ML20207P922

Rev 4 to Insp Program Scope, Element Rept

ML20207P922
Person / Time
Site:	Sequoyah
Issue date:	01/09/1987
From:	Akeley W, Barlow D, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207P893	List: ML20207P892 ML20207P895 ML20207P900 ML20207P903 ML20207P907 ML20207P910 ML20207P913 ML20207P916 ML20207P922 ML20207P926
References
80205-SQN, 80205-SQN-R04, 80205-SQN-R4, NUDOCS 8701200408
Download: ML20207P922 (6)

Text

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, 4 TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80205-SQN REPORT TYPE REVISION NUMBER:

Element Report- 4 TITLE: PAGE 1 0F 4 Inspection Program Scope PEASON FOR REVISION: Rewritten to comply with Writer's Guide and Incorporation of any SRP and TAS comments and-elimination of a concern.

Revision indicators are not shown on each page as the reformating entailed a complete rewrite.

Note: Sequoyah Applicability Only -

PREPARATION PREPARED BY: G. ARLOW JL

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[WWNY /-d-8f SRP : [~O~ 87 SIGNATURE DATE IGNATURE* DATE APPROVED BY:

h[ / /4"N N/A DATE ECSP MAMGER DATE MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL hD DO 5 0 27 REPORT ONLY)

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• SRP Secretary's signature denotes SRP concurrences are in files.

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TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80205-SQN REPORT TYPE REVISION NUMBER:

Element Report 4 TITLE

• PAGE 2 0F 4 Inspection Program Scope 1.0 CHARACTERIZATION OF ISSUE 1.1 Introduction The issue described below was derived from an Employee Concern generated as a result of the Watts Bar Employee Concern Special Program. This issue was determined to be site specific to the Sequoyah Nuclear Plant (SQN).

1.2 Description of Issue The basic issue raised by the concern is that Turbine Building non-code piping did not receive quality inspections. Inspection was performed by the foreman. (XX-85-007-003) 2.0 Sm{HARY 2.1 Summary of Characterization of Issue The issue raised by the concerned employee suggests that non-code piping for the Condensation, Heater Drain, Feedwater and Auxiliary Feedwater Systems was not inspected by QC and the only inspection that was performed was done by a foreman.

2.2 Summary of Evaluation Process The upper tier TVA Topical Report and Nuclear Quality Assurance Manual (NQAM) and lower tier procedures and instructions were reviewed to determine that appropriate requirements and responsibilities, along with procedural direction were provided to control the activities associated with the issues. Other quality documents such as drawings, inspection reports, correspondence, and Nonconformance Reports (NCRs) were also reviewed and discussions were conducted with TVA personnel to determine the extent of the concern and its significance.

After the criteria were established an evaluation was made to determine if the issue could be substantiated.

2.3 Summary of Findings

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In the issue of turbine Building non-code piping it was determined that the concerned employee meant non-CSSC piping as opposed to non-code piping, s ir.c a " a fi '">iping is fabricated / installed to established codes. Some codes pertain to CSSC systems and others to non-CSSC or non-critical piping systems.

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_TVA EMPLOYEE CONCERNS REPORT NUMBER:

SPECIAL PROGRAM 80205-SQN ,

REPORT TYPE REVISION NUMBER

Element Report 4

-TITLE: PAGE 3 0F 4 Inspection Program Scope It was found that the . piping in question did receive inspection coverage and these inspections were adequate as evidenced by review of selected inspection reports. Thus, the concern is unsubstantiated.

3.0 EVALUATORS W. M. Akeley.

D. G. Barlow 4.0 EVALUATION PROCESS 4.1 General Methods of Evaluation The evaluation process consisted of a research of the Employee Concerns files, the Quality Technology Corporation Employee Response' Team (ERT) files, and Nuclear Safety Review Stsff (NSRS) files, and reviews of the TVA Topical Report and NQAM to determine inspection requirements and commitments. Engineering documents were reviewed to determine system classification along with other quality documents to determine the extent of the issues raised. No investigative reports

.by ERT or NSRS were located.

Interviews were conducted and reviews of lower tier procedures and

' instruct. ions were also performed together with the codes applicable to the fabrication of piping systems.

A . listing of all documents reviewed during the investigations and evaluations of the issues making up this Element Report is included as Attachment B.

