ML20215A851
| ML20215A851 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 05/27/1987 |
| From: | Russell Gibbs, Hobbs R, Sacco R TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20215A652 | List: |
| References | |
| 80201-SQN, 80201-SQN-R06, 80201-SQN-R6, NUDOCS 8706170113 | |
| Download: ML20215A851 (19) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80201-SQN REPORT TYPE REVISION NUMBER:
Element Report 6
TITLE:
PAGE 1 0F 16 Inspection Criteria REASON FOR REVISION:
Tnis report was revised to incorporate NRC comments.
l Revision indicators are shown in the right margin of each affected page.
Note:
Sequoyah Applicability Only PREPARATION PREPA D BY:
R. D. RALVERSON C/77/V7 SIGNATURE DATE REVIEWS i
PEER:
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SIGNATUkE' e' DATE CONCURRENCES CEG-H :
f/[y/f7 SRP f Nx/,:/hiff d / /2 /f7 gIGNATURE*((
~DATE SIGNATURE DATE J
APPROVED BY:
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fw w 3
N/A SMCSP MANAGER DATE MANAGER OF NUCLEAR DATE POWER CONCURRENCE (FINAL REPORT ONLY) j
- SRP Secretary's sign.'*ure denotes SRP concurrences are in files.
8706170113 870605 PDR ADOCK 0500 7
P
TVA EMPLOYEE CONCERNS REPORT NUMBER:
~
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
1 Element Report 6
I TITLE:
PAGE 2 0F 16 j
Inspection Criteria i
l.0' CHARACTERIZATION OF ISSUES I
l 1.1 Introduction i
The issues described in this Element Report were derived from employee concerns generated as a result of the Watts Bar Employee Concern Special Program.
The issues were determined to be applicable to the Sequoyah Nuclear Plant and were investigated and evaluated on that basis.
1.2 Description of Issues The perceived issues reported by concerned employees are:
A.
Vendor welds are substandard.
(JAN-85-001 and JLH-85-005)
B.
Quality Assurance (QA) Program Adequacy.
(XX-85-050-001, XX 050-003, XX-85-102-006, and XX-85-125-006) 2.0
SUMMARY
2.1 Summary of Characterization of Issues The overall issues raised by concerned employees suggest that certain vendor welds made by Southwestern Engineering Company (SECO) and National Valve and Manufacturing Company (NAVCO) are substandard.
The adequacy of the QA program is questioned regarding installation of instrument compression fittings, visual acceptance criteria which covers the American Society of Mechanical Engineers (ASME),Section II, and TVA's Procurement Program regarding replacement parts for safety related equipment.
2.2 Summary of Evaluation Process The Quality As surance Category Evaluation Group (QACEG) Evaluation consisted of reviewing the appropriate requ'raments contained in documents such as:
Appendix B to 10CFR50; TVA'c Topical Report; Nuclear Quality Assurance Manual (NQAM);
ASME Codes; Standards; Specifications; Procedures; Instructions; and Reports.
In addition, discussions were held with cognizant personnel to gain additional information to aid in this investigation.
2.3 Summary of Findings The conclusions reached as a results of the QACEG Evaluation are:
The issues of vendor welds being substandard are substantiated.
A total of twenty-for welds made by SECO were identified as requiring rework.
Verificatiin of repair work was performed by Quality Control Inspectors and docuuented in a work plan.
Three welds made by NAVC0 a
TVA EMPLOYEE CONCERNS
. REPORT NUMBER:
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REPORT TYPE:
SPECIAL PROGRAM.
80201-SQN :
REVISION NUMBER:
Element Report 6
TITLE:
PAGE 3 0F 16 Inspection Criteria were also identified as requiring rework.
A maintenance request was issued and the' welds were repaired.
The issue of inadequate ' QA controls is partially substantiated-The QA Program controls for the installation of instrumentation compression fittings are inadequate or nonexistent.
The employee concerns regarding ' the visual examination procedure covering ASME Section 11 and TVA's Procurement Program allowing safety related parts to be purchased commercially are not substantiated.
2.4 Corrective Action Taken And The Results Achieved To Date Substandard welds made by NAVC0 and SECO have. been satisfactorily repaired.
Verification of repair work was. performed by QC Inspection and documented. TVA QA performed a survey of other welds.made by SECO with no additional adverse findings noted.
measures regarding instrument compression fitting.
Corr,ective installation activities included inspection and noninspection personnel training; evaluate compression fitting inadequacies for general applicability; and quality control inspection.
Inadequate compression fitting installation was also reported to the NRC under the rules of 10CFR50.55(e).
TVA' transmitted their final response to the NRC in July 1986.
3.0 LIST OF EVALUATORS W. M. Akeley R. D. Halverson J. E. Mann 4.0 EVALUATION PROCESS i
4.1 General Methods of Evaluation j
t Methods of evaluations included reviewing-the applicable TVA QA Program requirements and implementing procedures related to the issues.
Documentation was reviewed and discussions were held with the appropriate cognizant personnel.
4.2 Specifics of Evaluation i
4.2.1 Issue -
Vendor welds are substandard i
Reviewed Employee Concern Files including the Confidential Files for any additional information.
The Confidential Files contained additional infornation regarding the identification of the specific SECO and NA7CO welds in question.
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TVA EMPLOIEE CONCERNS REPORT NUMBER:
I REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element' Report 6
TITLE:
PAGE 4-OF 16 Inspection Criteria Reviewed Maintenance Request (MR) A-561926, da ted. 11/ 27/86, utilized in the repair of the NAVC0 welds and work plan 11777 which was utilized to repair the SECO welds.
Procedures N-VT-3, Revision. 4,.
" Visual Examiniation";
N-VT-4, Revision 2,.
" Liquid Penetrant Examination";
" Codes and Standards"; ASME Section-XI, Division I,
IWA. 4000, 1980 Edition, Winter 1981 addenda, " Rules for Inservice Inspection of Nuclear - Power Plants. Components"; and American National Standards Institute (ANSI) B31.7, 1969 Edition,. Summer 1970 addenda were reviewed to determine :the weld ac cep tanc e criteria.
Reviewed ASME Section. XI Summary Report, dated 1/20/86, indicating rework performed on NAVC0 welds and inspections conducted.
Inspected the three NAVC0 Safety Injection Welds (315D, 315E, and 316A) as identified on Drawing A 7257, j
Revision 4, Piece Mark.151-134.
4.2.2 Issue - QA Program Adequacy I
This issue addresses three areas of TVA's Quality As euranc e -
Program. The adequacy of the program is questioned regarding:
A.
Installation of Instrument Compression Fittings.
B.
Visual Acceptance Criteria for ASME Section II.
C.
Procurement of safety related parts.
{l Installation of Instyment Compression Fittings 1
Reviewed Employee Concern File - including Confidential Files for any additional information pertaining to this concern.
NSRS Report I-85-329-SQN (Attachment B) had been issued documenting the investigation and findings of this concern.
This report was reviewed and its ~ content re-evaluated.
Specifications, procedures, standards,
- codes, reports, ~ and-memorandums reviewed during this-investigation are included in the NSRS Report " Documents Reviewed.During Investigation I 329-SQN and References".
Construction Element Report C017304-SQN titled " Compression Fittings," was reviewed and the COCEG
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findings are'consistant with the results of this evaluation.
Visual Acceptance Criteria for ASME Section II Reviewed Employee Concern Files including the Confidential File for any additional information pertaining to this concern. No additional information was available.
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Reviewed ASME Section II, Parts A, B, and C, 1974 Edition and TVA Procedure BF-16.4, Revision 0,
" Material, Components, and Spare Parts Receipt, Handling, Storage, Issuing, Return to Storeroom, and Transfer".
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT. TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 6
TITLE:
Inspection Criteria PAGE 5 0F 16 Held discussion with a. cognizant individual from Quality As surance to determine if TVA has ever established and implemented a Visual Examination - Procedure related to ASME Section II.
Procurement of Safety Related Parts Reviewed Employee Concern File including the Confidential File 3
for any additional information pertaining to this concern.
No additional information was available.
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Reviewed Appendix B to 10CFR50; TVA Topical Report, TVA-TR75-
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1A/R8; Nuclear Quality Assurance Manual (NQAM) Part III, i
Section 2.1
" Procurement of Materials, Components, Spare
- Parts, and Services";
Division of Purchasing Procurement Manual, Revision 6/21/83; Reg. Guide 1.123, " Quality Assurance Requirements for the Control of Procurement of Items and Services for Nuclear Power Plants"; and Sequoyah Nuclear Plant Standard Practice (SQA 45), Revision 21, " Quality Control of Material and Parts and Services".
These documents were reviewed to determine the requirements and commitments for the procurement of items.
Held discussions with three cognizant personnel from Power Stores and Quality Assurance on the aspects of this concern.
5.0 FINDINGS 5.1 Findings on Issue - Vendor Welds are Substandard 5.1.1 Discussion QACEG investigation revealed th at SECO supplied twenty-four non-safety tube bundles for Units 1 and 2 Moisture Seperator Reheaters (MSR).
SECO installed the tube bundles in Unit 1 and TVA installed the tube bundles in Unit 2.
As stated in an un-numbered NSRS "Onsite Employee Concern Impact Evaluation", a snrvey was performed by a QC Inspector, a SECO representative, and the cognizant engineer to identify the defective welds.
In Unit 1,
a total of 24 SECO welds l
were identified as requiring rework.
SON Work Plan 11777 was reviewed and affected welds were reworked.
Verification of repair work was performed by QC Inspection and documented in the Work Plan.
The un-numbered NSRS evaluation "Onsite i
Employee concern Impact Evaluation" indicated that the concerned employee was notified of the repair work and +he employee was satisfied.
The three NAVC0 safety injection welds specified in this issue
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
I REPORT TYPE:
SPECIAL. PROGRAM.
80201-SQM f
Element Report REVISION NUMBER:
TITLE:
6 Inspection Criteria PAGE 6 0F 16' were identified as 315D, 315E, and 316A.
The welds were located in Fan Room #1, Unit 1, near valve 1-63-649 at the ceiling above the ladder access opening.
Several photographs were taken. by TVA Quality Assurance personnel showing actual weld conditions.
The welds were determined to be unacceptable in that they violated the visual acceptance requirements of N-VT-3.
Maintenance Request A-561926 was generated describing the rework necessary to correct the identified conditions.
Corrective Action consisted of grinding areas identified as unacceptable and performing the necessary nondestructive examinations (LP & UT) required for final acceptance in accordance with ANSI C31.7,1969 Edition, Summer 1970 Addenda.
Work was completed on January 20,
- 1986, with ANI/ANII concurrence.
As part of the QACEG cancern evaluation, an inspector from the TVA Quality Control group and a QACEG Investigator. verified weld identification and performed - visual inspection of the three welds in question to further substantiate corrective action and the proper closure of the Maintenance Request.
This reverification concluded that all icems were acceptable and that rework and reinspections were in accordance with the work instructions specified in the Maintenance Request.
5.1.2 Conclusion i
This issue is substantiated in that the welds in question were determined to be visually unacceptable.
Unacceptable SECO i
welds were properly identified and corrective action was I
accomplished in a satisfactory manner.
1 NAVC0
- welds, although visually unacceptable to the requirements of TVA's current procedure N-VT-3, did not require visual weld examination by the Fabrication Code, ANSI B31.7.
TVA, although not required, elected to rework ~ the NAVC0 welds in question to meet current visual weld acceptance criteria.
No further corrective action is required.
5.2 Findings on Issue - QA Program Adequacy A.
Installation of instrument compression fittings B.
Visual acceptance criteria for ASME Section II C.
Procurement of safety related parts 5.2.1 Discussion - Installation of instrument compression fittings An NSRS Investigation (I-85-329-SQN, dated 2/ 1/86) was j
conducted to determine the validity of this issue as received by the Quality Technology Company (QTC)/ Employee Response Team (ERT).
This report was reviewed by QACEG, its contents re-
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
l REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
6 Inspection Criteria PAGE 7 0F 16 evaluated, and the report was found to be accurate and factual.
In addition.to this investigation, NSRS has conducted two previous investigations of matters closely related to the above concern of record.
Those investigations resulted in specific recommendations from NSRS which were determined to be applicable to this issue.
Those investigations are documented as follows:
Reference 1 NSRS Report No R-85-02-SQN/WBN presents the results of a special review which was performed to investigate concerns expressed by Crawford Fitting Company.
Those concerns involved potential misapplication of the Swagelock tube fittings on the Westinghouse designed bottom-mounted incore instrumentation system seal tables.
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The report presents NSRS recommendation R-85-02-SQN-WBN-01 to NUC PR of fice-wide awareness bulletin on tube fitting maintenance activities.
Reference 2 NSRS Report No. IN-85-795-001; IN-85-795-002 presents j
investigation which was conducted the results of an regarding two employee concerns pertaining to Watts Bar.
Concern No. IN-85-795-001 stated that compression fittings on instrument tubing are not installed per vendor instructions.
The report contains evidence of potentially signi ficant conditions adverse to
- quality, and NSRS recommendation Q-85-795-001-01 states that an evaluation of this situation should b e.
conducted for generic applicability to all TVA plants.
Re ferenc e 1 presented NSRS' recommendation.R-85-02-SQN-WBN-01 which addressed the need for increased awareness of the critical and somewhat delicate nature of compression tube fittings in general.
The recommendation specifically encouraged NUC PR to prepare and distribute to the nuclear plants an office-wide awareness bulletin or similar mechanism to achieve an increased awareness.
This bulletin was issued September 20, 1985 to the nuclear plants with direction to take the following actions:
Issue the bulletin to employees whose work activities involve tube fittings.
Incorporate the concerns and policy stated in the bulletin into permanent hazard control instructions and plant instructions as appropriate.
Coordinate with the Nuclear Training Branch and implement training for employees involved in installation and maintenance of the tube fittings.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
1 REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
6 TITLE:
Inspection Criteria PAGE 8 0F 16 The text of the bulletin contains the following statements:
i "Sequoyah has initiated a training class on tube fittings in cooperation with the Power Operations Training Center (POTC)."
l "It is P&E (Nuclear) policy that compression-type tube
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fittings be installed consistent with manufacturer's instructions and that mainte nance activities involving these j
fittings shall not degrade the integrity of these fittings.'
Reference 2 presented NSRS' recommendation Q-85-795-001-01 which addressed evidence of a potentially significant condition adverse to quality regarding compression fitting inadequacies at Watts Bar (WBN).
The following actions were recommended and the results indicated:
NCR WBN-6278R0 was initisted to document the safety significance of the inadequacy of quality assurance controls on compression fitting installation for tubing connections.
The NCR states that installations were discovered at WBN which did not. agree with the manuf acturer's installation instruction.
The condition was identified as "significant".
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- b. The response to NSRS should include the results of an i
evaluation of this condition for generic applicability to all
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TVA plants.
It was determined that this evaluation had not been performed as of January 7, 1986.
NCR WBN-6278R0 received an engineering review by OE in accordance with the requirements of OEP-17, paragraph 3.2; OE has not performed an evaluation for generic implications of the condition to i
Sequoyah and Browns Ferry.
I evaluate compression fitting installation to determine the need for possible TVA process specification revisions.
As a result, OE developed a process specification 3.M.13.1 for installation and inspection of compression fitting joints in mechanical tubing systems.
This specification is applicable j
to all TVA projects.
Advance copies were distributed to all j
plant sites on January 2, 1986.
SQN DCU will route a copy to the SQN Modifications Branch for review.
- d. NCR WBN-6278R0 directed that OE provide analyses for certain compression fitting connections to determine the acceptability of these installations although leak tightness is achieved.
These analyses were performed by TVA's Singleton Materials Engineering Laboratory, and the results of the testing program are documented (Reference Attachment C).
The results provide technical information concerning the reliability and safety of
TVA EMPLOYEE CONCERNS REPORT I4 UMBER:
REPORT TYPE:
SPECIAL PROGRAM W 01-SQN Element Report REVISION NUMBER:
6 TITLE:
Inspection Criteria PACE 9 0F 16 compression fittings which may not have been installed with the manufacturer's recommendations but which achieve leak tightness.
On August 19, 1985, the Power Operations Training Center (POTC) established an initial tube fitting training program in cooperation with SQN.
This program is inte nded to provide individuals who install tube fittings with the necessary information to properly install tube fittings to. ensure a leak-proof, mechanically sound tubing connection.
The course material covers the most commonly used brands'of tube fittings.
Criterion II, requires that structures, systems, and components covered by the QA program he identified:
j Instrument sensing lines in safety-related systems have been identified in the QA programs for design and construction j
(Ref. Construction Specification N2G-877 " Identification of 1
Structures, Systems, and Components covered by the Sequoyah j
Nuclear Plant QA Program") and for the operation phases of SQN j
(Ref. SQA-134, " Critical Structura, Systems, and Components List").
Criterion II, also requires that the QA
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program provide control over activities affecting the quality of the identified structures, systemt, and components to an extent consistent with their importance to safety:
i The procedure which provided programmatic QA controls of activities during the construction phase of SQN is identified in DEDC-QAP-2.0.
However, lower-tier inspection procedures
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applicable to instrument sensing lines did not include
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provisions for quality control inspection of compression 1
fitting installation activities.
1 The procedure which provides programmatic QA controls of I
maintenance activities during the operational phase of SQN is identified in NUC PR QA Manaual Part II, Section 2.1.
- However, lower-tier SQN instructions applicable to instrument sensing lines do not include provisions for quality control inspection of compression fitting installation or maintenance activities.
Repaired instrument sensing lines are inspected by quality control personnel for cleanliness and leakage after reassembly.
Lower-tier SQN instructions (MI-1.9, Revision 7, " Bottom Mounted Instrument Thimble Tube Retraction and Reinsertion", and MI-1.10 Revision 3,
"Incore Flux Thimble Cleaning and Lubrication")
applicable to instrument thimble tubes do include quality control hold point provisions for mechanical verification and signoff, as well as cleanliness checks.
Critierion II, also requires that the QA
TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 6
TITLE:
Inspection Criteria PAGE 10 0F 16 program provide for indoctrination and training of personnel performing activities affecting the quality of the identified structures, systems, and components as necessary to assure that suitable proficiency is achieved and maintained:
The programmatic training requirements applicable to the construction phase of SQN were established.
The implementing doucument, QC-4,
(" Quality Control Instrumentation") contained modules for quality control inspector certification but not modules for training of personnel involved in installation of compression tube fittings.
The inspector certification module l
for instrument lines and loops had not been implemented by the time SQN construction was completed.
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The programmatic training requirements applicable to the j
operational phase of SQN are established by NUC PR QA Manual,
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Part III, Section 6.1.
Training requirements for training 1
l personnel are addressed in this procedure.
The lower-tier SQN instruction AI-14
(" Plant Training Program") which implements this procedure addresses maintenance. personnel training also, including personnel whose job function involves the installation of compression-type fittings on instrument sensing lines.
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However, the courses listed for these personnel do not cover tube fittings even though the office-wide bulletin previously discussed directs plant management to " implement training for employees involved in installation and maintenance of tube fittings."
1 Sequoyah Manuals SMI-1-68-20 and IMI-118 are examples of SQN maintenance instructions which involved compression-type fitting installation but do not specify personnel training requirements.
l Instruction MI-1.9 involves the installation of compression-type fittings on the instrument thimble tubes and does not specify that "all personnel working on tube fittings should have had the tube fitting class."
