ML20214M950
| ML20214M950 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/13/1987 |
| From: | Hutzler C, Russell J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20214M914 | List: |
| References | |
| MC-40400-SQN, MC-40400-SQN-R04, MC-40400-SQN-R4, NUDOCS 8706010475 | |
| Download: ML20214M950 (17) | |
Text
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN
.z.
~
SPECIAL PROGRAM REVISION NUMBER: 4 REPORT TYPE: Sequoyah Nuclear Plant - Subcategory (Final Report)
PAGE 1 0F 15 TITLE: Storage and llandling as Related to Material Control REASON FOR REVISION:
To incorporate Technical Assistance Staff and Senior Review Panel Revision 1:
coments.
Revised to include corrective action and addition of Attachment A.
Revision 2:
Revised to include additional corrective action plan supplement Revision 3:
(February 6,1987) and incorporate Senior Review Panel coments.
Revised to incorporate consolidated corrective action plan and Revision 4:
Nuclear Regulatory Comission coments.
PREPARATION PREPARED BY:
f/T 7
/N
'DATE
[ ~ ~ SIGNATURE REVIEWS PEER:
C%A &>. (-L d sh/ e,
/ D#tE GIGNATURE TAS:
4l/2lTI Y
' DATE f, y jf /( c;//.23 SIGNATURE CONCURRENCES CEG 8'/ '87 SRP SIGNATURE DATE SIGNATURE DATE APPROVED BY:
.64 d
N13M N/A
" ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY) s
- SRP secretary's signature denotes SRP concurrences are in files.
1353T 8706010475 870518 PDR ADOCK 05000327 P
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAM REVISION NUMBER:
4
-PAGE 2 0F 15 I.
INTRODUCTION Five concerns have been evaluated involving the storage and handling of permanent plant material and equipment at Sequoyah Nuclear Plant (SQN).
was a SQN specific concern and the One of the concerns (XX-85-122-045) other concern (IN-85-443-002) was a Watts Bar Nuclear Plant (WBN) specific concern that was determined to be generic to_all TVA nuclear power plants during the WBN evaluation. The remaining three concerns which were expressed (WI-85-100-040, XX-85-122-046 and XX-85-122-047) lR4 for the other TVA nuclear plants _(WBN - BLN (Bellefonte Nuclear Plant]
l and BFN (Browns Ferry Nuclear Plant] respectively) were identical to and therefore determined to be generic to SQN.
XX-85-122-045, II.
SUMMARY
OF PERCEIVED PROBLEMS This subcategory supplemental report deals with (a) inadequate material segregation during receipt and storage and (b) inadequate environmental*
control and protection through installation.
III. EVALUATION METHODOLOGY Reviewed expurgated files for the concerns this evaluation plan A.
addressed to determine if additional information was available on individual concerns.
Reviewed Employee Concerns Task Group (ECTG) subcategory report on B.
" Storage and Handling" (MC-40400) to determine if the evalustion results were applicable to SQN.
C.
Reviewed Nuclear Safety Review Staff (NSRS) investigation report to determine if concerns were adequately addressed.
NSRS Investigation Report I-85-990-SQN, " Poor Equipment Storage, 1.
Fire Protection, Storage Environment."
