ML20214G982
| ML20214G982 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 12/09/1985 |
| From: | Harwell E, Kidd M, Sauer R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082840729 | List: |
| References | |
| I-85-750-SQN, NUDOCS 8605290613 | |
| Download: ML20214G982 (17) | |
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TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT NO. I-85-750-SQN EMPLOYEE CONCERN NO. XX-85-065-001
SUBJECT:
PERFORMANCE OF REMOTE VISUAL INSPECTIONS OF RIGID PIPE SUPPORT DATES OF INVESTIGATION:
OCTOBER 11-23, 1985 s
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F. HARWELL DATE
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REVIEWED BY:
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BACKCROUND 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
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concern of record, as summarized on the Employeo Concern Assignment Request Form from QTC and identified'as XX-85-065-001, stated:
"During Spring outage (February or March 1984) at Sequoyah, CI i
witnessed 2 ISI inspectors (names known) from baseline group perfoming " Remote Visual Inspections" on ERCW system rigid pipe supports in auxiliary building elevation 669' on horizontal pipe runs off the ceiling. CI defines " Remote Visual Inspections" as perfunctory,' poorly performed visual inspections made from remote t;
distances without actually verifying the mandatory inspection attributes on the inspection checklist."
li The QTC/ERT followup group was contacted to obtain the names of the two inspectors in order to narrow the scope of the investigation.
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SCOPE iI Il A.
The scope of the investigation was determined from the concern of ji record to be that of two specific issues requiring investigation:
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Inspectors made inadequate visual inspections of suspended,
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rigid ERCW pipe supports in the auxiliary building at the 669' elevation during the February / March 1984 time frame.
2.
Visual inspections must be performed at close proximity to verify specific mandatory inspection attributes (particulars) on the inspection checklist.
J B.
To accomplish the investigation, NSRS reviewed a computer printout of hanger examinations performed during the Sequoyah unit 1 cycle 2 (U1C2) outage (ref. 3).
A determination was made as to which ERCW hangers on the 669' elevation could have been examined by the f}
inspectors named by the CI.
These inspection reports were then P
reviewed. Interviews were conducted with three-ISI inspectors, the if inspection supervisor in charge during the outage, a plant Quality Engineering and Control Croup supervisor..and the onsite Authorized I
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Nuclear Inservice Inspector (ANII) from Hartford Steam Boiler
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Company. Thirty ERCW hangers from the group inspected by one of the i
named inspectors were reexamined under the cognizance of the NSRS fjj investigator. The resultu of this reexamination were reviewed to determine if the supports had been examined properly and if the 2 *jf programmatic procedures used in tho inspections were adequate.
- Y III.
SUMMARY
OF FINDINCS i
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A.
Requirements and Commitments J
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ASME Section XI, " Rules for Inservice Inspection of Nuclear Power Plant Components" 7
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10CFR50.55a 3.
Sequoyah Technical Specifications, Section 4.0.5 and 3.4.4.10 I
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NQAM, Part II, Section 5.1, " Inservice Inspection - Nuclear Power Plant Components" S.
Area Plan Program Procedure 1502.7 (formerly DpH N80E3), "NDE Procedures Approved for Use on CSSC Items at All Nuclear Plants" B.
Findings 1.
The two ISI inspectors (Individuals C and D) named by the CI did not work together on ERCW hanger inspections.
Individual D worked mostly on ultrasonic examinations during the UIC2 outage.
i 2.
Individual C performed 20 ERCW hanger visual inspections on 5
elevation 669 on February 27, 1984, accompanied by Individual E l
(in training).
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3.
Both individuals (C and E), when interviewed, said it was j
impossible to perform an adequato visual inspection of a hanger i
without having hands-on access.
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4.
The onsite ANII witnessed inspections performed by this pair on k
4 several occasions but not on this particular day, h
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The inspection reports did not indicate any type examination i
other than direct visual was utilized.
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6.
Individual C submitted 31 ERCW support inspection reports for a
the day in question.
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7.. The results of reexamining all the supports during this investigation are as follows:
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a.
Arc strikes and weld splatter were found on embedded steel but had been there since initial construction and were d
painted over.