4.2 Specifics of Evaluation Issue -- Turbine building non-code piping did not receive quality inspections.

A review of the Sequoyah Non-Critical / Critical Systems Listing was performed to determine if TVA classifies those piping systems referenced in the concern as non-safety related, to determine the applicability of the QA Inspection Program requirements. Selected flow diagrams were researched as they relate to the feedwater system since portions of the system were considered CSSC piping which require a complete piping / welding inspection. This also encompassed a review of the applicable code (American National Standards Institute ANSI B31.7, 1969 Edition, Winter 1970 addenda). The code of record was substantiated by reviewing the Construction Specification N2M-863 which also determined the responsibility and requirements for inspection of the piping systems in question.

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o TVA EMPLOYEE CONCERNS REPORT NIRIBER:

SPECIAL PROGRAM 80205-SQN REPORT TYPE REVISION NUMBER:

Element Report 4 TITLE: PAGE 4 0F 4 Inspection Program Scope 5.0 FINDINGS Findings on Issue --

Turbine building non-code piping did not receive quality inspections.

Discussion A review of the Non-Critical / Critical Systems Listing, Appendix A, of SQA-134, indicated that the Condensate System, Heater Drains and Vents System, and portions of the Feedwater and Auxiliary Feedwater Systems, given as examples in the concern, were determined to be non-safety related and were not subject to the provisions of the TVA Quality Assurance Inspection Program. However, these systems receive on a random basis, inspection by the foreman or construction craft personnel or both which is specified in the NQAM. For those portions of the Feedwater and Auxiliary Feedwater System which are considered critical, a review of the series 47W803 flow diagrams further revealed that complete piping / welding inspections are required and had been completed. Inspection reports of non-CSSC systems were also reviewed indicating that informal inspections were performed by construction on randomly selected welds, further substantiating the fact that even though the systems do not require formal inspections, they were inspected by the foreman or construction craft personnel or both on a t random basis.

Conclusion The issue of non-code (non-CSSC) piping not receiving quality cuntrol inspections is true. As sts*ed above, noncritical systems do not require formal QC inspections to be performed in accordance with Code requirements. They do, however, receive randomly selected inspections by the foreman or craft personnel or both. Based on the fact that procedures have been developed for non-CSSC piping and specific requirements are well defined regarding non-CSSC piping regarding the inspection requirements, the issue is unsubstantiated and no corrective action is necessary.

6.0 ATTACitMENTS A. List of Employee concern Information Subcategory 80205.

B. List of Documents Reviewed

.8 TENNESSEE VALLEY AUTHORITY PAGE -

REFEREr3CE - ECPSI20J-ECPSI21C RUN TIME - 13:8 FREQUENCY - REQUEST OFFICE OF fiUCLEA~2 P0HER O!;P - 1555 - Rict EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) RUN DATE - 10/3 LIST OF EMPLOYEE CONCERf3 INFORMATION CATEGORY: CA CA/CC PROGRAMS SUBCATEGORY: 80205 INSPECTI0tt PROGRAM SCOPE S GENERIC KEYWORD A H APPL QTC/t!SRS P KEYHORD B INVESTIGATION S CONCERN KEYl40RD C CONCERN SUB R PLT B B S II KEYit0RD D NUM3ER CAT CAT D LOC FLQ3 REPORT R DESCRIPTION 80205 N SQN NNNN "" ! ! :27 0:2- SS SEQUDYAH - TURBINE BUILDING NON-CODE INSPECTION XX 037-003 CA PIPING HAD ND QUALITY INSPECTION. PROCEDURES T50052 K-FORM q INSPECTED BY FOREMAN ONLY. EXAMPLE: QUALITY ile lP7* ~ CONDENSATION, HEATER DRAIN, FEEDWAT PIPE ER AND AUX.-FEED WATER SYSTEM, UNIT I & 2. C/I HAS NO FURTHER INFORMATI DN.

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ATTACHMENT B List of Documents Reviewed o Nuclear Quality Assurance Manual (NQAM) Part 1, Section _1-2, " Quality Assurance Manual Scope", Part I, Section 2.10, " Inspection".

o TVA Topical Report TR 75-1A, Rev. 7 o Standard Practices, SQA 134, Part V, Appendix A "Non Critical System List", Part II " Critical Structures, Systems, and Components (CSSC List)".

o . Site Quality Nuclear Procedure, SQNP Al-20, " Inspection Program".

o Modifications and Additions Instruction, M&AI-l'.

o Flow Diagram 47W-803, Series 1, 2, and 3, "Feedwater/ Auxiliary Feedwater Systema".

4-o American National Standard Institute, ANSI B31.7 1969 Edition, Winter 1970 addenda J

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