ML20207S470

Rev 2 to Pipe/Fittings Re Const

ML20207S470
Person / Time
Site:	Sequoyah
Issue date:	03/10/1987
From:	Bryant J, Russell J, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20207S465	List: ML20207S464 ML20207S467 ML20207S470 ML20207S473 ML20207S481
References
C017105-SQN, C017105-SQN-R02, C17105-SQN, C17105-SQN-R2, NUDOCS 8703190508
Download: ML20207S470 (14)

Text

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TVA EMPLOYEE CONCERNS REPORT NUMBER: C017105-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report)

TITLE: Pipe / Fittings as Related to Construction PAGE 1 OF 10 REASON FOR REVISION:

Revised to add concern WI-85-053-012 to this evaluation, Revision 1 incorporate Line Managements responses to CATDs, and finalize report.

Revised to incorporate NRC ccament-incorporated SQN's Revision 2 generic review of WBN NCR 6420 into corrective action portion of report.

i PREPARATION PREPARED BY:

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DATE CONCURRENCES l

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• DATE APPROVED BY: V I

% .6 IOk1 N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

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TVA EMPLOYEE CONCERNS REPORT NUMBER: C017105-SQN >

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 10 I. Introduction Three of the concerns identified at Watts Bar Nuclear Plant (WBN) relative to material substitutions and procedure violations within the mechanical areas were evaluated as potentially generic to Sequoyah Nuclear Plant (SQN). This evaluation will address the applicability of IN-85-211-002 to material substitutions as well as IN-86-282-004 and WI-85-053-012 to procedure violations at SQN. .

II. Summary of Perceived Problems t

The two areas of concern were:

a A. The Essential Raw Cooling Water (ERCW) system was installed using

. material other than the design specified stainless steel. _

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A B. Pressure tests were not applied on many NPP-1 ASME Code Data Forms 2

for containment penetrations. The penetrations were installed and hydrostatic test inspections were never verified and/or documented.

j III. Evaluation Methodology The evaluation was broken into two areas:

A. Material Substitution

} 1. Employee concern files, including Quality Technology Company 1 (QTC) expurgated files, were reviewed for any more detailed information and other repo*ts related to these concerns.

2. Nuclear Safety Review Staff (NSRS) Investigation Reports I-85-166-WBN and I-85-118-WBN were reviewed to determine if evaluation resaits were applicable to SQN.

3. WBN Element Report (Pipe / Fittings) of Employee Concerns Task Group (ECTG) Subcategory C017100 (Mechanical) was reviewed to determine if evaluation results were applicable to SQN.

4. Cognizant Division of Nuclear Engia.ering (DNE) Engineers over the SQN ERCW System Mechanical Piping Design Evaluation Team were interviewed to determine the original pipe design requirements and the existing pipe status.

TVA EMPLOYEE CONCERNS REPORT NIJMBER C017105JJQ I SPECIAL PROGRAM

/

, REVISION NUMBER . 2

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1 PAGE 3 0F 10 ,

III. Evaluation Methodology (Continued)

5. Marked up as-built drawinga of the 47W450-and 47W845-series were c-

zeviewed to determine physical status of pipes on the IRCW system inside the plent buildings.

6. Drawings for SQN, 17W302-series, were revicted to determine -

original design and as-built status of pipes on ERCW system yard

. piping.

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7. Cognizant Engineers in Civil Piping Analyets Groep SQN Project were interviewed to determine the status of the as-built analysis for ERCW system.

8. ECN L5009. ECN L6534, and ECN L6560 were reviewed to determine ERCW system piplag reqairements.

B. Procedure Violation G N

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1. QTC expurgated flies were reviewed for more detailed information. 5

2. WEN Report (Pipe / Fittings) ol'Emplojoe Concerns Task Group ,

(ECTG) Subcategory C017100 (l'echanica'1) was reviewed to 4

determine if evaluation results were'opplicable to SQN.

k 3. NCR 5609 and NCR 6420 were reviewed.for content, disposition.

and relevance to SQN.

