ML20235B752
| ML20235B752 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/05/1987 |
| From: | Russell Gibbs TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082340470 | List:
|
| References | |
| 10700, 10700-V01-R03, 10700-V1-R3, NUDOCS 8902140414 | |
| Download: ML20235B752 (66) | |
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i EMPLOYEE CONCERNS SPECIAL PROGRAM VOLUME 1 CONSTRUCTION CATEGORY SUBCATEGORY REPORT 10700 INSTRUMENT TUBING i
UPDATED TVA NUCLEAR POWER
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REPORT TYPE:
Subcategory - Construction REVISION NUMBER:
3 (Final Report) l TITLE: Instrument Tubing PAGE 1 0F 43
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REASON FOR REVISION:
Revised to incorporate Corrective Action Plans, Executive Summary I
SRP comments, and finalize report Revision 1 Revised to incorporate SRP comments and refinalize report Revision 2 I
Revised to incorporate TAS comments and refinalize report Revision 3 PREPARATION PREPARED BY:
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- SRP Secretary's signature denotes SRP concurrences are in files.
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Preface. Glossary and List of Acronyms for ECTG Subcategory Reports HISTORY OF REVISION REV NUMBER PAGES REVISED REASON FOR CURRENT REVISION 3
i To clarify that one or more attachments will help the reader find where a particular concern is evaluated
TVA EMPLOM E CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM FRONT MATTER REV:
3 PAGE i 0F vill Preface This subcategory report is one of a series of reports prepared for the Employee Concerns Special Program (ECSP) of the Tennessee Valley Authority (TVA).
The ECSP and the organi:ation which carried out the program, the Employee Concerns Task Group (ECTG), were established by TVA's Manager of l
Nuclear Power to evaluate and report on those Office of Nuclear Power (ONP) employee concerns filed before February 1, 1986.
Concerns flied after that date are handled by the ongoing ONP Employee Concerns Program (ECP).
The ECSP addressed over 5800 employee concerns.
Each of the concerns was a formal, written description of a circumstance or circumstances that an l
employee thought was unsafe, unjust, inefficient, or inappropriate.
The mission of the Employee Concerns Special Program was to thoroughly investigate all issues presented in the concerns and to report the results of those investigations in a form accessible to ONP employees, the NRC, and the general public. The results of these investigations are communicated l
by four levels of ECSP reports:
element, subcategory, category, and final.
Element reports, the lowest reporting level, will be published only for those concerns directly affecting the restart'of Sequoyah Nuclear Plant's reactor unit 2.
An element consists of one or more closely related issues.
An issue is a potential problem identified by ECTG during the i
evaluation process as having been raised in one or more concerns.
For l
efficient handling, what appeared to be similar concerns were grouped into
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elements early in the program, but issue definitions emerged from the I
evaluation process itself.
Consequently, some elements did include only I
one issue, but often the ECTG evaluation found more than one issue per f
element.
Subcategory reports summarize the evaluation of a number of elements, j
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However, the subcategory report does more than collect element level I
evaluations.
The subcategory level overview of element findings leads to j
an integration of information that cannot take place at the element lovel.
This integration of information reveals the extent to which problems j
overlap more than one element and will therefore require corrective action l
for underlying causes not fully apparent at the element level.
To make the subcategory reports easier to understand, three items have been placed at the front of each report:
a preface, a glossary of the terminology unique to ECSP reports, and a list of acronyms.
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Additionally, at the end of each subcategory report will be a Subcategory f.
Summary Table that includes the concern numbers; identifies other j
l subcategories that share a concern; designates nuclear safety-related, J
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safety significant, or non-safety related concerns; designates generic applicability; and briefly states each concern.
l Either the Subcategory Summary Table or another attachment or a combination l
of the two will enable the reader to find the report section or sections in which the issue raised by the concern is evaluated.
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TVA EMPLOYEE CONCERNS
' REPORT NUMBER:
10700 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE 11 0F viii The subcategories are themselves summarized in a series of eight category reports.
Each category report reviews the major findings and. collective significance of the subcategory reports in one of the following areas:
management and personnel relations industrial safety construction i
material control operations quality assurance /guality control i
welding engineering l
A r.eparate report on employee concerns dealing with specific contentions of intimidation, harassment, and wrongdoing will be released by the TVA Office of the Inspector General.
Just as the subcategory reports intograte the information collected at l
the element lovel, the category reports integrate the information assembled in j
all the subcategory reports within the category, addressing particularly l
the underlying causes of those problems that run across more than one subcategory.
