ML20209C584

Rev 2 to TVA Employee Concerns Special Program:Box Hanger Weld Design Deficiency

ML20209C584
Person / Time
Site:	Sequoyah
Issue date:	01/23/1987
From:	Bateman R, Rose J, Russell J TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20209C049	List: ML20209C043 ML20209C311 ML20209C365 ML20209C389 ML20209C456 ML20209C507 ML20209C546 ML20209C584 ML20209C617 ML20209C635
References
I-85-560-SQN, I-85-560-SQN-R02, I-85-560-SQN-R2, NUDOCS 8702040298
Download: ML20209C584 (24)

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TVA EMPLOYEE CONCERNS REPORT NUMBER: I-85-560-SQN SPECIAL PROGRAN REPORT TYPE: Welding Project REVISION NUMBER: 2 TITLE: Box Hanger Weld Design Deficiency REASON FOR REVISION:

Revised corrective action plan - Attachment 5 SWEC

SUMMARY

STATEMENT: N/A PREPARATION PREPARED BY:

Original signed by R. M. Bateman 11-06-86 SIGNATURE DATE REVIEWS PEER:

Original signed by J. E. Rose 11-06-86 SIGNATURE DATE al frA TAS: p(I ' TECHNICAL REVIEW ONIX

$dhW SIGNATURE

/-N-97 DATE CONCURRENCES Original Signed By CEG-H: J. F. Lewis for LEM 11-25-86 SRP: w /* 23-U SIGNATURE DATE SIGNATURE

• DATE APPROVED BY Mukzed ECSP MANAGElt) i-es-s7 DATE NiA MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

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

2242T 8702040298 870127 PDR ADOCK 05000327 P PDR l

EMPLOYEE CONCERN

SUMMARY

SHEET Report Number: I-85-560-SQN Report

Title:

Box Hanger Weld Design Deficiency I. CONCERN CONSIDERED: XX-85-086-003 II. ISSUES INVOLVED

1. The Sequoyah 478100 series drawings show a butt weld on the rear plate of some seismic Class 1 supports that could extend to the pi pe .

2. Eight box anchors associated with ECN L6319, the detailed drawings for some of these anchors show welds that could extend to the pipe.

III. STATEMENT ON CONCERN / ISSUE VALIDITY Validity: Y X ,N , Substantiated: Y X ,N IV. EFFECT ON HARDWARE AND/OR PROGRAM

< None V. JUSTIFICATION -

Box anchors / support are fabricated and installed in accordance with design specifications, i

VI. REC 0mENDATION AND/OR CORRECTIVE ACTION NEEDED

1. Completion of. piping systems walkdown, containing those box anchors, and resulting corrective action under NCR 6264 VII. REINSPECTION NEEDED: Y ,-N X M l

! Page a l

l 3158T L . _ _ . . . _ _ . . .

Report Number: I-85-560-SQN VIII. ISSUE CLOSURE Closure based on this report

, IX. ATTACHMENTS

• f A. Approval sheet s 1. NSRS Report I-85-560-SQN

2. Text of employee concern XX-85-086-003 .

3. Summary of SQN specific employee concerns reviewed by WP

4. Program summarization of weld project (WP) evaluation

5. Corrective action plan b

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Attachment A WELDING PROJECT l SON SPECIFIC EMPLOYEE CONCERNS l l

DATE 11/6/86

SUBJECT:

SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -

SUMMARY

OF WP ENGINEERING EVALUATION CONCERN CONSIDERED: XX-85-086-003 PREPARED BY .

j ll /bf6 (o . DNC, WP REVIEWED BY \ .b - it:o . ll/ b/tia @ , DNC, WP REVIEWED BY .