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Some pipe clamps had unequal distance betwen the cars but j
had equal loading around the pipe, c.
One support had been deleted, but it appeared on the weld
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support isometric. A support in a grouping of five was q
improperly tagged with the deleted support number which j
resulted in an extensive inspection shoot being generated.
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One base plate had a loose bolt, but a conduit had to be j
moved to determine this condition.
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These discrepancies were evaluated by the cognizant Level III IIDE engineer (Individual I) and determined to be acceptable (ref. J).
IV.
C0!!CLUSIONS A!!D REC 0 time!!DATI0 tis A.
The employee concern could not be substantiated for the following reasons:
1.
The two inspectors named by the CI did not work together on ERCW hanger inspections.
2.
The two inspectors who did work together said it was impossible to do an adequate inspection remotely and recognized that it
~w3uld be'a violation of procedures to do so.
Both said that it was nob worth jeopardizing their jobs to do a poor inspection
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od inspections 'each day.
3.
The reexamination of EPCW pipe hangers conducted during this investigation did not identify any major problems.
4.
A plant'QA staff manager said that he had not heard of an incident such as this employee concern and would have been notified if it had been reported to a supervisor.
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The onsite luiII caid he witnessed the two individuals performing inspections and;did not believe they would do anything other than a proper inspection.
s-s B.
The CI mayLhave witnessed an ISI inspector performing a preliminary walkdown of the ERCW system, prior to inspection, where a determina-tion,is made concerning the need for metal identification tags,
, insulation removal, and, scaffolding and misconstrued this as a remote visual inspectic,of hangers. The actual documented inspec-tion takes: place at a later time when the identified preliminary findings have been addressed.
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k DOCUMENTS REVIEWED IN INVESTICATION I-85-750-SQN AND REFERENCES 1.
SQN Surveillance Instruction SI 114.1 Rev. 5, dated September 14, 1984, Unit 1 ASME Section XI In-Service Inspection Program 2.
SQN Surveillance Instruction SI 114.1 data packages for the UIC2 outage 3.
Printout of ERCW Hanger inspections performed during the unit I cycle 2 outage prepared by the NCO ISI Group 4.
Inspection Records of visual inspections performed on ERCW hangers of Elevation 669 by Individual C during outage
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Preservice and Inservice Visual Examination Procedure, N-VT-1, Rev. 4, dated July 1, 1983 6.
N-VT-1, Rev. 7, dated June 20, 1985 7.
Memorandum (45D) from M. E. Gothard to Fonda Harwell dated November 27, 1985, entitled " Unit 1 Cycle 2. In-Service Inspection Employee Concern Allegation" with results of reexamination attached **
- These records are considered confidential as they contain the name of one of the individuals named in this employee concern.
- This document is considered confidential as it contains information critical to this investigation and is in the personal possession of E. F. Harwell.
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r EMPLOYEE CONCERN ASSIGNMENT REOUEST TO: Director - NSRS TRANSMITTAL NUMBER T50163 ERT has received the Employee concern identified below, and has assigned the indicated category and priority:
Priority: 1 Concern # XX-85=-065-OO1 Category: 40 Confidentiality:
_YES
_NO (ILH)
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Supervisor tiotified: _X_YES ___NO NUCLEAR SAFETY RELATED
_YES_
r Concern:
DURING SPRING OUTAGE (FEB. OR MAR. 1984) AT SEQUOYAH, CI WITNESSED L
2 ISI INSPECTORS (NAMES'KNOWN) FROM BASELINE GROUP PERFORMING " REMOTE VISUAL 4
INSPECTIONS" ON ERCW SYSTEM RIGID PIPE SUPPORTS IN AUXILIARY BUILDING ELEVATION 669' ON HORI2ONTAL PIPE RUNS OFF THE CEILING.
CI DEFINES " REMOTE VISUAL INSPECTIONS" AS PERFUNCTORY, POORLY PERFORMED VISUAL INSPECTIONS MADE g
FROM REMOTE DISTANCES WITHOUT ACTUALLY VERIFYING THE MANDATORY INSPECTION I
ATTRIBUTES ON THE INSPECTION CHECKLIST.
CONSTRUCTION DEPT CONCERN.
CI HAS
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FURTHER INFORMATION.