I A final report will integrate and assess the information collected by all
'l of the lower level reports done for the ECSP, including the Inspector General's report.
l For more detail on the methods by which ECTG employee concerns were evaluated and reported, consult the Tennessee Valley Authority Employee Concerns Task Group Procedure Manual.
The Manual spells out the program's objectives, scope, organization, and responsibilities.
It also specifies the procedures that were followed in the investigation, reporting, and close-out of the issues raised by the over employee concerns.
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1 TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM FRONT MATTER REV:
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PAGE 111 0F vill ECSP SUBCATEGORY REPORT GLOSSARY OF TERMS
- 1 classification of evaluated issues the evaluation of an issue leads to one of the fo110 win 6 determination:
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Class A:
Issue can not be verified as factual i
Class B:
Issue is factually accurate, but what is described is not a problem (i.e., not a condition requiring corrective action)
Class C:
Issue is factual and identifies a problem, but corrective action I
for the problem was initiated before the evaluation of the issue I
was undertaken Class D:
Issue is factual and presents a problem for which corrective action has been, or is being, taken as a result of an evaluation i
Class E: Issue itself does not identify a problem, but as a result of the evaluation another problem was discovered for which corrective action was initiated or is needed 1
colloetive significance an analysis which determines the importance and l
uences of the findings in a particu]se ECSP report by putting those const findings in the proper perspective.
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l concern (see " employee concern")
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l corrective action steps taken to fix specific deficiencies or discrepancies revealed by a negative finding and, when necessary, to correct causes in I
order to prevent recurrence.
j criterion (pluralt critoria) a basis for defining a performance, behavior, or quality which ONP imposes on itself (see also " requirement").
I oloment or element report an optional level of ECSP report, below the y
subcategory level, that deals with one or more issues.
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omoloyee concern a formal, written description of a circumstance or circumstances that an employee thinks unsafe, unjust, inefficient or J
inappropriate; usually documented on a X-form or a form equivalent to the
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X-form.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM FRONT MATTER REY:
2 PAGE iv 0F vill evaluater(s) the individual (s) assigned the responsibility to assess a specific grouping of employee concerns, i
findinr.s includes both statements of f act and the judgments made about those facts during the evaluation process; negative findings require corrective action.
issue a potential problem, as interpreted by the ECTG during the evaluation process, raised in one or more concerns.
K-form (see " employee concern")
- i reautrement a standard of performance, behavior, or quality on which an evaluation judgment or decision may be based.
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root cause the underlying reason for a problem.
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- Terms essential to the program but which require detailed definition have been defined in the ECTG Procoduce Manual (e.g., generic, specific, nuclear i
safety-related, unreviewod safety-significant question).
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TVA EMPLOYEE CONCERNS-REPORT NUMBER:
10700 SPECIAL PROGRAM FRONT KATTER.REV:
2" PAGE v 0F viii l
Acronyms AI Administrative Instruction I
AISC American Institute of Steel Construction ANS American Nuclear Society ANSI American National Standards Institute i
ASME American Society of Mechanical Engineers l
ASTM American Society of Testin6 and Materials AWS American Welding Society BFN Browns Ferry Nuclear Plant BLN Bellefonte Nuclear Plant CAQ Condition Adverse to Quality CAR Corrective Action Report CATD Corrective Action Tracking Document CCTS Corporate Commitment Tracking System CEG-H Category Evaluation Group Head CFR Code of Federal Regulations CI Concerned Individual CMTR Certified Material Test Report C0C Certificate of Conformance/ Compliance DCR Desi6n Chan6e Reguest DNC Division of Nuclear Construction (see also NU CON) 6
