ML20214A514

Rev 2 to TVA Employee Concerns Special Program Final Element Rept MC-40703-SQN, Heat Code as Related to Matl Control

ML20214A514
Person / Time
Site:	Sequoyah
Issue date:	05/12/1987
From:	Brown W TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20214A438	List: ML20214A436 ML20214A480 ML20214A514 ML20214A530 ML20214A542
References
MC-40703-SQN, MC-40703-SQN-R02, MC-40703-SQN-R2, NUDOCS 8705190483
Download: ML20214A514 (42)

Text

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l TVA EMPLOYEE CONCERNS RE?OEI NUMBER: MC-40703-SQN SPECIAL PROGRAM REPORT TYPE:

Sequoyah Nuclear Plant - Element REVISION NUMBER:

2 lR2 (Final Report)

TITLE: Heat Code as Related to Material Control PAGE 1 0F 39 REASON FOR REVISION:

1.

To attach the " Executive Report on Heat Code Traceability Issues at Sequoyah l Nuclear Plant, issued April 21, 1987" (including the Corrective Action Plan) l l

NOTE: The issues were escalated to the Manager of Nuclear Power for resolution I

in accordance with Volume I of the Nuclear Performance Plan and the ECTG l

Program Manual. Resolution was received from the Manager of Nuclear l

Power in memorandum A02 870428 034. The memorandum and subject Executive l Report have been attached. The ECTG evaluators are not in agreement with l the corrective action plan. The revision level was raised to R2; I

however, the contents of the report at Revision Level 1 have not been 1

altered in order to preserve the report the evaluators prepared and IR2 signed. The nine CATDs eventually issued for this report (which replaced I the CATD indicated on page 38 of 39) are included in the attached l

Executive Report.

l l

2.

To make concern number 2850162001 a part of this evaluation.

l I

This concern was an allegation made to the NRC that " Watts Bar Nuclear Plant I

was constructed with non-code materials in certain areas."

[ Reference letter i

from NRC to TVA, dated March 19, 1986 (L44 860324 570)]. The NRC made the l

allegation applicable to all TVA sites plants; therefore, this concern is i

being included in this evaluation for SQN. Since ANSI B31.1, B31.7, and i

ASME III codes have been demonstrated by the Executive Report to have provided I

suitable materials, this allegation relative to SQN is of no consequence.

l PREPARATION PREPARED BY:

N/A (See NOTE under " Reason for Revision" No. 1)

SIGNATURE DATE REVIEWS PEER:

N/A (See NOTE under " Reason for Revision" No. 1)

SIGNATURE DATE TAS:

N/A (See NOTE under " Reason for Revision" No. 1)

SIGNATURE DATE CONCURRENCES N/A (See NOTE under " Reason for

. / /t N, g Q

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, w wlL D//2/J/

SRP: Revision" No. 1)

CEG-H-

/ SIGNATURE

/

/DATE~

SIGNATURE

• DATE l'L b N/A ECSP MANAGER Q)

DATt /

MANAGER OF NUCLEAR POWER DATE CONCURE2NCE (FINAL REPORT ONLY)

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

8705190483 870513 PDR ADOCK 05000327 P

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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 33 1

I.

INTRODUCTION The evaluation of the Sequoyah Nuclear F.snt (SQN), Construction Heat Code Program was performed due to recommendations contained in the Nuclear Safety Review Staff (NSRS) Report number I-84-34-SQN as follows:

"Therefore, it is NSRS's recommendation that a search of documents / files / procedures be made so that a history of the Heat Number Sort can be reconstructed to include the followits:

(1) The purpose / reason the !! eat Number Sort was generated.

(2) Those management controls designed and im;1emented to administer the program.

(3) The function the program was designed to serve and the function it has been serving, if different.

(4) The confidence OC [0ffice of Construction) management has with the available information in the program (Heat Number Sort printout)."

A response to these recommendations was prepared by the Office of the Manage of Construction (C01 850529 007) and was deemed not satisfactory by the Director of NSRS (Q01 850709 054). NSRS planned to investigate this matter further; however, no indication of further inventitution could be found, thus leaving the matter unresolved.

This evaluation was also performed due to a Watts Bar Nuclear Plant (WBN) Employee Concerns Tast Group (ECTG) report " Material Control, Procedural Control. Heat Code", Report number MC 40703, prepared for WBN and made generic to other TVA Nuclear Plant Sites, including SQN.

i

(T TVA EMPLOYEE CONCERNS RETORT NUMBER: MC-40703-SQN ~

SPECIAL PROGRAM REVISION NUMBER: 2 g,

PAGE 3 0F 39 II.

SUMMARY

OF PERCEIVED PROBLEM A.

Construction:

The perceived problem, as derived from the following concerns, is there is a lack of credibility of methods used in the Construction Program. Heat Number Sort Printout (HNSP), for verification of properly Certified Pressure Boundary Materials, at installation.

IN-85-545-X07 WI-85-008-002 XX-85-027-X02 Concern number XX-85-027-X02 was evaluated for Note:

This ECTG SQN in Element Report MC-40705-SQN.

Element Report, MC-40703-SQN, programmatically addresses material traceability to its CMTR, and relates to this concern.

B.

Nuclear Power:

The perceived problem, as derived from the following concerns, is there is a Jack of credibility of methods used in the Nuclear Power Program, Power Storeroom Reguisition (Form TVA-575), for verification of properly Certified Pressure Boundary Material, at installation.

EX-85-023-001 IN-85-660-001 III. EVALUATION METHODOLOGY A.

Construction:

Reviewed expurgated files to obtain additional information.

1.

Reviewed upper-tier criteria to determine the requirements 2.

governing the installation of pressure-retaining materials.

Reviewed site procedures to determine how the upper-tier 3.

criteria were implemented.

Conducted interviews to determine the process used in the 4.

verification of installed materials.

Performed a random sample of pressure boundary material 5.

installations and a review of the associated weld documentation to determine if the matarie.1 installed was properly identified and traceable to its Certified Material Test Report (CMTR).

16 TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN.

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 4 0F 39 l

h B.

Nuclear Power:

Reviewed expurgated files and SQN GENERIC CONCERN TASK FORCE-1.

(GCTF) Reports to obtain additional information.

. Reviewed uppar-tier criteria to determine the requirements 2.

governing the modification of American Society of Machanical Engineers (ASME)Section XI Components.

Reviewed site procedures to determine how the upper-tier 3.

I criteria were implemented.

4 Conducted interviews to determine the process used in the-4.

verification of material installed or divided into two or more

= pieces.

Performed a review of workplans for modification of ASME 5.

Section XI Components to determine if the material installed was properly identified and traceable to its CMTR.

IV.

SUMMARY

OF FINDINGS A.

Construction:

A review of the expurgated files revealed no additional 1.

information.

A review of the upper-tier criteria revealed the following:

2.

The Final Safety Analysis Report (FSAR), Revision 3, does a.

not contain a clear definition of the applicable Code of Record for Nuclear Class I, II, and III construction activities at SQN. Discussions with personnel in the Codes l

and Standards and Materials Engineering Group of the Nuclear Engineering Branch (NEB), Knoxville, confirmed this situation. They revealed, thc applicable Code of Record is American National Standards Institute (ANSI) B31.1.0 for design and ANSI B31.7 (1969) and 1970 Addenda for the i

fabrication, inspection, and test requirements of Nuclear Class I, II, and III (TVA Class A, B, and C/D) piping systems and agreed that a revision to the FSAR section 3.2.2.5 is necessary to clarify this situation. The FSAR I

stated, I

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_ __ _ _ _ ~.

4 TVA-EMPLOYEE CONCERNS

. REPORT NUEBER: MC-40703-SQN.

SPECIAL PROGRAM

~

REVISION NUMBER: 2

u PAGE 5 0F 39

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"The piping.has'been designed to ANSI B31.1.0 Code requirements.

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Fabrication,' inspection, and test requirements of ANSI B31.7 -including B31 Case 115, have been used in lieu of the

' applicable nuclear code cases.for all piping systems *ercept the primary coolan__

t loops and the pressurizer surge line piping. B31 Case 115 accept ASME Code,Section III as-meeting B31.7 requirements."

Note: The Code entitled as United States of America Standard (USAS)

B31.7-1969 was changed by the ANSI B31.7-1970 addenda to ANSI B31.7-1969 and is referred to as.such in this report.

Since the applicable code requirementa for the prim 6ry coolant loops are not defined and there is no clear distinguishing boundary between it and its branch lines,

.the Chemical Volume Control System (CVCS) and Safety Injection System (SIS) piping material included in this report has been evaluated based upon the applicable Code of Record for construction activities, ANSI.B31.7 (1969) and 1970 Addenda including, the' ANSI B31.7c-1971 Addenda 4

paragraph 1-723, for materiala identificatien and.

certification, per SQN Construction Specification NO.

N2M-865 " FIELD FABRICATION, ASSEMBLY EXAMINATION, AND TEST.

FOR PIPE AND DUCT SYSTEMS", Revision 3, dated 04/12/77.

4 The Code of Record, ANSI B31.7. (1969), 1970 Addenda and 1971c Addenda, paragraph 1-7:3, for material identification and certification, states in paragraph 1-723.1.3(a),

4'

.. identification of pressure-retaining

.material'shall consist of marking the material with the applicable material specification and grade, heat number, or heat code of the material,

• and'any additional marking required to facilitate traceability of the reports of the results of all.

tests and examinations performed on the material.

