ML20214A530
| ML20214A530 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 04/21/1987 |
| From: | Fox C, Klelly R, Landers D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214A438 | List: |
| References | |
| NUDOCS 8705190487 | |
| Download: ML20214A530 (49) | |
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EXECUTIVE REPORT ON HEAT CODE TRACEABILITY ISSUES AT SEQUOYAH NUCLEAR PLANT ISSUED APRIL 21, 1987 Submitted By:
1 R B. Kelly
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D.F. Landers Recommended y:
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i C. H. Fox, Jr.
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TABLE OF CONTENTS' LIST OF TABLES ACRONYM LIST EXECUTIVE
SUMMARY
1.0 INTRODUCTION
2.0 EXTENT OF THF ISSUE 2.1 ECTG Investigation 2.2 HCTTG Scoping Evaluation 2.2.1 Licensing Requirements 2.2.2 Procedural Control Evaluation 2.2.3 Hardware and Documentation Assessments 2.2.4 Third-Party Assessments 2.3 Quality Assurance Investigation 2.4 Summary 3.0 EVALUATION OF THE ADEQUACY OF THE INSTALLED SKALL BORE PIPING 3.1 Evaluation of Manufacturing Processes 3.1.1 Manufacturing Practices 3.1.2 Prefabricated Piping Materials Control 3.1.3 Material Property Dstabase and Analysis 3.1.4 Thickness Measurements (Fittings) 3.2 Service Experience Summary 3.2.1 Inspection Programs 3.2.2 Operational History 3.3 Piping Stress Analysis and Margins 3.3.1 Stress Analysis Criteria 3.3.2 Stress Reduction Penalty 3.3.3 Actual Material Properties 3.3.4 Evaluation of Piping 3.3.5 Evaluation of Socket Weld Fittings 3.4 Analysis for Flaw Tolerance 4.0
SUMMARY
. CONCLUSIONS. AND CCMMITNENTS 4.1 Adequacy of Installed Piping 4.2 Corrective and Preventive Actions REFERENCES APPENDIX 1 - THE CORRECTIVE ACTION PLAN AND CORRECTIVE ACTION TRACKING DOCUMENTS i
t LIST.0F TABLES Table 1 - Materia.. Tensile Properties Table 2 - Number of Preservice Inspections Conducted at Sequoyah Nuclear Plant Table 3 - Number of Inservice Inspections Conducted at Sequoyah Nuclear Plant Table 4 - Material Allowable Stresses at Room Temperature 0
Table 5 - Material Allowable Stresses at 650 F Table 6 - Stress Value Summary 11
ACRONYM LIST Item Description First Location ANSI American National Standards Institute [Formerly, Executive Summary American Standards Association (ASA) and United States of America Standards Institute (USASI)]
APTECH APTECH Engineering Services. Inc.
3.2 ASME American Society of Mechanical Engineers 1.0 ASTM American Society for Testing and Materials 2.2.1 B&PV Boiler and Pressure Vessel 2.2.1 CAP Corrective Action Plan 1.0 CAQ Condition Adverse to Quality Executive Summary CAQR Condition Adverse to Quality Report 4.2 CAR Corrective Action Report 4.2 CATD Corcective Action Tracking Document 2.1 CMTR Certified Material Test Report 2.1 DNC Division of Nuclear Construction 1.0 DNE Division of Nuclear Engineering 1.0 PNQA Division of Nuclear Quality Assurance Executive Summary ECN Engineering Change Notice 4.2 ECTG Employee Concerns Task Group Executive Summary FSAR Final Safety Analysis Report 1.0 HCITG Heat Code Traceability Task Group Executive Summary IA Integral Attachments 3.2.1 IQT Indefinite Quantity Term 2.2.3 ISI Inservice Inspection 3.0 LER Licensee Event Report 3.2 LM Loose Material 2.2.3 NAVC0 National Valve and Manufacturing Company 2.2.2 NCR Nonconformance Report 3.1.2 NDE Nondestructive Examination Executive Summary NOI Notice of Indication 3.2 NRC Nuclear Regulatory Commission [Formerly, 2.3
' Atomic Energy Commission (AEC)]
NPS Nominal Pipe Size 2.0 NSRS Nuclear Safety Review Staff Executive Summary NSSS Nuclear Steam Supply System 2.2.1 PIR Problem Identificatinn Report 4.2 PSAR Preliminary Safety Analysis Report 2.2.1 PSI Preservice Inspection 3.0 PT Penetrant Testing 3.2.1 2.2.4 QA Quality Assurance 3.1.2 QC Quality Control RCS Reactor Coolant System 3.1.2 S
Allowable Stress 3.3.3 SAR Safety Analysis Report Executive Summary 4.2 SCR Significant Condition Report 111
Item Description First Location SQN Sequoyah Nuclear Plant Executive Sununary Su Tensile Strength, Ib/in2 3.3.3 Sy Yield Strength, lb/in2 3.3.3 TVA Tennessee Valley Authority Executive Sununary USAS United States of America Standard 2.2.1 UT Ultrasonic Testing 3.2.1 WBN Watts Bar Nuclear Plant Executive Sununary IV l
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i EXECUTIVE
SUMMARY
As a result of the generic aspects of Tennessee Valley Authority (TVA) employee concerns and Nuclear Safety Review Staff (NSRS) issues identified at the Watts Bar Nuclear plant (WBN), the Employee Concerns Task Group (ECTG) investigated a number of potential concerns related to the adequacy and reliability of TVA's heat code traceability program at Sequoyah Nuclear plant (SQN).
In response to the findings of the ECTG investigation, the Division of Nuclear Engineering (DNE) established a Heat Code Traceability Task Group (HCTTG). The HCTTG was assigned lead responsibility to determine the extent of the findings and recommend a corrective action plan.
The HCTTG effort identified the SQN design basis requirements for nuclear piping from the Safety Analysis Reports (SARs) commitments and historical data, evaluated the extent of SQN compliance to these requirements, reviewed the adequacy of SQN procedures, analyzed the effects of incorrect implementation of these procedures, and assessed the adequacy of the installed hardware. The HCTTG established that the central issue was limited to the use of TVA Class B small bore pipe and fittings in TVA Class A applications.
The HCTTG determined that the implementing organizations developed procedures and implemented an overall program intended to be consistent with B31.7 requirements and the applicable criteria of 10CFR50, Appendix B.
The HCTTG evaluated records and physically inspected over 1,000 installed items. This evaluation confirmed the adequacy of the material control program for material controlled by mark number. However, the program was not effective in preventing material from being installed in small bore portions of piping systems of a higher class than the class for which the material was qualified. Discrepancies were assessed by the HCTTG for significance and the required Conditions Adverse to Quality (CAQs) have been initiated to resolve these concerns. The Division of Nuclear Quality Assurance (DNQA) was given the responsibility of investigating and bounding the issue given the objective evidence of record. Hundreds of audit and inspection reports, including those reports generated by the ECTG and HCTTG, were reviewed.
DNQA also verified the existence of data that supports the analyses and positions of this report. The conclusions of the DNQA substantiate thoselof the HCTTG. Other organizations within TVA along with outside contractors investigated this issue and their conclusions also substantiate those of the HCTTG.
To assess the adequacy of the installed small bore piping, additional evaluations and analyses were performed. The HCTTG performed an evaluation of the manufacturing and fabrication practices and considered the SQN inspection programs and operational history in order to assess the significance of potential discrepancies, performed engineering evaluations of the piping stress levels, and demonstrated the inherent toughness of austenitic stainless steel.
In conclusion, these engineering evaluations demonstrate that the installed small bore pipe and fittings comply with American National Standards Institute (ANSI) B31.7c code requirements when the 40-percent allowable stress reduction factor is used in lieu of nondestructive examination (NDE). These evaluations demonstrate the acceptability of the installed piping.
1.0 INTRODUCTION
The heat code traceability issue was identified as a result of the ECTG investigation of an NSRS report and concerns expressed by employees. The ECTG investigation identified discrepancies related to the control, suitability, and verification of material installed at SQN and concluded that the material control program failed to meet the requirements of 10CFR50, Appendix B, and ANS1 B31.7.
The ECTG investigation identified deficiencies which resulted in recommended corrective actions focused on the following six items:
- The need for more specific definition of code commitments.
- The need for site procedures with detailed instructions to implement code requirements for the receipt, storage, installation, and inspection of nuclear class piping components.
- The need to train site personnel in implementation requirements to ensure that material identification is verified and documented.
- The need for TVA design drawings to show where and how piping classification changes, as stated in the Final Safety Analysis Report (FSAR), are effected.
- The need for the boundary between the primary coolant loops and their-
-branch lines to be clearly defined in the design drawings and the FSAR.
