ML20214G973
| ML20214G973 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 12/11/1985 |
| From: | Harwell E, Kidd M, Sauer R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082840729 | List: |
| References | |
| I-85-735-SQN, NUDOCS 8605290597 | |
| Download: ML20214G973 (14) | |
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f TENNESSEE VALLEY AUTHORITY I-NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. I-85-735-SQN i
EMPLOYEE CONCERN: II-85-102-011 F
SUBJECT:
NDE INSPECTORS CANNOT WRITE NOTICE OF INDICATION FOR PRESERVICE-RELATED DEFECTS DATES OF INVESTICATION:
OCTOBER 25 - NOVEMBER 5, 1985
/3 8I INVESTICATOR:
E. F. HARWELL DARE /
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REVIEWED BY:
C R. C. SAUER DATE APPROVED BY:
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BACKGROUND A Nuclear 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 Assign-ment Request Form from QTC and identified as II-85-102-001, stated:
"Sequoyah:
NDE inspectors can only write a Notice of Inspection (correction:
Indication) on in-service related defects. Pre-service related defects can only be identified by a Maintenance Request. Nuclear Power Dept. concern."
II. SCOPE A.
The scope of the investigation was determined from the stated concern of record to be two specific issues requiring investi-gation:
1.
NDE inspectors report service-related defects only on Notices of Indication (NOI).
i 2.
Preservice defects are reported only on a Maintenance Request (MR).
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B.
In conducting this investigation NSRS reviewed the requirements of the Nuclear Quality Assurance Manual (NQAM), plant surveil-lance instructions, and plant instructions which govern defect reporting. Nuclear Central Office ISI group managers and level i
III's, plant QC section supervisors, and Power Operations Train-1 ing Center (POTC) NDE trainers were interviewed concerning the
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training, instructions, and practices of NDE inspectors on j
reporting defects. NSRS also reviewed random samples of NOI's generated during the present (Environmental Qualification) out-age.
III.SUNMARY OF FINDINGS A.
Requirements and Commitments 1.
ASME Section II, " Rules for Inservi.ce Inspection of Nuclear P
Power Plant Components."
2.
Title 10 Code of Federal Regulations Part 50, " Domestic Licensing of Production and Utilization Facilities."
.i 3.
NQAM, Part II, Section 5.1, " Inservice Inspection - Nuclear Power Plant Components."
l 4.
NQAM, Part II, Section 5.3, " Maintenance and Modification
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Inspection Program."
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B.
Findings e
1.
Part II, Section 5.1, of the NQAM (ref. 1) requires an NOI be written if a defect is found in the examination area for both preservice and inservice examinations.
2.
Individuals A and C stated in their interview that ISI inspectors are instructed to prepare NOIs for either pre-service or inservice inspection detected defects that are found within the scope of the examination area. However, if an inspector finds the examination area is not ready for inspection (i.e., needs polishing or grinding) he does not perform the inspection, but prepares an MR to have the area properly prepared for subsequent inspection.
If a defect (i.e., are strike) is found which is outside the scope of the examination area, is obviously not a service-related flaw and can be readily corrected, the inspectors are instructed to prepare an MR.
The inspectors are instructed
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to notify their supervisor if significant items are found j
outside the examination area and the reporting is done via l
other nonconforming condition reporting methods.
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3.
Individual D stated in his interview that plan'; QC inspec-J toes are instructed to prepare an NOI for defects found
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ff while performing an ASME Section II preservice or inservice I
et examination. However, defects found during examinations i
conducted after repairs or modifications for initial s
1 acceptance are recorded on the workplan data sheet, or the i
weld record data sheet, or on an MR, depending on the type
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work control document.
This is in accordance with NQAM J
Part II, Section 5.3 (ref. 2) requirements and plant j
instructions, i
4.
Fifty-eight NOI's (ref. 8) were reviewed and determined that they appropriately referenced an MR to cover any corrective actions required.
i; 5.
Two hundred and twenty-seven MRs (ref. 8) were reviewed associated with inservice examinations to determine if any i
noted defects for which NOIs were not written should have f
been written.