Alternatively, a markin6 eymbol may be used which identifies the material specification number and grade, and a marking code may be used which identifies the meterial heat number with the Certified Materials Test Report. *The Certified Materials Test Report shall contain an explanation of both the symbols and the code."

• UNDLRLINE ADDED FOR EMPHASIS IN THIS REPORT

TVA EMPLOYEE CONCERNS REPORT NUMBER:

MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 6 0F 39' SQN is committed, in section 3.1.2.1 of the FSAR, to the b.

requirements of 10 CFR 50 Appendix B. " Quality Assurance Criteria for Nuclear Power. Plants end Fuel Reprocessing Plants", which states in Criterion VIII,

" Measures shall be established for the identification and control of materials, parts, and components, including partially fabricated assemblies. These measures shal) assure that identification of the item is maintained by heat number, part number, serial number or other appropriate means, either on the item or on records traceable to the item, as required throughout fabrication, erection, installation, and use of the item. These identification and control measures shall be designed to prev'nt the use of incorrect or defective m&terial, parts, and components."

i 3.

Review of site procedures:

Site Procedures used during the construction of SQN a.

pertaining to marking and identification of received meterial, consisted of the following:

SNP CONSTRUCTION PROCEDURE NO. M-7, "EFECTION AND DOCUMENTATION REQUIREMENTS FOR PIPING SYSTEMS WITHIN TI'E SCOPE OF THE

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QUALITY ASSURANCE PLAN" (M-7), Revision 0, dated 08/25/72 through Revision 15, dated 01/02/80.

SNP CONSTRUCTION PROCEDURE No. P-12. " RECEIPT, INSPECTION, STORAGE, AND WITHDRAVAL OF PERMANENT Mt.TERIAL" (P-12), Revision 0, dated 12/12/72 tnrough Revi: ion 13, dated 11/19/84.

SUPPLEMENT A TO SNP CONSTRUCTION PROCEDURE NO. P-12, " RECEIPT, INSPECTION, ETORAGE, AND WITHDRAWAL OF NAVC0 MATERIAL ON TVA CONTRACT 71C38 - 92615" (P-12A), Revision 0, dated 05/28/75 through Revision 2, dated 04/23/76.

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 7 0F 39 SUPPLEMENT B TO SNP CONSTRUCTION PROCEDURE NO. P-12, " RECEIPT, INSPECTION, STORAGE, AND WITilDRAWAL OF NAVC0 MATERI AL ON TVA CONTRACT 76K53 - 91880" (P-12B), Revision 0, dated 03/23/76.

SNP INSPECTION INSTRUCTION NO. 30, " RECEIPT INSPECTION" (II-30), Revision 0, dated 05/04/77 through Revision 7. dated 09/20/82.

SND CONSTRUCTION PROCEDURE NO. P-34, " HEAT NLdBER VALIDATION" (P-34), Revision 0, dated 06/13/77 and Revision 1, dated 12/13/78.

SNP INSPECTION INSTRUCTION NO. II-39, " HEAT CODE TRANSFER AND ASTM DESIGNATOR TRANSFER" (II-39), Revision 0, dated 05/04/77 through Revision 2, dated 12/11/78.

SNP CONSTRUCTION PROCEDURE NO. P-31,

" IDENTIFICATION AND MARKING OF PERMANENT MATERIAL" (P-31), Revision 0, dated 05/04/77 througn Revirion 2, dated 12/17/79.

SNP INSPECTION INSTRUCTION NO. 35, " ISSUE INSPECTION" (II-35), Revision 0, dated 03/15/77 through Revision 3, dated 05/26/78.

SNP INSPECTION INSTRUCTION NO. 32, " INSPECTION OF MATERIALS IN STORAGE" (II-32), Revision 0, dated 05/04/77 through Revision 10, dated 04/21/82.

A review of these procedures revealed that only one procedure, M-7, Revision 0, dated 08/25/72 provided methods for the material to be trtced to *the certification re:ord, as per the code. Later revisions of M-7 and additional associated procedures, were developed that required received materials to be marked, so that, at best, materials could The only be traced back to the procurement contract.

procedures governing " heat number validation" upon material receipt (i.e., P-31, P-34, and II-39) do not contain a method for material identification and marking traceable to the CMTR.

• UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT I

i

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 8 0F 39 Site procedures used during construction of SQN pertaining b.

to material identification / verification at installation, consisted of the following:

SNP CONSTRUCTION PROCEDURE NO. M-7, " ERECTION AND DOCUMENTATION REQUIREMENTS FOR PIPING SYSTEMS WITHIN THE SCOPE OF THE QUALITY ASSURANCE PLAN" (M-7), Revision 0, dated 08/25/72 through Revision 15, dated 01/02/80.

SNP INSPECTION INSTRUCTION NO. 74, "FITUP AND CLEANLINESS" (II-74), Revision 0,-dated 02/14/77, through Revision 6, dated 07/28/82.

SNP CONSTRUCTION PROCEDURE NO. G-3, " ERECTION OF PIPING AND INSTRUMENT LINES" (G-3), Revision 0, dated 02/14/77.

SNP CONSTRUCTION PROCEDURE NO. W-3, " WELD PROCEDURE ASSIGNMENT AND WELDING SURVEILLANCE" (W-3), Revision 0, dated 01/31/77 through Revision 3, dated 12/04/78.

SNP INSPECTION INSTRUCTION NO. 35 " ISSUE INSPECTION" (II-35), Revision 0, dated 03/15/77 through Revision 3, dated 05/26/78.

SNP INSPECTION INSTRUCTION NO. 36, "0RIENTATION AND ALIGNMENT" (II-36), Revision 0, dated 02/04/77 through Revision 9, dated 02/16/83.

A review of these procedurcs revealed that only one procedure, M-7, Revision 0, dated 08/25/72, required the material certification to be on hand and be acceptable.

Later revisions only required the material to be listed on the Weld History Record, which was then certified to be in accordance with applicable drawings, codes, and specifications, by signature.

Site procedure II-74 Revision 0, dated 02/14/77, required examination and verification of

• acceptable material identification, heat number material specification and grade. and ASME Classification, with the provision that all material used shall have

• mark and/or heat number, which was certified, by signature, on the data sheet or equivalent data card.

Site procadure II-74, Revision 1, dated 05/12/77, required the examination and verification of *only the material identification, with the provision that material used shall have

• mark and/or heat number, which was certified, by signature, on the data sheet or equivalent data card.

• UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 9 0F 39 Site procedure II-74 Revision 3, dated 11/07/78, and subsequent revisions, required examination and verification that the

• component identification was as specified on the applicable weld map, with a provision that piping material required.* heat number verification, which was certified, by signature, on the data sheet or equivalent data card.

No site procedure could be found to Note:

describe the heat number verificatior.

process.

No site procedure could be found Note:

governing the accuracy of the information or the use of the HNSP, only a

• User's Guide was found, describing how information should be encoded, The following SQN construction Standard Operating c.

Procedures (SOPS) were reviewed:

Note: The Records Information Mana6ement System (RIMS) personnel stated that SOPS were not considered Quality Assurance (QA) documents; consequently, their latest revisions are the caly ones available (maintained in RIMS).

SNP SIANDARD OPERATING PROCEDURE NO. 001, " PREPARATION 0F SNP STANDARD OPERATING PROCEDURES" (SOP-001),

Revision 4, dated 12/21/79.

SNP STANDARD OPERATING PROCEDURE NO. 312 " LOCATION AND CONTROL OF MATERIAL FOR PRIORITY ACTIVITIES" (S0P-312), Revision 2, dated 11/08/79.

SNP STANDARD OPERATING PROCEDURE NO. 320, " LOCATING AND CATALOGING PERMANENT MATERIAL FOR ENGINEERING CONTROL" (S0P-320), Revision 0, deted 09/06/79.

SNP STANDARD OPERATING PROCEDURE NO. 600, " LOCATION AND CONTROL OF MATERIAL FOR PRIORITY ACTIVITIES" (SOP-600), Revision 1, dated 01/04/79.

SNP STANDARD OPERATING PROCEDURE NO. 601, " RECEIPT INSPECTION OF PERMANENT PLANT KATERIAL" (SOP-601),

i l

Revision 2, dated 07/13/78.

• UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 10 0F 39 SNP STANDARD OPERATING PROCEDURE NO. 310. " REQUISITION FROM AND RETURN OF PERMANENT MATERIAL TO THE WARE!!0USE" (SOP-310), Revision 4,. dated 11/08/79.

SOP-001, Revision 4, paragraph 5.A defines an S0P as:

. A procedure or detailed instruction written as a guide for craft and/or engineering section activities of operations but not written to include QA requirements or commitments,"

These SOPS were reviewed for information only rather than as QA implementing documenes; however, the guidelines presented in them did not provide for material marking and identification traceable to the CMTR.

Interviews conducted with persons who performed inspections 4.

and/or verifications of material during the construction of SQN revealed the following:

Interviewee A Interviewee was a construction Quality Control Record Unit (QCRU) reviewer. Interviewee said, " July 31, 1977, was the approximate date the weld review group was formed to input information that was available onsite into a computerized program. This contract information was used to develope a heat code or heat _ sort printout for

~

meterial received with CMTRs MTRs [ Material Test Reports), or C0Cs [ Certificates of Compliance 1 Material for SQN procured by Quality Engineering Branch Contracts by Knoxville and inspected at the factory were not always encoded because Knoxville received all of the CMTRs, C0Cs and other related documentation. The information encoded in the printout consisted of the heat number, sometimes the class of material, if known, the 209 number (receiving report), the contract number, and a description of the material.