WM ', #/!#0 85 , DQA, WP v c REVIEWEDBY[nmue/ Y. -Nual -

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• WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS 1

ATTACHMENT 1 NSRS REPORT I-85-560-SQN

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L*NITED STATES COVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY I

a' TO: C. C. Hason, Deputy Manager of Nuclear Power, LP6N37A-C FROM: K. W. Whitt Director of Nuclear Safety Review Staff, E3A8 C-K DATE: FEB 141906

SUBJECT:

CORRECTIVE ACTION RESPONSE EVALUATION REPORT NO. : I-85-560-SON SUBJECT  : BOK HANCER WELD DESIGN DEFICIENCY CONCERN NO.: II-85-086-003 (I) ACCEPT ( ) REJECT l We assume that the generic review will also address Browns Ferry and Bellefonte, Concern Numbers II-85-086-004 and II-85-086-002, respectively.

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. W. Whitt EFH:CDM ec (Attachment):

H. L. Abercrombie, SQU C. Bonine,12-108 SB-K -

R. P. Denise, LP6N40A-C W. C. Drotlefs, W12A12 C-K C. B. Kirk, SQN

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D. R. Nichols, E10A14C-K -

R..C. Parker, LP4N44A-C QTC/ERT, CONST-WBN E. K. Sliger, LP6N48A J. H. Sullivan SQN ,

Principally prepared by E. F. Harwell.

2/14/86--CDH.

cc (Attachment):

J. W. Coan, W9 Cl35 C-K i 'j F. E. Laurent, CEO-WBN

_;. Kent Therp, IOB-WBN kA4U L

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Memorandum TENNESSEE VALLEY AUTHORITY

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ati  : K. H. Whitt, Director of Nuclear Safety Review Staff. E3 A8 C-K FROM  : C. C. Mason, Deputy Manager of Nuclear Power, LP 6N 37A-C DATE  : January 23, 1986

SUBJECT:

NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT I-85-560-SQN - GENERIC APPLICABILITY TO WATTS BAR NUCLEAR PLANT g V- YT- o f 6 - 0 8.7 l-"'  :

Reierences: (1) Your memo to H. G. Parris dated November 29, 1985, " Nuclear Safety Review Staff Investigation Report Transmittal"

, y.) 7p ,' (2) Construction NCR 6264 R0 (B26 850925 010)

(3) Memo from R. O. Barnett to Those listed dated December 10,

, 1985 (B41 851210 004)

(4) Memo from J. W. Coan to G. Wadewitz dated September 25, 1985 (D26 850925 010)

This is in response to your request in reference 1.

~ ' '

~ ' ~7ri the subject report, reconsnendation I-85-560-SQN-02 stated that reference 2 should be reviewed for generic applicability by the Office of Engineering (OE).

Such a review was initiated by reference 3, even though at that time no programmatic requirement existed for OE to perform a generic condition review

' of NCRs developed by others. It should be noted that this review is also intended to address employee concern EX-85-039-003 of report I-85-541-WBN which apparently is a duplicate of th9 concern in the subject report.

It has been determined that NCR 6264 (reference 2) should be upgraded to significant. During OE review of NCR 6264, it was determined that the recommended Office of Construction (OC) disposition of use-as-is was not totally acceptable. Instead, each potential occurrence of rear plate weld fusing to the pipe needed to be evaluated on a case-by-case basis. A walkdown was initiated to. identify all occurrences for determination of need for corrective action. Since, at that time, no specific instances requiring repair or rework had been found nor had a generic condition been identified, it was not felt necessary to upgrade the NCR. During the walkdown and evaluation, only one instance of the'more than 100 potential occurrences was found to possibly require some corrective action. However, as a result of the generic applicability to other plants, action has been initiated to accomplish upgrading to process the NCR in accordance with program require-ments.

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K. H. Whitt January 23, 1986 1

--' NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT I-85-560-SQN- GENERIC APPLICABILITY TO WATTS BAR NUCLEAR PLANT The corrective action to initiate a generic condition review and completion of upgrading NCR 6264 to significant should resolve issues raised in recommenda-tion I-85-560-SQN-02. Completion of the corrective action in NCR 6264 should resolve the Watts Bar concern EX-85-039-003.