4. Cognizant Engineer in ONP Codes and Standards unit for SQN was 7

Interviewed to determine status of NCR 6420 with regard to SQN.

! IV. Summary of Findings j A. Material Substitutions

1. Files and listings, including QTC expurgated flies, re6e.aled no additional information or reports.

2. The NSRS reports addressed concerns related to the ERCW piping. 4 '

system not being stainless steel, as required, at WBN. The i '

evaluation addressed the portion of the ERCW system between the Intake Pumping Station and the plant buildings. It was determined that this portion of the piping was always supposed to be carbon steel. The NSRS evaluation addressed the area of yard piping because the description given by the concerned individual (CI) was so vague and on another similar concern this was the area described. QTC had contacted CI for additional information, but CI gave no further information.

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I ?g TVIEMPLOYEECONCERNS REPORT NUMBER: C017105-SQN

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'%s s-SPECIAL PROGRAM REVISION NUMBER: 2

' PAGE 4 OF 10

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IV. Summary of Findings (continued) s

3. The WBN ECTG report evaluated the concern from the point of view

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that the area of concern was the ERCW yard piping from the Intake Pumping Station to the plant buildings. The yard piping was addressed because of the concern description within another concern (IN-85-211-001) by the same CI on a similar subject.

The ERCW system yard piping at WBN was originally designed as carbon steel andsves installed as carbon steel. The evaluation wasappliceq.etdSQN,sincetheERCWyardpipingsystemwasa similar desit,n. The SQN evaluation by the WBN ECTG included the ERCW system piping inside the plant buildings as an additional scope to the concern, because of the changes to that portion of

' 'A the ERCW system at SQN, to insure that all questions invol7ing b possible stainless steel versus carbon steel would be evaluated I,

relative to the ERCW system.

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4. The cognizant DNE Engineers are in the process of taking marked up as-built drawings 47W450 and 47W845-series and evaluating the actual as-built condition of the pipe versus design of ERCW

i system piping.

The ERCW system piping was originally designed and installed at SQN as carbon steel pips, both yard and plant buildings. The ggs plant was fuel 1caded and put into operation under the carbon

' steel design.

i t ECN L5009, RO was issued on February 24, 1981, requiring

) l* portions of ERCW system piping inside plant buildiags to be changed-out from carbon steel to stainless steel, because of core %slon problems exparienced by carbon steel piping in raw

wateryystents.

SQN implemented the ECN L5009 change on a piece meal basis as li outages and manpower permitted. The complete status of the pipe change-out was not adequately known. DNE had SQN modifications unit walk the system down and make a set of drawings depleting where the stainless steel pipe had been installed. The DNE mechanical pipe unit was in the process of evaluating the as-built piping.

DNE will istut at ECN in approximately two months to document the piping that,has been installed as stainless steel or carbon

' ' steel., Ihe ECN will also leave the pipe presently installed as carbon steel in its present configuration. Pipes that are to be changed-out to stainless in the future, will be initiated from a

- new ECN with a defined scope.

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TVA EMPLOYEE CONCERNS REPORT NUMBERg C017105-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 5 0F 10 IV. Summary of Findings (continued)

ECN 6534 and ECN 6560 have already been issued to document that part of ERCW system was left as carbon steel instead of replaced by stainless.

The 17W302-series ERCW system yard piping was not included in ECN L5009 and was never intended to be changed to stainlees steel piping.

5. Drawings of the 47W450 and 47W845-series with as-built piping marked up show that a large portion of piping remains as carbon

, steel.

6. Drawings for SQN, 17W302-series, show the original designed and as-built ERCW system yard piping was carbon steel.

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s 7. Cognizant engineers in the Civil Piping Analysis Group, SQN project used the marked up as-built drawings to perform the

, necessary analysis to qualify the as-built piping, whether i

carbon steel or stainless steel. The analysis performed thus far, has verified that the piping not changed-out on ERCW system

) can remain as carbon steel.