1 I
l
't
'7 U 2*
- n
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 3 0F 15 Reviewed Quality Assurance (QA) Staff, Surveillance Section QA Inplant D.1 Survey Checklist for the Office of Nuclear Power (ONP) to determine if deficiencies were being detected and corrected. The following audits were reviewed:
3c-83-A-022 3d and f-83-P-002 3a-84-P-001 3d-83-S-003 3c-84-P-003 3a-83-A-006 3h-84-004 3f-83-A-007 3d-84-S-006 3f-83-A-008 3f-84-S-007 3f-83-A-009 3f-84-S-008 3d-83-A-010 3f-84-S-009 3f-83-A-011 3f-84-S-010 3f-83-A-012 3f-84-S-011 3f-83-A-013 3f-84-S-012 3b-83-A-014 3f-84-S-013 3-83-A-016 3f-84-P-005 3h-83-A-017 3-85-P-001 3f-83-A-019 3-85-P-002 3c-83-A-020 4
3e-83-A-021 3-85-P-003 3h-86-S-001 D.2 Reviewed SQN Storage Inspection Records from the Division of 1
Nuclear Construction (DNC) to determine if procedures were in place and deficiencies were being detected and corrected. The following records were reviewed:
MIG-4 C-3 MIG-5 E-94 MIG-6 E-96 MIG-7 E-117 MIG-8 E-118
. MIG-13 E-129 MIG-18 E-136 MIG-30 E-141 MIG-40 E-151 MIG-41 E-154 MIG-44 E-204 MIG-98 M-95 MIG-101 M-96 MIG-165 M-138 MIG-169 M-147 MIG-170 M-148 MIG-171 M-149 MIG-172 MIG-1 m.a
.'.1,
TVA EMPLOYEE CONCERNS:
REPORT NUMBER: NC-40400-SQN-
t SPECIAL PROGRAN REVISION ~ NUMBER: 4 RPAGE 4 0F 15 e
Reviewed Administrative Instruction _(AI) AI-36,~ Revision 9, dated E.
March 7, 1986, concerning storage and handling requirements for safety and nonsafety-related items to determine if it implemented
~American National Standards Institute:(ANSI) N45.2.2-1972 and Nuclear Quality Assurance Manual (NQAN), Part III.-Section 2.2, Revision dated June ~20, 1986, and performed the following:
Walkdowns of a. random sample.of-warehouses, storage yards, field-t 1.
storage, and holding; areas to determine if they were in-accordance with AI-36, Revision 9.
l Walkdowns of a random sample of st'orage areas to determine if 2.
and safety-Critical Systems, Structures, and Components (CSSC)
I nonsafety-related (non-CSSC) material was segregated in i-accordance with AI-36, Revision 9.
Conducted interviews with personnel that had been associated with i
F.
material storage and~ handling to determine if material controls had
~
been in place during construction.
Conducted interviews with fire protection engineer to determine if G.
fire protection was adequate for warehouses.
v i
i IV.
SUMMARY
OF FINDINGS
}
A review of the expurgated files for-the concerns did not reveal any A.
additional information. In addition, searched for other concerns-and/or. reports and no others were found except-for those identified i
j in Section I of this' report.
Reviewed ECTG subcategory report MC-40400 (Storage and Handling) and B.
This determined that the findings at WBN were applicable-to-SQN.
was due to the similar deviations being found by the_ Nuclear i
Regulatory: Commission (NRC) at SQN resulting in' violations.
4 Reviewed the NSRS'In'vestigation Repott I-85-990-SQN and determined C.
The It did not adequately address the perceived problems.
l investigation did not address field storage or storage during-l' construction.
In addition, several deviations were found during l
i this evaluation which were not detected during the NSRS investigation. However, the NSRS investigation identified.the following two areas to be addressed:
The fire protection for the storage buildings outside the 1..
new Office and Power Stores Building (addressed in this report i
in Section IV.G).
1 i'
,.9
~
AM %
T* '9'
1 TVA EMPLOYEE CONCEENS REPORT NUMBER: MC-40400-SQN-
~SPECIAL PROGRAN REVISION NUMBER:
4 PAGE 5 0F 15 2.
The poor condition of Hut 21 which stores. flammable paints and materials. The condition of Hut 21 has been addressed on Corrective Action Report (CAR) SQ-01-001 which will establish minimum requirements for paint and paint products and determine if Hut 21 will meet the minimum storage conditions.
D.:
1.
Reviewed QA Staff Audits on ONP. storage facilities and determined that deficiencies were being detected and corrected.
2.
Reviewed SQN Storage Inspection Records on DNC storage facilities and determined that deficiencies had been detected and corrected during construction.
E.
Reviewed AI-36 Revision 9, dated March 7, 1986, and determined it fully-implemented ANSI N45.2.2-1972 and NQAM, part III, Section 2.2, revision dated March 23, 1985. Additionally, the following was conducted:
1.