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Nti-FOLLOWUP REQUIRED.
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/g_,,__0CT U 71985 MANAGER, ERT DATE NSRS has assigned responsibility for investigation of the above concern to:
ERT ___
NSRS/ERT _____
NSRS b
TiRS (SPECIFY)
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TVA EMPLOYEE CONCERNS REPORT NUMBER: I-85-756-SQN SPECIAL PROGRAM REPORT TYPE: Welding Project REVISION NUMBER: 0 TITLE:
Improper Weld Rod Used in D/G Building REASON FOR REVISION:
N/A SWEC
SUMMARY
STATEMENT: N/A PREPARATION PREPARED BY:
Original Signed By R. M. Bateraan 11-06-86 SIGNATURE DATE S
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REVIEWS PEER:
Original Signed By J. E. Rose 11-06-86 SIGNATURE DATE TAS TE ICAL REVIEW ONLY 0M W/ht/Gf'W HlNbd SIGNATURE DATE CONCURRENCES Original Signed By CEG-H: J. F. Lewis for LEM 11-25-86
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SRP:
es,eie4 SIGNATURE DATE G
SIGNATURE
- DATE APPROVED BY:
mud??b n+tG NiA 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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WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS DATE 11/6/86
SUBJECT:
SEQUOYAH SPECIFIC EMPLOYEE CONCERNS -
SUMMARY
OF WP ENGINEERING EVALUATION CONCERN CONSIDERED: XX-85-041-001 Il/talGstp
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g This package guann.ariceu the actions taken by the Helding Project (WP) to evaluate and dispecition the subject SON-specific employee concern which was previously evaluated by NSRS/OTC/ERT and summarized in WP Phase I and Phase II reports.
) The Welding Project analyzed each SOM-specific employee concern (Attachment 2) to determine the statement (s) being voiced by these individuals.
Thase statement were then evaluated both individually and collectively to develop issues.
Each issue was then incorportated into the WP review activities of Phase I, "Fnocedural Assoccment" and Phase II, " Procedural Implementation."
j During Phase I, each issue was analy:ed against requirements of the applicable OA program, policies, NSRS/OTC/ERT Investigation Reports, and other relevant information to determine if program elements were deficient when evaluated against upper tier requirements.
f Phase II consisted of a sample reinspection of hardware and independent l
r program audit by Bechtel.
f In each area analyzed by Bechtel, the auditors found no objective evidence to I
j substantiate the employee concerns considered. The following areas directly related to employee concern were investigated by the audit team:
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Welder qualification and attendant records l
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Welder qualification and attendant on-the-job-training 3.
Welding inspections 4.
Welding inspectors training programs 5.
Wald material traceability I
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Welding inspections by craft personnel 7.
Weld material control 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 construction and operations phases have had and now have a functioning Welding Quality Assurance Program which meets code, standard, and regulatory reqtiirements and that the employee concerns considered were found to be unsubstantiated and witnout technical merit.
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The results of the reinspection program at SQN also give another, additional
,e verification of the Welding Quality Assurance Program for both construction
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and operations phases and serve to establish additional confidence in the accuracy and implementation of these programs through hardware inspections and j
attendant document reviews.
In all cases, the components and items were found to be acceptable upon initial reinspection or found to be acceptable after p-engineering analysis.
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The WP analysis of SQN Specific Employee Concern.1 supplemented by the f
independent Bechtel Audit, reinspection of installed components and systems, and independent (NSRS) overview and investigations has not revealed any significant or generic inadequacios in the welding programs for either the l
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 s
corrective action programs in the overall Nuclear Quality Assurance Program.
A sum:cary analysis of the WP evaluations and recommendations is included in
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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).
i 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 g.
Rejected NDE Items Report I-85-738-SQN (Attach-
?d 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 t
may be implemented.
4 XX-85-068-007 Manufacture of Dravo Spool Not substantiated by N3RS 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 f;;
XX-85-069-X05 substantiated by NSRS Report XX-85-069-007 I-85-373-NPS (Attachment 3).
No falsification of records k
was substantiated. WP con-N curs with report recommen-
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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-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.
11-85-041-001 Improper Weld Rod Used in Not substantiated by NSRS Diesel Generator Building Report I-85-756-SQN (Attachment 3).