However, even this instruction does not clearly establish the training as a requirement.
SQN management is committed to the training of these personnel (e.g., Mechanical Test Unit); however the applicable instructions do not formalize the requirement.
In addition, the NUC PR Quality Inspector Training Manual establishes the training requirements for quality control inspector certification.
These requirements do not include instruction in inspection of j
installation of compression-type fittings.
- However, quality l
control inspection is required in MI-1.9 "to verify that the tube fittings are properly tightened."
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Criterion V,
requires that activites affecting quality be prescribed by documented instructions, procedures, or drawings.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report TITLE:
6 Inspection Criteria PAGE 11 0F 16 The above paragraphs address several instructions. and procedures applicable to activities affecting the quality of instrument sensing lines.
In addition to these documents, SQN engineering drawings and construction specifications essentially prescribed the only requirements pertaining to instrument sensing line installation and quality requirements.
These documents contain very little specific instruction / guidance for compression-type fitting installation.
- However, this situation has improved with the development and distribution of Process Specification 3.M.13.1, Revision 0,
dated December 9,
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- 1985,
" Specification for installation and inspection of 4
compression fitting joints in mechanical tubing 2ystems."
NSRS Report I-85-329-SQN provided four recommendations regarding installation of compression fittings.
They were, I-85-329-SQN-01, evaluate compression fitting inadequacies of NCR WBN-6278 for generic applicability; I-85-329-SQN-02, provide Noninspection Personnel Training; I-85-329-SQN-03, provide Inspection Personnel Training; and I-85-329-SQN-04, provide site requirements for Quality Control Inspections.
SQN response to I-85-329-SQN-01 indicated that NCR WBN 6278 was reviewed for generic applicability for ell compression fitting installations within the scope of the Watts Bar QA Program.
The response further stated that a Significant Condition Report (SCR)
SCR 6278-S R0 (identical to NCR WBN 6278) was issued.
The SCR form goes into more detail, particularly in the generic condition area.
SQN response to I-85-329-SQN-02 indicated tha: plant maintenance personnel responsible for installation and maintenance of compression-type fittings attended a formal training' course, "Given by the Nuclear Training Branch, Power Operations Training Center (POTC)."
In addition, the plant QA Staff is working with plant management to determine if the training requirements need 3
to be incorporated into the applicable plant procedures.
SQN response to I-85-329-SQN-03 states that the Quality. Control j
(QC)' inspectors attended the training course identified in the response to I-85-329-SQN-02 prior to being assigned verification
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activities for compression-type fittings.
This training provides sufficient guidance for the QC inspectors to perform the required verification activities.
SQN response to I-85-329-SQN-04 states that plant QC inspectors i
are currently performing inspections on the compression fittings during mainte nanc e and modifications when required by the appropriate work instructions.
However, there is no upper-tier or site requirement to perform these inspections, and these
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
i REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
6 Inspection Criteria PAGE 12 0F 16 i
activities will be included in SQN Work Instructions at the discretion of the QA Staif.
Inadequate Compression Fitting Installation was reported to the Nuclear Regulatory Commission under the rules of 10CFR50.55 (e) via WBN NCR 6278.
TVA (WBN) transmitted their final response to 6
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NRC open items WBRD-50-390/85-43 and WBRD-50-391/85-42 on July l
30, 1986 (L44 860730 816 Attachment C).
This response included a description of WBN's evaluation process and the results.
A sample inspection of compression fittings identified discrepancies in the following areas:
tubing cuts not ~deburred; tubes not bottomed out inside the fittings; nuts were not properly tightened; and ferrules were either unidentifiable, missing, or reversed.
The NRC, to date, has not formally j
accepted this response and it is still an open issue.
TVA's corrective actions included a Laboratory Testing Program to determine the long term affect on installed instrument systems with the above noted discrepancies.
Affected drawings, process specification, and instructions and procedures were, or are being revised to prevent recurrence of this problem.
SQN Engineering, utilizing WBN's Engineering 10CFR50.55(e) r evaluation of the compression fitting
- problem, has issued memorandum dated May 22, 1987 (RIMS E25 870522 021) which states; "SQN had similar contracts to Watts Bar Nuclear Plant (WBN) on compression fittings and utilized the same manufacturer.
Foi l
these reasons the Singleton Lab Tests done to support WBN apply 6
to SQN.
The closed drains were not examined for SQN due to operating experience.
This is an exception to the WBN 50.55(e) report which committed to examine closed drain lines.
If these (closed drain) fittings were lecking, then airborn radiation would have escaped from the tritiated drain tank and been detected in the auxiliary building.
These drain lines have been utilized during operation and are subject to general observation by operational personnel."
5.2.2 Conclusion Criterion X of 10CFR50, Appendix B requires that a program for inspection of activities affecting quality be established and executed to verify conformance with the prescribed requirements for accomplishing the activity.
The employee concern is substantiated because this investigation has l
revealed that quality assurance program controls for SQN were l
nonexistant or inadequate to comply with the applicable i
criteria of 10CFR50, Appendix B,
relative to compression fitting installation.
This condition existed during the construction phase and has existed in the operational phase of SQN.
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'i' TVA EMPLOYEE CONCERNS
. REPORT NUMBER:
.o REPORT TYPE:
SPECIAL PROGRAM 80201-SQN J
REVISION NUMBER:
' Element Report TITLE:
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PAGE 13 0F 16'
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Inspection Criteria
.i 5.2.3 Discussion - Visual-Acceptance Criteria for ASME Section II Concern of record indicates the visual examination procedure which covers ASME Section' II is very nonspecific.
Based on review of pertinent documents and discussions with cognizant
.j personnel, it was concluded by this investigation that TVA does not.have a visual examination procedure that pertains to ASME Section II.
5.2.4 Conclusion This issue is not substantiated.
ASME Section II has no visual. examination requirements for
.a.
fabricator and/or installer.
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5.2.5 Discussion - Procurement of. safety related parts Concerned employee, states that' the TVA System Procurement l
Manual allows procurement of IE, safety related NSSS.and hold devices to be purchased commercially,
.and.
not through
. qualified suppliers because they are part -of a
larger component.
During the investigation, it was determined that there.is no TVA System Procurement Manual ao noted in the. concern.
There is a Division of Purchasing Procurement Manual, Revision June 21,
- 1983, which references the Nuclear Quality Assurance Manual for quality requirements.
The governing directive is the Nuclear Quality Assurance Manual (NQAM), Part III, Section 2.1,
" Procurement of Materials, Components, Spare - Parts, and Services".
Lower-tier documents. are Sequoyah Nuclear Plant Standard Practice (SQA 45), -Revision 21, June 23,
- 1986,
" Quality Control of' Material and Parts and Services", and l
Watts Bar Nuclear Plant Administrative Instruction, AI-5.1, Revision 19, March 26, -1986,
" Materials Procurement and Control." These directives require that:
Items which are QA Level I must be procured from suppliers who have a QA Program approved by Division of Quality Assurance, Procurement Evaluation Branch (DQA PEB).
QA Level II items may require the supplier have.an approved QA program which conforms to the original requirements.
For QA Level II and III items that require a Certificate of Conformance (C0C), the vendor shall be required to have a DQA PEB approved COC program that meets the requirements of NQAM Appendix En Attachment 6,.Part III, Section 2.1 (QA Requirements for a Certificate of Conformance Non-ASME Code Items and Small Products).
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN l
REVISION NUMBER:
Element Report 6
TITLE:
Inspection Criteria PAGE 14 0F 16 I
For all QA Level II and III items, the vendor shall be required to furnish
- a. completed copy of Appendix D (Changes / Substitutions for QA Level II and T. II Items), or the suppliers own certificate which provides the information requested, when the item offered is not identical to the contract requirements.
Suppliers of equipment used in Class 1E application (device as a
whole which requires qualification by supplier or manfacturer) to include electrical wire and cable shall be required to have a QA program which conforms to the applicable portions of ANSI N45.2 or 10CFR 50, Appendix B.
Suppliers of commercial-grade equipment that has been qualified for Class 1E application of TVA (replacement equipment must be identical to equipment qualified) shall comply with the QA program requirements for a Certificate of Conformance.
Suppliers of standard design, commercial grade replacement parts (subcomponent, assembly, or module) inside equipment used in a Class 1E application (device as a whole which requires qualification), as a minimum shall attest to the in-kind replacement requirements of the contract by furnishing a
completed copy of Appendix D
(Changes / Substitutions for QA Level II and III Items) or the supplier's own certificate which provides the information requested when the item is not identical to the contract requirements.
l It should be noted that the procurement of safety related piece parts is an open issue with the NRC as described in potential reports 50-327/86-61 and 50-328/86-61 and is a enforcement finding (Attachment G).
In a letter to the NRC dated April 1,
1987 (RIMS L44 870401 807), TVA acknowledges problems in the procurement program with regards to commerical-grade items and has 1
initiated the replacement items program (RIP) at SQN.
The j
RIP program describes the methodology for performing engineering evaluations and dedications in support of the following:
a.
The procurement and dedication of commerical-grade
]
material for use in safety-related applications, i
i 6
b.
The evaluation of commerical-grade items installed in safety-related equipment.
c.
The assessment of previous item replacements during maintenance activities for seismic sensitivity.
l l
TVA EMPLOYEE CO2CEfiNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
i TITLE:
6 Inspection Criteria PAGE 15 0F 16-I d.
The evaluation of commerical grade items located in-the plant warehouse.(Power Stores).
e.
The evaluation of Balance-of-Plant (B0P)
- items, inventoried within Power Stores, for which a specific safety-related application has been defined.
f.
The development of pre-engineered specifications for 6
safety-related equipment to provide assurance that replacement items are not introduced into critical components / systems that could degrade their ability to perform the required. safety-related functions (s).
The pre and post-restart status of the replacement items project has been clearly defined in the program, plan.
To summarize, seismically sensitive equipment within the boundaries of the phase I design baseline and verification program and 10CFR50.49 equipment will be. evaluated before restart.
5.2.6 Conclusion, Although TVA is experiencing problems in. the procurement program with regards to commerical-grade items, the concern of record states that the procurement program allows the 6
procurement of safety-related items and hold devices to be purchased commarcially.
Based on review of the above documents and discussions with cognizant personnel, this concern, as written, cannot be substantiated.
It should be noted that the concern refers to a specific case known to Quality Technology Corporation (QTC) and withheld to' maintain confidentiality.
This case was unobtainable during the investigation therefore the details could not be verified.
i 5.3 Corrective Actions Substandard welds made by SECO have been satisfactorily repaired.
Verification of repair work was performed by QC Inspection and documented in SQN Work Plan 11777.
NAVC0 welds which were visually unacceptable to TVA's Procedure N-VT-3 were reworked and documented on Maintenance Request A-561926.
A Corrective Action Tracking Document j
(CATD) 80201-SQN-01 (Attachment D) was issued to the Of fice of Nuclear i
Power (ONP).
The CATD identified that. although the SECO welds were repaired, there was no sample inspection performed on other welds made by SECO.
The SQN Site Director responded to this CATD on October 20, 1986.
The response stated that SECO performed work at Sequoy4 nd, once.
Sequoyah Modifications requested that Sequoy an Quality l
Assurance perform a survey.
This survey was conduc.ced by Quality
{
Assurance with the participation of a SECO representative, and documented on In plant Survey Checklist 21-85-5-021.
Deficient I
welding was identified and corrected by TVA.
The response went on to l
say, "It is therefore concluded that the inspection / review effort did l
l h
l l
4 p.
r TVA EMPLOYEE CONCERNS-REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN
. Element Report REVISION NUMBER:
TITLE:
6 Inspection CriteriaL PAGE 16 0F 16 include the majority of welding performed by SECO with repairs being completed accordingly;.thus, no additional surveys are warrented".
.QACEG concurs with this response and considers the issued closed..
I Nuclear Safety Review. Staff (NSRS) ~ investigation of instrument compression fitting installation activities was documented in NSRS Report I-85-329-SQ-This report provided. four recommendations which included:
evaluate.
.ompreseion fitting-inadequacies for. general-applicability;. inspection and noninspection personnel training; and.
Quality Control Inspection..
Inadequate compression
. fitting installation was also reported to the. Nuclear Regulatory Commis sion -
under'the rules.of 10CFR50.55 (e) via NCR 6278.
TVA transmitt'ed their final' response to the NRC on July 30, 1986.
These-recent actions have been taken by..'SQN management and others to improve.the controls 'in the area of ' compression, fitting installation.
However, QACEG has issued a Corrective Action Tracking Document (CATD) 80201-SQN-02 (Attachment E) on September 12, 1986,' which. identifies the lack of training requirements in various procedures.
The SQN Site Director responded on October 20,
- 1986, commit ting revision to Administrative Instruction (AI) 14 to include referance to tube fitting class MTU-MMT-28.
QACEG also issued CATD 80201-SQN-03 (Attachment F) identifying that TVA's commitment to the NRC of developing Procedure MAI-29,
" Instrument Tube Fitting and Installation" and. issuing. it by August 15, 1986 has not been accomplished to date.
The SQN Site Director responded on January 24,-
1987 (RIMS. S03 870123~ 802) indicating that the SQN Modification Group has the responsibility to initiate MAI-29 and the estimated completion date is March 9,1987.
Attachment A,
identified the concerns as potentially sety-significant or safety-related.
QACEG evaluation concludes that caly.
concerns JAN-85-001 and XX-85-050-001 were potentially safety-significant.
However, corrective measures,. as described in this report, have and are being taken.
f 6.0 ATTACHMENTS A.
Employee Concern Program System (ECPS) List of Employee Concern
.Information B.
NSRS Report I-85-329-SQN C.
Final Report for NRC Open Items WBRD-50-390/85-43, WBRD-50-391/85-42 D.
CATD 80201-SQN-01.
E.
CATD 80201-SQN-02 i
F.
CATD 80201-SQN-03 G.
Potential Enforcement Finding 50-327/86-61 and 50-328/86-61
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RFO A X
a ATTACHMENi
- TV A 60 to5 9 65) (oP WP 5-Q9) t'NITED STATES COVERf0!ENT TENNESSEE VALLEY AUTHORITY
,,-],lH O TdM d MM l
H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant Cantrell, Manager of Engineering, W12A12 C-K TO:
R. W.
K. W. Whitt, Director of Nuclear Safety Review Staff E3A8 C-K FROM:
FEB 131986 DATE:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT
SUBJECT:
I-85-320-SON Transmitted herein is NSRS Report No.
ALLATION__
Subject OUALITY ASSURANCE CONTROLS / COMPRESS' ION FITTING INST ld -
XI-85-050-001 Concern No.
vsafT!. hT 3,q cg,1.8 &E P AN,T,,3 reJ'J L
and associated prioritis:ed recommendations for your c,,m
- .g 13OE action / disposition.
l It is requested that you respond to this report and the attach
. - u t,.
(
, 4 28, 1986. -}hould - yi lhave any Priority 2 (P2) recc,mmendations by February gs
'ed-i j CA t
t f
W.
D. Stevens_ at telephone;g g ll questions, please contact c.
~..
i i
t i1 UkfF _ l l
Yes _
Recommend Reportability Determination:
,9
/
I irector, NSRS/ Designee 9
WDS:GDM Attachment ec (Attachment):
j W. C. Bibb, SQN f
W. T. Cottle WBU x
James P. Darling, ;,LN l
R. P. Denise, LP6N/0A-C G. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant p
Eric Sliger LP6N48A-C j
J. H. Sullivan, SQN g 455U 04
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i TENNESSEE' VALLEY AUTHORITY UUCLEAR SAFETY REVIEW ST/JF I-85-329-SQN NSRS INVESTICATION REPORT HO.
.j
~
XX-85-050-001 EMPLOYEE CONCERN:
QUALITY ASSURANCE CONTROLS FOR COMPRESSION FIT
SUBJECT:
INSTALLATION DATES OF SEPTEMBER 18 - OCTOBER 8, 1985 INVESTICATION:
l C
R+ n.
%.'.+ '
A d 8d D0d STIGATOR:
DATE R. E. MCCLURE A["7 d
wb d DATE INVESTIGATOR:
W. R. SIMONDS 2[4/f 6 M,-
d REVIEWED BY:
D.1TE -
M. W. ALEXANDER d
Q Od
, APPROVED BY:
DATE W. D. STEVENS n
O l l
4
^
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" "44-fsp 12DD a -
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l
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l I.
BACKGROUND investigation was conducted to A Huclear Safety Review Staff (NSRS) determine the validity of an ex The l
the Quality Technology Company (QTC)/ Employee Response Team (ERT).
concern of record, as summarized on the Employee Concern Assignment stated:
Request Form from QIC and identified as XI-85-050-001,
" Inadequate quality assurance controls'were applied to the installation of instrument tubing compression fittings at Sequoyah."
In addition to this investigation, USRS has conducted two previous
~
investigations of matters closely related to the above concern of Those investigations resulted in' specific recommendations from record.
NSRS which were determined to be applicable to this employee concern. '
Those investigations are documented as follows:
NSRS Report No. R-85-02-SQN/WBN (Ref. 1) presents the results of a special review which was performed to investigate f.oncerns expressed A.
Those concerns involved potential by the Crawford Fitting Company.
misapplication of the Swagelock tube fittings on the Westinghouse designed bottom-mounted incere instrumentation system seal tables.
The report presents USRS recommendation R-85-02-SQN/WBN-01 to NUC pR for the preparation and distribution to the nuclear plants of an
'?
'.lf],';)\\
office-wide awareness bulletin on tube fitting maintenance
- ~~
activities.
NSRS Report No. IN-85-795-001; IN-85-795-002 (Ref. 2) presents the results of an investigation which was conducted regarding two B.
Concern No.
employee concerns pertaining to Watts Bar. stated that compression fitting IN-85-795-001 The report contains are not installed per vendor instructions.
evidence of a potentially significant condition adverse to quality, and NSRS recommendation Q-85-795-0'O'l-01 states that an evalua
~
~
this rituation should be conducted for generic applicability to all TVA plants.
II.
scope The scope of the investigation is defined by the concern of record.
Since previous KSRS investigations involved matters closely related A.
to this concern, the results of those investigations were included as appropriate in the findings of this investigation.
Reviews of regulations, specifications, and other pertinent docu-and B.
ments were performed to identify requirements, commitments, j
programmatic controls applicable to the concern of record.
Cognizant personnel were interviewed to help establish the manner j
J in which compression-type fittings have been installed at SQN.
/
1
7 s
I u-j i
j i
III.
SUMP.ARY OF FIUDINGS A.
Requirements and Commitments 1.
10 CFR Part 30 Appendix B Criterion II, " Quality Assurance Program" a.
" Instructions, Procedures, and Drawings" b.
Criterion V, Criterion I, " Inspection" c_.
Topical Report TVA-TR75-1, Revision 8 2.
Section 17.1.2.3, " Indoctrination and Training" l
n.
Section 17.1.5, " Instructions, Procedures, and Drawings" b.
Section 17.2.2.3, " Indoctrination and Trainin'g" c.
Sectica 17.2.5, " Instructions, Procedures, and Drawings" d.
Section 17.2.10. " Inspection" e.
er.
