ML20234E911
| ML20234E911 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/11/1987 |
| From: | Brown W, Howard J, Inger J TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20234E875 | List: |
| References | |
| MC-40705-SQN, MC-40705-SQN-R04, MC-40705-SQN-R4, NUDOCS 8709220562 | |
| Download: ML20234E911 (19) | |
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- ~I TVA EMPLOYEE CONCERNS' ' REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM 1
REPORT: TYPE: Sequoyah Nuclear Plant - Element REVISION NUMBER: 4 (Final Report) ;l TITLE: Quality. Receiving ~ Unit PAGE 1 0F 18 1
ItEASON FOR REVISION:
To incorporate. Technical Assistance. Staff and Senior Review Revision 1 Panel comments.
To incorporate additional information and reflect comments by the Revision 2 I Nuclear Regulatory Commission. Report' status changed from' l
"" Final" to." Reopened".
To incorporate Senior Review Panel comments Revision 3 To incorporate Correc'tive Action Plan (CAP) Revision 4 l 1 I NOTE: .The issue was escalated to the Employee Concerns Task Group (ECTG) l l Manager in accordance with the ECTO Program Manual. Resolution was. l received from the line organization and agreed to by the ECTG Manager. lR4 The ECTG evaluators are not in agreement with the CAP submitted by:the i line organization. The revision level was raised to R4. The contents of I i the report at Revision Level 3 have not been altered except to incorporate' l SRP comments on pages 2 and 3 (noted'by lR4). This was done to preserve l
'the report the evaluators prepared and signed. )
PREPARATION PREPARED BY:
N/A (See NOTE under " Reason for Revision" No. 4)
SIGNATURE DATE REVIEWS PEER:
N/A (Sco NOTE under "Roason for Revision" No. 4) ,
SIGNATURE DATE TAS:
N/A (See NOTE under " Reason for Revision" No. 4)
SIGNATURE DATE CONCURRENCES <
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TVA EMPLOYEE CONCERNS REPORT NUMBER': MC-40705-SQN SPECIAL PROGRAM l REVISION NUMBER: 4
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PAGE 2 0F 18 j
- 1. INTRODUCTION 1 This evaluation was performed as a result of a Sequoyah Nuclear Plant (SQN) specific employee concern, number XX-85-027-X02.
II.
SUMMARY
OF PERCEIVED PROBLEM The perceived problem as stated in concern number KK-85-027-X02 is:
" Material inspectors were not allowed to validate heat numbers of structural steel received on site as required by procedure (;) heat No. 7438383 is an example."
This is an erroneous statement of the problem based upon additional IR4 information obtained from the Nuclear Safety Review Staff (NSRS) unexpurgated files (see Section IV.C of this report).
Based upon this additional information the perceived problem is as stated in NSRS Report 1 . I-84-34-SQN:
" Heat numbers for QA [ Quality Assurance) material (steel) may be entered into the ' log book' [ Heat Number Sort Printout (HNSP)] without Certified Material Test Reports (CMTRs) being in the record vault. Heat No. 7438383 was provided as an example."
III. EVALUATION METHODOLOGY A. Reviewed expurgated flies to obtain additional information.
B. Reviewed Employeo Concerns Task Group (ECTG) working files to obtain additional information.
C. Reviewed NSRS unexpurgated files to obtain additional information.
D. Reviewed site Procedures to determine the requirements for validation of heat numbers.
E. Conducted interviews to determine if any instances of material inspectors not being allowed to validate heat numbers for material received on site were known (This step was performed for the original perceived problem as stated in concern number XX-85-027-X02).
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 3 0F 18 IV.
SUMMARY
OF FINDINGS A. A review of the expurgated files revealed the number of an NSRS report, "(NSRS) Report Number XX-85-027-X02." IR4 B. A review of the ECTG working file revealed an Employee Response Team (ERT) Investigation Report number XX-85-027-X;2 and associated correspondence. This correspondence indicates that NSRS Report number XX-85-027-X02, referenced in Section IV.A, of this report (MC-40705-SQN), is in fact the ERT Investigation Report number XX-85-027-X02.
