ML20213A353
| ML20213A353 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 01/14/1987 |
| From: | TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20213A334 | List: |
| References | |
| 80201-SQN, 80201-SQN-R03, 80201-SQN-R3, NUDOCS 8702030233 | |
| Download: ML20213A353 (36) | |
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM _
80201-SQN REPORT TYPE REVISION NUMBER:
Element Report 3
TITLE:
PAGE 1 0F 15 Inspection Criteria REASON FOR REVISION:
This report was revised to incorporate SRP comments.
Revision indicators are not shown as the report was reformated.
Note:
Sequoyah Applicability Only PREPARATION PREPARED BY:
R. IIALVERSON
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SIGNATURE -
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REVIEWS PEER:
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' T AunAIURE DATE TAS:
SIGNATURE DATE CONCURRENCES hlh SRP :
SIGNATURE DATE SIGNATURE
- DATE APPROVED BYt N/A ECSP MANAGER DATE MANAGEE OF NUCLEAR DATE POWER CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in flies.
0702030233 870126 PDR ADOCK 05000327 P
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TVA EMPLOYEE CONCERNS REPORT NUMBER f
MEPORT TYPE:
SPECIAL PROGRAM 80201-SQN 3
Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 2 0F 15 1.0 CHARACTERIZATION OF ISSUES O
1.1 Introduction The issues described in this Element Report were derived from employee concerns generated as a result of the Watts Bar Employee Concern Special Program.
The issues were determined to be applicable to the Sequoyah Nuclear Plant and were investigated and eva lua ted on that basis.
1.2 Description of Issues The perceived issues reported by concerned employees are:
A.
Vendor welds are substandard.
(JAN-85-001 and JLH-85-005)
B.
Quality Assurance (QA) Program Adequacy.
(XX-85-050-001, XX 050-003, XX-85-102-006, and XX-85-125-006) 2.0
SUMMARY
2.1 Sumary of Characterization of Issues The overall issues raised by concerned employees suggest that certain vendor weld s made by Sou thwe s te rn Engineering Company (SECO) and National Valve and Manufacturing Company (NAVCO) are substandard.
The adequacy of the QA program is questioned regarding installation of instrument compression fittings, visual acceptance criteria which covers the American Society of Mechanical Engineers (ASME),Section II, and TVA's Procurement Program regarding replacement parts for safety related equipment.
2.2 Sumary of Evaluation Process The Quality Assurance Category Evaluation Group (QACEG) Evaluation consisted of reviewing the appropriate requirements contained in documents such as:
Appendix B to 10CFR50; TVA's Topical Report; Nuclear Quality Assurance Manual (NQAM);
ASME Codes; Standards; Specifications; Procedures; Instructions; and Reports.
In addition, discussions we re he ld with cognizant personnel to gain additional l
information to aid in this investigation.
2.3 Summary of Findings 1
The conclusions reached as a results of the QACEG Evaluation are:
i l
The issues of vendor welds being substandard are substantiated.
A total of twenty-four welds made by SECO were identified as requiring rework.
Verification 01 repair work was per formed by Quality Control I
i
p 8
e TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PkOGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:.
3 Inspection Criteria PAGE 3 0F 15 Inspectors and documented in a work plan.
Three welds made by NAVC0 were also identified as requiring rework.
A maintenance request was issued and the welds were repaired.
The issue of inadequate QA controls is partially substantiated.
The QA Program controls for the installation of instrumentation compression fittings are inadequate or nonexistent.
The employee concerns regarding the visual examination procedure covering ASME Section II and TVA's Procurement Program allowing safety related parts to be purchased commercially are not substantiated.
2.4 Corrective Action Taken And The Results Achieved To Date Substandard welds made by SECO have been satisfactorily repaired.
Verification of repair work was performed by QC Inspection and documented in SQN Work Plan 11777.
NAVC0 welds which were visually unacceptable to TVA's Procedure N-VT-3 were reworked and-documented on Maintenance Request A-561926.
Nuclear Safety Review Staff (NSRS) investigation of instrument compression fitting installation activities was documented in NSRS Report I-85-329-SQN.
This report provided four recoausendations which included evaluate compression inadequacies for general applicability; inspection and noninspection personnel training; and Quality Control Inspection.
Inadequate compression fitting installation was also reported to the Nuclear Regulatory Commission under the rules of 10CFR50.55 (e) via NCR 6278.
TVA transmitted their final response to the NRC on July 30, 1986.
3.0 LIST OF EVALUATORS W. M. Akeley R. D. Halverson J. E. Mann 4.0 EVALUATION PROCESS 4.1 General Methods of Evaluation Methods of evaluations included reviewing the appilcable TVA QA Program requirements and implementing procedures related to the issues.
Documentation was reviewed and discussions were held with the appropriate cognizant personnel.
r o
e TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 4 0F 15 4.2 Specifics of Evaluation 4.2.1 Issue -
Vendor welds are substandard Reviewed Employee Concern Files including the Confidential Files for any additional information.
The Confidential Files contained additional information regarding the identification of the specific Sc,00 and NAVC0 welds in question.
Reviewed Maintenance Request (MR) A-561926, dated 11/27/86, utilized in the repair of the NAVC0 welds and work plan 11777 which was utilized to repair the SECO welds.
Procedures N-VT-3, Rev.
4,
" Visual Examiniation";
N-VT-4, Rev.
2,
" Liquid Penetrant Examination";
10CFR50.55a " Codes and Standards";
ASME Section XI, Division I,
IWA 4000, 1980 Edition, Winter 1981 addenda, " Rules for Inservice Inspection of Nuclear Power Plants Components"; and American National Standards Institute (ANSI) B31.7, 1969 Edition, Summer 1970 addenda were reviewed to determine the weld acceptance criteria.
Reviewed ASME Section XI Summary
- Report, dated 1/20/86, indicating rework performed on NAVC0 welds and inspections conducted.
Inspected the three NAVC0 Safety Injection Welds (315D, 315E, and 316A) as identified on Drawing A 7257, Rev.
4, Piece Mark 151-134.
4.2.2 Issue - QA Program Adequacy This issue addresses three areas of TVA's Quality Assurance Program. The adequacy of the program is questioned regarding:
A.
Installation of Instrument Compression Fittings.
B.
Visual Acceptance Criteria for ASME Section II.
C.
Procurement of safety related parts.
Installation of Instrument Compression Fittings Reviewed Employee Concern Flie including Confidential Files for any additional information pertaining to this concern.
NSRS Report I-85-329-SQN (Attachment B) had been issued documenting the investigation and findings of this concern.
This report was reviewed and its content re-evaluated.
Specifications, Procedures, Standards, Codes, Reports, and Memorandums reviewed during this investigation are included in the NSRS Report " Documents Reviewed During Investigation I 329-SQN and References".
r TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 5 0F_15~
Visual Acceptance Criteria for ASME Section II Reviewed Employee Concern Files including the Confidential File for any additional information pertaining to this concern. No additional information was available.
Reviewed ASME Section II, Parts A, B, and C, 1974 Edition and TVA Procedure BF-16.4, Rev.
O,
" Material, Components, and Spare Parts Receipt, Handling, Storage, Issuing, Return to Storeroom, and Transfer".
Held discussion with a cognizant individual from Quality Assurance to determine if TVA has ever established and implemented a Visual Examination Procedure related to ASME Section II.
Procurement of Safety Related Parts Reviewed Employee Concern File including the Confidential File for any additional information pertaining to this concern.
No additional information was available.
Reviewed Appendix B to 10 CFR 50; TVA Tcpical Report, TVA-TR75-1A/R8; Nuclear Quality Assurance Manual (NQAM) Part III, Section 2.1
" Procurement of Materials, Components, Spare
- Parts, and Services";
Division of Purchasing Procurement Manual, Revision 6/21/83; Reg. Guide 1.123, " Quality Assurance Requirements for the Control of Procurement of Items and Services for Nuclear Power Plants"; and Sequoyah Nuclear Plant Standard Practice (SQA 45), Rev.
21,
" Quality Control of Material and Parts and Services".
These documents were reviewed to determine the requirements and commitments for the procurement of items.
Held discussions with three cognizant personnel from Power Stores and Quality Assurance on the aspects of this concern.
5.0 FINDINGS 5.1 Findings on Issue - Vendor Welds are Substandard 5.1.1 Discussion As stated in an un-numbered NSRS "Onsite Employee Concern Impact Evaluation", a survey was performed by a QC Inspector, a SECO representative, and the cognizant engineer to identify the defective welds.
A total of 24 welds were identified as requiring rework.
SQN Work Plan 11777 was reviewed and affected welds were reworked.
Verification of repair work was
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i.,
4 TVA EMPLOYEE CONCERNS REPORT NUMBER:
i REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
i-TITLE:
3 Inspection Criteria PAGE 6 OF 15 1
i-performed by QC Inspection and documented in the Work Plan.
The un-numbered NSRS evaluation "Onsite Employee concern 4
Impact Evaluation" indicated that the concerned employee was i.
notified of the repair work and the employee was satisfied.
i 3
The three NAVC0 safety injection welds specified in this issue i
were identified as 315D, 315E, and 316A.
The welds were located in Fan Room #1, Unit 1,
near valve 1-63-649 at the ceiling above the ladder access opening.
Several photographs I
were taken by TVA Quality Assurance personnel showing actual weld conditions.
The welds were determined to be unacceptable in that they violated the visual acceptance requirements of N-l VT-3.
-Maintenance Request A-561926 was generated describing i
the rework necessary to correct the identified conditions.
j Corrective Action consisted of grinding areas identified as unacceptable and performing the necessary nondestructive examinations (LP & UT) required for final acceptance in accordance with ANSI B31.7, 1969 Edition, Summer 1970 Addenda.
Work was completed on January 20,
- 1986, with ANI/ANII j
concurrence.
1 As part of the QACEG concern evaluation, an inspector from the l
TVA Quality Control group and a QACEG Investigator verified weld identification and performed visual inspection of the i
three welds in question to further substantiate corrective action and the proper closure of _ the Maintenance Request.
This reverification concluded that all items were acceptable l
and that rework and reinspections were in accordance with the i
i work instructions specified in the Maintenance Request.
i j
5.1.2 Conclusion This issue is substantiated in that the welds in question were j
determined to be visually unacceptable.
NAVC0 Welds, although i
visually unacceptable to the requirements of TVA's Procedure
{
N-VT-3, did not require Visual Weld Examination by the l
I Fabrication Code, ANSI B31.7.
- However, the unacceptable
{
conditions were properly identified and corrective action was j
accomplished in a satisfactory manner.
]
5.2 Findings on Issue - QA Program Adequacy i
A.
Installation of instrument compression fittings l
B.
Visual acceptance criteria for ASME Section II j
C.
Procurement of safety related' parts l
{
5.2.1 Discussion - Installation of instrument compression fittings i
l An NSRS Investigation (I-85-329-SQN, dated 2/11/86) was j
conducted to determine the validity of this issue as received l
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
t 4
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE-7 0F 15 by the Quality Technology Company (QTC)/ Employee Response Team (ERT).
This report was reviewed by QACEG, its contents re-evaluated, and the report was found to be accurate and factual.
In addition to this investigation, NSRS has - conducted two previous investigations of matters closely related to the above concern of record.
Those investigations resulted in specific reconusendations from NSRS which were determined to be applicable to this issue.
Those investigations are documented as follows:
Reference 1 NSRS Report No. R-85-02-SQN/WBN presents the results of a special review which was performed ta investigate concerns expressed by Crawford Fitting Company.
Those concerns involved potential misapplication of the Swagelock tube fittings on the Westinghouse designed bottom-mounted incore instrumentation system seal tables.
The report presents NSRS recommendation R-85-02-SQN-WBN-01 to NUC PR of fice-wide awareness bulletin on tube fitting maintenance activities.
Reference 2 NSRS Report No. IN-85-795-001; IN-85-795-002 presents the results of an investigation which was conducted regarding two employee concerns pertaining to Watts Bar.
Concern No. IN-85-795-001 stated that compression fittings on instrument tubing are not installed per vendor instructions. The report contains evidence of potentially significant conditions adverse to
- quality, and NSRS recommendation Q-85-795-001-01 states that an evaluation of this situation should be conducted for generic applicability to all TVA plants.
Reference 1 presented NSRS' reconenendation R-85-02-SQN-WBN-01 which addressed the need for increased awareness of the critical and somewhat delicate nature of compression tube fittings in general.
The reconusendation specifically encouraged NUC PR to prepare and distribute to the nuclear plants an office-wide awareness bulletin or similar mechanism to achieve an increased awareness.
This bulletin was issued September 20, 1985 to the nuclear plants with direction to take the following actions:
Issue the bulletin to employees whose work activities involve tube fittings.