OE is in the process of making changes to Office of Engineering Procedure OEP-17 to require assessment of potential generic implications and followup review of OC and Site P&E (Nuclear) NCRs/SCRs submitted to OE for disposition-ing. The program is being further expanded to require a review for potential generic impilcations for all NCRs/SCRs initiated by OE, OC, and Site NUC PR that are deemed significant. The OC program includes provisions in Quality Assurance Procedure QAP 16.7 for identification and notification of potential generic conditions to various OC projects and sites.

The existing OC procedure and implementation of the OE programmatic changes should provide for identification and disposition of such generic conditions in i

the future.

) U WRD:MS cc: H.' L. Abercrombie, NUC PR, Seguoyah C. Bonine,12-108 SB-K W. R. Brown, 9-169 SB-K R. W. Cantrell, W12 A12 C-K R. C. Parker, LP 4N 44A-C QTC/ERT, Watts Bar Nuclear Plant 1/29/86--JTH cc: E. F. Harwell--For evaluation.

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CORRECTIVE ACTION RESPONSE EVALUATION REPORT NO: f- 8 f- B B - S M

SUBJECT:

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CONCERN NO: )(Y , PM 69 (" dd.3

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.'L*NITED STATES COVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY l

. TO  : H. G. Parris, Manager of Power & Engineering (Nuclear), MR6N011 B-C FROM  : K. W. Whitt. Director of Nuclear Safety Review Staff, E3A8 C-K DATE

NOV 2 9 1985

SUBJECT:

NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSHITTAL Transmitted herein is NSRS Report No. I-85-560-SON Subject BOX HANGER WELD DESIGN DEFICIENCY - SON Concern No. II-85-086-003 and associated prioritized recommendations for your action / disposition.

It is requested that you respond to this report and the attached Priority 2 [P2] recommendation by December 20 1985 . Should you have any questions, please contact R. C. Sauer at telephone 2277.

Recommend Reportability Detemination: Yes I No

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Director, NSRS/ Designee RCS:JTH Attachment .

ec (Attachment):

H. L. Abercrombie, SQN C. Bonine,12-108 SB-K R. W. Cantrell, W12A12 C-K G. B. Kirk, SQN R. C. Parker, LP4N44A-C QTC/ERT, Watts Bar Nuclear Plant J. H. Sullivan, SQN .

W. F. Willis, E12B16 C-K (4) i e~~ Run l' t tarhaus Rands Retrularly on the Payroll .Savines Plan

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') TENNESSEE VALLEY AUTHORITY 0-NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT NO. I-85-560-SQN EMPLOYEE CONCERN: II-85-086-003 l

SUBJECT:

BOK HANGER WELD DESIGN DEFICIENCY - SEQUOYAH NUCLEAR PLANT DATES OF INVESTICATION: OCTOBER 2-23, 1985 INVESTICATOR: -

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E.f.HARWELL REVIEWED BY: ccu.At /

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27[81 R. C. SAOER DAtE APPROVED BY: _M W // 29[8)

M. S. KIDD DATE O

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A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern as received by Quality Technology Company (QTC)/ Employee Response Team (ERT).

The concern of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as II-85-086-003, stated:

"Sequoyah: A design deficiency has a wrong weld required on box hangers which, if performed per design, causes the weld to run into the pipe (SS or carbon steel code pipe)."

The ERT follow-up group was contacted to see if any additional information was available that would indicate the location or system. QIC called back stating that the CI had indicated that the drawings in question were 47B100 sheets 2 and 4.

II. SCOPE A. The scope of the investigation was determined from the stated concern to be that of a singl'a specific issue:

e A butt weld if made as shown on the typical drawings, could extend to the pipe and result in the collar plate being

,I welded to the pipe eliminating the freedom of move- ment which the pipe should have.

B. NSRS reviewed generic drawings of the 47B100 series and those specific engineered drawings associated with ECN L6319. Cog-nizant personnel of Sequoyah Design Services and Hodifications Groups and the Knoxville Office of Engineering were inter-viewed. The associated construction specification and pro-cedure which governed the installation of seismic supports were also reviewed.

III.

