ML20211C226

Rev 3 to Storage & Handling Re Matl Control, TVA Employee Concerns Special Program Element Rept

ML20211C226
Person / Time
Site:	Sequoyah
Issue date:	02/11/1987
From:	Howard J, Russell J, Stewart D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20211C076	List: ML20211C071 ML20211C144 ML20211C197 ML20211C226
References
MC-40400-SQN, MC-40400-SQN-R03, MC-40400-SQN-R3, NUDOCS 8702200039
Download: ML20211C226 (21)

Text

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. TVA EMPIAYEE CONCERNS REPORT NUMBER: MC-40 00-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant - Subcategory REVISION NUMBER: 3 (Final Report)

TITLE: Storage and Handling as Related to PAGE 1 0F 18 Naterial Control REASON FOR REVISION:

Revision 1: To incorporate Technical Assistance Staff and Senior Review Panel coiunents .

Revision 2: Revised to include corrective action and addition of Attachment A.

Revision 3: Revised to include additional corrective action plan supplement (February 6,1987) and incorporate Senior Review Panel coments.

PREPARATION PREPARED BY:

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'/ SIGNATURE DATE

/ 0 SIGNATURE DATE 2//[f7 CONCURRENCES

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SRP: f- 2*II~ 8 7 SIGNATURE DATE SIGNATORE DATE APPROVED BY:

/

[/087 N/A DATE ECSP MANAqER DATE MANAGER OF NUCLEAR POWER CONCURRENCE (FINAL REPORT ONLY)

• SRP secretary's signature denotes SRP concurrences are in flies.

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TTA IMPLOYRE CONCERNS REPORT NUMBER: NC-40400-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 2 0F 19 I. INTRODUCTION Five concerns have been evaluated involving the storage and handling of permanent plant material and equipment at Sequoyah Nuclear Plant (SQN).

• One of the concerns (I1-85-122-045) was a SQN specific concern and the other concern (IN-85-443-002) was a Watts Bar Nuclear Plant (WBN) specific concern that was determined to be generic to all TVA nuclear power plants during the WBN evaluation. The remaining three concerns (WI-85-100-040. 11-85-122-046 and 11-85-122-047) which were expressed for the other TVA ndelear plants (WBN, BLN and BFN respectively) were identical to 11-85-122-045, and therefore determined to be teneric to SQN.

II.

SUMMARY

OF PERCEIVED PROBLEMS This subcategory supplemental report deals with (a) inadequate material segregation during receipt and storage and (b) inadequate environmental control and protection through installation.

III. EVALUATION METHODOLOGY A. Reviewed exporgated files for the concerns this evaluation plan addressed to determine if additional information was available on individual concerns.

B. Reviewed Employee Concerns Task Group (ECTG) subcategory report oa

" Storage and Handling" (MC-40400) to determine if the evaluation results were applicable to SQN.

C. Reviewed Nuclear Safety Review Staff (NSRS) investigation report to determine if concerns were adequately addressed.

1. NSRS Investigation Report I-85-990-SQN, " Poor Equipment Storage, Fire Protection, Storage Environment."

l

TVA EMPIAYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 3 0F 19 D.1 Reviewed Quality Assurance (QA) Staff, Surveillance Section QA Inplant Survey Checklist for the Office of Nuclear Power (ONP) to determine if deficiencies were being detected and corrected. The following audits were reviewed:

3d and f-83-P-002 3c-83-A-022

'3d-83-S-003 3a-84-P-001 3a-83-A-006 3c-84-P-003 3f-83-A-007 3h-84-004 3f-83-A-008 3d-84-S-006 3f-83-A-009 3f-84-S-007 3d-83-A-010 3f-84-S-008 3f-83-A-011 3f-84-S-009 3f-83-A-012 3f-84-S-010 3f-83-A-013 3f-84-S-011 3b-83-A-014 3f-84-S-012 3-83-A-016 3f-84-S-013 3h-83-A-017 3f-84-P-005 3f-83-A-019 3-85-P-001 3c-83-A-020 3-85-P-002 3e-83-A-021 3-85-P-003 3h-86-S-001 D.2 Reviewed SQN Storage Inspection Records from the Division of Nuclear Construction (DNC) to determine if procedures were in place and deficiencies were being detected and corrected. The following records were reviewed:

C-3 MIG-4 E-94 MIG-5 E-96 MIG-6 E-117 MIG-7 E-118 MIG-8 E-129 MIG-13 E-136 MIG-18 E-141 MIG-30 E-151 MIG-40 E-154 MIG-41 E-204 MIG-44 M-95 MIG-98 M-96 MIG-101 M-138 MIG-165 M-147 MIG-169 M-148 MIG-170 M-149 MIG-171 MIG-1 MIG-172 l

TVA IMPLOYRE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 4 0F 19 l

l E. Reviewed Administrative Instruction (AI) AI-36. Revision 9 dated March 7, 1986, concerning storage and handling requirements for i safety and nonsafety-related items to determine if it implemented I American National Standards Institute (ANSI) N45.2.2-1972 and I o Nuclear Quality Assurance Manual (NQAM), Part III Section 2.2, Revision dated June 20, 1986, and performed the following:

1. Walkdowns of a random sample of warehouses, storage yards, field storage, and holding areas to determine if they were in accordance with AI-36, Revision 9.

2. Walkdowns of a random sample of storage areas to determine if safety-Critical Systems, Structures, and Components (CSSC) and nonsafety-related (non-CSSC) material was segregated in accordance with AI-36. Revision 9.

F. Conducted interviews with personnel that had been associated with material storage and handling to determine if material controls had been in place during construction.

G. Conducted interviews with fire protection engineer to determine if fire protection was adequate for warehouses.

IV.

SUMMARY

OF FINDINGS A. A review of the expurgated files for the concerns did not reveal any additional information. In addition, searched for other concerns and/or reports and no others were found except for those identified in Section I of this report.

B. Reviewed ECTG subcategory report MC-40400 (Storage and Handling) and determined that the findings at WBN were applicable to SQN. This was due to the similar deviaticns being found by the Nuclesr Regulatory Commission (NRC) at SQN resulting in violations.

. C. Reviewed the NSRS Investigation Report I-85-990-SQN and determined it did not adequately address the perceived problems. The investigation did not address fleid storage or storage during construction. In addition, several deviations were found during this evaluation which were not detected during the NSRS investigation. However, the NSRS investigation identified the following two areas to be addressed:

1. The fire protection for the storage buildings outside the new Office and Power Stores Building (addressed in this report in Section IV.G).

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,, TVA EMPLOYEE CONCERNS REP 0tf NUMBER: MC-40400-SQN SPECIAL PROGRAN EITISION NUMBER: 3 PAGE 5 0F 19

2. The poor condition of Hut 21 which stores flammable paints and materials. The condition of Hut 21 has been addressed on Corrective Action Report (CAR) SQ-01-001 which will establish minimum requirements for paint and paint products and determine o if Hut 21 will meet the minimum storage conditions.

D. 1. Reviewed QA Staff Audits on ONP storage facilities and determined that deficiencies were being detected and corrected.

2. Reviewed SQN Storage Inspection Records on DNC storage facilities and determined that deficiencies had been detected and corrected during construction.

E. Reviewed AI-36, Revision 9, dated March 7, 1986, and determined it fully implemented ANSI N45.2.2-1972 and NQAM, part III, Section 2.2, revision dated March 23, 1985. Additionally, the following was conducted:

1. A walkdown of a random sample of warehouses, storage yards, field storage and holding areas to determine if they were in accordance with AI-36. The findings were:

a. From the Power Stores storage facilities that wees observed, the following deviations or questionable conditions were found:

(1) Hut 11, an indoor storage building, had several leaks in the roof. AI-36, paragraph 5.6.1.1 states that the indoor storage shall be constructed so as to be weathertight and well drained with no standing water.

(2) Approximately 25 percent of the stock material items in the storage yard were not in compliance with AI-36, paragraph 5.8 which states all items or their containers shall be plainly marked so that they are easily identified.

(3) Approximately 10 percent of the stock material items were not in compliance with AI-36, paragraph 5.7.3.5 which states that items shall be arranged so that racks, cribbing, or crates are bearing the full weight without distortion of item.

(4) Approximately 50 percent of the austenitic stainless steel fittings (tees, elbows, reducers, etc.) were not in compliance with AI-36, paragraph 5.11.22 which states that austenitic stainless steel tubular products shall have end caps to prevent nesting or infestation of rodents, birds or insects.

_s

TVA IMPLOYEI CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 6 0F 19 4

(5) Approximately ten valves were not in compliance with AI-36, paragraphs 5.11.24, 5.11.25, and 5.11.26 which i state that caps or covers shall be provided for nonstainless valves 4 inches and over and under 4 inches a with flanged ends. Caps for flanged openings or veld props shall provide impact damage protection. Stainless steel valves shall have openings capped or covered, or small valves may be stored in bulk containers providing protection from insects.