Incorporate the concerns and policy stated in the bulletin into permanent hazard control instructions and plant instructions as appropriate.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 8 0F 15 Coordinate with the Nuclear Training Branch and implement training for employees involved in installation and maintenance of the tube fittings.
The text of the bulletin contains the following statements:
"Sequoyah has initiated a training class on tube fittings in cooperation with the Power Operations Training Center (POTC)."
"It is P&E (Nuclear) policy that compression-type tube fittings be installed consistent with manufacturer's instructions and that maintenance activities involving these fittings shall not degrade the integrity of these fittings.'
Reference 2 presented NSRS' recommendation Q-85-795-001-01 which addressed evidence of a potentially significant condition adverse to quality regarding compression fitting inadequacies at Watts Bar (WBN).
The following actions were recommended and the results indicated:
NCR WBN-6278R0 was initiated to document the safety significance of the inadequacy of quality assurance controls on compression fitting installation for tubing connections.
The NCR states that installations were discovered at WBN which did not agree with the manufacturer's installation instruction.
The condition was identified as "significant".
- b. The response to HSRS should include the results of an evaluation of this condition for generic applicability to all TVA plants.
It was determined that this evaluation had not been performed as of January 7, 1986.
NCR WBN-6278R0 received an engineering review by OE in accordance with the requirements of OEP-17, paragraph 3.2; OE has not performe I an evaluation for generic implications of the condition to Sequoyah and Browns Ferry.
- c. NCR WBN-6278R0 directed that Office of Engineering (OE) evaluate compression fitting installation to determine the need for possible TVA process specification revisions.
As a result, OE developed a process specification 3.M.13.1 for installation and inspection of compreasion fitting joints in mechanical tubing systems.
This specification is applicable to all TVA projects.
Advance copies were distributed to all plant sites on January 2, 1986.
SQN DCU will route a copy to the SQN Hodifications Branch for review.
- d. NCR WBN-6278R0 directed that OE provide analyses for certain compression fitting connections to determine the acceptability
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:-
'SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 9 0F 15-l of these installations although leak tightness is achieved.
These analyses were performed by TVA's Singleton Materials 2
Engineering Laboratory, and the results-of the testing program are documented _(Reference Attachment C).
The results provide technical information concerning the reliability and safety of compression fittings which may not have been installed with the manufacturer's recommendations but which achieve leak tightness.
On August 19, 1985, the Power Operations Training Center (POTC) established an initial tube fitting training program in cooperation with SQN.
This program is intended to provide
- individuals who install tube fittings with the necessary information to properly install tube fittings to ensure a leak-proof, mechanically sound tubing connection.
The course material covers the most conunonly used brands of tube fittings.
Criterion II, requires that structures, systems, and components covered by.the QA program be identified:
Instrument sensing lines in safety-related systems have been1 identified in the QA programs for design and construction (Ref. Construction Specification N2G-877 " Identification of Structures, Systems, and Components covered by the Sequoyah Nuclear Plant QA Program") and for the operation phases of SQN i-(Ref. SQA-134, " Critical Structure, Systems, and Components List").
10.CFR Part 50, Appendix B, Criterion II, also requires that the QA program provide control over activities affecting the quality i
of the identified structures, systems, and components to an extent consistent with their importance to safety:
The procedure which provided progrm=natic QA controls of activities during the construction phase of SQN is identified in-DEDC-QAP-2.0 However, lower-tier inspection procedures applicable to-instrument sensing lines did not include
+
provisions for quality control inspection of compression i'
fitting installation activities.
The procedure which provides programmatic QA controls of maintenance activities during the operational phase of SQN is identified in NUC PR QA Manaual Part II, Section 2.1.
- However, lower-tier SQN instructions applicable to instrument sensing lines do not include provisions for quality control inspection of compression fitting installation or maintenance activities.
Repaired-instrument sensing lines are inspected by quality control personnel for cleanliness and leakage after reassembly.
Lower-tier SQN instructions (MI-1.9, revision 7,
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.TVA EMPLOYEE CONCERNS REPORT NUMBER:'
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN
. Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria
-PAGE 10 0F 15 Instrument Thimble Tube Retraction and Reinsertion", and MI-1.10 revision 3,
"Incore Flux Thimble Cleaning and Lubrication")
applicable to instrument thimble tubes do include quality control hold point provisions for mechanical verification and signoff, as well as cleanliness checks.
10 CFR Part 50, Appendix B, Critierion II, also requires that the QA program provide for indoctrination and training of personnel performing activities affecting the quality of the identified structures, systems, and components as necessary to assure that suitable proficiency is achieved and maintained:
The progransnatic training requirements applicable to the construction phase of SQN were established.
The implementing doucument, QC-4,
(" Quality Control Instrumentation"). contained.
modules for ' quality control inspector certification but not modules for training of personnel involved in installation of compression tube fittings.
The inspector certification module for instrument lines and loops had not been implemented by the time SQN construction was completed.
The progransnatic training requirements applicable to the operational phase of SQN are established by NUC PR QA Manual, Part III, Section 6.1.
Training requirements for training personnel are addressed in this procedure.
The lower-tier SQN instruction AI-14
(" Plant Training Program") which implements this procedure addresses maintenance personnel training also, including personnel whose job function involves the installation of compression-type fittings on instrument sensing lines.
However, the courses listed for these personnel do not cover tube fittings even-though the office-wide bulletin previously discussed directs plant management to " implement training for employees involved in installation and maintenance of tube fittings."
i Sequoyah Manuals SMI-1-68-20 and IMI-118 are examples of SQN l
maintenance instructions which involved compression-type fitting i
installation but do not specify personnel training requirements.
j Instruction MI-1.9 involves the installation of compression-type fittings on the instrument thimble tubes and does not specify that "all personnel working on tube fittings should have had the tube fitting class."
However, even this instruction does not clearly establish the training as a requirement.
SQN management is committed to the training of these personnel i
(e.g., Mechanical Test Unit); however the applicable instructions do not formalize the requirement.
In addition, the NUC PR Quality Inspector Training Manual establishes the training requirements for quality control inspector certification.
These requirements do not include instruction in inspection of
m r
a TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 11 0F 15 installation of compression-type fittings.
However, quality control inspection is required in MI-1.9 "to verify that the tube fittings are properly tightened."
10 CFR Part 50, Appendix B, Criterion V, requires that activites affecting quality be prescribed by documented instructions, procedures, or drawings:
The above paragraphs address several instructions and procedures applicable to activities affecting the quality of instrument sensing lines.
In addition to these documents, SQN engineering drawings and construction specifications essentially prescribed the only requirements pertaining to 4
instrument sensing line installation and quality requirements.
These documents contain very little specific instruction / guidance for compression-type fitting installation.
However, this situation has improved with the development and distribution of Process Specification 3.M.13.1, Revision 0, dated December 9, 1985, " Specification for installation and inspection of compression fitting joints in mechanical tubing systems."
I NSRS Report I-85-329-SQN provided four recommendations regarding installation of compression fittings.
They were, I-85-329-SQN-01, evaluate coopression fitting inadequacies of NCR WBN-6278 for generic applicability; I-85-329-SQN-02, provide Noninspection Personnel Training; I-35-329-SQN-03, provide Inspection Personnel Training, and I-85-329-SQN-04, provide site requirements-for Quality Control Inspections, f
SQN response to I-85-329-SQN-01 indicated that NCR WBN 6278 was reviewed for generic applicability for all compression fitting installations within the scope of the Watts Bar QA Program.
The response further stated that a Significant Condition Report (SCR)
SCR 6278-S R0 (identical to NCR WBN 6278) was issued.
The SCR form goes into more detail, particularly in the generic condition area.
SQN response to I-85-329-SQN-02 indicated that plant maintenance personnel responsible for installation and maintenance of l
compression-type fittings attended a formal training course, "Given by the Nuclear Training Branch, Power Operations Training Center (POTC)."
In addition, the plant QA Staff is working with plant management to determine if the training requirements need to be incorporated into the applicable plant procedures.
SQN response to I-85-329-SQN-03 states that the Quality Control (QC) inspectors attended the training course identified in the response to I-85-329-5QN-02 prior to being assigned verification activities for compression-type fittings.
This training provides g g y g g u g g gor the QC inspectors to perform the required
~
e TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 12 0F 15 SQN response to I-85-329-SQN-04 states that plant QC inspectors are currently performing inspections on the compression fittings during maintenance and modifications when required by the appropriate work instructions.
However, there is no upper-tier or site requirement to perform these inspections, and these activities will be included in SQN Work Instructions at the discretion of the QA Staff.
Inadequate Compression Fitting Installation was reported to the Nuclear Regulatory Commission under the rules of 10CFR50.55 (e) via NCR 6278.
TVA transmitted their final response to the NRC on July 30, 1986 (L44 860730 816 Attachment C).
This response included a description of TVA's evaluation process and the results.
A sample inspection of compression fittings identified discrepancies in the following areas:
tubing cuts not deburred;-
tubes not bottomed out inside the fittings; nuts were not properly tightened; and ferrules were either unidentifiable, missing, or reversed.
TVA's corrective actions included a Laboratory Testing Program to determine the long term affect on installed instrument systems with the above noted discrepancies.
Affected drawings, process specification, and instructions and procedures were, or are being revised to prevent recurrence of this problem.
5.2.2 Conclusion Critierion X of 10CFR50, Appendix B requires that a program for inspection of activities affecting quality be established and executed to verify conformance with the prescribed requirements for accomplishing the activity.
The employee concern is substantiated because this investigation has revealed that quality assurance program controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10CFR50, Appendix B,
relative to compression fitting installation.
This condition existed during the construction phase and has existed in the operational phase of SQN.
5.2.3 Discussion - Visual Acceptance Criteria for ASME Section II Concern of record indicates the visual examination procedure which covers ASME Section II is very nonspecific.
Based on review of pertinent documents and discussions with cognizant personnel, it was concluded by this investigation that TVA does not have a visual examination procedure that pertains to ASME Section II.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
' REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 13 0F 15 5.2.4 Conclusion This issue is not substantiated.
ASME Section II has no visual examination requirements for a fabricator and/or installer.-
5.2.5 Discussion - Procurement of safety related parts Concerned employee states that the TVA System Procurement Manual allows procurement of IE, safety related NSSS and hold devices to be purchased commercially, and not through qualified suppliers because they are part of a larger component.
NOTE: The concern refers to " hold" devices. It is assumed that this is a misspelling and that the CI is referring to equipment used in Class IE application ( device as a whole which requires qualification by the supplier or manfacturer.)
During the investigation, it was determined that there is no TVA System Procurement Manual as noted in the concern.
There is a Division of Purchasing Procurement Manual, Revision June 4
21, 1983, which references the Nuclear Quality Assurance Manual for quality requirements.
The governing directive is the Nuclear Quality Assurance Manual (NQAM), Part III, Section 2.1,
" Procurement of Materials, Components, Spare Parts, and Services".
Lower-tier documents are Sequoyah Nuclear Plant l
Standard Practice (SQA 45), Revision 21, June 23,
- 1986,
" Quality Control of Material and Parts and Services", and Watts Bar Nuclear Plant Administrative Instruction, AI-5.1, Revision 19, March 26,
- 1986,
" Materials Procurement and Control." These directives require that:
Items which are QA Level I must be procured from suppliers who have a QA Program approved by Division of Quality Assurance, Procurement Evaluation Branch (DQA PEB).
QA Level II items may require the supplier have an approved QA program -which conforms to the original requirements.
For QA Level II and III items that require a Certificate of Conformance (COC), the vendor shall be required to have a DQA PEB approved C0C program that meets the requirements of NQAM Appendix E,,
Part III, Section 2.1 (QA Requirements for a Certificate of Conformance Non-ASME Code Items and Small Products).
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
3 Inspection Criteria PAGE 14 0F 15 For all QA Level II and III items, the vendor shall be required to furnish a completed copy of Appendix D (Changes / Substitutions for QA Level II and III Items), or the suppliers own certificate which provides the information requested, when the item offered is not identical to the contract requirements.
Suppliers of equipment used in Class 1E application (device as a whole which requires qualification by supplier or manfacturer) to include electrical wire and cable shall be required to have a QA program which conforms to the applicable portions of ANSI N45.2 or 10CFR 50, Appendix B.
Suppliers of commercial grade equipment that has been qualified for Class 1E application of TVA (replacement equipment must be identical to equipment qualified) shall comply with the QA program requirements for a Certificate of Conformance.
Suppliers of standard design, conumercial grade replacement parts (subcomponent, assembly, or module) inside equipment used in a Class 1E application (device as a whole which requires qualification), as a minimum shall attest to the in-kind replacement requirements of the contract by j
furnishing a
completed copy of Appendix D
(Changes / Substitutions for QA Level II and III Items) or the supplier's own certificate which provides the information requested when the item is not identical to the contract requirements.