SUMMARY

OF FINDINGS A. Requirements and Commitments l 1. Sequoyah FSAR, Section 3.7, " Seismic Design," and Section l 3.8, " Design of Category I Structures."

2. Sequoyah Design Criteria No. SQN-DC-V-13.3, " Detailed Analysis of Category I Piping Systems."

3. Sequoyah Design Criteria No. SQN-DC-V-1.3.3.1, " Additions

• After November 14, 1979 - Reinforced Concrete, Structural, and Miscellaneous Steel." =

4. General Construction Specification C-43, " Support and .

) Installation of Piping Systems in Category I Structures."

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J' B. Findinas

1. The Sequoyah 47B100 series drawings as designed, do show a butt weld on the rear plate of some seismic class I sup-ports that could extend to the pipe if made as the typical drawing specifies. Cognizant Design Services and Office of Engineering personnel (Individuals A, B, and C) identi-fled ECM L6319 (ref. 6) as the only application of seismic box anchors at Sequoyah which references the Sequoyah 47B100 series drawings for use.

2. There are eight box anchors associated with ECN L6319 (ref. 6) and only one has been installed. The detailed drawings for some of these anchors show welds that could extend to the pipe. The cognizant engineer (individual E) for the installation of these supports stated that on the installed anchor shown on drawing 47A491-3-6, a thin, approximately 1/8-inch land was left adjacent to the pipe prior to welding. When the plate was welded together, the thin land area was fused,together meeting the drawing configuration but not to the point that the weld extended j to the pipe. After completing the weld, the plate was checked to make sure it was free to move along the pipe.

, 3. Evaluation of the preparation for the remaining seven box 2 anchors indicates the preparation does not include the special precaution utilized by Sequoyah on the first anchor of placing a land adjacent to pipe to prevent extending the weld to the pipe.

4. A generic evaluation of this problem to WBN and BFN revealed:

a. A similar weld extension to pipe problem exists on sheet 4 of the Watts Bar generic drawings of the 47B100 series.

b. Browns Ferry has specific versus generic hanger draw-inss. An evaluation of these drawings reveals simi-lar weld extension to pipe configuration requirements specified on some drawings.

c. Though no hardware discrepancies were identified related to the inadequate drawing requirements, a generic deficiency exists whereby if the welding portion of drawings were followed verbatim, a noncon-forming condition would result with the clearance requirement of the same drawing.

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I l IV. CONCLUSIONS AND RECOMMENDATIONS A. The allegation'was substantiated by virtue of the fact that the )

typical drawings do show a weld configuration such that it could extend to the pipe when made. There is no concern related to the one installed anchor since special steps were l taken to prevent a problem.

B. I-85-560-SQN-01, FCR Revision Required to ECN L6319 Drawinas and 47B100 Drawina Series To assure that problems do not occur when installing the remaining seven anchors at sequoyah, the modifications cognizant engineer (Individual E) is processing FCRs to have the ECN and typical drawings revised for further clarifica-tion. The revised drawings will be included in the affected workplans. These corrective actions, when completed, will resolye the Sequoyah concern. NSRS will track this as an open '

.l_tgm. [P3] ,

C. I-85-560-SON-02. Nonconformance Evaluation for Box Anchor Welding Because of the generic aspects associated with box anchor weld-ing described in paragraphs III.B.3 and 4, a construction issued NCR 6264 dated August 24, 1985, for Watts Bar should be sent through design to the other plants for a generic review

! for applicability in accordance with Office of Engineering Procedure OEP-17 (ref. 9). [P2]

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DOCUMENTS REVIEWED IN INVESTIGATION I-85-560-SQN AND REFERENCES

1. Sequoyah drawing 47B100 series, 47B200 series 47A053 series notes.

2. ECN L6319 drawings 47A491-3-6, 47A491-68-5, 47A491-68-6, -6A, 47A491-68-7, -7A, 47A491-68-8, -8A, 47A491-68-9, 4A491-68-10, 47A491-79-3, -3A, all Revision 0, dated June 27, 1985