A walkdown of a random sample of warehouses, storage yards, field storage and holding areas to determine if they were in accordance with AI-36.
The findings were:
From the Power Stores storage facilities that were observed, a.
the following deviations or questionable conditions were-N found:
(1) Hut 11, an indoor storage building, had-several leaks in the roof.
AI-36, paragraph 5.6.1.1 states that the indoor storage shall be constructed so as to be weathertight and well drained with no standing water.
(2) Approximately 25 percent of the-stock material items in the storage yard were not in compliance with AI-36, paragraph 5.8 which states all items or their containers shall be plainly marked so that they are easily identified.
(3) Approximately 10 percent of the stock material items were 1
not in compliance with AI-36, paragraph 5.7.3.5 which states that items shall be arranged so that= racks, cribbing, or crates are bearing the full weight without distortion of item.
(4) Approximately 50 percent of the austenitic stainless:
steel' fittings (tees, elbows, reducers, etc.) were not in compliance with AI-36, paragraph 5.11.22 which states that austenitic-stainless steel ~ tubular products shall have end caps to prevent nesting or~ infestation of rodents, birds or insects.
o
- s. sum. t..ry r,.o 2m
l,,
.TVA EMPLOYEE CONCERNS
' REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAN REVISION NUMBER:
4 PAGE 6 0F 15 (5) _Approximately ten valves were not in compliance with AI-36, paragraphs 5.11.24, 5.11.25, and 5.11.26 which state that caps or covers shall be provided for nonstainless valves 4 inches and over and under 4 inches with flanged ends.. Caps for flanged openings or weld preps shall provide impact damage protection. Stainless steel valves shall have openings capped or covered, or small valves may be stored in bulk containers providing protection from insects.
(6) Hut 11 contained two circuit breakers and three motor operated valves which required indoor controlled storage.
Hut 11 was an indoor' storage building that does not have-environmental control.
AI-36,. paragraphs 5.11.14 and 5.11.27 which. state that indoor controlled storage is required for breakers and motor operated valves.
(7) QA Level I or II items were not stored'in' compliance with AI-36, paragraphs 5.8.1.3 and 5.8.1.5 which state that mixing of QA Level I and'II with QA Level III and no QA items is prohibited.
(8) Controls were not. implemented to ensure compliance with AI-36, paragraphs 5.6.1.3, 5.6.1.4, 5.6.2.1, and 5.6.2.2'which give temperature and dewpoint F-requirements.- Current methods do not provide assurance that temperature and dewpoint limits'have not been exceeded.
(9) Random lengths of coated-pipe were not stored in compliance with AI-36, paragraph 5.6'.3.3 which states that open sheds and/or covers may provide weather protection as required. Severe deterioration of-the coating was observed in many instances, apparently due to the lack.of protection from direct sunlight.
(10) Storage yard was not in compliance with AI-36, paragraph 5.5 which states outdoor storage areas:
shall be gravel covered or paved and well' drained.
Storage yard was partially. covered with gravel, not we11' drained, and had high weed growth, b.
From the Maintenance' Groups storage facilities that were observed, the following deviations were found at two outdoor storage huts:
1
~
.a m p..
. p; j
s
[TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN f.
SPECIAL PROGRAN REVISION NUMBER:
4 PAGE 7 OF 15 (1) Several hundred items that required either. indoor or.
indoor-controlled storage were stored in a breezeway.
These items included pumps, valves, motors, hangers, etc. Storage requirements tgr equipment / item category are listed in AI-36, paragraph 5.11, which gives the specific minimum _ requirements for the different categories of equipment and material.
(2) Items were not'on pallets or cribbing in compliance with AI-36, paragraphs 5.7.3.4 and 5.7.3.5 which state that items shall be stored on pallets, cribbing, shoring or equivalent in order to permit air circulation and prevent trapping moisture as well as bear full weight without distortion.
(3) Items did not have proper identification plainly marked on all items.