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XX-85-049-001 Welder Certifications XX-85-049-001 was XX-85-049-X03 Updated Without Meeting substantiated as it relates Requirements to Weldor Continuity Requiro-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-85-750-SQN (Attachment 3).
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EMPLOYEE CONCERN NUMBER ISSUE WP ACTION S
XX-85-083-001 SQN Weld Inspections not as Not substantiated by NSRS
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Strict as WBN Report I-85-652-SQN (Attachment 3).
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XX-85-098-001 Laminated Pipe in Unit 2 Not safety-related. Not 4
Condenser. This issue is substantiated by WP Evaluation 1;
also on the Generic Summary Report WP-18-SQN (Attachment 3).
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XX-85-100-001 Improper Weld Repair on an Not substantiated by ERT Undetermined Number of Report XX-85-100-001, dated jd Welds 3/5/86 (Attachment 3).
CMMg XX-85-101-006 Welder Certification for ERT Report XX-85-101-006 4
the Construction Era (Attachment 3) with NSRS b
Recommendations indicates
{j jy that this concern is sub-t "h.
stantiated. WP takes excep-h tion to this ERT Report based on subsequent information L
provided in Attachment 4.
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exceptions, recommen-F dations, and basis for b
closure were discussed with
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NSRS as documented in Attach-ment 5.
WP recommends this
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concern not be substantiated j
and that it be closed based on the WP-Bechtel Implemen-j tation Audit, Key Elements
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4.0, 5.0, 17.0 (Attschment 6).
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[f XX-85-102-011 NDE Inspectors Cannot Write Not substantiated by NSRS Notice of Indications for Report I-85-735-SQN h
Preservice-Related Defects (Attachment 3).
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lh XX-85-108-001 Socket Welds Not Inspected Not substantiated by NSRS XX-85-108-002 Report I-85-776-SQN (Attachment 3).
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s.u,e i or i 10/16/86 (EMPLOYEE CONCERNS) 12:53:38 CAT ISSUE PLANT PRIORITY ORG OTC EGG INSP SD RD GD 10
CONCERN-------
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NSRS LS SR XX-85-041-001 ncVWORDS:
ELECTRODE IMPLEMENTATION CONTROL PROB: WCPME AT SEOUOYAH. A WELD MADE IN '79 OR '80 IN DIESEL GENERATOR BUILDING. UNIT 1.
USING THE WRONG TYPE ROD TO WELD CARBON STEEL PIPE TO STAINLESS STEEL PIPE. A COVER PASS USING THE CORRECT ROD WAS RUN OVER THE EXISTING WELD. CONSTRUCTION
' DEPT CONCERN. Cl HAS NO MORE INFORMATION.
IR: 1-85-756-SON STAT:
RC:
TECHNICAL COMMENTARY:
ISSUE CONSIDERED: INCORRECT MATERIAL USED.
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4 WELDING PROJECT SQN SPECIFIC EMPLOYEE CONCERNS ATTACHMENT 3 NSRS REPORT I-85-756-SQN
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UNITED ST.\\TES GOVERN.11ENT Memorandum rtxxtsser vatter acruoniry C
TO
- H. L. Abercrombie, Site Director. Sequoyah Nuclear Plant FROM
- K. W. Whitt, Director of Nuclear Safety Review Staf f. E3A8 C-K
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DATE
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF INVESTICATION REPORT TRANSMITTAL Transmitted horcin is NSRS Report No.
I-85-756-SON Subject.
IMPROPER WELD ROD USED IN D/G BUILDING Concern No.
XX-85-041-001 No responso or correctivo action is required for this report.
It is being transmitted to you for information purposes only.
Should you have any questions, please contact R. C. Sauer at telephone 2277
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Recommend Reportability Determination: Yes No X
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' Director, NSRS/ Designee RCS:JTH Attachment ec (Attachment):
R. P. Deniso, LP6N35A-C R. J. Griffin, SQN E-18 C. B. Kirk, SQU D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nucioar Plant--for responso to employco.
Eric Sligor, LP6N48A-C J. H. Sullivan, SQN W. F. Willis, E12B16 C-K (4)
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