OEDC Quality Assurance Manual for Design and Construction N'
3.
OEDC-QAP-2.0, " Quality Assurance Program," Revision 1 a.
QAS-QAP-4.1, " Quality Assurance Indoctrination and b.
Training," Revision 0 CONST-QAP-2.02, " Quality Assurance Items," Revision 0 c.
CONST-QAP-2.07, " Qualification /Cortification of. Inspection,
- --l j
d.
~-
,,, Examination, and Testing Personnel," Revision 3 i
CONST-QAP-10.01, "In'spection," Revision 2 e.
Sequoyah Nuclear Plant General Desi;n Criteria No..SQN-DC-V-3.0, 4.
"The Classification of Piping, Pumps, Valves, and Vessels,"
Revision 1 Sequoyah Nuclear Plant Construction Specification No. U2M-865, 5.
" Field Fabrication, At embly Examination, and Tests for Pipe Duct Systems," Revision 3 j
Sequoyah Nuclear Plant Construction Specification No. N2G-877,
" Identification of Structures, Systems, and Components Covered 6.
by the Sequoyah Nuclear Plant Qunlity Assurance Program,"
i-
,. f Revision 5 2
J
~
4 6
4 NUC PR Uuclear Quality Assurance Manual 7.
Part II..Section 2.1, " Plant Maintenance," Revision 10/12/S4 a.
Part III, Section 6.1
" Selection and. Training of Personnel for Nuclear Power Plants " Revision-10/12/84 b.
' B.
Findings-recommendation R-85-02-SQN/WBN-01
' Reference 1 presented NSRS' itical which addressed the need for increased awareness'of the cr 1.
)
in and somewhat celicate nature of compression tube fittings The recommendation specifically encouraged NUC PR.to prepare and distribute to the nuclear plants an off general.
d 20, 1985
.This bulletin was issued September to the nuclear plants with direction to take the awareness.
(Ref. 39),
following actions:
Issue the bulletin to employees whose work activities o
involve them with tube fittings.
Incorporate the concerns and policy stated in the bulletin into permanent hazard' control instructions and plant o
I.'j%
instructions as appropriate, Coordinate with the Nuclear Training Branch and implement training for employee,s involved in installation and o
maintenance of the tube fittings.
The text of the bulletin contains the following statements:
Sequoyah has initiated a training class on tube fittings in o
cooperation with the P0TC.,,,_
It is P&E (Nuclear) policy that compression-type tube fittings be installed consistent with manufacturer's o
instructions and that maintenance activities involving these
'Tittings shall not degrade the integrity of these fittings.
Reference 2 presented NSRS' recommendation Q-85-795-001-01 which addressed evidence of a potentially significant condition 2.
adverse to' quality regarding compression fitting inadequacies at The following actions were recommended and the Watts Bar (WBN).
results indicated:
WBN CONST should initiate an NCR documenting this condition--
j ASME Significant NCR WBN-6278R0 (Ref. 21) was initiated to a.
document the safety significance of the inadequacy of quality assurance controls on compression fittingThe NCR states tha i
i.
installation f or tubing conne4ti;r.r.
installations were discovered at WBN which did not agree
,f The with the manuf acturer's installation instructions.
condition was identified as "significant."
3 f
e
4
'I The response to NSRS should include'the results of an evaluation of this condition for generic applicability to b.
all TVA plants--it wa's determined that this evaluation had NCR WBN-6278R0 not been performed as of January 7, 1986.
received an engineeringLreview by OE in accordance with the requirements of OEP-17 (Ref. 36) but contrary to OEP-17, paragraph-3.2, OE has not. performed an evaluation.for generic implications of=the condition to Sequoyah and Browns Ferry.
NCR WBA-6278R0 directed that OE evaluate compression fitting installation to determine the'need for possible'TVA process c.
As a result, OE developed'a specification revisions.
for installation and I
process specification (Ref. 27) inspection of compression fitting joints in mechanical This specification is applicable to all TVA tubing systems.
Advance copies were distributed to all plant projects.
sites on January 2,. 1986.
SQN DCU will route a copy to the SQN Modifications' Branch for review.
NCR WBN-6278R0 directed that OE provide analyses for certain d.
compression fitting connections to determine the accept-ability of these installations.although leak tightness is These analyses were performed by Singleton:
,-4, achieved.
,,,yi Materials Er.gineering Laboratory, and the results of the The testing program are documented in references 30 and;31.
.zi' results provide technical information concerning the reliability and safety of compression fittings which may-be-installed inconsistent with the manufacturer's recommenda-tions but which achieve leak tightness.
the Power Operations Training' Center (p0TC).
On August 19, 1985, 3.
established an initial tube fitting training program (Ref. 28).
in cooperation with SQN. _This,yrogram is intended to provide individuals who install tube fittings with the necessary ~ -
s i3 formation to properly install tube fittings to ensure a The course leak-proof, mechanically sound tubing, connection.
material ' covers"the most commonly used brands of tube fittings.
10 CFR part 50, Appendix B, Criterion II, requires that 4,
structures, systems, and components covered by the QA program be Instrument sensing lines in saf ety-related systems identified.
have been identified in the QA programs for design and cor.struc-tion (paragraph III.A.6) and for the operation (Ref 8.c) phases of SQN.
10 CFR part 50, Appendix B, criterion II, also requires that the 5.
QA program provide control over activities affecting the quality of the identified structurew,- systems,.and components to an
}
extent consistent with their importance to rafety.
4 j
4 a.
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The procedure which provided' programmatic QA controls of.
' identified in activities during the construction phase of SQN. isHowever, low
-]
(Ref. 35) did not' include il paragraph'III.A.3.a.
applicable to instrument sensing lines i
fitting provisions for quality control inspection of compress on f
i installation activities.
The procedure which provide's programmatic QA controls of f SQN is j
maintenance activities during the operational phase oHowever, lower-tier SQ j
identified in paragraph III.A.7.a.
8.a-d) instructions applicable to instrument' sensing li f
tivities.
compression fitting installation or maintenance ac lity Repaired instrument sensing lines are inspected by.qua ssembly.
control personnel for cleanliness' and leakage af ter rea i
l Lower-tier SQN instructions applicable to instrument th mb e j
do include quality control hold point ll as tubes (Refs. 8.e-f) provisions for mechanical verification and signoff, as we j
cleanliness checks.
t the 10 CFR part 50, Appendix B, Criterion II, also
}
ified l
6.
performing activities affecting the quality of the id
(
that
- 493, w.V.g; )
suitable proficiency is achieved and maintained.
i i
The programmatic training requirements applicable to the f
b and d.
construction phase of SQN pere established by III.A.3. contained modf J
The implementing document (Ref. 20) quality control inspector certification but no modules for.
f training of personnel involved in' installation of compression The inspector certification module f or-instru-nent lines and loops had not been implemented by the. time-SQN tube fittings.
construction was completed.,__,,,
T$e programmatic training requirements applicable to the
. Training operational phase of SQN are established by III. A.7.b.
i requirements for maintenance personnel are addressed in th s The' lower-tier SQN instruction (Ref. B.a) which implements this procedure addresses mainten procedure.
the installation of compression-type fittings on instru
~~'
- ~ '
do not cover tube fittings (e.g., Ref. 28) even though the sensing lines.
management to " implement training for empl installation and maintenance of tube fittings."
i 5
7 s
"s 1
)
f References 8.b and 8.d are examples of SQN maintenance instructions which involve compression-type fitting installatien t
Referenc but do not specify personnel training requiremen s.
8.e involves the installation of compression-type fittings on the instrument thimble tubes and does specify that "all-j personnel working on tube fittings should have had the tube j
fitting class" (presumably a reference to the program in Ref.
However, even this instruction does not clearly.cstablish j
28).
the training as a requirement, i
SQN management is apparently co.nmitted to the training of these however, the applicable personnel (e.g., Hechanical Test Unit);
In addition, instructions do not f ormalize the requirement.
j reference 22 establishes the training requirements for quality These requirements do not control inspector certification.
include instruction in inspection of installation of However, quality control inspection compression-type fittings.
is required in reference 8.e "to verify that the tube fittings are properly tightened."
10 CFR part 50, Appendix B, Criterion V, requires that 7.
activities affecting quality be prescribed by documented The above paragraphs instructions, procedures, or drawings.
address several instructions and procedures applicable to
,y3 activities affecting the quality of instrument sensing lines.
Ajf' In addition to these documents, SQN engineering drawings (e.g.,
and construction specifications (III. A.5 and 6)
Refs. 24.a-h) essentially prescribed the only requirements pertaining to l
instrument sensing line erection and quality requirements until These d0cuments contain very little specific recently.
instruction / guidance for compression-type fitting installation.
However, this situatioe has improved with the development and dist ibution of reference 27.
iit
,C,riterion I requires that a program f or inspection of act v t es 8.
affecting quality be' established and executed to verify conf ormance with the prescribed requirements f or accomplishing the activity.. Refer to paragraph III.B.5 above for findings related to this requirement.
IV.
CONCLUSIONS AND RECOMMENDATIONS
\\
A.
Conclusion The employee concern is substantiated because this investigation has revealed that quality assurance controls for SQN were nonexistant or
/
inadequate to comply with the applicaDie criteria of 10 CFR 50, This Appendix B, relative to compression fitting installation.
condition existed during the construction phase and has existed in However, recent actions have been
]
the operational phase of SQN.
taken by SQN management and others as described above to improve the
]
controls in the area of the employee concern.
6
V w
)
B, Recommendations I-85-329-SQN-01, Evaluate' Compression Fittinr. Inadequacies of 1.
.NCR WBN-6278 for Generic Applicability This recommendation is being reitereted from Q-85-795-001-01since previously identified in the original USRS report (Ref. 2) the actions taken by p&E (Nuclear) did not completely address Specifically, this - recommendation' as described in III.B.2.b.
NCR WBN-6278R0 has not been evaluated for generic applicability The NCR was transmitted.to OE on to all TVA nuclear plants.
for review. However, the review September 9, 1985 (Ref. 38),
did not include an evaluation for generic applicability as
.A,1though the findings presented required by OEp-17-(Ref. 36).
in-III.B.4-8 strongly.iadicate the applicability of NCR WBN-6278R0 to SQN, the ' final determination must bel performed' by Therefore, NSRS recommends that N.CR OE as described in OEp-17, WBN-6278R0 be evaluated for applicability to all TVA nuclear l
plants and that the results of this evaluation be documented and
- The response distributed as required by established p rocedures.
to NSRS should include a statement of whf the generic
[p2) applicability evaluation was not performed.
1 1-25-329-SQN-02, Noninspection personnel Training i.a
[u[
2.
As described in III.B.6, SQN management is'apparently. committed g
to training personnel involved in installation and maintenance However,-several applicable SQN of compression-type fitt'ings.
instructions do not formalize or clearly establish the personnel NSRS recommends that SQN instruc-training as a requirement.
tions applicable to the inst'allation and maintenance of l
compression-type fittings be revised to establish' training of
[p2) j personnel as a requirement as described in reference 39.
s 7-85-329-SQU-03, Inspection personnel Training.
~~
3.
NSRS recommends that tr'aining on compression-type fittings be l
developed and implemented for quality control inspectors at This training should provide specific instruction on the SQN.'
inspection methodologies for verification of the quality of 3
{F2) saf ety-related applications of compression-type fittings.
l 4.
1-85-329-SQN-04, Quality Control Inspection j
USRS recommends that requirements be established and amplemented in applicable SQN instructions that quality control inspectors conduct random sample inspections of compression-type. fitting installation activities. These inspections should be designed
'l to verify and document that these activities are performed in accordance with prescribed requirements.
Inspections could be
)
performed after installation bdt prior to hydcastatic testing.
Ip2]
I 7
I
)
DOCUMENTS REVIEWED IN INVESTIGATION I-85-329-SQN' AND REFERENCES Special Review of Manufacturer Identified Potential Misapplication of Swagelock Tube Fittings at Westinghouse Reactor Seal Tables - NSRS 1.
Report No. R-85-02-SQN/WBN Compression Fittings on Instrument Tubing - NSRS Report No.
2.
IN-85-795-001; IN-85-795-002 Swagekock Report on Imitation and Interchange - 1984
^
l 3,
0202.15 and 0202.16. " Instrument Mechanics 4.
NUC PR Area Plan Procedure Training" NUC PR DPM N77A12, " Requirements for Repair and/or Replacement of 5.
Nuclear Power Plant Process - Control Instrumentation" Swagelock " Gold Book" - Tube Fitting and Installation Manual 6.
t Westinghouse Installation and Standards Manual, Instrumentation and 7.
Control Standards, Section 3.0, " Pressurizer Scaled Reference Leg Level System," Revision 8/11/71
- +
8.
Sequoyah Instruction Manuals a.
AI-14 " Plant Training Program," Revision 30 SMI-1-68-20, " Repair Leak in Tubing Fitting 1-VLV-68-442A,"
b.
6 Revision 1 List,"
SQA-134, " Critical Structure, Systems, and Components (CSSC)
-a c.
- Revision 7 IMI-11B, " Filling of Scaled Instrument Systems Backfilling, Venting, d.
and/or Flushing of Instrument Sensing Lines," Revision 5 I
MI-1.9,'" Bottom Mounted Instrument Thimble Tube Retraction and j
e.
Reinsertion," Revision 7 MI-1.10. "Incore Flux Thimble Cleaning and Lubrication," Revisien 3 f.
9.
NUC PR Nuclear Quality Assurance Manual Part II, Section 2.1, " Plant Maintenance " Revision 10/12/84 a.
Part III, Section 6.1, " Selection and Training of Personnel for b.
Nuclear Pow.tr Plants," Revision 10/12/84
}
8
)
OEDC Quality Assurance Manual for Design and Construction 10.
a.
OEDC-QAP-2.0, " Quality Assurance Program." Revision 1 j
Q AP-Q AP-4.1, " Quality Assurance Indoctrination and Training,"
b.
Kevision 0 1
CONST-Q AP-2.02, " Quality Assurance Items," Revision 0 1
c.
CONST-QAP-2.07, " Qualification / Certification of Inspection, d.
Examination, and Testing Personnel." Revision 3
- . INST-QAP 10.01, " Inspection," Revision 2
~
e.
MEDS Search on CONST QA Training Requirements 11.
12.
10 CFR Part 50, Appendix B Criterion II, " Quality Assurance Program" a.
Criterion V, " Instructions, Procedures, and Drawings" b.
Critorion I,'" Inspection" c.
ANSI Standard N45.2-1971, " Quality Assurance Program Requirements for se-
- [
13.
Nuclear Power Plants" iv;i ANSI Standard N18.7-1976, " Administrative Controls and Quality Assurance i
14.
f or the Operational Phase of ' Nuclear Power Plants" 15.
ANSI Standard N45.2.11-1974, " Quality, Assurance Requirements f or the Design of Nuclear Power Plants" '
ANSI Standard N45.2.6-1978, " Qualifications of Inspection, Examination,
~ ~ -d 16.
and Testing Personnel for Nuclean P.ower Plants" TopicalRehortTVA-TR75-1;17.1.2.3;17.1.5;17.2.2.3;17.2.5;17.2.10, 17.
Revision 8 Sequoyah Nuclear Plant General Design Criteria No. SQN-DC-V-3.0, "The 18.
Classification of Piping, Pumps, Valves, and Vessels," Revision 1 19.
Sequoyah Nuclear Plant Construction Specifications N2M-865, " Field Fabrication, Assembly Examination, and Tests for Pipe a.
and Duct Systems," Revision 3
/
'N2G-877, " Identification of Structures, Systems, and Components b.
1 Covered by the Sequoyah Nuclear Plant Quality Assurance Program,"
4 Revision 5 20.
CONST QA Training Program Plan Program No. QC-4, " Quality Control -
1 Instrumentation," Revision 2 1
k 9
4
/
21.
WBNP-CONST ASME Significant Nonconforming Condition Report (NCR) No.
WBN-6278, Revision 0 22.
NUC PR Quality Centrol Inspector Training Manual j
23.
ANSI Standard B31.7-1969, " Nuclear Power Piping"
~
24 Sequoyah Nuclear Plant Mechanical Instruments and Controls Drawings
{
l 47B001-15, " Mechanical Branch Valve Connection seismic Support,"
a.
l Revision 2 1
b.
alW6001133, " Mechanical Instruments and Controls," Revision 8
~
47W600-1, " Mechanical Instruments and. Controls," Revision 12 i
c.
d.
47W813-1, " Flow Diagram Reactor Coolant System," Revision 25 j
q 47W555-1, " Mechanical CVCS - Chemical Control and Makeup Piping,"
e.
Revision 13
{
f.
47W600-24, " Mechanical Instruments and Controls," Revision 16 47W600-18. " Mechanical Instruments and Controls," Revision 6 fe.
g.
.E h,
47W600-16. " Mechanical Instruments and Controls," Revision 4 25.
Swagelock Tube Fitting Catalog C-983 26.
Parker CPI Catalog No. 4230, January 1977 27.
Process Specification 3.M.13.1 (RO), " Specification for Installa-tion and Inspection of Compression Fitting Joints in Mechanical 1
Tubing Systems," General Construction Specification G-29M, J
~
December 9, 1985
..{
s
\\
t 28.
MTU-KMT-28,'" Initial Tube Fitting Training," Nuclear Training Branch, Power Operations Training Center, Revision 1 29.
SQN Corrective Action Tracking' Report, CATS No. 85219, May.23, 1985 30.
Memorandum from W. M. Childress to R. M. Jessee, " Watts Bar Nuclear Plant - ASME Significant Nonconformance Report (NCR) 6278R1 -
Laboratory Testing," dated December 6,1985 (B46 851206 001) 31.
Memorandum from W. H. Childress to R. M. Jessee, " Watts Bar Nuclear j
Plant - ASME Significant Nonconformance Report (NCR) 6278R1 -
Laboratory Testing - Supplemental Data," dated December 17, 1985 (B46 851212 001)
J l
32.
Memorandum from M.
G. Parris to G. Wadewitz, " Requests for Investigation / Evaluation," dated August 15, 1985 (Col 850827 005) l 10 i
)
~~
~
", W. Whitt, "Sequoyah (SQN) and Hemorandum from James P. Darling
- Special Review of Manufacturer-33.
Watts Bar (WBN) Nuclear Plan Identified Potential Hisapplication of Swagelock Tube Fittings at j
Westinghouse Reactor Seal Tables - NSRS Report No. R-85-02-SQN/WBN,"
j dated May 6, 1985 (L44 850426 807)
SQN Workplan Specification kT No.10721. February 1,1984 34 85, " Installation Verification, CONST-SNP Inspection Instruction No.
Flushing and Pressure Testing of Instrumentation Sensing Lines, 35.
Campling Lines, Control Supply Headers and Signal Lines," RO Office of Engineering OEP-17, " Corrective Action," Revision 2
~~
36.
to K. W.'Whitt, " Watts Bar Nuclear Hemorandum f rom Guent er Wadewit:
Plant - Request for Investigation / Evaluation," October 1, 1985 37.
to J. W. Co'an, " Watts Bar Nuclear Plant Hemorandum from Guenter Wadewit:- ASHE Significant tionconformance Rep 38.