(See paragraph IV,.E.1.a.(2) of this report).
(4)
Items that were stored outdoors were o'ften on the ground.
(See paragraph IV, E.1.b.(2) of'this report).
(5) Austenitic stainless steel pipe was not capped or plugged.
(See paragraph IV, E.1.a.(4) of this report).
(6) Valves did not have ends capped or plugged.
(See paragraph IV, E.1.a.(5) of this report).
(7)
Items were stored in piles.
(See paragraph'IV E.1.b.(2) of this report).
(8) No access control to storage area.
Huts were locked but access to items in breezeway was not controlled.
AI-36, paragraph 8.0, and ANSI N45.2.2-1972, Section-6.2, states access to storage areas shall be controlled and limited only to personnel designated by the responsible organization.
(9) Austenitic stainless steel was not stored in compliance with AI-36, paragraph 5.7.4 which states austenitic stainless steel shall not be stored in contact with carbon steel, From the Modification Groups and Materials Section storage c.
facilities that were observed the following deviations or questionable conditions were found:
~-'
'~
u
',_Wh 9
- _ - - ~
TVA EMPLOYEE CONCERNS REPORT NUMBER:. NC-40400-SQN.
'SPECIAL PROGRAN J**
- -l REVISION' NUMBER:
4 PAGE 8 0F 15 I -
Nitrogen pressure was not maintained on heat exchangers (1)-
in storage yards.
AI-36, paragraph 5.7.1.c rtates that items pressurized with inert gas shall be mor.itored at such a frequency as to ensure that_the gas pressure is
~
maintained, within specified limits during storage.
~ Materials Section storage yard by Hut 21 had high weed (2) growth. ~(See paragraph IV, E.1.2.(10) of this report).
Naterials Section storage yard by Hut 21 had items I'
(3) with inadequate cribbing or stored on the ground.
(See paragraph IV. E.1.b.(2) of this report).
i (4) Naterials Section storage yard by Hut 21 had items that did not have proper identification.
(See paragraph IV, E.1.a.(2) of this report).
A walkdown of a random sample of warehouses, storage yards, field i
2.
storage and holding areas to determine if safety (CSSC) and.
nonsafety-related (non-CSSC) materials were segregated in 4
5 accordance with AI-36. The findings were:
From the Power Stores storage facilities observed, the a.
~
j following deviations or questionable conditions were found:
(1) As stated in Section IV.E.1.a.(7) of this report, QA Level I or II items were stored in the same bins without physical. separation of items QA Level III and I
non-QA although items were tagged.
(2) In the storage yard, stock material was not segregated into areas designated for certain QA Levels to prevent inadvertent mixing of materials.
b.
From the Maintenance Groups storage facilities that-were observed the following deviations were found:
~
(1) The storage areas did not have a Section designated for safety-related material,~although materials were identified and boxed. The safety and nonsafety-related materials could inadvertently get mixed.
1 (2) The storage racks had safety and nonsafety-related stock items on the same shelf. These items were mixed but did have 575s attached to identify material.
(See paragraph IV, E.1.a.(7) of this report).
From the Modification Group storage facilities that were-c.
~ observed, the following deviations were found:
i I
.n.
-TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAM l
REVISION NUNBER: 4 PAGE 9 OF 15 In _the.back of the Modification Building, there was a-storage area where nonsafety-related materials were stored in_ bins for various fabrications..This storage area.was designated non-CSSC material only, but it had material that could be_ identified and acceptable for This material is not segregated according to CSSC use.
AI-36 (See paragraph IV,' E.1.a.[7]).
This area of concern has also been addressed in the element report MC 40307,
" Scrap Material."
Interviews with personnel revealed that material controls were in F.
place during construction to control storage'and handling of' materials.
Interviews with Fire Protection Engineers' revealed that the new
-G.
Power Stores warehouse has adequate fire protection, and the old warehouses in the yard are protected by a fire hydrant system This lack-of fire which was not adequate for insurance purposes.
protection was an economic consideration and not a safety consideration. Fire protection shall be commensurate with type of storage area according to ANSI N45.2.2-1972.