(6) Hut 11 contained two circuit breakers and three motor operated valves which required indoor controlled storage.

Hut 11 was an indoor storage building that does not have environmental control. AI-36, paragraphs 5.11.14 and 5.11.27 which state that indoor controlled storage is required for breakers and motor operated valves.

, (7) QA Level I or II items were not stored in compliance with i

AI-36, paragraphs 5.8.1.3 and 5.8.1.5 which state that mixing of QA Level I and II with QA Level III and no QA items is prohibited.

(8) Controls were not implemented to ensure compliance

, with AI-36, paragraphs 5.6.1.3, 5.6.1.4, 5.6.2.1, and 5.6.2.2 which give temperature and dewpoint requirements. Current methods do not provide assurance that temperature and dewpoint limits have not been ezeseded.

(9) Random lengths of coated pipe were not stored in compliance with AI-36, paragraph 5.6.3.3 which states that open sheds and/or covers may provide weather protection as required. Severe deterioration of the coating was observed in many instances, apparently due to i the lack of protection from direct sunlight.

(10) Storage yard was not in compliance with AI-36, paragraph 5.5 which states outdoor storage areas shall be gravel covered or paved and well drained.

Storage yard was partially covered with gravel, not well drained, and had high weed growth,

b. From the Maintenance Groups storage faellities that were observed, the following deviations were found at two outdoor storage huts:

TVA IMP 14YRE CONCERNS REPORT NUMBER: HC-40400-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 7 0F 19 (1) Several hundred items that required either indoor or indoor-controlled storage were stored in a breezeway.

These items included pumps, valves, motors, hangers, etc. Storage requirements by equipment / item category o are listed in AI-36, paragraph 5.11, which gives the specific minimum requirements for the different categories of equipment and material.

(2) Items were not on pallets or cribbing in compliance with AI-36, paragraphs 5.7.3.4 and 5.7.3.5 which state that items shall be stored on pallets, cribbing, shoring or equivalent in order to permit air circulation and prevent trapping moisture as well as bear full weight without distortion.

(3) Items did not have proper identification plainly marked on all items. (Eee paragraph IV, E.1.a.(2) of this report).

(4) Items that were stored outdoors were often on the ground.

(See paragraph IV. E.1.b.(2) of this report).

(5) Austenitic stainless steel pipe was not capped or plugged.

(See paragraph IV E.1.a.(4) of this report).

(6) Valves did not have ends capped or plugged.

(See paragraph IV E.1.a.(5) of this report).

(7) Items were stored in piles. (See paragraph IV. E.1.b.(2) of this report).

(8) No access control to storage area. Huts were locked but access to items in breezeway was not controlled.

AI-36, paragraph 8.0, and ANSI N45.2.2-1972 Section 6.2, states access to storage areas shall be controlled and limited only to personnel designated by the responsible organization.

(9) Austenitic stainless steel was not stored in compliance with AI-36, paragraph 5.7.4 which states austenitic stainless steel shall not be stored in contact with carbon steel.

d

c. From the Modification Groups and Materials Section storage facilities that were observed, the following deviations or questionable conditions were found:

)

l TVA EMPIAYIE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL P90GRAN REVISION NUMBER: 3 PAGE 8 0F 19 (1) Nitrogen pressure was not maintained on heat exchangers in storage yards. AI-36, paragraph 5.7.1.c states that items pressurized with inert gas shall be monitored at such a frequency as to ensure that the gas pressure is e maintained, within specified limits during storage.

(2) Materials Section storage yard by Hut 21 had high weed growth. (See paragraph IV E.1.2 (10) of this report).

(3) Materials Section storage yard by Hut 21 had items with inadequate cribbing or stored on the grocnd.

(See paragraph IV E.1.b.(2) of this report).

(4) Materials Section storage yard by Hut 21 had items that did not have proper identification. (See paragraph IV. E.1.a.(2) of this report).

2. A walkdown of a random sample of warehouses, storage yards, field storage and holding areas to determine if safety (CSSC) and nonsafety-related (non-CSSC) materials were segregated in accordance with AI-36. The findings were:

a. From the Power Stores storage facilities observed, the following deviations or questionable conditions were found:

(1) As stated in Section IV.E.1.a.(7) of this report, QA Level I or II items were stored in the same bins without physical separation of items QA Level III and non-QA although items were tagged.

