ML20214H865

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Rev 3 to TVA Employee Concerns Special Program Rept C010703-SQN, Bending Equipment/Matl
ML20214H865
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 11/12/1986
From: Howard J, Rachel Johnson, Lofts H
TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20214H850 List:
References
C010703-SQN, C010703-SQN-R03, C10703-SQN, C10703-SQN-R3, NUDOCS 8612010068
Download: ML20214H865 (9)
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 '                            TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REPORT TYPE: Sequoyah Nuclear Plant Element                   R8 VISION NUMBER:       3 TITLE: Bending Equiprient/ Material                           PAGE 1 0F 8 REASON FOR RRVISION:

To incorporate TAS and SRP coments. Revision 1 To incorporate additional SRP coments. Revision 2 To incorporate additional SRP coments. Revision 3 PREPARATION PREPARED BY: L 0 . L krin,,,1. ee 11.ti). Log r,s IGNATURE it-i2-ac DATE A / T' REVIEWS PEER: S URE 

                                                                               / /- / 2 -[6 DATE TAS:

SIGNATURE DATE CONCURRENCES CEG- j }/-/2 '88 i SIGNATURE DATE SIGNATURE

  • DATE APPROVED BY:

N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) 

     *SRP Secretary's signature denotes SRP concurrences are in files.

1251T 8612010068 PDR ADOCK h000327 PDR P l L 1< ' 5-

  • TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 2 0F 8 I. INTRODUCTION Five employee concerns relating to two basic issues were evaluated at Watts Bar Nuclear Plant (WBN), and as a result of the evaluations, the generic applicability of the issues was deemed pertinent to the Sequoyah Nuclear Plant (SQN) Quality Assurance Program. These two issues relate to the implementation of Division of Nuclear Engineering (DNE) process specifications (PS) for qualifying tubing bending tools and operations and procurement specifications used to purchase copper pressure tubing.

IN-85-707-002 IN-85-740-002 IN-85-740-003 IN-85-773-002 IN-85-831-001 No related site-specific concerns had been identified by SQN's Employee Concerns Program. II.

SUMMARY

OF PERCEIVED PROBLEMS

1. Programmatic deficiencies resulting from inadequate implementation of DNE requirements concerning the qualification and control of bending equipment may allow questionable quality bends to be produced and damaged or defective bending equipment may remain undetected.
2. DNE procurement specifications may have been inadequate by not clearly specifying " Bending Quality" tubing in the copper tubing description.

l III. METHODOLOGY ,

a. Discussions were held with responsible SQN Modifications and Additions engineers to determine which site procedures governed tubing bending and installation operations.

i b. Reviewed WBN Element Report C010703, " Bending Equipment / Material," to ascertain if WBN's bending equipment control methods were j applicable to SQN's program, c. - Reviewed SQN's Division Procedure Manual (DPM) N73M2 PS 4.M.2.1 (revision 7) for general bending requirements, tool requirements, qualification of bending processes and material requirements governing SQN's program, i l sh r_ .A - L' '

c

  • TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 3 0F 8 d.

Reviewed addendum number 3 to PS 4.M.2.1 (revision 7) for code requirements for acceptable wall thickness of pipe or tube bends and revision to qualification tests for bending procedures. The addendum was dated January 7, 1986.

e. Discussions were held with Office of Nuclear Power Quality Assurance (ONP QA) engineers, Modifications and Additions engineers, and Site Services engineers to ascertain methods being used to govern the control of bending equipment after initial qualification of that equipment, f.

Reviewed Administrative Instruction AI-12. " Adverse Conditions and Corrective Actions," to establish controlling guidelines for identifying and correcting Conditions Adverse to Quality (CAQ).

g. Reviewed historical file for Discrepancy Report (DR)

SQ-DR-85-04-045R, " Qualification of Tube Benders," in order to evaluate program deficiencies previously identified by ONP QA.

h. Reviewed memorandum from D. C. Craven, QA Supervisor, ONP to R. W. Olson, Modifications Manager, DNC, dated April 10, 1986 upgrading SQ-DR-85-04-045R to a CAR, SQ-CAR-86-04-017, as part of the problem history evaluation.

1. Reviewed memorandum from R. W. Olson to D. C. Craven dated September 26, 1986, responding with remedial corrective actions taken by Modifications in answer to CAR SQ-CAR-86-04-017 (RIMS S02 860926 942).

j. Reviewed Procurement Specification 47BM600, Revision 4, sheet 8 of 73, dated June 8, 1977, to determine DNE specifications for copper tubing.
k. Reviewed ASTM B88-83-A and ASTM B75-84 Standard Specifications for copper tubing material to determine the type of tempers contained in each specification.