- The need to examine all Nuclear Class 1, 2, and 3 (TVA Class A, B, and C/D) pressure retaining piping components, verify and document their suitability for service in accordance with the applicable requirements, or replace them.
To determine the scope of the deficiencies and provide a corrective action plan, the Division of Nuclear Engineering (DNE) established the HCTTG. An investigation was initiated in September 1986 and included resources from the Division of Nuclear Engineering (DNE), the Division of Nuclear Construction (DNC), and DNQA.
i The HCTTG agreed with ECTG on the first five items concerning corrective action. The actions in place to achieve resolution on the first five items are described in Section 4.2, Corrective and Preventive Actions, and detailed in Appendix 1.
i The last item is the result of an inability to demonstrate that some j
material used in Class A systems was examined under B31.7 or American l
Society of Mechanical Engineers (ASME)Section III per the FSAR.
This material was traced by heat number, material type, size, and schedule, but not by code class.
Documented cases exist whe,re: l
- Class A and Class B piping material was manufactured from the same heat of material, possibly leading to their being interchanged.
- Material had been upgraded in the field without formal procedures to control the upgrade or its documentation.
- Material had been installed in systems of a higher class than the class for which the material was qualified.
The approach taken by HCTTG to demonstrate the adequacy of the installed piping at SQN involved the following steps:
- Delineation of the licensing commitments for base code requirements.
- Sample inspections to define and bound the issue.
- Evaluation of data collected by the ECTG, HCTTG, and others to assess the impact and define the corrective action plan (CAP).
- Evaluation of manufacturing and fabrication practices to assess the quality differences between code classes.
- Review of the piping stresses to determine margins.
- Analysis to determine flaw tolerance.
The inability of HCTTG and ECTG to reach agreement on the corrective action of the sixth item resulted in escalation of the heat code traceability issue to the Manager of Nuclear Power. A; a result, the Manager of Nuclear Power contracted with consultants Mr. R. B. Kelly, Stone and Webster Engineering Corporation, and Mr. D. F. Landers, Teledyne Engineering Services,.to provide an independent assessment of the heat code traceability issue at SQN, which led to the issunnce of this report.
In addition to reporting actions to resolve the first five items, this report establishes and resolves the central technical issue of the remaining unresolved concern, bounds the exten.t of the issue, and defines the corrective action to prevent recurrence.
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2.0 EXTENT OF THE ISSUE TVA initiated a variety of activities under the direction of the HCTTG.
These activities were intended to distinctly define and scope the findings identified by the ECTG effort. These activities established clear statements of the SQN commitments to material traceability requirements, evaluated the materials installed and the associated documentation, and performed a review of other historical quality data. The activities accomplished as part of this effort establish that the issue is limited to failure to locate objective evidence of or to install material which had the required NDE for Class A small bore piping.
In this context, small bore piping is defined as 2-inch and smaller nominal pipe size (NPS) austenitic stainless steel pipe and fittings.
2.1 ECTG Investigation ECTG evaluated material control at SQN by: reviewing upper tier criteria applicable to SQN (e.g., FSAR), employee concerns, and NSRS investigations related to material control; sampling installed piping material and reviewing its associated installation documentation; and interviewing available personnel involved in the material control process during construction and operation.
The evaluation concluded that there was a lack of credibility in the methods used by construction and operations personnel for the verification of properly certified pressure boundary materials installation. The evaluation further concluded that upper tier documents do not clearly define the applicable code of record for nuclear piping systems; the site procedures have not provided adequate measures to ensure that the commitments have always been met; and the implementing personnel lacked an understanding of the essential elements of material identification systems.
These ECTG conclusions show that, in some cases, the original nuclear class piping installations and subsequent modifications performed under ASME Section XI do not comply with the requirements of the code of record and 10CFR50, 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 some material that cannot be traced to the Certified Material Test Report (CMTR), thus preventing verification of its suitability for the code class in which it is installed.
The discrepancies identified by ECTG were issued as nine corrective action tracking documents (CATDs). A six-element CAP was proposed by ECTG to cover the nine CATDs. This CAP and the nine CATDs are contained in Appendix 1.
In addition, DNE has identified other types of discrepancies. These discrepancies are identified in the CAQ system and are being tracked to resolution.
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2.2 HCTTG Scoping Evaluation The scope of the investigation addressed all pressure boundary piping material. Due to the nature of the central technical issue, i.e.,
failure to install material which had the required NDE for Class A small bore piping, the sample documentation search and field verification effort was heavily biased toward Class A applications.
The HCTTG performed:
- 1. Historical assessment of commitments and requirements.
- 2. Evaluation of the chronology of changes in procedural controls during construction and operations.
- 3. Hardware and documentation assessments.
- 4. Third party historical assessment of commitments and requirements, evaluation of programs and practices, and validation of TVA's documentation and field verification samples.
2.2.1 Licensing Requirements
- a. Base Code Requirements Base code requirements for SQN were established in 1968 by the Westinghouse Nuclear Steam Supply System (NSSS) contract and the Preliminary Safety Analysis Report (PSAR). These original code requirements were United States of America Standard (USAS) B31.1.0-1967, plus the NDE requirements of B31.1, code cases N7, N9, and N10. The piping requirements were upgraded by commitment to post-1968 codes in keeping with state of the art technology. This resulted in the mixture of codes presented in SQN's FSAR as discussed below:
- b. Design The SQN piping design is in accordance with B31.1.0-1967 and includes features such as initial material selection and sizing based on pressure / temperature considerations, use of allowable stress values in the wall thickness calculations, and analysis of piping to verify acceptable design basis.
The analysis was augmented by the provisions of Class 2, NC-3600, ASME III, 1971 Edition, up to and including Winter 1972 Addenda, and specific provisions of later editions and addenda.
- c. Procurement of Materials Procurement includes specification of material by product form, documentation, certification, NDE applicable to intended use, and vendor fabrication, inspection and testing activities. FSAR commitments, as reflected by TVA specifications for the respective classes of construction, require SQN piping materials to comply with American Society for Testing and Materials (ASTM) specifications in USAS B31.1.0-1967 plus material requirements in B31.7-1969 in lieu of the base code requirements, i.e., B31.1 plus applicable nuclear code cases.
These code requirements governed SQN piping materials procured before April 2, 1973. After that date, B31.7 was replaced with Section III of the ASME Boiler and Pressure Vessel Code (B&PV).
In addition, 10CFR50, Appendix B, Criteria VII and VIII required control of purchased material, equipment, and services, and identification and control of material, parts, and components, respectively,
- d. Field Fabrication, Installation, Examination, Inspection and Testing TVA elected to upgrade the original PSAR commitment for these activities to the requirements of B31.7 in lieu of B31.1 and applicable nuclear code cases.
In addition, 10CFR50, Appendix B, Criteria VII and VIII were required.
2.2.2 Procedural Control Evaluation Procedures for construction and modification activities were written to implement the requirements of ANSI B31.7.
The evaluation concluded through a review of historical procedures and implementation documents that site procedures lacked the detail to control the different nuclear classes of material but provided control of material by the heat number or component mark number. Except for the loose material on systems fabricated by National Valve and Manufacturing Company (NAVCO),
material was controlled by mark number or other unique identifiers.
2.2.3 Hardware and Documentation Assessments The HCITG effort examined the installed hardware and associated documentation for a variety of piping groups.
Samples were selected that included large bore piping fabricated by others and installed by TVA and small bore piping supplied as bulk material to be fabricated and installed by TVA.
- a. Large Bore Piping Results Review of documentation for fabricated assemblies showed the vendors' material control program had been effective in tracing the documentation to each component of the fabrication, including documentation for the additional NDE invoked by the B31.7 code requirements.
The assessment of the large bore piping indicated that the site control process had been effective in controlling the installation of fabrications supplied to TVA as discussed in section 3.1.2.
Since large bore piping furnished as loose material was subjected to the same site control process as utilized for small bore piping, a 100-percent review was performed of large bore material modifications where such material was used. This review identified one piece of 6-inch pipe for which both Class A and Class B material from the same heat was available onsite. Therefore, the code class was indeterminate.
This 100-percent review of large bore modifications further limits the technical issue to small bore piping.
- b. Small Bore Piping Assessment The assessment of the small bore piping indicated that control had not always been adequate to prevent the installation of material in a system of a higher class than the class for which the material was qualified as discussed in section 3.1.
This was indicated from a review of material for 16 weld maps documenting Class A small bore piping installation. Material had been installed in Class A systems that was manufactured from the same heat of steel, some qualified as Class A and some as Class B.
During this review, a determination of the class instelled could not always be made by visually inspecting the material or its physical markings, nor from the installation documentation because the control had been maintained by heat number and physical description only.
