ML20207L046
| ML20207L046 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 12/30/1986 |
| From: | Owen D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20207K584 | List: |
| References | |
| C011106-SQN, C011106-SQN-R03, C11106-SQN, C11106-SQN-R3, NUDOCS 8701090602 | |
| Download: ML20207L046 (7) | |
Text
{{#Wiki_filter:. TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUNBER: 3 (FINAL REPORT) TITLE: Hanger Inspection Documentation PAGE 1 0F 6 REASON FOR REVISION: Revised to incorporate Senior Review Panel and Technical Assistance Staff comments and add concern XX-85-053-001. Revision 1 Revised to incorporate Senior Review Panel comments. Revision 2 Revised to incorporate Line Management response and finalize report. Revision 3 PREPARATION PREPARED BY:
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. TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN 1 SPECIAL PROGRAM l REVISION NUMBER: 3 PAGE 2 0F 6 I. INTRODUCTION -
This report addresses two concerns (XX-85-053-002 and XX-85-053-001) dealing with engineering evaluations on conduit and pipe supports. These concerns are specific to Sequoyah Nuclear Plant (SQN). II.
SUMMARY
OF PERCEIVED PROBLEMS The perceived problems addressed by this report are that engineering evaluations were not performed properly on pipe and conduit supports. The hardware was not always examined prior to the evaluation. Cases of* missing documentation were evaluated away, where 10 percent of the documentation was not found, inspections test were redone to the extent necessary to reach 10 percent. The timeframe for this was from 1978 to 1980. III. EVALUATION METHODOLOGY The evaluation methodology used for this element was: A. Reviewed NSRS Investigation Reports I-85-695-SQN and I-85-709-SQN which address the subject concerns. B. The following site procedures were reviewed:
- 1. TVA SQN Standard Operating Procedure (SOP) lR3 Number 551, Revision 3 " Review of Past Records" l
- 2. SNP-Construction Procedure Number P-24, Revisions 1, 2, 3 and 4, " Inspection and Test Status"
- 3. SNP-Construction Procedure Number P-8, Revision 13, " Quality Assurance Records" C. Reviewed hanger General Notes and hanger typical drawings.
D. Reviewed documentation for engineering evaluations on pipe supports and conduit supports. E. Interviewed six individuals involved with engineering evaluations in the subject time frame. (Four Construction engineers, two Quality Control inspectors)
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 3 0F 6 IV.
SUMMARY
OF FINDINGS A. The review of NSRS Investigation Reports I-85-695-SQN and I-85-709-SQN revealed that in the subject timeframe construction management revised procedures and instructions to utilize various computer programs as a method of indicating inspection, test, and operating status of plant features. This allowed engineering evaluations to be performed on inspections completed under previous procedures. These evaluations were based lR3 on the guidelines in S0P Number 551. l B. It was determined by reviewing site procedures for the subject timeframe:
- 1. In 1977 the SQN procedures and instructions were revised to utilize computer programs as the methods of indicating inspection, test, and operating status of plant features.
- 2. SNP Construction Procedure No. P-8, " Quality Assurance Records" Revision 13, required features that had been completed and inspected by previous procedures to be evaluated in terms of current inspection instructions. Where equivalent activities were performed the responsible engineering unit was to provide written justification to indicate satisfactory completion of the requirements. When current requirements differed from those in effect at the time of installation the feature was to be evaluated to determine its acceptability. Where evidence of satisfactory acceptance could be shown it was to be documented. When insufficient evidence existed the feature in question was to be noted as nonconforming.
- 3. Sequoyah Nuclear Plant S0P No. 551, revision 3, addresses IR3 engineering evaluations. This procedure was initially I issued in 1977 and sites three basic methods of performing engineering evaluations.
- a. Evaluation and acceptance of existing record - requires a written, signed evaluation attachment to record.
- b. Perform a reinspection and new documentation
- c. When a. or b. above will not satisfy requirements, an nonconformance Report (NCR) will be generated.
Revision 2 of this SOP was issued 11/28/78 this revision added a policy statement as attachment" F." This policy statement is shown below.
TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 4 0F 6 POLICY STATEMENT Structural Welds Structural welding on miscellaneous steel, protective devices, rupture restraints, and hangers and supports has been inspected and documented through the use of individual inspection records, los entries, notation on the item, and notation on the drawings. These records are not traceable to specific features or weld joints in all cases as required by the present program and in cases where documentation was not prepared, the record has been obliterated by subsequent painting. The program in effect at that time required verification of welding inspection before painting. In order to assure the required quality, such welds will be identified in lots and representative samples reinspected for fillet size, length and general appearance. The required II-75 inspections can then be satisfied by the methods described in SNP CP No. I-24. Expansion Anchors Some anchors are not traceable to a lot. Where this condition exists, areas may be divided into lots, total number of anchors counted, and compared to the records of anchors tested in that area. If the records show 10% or more of the total anchors have been tested, this is considered satisfactory. If less than 10% of the total was tested, then additional tests should be performed to achieve the 10% minimum. C. It was found by reviewing the Hanger General Notes and the hanger typical drawings that some supports with bolt anchor installations could have the bolt anchors deleted and be welded. Drawings 47A056-40A, Revision 0, 47A056-3, Revision 0, and 47A053-150 Revision 0 are examples of this type of optional installation. D. It was found by reviewing the documentation on engineering evaluations for 20 pipe supports and 20 conduit supports in the subject timeframe, that the following was used:
- 1. The evaluation was based on past documentation. The past documentation meets current requirements. In these cases the past documentation was with the evaluation attachment.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 5 0F 6
- 2. The evaluation was based on past documentation. The past documentation does not meet current requirements but is acceptable and satisfies licensing commitments. In these cases the past documentation was with the evaluation attachment.