ERT Investigation Report number XX-85-027-X02, written to IR4 address the perceived problem as stated in concern number XX-85-027-X02, contained the following conclusion: IR4 "This concern is not substantiated. This conclusion is based on the following:
(1) Interviews of the other material inspectors provided no evidence to support an impedance of inspectors to validate heat numbers as directed in the approved procedures.
(2) Material heat numbers randomly extracted from the H.N.S. [ Heat Number Sort] satisfactorily proved themselves to be adequate in that proper certified material test reports were readily available for all numbers picked.
The discrepancy noted in the observation section of this report requires further evaluation by TVA."
This conclusion, "This concern is not substantiated", is concurred with. Basis number (1) is agreed with, see Section IV.E. of this ECTG report (MC-40705-SQN). Basis number (2) is not agreed with due to the results of the heat code evaluation performed at SQN in ECTG Report MC-40703-SQN and the following inquiries.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 l
PAGE 4 0F 18 i
A Certified Material Test Report (CMTR) for each of the eleven heat numbers (7439599, 7438383, 318246, 3457, 4464622, 52795, 56434, 59139, 59569 K6024, and M2026), including the example heat number i 7438383 given by the Concerned Individual (CI), referenced in the ERT report was requested from the Document Control Unit (DCU). Only four (7439599, 7438383, 4464622, and 52795) of the eleven requested CMTRs were obtained from the DCU, one of these four was the example heat number 7438383 given by the CI. However, one heat number (3457) referenced in the ERT report is not listed in the HNSP.
These DCU personnel were again requested to conduct a thorough l search for CMTRs for these eleven heat numbers and to ascertain whether or not they could be considered to be "readily available". l I
This search revealed the following:
l CMTRs were found for only the following eight heat numbers: 7439599, 7438383, 31B246, 4464622, 52795, 59569, K6024, and M2026.
DCU personnel did not consider any of the :
CMTRs to be "readily available", and they stated, "it was a very difficult and time consuming process to locate these CMTRs."
CMTRs for the following three heat numbers, 3457, 56484, and 59139, could not be found.
NOTE: The above inquiries were employed l to determine whether or not a CMTR could be found for the subject heat numbers. ECTG report MC-40703-SQN '
programmatically addresses the methods employed to establish and maintain material traceability to the CMTR and the results of the lack of this ;
traceability.
The discrepancy noted in the observation section of the ERT Report is: i there is nothing adequately describing the use, metbods of maintenance or controlled distribution of the HNSP, ac required by 10 CFR 50, Appendix B, j Criterion V.
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TVA EMPLOYEE CONCERNS REPORT NUMdER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 5 0F 18 This discrepancy became an NSRS recommendation (Q-85-027-X02-01) to SQN. SQN's response, which is contained in the ECTG working files, was as follows:
. . . generation of a new procedure to control a document no longer in use at SQN is not justified."
SQN's, " Corrective Action Response Evaluation", was " accepted" {
by NSRS and ERT report XX-85-027-X02 closed. The NSRS acceptance transmittal is maintainad in the ECTG working files.
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SQN's response to, and USRS's closure of, this discrepancy is not concurred with because it did not address SQN's violation of 10 CFR 50, Appendix B, Criterion V, which states: ;
" Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, 1 of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.
Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have beca satisfactory accomplished."
The HNSP was used during a portion of the construction activities, at SQN, as the primary method of material verification, at installation, and also during the review for acceptability of the weld record documents. The HNSP remains available for use and, in fact, is used today as an aid in locating CMTRs for heat numbers (e.g., the HNSP was used by DCU personnel in locating the CMTRs referenced in Section IV.B of this report). The results of a lack of procedure governing the HNSP and its use are addressed in ECTG report MC-40703-SQN.