- c. Additional Assessments Additional assessments were conducted by the HCITG to determine compliance with B31.7 traceability criteria.
The HCTTG reviewed a sample of 200 pieces from available material requisition forms (i.e., Form 575). The sample included 60 weld maps with 200 pieces and primarily included Class A systems. The 12 discrepancies found were a result of incorrect substitution of Class B material in small bore piping portions of Class A systems.
The ECTG evaluation raised an issue as to the adequacy of control of special flow restricting orifice inserts. Since flow restricting inserts with a special 3/8-inch inside diameter had been installed using heat number control for identification and externally identical reducing inserts had been installed with standard piping inside diameter that had the same heat number as the special inserts, neither visual examination nor installation documentation could confirm the locations of special flow restricting orifices.
The HCTTG evaluation examined all locations requiring special flow restrictors. All 231 locations were examined and eight had been installed with incorrect orifice size. The correct code class had been installed in 230 of the 231 locations.
The review of the material certifications identified that some small bore material had been upgraded by performing the additional NDE at the SQN jobsite.
Interviews with available personnel and the inconsistencies in the documentation of sample pieces indicate that control and documentation of the process was not totally effective.
Upgrading Practices Most of the materials for SQN construction and modifications were procured for a specific TVA piping class. This is the principal reason field NDE upgrades of piping components were infrequent. Based on this limited activity. TVA did not generate formal procedures covering the requirements for field NDE upgrading of piping components.
The result of the lack of formal procedures is that complete traceability and assurance of NDE upgrades of Class A piping systems are not always possible. The marks on components made by some manufacturers were obliterated during the fabrication process or removed in accordance with SQN procedures covering cleanup of piping.
Incomplete records of field NDE upgrades resulted due to lack of a consistent upgrade procedure covering SQN construction. No evidence could be found to indicate that the construction engineering organization approved substituting Class B material for Class A without requiring upgrading of the material.
Craft Substitutions One element of the HCTTG investigation was an evaluation of material requisition forms (i.e., Form 575). This evaluation was initiated to provide a means of assessing the effectiveness of the material control program in assuring that the correct piping components were issued to the crafts for original construction and to identify where substitutions were made.
The scope of this evaluation included 200 items randomly selected from 60 weld maps which mainly included Class A piping systems. Of the 200 items sampled, 12 discrepancies were found that resulted from incorrect substitution of small diameter Class B piping components in Class A systems.
No instances of incorrect material type or pipe schedule were observed. The timeframe when these discrepancies occurred was apparently coincidental with the discontinuation of small diameter piping components furnished by NAVC0 and identified by the loose material (LM) sheet number system and initiation of supply by others on direct or indefinite quantity term (IQT) contracts.
Summary These facts provide further confidence that the central issue of material traceability lies within small bore piping and involves only code class identity.
2.2.4 Third-Party Assessments An independent audit was performed by Bechtel to verify, by examination of objective evidence, compliance with the aspects of the TVA Quality Assurance (QA) program associated with materials during both the construction and operation phases. The audit concluded that there was general compliance with quality programs with some findings in the implementation.
The following tasks were conducted by Structural Integrity Associates under contract to TVA:
- 1. Survey the available documentation and industry personnel involved in the construction of othe'r light water reactors built during the same timeframe as SQN to determine the codes and standards invoked for design and construction of these plants and to summarize the methods used by other utilities for materials control and maintenance of traceability during plant construction.
Based on this survey, the design, materials control and traceability approaches utilized for SQN are considered typical of the industry for SQN-vintage plant.
- 2. Obtain a knowledgeable, independent interpretation of the traceability requirements of the various construction codes along with the historical background of traceability and marking requirements.
Their interpretation was that traceability of materials from completed assemblies back to specific heats or manufacturing lots is not required by any of the applicable canstruction codes, but is an item of major interest to the constructor or owner in the event that questions on the suitability of specific lots should arise later.
2.3 Ouality Assurance Investir>ation DNQA performed a review of 332 construction and 9 operations audits to determine to what extent piping material traceability problems had been previously identified. Only five of these audits identified deficiencies related to piping material tracsability and they were limited to small bore fittings. Nuclear Regulatory Commission (NRC) inspection reports issued from 1972 to present at SQN were also reviewed.
No significant problems were identified with TVA's piping material or traceability control program or its implementation by NRC. In addition, the ECTG, HCITG, and the Bechtel audit reports and supporting documentation were reviewed by DNQA for the same purpose.
Based on DNQA's rey!ew of QA audit reports, NRC inspection findings, and evaluations conducted by ECTG, HCTTG, and the Bechtel audit, there is adequate data to substantiate the following:
- TVA did not provide adequate controls in the area of Code Class verification to prevent Class 2 (TVA Class B) materials from being installed in Class 1 (TVA Class A) systems.
- The issue is limited to Code Class verification of small bore piping installed as loose material.
2.4 Summary The evaluations performed show that problems have existed in the control of small boro Class A materials at SQN. Commitments and requirements have not been well defined nor reflected in drawings.
This has contributed to problems in implementation by TVA. Site procedures did not contain sufficient detail to control all aspects of material identification and implementing personnel did not have a full understanding of the noed for or methods of identifying nuclear Class 1, 2, and 3 materials.
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r The evaluations also show that these problems are limited to material controlled by TVA with a process that controls material by heat number, material schedule, type, and grade without controlling the pipe class.
The piping material affected at SQN has been the TVA Class A small bore piping material. Material for large bore fabrications has been controlled by vendors' programs which controlled the essential elements including piping class, except for modifications utilizing loose materials which had been 100 percent evaluated.
The conclusion of this section is that the material control problem is limited to code class verification of TVA Class A small bore piping installed as loose material.
Evaluation by HCITG confirmed that some lower class material was installed in Class A applications. The only difference between Class A and lower class material is the extent to which NDE is used to ensure product quality.
3.0 EVALUATION OF THE ADEQUACY OF THE INSTALLED SMALL BORE PIPING This section assesses the adequacy of the plant piping when the Class A NDE cannot be verifled.
It examines the manufacturing and fabrication practices relative to material quality as well as the impact of upgrading and substitution of material on plant safety.
Inferences regarding the inherent quality of installed piping systems were made from Preservice Inspection (PSI), Inservice Inspection (ISI), and operational history data. Analysos were performed to demonstrate the inherent stress margins and flaw tolerances in pipe and fittings. The results of this evaluation verify the adequacy of the installed Class A systems small bore piping.
3.1 Evaluation of Manufacturing Processes 3.1.1 Manufacturint Practices One element of the investigation conducted by the HCTTG at SQN was an evaluation of the manufacturing processes used for small bore piping and materials for TVA Class A and other piping classes. This effort included contacting material nanufacturers to determine their methods at the time materials were being produced. The methods used for documenting the NDE required for qualification of Class A piping components and the methods used for marking heat (or heat codes) were also investigated.
l To the extent information could be obtained, this evaluation showed that small diameter pipe and forged or machined fittings produced by qualified nuclear materials manufacturers were manufactured using the same process regardless of their intended piping class application under B31.1 or 831.7.
Where a Class A fitting was required, any of these production fittings could have been upgraded by an additional NDE test as required by the appilcable code.
Several of the manufacturers contacted Indicated that the NDE acceptance rate for Class A upgrades exceeded 99 percent of the fittings examined. This level of acceptance indicates that the production methods used by these suppliers was capable of regularly producing high quality materials suitable for Class A appilcations at SQN.
In some cases, the actual Class A component was not marked to indicate that the NDE had been completed. However, completion of NDE was indicated on the CMTR, by certification attached to the CMTR and/or by tage on the lots of material that were inspected.
These methods of identification moet the requirements of D31.7. -
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3.1.7 Profabricated Pipinr. Materials Control The impact of the materials control systems imposed by the suppliers of prefabricated piping on the materials traceability issues at SQN were evaluated by the HCTTG.
prefabricated piping was furnished by both NAVC0 and Westinghouse and consisted of large diameter spool pieces.
For the original construction, Vostinghouse supplied the reactor coolant loop piping and pressurizer surge line. NAVC0 supplied the remainder of the large bore Class A piping fabrications and those Class B systems through which reactor coolant flows directly from the reactor coolant system (RCS) or the containment sump, the Class B piping of the main steam system, foedwater system, and auxiliary foedwater system, and the component cooling system.
Until the contract changed in 1977 NAVC0 supplied the small bore pipe in these systems.
i Fabrication of materials at the NAVC0 facility was done in accordance with the TVA-approved NAVC0 QA program and verifled by TVA's resident inspector, quality assurance audits and by i
l resident third-party inspectors.
