ML20213D422
| ML20213D422 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 10/31/1986 |
| From: | Hutzler C, Owen D, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082401853 | List: |
| References | |
| MC-40301-SQN, MC-40301-SQN-R02, MC-40301-SQN-R2, NUDOCS 8611120086 | |
| Download: ML20213D422 (6) | |
Text
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40301 SPECIAL PROGRAM SQN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 (Final Report)
TITLE: Valve Substitution as Related to Material PAGE 1 0F 5 Control REASON FOR REVISION:
Revision 1:
Revised to incorporate TAS and SRP comments.
Revision 2: Revised to include corrective action and addition of Attachment A PREPARATION PREPARED BY:
h
/W/Sl8b 6 ATE SIGNATURE REVIEWS PEER:
l0 l/WBG 4<.
- DATE TIGNATURE TAS-N SIGNATURE DATE
~
CONCURRENCES 1
s CEG-(G(d, 10 0 l
/0 66 SRP:
L SIGNATURE DATE SIGNATURE
- DATE APPROVED BY-h Y
l0'Sl-8(o ufA
/
ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DAk?
CONCURRENCE (FINAL REPORT ONLY)
- SRP secretary's signature denotes SRP concurrences are in files.
8611120086 861105 PDR ADOCK 05000259 P
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40301 SPECIAL PROGRAM SQN REVISION NUMBER: 2 PAGE 2 OF 5 I.
INTRODUCTION This report addresses the portion of concern EX-85-181-001 dealing with valves being substituted. It should be noted that this concern was initially determined to be generic to Sequoyah Nuclear Plant (SQN) at the concern level, but was later determined not to be generic as a result at the Employee Tast Group (ECTG) evaluation at Watts Bar Nuclear Plant (WBN) (see Element Report MC-40301). However, the TVA SQN Generic Concern Task Force (GCTF) evaluated this concern relative to the Office of Nuclear Power's (ONP's) program and this report will address both the accuracy of the GCTF report and the program used during the construction of SQN.
II.
SUMMARY
OF PERCEIVED PROBLEMS The perceived problem is that valves may have been substituted from what the drawing requires without documenting the substitution, and the bill of materials is not revised to show the change. This report addresses only the portion of the concern shown in brackets below. The remainder of this concern is addressed in Material Control Subcategories, Purchasing and Requisitioning (MC-40200) and Material Identification (MC-40500).
On valve inspections (Test 70), Quality Control (QC) verifies the proper valve by the mark number tag which is installed by the warehouse or vendor and is often just a paper or metal tag which can be removed or or replaced by anyone.
[If the valve has been substituted from what the drawing lists, the bill of materials does not reflect the change.
No paperwork to Watts Bar engineering to document that it is an acceptable replacement.] Many substitutes have come in from Hartsville, Phipps Bend, Yellow Creek and are a different type than what the drawing calls for. Check Unit 2. R1 Steam Generator blowdown system as an example.
Construction Dept. Concern. Concerned Individual (CI) has no additional information.
III. EVALUATION METHODOLOGY A.
Reviewed expurgated file to determine if additional information was available.
B.
Reviewed SQN GCTF report for concern EX-85-181-001 and related l
documen.ts to determine if this report's findings and conclusions l
are adequate.
l I
TVA EMPIAYEE CONCERNS REPORT NUMBER: MC-40301 SPECIAL PROGRAN SQN REVISION NUMBER: 2 PAGE 3 0F 5 C.
Determined if any other investigations had been conducted regarding the subject concern.
D.
Interviewed personnel involved with valve installation during the i
construction phase of SQN to determine how'the construction valve program was implemented.
E.
Reviewed construction procedures related to valve installation to determine if a program was implemented that would require documenting valve substitution.
F.
Reviewed a sample of the 47W piping drawings to determine if there was evidence of valve substitution on the drawings.
G.
Reviewed construction valve documentation for 200 valves to deterraine if valve substitution was a standard practice at SQN during construction.
IV.
SITMMARY OF FINDINGS A.
No additional information was obtained from the expurgated file.
B.
It was determined by reviewing TVA SQN GCTF Report EI-85-181-001 Revision 1, and related documents that the methodology used in this evaluation was sound and the findings, conclusions, and recommendations were adequate.
C.
No additional investigations were found for the subject concern.
D.