The ECN that will be issued by the SQN mechanical piping unit will incorporate all analysis performed by the Civil Piping

, Analysis Group. This ECN is not required for the restart of

. either cha? 1 or 2.

8. The above information was confirmed through a review of the change documentation.- ECN L5009 was initiated on February 24, y 1981, requiring the change-out of the carbon steel piping on the ERCW system to stainless steel for the majority of the system lines that were two inches and smaller. Other ERCW lines were 6 to be changed-out where system performance had deteriorated or calculations had indicated potential problems existed. ECN L5009 was intended to apply to plant building piping only, not yard ERCW piping. ECN L6534 was initiated on November 15, 1985, to resolve ERCW drawing discrepancies and remove rigorously analyzed piping from design drawings that had not yet been changed-out from carbon steel to stainless steel. ECN L6560 was initiated on December 18, 1985, to change ERCW supply piping to upper containment vent cooler to carbon steel. The piping previously had been designated to be changed from carbon steel to stainless steel on ECN L5009, but SQN had never actually made the change. The ECN L6534 and ECN L6560 were initiated to leave the pipe as carbon steel as originally designed.

l IVA EMPLOYEE CONCERNS REPORT NUMBER: C017105-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 6 0F 10 IV. Summary of Findings (continued)

B. Procedure Violation ,

1. The QTC expurgated files revealed no additional information.

2. The WBN ECTG Report C017105 evaluated the concerns of pressure tests not being applied on many NPP-1 ASME code data forms for containment penetrations and TVA not inspecting the welds at the time of system hydro. The evaluation found that two NCRs (NCR 5609 and NCR 6420) had been generated against the problem at WBN. The evaluation found that NCR 5609 was closed on a use-as-is basis and NCR 6420 was still open.

NCR 6420 is open pending arbitration between the NRC and TVA h relative to the acceptability of the unit 1 penetration welds I (use-as-is). The WSN ECTG evaluation applies to SQN with respect to the NCR's being generated at WBN and their possibly being applicable to SQN also.

3. NCR 5609 RO was initiated on April 27, 1984. It was written

. against applicable unit 1 and 2 penetrations at WBN. The NCR was written against primary containment vessel piping penetrations fabricated by the vendor, Tube Turns. The penetrations were fabricated according to ASME section III, class 2 requirements, but have et least one internal process l

piping weld that was not hydrostatically tested in accordance with NC-6000. NCR 5609 was dispositioned use-as-is and has been approved by all parties. NCR 6420. RO was in'itiated on October 28, 1985. It was written against unit 2 at WBN and includes

! thirty-two penetrations that had not been nonconforming on NCR 4 5609 because of the pressure tests not being performed at the

[ time of closing NCR 5609. NCR 6420 was dispositioned use-as-is, i but is still open pending final approval by NRC. NCR 6420 y provided recommendations for pressure testing the applicable

! penetrations and inspection of the welds in question. The weld, which neither TVA nor the vendor had hydro-tested, was a circumferential vendor weld hidden from view by the guard pipe.

I NCR 6420 was forwarded to SQN by a memorandum from the Chief of Nuclear Engineering to SQN Engineering Project Manager, (B45 86

< 0311 255) for SQN potential generic condition evaluation of a l condition adverse to quality that was identified on WBN. The evaluation for that potential applicability to SQN was forwarded to ONP SQN Codes and Standard Unit.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: C017105-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 10 IV. Summary of Findings (continued)

4. The cognizant Engineer in the ONP Codes and Standards Unit for SQN was in the process of performing an operating experierce review on the WBN NCR 6420. He had already determined that the condition does exist at SQN since the same vendor. Tube Turns, was the supplier and since the deficient criteria, with respect to hydrotesting the penetrations, was not identified until 1984. His evaluation is scheduled for completion by August 16, 19J6. An SQN NCR will be generated at that time as appropriate. NCR 5609 was being evaluated, along with NCR 6420, for generic applicability to SQN.

