ML20214E716
| ML20214E716 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 11/29/1985 |
| From: | Harwell E, Kidd M, Sauer R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082840729 | List: |
| References | |
| I-85-560-SQN, NUDOCS 8604230350 | |
| Download: ML20214E716 (78) | |
Text
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TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT No. I-85-560-SQN EMPLOYEE CONCERN: II-85-086-003
SUBJECT:
BOX HANGER WELD DESIGN DEFICIENCY - SEQUOYAH NUCLEAR PLANT DATES OF INVESTIGATION:
OCTOBER 2-23, 1985
// 7 h INVESTIGATOR:
E.f.HARWELL DATE /
f 2"7/S5 REVIEWED BY:
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R. C. SAUER DATE APPROVED BY:
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BACKCROUND I
A Huclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern as received by Quality Technology Company (QTC)/ Employee Response Team (ERT).
The concern of record, as summarized on the Employee Concern Assignment Request Form from QTC and identified as II-85-086-003, stated:
"Sequoyah: A design deficiency has a wrong weld required on box hangers which, if performed per design, causes the weld to run into the pipe (SS or carbon steel code pipe)."
The ERT follow-up group war, contacted to see if any additional information was available that would indicate the location or system. QTC called back stating that the CI had indicated that the drawings in question were 47B100 sheets 2 and 4.
II.
SCOPE A.
The scope of the investigation was determined from the stated concern to be that of a single specific issue:
A butt weld if made as shown on the typical drawings, could e
extend to the pipe and result in the collar plate being
' '{" 'g T7 welded to the pipe eliminating the freedom of move-ment which the pipe should have.
B.
NSRS reviewed generic drawings of the 47B100 series and those specific engineered drawings associated with ECN L6319.
Cog-nizant personnel of Sequoyah Design Services and Modifications Groups and the Knoxville Office of Engineering were inter-viewed.
The associated construction specification and pro-cedure which governed the installation of seismic supports were also reviewed.
III.
SUMMARY
OF FINDINGS A.
Recuirements and Commitments 1.
Sequoyah FSAR, Section 3.7, " Seismic Design," and Section 3.8, " Design of Category I Structures."
2.
Sequoyah Design Criteria No. SQN-DC-V-13.3, " Detailed Analysis of Category I Piping Systems."
3.
Sequoyah Design Criteria No. SQN-DC-V-1.3.3.1, " Additions After November 14, 1979 - Reinforced Concreto, Structural, and Miscellaneous Steel."
4.
Ceneral Constru: tion Specification G-43, " Support and k
Installation of Piping Systems in Category I Structures." -
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Findings 1.
The Sequoyah 47B100 series drawings as designed, do show a butt weld on the rear plate of some seismic class I sup-ports that could extend to the pipe if made as the typical 2
drawing specifies. Cognizant Design Services and Office of Engineering personnel (Individuals A, B, and C) identi-fled ECN L6319 (ref. 6) as the only application of seismic box anchors at Sequoyah which references the Sequoyah 47B100 series drawings for use.
2.
There are eight box anchors associated with ECN L6319 j
(ref. 6) and only one has been installed. The detailed drawings for some of these anchors show welds that could
)
extend to the pipe. The cognizant engineer (individual E) for the installation of these supports stated that on the installed anchor shown on drawing 47A491-3-6, a thin, j[
approximately 1/8-inch land was left adjacent to the pipe prior to welding. When the plate was welded together, the a
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thin land area was fused together meeting the drawing configuration but not to the point that the weld extended j
to the pipe. After completing the weld, the plate was checked to make sure it was free to move along the pipe.
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Evaluation of the preparation for the remaining seven box f
anchors indicates the preparation does not include the 4
special precaution utilized by Sequoyah on the first anchor f
of placing a land adjacent to pipe to prevent extending the j
weld to the pipe.
k 4.
A generic evaluation of this problem to WBN and BFN revealed:
3 a.
A similar weld extension to pipe problem ex." 'ts on i
sheet 4 of the Watts Bar generic drawings of the 47B100 L
series.
4 b.
Browns Ferry has specific versus generic hanger draw-l ings. An evaluation of these drawings reveals simi-
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lar weld extension to pipe configuration requirements specified on some drawings.
Though no hardware discrepancies were identified E
c.
3 related to the inadequate drawing requirements, a
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generic deficiency exists whereby if the welding g
portion of drawings were followed verbatim, a noncon-forming condition would result with.the clearance requirement of the same drawing.
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CONCLUSIONS AND RECOMMENDATIONS A.
The allegation was substantiated by virtue of the fact that the typical drawings do show a weld configuration such that it could extend to the pipe when made. There is no concern related to the one installed anchor since special steps were taken to prevent a problem.
B.
I-85-560-SQN-01, FCR Revision Recuired to ECN L6319 Drawings and 47B100 Drawing Series l
To assure that problems do not occur when installing the remaining seven anchors at Sequoyah, the modifications cognizant engineer (Individual E) is processing FCRs to have the ECN and typical drawings revised for further clarifica-i tion. The revised drawings will be included in the affected I
workplans. These corrective' actions, when completed, will resolys the Sequoyah concern. NSRS will track this_as an open
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C.
I-85-560-SON-02. Nonconformance Evaluation for Box Anchor l
Welding j ' f'57.
Because of the generic aspects associated with box anchor weld-ing described in paragraphs III.B.3 and 4, a construction i
l issued NCR 6264 dated August 24, 1985, for Watts Bar should be i-sent through design to the other plants for a generic review j
for applicability in accordance with Office of Engineering i
Procedure OEP-17 (ref. 9).
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DOCUMENTS REVIEWED IN INVESTIGATION 1-85-560-SQN AND REFERENCES 1.
Sequoyah drawing 47B100 series, 47B200 series, 47A053 series notes.
2.
ECN L6319 drawings 47A491-3-6, 47A491-68-5, 47A491-68-6, -6A, 47A491-68-7, -7A, 47A491-68-8, -8A, 47A491-68-9, 4A491-68-10, 47A491-79-3, -3A, all Revision 0, dated June 27, 1985 3.
Sequoyah Design Criteria SQN-DC-V-13.3, Revicien 3 dated August 13, 1984, " Detailed Analysis of Category I Fiping Systems" 4.
SQN-DC-V-1.3.3.1, Revision 4, dated September 4, 1984, " Additions i
After November 14, 1979 - Reinforced Concrete, Structural, and f
Miscellaneous Steel" i
i 5.
General Construction Specification No. 43 Revision 8, dated August 8, 1985 " Support and Installation of Piping Systems in j
Category I Structures" 6.
ECN L6319. " Relocate Sprinkler Head for Appendix R," Revision 0,
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dated January 24, 1985 (SQP 841218 005)
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BFN specific drawings 8.
WBN 47B100' sheet 2. Revision 5, dated September 7, 1983, and 47B100 sheet 4 Revision 0, dated February 7,1978 4
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9.
Office of Engineering Procedure OEP-17. " Corrective Action," Revision p
2, dated August 30, 1985 i
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I EMPLOYEE CONCERN ASSIGNMENT REQUEST TO: Director - NSRS TRANSMITTAL NUMBER T50147 ERT has received the Employee concern identified
- below, and has assigned the indicated category and priority:
Priority:
1 Concern # XX-85-086-OO3
[
I-t 5 - Sbo-SQd Category:
33 Confidentiality:
_YES
_NO (I&H) i j
Supervlaor Notified: _X_YES
___NO NUCLEAR SAFETY RELATED
_YES_
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Concern: Sequoyah: A design deficiency has a wrong weld required on Box d
Hangers which, if performed per design, causes the weld to run into the pipe (SS or Carbon Steel Code pipe).
Construction dept concern.
CI has no further information.
L
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j No followup required.
e___S E P 14__to85 MANAGER, ERT DATE
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s NSRS has assigned responsibility for investigation of the above concern to:
j ERT ___
NSRS/ERT _____
f NSRS ___ __[] $
4 OTHERS (SPECIFY) d h
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DATE f
NSRS
TVA EMPLOYEE CONCERNS REPORT NUMBER:
I-85-135-SQN SPECIAL PROGRAM REPORT TYPE: Weldin6 Project REVISION NUMBER: 0 TITLE: Welder Certification Update Without Meeting Requirements REASON FOR REVISION: N/A s
SUMMARY
STATEMENT: Concerns Considered:
XX-85-049-001 and XX-85-049-XO3 PREPARATION PREPARED BY:
11-06-86 Original Signed By R. M. Bateman DATE SIGNATURE REVIEWS r) v)
PEER:
11-06-86 Original Signed By J. E. Rose DATE SIGNATURE jp, TEC11NICAL REVIEW ONLY TAS
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RAN Y
i DATE SIGNATURE CONCURRENCES Oriainal Signed By LEM i
i CEG-11:
.1nmne r Lewig_
11-25-86
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SRP:
SIGNATURE DATE SIGNATURE
- DATE APPROVED BY:
l ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE I
CONCURRENCE (FINAL REPORT ONLY) i
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- SRP Secretary's signature denotes SRP concurrences are in files.
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WELDING PROJECT SON SPECIFIC EMPLOYEE CONCERNS DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS ~,
SUMMARY
OF WP ENGINEERING EVALUATION CONCERN CONSIDERED: XX-85-049-001 PREPARED BY
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, DNC, WP REVIEWED BY
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APPROVED BY
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06470
WELDING PROJECT SON SPECIFIC EMPLOYEE CONCERNS DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMARY
OF WP ENGINEERING EVALUATION CONCERN CONSIDERED: XX-85-049-XO3 U/4[@Q
, DNC, WP PREPARED BY J
REVIEWED BY \\.E k%.
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, DQA, WP REVIEWED BY ww/^
oc REVIEWED BY hmuAJ Y buME) 11l2 Sl f A 1:'en / >4 m, CEG-H, Welding
, Program Manager APPROVED BY a
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TV A 64 (O%9-65) (OP-WP+4 51
- UNITED STATES GOVERNMENT cmOTdMdMM TENNESSEE VALLEY AUTHORITY TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FRCH: K. W. Whitt, Director of Nuclear Safety Rev5.ew Staff, E3AB C-K
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DATE:
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SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSHITTAL Transmitted herein is USRS Report No.
T-85-135-SON Subject WELDER CERTIFICATIONS UPDATED WITHOUT MEETING REOUIREMENTS Concern No.
M YM M M 3 nd IX-85-049-IO3 and associated prioritized reco:::mendations for your action / disposition.
This report contains one Priority 1 [P1) reco=mendation which must be addressed before startup. It is requested that you respond to this report i
and the attached Priority 2 [P2} recommendation by April 17 1986 The
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Priority 3 [P3] recommendation will be looked at for corrective action follow through by June 1. 1986 No response is required for this item.
Should you have any questions, please contact W.
D.
Stevens at telephone
_6231-K Recommend Reportability Determination: Yes X
No
/
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pDire_stor,NSRS/ Designee y
N).
WDS:JTH ~
Attachmcnt l'
ce (Attachment):
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W. C. Bibb, SQU J. W. Coan, W9Cl35 C-K W. T. Cottle, WBU James P. Darling, BLU R. P. Denise, LP6N40A-C G. B. Kirk, SQN F. E. Laurent, CEO-WBN W. E. Hason, EllC49 C-K--Review to confirm NSRS determination of no falsifcation D. R. Nichols, ElOA14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C J. H. Sullivan. SQN Kent Therp, IOB-WBN U
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'This package summarizes the actions taken by the Welding Project (WP) to
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l evaluate and disposition the subject SQN-specific employee concern which was previously evaluated by NSRS/QTC/ERT and summarized in WP Phase I and Phase II reports.
4 l
The Welding Project analyzed each SQN-specific employee concern (Attachment 2) to determine the statement (s) being voiced by these individuals.
l These statements were then evaluated both individually and collectivsly to develop issues.
Ecch issue was then incorporated into the WP review activities of Phase I,
" Procedural Assessment" and Phase II, " Procedural Implementation."
..q v
During Phase I, each issue was analyzed against requirements of the applicable QA program, policies, NSRS/QTC/ERT Investigation Reports, and other revelant information to determine if program elements were deficient when evaluated against upper tier requirements.
Phase II consisted of a sample reinspection of hardware and independent program audit by Bechtel.
l l
In each area analyzed by Bechtel, the auditors found no objective evidence to i
substantiate the employee concerns considered. The following areas directly related to employee concerns were investigated by the' audit team:
'h age 1 3
0337I
1.
Welder qualification and attendant records 2.
Welder qualification and attendant on-the-job-training 3.
Welding inspections 4.
Welding inspectors training programs S.
Weld material traceability 6.
Welding inspections by craft personnel 7.
Weld material control
,)
Each of these areas was investigated by the auditors for both construction and
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operations phases. In all cases, there was no objective evidence to substantiate the employee concerns. The audit report concludes that both construction and operations phases have had and now have a functioning Welding Quality Assurance Program which meets code, standard, and regulatory requirements and that the employee concerns considered were found to be unsubstantiated and without technical merit.
