ML20214G970
| ML20214G970 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 12/09/1985 |
| From: | Breeding C, Kidd M, Sauer R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082840729 | List: |
| References | |
| I-85-636-SQN, NUDOCS 8605290573 | |
| Download: ML20214G970 (18) | |
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TENNESSEE VALLEY AUTHORITY l
NUCLEAR SAFETY REVIEW STAFF NSRS INVESTIGATION REPORT NO. I-85-636-SQN 1
EMPLOYEE CONCERN:
XX-85-068-007 s
SUBJECT:
TVA MANUFACTURE OF A DRAVO ASME-CLASS SPOOL PIE.CE DATES OF INVESTIGATION:
OCTOBER 8 - NOVEMBER 21, 1985 I
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STIGATOR:
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/A 4 f 3 C. L. BREEDING DAiE #
REVIEWED BY:
R. C. SAUER DATE 3
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APPROVED BY:
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~ h M.gS/ KIDD DATE /
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BACKGROU!ID A Nuclear Safety Review Staff (NSRS) investigation was conducted to determine the validity of an expressed employee concern 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 XX-85-068-007, stated:
"Sequoyah - TVA may have manufactured a spool piece to replace, under ASME Section XI, a DRAVO ASME-class spool piece. When the spool piece was replaced, the Code nameplate from the DRAVO spool piece was removed, and affixed to the TVA manufactured spool. This may have been noted by a cognizant inspection individual (position unknown), and not reported due to the individual not wanting
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to get involved."
I The ERT followup group was contacted for further details and information. None was available because they received this concern from j
an anonymous telephone call, j
II.
SCOPE
.l A.
The scope of this investigation as determined from the stated concern to be that of four issues requiring investigation.
.1 1.
TVA may have manufactured an ASME Section II spool piece.
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2.
TVA replaced a DRAVO spool piece with TVA manufactured spool I
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piece.
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3.
The code nameplate was moved from the DRAVO piece to the TVA l
- piece, i
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TVA inspector may have been aware of switch but did not report it.
B.
The concern did not specify the location or equipment or piping that is of concern; therefore, a search was made for all DRAVO pipe supplied to Sequoyah. Also, the concern mentioned the ASME code used for the inservice inspection of nuclear power plant components; therefore, the requirements of this code for the Sequoyah plant were 3
researched. The ability of TVA to manufacture spool pieces was also
'l investigated.
III.
SUMMARY
OF FINDINGS A.
Requirements and Commitments 1.
10CFR50, Appendix A, General Design Critorion 1, " Quality Standards and Records," requires that structures, systems, and components important to safety be designed, fabricated, crocted, and tested to quality standards commensurate with the importance
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of safety functions to be performed.
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2.
10CFR50.55a " Codes and Standards," requires that components of the reactor coolant pressure boundary be designed, fabricated, erected, and tested in accordance with the requirements for class 1 components of section III of the ASME Boiler and Pressure Vessel Code or equivalent quality standards.
This requirement went into ef fect for nuclear plants with construc-tion permits submitted after January 1, 1975.
Sequoyah had already received a construction permit.
3.
The original design of Sequoyah was in accordance with ANSI B31.1 code for power piping with installation and inspection to ANSI B31.7.
Additions and modifications at Sequoyah were made in accordance witn the ASME code after April 1973 as stated in Sequoyah Nuclear Plant Design Criteria Manual, SQN-DC-V-3.0,
" General Design Criteria for the Classification of Piping, i
Pumps, Valves, and Vessels," table 3.1-2.
This table lists the code requirements for the plant design and their related TVA safety class.
4.
The TVA Nuclear Quality Assurance Manual (NQAM), Part II, Section 2.3, revision 8/20/84, establishes controls to assure that repairs and replacements of ASME Section XI components are performed in accordance with ASME Section XI. IWA-4000 and IWA-7000, requirements.
t 5.
TVA Construction Specification N2G-877, " Identification of Structures, Systems, and Components Covered by the Sequoyah Nuclear Plant Quality Assurance Program," requires certified material test reports (CMTRs), material traceability, and inspection documentation for Quality Level I materials.
6.