Interviewee did not know of a procedure governing the use of the printout or for its control. There was a Users Guide and other information When compiled to aid in the encoding process involved.

interviewee began working in the QCRU, part of the responsibility of the group was to review the weld cards (ShP-II-74). When the cards were received they were checked for the following. All blanks were filled in or N/A, the welder was certified to the process used, the inspector was certified to the inspection procedure, and that both components' heat numbers were in the printout.

If the heat numbers were in the printout it meant that there was either a C0C or CMTR or some kind of documentation."

I TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN

]

SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 11 0F 39 Note: During the interview it was revealed there was some problem with some people not knowing the difference between a CMTR and a C0C.

Interviewee said, "There was not a requirement for the reviewer of the data card to check for class, size, type or grade of the material. When the review of the cards was complete the heat numbers were then written on the weld nap.

The hett code printout was up-dated, usually once a week."

Interviewee B Interviewee was a Construction Welding Inspector.

Interviewee said, "I do not remer;ber very much about the program that was used at that time except that they recorded the information, heat numbers of the material.

welded together, on a data card. They wrote the heat number down which was on the material and then wrote it down on the data card. They verified the heat numbers egsinst the printout, but, I do not remember if they were required to check to see if it was the correct code Class."

Interviewee C Interviewee was a Construction Welding Inspector.

Interviewee said, "There was a procedure used before SQN II-74.

An (M-7), where code welds were controlled on what was called a Weld History Record. It contained all information needed to track the work. I think the information on the Weld History Record was then transferred to the data card. They used the weld map to determine what material was to be used but there was not a requirement that they go back to the printout to see if what the fitters had was the correct code class. We did check t) see if the material was in the printout."

Interviewee D Interviewee was a Construction Welding Inspector.

Interviewee said, "I verified the material was correct by checking the heat sort printout. Some of the material had the code class marked on it with a pink paint stick. If we could not find the class in the printout or if it wasn't marked on the pipe we would rely on the craft to tell us if it was the right material."

[

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 12 0F 39 Interviewee E Interviewee was a Construction Welding Inspector.

Interviewee seid, "I verified material by use of the II-74 data cerd." The question was asked, "If the interviewee checked the class of the material before signing the card?"

Interviewee said, "No, I only wrote down the number of the material that was used. I did not use the printout. I think Record Review checked this later because if we made a mistake they would eend the card back."

Interviewee stated again, "I didn't use the printout. I only checked the veld maps and filled out the data card."

Interviewee F Interviewee was a Construction Welding Inspector.

Interviewee said, "We verified heat numbers by checking to see that they were on the material being used, we then wrote this number down on the data card, QCRU reviewed the cards and I think they checked to see if the number was in the printout. We [ welding inspectioni did not do any checking to see if the material was the correct code class, I did not use the heat sort printout. I only wrota down the heat number that was (n the material. Before we used the data cards we verified material on a weld history record under a different procedure I do remember, one case, where I found some schedule 40 material with the same heat number as schedule 80, but this was changed out."

Interviewee G Interviewee was a Construction Welding Inspector.

Interviewee said, "The fitters would have a piece of material with a mark number and/or heat number written on it.

I would log the heat number down on the Weld History Record. Later, we used data cards to log the material down on."

The question was asked, "Did you check to see if the material was the right class and type or grade?"

Interviewee said, "Inspectces were not required to check l

the class but sometimes the class was written on the material with a pink paint marker. I only checked to see if it was in the printout which was kept in the pipe shop.

If it was in the printout it was considered good.

Sometimes it would not be in the printout and we would call the Mechanical Engineer, over the system, if the engineer said the material was good, I would sign the card."

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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER:

2 J

PAGE 13 0F 39 Interviewee 11 Interviewee was a Construction Mechanical Engineer.

Interviewee did not know of any official system or process used to verify that cdditional checks other than inspection, were performed to ensure that the correct class of material was used..Tnterviewee stated, "That an employee who worked in Welding did a lot of checking of material to see if it had a CMTR. There was a printout in Wolding and when the inspectors called in, the employee would look it up to see if it wss in the printout, if not, the employee would check to see if it was good material.

Good means it has a CMTR. The program changed as did the procedure throughout construction. This was due to recognizing a need for better control.

I have a high degree of confidence that material used was of the correct class but do not know of the special programs or procedures that assured this. My feeling is based on very good and confident Engineers and Craftsmen, that took pride in doing the best job possible."

Interviewee I Interviewee was a Construction Mechanical Supervisor.

Interviewee relied on the HNSP whenever a question of material verification came up.

National Valve and Manufteturing Company (NAVCO) supplied pipe had unioue serial or mark numbers on it.

Some TVA loose material had TVA mark numbers and is identified this way; however, material bought on Indefinite Quantity Term (IQT) contracts did not have mark numbers, only heat numbers.

Interviewee J Intsrviewee was a Construction Welding Inspector.

Interviewee stated, "I was connected with the program in come way, shape, or form and correct class verification of material was not used, inspectors only checked to see if the material's heat number was in the printout, if it was, it was considered good material and used in any code system.

I feel SQN is required to use code material and all Class A must have a CMTR for Class A or material must be up-graded, which requires a CMTR and an NDE [ Nondestructive Examination), PT [ Penetrant Test), minimums."

l TVA EMPLOYEE CONCERNS REPORT NUMBER:

MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 14 0F 39 Interviewee K Interviewee was a Construction Mechanical Engineer.

Interviewee stated, "We found material installed at SQN, that we did not have CMTPs for and the manufacturer supplied them at a later date. There were cases where no ChTR could be obtained and this material was cut out and removed (replaced with different material). The vendors started supplying CMTRs with some material no matter how it was requested. SQN has also received CMTRs for material that they may not nave even received. Loose Material, referred to es LH sheets designated what material was to be installed at what locction.

However, during construction it was learned there could not be relied upon for accuracy, due to warehousing lack of control in issuing material.

Prior to QC [ Quality Controll becoming involved in issue of material, approximately December, 1974, werehousing personnel wou2d pick up a like fitting and write the needed LM number on it and issue it."

Interviewee further stated, "SQN operated under the principlo that if they, SQN had a CMTR or MTR for a particular heat number, it was considere6 good for any product or type piece of material that was made out of it.

There was a lot of material that was installed that SQN did not have a CMTR for and I contacted the manufacturer to obtain a CMTR, if one could not be obtained, the material was cut out. CMIRs for Class A were not looked at as being unique to the actual materiel that was received."

Interviewee L Interviewee was part of a Construction task force set up to correct heat codes on weld documentation. The following is a summary of interviews with this person.

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If the weld documentation material identification (heat code) did not agree with the heat code on the adjacent wold documentation the interviewee was directed by supervisory personnel to analyze and correct erroneous and discrepant weld documentation / heat numbers, as required.

Interviewee stated, " Inspectors were used to reverify, discrepant heat codes. If the heat number could not be read in the field, the supervisors' instructions were to change the weld documentation so that both documents would agree, with the information on the document with the latest date."

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER:

2 PAGE IS OF 39 Interviewee changed approximately ten to twenty discrepent heat codes per day, from 1977 through 1979. These were lined through, initialed and dated by the interviewee, based upon, inspectors information, or personal judgment that the heat code number had been incorrectly written, (e.g., character transposition or omission) based upon how the heat code appeared in the HNSP.

No e:

Interviewee expressed doubt that all the heat code numbers to be rechecked were actually field verified.

Interviewee stated, "When weld documentation was lost or could not be located the inspectors were requested to check the field installed materic1, if no identifying markings were found, new documentation was constructed from the best available information, obtained from the following:

inspectors' memory, inspection log sheets or Operation Checklist."

Interviewee M Interviewee was a Construction Welding Inspector.

Interviewee stated, "I was working second shift as an inspector, there was some Class A fabrication and installation of pipe being perfctmed in unit number 1, Reactor Building." The question was asked, "Do you know the location where this material was installed?" Interviewee said, "It was 2" schedule 160 pipe Chemical Volume Control System, unit number 1, in the raceway of the Reactor Building about three feet off the crane-wall, up near the ceiling."

Note: This is the location of some of the Class "A" material ecvered in the construction portion of this ECTG random sample review (see section IV.A.5).

Interviewee said, "When I checked the heat number on the pipe it was listed as Class "B" and I would not sign it off.

The question was asked "How did you know it was Class "B"?"

Interviewee said, "That was the way it was listed in the heat number printout. When I objected to signing the fit-up off [ Weld Data Sheet] I was taken off the job and someone else was put on it; however, I think that the pipe has later been upgraded to Class "A" and there should not be a problem with it."

The question was asked, "What all did you check to verify that the correct material was used?"

Interviewee said, "I verified the heat number by the printout

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 16 0F 39 and the lead inspector enected our work at the end of the day to see if the heat numbers were good."

The question was acked, "Was anything clse checked to verify the material?" Interviewee said, "I checked the heat number." The question was asked, "You did check schedule, type and grade, didn't you?" The interviewee said, "Yes."

The interviewee was asked, "How did you check the type of material?" Interviewee said, "I checked to see if it was P1 or P8, P1 is carbon steel and P8 isstainless steel." The question was asked, "Does type 316 or type 304 mean anything to you?" Interivewee said, "No."