1 REPORT NUMBER: '10700.
TVA EMPLOYEE CONCERNS SPECIAL PROGRAM FRONT MATTER REV:
2 PAGE vi 0F vili Division of Nuclear Engineering DNE Division of Nuclear Quality Assurance DNQA Division of Nuclear Training DlJT I
DOE Department of Energy Division Personnel Officer DP0 Discrepancy Report or Deviation Report DR Engineering Change Notice ECN ECP Employee Concerns Program Employee Concerns Program-Site Representative ECP-SR ECSP Employee Concerns Special Program f
ECTG Employee Concerns Task.' Group Equal Employment Opportunity Commission EEOC Environmental Qualification EQ Employee Re 9onse Team or Emergency Response Team ERT FCR Field Change Request Final Safety Analysis Report FSAR FY Fiscal Year General Employee Training l
GET Heating. Ventilating. Air Conditioning HVAC Installation Instruction II Institute of Nuclear Power Operations INPO IRN Inspection Rejection Notice 1
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM FRONT MATTER REV:
2 I
PAGE vii 0F vili I
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l L/R Labor Relations Staff M&AI Modifications and Additions Instruction MI Maintenance Instruction 1
MSPB Merit Systems Protection Board l
MT Magnetic Particle Testing l
NCR Nonconforming Condition Report NDE Nondestructive Examination NPP Nuclear Performance Plan NQAM Nuclear Quality Assurance Manual NRC Nuclear Regulatory Commission NSB Nuclear Services Branch l
NSRS Nuclear Safety Review Staff NU CON Division of Nuclear Construction (obsolete abbreviation, see DNC) l NUMARC Nuclear Utility Management and Resources Committee OSHA Occupational Safety and Health Administration (or Act)
ONP Office of Nuclear Power OWCP Office of Workers Compensation Program PHR Personal History Record PT Liquid Penetrant Testing QA Quality Assurance QAPP Quality Assurance Program Plan QC Quality Control QCI Quality Control Instruction L_________________________-_________-___
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM FRONT MATTER REV:
2 PAGE vili 0F vill i
QCP Quality Control Procedure QTC Quality Technology Company RT Radiographic Testing 1
SQN Seguoyah Nuclear Plant SI Surveillance Instruction SOP Standard Operating Procedure SRP Senior Review Panel SWEC Stone and Webster Engineering Corporation TAS Technical Assistance Staff TVA Tennessee Valley Authority UT Ultrasonic Testing VT Visual Testing i
WBECSP Watts Bar Employee Concern Special Program j
1 WBN Watts Bar Nuclear Plant WR Work Request or Work Rules WP Workplans i
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700' SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 2 0F 43 OUTLINE OF CONTENTS h:.
EXECUTIVE
SUMMARY
1.0 Characterization of Issues t-l 1.1 Introduction 6
1.2 Description of Issues 6
1.2.1 Bending Equipment / Material 6
1.2.2 Cleanliness 7
1.2.3 Venting 7
h 1.2.4 Routing 7
1.2.5 Installation 7
2.0 Summary 8
2.1 Summary of Issues 2.2 Summary of the Evaluation Process 8
2.3 Summary of Findinr.s 9
2.4 Summary of Collective Sir.nificance 10 2.5 Summary of Causes 11 2.6 Summary of Corrective Action 11 3.0 Evaluation Process 12 3.1 General Methods of Evaluation 12 3.2 Requirements or Criteria Established for Individual Issues 13 3.2.1 Bending Equipment / Material 13 1
3.2.2 Cleanliness 14 1
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I TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 3 0F 43 l
OUTLINE OF CONTENTS (continued) i Part 3.0 Evaluation Process (continued) 3.2.3 Ver. tin 6 15 i
k 3.2.4 Routin6 35 I
3.2.5 Installation it 1
4.0 Findings
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4.1 Bending Equipment / Material 16 4.1.1 Generic 4.1.2 Site Specific 4.2 Cleanliness 26 4.2.1 Generic 4.2.2 Site Specific 4.3 Ventinr.
28 4.3.1 Generic 4.3.2 Site Specific l
4.4 Routinr.
29 4.4.1 Generic 4.4.2 Site Specific 4
f 4.S Installat! 9 3 C.
4.5.1 Generic l
4.5.2 Site Specific-WBN 4.5.3 Site Specific-BLN I
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
30700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 4 0F 43 i
l OUTLINE OF CONTENTS (continued)
Fafe 5.0 Collective Significance 33 5.1 Significance of Each Issue 33 5.1.1 Bending Equipment / Material 33 l
5.1.2 Cleanliness 34 l
5.1.3 Venting 34 5.1.4 Routing 3e 5.1.5 Installation 34 j
l 5.2 Collective Significance of the Subcategory 34 5.2.1 Generic 6.0 Cause 35 l
l 6.1 Rendinr. Equipment / Material 35 g
l 6.2 Cleanliness 35 6.3 Ventinr.
35 6.4 Routinr.