Interviews with Power Stores personnel and-a random check of_ ten H.
nonsafety-related items did not reveal any evidence that safety and nonsafety-related material had been received with identical +.
identification markings and heat numbers. However, the issue of l
material traceability and the use of identical heat numbers received for different TVA piping system classifications has been addressed in the ECTG subcategory " Procedural Control" in the element report MC 40703, " Heat Code."
Conclusion this Many of the perceived problems indicated by.the concerns it; supplemental report were valid. During the evaluation, several deviations were observed along'with conditions that were questionable.
The overall' storage facilities at SQN were acceptable except for the leaking roof in Hut 11, the high weed growth in the storage yards, the storage yards not being well-drained, and the poor condition of Hut 21.-
The deviations to specified storage requirements that were observed include the following:
1.
Items were not plainly marked or identified in various storage j
locations.
2.
Items were stored with inadequate or no cribbing.
3.
Items were not stored in the appropriate storage level.
m 3.
m
%*2 u
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 10 0F 15 4.
Several items in various locations did not have caps or plugs. These included valves, austenitic stainless steel pipe and fittings.
5.
Proper segregation was not maintained for safety and nonsafety-related materials.
6.
Austenitic stainless steel was stored in contact with carbon steel.
7.
No access control to storage area.
8.
Nitrogen pressurization was not being maintained on heat exchangers.
9.
Inadequate methods were being used to determine if temperature and humidity levels were maintained within specified limits.
The final conclusion of this evaluation was that storage conditions were/are not always maintained in accordance with applicable requirements. However, it should be noted that during the construction phase of SQN as well as maintenance or modifications, installation and functional inspections / tests should identify any adverse conditions of material or equipment resulting from improper storage conditions. Additionally, any adverse conditions which are time delayed by nature should be identified during normal / routine plant operations, maintenance, tests, and inservice inspections.
Due to SQN's operating history, it appears that storage practices have not affected its safe operation in the past; and they should not have any detrimental effect on its safe operation in the future.
V.
ROOT CAUSE The deviations identified in this report resulted from the following two causes:
A.
Lack of attention to detail of storage requirements of AI-36 by the responsible line organizations.
B.
Misinterpretation of procedural requirements of AI-36 by the responsible line organizations.
VI.
CORRECTIVE ACTIONS The following is the~ pertinent contents of the consolidated Corrective-l Action Plan (CAP) that was submitted to ECTG by SQN ONP (Reference lR4 memorandum S03 870417 805), in response to the findings of this report.
I i
N
2 TVA EMPLOYEE. CONCERNS REPORT NUMBER: MC-40400-SQN
\\,
- SPECIAL PROGRAN REVISION NUMBER:
4 PAGE 11 0F 15-The.following corrective actions are.for' deviations noted in section-
-l l
IV.E.1.a of-this report:
-l The roof l leak identified in Hut 11 was corrected by site building l
1.
maintenance personnel. All warehouse facilities are inspected at
-l
.I specific _ intervals and any future leaks will be addressed and_
l corrected as'they are discovered.
l The material in the Power Stores yard that.was not properly marked l
2.
or identified was re-indentified and' remarked to provide positive l
l
' traceability on each item to conform to AI-36. requirements.
1 l
Material that has lost it's positive traceability due to ege of the
.l material, rust and corrosion was segregated in a separate area and l
marked as "Non-CSSC" material only.
1 The material in the Power Stores yard that required additional l
3.
cribbing to support the material was corrected by adding a third
_ l supporting timber to help bear the load.