The question was asked, "Does A105 or SA105 have a meaning to you?" Interviewee said, "No, I only checked to see if it was 21 or P8."

The question was asked, "Were there any other markings on the pipe, except f or the heat number?" Interviewee said, "Sometimes there were pink paint markings; but, I used-the factory ink markings for the heat number check." The question was asked "Have you ever heard of an LM number?"

Interviewee said, "I sure have, but inspectors were not allowed to use them, if we did our supervisor would chastize us in front of the whole group. We were only allowed to use heat numbers and we would get a letter if we Ifouled) up."

The question was asked, "Have you ever seen a cultiple listing in the heat code printout?" Interviewee said, "No."

5.

Random Sample Review:

A review of material identified on 16 TVA SQN weld maps, consisting of 8 for Unit 1 and 8 for Unit 2, on Class "A" Systems (Chemical Volume Control System, 62, and Safety Injection System, 63) was performed to determine if material with the proper certification was installed.

The reviewed Weld Mao Drawings are as follows:

Unit 1 Unit 2 1-CVC-500-IW 2-CVC-500-1W 1-CVC-501-1W 2-CVC-501-1W 1-CVC-501-2W 2-CVC-501-2W 1-CVC-502-1W 2-CVC-502-1W 1-CVC-502-2W 2-CVC-502-2W 1-CVC-503-1W 2-CVC-503-1W 1-CVC-509-1W 2-CVC-SO9-1W 1-SI-500-iW 2-SI-500-1W This review was limited to a small sample of dr: wings for 1" through 2", TVA Class "A" pressure boundary materials.

--e

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 17 0F 39 The heat codes used for material identification shown on these drawings were tabulated and consisted of 69 heat codes, identifying 517 items. A copy of the construction HNSP (run dated 04/25/84) was reviewed to determine if these heat codes were traceable to their CMTRs.

From references listed in the HNSP for these heat codes, TVA Receiving Reports (IVA-209s),

containing material quantitles and documentation received, were obtained.

Note:

In some cases the TVA-209 reference was in error, omitted or did not contain the material documentation.

A review of the TVI-209s and their attached documentation revealed:

1.

Class ' A" and "B" or lesser material was received with identical heat codes, material description, and no marks to distinguish between classes.

2.

Material with identical heat codes was received with differing material descriptions, (e.g., size, schedule, or pressure class).

3.

Some material was identified by a Loose Material (LM)

Number (e.g., NAVC0 Piping), and some was not (e.g.,

Capitol Pipe & Steel Products). LM numbers are not unique to the heat number / code, pressure class, material description or product form, and in most cases arenotreferencedDatheCMIR,filedwitptheTVA-209.

4.

Some material had additional markings identifying it as acceptable for Class "A" use.

Therefore, a comprehensive walkdown of the piping on the referenced drawings was performed by Modifications Unit personnel to determine what, if any, additional markings were on the installed material.

Results of th*s walkdown differed significantly from the heat code information on the Weld Maps; therefore, a detailed review of the weld documents for these drawings was performed, comparing the documented material identificction information with that on adjacent weld documents and information obtained T 9m the piping systems walkdown. This review, consisting of 573 weld documents, revealed that 65% of the documented welds contained material identification discrepancies (e.g.,

incomplete heat numbers, distgreement with walkdown l

information, illegible entries on weld documents, missing weld documents, disagreement between adjacent weld documents).

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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 18 0F 39 This review of documentation related to the 517 items installed, per the referenced weld maps, revealed that 7 of the 517 items (1.4%) were identified by markings, on them, traceable to their CMTR.

The following list of examples is presented as representative of some of the findings of this evaluation; however, it must not be considered comprehensive in nature.

Example A:

" CMC" is used as the heat code for material identification of one of the components on the weld document for weld number 2CX-01114A 1, on weld map 2-CVC-501-2W.

" CMC" is listed in the HNSP and refers to items of various heat codes, cla:ses, and material descriptions, manufactured by Colonial Hachine Co.

However, " CMC" is not a heat code; rather, it is the manufacturer's identification code and stands for

• Colonial

• Machine

• Company.

Example B:

"CCI" is a heat code for a 2" 6000# socket weld (S/W) coupling (cp1g.), Schedule (Sch) 160 Bore, A182 F304, for which there are two entries in the HNSP, one each for Class "A" and "B".

The material identified in the HNSP as Class "A" was received on 10/02/75, on TVA-209 #76-2823. The CMTR filed with this TVA-209 identified the fittings as having been Liquid Penetrant Tested and as Nuclear Class I-TVA Class "A"; however, no special identification markings were denoted on the CMTR, traceable to the fittings. The material identified in the HNSP as Class "B" was received on 08/21/75, on TVA-209 #76-1379. The CMTR filed with this TVA-209 identified the fittings as ** Nuclear Class III-TVA Class "B"; again, no special identification markings were denoted on the CMTR, traceable to the fittings.

Approximately 40 of these fittings are installed, per the walkdown performed for this evaluation. One example of installation is weld map 2-CVC-503-1W, weld numbers 2-CX-01256 and 2-CX-01257.

Example C:

"CZC" is a heat code for 2"X3/4" 6000# inserts, A182 F304, for both Sch 160 bore and a special 0.375 inch bore. The HNSP

• UNDERLINE ADDED FOR EMPHA3IS IN THIS REPORT

• • UNDERLINE DENOTES DOCUMENT DISCREPANCY

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMDER: 2 PAGE 19 0F 39 revealed three references to TVA-209s, one for Class "A" and two for Class "B".

The material identified in the HNSP as Class "A" was received on 09/17/75, on TVA-209 #76-2235. Thd CMTR filed with this TVA-209 identifieil the fittings as having l

a special bored inside diameter (ID) of 0.375 inch, as having been Liquid Penetrant Tested and as Nuclear Class I-TVA Class A; however, no special identification markings were denoted on the CMTR, traceable to the fittings. The material identified in the HNSP as Class "B" was received on 03/17/75, on TVA-209s

1. 75-5643 and #75-5674. The CMTR's filed with these TVA-209s identified the fittings as having a Sch 160 bore and as Nuclear Class II; again, no special identification markings were denoted on the CMTRs, traceable to the fittings. Approximately 10 of these "CZC" fittings are installed, per the weld documentation for the referenced weld map drawings; however, the walkdown performed for this evaluation identified only two.

Note: The FSAR in paragraph 3.2.2.1 states in part "... Branch piping 3/8-inch inside diameter or smaller, or protected by a 3/8-inch diameter or smaller orifice, is exempted from Class A..."

The use of the 3/8-inch diameter or smaller orifice is not consistently identified on the weld documents for material identification.

An example of installation is Weld Map 1-CVC-502-2W; weld numbers 1-CX-02143 and 1-CX-02144 1.

These weld documents do not denote this fitting as having a special 3/8-inch bore, as required by the weld map. The field walkdown revealed this fitting is a 2"X3/4" S/S reducing insert stamped "CZC".

Another example is Weld Map 2-CVC-502-1W: weld number 2-CX-01265 identifies the material as a 2"X3/4" reducing insert with the heat code "CNC" which has been lined through, initialed and dated, and changed to "CZC".

Adjacent Weld number 2-CX-01266 identifies the material as a 2"X3/4" special flow insert, with heat code "CZC".

Example D:

"CCF" appears on the marked up copy of Weld Map 2-CVC-500-1W and is identified as a 2"X3/4" reducing insert 6000# S/W.

"CCF" is not listed in the HNSP. The weld documentation for 2-CX-01020 and 2-CX-01021 were reviewed to determine what is

TVA EMPLOYEE CONCERNS REPORT NUMBER:

MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 20 0F 39 documented as installed. Weld document for 2-CX-01020, (dated 04/16/79) denotes a 2"X3/4" 6000# insert with the heat code "CNC".

Adjacent weld document for 2-CX-01021, (dated 04/11/79) denotes a 3/8" special " rest", with the heat code "CNC".

Note: Weld, number 2-CX-01021, has been cut out and reinstalled two additional times, creating weld documents 2-CX-01021 1 and 2-CX-01021 2.

Wold document for 2-CX-01021 1, (dated 05/11/79) denotes a 3/4" Special Flow Restrictor with heat code "CVC", this heat code was lined through, initialed and dated (05/30/79), and changed to "CCV".

Weld document for 2-CX-01021 2, (dated 11/17/79) denotes a 2"X3/4" insert S/S (flow restrictor) with the heat code "CCV".

The field walkdown revealed that no identification markings were on this fitting.

Note: The heat code for the fitting was initially identified as "CNC", later changed to "CVC",

and then changed again to "CCV";

however, the field walkdown revealed *no identification markings.

Example E:

"CNC" is a heat code for 2"X3/4" 6000# and 3000# reducing inserts, bored for Sch 160 and Sch 40, respectively.

"CNC" is also the heat code for other material descriptions. From references in the HNSP two TVA-209s were found, TVA-209

1. 75-6874 and #75-6875, both were received on 05/27/75. The CMTRs filed with these TVA-209s revealed the material to be 2"X3/4" 6000# reducing inserts, *Sch 160 bore, as having been Liquid Penetrant Tested and as Nuclear Class I-TVA Class "A";

however, no special identificatien markings were cenoted on the CHTR, traceable to the fittings.

Approximately three of these fittings were installed per the weld documentation.

Examples of installation are:

• UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 21 0F 39 Weld Map 2-CVC-500-lW; weld number 2-CX-01059 and adjacent weld number 2-CX-01060 both identify the materici as a special reducing insert, with heat code "CNC".