1985 Cottle to Those listed, " Tube Fitting Awareness 39.
Hemorandum from W. T.
and Initial Training," dated September 20, 1985 (L29 850909 817)
- ey
. :. ' 0 -
wy 4
4 4
.e,_
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i
.3 I
}
1
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11
~'
TWA e4 106 9 498
~
. UNITFD STATES COVERNMENT 3
[C7M O 76U d MM TENNESSEE VALLEY AUTHORITY l
R. K. Seiberling, Manager of Huclear Manager's Review Group (NMRC),
- H. L. Abercrombie, Site Director, ONP, 06PS-4, Sequoyah Nuclear Plant DATE
- April 18, 1986 g,,, (
SU BJ ECT: NUCLEAR SAFITY PIVIEW STAFF (NSRS) INVESTIGATION REPORT No. I-85-329-SQN, f
" QUALITY ASSURANCE CONTROLS /COMPPISSION FITTING INSTALLATION"
{
l
References:
1.
Menorandum from K. W. Whitt to R. W. Cantrell and me dated February 13, 1986, " Nuclear Safety Review Staff
)
Investigation Report Transmittal"
{
i 2.
Memorandum f rom J. P. Vineyard to H. B. Rankin dated March 28, 1986, "Sequoyah Nuclear Plant - Potential Generic Condition Evaluation" (B25 860328 005) (copy attached) j k
3.
Memorandum from John A. Raulston to Those listed dated j
February 25, 1986, " Potential Generic Condition Evaluation" (B45 860225 259) (copy attached)
,JN
- n.. :-
Attached is my response to NSRS Report No. I-85-329-SQN.
A_)
H. L, Abercrombie
(
PRW:GBK:RCB:DR Attachments APR > d '80 l
cc (Attachment;),:
Employee Concern Files, PIS, ONP, SB-2, Sequoyah
).,
--j i
J. L. Hamilton, QA, O&PS-3, Sequoyah
{ }
T. L. Hughes, ONP, 0&PS-3, Sequoyah E El Nueo I L. L. McCormick, ONP, SB-2, Sequoyah I 4 wmn l
m ill I pg.5 a ~'
COORDINATED: Q A/ JLHamil ton, Regulatory Engineering /LLMcCormp;h y I
- j. I i.vts 4
f--.Lh#H i
L iem l _! / _,.., i W $ ///nV t i ' T A AG l
l i, f 4 l
/.
_1Fu
}
T' 6T Rnv l' t gn;.i,rn Rnnals Rr orninriv nn the Pnvrnll Savin.ns Plan
./
NUCLEAR SAFETY REVIEW STAFF REPORI NO. I-8 5-329-SQN NSRS REPORT No. I-85-329-SQN_
Concern
" Inadequate quality assurance controls were applied to the installation tubing compression fittings at Sequoyah."
l of instrument q
Conclusion The employee concern is substantinted because this investigation has revealed that quality assurance controls for SQN were nonexistant or 10 CFR 50, Appendix inadequate to comply with the applicable criteria ofThis condition existed relative to compression fitting installation.
j B,during the construction phase and has existed in the operational phase and
)
actions have been taken by SQN management j
of SQN. However, recent the area of the others as described above to improve the controls it cmployee concern.
Recommendations I-85-329-SQN-01, Evaluate Comoression Fitting Inadecuacies of NCR
)
1.
s 't,..
WBN-6278 for Generic Aenlicabilitv_
j
. mS
%eG This recommendation is being reiterated f rom Q-85-795-001-01 pre-viously identified in the original NSRS report (Ref. 2) since the actions taken by P&E (Nuclear) did not completely address this l
recommendation as described in III.B.2.b.
Specifically, NCR WBN-6278R0 has not been evaluated for generic applicability to all The NCR was transmitted to OE on September 9, TVA nuclear plants.
1985 (Ref. 38), for review. However, the review did not include l
an evaluation f or generic applicability as required by OEP-17 (Ref. 36). Although the findings presented in III.B.4-8 strongly indicate the applicability of NCR WBN-6278R0 to SQN, the final determination must be performed by OE as described in OEP-~17.
Theref ore, NSRS recommends that NCR WBN-6278R0 be evaluated for the results of applicability to all TVA nuclear plants and that this evaluation be documented and distributed as required by estab-lished procedures.
The response to NSRS should include a statement of why the generic applicability evaluation was not performed.
(P2) 2.
I-85-329-SQN-02, Noninspection Personnel Training As described in III.B.6. SQN management is apparently co=mitted to training personnel involved in installation and maintenance of co=pression-type fittings.
However, several applicable SQN formalize or clearly establish the personnel instructions do not NSRS recommends that SQN instructions training as a requirement.
applicable to the installation and maintenance of compression-type fittings be revised to establish training of personnel as a require-ment as described in reference 39 (P2)
1
/
i
~
3.
1-85-329-SQN-3, Inspection Personnel Training
)
NSRS recommends that training on compression-type fittings be l
developed and implemented for quality control inspectors 'at SQN.
This training should provide specific instruction on the j
inspection methodologies for verification of the quality of j
safety-related applications of compression-type fittings.
(P2) _
4.
I-85-329-SQN-04, Ouality control Inspection NSRS recommends that requirements be' established and implemented j
in applicable SQN instructions that quality control inspectors conduct random sample inspections of compression-type fitting installation activities. These inspections should be designed to verify and document that these activities are performed in accordance with prescribed requirements.
Inspections could be performed af ter installation but prior to hydrostatic testing.
(P2)
)
-(
SON Response to I-85-329-50N-01 NCR WBN-6278R1 was transmitted to SQN Engineering Project (SQEP) by reference 3.
A request was made to perform a review and determine applicability to SQN by reference 2.
The NCR was then forwarded to the g3yy SQN Regulatory Engineering Section for distribution to the appropriate
%f 4:]
site sections and inclusion in the operating experience review (OER) program for any generic applicabil1ty.
It appears that the need for a generic review of NCR WBN-6278R0 was inadvertently overlooked in September
]
1985.
SON Response to I-85-329-SON-02 The plant maintenance personnel responsible for installation and main-tenance of compression-type fittings attended a formal training course, MTU-FEE-28, " Initial Tube Fitting Training," given by the Nuclear Training Branch, Power Operations Training Center (FOTC).
In addition, the plant Quality Assurance S taf f is working with plant management to determine if the training requirements need to be incorporated into the applicable plant procedures.
SQN Response to I-85-329-50N-03 The SQN quality control (QC) inspectors attended the training course identiiied in the response to I-85-329-SQN-02 prior to being assigned verification activities f or compression-type fittings. This training provides sufficient guidance for the QC inspectors to perform the required verifica tion activities.
}
)
SON Response to I-85-329-SON-04 The plant QC inspectors are currently performing inspections on the compression fittings during maintenance and modifications when required by' the appropriate work instructions. However, there is no upper tier or site requirement to perform these :.aspections, and these activities will be included in SQN work instruct.ons at the discretion of the Quality Assurance S taf f.
4 S[
6 4=.
--e.
I l
l ATTACHMENT C L44 860730 816 85080100038 SN 157B Lookout Place 37402-2801 Chattanooga, Tennessee
/
WBRD-50-390/85 43 WBRD-50-391/85-42 U.S. Nuclear Regulatory Conrnission q
Region II Regional Administrator f
Dr. J. Nelson Crace, Attention:
201 Marietta Street, NV, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
SION WATTS BAR IrUCLEAR PLANT (WBN) - UNITS 1 AND 2 - Q 85 42 -
TITTINOS OM INSTRtJKENTATION TUBINC - WBRD-50-390/85-43, WBR I'
Try AL REPORT The subject defleiency was initially reported to NRC-Region II Inspector 1985, in accordance with 10 CTR 50.55(e) 4 as Al Ignatonis on September 24, Previous interim reports were submitted on O 1985, and Enclosed is our final report.
W55 6278.
January 31 and March 31, 1986.
q-a f"y belay in submittal of this report was discussed with Morris Branch on
+
3 July 17, 1986.
If there are any questions, please get in touch with J. A. Mcdonald at
.~.....
(615) 365-2527.
very truly yours, N
TEF SS E V Y AUTHORITY l
J' N
R. L. Cridley Director C)
~
Nuclear Safet and Licensing tncloeure l
ec (Enclosure):
Er, James Taylor, Director f
Office of Inspection and Enforcement i
U.S. Duelaar Regulatory ConsLission i
j Washington, D.C.
20555 -,
-m Records Center Institute of kuelear Power Operations 1100 circle 75 Parkway, suite 1500 Atlanta, C+orgia 30339 RKE:CPP:3CP cc (Enclosure):
E. A. Padde, 9-169 SB-E i
i tIxg y av TRA-C J. A. Raulston, W10 C126 C-K C W. Cantrell, BE 1E 76B-C 3rRC Resident Inspector, Watts Bar j E. E. Ennis, Watts Bar-OsrP Cuenter Wadewitz, Watts Bar NU CDs
- 1. E. Ke ll y, LP a f 4 5 A-C J. A. Mcdonald, Site Lic. WBN-ONP l
COORDINATED: DKE/Prahl VBM/Tickey b. c. LSC, LP S H 106 B-C
{
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QhDD1DN[
0958b i
s 1
ENCLOSURE j
WATTS RAR NUCLEAR PLAET UNITS 1 AND 2 QUESTIORABLE COMPRESSION TITTINGS ON INSTRUM WBRD-50-390/85-43, VERD-50-391/85-42 NCR 6278 10CTR50.55 (e) rINAL REPORT l
l peserirtion of t>efieleney TVA has identified through its employee concern program (eaployee concern that various j
Tv-85-795-001 and 002) and, subsequently through WCR 6278 R0, i h fitting compression fitting installations were not in accordance w tThese compression fitt manuf acturer's installation reconsnandations.
i i
used for instrument-related ASME Section III tubing connections on var ous f
ASME Section III requirements for use of l
. systems throughout the plant.
' compression fitting joints include installation in accordance withThe type l
manuf acturer's recommendations.
fittings as well as Imperial gastman "Hi-Saal" fittings.
k i
l As a result of these employee concerns, a sample inspection of 107 compress onl fittings used in instrument or sampling lines was performed and 60 discrepancies identified whleh fall in the following general categories:
7 tubing cuts were not deburred; tubes were not bottomed out inside the l
- q fittings; nuts were not properly tightened; and ferrules were either W1 unidentifiable, missing, or reversed. ' These installation problems are
[*.
3 attributed to inadequate or nonaxistent site procedures and inadequa J
T trained construction craftsmen.
- y of requirements.,
Af ter this sample inspection was completed, WBK ma 3
This category involves the use of Parker-CPI tube end reducers with N
1mperial-Eastaan "Hi-goal" nuts and ferrules as a means to connect t 6274.
N instrument panel isolation valves.
(It should be noted that these type with manufacturer's recommandations.
installations are not in the ASME code boundary.)~ The cause of this particular condition was determined to be an error in TVA drawings which C
a,llowed the use of either Parker or Imperial-Eastman tube and reducers.
Esf ety Iss*11citient In general, without adherence to manuf acturers' recon All " closed-ended,". safety-related instrumentation leaktas conn +ctions.
This testing tubing receives hydrostatic or pneumatic pressure testing.
elle hntas any concern with the adequacy of the initial seal of theH compression fittings.
ir adequacy of the seal due to vibration induced during normal plant operat on o Either of these cituations had the potential for during a seismic event.
- Also, allowing the vibrations to loosen the fittings and develop a leak.
kners in instrumentation tubing would not be detected during pressure testing ii and could land to an accumulation of " crud" and an eventual flow restr ct o Tube laakage or flow restriction could cause errors in instrument readings of instrument in question and the type of varytng degrees depending on thesuch instrumentation errors could adversely af f ect problem.
$9h
,l I. $
2-I nd vent lines, the lines lg i
In the case of open-ended instrument tubing, dra ns, a ld be tested and any leakage due to inadequate fittings wou g
significant pressure behind it.
are not pressure minimal as such leakage would not have g
corrective Action items identified in Revision 0 b
A compression fitting testing program for these This Material Laboratory.
l of yrt 6278 was Perf ormed at TVA's Sing e onflow rate due to the presence of j
lt installation j
program included testing of the ef f ect onintegrity of fittings with varioustests; and seiss tubing bures; testing of the i
defleiencies, by tens 11* Pullout and vibration f at gueThe results instances where tube ends were not deburred, tubes were nottill be satisfactory even event tests.
properly tighterned, fitting performance would sthough the j
i integrity. Also, nomal D
l" ferrules installed backwards),
operation fatigue testing exhibited no (including Imperial-gastman Fastener "HL-Seaand seismic eve light leakage (undetectable on 1
in 2 of 47 samples.
I the pressure gauges) and are a severe test of fitting integrity.
?
ror fittings with alssing, reversed, or unidentified ferrules, it was k,,
?
7 ite leak during determined that a missing ferrule would cause a defin it was a ** CPI" fitting, 4.
9 p(
hydrostatic testing; a reversed ferrule would leak ifbut wo
.y l
and that the g
g.:
unidentified ferrule noted on the nonconf omance reporever f;
i htening. This N
- 1..
if i
specific case was a
llations, unacceptable b
during pressure testing.
three particular types of questionable ferrule insta N
to leakage or h
installations would be detected during hydrostatic test h
would be no M
driving force to crsata any significant leakage. -
h overall TYA hay detemined that it is acceptable to use these type f G.
C3 t subject to f
"as-is" with th exception of fittings on lines which are nolocal instrument pressure tests but could s** radioactive servlee, and sor.eOn lines that are panels whicb may not have been hydrostatically tested.been pressure tested ar
[;
d r
eubject to pressure testing, those that have alrea yacceptab k
that they will i
provide satisf actory service, and t. hose fittings instawhich
- }
i f normal hydrostatic testing if they laak.
tested d
For those fittings seeing radioactive service in lines not pressure d and any (e.g., drains) TTA plans t.o have the connections reinspecte l
d by fuel discrepant fittings f ound during this reinspection will be rep acelocal pa insp+ct all the panels for safety-related instrumentation f or leaking load for each unit. For the L
i het compression fittings during initial heatup for unit 1 and dur ng functional testing for unit 2.
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f With regard to the Parker-Mannifin tube end reducers installed with the imperial-gastnan "Hi-Seal" nuts and f errules. TVA has determined through 7I tensile and vibration tests and analysis that fittings with this type discrepancy are functionally reliable and all existing installations are acceptable as-is.
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i To prevent recurrence of the type problems in revision 0 of WCR 6278, TVA has
- I revised Construction specification G-09, " Process Specification for Weldins, Heat Treatment, Won-destructive Exarnination and Allied Field rabrication
]'
Operations," to detail the requirements for installation, remake and inspection of compression fittings. These requirements have been incorporated
";,r into the Division of Nuclear Constructions' (NU COM) Quality Control Procedure
(
QCP 3.13-6, " Installation and Inspection of Tubing Instrumerit Lines," as well as Quality control Instruction (QCI) 3.13. " Mechanical Tube Fitting Installer
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Perf ormance Certification," to which appilcabib NU CON craft have been trained and certified. Work on compression fittings which would be done by operations E4 personnel will be controlled by MAI-29, "Instrusent nsbo Fitting and Installation" which is scheduled to be issued by August 15, 1986.
W N
To prevent a recurrence of the type problem identified by revision 1 of this X
NCR, TVA has revised its applicable drawings through ECW 6313 to specif y use
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of tube end reducers runde by the same manuf acturer as the fitting it is to be D
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. Abercrochie, Site Dire::or, Secuoyah Nuclear Plant ONP TROM
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SU EJE CT ' SEQUOYAH NUC*.IA? Pl.AN!-E".Pl.0YEE CONCEPJ;S TASK CROUP (ECTC) ELIMENT FIPor,TS S0101-SQN, SC2C.-SQN, AND 80203-SQN-QUAL ~TY ASSURANCE CATIC0KY-CORFICTIVE j
AC !CN FL/J S A: ached are :::ies of ESCP C:Tre :ive A : ion Tracking Documents (CATD)
Nos. 50101-SQN-21, 80201-SQN-01, 80201-SQN-02, 80201-SQN-03, 80203-SQN-01, t
and 802C0-SQN-C2 along with the Cerree:ive A:: ion ?lan responses l
concerning :he subje : elemen: repor:s.
The Quali:y Assurance Cz eg:ry Group Eead concurs with your terree:ive action plans at:i has incerperated the= into their apprcpriate elemen:
repert.
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W. R. Brown, Program Manager, Employee Concerns Tast Group. ONP, Watts Bar Nuclear Plant FROM H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant DATE October 20,'1986 SL'BJECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT 3
REPORT 802.01 SQN R1 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated September. 12, 1986, " Watts Bar Nuclear Plant - Employee Concerns Tast Group (ECTG) Element Report 80201-SQN - Inspection Criteria (Sequoyah)'? (T25 860916 991) l l
I acknowledge receipt of your element report and in accordance with your request (see reference), Element Report 802.01 SQN R1 has been reviewed for applicable corrective action.
By this memorandum I am endorsing the site line organi::ation CAPS and attaching these CAPS for your review and concurrence in response to your T"
CAID 80201-SQN-1 and CATD 80201-SQN-2.
These CAPS are not restart requirements.
(
If you agree with the proposed CAPS, please sign the ECTG concurrence space below item 9 on the CAP tracting checklists and return the CAP tracking checklists.
l h
Y M&?n E. L. Abercrombie RCD:JDS:JB:CS Attachments RECEIVED l
et (Attachmelts):
A. G. Debbage, ONP, ECTG Building, WBN
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1= media:e Corrective Ac:icn Required:- -/Y/ Yes
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Stop Work R e c o=:m e nd e d :./../ Yes
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Carp No.
EC201-SON-1 4
IN!!!/.T;0N DATE 9 /12 /86 3.
FISPONSIELE ORCAN1.A~10N: Office of Nuclear Power 6.
FROE'.lM DESC?."? TION :
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liQR Vender velds. identified-in this-I'emen F.e c e r : (Concern JAN-ES-001 an:
.'LM-15-005 ) were = ace ov National Valve enc M:nufacturine Comnanv (NAVCD) and Sentrv Ecuiement Nrocration (SECO) were s u t.-
stancard and recuired rework.
Corrective Ac: lens for these welcs ci no: incluce a samole insnee:lon of c:ner veles erocuted ev NAVC0 cr SECO.
/ / ATTACHMENTS 7.
FFl?AFID EY:
NAM.E R.
D. Mc1verson MA DATE:
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Corrective Action Plan of Employee Concern Investigation i
Iracking Checklist ECTG Report /CATD Number
- 4 4/ JT#8///
Lead Organi::stion Responsible f or Corrective K' tion Plan c
CORRECTIVE ACTION PLAN (CAP) 1.
Does this report require corrective action?
Yes No e (If yes, describe corrective action to be taken, if no, provide justification)
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Identify any Similar item / instances and corrective action taken.
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Will corrective action preclude recurrence of findings? Yes No Does this report contain findings that are conditions adverse to 4.
cuality (CAQ) as defined by AI-12 or NEP 9.1?
Ies No A
e.R.,4 5.
If a CAQ condition exists, what CAQ document was initiated?
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Which site section/ organization is responsible for corrective action?
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Is corrective action required for, restart?
Ies No X (This determination is to be made using the " Criteria for Determination of Restart Items" in accordance with the Nuclear Performance Plsn, Volume 2.)