Conclusions

[t The concern relative to the ERCW piping required to be stainless

( A.

steel was partially accurate with respect to SQN. Portions of the A ERCW piping system within the plant buildings were changed from the original design of carbon steel to stainless steel on ECN L5009 in P

February, 1981. Some of the piping was changed-out as plant operations permitted. However, SQN DNE is in the process of analyzing the ERCW system as-built piping and initiating a new ECN d to leave the pipes as they now exist. The ERCW yard piping was originally designed and installed as carbon steel. Even though some d piping remains carbon steel, no problem exists with operations and safety of the plant.

B. Procedure' Violation

- The concerns relative to pressure tests not being applied on many NPP-1 ASME code data forms for containment penetrations was accurate 4, and generically applicable to SQN, as well as WBN. NCR 6420 and NCR 5609 were written against the problem at WBN and dispositioned

,. use-as-is, with NCR 5609 closed and NCR 6420 still open. The two 4 NCR's are presently being evaluated by the SQN ONP Codes and Standards Unit for disposition with regard to SQN. The evaluation was due to be completed August 16, 1986. SQN NCR's will be generated at that time as appropriate.

V. Root Cause A. The portion of the SQN ERCW system piping required to be stainless steel under the applicable ECN's was not changed from carbon steel because the design change had been initiated after the plant had gone into operation with the originally designed carbon steel piping. The plant operations restricted the ability to get all the changes made.

TVA EMPLOYEE CONCERNS REPORT NUMBER: C017105-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 8 0F 10 m Conclusions (Continued)

B. Procedure Violation ,

r Per the NCR root cause statements, the DNE Contract Engineering Unit failed to ensure that code requirements had been met on the DNE procured penetrations in question.

VI. Corrective Action The following corrective action plans (CAPS) were provided by line in management response to the CATDs as shown below.

t One corrective action; CATD 17105-SQN-01, item 1; was required prior to SQN restart. The remaining items were not restart activities.

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CATD 17105-SQN-01 j This was an SQN restart activity.

1. The seismic analysis has been revised to incorporate the Carbon E steel to stainless steel piping changes per ECM L5009. ONP (Me-h Nodifications) transmitted information to DNE on the partial f implementation of ECN L5009. This information was used to evaluate the effect of partial implementation on the seismic analysis and no problems were found. The information was not quality information;

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therefore DNE will ask that it be resubmitted as quality information. Differences fram the previous submittal will be i evaluated for effects on analysis. This will be done before restart.

This was not an SQN restart activity.

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{ 2. An ECN will be written to back out portions of ECN L5009 that were

1. ~ not implemented using the information from ONP. This will be a post-restart activity.

CATD 17105-SQN-02.

These three items were not SQN restart activities.

1. The design basis for SQN piping is USAS B31.1.0 - 1967. The use of a B31.7 was an enhancement at SQN in lieu of the applicable B31 Nuclear Code Cases N7, N9, and N10. The SQN FSAR Table 3.2.2-1,

" Summary of Codes and Standards for Components of the Sequoyah Nuclear Plant for Procurement prior to April 2, 1973", is currently being clarified in accordance with PIR SQNNEB8638 to more accurately reflect the SQN piping code requirements. ANSI B31.1.0 - 1967, paragraph 137.1, states, "Where a hydrostatic test is not practicable, an initial service leak test, a vacuum test, or 100

. l TVA EMPLOYEE CONCERNS REPORT NUMBER: C017105-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 10 VI. Corrective Action (continued) l l percent radiography of all welded joints in all-welded syst,em may be substituted." The penetrations were hydrostatically tested to the requirements as specified in G29M, process specification 3.M.9.1.

The welds in question wece given 100 percent radiography and a surface exam, either MT or PT, by Tube Turns. Although not required, the penetrations at SQN were N-stamped by Tube Turns.