The NSSS scope of supply piping was fabricated in accordance with the TVA-approved Westinghouse QA/ Quality Control (QC) procedures.
The effectiveness of the NAVC0 controls were evaluated by reviewing a sample of 58 large diameter piping prefabricated spools to verify correct location installation. There were no discrepancies found during this evaluation. A review of Nonconformance Reports (NCRs) pertaining to NAVC0 large diameter component fabrication did not reveal any evidence of problems with traceability to the appilcable CMTR or failure to perform the NDE required for Class A components.
l Thirty-five reactor coolant loop assemblies under the Westinghouse scope of supply were evaluated for correct location installation. These assemblies had been installed as depicted in the drawings.
The results of these investigations demonstrate that I
traceability problems do not exist in largo diameter fabricated systems.
3.1.3 Materint property Database and Analysis To provide an evaluation of actual material quality against minimum design requirements, a compliation of property data representing the scope of SQN small boro, stainless steel pipint. materials was developed. This compliation was accomplished through a review of CMTRs furnished by the manufacturers / suppliers and the creation of a database (reference 1) containing the following information! e
- Company Name (manufacturer and/or supplier)
- Quantity (if available)
- Material's description (site, type / form, schedule, grado)
- Class to which certified
- Heat code and/or heat number
- Ultimate tenslie strength, Ib/in2
- Yield strength at 0.2% offset, Ib/in2
- Porcent elongation
- Percent reduction in area The primary objective of the material database evaluation was to assess actual material strength proporties against the minimum requirements speelfled by the code.
Since minimum specified property values were utilized for design, the actual properties reflected by the database provide an indication of the true design margins in SQN small bore piping. Specifically, the CMTR material proporties can be assessed to reflect actual design allowable stresses.
To achieve this objective, the following procedure was implemented as documented by reference 2:
- 1. The database was sorted to group particular material specifications (e.g., SA182 F304).
- 2. The material specification groupings were extracted from the database as subsets.
- 3. Each specification subset was resorted by both material ultimate and yield strength test values.
- 4. Actual minimum yle1d and ultimate strength values for each speelfication were determined and are delineated in the following table:
TABLE 1 MATERIAL TENSILE PROPERTIES Material Yleid Stress (ksi) Ultimate Stress (ksi)
Epeelflention Roautred Actual Ecautrod Actunt SA182 F304 30.0 30.1 75.0 76.3 SA182 F316 30.0 32.8 75.0 77.1 CA312 TP304 30.0 38.4 75.0 85.8 SA376 TP304 30.0 34.8 75.0 81.4 SA312 TP316 30.0 73.2 75.0 88.7 SA376 TP316 30.0 38.6 75.0 82.3 l.
These values can be utilized to calculate actual minimum ylold, ultimate and allowable stress at operating temperatures (Section 3.3.3).
3.1.4 Thickness Monsuromonts (Fittings 1 Thickness measurements were made to quantify as-manufactured fitting thicknesses relativo to ANSI B16.11 and to ensure consistency with the previous work of Rodabaugh, et al.
(reference 3).
Wall thickness measurements were taken on sixty-four 1-to 2-inch NPS socket wold pipe fittings produced by various manufacturers. This included 900 elbows, 450 elbows, crossos, toes, couplings, and flanges.
The measuring process was consistent with the method for ultrasonic examination in Construction Specification G-29 Process Specification 5.M.1.1, Revision 6.
The data was collected by a Lovel II Inspector (reference 4).
The tabulation identifies only the minimum thicknesses found on the socket and base metal of the fittings checked.
Those measurements confirm that minimum wall thicknesses of SQN pipo fittings are significantly larger than specified minimums.
3.2 Service Experience Summary The significance of material traceability issues at SQN may be answered in part by a review of the plant operating history. A review of the operating history and the significance of the PSI and the ISI results was performed by APTECil Engineering Services. Inc. (APTECH)
(roference 5).
This review included development of a plan to determino the value of operational history records (e.g., operating time, Licensee Event Reports (LERs)], PSI, and ISI in providing an indication of adverse wold quality.
It was concluded in reference 5 that the operating history and examination results provided positive evidence of good weld and base material quality. The few ISI Notice of Indications (NOIs) indicated that the wolds and matarlais compiled with code requirements and that PSI and ISI data were a useful quality indicator. These data were reviewed to determino the applicability of SQN wold review to the heat code traceability issue.
The basic approach is summarized in reference 5.
The ISI and PSI results, although they represent weld examinations, were considered to be applicable since the adjacent piping materials would also be evaluated by tho inspection process.
Details are developed below.
3.2.1 Inspoetion Pror.rnms Diseropancies found during PSI and ISI evaluations are summarized on NOIs.
It is not possible to develop an ISI program that will discriminate service induced flaws from other types. On this basis, the NOI system has boon used to give an indicator of original material and component quality.
The review of PSI records from SQN included shop-produced welds, field welds and integral attachments (IA) betwoon hangers and pipe. The scope of the preservice field wold (i.e., wolds made by TVA) inspection is summarized in the following table.
TABLE 2 NUMBER OF PRESERVICE INSPECTIONS CONDUCTED AT SEQUOYAH NUCLEAR PLANT Unit 1 Unit 2 Flold Piping Wolds 473 484 Fleid Socket Wolds 20 124 Integral Attachments 25 14 In the PSI, only one NOI was reported for all categories of field welds that reflected a weld defect. No NOIs were reported for unacceptable material quality. About 10 percent of the welds were inspected by penetrant testing (PT) methods and the remainder by ultrasonic testing (UT) methods.
No NOIs related to original material quality were reported after PSI of a significant fraction of the field weld population. These results provide an indication that acceptable piping components were installed.
Although the ISI program is directed toward detection of wolding related defects, the inspection results provide a measure of the original piping component quality as discussed above. A summary of the number of welds involved in the ISI program is shown in the following table.
TABLE 3 NUMBER OF INSERVICE INSPECTIONS CONDUCTED AT SEQUOYAH NUCLEAR PLANT ISI 10 Year 40 Year Completed (Tota 11 (Total)
Unit 1 Class 1 Large Dore 45 60 239 Small Bore 129 180 721 Class 2 Large Boro 100 26 106 Unit 2 Class 1 Large Bore 24 56 225 Small Bore 75 175 701 Class 2 Large Boro 16 30 121 389 527 2113 None of the NOIs resulting from ISI relate to defects in the original piping components even after examination of a significant number of the 40-year total. This provides additional evidence that the installed piping component materials are acceptable and assurance that the accelerated ISI program will validate material quality.
Current plans require an accelerated ISI program where all of the wolds designated for the 10-year total will be completed after the next two fuoi cycles.
3.2.2 Operational History A further indication of installed material quality is provided by the SQN operational history.
Each unit has boen operated over 20,000 hours0 days <br />0 hours <br />0 weeks <br />0 months <br />. Once a plant is in operation, failures in safety-related systems are reported to the NRC as LERs.
A review of the SQN LER file with respect to piping component problems determined that none related to material quality were recorded. -
3.3 fi_p h Stress Analysis and Martins l
The safety margins addressed in this section indicate thatt The actual analyzed stress levels are much lower than the design allowables for the majority of the piping.
The actual pipe strength excoeds the codo-specified minimums used for design purposes.
The actual strength of the socket wold fittings exceed the minimum requirements for manufacture.
3.3.1 Stress Analysis Critoria The service loading conditions considered for the analysis of piping are normal, upset, omorgency, and faulted.
Since B31.1 did not address allowables for all conditions Subsection NC-3000 of the Wintor 1972 Addenda of ASME Section III was used to define the stress limits. The TVA Class A piping stresses were calculated using either the B31.1 or the Class 2 stress equations. References 6 and 7 provido a description of the loading combinations and associated allowables.
3.3.2 Stross Reduction Penalty ANSI D31.7c-1971, paragraph 1-724, providos for reduction in allowable stress in llou of NDE. The conditions described in B31.7 for which the 40-percent stress reduction is imposed are applicable to the identical piping conditions we are addressing.
3.3.3 Actual Material Properties To project the actual material strength, the allowablo stress was calculated using the actual tons!!o and yield strengths given in section 3.1.3.
The projected material allowable stress (S) was calculated using the lessor oft (1) 1/4 of the tensile strent.th (Su) at room temperaturo (2) 5/8 of the yield strength (Sy) at room temperature (3) 1/4 of the tonslie strength at temperature (4) 9/10 of the ylold strength at temperature Where Su and Sy at room temperature are the actual values given in Section 3.1.3.