P2 cone number for restart corrective action? Zone 8.
9.
Estimate completion date for corrective action.
Completed By
/
MNom I ate a'-Af'C Approved By 7 >J 01%
Date
! n-2-8 /l ECIG Concurrence U 5 h hf/ ~
Date
'10.
Was your corrective action initiated and completed in accordance with step 1?
Yes No 11.
If step 10 is no, describe the corrective action taken.
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12.
Is the corrective action implementation complete!
Ies No 13.
Is the corrective action documentation closed?
Yes No 14 What documents were used to implement the corrective action?
Completed By:
l Date j
Verified By:
Date Er~G Closure:
j Date i
k Centinued on back page I
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Reference:
i ECTG Report CAT D 80201-SQN-1 (T25 80916 991)
In reference to the EC~G report effort, concerns investigated (JAN-8-001 and JLH-85-005)it should he noted that both were:
1.
Specific to a referenced location job or j
2.
Investigated by the site nnager fo: whom the concerned Individual reported his concern.
i 3.
The concerned individual in both cases was satisfied with the response.
Additional comments are provided for each concern.
{
Concern JAN-85-001 Contrary to the investigator'c report, SECO does not reference S i
Eguipment Corporation but references work performed by Southwester l
l entry i
Engineering Company (SECO).
once, with that occurring be* ween September 1985 and Novem n
concern was received November The 26, 1985.
Sequoyah Hodifications This was accomplished by QA and documented on a checklist (21-85-5-021).
3 returned to Sequoyah to participate in the eval,ation. Additionally, a SEC e
,,6 welding was corrected by TVA and a warranty claim was submitted f Deficient
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processing.
or It is therefore concluded that the inspection / review effort did i the majority of welding performed by SECO with repairs bei nclude accordingly; thus, no additonal surveys are warranted.
ng completed Concern JLH-85-005
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\\N The review of this concern included a discussion with an ind y p
\\1 (L. G. Herbert) who was the cognizant construction i v ual i;
time that NAVCD piping was received onsite at Seq toyah nspector during the
$> [Y a similar concern was expressed in 1976 to the visual adequacy of NAV He stated that j
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This concern was satisfied by reviewing radiography film of th 0
potential worse-case basis.
welds were not ground flush or at least smooth, as was the TVAThe
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r the welds were satisfactory (passed X-ray criteria) practice, /t memorandum from L. G. iferbert to J. L. Hamilton dated May 29 Reference
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, 1986.
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' Sequoyah has recently completed a study on velding which was per
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by contractors, TVA weld project personnel, ANIS M
others.
TVA and contract suppliers.This effort included a review of field welds perform that Sequoyah welding _ practices _were acceptableThe conc 2.usion reached b y
Force Report L44 860207 800 gs, and later revisions.
Reference Welding Task
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Many of the NAVC0 wolds have been inspe:ted as part of the in-service-
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inspection program required by Section XI of the ASME Cede. Others will be inspected as the program (SI-ll4) continues through the plant life.
(
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These inspections have yielded. no evidence of an abnormal rejection rate
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in NAVCD welding.
1
'I Based upon these efforts, it is concluded that no justification exists for additional surveys.
LDA.GDL 10-1-86 0212M
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UNITED STATES GOVERNMENT ISMO 7dndum TENNESSEE VALLEY AUTHORITY p%.
9
-Ib John L. Hamilton, Jr.', Supervisor, Quality Enginee*.ng/ Quality Control, ONP, Sequoyah Nuclear Plant TROM 4
Leo G. Hebert, Quality Assurance Evaluator, DNQA, WBN, ONP, r
DATE May 29, 1986 L
SUBJECT:
WELD RADIOGRAPH REVIEW
{
This raemorandum is in response to our conversation on April 17 and P.ay 23, 1986 regarding a review of weld radiographs at NAVCO Corporation, Pi,ttsburgh, Pennsylvania.
In early 1976, March / April, verbal concerns were expressed by the craft welders at Sequoyah Nuclear Plant in regards to the poor visual appearance of NAVCO spool piece welds; yet the Construction Quality Control inspectors 1
.were rejecting velds that appeared. to have a higher standard of quality.
]
Arrangements were made with Mr. Robert Jackson.of NAVC0 for me to review radiographs at their facility. A usik-through, utilizing construction management, was made; welds were selected on a worse-case basis; and d
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- photographs were taken to allowHAVC0 personnel to understand our concern.
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I made a trip to Pittsburgh, Pennsylvania and' reviewed the radiographs of 3
the selected welds; even though the welds did have a poor visual appearance,
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all radiographs reviewed did meet the appropriate quality standards.
For
' record purposes, it should be noted that at the time of this action, I vas a certified Level III in RT, FT, MI and UT in accordance with SNT-TC-1A.
9 I am certain that correspondence was written concerning this situation and the visit to NAVCO, but due to organirational changes and the time frame p
involved, I do not know if it could be retrieved.
If I can be of further assistance, please do not hesitate to call re at Knoxville extension 6863 or Warts Bar extension 3516.
I SQN SITE g
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QUALITY MANAGEWS OFFICE c.-<4
. 7317 f
Leo G. Hebert b
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S:op ' Jerk Rec oc:nend ed :
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CATD No.
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?2S PON S
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Ce n c e -- :0:-2 5-05 0-001 (Findines Se :icn) incenti::es :c la:x et soecif t: ::aintne renuirements in :ne fellewine cetuments:
OC-e. Reristen 2. "Ouclity Control Ins:ruments:ien" -- iio m oc u l e s for trainanc.
AI-16 Revis en 30. "Plent Trainine Precrem" Courses listec ce no: incluce tuoe fit:ines.
MI's' SMI-!-65-20. Revision 1.
and IMI-115. Rev: sten 3.
-- Do not soecifiv eersonnel trainine reeutrements.
NUC PR Cuali:v Insne :cr Trainine Manual -- No ins: rue:: ens in insee : en of ins:allation of comeres sion vee f :: nes.
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Corrective Action Plan of Employee Concern Investigation j
g l
Tracting Checklist i
($f9 ECTG Report /CATD Number M7. #/ It%/- C Lead Organization Responsible for Corrective Action Plan Cco JT CORRECTIVE ACTION PLAN (CAP) 1.
Dres this report require corrective action?
Yes V No j
(If yes, describe corrective action to be taken, if no, provide justification) keneJ J
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1 2.
Identify any Similar item / instances and corrective action taken.
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Will corrective action preclude recurrence of findings? Yes AC No 4.
Does this report contain findings that are conditions adverse to Ies No k'
cuality (CAQ) as defined by AI-12 or NEP 9.1?
. -m.
5.
If a CAQ condition exists, what CAQ document was initiated?
c/4-
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6.
Which site section/ organization is responsible for corrective action?
Si17 7t M a rrem./
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7.
Is corrective action required for restart?
Yes No
.N (This determination is to be made dsing the " Criteria for Determination of Restart Items" in accordance with the Nuc2 ear Performance Plan, Volume 2.)
8.
P2 :ene number for restart corrective action? Zone
- /4 9.
Estimate completion date,for corrective action.
///4 j
Comp 1eted By edD
<"A. sex-Date so-/-94 Approved By
>L kiEwy Date
/d-G-/t ECIG Concurrence " u f M/#6 Date 2-6-f"?
SRP Concurrance Date CAP CLOSURE 10.
Was your corrective action initiated and completed in accerdance with rtep 1?
Yes No 11.
If step 10 is no, describe the corrective action taken.
12.
Is the correct.ive action implementation complete!
Ies No 13.
Is the currective action documentation closed?
Yes No 14 What documents were esed to implement the corrective action? _
Completed By:
Date Verified By:
Date ECTG Closure:
Date Continued on back page
Reference:
CATD 80201-SQN-2
~
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All instrumentation attached to the RC3 is restricted by special 3/8-inch transition couplings, thus restricting the amount of leakage to that which the charging system is capable of normally making up.
All ins trumentation a ttached to o ther sys tems important to safe operation of the plant are provided in redundancy (Trains A and B).
Based upon these facts, I conclude that a break in the line.or a. defective tube-fitting would not create an unsafe nuclear operating condition.
Sequoyah safety procedure ( AI-3) requires personnel working on systems or systhm components to,obtain appropriate hold orders on clearances.
In addition, a recent study completed by Singleton Laboratory
- (F01 8 51211 601) in response to employee concerns at Watts Bar Nuclear Plant concluded that improperly installed-fittings would not be a problem if they did not leak and that leaking fittings would be repaired before an unsafe condition would exist.
~
It is.therefore concluded that if existing procedures are followed, the potential for personnel injury is minimum.
Appendix B of 10CFR50 requires procedures and inspection programs be established and executed for work on safety-related' equipment.
The level of detail is not stated.
Sequoyah performs all C33C work in accordance with written procedures (specifically work requests and 1~~
workplans) which appear to meet Criterian V requirements. The level of
-?
- detail is determined by the complexity of the task which may generate specific instructions such as MI's, SMI's, etc. ' Additionally, all of the work documents are reviewed by QA for adequacy and adherance to applicabl9 requirements including the, establishment of QC hold points which seems to meet Criterian X requirements.
It shou]d be noted that neither Criterian V or X specifically states the level of detail of instructions or that specific QC hold points be 1
established.
These determinations are the responsibility of the utility in accordance with applicable codes, etc.
I therefore conclude that sequoyah is in compliance with these requirements.
In response to the specific problems addressed by the investigators, the following comments are provided:
1.
QC 4 is an instruction utilized by the Constructica organization during the construction phase of the plant.
It has not been used at Sequoyah for several years and never by Nuclear Operations.
Therefore, no corrective action is, required.
AI-14 does not list all courses required or taught.at. Sequoyah.
The 2.
original intent of this instruction was to address minimum training requirements for employees at Sequoyah.
Additional requirements were implemented through the :nitiative of plant supervisors in response to conditions adverse to quality, and other directives such as the referenced memorandum from W. T. Cottle.
These-requirements were initiated administratively by memorandum as was the case in the m
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W. T. Cottle memorandum.
AI-14 is currently being revised with additional reference to tube-fitting class MTU-MMT-22 referenced, x)
The estimated completion date is December 8, 1986, per discussion
)
i with Doug Bateson, Sequoyah Training Officer.
3.
personnel training requirements are not placed in procedures on a general basis.
Reference to AI-14 or section requirements are sufficient to address this.
Therefore, no revisions are necessary.
l 4.
The QA supervisor (John L. Hamilton) for engineers and inspectors responsible for review of work documents and inspection activities has directed his representatives to insure that requirements are placed in maintenance requests and workplans to use only qualified, trained, maintenance personnel for tube-fitting installation and that inspecto s aarigned to the related inspection activities are trained in tube-fitting practices.
Approximately ten QC inspectors have attended MTU-MMT-28 to date.
The mechanical inspector training class will be revised to include tube-fitting inspection criteria
'and additional inspectors certified as they return to the Power operations Training Center for recertification.
LDA:GDL 10-1-86 0210M
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\\O-AI-4 Page 42 of 62 Rev. 50 Appendix H PLANT INSTRUCTICN REVISION REQUEST ROUTING b
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p Originator's Supv./Da e Approved Responsible Supervisor /Date Approved
- 2. Administrative Services - Date Received Approved N.....
Adm Svs, WPU Supv
- 3. SI Scheduler (sis Only)- Date Reviewed i
Approved f
plant Instruction Revision Request (To be filled out by originator of revision request and routed to j
appropriate section supervisor. )
i I:fs Originator M
OMvdt
,,6 " M Date M-[~$ 6 MZ- /g I
Instruction No.
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. 1 Page Numbers Affected
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THIS Er/ISION !MPLEMD:TS SOURCE DOCUMO;T:
(NQAM, Area Program - etc.)
Sum.aary description cf Revision (If possible, marked up pagas on latest revision should be attachad).
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1 AI-14 Page 28.of 50.
i Revision 33 i,
i II.
TRAINING OUTLINES (continued)
)
F.
SPECIALIZED TRAINING (continued)
I
)
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a Those portions dealing with the SQN response are discussed in greater detail. Addionally, the plant's Implementing
~
Procedures are addressed and summarized during the training.
Sufficient training must be given to those individuals who t
are designated in the Implementing Proce'dures as being re-sponsible for performing various functions. during an emer-f-
t gency.
c.
EFERENCE-TVA-REP d.
RESPONSIBILITIES-The SQN Project Engineer (PIP) or a designated alternate shall be responsible for administering this training.
l 3
DOCUMENTATION-A training roster will be completed and provided I
e.
to the SQN Training Office for all persons successfully complet-i ing P2P training.
J x,....e.
'Mifk f.
RETRAINING-Annually
'l g.
TRAIN Code - PIP l
6.
HEALTH PHYSICS SCIENTIFIC AIDE AND TECHNICIAN OUALIFYING PROGRAM.I PL720SE-The objective of these HP training programs is to I
a.
~
ensure a fully qualified HP staff is maintained to assist i
in the safe operation of TVA's Nuclear PInnts. In achieving this objective, TVA complies with NRC regulations.
b.
SCOPE-The positions covered by this training include HP r
scientific aides, dosimetry engineering aides, HP technician trainees, HP technicians, and contract HP technicians.-
c.
REFEPINCE-PMP 0202.I2 d.
RESPONSIBILITY-The HP section supervisor for coordinating the training required for the HP staff and ensuring staff-
- i..
members mainta'in appropriate qualifications..
t L_
4 DOCUMENTATION-The associated training documentation vill be e.
caintained at the POTC as described in the HP administrative section instruction letter (HP ASIL) -3.
l This training program is. completely described in HP ASIL -3.
f.
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Page 3-of 50 Revision 33 D.
RESPONSIBILITIES (continued)
~
4 (continued)
X (e) Insuring' that all temporary and service personnel under their cognizance are trained to the extent necessary to assure safe execution'of their duties
-(for unescorted access, see Apperdix-B).
f (f) Reviewing the Plant. Training Office computer status l'
Y program printout of plant per.connel issued to the sectionandreporttotheTrainingOffjcegn,vgrgers S*""di u. uo,ue A w+ e~s:r -w <as A n o* w-.
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5.
The Health Physics (HP) Supervisor shall be responsible for.
6.
The plant Public Safety Supervisor shall be responsible for providing training and retraining in " Plant Security and Emer-gency Plans" (GET 3.1) and " Drug Awareness" (GET 3.2).
11,...
7.
17Q The Nuclear Training Branch is responsible for the development and update. of the courses in the GET program through the utili-f
- Ml
- ation of information provided by the plants, the DNQA Quality y
Systems Branch, and other ONP personnel.
This responsibility includes ensuring that the course material is in compliance with the various regulatory guidelines which are applicable.
L 8.
Vnen revisions occur to courses under the responsibility of y
the Plant Training Office, Attachment 4 shall be complet< d.
g Any revisions shall be reviewed by the plant Training Officer and the responsible site supervisor for completeness, accuracy, and applicability to Sequoyah Nuclear Plant. When a review discloses discrepancies between the. course and Sequoyah plant procedures, the Plant Training Office vill initiate a formal revision request form.
9.
The supervisors of the sections belov' listed shall be respon-sible for providing plant specific information for GET training y
packets and instructors for the other designated courses. They
)
shall also notify the Training Officer when revisions to docu-ments or plant procedures covered in this training indicate the possible need for revision of GET course:; and/or retraining of plant personnel in a particular subject. For all other courses, designated supervisors shall be responsible.for the development and maintenance of complete training packets. Each training packet will have as a minimum a training outline, audiovisual aids where appropriate, and written examination covering.the f~
.g.
material. Approval of the p ckets shall be the collaterial re-sponsibility of the Training Officer and the su;ervisor of the
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urtro sures ame.nsust 803 870123 802 Cin O 7d n d itin TENNESSEE VALLEY AUTHORITY
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V. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plar)t H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant ynnu DATE January 24, 1987 SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) st nJECT:
ELEMENT REPORT.802.01 SQN R3 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTIO (CAP)
Reference:
Your memorandum to me dated January 15, 1987, " Watts Bar Nuclear Plant - Employee Concerns Tast Group (ECTG)' Element Report 80201-SQN - Inspection Criteria (Sequoyah)"
(T25 860115 915)
I acknowledge receipt of your elemet t report and in accordance with your request (see reference),
Element Report 802.01 SQN R3, Corrective Action Tracking Document (CATD) No. 80201-lQN-03 has been reviewed for applicable corrective action.
By way of this memorandum I am endorsing the site line organization CAP,
,.03,q.
returning your CATD No. 80201-SQN-~03, and attaching the CAP for your c'
review / concurrence.
.y-f This CAP is tiot a restart requirement.
If you agree with the proposed CAP, please sign the ECTG concurrence space below item 9 on the CAP tracking checklist and return the CAP tracting checklist.
N H. L. Abercromble RCD:JDS:JB:CS A ttachments cc (Attachments):
RIMS, MR 4N 72A-C (S02 870121 952)
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Action Irackint Document l
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I=mediats Corrective Action Required: {5/ Yes // No
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Stop Worx Recocmended:
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CATD No.--
80201-SON-03 i-t, 7'
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4 I' E RESPONSISLE ORGANIZ.AIION:
INITIATION DATE 1/8/87 6.
PROBLEM DESCRIPTION:
Office of Nuclear Power u i..
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As identified in this Element Reoort. Attachment C (LAA I
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816). TVA c ocm:i t t ed :o the NRC that-"verk on com which would b e, d_o n e bv coerations eersonnel will be controlled MAI-29.
' Inst.
tent Tube Fitting and Installation' which is I
scheduled to be issued by Aucust 15. 1986."
To date. no evidence c
exists that l,.
this orocedure has been issued.
7.'
PREPARED BY: NAME F.. D. Halverson KW; DATE: 1/8/87 A
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// ATTACHMENTS
- 8. t CONCUPJINCE: I CEG-H 'AL/r E //)'/ r
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9.j. APPROVAL: ECTG PROGPJ.M MGR:
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. DATE: 1/8/87 t
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_COPJ2CTIVE ACTION
- 10.,
PROPOSED 50RPICTIVEACTIONPLAN:
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PROPOSED BY:,, DIP 2CIOR/MGR:
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CONCURPINCEi,!CEG-H 16b2/ 4--
DATE: _249-V7_
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DATE:
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Approved corrective actions have been verified i
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satisfactorily as
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Page 8 I
SQA166 Revision 8 Attachment A Page 1 of 2 Corrective Action Plan of Employee Concern I.westigation i,
Tracking Checklist ECTG Report /CATD Number 488., C[f'I Lead Organization Responsible for Corrective Action Plan Initiation Date COFSICTIVE ACTIOt1 PLA?J (CAP)
- 1. Does this report require corrective action?
Yes
/
(If yes, describe corrective action to be taken No G-6C r62~.
/ 75, od fc A'
, if no, provide justification)
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2.
Identify any similar item / instances and corrective action taken.
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- 3. Will corrective action preclude recurrence of findings?
- 4. Does this report contain findings that are conditions adverse t Yes o'
No as defined by AI-12 or NEP 9.1?
o cualitv (CAQ) 5.IFaCAQconditionexists,whatCAqdocumentwasinitiated?
yIS No D
fv/IV
- 6. Whien site section/organica:ic s responsible for corrective action?
- 7. Is corrective action required fc:: restart?