35 6.5 Installation 35 I
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7.0 Corrective Action 36 i
i 7.1 Corrective Action Already Taken er Planned 36 i
l 7.1.1 Site Specific 36 l
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7.1.1.1 WBN i
7.1.1.2 BFN I
7.1.1.3 SQN l
I 7.1.2 Generic 37 I
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l TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 5 0F 43 OUTLINE OF CONTENTS (continued) j Entt
,l 7.0 Corrective Action (continued) 7.2 Corrective Action From CATD's 37 J
l 7.2.1 Site Specific 37 1
7.2.1.1 WBN 7.2.1.2 BLN 7.2.1.3 SQN f
7.2.2 Generic 40 l
I 8.0 Attachments 43 l
i 8.1 Attachment 'A' Subcategory Summary Table and List of Concerns 43 8.2 Attachment
'B' Referonce Memorandum on Installation of Instrument 43 Lines l
8.3 Attachment
'C' List of Concerns by Issue 43
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8.4 Attachment "D" List of Evaluators 43 l
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Executive Summary Instrument Tubing' I
Report Number:
10700 Issue Assessment This subcategory report addresses twelve concerns associated with tubing bonding equipment, configuration of Radiation Monitoring System tubing bends, tubing materials, cleanliness of stainless tubing assemblies, venting of tubing assemblies before hydrostatic testing, routing of panel drain tubing and instrumentation line installation practices. The bending issues were associated with the qualification, periodic inspection and segregation of tubing benders and the perceived problem that defective copper tubing materials were being used at WBN. The cleanliness issue was associated with two employee's perceptions that stainless stoel tubing was being contaminated by bending machines which were coated with rust, dirt or grease as a result of l
being stored in an environment w2th no cleanliness control. One concern was I
voiced as a suggestion to use teflon tape as an alternative thread sealant on tubing connections. The venting issue involved an employee's perception that venting practices at WBN possibly adversely affected system hydrostatic tests results. The routing issue portained to the routing scheme chosen for panel drains in the Unit One Reactor Buildinr, raceway at WBN. The installation issue surfaced when employees voiced concerns about the amount of rework caused by the installation of tubing systems in areas with pro-existing interferences and the installation of incorrect tubing sizes.
Major Findinr,s l
Review of each site's tubing bonding and installation controlling procedures I
diagnosed weaknesses in the storer,e and ser,regation controls in effect before the issue evaluations.
Inadequacies were apparent in each site's bending l
equipment qualification and maintenance methods.
WBN completed a sampling l
program designed to qualify the installed configurations of all unit one tubing bends in all of the powerhouse buildings.
The unit one sampling program results were expanded to accept all of the unit two tubing bunds installed before the current controlling procedures became effective. The TVA fabricated benders used to bend 1" 0 o.d. and 1 1/2" 0 o.d. Radiation Monitoring System had been repaired and requalified to maxe acceptable bends before the issue evaluation.
Evaluation of the perceived problem with " defective" copper tubing revealed that hard copper tubing (non-bending quality) was being supplied by vendors.
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Review of the Bills of Materials for each site showed that the procurement I
specifications were worded in such a way that.hard copper could be supplied by i
vendors and still be ompliance with contract specifications.
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l Evaluation of the cleanliness issues revealed that bending equipment storage facilities were inadequate at WBN. As a result of the WBN-DNC concern i
evaluation, QCP 3.13-5 was revised to include control and storage requirements
~j for bending equipment. Cleanliness requirements for bending equipment were J
also addressed in the procedure revision to preclude stainless rteel tubing contamination. Tubing for critical systems is cleaned before system transfer.
A sample review of the hydrostatic test documentation proved that venting requirements for tubing assemblies were an integral part of each test package. Field observations revealed that high point vents were properly installed or that venting could be performed through the process piping associated with each tubing assembly.
The routing issue evaluation showed that panel drains were incorrectly field routed into a floor drain system that was designed to be a closed loop system to retain water inside the unit one cranewall. The closed loop breach was documented by NCR 5899..The drain lines were rerouted to open floor drains as designed.
i Review of the DNE issued installation criteria for~ instrument tubing proved i
the issue concerning separation violations existing in WBN's Unit Two South Valve Room to be factual. The installation specification N3E-885, requires a field evaluation by DNE to determine final acceptability of tubing installations before system transfer to ONP.
It was concluded that the noted interferences existed, the interferences were known during installation and the installation program requires evaluation at a later date. As stated in the foreward of the subject construction specification., " failure to meet these requirements does not necessarily mean that pipe rupture requirements are violated." The issue was determined to be factual but no corrective action is required at this time.
The BLN evaluation for the installation issue proved to be not technically factual.
Rework of tubing was encountered, but was traced to criteria changes issued by DNE.
I Collective Significance i
l All sites' bending equipment controlling procedures and copper tubing
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procurement specifications were deemed 'o be inadequate. As a result of the ECTG evaluation for the issues addressed by this subcategory report the following program revisions are being implemented and standardized: Controls for qualification of bending equipment, segregation and storage of bending equipment, detection methods for damcged bending equipment and procurement specifications for copper tubing.