Su and Sy at temperaturo are calculated using the following equations:
Su O Temp Su 0 Temp Su 9 Room Tomp Actua; Su 9 Room Temp ASME Code Sy 0 Temp Sy 0 Temp
=
Sy 0 Room Tomp Actual Sy 0 Room Temp ASME Codo The following tables provide a summary of the results; the calculations are documented in reference 8.
TABLE 4 MATERIAL ALLOWABLE STRESSES AT ROOM TEMPERATURE Code Allowablo Actual Allowablo Material S 0 Hoom Tempt S 0 Room Temp,
% Increase (ksi)
(ksi) t SA182 F304 18.8 18.8 0.0 SA182 F316 18.8 19.3 2.7 SA312 TP304 18.8 21.5 14.4 SA312 TP316 18.8 22.2 18.1 SA376 TP304 18.8 20.4 8.5 SA376 TP316 18.8 20.6 9.6 TABLE 5 MATERIAL ALLOWADLE STRESSES AT 650'F Code Allowablo Actual Allowable Material
__C 0 650'F S 0 650'F
% Incranse (ksi)
(ksi)
SA182 F304 15.9 16.2 1.9 UA182 F316 16.7 18.2 8.9 SA312 TP304 15.9 18.2 14.5 SA312 TP316 16.7 21.2 27.0 SA376 TP304 15.9 17.2 8.2 SA376 TP316 16.7 19.7 18.0 3.3.4 fa duation_of Piglaf.
1ho current, as-analyzed stress values of TVA Class A small boro piping have boon reviewed.
The nodal points which escoeded 60 porcent of olther code allowable stress or actual allowable stress were tabulated. There were approximately 2600 nodal points used for the small boro piping analysis of TVA Class A piping.
Two and one-half percent of the nodel points had stress ratios which woro not capable of meetint. the 40 percent
-18
reduction on the code allowable stress. Similarly, 1.8 percent of the nodal points had stress ratios which were not capable of mooting the 40-percent reduction on the actual allowable stress. The stress ratio is defined as the ratio of the analytically calculated stress divided by the allowable stress.
The largest ratio at each nodal point was tabulated; the following table shows the distribution of stresses as a function of stress ratto. The calculations are documented in reference 9.
TABLE 6 STRESS VALUE
SUMMARY
% of Nodal Points Escoedl_nt Stross_ Ratio Based on Code Based on Actual stress Ratio Allowables_
Allowables __
0.6 2.5 1.8 0.7 1.6 1.1 0.8 0.7 0.5 0.9 0.5 0.1 A significant point is that the weld and heat-affected zones were inspected (ISI and PSI) for flaws after welding.
Thus, the concern does not exist at the weld or heat-affected zones.
Ninety-nine percent of the nodal points which have stress ratios greater than 0.6 (based on actual allowable stresses) are located at weld points.
i 3.3.5 Evaluation of_ Socket Weld FittlnLg In addition, socket weld fittings have been evaluated using the actual wall thickness measurements (Section 3.1.4) and the actual minimum yloid and ultimate allowables (Section 3.3.3).
The minimum wall thickness requirements for socket weld fittings are given in ANSI B16.11. The actual fittings have wall thicknesses that escoed the minimum. The excess wall thickness of the actual fitting was used to determine the amount of additional strength available.
Usinr. the additional thickness of the actual fittings and actual allowable stresses, the socket weld fittings were found to moet the 40-percent reduction in the allowable stress requirements of B31.7.
The calculations are documented in reference 10.. - -.-
3.4 Analysis for flaw Tolerance The pipes encoeding the stress ratio of 0.6 were assessed for the possibility for flaw propagation. A fracture mechanics analysis (reference 11) consistent with ASME Section XI was performed to assess the effect of postulated material flaws. The calculations indicate that such flaws will not lead to pipe rupture while maintaining ASME Codo safety margins. This analysis demonstratos the excellent flaw tolerance of austen! tic stainless stool in small bore pipinr. configurations.
l l
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4.0
SUMMARY
. CONCt.USIONSa AND_COMMlIMENTS 4.1 Adocluncy of Installed PipLng Section 3.0 summarizos the results of analyses that substantiate the adoquacy of the installed small bore piping material at SQN.
The pSAR established the base codo requirements for SQN piping as B31.1 plus the applicablo nuclear code casos. The FSAR reflects l
programmatic upgrados which committed SQN to the requirements of 831.7 which was used to procuro material from quallflod vendors.
A comparison was performed of materials procured for SQN to the requirements of B31.1 and the applicable D31.1 code case N7 for small bore piping.
It was concluded that none of the small bore material would require additional NDE for Class A application. Class 1 piping, matorial, 1-irch NPS and loss, procured to today's ASME D&pV Code Section I!! requirements would not require additional NDE. SQN does not have a single " code of record" but in fact has applied a misture of codes for design, procuroment, and installation.
A reverification of installed materials was conducted.
It was concluded that the control program did not prevent lower class material from being installed in Class A applicatlor.s in small bore piping.
In addition, B31.7, Class I, allows material which is 2-inch NPS and less to be used without additional NDE if a 40-percent reduction in allowable stresses can be taken. Section 3.3 demonstrated that by using actual wall thicknessos and actual stress allowables, 98.2 percent of the small boro piping installed at SQN la l
adequate using the 40-percent stress penalty specified in 831.7.
For the remaindor, section 3.4 demonstrates the inhoront toughness of small bore stainless stool austenitic piping.
A review of manufacturing practicos revealed that material from quellflod vendors woro made to the same high quality level regardless of their intended piping class under ANSI B31.1 or 831.7. The only difference betwoon Class A and lower class materials was the completion and reporting of the required NDE.
Several manufacturers of SQN material were contacted and indicated that the NDE acceptance rate for Class A upgrados encoedad 99 percent of the fittings examined.
The service esperience, includinr. ISI/pS! records, were evaluated and no instances of adverso conditions were found. Althour,h the ICI pror, ram le primarily almed at inspection of the wolds, the cruelal heat affected zone and some portion of the beso material is osamined.
Inspectors are trained to look for other obylous problems. SQN's commitment to an accelerated ICI pror, ram because of the welding issue will provido additional confidence in small boro piping inter,rity. '
In summary, the material control problem is limited to small bore piping. This report demonstrates that there is no technleal difference in Class A and Class B piping components.
In conclusion, the engineering evaluations demonstrate that the installed small bore pipe and fittings comply with ANSI B31.7c code requirements when the 40 percent allowable stress reduction factor is used in llou of NDE.
Thus, plant safety is assured.
4.2 Co,rrectiva and Proventive Actions When ECTO first notified Sequoyah management that matarla1 traceability concerns had been confirmed, corrective action was initiated. A stop work order was issued by the Site Director on October 6, 1986, and placed additional control on work instruction package approval and installation verification. The prowork QA revlow was modit',ad to ensure that: material allocated for the work is proper for the installation including code classi proper QC terification at points of installation of the unique number assigned to the material is speelfledt and requirements to witness any necessary identification transfer is specified.
Prior to implementation of each work package, the stop work order is lifted based on an adequacy review by the site quality manager and site director. To accomplish long-term preventive action, a site procedure review effort was initiated.
Section 1.0 listed the defielencies identitled by the ECTO investigation. The following corrective actions address each deficiency!
The need for more speelfte definition of code commitments.
This is being tracked by 1:CTO corrective action tracking documents 40703-SQN-01-R2, and 4070:1-SQN-03-R0 while implementation is being i
ach.eved by Problem Identification Report (PIR) SQNNED8638.
The need for site procedures with detailed instructions to implement code requirements for the receipt, storage, installation, and inspection of nuclear class piping components.
This is being tracked by ECTO CATD 40703-SQN-04-R0 while implementation is being achieved by Corrective Action Report (CAR)
~22
The nood to train alte personnel in implementation requirements to ensure that verification of material identification is performed and documented.
This is being tracked by ECTG CATD 40703-SQN-05-RO while implementation is being achieved by CAR-86-064.
The need for TVA design drawint.s to show where and how piping class changes, as stated in the FSAR, are effected.
This !s being tracked by ECTO CATD 40703-SQN-08-R0 and implomonted by Significant Condition Report (SCR) SCRMEB8614-R1 and Engineering Change Notico (ECN) 1.6784.
The nood for the boundary betwoon the primary coolant loops and thole branch linos to be clearly defined in the design drawings and the FSAR.
This is being tracked by ECTG CATD 40703-SQN-09-R0 while implementation is being accomplished by PIR SQNMEB8793.
The need to examine all Nuclear Class 1, 2, and 3 (TVA Class A, B, C/D) pressure-rotalning piping components, verify and document their suitability for service in accordance with the appilcable requirements, or replace them.