Weld Map 2-CVC-502-lW; weld number 2-CX-01158 and adjacent weld number 2-CX-Oll59 both identify the material as a reducing insert (special 3/8" ID. flow restrictor), with hett code "CNC".

Weld Map 2-CVC-503-lW; weld number 2-CX-01245A and adjacent weld number 2-CX-01245B both identify the material as a 2"X3/4" reducing insert, with heat code "CNC".

Note:

No documentation could be found showing any 2"X3/4" 6000#

reducing inserts, with a *special 3/8" bore, with the heat code "CNC", as having been received.

Exemple F:

"S4FDY" is a heat code for 2"-6000#, S/W, 45* ells, ASTM A182-F304. The HNSP contains four entries for this heat code; two for Class "A", one for Class "B", and one with no Class.

The Class "A" entries reference TVA-209 #76-0399, received on 07/21/75. A review of the documentation filed with this TVA-209, revealed there were CMTRs filed with it that identified the fittings as NUCLEAR CLASS 2 and stated the specific markings were, "(L) 2" 6000# WOG A182F304 S4HDY"; and also as NUCLEAR CLASS 1, having been Liquid Penetrant inspected, and having specific markings, "(L) 2" 6000# WOG A182F304 S4HDY PIB".

One of the CMTRs also referenced TVA-209

1. 75-7057.

A review of TVA-209, #75-7057 revealed that this material was received on 06/05/75. The CMTRs filed with the TVA-209 identified the fittings as NUCLEAR CLASS 2 and having specific markings, "(L) 2" 6000# WOG A182F304 S4HDY". One of the CMIR's contained the following handwritten notation, "6 PIECES WITH HEAT NO S4HDY SHALL BE UPGRADED TO CLASS A.

THE UNIQUE HEAT NO SHALL BE DESIGNATED AS S4HDYPT. UPGRADE TEST TO BE LIQUID PENETRATE (SIC) ON ALL ACCESSIBLE SURFACES INSIDE AND OUT PER.

• UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT i

TVA EMPLOYEE CONCERNS REPORT NUMBER:

MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 22 0F 39 Note:

Engineers' and Inspector's names omitted in this quotation.

Note:

S4HDY PTB is in the HNSP; however S4HDY PT is not.

An example of installation is Weld Map 1-CVC-503-1W; weld number 1-CX-02161 2 and adjacent weld number 1-CX-02162 2.

Weld documents for these welds denote this fitting as a 2" 6000// 45" Ell, with heat code "S4HDY".

The field walkdown revaaled this fitting is "S4HDY".

The manufacturer of this fitting, when contacted for an explanation of the marking code shown on this fitting, revealed the following:

1. "S4HD" denotes the heat number of the fitting identifying its chemical and physical analysis.

2. "Y" denotes the heat treatment received by that particular batch of fittings.

3. Had the fitting been Liquid Penetrant Tested it would have been stamped. "PTA", "PTB", etc. identifying the technician who performed the test.

4. The markings on the fittings do not provid'e traceability to its CMTR.

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TVA EMPLOYEE CONCERNS REPOET NUMBER: MC-40703-SQN SPECIAL PROGRAM j

REVISION NUMBER: 2 P GE 23 0F 39 L

t, Another example is Weld Map 2-CVC-502-1W; weld number 2-CX-01143C and t.djacent weld numberi2-CK-01143B 1 (See figure 1 below).

t Weld Document Weld Document 2-CX-01143C.

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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN

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SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 24 0F 39 Example G:

"S4HAR" is a heat code for a 2" 6000# 90* Ell S/W A182 F304.

From a reference in the HNSP. TVA-209 #76-5529, dated 02/13/76, was found. A review of the CMTR filed with this TVA 209 revealed no NUCLEAR CLASS, and the specific markings on the fittings are, "(L) 2" 6000# WOG A182 F304 SAMAR & S4KTR".

Weld Map 2-CVC-503-1W; weld number 2-CX-01250 revealed the material identification to be 2" 6000# 90* with the heat code "S4 MAR", adjacent weld number 2-CX-01251 revealed the material identification to be 2" 6000# 90* L A182 with the heat code "S4HXM".

The field walkdown revealed the material identification to be "S4 MAR PTA".

Example H:

"AX" appears on the marked ur. e,cy of Weld Map 1-CVC-502-lW and is identified as a 2" 6000# f W 50' ell.

"AX" is not listed, by this material description. in the HNSP. No CMTR could be found for this material.

Weld number 1-CX-02091 2 revealed the material identification to be 2" Sch 160, 90* ell A182 with the heat code "S4KNAX" which was lined through, initialed and dated, and changed to "AN"; this was lined through, initialed and dated, and changed to "AX".

Adjacent weld number 1-CX-02092 2 revealed the material identification to be 2" 6000# 90* Ell, A182 with the heat code "AX".

The field walkdown revealed the material identification to be "S4KNAX-PTA".

Example I:

"M8963" appears on the marked up copy of Weld Map 2-SI-500-1W as 1-1/2" Sch 160 S.S. A376 TP 304 pipe. The HNSP revealed one entry identified as Class "A" referencing TVA-209 #75-5836.

This TVA-209 revealed that an undetermined quantity of this material was received. The CMTR filed with this TVA-209 did not reveel the quantity that was tested nor any specific material identification markings traceable to the material.

f

TVA EMPLOYEE CONCERN 3 REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 25 0F 39 Example J:

During the Weld Document Review performed on Weld Map 1-CVC-502-2W the weld documents for weld numbers 1-CX-02113 and 1-CX-02116 could not be found. The weld documents were not located on the microfilm rolls and the weld tabulation sheet had been " whited out".

Note: These were the only twe weld documents of the 573 reviewed that could not be located; however, during the search for these documents it was learned that a document audit was not performed verifying their existence, prior to the system transfers to Nuclear Power.

Example K:

" Class Change Discrepancies" Inconsistencies in denoting changes from Class "A" to Class "B"

were discovered during the weld map review for Class "A" material installations. TVA flow Diagram 47W813-1, Revision 27 " Flow Diagram Reactor Coolant System", and 47W809-1, Revision 27,'" Flow Diagram Chemical and Volume Control System",

were reviewed to determine the accurate locations of these Class changes.

This review revealed the following:

1.

The 1" supply line to the " Excess Letdown Heat Exchanger" from the " Loop Number 3 Cold Leg" is shown on 47W813-1, Revision 27, as changing from Class "A" to Class "B" at the Cold Leg, upstream of valve 68-579; however, when the continuation of this line is followed on to 47W809-1, Revision 27, there is another change from Class "A"

to Class "B" noted, downstream of valve 68-579.

2.

Note number 8 on 47W813-1, Revision 27, and note number 9 on 47W809-1, Revision 27, states, "Special transition piece (3/8" I.D. Flow Restrictor) required for transition from Class A to Class B pipe." There are several locations on these drawings where these notes are referenced and no clear statement of Class change is made.

Consequently, this has resulted in the piping systems being installed in a manner not depicted by the Flow Diagrams and according to the FSAR, Section 3.2.2.1

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 26 0F 39

. whose failure could cause a loss of reactor coolant which would not permit an orderly reactor shutdown and cooldown, assuming that makeup is only provided by the normal makeup system.

Example L:

"BVK24H", "BVH13Z", and "BVK24C" appear on several weld maps as heat codes for 2" Sch 160 A376 TP304 S/S pipe. The field walkdown revealed that, in most cases, the factory markings and TVA paint stick markings have been removed. The following are examples of discrepancies that exist between those that can be read and the weld documentation.

TVA Weld Map 1-CVC-503-1W; weld document 1-CX-02160 1 identifies this material as, A376 2" Sch 160 pipe with the heat code "BVM13Z",

Adjacent weld document 1-CX-02161 2 identifies this material as, A376 2" Sch 160 pipe with the heat code "BVK24C".

The field walkdown revealed this material to have heat code "BVK24C" marked on the pipe with a paint stick and factory markings "BVH13Z" etched on the pipe.

TVA Weld Map 1-CVC-502-2W; weld document 1-CX-02114A identifies this material as, 2" Sch 160 S/S pipe, LM 34-13, with the heat code "BVK24H".

Adjacent weld document 1-CX-02115 identifies this material as 2" Sch 160 S/S pipe. LM 34-13, with the heat code "BVM13Z", which has been lined through, initiated and dated, and changed to "BVK24H".

The field walkdown revealed this material to have heat code "BVM132" (Factory Mark).

B.

Nuclear Power:

1.

A review of the expurgated files revealed no additional information.

A review of the SQN-GCTF report for Employee Concern Number EX-85-023-001, Revision 0, revealed:

The report (GCTF) presented a brief summary of s review of the site procedures used for material traceability and transfer of heat numbers; however, it did not verify the actual implementation of these procedures.

'TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 27 OF 39 The conclusions of the report (GCTF) are not valid.

Although, SQN does transfer heat numbers with QC verification and uses the TVA-575, rather than a computer program for material traceability; the TVA-575 method used provides traceability only to the material's procurement document, rather than its CMTR. This determination is based upon the findings contained in this report (ECTG).

A review of the SQN-GCTF report for Employee Concern Number EX-85-023-001 - Revision 1, revealed:

The report (GCTF) presented a summary of a review of the site procedures used for material traceability and transfer of heat numbers; however, it did not verify the actual implementation of these procedures.