NOTE: Although no specific timeframe can be established for this concern, it was determined to be construction related due to ERT report references to Construction Procedurec and the concurrence of the CI with the results of the subject investigation, as stated in the report, "
. . . The CI was contacted to discuss results of the subject investigation and does not have any further questions in the area."
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TVA EMPLOYEE CONCERNS REPORT NUMBERI MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 6 0F 18 C. A review of the NSRS unexpurgated file revealed that several l l
investigations into concerns raised by this CI had been performed; the results of which failed to satisfy the CI. Consequently, as j
L stated in NSRS Report No. I-84-34-SQN (Q01 850315 052) a team i of'NSRS investigators met with the CI, in December 1984:
"The NSRS objectives were to.(1) obtain a precise and complete definition of.the employee's concerns, whether it was the restatement of previously evaluated concerns or identification of new concerns, and (2) to evaluate, indepth..allLitems of-concern as identified in'(1) above, L
regardless of whether or not it had been previously evaluated, to determine the validity of the concerns and, if valid, the safety significance of the concern."
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The concerns were documented and concurred with, by the CI, as follows:
" Concern No. 1 Individual 'A' has not been'following QA procedures since 1977,-and also, individual
'B' (the-concerned employee) has not been allowed to follow QA procedures during the same time period. The following three examples were provided to support this allegation.
Example A - Cable reels were not meggered upon rereeling for the reels documented.on Data Sheet 6 of Inspection Instruction (II)-32, ' Inspection of Material in Storage and Housekeeping Conditions,' for report :;os. MIG-828 -827, 710 -755, -756, and -757.
Individual B stated that the ' Data Sheet 6s' of II-32 for these MIG reports were not in the Material Inspection Group trailer and he did not.know whether they were in the Quality Control Records Unit or not.
I' TVA EMPLOYEE CONCERNS- REPORT NUMBER': 'MC-40705-SQN i SPECIAL PROGRAM REVISION NUMBER: A PAGE 7 0F 18 I, -
Example B - Cable: identification information may not have been transferred properly when cables were rereeled. In some cases cable catalog numbers were.used on the II-32 Data
! Sheet 6s inutead of cable reel numbers
. (SNP numbers)Las required by the procedures.
The concerned employee stated that this violation occurred during the.1981 through July 1982 timeframe.
Example C -~A reel of cable with TVA mark No.
'WDU' was transferred to SQN from Watts Bar Nuclear Plant (WBN). TVA mark No. WDU is class 1E cable at SQN, where.as it is non-class 1E at WBN. Individual B was concerned that this reel of cable may have been used in a class 1E system. Individual B provided a form TVA 45D dated January 13,11983, to the investigation team on this subject.
Concern No. 2 Quality assurance training was not always ,
received as documented on the SQN Report of -l Training or Instruction form. He alleged that 1 those records were altered by the instructors or
-clerks after the training sessions were completed and forms signed by the alleger. The alleged alteration dealt with addition / expansion of the description of instruction or training gi ven '. He provided documents dated July 18, 1983, and June 27, 1983, to illustrate this allegation.
Concern No. 3 Heat numbers for QA material (steel) may be )
entered into-the ' log book' without Certified Material Test Reports (CMTRs) being in the record vault. Heat No. 7438383 was provided as an example. He stated that he had not bosi able to locate CMTRs for three other heat. numbers in the past but that he did not remember those numbers."
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 8 0F 18 These concerns and their related conclusions and recommendations identified as a result of the NSRS investigative actions (referred to as NSRS " classical" investigations) are required to be evaluated and closed by'the ECTG "Other Site" Category Evaluation Group in accordance with:
" TENNESSEE VALLEY AUTH0klTY EMPLOYBE CONCERNS TASK GROUP PROCEDURE ECTG M.2 PROGRAM PLAN FOR SWEC AND NSRS ISSUES",
Revision 0, dated 08/28/86.