The TVA Division of Nuclear Power Procedure DPM-N76A10, revised September 28, 1984, " Purchase Specifications for CSSC Metallic.
Wire, and Cable Used Inside Primary Containment, Welding, and Brazing Materials, Valve Parts, and Pump Parts," specifies the
" Code of Record," for Sequoyah.
The code listed is ANSI
, B31.7-1971 Addenda.
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7.
Sequoyah Nuclear Plant Standard Practice SQA162, " Purchase Specifications for CSSC Materials," also lists ANSI B31.7 as the
" Code of Record."
B.
Findinns 1.
TVA has manufactured spool pieces at Sequoyah.
Spool pieces are generally pipes, but sometimes the term " spool piece" is used for a pipe with flanges on each end that can be bolted into place.
To manufacture one requires that a longer pipe be cut (thereby yielding two spool pieces) and flanges be welded on to make it a bolt-in " spool picco." TVA does this type of work i
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in compliance with ANSI B31.1 and B31.7 the " Codes of Record" for the plant.
Fabricating pipe pieces to replace worn out, damaged, or otherwise unsuitabic pipe is a normal part of operating and maintaining a power plant.
A scarch of the maintenance records for spool pieces f abricated at Sequoyah was made.
Several have been produced since the plant went into operation.
A detailed review of the maintenance requests and inspection reports for four examples of this work was made.
Maintenance requests for the fabrication of spool pieces in the component cooling system (MR 0654546), water treatment system (MR A049809), Auxiliary Feedwater System (MR A237954), and Reactor Coolant Pump Motor oil cooler (MR A299465) were reviewed along with the QA inspection reports of this work (refs. 14-17).
No deviations from TVA procedures or code requirements were found.
2.
No record of any DRAVO spool pieces having been delivered can be found at Sequoyah.
DRAVO was contacted, and they ha've no record of supplying any spool pieces to Sequoyah.
TVA records at the site and in the Chattanooga central offices show no contracts with DRAVO for pipe or spool pieces.
3.
Spool pieces do not normally have ASME nameplates affixed.
Nameplates are used on pressure vessels and other pressure containing devices but not on pieces of pipe. Most of the IS' pressure vessels, piping, and other equipment at Sequoyah was designed and procured under the ANSI B31.1 code that did not v,
require nameplates.
Therefore, it is unlikely that a nameplate could have been moved since almost none exist at Sequoyah and there is no requirement for a nameplate on a new piece of pipe.
Some of the spool pieces fabricated at Sequoyah were for temporary service such as flood mode croscties or nitrogen filling of steam generators.
These temporary spool pieces are often reused and are labeled when built so they can be identified when needed.
4.'
It is permissible, even required in some cases, for the pipe identification number (the heat number) to be transferred from t
the original pipe to any spool piece cut from that pipe.
An I*
inspector is required to witness this activity.
It is possible that an observer of this activity could have misconstrued the transfer of heat numbers to be the moving of a nameplate.
i IV.
CONCLUSIONS AND RECOMMENDATIONS 1
l A.
This employee concern is not substantiated for the following reasons:
1.
No evidence of DRAVO spool pieces could be found at Sequoyah, and no record of their purchase was found.
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2.
Even though TVA does manufacture spool pieces for repair, ll I,
replacement, or modification of plant piping systems, there 1
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could have been no exchange with DRAVO.
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Code nameplates are not required at Sequoyah; therefore, the concern about any removal or attachment is not valid. No evidence of such activity was found in this investigation.
4.
Inspection personnel at Sequoyah are familiar with the requirements for spool piece manufacture and know that nameplates are not required. There would, therefore, be no reason for an inspector to report an activity that did not violate a requirement or procedure.
B.
This concern appears to have resulted from a' misconception or misunderstanding of the requirements for producing spool pieces at Sequoyah.
It is possible that an observec misconstrued the transfer of piping heat numbers to be the transfer of a nameplate. No action at Sequoyah is required.
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DOCUMENTS REVIEWED IN INVESTICATION 1-85-636-SQN
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AND REFERENCES i
1.
ASME Doiler and Pressure Vessel Code,Section XI Article IWA-7000, IWA-4000, and Section III 2.