This !s being tracked by ECTOs CATD 40703-SQN-02-RO, CATD 40703-SQN-06-RO, and CATD 40703-SQN-07-R0 while implementation is being addressed by Condition Averse to Quality Report (CAQR) SQP870627 and this report.
The evaluation of the effects of the material control inadequacles at SQN has produced additional actions to correct identified deficiencies and to prevent recurrence. These actions are being implemented by the TVA Condition Adverse to Quality Pror, ram, and the analyses and evaluations presented in this report.
-23
REFERENCES 1.
Calculation, RIMS B45 870415 803.
2.
Calculation, RIMS B41 870416 016,
~
3.
Rodebaugh, E. C. and Moore, S. E.. " Stress Indices for ANSI Standard 816.11 Socket-Welding Fittings " ORNL-TM-4929 August 1975.
4.
Calculation, B29 870409 001.
5.
Orover, J. L. and Cepener, E.
L.,
" Evaluation of Quality of Welds at Sequoyah Nuclear Plant " APTECH Report Number AES 8511598AQ-1, January 1986.
6.
Design Criterla, SQN-DC-V-13.3.
7.
Design Criteria, SQN-DC-V-13.3.1.
8.
Calculation, RIMS B41 870420 009.
9.
Calculation, RIMS B41 870422 004.
- 10. Calculation, RIMS B41 870420 010.
- 11. Calculation, RIMS B41 870418 001.
24
h APPENDIX 1 THE CORRECTIVE ACTION PLAN AND CORRECTIVE ACTION TRACKING DOCUMENTS Corrective Action Plan (CAP)
Report MC-40703-SQN The following corrective actions have been implemented to correct the existing problems identified by the ECTG Report and to preclude their recurrence:
1.
PIRSQNNES8638 will ensure the clear definition of the applicable code edition and addenda of ANSI B31.7 used in the fabrication, erection, installation, and use of Nuclear Class Piping Components, in the upper-tier documents.
(CATD No. 40703-SQN-01-R2 and CATD No.
40703-SQN-03-RO) 2.
CAQR SQP870627 will ensure that all Nuclear Class I, II, and III (TVA Class A, B, and C/D) pressure-retaining piping components will be examined and their suitability for use verified and documented in accordance with the applicable requirements, or replaced.
(CATD No. 40703-SQN-02-RO, CATD No. 40703-SQN-06-RO, and CATD No. 40703-SQN-07-R0) 1 3.
CAR-86-064 will ensure that site procedures contain the necessary detailed instruction to provide for the receipt, storage, and installation of Nuclear Class Piping Components in compliance with the applicable code requirements.
(CATD No. 40703-SQN-04-RO) 4.
CAR-84-064 will ensure that inspectors will receive the required training to ensure that Nuclear Class Piping Component material identification verification is performed and documented, in accordance with the applicable code requirements, throughout their receipt, storage, and installation at SQN.
(CATD No. 40703-SQN-05-RO) 5.
SCRSQNMEB8614 R1 and ECN L6784 will ensure that TVA design drawings contain clear and consistent identification of where (locatlan) and how (e.g., double automatic valve, specially bored fitting) the piping classification changes, as stated in the FSAR, are effected.
(CATD No.
40703-SQN-08-RO) 6.
PIRSQNMEB8793 will ensure that either the FSAR or the design drawing contain a clear definition of the boundary between the primary coolant loops and their branch lines.
(CATD No. 40103-SQN-09-RO)
ECO C.3 Attaclament A fase 1 of 1 Retision 2 RCSP Corrective Action Tracking Document (CATD)
INITIATION Applicable ECSP Report No:
NC-a0703-808 1.
Immediate Corrective Actjpn Required: k Yes D No
- 2.
- Stop Work Recommended: A Yes O No 3.
CATD No. 40703-SON t 2 4.
INITIATION DATE 1/04/87
- 5.
RESPONSIBLE ORGANIZATI N:
SON Site 6.
PROBLEM DESCRIPTION:
QR D NQR
-The FSAf and associated tiocuments-do not clearir define the applicable
-~
code editions and addends of ANSI B31.7 used is the fabrication.
erection. installation, and use of Nuclear Class Piping Components.
A
>>l 11 sO ATTACKEENTS a
7.
PREPARED BT: NAMENX'AWJ) J/m(, Ud)hMbAT8:
/-f-89 8.
CONCURRENCE:
CEG-H W M d% d44, C 7 DATE: ' V0/J7 9.
APPROVAL: ICTG PR00kAN'MGR.
W DATE:
t/sf#1 CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
son,e*vkna enn* -
O ATTACHMENTS 11.
PROPOSED BY:
DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
DATE:
DATE:
DATE:
SCTG PROGRAM MGR:
DATE:
VitIFICATION AND CI4SE00T
- 13. Approved corrective actions have been verified as satisfactor!!y implemented.
SIGNATURE TITLS DATE
- II:r:ediate Stop Work Orders should be issued for the follotting:
Procurement, receipt. issue and installation activities pertaining to Nuclear Class I, II, and III (TVA Class A, 8, and C/D) or ASNE Section II pressure retaining piping components.
CATD No. 40703-SQN-01-R2 Corrective Action 10.
Proposed Corrective Action Plan: The FSAR will be clarified. A SQN engineering requirements specification will be written under the master Other specification program to provide a baseline for the requirements.
affected lower tier documents such as N76A10, N2M-865, etc., will be revised as appropriate to clearly reflect the applicable code i
requirements.
Problem Identification Report No. SQNNEB8638 has been issued to track this to completion.
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,,,,,--,----,---r
,,,---~n,..-,-
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., - - - -,,_,,.-,,,-~.,.,
l ECTU C.3 Attcehment A Page 1 of 1 tarision 2 RCSP Corrective Action Trackina Document (CATD)
INITIATION ADolicable ICSP Report No:
MC-40703-50N 1.
Immediate Corrective Ac n Required: kYes D Wo
- 2.
- Stop Work Recommended:
Yes O No 3.
CATD No. 40703-SON 0 4.
INITIATION DATR 1/04/87
~~5.
RESPONSIBLE ORGANI2ATJ,0N:
SON Site 6r PROBLER-DESCRIPTIONrp QR 0 NQR-
~
'" - ' Sbme Nuer._e_ar* Class' Pipint'ConDonents installed at SON de-not comply with the requirements of ANSI B31.7 or 10 CFR 50. Appendir 8.
Criterion VIII for their identification and control during fabrica-tion, erection. Installation, and use. Tbis noncompliance has resulted in the receipt, stor ste and installation of material that cannot be traced to the CNTR. sttestint to its suitability for the Nuclear and/or Pressure C1sss in which it is installed.
A Ad 9.
s
.O AITACKNENTS 7.
PREPARED BY:
NAME/hr#eM f/d) fg4//#1/ M ATE:
/-5 -M
/ DATE:
' /#//f 8.
CONCURRENCE:
CEG-H 'WW(.WAL. ~
9.
APPROVAL: ICTG PROGElk AGE.
(ZEWife v*.
DATE:
s'/f//'/
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
see attached sheet.
O ATTACHNinT5 11.
PROPOSED BY:
DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
_ DATE:
SRP:
DATE:
l DATE:
DATE:
DATE:
RCTG PROGRAM NGR:
DATE:
VERIFICATION AND CLOS 50UT Approved corrective actions have been verified as satisfactorily 13.
implemented.
SIGNATURE TITLE DATR
- I::enediate Stop Work Orders should be issued for the following:
Procurement, receipt, issue and installation activities pertaining to II, and III (TVA Class A. B, and C/D) or ASME Section Nuclear Class I,ining piping components.
t II pressure reta l
CATD No. 40703-SQN-02-RO Corrective Action 10.
Proposed Corrective Action Plan:
Large bore piping will be assessed and acceptability for service demonstrated or replaced.
For small bore piping, 2-inch NPS and less, an analysis will be performed to determine whether or not the ANSI B31.7 40 percent stress reduction can be met for Class A applications.
If the 40 percent stress reduction i
cannot be applied and compliante to B31.7 shown, then acceptability for service will be demonstrated or the material replaced.
Condition Adverse to Quality Report (CAQR) No. SQP 870627 has been issued to track this to completion.
l 4
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- d P!: 01 40 50'10 aces
~
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ECTG C.3 Attachment A Pge l of 1 Revision 2 ECSP Corrective J
Action Tractina Document (CATD)
INITIATION Applicable ECSP Report No:
NC-40703-80N 1
Immediate Corrective Ac i n Required: k Yes D No 1.
- 2.
- Stop Work Recosamended:
Yes a No
" 3.
CATD No. 40703-80N t 0 4.
INITIATION DATE 1/04/87 5.
RESPONSIBLE ORGANIZATION: SON Site 6.
