ( PAGE 32 0F 35 APPENDIX A (Cont'd) vv. As-constructed and/or as-designed support detail drawings by Basic Engineers for the problem #0600104-01-01: j DWG. # REV. DWG. # REV. DWG. # REV. 1-H21-1 2 1-H21-7 4 1-H21-30 1 3 1-H21-2 2 1-H21-14 4 1-H21-31 2 1-H21-3 2 1-H21-15 4 1-H21-32 1 1-H21-4 2 1-H21-16 4 1-H21-33 1 1 -H21 -5 6 l-H21-17 5 1-H21-6 3 1-H21-18 7 ww. As constructed and/or as-designed support detail drawings by Basic Engineers for the problem #N2-72-01A: i DWG. # REV. DWG. # REV. DWG. # REV. 2-H21-409 1 2-H21-412 3 2-H21-415 1 p" 2-H21-410 1 2-H21-413 1 2-H21-411 4 2-H21-414 1 xx. As-constructed and/or as-designed support detail drawings by j Basic Engineers for the problem #N2-72-03A: DWG. # REV. DWG. # REV. DWd.# REV. 2-H21-416 903 2-H21-424 1 2-H21-432 1 i 2-H21-417 1 2-H21-425 1 2-H21-433 1 2-H21-418 2 2-H21-426 1 2-H21-434 1 g 2-H21-419 1 2-H21-427 1 2-H21-435 1 2-H21-420 2 2-H21-428 1 2-H21-436 1 l 2-H21-421 2 2-H21-429 1 2-H21-437 1 } 2-H21-422 2 2-H21-430 1 2-H21-438 1 2-H21-423 3 2-H21-431 2 2-H21-439 2 l yy. EDS piping analysis calculation 0600104-01-01 (inside containment), (10/19/79) zz. TVA piping analysis calculation N2-72-OlA (outside containment),(06/06/81) C 04290 (12/03/86) L
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUM8ER: 1 PAGE 33 0F 35 APPENDIX A (Cont'd) aaa. TVA piping analysis calculation N2-72-03A (outside containment),(04/24/80) bbb. List of calculations performed by rigorous analysis for containment spray system, received on 06/26/86 ccc. CEB 76-5, Section 2.1, alternate analysis criteria of Watts Bar Nuclear P1 ant, R3, (06/13/83) ddd. CEB 80-5, Section 2.3.2, alternate analysis criteria of Sequoyah Nuclear Plant, R1, (06/24/75) eee. Alternate analysis review program, #SQN-AA-001, of Sequoyah Nuclear Plant (07/1/86) fff. Alternate analysis calculation #N2-72-A-301A of the Containment Spray System, (07/25/86) h 6. WHAT REGULATIONS, LICENSING COMMITMENTS, DESIGN REQUIREMENTS, OR OTHER APPLY OR CONTROL IN THIS AREA? a. NRC IE Bulletin 79-14 b. App. A.S. e. g, h, i, k, 1, m, n, y, gg, hh, ii, jj, kk, 11, mm c. Sequoyal Nuclear P1 ant rigorous analysis handbook d. CEB 76-5, Alternate analysis criteria of Watts Bar Nuclear Plant i e. CEB 80-5, Alternate analysis criteria of Sequoyah Nuclear l Plant f. SQN-AA-001, Alternate analysis review program of Sequoyah Nuclear Plant b l 0429D (12/03/86) i L