10CFR Part 50. Appendix A, General Design Criterion 1, " Quality Standards and Records" 3.
ANSI B31.1 - 1971 Addenda,~" Power Piping" 4.
ANSI B31.7 - 1971 Addenda, " Nuclear Power Piping" 5.
UQAM Part II, Section 2.3, Revision 8/20/84, " Repairs and Replacement of ASME Section XI Components" 6.
TVA Construction Specification N2G-877, " Identification of Structures, Systems, and Components Covered by the Sequoyah Nuclear Plant Quality Assurance Program," revised May 3, 1985 7.
TVA Construction Specification U2M-865, " Field Fabrication, Assembly Examination, and Tests for Pipe and Duct Systems" 8.
Division of Nuclear Power, Division Procedure DPM-U76A10, Revised September 28, 1984, " Purchase Specifications for CSSC Metallic Wire and Cable Used Inside Primary Containment, Welding and Brazing Materials, Valve Parts, and Pump Parts" s~
9.
Sequoyah Nuclear Plant Standard Practice SQA162, " Purchase Specifications l
for CSSC Material," dated October 9, 1905, Rev. O j
10.
U.S. NRC Regulatory Guide 1.26, Rev. 3, dated February 1976, " Quality Group Classifications and Standards for Water, Steam, and I
Radioactive Waste-Containing Components of Nuclear Power Plants" 11.
Sequoyah Nuclear Plant Design Criteria Manual, SQN-DC-V-3.0, " General Design Criteria for the Classification of Piping, Pumps, Valvec, and Vessels" i
12.
SNP Construction Procedure No. P-34, " Heat Number Validation," revised December 12, 1978 l
13.
Sequoyah FSAR, Chapter 3 14.
MR 064546, dated January 8, 1981, " Fabricate Spool Piece for the I
Component Cooling System" 15.
MR A049809, dated January 13, 1982, " Fabricate and Install Spool Piece for Train A DI," for Water Treatment System l
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MR A0237954, dated August 15, 1984, "1-PIPC-003, Rework to Venturi :: pool Section to Match Length of Cavitating Venturi ::ections," for the Auxiliary Feedwater System 17.
- MR A299465, dated September 20, 1985, "1-068, Fabricate Spool Piece for No. 1 RCPM 0.1 Cooler," for the Reactor Coolant Pump Motor Oil Cooler l
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TVA EMPLOYEE CONCERNS REPORT NUMBER: I-85-652-SQN SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 0 TITLE: Sequoyah Weld Inspections Not As Strict As Watts Bar REASON FOR REVISION: N/A SWEC
SUMMARY
STATEMENT: N/A PREPARATION PREPARED BY:
Original Signed By R. M. Bateman 11-06-86 SIGNATURE DATE REVIEWS PEER:
Original Signed By J. E. Rose 11-06-86 SIGNATURE DATE TA :
F TECHNICAL REVIEW ONLY WW
$ $ // W N/o/G SIGNATURE DATE f
CONCURRENCES Original Signed By CEG-H: J. F. Lewis for LEM 11-25-86
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SRP:
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SIGNATURE
- DATE I
SIGNATURE DATE APPROVED BY:
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ECSP HANGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Socratary's signaturo denotos SRP concurrencos are in filos.
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_SQN SPECIFIC EMPLOYEE CONCERNS DATE 11/6/86 SU4 JECT: SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMARY
OF WP ENGINEERING EVALUATION CONCERN CONSIDERED: XX-85-083-001 Il/b/dibt.
. DNC, WP PREPARED BY i
REVIEWED BY(
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, DQA, WP REVIEWED BY 4
v REVIEWED BY,herwis/ W bunk n/9 s /gb J 's p i ); m, CEG-H, Weldins APPROVED BY ON
/ I*I' b, Program Manager C
06470
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This paci. age nummarice:
- t. h e actiont
- t. a l.e n b '/ the Welding Froject (WP) to evaluate and dispocition thc subJuct SON-specific employee concern which was previously evaluated by NSR3/DTC/ERT and summarined in WP Phase I and Phace II reports.