.31 Page 2 of 3 0337I
1 The results of the reinspection program at SQN also give another, additional i
verification of the Welding Quality Assurance Program for both construction i
and operations phases and serve to establish additional confidence in the i
accuracy and implementation of these programs through hardware inspections and attendant document reviews. In all cases, the components and items were found to be acceptable upon initial reinspection or found to be acceptable after i
engineering analysis.
i The WP analysis of SQN Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed ccmponents and systems, and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified through the Employee Concern Program. The Employee Concern Program has simply d'A reiterated problems which have been or are now being resolved through existing corrective action programs in the overall Nuclear Quality Assurance Program.
k A summary analysis of the WP evaluations and recommendations is included,in.
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Page 3 of 3 l
Page 1 of 3
SUMMARY
OF SQN SPECIFIC EMPLOYEE CONCERNS REVIEWED BY WELDING PROJECT EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XI-85-088-003 Alterations to Welder Not substantiated by ERT Qualification Records in Report XX-85-088-003 of Knoxville 3/8/86 (Attachment 3).
XX-85-124-001 Burial of Electrode Stubs Not safety-related. No action required.
XX-85-086-003 Box Anchor Design Substantiated by NSRS Report Deficiency.
I-85-560-SQN (Attachment 3).
WP concurs with report recommendations.
XI-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS
,':)
Rejected NDE Items Report I-85-738-SQN (Attach-
" ~
ment 3).
WP concurs with report recommendations.
2
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SQM-5-001-001 Uncertified Welder Foreman Substantiated by WP Evaluation SQM-5-001-002 Performing Proweld Report WP-16-SQN (Attachment WBM-5-001-002 Inspections 3).
Interim correctivc (Also Listed in actions are being the Generic formulated. Closure is Summary) based on these actions.
~ Additional corrective actions may be implemented.
II-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS Piece REPORT I-85-636-SQN l
(Attachment 3).
XI-85-069-001 Inadequate OJT-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for NO inadequate OJT-records was II-85-069-X05 substantiated by NSRS Report XX-85-069-007 I-85-373-NPS (Attachment 3).
No falsification of records was substantiated. WP con-curs with report recommen-dations.
I 05640
Page 2 of 3 EMPLOYEE CONCERN NUMBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapablo of SQM-6-005-001 was SQM-6-005-X02 Making Proper Welds substantiated; SQM-6-005-X02 was not substantiated by NSRS Report I-86-115-SQN (Attach-ment 3).
WP concurs with report.
XX-85-013-001 E309 Electrode Used to Weld This is an acceptable E316 Steels practice. ERT investigated in ERT Report XX-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
XX-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
/'..
XX-85-049-001 Welder Certifications XX-85-049-001 was XX-85-049-X03 Updated Without Meeting substantiated as it relates Requirements to Welder Continuity Require-ments. This had previously been identified by NO in an audit. XX-85-049-X03 was not substantiated. Details and recommendations are given in NSRS Report I-85-135-SQN
- (Attachment 3).
WP concurs with I-85-135-SQN-01 through
-03 and recommends they be closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).
XX-85-054-001 QC Holdpoint Sign-Off Not substantiated by NSRS Violation
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Report I-85-346-SQN (Attachment 3).
XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Inspections Report I-85-750-SQN (Attachment 3).
05640
Page 3 of.3 EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XX-85-083-001 SQN Weld Inspections not as Not substantiated by NSRS Strict as WBN Report I-85-652-SQN (Attachment 3).
XX-85-098-001 Laminated Pipe in Unit 2 Not safety-related. Not Condenser. This issue is substantiated by WP Evaluation also on the Generic Summary Report WP-18-SQN (Attachment 3).
XX-85-100-001 Improper Weld Repair on an Not substantiated by ERT Undetermined Number of Report XX-85-100-001, dated Welds 3/5/86 (Attachment 3).
XX-85-101-006 Welder Certification for ERT Report XX-85-101-006 the Construction Era (Attachment 3) with NSRS Recommendations indicates J$$7 that this concern is sub-stantiated. WP takes excep-tion to this ERT Report based on subsequent information provided in Attachment 4.
WP exceptions, recommen-dations, and basis for closure were discussed with NSRS as documented in Attach-t ment 5.
WP recommends this
- concern not be substantiated and that it be closed based on the WP-Bechtel Implemen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachment 6).
XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS Notice of Indications for Report I-85-735-SQN Preservice-Related Defects (Attachment 3).
XX-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS IX-85-108-002 Report I-85-776-SQN (Attachment 3).
05640
Page 1 of/(3 Y
11/04/86 (EMPLOYEE CONCERNS) 11:27:14 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
S 1
NSRS A3 SR XX-85-049-X03
.WORDS:
CERTIFICATION IMPLEMENTATION FALSE NONSPEC PROB: WCPIF F
i SEQUOYAH: WELDER CERTIFICATION CARD FALSIFIED. CONSTRUCTION DEPT CONCERN. Cl j
HAS NO MORE INFORMATION.
I 1R: 1-85-135-SON STAT:
RC:
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T 11:26:33 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
S 1
SR XX-85-049-001 WORDS:
CERTIFICATION PROGRAM ELEC WELDERS PROB: WCPOW SEQUOYAH:
WELDER CERTIFICATIONS HAVE BEEN UPDATED FOR WELDERS WHO DID NOT MEET UPDATE REQUIREMENTS OR BACKDATED TO GIVE THE APPEARANCE OF REQUIREMENT COMPLIANCE.
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CONSTUCTION DEPARTMENT CONCERN.
Cl DECLINED TO PROVIDE FURTHER INFORMATION.
j IR: l-85-135-SON STAT:
RC:
TECHNICAL COMMENTARY:
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TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT No. I-35-135-SQN EMPLOYEE CONCERN: XX-85-049-001 XX-85-049-XO3
SUBJECT:
WELDER CERTIFICATIONS UPDATED WITHOUT' MEETING j
REQUIREMENTS l
l DATES OF i
INVESTIGATION:
NOVEMBER 26 - DECEMBER 12, 1985 I
INVESTIGATOR:
[M E.[F.HARWELL DATE /
l REVIEWED BY:
.h 2 [/4'!/L L. E. BROCK DATE l
APPROVED BY:
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W. D. STEVENS DATE j
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BACKCROUND
+
A Nuclear Safety Review Staff (NERS) investigation was conducted to detennine the validity of two expressed employee concerns as received by Quality Technology Company (QTC)/ Employee Response Team (ERT). The concerns of record as summarized on the QTC computer printcut and identified as IX-85-049-001 and II-85-049-X03, respectively. stated:
Sequoyah: Walder certifications have been updated for I
welders who did not meet update' requirements or backdated to give appearance of requirement compliance.
Sequoyah: Walder Certification card falsified.
Construction Dept Concern. CI has no more information.
i i
The K-form for xx-85-049-001 had not been received from QTC/ERT when
}
this investigation began on November 26, 1985, although the concern was
.4 received by them on July 12, 1985. NSRS requested that QTC/ERT provide i
the K-form so the investigation could proceed. On January 24, 1986, the j
K-form was received the concern and was exactly as described by the above statement'of the employee concern which was obtaine'd from the j
summary on QTC computer printout.
- a
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Since these two concerns deal with the same area, the investigation was A
done in such a manner that a single report covers both concerns.
k II.
SCOPE i
4 w.4 1
A.
The scope of the investir,ation is defined by the concerns of record j
which entailed determining three specific issues:
i l
1.
Were welder certification / continuity records correctly l
maintainted?
2.
Was there any evidence that records were backdated or falsified?
3.
Are there any safety implications? '_
.'b Bf 'In conducting this investigation NSRS reviewed the requirements of the ASME Code, the Nuclear Quality Assurance' annual (NQAM), Nuclear Power Welding Program Requirettents, and' audit and corrective action g
reports. 'Saveral cognizant individuals were interviewed concerning i
the welder certification, continuity requirements, and recording.
ti NSRS also reviewed a random sample of appecximately 25 welder certification and continuity records.'
h III.
SUMMARY
OF FINDINGS
'I
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A.
Requirements and Commitments
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TVA Topical Report, TVA-T275-1A, Section 17.2, " Quality i
Assurz.nce Program Program Applicable to Operation" t
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NQAM, Part II, Section 6.1, " Welding" 3.
ASME,Section IX, " Welding and Brazing Qualifications" B.
Findings 1
1.
References 1 and 12 require personnel performing special processes (i.e., welding) to be qualified and their qualifica-tions to be documented.
2.
A.PME Section II (Ref. 4) provides requirements to the power industry for qualifying welders and guidance on how to continue to maintain their qualification (continuity).
3.
Nuclear Power has defined in reference 3 how to meet the requirements of ASME Section II.
Reference 2 provides the requirements that the Division of Construction must follow.
4.
Sequoyah Nuclear Plant (SQN) utilizes references 7 and 8 to implement the requirements of the welding program.
5.
In the past, Nuclear Power has accepted construction welder performance qualification without retesting. However, because of the welder certification questions recently' raised at Watts Bar (Ref. 10), the SQN Site Director issued a memorandum (Ref. 9) to site management directing them to discontinue this l([ a, practice.
M.
6.
In August 1985, an investigation of the welder certification and continuity program was started at SQN with the Plant QA Staff, Mechanical Maintenance, Mechanical Modification, and Hartford Inspector being involved (Refs 6, 10, and 11).
7.
As a result of this investigation, a corrective action report (Ref. 13) was issued identifyi,ng problems found.
8.
A copy of a memorandum from Individual F. Mechanical Modifica-tions Supervisor, to Active Welder's Files, dated October 23, 1985, was placed in each welder's files indicating that all active welder's files were reviewed by QA surveillance personnel and weld-test representatives and discrepancies,orrected.
There were 10 welders whose certification papers were missing or there were gaps in their construction continuity records. Their weld cards were pulled, and these welders were not allowed to weld until qualification requirements were met. Two welders' qualification test records were obtained and placed in their files. These two did not have a continuity problem. The remaining cisht whose continuity records could not be obtained were retested in accordance with the renewal requirements of the ASME Section IX Code.
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In discussion with a toolroom clerk (Individual H) who update;=
the continuity records based on wold filler material draws, he indicated that some draws may be inadvertently.left off the wclder certification printout. Once the error or omission is detected, the records arol corrected for the timeframe for which they were missing. The welder certification printout is presently done once a month.
However, Individual H said they',
may start doing the printouts more often; and, therefore, errors could be detected sooner and corrected before a month's time elapses.
o, 10.
A proposed corrective-action response was received from the responsible supervisor and concurred with by QA on October 25, 1985. >The response identified several root causer for the problems found.
One main cause was clerical errors in the recording of and transfer of information. Another contributing factor was the different methods of updating continuity by the various organizations, such as the different' construction sites and Nuclear Power. These methods have changed over the years and are much more stringent by today's standards. The CAR i
response f.onclusion uas that no safety concern existed since all active welders were brought into compliance with requirements and all safety-related welding was performed in i
accordance with an approved QA inspection program. Plant procedure M&AI-5 has been revised to clarify the responsibilities and method utilized to maintain continuity.
- 11.
A random review by NSRS of welder certification files revealed that corrections had been made and initialed by a responsiblo weld-test representative. However, no indications of backdating or falsification were found.
IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusion i.
1.
The concern that the welder update (continuity) requirements were not being met was substantiated and had been identified recently in a QA audit finding. All active welder records have been properly updated by supporting documentation or the welder retested.
2.
The concern that records may have been backdated in order to give an appearance that the welder was qualified could not be substantiated. There were some clerical-type errors where incorrect dates sere entered on welders' records, but these I
were corrected when a review identified discrepancies between welde continuity record sheets and supportive documentation i
(i.e., welder performance qualification record). In addition, the toolroom clerk may have missed entering weld filler j
material draws on a welder's record and correctly updated the
![
continuity records later, but this is not considered i
backdating. No evidence was found that indicated falsification of records had occurred.
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There appears to be no safety concern since all active welder records were either correct or readily restored to require-ments. Also, all safety-related welding is independently
(
inspected per an approved QA program.
4.
Corrective Action Report SQN-CAR-85-09-14 (Ref. 13) did not address the consequences of the previous (nonactive) welder continuity program.
B.
Recommendaticns 1.
I-85-135-SQN-01, Evaluation of Previous Welder Continuity Records 4
A sample of previous nonactive welder records should be performed to gain adequate confidence that welder certifications were maintained and that no safety implication currently exists.
[P1) 2.
I-85-135-SQN-02, Corrective Action Backfit Evaluation TVA formal corrective action processes such as corrective action reports, nonconformance reports, etc., should be evaluated to include a backfit evaluation provision to determine if the identified deficiency requires such action to provide substantial, additional protection for the public health and safety or the common defense and security.
[P2]
- .m
" O 91 3.
I-85-135-SQN-03, Verification of Corrective Action Taken on S0-CAR-85-09-14 To assure that all documentation problems have been resolved and all corrective actions have been completed or implemented, the plant QA staff will perform another indepth audit of the welder certification and continuity program in the next few months. This verification (audit) will allow satisfactory
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resolution of the CAR.
This is an NSRS tracking item only.
[P3]
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O DOCUMENTS REVIEWED IN INVESTICATION No. I-85-135-SQN AND REFERENCES 1.
NQAM, Part II, Section 6.1, dated October 12, 1984, " Welding" 2.