No inadequacies were identified. The MRs reviewed were determined to be properly written for corrections found during examination and coupled to an NOI, and as deficient items discovered outside the official inspection area but considered necessary for correction by j
the inspector, l
IV. CONCLUSIONS AND RECOMMENDATIONS a
The concern of record could not be substantiated because this inves-tigation revealed that NOIs are prepared for both preservice and I
inservice defects found within the area of scope for ASME Section XI f
examinations.
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DOCUMENTS REVIEWED IN INVESTIGATION I-85-735-SQN AND REFERENCES 1.
NQAM, Part II, Section 5.1, Revision dated March 28, 1984, " Inservice Inspection - Nuclear Power Plant Components" 2.
NQAM, Part II, Section 5.3, Revision dated July 30, 1984, "Mainte-nance and Modification Inspection Program" 3.
SQNP Surveillance Instruction SI-114.1, Revision 5, dated September 14, 1984 ASME Section XI, "In-service Inspection Program" 4.
SQNP Technical Instruction TI-51. Revision 29, dated September 5 1985, " Assignment of Detailed Test Methods and Responsibility for Nondestructive Testing" 5.
SQNP Administrative Instruction AI-12 Revision 20, dated August 2, 1985, " Adverse Conditions and Corrective Actions" h..
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SQNP Modification and Additions' Instruction M&AI-1, Revision 9. -dated t
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August 5,1985 " Control of Weld Documentation and Heat Treatment" 7.
SQNP Quality Assurance Section Instruction Letter No.10.4, Revision 7, dated August 16, 1985, " Inspection - QC Inspections" l
8.
Sequoyah Notices of Indication (NOI) SQ-0139 through SQ-0202 (58 total) and 227 MRs involving ISI work beginning UIC3 up to November 2, 1985 1
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TVA EMPLOYEP. CONCERNS REPORT NUMBER: I-85-750-SQN SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 0 TITLE: Performance of Remote Visual Inspection / Rigid Pipe Supports REASON FOR REVISION: N/A i
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SUMMARY
STATEMENT: N/A Y
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PREPARATION 1
PREPARED BY:
' l II Original Signed By R. M. Bateman 11-06-86 h
SIGNATURE DATE 1
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REVIEWS PEER:
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Original Signed By J. E. Rose 11-06-86 SIGNATURE DATE 1
i TAS PTECHNICAL kEVIEW ONLY Whak
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l CONCURRENCES l
Original Signed By CEG-H: J. F. Lewis for LEM 11-25-86 RM Md M SRP:
SIGNATURE DATE SIGNATURE
- DATE 1
APPROVED BY:
Mt18,159' ic+80 NiA l, f ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
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i WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMARY
OF WP ENGINEERING EVALUATION I
?j CONCERN CONSIDERED: XX-85-065-001 1
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This pact. age summarizec the actions taken by the Welding Pro.iect (WP) to evaluate and disposition the subject SON-specific employee concern which was previously evaluated by NERS/DTC 'ERT and summarized in WP Phase I and Phase II reports.
s The Welding Project analyzed each SCN-cpecific employee concern (Attachment 2) 3-to determine the statement (s) being voiced by these individuals.
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'n These statement were then evaluated both individually and collectively to k,
develop issues.