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The Wolding Project analy:ed each SON-specific employee concern (Attachment C) i to determine the statement (s) being voiced by these individuals.
These statement were then evaluated both individually and collectively to develop issues.
Each issue was then incorportated into the WP review activities of Fhase I, pcodural Assessment" and Phase II, " Procedural Implementation."
.t During Phase I, each issue was analy:cd against requirements of the applicable OA program, policies, NSRS/QTC/ERT Investigation Reports, and other relevant 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
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program audit by 9echtel.
In each area analy:cd by Bechtel, the auditors found no objective evidence to substantiate the employee concerns considered. The following areas directly related to employee concern were investigated by the audit team g7,'*,71 Page 1 of 3 lk /
1.
Welder qualification and attendant records E.
2.
Welder qualification and atter. dant on-the-job-training 3.
Welding inspections 4.
Welding inspectors training programs 5.
Wald material traceability P
6.
Welding inspections by craft personnel i!
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Weld material control
[i Each of these areas was investigated by the auditors for both construction and Ei operations phases.
In all cases, there was no objectivo evidenco to
- .1 substantiate the employee concerns. The audit report concludes that both i
construction and operations phases have had and now have a functioning Welding l4 Quality Assuranco Program which meets code, standard, and regulatory j
i requirements and that the employeo concerns considered were found to be l
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unsubstantiated and without technical merit.
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The results of the reinspection program at SQN also give another, additional
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verification of the Wolding Quality Assuranco 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 casos, the components and items woro found to be acceptable upon initial reinspection or found to be acceptable after engineering analysis.
The WP analysis of SQN Specific Employeo Concerns supplemented by the indcpondent Dechtel Audit, reinspection of installed components and systems, l
and independent (NSRS) overview and investigations has not revealed any significant or generic inadoquacios in the wolding proscams for either the construction or operations phase at SQN which have bocn directly identified
. 3 through the Employco Concern Program.
The Employco Concern Program has simply
- :,r reiterated problems which have been or are now boing resolved through existing correctivo action programs in the overall Nuclear Quality Assurance Program.
A summary analysis of the WP ovaluations and recommendations is includod in.
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Pago 3 of 3 37 I
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).
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WP concurs with report recommendations.
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XX-85-069-003-R1 Acceptance of Previously Not Substantiated by NSRS I
Rejected NDE Items Report I-85-738-SQN (Attach-I
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ment 3).
WP concurs with j
report recommendations, e
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SQM-5-001-001 Uncertified Welder Foroman Substantiated by WP Evaluation 1
SQM-5-001-002 Performing Proweld Roport WP-16-SQN (Attachment i
WDM-5-001-002 Inspections 3).
Interim corrective (Also Listed in actions are being the Generic formulated.
Closure is Summary) based on these actions.
l Additional corrective actions may be implemented, k
XX-85-068-007 Manufacture of Dravo Spool Not substantiated by NSRS 1
Pieco REPORT I-85-636-SQN I
(Attachment 3).
1 0
XX-85-069-001 Inadoquate OJT-Rocords for The 60neral issue of j
XX-85-069-001-R1 ISI and QC Personnel for NO inadoquate OJT-records was f
XX-85-069-X05 substantiated by NSRS Report XX-85-069-007 I-85-373-NPS (Attachment 3).
5 No falsification of records was substantiated. WP con-
'j curs with report recommon-3 dations.
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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-mont 3).
WP concurs with
- report, XX-85-013-001 E309 Electrode Used to Weld This is an acceptable r
E316 Steels practico.
ERT investigated in ERT Report XX-85-013-001, dated 3/22/85 (Attachment 3).
WP concurs.
XX-85-041-001 Improper Wold Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
f.
XX-85-049-001 Wolder Certifications XX-85-049-001 was i
XX-85-049-X03 Updated Without Meeting substantiated as it relates Requirements to Welder Continuity Requiro-monts. This had previously i
been identified by NO in an i
audit. XX-85-049-XO3 was not substantiated.
Details and recommendations are given in NSRS Report I-85-135-SQN (Attachment 3).
WP concurs i
With I-85-135-SQN-01 through l
-03 and recommends they be j
closed based on the WP-Dechtel Audit of SQN in J.