5.2.6 Conclusion Based on review of the above documents and discussions with cognizant personnel, this concern, as written, cannot be substantiated.
As noted in the Summary of Findings, adequate controls are in effect that preclude procurement of safety related material from unapproved suppliers.
It should be noted that the concern refers to a specific case known to Quality Technology Corporation (QTC) and withheld to maintain confidentiality.
This case was unobtainable during the investigation therefore the details could not be verified.
i 5.3 Corrective Actions Substandard welds made by SECO have been satisfactorily repaired.
A Corrective Action Tracking Document (CATD) 80201-SQN-01 (Attachment D) was issued to the Office of Nuclear Power (ONP).
The CATD identified that although the SECO welds were repaired, there was no sample inspection performed on other welds made by SECO.
The SQN Site
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN
' Element Report REVISION NUMBER:
TITLE:
3 l
Inspection Criteria PAGE 15 0F 15 Director responded to this CATD on October 20, 1986.
The response stated that SECO performed work at Sequoyah only once.
Sequoyah Modifications requested that Sequoyah Quality Assurance perform a survey.
This survey was conducted by Quality Assurance with the participation of a SECO representative, and documented on In plant Survey Checklist 21-85-5-021.
Deficient welding was identified and corrected by TVA.
The response went on to say, "It is therefore f
concluded that the inspection / review effort did include the majority of welding performed by SECO with repairs being completed accordingly; thus, no additional surveys are warrented".
QACEG concurs with this response and considers the issued closed.
Recent actions have been taken by SQN management ~and others to improve the controls in the. area of compression fitting installation.
However, QACEG has issued a Corrective Action Tracking Document (CATD) 80201-SQN-02 (Attachment E) on September 12, 1986, which. identifies the lack of training requirements in various procedures.
The SQN Site Director responded on October 20,
- 1986, committing revision to Administrative Instruction (AI) 14 to include reference to tube fitting class MTU-MMT-28.
QACEG also issued CATD 80201-SQN-03 (Attachment F) - identifying that-TVA's commitment to the NRC of developing Procedure. MAI-29,
" Instrument Tube Fitting and Ir.sta11ation" and issuing it by August J
15, 1986 has not been accomplished to date.
Attachment A,
identified the concerns as potentially safety-significant or safety-related.
QACEG evaluation concludes that only
}
concerns JAN-85-001 and XX-85-050-001 were potentially safety-significant.
However, corrective measures, as described in this report, have and are being taken.
6.0 ATTACHMENTS A.
Employee Concern Program System (ECPS) List of Employee Concern Information B.
NSRS Report I-85-329-SQN C.
Final Report for NRC Open Items WBRD-50-390/85-43, WBRD-50-391/85-42 D.
CATD 80201-SQN-01 E.
CATD 80201-SQN-02 F.
CATD 80201-SQN-03 l
i.
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ATTACHMENT A PAGE 1 OF 2 REFER 5NCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 21 FREQUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 14:41:45 i DNP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 01/21/87 EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY
- ATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80201 BASIS OF INSPECTION S
1 REPORT APPL H
2 SAF RELATED SUB R PLT 3 FIND CLASS HISTORICAL CONCERN CONCERN NUMBER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION
-=-
JAN-85-001 01 QA 80201 N SQN 1N N Y N OECP HELDING PERFORMED BY SECO (OUTSIDE CONTRACTOR) ON 2 NA NA SR NA MSR TUBE BUNDLE REPLACEMENT MODIFICATION IS SUBSTA 3 NA NA E NA NDARD.
SLAG NOT REMOVED, PIPING NOT ALIGNED PROPE
}
RLY, HELDS NOT CLEANED UP, TUBING NOT INSTALLED PR OPERLY, ETC.
,JLH-85-005 01 QA 80201 N SQN 1N N Y N OECP THIS CONCERN HAS NOT DOCUMENTED PER SQA166 BUT HAS 2 NA NA SS NA BEEN INCLUDED IN THE EMPLOYEE CONCERN LOG.
THREE 3 NA NA E NA SAFETY INJECTION HELDS ON NAVCD SPOOL PIECES DISP LAYED EXCESSIVE OVERLAP, ARC STRIKES, UNDERCUT HEA i
VE HIDTH, AND RUST.
THESE HELDS HOULD NOT MEET CU RRENT ACCEPTANCE CRITERIA.
XX 050-00101 CD 17300 S SQN 1
I-85-329-SQN QTC INADEQUATE QUALITY ASSURANCE CONTROLS HERE APPLIED T50096 2
TO THE INSTALLATION OF INSTRUMENT TUBING COMPRESS 3
ION FITTINGS AT SEQUDYAH. NO FURTHER INFORMATION 02 QA 80201 S SQN 1N N Y N AVAILABLE. NO FOLLOH UP REQUIRED.
2 NA NA SS NA 3 NA NA E NA i
NA
,XX 050-00301 CO 17300 S BLN 1Y Y Y Y QTC INADEQUATE QUALITY ASSURANCE CONTROLS ARE APPLIED T50096 2
TO THE INSTALLATION OF INSTRUMENT TUBING COMPRESSI 3
DN FITTINGS AT BELLAFONTE. NO FURTHER DETAILS AVA s
02 QA 80201 S BLN 1N N Y N ILABLE. NO FOLLOH UP REQUIRED.
2 NA NA SR NA 3 NA NA E NA 03 QA 80202 S BLN 1Y Y N Y i
2 SR SR NA SR 3
NA (X 102-00601 QA 80201 S BFN 1N N Y N QTC BROWN'S FERRY: THE VISUAL EXAMINATION PROCEDURE HH T50172 2 NA NA SR NA ICH COVERS ASME SECTION II IS VERY NON SPECIFIC.
3 NA NA A NA NUCLEAR P0HER DEPT. CONCERN. CI HAS NO ADDITIONAL 1
02 QA 80202 S BFN 1Y Y N Y INFORMATION. NO FOLLOH UP REQUIRED.
I 2 SR SR NA SR 3
NA l
e 1
ATTACHMENT A PAGE 2 0F 2
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REFER'ENCE
- ECPSI20J-ECPSI2IC TENNESSEE VALLEY AUTHORITY FREQUENCY
- REQUEST PAGE 22 ONP - ISSS - RHM OFFICE OF NUCLEAR POWER RUN TIME - 14:41:45:
EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 01/21/87 EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY CATEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80201 BASIS OF INSPECTION S
1 REPORT APPL H
2 Sfr RELATED SUB R PLT 3 F.tND CLASS HISTORICAL CONCERN CONCERN NUM CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION L-----------BER---
XX 125-00601 QA 80201 S NPS 1N N Y N QTC KNOXVILLE - THE TVA SYSTEM PROCUREMENT MANUAL ALLO T50221 2 NA NA SS HA HS PROCUREMENT OF IE, SAFETY RELATED, NSSS AND HOL 3 NA IIA A NA D DEVICES EQUIPMENT TO BE PURCHASED COMMERCIALLY, 02 QA 80202 S NPS 1Y Y N Y NOT THROUGH QUALIFIED SUPPLIERS, BECAUSE THEY ARE 2 SS SS NA SS PART OF A LARGER COMPONENT.
(NAMES / DETAILS TO THE 3
NA l
SPECIFIC CASE ARE KNOHN TD QTC AND HITHHELD TO MA INTAIN CONFIDENTIALITY). NUCLEAR P0HER CONCERN CI HAS NO MORE INFORMATION.
6 CONCERNS FOR CATEGORY QA SUECATEGORY 80201 1
1 i
e
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c ATTACHMENT B,
.Tv A +4 ios e-es) comwns-es)
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UNITtD STATES GOVERNMENT Memorandum rzwussszz vatter Aurnoniry TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant R. W. Cantrell, Manager of Engineering, W12Al2 C-K FROM: K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K
((g } $ }986 DATE:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL
SUBJECT:
Transmitted herein is NSRS Report No.
I-85-329-SON Subject OUALITY ASSURANCE CONTROLS / COMPRESSION FITTING INSTALLATION h
Concern No.
XX-85-050-001 and associated prioritized recomendations for your mTin"l, y,,3 f
,313'd action / disposition.
i.%
It is requested that you respond to this report and the attached.K(urg i,i
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Priority 2 [P2) recommendations by February 28. 1986. -Shonit. yde lhO; any S-i f
I at telephone p'J p-questions, please contact W. D. Stevens_
Recommend Reportability Determination: Yes NF i~
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///,
/ Eector, NSRS/ Designee WDS:GDH Attachment
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cc (Attachment):
W. C. Bibb, SQN W. T. Cottle, WBN James P. Darling, BLN R. P. Denise, LP6N40A-C G. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C J. H. Sullivan, SQN 455U 4
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- __. n,.
- .. c 3
TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-85-329-SQN
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EMPLOYEE CONCERN: XX-85-050-001
- s QUALITY ASSURANCE CONTROLS FOR COMPRESSION FITTING
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SUBJECT:
INSTALLATION DATES OF INVESTIGATION:
SEPTEMBER 18 - OCTOBER 8, 1985 A
STIGATOR:
DATE R. E. MCCLURE uE - -
A[7 d
INVESTIGATOR:
DATE W. R. SIMONDS
~~.-
^
9 N
2 4
[.
REVIEWED BY:
M. W. ALEXANDER -
DATE
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D t
=
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APPROVED BY:
DATE
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W. D. STEVENS A
eGazano-j ag
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I.
BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the vali'dity of an expressed employee concern as received by the Quality _ Technology Company (QTC)/ Employee Response Team (ERT). The concern of record, as sununarized on the Employee Concern Assignment Request Form from QTC and identified as IX-85-050-001, stated:
" Inadequate quality assurance controls were applied to the installation of instrument tubing compression fittings at Sequoyah."
In adiition to this investigation, NSRS has conducted two previous investigations of matters closely related to the above concern of record. Those investigations resulted.in specific recommendations from NSRS which were determined to be applicable to this employee concern.~
Those investigations are documented as follows:
A.
NSRS Report No. R-85-02-SQNIWBN (Ref. 1) presents the results cf a special review which was performed to investigate concerns expressed by the Crawford Fitting Company. Those concerns involved potential g
misapplication of the Swagelock tube fittings on the Westinghouse designed bottom-mounted incore instrumentation system seal tables.
The report presents NSRS recommendation R-85-02-SQN/WBN-01 to NUC PR for the preparation and distribution to the nuclear plants of an office-wide awareness bulletin on tube fitting maintenance activities.
B.
NSRS Report No. IN-85-795-001; IN-85-795-002 (Ref. 2) presents the results of an investigation which was conducted regarding two employee concerns pertaining to Watts Bar. Concern No.
IN-85-795-001 stated that compression fittings on instrument tubing,
are not installed per vendor instructions.
The report contains evidence of a potentially significant condition adverse to quality.
~
and NSRS recotamendation Q-85-795-0'0'l'-01 states that an evaluation-of-
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this situation should be conducted for generic applicability to all TVA plants.
II.
SCOPE A.
The scope of the investigation is defined by the concern of record.
Since previous NSRS investigations involved matters closely related 3
l to this concern, the results of those investigations were included as appropriate in the findings of this investigation.
B.
Reviews of regulations, specifications, and other pertinent docu-ments were performed to identify requirements, commitments, and programmatic controls applicable to the concern of record.
Cognizant personnel were interviewed to help establish the manner in which compression-type fittings have been installed at SQN.
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III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments '
1.
Criterion II, " Quality Assurance Program" b.
Criterion V, " Instructions, Procedures, and Drawings"
~
Criterion I, " Inspection" c.
~~
2.
Topical Report TVA-TR75-1, Revision 8 a.
Section 17.1.2.3, " Indoctrination and Training" b.
Section 17.1.5, " Instructions Procedures, and Drawings".
c.
Section 17.2.2.3, " Indoctrination and Trainin'"
s d.
Section 17.2.5, " Instructions, Procedures, and Drawings" e.
Section 17.2.10. " Inspection" 3.
OEDC Quality Assurance Manual for Design and Construction OEDC-QAP-2.0, " Quality Assurance Program," Revision 1 a.
b.
QAS-QAP-4.1, " Quality Assurance Indoctrination and Training," Revision 0 c.
CONST-QAP-2.02, " Quality Assurance Items," Revision 0 d.
CONST-QAP-2.07, " Qualification /Cartification of. Inspection.
~
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Examination, and Testing Personnel " Revision 3 -
CONST.QAP-10.01, "In'spection " Revision 2 e.
4.
Sequoyah Nuclear Plant General Design Criteria No..SQN-DC-V-3.0, "The Classification of Piping, Pumps, Valves, and Vessels,"
Revision 1 5.