- 8. P2 ::ene number for restart corrective action?(This determina Yes No
+'
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- 9. Estimate completion date fer correction action. Zone
~
Ce=pleted By 2#/dd
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Approved By
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/- 2'/-8 7 Date ECTG Concurrence Mu/C_
/- 2 /- V 2 Date Date 2 - l *7 -d'~?
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SQA166 i
Revision 8 t
ATTACHMD!T A Page 2 of 2 CAP CLOSURE
- 10. Was your corrective action initiated and completed in accordance with step 1?
- 11. If step 10 is no, describe the corrective action taken Yes No
- 12. Is the corrective action implementation complete?
- 13. Is the corrective action documentation closed?
Yes No
- 14. What documents were used to implement Yes No Completed 3y:
the corrective action?
Verified Ey:
Date ECTG Closure:
Date Date j
(Step No.)
Description
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l TUA 60 (C5 9 6 5) (Op.wp 7 06) uxirco.surcs covenNMcNT
,M Memorandum L
TENNESSEE VALLEY AUTHORITY i
0,0 R. C. Denney, Employee, Concerns Special Project Manager, ONP, DSC-P,
'Sequoyah Nuclear Plant FROM R. W. Olson, Modifications Manager,' DNC, SB-2, Sequoyah Nuclear Plant-DEC 0 31986 DATE SUBJECI: SEQUOYAH NUCLEAR PLANT - EMPLOYEE CONCERNS TASX GROUP (ECTG) ELEMENT REPOKIS REPORT 173.04 SQN R2 - REVIEW AND CORRECTIVE ACTION PLAN (CAP)
INITIATION
Reference:
. Memorandum from V. R. Brown to H. L. Abercrombie dated November 12, 1986, "Sequoyah Nuclear Plant-(SQN).- Employee Concerns Tast Group (ECTG) Element Report C017304-SQN -
Construction Category.- Corrective Action Plan-(CAP)
Rejection Iransmittal"JT25 861112 993) i In accordance with the revised ECTG element report, I provide the additional response:
4f-1.
A memorandum (S02 861202 827) was transmitted to DNE requesting their l'lh evaluation of NCE/SCR 6278.
.w 2.
A procedure will be written defining requirements for installation of tube fittings at Sequoyah.
3.
Retraining requirements will'be established on a frequency of one year for Modifications personnel and two years for Maintenance personnel.
Nh H
R. W. Olson LDA:GDL cc:
RIMS,liR 4N 72A-C This was prepared principally.by L. D. Alexander.
- - ~ ^ ~
COORDINATION:
Rick Collins, DNE; E. M. Patterson,'Maint,sunce 0293M 1
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- iines Plan
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Standard Practice Page 8 I
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SQA166 i
Revision.8 Attachment A Page 1 of 2
}
Corrective Action Plan of Employee Concern Investigation i
i Tracking Checklist ECTO Report /CATD Nu.ber __/ ~P -3, C V S PA) 6L Lead Organization Responsable for Corrective Action Plan
)
Initiation Date
//-/ 3 - f 4:'
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- 1. Does this report require corrective action?
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(If yes, describe corrective action to be taken, if no Yes K No Jin; nmo SCZ E//2O3 SW
, provide justification; t.
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- 3. 'Aill corrective action preclude recurrence of findings?
- 4. Does this report centain findings that; are conditiens adverse to cualit Yes _.K No as defined by AI-12 c: NIP 9.1?
v (CAQ)
yrs 30 jg
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- 6. 'n~nich site section/c ganitation is responsible for corrective action?
j b^) E R106 t m c a t o, y
- 7..s correc ive acticn required for restart?
a
- 8. P2 :ene number fcr restart corrective action?(~~his determinati Yes No X
.)
~
- 9. Tstirete ccepletien date for correction action. Zone 5-9-97 Ccmpleted By Approved 3v
_ //)[,_ _j-page 7g _y.gg Ky.~/ gg-em v***mb Date
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Pace 2 of 2 t
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s CAP CLCSURE
- 10. Was your corrective action initiated and completed in accordance wi.h step 1?
Yes 11 o
- 11. If step 10 is no, de::cribe the corrective action taken.
I 1
- 12. Is the corrective action implementation cc.m,clete?
Yes-11 o 13..Is the corrective action documentation closed?
Yes No
- 14. What documents were used to implement'the corrective action?
Cc=pleted By:
Date Verified Ey:
Date ICTG Closure:
Date
~
(Step No.)
.Descri= tion
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- b v8 64 (05 9 65) (Op we 7 84) 4 WITED STATES COVERNMENT
'502 861202 827
..~ Memorandum
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rzxxesses vAttsy Aurnoniry !
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L'TO D. V. Wilson, Project Engineer, Sequoyah Engineering Project, DNE, DSC-E, Sequoye5 Nuclear Plant j
FROM R. W. Olson, Modifications Manage., DNC, SB-2, Sequoyah Nuclear Plant DEC 0 21985 DATE
SUBJECT:
WATTS BAR NUCLEAR PLANT - OC NCR 6278 RO, R1 (SCR 6278 - SRO) AND ECTG REPORT 173.04 SQN R2 (IUBE FITTINGS)
References:
1.
Memorandum from J. A. Raulston to Those listed dated February 25, 1986, " Potential Generic Condition Evaluation" (B45 860225 259)
.2.
Memorandum from W. C. Drotleff to K. W. Whitt dated April 7, 1986, "NSRS Report No. I-85-329-SQN, Finding I-85-329-SQN-01, ' Evaluate Compression Fitting Inadequacies of NCR WBN-6278 for Generic j
Applicability' - XX-85-050-001" (B05 860404 002) i l
Q@3 Although th re seems to be some confusion and procedural variances in the
<.M, processing of the subject NCE/SCR, a DNE evaluation is required to
[e^g satisfactorily resolve this employee concern.
This item has been i
l-discussed among Larry Alexander of the Modifications Group and Rick Collins and Adrian Smith of DNE, Sequoyah.
i
- I request that you perform the requested evaluation and coordinate any
. corrective action with Larry Alexander (6862).
The Modifications Group will support;you as required.
i Your prompt attention will be appreciated.
M/
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R. W. Olson LDA:GDL cc:
RIMS, MR 4N 72A-C This was prepared principally by Larry D. Alexander.
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i CORPICTIVE ACTION FISPONSE EVALUATION FIPORT NO:
3-73'"M bA9 SUEJECT:
OA CouTROLS COR CDk r o c c(102 FI7 TINGS ItLsTA Lt. ATtoN CONCERN No:
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J. H. Sullivan,' Supervisor, Regulatory Engineering ONP, SB-2. Sequoyah i
To
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Nuclear Plant.
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E. W. Olson/ Modificat,lons' Manager, ONP, SB-2. Sequoyah Nuclear Plant rnox 2
MAY 2 01986 g
ano st;na nc r: WATTS BAR WUCLEAR PLANT - NCE 6278 R1 - COMPRESSION FITTINGS FOR TUBING COMMECTIONS AND TUBE-END REDUCEES d3
Reference:
Transmittal from Regulatory Engineering Section to d
me dated April 21, 1986 (attached)
I$
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b The generic issues have been previously included as part of the employee 8
concern program with physical testing being performed at Singleton Materials fj Engineering, Laboratories.
This study addressed the issues listed as W
Deficiency I including toe development of a new General Construction Specification (G-29 PS 3M13.1 Addenda).
y 2
Deficiency II addresses a mismatch of valve fittings and tube fittings. It h
should be noted that the bill of materials states "...or equal." DNE d
w Engineer. 'im Staub, has poen reque. M by Operations to buy only Drston
[
- ~+ 1 valves with Parker fittings in the !tt
.s.
The general rule of thumb by the 5
fleid was to install matching fitti a" a by using the "or equal" statement.
[
9 Since Sequoyah has been through colo hydros, hot functional testing, preoperational testing, and years of service, it is concluded that incorrect y'
installations have been identified and corrected. Additionally, all current i
Sequoyah employees worting with tube fittings have been trained by MKT-28.
r This training was presented by the Power Operations Training Center, in O
which emphasis was placed on not mismatching fittings.
h It is therefore concluded that no addition. 1 corrective action is required 5
by tha Office of Nuclear Power.
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E. W. Olson
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Attachment L
EIMS,MRAN72A-C(Attachment {,
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This was prepared principally by L. D. Alszan eh.
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yNMfD STATES COVERN. MENT 4m ordn G14m TENNESSEE VALLEY AUTHORITY B05 '86 0 4 0 4 002' T"
K. W. Whitt, Director of Nuclear Safety Review Staff E3 A8 C-K
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FHUM W. C. Drotleff, Director of Nuclear Engineering, W12 A12 C-K D^"
- April 7, 1986 860411T0169 St'HJ ECT:
NSRS REPORT NO. I-85-329-SQN, FINDING I-85-329-SQN-01, " EVALUATE COMPRESSION FITTING INADEQUACIES OF NCR VBN-6278 FOR GENERIC APPLICABILITY"
~
Reference:
Your memorandum to H. L. Aberernmble and R. W. Centre 11 dated February 13,1986(c,6e0)
In the reference memorandum under Section IV, " Conclusions and Recommendations," you addr.ased f ouc reconnundations.
They were I-85-329-SQN-01, Evaluate Compression Fitting Inadequacies of NCR VBN-6278 for generic applicability; I-85-329-SQN-02, Noninspection Personnel Training; j
I-85-329-SQN-03, Inspection Personnel Training, and I-85-329-SQN-04, Quality s
Control Inspection.
The only recommendation which involves the Division of Nucioar Engineering is I-85-329-SQN-01.
DNE has reviewed this recommendation
' b;r. the following comment:
When NCR WBN-6278 RO was issued by the Office of Construction, they (OC) yd were not yet following *be intent of naragraph 4.5.1.2 of OEP-17.
Since then, the Office of Construction started following paragraph 4.5.1.2 of OEP-17, and NCR VEN-6278 RI along with SCR 6278-S R0 (identical to NCR VBN-6278 RI) was issued.
The SCR' form goes into more detail, g
particularily in the generic cor.dition area than the NCR fora which was s
The " generic blocs." on NCR WBN-6278 R0 had been marked "yes" and was g
justified by saying "this condition is applicable to all compression fitting installations within the scope of the WB QA program."
DNE did not review NCR VBN-6278 R0 for generic applicability because OC g )
had already indicated it was.
However, since NCR WbN-6278 R1 and SCR 6278-S RO have been issued, DNE has issued a generle memorandum dated j
,3 February 25, 1986 (B45 860225 259).
Id OEP-17 was revised on March 28, 1966, to require assessnient of the generic 9
3 implications of NCRs/SCRs/ CARS initiated by Construction or Operations and /, \\
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referred to DNE for disposition.
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Raulston, VIO C12-6 C-X ki J. C. Standifer. P-104 SB-X II J.
F. Weinhold, V12 B34 C-X W. D. DeForc. V12 B32 C-X Q
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- s...o e f-nt Lo uvredt'/3.a r e.*'ai Rev. 6 EXPERIENCE REVIEW APR21'86 EVAL,UATION FORM i-TO: [OM, b 5 RETURN TO RECULATORY ENGINEERING SECTION- /!'1!'h
- W UPON COMPLETION
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Supervisor, Regulate ry Engineering Section i
DATE:
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SUBJECT:
OPERATlHG EXPERIENCE REVIEW I
Item No. M
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Priority:
Significant
' Normal'
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References:
Please review and evaluate the attached Operating Experience Review infomation.
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Check the appropriate disposition statement listed below supplying the necessa -
M n and return this transmittal form to Regulatory Engineering with A0_L.d>yd of the transmittal date for normal experience iter:s or twenty (20[) any for significant experience items. This information has also been forwarded to o
)r,L ot her groups listed above. Coordinate your response with them as applicable.
bj;j;a.
M r..:.c coordin:*.e any necessary due date extensions with RES prior to the
'9 herr. ming overdue.
response b
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Disposition Statements n
1.
I have reviewed the subject information and no action is necessary because:
( )
a.
This item is already covered by instruction
( )
b.
This information is not applicable to SNP because of a dif f ere: ice U
in design. Explain:
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c.
Other (Explain)
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I have reviewed the subject information and the following action is required.
A due date of should be placed in the OER database
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for completion of this actica.
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This OER item is 10CTR50.49 related:
Coordinator will initial showing that this Yes _ No (If yes, the EQ with him).
response has been coordinated r
Reviewer Date Section Supervisor Date Disposition statement reviewed and concurred with INTO ONI,Y TO: N N _/ bed. k i
NOTE:
A copy of all coorpleted Attachment 3 forms which are 10CTA50 49 related shall be sent to the Site EQ Coordinator.
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i TENNESSEE VALLEY AUTHORITY A
B25 '86 032 8 005 To i
E. 3. Rank nager. Design Services, WP, D8C-E, Sequoyah Wuclear Plant J. P. Yineyard, Project Manager Sequoyah Engineering Project, OE, DSC-A, raox Sequoyah Wuclear Plant
^'"
MAR 281986 st'tu r cT: SEQUOTAE NUCLEAR PLANT - POTENTIAL CENERIC CONDITION ETALUATION 1
l Please review Watts Bar nonconf ormance report (NCR) OC NCR627811 and determine applicability to Sequoyah per the attached memorandum from John A. Eaulaten to Those listed dated February 25, 1986 (545 660225 259).
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D John A. Raulston, W10 C126 C-K w
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Principally Prepared By:
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- M070.02 Buy U.S. Savines Bonds Recularly on the Payroll Savines Plan t
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DMETE 9?f q w w - o.
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.To Those listed si John A. RaulstoE, Chie f Nuclear Engineer, W10 C126 C-K d
TROM i
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FEB 251986 b
SUBJECT:
POTENTIAL CENERIC CONDITION EVALUATION Ng
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p The at tached document, OC NCR 6278R1, describes a condition adverse to quality A
which was identified at Watts Bar Nuclear Plant.
Please examine the attached to determine if this co'ndition' exists in your area of responsibility. The botton portion of this form should be completed and this memorandum returned to me d
within two weeks of the above date.
Should this condition be found to axis t in
(
your area of responsibility, the generation of a problem identification report or a significant condition report per OEP-17 is required within two weeks of the above date.
Orisical O!.L.ed D7 SQEP John F. Cox i
I John A. Raulston
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- N. R. Beseley, A10-BFN g
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R. Boesly, 9-113 SB-K W
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At t a chme nt
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DATE1 N
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7 We have examined our activities in the area of concern and C
found that the conditiont
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Does not exist / /
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Does exist / / PIR/SCR No.
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UNITED KTATE3 GOVERNWa_FW 121800812
- .l Memorandym '
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TEWESSEE VALLEY '.UTHORITY j s
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'860225 259 TO Those lioted rROM i
John A. Raulscon, Chis f Nucle ar Engineer, W10 C126 C-K
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FEB 251986 sunJECT:
POTENTIAI, CENERIC CCNDITION EVALUATION d
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The attached document, identified at Matta Bar Nuclear Plant.OC NCR 6278R1, describ which was
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determine if this condition exists Please examine the attached to in your area of responsibility.
within two weeks of the above date. portion of this form sho.:1d b The bottoa j
ned to me your area of responsistlity, Should this cd ondition be Itund to exist in i
the generation of a problem identification report et algnificant condition report a
per OEP-17 is required within two weeks of the above date.
Original 01.:.ed Dr John F. Cox satp i
d John A. Raulaton j
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R. Beas ley, A10-BFH V r,.a*,;y+g q
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TO :
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Tb-Olson. Modifications Manager, DNC. SB-2 Sequoyah. N
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FROM5 iw D. W. Wilson, Proje~c~t' Engineer, Sequoyah Engineering 1
m' Project, DNE, DSC-E, Sequoyah Nuclear Plant l
N~i DATE:
December 4, 1986 N-4 " '
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We have examined our activities
?r,'
Y.,D found that the condition:
in the area of 2ncern and.
Reference:
S0 d60520 941 a.
Does not exist /X / _ - \\
B05 860404 002 502 861202 827'
~
b Does ' exist"/' / ~ PIR/SCR No.
N Review performed by _
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'UNITh.D STATE 3 COVERNMENT
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7 imorandum TENNESSEE VALLEY AUTHORITY
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B26 '86 0 2 0 6-~D 17 l
J. C. Standifer, Project Manager, Watts Bar Engineering Project, t
O P-104 53-K (3) t TROM Wenter Vadewitz, Project Manager, Watts Bar Nuclear Plant OC February 5, 1986
[
DATr.
,qt: nJ r,cT:
WATT 3 BAR K1X1 EAR P1. ANT - ASME SIGNIFICAKT NONCOKTORMANCE FIPORT 6278 R1 Attached for your review and approval of disposition is NCR 6278 R1 which we consider to be significant. Please approve and return L
with attached fors(s) for our documenta, tion purposes.
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Guenter Wadevit/
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R. W. Dibeler,11-142 SB-K g_ _l- ;
ism T. W. Hayes NLU-WBN OC aca j-
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R. C. McKay, PHO-WBH OC
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J. W. Mabee, 366 SPB-I
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NRC Resident Inspector, VBN-NUC PR i_'" ~ ~ _,.
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Principally prepared by R. A. Aikens,I I
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Instrumentation Tubing Connection Integrity IC. 8EF NCR orIN-8 5-79 5-001 AUDIT *-o.:-002. NCR 63 7 I
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- 11. LMmAT1NG Deficiency UMtT NSB-B Comp res s ic fittings for tubing connections have Lt. VENDOM g
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3 been discovged with installations which do not i
ADDRESS agree with thu manuf acturer's installation ins t ruc tions.
These discrepancies are as N
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7eJ57p8s)
- a. Tube cuts not deburred b.
Tube cat tottooed out in fitting (See a ttached continuation page
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'.ncy 1 - There are no requirements to verify.the' integrity o
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.ng joints which were not s ub j e c t e d to hy,d ro s t a t i c o r pneu::.a tl t#8ti"8' Responsible Organ $zation IEU /0E
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Deficiency I - VBN OC and NUC PR shall establish nessures for documented train-ing of their respective craf t personnel involved with compression fitting ins tAlla tio n.
Inspect drain connections to the closed drain system which do
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not require hydrostatic testing and are subjected to potentially radioactive service.
These inspections shall be in accordance with the.:.anuf acturer's
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Authorsreo Nucise, innoeetor Date
' Appro==d Correcison C.>mpeted. and twm Rewaard F tom Noricon6ormang Stacus n m x m.o= 6,o, a tai Dew Acon =e a y Om C 7M & y
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'=cneacsif mesuma Nasa CDsOmos REFORT CONT 14uAT10e pas t Wtts Bar Ifoc Plant l
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1A Description continued:
- c. Ibt not completely covering thtuads-g#
- d. Missing f atrule
- e. Raversed f erruls f
- f. Unidentifiable fstrule Deficf m ey II:
Engineering drsvings 47V600 series and 47BM600 serien specify G
)
the use of either an In:perid-Eas'tman (I-E) 78F TSS or a Parker Rannafim CPI TR3Z-SS 1/2 to 1/4 inch tube and reducer f
(Mk 28A), but she sid specify only the use of,I-E reducer.
Q The reducer connects to a Dragon panel isolation valve (Mk1) i#
~
with an I-E fitting.