Key Elements 4.0, 5.0, and
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17.0 (Attachment 4).
I Jl XX-85-054-001 QC lloldpoint Sign-Off Not substantiated by NSRS
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Violation Report I-85-346-SQN
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(Attachmont 3).
i XX-85-065-001 Performance of Remoto Visual Not substantiated by NSRS Inspections Report I-85-750-SQN (Attachment 3).
W 05640
Pat,e 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 Pipo in Unit 2 Not safety-related. Not Condensor. This issue is spbstantiated by WP Evaluation also on the Generic Summary Report WP-18-SQN (Attachment 3).
XX-85-100-001 Improper Wold Repair on an Not substantiated by ERT Undetermined Number of Report XX-85-100-001, dated Wolds 3/5/86 (Attachment 3).
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XX-85-101-006 Welder Certification for ERT Report XX-85-101-006 I
the Construction Era (Attachment 3) with NSRS f
Recommendations indicates that this concern is sub-j fr
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stantiated. WP takes excep-tion to this ERT Report based on subsequent information provided in Attachment 4.
WP oxceptions, recommon-dations, and basis for closure woro discussed with NSRS as documented in Attach-3 ment 5.
WP recommends this concern not be substantiated and that it be closed based j
on the WP-Bechtel Impicmen-tation Audit, Key Elements 4.0, 5.0, 17.0 (Attachmont 6).
i XX-85-102-011 NDE Inspectors Cannot Writo Not substantiated by NSRS j
Notico of Indications for Report I-85-735-SQN 4
Prosorvice-Related Dorocts (Attachment 3).
j XX-85-108-001 Socket Wolds Not Inspected Not substantiated by NSRS XX-85-108-002 Report I-85-776-SQN (Attachment 3).
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10/16/86 (EMPLOYEE CONCERMS) i 12:58t42 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN-------
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NSRS P2 SR XX-85-083-001 WORDSt INSPECTION PROGRAM CRITERIA DIFFER PROB: WCDPW SEQUOYAH: INDIVIDUAL EXPRESSED THAT DURING PREVIOUS EMPLOYMENT AT SEQUOYAH, WELDING IfJSPECTION WAS NOT AS STRICT AS IT IS AT WBNP. THE CONCERN IS THAT EITHER SEQUOYAH WAS NOT PROPERLY INSPECTED, OR THAT WBNP IS EXCESSIVELY IN-SPECTED, AND UNDULY INCREASES THE COST OF WELDING. Cl HAS NO FURTHER INFORMATION.
IR: I-85 652-SON STAT:
RC:
TECHNICAL COMMENTARY:
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I WEl, DING PROJECT SQN SPECIFIC EMPt/YEC CONCERNS ATTACHMENT 3 N3RS REPORT I-85-652-SQN hk 1
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i exerto sTm:s imen.s.uxr Memorandum Texxesses vatter acrnonirr l
TO
- H. L. Abercrombio Sito Director. Sequoyah Nucicar Plant FROM
- K. W. Whitt, Director of Nuclear Safety Review Staff E3A8 C-K j
- DEC 1 3 1985 DATE SJBJECT: NUCLEAR SAFETY F IEW STAFF INVESTICATION REPORT TRANSMITTAL Transitted heroin is NS23 Report No.
I-85-652-SON i
l Subjnct ' FOUOYAH WELD lilSPECTIONS NOT AS STRICT AS WATTS BAR l
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Concern No.
XX-85-083-001 i
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No response or corrective action is required for this report.
It is j
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being transmitted to you for information purposes only.
Should you have i
l any questions, please contact R. C. Sauer at telephone 2277
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1 Recommend Reportability Determination:
Yes No X I
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9ector, NSRS/Designe P
/ftachment cc (Attachment):
j R. P. Denise, LP6N35A-C R. J. Griffin, SQN E-10 j
j G. B. Kirk, SQN 1
D. R. Nichoin. E10A14 C-K QTC/ERT, Watto Dar Nuclear Plant f
Eric Cliger, LP6N48A-C
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i J. H. Sullivan, SQN t
W. F. Willis, E12B16 C-K (4) l Y
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