General Construction Specification G-29, Process Specification 1.M.2.2 (Revision 2), dated February 10, 1983, " Welder and Welding Operator Performance Qualification" 3.
Area Plan, DPM No. N73M2, dated August 28, 1984, " Process Specification for Welding, Heat Treatment, and Allied Field Operations" 4.
ASME Section II. 1983 Edition Winter 83 Addenda, " Welding and Brazing Qualifications," Section QW-320 " Retest and Renewal of Qualification" 5.
SQN Construction Procedure No. W-2, Revision 1, dated July 6, 1981,
" Welder and Welding Operator Performance Qualification" 6.
Compliance Visits, Audits, and Inspections - Inplant Survey Checklist No. Sa-85-S-007, dated September 22, 1985, survey
Title:
Welder Qualifications and Continuity 23 7.
{P 7 SQN Standard Pract3 r SQM 17 Revision 2, dated May 17, 1984, " General Welding Requirements for Nuclear Plants - DPM N73H2" 8.
SQN Modification and Additions Instruction, M&AI-5, Revision 8, dated October 7, 1985, " Welding Material control Procedure" 9.
Memorandum from H. L. Abercrombie to Those listed dated August 29, 1985 " Welders' Certifications" (S02 850828 979) i 10.
Memorandum from David H. Tullis to Boyd M. Patterson dated September 13, 1985, "Sequoyah Nuclear Plant - Welder Continuity Program" 11.
John C. Brady's notes of September 3,1985, concerning survey conducted by-Doug Frye and himself to review the welder continuity program at SQN and determine if any problems existed 12.
TVA Topical Report TR75-1A, Revision 8, Section 17.2.9, " Control of Special Processes" 13.
Corrective Action Report SQN-CAR-85-09-14, dated September 12, 1985 14.
Random (approximately 25) welder certification flies 0046W 5
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k EMPLOYEE CONCERN ASSIGNMENT REQUEST TO: Director - NSRS TRANSMITTAL NUMBER T50230 ERT has received the Employee concern identified
- below, and has assigned the indicated category and priority:
priority:
1 Concern # XX-85-049-001 Category:
88 Confidentiality: NA_ YES NA_NO(I&H)
Supervisor Notified:
___YES _X_
NO NUCLEAR SAFETY RELATED YES_
Concern:
Sequoyah: Welder certifications have been updated for welders who did not meet upaate requirements or backdated to give the cppearance of requirement comoliance.
Construction department concern.
CI declined to provide further information.
C.c.,No follow up required.
$Cp t4 e 'd : is 1-i i c d't \\
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12-17-85__
MANAGER',.ERT DATE NSRS has assigned responsibility for invesEigation of the above concern to:
ERT ___
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4 OTHERS (SpECIFY)
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WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS t-f, f:
f ATTACHMENT 4
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WP-bECHTEL AUDIT OF SQN
. KEY ELEMENTS 4.0, 5.0, AND 17,0
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KEY ELEMerr 4.0 kk
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OFFICE OF CONSTRUCTICN MAINTCIANCE OF WELDER OR WELDING OPERAT Based on audit of welder maintenance records, TVA welder welding within certification expiration dates as required b s demonstrated and procedures.
y TVA programs KEY ELD 4DIT 5.0 OFFICE OF CONSTRUCTION RDIEWAL OF WELDER OR WELDING OPERATOR OUALI Based on audit of welder qualification records'and maintenan welders were requalified in accordance with TVA programs ce records, TVA In many cases TVA welders were given the original qualificati and procedures.
renewal which exceeded ASME IX and AWS Dl.1 requirements for renewal on test for KEY ELEMDIT 6.0
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OFFICE OF CONSTRUCTION n
_ INITIAL WELDING INSPECTION PERSONNEL OUALIFICATIO a-Qualification / Certification records for nondestructive examination pers (weld inspection) were reviewed for compliance with TVA NDE qualification procedures covering a time span from January,1971 throu h personnel March, 1983.
g TVA personnel qualification procedures t$ sed for the qualificatin /
edition of SNT-TC-1A (American Society of Nondest n
e detail to confirm compliance with applicable codes, sta u
c ent specifications in effect during construction activities.
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KEY ELDENT 17.0 OFFICE OF CCNSTRUCTION EMPLOYEE CONCERNS I
17.1 Concern No. XX-85-049-X03 and XX-85-101-006 regarding welder certification.
This concern was not substantiated by the audit of a random sampling of 37 welders which involved 124 welder qualification i
records from 1970 to 1979.
17.2 Concern No. XX-85-69-001 and XX-85-069-X05 regarding welder certification and on-the-job training. This concern was not substantiated by the audit of a randem sampling of 37 welders which involved 124 welder qualification records from 1970 to 1979
-17.3 Concern No. XX-85-108-001 and XX-85-108-002 inspections.
regarding weld audit of a minimum of 14 inspection procedures.This concern could 17.4 Concern No. IN-85-476-004 and WI-85-041-002 inspectors training program.
regarding welding
(,,
as evidenced by audit, of training programs.This concern could not be substan 17.5 Concern No. Wl-85-053-004 and XX-85-68-006 satisfying code requirements.
regarding weld rod control audit of a random sampling of 48 receiving documents and associated CMTR's which involved 83 heat and/or lot number, 8 types of weld metal covering the years 1972 to 1980.
This represents approximately 572,000 pounds of weld metal. Although'. audit finding, AF-01-01, against Xey Element No.12 of this report is documented against the TVA program, it involves details required by TVA procedures over and above that required by ASME filler metal specifications and had no impact on weld quality.
The statement in the concern,shows a-lack of understarding of the code.
For example, ASME III, NB-4122 requires traceability of the weld filler metal but gives two methods to chose from.
Either trace to each component or ensure the specified material is used by a control procedure.
the standards and, therefore, did not require traceability to aTVA component.
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C' 4CE OF CONSTRUCTron g.gr EMPLOYEE CONCERNS ~
(continued) 17.6 Concern No. XX-85-054-001 from the weld history records for the welds revic regarding weld inspecti on by craft. This ectors pulled well as by an additional random sampling of 13 inewed in the audit as
+
holdpoints were found to have been signed off by a
~
spectors. No certified inspectors.
a nyone other than i
h This concern may be referring to structural welds i up and final inspection. Structural welds and piping have different i
4 procedures for structural welds.No holdpoints are required by the TVArements for f 17.7
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Concern No. EX-85-039-001 regarding weld control (st b Q
rod).
This concern was not substantiated by the audit of u s and unused procedures.
j included verification of welder identificationA daily surveillan applicable
.g welded and the procedure being used.
j
, the feature being (such as amperage) were verified to assure thatVariables from the procedure n
, f-the procedure properly.
monitored to assure that the welder had requested th m~"
issued the proper rod, and was using the proper oper rod, was 300 surveillances a month were performed during years ofApproximate rod.
h construction.
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KEY ELD 4DIT NO. 4.0
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NUCLEAR OPERATIONS MAINTDIANCE OF WELDER OR WELDING OPERATOR l
welding within certification expiration dates as requi s rated and procedures.
programs t
i KEY ELDfENT NO. 5.0 NUCLEAR OPERATIONS
^
RDIEWAL OF WELDER OR WELDING OPERATOR QUALIFICATIO i
q welders are requalified in accordance with TVA prog j
1 r s, TVA s.
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i KEY ELD!DJT 6.0
.g NUCLEAR OPERATIONS I
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INITIAL WELDING INSPECTICN PERSONNEL OUALIFICATICNS e
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audited indicated compliance with TVA programs aad
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4 referenced codes and standards.
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OBSERVATION 3
l TVA Form 6780 (as referenced in procedure 0202.14) qualification and certification does not clearly identify theused to document NDE recertificatian status of the individual.
Additionally, certification when individuals are actually certified in accordance w j
-3 '
requirements of Procedure Certification Program for NDE Personnel.0202.14 (formerly N75C01), Qualification c
l]
program clarity and definition could be improved by adding either the J
F certification expiration date or recertification status as an entry on Fo j
6780.
Specific reference to Procedure rm 0202.14 on certification forms (6780) would provide for direct reference and compliance with TVA NDE p (g
qualification, certification requirements and practices for each ND$
ersonnel g
employed.
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1 KE7 ELEfttr 17.0 OTTICI. OF MUCLEAR OPERATIONS 17.1 Concern No. XX-85-049-XO3 and XX-85-101-006 certification.
regarding welder This concern was not substantiated by the audit of a i
random sampling of 25. welders which involved.107 welder qualification a
records from 1972 to 1985.
17.2 Concern No. XX-85-69-001 and XX-85-069-XO5 regarding welder L
certification and on-the-job training.
L This concern was not involved 107 welder qualification records from 1972 to 19 17.3 Concern No. XX-85-108-001 and XX-85-108-002 inspections.
regarding weld audit of a minimum of 14 inspection procedures.This concern could no 17.4 l
Concern No. IN-85-476-004 and WI-85-041-002 inspectors training program.
regarding welding as evidenced by audit of training programs.This concern could not be substatiated I'
7 17.5 Er Concern No. Wl-85-053-004 and XX-85-68-006 A. s satisfying code requirements.
regarding veld red control
[
audit of a random sampling of 25 receiving documents and associate i
weld metal covering the years 1976 to 1985.CMIR's which involved s
[
l approximately 19,000 pounds of weld filler metal.This represents 1
The statement in the concern shous a lack of understanding of the weld filler metal but gives two methods to chose from.For examp code.
h to each component or ensure.the specified material is used by a Either trace control procedure.
the standards and, therefore, did not require traceability to aTVA I
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cos.conent.
i 17.6 Concern No. XX-85-054-001 I
regarding weld inspection by craft.
from the wcld history records for the welds reviewed in the This well as by an additional random sampling of 10 inspectors.
as holdpoints were found to have been signed off by anyone other than No certified inspectors.
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a E W EL MENT 17.0
- W~" * -
OFFICE OF NUCLEAR OPERATIONS (continued)
Structural welds and piping have different code nstead of piping.
up and final inspection.
procedures for structural welds.No holdpoints are. required by the TVAq 17.7 Concern No. EX-85-039-001 regarding veld control ( t b i
rod).
This concern was not substantiated by the audit of s u s and unused
{
procedures.
verification of welder identification, the feature b iA s applicable j
the procedure being used.
3 amperage) are verified to assure that welders are usiVariab i
f properly.
that the welder has requested the proper rodWelding rods ng the procedure i
assure rod, and is using the proper rod.
1
, was issued the proper k
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TVA EMPLOYEE CONCERNS REPORT NUMBER: I-85-738-SQN SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 0 TITLE: Acceptance of Previously Rejected NDE Items RRASON FOR REVISION: N/A 4
SUMMARY
STATEMENT: N/A i
i I
f PREPARATION PREPARED BY:
0 R. M. Bateman 11-06-86 I
SIGNATURE DATE 1
,1 l
I REVIEWS l
PEER:
V J. E. Rose 11-06-86 SIGNATURE DATE TAS F TECHNICAL REVIEW ONLY Mi l us Y DATE
//
dG SIGNATURE
~
CONCURRENCES Original Signed By CEG-H:
J. F. Lewis for IEM 11-25-86 j
1 1
SltP:
I SIGNATURE DATE SIGNATURE
- DATE APtROVED BY:
N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL. REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in flies.
2242T
!j
J WELDING PROJECT SON SPECIFIC EMPLOYEE CONCERNS
- 1 4
DATE 11/6/86
\\
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMARY
OF WP ENGINEERING EVALUATION 0-1 i
CONCERN CONSIDERED: XX-85-069-003, R1 ii l
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, DNC, WP PREPARED BY s
REVIEWED BY NL6 ll_/ ddWm
. DNC, WP
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, DQA, WP REVIEWED BY e >",
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REVIEWED BY h w >A / Y. bsen > nl24lCf&
F /)J7 dan 9EG-K, Melding j
/
, Program Manager l
APPROVED BY 4
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NOTE:
XX-85-069-003, RO is a Bellefonte - specific employee concern with a different issues.
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06470
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'#tNITED STATES GOVERN 31ENT Memorandum TENNESSEE VALLEY AUTHORITY TO: H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant FRON: K. W. Whitt, Director-of Nuclear Safety Review Staf f,' '5'3A8 C-Ke
((g Q g jg@@
DATE:
~
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSMITTAL-'
kdb j
Transmitted herein is NSRS Report No.
T-8 5-3M-NPS l
Subject Acceptance of Previously Re_iected NDE Items I
k Concern No.
XX-85-069-003. R1 O
I and associated prioritized recommendations for your i
action / disposition.
,q -
It is requested that you respond to this report and the attached two Priority 2 [P2] recommendations by April 20. 1986
'Should you s
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have any questions, please contact W. D. Stevens at telephone 6231-K L
Recommend Reportability Determination: Yes.
No X 1
ll
/[/ irector, NSRS/ Designee 1
(
WDS:JTH..