(2) In the storage yard, stock material was not segregated into areas designated for certain QA Levels to prevent inadvertent mixing of materials,

b. From the Maintenance Groups storage facilities that were observed the following deviations were found:

(1) The storage areas did not have a Section designated for safety-related material, although materials were identified and boxed. The safety and nonsafety-related materials could inadvertently get mixed.

(2) The storage racks had safety and nonsafety-related stock items on the same shelf. These items were mixed but did have 575s attached to identify material. (See paragraph IV, E.1.a.(7) of this report).

c. From the Modification Group storage facilities that were l observed, the following deviations were found:

1 l

l

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAR REVISION NUMBER: 3 PAGE 9 0F 19 In the back of the Modification Building, there was a storage area where nonsafety-related materials were stored in bins for various fabrications. This storage area was designated non-CSSC material only, but it had o material that could be identified and acceptable for CSSC use. This naterial is not segregated according to AI-36 (See paragraph IV E.1.a.[7]). This area of concern has also been addressed in the element report MC 40307,

" Scrap Material."

F. Interviews with personnel revealed that acterial controls were in place during construction to control storage and handling of materials.

G. Interviews with Fire Protection Engineers revealed that the new Power Stores warehouse has adequate fire protection, and the old warehouses in the yard are protected by a fire hydrant system which was not adequate for insurance purposes. This lack of fire protection was an economic consideration and not a safety consideration. Fire protection shall be commensurate with type of storage area according to ANSI N45.2.2-1972.

H. Interviews with Power Stores personnel and a random check of ten nonsafety-related items did not reveal any evidence that safety and nonssfety-related material had been received with identical identification markings and heat numbers. However, the issue of material traceability and the use of identical heat numbers received for different TVA piping system classifications has been addressed in the ECTG subcategory " Procedural Control" in the element report MC 40703, " Heat Code."

Conclusion Many of the perceived problems indicated by the concerns in this supplemental report were valid. During the evaluation, several deviations were observed along with conditions that were questionable. The overall storage facilities at SQN were acceptable except for the leaking roof in Hut 11, the high weed growth in the storage yards, the storage yards not being well drained, and the poor condition of Hut 21.

The deviations to specified storage requirements that were observed include the following:

l 1. Items were not plainly marked or identified in various storage locations.

2. Items were stored with inadequate or no cribbing.

3. Items were not stored in the appropriate storage level.

TTA EMPLOTEE N m REPORT WIRIBER: NC-40 00-SQN SPECIAL P90GRAN EITISION NUMBER: 3 l PAGE 10 0F 19

4. Several items in various locations did not have caps or plugs. These included valves, austenitic stainless steel pipe and fittings.

5. Proper segregation was not maintained for safety and a nonsafety-related materials.

6. Austenitic stainless steel was stored in contact with carbon steel.

7. No access control to storage area.

8. Nitrogen pressurization was not being maintained on heat exchangers.

9. Inadequate methods were being used to determine if temperature and humidity levels were maintained within specified limits.

The final conclusion of this evaluation was that storage conditions

, were/are not always maintained in accordance with applicable requirements. However, it should be noted that during the construction phase of SQN as well as maintenance or modifications, installation and functional inspections / tests should identify any i adverse conditions of material or equipment resulting from improper

, storage conditions. Additionally, any adverse conditions which are

• time delayed by nature should be identified during normal / routine plant operations, maintenance, tests, and inservice inspections.

Due to SQN's operating history, it appears that storage practices have not affected its safe operation in the past; and they should not have any detrimental effect on its safe operation in the future.

! V. ROOT CAUSE i

The deviations identified in this report resulted from the following two causes:

i

{ A. Lack of attention to detail of storage requirements of AI-36 by i the responsible line organizations.

B. Misinterpretation of procedural requirements of AI-36 by the responsible line organizations.

I i

VI. CORRECTIVE ACTIONS i The following is the pertinent contents of the Corrective Action Plan (CAP) that was submitted to ECTG by SQN ONP, in response to the findings

of this report, on September 8, 1986 (S03 860827 805).

l

. TVA EMPIDYEE CONCERNS REPORT NURSER: MC-40400-SQN 1 SPECIAL PROGRAR REVISION NUMBER: 3 PAGE 11 0F 19 Response to Subcategory Report MC-404.00 For SON Material Control Part I - Power Stores a The water problem identified in the ECTG inspection has been addressed and building maintenance at SQN has inspected and repaired the roof on Hut 11. The drought has prevented the verification of the corrective action taken, but the warehouse area is inspected at specific intervals, any further leaks will be addressed and corrected.The water problem is a recurring problem due to the age of the buildings.