Sequoyah Nuclear Plant Construction Specification No. N2M-865,
" Field Fabrication, Assembly Examination, ind Tests for Pipe Duct Systems," Revision 3 6.
Sequoyah Nuclear Plant Construction Specification No. N2G-877,
" Identification of Structures Systens, and Components Covered by the Sequoyah Nuclear Plant Quality Assurance Program,"
Revision 5 2
1
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i 7.
NUC PR Nuclear' Quality Assurance Manual Part II, Section 2.1,~ " Plant Maintenance," Revision 10/12/84 a.
b.
Part III, Section 6.1, " Selection and Training of Personnel for Nuclear Power Plants," Revision 10/12/84 B.
Findings 1.
Reference 1 presented NSRS' recommendation R-85-02-SQN/WBN-01 which addressed the need fee increased awareness of the critical
_. and somewhat delicate nature of compression tube fittings in general. The recommendation specifically encouraged NUC PR to prepare and distribute to'the nuclear plants an office-wide awareness bulletin or similar mechanism to achieve an increased awareness. This bulletin was issued September 20, 1985 (Ref. 39), to the nuclear plants'with direction to take the ',
following actions:
Issue the bulletin to employees whose work activities o
involve them with tube fittings, Incorporate the concerns and policy stated in the bulletin o
into permanent hazard control instructions and plant instructions as appropriate.
Coordinate with the Nuclear Training Branch and implement o
training for employees involved in installation and maintenance of the tube fittings.
The text of the bulletin contains the following statements:
Sequoyah has initiated a training class on tube fittings in o
cooperation with the POT,C,.,,,
It is'P&E (Nuclear) policy that compression-type tube o
fittings be installed consistent with manufacturer's instructions and that maintenance activities involving these
(
-fittings shall not degrade the integrity of these fittings.
l 2.
Reference 2 presented NSRS' recommendation Q-85-795-001-01 which addressed evidence of a potentially significant condition adverse to quality regarding compression fitting inadequacies at Watts Bar (WBN). The following actions were recommended and the results indicated:
WBN CONST should initiate an NCR documenting this condition--
a.
ASME Significant NCR WBN-6278R0 (Ref. 21) was initiated to document the safety significance of the inadequacy of i
quality assurance controls on compression fitting l
installation for tubing connections. The NCR states that installations were discovered at WBN which did not agree with the manufacturer's installation instructions. The condition was identified as "significant."
l 3
l 1
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a b.
The response to NSRS should include the results of an i
evaluation of this condition for generic applicability to all TVA plants--it wa's determined that this evaluation had not been performed as of January 7, 1986. NCR WBN-6278R0 received an engineering review by OE in accordance with the requirements of OEP-17 (Ref. 36) but contrary to OEP-17, i
paragraph 3.2, OE has not performed an evaluation for generic implications of the condition to Sequoyah and Browns Ferry.
NCR WBN-6278R0 directed that OE evaluate compression fitting c.
installation to determine the need for possible TVA process
~
specification revisions.
As a result, OE developed a process specification (Ref. 27) for installation and inspection of compression fitting joints in mechanical tubing systems. Tnis specif(pation is applicable to all,TVA proj ects. Advance copies were distributed to all plant,
sites on January 2,. 1986. SQN DCU will route a copy to the SQN Modifications Branch for review.
d.
NCR WBN-6278R0 directed that OE provide analyses for certain compression fitting connections to determine the accept-ability of these installations although leak tightness is achieved. These analyses were performed by Singleton Materials Engineering Laboratory, and the results of the testing program are documented in references 30 and 31.
The results provide technical information concerning the reliability and safety of compression fittings which may be installed inconsistent with the manufacturer's recommenda-tions but which achieve leak tightness.
3.
On August 19, 1985, the Power Operations Training Center (POTC) established an initial tube fitting training program (Ref. 28)
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in cooperation with SQN.._This,yrogram is intended to provide e
individuals who install tube fittings with the necessary information to' properly install tube fittings to ensure a leak-proof.. mechanically sound tubing. connection. The course material ' coversthe most cosmonly used brands of tube fittings.
4, 10 CFR Part 50, Appendix B, Criterion II, requires that structures, systems, and components covered by the QA program be identified. Instrument sensing lines in safety-related systems have been identified in the QA programs for design and construc-tion (paragraph III.A.6) and for the operation (Ref. 8.c) phases of SQN.
5.
10 CFR Part 50 Appendix B, Criterion II, also requires that the QA program provide control over activities affecting the quality of the identified structures, systems, p.nd components to an extent consistent with their importance to safety.
1 c>
The procedure whi'ch provided programmatic QA controls of activities during the construction phase of SQN is identified in o
paragraph III.A.3.a.
However, lower-tier inspection procedures applicable to instrument sensing lines (Ref. 35) did not include provisions for quality control inspecticn of compression fitting installation activities.
The procedure which provides programmatic QA controls of maintenance activities during the operational phase of SQN is identified in paragraph III.A.7.a.
However, lower-tier SQN instructions applicable to instrument sensing lines (Ref. 8.a-d) do not include provisions for quality control inspection of' compression fitting installation or maintenance activities.
Repaired instrument sensing lines are inspected by quality control personnel for cleanliness and leakage after reassembly.
Lower-tier SQN instructions applicable to instrument thimble tubes (Refs. 8.e-f) do include quility control hold point provisions for mechanical verification and signoff, as well as cleanliness checks.
10 CFR Part 50, Appendix B, Crite'rion II, also requires that the 6.
QA program provide for indoctrination and training of personnel performing activities affecting the quality of the identified structures, systems, and components as necessary to assure that suitable proficiency is achieved and maintained.
The programmatic training requirements applicable to the construction phase of SQN were established by III.A.3.b and d.
The implementing document (Ref. 20) contained modules for quality control inspector certification but no modules for training of personnel involved in installation of compression tube fittings. The inspector certification module for instru-ment lines and loops had not been implemented by the time SQN construction was completed.,_,,,,
The programmatic training requirements applicable to the operational phase of SQN are established by III.A.7.b.
Training requirements fo,e maintenance personnel are addressed in this procedure. The' lower-tier SQN instruction (Ref. 8.a) which implements this procedure addresses maintenance personnel training also, including personnel whose job function involves the installation of compression-type fittings on instrument sensing lines. However, the courses listed for these personnel do not cover tube fittings (e.g., Ref. 28) even though the office-wide bulletin discussed above (Ref. 39) directs plant management to " implement training for employees involyc.d in installation and maintenance of tube fittings."
5
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References 8.b and 8.d are examples of SQN maintenance instructions which involve compression-type fitting installation but do not specify personnel training requiremen.ts. Reference 8.e involves the installation of compression-type fittings on the instrument thimble tubes and does specify that "all personnel working cm tube fittings should have had the tube fitting class" (presumably a reference to the program in Ref.
28).
However, even this instruction does not clearly establish the training as a requirement.
i SQN management is apparently committed to the training of these
____ personnel (e.g., Mechanical Test Unit); however, the applicable j
instructions do not formalize the requirement.
In addition, reference 22 establishes the training requirements for quality control inspector certification. These requirements do not include instruction in inspectio,n of installation of compression-type fittings..However, quality control inspection is required in reference 8.e "to verify that the tube fittings are properly tightened."
i 7.
10 CFR Part 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented l
instructions, procedures, or drawings. The above paragraphs address several instructions and procedures applicable to activities affecting the quality of instrument sensing lines.
l In addition to these documents, SQN engineering drawings (e.g.,
Refs. 24.a-h) and construction specifications (III.A.5 and 6) l
~
essentially prescribed the only requirements pertaining to instrument sensing line erection and quality requirements until recently. These documents contain very little specific instruction / guidance for compression-type fitting installation.
However, this situation has improved with the development and l
distribution of reference 27.
I 8.
Criterion X requires that a program for inspection of activitres-affecting quality be' established and executed to verify conformance with the prescribed requirements for accomplishing the activity... Refer to paragraph III.B.$ above for findings related to this requirement.
j IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusion The employee concern is substantiated because this investigation has
]
revealed that quality assurance controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10 CFR 50, Appendix B, relative to compression fitting installation. This condition existed during the construction phase and has existed in the operational phase of SQW. However, recent actions have been taken by SQN management and others as described above to improve the controls in the area of the employee concern.
6 4
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[
B.
Recommendations 1.
I-85-329-SQN-01, Evaluate' Compression Fittinr. Inadequacies of NCR WBN-6278 for Generic Applicability This recommendation is being reiterated from Q-85-795-001-01 previously identified in the original NSRS rcport (Ref. 2) since the actions taken by P&E (Nuclear) did not completely address this recommendation as described in III.b.2.b.
Specifically, NCR WBN-6278R0 has not been evaluated for generic applicability to all TVA nuclear plants.
The NCR was transmitted to OE on September 9, 1985 (Ref. 38), for review. However, the review did not include an evaluation for generic applicability as required by OEP-17 (Ref. 36).
Although the findings presented in III.B.4-8 strongly indicate the applicability of NCR WBN-6278R0 to SQN, the final detkemination must be performed.by OE as described in OEP-17.
Therefore, NSRS recommends that N.CR WBN-6278R0 be evaluated for applicability to all TVA nuclear plants and that the results of this evaluation be documented and distributed as required by established procedures. The response to NSRS should include a statement of why the generic applicability evaluation was not performed.
[P2]
2.
I-85-329-SQN-02, Noninspection personnel Training As described in III.B.6, SQN management is apparently committed to training personnel involved in installation and maintenance of compression-type fittings. However, several applicable SQN instructions do not formalize or clearly establish the personnel training as a requirement. NSRS recommends that SQN instruc-tions applicable to the installation and maintenance of compression-type fittings be revised to establish training of personnel as a requirement as described in reference 39.
[P2]
I-85-329-SQN-03, Inspection Personnel Training s
3.
NSRS recommends that tr'aining on compression-type fittings be developed and implemented for quality control inspectors at SQN.'
This training should provide specific instruction on the inspection methodologies for verification of the quality of safety-related applications of compression-type fittings.
[P2]
4.
I-85-329-SQN-04, Ouality control Inspection NSRS recommends that requirements be established and implemented in applicable SQN instructions that quality control inspectors conduct random sample inspections of compression-type fitting installation activities. These inspections should be designed to verify and document that these activities are performed in accordance with prescribed requirements.
Inspections could be performed af ter installation but prior to hydrostatic testing.
(P2]
7
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.e DOCUMENTS REV'IEWED IN INVESTIGATION 1-85-329'SQN AND REFERENCES 1.
Special Review of Manufacturer Identified Potential Misapplication of Swagelock Tube Fittings at Westinghouse Reactor Seal Tables - NSRS Report No. R-85-02-SQN/WBN 2.
Compression Fittings on Instrument Tubing - NSRS Report No.
IN-85-795-001; IN-85-795-002
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3.
Swagekock Report on Imitation and Interchange - 1984 4.
NUC PR Area Plan Procedure 0202.15 and 0202.16, " Instrument Mechanics Training"
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5.
NUC PR DPM N77A12. " Requirements for Repair and/or Replacement of Nuclear Power Plant Process - Control Instrumentation" 6.
Swagelock " Gold Book" - Tube Fitting and. Installation Manual 7.
Westinghouse Installation and Standards Manual, Instrumentation and '
Control Standards, Section 3.0, " Pressurizer Sealed Reference Leg Level System," Revision 8/11/71 8.
Sequoyah Instruction Manuals a.
AI-14. " Plant Training Program," Revision 30 b.
SMI-1-68-20. " Repair Leak in Tubing Fitting 1-VLV-68-442A,"
Revision 1 SQA-134, " Critical Structure, Systems, and Componente (CSSC) List,"
c.
~. Revir; ion 7 d.
IMI-118, " Filling of Sealed Instrument Systems Backfilling, Venting, and/or Flushing of Instrument Sensing Lines," Revision 5 MI-1.9,'" Bottom Mou ted Instrument Thimble Tube Retraction and e.
Reinsertion," Revision 7 f.
MI-1.10. "Incore Flux Thimble Cleaning and Lubrication," Revision 3 j
9.
NUC PR Nuclear Quality Assurance Manual Part II, Section 2.1, " Plant Maintenance," Revision 10/12/84 n.
b.
Part III, Section 6.1, " Selection and Training of Personnel for Nuclear Power Plants," Revision 10/12/84 I
8 1
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l_
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10.
OEDC Quality Assurance Manual for Design and Construction a.
OEDC-QAP-2.0, " Quality Assurance Program " Revision 1 b.
QAP-QAP-4.1, " Quality Assurance Indoctrination and Training,"
Revision 0 c.
CONST-QAP-2.02, " Quality Assurance Items," Revision 0 d.
CONST-QAP-2.07, " Qualification / Certification of Inspection, Examination, and Testing Personnel," Revision 3 e.