3. Sequoyah Desi8n Criteria SQH-DC-V-13.3, Revision 3 dated August 13, 1984, " Detailed Analysis of Category I Piping Systems"

4. SQN-DC-V-1.3.3.1, Revision 4, dated September 4, 1984, " Additions After November 14, 1979 - Reinforced Concrete, Structural, and Miscellaneous Steel"

5. General Construction Specification No. 43 Revision 8, dated August 8, 1985, " Support and Installation of Piping Systems in Category I Structures" ,

6. ECN L6319. " Relocate Sprinkler Head for Appendix R." Revision 0, dated January 24, 1985 (SQP 841218 005)

'.) : 7. BFN specific drawings

8. WBN 47B100 sheet 2 Revision 5, dated September 7, 1983, and 47B100 sheet 4, Revision 0, dated February 7,1978

9. Office of Engineering Proce' dure OEP-17. " Corrective Action," Revision 2, dated August 30, 1985 A

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EMPLOYEE' CONCERN ASSIGNMENT REQUEST TO: Director - NSRS TRANSMITTAL NUMBER T50147 ERT has received the Employee concern identified below, and has assigned the indicated category and priority:

priority: 1 Concern # XX-85-086-003 I-id T -Sho-540 Category: 33 Confidentiality: _YES _NO (I&H)

Supervisor Notified: _X_YES ___NO NUCLEAR SAFETY RELATED _YES_

Concern: Sequoyah: A dealgn deficiency has a wrong weld required on Box Hangers which, if performed per dealgn, causes the weld to run into the pipe (SS or Carbon Steel Code pipe). Construction dept concern. CI has no further information.

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'/ No followup required.

W & ~k _ ) / e- - _S E PDATE -

RtB5 MANAGER, ERT NSRS has assigned responsibility for investigation of the above concern to:

ERT ___

NSRS/ERT _____ .

NSRS ___ __ Q S l OTHERS (SpECIFY) _______________________________ ___________________

I Q _____9/2/2Y

" DATE

, NSRS i

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. 10/16/86 (EMPLOYEE CONCERNS) 11:23:55 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------

S 1 NSRS 00 SR XX-85-086-003

'WORDS: DESIGN BOX ANCHOR EXCESS WELD PROB: WDDDD SEQUOYAH: A DESIGN DEFICIENCY HAS A WRONG WELD REQUIRED ON BOX HANGERS WHICH, IF PERFORMED PER DESIGN. CAUSES THE WELD TO RUN INTO THE PIPE (SS OR CARBON STEEL CODE PIPE). CONSTRUCTION DEPT CONCERN. Cl HAS NO FURTHER INFORMATlON.

IR: 1-85-560-SON STAT: RC:

TECHNICAL COMMENTARY:

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Attechnent 3 Page 1 of 3

SUMMARY

OF SQN SPECIFIC EMPLOYEE CONCERNS REVIEWED BY WELDING PROJECT EMPLOYEE CONCERN NUMBER ISSUE WP ACTION II-85-088-003 Alterations to Welder Not substantiated by ERT Qualification Records in Report 11-85-088-003 of Knoxville 3/8/86 (Attachment 3).

II-85-124-001 Burial of Electrode Stubs Not safety-related. No action required.

II-85-086-003 Box Anchor Design Substantiated by NSRS Report Deficiency. I-85-560-SQN (Attachment ).

WP concurs with report recommendations.

II-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS

, j "' - Rejected NDE Items Report I-85-738-SQN (Attach-

"~"" ment 3). WP concurs with report recommendations.

SQM-5-001-001 Uncertified Walder Foreman Substantiated by WP Evaluation SQM-5-001-002 Performing Preweld Report WP-16-SQN (Attachment WBM-5-001-002 Inspections 3). Interim corrective (Also Listed in actions are being the Generic formulated. Closure is based on these actions.

Summary)

~ Additional corrective actions may be implemented.

l II-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS Piece REPORT I-85-636-SQN (Attachment 3).