The Parker tube end reducer is a hard
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e.aterial which is machined for a Parker ferrule and is not designed to be used with the I-E ferrule.
Because of the hardness and the machined groove, the I-E ferrule does not seat properly on the tube end reducer and presents a blevout y
hazard.
.e Apparent Cause continued:
4 SE Deficiency II:
I-Irror in r.he 47BM600 drawings allowing the use of incompatible V
fittings.
3
.. Correction Method continued:
h Deficiency I:
instructions to verify proper tube deburring, tightening require =ents, and f errule type and orientation.
e All cystems subjected to hydrostatic testing or pneumatic testing have been. verified with leak tight joints which indicate adequate joint s.akeup for pressure retention.
However, OE shall provide vibrational analysis for connections f
in which the tube is not bottomed out in the fitting, nuts not properly tf,htened, ferrules reversed, and deburring was not perforned to de termine the acceptability of such insta11ations although leak tightness is achieved.
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3 Correction Method continued Deficiency 1:
OE to evaluate coegression fitting installation to determine the need for possible TVA process specification revisions.
Deficiency II:
{
Correct drawings to specify the use of only Imperial-Eastman 78}-TSS tube end reducer.
Inspect panals and replace Parker reducers with latperial Eastman reducers.
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8512 0h 0 0 3 5 9 rouxzssez vittzy turnoarry 2emorandum D. W. Vilson, Project Engineer, Sequoyah Engineering Project, DKI, DSC-I,
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Sequoyah Nuclear Plaat E. W. 01 son, Hodifications Etnager. Drc, 8B-2, Sequoyah Nuclear Plant j TROM t
DEC 0 21986' Du!
6278 10, 11 (BCE 6278 320) AND ICTO WATT 3 E11 NUCLEAR PLANT - OC NCE SUBJECT EEPOET 173.04 SQW E2 (TUBE TITTINGS)
Memorandum from J. A. Raulston to Those Aisted C
25, 1986, " Potential Generic Condition
References:
1.
dated February Ertluation" (545 860225 259)
Eamorandum from W. C. Drotleff to K. W. Whitt dated Apell 7, lon6. "KSRS Esport No. I-85-329-8QW, Finding 2.
I-85-329-SQN-01, ' Evaluate Compression Fitting Inadequacies of NCR WBN-6278 for Generic (505 840404 002)
Appilcability' - II-85-050-001" I
in the Although there seems to be some confusion and procedural Variances DNE evaluation is required to
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_ hl processing of the subject NCR/SCR, 4 This item has been I
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~'
satisfactorily resolve this owployee :encern.
discussed among Larry Alexander of the Modifications Group and Eich
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1; Collins and Adrian Salth cf DNE. Sequoyah.
J ordinate any I request that you perform the requested evaluation afThe..,n.idications Group corrective action with Larry Alexander (6862).
will supoort you as requirec.
y Your prompt attention will be appreciated.
1
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R. W. Olsen
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This was prepared principally by Larry D. Alexander.
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. ATTACHMENT G pn eton j
E UNITED ST ATEs
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NUCLEAR REGULATORY COMMISSION o,
j W ASMNGTON, D. C. 20555 l
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flovember 14, 19J6 i
Cocket Nos.:
50-327 and 50-328 l
Tennessee Valley Authority f
ATTN: Mr. C. C. Mason
. Acting Manager of Nuclear Power l
6N 38A Lookout Place 1101 Market Place Chattanooga, Tennessee 37402-2801 Gentlemen:
This refers to the inspection performed by Messrs. E. T. Baker, J. C. Harper, and 1
J. J. Petrosino of the Vendor Program Branch and Mr. 5. R. Stein.of the Reactor Construction Programs Branch on September 15-19 and September 26 thru October 3, 1986, at the Sequoyah Nuclear Plant, Units 1 and 2.
The inspection related to h.ja.
activities authorized by NRC License Nos. DPR-77.and DPR-79. Our findings were We.
discussed with Mr. H. L. Abercrombie and others of your staff at the conclusion J
~
of the inspection and were the subject of the October 21, 1986 letter from j
J. M. Taylor to S. A. White.
The purpose of this inspection was to review Tennessee Valley Authority's (TVA) 3 corrective action to Nuclear Safety Review Staff (NSRS) Reports R-84-17-NPS, j
I-83-13-NPS, and R-85-07-NPS. The inspection included a review of contracts for original and replacement equipment, maintenance requests, quality assurance I
program requirements, site procurement procedures and practices, and associated documenta tion. The findings in the areas of procurement of safety-related equip-ment, record storage and retrieval, and receipt inspection indicate a failure to take adeouate corrective action to these previously identified concerns.
In particular, your program has allowed previously qualif4ed equipment (seismic and environmental) to be degraded by purchasing replacement components and parts as j
commercial grade, without documentation of its qualification, and without adequate 1
dedication of the items by TVA.
Ir. addition, retrieval of quality assurance i
records for installed equipment was extremely difficult and in some instances, where the equipment did not have a unique plant identification number, the records could not be retrieved.
Further, in some cases receipt inspectors have not been provided with adequate instructions to enable them to perform i
meaningful inspections. These deficiencies have been classified as a single Potential Enforcement Finding (50-327, 328/86-61-01) concerning failure to take adequate corrective action.
i 4
9
4 4 November 14, 1936 Tennessee Valley Authority The Potential Enforcement Finding is being referred to the NPC Region 11 office Your corrective action for Seouoyah for their review and appropriate action.
~
and assessment of the applicability of the identified deficiencies for other TVA facilities should not await further NRC action.
Should you have any questions on this matter, we would be, pleased to discuss them with you.
Sin erely, hk Me Brian K. Grimes, Director Division of Quality Assurance. Vendor and Technical Training Center Programs Office of Inspection and Enforcement
Enclosure:
1.
Potential Enforcement Finding
~$,
50-327, 328/86-61-01 2.
Inspection Report No. 50-327, 328/8,-61 6
7
- pgy cc w/ enclosures
H. L. Abercrombie, Sequoyah Nuclear Plant Site Director 1
Post Office Box 2000 Soddy-Daisy, Tennessee 37379 P. R. Wallace, Plant Manager Post Office Box 2000 Soddy-Daisy, Tennessee 37339 J. A. Kirkebo, Director Nuclear Engineering Tennessee Valley Authority 400 West Summit Hill Drive, W12 A12
^
Knoxville, Tennessee 37902 R. L. Gridley, Director i
Nuclear Safety and Licensing Tennessee Valley Authority SN 157B Lookout Place Chattanooga, Tennessee 37402-2801 M. R. Harding, Site Licensing Manager
'~
Tennessee Valley Authority i
5N 157B Lookout Place l
Chattanooga, Tennessee 37402-2801 l
t
POTENTIAL ENFORCEMENT FINDING Docket Nos.:
50-327/328 Tennessee Valley Authority License Nos.: OPR-77/79 1101 Market Place 37402-2801 Chattanooga, Tennessee Potential Enforcement Findina 50-327, 328/86-61-01 As a result of the inspection conducted on September Procedures for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) the following Potential Enforcement finding was identified.
10 CFR Appendix B, Criterion XVI, states, in part, " Measures shall be estab-lished to assure that conditions adverse to quality, such as failures, malfunc-tions, deficiencies, deviations, defective material and equipment, and noncon-formances are promptly identified and corrected."
Contrary to the above, TVA has failed to correct deficiencies in the areas o procurement of safety-related equipment, storage and retrieval of quality ass ante records, and reccipt inspection of safety-related equ gyyd c' -
R-85-07-NPS.
4 1
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50-327/86-61 and 50-328/86-61 Report No.:
Tennessee Valley Authority
]
Licensee:
EN 38A Lookout Place 1101 Market Street Chattanooga, T" 37402-2801 License Nos.: DPR-77 and,DPR-79 50-327 and 50 '228 Docket Nos.
Sequoyah Nuclear Station Units 1 and 2 Facility Name:
September 15-19 and September 29-October 3,'1986 Inspection Conducted:
I5 d
V Date Inspectors:
E. Baker, Tea -
cer f
n/;46
,s wiJJ kate
,.J. f. /etrosino, Quality Assurance Specialist
/
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$A D4 Date
'5. R. Stein, Electrical Engineer su e
/hf[-
r.;v;t
.h: 3 Date J. C. Harper, Metallurgical Engineer nrn Date j
Approved by:
- 1. W. Merschoff,
, Reactive inspection Section, Vendor ogram Branch
SUMMARY
This was an announced reactive inspection which was conducted at th Sequoyah Nuclear Station to determine the ef fectiveness of TVA's corr scope:
action for problems identified in Nuclear Saft.ty Review Staff Reports R-84-17-NPS, I-83-13-NPS, and R-85-07-NPS con:erning pa record storage practices.for replacement of safety-related electrical End
)
residual heat removal, control air, and eme*gency power (diesel-generator systems; a sample of procurement actions' ic,ntified by TVA's review 1E replacement devices; a sample of procurement actions taken o i
selected during a plant walk-through;.
Stores receiving inspection practices.
One Potential Enforcement Findino was identified.
Results:
l'fW
, =. -
REPORT DETAILS' 1.
Persons Contacted:
Licensee Employees
- H. L. Abercrombie, Site Director
- W. E. Andrews, Site Quality Manager
- J. Blankenship, Information Office Manager i. D. Brewer. Control Shif t Operator-R. Bruce, Program and Standards Section Supervisor
- R. H. Buchholz, Office of Nuclear Projects (ONP) Site Representative
- S. K. Chapman, Electrical Maintenance General Foreman M. Crane, Site Services Procurement Supervisor
- 0. C. Craven, Quality Assurance Manager
- M. R. Harding, Site Licensing Manager R. Jenkins, Division of Nuclear Eigineering (DNE) Supervisor
- 2. M. Kabiri, Site Services Manager
- J. W. Kelly, EA Engineer G. Kirk, TVA Compliance T. Kontovich, Electrical Maintenance Engineering Supervisor
- J. E. Law, Chief Quality Systems Branch g.3..
- A. S Lehr, Instrument Maintenance Group Engineer
- MB M?
- M. R. Matthews, Restart Task Force
- B. Patterson, Maintenance Superintendent G. W. Petty, Materials Officer l
H. L. Popt, QC Supervisor
- M. A. Purcell, Licensing Engineer
- B. Schofield, Licensing Engineer
- J. R. Staley, Power Stores Supervisor C. Stutz, OA Engineer
- P. R. Wallace, Plant Manager
- J. R. Watson, 0A Engineer
- W. J. Wilburn, Site Maintenance
- L. J. Wheeler, Materials Manager
- C. R. Wherter, Materials and Procurement Services Staff Chief The inspectors also contacted or interviewed other licensee personnel from the operations, training, maintenance, and technical staff.
Other Oraanizations k
R. V. Matheison, Westinghouse Site Representative NRC
- P. E. Harmon, Pesident Inspector 1
- K. M. Jenison, Senior Resident Inspector
- D. P. Loveless, Resident inspector
- E. W. Merschoff, Chief, Reactive Inspection Section
- attended exit meeting 2
I i
2.
Exit Interview The inspection scope and findings were summarized and discussed with The team members those individuals identified in paragraph 1 above.
described the areas inspected and discussed the inspection findines listed below. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection.
3.
Licensee Action on Previous Enforcement Matters _
j This subject was not addressed in this inspection.
4.
Unresolved Issues l
No unresolved issues were identified during the inspection.
q 5.
Backaround TVA's Nuclear Safety Review Staff (NSRS) performed in-depth audits of TVA's q
The results of these procurement system and records retention system.
audits are documented in reports I-33-13-NPS dated June 17, 1983, R-84-17-NPS dated March 8, 1985 and R-85-07-NPS dated July 5, 1985. These reports high-lighted programatic deficiencies without providing specific examples of the problems found. One of the more significant findings related to the use of XS components purchased " commercial Stade" and used in safety-related systems M' T without any additional determination by TVA of th3 components' qualifications for use in safety-related applications.
Another significant finding dealt with the difficulty or inability to retrieve quality assurance records in TVA took corrective action in response to these findings a timely manner.
to improve their procurenent and record storage programs to prevent similar However, these corrective actions did not appear problems from recurring.
to address the effect past procurement practices may have had on the quality of installed equipment.
This inspection was conducted to determine how procurement practices for original and replacement components and parts affected the original quali-fication or design requirements of safety-related equipment installed in the plant or if record storage practices prevent determining whether or not the qualification of equipment has been adversely affected. The inspection utilized three separate methods for selecting equipment for detailed review:
A sample of electrical, mechanical, and instrumentation components a.
was selected during a plant walk-through for a review of the related
{
procurement documents. Equipment was selected based on problems identified during previous inspections of licensees and vendors.
Problems noted in paragraph 6.b.7 were identified for an item from j
l this sample.
4 i
4 3
]
A computer listing of maintenance requests (MRs) initiated during b.
the time period 1980 to 1984 was obtained for selected systems and MRs were selected from these lists for follow-up based on whether or not a safety-related component was replaced. Problems noted in J
{
paragraphs 6.b.1, 6.b.6, 6.b.9, 7.a, and 7.b were identified for j
items drawn from this sample.
TVA began aa effort in July 1986 to evaluate the,eismic qualifica-s tions for a sample of Class 1E devices that had been f.eplaced. From c.
a total of approximately 125,000 MRs, they identified 238 MRs under l
which Class 1E devices had been replaced. At the time of this inspec-tion TVA was in the process of determining the status of seismic qualification for a sample of 50 MRs which represented Class IE replacement devices supplied directly from stock. This inspection reviewed several MRs from the 238 that were not part of TVA's sample l
Problems noted in paragraphs 6.b.2, 6.b.3, 6.b.4, and 6.b.5 of 50.
were identified for items drawn from this sample.
6.
Review of Procurement a.
Procram Review The team reviewed Part III, Section 2.1, " Procurement," of the Operating Quality Assurance Manual; SQA-45, " Quality Control of Materials, Parts, and Services," Sequoyah's site specific require-ments for procurement; and Sequoyah's Administrative Instruction W.
@i AI-11, " Receipt Inspection, Handling, and Storage of QA Materials, Substitutions and QA Level / Descriptions Changes."
A review of the definitions section of SOA-45 shows that TVA accu-rately reflected the NRC's intent for the terms " basic component,"
" Class IE," and " commercial grade item," terms commonly used when Three other definitions of interest to discussing procurement.
the team were, " Level I Quality Assurance Material," and " Level II Quality Assurance Material," commonly referred to as QA Level I and 0A Level II, and " Critical Structures, Systems, and Components (CSSC)." A significant part of the problems discovered during this inspection stem from the definitions given for QA Level I and QA Level II and their use. TVA's definitions for these terms are as follows:
Level I Quality Assurance Material--(1) Those CSSC materials, components, and spare parts which are a part of and whose failure would violate the reactor coolant pressure boundary; (2) those other CSSC items that cannot be bought by industrial standards and reference part number; (3) certain items that must be specifically bought as Level I as required by Attachment 21 (reference DP N76A10) of this standard practice, and (4) electrical equipment defined as Class IE.
i i
4 I
e Level 11 Ocality Assurance--CSSC materials, components, and spare parts tnat can be purchased by positive identifica-
' ion, provided that these items are not GA Level I.
QA Level II permits in-kind replacement of items when the specified industry code or standard provides positive identification.
Positive identification is established for an item by using one of the following methods:
Documentation supplied with the origina'l equipment j
3 a.
and/or from nameplate / tag information attached to the equipment.
The item's description as specified by the engineering b.
drawing bill of material, provided no special process is performed due to drawing notes, etc.
The' item's description as specified in the procurement i
c.
technical specification.
The item's noun name and part number when supplied by d.
the originel supplier, manufacturer, or vendor.
These definitions are atypical of what is normal industry practice in that they describe what equipment falls into each category rather than describing the quality assurance requirements acplicable to each Appendices to Attachment 20, " Specification of QA Program
-o 5 hj) category.
Requirements for Nuclear Power Requisitions," of SOA-45 contain the actual quality assurance requiremen+. These appendices are written for particular categories of eouipmsat, e.g., Appendix 1, "ASME Section III Materials;" Appendix 2, "ASME Section III Valves;"
Appendix 5, " Class 1E Materials and Equipment;" Appendix 8, "Non-ASME Code Items Which Have Unique Nuclear Requirements."
A note which is pertinent to the findings of this inspection appears 4
under the title of Appendix 8 as listed on page 250 of the 7/12/82 version of SQA-45. The note reads as follows:
... Used for procurement of QA Levels I and II (10 CFR 21 Applicable) basic components which have unique nuclear requirements, including Seismic Category I Application and equipment used in Class 1E application [ device as a whole which requires qualification by supplier or j
manufacturer]whicharenotASMESectionIIICode."
A cursory reading of this note by someone not familiar with TVA's interpretation of the phrases "10 CFR 21 Applicable," " Seismic Category I Application," and " Class 1E application," would lead one to believe that electrical and non-ASME mechanical equipment that was reouired to operate during and after a seismic event would be subject to the requirements of Appendix 8.
However, as the next two paragraphs show, this is not the case.
5 1
a 1
When TVA procedures discuss requirements for Seismic Category I application and Class 1E application, they are not necessarily referring to the specific pieces of equipment which must function during or after a seismic event.
The statement, "cevice as a whole j
which requires qualification by the supplier or manufacturer,"
l appears in the note quoted above.
As explained by TVA personnel
]
during the inspection and as can be seen from the examples cited in j
paragraph 6 b. below, TVA personnel interpreted this to mean that seismic and IE qualification was only applicable to the asseubly Therefare, if e qualified and supplied by the manufacturer.
"whole device" (e.g., motor control center, diesel generator set) was replaced, seismic qualification of the replacement was recired.
However, if a subcomponent of the whole device was replaced (e.g.,
relay, circuit breaker, air starter motor) seismic oualification was not required for the replacement, regardless of whether or not the replacement had to function during or af ter a seismic event. The reason given for this practice was that TVA was orcering replacements by part number and was receiving an "in-kind" or "like-for-like" part.
This practice was not adequate to assure a qualified part, however, because the procurements were made OA Level II, no documentation required, which amounted to commercial grade and provided no assurance that the replacements were in f act "like-for-like."
The procurement of safety-related equipment requiring seismic and environmental qualification as 0A Level II occurred because of L-two problems.
The second statement in.the definition QA Level I pf$$
and the definition of OA Level II allow items which can be identified N
by a unique manufacturer's part number and are produced to industry standards to be procured as OA Level II regardless of_the safety function of the item or the industry standard invoked. The other problem is that rather than basing quality reouirements solely on the. importance of the item being procurec', TVA based quality requirements on whether or not 10 CFR 21 was judged applicable to the item.
This problem was compounded by the fact that the form for
_ detennining Part 21 applicability, Attachment 11 to SOA-45, was biased
- towards not imposing Part 21 on anything less than a whole device.
Therefore, a piece of equipment which was originally supplied by the manufacturer as seismically qualified could be replaced by a commercial grade item without appropriate engineering analysis because TVA's i
procedures allowed the equipment to be classifiec' as QA Level II, j
Part 21 Not Applicable.
Paragraph 10.3 of ANSI N45.2.13 states that equipment may be accepted by source verification, receiving inspection, supplier certificate of conformance, post installation testing, or a combination thereof.