CONST-QAP 10.01, " Inspection," Revision 2
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11.
MEDS Search on CONST QA Training Requirements 12.
- I a.
Criterion II, " Quality Assurance Program" b.
Criterion V, " Instructions, Procedures, and Drawings" c.
Criterion I, " Inspection" 13.
ANSI Standard N45.2-1971, " Quality Assurance Program Requirements for Nuclear Power Plants" 14.
ANSI Standard K18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" 15.
ANSI Standard N45.2.11-1974, " Quality Assurance Requirements for the Design of Nuclear Power Plants" 16.
ANSI Standard N45.2.6-1978, " Qualifications of Inspection, Examination, and Testing Personnel for Nuclean Eower Plants"
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17.
Topical Report TVA-TR75-1; 17.1.2.3; 17.1.5; 17.2.2.3; 17.2.5; 17.2.10, Revision 8 18.
Sequoyah Nuclear Plant General-Design Criteria No. SQN-DC-V-3,0, "The Classification of Piping, Pumps, Valves, and Vessels," Revision 1 19.
Sequoyah Nuclear Plant Construction Specifications a.
N2M-865, " Field Fabrication, Assembly Examination, and Tests for Pipe and Duct Systems," Revision 3 b.
N2G-877, " Identification of Structures, Systems, and Components Covered by the Sequoyah Nuclear Plant Quality Assurance Program,"
Revision 5 20.
CONST QA Training Program Plan Program No. QC-4, " Quality Control -
Instrumentation," Revision 2 9
a 3
2 21.
WBNP-CONST ASME Significant Nonconforming Condition Report (NCR) No.
WBN-6278. Revision 0 22.
NUC PR Quality Control Insp,ector Training Manual 23.
ANSI Standard B31.7-1969, " Nuclear Power Piping" 24.
Sequoyah Nuclear Plant Mechanical Instruments and Controls Drawings a.
47B001-15 " Mechanical Branch Valve connection Seismic Support,"
Revision 2 b.
AlW6001133,'" Mechanical Instruments and Controls," Revision 8 c.
47W600-1, " Mechanical Instruments and Controls," Revision 12 d.
47W813-1, " Flow Diagram Reactor Coolan't System," Revision 25 e.
47W555-1, " Mechanical CVCS - Chemical Control and Makeup Piping "
Revision 13 f.
47W600-24, " Mechanical Instruments and Controls," Revision 16 g.
47W600-18, " Mechanical Instruments and Controls," Revision 6 h.
47W600-16, " Mechanical Instruments and Controls " Revision 4 25.
Swagelock Tube Fitting Catalog C-983 26.
Parker CPI Catalog No. 4230, January 1977 27.
Process Specification 3.M.13.1 (RO), " Specification for Installa-tion and Inspection of Compression Fitting Joints in Mechanical Tubing Systems," General Construction Specification G-29M, December 9, 1985 28.
MTU-MMT-28, " Initial Tube Fitting Training," Nuclear Training Branch, Power Operations Training Center, Revision 1 29.
SQN Corrective Action Tracking' Report, CATS No. 85219, May,23, 1985 30.
Memorandum from W. H. Childress to R. M. Jessee, " Watts Bar Nuclear Plant - ASME Significant Nonconformance Report (NCR) 6278R1 -
Laboratory Testing," dated December 6,1985 (B46 851206 001) 31.
Memorandum from W. M. Childress to R. M. Jessee, "Wattu Bar Nuclear Plant - ASME Significant Nonconformance Report (NCR) 6278R1 -
Laboratory Testing - Supplemental Data," dated December 17, 1985 (B46 851212 001) 32.
Memorandum from M. G. Parris to G. Wadewitz, " Requests for Investigation / Evaluation," dated August 15, 1985 (Col 85082/ 005) 10 I
}
a Memorandum from James P. Darling to K. W. Whitt, "Sequoyah (SQN) and e
33.
Watts Bar (WBN) Nuclear Plants - Special Review of Manufacturer-Identified Potential Misapplication of Swagelock Tube Fittings at Westinghouse Reactor Seal Tables - NSRS Report No. R-85-02-SQN/WBN,"
dated May 6, 1985 (L44 850426 807) 34.
SQN Workplan Specification WP No.10721, February 1,1984 CONST-SNP Inspection Instruction No. 85, " Installation Verification, 35.
Flushing and Pressure Testing of Instrumentation Sensing Lines, Sampling Lines, Control Supply Headers and Signal Lines," RO
~
Office of Engineering OEP-17. " Corrective Action," Revision 2 36.
37.
Memorandum from Guenter Wadewitz to K. W. Whitt, " Watts Bar Nuclear Plant - Request for Investigation / Evaluation," October 1, 1985 Memorandum from Guenter Wadewitz,to J. W. Coan, " Watts Bar Nuclear Plant 38.
- ASME Significant Nonconformance Report 6278RO," dated September 9, 1985 39.
Memorandum from W. T. Cottle to Those listed, " Tube Fitting Awareness and Initial Training," dated September 20, 1985 (L29 850909 817) e e
- Mme m o g, e
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e e 11
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TCNITED STATES COVERNME.NT:
Memorandum TENNESSEE VALLEY AUTHO'RIT.*
TO
- R. K. Seiberling, Manager of Huclear Manager's Review Group (NMRG),
- H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant DATE
- April 18, 1986 g,55-sio-as(
a s
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF (NSRS) INVESTIGATION REPORT NO. I-85-329-SQN,
" QUALITY ASSURANCE CONTROLS / COMPRESSION FITTING INSTALLATION"
References:
1.
Mecorandum f rom K. W. Whitt to R. W. Cantrell and me dated February 13,1986, " Nuclear Safety Review Staf f Investigation Report Transmittal" 2.
Memorandum from J. P. Vineyard to H. B. Rankin dated March 28, 1986, "Sequoyah Euclear Plant - Potential Generic Condition Evaluation" (B25 860328 005) (copy attached) 3.
Memorandum from John A. Raulston to Those listed dated February 25,1986, " Potential Generic Condition Evaluation" (B45 860225 259) (copy attached)
Attached is my response to NSRS Report No. I-85-329-SQN.
A' H. L. Abercrombie PRW:GBK:RCB:DR Attachments APR ; 2 'gg j
cc (Attachment):
Employee Concern Files, RES, ONP, SB-2, Sequoyah J. L. Hamilton, QA, O&PS-3, Sequoyah j j
-l r u i.,3 T. L. Hughes, ONP, O&PS-3, Sequoyah l
l 4ww L. L. McCormick, ONP, SB-2, Sequoyah s
f/
' P.ts 2-COORDINATED: QA/JLHamilton, Regulatory Engineering /LLMcCormy ]
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SON Response to I-85-329-SON-04 The plant QC inspectors are currently performing inspections on the compression fittings during maintenance and modifications when required by the appropriate work instructions. However, there is no upper tier or site requirement to perform these inspections, and these activities will be included in SQN work instructions at the discretion of the Quality Assurance Staff,
~.
4
~
~
NUCLEAR SAFETY REVIEW STAFF REPORT NO. I-85-329-SQN NSRS REPORT No. I-85-329-SQN Concern
" Inadequate quality assurance controls were applied to the installation of instrument tubing compression fittings at Sequoyah."
Conclusion The employee concern is substantiated because this investigation has revealed that quality assurance controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10 CFR 50, Appendix B, relative to compression fitting installation. This condition existed during the construction phase and has existed'in the operational phase
~
of SQN. However, recent actions have been taken by SQN management and others as described above to improve the controls in the area of the employee concern.
Recommendations 1.
I-85-329-SQN-01, Evaluate Comoression Fitting Inadecuacies of NCR WBN-6278 for Generic Applicability This recommendation is being reiterated from Q-85-795-001-01 pre-viously identified in the original NSRS report (Ref. 2) since the actions taken by P&E (Nuclear) did not completely address this recommendation as described in III.B.2.b.
Specifically, NCR WBN-6278R0 has not been evaluated for generic applicability to all TVA nuclear plants. The NCR was transmitted to OE on September 9, 1985 (Ref. 38), for review. However, the review did not include an evaluation for generic applicability as required by OEP-17 (Ref. 36). Although the findings presented in III.B.4-8 strongly indicate the applicability of NCR WBN-6278R0 to SQN, the final determination must be performed by OE as described in OEP-17.
Therefore, NSRS recommends that NCR WBN-6278R0 be evaluated for applicability to all TVA nuclear plants and that the results of this evaluation be documented and distributed as required by estab-lished procedures. The response to NSRS should include a statement of why the generic applicability evaluation was not performed.
(P2) 2.
I-85-329-SQN-02, Noninspection Personnel Training As described in III.B.6, SQN management is apparently com=1tted to training personnel involved in installation and maintenance of compression-type fittings. However, several applicable SQN instructions do not formalize or clearly establish the personnel training as a requirement. NSRS recommends that SQN instructions applicable to the installation and maintenance of compression-type fittings be revised to establish training of personnel as a require-ment as described in reference 39.
(P2)
3.
I-85-329-SQN-3, Inspection Personnel Training NSRS recommends that training on-compression-type fittings be developed and implemented for quality control inspectors 'at
~
SQN. This training should provide specific instruction on the inspection methodologies for verification of the quality of safety-related applications of compression-type fittings.
(P2) 4.
I-85-329-SQN-04, Qualiev Control Inspection NSRS recommends that requirements be established and implemented in applicable SQN instructions that quality control inspectors conduct random sample inspections of compression-type fitting installation activities. These inspections should be designed to verify and document that these activities are performed in accordance with prescribed requirements.- Inspections could be performed af ter installation but prior to hydrostatic testing.
(P2)}
SQN Response to I-85-329-SON-01 NCR WBN-6278R1 was transmitted to SQN Engineering Project (SQEP) by reference 3.
A request was made to perform a review and determine applicability to SQN by reference 2.
The NCR was then forwarded to the SQN Regulatory Engineering Section for distribution to the appropriate site sections and inclusion in the operating experience review (GER) program for any generic applicability. It appears that the need for a generic review of NCR WBN-6278R0 was inadvertently overlooked in September 1985.
SON Response to I-85-329-SON-02 The plant maintenance personnel responsible for installation and main-tenance of compression-type fittings attended a formal training course, MTU-MMI-28, " Initial Tube Fitting Training," given by the Nuclear Training Branch, Power Operations Training Center (POTC).
In addition, the plant Quality Assurance Staf f is working with plant management to determine if the training requirements need to be incorporated into the applicable plant procedures.
SQN Response to I-85-329-SON-03 The SQN quality control (QC) inspectors attended the training course identified in the response to I-85-329-SQN-02 prior to being assigned verification activities for compression-type fittings. This training provides sufficient guidance for the QC inspectors to perform the required verification activities.
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Tw A se,om8, W UNITED STATES OOYERNMDr?
Memorandum mm== vmzr wraoarrr B45
'860225 259 I
l To Those usted NM
' John A. Rauleton, Quie f Buclear tagineer, W10 C126 C-E FEB 251986 86030550672 5
- ^ " '
W BJECT:
POTENTIAL 2NERIC CDKDITIOE IVALCATION The attached document, OC BC1 627811, describes e tondition adverse to quality which wee identified et Watte Ear Nuclear Plant. Please namine the attached to detersloe if this condition exista in your ares of responsibility. The bottaa portion of this forie should be completed and this memorandue returned to us within two weeks of the above date.
Should this condition be foamd to exist la your area of responsibility, the generation of a problem identification report er a significant condition report per PEP-17 is required within two weeks of the l
above date.
8 bn A. kaale ton E. 1. Reasley, A10-BrW E. E. Ros e ly, 9-113 83-E 2C' J. F. Vineyard, A8 Sequoyah, CE, DSC-A i.cx.
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We tieve esamined oor activities in the area of concern and g
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found that the conditions..
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" pZ e. :e Review performed by Date d2 j'
sc IDS, IL 26 C-C E. C. Beas ley, W12 534 C-t Joyce Lane, 31 15 775-C E260$3.35 Buy U.S. Samags BoedJ Regularly on the Peyrou Savings Pisa
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uW== mm Comx=xt Memorandum Trmessor vru.tr wrsonrry B26 '88 0 20 6' 017
,0 J. C. Standifer, Project Manager, Watts har tagineerlag Project.
P-104 3B-t (3)
F RO M Cuentar Wadewitt, Project Manager, Watts Bar Buolear Plant OC i
l DATP.
February 5, 1986 W AT 3 BAR rJCLEAR PLAC - ASME SICEITICAC KalCOETORMANCE REPORT 6278 U S t ' N r.C;.
Attached for your review and approval Cf diaposition la NOR 6278 11 which we consider to be alanificant. Please approve and return with attached fom(a) for aJr documen ion purposes.