The concerns addressed within the bending equipment / material issue pertaining I
l to copper tubing and the existing copper tubing installations were deemed to be not safety-related. The concerns for the other identified issues had either IE2 been addressed before the concerns were evaluated or were considered :.o not be i
problems requiring immediate corrective action.
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i TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION-NUMBER:
3 PAGE 6 0F 43 l
1.0 CHARACTERIZATION OF ISSUES 1
1.1 Introduction
.j This subcategory report on Instrument Tubing in the Construction Category addresses twelve safety-related concerns. Thel concerns were specific to Watts Bar Nuclear Plant (WBN), with one exception, and pertain to the adequacy of bending Lquipment/ material, L!
cleanliness, venting, routing, and installation of instrumentation i
tubing. The coacerns were categorized for evaluation into five issues; Bending Eauipment/ Material IN-85-707-002 IN-85-740-002 IN-85-740-003 IN-85-773-002 IN-85-831-001 Cleanliness WBN-86.-052-001 I
IN-85-447-001 IN-86-289-001 4
Venting IN-85-866-002 Routing IN-85-532-002 Installation IN-85-858-001 XX-85-086-001 (Specific to Bellefonte Nuclear Plant - BLN) 1.2 Description of Issues 1.2.1 B.ending Eaulpment/ Material Five concerns are addressed in the issue of bending operations and materials used for instrumentation systems and are WBN specific.
I l
-y____._._----._--_-_-_---_--
t TVA EHpLOYEE CONCERNS REPORT NUMBER:
10700
.I SPECIAL PROGRAM y
q REVISION NUMBER:
3 l
l PAGE 7 0F 43 1.2.1 Bencing Equirment/ Material (continued)-
The V3N issues are associated with the damade of copper' tubing and 1"c o.d. and 1-1/2"o o.d. stainless steel tubing.
l The damage was' attributed to defective bending machines and/or j
the material used.
Specifically, the perceivcd problems were that " Imperial" brand hand' held benders break, deform, and/cr crack copper tubing during bending operations. This could have been the result of defective bending machines or defective copper material.
Hand-made benders for 14" and 20" j
radius bends of 1"c o.d. and 1-1/2"4 o.d. stainless steel tubing for the Radiation Monitoring System dams 3ed the tubing.
1.2.2 Cleanliness l
Two concerned employee.t perceived that stainless steel tubing was being contaminated by bending machines which were coated with rust, dirt, or grease as a result of the~ pipe and/or j
tubing benders.being stored in a leaky shack.
One' concern was. voiced as a suggestion to use, teflon tape on pipe fittings instead of pipe dope (lock-tite).
1.2.3 Ventinr.
l 1
1 One issue was evaluated concerning the venting methods used I
for instrumentation systems during nycrostatic testing.
The concerned individual perceived that improper venting methods adversely affected hydrotest results.
1 3.2.4 Routing One issue was evaluated relating to the incorrect routing of instrument panel drain lines in the WBN Reactor Building.
The employee perceived that a problem existed in the routing of instrument panel drain. lines. The lines were routed to a
" closed" system, but are now routed to "open" floor drains.
The " closed" system identified by the employee was a radiologically separate drainage. system designed for leakage detection.
1.2.5 Installation One concern pertaining to. instrumentation line installation identified an interference existing between an instrumentation line and a 36-inch pipe in the WBN Unit 2 South Valve Room.
The concerned employee indicated that the interference was known to exist during installation, but the decision was made to complete the installation and reroute the instrumentation line later if necessary.
l o
l l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
1070C SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 8 0F 43 1,2.5 Installation (continued)'
One BLN employee perceived a problem existed with "a Icc-of tubing rework". resulting from the frequent installation of the wrong size. tubing which was possibly caused by inadequate installation control methods. This report addresses the technical aspect of the issue. The Employee Concerns Task Group Management and. Personnel Section will address the portion of the concern dealing with inadequate control methods (see Subcategory Report Number MP71700).
2.0
SUMMARY
2.1 Summary of Issues The issues evaluated in this report involve concerns pertaining to instrumentation tubing material, tube bending, the quantity of instrumentation tubing requiring' rework, the cleanliness of stainless steel instrumentation pipe, the adequacy of venting instrumentation tubing before testing and it's effect on test result:, the routing of instrument panel drain lines in the Reactor Building, the possibility of an interference between an instrumentation line and a process pipe in the Valve Room, and the use of teflon tape as a thread sealant.