However, concern No. 3 is directly related to concern number XX-85-027-X02 and therefore it is evaluated in this report.
It is apparent that the concern as stated by QTC in concern number XX-85-027-X02 was derived by combining statements in the CI's concern Nos. 1 and 3. Concern No. 1 deals with incidents of impediment in following QA procedures:
. . . individual 'B' (the concerned employee) "
has not boon allowed to follow QA procedures. . .
while concern No. 3 deals with program inadequacies:
" Heat numbers for QA material (steel) may be entered into the ' log book' without Certified Material Test Reports (CMTRs) being in the record vault . . . .
Having roguested and obtained a CMTR for heat number 7438383 NSRS stated they could not substantiate the specific allegation of concern No. 3. However, in order to have a higher level of confidence in the HNSP they requested CMTRs for five additional randomly selected heat numbers (4?8990, 434221, 19047, 2-TW-67-'426, t
and 1815533). CMTRs were obtained for all of these except l 2-TW-67-426. As a result of the review of these and "other documents" in conjunction with their interviews, NSRS compiled a historical synopsis of the Heat Number Sort program used and reached the following conclusion:
"The specific allegation was not substantiated; however, there appear to be inconsistencies in ;
the implementation of the compilation of l required materials certification as well as !
ambiguity in the program established to control it . . .
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-10705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 9 0F 18 i
The portion of the conclusion dealing with the consubstantiation of the " specific allegation" is not concurred with because the allegation that heat numbers may be entered into the " log book" without CMTRs being in the record vault is valid (see Section IV.B ,
of this ECTG report). However, the balance of the conclusion is agreed with.
The NSRS report (I-84-34-SQN) also contained the following recommendation:
"As a result, the investigators could not confidently determine (1) the purpose (s) for which the Heat Number Sort was generated, (2) the specific administrative controls designed and practiced to maintain the integrity and adequacy of the program, and (3) the complete scope of application and utilization of the printout.
Therefore, it is NSRS's recommendation that a search of documents / files / procedures be 4 made so that a history of the Heat Number Sort can be reconstructed to include the following:
(1) The purpose / reason the Heat Number Sort was generated.
(2) Those management controls designed and implemented to administer the program.
(3) The function the program was designed to serve and the function it has been serving, if different.
(4) The confidence OC [0ffice of Construction) management has with the available information in the program (Heat Number Sort printout).
NSRS further recommends that appropriate actions be taken to obtain CMTRs for items listed for examplo 4 (2-TW-67-426)."
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! TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 10 0F 18 This recommendation is concurred with; however, it has yet to be adequately addressed as shown by the fo11owin6 correspondence:
A memorandum dated March 15, 1985, from the Director of NSES to the Manager of Construction and the Manager of Engineering (Q01 850315 051) requested OC:
". . . to provide NSRS with the l
actions taken er planned to resolve these issues within 30 days of the date of this memorandum."
l A memorandum dated April 16, 1985, from the Manager of Construction to the Director of NSRS (C01 850416 007) requested a 30-day extension to permit a more thorou6h investigation of the issues, includin6 the recommendation, raised by the NSRS report.
A memorandum dated May 15, 1965, from the Manager of Construction to the Director of NSRS (C01 850515 005) requested an additional ten workin6 days to complete their l response to the recommendation. A postscript dated May 16, 1985, (C01 850516 005) directed the SQN OC that:
"A response to I-84-34-SQN-03 [the NSRS recommendation] is to be drafted and reviewed by OC QAB [ Quality Assurance Branch) by the end of business on May 28. I will not request another extension for this item."
A memorandum dated May 20, 1985, from the Director of NSRS to the General Manager (Q01 850520 050) supplied the status of the recommendation response as:
. . . Awaiting OC's completion of research".
A memorandum dated May 21, 1985, from tae Project Manager, SQN OC to the Assistant to the Manager of Construction (C23 850521 008) stated:
"I can understand your desire not to request an additional extension.