.j Attachment j
cc (Attachment):
j W. C. Bibb, BFN j
W. T. Cottle, WBN James P. Darling, BLN R. P. Denise, LP6N40A-C L
C. B. Kirk, SQN D. R. Nichols, E10A14 C-K i
QTC/ERT, Watts Bar Nuclear Plant
(
Eric Sliger, LP6N48A-C J. H. Sullivan, SQN h
1529U
!I j
.c
This package summari:ec the actions taken by the Welding Project (WP) to evaluate and disposition the subject SON-specific employee concern which was previously evaluated by NSRS/DTC/ERT and summarined in WP Phase I and Phase II reports.
The Welding Project analyzed each SON-cpecific employee concer'n (Attachment 2) to determine the statement (s) being voiced by these individuals.
Those statement were then evaluated both individually and collectively to develop issues.
l Each issue was then incorportated into the WP review activities of Phase I,
" Procedural Assessment" and Phase II, " Procedural Implementation."
During Phase I, each issue was analyzed against requirements of the applicable OA program, policies, NSRS/OTC/ERT Investigation Reports, and other relevant l
information to determine if program elements were deficient when evaluated l
against upper tier requirements.
Phase II consisted of a sample reinspection of hardware and independen't program audit'by Bechtel.
i l
In each area analy:ed by Bechtel, the auditors found no objective evidence to substantiate the employee concerns considered. The following areas directly l
related to employee concern were investigated by the audit team-0337I Page 1 of 3 l
1.
Welder qualification and attendant records 2.
Welder qualification and attendant on-the-job-training 3.
Welding inspections 4.
Welding inspectors training programs 5.
Weld material traceability 6.
Welding inspections by craft personnel 7.
Weld material control Each of these areas was investigated by the auditors for both construction and s
operations phases. In all cases, there was no objective evidence to substantiate the employee concerns. The audit report concludes that boih construction and operations phases have had and now have a functioning Welding Quality Assurance Program which meets code, standard, and regulatory requirements and that the employee concerns considered were found to be unsubstantiated and without technical merit.
.y Page 2 of 3 0337I
i The results of the reinspection program at SQN also give another, additional verification of the Welding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the accuracy and implementation of these programs through hardware inspections and attendant document reviews.
In all cases, the components and items were found l
to be acceptable upon initial reinspection or found to be acceptable after l
engineering analysis.
The WP analysis of SQN Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed components and systems, 1
and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been diractly identified
.)
through the Employee Concern Program. The Employee Concern Program has simply f
J f
reiterated problems which have been or are now being resolved through existing corrective action programs in the overall Nuclear Quality Assurance Program.
A summary analysis of the WP evaluations and recommendations is included in I.
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Page 3 of 3 0337I 1
Page 1 of 3
SUMMARY
OF SQN SPECIFIC EMPLOYEE CONCERNS REVIEWED BY WELDING PROJECT EMPLOYEE CONCERN NUMBER ISSUE WP ALTION XX-85-088-003 Alterations to Welder Not substantiated by ERT Qualification Records in Report XX-85-088-003 of Knoxville 3/8/86 (Attachment 3).
XX-85-124-001 Burial of Electrode Stubs Not safety-related. No action required.
XX-85-086-003 Box Anchor Design Substantiated by NSRS Report Deficiency.
I-85-560-SQN (Attachment 3).
WP concurs with report recommendations.
-t XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS Rejected NDE Items Report I-85-738-SQN (Attach-I' g; '
ment 3).
WP concurs with e
report recommendations.
SQM-5-001-001 Uncertified Welder Foreman Substantiated by WP Evaluation SQN-5-001-002 Performing Preweld Report WP-16-SQN (Attachment i
WBM-5-001-002 Inspections 3).
Interim corrective (Also Listed in actions are being the Generic formulated. Closure is based on these actions.
Summary)
- Additional corrective actions may be implemented.
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS Piece REPORT I-85-636-SQN (Attachment 3).
XX-85-069-001 Inadequate OJT-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for NO inadequate OJT-records was XI-85-069-X05 substantiated by NSRS Report I-85-373-NPS (Atcachment 3).
XX-85-069-007 No falsification of records was substantiated. WP con-curs with report recommen-dations.
05640
i Pege 2 of 3 EMPLOYEE CONCERN NUMBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was SQM-6-005-X02 Making Proper Welds substantiated; SQM-6-005-X02 was not substantiated by NSRS Report I-86-115-SQN (Attach-ment 3).
WP concurs with report.
XX-85-013-001 E309 Electrode Used to Weld This is an acceptable E316 Steels practice. ERT investigated in ERT Report XX-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
XX-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
XX-85-049-001 Welder Certifications II-85-049-001 was y'
XX-85-049-X03 Updated Without Meeting substantiated as it relates to Welder Continuity Require-Requirements ments. This had previously been identified by N0 in an audit. XX-85-049-X03 was not substantiated. Details and recommendations are given in NSES Report I-85-135-SQN (Attachment 3).
WP concurs with I-85-135-SQN-01 through
-03 and recommends they be closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).
XX-85-054-001 QC Holdpoint Sign-Off Not substantiated by NSRS Violation Report I-85-346-SQN (Attachment 3).
XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Inspections Report I-85-750-SQN (Attachment 3).
05640
Page 3 of 3 EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XX-85-083-001 SQN Weld Inspections not as Not substantiated by NSRS Strict as WBN Report I-85-652-SQ4 (Attachment 3).
4 XX-85-098-001 Laminated Pipe in Unit 2 Not safety-related. Not Condenser. Ihis issue is substantiated by WP Evaluation
.l also on the Generic Summary Report WP-18-SQN (Attachment 3).
1 XX-85-100-001 Improper Weld Repair on an Not substantiated by ERT Undetermined Number of Report II-85-100-001, dated 1
Welds 3/5/86 (Attachment 3).
XX-85-101-006 Walder Certification for ERT Report XX-85-101-006 the Construction Era (Attachment 3) with NSRS Recommendations indicates that this concern is sub-l stantiated. WP takes excep-tion to this ERT Report based i
I on subsequent information i
provided in Attachment 4.
WP exceptions, recommen-dations, and basis for closure were discussed with NSRS as documented in Attach-ment 5.
WP recommends this
_ concern not be substantiated and that it be closed based on the WP-Bechtel Implemen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachment 6).
XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS Notice of Indications for Report I-85-735-SQN Preservice-Related Defects (Attachment 3).
XX-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS Report I-85-776-SQN XX-85-108-002 (Attachment 3).
05640
Page 1 of 1 10/16/86 (EMPLOYEE CONCERNS) 11:24: 33 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
S 1
SR XX-85-069-003-R1
'WORDS:
INSPECTION IMPLEMENTATION JUDGEMENT PROB: WCDPW SEQUOYAH:
VERY OFTEN. REJECTED ITEMS ARE ACCEPTED BY SOME ONE OTHER THAN A SUPERVISOR OR A HIGHER LEVEL (GRADE).
TO ILLUSTRATE THE POINT, C/l STATED THAT THE SUPERVISOR WILL SEND ANOTHER EXAMINER / INSPECTOR WITH LESS QUALIFICATION AND EXPERIENCE TO RE-EXAMINE THE ONCE REJECTED ITEMS AND WILL GET ACCEPTANCE.
C/l HAS NO FURTHER INFORMATION.
NUC. POWER CONCERN.
7.
IR: 1-85-738-SON STAT:
RC:
TECHNICAL COMMENTARY:
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BACKGROUND A Nuclear Safety Review Staff (NSRS) investigation was conduhted to determine the validity of an expressed employee concern as received by the' Quality Technology Company (QTC) Employee Response Tema (ERT). The concern of. record, as sununarized on the Employee Concern Assignment Request Form from QTC and identified as II-85-069-003-R1', stated:
SEQUOYAH: Very of ten, rejected items are accepted by" someone other than a supervisor or a higher level i
(grade). To illustrate the point, CI stated that the supervisor will send another examiner / inspector with less qualification and experience to.re-examine the once rejected items and will get acceptance. CI has no further information.
This investigation did not pursue aspects of the concern of record regarding the propriety of examiner / inspector qualification and experience. NSRS was conducting an investigation of Employee Concern II-85-069-001 concurrently with this investigation, and II-85-069-001 addressed employee certification and qualification as a much broader issue. The results of that investigation are applicable to this aspect of the concern of record.
NSRS obtained additional information from the ERT follow-up group which
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further specified the concern to be that the concerned individual (CI) g has seen examiners frequently reject items only to have someone with N
lesser qualifications go out and approve the rejected items. As an example, a Maintenance Request (MR) will be written up with a s
Notification.of Indication (NOI) rejecting a hanger for a loose bolt or missing part. The employee rejecting the hanger may then be transferred (or reassigned) and does not know the status or resolution of the NOI.
]
Later another employee will accept the hanger as is.
Based upon the stated concern and the additional information provided by ERT, NSRS made the following assumptions.
- d. The first sentence of the concern of record ~means that rejected items are accepted by someone other than a supervisor or a higher-level examiner.
B.
The concern of record specifically focuses on the administration of the.. Inservice Inspection'(ISI) program at Sequoyah Nuclear Plant (SQN) because:
3 3
1.
Reference Sb stated that an NOI is used in the ISI program to report unacceptable results of nondestructive examinations (NDE).
2.
Reference 4a states that NDE personnel conduct visual examinations under the ISI program to determine the general mechanical and structural conditions of components and their supports (e.g., hangers), such as missing parts and tightness of bolting.
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NOIs are used occasionally by the SQN Plant Quality Assurance Staff.for purposes which are unrelated to the ISI program.
However,- this occasional use_ does not correspond with the CI's description (e.g., "Very of ten rejected items. are accepted," and "CI has seen examiners frequently reject.
.").
II.
SCOPE A.
The scope of the investigation is defined by the concern of record, additional information provided by ERT, and the assumptions described above. Since the information provided by ERT contained specific details of the concern, the area requiring investigation'is defined to be administration of ISI visual examinations at SQN, principally regarding component hangers. However, as ISI-program deficiencies were discovered in the course of this investigation, they were also noted and are addressed in the text of this report.
Two specific issues in the-above area require investigation as follows.
1.
Previously rejected items (e.g., hangers) are very of ten accepted by someone other than an NDE supervisor or higher-level NDE examiner.
2.
A MR will be written with an NOI rejecting a hanger for a loose
/'
bolt or missing part. Later another NDE examiner will accept
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the hanger "as is."
B.
NSRS reviewed regulatory requirements, ASME rules, ISI program procedures, and,SQN instructions to determine programmatic controls applicable to the above issues. Additionally, a detailed inspection of all applicable unit 1 and 2 ISI NOIs and visual examination data sheets was made to identify any records which document the occurrence of the above issues. The NDE Unit Supervisor at SQN was interviewed to obtain details of current practices in conducting ISI visual ~ examinations at SQN.
r III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments
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- 1. ~10CFR Part 50.55a, " Codes and Standards," contains inservice inspection requirements for NDE of components applicable to SQN. These requirements state that the inspegtion of plant components (including 'their sup' ports) shall meet the requirements of ASME Boiler and Pressure Vessel Code,Section XI, and Addenda.
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s 2.
ASME Boiler and Pressure Vessel Code Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components" -
Division 1. " Rules for Inspection and Testing of Components of Light-Water Cooled Plants," contains specific, requirements applicable to the issues under investigation. These
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requirements are presented in Subsection IWA, " General Requirements," as follows.
e a.
Article IWA-2210 states that a visual examination is employed to provide a report of the general condition of the
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part, component, or surface to be examined.
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F b.
Article IWA-2300 states that personnel performing NDE I
operations shall be qualified with a procedura prepared in accordance with SNT-TC-1A-1975 (Ref. 9) for the applicable k
examination technique and methods.
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c.
Article IWA-4220 states that reexaminations shall include t
the method that detected the flaw requiring repair.
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d.
Article IWA-6210 states that records shall be available for
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examination results and reports.
3.
NUC PR Program Procedure 0202.14 (formerly DPM No. N75C01),
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" Qualification and Certification Program for Nondestructive f
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Examination Personnel " March 6, 1985, implements the requirements of 2.b above and establishes requirements for NUC PR.
4.
NUC PR Program Procedure 1502.07 (formerly DPM No. N80E3),
" Nondestructive Examination Procedures Approved for Use on CSSC Items at All Nuclear Plants," January 18, 1985, implements the requirements of 2.a above and establishes requirements for NUC L
PR.
5.
NUC PR NQAM, Part II, Section 5.1', " Inservice Inspection -
"I Nuclear Power Plant Components," October 12, 1984, implements f
the requirements of 2.a-d, 3, and 4 above and establishes upper-tier requirements for NUC PR.
L 6.
NUC PR NQAM, Part II, Section 6.3, " Nondestructive Examination,"
h March 26, 1985, implements the requi'rements of 2.a-d, 3, and 4 A
above and establishes upper-tier reqtiirements for NUC PR.
I B.
Findings i
1.
SQN ISI Program Implementation p
[
a.
TI-51 (Ref. 6e) impit.ments upper-tier.gequirements contained
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in procedures described in III.A.5 and 6.
Procedure No.