2. The generic review of WBN NCR 6420 under the OER Program, SQA 26 Attachment 3. has been revised and completed. See Attachment B. lR2

3. When it was asked that SQNs corrective action plan be coordinated with BFN, BLN, and especially WBN; SQN responded in their CAP stating, "Each nuclear plant has a different code of record based on its construction permit date. Therefore, each plant has different code requirements it must follow. Watts Bar's code of record is ASME Section III, 1971, Summer 73 Addenda. SQN's code of record is USAS B31.1.0 - 1967. Since each plant has a different

$ design basis, each plant would have different CAPS. Therefore.

coordination of this issue with TVA's other nuclear plants is not e necessary."

r The first two items in SQN line managements CAP for CAID 17105-SQN-02 h as cited above were acceptable; however, the item three statement that

". . . coordination of this issue with TVA's other nuclear plants is not necessary," was not acceptable. The evidence to support this argument follows. WBN NCRs 5609 and 6420 documented a condition that was y potentially generic to all sites. Poten.ial Generic Condition 7 Evaluation (PGCE) memorandums were forwarded to each site. In response to this CAQ:

WBN has planned to rehydro the welds nonconformed by NCR 6420 and go to great lengths to inspect the subject welds (see memorandum B26 860429 014, Standefer to Wadewitz) during the hydros. This proposed corrective action was coordinated betwean DNE, DNC, and the ANI.

BLN responded promptly to their PGCE memorandum stating that the potential CAQ did not exist at BLN (memorandum B21 860325 001) since they were aware of the welds existence and had been inspecting these welds during applicable system hydros.

At the time of this evaluation, BFN had not yet performed their evaluation of this PGC.

SQN has now evaluated this PGC at their plant and determined that, upon revision of their FSAR clarifying the applicable Code of Record, the condition described in NCR 6420 does not exist at their plant.

- 1 TVA EMPLOYEE CONCERNS REPORT NUMBER: C017105-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 10 VI. Corrective Action (continued)

The root cause of this CAQ (NCRs 5609 and 6420) as cited by ENDES in NCR 5609 RO, section 10, was that " Design did not alert constructio'n of need to witness the unhydroed welds. Construction did not review the containment penetration data package prior to performing the system hydro to determine which welds needed to be included in the hydro inspection program". The generic evaluation of this root cause to TVA had not been performed. Only non concerted site evaluations of the CAQ itself (NCR 6420) were conducted as cited in section 7.2.5 of subcategory

. report 17100. SQNs CAP to CATD 17105-SQN-02 was accepted as-stated; however, the CAQ coordination issue has been identified and tracked by CATD 17105-NPS-01 as a corporate level problem. This CAID was issued as

! part of Construction Subcategory Report 17100, Mechanical.

I I

' VII. Generic Applicability k

A. Material Substitutions The concern was evaluated by the WBN ECTG to be generically applicable to SQN since WBN and SQN were practically identical i designs and that some piping had been changed to stainless steel.

$? The WBN ECTG does not consider the concern applicable to either l

Browns Ferry (BFN) and/or Bellefonte Nuclear Plant (BLN) due to the fact that the concern was limited to the yard piping at WBN. The

! BFN and BLN plant designs are both different. The BLN ERCW system

+ is still being constructed.

B. Procedure Violation The concerns were evaluated by the WBN ECTG and found to be i potentially applicable to SQN because the same vendor, used at WBN,

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supplied the containment penetrations without hydrostatic tests I and/or documentation.

l The concerns were evaluated by the WBN ECTG to be potentially generic to BFN and/or BLN as well.

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C017105-SQN, R2 Attachment A GENERIC APPL QTC/NSRS P SUB PLT BBSW INVESTIGATION S CONCERN CONCERN NO. CAT CAT LOC FL0B REPORT R DESCRIPTION 4

IN-85-211-002 CO 17100 WBN NNYY I-85-166-WBN SR ERCW lin'e was T50038 K-Form designed to be stainless steel however it is not.