4 TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 \\ PAGE 34 0F 35 APPENDIX A (Cont'd) 7. LIST REQUESTS FOR INFORMATION, MEETINGS, TELEPHONE CALLS, AND OTHER DISCUSSIONS RELATED F0 ELEMENT. r a. RFI #SQN-516, (08/28/86) b. RFI #SQN-551, (09/10/86) c. RFI #SQN-578, (09/22/86) d. RFI #SQN-614, (10/03/86) e. RFI #SQN-627, (10/09/86) f. RFI #SQN-631, (10/13/86) g. RFI #SQN-636, (10/15/86) h. RFI #SQN-643, (10/17/86) { 1. RFI #SQN-646, (10/20/86) j. RFI #SQN-654, (10/22/86) k. RFI #SQN-663, (10/28/86) 1. RFI #SQN-665, (10/29/86) l m. RFI #SQN-682, (11/03/86) n. RFI #SQN-697, (11/06/86) o. RFI #SQN-706, (11/11/86) p. RFI #SQN-714, (11/14/86) q. TVA Transmittal #140, (10/28/86) Telecon between S. Chitnis (Bechtel) and N. Liakonis, 0. ' r. Hafley, J. Beasen, W. Smathers (TVA) IOM #305, (10/08/86) s. RFI #SQN-523, (08/29/86) b 0429D (12/03/86)
TVA EMPLOYEE CONCERNS REPORT NUMBER: 212.2(B) SPECIAL PROGRAM REVISION NUMBER: 1 PAGE 35 0F 35 APPENDIX A (Cont'd) t. RFI #SQN-532, (09/09/86) I u. RFI #SQN-604, (09/29/86) v. RFI #SQN-606, (10/01/86) w. RFI #SQN-698, (11/06/86) x. RFI #SQN-732, (11/20/86) y. Telecon between S. Chitnis (Bechtel), and N. Liakonis, D. Hafley (TVA) (11/19/86) z. Telecon between S. Chitnis (Bechtel), and D. Hafley (TVA), (11/25/86) aa. RFI #SQN-735, (11/24/86) bb. Telecon between S. Chitnis (Bechtel), and N. Liakonis, D. Hafley, L. Ketcham (TVA), (12/03/86) G 0429D (12/03/86)
. ~.. _. - m, y __---_.%..,-.,__-m,,, m. _- 't Ill O ~' ) ' TENNESSEE VALLEY AUTHORITY PAGE-76 REFERENCEi - ECPS120J-ECPS121C FREQUENCY..- REQUEST ~ . _ijt._. .. OFFICE OF NUCLEAR PONER RUN TIME - 12:57:19 b ONP --ISSS- ;RWi -: .-/ s-ew+ -- EMPLOYEE-CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 12/02/86 LIST OF EMPLOYEE CONCERN INFORMATION CATEGORY: EN DES PROCESS & OUTPUT SUBCATEGORY: 21202 NRC BULLETIN 79-14, ABR PROGRAM O S GENER1t: KEYHORD A H _ APPL QTC/NSRS P KEYNORD B CONCERN SUB - R PLT _ 555H INVESTIGATION-S CONCERN KEYWORD C NUMBER CAT ' CAT -D LOC ~ F ' L' 9. B ' REPORT R DESCRIPTION KEYHORD D IN 027-001-EN ~ '21202 N HBN YYYT~ ~I SR TVA PROGRAM FOR IMPLEMENTING HRC BUL DESIGN PROCESS T50010 K. FORM ~~ ~ ~ ULATION DOCUMENTATION IS LACKING ENGINEERING LETIN 79-14 INADEGUATE. DESIGN CALC SPECIFICATIONS .O eleE ~ SQN-86-002-002 EN 21202 N SON YYYY SS DURING THE EXIT INTERVIEH THE CI STA O K-FORM,_. i TED THAT CONTAINMENT SPRAY LINE PIPI ~ NG DRANINGS AND HELD MAP DO NOT AGRE -TC E HITH THE AS-BUILTS. ALTERNATE ANA LYSIS HAS USED INSTEAD OF RIGOROUS A O NALYSIS, DANINGS HERE NOT CORRECTED. 2 CONCERNS FOR CATEGORY EN SUBCATEGORY 21202 O = g.y. g( w e m ~. >- O ~ O' 9 3-n ' - ~ ~ i O 7 = ~ m.s__ +. .a== -/: i-: O e l O O -~ fl.. C' ~"' 8 L;. W., l ' _. _ \\ \\ \\. _ _ -___. _ _.. _ _ _ _ _ _ __, , ~ _.-. _,m.. . - - -}}