N-VT-1 of TI-51 specifies methods and requirements for ISI visual examinations to determine mechanical and structure.1 I
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k conditions of components and component supports. Visual examination VT-3 of the procedure is specified for use to determine conditions such as the presence of loose parts (e.g.,
loose bolts, loose jam nuts, and missing cotter pins) and tightness of bolting. These determinations must be documented on the examination data sheet identified as
" Record of VT-3 Visual Examination" by the NDE employee who conducted the examination. The data sheet h'as provisions for the examiner to document each applicable condition (e.5., loose parts and tightness of bolting) is satisfactory or unsatisfactory.
b.
The examination data sheet is subsequently reviewed by ISI i
group examiners to assure accuracy and completeness and to j
verify that the examination was performed by qualified
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personnel in accordance with reference Sc.
c.
SI-114.1 and SI-114.2 (Ref. 6c and 6d) implement upper-tier j
requirements contained in procedures described in III.t. 5 and 6.
These surveillance instructions outline program requirements for performing ISI examinations for unit 1 and unit 2 respectively. When an unsatisfactory condition
[
(i.e., unacceptable indication or indication) is detected 1
- l during the performance of the VT-3 visual examination ~
[
described above, a formal notification is submitted to plant management.
This notitication consists of a " Notification of Indication" I-(NOI)
(i.e., Appendix D of the applicable surveillance
};
completed by the NDE Level II or Level III examiner who instruction identified above).
Part I of the NOI must be s
]
3 detected the unsatisfactory condition.
(Examiners j
frequently work in teams on conducting an examination of a component; and, in these cases, one of the participating examiners will complete part I of the NOI.) The NOI is then i
reviewed and signed by the "NDE Section Representative."
j (This person is the Supervisor of the NDE Unit or his 3
designee. The designee may at times be a Level III examiner 3
or a Level II examiner. This matter is addressed in greater detail in the following paragraphs of this report.) The NOI is then forwarded to plant management for disposition and performance of the associated corrective action, part II of
}
the NOI is completed by the cogn'izant plant management to document the disposition.
(Dispositions to accept the
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unsatisfactory condition as is must provide the basis for 3
the disposition in part II and include a properly prepared Unresolved Safety Question Determination (USQD).] Upon 4
completion of corrective action, the NOI is returned to the i
NDE Unit for verification of completion of corrective 4
action. part III of the NOI must be completed and signed by the NDE Unit Supervisor or his designee to document this verification. If reexamination was performed (as described j
in 1.a above), a copy of the completed NOI remains with the reexamination data sheet, m
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2.
Indications Related to the Issues Under Investigation a.
A search was conducted of the ISI records (Refs. 8a through 8e) to locate documentation which indicated that an examiner had rejected an item and another examiner had later accepted the previously rejected item. Several voided NOIs were found (e.g., SQ-0149 of Ref. 8e and SQ-0097 bf Ref. 8d) which indicated that this had happened; but in each instance, the examiner indicating acceptance af the item was a certified Level III examiner whereas the examiner initially rejecting the item was a certified Level II examiner. Therefore, the latter acceptance is consistent with procedures (Ref. Sc), and no violation of program requirements could be established, b.
A search was conducted of the ISI records (Ref. 8a through 8e) to locate documentation which indicated that previously rejected items had been accepted by someone other than an NDE supervisor or a higher-level NDE examiner. Several NOIs were found (e.g., SQ-0143, SQ-0189, and SQ-0227 of reference 8e) in which Part III had been signed by another certified Level II examiner.
(Signing Part III of the NOI in effect i
is acceptance of the previously rejected item based upon acceptable disposition of the unacceptable condition.)
However, this process does not appear to violate any program e*
requirements based upon the following.
(..
A subsequent interview was conducted with the NDE Unit Supervisor on the process of completing Part III of an NOI.
s The supervisor indicated that it was his responsibility to complete Part III and sign the NOI as "NDE Section Representative. However, at times he may not be available and will designate someone to be acting supervisor in his absence. The designee's. responsibility will include signing i
NOIs as "NDE Section Representative," and the designated
- employee may be an.ISI Group Level III examiner or an NDE Unit Level II examiner. The supervisor also indicated that Part III of any NOI should not be completed until acceptable disposition of all unaccepteble conditions of the item is achieved and documented, AsearchwasconductedoftheIhIrecords(Ref.Sa-8e)to c.
locate documentation which indicated that an NR had been I
written with an NOI rejecting a hanger for a loose bolt or missing part'and another NDE examiner later accepted the hanger as is.
Only one Nor could be found which even appeared to resemble the CI's example (II.A.2).
The NOI is SQ-0189 (Ref. 8e) which has a reexamination data sheet j
showing that a Work Request (WR) was written to replace a 4
missing lock wire which was discovered during reexamination to verify corrective action for the previously rejected hanger. part III of the NOI was signed but does not show Y
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that there was a follow-up verification that the WR had been i
completed. In addition, part III was signed by a Level II examiner which was the same leveltas the examiner who performed the reexamination. However, the employee was designated acting supervisor which sis not a violation of program requirements. Also, since the completed NOI does not adequately document verification of; completed corrective acticy (e.g..'the WR), there was a failure t'o meet the intent of program requirements outlined in 1.c above.
Alth,ough program procedures do not specificalI? address what actions are required when an NDE examiner discovers a new unacceptable condition during reexamination of an item, the NDE Unit Supervisor,h'as indicated that any NOI should not be completed until disposition of all unacceptable conditions of the item is achieved and documented.
3.
Indications Unrelated to the Issues Under Investigation NOIs SQ-0092 and SQ-0127 (Ref. 8d) reflect a failure to follow procedures by NDE examiners. The NOIs have examiners listed as detecting the unsatisfactory condition which are not the examiners listed on the corresponding examination data sheet.
I Therefore these NOIs were not prepared in accordance with program requirements described in 1.c above.
4.
Documentation Discrepancies
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a.
Examination data sheets R-1846 and R-1849 for reexamination to verify corrective action regarding NOIs SQ-0111 and SQ-0102 respectively (Ref.
8d) indicate that the s
reexaminations were performed by an examiner'whose name and certification to perform visual examinations do not appear in the summary of NDE personnel certifications contained in f
reference 8d.
However, documentation was obtained which j
shows that the examiner was. certified to perform the examinations. It appears that the examiner's name and E
- certification were. inadvertently omitted when the summary was prepared (Ref. Sb).
b.
Examination data sheets R-545 and R-622 for reexamination te verify corrective action regarding NOIs R-450 and R-529 l
respectively and NOI R-1013 (Ref. 8a) indicate that the examinations were performed by a'q examiner who is not shown to be certified to perform visual examinations in the summary of NDE personnel certifications contained in reference Sa.
However, documentation wasiobtained which
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shows that the examiner was' certified to perform the J
examinations. It appears.that the certification was inadvertently omitted when '.the summary was prepared.
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5.
Procedure Deficiencies a.
TI-51 (Ref. 6e) contains a note following the " Purpose" which states that the detailed instructions in Attachment 1
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shall be used in performing NDE of CSSC items. This attachment is not identified in the body of the instruction, k
b.
SI-114.1 and SI-114.2 (Ref. 6e and 6d) contain specific instruction on the preparation and handling of-NOIs.
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However, these instructions do not address the practice of voiding NOIs. Several NOIs were found which had been voided r
f (e.g., SQ-0149 in reference 8e, and SQ-0088 in reference 8d).
c.
SI-114.1 and SI-114.2 (references 6c and 6d), paragraph 5.0,
/
state:
"The inservice examinations will be performed by either QEB personnel or outside contractors." The NDE Unit, Mechanical Branch, is generally the organization which f
conducts.ISI examinations although QEB and outside g
contractor personnel may also perfom examinations.
C d.
SI-114.1 and SI-114.2 (references 6c and 6d) state the following:
W Paragraph 16.2, "The QEB NDE Section shall.
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Paragraph 17.0, "The NDE Section Ac resentative of QES shall.
j Paragraph 17.0, "... the NDE Section Representative s
y shall...."
Organizationally, the NDE Unit, Hechanical Branch, performs j
the functions addressed in these paragraphs. In addition, the "NDE Section Representative," who is required to sign NOIs, is not defined in the text of the instructions (e.g.,
j Supervisor, NDE Unit or his designee which may be either a Level III or Level II examiner).
e.
SI-114.1 and SI-114.2 (references'6c and 6d), paragraph 12.0, state that personnel performing NDE operations sh 111 4
f be qualified. This is not consistent with the requirw.ent that NDE personnel be certified'as stated in reference 3 j
(paragraph 4.1.2), reference 5b (paragraph 1.2.5), reference f
Sc (paragraph 2.1), and reference.4a (paragraph 3.1).
i f.
The " Purpose" of reference Se states:
. NDE is performed under controlled conditions by qualified personnel...." This statement is not consistent with paragraph 2.1 of the reference or othqr, references identified in item 5.e above. Paragraphs 2.1 and 2.5 of the reference also contain similar inconsistencies, r
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O g.
Reference 5b (paragraphs 1.3.3 and 1.3.5) contains
..iconsistencies related to those discussed in item 5.d above, h.
Reference Sc (paragraph 2.5) states:
shall additionally prepare reports in accordance with NQAM, Part II, Section 5.1."
The reports are not clearly identifiable 3
(e.g., inservice examination reports).
~
1.
Reference Sc (paragraph 1.2) states:
NDF. procedures to comply with the requirements of Source Document 3 or 4."
There is no source document listed as number 4 This appears to be a typographical error.
J.
Reference Sc (paragraph 1.6) refers to "the cognizant dngineer." This,is the only reference to a cognizant engineer.found in the text of the procedure, and it is not clear to what position this refers.
e IV.
COliCLUSIONS AND RECOMMENDATIONS A.
Conclusions The two issues of the employee concern are not substantiated. The basis for this conclusion follows.
-~
1.
Previously rejected items have been accepted at times by a second examiner who was a certified Level III examiner. On each occurrence the examiner would note on the NOI and the s
corresponding data sheet the basis for acceptance of the item which, in effect, voided the NOI.
This process does not appear to violate any specific regulatory requirement or ASME rule applicable to the ISI program.
2.
Previously rejected items have been accepted by Level II NDE examiners who were designated as Acting NDE Unit Supervisor.
1 The acceptances occurred when Part III of the associated NOI was completed by the acting supervisor. This process does not appear to violate any specific regulatory requirement or ASME rule applicable to the ISI program.
3.
OneNOIwasfoundtohavePartIIIekosedwithoutdocumenting
..that all of the corrective action had been completed for the affected item. This occurrence is a failure to meet the intent of existing program requirements (reference 64).
This NOI does not clearly fit the CI's description; however, no other examples h
could be found which support the stated concern.
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s B.
Recouemendations I-85-738-SQM-01, NDE Procedure Revisions The deficiencies in NDE program procedures identified in III.B.2.b and c and III.B.5 constitute a lack of completeness and consistency.
in detail which are necessary for effective implementation of the j
NSRS reconumends that the SQN staf f take the lead in program.
I coordinating the resolution of these deficiencies with the l
appropriate organizations.
[P2]
I-85-738-SQN-02, NDE Record Chantes The discrepancies in the ISI reports described in III.B.4 and III.B.2.c constitute incomplete and inaccurate quality assurance records (reference 6a). NSRS recommends that the 3QN staff correct and complete these records as provided for in established plant instructions.
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DOCUMENTS REVIEWED IN INVESTICATION I-85-73 3-SQN AND REFERENCES 1.
10CFR Part 50.55a, " Codes and Standards" 2.
ASME Boiler and Pressure Vessel Code,Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components," July 1, 1974 -
Division 1. " Rules for Inspection and Testing of Components of Light-Water Cooled Plants" a,
Subsection IWA, "Ceneral Requirements" b.
Subsection IWB, " Requirements for Class 1 Components of Light-Water Cooled Power Plants" c.
Subsection IWC, " Requirements for Class 2 Components of Light-Water Cooled Power Plants" d.
Subsection IWD, " Requirements for Class 3 Components of Light-Water Cooled Power Plants" 3.
NUC PR Program Procedure 0202.14 (formerly DPM No. N75C01), " Qualification and Certification Program for Nondestructive Examination Personnel."
March 6, 1985
/d$n f
4.
NUC PR Progran Procedure 1502.07 (formerly DPM No. N80E3), " Nondestructive Examination Procedures Approved For Use Ou CSSC Items at All Nuclear Plants," January 18, 1985 -
s a.
Procedure No. N-VT-1, "Preservice and In-Service Visual Examination Procedure," June 18, 1985 5.
NUC PR Nuclear Quality Assurance Manual Part II. -Section 2.1, " Plant.Maintenanc'e," April 18, 1985 a.
b! Part II, Section 5.1, " Inservice Inspection - Nuclear Power Plant Components," October 12, 1984 Part II, Section 6.3, " Nondestructive Examination," March 26, 1985 c.
6.
SQN Instruction Manuals AI-7, " Recorder Chart's and Quality Assurance Recordq." Revision 36 a.
J b.
AI-20. " Inspection Program," Revision 10
'c.
SI-114.1, "ASME Section XI In-Service Inspection, Program - Unit 1,"
Revision 6
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d.
SI-114.2, "In-Service Inspection Program for Tennessee Valley Authority Sequoyah Nucleac Plant Unit 2 Only," Revision 6 TI-51, " Assignment of Detailed Test Methods and Responsibility for e.