The weed control problem identified in Power Stores' Yard has been addressed. Power Stores and Natural Resources personnel will be responsible for controlling the weed growth in the storeroom yard areas. Natural Resources cut the existing weed growth in the yard and will maintain and control the yard areas in the future.

Deviation Response:

A. The material in the Power Stores yard that was not properly marked or identified was re-identified and remarked to provide positive traceability on each item to conform to AI-36 requirements.

Material that has lost it's positive traceability due to age of the material, cust and corrosion was segregated in a separate area and marked as "Non-CSSC" material only.

B. The material in the Power Stores yard that required additional cribbing to support the material was corrected by adding a third supporting timber to help bear the load.

C. The circuit breakers stored in Hut 11 were removed from site and transferred to Power Stores Distribution Center (PSDC) at Hartsville Nuclear Plant (HNP). The breakers were surplus SQN Construction items which should have been transferred to HNP prior to 9/85 (the material belonged to HNP).

The Liritorque valve operators located in Hut 11 were Non-CSSC r items and do not require an indoor controlled environment, but they were relocated to Hut 12 which has a Class B environment.

D. The stainless steel pipe and fittings which were not plugged or capped were dispositioned as follows:

a. Pipe - all S/S pipe is either plugged or taped to meet AI-36 paragraph 5.11.22 requirements.

_____. - _ - - - - _ . - . ---__ 3

TVA EMPLOYEE CONCERNS EEPORT NUMBER: NC-40400-SQN SPECIAL PE0 GEAR EITISION NUMBER: 3 PAGE 12 0F 19

b. Fittings - (tees, elbows, reducers, etc.) are not specifically addressed as a requirement in paragraph 5.11.22, but it is a " recommended practice" to have the. ends plugged or taped. The weld prep surfaces for fittings that a have factory prepared ends are protected by either plugging or taping the ends.

SQN Quality Assurance Staff concurs with the existing requirements of AI-36 paragraphs 5.11.22 which states it is a " recommended practice" not a requirement to plug and cap all S/S fittings. Existing procedures allow for repairs to damaged weld prep ends. (See Section 1 of the Corrective Action Plan Supplement below to enhance subject corrective action)*

The valves and pumps identified in the ECTG inspections that required a protective cover were corrected to be in compliance with AI-36 paragraph 5.11.24, .25 and .26.

E. The bin locations that contained QA I, II, III and No QA material were inspected and corrective action taken co that only QA I and II material is in the same bin location.

F. The ECTG concern which questioned the implementation of AI-36 storage procedures to require temperatures and humidity recording devices was addressed in resolving CAR 83-08-026. Plant management determined that the recording devices were not required and documented in surveys 3F-84-S-005, 009, 010, 011, 012 and 013 as well as the CAR response. The referenced surveys as well as material inspection, have not found any problems due to humidity.

The warehouse areas are inspected on a daily basis per Power Stores SIL-30 which is an AI-36 requirement that allows Power Stores to monitor any variances in environmental conditions.

The deviations noted in the storeroom areas (yard and warehouse) had corrective actions taken to immediately bring deviations in compliance with AI-36 requirements.

Power Stores is routinely audited by Site Quality Assurance personnel, as well as off sito audit personnel to ensure that 1 the storeroom is in compliance with existing procedures. Audit l findings are documented and violations are addressed and 1 corrected.

• Parenthetical statement added by ECTG for continuity of Corrective Action Plan provided by SQN and is editorial.

TTA IMPLOYEE CONCERNS REPORT NUMBER: NC-40400-SQN SPECIAL PROGRAN RETISION NUMBER: 3 PAGE 13 0F 19 All items identified as being a Power Stores item have been addressed and corrected.

• Part II - Modification The items identified in the ECTG survey are addressed as follows:

Item E.1.C (1) Nitrogen purge - The nitrogen purge was reestablished on the heat exchangers. The heat exchangers are Non-CSSC items, but they will be maintained to the manufacturer's specifications.

(See Section 3 of the Corrective Action Plan Supplement below to enhance the subject corrective action)*

The items addressed in 2, 3 and 4 are all related to the Modification storage area which is designated for Non-CSSC materials only. This yard is north of Hut 21.

(2) The weed growth in the modification yard will be maintained by the Natural Resources personnel on

+

site and be cut to an acceptable height.