~
~
l I
The discrepancy identified concerning the storage of austenitic l
4.
l stainless steel fittings is being addressed per memorandum from J. R. Staley to J. A. Teague dated December 16, 1986.
l l
~
IR4 An evaluation of the intent'of Division Procedure Manual
~
l (DPM) N82A17, regarding capping or plugging austenitic stainless l.
steel tubular products, Paragraph 7.21, item 2, was requested through James A. Teague, Supervisor, Electrical Component Engineer I
and Service Group. Specific attention was directed to item 2 which l
references a " Recommended Practice". The evaluation requested is I
for a clarification of the terminology " Recommended Practice" within l
l the DPM (Reference memorandum to James A. Teague, Supervisor,_
l Electrical Component Engineering and Service Group from John R. Staley, Supervisor, Power Stores, SQN, dated December 16,.
l l
1986).
1 A
l All valves identified which lacked proper capping'were corrected.
5.
review of all existing valves was conducted and storage conditions I
l were brought into-compliance with AI-36 storage specifications.
l The circuit breakers stored in Hut 11 were removed from the site I
6.
i and transferred to Power Stores Distribution Center (PSDC) at Hartsville Nuclear Plant. The breakers were surplus SQN l
l-Construction items.
m w
cw c;
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 12 0F 15 The Limitorque valve operators located in Hut 11 were Non-CSSC items I
and do not require an indoor controlled environment, but they were I
relocated to Hut 12 which has a Class B environment.
l l
7.
The bin locations that contained QA I, II, III and No QA material were l inspected and corrective action taken so that only QA I and II I
material is in the same bin location.
I I
8.
-The ECTG concern which questioned the implementation of AI-36 l
storage procedures to require temperatures and humidity recording i
devices was addressed in resolving CAR 83-08-026.
Plant management I
determined that the recording devices were not required and this I
was documented in surveys 3F-84-S-008, 009, 010, 011. 012 and 013 l
as well as the CAR response. The referenced surveys, as well as l
material inspection, have not found any problems due to humidity.
l The warehouse areas are inspected on a daily basis per Power Stores I
(Section Instruction Letter) SIL-30 which is an AI-36 requirement I
which allows Power Stores to monitor any variances in environmental I
conditions.
l l
9.
The random lengths of coated pipe stored in the outdoor yard were l
covered to protect the coating surface from direct sunlight.
l l
- 10. The weed control problem identified in the Power Stores' Yard has lR4 been addressed. Power Stores and Natural Resources personnel w'111 l
be responsible for controlling the weed growth in the storeroom l
yard areas. Natural Resources cut the existing weed growth in the 1
yard and will maintain and control the yard areas in the future.
l Areas requiring additional gravel or paving have been brought up to l
standards, providing adequate drainage.
l l
The deviations noted in the storeroom areas (yard and warehouse) had I
corrective actions taken to immediately bring the deviations in com-I pliance with AI-36 requirements.
(
I Power Stores is routinely audited by Site Quality. Assurance personnel, I
as well as offsite audit personnel, to ensure that the storeroom is in l
compliance with existing procedures. Audit findings are documented and l
violations are addressed and corrected.
l l
The following items address the maintenance storage-issues as referenced l
in items 1-9 of IV. E. 1. b of this report, and are intended to resolve l
those items:
l l
Administrative Instruction (AI-36), Storage. Handling, and Shipment-1 of QA Material, will be revised to require scrap or salvageable i
material storage areas to be so designated and access to be con-l trolled through administrative procedures.
l j..p r,
u mt
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAM
'C*
REVISION NUMBER: 4 PAGE 13 OF 15 Maintenance Section Superintendent will issue a memorandum to I
establish administrative controls'for key control and access to the i
maintenance groups storage areas.
I l
Maintenance Group will place signs on scrap / salvage. storage huts to' l
designate these areas as referenced in AI-36.- Signs will specify l
material evaluation requirements for scrap / salvage material stored l-in the maintenance storage areas.
l 1
Maintenance will revise (Sequoyah Maintenance Instruction) SQM-1 to-l define the requirements and responsibilities for spare part storage l
areas within the section and for controls of salvageabic material l
usage in plant applications.
Elements to be included in the l
revision are:
l
~
l
- Include requirements for maintenance section to review stor6ge l
requirements for materials kept and issued by the sections for-l spare parts and to initiate action to ensure that storage require-l ments of AI-36 are met.