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Each issue was then incorportated into the WP review activities of Phase I, " rocedural Assessment" and Phase II, " Procedural Implementation." l i t ) w h Du'[ing Phase I, each issue was analyzed against requirements of the applicable Uj! OA program, policies, NSRS/QTC/ERT Investigation Reports, and other relevant d dj information to determine if program elements were deficient when evaluated y against upper tier requirements. l. gy j; Phase II consisted of a sample reinspection of hardware and independent lj program audit by Bechtel, fr.Ij j; In each area analyzed by Bechtel, the auditors found no objective evidence to substantiate the employee concerns considered. The following areas directly j related to employee concern were investigated by the audit team: 4
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e k - ,k 1. Welder qualification and attendant records. A Welder qualification and attendant on-the-job-training 2. l' 3. Welding inspections 7 4. Welding inspectors training programs g. ?. 1f 5. Weld material traceability t i } 6. Welding inspections by craft personnel 1* 7. Wald material control I p[ C%. g Each of these areas was investigated by the auditors for both construction and operations phases. In all cases, there was no objective evidence to substantiate the employee concerns. The audit report concludes that both 5 3 construction and operations phases have had and now have a functioning Welding a. 1 Quality Assurance Program which meets code, standard, and regulatory I requirements and that the employee concerns considered were found to be f unsubstantiated and without technical merit. t 2 i! 4 d 4eI 1 Page 2 of 3 I 0337I
The results of the reinspection program at SQN also give another, additional verification of the Wolding 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. i The WP analysis of SQN Specific Employee Concerns supplemented by the independent Bechtel Audit, reinspection of installed components and systems, l and independent (NSRS) overview and investigations has not revealed any a 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 reiterated problems which have been or are now being resolved through existing j corrective action programs in the overall Nuclear Quality Assurance Program. k A summary analysis of the WP evaluations and recommendations is included in [,'. lq i 't C.. f. i i .t. l E 0337I V t 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 Report I-85-738-SQN (Attach-(e ment 3). WP concurs with report recommendations. SQM-5-001-001 Uncertified Welder Foreman Substantiated by WP Evaluation SQM-5-001-002 Performing Preweld Report WP-16-SQN (Attachment WBM-5-001-002 Inspections 3). Interim corrective (Also Listed in actions are being the Generic formulated. Closure is Summary) based on these actions. Additional corrective actions may be implemented. XX-85-06P-007 Manufacture of Dravo Spool Not substantiated by NSRS Pieco 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). l No falsification of records was substantiated. WP con-i l curs with report recommen-dations. 05640 l l Page 2 of 3 l' 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 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). h l'~ i' (s_ XX-85-049-001 Welder Certifications XX-85-049-001 was XX-85-049-XO3 Updated Without Meeting substantiated as it relates Requirements to Welder Continuity Requiro-ments. This had previously i 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 fi closed based on the i f 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 l Violation Report I-85-346-SQN (Attachment 3). ll XX-85-065-001 Performance of Remote Visual Not substantiated by NSRS { Inspections Report I-85-750-SQN (Attachment 3). i ! +- 05640
e ) Page 3 of 3 EMPLOYEE CONCERN NUMBER ISSUE WP ACTION XX-85-083-001 SQN Ueld 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 (" W ' that this concern is sub-stantiated. WP takes excep-g 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 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 XX-85-108-002 Report I-85-776-SQN (Attachment 3). 05640
l'.uw I of i 10/16/86 .(EMPLOYEE CONCERNS) 13:58:16 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10 ------CONCERN------- S 1 NSRS SR XX-85-065-001 ' WOR D S : INSPECTION IMPLEMENTATION SPECIFIC PROB: WCPlF DURING SPRING OUTAGE (FED. OR MAR. 1984) AT SEQUOYAH, Cl WITNESSED 2 ISI INSPECTORS (NAMES KNOWN) FROM DASELINE GROUP PERFORMING " REMOTE VISUAL INSPECTIONS") ON ERCW SYSTEM RIGID PIPE SUPPORTS IN AUXILIARY BUILDING ELEVATION 669' ON HORIZONTAL PIPE RUNS OFF THE CEILING. Cl DEFINES " REMOTE VISUAL INSPECTIONS" AS PERFUNCTORY. POORLY PERFORMED VISUAL INSPECTIONS MADE FROM REMOTE DISTANCES WITHOUT ACTUALLY VERIFYING THE MANDATORY INSPECTION ATTRIBUTES ON THE INSPECTION CHECKLIST. CONSTRUCTION DEPT CONCERN. Cl HAS NO FURTHER INFORMATION. IR: 1-85-750-SON STAT: RC: TECHNICAL COMMENTARY: k 5 ) ? l} e, j
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