2.2 Summary of the Evaluation Process The concern evaluations were based on applicable criteria and requirements established after a review of standards, Division of:
Nuclear Engineering (DNE) specifications (upper-tier), and appilcable site procedures. Discussions were held with site personnel directly involved in the work pertaining to the concerns.
In some instances, field observations were made to determine the as-built configuration of features.
Nonconforming Reports (NCRs) were reviewed in detail to establish the history of problems in the concerns areas, as well as for any actions currently being taken to resolve problems.
Documentation records were reviewed for adequacy, as were applicable work contro111ngt documents and drawings. Quality Technology Company (QTC) files were reviewed and additional information was requested from.them to determine if specific items of concern could be identified as.
required.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 9 0F 43 2.2 Summary of the Evaluation Process (continued)
After the criteria was established, and.all available historical information was obtained, the investigation was conducted to determine if the problem the employee reported was a valid concern.
If the reported situation was substa4 iated, the concern-was concluded to be factual, whether or not a troblem existed.
If the situation the employee reported could not be found, the concern was determined to be not factual.
The Findings Section (4.0) will report if the situation presented a problem area. The Corrective Action Section (7.0) will summarize if corrective action is needed i
in addition to any actions already taken by the responsible organization (s).
2.3 Summary of Findings of the five issues investigated, the isr.ue of Bending Equipment / Material was deemed potentially generic to all active nuclear plant sites.
Evaluation at the sites concluded an implementation problem existed for the adequate control of tubing bending equipment. The review of the design output procedures applicable to the use of bending equipment determined those procedures to be in compliance with the app 1'icable codos and standards.
In summary, the issues addressing Bending Equipment /
Material are factual and require corrective action as a result of ECTG investigations.
The review also determined each site has experienced procurement problems in which " bending quality" copper tubing for instrumentation had not been ensured by the DNE contracts. ASTM B75 H-80 ("Nonbending Quality") material was supplied by vendors, but was in compliance with the specifications given in the procurement documents.
This resulted in problems encountered from non-bending quality tubing (hard) being utilized in bending operations. This was concluded to be the problem that the employee concerns referred to as " defective" material used during bending activities.
Considering the issue of cleanliness, the concerns associated with the improperly stored and rusty bending machines were valid at WBN, but not generic. Corrective action was taken by the responsible organization and was complete at the time of this investigation.
The evaluation of the third concern addressed in this issua involving the use of teflon tape as an alternative pipe thread sealant considered teflon tape to be unapproved for use at the time the evaluation was performed. As a result of further analysis, DNE issued Engineering Requirements Specification number ER-WBN-EEB-001 revision 1, which allows the use of " teflon" film tape within
l TVA EMPLOYEE CONCERNS REPORT NUMBER:
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3 PAGE 10 0F 43 l
2.3 Summary of Findings (continued) specific temperature, radiation and system application parameters.
These parameters are established in. General Construction.
l Specification G-29, Volume IV, Process Specification 4.M.1.1 and DPM-N73 M2.
For further evaluation, reference Operations SQN j
Element report number 309.01-SQN and CATD 30901-NPS-01.
The issues associated with the adequacy of venting, and the routing.
of instrumentation panel drain lines, were found to be not valid.
The Installation issue addressed a potential' conflict of an instrumentation line and piping was found to be factual. No i
corrective action was deemed necessary at this time since the installation' program addressed this type of condition and provic for a DNE evaluation of the installation.
l l
2.4 Summary of Collective Significance Collective Significance was concluded to exist generically only.in-the Bending Equipment / Material issue, as each site had experienced I
some problems with the control and storage of bending machines and the material used. This pattern of recurring problems reveals an l
area where establishment of an adequate program to control the l
storage and use of bending equipment was lacking; therefore,.
]
l l
management effectiveness is involved.
The concerns addressing the copper tubing installations were not considered to be safety-related.
The other issues had already been addressed through the existing controlling procedures and design specifications.
Consideration should be given to establishing a program to identify and correct recurring problems, perceived as either nonsafety-related or a product of defective work that will be replaced before inspection since these were concluded to be the areas where the problems had occurred and generic recognition or a corrective action program was not implemented. This is recommended' to offer a possible improvement in the early' identification of problems. The establishment of Quality Circles, which are now being instituted, and the DNQA formation of the Quality Improvement Section at each site should sufficiently. address these areas of concern, provided the proper attention is given, i
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2.5 Summary of Causes r
f The cause of the problems identified in the Bending I
Equipment / Material issue, along with the control and use of instrumentation tubing bending machines, was attributed to inadequate site programs which establish proper storage methods for
[
bending equipment and ensure that qualification of bending equipment I
is maintained.