Non-Destnictive Testing," Revision 29 f.
SQM2, " Maintenance Management System," Revision 15 g.
MS/DCU6, " Changes, Corrections, and Supplements to QA Retords,"
Revision 0 7.
Office of Quality Assurance Audit Report No. SQ-8400-03, " Plant Staff Performance Training and Qualification," March 19, 1984 (0QA 840319 702) 8.
Sequoyah Nuclear Plant Inservice Inspection Reports l
l a.
Unit 1 Cycle 1. Fall 1982 l
b.
Unit 2 Cycle 1, 1983 l
c.
Unit 1 Cycle 2. Winter 1984 l
d.
Unit 2 Cycle 2, 1984-1983 27 e.
Unit 1 Cycle 3, (In progress) 4.
SNT-TC-1A-1975, " Recommended Practice for Nondestructive Testing Personnel Qualification and Certification " published by the American Society s
for Nondestructive Testing es G
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
308.02-SQN SPECIAL PROGRAM REPORT TYPE:
Sequoyah Nuclear Plant Element REVISION NUMBER:
3 TITLE:
Preventive Maintenance
/
3 REASON FOR REVISION:
To incorporate SRP and TAS comments.
Revision 1 3
To incorporate additional SRP commer,ts.
Revision 2 To incorporate additional SRP co:nments.
Revision 3
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PREPARATION PREPARED BY:
Nt McAr J
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SIGNATURE DATE REVIEWS PEER:
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SIGNATURE DATE TAS:
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SIGNATURE DATE I
CONCURRENCES sb AEG-S lY i
4 SRP:
SIGNATURE DATE SIGNATURE
- DATE
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lj APPROVED BY:
j N/A
.l ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
1781T e
4 i
TENNESSEE VALLEY AUTHORITY i
SEQUOYAH NUCLEAR PLANT I
J EMPLOYEE CONCERNS TASK GROUP OPERATIONS
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i' Subcategory: Maintenance Element: Preventive Maintenance 7
Report Number:
308.02-SQN Revision 3 IN-86-316-XO9
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Evaluator:
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Richard unn s Date Reviewed by:
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//-/["Id OPS Mpdber Date Approved by:
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A W. R. Lagergren Date
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I.
. PREVENTIVE MAINTENANCE 1
b This report evaluated one concern regarding engineering disregard toward the use of vendor manuals in the Preventive Maintenance Program y.
at Sequoyah Nuclear Plant (SQN).
c 9:
R II.
SPECIFIC EVALUATION METHODOLOGY R'
I One concern was included in the element evaluation report, j
Concern Number IN-86-316-X09 states:
"TVA cannot have a safe and 1
adequate Preventive Maintenance Program if engineering continues to f
disregard the vendor's manual for safety-related equipment."
The interface issue concerning Vendor Manual Control between Tennessee l
Valley Authority (TVA) and Vendors, as addressed by Nuclear Regulatory Comunission (NRC) Generic Letter 83-28, was not evaluated as a part of this concern. The issues of NRC Generic Letter 83-28 are being addressed by TVA Corporate connaitments. Vendor manual use was k,
evaluated from corporate program procedures down to the implementing E
preventive maintenance procedures to determine if engineers had 1
disregarded the use of vendor manuals in the performance of preventive maintenance activities.
[
Engineers from the Division of Quality Assurance (DQA) Nuclear l
Engineering (DNE), maintenance, and craft personnel were interviewed.
j In addition, document research, procedure reviews, and comparison to j
regulatory requirements wera conducted.
L This concern was previously evaluated by Generic Concern Task Force
[
(GCTF) report " Vendor Manual Control and Use," dated June 3, 1986, and a report was issued which contained their findings, i
t i
I The above referenced GCTF report was reviewed to determine whether the evaluation conclusively established the validity of the concern, and verify that the report information was current.
l NkC Generic Letter 83-28 dated July 8,1983, " Required Actions Based lR3 on Generic Implications of Salem ATWS Events," was reviewed.
l I
L III. FINDINGS Previous to the issuing of Generic Letter 83-28 by the NRC, (as noted I
above in section II). TVA did not have a uniform Vendor Manual Control l
Program.
This lack of program control led to problems with processing l
vendor manual revisions at DNE. The site Vendor Manual Control Units IR3 could not be assured of receiving the latest revisions to vendor manuals I
to be incorporated into their control copies in a timely manner.
1 However, there were no identified instances where engineers had l
disregarded the use of vendor manuals during this timeframe.
This l
s C
i Page 1 of 6 L
pr oblem has since been corrected at the corporate level by the issuing I
of Part V, Section 6.2, " Vendor Manual Control" to the Nuclear Quality IR3 Assurance Manual (NQAM).
However, problems still exist in the 1
implementation of Generic Letter 83-28 commitments, and these are l
documented.in Corrective Action Report (CAR) SQ-86-01-004, and Institute I
of Nuclear Power Operations (INPO) reports dated February 1984 and l
April 1985.
1 Administrative Instruction (AI)-23, was revised to, address Environmental lR3 Qualification (EQ) application of Vendor Manual and to implement a i
control program to be in line with Generic Letter 83-28.
I AI-23. " Vendor Manual Control," was reviewed to determine the
{
requirements for the use of vendor manuals. The scope of the instruction applies to activities affecting Critical Systems Structures i
and Components (CSSC) and 10 CFR 50.49 equipment for SQN. The l
responsibilities, vendor manual control, and requirements of vendor manuals were found to be clear and concise as written in the
[
procedure. The effort to control and validate vendor manuals is in progress at this time 7
- i A review of standard practice SQM57, " Preventive Maintenance Program,"
l was made to determine the requirements and use of vendor manuals for the i i :
Preventive Maintenance Program.
It was found that reference was made IR3 to the use of vendor manuals or 10 CFR 50.49 Envirocaental Qualification l l qg (EQ) Binders.
l x.y An interview with a cognizant engineer from the Preventive Maintenance L
QA Staff was conducted about problems with the Preventive Maintenance Program. The cognizant engineer stated that the Preventive Maintenance Program needed complete procedure reviews, that the Preventive h
Maintenance Instructions were unclear as written, and more detail was
'lj needed to ensure all information necessary to perform the work activities l
was included. A review of NMRG Maintenance Review " Exit Meeting at lR3 i
Sequoyah Nuclear Plant," dated July 29, 1986, was conducted and found si to be in agreement with the cognizant engineer's statement.
q) i ?
- 4. review and evaluation was conducted on 15 preventive maintenance f i instructions (PMs) on CSSC equipment. Note the sample of 15 PMs was not intended to produce statistically correct projections of trends in the 7
parameters sampled, but it was sufficient to identify the existence of
'f.:
problems. The PMs were reviewed to verify that requirements as stated in the source documents (vendor manuals, FSAR, and instruction manuals) were d!
implemented into the PM instructions. All requirements were met, and no l
discrepancies were found.
!!I Interviews were conducted with DQA engineers, DNE engineers, EQ Engineers, l
Maintenance Section engineers, and Maintenance Section craft personnel.
jg During the interview, cognizant individuals were asked if they had any knowledge of engineer (s) that disregarded the use of vendor manuals in the p j i j performance of preventive maintenance activities on CSSC equipment. They all replied, "no, not to their knowledge."
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!t ti Page 2 of 6 il di
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A review and ovaluation of the GCTF report was conducted. The findings lR3 of this report were foui.d to be correct and in full agreement with this evaluation.
Follow-up evaluation of the recommendations of GCTF report found.that:
l 1.
AI-23, should be revised to require stickers to be placed on I
certified vendor manuals by Vendor Manual Control stating, " Drawings l
l for Info Only." The evaluator verified that AI-23, was revised and IR3 incorporated the requirement that stickers stating, " Drawings for i
Info Only," will be placed on certified manuals by Vendor Manual l
Control.
I 2.
"AI-19 and SQM2 should be revised to add a statement that vendor i
i manuals be used, where applicable, when writing Workplans and l
Maintenance Requests on CSSC equipment." The evaluator verified lR3 that AI-19, was revised and incorporated the use of vendor manuals.
l However, SQM2 was reviewed and no statement referenced the use of I
vendor manuals.
I 3.
As recommended, implementing all changes to the Vendor Manual i
Program for NRC Generic Letter 83-28 should be completed before the March 1988 due date. The implementation of a Vendor Manual Control Program is currently in development by DNE.
Conclusions Concern IN-86-316-IO9 was not valid. The PMs reviewed showed no I
discrepancies in implementing the vendor manual control requirements lR3 of AI-23 and SQM57. Interviews with cognizant engineers and craft I
personnel found that to their knowledge no engineer (s) disregarded the l
use of vendor manuals in the performance of preventive maintenance I
activities. GCTF report found that " problems with engineers not using i
vendor manuals was not validated based on interviews with maintenance
-l 1
and modification craftworkers." This evaluation is in full agreement 1
with GCTF report findings. However, problems with the Vendor Manual l
Program previously identified by QA, in CAR SQ-86-01-004, are still open. l Efforts to incorporate requirements of NRC Generic Letter 83-28 into lR3 procedures are in progress at this time.
1 The identified problems with the Vendor Manual Control Program prior i
to the revision of AI-23 had the potential to be safety-related in l
the performance of preventive maintenance on CSSC equipment. However.
lR3 the review and evalution of 15 preventive maintenance instructions on l
CSSC equipment, found that the requirements from thc vendor manuals had l
been incorporated into those preventive maintenance instructions.
1
~
IV.
ROOT CAUSE Based on the findings that concern IN-86-316-X09 was not valid, there is no root cause.
e i
i Page 3 of 6
V.
GENERIC APPLICABILITY Concern IN-86-316-X09 is generic to all TVA nuclear sites because of the TVA-wide use of vendor manuals.
VI.
REFERENCES l
1.
10 CFR 50.49-1985 2.
SQA-174, 10 CFR 50.49, " List and Environmental Qualification Binder q
Control." Revision 0, dated November 18, 1985 l
3.
FSAR Sections 11.2.4, 11,3.4 4.
NRC - Generic Letter 83-28. Section 2.2, " Equipment Classification and Vendor Interface" (Programs for all safety-related components) dated July 8, 1983 5.
NQAN, Part 1. Section 6.2, " Vendor Manual Control " Revision 0 dated June 18, 1986 6.
AI-23. " Vendor Manual Control." Revision 22, dated July 30, 1986 l
7.
Area Plan 1707.03.04, " Vendor Manual Program," dated December 21, 1984 8.
SQN57. Preventive Maintenance Program, Revision 5, dated February 25, 1986 9.
NMEG Naintenance Review "Rxit Meeting at Sequoyah Nuclear Plant" dated July 29, 1986 S53-860805-256
-10. SQN INPO Report dated, April 1985 RINS L44 850816 803
- 12. Corrective Action Report (CAR) Number SQ-CAR-86-01-004, dated January 30, 1986 e
13.,NSRS Report I-85-788-WBN dated December 18, 1985 14.
Generic Concern Task Force (GCTF) Employee Concern Numbers IN-86-073-001, IN-86-073-002, IN-86-316-109, " Vendor Manual Control j
and Use," Revision 1 dated June 3, 1986 5
\\
I L
lk I
k
?
Page 4 of 6 t
1 15.
The following listed Preventive Maintenance (PMs), and Instruction Source Documents (Vendor Manuals) on CSSC equipment.
a.
FM number 1477-032 Revision 1
" Auxiliary Control Air Prefilter B-B Operation Maintenance Manual Contract 74C35-63630-1" b.
FM number 1588-062 Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge, PMP Westinghouse Letter, TVA-85-065," Dated April 4, 1985 c.
PM number 1589-062, Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge PMP Westinghouse Letter, TVA-85-065," dated April 4, 1985 d.
PM number 1590-062 Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge, PMP 1-PHP-062-108 SPD, INCR. Westinghouse Letter, TVA-85-065," dated April 4, 1985 e.
PM number 1591-062 Revision 0, " Lube Oil Pump and Couplings For Centrifugal Charge, PMP 2-PMP-062-108 SPD. INCR. Westinghouse Letter, TVA-85-065," dated April 4, 1985 f.
PM number 1609-077, Revision 0, " Waste Evaporator Feed Pump B" FSAR 11.2.4 g.
PM number 1607-077 Revision 0, " Waste Evaporator Feed Pump A" FSAR 11.2.4 h.
PM number 1610-077, Revision 0, " Auxiliary Waste Evaporator Feed Pump A" FSAR 11.2.4 1.
PM number 1612-077 Revision 1 " Waste Gas Compressor B" FSAR 11.3.4
PM number 1640-001, Revision 0, " Auxiliary Feedwater Pump Turbine, 1-TRB-001-0017" Vendor Manual Contract Number 92610"
, 1.
PM number 1640-001, Revision 0, " Auxiliary Feedwater Pump l
Turbine, 2-TRB-001-0017" Vendor Manual Contract Number 92610" m.
PM number 1642-032, Revision 0, " Auxiliary Control Air After Cooler A-A Ingersoll-Rand Instruction Manual-Contract Number 73C31-83582" n.
PM number 1643-032, Revision 0, " Auxiliary Control Air After Cooler A-A Ingersoll-Rand Instruction Manual-Contract Number 73C31-83582" l
l i
Page 5 of 6 e
1 u
o.