The reason for both previously requested extensions was that we have informally coordinated drafts with NSRS.
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REPORT NUMBER": MC-40705-SQN-
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TVA EMPLOYEE CONCERNS SPECIAL PROGRAM REVISION NUMBER: 4 PAGE li OF 18 We have not thus far been able to provide words satisfactory to them.
SQN grew through the maturation of 10CFR50. What was seceptable no longer is. The heat code printout was in fact'used as a quality assuring mechanism.but in fact never had any formal controls applied to it. This was considered acceptable at that point in time'and the mechanism was in fact an improvement over what had been done before. The challenge is to gain understanding of that condition without
. exerting a massive record review program."
A memorandum dated May 28, 1985, from the Manager of' Construction to the Director of NSRS (Col 850529 007) contained the following response to the recommendation:
"We have studied the' subject NSRS investigation and herein provide the following responses:
Recommendation I-84-34-SON-03.
Availability of the Material Certification and Requirements for Heat Number Sort Printout Entries A search of documents / flies / procedures has been made as well as discussions with personnel who were involved with the Heat Number Sort Program. The following information is supplied in answer to the four areas mentioned in the NSRS report.
- 1) The purpose / reason the Heat Number Sort was gonorated.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN l i
SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 12 0F 18 The HNSP was developed to provide a quick reference for document reviewers to verify heat numbers recorded on QA inspection records.
For example, before weld data sheets were flied in the records storage vault a record reviewer would verify by way of the HNSP that the material used was appropriate.
If a record was received bearing a number which was not in the HNSP the record was rejected and researched.
- 2) Those management controls designed and implemented to administer the program.
There were no formal management controls placed on the HNSP.
A Soyuoyah Heat Number User's Guide was published and used for providing basic instructions on how to enter data into the program.
- 3) The function the program was designed to serve and the function it has been serving, if different.
Same as 1.
- 4) The confidence OC management has with the available information in the program.
OC management is confident that the information in the program was/is sufficiently accurate to statistically support a reasonable assurance that the plant was constructed in accordance with applicable codes and standards.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 13 0F 18 It must be remembered that the SQN QA program grew and matured with the l 10CFR50 QA program. It is understood
' and accepted that the SQN QA program would not meet todays standards but it did meet the standards of the time.
Weed Instrument Company was contacted on March 28, 1985 and appropriate documentation was received for the items listed in example 4 of your basic report."
A memorandum dated July 8, 1985, from the Director of NSRS to the General Manager (Q01 850709 055) supplied the SQN OC response to the recommendation (C01 850529 007) along with the following comment:
"We do not find the response satisfactory and plan to investigate this issue ourselves in the near future."
A memorandum dated July 8, 1985, from the Director of NSRS to -
the Manager of Construction (Q01 850709 054) contained the following:
"We have reviewed your response to NSRS recommendation I-84-34-SQN-03, Availability of the Material Certification and Requirements for Heat Number Sort Printout Entries, and do not find it satisfactory.
We plan to investigate this matter further ourselves in the near future.
Please provide us with copies of all SQN procedures since the inception of the Heat Number Sort Printout that controlled or referenced this program for any and all applications. These procedures should include all that could have been in effect since then as well as those deleted or inactivated. Our intent is to determine the historical background of the program as well as its potential / perceived /
actual application. We appreciate your cooperation on this matter and expect the results of the historical review by August 1, 1985."
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TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 14 0F 18 A postscript dated July 16, 1985, (C01 850716 001) directed an addressee to:
. . . assemble the requested information (what is available) and prepare response for . . . (The Manager of Construction's]
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. . . signature ASAP."
A memorandum dated July 23, 1985, from the Manager of Construction to the Director of NSRS (C01 850723 004) contained the following:
"We have performed a review of SQN's Quality Program to identify any procedures referring to or controlling the Heat Number Sort Printout and were unable to identify any such interfacing quality program procedures. We have attached a Program User's Guide to assist you. Please be advised that this guide and the HNSP are not and never were a part of the Quality Program "at Sequoyah."