The lack of recurring problem recognition and the l
lack of a trend analysis program perpetuated the problem areas i
identified during the concern evaluation.
I The cause of the material problems encountered was a result of inadequate DNE procurement specifications, which were not specific enough to prevent non-bending quality (ASTM B75 H80) material from 1
being supplied by vendors.
The cause of the potential contamination of stainless steel tubing in the l
cleanliness issue was due to rusty, dusty, and greasy bending machings that were improperly maintained and stored.
2.6 Summary of Corrective Action Corrective action is required at all sites for the Bending Equipment / Material issue to ensure bending operations are implementing design output requirements.
Generically, corrective actions are required by DNC and CNP to establish consistent and effective guidance to all sites by way of establishing a program to control bending equipment, including storage, and copper tubing intended for bending applications.
DNE is required to revise procurement specifications for copper tubing to clarify when bending-quality tubing is required, and to ensure no substitution is supplied unless uniquely identified.
Corporate Management has mandated changes to Cite Construction and modifications procedures to establish control requirements for qualification and storage of bending equipment.
The entire subject I
l l
of control and storage of bending equipment will be addressed as
)
part of the Specification Improvement Program.
l Corporate Management will implement a revision to the specifications v
of copper tubing on applicable drawings and bills of materials.
l Each site will be required to provide their craft personnel with I
training,in tne discrimination and use of each type of copper l
tubing.
Craft personnel will be instructed to contact their I
responsible DNC engineers when bending difficulties arise while forming bends in copper tubing.
ll il i
1
TVA EMPLOYEE CONCERNS REPORT' NUMBER:
10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 12 0F. 43 2.6 S u r.m a r y of Cerrective Action (continued)
WBN er.anged QCP-3.11-2 >>ction 7.15 to clarify ovality requirements for 1/2" d and smaller tubing.
SQN has revised SSMC 5 to detail requirements for use, handling, and qualification of tube benders, in accordance with-G-29 PS 4.M.2.3.
Bending tools will receive periodic visual inspections.
Damaged tools will be tagged as defective until verification of adequacy is determined.
]
DNC-BLN !s to revise their QCP-4.6 to more clearly state a separation between the engineer associated with the physical installation of category 1(L) tubing and the engineer performing the inspection of the tubing.
BLN will also establish a procedure to control the use of instrumentation tubing bending equipment.
l Corporate DNC will perform and document copper tubing bending tests
)
to supplement the existing test documentation to qualify the installed configurations at BLN.
The additional tests of the copper l
bending process will include the use of three different bender manufacturers (one of which must be Imperial Eastman) making sample l
bends on representative: sizes of available hard copper tubing (one of wnich must be 1/2"6
.049 wall, hard drawn (H-80) temper tubing). Quality Control inspectors will monitor the tests and provide information as to the tubings' acceptability based on.a liquid penetrant examination performed in the area of the bend for each sample. Segregation plans will be based.on the'results of the aforementioned tests.
Personnel involved with the installation of copper tubing will be trained in the process of bending hard drawn copper.
3.0
[ VALUATION PROCESS t
3.1 General Methods of Evaluation The general evaluation methodology consisted of compiling applicable standards, design specifications, drawings, and site implemented procedures. A review of requirements was undertaken to determine if the issues raised had ever been procedurally addressed.
Site NCR Logs were reviewed and potentially applicable NCR's were evaluated to determine if any previous documentation existed for the concern areas.
QTC flies were reviewed and information was requested that would be pertinent to the issues.
)
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PAGE 13 0F 43 3.1 General Methods of Evaluation (continued)
Discussions and plant observations with cognizant personnel were performed to determine the condition of the as-installed components.
Applicable work controlling documents were reviewed to determine if the issues raised were addressed and documented.
After the applicable criteria was established and all available historical information was obtained, the investigation was conducted to determine if the problem the employee reported was a factual concern.
If the situation was found, the concern was concluded to be factual, whether or not a problem existed.
If the situation the employee reported could not be substantiated, the concern was concluded to be not factual. The following section, findings (4.0),
will report if a problem existed and if the situation was factual.
Corrective action will have been determined previously through the responsible organization, or included in the Corrective Action Section (7.0) as a result of the ECTG investigations.