(Note: This only applies to spare parts l
and not material retained for cannibilization).
l 1
- Include requirements for sections to evaluate, prior to use,.
lR4 materials salvaged or cannibilized from used material, material-
- l 1 eft over from previous work, or material retired to ascertain-l that the material is fully acceptable for its intended use. '
l Since the quality of this type of material may not be initially l
known, all items being evaluated for use on CSSC-systems shall.be l
nonconformed per AI-11 requirements. Material shall also be.
I evaluated, dispositioned, and' documented per AI-11 procedures.
l Also, in order to upgrade material for QA applications,-trace-l ability must be maintained during storage per SQA45 requirements.
l It should be noted that currently the NQAM Part III, Section 7.1 l
requires Plant Operation Review Committee (PORC) review, the Plant l
Manager's approval, and Division of Nuclear Engineering (DNE) l approval of nonconforming items which are recommended to-be l
dispositioned "use-as-is" or " repair". This NQAM requirement l
will be implemented at SQN in AI-11 within the required-timeframe-l The process of upgrading material for QA applications is not l
routinely used.
It is limited to occurrences of extreme urgency.
I l
- Maintenance will e quest that AI-11 be revised to reflect the i
requirements of the SQM-1 revision.
l
l TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN'
'?*'**.
SPECIAL PROGRAM _
REVISION NUMBER:
4 PAGE 14 0F 15
- Maintenance Group storage huts will be purged in an effort to l
reduce their inventory. Identified scrap material will be l
disposed of.through the Power Stores scrap yard. Surplus I
material will be returned to Power Stores to place the material 1
I in inventory for future usage.
I i
Sequoyah Administrative Instruction (SQA) 66, Plant Housekeeping i
Instructions, have been revised and strengthened to require a l
final checklist and sign off after completion of maintenance and l
modification work. Items included in the. final checklist are:
l l
proper designation for removal and uisposal of waste material, unused material, expendable items, old parts, removed components, l
and package material. The foremen are required to review and I
ensure that the final checklist complies with the requirements I
of SQA 66.
SQA 66 revision was approved on October 14, 1986 and l
l 1s being implemented.~
i The following actions will be taken to correct deviations noted in
. l:R4 l
section IV.E.1.c of this report:
l Measure dewpoint of existing nitrogen blanket gas in feedwater I
l heaters.
l If the dewpoint of any feedwater heaters exceed +20 degrees F, perform I inspection of the feedwater heater with the highest dewpoint above l
+20 degrees F to determine acceptability for service and if any I
additional feedwater heaters need to be inspected and evaluated.
I I
Appropriate corrective action will be taken if necessary.
l Purge feedwater heaters to obtain dewpoint not in excess of +20 1
l degrees F.
l Monitor feedwater heaters' nitrogen blanket pressure with the l
plant preventative maintenance program to maintain approximately l
l 10 psig.
l Items 1 through 3 have been initiated. Item 4 was implemented in l
l
" uary 1987.
I The weed growth in the Engineering Change Notice (ECN) storage yard l
will be~ controlled by Natural Resources personnel as identified in l
l IV. E. la(10).
y 7 w a n.
a u a p
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40400-SQN SPECIAL PROGRAM REVISION NUMBER:
4 PAGE 15 0F 15 The cribbing deficiencies identified in the ECN storage yard was l
corrected to provide adequate support for all material.
l l
The ECN storage yard was posted as a non-QA storage area for l
Modification material. Material has been evaluated as having 1
potential use, and will be retained for non-QA applications as I
shop spares.
I I
Additional Corrective Action i
i In accordance with a directive from the manager of Nuclear Power spare l
material for safety-related applications will be stored only under Power l
Stores control. This action will result in fewer areas where safety-lR4 related material is stored and positive identification end control of l
those areas. The directive will be implemented by March 10, 1987.
l The directive also includes a requirement for control of non-safety-I related material to prevent use in safety-related applications that will l
also be implemented by March 10, 1987.
l I
In accordance with existing procedures (AI-36, paragraph 5.10), a i
quarterly inspection of all storage areas is performed by Power Stores I
to ensure compliance with procedural requirements. Inspections are docu-l mented in accordance with AI-36 in Power Stores files. A special in-l spection of all safety-related material storage areas will be completed I
by Power Stores before April 30, 1987. The purpose of this inspection I
is to identify and correct deficiencies similar to those identified in l
ECTG Report MC-404.00.
l VII. GENERIC APPLICABILITY A.