II-85-069-001 Inadequate OJT-Records for The general issue of II-85-069-001-R1 ISI ana QC Personnel for NO inadequate OJT-records was 17-85-069-105 substantiated by NSRS Report i

11-85-069-007 I-85-373-NPS (Attachment 3).

No falsification of records was substantiated. WP con-

' curs with report recommen-

[' dations.

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Attechnent 1 Page 2 of 3 EMPLOYEE CONCERN NUNBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was SQM-6-005-102 Naking Proper Welds substantiated; SQM-6-005-IO2 was not substantiated by NSRS Report I-86-115-SQN (Attach-ment 3). WP concurs with report.

K1-85-013-001 E309 Electrode Used to Weld This is an acceptable E316 Steels practice. ERT investigated in ERT Report 11-85-013-001, l dated 3/22/85 (Attachment

3). WP concurs.

11-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).

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II-85-049-001 Welder Certifications 11-85-049-001 was 11-85-049-103 Updated Without Meeting substantiated as it relates Requirements to Welder Continuity Require-4 ments. This had previously been identified by N0 in an audit. II-85-049-103 was not substantiated. Details and recommendations'are given in NSRS Report I-85-135-SQN (Attachment 3). WP concurs with I-85-135-SQN-01 through

-03 and recommends they be closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).

II-85-054-001 QC Holdpoint Sign-Off Not substantiated by NSRS Violation Report I-85-346-SQN (Attachment 3).

II-85-065-001 Performance of Remote Visual Not substantiated by NSRS i Inspections Report I-85-750-SQN l [, , (Attachment 3).

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Attachment 3 Page 3 of 3 EMPLOYEE CONCERN NUNBER ISSUE WP ACTION II-85-083-001 SQN Weld Inspections not as Not substantiated by NSRS l Strict as WBN Report I-85-652-SQN '

(Attachment 3).

11-85-098-001 Laminated Pipe in Unit 2 Not safety-related. Not Condenser. This issue is substantiated by WP Evaluation also on the Generic Summary Report WP-18-SQN (Attachment 3).

11-85-100-001 Improper Weld Repair on an Not substantiated by ERT Undetermined Number of Report 11-85-100-001, dated Welds 3/5/86 (Attachment 3).

11-85-101-006 Walder Certification for ERT Report II-85-101-006 the Construction Era (Attachment 3) with NSRS

.. Recommendations indicates

, that this concern is sub-stantiated. WP takes excep-tion to this ERT Report based on subsequent information provided in Attachment 4. WP exceptions, recommen-dations, and basis for closure were discussed with NSRS as documented in Attach-ment 5. WP recommends this

- concern not be substantiated and that it be closed based on the WP-Bechtel Implemen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachment 6).

11-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS l Notice of Indications for Report I-85-735-SQN Preservice-Related Defects (Attschment 3).

! II-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS II-85-108-002 Report I-85-776-SQN i (Attachment 3).

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O PROGRAN SurftARIZATION OF WELD PROJECT (WP) EVALUATION This package summarizes the actions taken by the Welding Project (WP) to evaluate and disposition the subject SQN-specific employee concern which was previously evaluated by NSRS/QTC/ERT and summarized in WP Phase I and Phase II reports.

The Welding Project analyzed each SQN-specific employee concern to determine the statement (s) being voiced by these individuals.

These statements were then evaluated both individually and collectively to develop issues.

Each issue was then incorporated into the WP review activities of Phase I,

" Procedural Assessment" and Phase II, " Procedural Implementation."

During Phase I, each issue was analyzed against requirements of the applicable QA program, policies, NSRS/QTC/ERT Investigation Reports, and other relevant information to determine if program elements were deficient when evaluated against upper-tier requirements.

Phase II consisted of a sample reinspection of hardware and independent program audit by Bechtel. .