(3) The material in the modification yard will be cribbed or supported to meet AI-36 requirements.

The material stored in the referenced yard is Non-CSSC material only, see item 4.

(4) The modification yard is posted as Non-CSSC material only, and therefore, item traceability is not required.

The material stored in the modification yard will be evaluated by Power Stores and Modification personnel to determine if sufficient traceability is available to return the material to Power Stores inventory or designate the material for Engineering Change Notice (ECN) use.

The material stored in the modification yard is surplus or excess material with a potential value or use. The material will be evaluated and if no use is found, the material will be surplused or scrapped.

• Parenthetical statement added by ECTG for continuity of Corrective Action Plan provided by SQN and is editorial.

TVA EMPIAYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGEAR EETISION NUMBER: 3 PAGE 14 0F 19 Part III - Maintenance The material identified in the ECTG inspection was located in the warehouse building and breezeway areas south of the switchyard. The o material in this area is either scrap, surplus or cannibalized parts which were not intended for installation in the plant.

Corrective action taken to ensure that the referenced material is properly addressed is to revise SQH1 and SQM2 to define the requirements and responsibilities to control the use of material to prevent inadvertent use of scrap material, use of material in an application for which it was not intended, or use of material that has degraded due to inadequate storage. Elements to be included in the proposed revisions are:

1. Requirements for maintenance groups to review storage requirements for material kept under the group's control for spare parts inventory and initiate action to ensure the material is stored in compliance with AI-36 program requirements. (Note:

This applies only to spare parts and not material retained within the groups left over from previous work for possible future cannibalization).

2. Requirements for maintenance groups to evaluate, prior to use, materials obtained from cannibalization of new or used equipment, scrap or surplus material, material left over from or retired from previous work to ascertain that (1) traceability can be verified to the purchase documentation, (2) the material has not degraded due to prior storage conditions or use, and (3) that the intended use of the material is for the correct application.

The proposed CAP would control the use of material instead of attempting to control the storage areas for scrap material or material kept for future cannibalization. (See Section 2 of the Corrective Action Plan Supplement below to enhance the subject corrective action)*

To enhance the initial Corrective Action Plan, SQN submitted a Corrective Action Plan Supplement on December 23, 1986. The following is the pertinent contents.

• Parenthetical statement added by ECTG for continuity of Corrective Action Plan by SQN and is editorial.

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40:00-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 15 0F 19

1. Poder Stores, paragraph IV.E.1.s (4) of this report; AI-36 paragraphs 5.11.22 storage of Fittings, etc. An evaluation of the intent of Division Procedures Manual (DPM) N82A17, paragraph 7.21 item 2, was requested through the Electrical

• Component Engineer and Service Group. Specific attention was directed to item 2 which references a." Recommended Practice."

The evaluation asks for a clarification of the terminology

" Recommended Practice" within the DPM.

The following is the pertinent contents of the memorandum to the Electrical Component Engineer and Service Group on December 16, 1986 (A23 861217 250) requesting clarification of the DPM:

In order to resolve the Sequoyah Nuclear Plant Employee Concerns Task Group Element Report (404.00), an engineering evaluation is needed. The specific area that needs to be addressed is DPM M82A17, paragraph 7.21 (storage of pipe, tubular products) etc. The evaluation is required to resolve item 2 of paragraph 7.21 which referenced the " Recommended Practice" for storage of bulk small pipe fittings, etc.

• The ECTG evaluation of Power Stores compliance with AI-36, paragraph 5.11.22 (same as DPM N82A17, paragraph 7.21) stated we were not complying with the requirements of paragraph 5.11.22 with specific emphasis directed toward the

" Recommended Practice" of storing bulk fittings. Power Stores and Site Quality Assurance Staff personnel interpret this procedure to read that a recommended practice is not an enforceable procedure, but a recommendation if there appears to be substantiated evidence that degradation to material might occur, in which case steps should be taken to protect material as recommended.

In order to resolve this issue, the DPM should be reviewed to address the following comments.

1. Is the intent of a " Recommended Practice" to be an enforceable procedural requirement? If it is, then revise the terminology of the DPM to reflect an enforceable requirement or;

2. If not an enforceable issue, and if there is not any documented evidence to support the DPM requirements, drop all reference to the hult storage requirements for fittings.