PM number 1633-043, Revision 0, "RCS Hot Legs HDR. CNTMT Isolation Valve 1-FCV-043-0022" Instruction Source Document PRO 1-85-249 16.
AI-25, Revision 15. " Drawing Control After Unit Licensing" (Part I) 17.
AI-19. Revision 18, "Plart Modifications After Licensing," approved July 7, 1986
/
18.
SQM2, Revision 19. " Standard Practice Maintenance Management System" VII. IMMEDIATE AND LONG-TERM CORRECTIVE ACTION 1.
Although no specific deficiencies with vendor manual information l
being included in PMs was found, additional findings indicate a IR3 potential need for enchancements in the area of clarity and details l
i of information. Item is being tracked by CATD 30802 SQN 01.
l 1
2.
Problems with the Vendor Manual Control Program have been previously i
identified by CAR SQ-CAR-86-01-004 and are being tracked by QA and DNE.
Site DNE has in development a Vendor Manual Control Program procedure to address equipment classification and vendor interface to ensure that vendor information for safety-related components are complete and in accordance with NRC Generic Letter 83-28 requirements. No further action is necessary.
- 3. GCTF report recommended that Standard Practice SQM2 be revised to l
add a statement that vendor manuals are to be used, where applicable, l
when writing workplans and maintenance requests on CSSC equipment.
lR3 This recommendation has not been completed.
Item is being tracked by l CATD 30802 SQN 02.
I i
)
i i
f b
i.
I I
Page 6 of 6
- = _ -
D Ri f f RT f1CE
- ECP5120J-ECPS121C TENNESSEE VALLEY AUTNORITY PAGE-IRIQUlriLY
- HLQULST OFFICE OF NUCLEAR PONER RUN TIME -
g Ofte - 155S - ElJM EMPLOYEE CONCER2 PROGRAM SYSTEM (ECPS)
RUN DATE -
LIST OF EMPLOYEE CONCERN INFORMATION-CATEGORY: OP PLANT OPER. SUPPORT SUBCATEGORY: 30802 PREVENTATIVE MAINTENANCE g
S GENERIC KEYHORD A H
APPL QTC/NSRS P
KEYWORD B C0!!CERN SUB R PLT BBSH INVESTIGATION S
CONCERN KEYWORD C flUMLER CAT CAT D LOC FLQB REPORT R
DESCRIPTION KEYWORD 0 IN 316-XO9 OP 30302 N HBN YYYY I-85-788-NBN NS TVA CANNOT HAVE A SAFE AND ADEQUATE PREVENTIVE MAIN T50168 REPORT PREVENTIVE MAINTENANCE PROGRAM IF EN GA PROGRAM GINEERING CONTINUES TO DISREGARD THE ENGINEERIiiC VENDOR'S MANUALS FOR SAFETY RELATED GENERAL EQUIPMENT. NUCLEAR P0HER CONCERN.
CI HAS NO FURTHER INFORMATION.
3 1 CottCERNS FOR CATEGORY OP SUBCATEGORY 30802 b
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ENCLOSURE 2 f
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SWEC-SQN-49 SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER:
0 TITLE: Employee Concerns Program REASON FOR REVISION: N/A SWEC
SUMMARY
STATEMENT: The items in this report were identified by the Nuclear Regulatory Commission (NRC) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report were verified to be adequately addressed.
PREPARATION PREPARED BY: %d Cub M0, alais SIGNnTURE '
DATE REVIEWS PEER:
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- SRP Secretary's signature denotes SRP concurrences are in files.
2242T l
TENNESSEE VALLEY AUTHORITY Q
WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG i.
Element
Title:
Employee Concerns Program i
SWEC Concern: A02860107013-001 A02851125014-001 i
Source Document: NRC Letters of November 19, 1985 l
and January 6, 1986
}
i Report Number: SWEC-SQN-49 f
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Evaluatoq:
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Lif 4 J. J. Knightly Date i
Reviewed By:
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Report SWEC-SQN-49 8
Employee Cancerns Program I.
INTRODUCTION Nuclear Regulatory Commission (NRC) letters of November 19, 1985 (reference 1) and January 6, 1986 (reference 2) communicated to TVA two concerns which were addressed as issues in the Stone & Webster Engineering Corporation (SWEC) systematic analysis, as follows:
A.
A02860107013-001, Possible harassment and intimidation by site supervision or management.
B.
A02851125014-001, Employee concerns program not adequately addressed in SQN Startup Readiness Plan.
Information on the background, the corrective actions taken, the verification methodology and analysis, the completion status, and any pertinent references are included in this report.
II.
VERIFICATION OF SWEC ISSUES A.
A02860107013-001, Possible Harassment and Intimidation
===1.
Background===
NRC Region II transmitted a letter (reference 2) to TVA January 6, 1986 stating that NRC had received allegations from Sequoyah reflecting concerns over reported acts of harassment and intimidation alleged to have been committed by a few members of supervision and site management. The employees told NRC that they had received "no-nevermind" responses from their supervision or management when the employees came forward with their concerns; that the employees were told not to go to NRC; and that it would be detrimental to their careers if they u d.
i 2.
Corrective Actions Taken a.
In order to improve employee trust and confidence as well as the overall effectiveness of the nuclear organization, TVA established an extensive Employee Concerns Program (ECP). A description was provided to the NRC May 2, 1986 (reference 3).
Program objectives and key elements of the program are described in Sequoyah's Nuclear Performance Plan (reference 4).
3.
Verification Methodology
.i The SWEC concern identified for Employee Concerns Task Group (ECTG) verification was stated as follows:
c' il Page 1 of 3
RIMS NUMBER ISSUE RIMS ITEM A0286107013 Existence of possible Acts of RIMS-001 Ilarassment and Intimidation by members of Site Supervision or Management.
ECTG reviewed the employee concerns program commitments from Sequoyah's Nuclear Performance Plan as the basis for this verification activity.
4.
Verification Status TVA has committed (reference 4) to establishment of a system in which employees can express concerns to nuclear management without fear or reprisal and with assurance that these concerns will be fully addressed. An Employee Concerns Program is in place at Sequoyah to help meet this commitment.
5.
Completion Status Sequoyah has committed to address and resolve all allegations of intimidation or harassment. The effective implementation of the Employee Concerns Program will close this SWEC issue.
B.
A02851125014-001, Need to resolve employee concerns before startup.
===1.
Background===
NRC's Washington, D.C. office stated (reference 1) that the SQN Startup Readiness Plan did not adequately address the Employee Concerns Program. TVA was requested to identify and address any safety-related concerns applicable to SQN before startup.
2.
Corrective Actions Taken The TVA response (reference 5) included the following descriptions and listing:
TVA's process of identifying potentially safety-related employee concerns.
TVA's process of reviewing concerns at one site for generic applicability to other sites.
The listing of " employee concerns specifically applicable to Sequoyah to be evaluated before restart "(enclosure 6 to reference 5).
3.
Verification Methodology The SWEC concern identified for ECTG verification was stated as follows:
Page 2 of 3
RIMS NUMBER ISSUE RIHS ITEM A02851125014 Employee concerns program was RIMS-001 not adequately addressed-no specific TVA words identify issues of significance nor provide justification for operation.
ECTG reviewed TVA-NRC correspondence related to the resolution of employee concerns before Sequoyah startup. This documentation review formed the basis for this verification activity.
4.
Verification Status b
SQN's startup readiness plan now adequately addresses the N
Employee Concerns Program. Safety-related concerns applicable 3{
to SQN before startup have been specifically identified, and are
.;3 in the process of investigation and resolution.
b-5.
Completion Status if jj The Employee Concerns Program is adequately addressed. This 1:
SWEC issue can be closed.
Sail III.
REFERENCES 3]
1.
NRC letter, "TVA's November 1, 1985, Response to September 17, 1985 4:
10 CFR 50.54(f) Letter," dated. November 19, 1985.
H. L. Thompson to J,j H. G. Parris
$1 jj 2.
NRC letter, " Allegations from Sequoyah Workers," dated jj January 6, 1986, J. N. Grace to C. C. Mason il!!
3.
TVA letter, "TVA Employee Concern Program " dated May 2, 1986,
('
S. A. White to V. Stello
.> i i
4,, Sequoyah Nuclear Performance Plan, dated June 17, 1986 1
i Iq 5.
TVA letter " Response to Hugh Thompson's letter dated C
November 19, 1985 (and other matters)," dated December 27, 1985, J. A. Domer to H. R. Denton 1
1 il I
l-a t
i Page 3 of 3 M.
TVA EMPLOYEE CONCERNS REPORT NUMBER: SVEC-SQN-58 SPECIAL PROGRAM REPORT TYPE:
Sequoyah Nuclear Plant Element REVISION NUMBER: 0 TITLE: ANI Inspection Report September 1985 REASON FOR REVISION:
SUMMARY
STATEMENT: The items in this report were identified by American Nuclear Insurers (ANI) and were included in the Stone & Webster Engineering Corporation (SWEC) systematic analysis. All items evaluated within this report are being adequately addressed and improvements have been made, however, some areas need further improvements, as noted in ANI report dated March 25-29, 1986.
PREPARATION PREPARED BY:
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SIGNATURE DATE REVIEWS PEER:
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SIGNATURE' DATE TAS-
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- DATE APPROVED BY-
/f-2-[d' N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) i l
- SRP Secretary's signature denotes SRP concurrences are in files.
2242T L
TENNESSEE VAttFY AUTHORIIY WATTS BAR NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OTHER SITES CEG
'l i.
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Element
Title:
Fire Protection Concerns j
SWEC Concerns:
L99851212025-001 1
1 Source Document:
ANI Inspection Report September 1985 1
]
Report Number:
SWEC-SQN-58 1
i
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Evaluator:
T[ Msg
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K. R. Gass Date g
Reviewed by:
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J. J. Knightly Cate Approved by:
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l SWEC-SQN-50 ANI Inspection Report September 1905 I.
INTRODUCTION An inspection by American Nuclear Insurers (ANI) covering the period of Saptember 24 thru 26, 1985, identified (reference 1) several conditions which were included in the Stone & Webster Engineering Corporation (SWCC) systematic analysis, as follows:
L99051212025-001 - Fire protection concerns, housekeeping, out-of-service waterspray systems, floor and wall penetrations unsealed.
Information on the background, corrective actions taken, verification L
methodology, verification analysis, completion status, and any pertinent h
references for the area of concern is included in this report.
II.
VERIFICATION OF SWEC ISSUE s
A.
Background
gi Lj ii The ANI inspector identified the following:
31 1.
Housekeeping conditions and/or combustibles control
- 1 il pl Several areas of the plant still continue to have poor Li housekeeping conditions and/or inadequate control of combustibles.
Immediate attention should be directed to the areas in order to improve the conditions.
Problem areas are:
1.
Railroad bay of Turbine Building (conditions improved but ll combustible storage still present).
'I
]
2.
North contral section on elevation 706 of unit 1 Turbine Building (combustible cardboard cartons containing g
j insulation still being stored).
.l 3.
Mechanical equipment room occupied by Electrical Maintenance
]
Section on elevation 669 in the southeast corner of the Unit
,)
2 Turbine Building (housekeeping condition and orderliness has worsened; smoking occurring in area).
1
]
4.
Titration room on elevation 690 of unit 1 Auxiliary Building
'I (combustibles noted during previous survey; conditions not i
verified this visit).
5.
Vent / purge air room on elevation 714 of unit 1 Auxiliary I
Building (combustibles noted during previous survey; conditions not verified this visit).
e I
l i
s Page 1 of 4 J
ht L
r 6.
Computer room on elevation 605 of Control Building (disorderly housekeeping noted during previous survey; conditions not verified this visit).
7.
"Old" hot tool room on elevation 669 of Auxiliary Building (extend automatic sprinklers).
8.
Switchgear Room on second floor of Service Building (conditions greatly improved; only a minimal amount of empty cardboard filing boxes remain).
9.
Telephone equipment room located on first floor office level of the Office and Power Stores Building (new area; poor housekeeping and smoking occurring).
'i 10.
Warehouse level of the Office and Power Stores Building (housekeeping improved to an acceptable level; smoking j
occurring and should be prohibited).
't 2.
Out-of-Service Waterspray Systems 1.
j.
Work should be expedited on the following fire protection systems to correct the noted deficiencies so that the systems can be placed in-service and/or automatic operation of the
)
extinguishing effectiveness of the system can be improved:
3j A.
Office and Power Stores Building preaction sprinkler and j
hose station.
t'\\j Correct sprinkler head obstructions; extend systems; o
- 1 complete circuitry.
i I
B.
Sprinkler system for Service Building.
i C.
Field Services Building preaction sprinkler systems.
3i D.
Addition to Emergency Diesel Generator Building foam-watar sprinkler system.
+
E.
Preaction sprinkler system for post accident sampling station rooms of Auxiliary Building.
}
5 F.
Sprinkler system for railroad bay of Auxiliary Building, elevation 714.
i.
G.
Hose station system for Domineralizer/ Worker Treatment il Building.