1. Discussions were held with SQN Mechanical Maintenance (MM) craft personnel to determine if difficulties had been encountered and/or documented during copper tubing bending operations,

m. Reviewed Quality Technology Company (QTC) expurgated files and other investigation reports for any additional pertinent information.

_ fE _ t d w _3

l TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 4 0F 8 IV.

SUMMARY

OF FINDINGS

a. SQN Modifications and Additions engineers stated that tube bending operations were governed by DPM N73M2 PS 4.M.2.1.
b. Review of WBN Element Report C010703 verified that WBN's controlling procedure, General Construction Specification (GCS)

G-29 PS 4.M.2.1, was essentially the same as SQN's DPM N73M2 PS 4.M.2.1, and the same program deficiencies identified during WBN's evaluation would be inherrent in SQN's controlling procedure. In addition to the identified program deficiencies, WBN's procurement specifications for copper tubing were inadequate by not specifying " Bending Quality" in the description given in the Bill of Materials. "Nonbending Quality" material was supplied by vendors, but was in compliance with the specifications given in the procurement documents. Difficulties were encountered during bending operations when "Nonbending Quality" material was used. Cracks and breakage were inadvertantly attributed to " bad material or benders."

c. Review of SQN DPM N73M2 PS 4.M 2.1, section 3.0, revealed that: "A qualification test shall be performed whenever essential variables are changed. Two of the essential variables listed were equipment and material. The qualification test consists of bending three samples. If the three samples are from a single heat, that heat is considered qualified. Qualification on three separate heats of material qualifies the procedure for the material being bent.

Requalification is required whenever the equipment manufacturer or model number is changed or the bending process is for any reason suspected of being out of control. Tools used for bending shall be controlled in a manner appropriate to their application so as to ensure reproducibility of bend geometry. Tools used in bending stainless steel shall be used exclusively to bend stainless steel. To alleviate the possibility of galling when bending stainless steel, it is recommended that tools and formers be chrome plated. Copper received in the hard drawn condition may require annealing prior to cold bending in order to obtain acceptable bends."

d. Review of addendum number 3 to PS 4.M.2.1 (revision 7) supplied the following: " Code Requirements for acceptable wall thickness of pipe or tube bends are basically that the minimum wall thickness after bending shall not be less than the minimum calculated design thickness for straight pipe or tube. Bending qualification test requirements were clarified to say: If the samples are one each from three different heats, the procedure is qualified for the material being bent."

i _ _ - '

Y 

  ,'                           TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAN REVISION FUMBER:    3 PAGE 5 0F 8
e. Discussions with ONP QA Engineers revealed that during routine surveillance of work associated with Modifications and Additions Workplan 11006, procedural discrepancies were identified and were documented on DR SQ-DR-85-04-045R as follows:

1

1. Tools used to bend stainless steel pipe were not segregated from tools used to bend other materials.
2. Not all bending tools (19 of 22) were properly and/or fully identified as listed in attachment B of PS 4.N.2.1.

3. Process Qualification Records (attachment A of PS 4.N.2.1) for bending pipe and tubing could not be located by plant personnel responsible for same. , 4. Some existing tubing benders had not been qualified.

5. The governing site procedures do not specifically address the handling, storage, or the administration of the site's tube bending program requirements as set forth by PS 4.N.2.1 Conversations with Modifications and Additions engineers'and Site Services engineers supported the findings voiced by the site QA

} engineers. I f. The escalation of DR SQ-DR-85-04-045R to SQ-CAR-86-04-017 was in accordance with guidelines stipulated by Administrative Instruction AI-12.

g. Program deficiencies as noted above in section 4.f. were verified i to exist.

I

h. The noted memorandum emphasized the fact that corrective actions had not been implemented in a timely manner and that the
               " corrective actions required" fulfilled the criteria to upgrade the DR to a CAR.

r ! 1. R. W. Olson's memorandum to D. C. Craven showed substantial program I improvements had been made to implement upper tier requirements for personnel training and bender segregation, qualification, and identification. This evaluation takes exception to section II, l paragraphs 3 and 4 of the memorandum as follows:

1. By not being able to locate purchase documents for all benders currently in stock, qualifications for bends made by unknown benders are questionable, t

rv s. 9-{ t Q3 w s rf '

IVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 6 0F 8

2. Testing for benders removed from existing and/or prior stock did not meet minimum criteria required by Process Specification 4.N.2.1 as noted in section III.d. above. Qualification tests lR3 shall consist of bending three samples per heat of a product form which qualifies that one heat of material only, not all IR3 heats.
3. Two of the 58 benders tested damaged the tubing samples. No verification is performed which would detect damaged or defective equipment before use. No control existed to detect or document where benders were used in order to identify suspect tubing should problems be encountered with a particular bender. Steps should be taken to curtail use of the defective benders until evaluation of the defective bends by DNE is complete.
4. Pressure testing the 1/2-inch, 1-inch, and 1-1/2-inch diameter tubing bent by the defective hydraulle bender blocks does not
meet DNE PS qualification criteria. No mention of the disposition for the defective radius and slide blocks was noted. It is suggested that the use of the defective hydraulic bender blocks be curtailed until DNE's evaluation of the defective bends is completed.

J. Review of DNE Procurement Specification 47BM600, revision 4. sheet 8 of 73 revealed copper tubing material was specified as: tubing - seamless copper, hard, ASIM B88, type K or ASTM B75, type 120 or 122, 20 foot lengths, in sizes shown. The procurement specification implies hard temper qualities are part of the ASTM B88 properties. This is a misnomer. Type K refers to wall thickness only, which is independent of temper quality. Types 120 and 122 refer to the chemical analysis of the copper tubing materials without reference to temper quality.

k. Review of the ASIM B88-83A specification indicated that annealed or lR3 drawn copper water tubes suitable for general plumbing and similar applications were manufactured to this standard and no mention of hard-drawn tempers was included. ASTM B75-84 specifies seamless copper suitable for general engineering purposes, and is supplied as annealed and drawn tempers. The drawn tempers (H-tempers) are specified as drawn H-58 (general purpose) H-55 (light-drawn, bending quality), and H-80 (hard-drawn). Drawn copper tubing as specified in ASTM B88 is suitable for general plumbing and is most commonly used where there are no specific requirements for high strength. Hard-drawn temper as specified in ASTM B75 is used only

, where there is a need for a tube as strong as is commercially i feasible. Tubing of this temper is not bending quality and will l crack or break during bending operations. Hard temper tubing is suitable for straight runs only. C _  : . . . _w-- -- - - - - - = - "

TVA EMPLOYEE CONCERNS REPORT NUMBER: C010703-SQN SPECIAL PROGRAM REVISION NUMBER: 3 PAGE 7 0F 8

1. Discussion with Mechanical Maintenance personnel revealed that difficulties such as cracking and breaking had been encountered when bending attempts were made utilizing some copper tubing materials. No documentation for the problem could be obtained.
m. No additional relevant information was obtained from QTC expurgated files or other investigative reports.

CONCLUSIONS A. SQN site implemented procedures governing maintenance and modifications activities were inadequate in implementing requirements specified in DPM N73M2 PS 4.M.2.1. The engineering i evaluation or justification to hydrostatically test the worst-case lR3 sample bend to qualify past installations is a deviation from the design specifications and requires DNE approval in order to maintain the design basis for SQN related to bending activities. It is suggested that SQN ensure that all deviations from the design requirements noted receive formal evaluation and approval from lR3 DNE. This referral to DNE should address the qualifications of the benders for all heats of a given product form and should also consider the WBN sample inspection program results for an evaluation related to the installed conditions of the bends at SQN. The defective benders require special evaluation by DNE and should be addressed. (CATD 10703-SQN-01 and 10703-SQN-02) B. Procurement specifications for copper pressure tubing were inadequate by not specifying " Bending Quality" in the description supplied by the Bill of Materials. The vendor's interpretation of l TVA's temper quality requirements resulted in shipment of ASIM B88 (R3 

           " Bending Quality" or ASIM-B75 (H-80) hard drawn "Nonbending              l Quality" material. Since hard copper tubing has been shown to             I break or crack during bending operations, and no reports of copper tubing ruptures during construction hydrostatic testing or system operations have been documented, it is reasonable to assume no "hard" copper tubing is installed. DNE should revise the i

procurement specifications to clearly indicate the required temper l quality (bending quality) tubing to prevent any future acquisition l of "nonbending quality" copper tubing. (CATD 10703-SQN-03) L. x .- h

l TVA EMPLOYEE CONCERNS . REPORT NUMBER: C010703-SQN SPECIAL PROGRAN REVISION NUMBER: 3 PAGE 8 0F 8 Y. ROOT CAUSE

1. ONP failed to implement the requirements of DPN N73M2 PS 4.M.2.1 into their bending operation program procedure.
2. The Bill of Materials description for copper tubing requirements was not clear enough to preclude the acquisition of "Nonbending Quality" tubing. The term " Bending Quality" should have been part of the material description used to procure copper tubing. The l technical review of the procurement specifications was inadequate, since the interpretation of the requirements was left up to the supplying vendor.