, . TVA EMP14YEE CONCERNS REPORT NUMBEtt MC-40400-SQN SPECIAL PROGRAN 1 REVISION NUMBER: 3 PAGE 16 0F 19 1

3. Is the intent of paragraph 7.21 to address austenitic stainless steel products only, or does it also include carbon steel products? If it does, the procedure should address both products. '

o

4. If, as a result of this evaluation, it is determined that pipe fittings require special storage requirements, it mir,ht resolve some of the individual interpretations if there was one paragraph for pipe and tubing products, and one paragraph for fittings, with emphasis placed on

, specific S/S or C/S storage requirements.

General Construction Specification G-29M, Vol IV, Section P.S.4.M.1.1, paragraph 3.1.7.1 was revised under Revision 10, to delete end caps for tube or pipe fittings. TVA Metallurgical Engineers are currently conducting a study through Singleton Lab in Knoxville to document this revision to G29.

Note: The purpose for the study is to determine if storage i environments at TVA sites allow for contamination of l stainless steel pipe that may have long-term deleterious lR3 effects, such as, stress corrosion cracking as a result l of chloride contamination. The study will be used to I determine the need for capping tube and pipe fittings. l

2. Maintenance Group Storage, paragraph IV.E.1.b. of this report; Storage of non-designated material. The following items address the maintenance storage issue as referenced in items 1-9 of the referenced paragraph, and are intended to resolve this item.

A. Administrative Instruction (AI-36), Storage, Handling and Shipment of QA Material will be revised to require scrap or salvageable material storage areas to be designated and access controlled through administrative procedures.

B. Maintenance Section Superintendent will issue a memorandum to establish administrative controls for key control and access to the maintenance groups storage areas.

C. Maintenance Group will placs signs on scrap / salvage storage huts to designate these areas as referenced in AI-36. Signs will specify material evaluation requirements for scrap / salvage material stored in the maintenance storage areas.

. . - _ - -_ .s

. . TVA EMPIAYBE CONCERNS REPORT NUMBER: MC-40 00-SQN SPECIAL PROGEAN REVISION NUMBER: 3 PAGE 17 0F 19 D. Maintenance will revise SQM-1 to define the requirements and responsibilities for spare part storage areas within the section and for controls of salvageable material usage in plant applications. Elements to be included in the

. revision are:

(1) Include requirements for maintenance section to review storage requirements for materlais kept and issued by the sections for spare parts and to initiate action to insure that storage requirements of AI-36 are met.

(Note: this only applies to spare parts and not material retained for cannibalization).

(2) Include requirements for sections to evaluate, prior to use, materials salvaged or cannibalized from used material, material left over from previous work, or material retired to ascertain that the material is fully acceptable for its intended use. Since the quality of this type of material may not be initially known, all items being evaluated for use on CSSC systems shall be nonconformed per AI-11 requirements. Material shall also be evaluated, dispositioned and documented per AI-11 procedures. Also,

. In order to upgrade material for QA applications, traceability must be maintained during storage per SQA 45 requirements. It should be noted that currently the NQAM Part III, Section 7.1 requires the Plant Operations Review Committee's (PORC) review, the Plant Manager's approval, and Division of Nuclear Engineering's (DNE) approval of nonconforming items which are recommended to be dispositioned "use-as-is" or " repair". This NQAM requirement will be implemented at SQN in AI-11 within the required timeframe.

(3) Maintenance will request that AI-11 be revised to reflect the requirements of the SQM 1 revision.

(4) Maintenance Group storage huts will be purged in an effort to reduce their inventory. Identified scrap material will be disposed of through the Pcwer Stores Scrap Yard.

Surplus material will be returned to Power stores to place the material in inventory for future usage.

(5) SQA 66, Plant Housekeeping Instructions, have been revised and strengthened to require a final checklist and sign off after completion of maintenance and modification work.

Some items included in the final checklist are removal and disposal to proper designations for waste material, unused material, expendable items, old parts, removed components, and package material. The foremen are required to review the final checklist and to ensure that the requirements of SQA 66 are complied with. SQA 66 revision was approved on October 14, 1986 and is being implemented, i

1

.- . . TVA ERPIAYEE CONCERNS REPORT NUMBER: NC-40400-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 18 0F 19

3. Modification Groups and Materials Section, paragraph IV.E.1.C (1) of this report; Nitrogen Purge on Heat Exchanges. The heat exchangers referenced in the ECTG Element Report were added to the plant Preventative Maintenance (PM) Scheduling Report with the site Modification Group being responsible for compliance with the PM. The PM package will be used to document the heater inspections. Inspection frequency rate was established at a monthly rate.