The recommendation for expedited work on the fire protection systems is identified as ANI recommendation 85-3.
l 3o i
Page 2 of 4
.i i
S
3.
Eloor and Wall ' Penetrations Unsealed Numerous other fire protection and loss prevention related deficiencies have been noted with the Office and Power Stores Duilding construction project.
Some of the items are unsealed floor and fire wall penetrations, inoperative fire doors, etc.
The Industrial Safety Staff has also performed an evaluation of the building deficiencies and has developed a list of the items. ANI will track the correction of the deficiencies by means of the safety staff's checklist.
B.
Corrective Action Taken 1.
Housekeeping Conditions and/or Combustibles Control The follow-up ANI report dated March 25-27, 1986 (reference 2),
noted a number of corrective actions or improvements.
General housekeeping throughout the plant was noted as improved over past conditions.
Areas where housekeeping and/or control of combustibles was in need of attention were:
Railroad bay of Turbine Building (condition improved but a
combustible storage still present).
Tool room storage in the southeast corner of the unit 2 Turbine Building on elevation 669'.
Computer room on elevation 685' of Control Building a
(disorderly housekeeping and excessive amounts of combustibles including paper storage).
Telephone equipment room located on second floor of the Office and Power Stores Duilding.
2.
Out of Service Waterspray Systems The extensive SQN corrective actions for the waterspray systems are outlined in the March 1986 ANI report (reference 2).
These l
corrective actions include the necessary evaluations, bid requests, schedules, and Design Change Requests to accomplish the scope of work described for the waterspray systems.
3.
Floor and Wall penetration Unsealed As stated in the ANI report dated September 24-26, 1986, ANI will track the correction of the deficiencies of the Office and Power Stores Building by means of the safety staff checklist.
The safety staff stated to Employee Concerns Task Group (ECTG) that following correction of the floor and wall penetration seals, procedures will be developed to periodically inspect and/or test all penetrations.
Page 3 of 4 L_
J l
I C.
Verification Meth_ojiglogy.
The SWEC concern identified for LCTG verification were stated as follows:
R3MS Number Issuo RIMS Item L99851212025 Fire Protection Concerns, Housekeeping, RIMS-001 Out of Service Waterspray Systems, Floor
& Wall Penetration Unsealed (Need Item by Item Closcout with ANI)
ECTG interviewed safety staff personnel and reviewed the SQN master files for internal and external correspondence related to this issue.
This review of the pertinent documentation formed the basis for this verification activity.
D.
Verification Analysis The ECTG review indicated that general housekeeping throughout the plant has improved. Control of combustibles is still in need of attention in some areas. Corrective action for out-of-service waterspray systems has been initiated.
Deficiencies have been evaluated in order to obtain bids for correcting unsealed floor and wall penetrations.
E.
Completion Status The SWEC issue is in process of being addressed by TVA and SQN.
Upon implementation of the corrective actions in this area, the SWEC issue will be complete and ready for closure.
III.
REFERENCES 1.
American Nuclear Insurers, Insurance Inspection Report, dated
., September 24-26, 1985, by:
D. W. Eaves, Property File No. N-229 2.
American Nuclear Insurers, Insurance Inspection Report, dated March 25-27, 1986, by:
D. W. Eaves, Property File No. N-229 Page 4 of 4
TVA EMPLOYEE CONCERNS REPORT NUMBER: I-85-346-SQN SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 0 TITLE: QC Holdpoint Signoff Violation REASON FOR REVISION:
N/A k
r E
SUMMARY
STATEMENT: N/A f4m h:
+
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PREPARED BY:
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Original Signed By R. M. Bateman 11-06-86 SIGNATURE DATE g
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b Original Signed By J. E. Rose 11-06-86 2
SIGNATURE DATE a
b TA 8 TECHNICAL REVIEW O hk
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Original Signed By N
CEG-H: J. F. Lewis for LEM 11-25-86 SRP:
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SIGNATURE
- DATE SIGNATURE DATE APPROVED BY:
dih N/A h 84 ECSPMANAGF/
DATE MANAGER OF NUCLEAR POWER DATE
~ -
CONCURRENCE (FINAL REPORT ONLY) 4
- SRP Secretary's signature denotes SRP concurrences are in files.
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WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS s
DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMARY
OF WP ENGINEERING EVALUATION 2
~
CONCERN CONSIDERED: XX-85-054-001 h
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, DNC, WP REVIEWED BY
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REVIEWED BY M
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REVIEWED BY A2 m a /
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1 This pact: age eummarizec the actions t al en b'/ the Helding Project (WP) to
(:
1 evaluate and ditposition the subject SON-cpecific employee concern which was previously evaluated by flSRS/DTC/ERT and cummarized in WP Phase I and Phase II j#
reports.
i The Welding Project analy ed each SON-specific employee concern (Attachment 2) s il 9
to determine the statement (s) being voiced by these individuals.
~
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D>
- g These statement were then evaluated both individually and collectively to
>e develop issues, il b
Each issue was then incorportated into the WP review activities of Phase I,
s J
" Procedural Assessment" and Phase II, " Procedural Implementation."
y D'br #1ng Phase I, each issue was analyzed against requirements of the applicable
%[
OA program, policies, NSRS/QTC/ERT Investigation Reports, and other relevant k
(
information to determine if program elements were deficient when evaluated V
against upper tier requirements.
1 Phase II consisted of a sample reinspection of hardware and independent i
program audit by Bechtel.
In each area analy:ed by Bechtel, the auditors found no objective evidence to cubstantiate the employee concerns considered. The following areas directly related to employee concern were investigated by the audit team:
0337I Page 1 of 3 1
l i
1.
Welder qualification and attendant records 2.
Welder qualification and attendant on-the-job-training 3.
Welding inspections
- )
4.
Welding inspectors training programs
.i f
5.
Weld material traceability l4 3
6.
Welding inspections by craft personnel 1.
3i j
7.
Weld material control i
..s.
~1 j
Each of these areas was investigated by the auditors for both construction and 1
operations phases.
In all cases, there was no objective evidence to
{
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substantiate the employee concerns. The audit report concludes that both
.A
}
construction and operations phases have had and now have a functioning Welding
- l Quality Assurance Program which meets code, standard, and regulatory
-V r.
{
requirements and that the employee concerns considered were found to be
')
,?
unsubstantiated and without technical merit.
ll'i i
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l' Page 2 of 3 J
0337I h
The results of the reinspection program at SQN also give another, additional j
f verification of the Welding Quality Assurance Program for both construction and operations phases and serve to establish additional confidence in the accuracy and implementation of these programs through hardware inspections and attendant document reviews. In all cases, the components and items were found to be acceptable upon initial reinspection or found to be acceptable after engineering analysis.
The WP analysis of SQN Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed components and systems, and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacies in the welding programs for either the construction or operations phase at SQN which have been directly identified through the Employee Concern Program. The Employee Concern Program has simply j
reiterated problems which have been or are now being resolved through existing corrective action programs in the overall Nuclear Quality Assurance Program.
1 l
A summary analysis of the WP evaluations and recommendations is included in u
I i
($
Page 3 of 3 0337I
-~
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)
Page 1 of 3
/
SUMMARY
OF SQN SPECIFIC EMPLOYEE CONCERNS REVIEWED BY WELDING PROJECT EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XX-85-088-003 Alterations to Welder Not substantiated by ERT Qualification Records in Report XX-85-088-003 of Knoxville 3/8/86 (Attachment 3).
XX-85-124-001 Burial of Electrode Stubs Not safety-related. No action required.
XX-85-086-003 Box Anchor Design Substantiated by NSRS Report Deficiency.
I-85-560-SQN (Attachment 3).
WP concurs with report recommendations.
XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS Rejected NDE Items Esport I-85-738-SQN (Attach-
~~
ment 3).
WP concurs with 1
report recommendations.
?
SQM-5-001-001 Uncertified Welder Foreman Substantiated by WP Evaluation i
SQM-5-001-002 Performing Preweld Report WP-16-SQN (Attachment i
WBM-5-001-002 Inspections 3).
Interim corrective (Also Listed in actions are boine the Generic formulated.
.re is Summary) based on theco actions.
Additional corrective actions may be implemented.
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS Piece REPORT I-85-636-SQN (Attachment 3).
XX-85-069-001 Inadequate OJT-Records for The general issue of XX-85-069-001-R1 ISI and QC Personnel for N0 inadequate OJT-records was XX-85-069-X05 substantiated by NSRS Report XX-85-069-007 I-85-373-NPS (Attachment 3).
No falsification of records was substantiated.
WP con-
~
curs with report recommen-dations.
05640 i
At achment 1 Page 2 of 3
[
EMPLOYEE CONCERN NUMBER ISSUE WP ACTION SQM-6-005-001 Craft Welder Incapable of SQM-6-005-001 was SQM-6-005-X02 Making Proper Welds substantiated; SQM-6-005-X02 was not substantiated by NSRS Report I-86-115-SQN (Attach-ment 3).
WP concurs with report.
XX-85-013-001 E309 Electrode Used to Weld This is an acceptable E316 Steels practice. ERT investigated in ERT Report XX-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
XX-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
f.
N, XX-85-049-001 Welder Certifications XX-85-049-001 was XX-85-049-%03 Updated Without Meeting substantiated as it relates Requirements to Welder Continuity Require-ments. This had previously been identified by NO in an audit. XX-85-049-X03 was not substantiated. Details and recommendations are given in NSRS Report I-85-135-SQN (Attachment 3).
WP concurs with I-85-135-SQN-01 through
-03 and recommends they be closed based on the WP-Bechtel Audit of SQN in Key Elements 4.0, 5.0, and 17.0 (Attachment 4).
XX-85-054-001 QC Holdpoint Sign-Off Not substantiated by NSRS Violation Report I-85-346-SQN (Attachment 3).
XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS Inspections Report I 'J5-750-SQN (Attachment 3).
05640
Page 3 of 3 EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XX-85-083-001-SQN Weld Inspections not as Not substantiated by NSRS Strict as WBN Report I-85-652-SQN (Attachment 3).
XX-85-098-001 Laminated Pipe in Unit 2 Not safety-related. Not Condenser. This issue is substantiated by WP Evaluation also on the Generic Summary Report WP-18-SQN (Attachment 3).
XX-85-100-001 Improper Weld Repair on an Not substantiated by ERT Undetermined Number of Report XX-85-100-001, dated Welds 3/5/86 (Attachment 3).
XX-85-101-006 Welder Certification for ERT Report XX-85-101-006 n
the Construction Era (Attachment 3) with NSRS Recommendations indicates U
that this concern is sub-FI[
stantiated. WP takes excep-(".
tion to this ERT Report-based on subsequent information provided in Attachment 4.
WP exceptions, recommen-dations, and basis for
(;
closure were discussed with NSRS as documented in Attach-ment ?.
WP recommends this concern not be substantiated
[l and that it be closed based on the WP-Bechtel Implemen-j tation Audit, Key Elements 1.
4.0, 5.0, 17.0 (Attachment 6).
k XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS Notice of Indications for Report I-85-735-SQN 1;
Preservice-Related Defects (Attachment 3).
h XX-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS XX-85-108-002 Report I-85-776-SQN (Attachment 3).
y f4 05640 I_.
I:
Page 1 of 1 10/16/86 (EMPLOYEE CONCERNS) 12:57:22 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10
CONCERN-------
S 1
NSRS SR XX-85-054-001 WORDS:
INSPECTION IMPLEMENTATION DOCUMENT HD PT PROB: WCPIF L
SEQUOYAH-OC HOLDPOINTS ARE SIGNED OFF BY CRAFTSMEN (CRAFT KNOWN) PER-FORMING THE WORK.
PERSONAL FRIENDSHIP.BETWEEN INSPECTORS & CRAFT ALLOW THIS TO OCCUR WITHOUT BEING REPORTED.
TIME FRAME IS BETWEEN 1979 TO 1984 NO SPECIFICS PROVIDED.
IR: 1-85-346-SON STAT:
RC:
TECHNICAL COMMENTARY:
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WEl. DING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS
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ATTACHMENT 3 l
NSRS REPORT I-85-346-SQN t
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I.. *I TEl STAT S GOVElt 13f ENT TMemorandum TENNESSEE VALLEY AUTHORITY TO
!!. L. Abercrombio, Site Director, Sequoyah Nuclear Plant FROM K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K
- NOV 2 9 G85 DATE
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSMITTAL Transmitted herein is NSRS Report No.
I-85-346-SON Subject OC HOLDPOINT SIGNOFF VIOLATION Concern No.
XX-85-054-001 No response or corrective action is required for this report.
It is being transmitted to you for information purposes only.
Should.you have any questions, please coranct R. C.
Sauer at telephone 2277 U
q Recommend Reportability Determination: Yes No X
N 7
c&
d Director, NSRS/Designec
- s RCS:JTH
- i Attachment cc (Attachment):
1 j
G. B. Kirk, SQN ij R. C. Parker, LPAN44A-C j
QTC/ERT, Watts Bar Nuclear Plant 1j J. H. Sullivan, SQN j
W. F. Willis, E12B16 C-K (4)
..J l
s 1:
- i.
!n w
'l i
al Buy l!.S. Savings Bonds Regularly on the Payroll Savings Plan s!!
.=
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