In each area analyzed by Bechtel, the auditors found no objective evidence to substantiate the employee concerns considered. The following areas directly

'7 related to employee concerns were investigated by the audit team:

1. Walder qualification and attendant records

2. Welder qualification and attendant on-the-job-training t

3. Welding inspections ,

4. Welding inspectors training programs

5. Weld material traceability

6. Welding inspections by craft personnel

7. Weld material control Each of thsse areas was investigated by the auditors for both construction and j operations phases. In all cases, there was no objective evidence to

substantiate the employee concerns. The audit report concludes that both i

construction and operations phases have had and now have a functioning Welding Quality Assurance Program which meets code, standard, and regulatory requirements and that the employee concerns considered were found to be unsubstantiated and without technical merit.

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Attachment 4 The results of the reinspection program at SQN also give another, additional verification of the Welding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the accuracy and implementation of these programs through hardware inspections and attendant document reviews. In all cases, the components and items were fourd to be acceptable upon initial reinspection or found to be acceptable after engineering analysis.

The WP analysis of SQN-Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed components and system, and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified through the Employee Concern Program. The Employee Concern Program has simply reiterated problems which have been or are now being resolved through existing corrective action programs in the overall Nuclear Quality Assurance Program.

A summary analysis of the WP evaluations and recommendations is included in Attachment, Page 2 of 2

I-as-560-squ

,' Attachment 5 Page 1 of 2

1. Problem Dascription Butt welds, for pipe box hangers, if made as shown on the typical drawings could extend to the pipe and result in the collar plate being welded to the pipe. This would eliminate the freedom of movement which the pipe should have.

2. Corrective Action Plan The scope of this program is to determine the extent of drawing and installation discrepancies at Sequoyah Nuclear Plant (SQN) involving box anchor rear plate supports that may be identical to those identified by WBW NCE 6264.

Evaluation

NCR 6264 identified drawing and installation discrepancies associated with load transfer supports (box anchors) used on various piping systems. The drawings do not specify that the rear plate seam weld should be stopped short of the pipe in order to ensure that the weld would not be fused into the pipe. Fusion of this weld to the pipe with a temperature rise could create a potential locking of the pipe between the front and rear plates causing the fused welds to tear loose and damage the pipe or cause thermal overstresses in the restrained pipe.

i Four types of conditions were observed upon investigation of the welds la the field at WBN.

Condition 1 involved box anchors displaying fusion of the seam weld to the pipe on at least one of the final passes of the weld. The extent of fusion could not be determined,through visual examination.

Condition 2 involved box anchors which had no observed fusion of the seam weld to the pipe, but the absence of fusion could not be determined due to the close contact of the plate to the pipe.

Condition 3 involved box enchors that were determined as inaccessible due to requirements for extensive scaffolding or the removal of piping insulation. Inspection of these items would be performed if it was determined to be beneficial to the evaluation of the discrepancy.

Condition 4 identified those box anchors which were able to be verified visually as not exhibiting any fusion to the pipe.

Sequoyah Evaluation Program The program to identify and evaluate the conditions of the rear plate seam welds on box anchors at SQN will consist of a review of the drawings, a

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I-85-560-SQN Attachment 5 Page 2 of 2 walkdown of the piping systems containing these box anchors, documenting the conditions observed in the field, and evaluating the conditions identified.

The following tasks shall be performed.

1. DNE will identify and locate the box anchors to be inspected and initiate the required drawing changes to reflect the proper configuration of the rear plate seam weld to prevent fusion with the process piping.

2. Inspection shall be performed by the SQN Quality Assurance Staff to identify and document the field conditions of the identified rear plate seam welds. l

3. Upon completion of items 1 and 2, an evaluation shall be made by the SQN Division of Nuclear Engineering to determine the significance of the reported discrepancies, report the conclusions of the evaluation, and provide disposition that are consistent with the evaluation l results.

3. Action to Prevent Recurrences Revise drawings 478100 sheets 2 and 4 and specific ECNL6319 drawings so

, a butt weld as shown on the 478100 drawings will not extend to the pipe and result in the collar plate being welded to the pipe. The modification

, cognizant Engineer has processed FCRs to revise these drawings.

4. The proposed corrective action plan was submitted by the Director / Manager l Office at SQN in response to Corrective Action Tracking Document Number l I-85-560-SQN-01-013 and I-85-560-SQN-02-014. l l

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