It was learned by the interviews conducted that all safety-related valves at SQN received a unique identifier and the program required a Field Change Request (FCR) to be written for valve substitution.
(Note: FCRs result in drawing revisions.)
E.
It was determined by reviewing the construction valve installation program that the Division of Nuclear Engineering (DNE) drawing was used to verify valve installation, and the valve identification system on the drawings prevented valve substitution without a FCR.
F.
It was determined by reviewing 30 piping drawings that the identification system for valves at SQN was not like the system used at WBN. There were indications on 6 of these drawings that the drawing had been properly revised when valves were substituted.
There was no indication of valve substitution on the other 24 drawings reviewed.
G.
It was found by reviewing construction valve installation documentation for 200 valves that valves were not substituted without the required documentation during the construction phase of SQN.
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-00301
~
SPECIAL PROGRAM SQN REVISION NUMBER: 2 PAGE 4 OF 5
==
Conclusion:==
During the construction phase of SQN, the valve installation progets maintained adequate control of valve substitutions. There was no indication that valves were substituted without the required documentation, thus verifying that the valves used were appropriate.
The program, in use currently at SQN, adequately controls valve substitutions, prevents valves from being improperly substituted, and requires proper authorization. Therefore, this concern is not valid for SQN. However, the procedure controlling material substitution (AI-11) is not referenced in the work control procedures (AI-19 and SQM-2) as recommended in GCTF report EX-81-181-001, Revision 1 and this needs to be addressed by the line organization.
V.
ROOT CAUSE Not applicable.
l lR2 No problem validated / substantiated.
l VI.
CORRECTIVE ACTION As provided by line management:
l 1
SQN engineers responsible for CSSC activities are aware of AI-11 l
requirements as well as many'other SQN requirements which govern CSSC l
activities. Since AI-19 and SQM-2 are the major instructions outlining I
control of work activities, referencir.g every other plant instruction l
which has work requirements in these two instructions would require IR2 several pages of references. This would not necessarily ensure any l
better compliance with AI-11 (or any referenced instruction) and would l
further complicate AI-19 and SQM-2 with increased " tiering of I
instructions" which has been recognized to be poor practice. Therefore, l
revisions to AI-19 and SQM-2 are not necessary.
l l
Reference:
CATD 40301-SQN-01 l
VII. GENERIC APPLICABILITY There is no indication that this perceived problem is generic to BFN or BLN.
T VIII. ATTACHMENTS Attachment A:
Listing of concerns indicating relationship to Nuclear lR2 Safety and Generic Applicability.
l i
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40301 SPECIAL PROGRAN SQN REVISION NUMBER: 2 PAGE 5 0F 5 Attachment A GENERIC APPL QTC/NSRS P#
CONCERN SUB PLT BBSW INVESTIGATION S
CONCERN NUMBER CAT CAT LOC F L-Q B REPORT R
DESCRIPTION EX-85-181-001 MC 402 WBN NYYY*
NS On valve inspection T50225 MC 403 Report (Test 70), QC MC 405 verifies the proper valve by the mark number tag which is installed by the warehouse or vendor and is often just a paper or metal tag Note: This report addresses only the underlined which can be removed or portion of the concern.
replaced by anyone. If the valve has been substituted from what the drawing
- Portions of this concern are generically lists, the bill of applicable to elements contained in subcategories materials does not MC-40200 and MC-40500. It is not generically properly reflect the change. No applicable to this element.
paperwork is provided to Watts Bar engineering to document that it is an acceptable replacement. Many substitues have come in from Hartsville, Phipps i
Bend.
- PSR Codes:
i NS--Nuclear Safety-Related SS--Nuclear Safety Significant NO--Not Nuclear Safety-Related i
wn-
-_-y m
~,yg
-m-m
TVA EMPI4YEE CONCERNS REPORT NUMBER: MC-40307-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 8 0F 8 IN-85-339-002 MC 403 WBN YYYN NS Foreman (Name known)
T50039 Report admitted to the individual that a hanger baseplate had been procured, at his order, from the steamfitter scrapyard and installed when the concerned individual was not at work. Location was given as unit
- 2, elevation 786',
rod control room, on the ceiling.
Time frame was first 6 months of 1981.
- PSR Codes:
NS - Nuclear Safety Related SS - Nuclear Safety Significant NO - Not Nuclear Safety Related.
i
-.