VI. CORRECTIVE ACTION (To be provided by line management.) VII. GENERIC APPLICABILITY The generic applicability determinations resulting from the WBN ECTG evaluation of the subject employee concerns were accurate related to inadequate: a) site implementing procedures for bending activities and, b) procurement specifications for copper pressure tubing materials. Additionally, the potential exists for these conditions to be present at BLN & BFN, as stated in the WBN ECTG Element Report C010703 Bending Equipment / Material. VIII. ATTACHMENTS Attachment A Listing of concerns indicating Safety Relationship and Generic Applicability. 1 

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ATTACHMENT A 

                ,.          * , g.                              .
  *IN 707-002                              CD        10700 N HBN             YYYH
         .750070                                                                 REPORT
                                                                                                                       <  11 5 TUBING CRACKED HHEN BENT HITH HAND B
                                                                                                                -    >          EllDER. HAS LOCATED Ill REACTOR DUILD 8
                                                                                                               -                IIIG 2, THROUGH HATCH, UP SPIRAL STAI RCASE, ON IST LAllDIllG-3/8" COPPdR TU -
                                                                                                  -                            BING. HAS BEEN REPLACED WITH ACCEPT
  • ABLE TUBIllG. CRACKED TUDIllG HADit'T
                                                                                                                 .             BEEN INSPECTED AT TIliE THAT IT HAS D ISCOVERED AllD FIXED. C/I' HAS 110 MOR E DETAIL. Il0T E s C/I HAS Il0 MORE Ill FORMATI0ll. HE REPLACED CRACKED TUBI 11G   HHEllEVER llE FOUllD IT - Kil0HS OF H 0 110R E.

Ill -8 5-7 4 0'-0 02 CO 10700 H HBil YYYY T50199 REPORT HS ALL HAND BENDERS ARE THE " IMPERIAL" BRAND, AllD ALL BEllD THE SAME. THESE BEllDERS HORK OK FOR STAllllESS STEEL BUT THEY CRACK AllD " EGG SHAPE" CDP PER TUBIllG. CI DECLIllED TO PROVIDE 

                                                             ,                                                                 FURTHER INFORMATION. CollSTRUCTI0tt D EPT. CollC ERil . ..,

iN 740-003- CO 10700 H HBil YYYY T50199 ' REPORT . HS HAHD MADE TUBIllG BEllDERS USED TO Bell D RADI ATION HONITORIllG TUBIl10 (I" All D 1 1/2") DAMAGE TUBIllG. BEHDERS LO CATED 729' 0F TURBIllE BUILDING (14" 

                                                                                   ,                                           AllD 20" RADIUS). TUBIllG LOCATED Ill 3                                                                            .

ADDITIONAL EQUIPl1ENT BUILDIllGs GO I H CRANE BAY DOOR OF UllIT 2. TAKE RIG HT llAND DOOR, LOOK BEHIND HIllG HALL llEAR OR BEHIllD SollE STAIRS. C0llSTRU CTI0ll DEPT. CollCERil. CI DECLIllED T IN 773-002 0 PROVIDE FURTHER IliFORMATI0ll. CO 10700 H HBil YYYY T50081

  • REPORT HS COPPER TUBIllG BREAKS OR SQUEEZES TOG ETHER HHEli BEHDIllG 90 . MATERIAL OR BENDER IS~ DEFECTIVE. 110 MORE * ' Il(FOR MATI0li AVAILABLE.

IH 831-001' CD 10700 II Hall YYYY T50086 REPORT  !!$ C0FPER INST'RUMEllTATI0tt TUBIllG IS C0ll SISTEllTLY "BREAKIllG" lillEli Belli USIllG THE HECHAlllCAL (HAllD-OPERATED) B Ello ING TOOLS. BECAUSE OF THE CollSISTFleC Y AT HHICH THE " BREAKAGE" OCCURS,IHE RE IS A CONCERil THAT THE " GOOD" BEllD S MAY VIOLATE 111till1UH llALL OR OTHERH 

                                 .
  • ISE HEAKEll THE COPPER TUBIllG. PROBL EM MAY BE THE CONDITI0li 0F THE BEllDI IIG TOOLS. (HO SFECIFICS GIVEH) lj -

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