The validation of the concern as stated in the conclusions of the report (GCTF) is correct; however, the conclusion, that"Even though Sequoyah's program is not equal to Constructions, it does meet all the upper-tier requirements for traceability.", is not concurred with. The recommendation for a Quality Assurance survey to ensure the plant procedure implementation, is of little value, until' the procedures are revised to include verification of acceptable material; in addition to witnessing transfer of identification markings. These determinations are based upon the findings contained in this report (ECTG).

2.

A review of upper-tier criteria revealed the following:

a.

TVA Nuclear Quality Assurance Manual (NQAM), " PLANT MODIFICATION: AFTER LICENSING", Pa'rt II, Section 3.2, Revision 0, dated 06/24/86 and its'immediate predecessor document dated 03/31/86, and " REPAIRS AND REPLACEMENTS OF ASME SECTION XI COMPONENTS", Part II, Section 2.3, Revision 0, dated 06/20/86 and its predecessor documents dated back to 04/12/86, contain the requirement that modifications of the Critical Structures, Systems, and Components (CSSC) of TVA Nuclear Plants, including SQN, be controlled in accordance with the requirements of ASME Section XI, IWA-7000, which states in paragraph IWA-7210(a),

" Replacements shall meet the requirements of the edition of the Construction Code to which the original component or part was constructed.

However, " PLANT MODIFICATION: AFTER LICENSING", Part II, Section 2.3, dated 08/06/82 through 12/23/85, did not include the requirement to meet ASME Section XI.

TVA EMPLOYEE CONCERNS EEPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 28 0F 39 b.

TVA-NQAM, " IDENTIFICATION AND CONTROL OF MATERIALS, PARTS, AND COMPONENTS", Part I' Section 2.8, Revision 0, dated 06/18/86 wcs reviewed. This is the original issue of this document and it contains the requirement for programs and procedures for the identification and control of items in accordance with 10 CFR 50, Appendix B,. Criterion VIII.

c.

TVA-NQAM, " PROCUREMENT OF MATERIALS, COMPONENTS, SPARE PARTS, AND SERVICES", Part III, Section 2.1, Revision 0, dated 06/20/86 and its predecessor documents dated back to 11/24/82, incorrectly define the Code of Record for SQN as "* ANSI B31.7C-1971 addenda".

The preceding revisions of this document, dated 04/17/81 through 10/18/82, defined the Code of Record for SQN as

"*NSI B31.7 - 1971 addenda."

d.

TVA-NQAM, " RECEIPT INSPECTION, HANDLING AND STORAGE OF MATERIALS, COMPONENTS, AND SPARE PARTS", Part III, Section 2.2, Revision 0, dated 06/20/86 and its predecessor documents dated back to 04/18/79, require that all CSSC items be traceable only to their procurement document; however, they do not adequately establish the controls to ensure that all CSSC items received, are properly marked and identified, traceable to their CMTR, as per the Code of

Record, e.

TVA-NQAM, " ISSUING OF MATERIALS, COMPONENTS, AND SPARE PARTS", Part III, Section 2.3, Revision 0, dated 06/18/86 and its predecessor documents dated back to 05/12/80, contain requirements for issuing of CSSC items, the traceability of which is maintained only to the contract or procurement document.

l 3.

A review of site procedures for marking identification and l

verification of Nuclear Class Piping Components used for modification of CSSC items, at SQN, revealed the following:

a.

SNP ADMINISTRATIVE INSTRUCTION AI-19 (Part IV), " PLANT MODIFICATIONS: AFTER LICENSING" (AI-19), Revision 0, dated 03/11/83 through Revision 18, dated 07/07/86, contains requirements for the preparation and execution of a "workplan" to control modifications performed, at SQN.

Modifications falling under the jurisdiction of ASME Section XI (CSSC items) are required by AI-19, to be performed in accordance with the Code of Record.

AI-19, provides instructions for the engineer to obtain the Code of Record for piping systems from,

• UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT

k TVA EMPLOYEE l CONCERNS REPORT NUMBERi MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2

'PAGE 29 0F 39 4

paragraph 5.0 of General Construction Specification N2M-865. Field Fabrication, Assembly, Examination, and Tests for: Pipe and Duct System AI-19 also defines the Construction Code of Record as ANSI B31.7 (1969) and 1970 Addenda; however, it mistakenly omits the ANSI B31.7c-1971 addenda, paragraph 1-723, for material.

identification and certification.

The " MATERIAL TRACEABILITY SECTION" of AI-19 does not contain requirements for material to have marking identification traceable to its CMTR, as required by the

Code, b.

SNP ADMINISTRATIVE INSTRUCTION AI-11. " RECEIPT INSPECTION, NONCONFORMING ITEMS, QA LEVEL / DESCRIPTION CHANGES AND SUBSTITUTIONS" (AI-11), Revision 0, dated 04/22/76 through Revision 37, dated 06/20/86 was reviewed. This procedure, requires that material markings agree with'the TVA purchase contract or work order authorizing procurement, rather than being marked traceable to the CMTR, as required by the Code.

AI-11. Revision 33, dated 08/06/85 through Revision 37, dated 06/20/86, states, " Certification - A manufacturer's Mill Test Report (MTR) or CMIR is acceptable in lieu of a manufacturer's COC. A computer printed MTR or facsimile from the material manufacturer is acceptable es a CMTR whether signed or unsigned." This description for certification does not agree with the requirements of the Code of Record.

i AI-11. Revision 33, dated 08/06/85 through Revision 37, dated 06/20/86, Attachment 3, secti,on IV, provides the method for transfer of markings (heat and contract number) on 1" and i

larger QA Level I pressure retaining material used in T7A i

Class A, B, C, or D systems. The QA inspector indicates acceptance of the marking transfer by stamping the material next to the heat and contract number or marking QA and initialing.

SNP ADMINISTRATIVE INSTRUCTION AI-36, " STORAGE, HANDLING,

\\'

c.

AND SHIPPING OF QA MATERIAL" (AI-36), Revision 0, dated 12/30/83 through Revision 9 dated 03/07/86, establishes, for the power stores section, an adequate method of maintaining, prior to issue, positive identification between CSSC material and its " Quality Assurance Documentation"; providing,

" Quality Assurance Documentation" is defined as its CMTR.

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f TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 30 0F 39 d.

SNP-STANDARD PRACTICE - SQA45, " QUALITY CONTROL OF MATERIAL AND PARTS AND SERVICES" (SQA45), Revision 0, dated 01/05/80 through Revision 21. dated 06/?3/86 was reviewed.

Revision 0, dated 01/05/83 through Revisicn 17, dated 09/27/85 did not contain a specific section on material traceability.

Revision 18 dated 11/21/85 through Revision 21, dated 06/23/86 contained a specific section on material traceability; however, the material is required to be traceable only to the procurement document.

SNP MODIFICATIONS AND ADDITIONS INSTRUCTION, " CONTROL OF e.

WELD DOCUMENIATION AND HEAT TREATHENT" (M&AI-1),

Revision 0, dated 04/26/79 through Revision 11, dated 10/30/86, was reviewed.

Revision 0, dated 04/26/79 through Revision 2, dated 08/04/80, contained no provisions for material identification and/or traceability.

Revision 3, dated 03/26/82 through Revision 8, dated 11/09/84, Appendix B, paragraph 4.0, provided direction for completion of the weld data sheet as follows:

" Component Identification (Material Verification) shall be completed by the originator / planner previous to the weld being made. Identification shall consist of a brief description procurement document number /date and other information as known.

Note: When welding to existing components a description and notation ' existing' shall be satisfactory. If the inspector is not satisfied with the description provided, additional information may be added by the inspector."

Revision 9, dated 08/05/85 through Revision 11, dated 10/30/86 contain the following definition in paragraph 4.10;

" Material Traceability by Heat Number / Code:

Identification of piping and fittings by heat number / code for QA Level I pressure retaining materials used in TVA Class A, B,C, and D systems greater than 3/4-inch and bolting 1-inch and above."

TVA EMPLOYEE CONCERNS REPORT NUMBER: HC-40703-SQN SPECIAL PROGRAM REVISION NUMBER:

2 PAGE 31 0F 39 and in Appendix B, paragraph 4.0, provided expanded

(

direction for completion of the weld data sheet as follows; f

. For prefabricated items too small to put-material traceability number on (i.e., short section of small pipe in a fitting) the documentation from the weld data sheet will be used for the next weld in completing the material verification part of the data sheet."

The identification and traceability requirements described above do not provide adequate material description traceability to the CMTR, as required by the Code.

4.

Interviews conducted with persons performing inspections and/or verifications of material during modifications at SQN revealed the following:

Interviewee A The question was asked, "What do you do when you are requested to witness a heat number transfer?" Interviewee said, "If it has a heat number or contract number we witness its transfer.

If it doesn't have a contract number we only check to see if the heat number is on it and transfe'r it.

If the workplan does not have a 575 for the material. I will not transfer the number."

The question was asked, "Do you verify the class of material when it is installed, and please explain what you do when verifying material identification for a code weld?" Interviewee said, "I don't. check the class of material when it is installed and I don't think the 575 has it on it.

I look to see if the 575 agrees with what is written in the material section, this is written in, either by the craft or the engineer, if it is the same I sign the weld sheet. Sometimes if the heat number is not on the weld sheet I will put it on it.