As the examples in paragraph 6.b. show, TVA chose to accept equipment i
based on receiving inspection and post installation testing.
The receiving inspection performed by TVA during the time period 1980-1984 consisted only of a check for shipping damage and cleanliness, and a comparison of the part number on the item to the ordered part 4
number.
Functional testing is performed after installation and assures that the piece of eouipment will function during normal operation.
However, receipt inspection and functional testing in-situ cannot I
l l
l
validate the ability of a piece _ of equipment.to function during or af ter a seismic event or exposure to a harsh environment. The other methods of acceptance available to TVA were source verification and supplier certificate of conformance. The " source verification required" block and the " documentation required" block were marked N/A for all;QA Level II procurements reviewed, although some manu-facturers submitted certificates of conformance (C of Cs) anyway.
However, in order to take credit for C of Cs, paragraph 10.2 of ANSI N45.2.13 reouires that the purchaser have a means of v'erifying the validity of the C of C.
The means permitted by paragraph 10.2 are audits 4 the supplier or independent inspections or tests. While armed independent inspections and_ tests, these tests could TVA pet not be used to validate a C of C for seismic or environmental quali.
fication since they only involved functional testing during. normal operating' condi tions. TVA also performed audits of the suppliers 'of most of the equipment for which documentation packages were reviewed.
However, a review of those audits indicates that the programs reviewed q
were the nuclear quality assurance programs and not the commercial grade programs. Based on previous NRC vendor inspection experience, if the nuclear quality assurance program is not invoked in the i
procurement document, the items being procured are usually not Therefore, manufactured under the nuclear quality assurance program.
a C of C received based on a contract which invoked the commercial grade quality program can only be considered valid.if the comercial g$
N,.f grade program has been audited and found acceptable.
b.
Procurement Imolementation The following describes the results of the review of MRs, procurement documents, receipt inspection records, and other associated document-ation for selected equipment.
l 1)
Steam Generator Level Solenoid Valve (2-LSV-003-174):
MR A-593379 was issued on 12/2/85 to replace the coils in this ASCO solenoid valve (model 206-381-2RVU) which provides a control function for the Main Steam Isolation Valves. The valve being worked on, S/N 49243J-90, was an environmentally j
and seismically qualified valve, purchased under contract 80KJ3-00827551, which had imposed 10 CFR Part 21 and an Appendix B quality assurance program on the manufacturer.
The valve location is the West Valve Room, a harsh environ-i ment.
Because of this, the maintenance was being controlled-l under the Qualified Maintenance Data System (0MDS) and the
)
MR was marked "QMD5" and "10 CFR 50.49 Device."
l As stated above, the original scope of work was to replace the coils in this valve.
However, because the craftsman could not remove the ceil subassembly with the tools supplied for the jcb, the whole valve was replaced with t\\.
another fully qualified valve, S/N 84146N-8.
j
.j 1
7 I
.I If the craftsman had not' encountered difficulty installing the replacement coils, the qualification of the original valve would have been indeterminate since the coils were procured as pieceparts, OA Level II, no documentation required, and no review of the effect of the commercial grade coils on the seismic and environmental qualification
{
of the original valve was made.
2)
Reactor Trip Bypass Breaker B (2-BKRC-099-KH/3151-G):
The undervoltage trip attachment (UVTA) on this Westinghouse D8-50 breaker was replaced under MR A-101112 on June 24. 1985.
The UVTA withdrawn from stock was one 'of 22 UVTAs pur chased under contract 84P64-343921 in November 1983. The contract identified the UVTAs as QA level II, and did not impose QA, 10CFR21, seismic or documentation requirements on the supplier.
However,' the supplier (Westinghouse) modified the original bid and self-imposed QA and 10CFR21 requirements. The microfilmed contract file at Sequoyah includes a Certificate of Qualification from Westinghouse for ten UVTAs, but only four of the ten listed cortespond to the UVTAs delivered under contract 84P64-343921 and the VVTA installed on this breaker is not one of them. As there is no documentation to support qualification of the VVTA, f.
the cualification of the breaker assembly is indeterminate.
3)
Normal Feed Breaker to Reactor Vent Board 2B-B (2-BDC-201-JQ-B):
f in0k The Reactor Vent Board 2B-B was originally purchased with the 480V motor control centers under contract 71C2-54752, dated May 5, 1971. The contract required a cuality assurance program and seismic testing and qualification for the safety-related motor control centers listed on the contract. The seismic test report, dated March 1972, also documented successful separate testing of internal components, including a circuit interrupter of the type a cified for the motor control center feed breakers.
On December 26, 1978, Purchase Requisition 272924 was issued to procure a replacement for the Reactor Vent Board 2B-B normal feed j
breaker and two additional overload trip units. The purchase requisitica and contract classified the items as QA level II, did not impose QA requirements on the supplier, did not require any quality documentation from the supplier, and determined that 10CFR21 was not applicable to this procurement.
The receiving inspection consisted of a comparison of nameplate data to the purchase documents.
One of the two overload trip units was withdrawn from stock on September 8, 1979, and installed on the normal feed breaker for the Reactor Vent Board 26-B under MR 00226. As there is no documented evidence of qualification for the trip unit, it renders the qualification of the feed breaker and the safety-t related motor control center it services indeterminate.
8
1
)
l 4).
Auxiliary Relay in 6.9kV Shutdown Logic Relay Cabinet 2A-A (2-PNLB-202-5C-A):
This safety-related logic cabinet was originally purchased in l
June 1972 under contract.72C02-83403,.which required a full OA program and seismic qualification.. Contract l78P15-24576, dated September 29, 1979, purchased as OA level II, 15 relays of-various styles without imposing-QA 10CFR21,.seispic, or quality documentation requirements on the supplier.
One of the replacement relays was withdrawn from stock and installed in the 6.9kV Shutdown Logic Relay Cabinet 2A-A-under MR A-019533 on May 28, 1982.
As there is no documented evidence of qualification for the relay, it renders the avali-fication of the safety-related relay cabinet indeterminate.
00, ing research of the contract files for this panel, the origi-nal seismic report and additional correspondence was found to indicate problems with the seismic testing of two types of relays, including the type of relay replaced under MR A-019533.
Although a letter from 1"A indicates acceptance of additional seismic testing of the relays, the report documenting the additional testing could not be located in the docur. ant control system during the three week period over which the inspection was conducted but was later obtained from an engineer who had
~
.4%
retained a personal copy.
W I
5)
Boric Acid Transfer Pump Motor (2-MTRB-62-230-A):
The original pump and motor assembly was supplied under the NSSS -
i contract with Westinghouse.
The applicable Westinghouse speci-fication (677123 Rev 0) imposed seismic requirements-for the assembly and required the supplier to provide documented proof of compliance to those requirements. Westinghouse provided 11358-1, dated January 9,1974, as documentation Quality Release that the boric acid transfer pump and motor ' assembly met the requirements of Specification 677123, Rev.0.
A replacement pump motor was purchased on January 13, 1982 under contract 82P64-323717. Although TVA classifies the motor as Class 1E, the contract identified the purchase as OA level II and did not impose QA, seismic, 10CFR21, or documentation requirements on the vendor. A motor different than ordered was supplied. A TVA substitution evaluation form (SONP AI-11 0, Appendix A Rev.10) was completed on August 9, 1982, but the engineering concurrence for Class IE substitutions was marked as not applicable.
On January 13, 1983, the replace-ment motor was installed.
As there is no documentation to support qualification of the pump motor, the qualification of the pump motor assembly is indeterminate.
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6)
Diesel Generators:
The diesel generators were procured under contract 71C61-92652 l
from Bruce-GM which required manufacturing under a 10 CFR 50, l
Appendix B cuality assurance program and seismic qualification Under RD-579489, dated 6/6/77, to contract of all equipment.
TVA procured replacement air starter motors from 73223-65906, TVA Ingersoll Rand as QA Level II, no documentation required.
has replaced these air starter motors numerous times either with motors procured from Ingersoll Rand or rebuilt by Sequeyah plant As there is no documentation to support qualification personnel.
of the replacement or rebuilt air starter motors, the qualifi-cation of the air starter mot)rs and the diesel generators in which they are installed is indeterminate.
Shutdown Board 2A-A Logic Relay Panel (2-8DA-202-CO-A):
7)
Items selected by the inspection team during the plant walkdown included two Agastat time delay relays from this safety-related Class 1E panel. These were Agastat model number 7012PD relays, serial numbers (S/Ns) 81031110 and 80362242, and are in the control logic circuits for the essential raw cooling water and The markings on tnese two the component cooling water systems.
relays indicate that they were not manufactured as qualified Class 1E components since the model number is not proceeded by gn.
This was subsequently confirmed with the relay manu-djp; an "E."
When contacted af ter completion of the facturer, Amerace Corp'.
80362242 inspection, Amerate Corp. indicate J that the relays, S/Ns N.' '
were manufactured commercial grade during the thirty-and 81031110, sixth week of 1980 and the third week of 1981, respectively.
Althcugh requested during the first week of the inspection, TVA was unable to identify or produce the procurement documents for However, since these relays are not uniquely these relays.
identified by TVA as Class IE de' ':es, the inspection team
'iece parts, QA Level II, assumes that they were procured t without the imposition of QA or documentation requirements on the supplier.
As there is no documentation to support qualification of the relays and the vendor's records indicate that they were not aalified devices, the qualification of the supplied as relays and shutdown board in which they are installed is indeterminate.
J 8)
Containment Isolation Valve (2-FCV-32-103):
This air operated globe valve is required to close on a Class B isolation signal and is listed in Table 9.3.1-2 of the FSAR as a seismic category I valve. This valve was chosen during the walk-through by the team to trace the procurement chain from an installed condition back to the documentation, and was also included in the sample of items for which the maintenance history l
1 10 i
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C'
~
The valve 'as ordered asLan ASME' Class 12 valve, w
was reviewed.
seismically cualified, under contract-73C34-83577, dated 3/15/73, The serial number of the.
fror,Masoneilan International Inc. traces back to a sive data package installed valve, N00137-21-4,However, a valve data orderirg sheet could for valve PCV-32-103.
,at be located for either PCV-32-103 or FCV-37-103'under contract 73C34-83577.
A review of Lthe maintenance history for 'this val've indicates -
that the valve failed its locallleak rate test. and was repaired The MR indicates that the. soft under MR A-081518, dated 8/1/83.
The rubber seat had been damaged in service and was replaced.
seat was rrecared QA Level II, no documentation required, under Because the alcng with two other items.
contract 79Fi?-278023as GA Level II, the receipt inspection did
. seat was class 1 fit. '
'* tics such as material' type, cure date, not include charac sted shelf life and storage conditions, durometer standard,
- ro ified for this type of material.
all of which should be vr 9)
Control. Valve-(2-FSV-32-1031):
i 206-380-2RVU, serves a control This ASCO solenoid valve, modelfunction for air operated co and is listed in Table 9.3.1-2 of the FSAR as a seismic category i
This valve was chosen during the walk-through by the
,$yjpg team to try to trace from the installed condition back through I valve.
The valve (serial the procurement chain to the documentation.
tre number 68337K), was purchased under contract 82PK1-330545, dated 4/8/82, from Mills & Lupton Supply Co. as OA Level II, no docu-Also purchased as 0A Level II under this mentation required.
contract were replacement coils and repair kits for this model Although no documentation was requested and the receipt inspection report for the valve had the " Certifying Document'No."
,, valve.
block marked "N/A," a Certificate of Compliance for the valve-certifying its compliance to IEEE-323 and IEEE-344 was in the contract file.
Conclusions Drawn'from Insoection Findings c.
10 CFR.50, Appendix B, Criterion XVI requires that conditions adverse However, although to quality be promptly identified and corrected. pointed out that TVA 12,.1985, NSRS Report R-84-17-NPS, dated March was using commercial grade items as basic components without deter-mining the effect on the safety function of the compo equipment which may be in nonconformance with seismic or environmen qualification requirements as a result of this practice.
Sequoyah personnel have started a review of Class 1E replacement de However, the effect of using commercial for seismic qualification.
grade piece parts on seismically and environmentally qualified device had not been considered at the time' of the inspection.
11-
j
=
The method used by TVA to identify their sample of 50 devices resulted J
in the majority of the sample being instrumentation items-such as level, 4
TVA's selection process started with pressure, or temperature switches.
equipment identification numbers that were categorized as Class IE, However, TVA's.
10 CFR 50.49, or had a safety train designation.
program only' identifies "those devices qualified as a whole" as Class IE and does not consider components or parts within a deviceAs as being Class 1E or affecting the qualification of the device..
a result, many safety-related electrical item's'sdch as circuit breakers, relays, and solenoid coils are not classified as 1E and therefore were not included in TVA's original sample.
TVA management stated that they intended to look at the 238 MRs iden-
~
tified as involving Class 1E device replacements rather than only the sample of 50 as originally intended.. This would still not account for the piece part replacements for safety-related electrical or mechanical equipment which comprise the majority of the replacements performed.
The concerns identified _ above constitute examples which support Potential Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective Action to Previously Identified NSRS Procurement Findings.
7.
Record Retrievability At the start of the inspection approximately 30 components were identified.
by the inspectors during a plant walk-through to determine if the inst.alled
$gi:q4620 This hardware was traceable back to the required procurement documents.
was in addition to the equipment documentation requested as a result of the review of MRs.
In addition to exam;les 7.7 and 7.b below, which involve record retrieva-bility, paragraphs 6.b.2), 6.b.4), 6.b.7), and 6.b.8) above provide examples of record retrievability in addition to procurement problems, a)
Residual Heat Removal Isolation Valve (2-FCV-74-1):
MR A-10737, for the fabrication and installation of sixteen 1-3/4" x 8" bonnet studs, was issued 8/20/83. Although no procurement deficiencies were noted, a record retrieval or The MR required a visual accuracy problem was identified.
examination of the studs.
Inspection report R-0686, dated
'l 8/20/83, referenced visual inspection procedure N-VT-1, During the course of the inspection this revision l
Revision 4.
of the procedure was requested, but TVA was unable to produce i t, f
b)
Residual Heat Removal (RHR) Pump. Motor (2-PMP-74-10):
MR A-080564, dated 3/15/83, requested that che 2A-A RHR pump motor shaft material be verified.
The method chosen to identify.the shaft j
material was the application of a copper sulfate solution, which in 3
combination with visual observation, can be used in making a quali-j i
l tative decision as to whether the material is' carbon' steel or stainless steel. 'Sequoyah Nuclear Power personnel performed the test and deter-
'l mined that the material was stainless steel.
i 1
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F S
p o,
When the inspector requested the procedure for performing the test, TVA could not produce it.
As a minimum, there should have been written instructions concerning the strength of the copper sulfate solution, the length of time between application and evaluation, temperature of the material prior to application, method of appli-cation, and evaluation criteria.
Several completed Power Stores material receipt inspection packages that were ready to be micro-fisched were review' d:
Tite review revealed e
i that some packages for safety-related components did not contain -the required objective evidence of acceptability, i.e., manufacturer's Certificate of Conformances and the component functional test data sheets.
Discussions with Division of Nuclear Engineering (.DNE) personnel determined that separate organizational files of these documents were kept by DNE.
Therefore, several areas would have to be researched before the required objective evidence of acceptability for an item was available.
As an example, package #839407, for eight nuclear grade Agastat time delay relays (Models E7012/E7022) procured by DNE, contained a closed OC inspection report that accepted the relays based on a handwritten note from DNE stating that DNE intended to accept the manufacturer's C of Cs. The required manufacturer's functional test data sheets were not in this package, but TVA personnel stated that the test data sheets were in a DNE file. When asked how the equipment was controlled or R.'(M tracked until DNE approved the C of Cs, Sequoyah personnel stated that no additional controls were placed on the equipment and no trackinn system existed.
If DNE eventually decided that the C of Cs were nrt acceptable, the equipment may have already been installed.
Similar e.,amples were found in package 838674 for four nuclear grade Foxboro differential pressure transmitters, and package 836394 for Atwood and Morrill ASME Section III diesel generator plug valves.
The lack of objective evidence of acceptability in the closed procure-ment and receipt inspection packages appears to have been caused by the following items.
(Items a) and b) were addressed in the NSRS reports.)
a)
Failure to establish a procedure, including acceptance criteria, for closed package review to ensure that the necessary documents are included in each package.
b)
Lack of adequate TVA organizational coordination, communication and/or procedures to provide one central focal point for review and storage of quality related documents.
c)
Failure to establish a tracking system to assure receipt inspec-tion packages eventually contain all necessary documentation or a reference to where the docume,tation is located.
d)
Failure to adequately review and approve the completed QC f
inspection reports by the QC inspectors immediate manacement.
a 13 i
1 l
l 10 CFR 50, Appendix B, Criterfon XVII requires that records be identi-l fiable and retrievable. ANSI N45.2.9, paragraph 6.2, requires that records be retrievable without undue delay. However, records for installed equipment which do not have a unique plant identification l
number (i.e., piece parts) could not be identified or retrieved during f
the three week period between the time the inspection started and the exit interview. Additionally, certain records could not be locaten through the record retrieval system and were lo.cated only by contacting an engineer in the Division of Nuclear Engineering whd had a pertonal copy.
This problem was previously identified in NSRS Reports I-83-13-PS and R-85-07-NPS and provides an additional example of TVA's failure to take adequate corrective action to NSRS findings. The concerns identified above contributed to Potential Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective Action to Previously l
Identified NSRS Procurement Findings.
8.
Receipt Inspection Receipt inspection packages for both past and present procurements and the associated versions of Administrative Instruction AI-11 " Receipt Inspection, Handling, and Storage of QA Materials, Substitutions, and 0A Level / Description Changes," were reviewed. AI-11, Attachment 1, Q"$
" Materials Receipt Inspection Report," is a listing of types of inspec-
.c.
t tions such a shipp'ng damage, markings, cleanliness, dimensiona'.,
i electrical '
ulatian, etc., with three check-off columns, "Yes," "No,"
and "N/A."
.ragraph 2.4 of AI-11 states that the inspector is respon-sible for dinermining which of the twenty inspection requirements apply.
Paragraph 2.4.1 of Al-11 states that if any inspections in addition to the twenty listed are needed, the originator of the purchase request is responsible for preparing appropriate inspection instructions.
- However, AI-11 does not contain or reference any detailed inspection or test l
procedures which would tell receipt inspectors what dimensions or any other characteristic to check, what tools or equipment should be used, or what the acceptance criteria are.
The inspection report does not provide 1
any space for recording the results of any inspections other than "Yes,"
f "No," and "N/A."
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instructions or procedures and include appropriate quantitative or qualitative acceptance criteria for determining that activities have been satisfactorily accomplished.
Contrary to the above, Sequoyah has not established detailed receipt inspection procedures which provide appropriate guidance to the receipt inspectors. This lack of instructions contributed to the problem discussed in Section 7 of this report concerning closing of incomplete l
receipt inspection folders without a tracking system to assure that C of Cs are eventually approved.
f II l[
This problem was previously identified in NSRS Report R-84-1-17-NPS and l
provides an additional example of TVA's failure to take adequate corrective
)
action to NSRS findings. The concerns identified above contributed to i
Potential Enforcement Finding 50-327, 328/86-61-01, Inadequate Corrective l
1 l
Action to Previously Identified NSRS Findings.
i i
14 N
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