No further correspondence concerning this recommendation was found; thus leaving the matter unresolved.
D. Site Procedures governing the validation of heat numbers, consisted of the following:
SNP Inspection Instruction No. 30, " Receipt Inspection" (11-30), Revision 0, dated 05/04/77 through Revision 7, dated 09/20/82.
SNP Construction Procedure No. P-34, " Heat Number Validation" (P-34), Revision 0, dated 06/13/77 and Revision 1, dated 12/13/78.
SNP Inspection Instruction No. 11-39, " Heat Code Transfer and ASTM 1 Designator Transfer" (II-39), Revision 0, dated 05/04/77 through Revision 2, dated 12/11/78.
ENP Construction Procedure No. P-31,
" Identification and Marking of Permanent Material" (P-31), Revision 0, dated 05/04/77 through Revision 2, dated 12/17/79.
l Amorican Society for Testing and Materials
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 15 0F 18 These procedures require that heat numbers be validated; either at roceipt of material into the warehouse (II-30 and II-39) or upon division of the material into two or more pieces, after issue from the warehouse (P-34). A valid heat number is defined in II-39 as follows:
l "The heat number or beat code shall be considered valid if the number or code marked or stamped on the material agrees with that on the applicable matorial certification or if the heat number or heat code has been previously validated "
Those. procedures provide methods to permanently mark the material with a validation confirmation mark; but, they do not require a permanent mark.
Markings of a nonpermanent nature would probably, with the passage of timo, become partially or totally obliterated; thus giving the illusion of its having never been validat d, when the item is viewed in the fleid.
NOTE: No site procedure could be found governing the accuracy of the information or the use of the HNSP, only a User's Guide2 was found describing how information should be encoded.
E. Interviews conducted with eight materials inspection personnel, active during the construction phase of SQN revealed no known instances of material inspectors being prevented from vclidating heat numbers / codes of material received on site, as required by the procedures.
NOTE: Any potential intimidation or harassment of this CI is being handled by the Inspector General's Office by concern number HI-85-005-001, 2 UNDERLINE ADDED FOR EMPHASIS IN THIS REPORT.
J TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN j SPECIAL PROGRAH !
REVISION NUMBER: 4 l
d pAGE 16 0F 18 )
i Conclusions The perceived problem as originally evaluated (i.e., incidents of impediment in following QA procedures) was in error; however, the perceived problem as presently stated (i.e., programmatic inadequacies) was determined to be valid based upon the findings contained in this report. Contrary to the requirements of 10 CFR 50, Appendix B, Criterion V, the Heat Number Validation process and HNSP used for heat number documentation accountability /retrievability, were/are not sufficiently controlled by QA procedures.
With respect to pressure boundary materials, the results of the lack of IR4 procedural control to ensure that only properly certified materials were used during and subsequent to construction activities at SQN, is addressed in ECTG report number MC-40703-SQN " Heat Code as Related to Material Control".
V. ROOT CAUSE Management's failure to initiate and maintain adequate administrative controls (site procedures) to implement regulatory and code requirements.