- 3. The evaluation attachment contained a statement that indicated the basis for the evaluation was the policy statement on attachment F of SOP Number 551, or referenced a memorandum that was attached. This memorandum contained a statement similar to this policy statement in SOP 551. Past documentation was not always with these evaluations.
E. It was learned from the interviews that in the subject timeframe a group was formed at SQN that routinely performed engineering evaluations according to the procedures. Some of these evaluations were made for anchor installations as shown in D-3 above. These lR3 evaluations were made without visual examination of the hanger and examination of the hardware was not required. CONCLUSION Since this evaluation addressed more than one perceived problem below is a list of perceived problems and findings. Perceived Problem
- 1. Engineering evaluation were not performed properly on pipe and conduit supports, the hardware was not always examined.
Finding Engineering evaluations were done in accordance with site procedures. These evaluations were done to verify that the necessary inspections had been performed. Therefore this is not a problem. Perceived Problem
- 2. Cases of missing documentation were evaluated away, where 10 percent of the documentation was not found, inspections / test were only re-done to the extent necessary to reach 10 percent.
.' TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 6 0F 6 Finding Evaluations were done for bolt anchor inspections where the anchors were not traceable to a lot based on records showing 10% of the anchors in the area being tested. If less than 10% of the total was tested, then additional tests were performed to achieve the 10%
minimum. This was done in accordance with the policy statement in SOP-551 or a similar statement in a memorandum. Similar evaluations were used for welds. The adequacy of these evaluations needs to be addressed by line management. V. ROOT CAUSE Failure to implement a program to adequately control engineering evaluations. VI. CORRECTIVE ACTION The following is the Line Managements corrective action response. l l The corrective action is not a restart item. l lR3 DNE to provide evaluation to determine if evaluations performed by l construction in accordance with SOP-551 Attachment F were acceptable. l i l . CATD 11106-SQN-01, R1 l VII. GENERIC APPLICABILITY Based on the fact that the concerns addressed by this report are site specific and the evaluation identified that this occurred during program changes at SQN that were unique to SQN, there is no generic applicability. VIII. ATTACHMENTS Attachment A - List of Concerns
Att chment A Coll 100-SQN-g . S$ &
/2-IS-L CATEGORY PROCESS & CUTPUT SUBCATEGO'Y: R 11100 SUPPORT AS-3UILT DOCUMENTATION 5 GENERIC H APPL JTC/NSRS PI CONCERN SUB R PLT BB5W INVESTIGATION 5 CONCERN -
HUM 3ER CAT [L CAT D LOC FLQ3 REPORT R DESCRIPTION XX 053-002 CO- N N Y N- I-85-559-SQN NO SEQUDYAH- ENGINEERING EVALUATIONS FD DESIGN REVIEW T50164
- h.11100 N SQN .. R DOCUMENTATION MISSING 03 PIPE SUPP REPORT.1 g,.
NONCONFORMANCE 5, '- : - . . _ _ . ORTS AND CONDUITS SUPPORTS WAS NOT A HVAC
- LWAYS DONE PROPERLYs SOMETIMES THE REPORTS HARDWARE WAS NOT EXAMINED BEFORE THE
- EVALUATION WAS MADE. EG IN ONE CAS <
E, THE NRC FOUND A HANGER DOCUMENTED AS BOLTED, BUT IT WAS ACTUALLY WELD ED. (CI HAS NO MORE INFORMATION) UN
-- IT 1- 1978 TO 1980 CONSTRUCTION /ENGI -
HEERING - AUX, CONTROL & DIESEL GEN BUILDINGS. ND FOLLOWUP REQUIRED.
- XX 053-001 CO 11100 N SQN N.NY N I-85-709-SQN !.S T50167 K-FORM SEQUOYAH- DOCUMENTATION SAMPLING PLA RECORDS N FOR PIPE SUPPORTS AND CONDUIT SUPP PROCEDURES ORTS /WAS INADEQUATE: PLAN ALLOWED A OPERATIONS CCEPTING SYSTEMS WITH ONLY 10% OF TH SUPPORTS ELEC1 E ORIGINALLY REQUIRED DOCUMENTATION.
CASES OF HISSING DOCUMENTATION HER E."tVALUATED" AWAY. IN CASES WHERE
- 10% OF THE DOCUMENTATION WAS NOT FOU ND, INSPECTIONS / TESTS WERE ONLY RE-D DNE TO THE EXTENT NECESSARY TO REACN 10%. THE CI DOES NOT BELIEVE THIS WAS ADEQUATE, AND MIGHT NOT HAVE MET
' NRC REQUIREMENTS. (UNIT 1- 1978 TO
, , , , 1980. CONSTRUCTION ENGINEERING
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#PSR Codes .
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NS - Nuclear Safety Related . SS - Nuclear Safety Significant " , , . NO - Not' Nuclear Safety Related ,
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