IN-86-282-004 CO 17100 WBN YYYY SR Pressure tests were not applied on many vendor NPP-1 ASME code

, data forms for 3 containment penetrations.

The penetrations were installed and hydro tests were never verified and 2 documented.

, Additional Q information known to QTC, withheld to maintain confidentiality.

No further l information may be released.

J L Construction department g concern. CI has no further

, information.

N WI-85-053-012 QA 80203 WBN NNNY SR Buried penetratiens have vendor welds that were not inspected during hydro tests.

rl Construction y department concern. CI has no further information. No follow up required.

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~ Memorandum TENNESSEE VALLEY AUTHORITY To  :

W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant FRO 51  : H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant DATE  : February 5, 1987

SUBJECT:

SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 171.05 SQN - CONSTRUCTION CATEGORY - CORRECTIVE ACTION PLAN (CAP)

Reference:

My memorandum to you dated January 16, 1987 (S03 870115 803)

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. Attached is a copy of the Experience Review Evaluation for WBN NCR 6420 in accordance with my previously submitted CAP for Element Report

.j 171.05 SQN.

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p H. L. Abercrombie

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EVALUATION FDIM yg I A /l/

. b RETURN TO REGULATORY

/ LICENSING SECTION UPON CINPLETIDM FROM  : Supervisor. Regulatory Licensing Section DATE f.

~ .E . SusJECT: OPERATING EXPERIENCE REVIEW - ITEM kJ8eJ ^)d /M 4A

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P' lease review and evaluate the attached inforustion and answer the appropriate disposition statement

, below by supplying the appropriate inforwation. Please coordinate your response with the other b '

sections listed above. if necessary, and return this form to RLS by the above due date. Please

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' ~ coordinate any necessary due date extensions with RLS prior to them becoming overdue.

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3 :e 1. .I have reviewed the subject information ani no action is necessary because:

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2. I have reviewed the subject infomation and the following action is reeutred. A due date 4 . of should be placed in the OER data base for completion of this action.

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3. This OER item ts 10CFR50.49 related: Yes Y No (If yes. the EQ Coordinator will initial showing this response has been coordina wit.h him).

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ud.e - I-//Date-R7 Reviewer / Date Sectioh Supervisor c.Jb Disposttion statement reviewed g .A VN /rf, 121 E /

and concurred with:

! Regulatory Licens / Date INFO ONLY TO:

NOTE: (1) A copy of all completed Attachment 3 forms which are 10CFR50.49 related shall be sent to the Site EQ Coordinator.

(2) A copy of all completed Attactwnent 3 forms addressing WBN NCRs shall be sent to M.L. Jones.

Lead Nuclear Engineer. DSC-A. SON.

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2./aMe7 ATTACEME:'T A The desiCn basis for Sequoyah Nucle:r Plant (SQN) pipin; is

- USAS 331.1.0 - 1967 ne use of S31 7 was an er.hcncement at SQU in T 4 lieu of the applicable S31 Nuclear Coce C ::es 117, N9, and N10. The i ,Ta d # ~- ." M SAR p or m_ tfis currently being clarified in g yr* h g7 N accordance with PIR SON!'E38655 to = ore accurately reflect the SQN pipinC code requirements. ANSI D31.1.0 - 1967, paragraph 137 1, states, "Where a hydrostatic test is not practicable, an initial

.' service leak, test, a vacuum test, or 100 percent radiography of all

. , welded joints in an all-welded system may be substituted." The

.'1, "' ; , penetrations were hydrostatically tested to the require =ents as 1

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specified in G29ii, process specificction 3.M.9.1.

• The welds in question were Given 100 percent radio 5raphy and a surface exam, either W

. MT.or PT, by Tube Turns. Althouch not required, the penetrations at

.. ; . n. SQN were N-stamped by Tube Turns.

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