VI. CORRECTIVE ACTION 1 Provided by the line organization on Corrective Action Tracking Document 1 (CATD) number 40705-SQN-01, Revision 0. l l
The Heat Number Sort Printout (HNSP) is not used at SQN to control I activities that affect quality. It is used to assist in locating I certified mill test reports and other document search activities. I Consequently, its use does not represent a potential for degradation of I safety-related equipment at the present time nor in any future activities. I Additionally, a stop work order was issued to require any installation of 1 material on 'fVA Class A, B, and C/D pressure retaining piping components I to be specifically approved by the Site Director. This approval requires 1 that traceability of material be contained in a work package, which ensures I proper traceability. I I
It is recognized that the HNSP has errors and omissions; however, the l consequences of those errors and omissions have not adversely affected I the plant safety as demonstrated by the Kelly and Landers report as I related to pressure retaining material (Executive Report, Reference 1). IR4 The HNSP will be used in QA activities only as a tool in locating I documentation for retrieval. When material verification / searches are i performed, hard copy documentation, microfilm, and/or physical I verifications will be used to the extent necessary to ensure adequate i material verifications / searches. The Site Director has issued directives I (References 2 and 3) to ensure this; however, since the HNSP is not being used and will not be used for QA verification, a formal procedure addressing its use is not necessary. I
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN l SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 17 0F 18 The HNSP was not.used for installation verification of civil items, I structural plates and shapes. During construction, structural plates I and shapes were verified at installation, only to assure heat number I marking, because material was verified at receiving and heat numbers I were maintained to identify the material as acceptable. Non-QA material l did not have heat numbers and could not be used in QA application. At I approximately 1975, all non-QA structural material was' eliminated from I the site to ensure enly QA material was available and all further civil I structural material was procurred as Quality Level I which requires heat I number traceability. Most structural material was input into in the HNSP l at approximately 1978. This was done when the Materials Services Unit I assumed responsibility for input to the program. All material with I certification was eventually encoded into the HNSP if the certification I was known to exist. l 1
Structural material issued as pressure boundary attachments was initially I issued by the civil group. After the material was received at the pipe I shop, control and verification for pressure boundary attachments was l handled in the same manner as for pressure retaining material. The l evaluation of pressure retaining piping materials (HCTTG Final Report, i Reference 4 and Executive Report, Reference 1) which involved over 500 l Individual items did not identify a single instance where the wrong i material specification was installed as identified in the HCTTG Final i Report (Reference 4). The report identified problems with pipe class IR4 distinction but no instances where the wrong material specification was l installed. Based on this evaluation and the fact that the installation I verification process was the same, although not evaluated, there is no I reason to believe that pressure boundary attachments verified by use of l the HNSP were not the proper material specification. l l
Additionally, the heat numbers identified in the subject ECTG report i for which CMTRS were not found (i.e., readily retrievable) have had l certifications located by SQN. Appropriate certifications are readily I retrievable in the permanent records storage vault in the plant offico I building. l l
References:
1 I 4
- 1. Memorandum from S. A. White to W. R. Brown, dated May 5, 1987, " Heat I Code Traceability Issues at Sequoyah Nuclear Plant (SQN), dated l April 21, 1987", (A02 870428 034) l l
- 2. Memorandum from H. L. Abercrombio to W. E. Andrews, R. W. Olson, 1 P. R. Wallace dated October 6, 1986, "Sequoyah Nuclear Plant ]
(SQN) - Installation of the Modifications Performed on Nuclear l Class I, II, Nd III (TVA Class A, D, and C/D) Pressure Retaining i Piping Components," (S00 861006 802) l l
- 3. Memorandum from H. L. Abercrombie to Those L8 #d, dated l
! March 30, 1987 "SNP (SQN) - Employee Concern. 2ask Group (ECTG) l ,
Element Report No. MC-40705-SQN-R2 - Material Control Category" (SO9 870327 804)
TVA EMPLOYEE CONCERNS REPORT NUMBER: MC-40705-SQN SPECIAL PROGRAM REVISION NUMBER: 4 PAGE 18 0F 18 i
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- 4. Final Report, dated January 1907, " Materials Traceability for Piping lR4 Systems - Sequoyah Nuclear Plant" (B25 870225 036) l VII. GENERIC APPLICABILITY _
Determined to be generically applicable to Bellefonte Nuclear Plant (BLN) and WBN due to the necessity to provide adequate administrative controls (site procedures) to implement regulatory and code requirements.
VIII. ATTACHMENTS Attachment A - Concerns Printout (Identifies relationship to Nuclear Safety and Generic Applicability) i l
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