PROBLIN DESCRIPTION: % QR O NQR The TVA-NOAM does not accurately define the applicable code edition and addends of ANSI B31.7. nor does it provide for the preparation of__
site procedures to insure compliance with the code requirements for material identification and control durina the receipt, storaae, and__
installation activities of the repair and/or replacement of ASM8 Section XI Pipina Components, at SQN.
M 4A o
~ O ATfACNNENTS 7 //d /hL)wldLJAATE:
/ tf '80 7.
PREPARED BY:
MANfgd/Ea -W 8.
CONCURRENCE:
CEG-H 'WW.MA
' / DATE:
//$/f7 9.
APPROVAL:
ECTG PROGl@!!(G1.
M4 DATE:
/A-//P CORRECTIVE ACT R See attached sheet.
10.
PROPOSED CORRICTIVE ACTION PLAN:
O ATTACIGUUG5 DATE:
11.
PROPOSED BT:
DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-N:
DATE:
SRP:
DATE:
DATE:
_ DATE:
DATE:
ECTG PROGRAN NGE:
VERIFICATION AND CLOSE0UT Approved corrective actions have been verified as satisfactorily 13.
implemented.
TITLE DATE SIGNATURE
- Irenediate Stop Wort orders should be issued for the following:
Procurement, receipt, issue and installation activities pertaining to Nuclear Cisss I, II, and III (TVA Class A, 8, and C/D) or ASME Section II pressure retaining piping components.
i
CATD No. 40703-SQN-03-R0 Corrective Action 10.
Proposed Corrective Action Plan: The NQAM will be reviewed to determine if references to applicable code edition and addenda are accurate.
It shall not define the code editions and addenda, this will be done in the engineering requirements specifications as.part of the master specification program.
Further, the NQAM will be reviewed to assure it requires SQN to issue procedures to comply with code requirements for material identification and control during receipt, storage, and installation activities of the repair and/or replacement of ASME Section XI Piping Components at SQN.
Problem Identification Report (PIR) No. SQNNEB8638 has been issued to track this to completion.
(
i l.
r.
1 l
i l'
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8
- d 51:81 48/50<!0 ws ECTG C.3 Attachment A Page 1 of 1 Revistorr 2 ECSP Corrective Action Tractier Document (CATD)
NC-40703-30N INITIATION Applicable ICSP Report No:
1.
Immediate Corrective Action Required: k Yes O No
- 2.
- Stop Work Recosusended: g Yes O Ncf
~ ~3.
CATD No. 40703-SQN R 0 4.
INITIATION DATE 1/04/87
- $ r~ "1ESPONSIBLE-0RGANIZATION:~ SCN 5ito
_ _ XQR O NQR 6.
PROBLEN DESCRIPTION:
The Site Procedures do not provide a documented traceability path between the Nuclear Class Piping Components installed and their CNTR.
4 A >>
n 20 ATTACHMENTS 7.
PREPARED BY: NAME/k(fbasidh [d//hMw)3DATE:
/-f TO 8.
CONCURRENCE: CEG-Hf WMfh r /DATE:
/M/87 l
9.
APPROVAL: ECTG PROGRAK MGk. 7) N DATE:
17f/#9 i
i l
CORRECTIVE ACTION t
See attached sheet.
10.
PROPOSED CORRECTIVE ACTION PLAN:
O ATTACHNF.KTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
DATE:
l l
DATE:
DATE:
ECTG PROGRAM MGR:
DATE:
VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DAT$
- Immediate Stop Work Orders should be issued for the following:
l Procurement, receipt, issue and installation activities pertaining to Nuclear Class I, II, and III (TVA Class A, B. and C/D) or ASME Section II pressure retaining piping components.
CATD No. 40703-SQN-04-R0 Corrective Action 10.
Proposed Corrective Action Plan: The following plant implementing procedures require revision to provide additional verifications to ensure unquestionable control and traceability of the material. The revisions will be made to the procedures generally as shown below:
1.
SQA162 - Revise to include changes made to DPM N76A10 for clarifying when Cf1TRs are required and to require traceability between the CMTR and contract line item.
2.
AI Revise to require verification of traceability between CMTR and related contract line item in addition to contract number and heat r. umber and to include QC verification of any additional markings.
3.
AI Revise to include the addition of the " code class" to required markings / tagging and QC verification of the Power Stores markings / tagging.
4.
SQM2 or SQM1 - Revise to require that when code class material is needed by the maintenance activity that specific instructions on material requirements (i.e., type, grade, and code class) be included in the WR/MR or maintenance instruction.
(Bill of material and drawings required for review cycle.)
5.
AI-19, Part IV - Revise to require that when material is needed by the modification activity that specific instructions be given in the workplan on material required (i.e., type, grade, and code class).
(Bill of material and drawings required for review cycle.)
6.
SQA45 - Revise to include code class to items recorded on the form o
TVA 575.
9 7.
M&AI (1) Revise to reflect that traceability also must be to the CMTR for the item; (2) revise Data Sheets A and B to require material verification by a QC inspector (as required by the NQAM, Part II, Section 6.1); (3) revise to clearly state QC material verification requirenants (e.g., add instruction to verify proper material type and code class by reviewing work instruction, description on form TVA 575, and markings / tagging on the item); and (4) revise text and Weld Data Shdets to include the following fcr material ID:
- Contract Number
- Item Number
- Heat Number Corrective Action Report (CAR) No. SQ-CAR-86-064 has been issued to track thin to completion.
T I
)
6
'd 51:01 19 o0 10 w0a3 ECTG C.3 Page 1 of 1 Revision 2 ECSP Corrective
-Action Tracting Document _, _ _,
(C&TD)
INITIATION Applicable ECSP Report No:
MC-40703-SQN 1.
Immediate Corrective Action Required:No% Yes O No
- 2.
- Stop Work,toconsnended:
Yes O
--3.
CATD No. 40703-SON 0 4.
INITIATION DATE 1/04/87
__._5mRESP0NEIBLEe0RGANIZATION&SQF Site L.
PROBLEXDESCRIPTION:gQR O NQR
.. ~
~~c.
~~
.: -Inspectorsr1 ret an wderstandint of the significance of why or the manner in which _Niselear Class Piping Corsoonent 11,rstification verificatlon at receipt. storate, and installation is performed and documented:
/> A n
//
_.O ATTACHMENTS s
7.
PREPARED BI: NAME/(.Ed_ mdebi? F#h/./.k)/1425AtrKTE:
/-f f 9 8.
CONCURRENCE: CEG-MLAeup4dCWdrtL.
' ' DATE:
IMf87 9.
APPROVAL: ECTG PROGl[hti (GR. _6thd DATE:
dr7M CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
sgo aernched sheet.
O ATTACHMENTS 11.
PROPOSED BT: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
l DATE:
DATE:
DATE:
ECTG PROGRAM MGR:
DATE:
l VERIFICATION AND CLOSEOUT
- 13. Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
- Immediate Stop Work. Orders should be issued for the following:
Procurelaent, recolpt, issue and installation activities pertaining to Nuclear Class I, II, and III (TVA Class A, B, and C/D) or ASME Section II pressure retaining piping components.
I
CATD No. 40703-SQN-05-R0 I '
Cor rective Action 10.
Proposed Corrective Action Plan: AI-14 is being revised to require inspectors to receive'the required training to ensure.that nuclear class piping component material identification. verification is performed and documented, in accordance with the applicable code requirements, throughout their receipt, storage, and installation at SQN.
Corrective Action Report (CAR) No. SQ-CAR-86-064 has been' issued to track this to completion.
f i
i
Ol'd 9e101 Ol'd 91:81 40 50/10 WOdd ECTG C.3 Attachment A Fase 1 of 1 Revision 2
.,_,ECSP Corrective
_ Action Trackina Document
. j CATO) -
INITIATION Applicable ICSP Iseort No:
NC-40703-80N 1.
Immediate Corrective Action Required: k Yes O No 40703-80N-06
% Tes
- 2.
- Stop. Work Recomunended:
O No
-3.
CATD No.
R0 4.
INITIATION DATE 1/04/87
-5A:2.RESPONSISLI*CRGANIZA 10N.WQN#31te"---
~ - ' ' ~ " ~
~6 G~1 PROBLEN DESfRIPTION -
QR> 0 NQR*
_ ~ v
_.2 e-f;
, - - = - ~
- ?'Jt The modifications performed! on: ASRE Seetion II-Pipine Ca==Ponents, at
~SQN. do not comoir with the reunirements of ANSI B31.7 and 10 CFR 50 Appendir B.- Criterion VIII. 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 asterial other than what was specified.
D Ah 9
s,
. O ATTACNNENTS 7.