I don't sign the weld sheet unless there is a 575 for the material. I am not responsible for verifying anything, I just sign the sheet."

f i

l

TVA EMPLOYCE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMDER: 2 PAGE 32 0F 39 Interviewee B The question was asked, "What do you do when you are requested to witness a heat number transfer?" Interviewee said, "It needs a heat number on the material. If it is in the werkplan there is a 575.

If the heat number is inked on the pipe, we would write the heat number on the section cut off. If the heat number is not on the 575 we transfer the number that is on-the pipe.

Until last year the procedure for transferring heat numbers was lacking, shakey. After the heat number is written on the other piece, I would initial it with a paint stick."

The question was asked, "Have you ever had an occcsion to transfer a heat number without a 575?" Interviewee said, "If it had a factory heat number I would not need a 575."

The question was asked, "What is required to perform material verification on Code piping systems, for a weld fit-up sheet?" Interviewee said, "I check the heat number I

on the pipe and then check the workplan and 575.

If there was a 575, I would list the material, a short description, plus the heat number on the sheet. If we were welding to an existing piece, I would log, existing piece.

If a heat number is used in the workplan a lot, I don't go back and check it each time, because I can tell that other inspectors have already checked this.*

The question was asked, "How do you verify that the correct class of material is installed?" Interviewee said, "I don't; that is the engineer's responsibility. He is directing the craft as what to do."

5.

Random Sample Review:

A review of material identified in two workplans (WP), one each for Unit 1 and Unit 2, for Class "A" Systems (Reactor Coolant System, 68) was performed to determine if material with the proper cortification was installed.

The reviewed workplans are as follows:

WP 10688, Unit 1 Power Operated Relief Valves, Pressurizer Piping.

WP 10478, Unit 2, Power Operated Relief Valves, Pressurizer Piping.

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 33 0F 39

.This review was limited to two WPs, due to the small number of modifications to TVA Class "A" pressure boundary material.

Review of WP 10688 This review revealed four documented welds, weld numbers F-25A, F-25B, F-29A and F-29B which were reviewed for their material identification.

Weld Data Sheet (WDS) for weld number F-25A identifies the installed material as 3" sch 160, SS pipo; however, the adjacent WDS for weld number F-25B identifies this material as 3" sch 160, pipe, SS, with the heat number /

code N7212. A field walkdown was performed by

' Modifications Unit personnel, to. determine the identification markings, if any, on the installed material. The walkdown revealed this material to be identified with the heat number / code N7212.

TVA-575 number D/C 0599, contained in the WP, identifies this materisl as 3" sch 160, SS pipe, Class I, and references shipping ticket number G234493, item number 5.

This shipping ticket revealed item number 5 to be 100-ft. of 3" sch 160 SS pipe having heat numbers / codes N3307 N7212, *N1046, N3207, *N1046, RD-739894, item number 1, (RD represents Request for Delivery).

RD-739b94, item number 1, is identified as 100-ft. of 3" sch 160 SS pipe Class I with heat numbers / codes N1046,!!3207, N3307, *N2438, and N7212. The CMTR filed with RD-739894 revealed this material to be Class C".

WDSs for weld nrmbers F-29A and adjacent weld number F-29B identify another piece of installed material as 3" sch 160, SS pipe with the heat number / code N7212.

Following the identical traceability path outlined in the preceding paragraph this material is also Class "C".

Note: This is a Class "A" system in which Class "C" material is installed.

WDSs for weld numbers F-25B and F-29B identify that 3" 2500# SS flanges, with the heat number / code CUS35302 for F-25B and *wCVS35102 for F-29B, are installed. The field walkdown revealed both the F-25B and F-29B flanges to be identified as, 3" Flange, S160, 2500, SA182, F-304, **CUS35102.

• NUMBERS UNDERLINED AB0VE TO EMPHASIZE INCONSISTENCIES OF NUMBEP.

LISTINGS ON THE IWO DOCUMENTS.

• • UNDERLINE ADDED TO DENOTE DISCREPANCY BETWEEN WDS AND ACTUALLY INSTALLED MATERIAL

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 34 0F 39 TVA-575 number D/C 1108, contained in the_WP, identifies these. flanges as, 3", 2500#, SA182. F304 or F316, Sch 160 bore, WN, ASME Section III, CL1, RF, and references RD-809043, Item 6. QA I.

RD-809043 - item number 6, is ideatified as 4 each, 3" Flanges, Stainless Steel, ASME SA-182. F304 or F316, Schedule 160 bore, ASME Section III, Class I, 2500#. The CMTR filed with this RD identifies these flanges-as 3" 2500#, R. F. weld neck, Sch 160, SA-182 F-304,Section III CL I, having the heat number CU3. NAVC0 Drawing Number A7263, Eavision 9, referenced in this workplan, specifies that Class "A" flanges used are to be A-182 F-316 stainless steel.

Note: The material specifications (F-304) of the installed flanges do not meet the material specifications (F-316) as stated on the NAVC0 drawing.

Note: The material identifications on the Weld Data Sheets are not, by themselves, sufficient to identify the installed material.

Review of WP 10478:

This review revealed there see no TVA-575s for the pipe or flanges. From the documentation, WDSs RDs, Shipping Ticket, etc., found in the WP, there is no way to identify the pipe and flanges installed. A field walkdown was performed by Modifications Unit personnel to determine what, if any, identification markings were on the pipe and flanges in the Class "A" installation. The walkdown revealed the material installed between weld number F-25A and F-25B to have'the following identification markings, HT-4801, 2RC-20A, F-35-20?, and serial number 256?.

Note: NAVC0 drawing A7548. Revision 9, and the weld map, included in the WP, depict these identification markings (2RC-20A and F-35) as possibly being assigned to other locations.

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TVA EMPLCYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 35 0F 39 The walkdown revealed the material installed between weld number F-30 and F-30E to have the following identification markings, HT-N3207. Shipping Ticket number G234493 (included in the WP) references RD-739894, item 1, for 3" pipe with the heat number N3207. The CMTR filed with this RD revealed this pipe to be Class "C".

The field walkdown revealed the two Class "A" flanges to have the following identification markings. 3" Flange,

• • SAC, 3W, 2500, E16, SA-132, *F-304, 34541, 1009, S160, Cl IA.

Traceability to the CMTRs for these flanges is not provided in the workplan.

Note: The material specifications (*F-304)

the installed flanges do not meet the material specifications (*F-316) as stated on the NAVC0 drawing.

Note: The material identification on the Weld Data Sheets, and the documentation contained in the WP are not sufficient to identify the installed material.

Note: The weld map contained in the WP shows a 6" spool piece by TVA with the heat number M241E, installed between weld numbers F-24C and F-24D.

The Construction HNSP revealed this heat number to be for 6" pipe, (*A312 T304), Class "A".

The NAVC0 drawing A7548. Revision 9. specifies this pipe to be, (*A376 TP316), Class "A".

A CMTR, obtained from the SQN QC Record Veult, for this heat number / code (M2415) revealed the Material Specification and Class to be as follows:

"HIGH TEMPERATURE SERVICE PIPE STAINLESS SMLS, CR0304/304H, EF, CD AW ASTH-A-312-77 ASME-SA-312 ASTM-A-376-76 ASME-SA-376 PICKLED ASME SECTION III 1977 EDITION THRU SUMMER ADDENDA 1977 CLASS 2.

• UNDERLINE ADDED TO DENOTE MATERIAL DIFFERENCES

• • UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2

1 PAGE 36 Of 39

-While this pipe was outside the scope of this WP review, verification of the acceptability of the installed material must be made.

CONCLUSIONS:

A.

Construction:

The perceived problem, as derived from the subject concerns, that there is a lack of credibility of the n.ethods used by Construction personnel (i.e., HNSP) for the verification of pecperly Certified Pressure Boundary Materials, at installation at SQN, is substantiated because of conditions determined to exist as a result of this evcluation.

The FSAR does not clearly define the app 1'icable Code of Record for Nuclear Class I, II, and III piping systems nor does it define the applicable Code of Record for the primary coolant loops and pressurizer surge line piping; however, SQN is committed by its Code of Record and 10 CFR 50, Appendix B, to the use of Nuclear Class Piping Components, the identification of which is maintcined The throughout their fabrication, erection, installation, and use.

site procedures, with the exception of the initial issue of SNP-CP-M7, did not provide adequate measures to ensure these commitments were met.

The individuals involved in the material identification verification process lacked an understanding of the significance of why, or the manner in which, Nuclear Class Piping Components should be identified. Although a variety of nethods were employed to verify the identification of the installef material, no consistent method Neat was developed, except the reliance upon the heat code / number.

codes / numbers at SQN were considered good; "if it was in the HNSP",

"been used before", or "if it existed on the material"; however, since heat codes / numbers are not unique to Nuclear Class, Pressure Class or material description, they cannot be relied upon for adequate material identification.

The Nuclear Class Piping Components, installed at SQN, do not comply with the requirements of the Code of Record and 10 CFR 50, Appendix B, for identification and control of these components during their fabrication, erection, installation, and use. This noncompliance has resulted in the receipt, storage, and installation of material that cannot be traced to the CMTR, attesting to its suitability for the Nuclear and/or Pressure Class in which it is installed.

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 37 0F 39 B.

Nuclear Power:

The perceived problem, as derived from the subject concerns, that there is a lack of credibility of the methods used by Nuclear Power personnel (i.e., TVA-575) for the verification of properly Certified Pressure Boundary Materials, at installation at SQN, is substantiated because of conditions determined to exist as a result of this evaluation.