/
1A Goenter hacewiti
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JES:CMR y; ;7 ECOS;CASMES.CR Attachment J O cc (Attachment):
RIMS, MR4W72 A-C R. W. Dibeler,11-142 SB-K
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- f. W. kayes, NLD-WBM CC
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R. C. McKay, PMbWBE E j'*,
W J. W. Mabee, 366 SPB-K B. P. Painter, CSG-WBW OC
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C. E. Roberta, W11C114 C-E G.
J. W. Self, E-5 Croup WBE oc
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'Q. j B. J. Thomaa, W TE OC D. W. Wilson, ts., WBN-rJC PR
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CA-Site. WBE QC
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NBC Resident Inspector, VEW-rJC PR
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Principally prepared by R. A. Aikena,'exM v
02/06/86 - JCS ICI DATE REC cc (Aten h t):
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RIMS, EL 26 C-E 4g J. C. Lane, la 13 77M
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Deficiency :
Q 11 vspeoon Compressiog fitti.ngs for tubing connections havn
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been discoveted with installations vt11ch do not A00A133 agree with ttia manuf acturer's installation ins truc tions, h oe discrepancies are as b
follows:
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- a. Tube cuts not deburred
- b. Tube not bottooed out in fitting (See attachad continuation page l
- Amossent Cass:
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Deficiency I - There are no requirements to verif y the
- integrity o
-es-sion fitting joints wttich were not subjected to by.drostatic or pneuma l
pressure tasting.
Easponsible Organtaation tr' /02
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o-tc>ssa stama sus Deens esas=1 Deficiency 1 - WEN OC and EDC F1 shall establish maasuras for documented trairr-ing of thair respective craf t personnal involved with compression fitting ins tal.lation. Inspect drain connections to the closed drain system wtLich do not require trydrostatic tasting and are subjected to potentially radiwtive nervice. These inspections shall be in accordance with t manufacturer's Dam M
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tasemos streat tearsenaries Past Vatts Bar Ruc Plant E
l LA Description continuads
- c. hat not completaly covering threada 6
- d. Missing f errula j
haversed ferrule e.
- f. Thidantifiable f errule Deficiency Ils Engineering drawings 47W600 series and 47BM6CO series specify the use of either an Imperial-Eastaan (I-E) 783-F33 or a nann = fin CPI TE12.-S$ 1/2 to 1/4 inch tche and reducer Parkar Ott 28A), but should specify only the use of. I-E reducer.
The reducer connects to a Dragon Panal isolation valve OQL1)
The Park.ar tube end reducer is a hard with en I-E fittins.
l estarial which is --N for a Partar ferrula and is not w anae of the designed to be used with the 1-E f errule.
hardnasa and the==rhiand groove, the I-E ferrule does not mest properly on the tube and reducer and presents a blowout O
basard.
Apparent Cause conti d:
Dafieianey III e
Error in the 473M600 drawings allowing the use of 1 ira-patibla fittings.
3 Correction Mstbod continnad a Datiei=ary It instructicos to verify proper tube daburring, tight =ning requiremmats, and farrula type and oriantation.
All systems subjected to hydrostatic tasting or possmatic testing have been. verified with laak tight joints which indf rat a adequata joint makeup for pressura retanties.
Boeuver. Og shall provida vibrational analysis for carmeetions l
La skich the tube is not bottomed out in tbs fittias, mats not properly tightmand, f arrules reversed, and debarring was not perfors=4 to detarmina the acceptability of each installatines although lash tigntmasa is nenhved.
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3 Correct. ion Method continued i
Deficiency 1:
j OE to evaluate conspression fitting installation to datarmina the nand for possible T7A process specification revisions.
l i
l Deficiency III 1
Correct drawings to specify the use of only Imperial-tastaan I
78}-FSS tube end reducar. Inspect panals and replace Partar reducers with Imperial E.astaan reducers.
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CORRECTIVE ACTION. RESPONSE EVALUATION b7d'dd 7" 9
REPORT NO:
SUBJECT:
0A CouTR0L S roR CDk i? E!UoW.Fl7 TINGS INSTAL L ATroN Y Y (5" $5E ~0ll}
CONCERN NO:
OACCErr REJECT DNE y (B05 Gbo+04 L 339-50W-Cl
% hdeAN 4 y pu a p. r4
- p u wG y, ear enns m, N Ea W
0 329-5 %
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tva soseen ITN!tED STATES GOVERNMENT' Memorandum TENNESSEE VALLEY AUTHORITY
~
B05 '86 0 4 0 4 002 TO K. W. Whitt, Director of Nuclear Safety Review Staff. E3 A8 C-K W. C. Drotleff, Director of Nuclear Engineering, W12 A12 C-K FROM April 7, 1986 DATE
, " " " ' "rR? REPORT NO. I-85-329-SQN, FINDING I-85-329-SQN-01, " EVALUATE COMPRESSION FITTING INADEQUACIES OF NCR WBN-6278 FOR GENERIC APPLICABILITY"- X X-r,s.o ro.c o f
}APR7'x i
Referpnce: Your memorandum to H. L. Abercrombie and R. W. Cantrell dated February 13, 1986 S
I:*'*Ehe reference memorandum under Section IV, " Conclusions and E
Sc ; e.;.Lendations," you addressed four recciamendations. They were
[g,",
329-SQN-01, Evaluate Compression Fitting Inadequacies of NCR WBN-6278 for h
1 ic applicability; I-85-329-SQN-02, Noninspection Personnel Training; am gener 329-SQN-03, Inspection Personnel Training, and I-85-329-SQN-04, Quality wcs T
- Ca *ol Inspection. The only recommendation which involves the Division of INcluar Engineering is I-85-329-SQN-01.
DNE has reviewed this recommendation
,gg and has the following comment:
When NCE WBN-6278 RO was issued by the Office of Construction, they (OC)
NG were not yet following the intent of paragraph 4.5.1.2 of OEP-17.
Since then, the Office of Construction started following paragraph 4.5.1.2 of j,u g g OEP-17, and NCR WBN-6278 El along with SCR 6278-S R0 (identical to NCR WBN-6278 Rl) was issued. The SCR form goes into more detail, particularily in the generic condition area than the NCR form which was used for NCR WBN-6278 RO.
The "geneYic block" on NCR VBN-6278 R0 had been marked "yes" and was justified by saying "this condition is. applicable to all compression fitting installations within the scope of the WB QA program."
I DNE did not review NCR WBN-6278 RO for generic applicability because OC
~
had already indicated it was. However, since NCR WBN-6278 R1 and SCR 6278-S R0 have been issued, DNE has issued a generic memorandum dated February 25, 1986 (B45 860225 259).
OEP-17 was revised on March 28, 1986, to require assessment of the generic implicaticas of NCRs/SCRs/ CARS initiated by Construction or Operations and referred to DNE for disposition.
/ /
. C. Drotleff JFW:WDD:MBP cc:
RIMS, SL26 C-K J. A. Raulston, VIO C126 C-K J. C. Standifer, P-104 SB-K U
J. F. Weinhold, W12 B34 C-K OA [leC0rd W. D. DeFord, V12 B32 C-K OE01 - 1685E I
EA 03/12/86 A
n.... T ? c es,d,,"_r Rande Renuinriv nn the Pavrnli Sat in ns Plan
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C*m L44 860730 816 85080100038 SN 157B Lookout Place I
Chattanooga, Tennessee 37402-2801 WBRD-50-390/85-43 WBRD-50-391/85-42 U.S. Duclear Regulatory Coramission Region II Dr. J. Nelson Grace, Regional Adasinistrator j
Attention:
l 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
~
Dear Dr. Grace:
WATTS BAR NUCLEAR PLANT (WBN) - UNITS'1 AND 2 - QUEST FITTINGS ON INSTRUMENTATION TUBING - WBRD-50-390/85-43, WBRD-50l
.d-FINAL REPORT The subject deficiency was initially reported to NRC-Region II Inspector 1985, in accordance with 10 CFR 50.55(e) as Al Ignatonis on September 24, 1985, and Previous interim reports were submitted on October 24, WB5 6278.
av ~
January 31 and March 31, 1986. Enclosed is our final report.
3.
j-3. -
Deley in submittal of this report was discussed with Morris Branch on July 17, 1986.
4 If there are any questions, please get in touch with J. A. Mcdonald at
.n-(615) 365-8527.
Very truly yours, N
T SS E V LCtY AUTHORITY N
J' E. L. Cridley Director O
Nuclear Safet and Licensing Enclosure ec (Rnclosure):
Mr. James Taylor, Director Office of Inspection and Enforcement if.'u.,
U.S. Buclear Regulatory Coeumission
{
fv, j-Washington, D.C..
20555 i.k. g }r.
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Institute of Nuclear Power Operations 1100 circle 75 Parkway, suite 1500 Atlanta, Georgia 30339 i
RMI:EFF:SCP cc (Inclosure):
E. A. Pedde, 9-169 SB-K RDts_we AW ~121-C J. A. Raulston, W10 C126 C-K f' W. Centre 11, 82 JN 768-C NEC Resident Inspector, Watts Bar E. R. Ennis, Watts Bar-cerP Cuenter Wadevitz, Watts Bar EU COW E. B. Eelly, LP 45 45A-C J. A. Mcdonald, Site Lic, WBN-ONP C00EDIRATED: DerE/Prahl WBN/Fickey b.c. LSC, LP 5N 106B-C 0958b
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I ENCLOSURE e
WATTS BAR NUCLEAR PLANT UNITS 1 AND 2 QUESTIOmant r COMPRESSION FITTINGS ON INSTRUME WRED-50-390/85-43 WBRD-50-391/85-42 i
WC1 6278 l
)
10CFR50.55(e) i FINAL REPORT Descrirtion of Deficioner TVA has identified through its essployee concern program (emplo f
15-45-795-001 and 002) compression fitting installations were not in accord
/
These cotapression fittings are manuf acturer's installation recoermendations.
l i
various used f or instrument-related ASME Section III tubing connect ons onASME Se
, systems throughout the plant. compression fitting joints include in manuf acturer's recosumendations.
fittings as well as Imperial Eastman "Hi-Seal" fittings.
i As a result of these employee concerns, a sample inspection of 107 cotapress o fittings used in instrument or sampling lines was perf ormed and 60 discrepancies identified which f all in the following general categories:
tubLng cuts were not deburred; tubes were not bottomed out inside the
'n fittings; nuts were not properly tightened; and f errules were either m
These installation problems are
.3 7.., M unidantifiable, missing, or reversed.
d inadequately
- ~~I' attributed to inadequate or nonaxistent site procedures anThis resulted from inadeq 7
l
'3
- I. trained construction craftsman.
l l
,,k of requirements.,_
Af ter this sample inspection was completed, WBN maintenance personnel identified an additional category which was then included in revision 1 to NC This category involves the use of Parker-CPI tube end reducers with P%
1mperial-Eastman "Hi-geal" nuts and ferrules as a means to connect 6278.
I N
instrument panel isolation valves.
(It should be noted that these type with manuf acturer's reen==andatiws.
The cause of this installations are not in the ASME code boundary.)
particular condition was determined to be an error in TVA drawings which c
allowed the use of either Parker or Imperial-Eastman tube end reducers.
l J
Safety implications
- In general, without adherence to manuf acturers' recommendations during l
lt in
, _' S :
e,.s j instanation, compression fittings may not totally seal which wou d r l
- - tions.
This testing
'.;+../.ii. g 1-W etubing receives hydrostatic or pneumatic pressure testing.
ellminates any concern with the adequacy of the initial seal of theH e.m j
compression fittings.Mvy of the seal due to vibration induced during normal pla l
Either of these cituations had the potential for during a seismic event.
- Also, allowing the vibrations to loosen the fittings and develop a leak.
burrs in instr =aritation tubing would not be detected during pressure testing i
i and could lead to an accumuistion of " crud" and an eventual flow rest Tube leakage or flow restriction could cause errors in instrument readings of c
varying degrees depending on the instrument in question and th problem.
v I the lines In the case of open-ended instrument tubing, drains, and vent lines, I
fittings wnuld be are not pressure tested and any leakage due to inadequatebehind it.
minimal as such leakage would not have significant pressure Corrective Action i ion O A compression fitting testing program for those items identified in Rev s i l Laboratory. This of 3CE 6273 was perf ormed at TVA's Singleton Mater a the presence of program included testing of the effect on flow rate due to i
installation I
tubing burrs; testing of the integrity of fittings with var ous i i deficiencies, by tensile pullout and vibration f stigue tests; and se l
t were not tube ends were not deburred, tubes were not bottomed out or nu s event tests.
i f t ry even
~
'"though there would be some reduction in fitting integrity. pro Also, normal f the samples tested operation f atigue testing exhibited no leaks in any o(including l
installed backwseds),
' - e leakage (undetectable on and seismic event testing only produced very slightm seismic tests are conservative in 2 of 47 samples.
l the pressure gauges) and are a severe test of fitting integrity.