PEEPARED BT: NAMEgh ZiYT Md41 h L/2)Jsildr ATE:
},'f 4')
i 8.
CONCURRENCE:
CEG-H/ N E d %->e__-
~
"' DATE:
@/87 9.
APPROVAL:
ICTG PROGRAX M@.
Guh DATE:
/Nf4')
CORRECTIVE ACTION i
i 10.
PROPOSED CORR 8CTIVE ACTION PLAN:
see attached sheet.
l l
O ATTACNMENTS 11.
PROPOSED BT: DIRECTOR /NGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
DATE:
DATE:
DATE:
ECTG PROGRAN MGR:
DATE:
VERIFICATION AND CI4SB007
- 13. Approved corrective actions have been verified as satisfactorily laplemented.
SIGNATURE TIILE DATE
- Immediate Stop Work Orders should be issued for the following:
l Procurement, receipt, issue and installation activities pertaining to Nuclear Class I, II, and III (TVA Cisss A, B, and C/D) or ASNE Section II pressure retaininE pipinE components.
_~_ _,. _ _ _ _
CATD No. 40703-SQN-06-R0 Corrective Action 10.
Proposed Corrective Action Plan: All modifications performed on ASME XI piping, components at SQN will be assessed, and if found not to meet ANSI B31.7 and 10CFR50 Appendix B requirements, acceptability for service will be demonstrated or they will be replaced.
Condition Adverse to Quality Report (CAQR) No. SQP 870627 has been issued to track this to completion.
e ECTG C.3 Attachment A Page 1 of 1 Revision 2 ECSP Corrective Action Tracking Document (CATD)
INITIATION Applicable ECSP Report No.:
MC-40703-SON 1.
Immediate Corrective Action Required: p[Yes O No
- 2.
Stop Work Recommended: h( Yes O No 3.
CATO No.
40703-SON-07-RO 4.
INITIATION DATE 01/29/87 5.
RESPONSIBLE ORGANIZATION:
SON Site 6.
PROBLEM DESCRIPTION: )(' QR O NQR Nonconforming Condition Report (NCR) 5087 RI. Identifying material with identical heat numbers and
_ descriptions for Class I and also other code classes installed in
, Class I systems. at Watts Bar Nuclear Plant. and made generic to Seouoyah Nuclear Plant (SON) has remained open. at SON, since
_06/18/85.
O ATTACHMENTS 7.
PREPARED BY: NAME6 Mw Eh_ #ff U.th#whi-DATE:
/-n *1 8.
CONCURRENet: CEG-Iti M / f.' J/tdh.
DATE: J/#f 7-9.
APPROVAL:
ECTGPR0(BdMMGR.
f)'/Wfr/,,d es DATE: ' ??.W)
CORRRCTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
Resolution of CATDs 40703-SON-02-R0 and 40703-SON-06-RO will assure adequate resolution of this problem.
CAOR Mn_ ROP 870627 has been issued to track these CATDs to closure.
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
DATE:
i DATE:
DATE:
ECTG PROGRAM MGR:
DATE:
yERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
- Immed, late Stop Work Orders should be issued for the following:
Procurbment, receipt, issue and installation activities pertaining to Nuclear Class I, II. and III (TVA Class A. B. and C/D) or ASME Section XI pressure retaining piping components.
4 1441T
~. - - -. - _ _ - _
gr.
B ECTG C.3 Attachment A Page 1 of 1 Revision 2 ECSP Corrective Action Tracking Document (CATD)
INITIATION Applicable ECSP Report No.:
MC-40703-SON 1.
Immediate Corrective Action Required: )(' Yes O No
- 2.
Stop Work Recommended: )(' Yes O No 3.
CATD No.
40703-SON-08-R0 4.
INITIATION DATE 01/29/87 5.
RESPONSIBLE ORGANIZATION: SQN Site 6.
PROBLEM DESCRIPTION: )(QR O NQR Inconsistencies in denoting class changes on TVA design drawings have resulted in the installation of piping systems in a manner not depicted by the Flow Diagrams and in violation of the Final Safety Analysis Report (FSAR), Section 3.2.2.1 which states in part:
whose f ailure could cause a loss of reactor coolant ishich would not permit an orderly reactor shutdown and cooldown, a s sitmi ng that makeup is only provided by the normal makeuo system.
a O ATTACHMENTS 7.
PREPARED BY: NAMEgi / 8 A J A O du/C M DATE:
<->y 99 CEG-H '_@dh.'y' >.*eL i
DATE:
2 L(f 7 8.
CONCURRENCE:
ECTG PROGEAM )(GR.
/ '#fr/e7
/d DATE:
Nb 9.
APPROVAL:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
ECN No. L6784 was written August 25. 1986, to require system flow diagrams and physical piping drawings for all systems to be reviewed and revised as required to properly and clearly define all piping class breaks.
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
DATE:
DATE:
DATE:
ECTG PROGRAM MGR:
DATE:
VEHIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
- Immediate Stop Work Orders should be issued for the following:
Procutement, receipt, issue and installation activities pertaining to Nuclear Class I, II, and III (TVA Class A. B, and C/D) or ASME Section XI pressure retaining piping components.
3442T
l pf i ' '
ECTG C.3 Attachment A Page 1 of 1 Revision 2 ECSP Corrective Action Tracking Document ICATD) i INITIATION Applicable ECSP Report No.:
MC-40703-SON 1.
Immediate Corrective Action Required:No)( Yes O No
- 2.
Stop Work Recommended: )(' Yes O
3.
CATD No.
40703-SON-09-R0 4.
INITIATION DATE 01/29/87 5.
RESPONSIBLE ORGANIZATION: SON Site 6.
PROBLEM DESCRIPTION: )(QR O NQR _Neither the Final Safety Analysis Report (FSAR) nor the Design Drawings contain a clear distinguishing boundary between the primary coolant loops and their branch lines.
, O ATTACHMENTS 7.
PREPARED BY: NAME/i/46 r-,K/42fMr//L!m4v.s/7DATE:
Ae-fa 8.
CONCURRENCE: CEG-H8' L4srg/P7Fdbot DATE:
J/5/f 7 -
9.
APPROVAL:
ECTGPROGyMM8R.
h6bP/.';M
- 5 DATE:
l'h/b)
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
No Corrective Action required.
A condition adverse to quality does not exist. DNE review has shown that a clear boundary exists - See Attachment A.
PIR No. SQMEB8793 was issued to track this CATD to closure.
O ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MCR:
DATE:
12.
CONCURRENCE: CEG-H:
DATE:
SRP:
DATE:
DATE:
DATE:
DATE:
ECTG PROGRAM MGR:
DATE:
VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
- Immediate Stop Work Orders should be issued for the following:
Procurement, receipt, issue and installation activities pertaining to Nuclear Class I. II and III (TVA Class A. B. and C/D) or ASME Section XT pressure retalning piping components.
3442T
CATD No. 40703-SQN-09-R0 Corrective Action (Page 1 of 2)
- 10. ATTACHMENT A The design drawings do contain a clear definition of the boundary between the primary coolant loops and their branch lines.
The primary coolant loops were supplied by Westinghouse as a part of their scope of supply in the NSSS contract. TVA supplied the branch lines.
DNE combined many Westinghouse drawings and details into a single set of drawings for the purpose of locating the piping within the reactor building and providing a clear definition of the loops and a detailed listing of all branch connections. This set of drawings are 47W304-1 and 47W304-2. The drawings clearly show the piping surge line. Both units are shown--each on a separate drawing.
The branch lines are detailed on TVA individual system drawing sets.
These are orthographic drawings with details and sections showing the exact locations where the branch lines connect to the primary loops.
Those orthographic drawings are the ones used by DNE for construction The flow diagrams, used to demonstrate the flow paths, do not purposes.
show where the loop piping and the branch piping boundary is.
1 I
4 1
CATD No. 40703-SQN-09-R0 Corrective Action (Page 2 of 2)
- 10. DRAWINGS REVIEWED Orthographic Drawings Reactor Coolant Piping 47W304-1 and 2 Chemical and Volume Control Piping 47W406-1 thru 15 Residual Heat Removal Piping 47W432-1 thru 5 47W435-1 thru 26 Safety Injection Piping Reactor Coolant Auxiliary Piping 47W465-1 thru 7 Flow Diagrams 47W809-1 thru 7 CVCS RHR 47W810 47W811-1 and 2 SIS Reactor Coolant System 47W813-1 Examples of Specific Sections and Details which show the boundary:
Drawing Section 47W465-1 Section B1-B1 47W465-2 Section F2-F2 47W465-3 Section C3-C3 47W406-8 Section L8-L8 47W406-13 Section K13-K13 i
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4 1
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