The TVA-NQAM does not accurately define the applicable Code of Record; nor does it accurately define the requirements for the development of material identification and control procedures, necessary to ensure compliance with the applicable Code of Record and 10 CFR 50 Appendix B, Cr!terion VIII, for the repair and/or replacement of ASME Section XI Components, at SQN. ASME Seccion XI, IWA 7210(a) states,

" Replacements shall meet the requirements of the edition of the Construction Code to which the original component or part was constructed..."

The Site Procedures do not provide a positive documented traceability path between the material installed, or divided into two or more pieces, and its CMTR.

Inspectors interviewed, lack an understanding of the significance of why, or the manner in which, material identification verification at installation or material division into two or more pieces is performed and documented.

The modifications perfo med on ASME Section XI Components, at SQN, do not comply with the requirements of the Code of Record and 10 CFR 50, Appendix B, for identification and control of these components throughout their fabrication, erection, installation, and use. This noncompliance has resulted in the receipt, storage, and installation of material other than what was specified.

V.

ROOT CAUSE:

A.

Construction:

TVA personnel responsible for the adequacy and accuracy of site procedures, nor material manufacturers and suppliers, either were not cognizant of or did not have full appreciation of the Code of Record and 10 CFR 50, Appendix B, requirements, regarding i

identification and control of Nuclear Class Piping Components.

TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 38 0F 39 B.

Nuclear Power:

TVA personnel responsible for the adequacy and accuracy of site procedures, nor material manufacturers and suppliere, either are not cognizant of or do not have full appreciation of the Code of Record and 10 CFR 50, Appendix B, requirements, regarding identification and control of ASME Section XI Components.

VI.

CORRECTIVE ACTION:

A.

Construction:

To be provided by line organization.

Reference CATD No. 40703-SQN-01, Revision 1 B.

Nuclear Power:

To be provided by line organization.

Reference CATD No. 40703-SQN-01, Revision 1 VII. GENERIC APPLICABILITY:

A.

Construction:

Determined generic to the Sequoyah Nuclear Plant Material Identification Verification Program and Material Manufacturers' and Suppliers' Material Identification Marking Program for Nuclear Class Piping Components, i.e., Nuclear Class I, II, III, and/or TVA Class A, B, C/D.

The generic applicability of WBN-ECTG report number, MC 40703, remains valid for all other TVA Nuclear Plant Sites; however, it must be revised to include the Material Manufacturers' and Suppliers' Material Identification Marking Program for Nuclear Class Piping Components.

B.

Nuclear Power:

Determined generic to the Sequoyah Nuclear Plant Material Identification Verification Program for ASME Section XI Components and Material Manufacturers' and Suppliers' Material Identification Marking Program for Nuclear Class Piping Components, i.e., Nuclear Class I, II, III, and/or TVA Class A, E, C/D.

l TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40703-SQN l

SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 39 0F 39 i

The generic applicability of WBN-ECTG report number, MC 40703, remains valid for all other TVA Nuclear Plant Sites; however, it must be revised to include the Material Manufacturers' and Suppliers' Material Identification Marking Program for Nuclear Class Piping t

Compon.nts.

VIII. ATTACHMENTS Attachm?nt A - Concerns Printout (Identifies relationship to Nucleae Safety and Generic Applicability) 9 l

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PAGE A

s RUN TIME - 10 :33:44 RUN DATE - 10/31/86 REFERENCE SECTION 8 d

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CATEGORY - MC SUBCATEGORY - 407 E..

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.REFEREllCE

- ECPS131J-ECPS131C OFFICE OF flUCLEAR POWER n

FREQUENCY

- REQUEST EMPLOYEE C0tlCERt1 PROGRAM SYSTEM (ECPS)

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^m OtJP - ISSS - RHM LIST OF EMPLOYEE CollCERN INFORMATION I23 CATEGORY: MC ADEQUACY OF MATERIAL SUBCATEGORY: 407 PROCEDURAL CONTROL

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REPORT IONS HAVE BEEN DISCOVERED AFTER SYST T50059 EMS HAVE BEEN TURNED OVER T0 tiUCLEAR g

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MATERIAL INSPECTORS HERE NOT ALLOWED

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XX 027-X02 MC 407 SQfi NNNY TO VALIDATE HEAT NUMBERS OF STRUCTU 5

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a REPORT RAL STEEL RECEIVED ON SITE AS REQUIR T50078 ED BY PROCEDURE HEAT NO. 7438383 IS

'g AN EXAMPLE. SEQUOYAH.

y CONCERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY ftUMBER.

• PSR Codes:

SR--Nuclear Safety-Related SS--Nuclear Safety Significant NO--Not Nuclear Safety-Related e

s PAGE 2

RUN TIPE - 10:33 44 RUN DATE - 10/31/86 PEFERENCE SECTION i m

CATEGORY - MC Z

Q SUBCATEGORY - 407 p

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=

REFERENCE

- ECPS131J-ECPS131C TEllNESSEE VALLEY AUTHORITY g

TREQUENCY

- REQUEST OFFICE OF NUCLEAR POWER rr ONP - ISSS - RHM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS) n LIST OF EMPLOYEE CONCERN INFORMATION-o ^ o CRTEGORY: MC ADEQUACY OF MATERIAL SUBCATEGORY: 407 PROCEDURAL CONTROL S"23

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EX 023-001 MC 407 HBN YYYY SR NUCLEAR POWER SHOULD UPGRADE ITS HEA 5 O$3 n.

T50080 REPORT T CODE PROGRAM TO CONSTRUCTION STAND o

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THIS HOULD INCLUDE A COMPUTER 40sn PRINT OUT FOR THE TRACEABILITY OF A y.

2 49-LL HEAT CODE ITEMS. THE CURRENT PRO e

A E5 GRAM HAS TOO MANY HOLES IN IT.

NO F 2.

33H URTHER DETAILS AVAILABLE.

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IN 660-001 MC 407 HBN YYYH NO UNIT 51, MA, MODIFICATION, NUCLEAR P o

T50067 REPORT ONFR.

REQUIPED PAPERHORK TO SUBSTAN P

TI ATE TRACEABILITY OF CLASS C A!!D AB

'1 OVE PIPIllG COULD BE MADE MORE EFFICI ENT BY MAKING IT SIMPLER. THE COMPL EX SYSTEM NON IN USE ALLOWS FOR POSS 3

IEILITY OF ERROR AND DOES NOT PREVEN n

T THE ILLEGAL USE OF A HEAT NUMBER B M

2 Y THE CRAFT, I.E. CRAFT COULD BRING o

O A PIPE HITH NO HEAT NUMBER, PUT DN A E

KNOWN GOOD HEAT NUMBER AND THEN CAL o

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OF HEAT NUMBER.

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C0!!CERNS ARE GROUPED BY FIRST 3 DIGITS OF SUBCATEGORY llUMBER.

• PSR Codes:

5 SR--Nuclear Safety-Related SS--Nuclear Safety Significant a

NO--Not Nuclear Safety-Related S

9 m

l Tv A 64 cos e.sn top wp s os:

A02 870428 034 l' NITE 9 STATES GOVERNMENT

' Memorandum TENNESSEE VALLEY AUTHORITY W. R. Brown, Jr., Manager, Watts Bar Employee Concerns Task Group, TO ONP, Watts Bar S. A. White, Manager of Nuclear Power, LP 6N 38A-C FROM DATE

May 4, 1987 DATED HEAT COPE TRACEABILITY ISSUES AT SEQUOYAH NUCLEAR PLANT (SQN)

SUE.1ECT:

APRIL 21, 1987 As a result of the generic aspects of the Tennessee Valley Authority (TVA) employee concerns and N" clear Safety Review Staff (NSRS) the Employee issues identified at the Watts Bar Nuclear Plant (WBN),

Concerns Task Group (ECTG) investigated a number of lotential concerns related to the adequacy and reliability of TVA's heat code traceability program at SQN.

In response to the findings of the ECTG investigation, the Division of tiuclear Ent'Lneering (DNE) established a Heat Code Traceability Task Group (HCTTG) with responsibility to determine the extent of the findings and recommend a cortective action plan.

Due to an inability to reach agreement between the HCTTG and ECTG regarding the extent of required corrective action to resalve the concerns, this issue was referred to this office for resolution on 24, 1987. I asked my Deputy, C. H. Fox, to obtain the February arpropriate technical expertise in the industry to review and recommend disposition of the heat code issues. He contracted with two naticnally recognized experts in the areas of Quality Assurance and Code Material Application for nuclear power plant construction.

Richard B. Kelly, Vice President and Director of Quality Assurance, Stone & Webster Engineering Services, and Don F. Landers, President, Teledyne Engineering Services, provided an independent assessment of the heat code traceability issue at SQU as described in the attached correspondence and Executive Report both dated April 21, 1987.

RECEIVED 1 agree with the conclusions of their Executive Report which is attached fo your further processing in accordance with ECTG

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~, 'y procedures.

E44r. Cc. : r:: Ta9 Croun WEN

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!snt ven Re CHF:MLG in Attachment

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cc (Attachment):

oric RIMS, MR AU 72A-C H. L. Abercrombie, OUP, Sequoyah Mc C. H. Fox, Jr., LP 6N 38A-C

.l N. C. Kazanas, LP AU 454-C

-'s J. A. Kirkebo, W12 A12 C-K

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D. R. Nichols LP SN 302B-C WSJ fr D. W. Wilson, ONP, Sequoyah Lap JEn O

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