To enhance the initial Corrective Action Plan and Corrective i Action Plan Supplement, SQN submitted another supplement on l February 6, 1987 to further address corrective action for the l Heat Exchangers (Feedwater Heaters). SQN submitted the i folicwing additional measures to ensure Heat Exchangers were I not damaged due to loss of nitrogen purge. I l

1. Measure dewpoint of existing nitrogen blanket gas in i feedwater heaters. l I

2. If the dewpoint of any feedwater heaters exceeds +20 F,0 I perform inspection of the feedwater heater with the highest l dewpoint above +20 0 F to determine acceptability for service l

, and if any additional feedwater heaters need to be inspected lR3 and evaluated. Appropriate corrective action will be taken l if necessary. I l

3. Purge feedwater heaters to obtain dewpoint not in excess of l

+200F. l l

4. Monitor feedwater heaters nitrogen blanket pressure with the l plant preventative maintenance program to maintain l

' approximately 10 psig. l The original Corrective Action Plan along with the supplements should correct discrepancies and ensure future compliance with accepted storage and handling practices.

VII. GENERIC APPLICABILITY

'A. The problems identified with capping and lack of attention to detail were determined to be generically applicable to Bellefonte and not to Browns Ferry by the WBN evaluation and are still considered applicable.

B. The perceived problem of safety and nonsafety-related material being received with identical identification markings and heat numbers was determined to be generically appilcable to all plants by the WBN evaluation and is still considered applicable.

TVA ERPIAYEE CONCERES REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAN REVISION NURBER: 3 PAGE 19 0F 19 VIII. ATTACHMENTS Attachment A: Listing of concerns indicating relationship to Nuclear Safety and Generic Applicability.

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l

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REPORT NUMBER: NC-40C00-SQN REVISION NUMBER: 3 e PAGE 1 0F 2 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM ,

Attachment A 1

GENERIC APPL QTC/NSRS P#

CONCERN SUB PLT B B S W Investigation S CONCERN NUMBER CAT CAT LOC F L Q 8 REPORT R DESCRIPTION IN-85-443-002 NC 40400 WBN Y Y Y N SS SAFETY AND NON-SAFETY MATERIALS ARE T50034 REPORT NOT KEPT SEGREGATED IN RECEIVING AND i STORAGE.

WI-85-100-040 MC 40400 WBN Y Y Y Y SR HANDLING OF EQUIPMENT IN STORAGE AND T50213 REPORT DURING AND AFTER CONSTRUCTION IS POOR.

EQUIPMENT IN MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE. ENVIRONMENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE.

CI HAS NO FURTHER INFORMATION.

ANONYNOUS CONCERN VIA LETTER.

. H-85-122-045 MC 40400 SQN Y Y Y Y I-85-990-SQN SR SEQUOYAH: HANDLING OF EQUIPNENT IN T502IS REPORT STORAGE AND DURING AND AFTER CONSTRUCTION IS POOR. EQUIPMENT IN MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE.

ENVIRONNENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE. ANONYMOUS

' CONCERN VIA LETTER.

e O r

a REPORT NUMBER: MC-40400-SQN , ,

REVISION NUMBER: 3 PAGE 2 OF 2 TVA EMPIAYEE CONCERN SPECIAL PROGRAM .

I 1

Attachment A GENERIC APPL QTC/NSRS P#

SUB PLT B B S W Investigation S CONCERN CONCERN CAT CAT IhC F L Q B REPORT R DESCRIPTION NUMBER 40400 BLN Y Y Y Y I-85-126-BLN SR BELLEFONTE - HANDLING OF EQUIPMENT IN XI-85-122-046 NC STORAGE AND DURING AND AFTER T50222 REPORT CONSTRUCTION IS POOR. EQUIPMENT IN MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE.

ENVIRONMENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE. CI HAS NO FURTHER INFORMATION. ANONYMOUS CONCERN VIA LETTER.

40400 BFN Y Y Y Y I-85-152-BFN SR BROWN'S FERRY - HANDLING OF EQUIPMENT XX-85-122-047 MC REPORT IN STORAGE AND DURING AND AFTER T50222 CONSTRUCTION IS POOR. EQUIPMENT IN

' MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE.

ENVIRONMENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE. CI HAS NO FURTHER INFORMATION. ANONYMOUS CONCERN VIA LETTER.

1. PSR CODES:

SR-NUCLEAR SAFETY-RELATED SS-NUCLEAR SAFETY SIGNIFICANT NO-NOT NUCLEAR SAFETY-RELATED

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