?
i For fittings with missing, reversed, or unidentified ferrules, it was deterimined that a missing ferrule would cause a definite leak during 3._
i hydrostatic testing; a reversed ferrule would leak if it was a " CPI" fitt ng, -
+
[f, ~*~ ^
b,.;.
but would not leak if it was a reversed "Hi-goal" ferrule; and that the i
b bly a unidentified ferrvie noted on the nonconferinance report was pr N {.g.
This j
g* y:r, '
found to leak specific case was a " CPI" fitting, and this condition has beenBecause of this
~
ble during pressure testing.
three partLeular types of questionable f errule installations, unaccepta N'
installations would be detected during hydrostatic testing driving force to create any significant leakage.
overall TVA has determined that it is acceptable to use these type fittings O
"as-is" with the exception of fittings on lines which are not subject to pressure tests but could see radioactive service, and some local instrument On lines that are panels which may not have been hydrostatically tested.
tested are
., g 3,, subject to pressure testing, those that have already been pressure that they will
- : Q fv r,ecceptabla as their lack of leakage is sufficient assurance QXhb'36 which beve not yet been tested will be replac c
Th./2.
hydrostatic testing if they laak.
-T*W id.
For those fittings seeing radioactive service in lines not pressure tested (e.g., desins) TVA plans to have the connections reinspected and any
~
J discrepent fittings found during this reinspection will be replaced by fuel For the local panels mentioned above, TVA plans to load for each unit.
inspect all the panels for safety-related instrumentation for leaking compression fittings during initial bestup for unit 1 and during hot functional testing for unit 2.
]
C-h--me,
I With regard to the Parker-Mannifin tube end reducers installed with the Imperial-gastman "Hi-Seal" nuts and f errules. TVA has deteratined through tensile and vibration tests and analysis that fittings with this type discrepancy are functionally reliable and all existing installations are acceptable as-is.
To prevent recurrence of the type problems in revision O of WCR 6278, TVA has revised coststruction Specification G-29. " Process Specification f or Welding.
Heat Treatment, Non-destructive Examination and Allied Field Fabrication Operations," to detail the requirements for installation, remake and These requirements have been incorporated inspection of compression fittings.
(NU COM) Quality Control Procedure tnto the Division of Nuclear Conettvetions' QCP 3.13-4, " Installation and Inspection of Tubing Instrument Lines," as well as Quality control Instruction (QCI) 3.13. " Mechanical Tube Fitting Installer Perf ormance Certification," to which applicable
- NU COM craf t have been trained Work on compression fittings which would be done by operations and certified.
personnel will be controlled by MAI-29. " Instrument Tube Fitting and Installation" which is scheduled to be issued by August 15, 1986.
I To prevent a recurrence of the type problem identified by revision 1 of this NCE. TVA has revised its applicable drawings through ECN 6313 to specify use N
of tube end reducers made by the same manuf acturer as the fitting it is to be l
~3 maLed with.
"T N
s N
e
WEE *':Q der
_'VERNMES.
S03 861009 805 y,v.7 Memorandum TENNESSEE VALLEY AUTHORITY To W. R. Brown, Program Manager, Employee Concerns Task Group. ONP, Watts Bar Nuclear Plant FROM H. L. Abercrombie, Site Director, ONP, O&PS-4 Sequoyah Nuclear Plant DATE October 20, 1986
SUBJECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 802.01 SQN R1 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated September 12, 1986, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report 80201-SQN - Inspection Criteria (Sequoyah)" (T25 860916 991) 1 I acknowledge receipt of your element report and in accordance with your request (see reference), Element Report 802.01 SQN R1 has been reviewed for applicable corrective action.
By this memorandum I am endorsing the site line organization CAPS and attaching these CAPS for your review and concurrence in response to your CATD 80201-SQN-1 and CATD 80201-SQN-2. These CAPS are not restart requirements.
If you agree with the proposed CAPS, please sign the ECTG concurrence space below item 9 on the CAP tracking checklists and return the CAP tracking checklists.
/
//d@
H. L. Abercrombie RCD:JDS:JB:CS Attachments RECEIVED cc (Attachments):
RIMS, NR AN 72A-C firT 2 2 5 A. G. Debbage, ONP, ECTG Building, WBN Emplefae.a.o" terns Task 0181T
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ECSP CORRECTIVE Action Tracking Document (CATD) i 4'
INITIATION' 1
1.
Immediate Corrective Action Required:
// Yes /X/ No l
j 2.
Stop Work Recommended: // Yes /1_/ No 3.
CATD No.
80201-SQN-01 4.
INITIATION DATE 1/8/87 I
5.
'2ESPONSIBLE ORGANIZATION: Office of Nuclear Power 6.
~ PROBLEM DESCRIPTION:
/I_/ QR /[/NQR I
As identified in this Element Report, vendor welds made by Southwestern Engineering Co. (SECO) were substandard and required
}
rework.
Corrective actions for these welds did not include a sample inspection produced of welds produced by SECO.
NOTE: This CATD was revised to -eliminate reference to National Valve and Manufacturing Co. (NAVCO) Welds.
o /
// ATTACHMENTS
{
7.
PREPARED BY: NAME R. D. Jialverson M DATE: 1/8/87 8.
CONCURRENCE:
CEG-H 7Ae44fM //We /
DATE: 1/8/87 j
l 9.
APPROVAL: ECTG PROGRAM MGR DATE:
CORRECTIVE ACTION l
10.
PROPOSED CORRECTIVE ACTION PLAN:
f i
1 i
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1 l
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/ / ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
1 12.
CONCURRENCE: CEG-H DATE:
SRP DATE:
j ECTG PROGRAM MGR:
DATE:
1 VERIFICATION AND CLOSEOUT e
13.
Approved corrective actions have been verified as satisfactorily 1
implemented.
4 l-SIGNATURE TITLE DATE i
l 1
i 4
, -.-_v, - _,
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7 Pcg3 1 et 2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Number
///,8/ 5~4r/E/!/
Lead Organization Responsib1e for Corrective A'etion Plan
~
. CORRECTIVE ACTION PLAN (CAP) 1.
Does this report require corrective action?
Yes No r (If yes, describe corrective action to be taken, if no, provide justification)
/11A ckM ENT " Y I
m 2.'
Identify any Similar item / instances and corrective action taken.
Af
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Ahoncemoc~
sue -
um ~IEt:r SW s+4 3.
Will corrective action preclude recurrence of findings? Yes x
No Does this report contain findings that are conditions adverse to 4.
cuality (CAQ) as defined by AI-12 or N3P 9.1?
.,e Yes No 5.
If a CAQ condition ezists, what CAQ document was initiated?
"/#
6.
Which site section/ organization is responsible for corrective action?
Comtra Am.J ( m e#eMO coaucune 4v rs>r.rmo+
7.
Is corrective action required for restart?
Yes No.K (This determination is to be made using the " Criteria for Determination of Restart Items" in accordance with the Nuclear Performance Plan, Volume 2.)
8.
P2 zone number for restart corrective action? Zone 9.
Estimate completion date for corrective action.
Completed By
/
bw I ate N -/- M Approved By
'#1_) /> 1%
Date m-2-8g ECTG Concurrence Date SRP Concurrence Date CAP CLOSURE 10.
Was your corrective action initiated and completed in accordance with step 1?
Yes No-
, ', 11.
If step 10 is no, describe the corrective action taken.
....v..
4 12.
Is the corrective action implementation complete?
Yes No 13.
Is the corrective action documentation closed?
Yes No 14.
What documents were used to implement the corrective action?
Completed By:
Date Verified By:
Date ECTG Closure:
Date Continued on back page
T 1
Att:chment T
Reference:
ECTG Repord CAT D 80201-SQN-1 (T25 80916 991)
In reference to the ECTG report effort, it should be noted that both concerns investigated (JAN-8-001 and JLH-85-005) were:
1.
Specific to a referenced location job or 2.
Investigated by the site manager for whom the concerned individual reported his concern.
3.
The concerned individual in both cases was satisfied with the response.
Additional comments are provided for each concern.
Concern JAN-85-001 Contrary to the investigator's report, SECO dqes not reference Sentry Equipment Corporation but references work performed by Southwestern Engineering Company (SECO). SECO has performed work at Sequoyah only once, with that occurring between September 1985 and November 1985. The concern was received November 26, 1985. Sequoyah Modifications requested that Sequoyah QA perform a survey on the referenced work.
This was accomplished by QA and documented on an in-plant-survey checklist (21-85-5-021). Additionally, a SECO QA representative returned to Sequoyah to participate in the evaluation.
Deficient welding was corrected by TVA and a warranty claim was submitted for processing.
It is therefore concluded that the inspection / review effort did include the majority of welding performed by SECO with repairs being completed accordingly; thus, no additonal surveys are warranted.
Concern JLH-85-005 The review of this concern included a discussion with an individual (L. G. Herbert) who was the cognizant construction inspector during the time that NAVC0 piping was received onsite at Sequoyah.
He stated that a similar concern was expressed in 1976 to the visual adequacy of NAVC0 welds. This concern was satisfied by reviewing radiography film of the
- potential worse-case basis. The effort concluded that although the welds were not ground flush or at least smooth, as was the TVA practice, the welds were satisfactory (passed I-ray criteria). Reference memorandum from L. G. Herbert to J. L. Hamilton dated May 29, 1986.
Sequoyah has recently completed a study on welding which was performed by contractors, TVA weld project personnel, ANIS, QA organizations, and others. This effort included a review of field welds performed both by TVA and contract suppliers. The conclusion reached by these parties was that Seguoyah welding practices were acceptable.
Reference Welding Task Force Report L44 860207 800 and later revisions.
3 i
Many cf the NAVC0 welds hav3 bee 3 igspectcd cs p rt of th3 in-s:rvics-inspection program' required by Section II of the ASME Code. Others will be inspected as the program (SI-ll4) continues through the plant life.
~
These inspections have yielded no evidence of an abnormal rejection rate in NAVC0 welding.
~
Based upon these efforts, it is concluded that no justification exists for additional surveys.
i DA:GDL 10-1-86 0212M
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. UNI.TED, STATES GOVERNMENT t
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' Memorandum
.Ttxxtssts ver2YY AUTHORITY John L. Hamilton, Jr.', Supervisor, Quality Engineering / Quality Control, To ONP, Sequoyah Nuclear Plant TROM 4
Leo C. Hebert, Quality Assurance Evaluator, DNQA, WBN, ONP, DATE
- May 29, 1986
SUBJECT:
VELD RADIOGRAPH REVIEW This memorandum is in response to 'our conversation on April 17 and May 23, 1986 regarding a review of weld radiographs at NAVC0 Corporation, Pittsburgh, Pennsylvania.
In early 1976, March / April, verbal concerns sere expressed by the craf t -
welders at Sequoyah Nuclear Plant in regards to the poor visual appearance of NAVC0 spool piece welds; yet the Construction Quality Control inspectors
.were rejecting welds that appeared to have a higher standard of quality.
L, Arrangements were made with Mr. Robert Jackson of NAVC0 for me to review radiographs at their facility.
A walk-through, utili:ing construction management, was made; welds were selected on a worse-case basis; and photographs were taken to allow"NAVC0 personnel to understand our concern.
I made a trip to Pittsburgh, Pennsylvania and reviewed the radiographs of the selected weldo; even though the welds did have a poor visual appearance, all radiographs reviewed did meet the appropriate quality standards.
For
' record purposes, it should be noted that at the time of this action, I was a certified Level III in RT, PT, MI and UT in accordance with SNT-TC-1A.
~
e-f I am certr.in that correspondence was written concerning this, situation and the visit to NAVCO, but due to organizational changes and the time frame involved, I do not know if it could be retrieved.
If I can be of further assistance, please do not hesitate to call me at Knoxville extension 6863 or Watts Bar extension 3516.
QUAUTY R S OFFICE h
. Leo G. Hebert LCH:FC JUN02'86 h
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ATTACIDiENT E e
ECSP CORRECTIVE
\\
Action 1rackint Document (CATD)
INITI ATION_
~
1.
Immediate Corrective Action Required:
/Y/ Yes
// No 2.
Stop Work Recommended:
/~/ Yes /I/ No 3.
CATD No.
80201-SON-2 4.
INITIATION DATE 9/12/86 5.
RESPONSIBLE ORGANIZATION: Office of Nucient Power 6.
PROBLEM DESCRIPTION:
/X/ QR /~/ NQR Concern XX-85-050-001 (Findings Section) indentities the lack of
~
specific trainint renuirements in the followinr documents:
OC-4 Revision 2.