The problems identified with capping and lack of attention to detail were determined to be generically applicable to Bellefonte and not to Browns Ferry by the WBN evaluation and are still considered applicable.
B.
The perceived problem of safety and nonsafety-related material being received with identical identification markings and heat numbers was determined to be generically applicable to all plants by the WBN evaluation and is still considered applicable.
VIII. ATTACHMENTS Attachment A:
Listing of concerns indicating relationship to Nuclear Safety and Generic Applicability.
m
~
' d,'
REPORT NUMBER: MC-40400-SQh REVISION NUMBER:
4
[
PAGE 2 0F 2 TVA EMPLOYEE CONCERN SPECIAL PROGRAM Attachment A GENERIC APPL QTC/NSRS P#
CONCERN SUB PLT B B S W Investigation S
CONCERN NUMBER CAT CAT LOC F L Q B REPORT R
DESCRIPTION XX-85-122-046 MC 40400 BLN Y Y Y Y I-85-126-BLN SR BELLEFONTE'- HANDLING OF EQUIPMENT IN T50222 REPORT STORAGE AND DURING AND AFTER CONSTRUCTION IS POOR. EQUIPMENT IN MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE.
ENVIRONMENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE. CI HAS NO FURTHER INFORMATION. ANONYMOUS CONCERN VIA LETTER.
XX-85-122-047 MC 40400 BFN Y Y Y Y I-85-152-BFN SR BROWN'S FERRY - HANDLING OF EQUIPMENT T50222 REPORT IN STORAGE AND DURING AND AFTER CONSTRUCTION IS POOR. EQUIPMENT IN MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE.
ENVIRONMENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE. CI HAS NO FURTHER INFORMATION. ' ANONYMOUS CONCERN VIA LETTER.
- PSR CODES:
SR-NUCLEAR SAFETY-RELATED SS-NUCLEAR SAFETY SIGNIFICANT NO-NOT NUCLEAR SAFETY-RELATED
REPORT NUMBER: MC-40400-5 N
/#
REVISION NUMBER:
4 PAGE 1 0F 2 TVA EMPLOYEE CONCERNS SPECIAL PROGRAM Attachment A GENERIC APPL QTC/NSRS P#
CONCERN SUB PLT B B S W Investigation S
CONCERN NUMBER CAT CAT LOC F L Q B REPORT R
DESCRIPTION IN-85-443-002 MC 40400 WBN Y Y Y N SS SAFETY AND NON-SAFETY MATERIALS ARE T50034 1.EPORT NOT KEPT SEGREGATED IN RECEIVING AND STORAGE.
WI-85-100-040 MC 40400 WBN Y Y Y Y SR HANDLING OF EQUIPMENT IN STORAGE AND T50213 REPORT DURING AND AFTER CONSTRUCTION IS POOR.
EQUIPMENT IN MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE.
ENVIRONMENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE.
CI HAS NO FURTHER INFORMATION.
ANONYMOUS CONCERN VIA LETTER.
t d
XX-85-122-045 MC 40400 SQN Y Y Y Y I-85-990-SQN SR SEQUOYAH: HANDLING OF EQUIPMENT IN T502IS REPORT STORAGE AND DURING AND AFTER CONSTRUCTION IS POOR. EQUIPMENT IN MANY CASES IS IN POOR CONDITION AND FILTHY DIRTY INSIDE AND OUTSIDE.
ENVIRONMENTS AND FIRE PROTECTION FOR STORAGE IS INADEQUATE. ANONYMOUS CONCERN VIA LETTER.
.+
A A
_ _ _.