"Ouclity Control Ins trumen ta t ion" -- 14o module s for traintnr.
AI-14 Revision 30. " Plant Trainint Procram" -- Courses lirted do not include tube fittines.
6 MI's' SMI-1-66-20. Revision 1. and IMI-ilt. Kevision S. -- Do not specifiv nersonnel training reauirements.
NUC PR Oualiev Insnector Trainin? Manual -- No inetructinns i r.
insnection of installation of comnression tvoe fittines.
/ / ATTACH'!ENTS
~
7.
PREPARED BY: NAME R. D. Halverson h
DATE: 9//.lt/JW B.
CONCURRENCE: CEG-H
'/( C //V7 s DATE: '-/ 2-PG 9.
APPROVAL: ECTG PROCRAM MGR:
DATE:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION Pl.AN:
JE Armcco i,
,r, f
/X/ATTACRMENTS 11..
PROPOSED BY: DIRECTOR /MOR: fpt/zAW/w /r #
DATE v///r/#
12 ',T " CONCURRENCE:
CEG-11 DATE:
S RP.:
DATE:
ECTG PROGRAM MOR:
DATE:
VERITICAT ON AND CLOSE0UT 13.
Approved corr'ec tive actions have been verified as satiTfactorily implemented.
SIGNATURE TITLE DATE
P:s2 1 ef 2
- ~
' ~
Corrective Action Plan of Employee Concern Investigation Tracking Checklist CAW ECTG Report /CATD Number f8'/; #/ f/% - O
/
Lead Organization Responsible for corrective Action Plan C o N-rT.
CORRECTIVE ACTION PLAN (CAP) 1.
Does this report require corrective action?
Yes V No (Ifyes,describecorrepeve action to be taken, if no, provide justification) kmsJ t
J.7-/ '
2.
Identify any Similar item / instances and corrective action taken, m:ah!
r*Aww M7ws ew' r/w< w //nm 3*.swer-A-*~,
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Will corrective action preclude recurrence of findings! Yes AC No 4.
Does this report contain findings that are conditions adverse to cuality (CAQ) as defined by AI-12 or NEP 9.17 Yes No k'
S.
If a CAQ condition ezists, what CAQ document was initiated? 4/4-6.
Which site section/ organization is responsible for corrective action?
n7r 77a*14 M Aceno/
Aik Afnwa cd 17~W 7.
Is corrective action required for restart?
Yes No Jr (This determination is to be made using the " Criteria for Determination of Restart Items" in accordance with the Nuclear Performance Plan, Volume 2.)
8.
P2 zone number for restart corrective action? Zone
///A 9.
Estimate completion date,for corrective action.
n /A Completed By dN Mes*
Date
/eeB6 Approved By X
AC L Date ', /o -A.
ECTG Concurrence Date SRP Concurrence Date CAP CLOSURE 10.
Was your corrective action initiated and completed in accordance with step 1?
Yes No 11.
If step 10 is no, describe the corrective action t'aken.
- 12. Is the corrective action implementation complete?
Yes No 13.
Is the corrective action documentation closed?
Yes No 14.
What documents were used to implement the corrective action!
Completed By:
Date Verified By:
Date ECTG Closure:
Date Continued on back page
]
- Rsfcrenca: C^TD 80201-SQN-2 All instrumentation attached to the RCS is restricted by spe'cial 3/6-inch transition couplings, thus restricting the amount of leakage to that which the charging system is capable of normally making up.
All instrumentation attached to other systems important to safe operation of the plant are provided in redundancy (Trains A and B).
Based upon these facts, I conclude that a break in the line or a defective tube-fitting would not create an unsafe nuclear operating condition.
Sequoyah safety procedure (AI-3) requires personnel working on systems or system components to obtain appropriate hold orders on clearances.
In addition, a recent study completed by Singleton Laboratory 1
(F01 851211 601) in response to employee concerns at Watts Bar Nuclear Plant concluded that improperly installed fittings would not be a problem if they did not leak and that leaking fittings would be repaired before an unsafe condition would exist.
~
It is therefore concluded that if existing procedures are followed, the potential for personnel injury is minimum.
]
Appendix B of 10CFR50 requires procedures and. inspection programs be established and executed for work on safety-related equipment. The
]
level of detail is not stated.
Sequoyah performs all CSSC work in 1
accordance with written procedures (specifically work requests and j
workplans) which appear to meet Criterian V requirements. The level of i
detail is determined by the complexity of the task which may generate specific instructions such as MI's, SMI's, etc.
Additionally, all of the work documents are reviewed by QA for adequacy and adherance to j
applicable requirements including the establishment of QC hold points s,
which seems to meet Criterian X requirements.
i It should be noted that neither Criterian V or X specifically states the j
level of detail of instructions or that specific QC hold points be established. These determinations are the responsibility of the utility in accordance with applicable codes, etc. I therefore conclude that Sequoyah is in compliance with these requirements.
l In response to the specific problems addressed by the investigators, the following comments are provided:
1.
QC 4 is an instruction utilized by the Construction organization i
during the construction phase of the plant. It has not been used at i
Sequoyah for several years and never by Nuclear Operations.
Therefore, no corrective action is required.
I 2.
AI-14 does not list all courses required or taught at Sequoyah. The original intent of this instruction was to address minimum training i
requirements for employees at Sequoyah.
Additional requirements 6
were implemented through the initiative of plant supervisors in j
response to conditions adverse to quality, and other directives such i
as the referenced memorandum from W. T. Cottle. These requirements i
were initiated administratively by memorandum as was the case in the
]
W. T. Cottlo memorcndum. AI-14 is currently being rcvised with additional reference to tube-fitting class MTU-MMT-28 referenced.
The estimated compl'etion date is December 8, 1986, per discussion with Doug Bateson, Sequoyah Training Officer.
3.
Personnel training requirements are not placed in procedures on a 9eneral basis.
Reference to AI-14 or section requirements are sufficient to address this. Therefore, no revisions are necessary.
4 The QA supervisor (John L. Hamilton) for engineers and inspectors responsible for review of work documents and inspection activities has directed his representatives to insure that requirements are placed in maintenance requests and workplans to use only qualified, trained, maintenance personnel for tube-fitting installation and that inspectors assigned to the related inspection activities are trained in tube-fitting practices.
Approxinately ten QC insoectors have attended MTU-MMT-28 to date. The mechanical inspector training class will be revised to include tube-fitting inspection criteria and additional inspectors certified as they return to the Power Operations Training Center for recertification.
DA:GDL 10-1-86 0210M a
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Page 42 of 62 Rev. 50 Appendix H PLANT INSTRUCTION REVISION REQUEST ROUTING F
I.
At/p/Pr /
/
~ Originator'.s Supv./Dato Approved Responsible Supervisor /Date Approved i
m.3s g
- 2. Administrative Services - Date Received Approved I
N -J _.
Adm Sys, WPU Supv i.'
- 3. SI Scheduler (sis Only)- Date Reviewed Approved
)
Plant Instruction Revision Request (To be filled out by originator of j
revision request and routed to appropriate section supervisor.)
Originator A
To#1JfM Date N Y~-Sf-Instru-tion No.
Mt.
[
Title
/YM/A df
&Fe-- -
Page Numbers Affected "I, 28
- MATS #
CATS a CAR a THIS REVISION IMPLEMDJTS SOURCE DOCINDJT:
(NQAM, Area Program, etc.)
Sumary description of Revision (If possible, marked up pages on latest revisionshouldbeatta[ched)._ Afpg f/4 o 4 e-F.#'<',w/
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17)~'C
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i SQNP AI-14 f
Page 28 of 50 Revision 33 II. TRAINING OUTLINES (continued)
F.
SPECIALIZED TRAINING (continued)
Those portions dealing with the SQN response' arc discussed in greater detail. Addionally, the plant's Implementing f
Procedures are addressed and summarized during the training.
l Sufficient training must be given to those individuals who are designated in the Implementing Procedures as being re-
[
sponsible for performing various functions during an emer-gency.
[
j c.
EFERENCE-TVA-REP f
d.
RESPONSIBILITIES-The SQN Project Engineer (REP) or a designated alternate shall be responsible for administering this training.
DOCUMENTATION-A training roster will be completed and provided e.
to the SQN Training Office for all persons successfully complet-ing REP training.
f.
RETRAINING-Annually g.
TRAIN Code - REP 6.
HEALTH PHYSICS SCIENTIFIC AIDE AND TECHNICIAN QUALITYING PROGRAM.
PURPOSE-The objective of these HP training programs is to a.
ensure a fully qualified HP staff is maintained to assist in the safe operation of TVA's Nuclear Plants. In achieving this objective, TVA complies with NRC regulations.
b.
SCOPE-The positions covered by this training include HP s
[
scientific aides, dosimetry engineering aides, HP technician trainees, HP technicians, and contract HP technicians.-
c.
REFERENCE-PMP 0202.12 d.
RESPONSIBILITY-The HP section supervisor for coordinating the training required for the HP staff and ensuring staff sembers maintain appropriate qual'ifications.
DOCUMENTATION-The associated training documentation will be e.
maintained at the POTC as described in the HP administrative section instruction letter (HP ASIL) -3.
f.
This training program is completely described in HP ASIL -3.
l l
f, Ctuntnm krrko.sw de ceau a. g er e.
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Page 3 of 50 Revision 33 I
D.
RESPONSIBILITIES (continued) l 4
(continued)
(e) Ensuring that all temporary and service personnel under their cognizance are trained to the extent necessary to assure safe execution of their duties I
(for unescorted access, see Appendix B).
f (f) Reviewing the Plant Training Office computer status V
program printout of plant personnel issued to the j'
l section and report to the Training Office gngrgors foun
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enco*"tED M'"N '
5.
The Health Physics (HP) Supervisor shall be responsible for
~
6.
The plant Public Safety Supervisor shall be responsible for providing training and retraining in " Plant Security and Emer-gency Plans" (GET 3.1) and " Drug Awareness" (GET 3.2).
j l
7.
The Nuclear Training Branch is responsible for the development and update of the courses in the GET program through the utili-f zation of information provided by the plants, the DNQA Quality y
Systems Branch, and other ONP personnel. This responsibility includes ensuring that the course material is in compliance with tre various regulatory guidelines which are applicable.
8.
When revisions occur to courses under the responsibility of y
the Plant Training Office, Attachment 4 shall be completed.
g-Any revisions shall be reviewed by the plant Training Officer and the responsible site supervisor for cost.leteness, accuracy, and applicability to Sequoyah Nuclear Plant. When a review l
discloses discrepancies between the course and Sequoyah plant procedures, the Plant Training Office will initiate a formal revision request form.
l 9.
The supervisors of the sections below listed shall be respon-sible for providing plant specific information for GET training y
packets and instructors for the other designated courses. They shall also notify the Training Officer when revisions to docu-L,,,
ments or plant procedures covered in this training indicate the C D possible need for revision of GET courses and/or retraining of 3
plant personnel in a particular subject. For all other courses, designated supervisors shall be responsible for the development and maintenance of complete training packets. Each training packet will have as a minimum a training outline, audiovisual 4
aids where appropriate, and a written examination covering the
[
n' material. Approval of the packets shall be the collaterial re-sponsibility of the Training Officer and the supervisor of the N
3
. se ATTACIMENT F
- o ECSP CORRECTIVE Action Tracking Document (CATD) 1 INITIATION 1.
Immediate Corrective Action Requiredt d/ Yes /_/ No
^
2.
Stop Work Recomunendedt /;/ Yes /I/ No 3.
CATD No.
80201-SQN-03 4.
INITIATION DATE 1/8/87 5.
RESPONSIBLE ORGANIZATION: Office of Nuclear Power 6.
PROBLEM DESCRIPTION:
/I/ QR /;/NQR As identified in this Element Report, Attachment C (L44 860730 816), TVA coannitted to the NRC that " work on compression fittings which would be done by operations personnel will be controlled by MAI-29,
' Instrument Tube Fitting and Insta11stion' which is scheduled to be issued by August 15, 1986."
To date, no evidence exists that this procedure has been issued.
i A
/
// ATTACHMENTS i
7.
PREPARED BY: NAME R. D. lialverson EO - DATE: 1/8/87 L
8.
CONCURRENCE: CEG-H 'A1./#E //)b /
DATE: 1/8/87 9.
APPROVAL:
ECTG PROGRAM MGRt
/
DATE:
j CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
I i
/ / ATTACHMENTS
)
11.
PROPOSED BY DIRECTOR /MGRt DATEt 12.
CONCURRENCE:
CEC-H DATE:
I SRPt DATEt ECTG PROGRAM MGRt DATEt 1
j VERIFICATION AND CLOSEOUT i
13.
Approved corrective actions have been verified as satisfactorily implemented.
I SIGNATURE TITLE DATE 4
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