3.2 Requirements or Criteria Established for Individual Issues 3.2.1 Bending Eculpment/ Material General Construction Specification 'G-Spec) G-29 Process Specification (PS) 4.M.2.1, Revision 7, Addenda 1, 2, 3 and American Society of Mechanical Engineers (ASME)Section III, Division 1. Sub-section NB, NC, and ND were reviewed to determine the acceptance criteria cnd methods used to qualify bends and/or bending equipment.
1 Site procedures at WBN, BFN, SQN, ar.d BLN were reviewed to determine compliance with the above requirements.
Discussions were held with the craftsmen familiar with the particula'r benders used to fabricate the Radiation Monitorir.g System. A walkdown of this system was performed to determine the condition of the as-installed bends..
The hand-made (TVA fabricated) benders used to form the Radiation Monitoring piping were located and inspected for any obvious physical
)
damage.
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3.2.1 Bending Equipment / Material (continued)
TVA Division of Nuclear Engineering (DNE) WBN drawing series 47W600 and bill of material series 47BM600 were reviewed and discussions were held with selected WBN Division of Nuclear Construction (DNC) inspection personnel in the Instrumentation Quality Control (IQC) unit. These discussions were held to determine the material specification required by DNE and the systems where copper tubing is specified for installation.
Various aspects of the bending program were discussed and a walkdown was performed with WBN DNC Instrumentation Engineering personnel to evaluate the adequacy of bending equipment used to bend copper tubing and the adequacy of the bends produced by craftsmen.
The DNC responses to the associated concerns (which were obtained from QTC files) were reviewed.
NCR's taken from logs which appeared to be associated with instrumentation tubing bending or material problems were reviewed in detail.
From these NCP's, the scope, corrective action, and implementation was reviewed for additional relevant information.
i 3.2.2 Cleanliness DNE General Construction Specification (G-Spec) G-29, PS 1
4.M.A.1, Revision 4, was reviewed to determine the l
cleanliness requirements for austenitic stainless steel tubing.
DNE process specification 4.M.1.1, Revision 9, was reviewed to determine the requirements for removing J
l contamination. The requirements and intent of these specifications were discussed with the cognizant DNE 4
personnel.
The DNC WBN response related to the cleaning of stainless steel tubing was obtained and reviewed.
The review of the DNC WBN response addressing the use of teflon tape was evaluated.
The Engineering Requirements Specification Number ER-WBN-EEB-001 was evaluated for teflon tape application restrictions,
3 TVA EMPLOYEE CONCERNS REPORT NUMBER:
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l PAGE 15 0F 43
)
3.2.3 Venting Additional information was requested from the QTC file on this j
concern. The procedural requirements related to high point v e r.;!
in instrumentation hydrostatic tests was the area of concern.
The WBN site procedure, WBN QTC-3.13. Revision 5, was reviewed to determine the specific requirements related to venting of i
instrumentation tubing during hydrostatic testing. The complete:
documentation of the testing was reviewed to evaluate confermance to venting requirements.
I Field observations of installed instrumentation tubing were conducted to determine overall placement of high point vents.
Discussions were held with Instrumentation craft personnel to determine the position and effectiveness of hign point vents.
3.2.4 Routing A review of the TVA ONE drawings and Ehgineerint Change Notice (ECN) 1726 was required to determine the reasoning behind sealint six of the floor drains in the raceway area of the WBN Reactor Building Units 1 and 2.
A review ?f N2? 5599, ECN 5432, anc Work.lan.47 was recu;rei -
- scover wnat was done wnen ene sealec f loor crains wero inadvertently mocified, l
A field observation was conducted in the raceway area of the l
Reactor Building to verify tnat the six closed drains hac been sealed and wnat routing had been taken for the instrument panel j
drains.
I A cogni: ant WSN chemical engineer was interviewed concerning the use of open floor drains as instrument panel drains.
3.2.5 Installation The DNE WBN criteria, Construction Specification N3E-885, Revision 1, was reviewed for separation parametors.
i Instrument line isometric drawings detailing the locations for lines in the VBN Unit 2 South Valve Rooms were obtained.
l l
The responsible system engineer for the instrumentation system involved was interviewed.
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v TVA EMPLOYEE CONCERNS REPORT NUMBER:
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)
i PAGE 16 0F 43 1
3.2.5 Installation (centinued)
Documentation.was rosearched to determine time periods of installation of instrumentation lines, j
Reviewed the trend analysis at BLN to determine if improper tubint diameter installations had occurred.
Reviewed BLN site procedures BNP-QCP-4.3 and 4.6 to ensure the y
proper size of tubing was inspected and necessary inspections and l
verifications were required to detect tubing which is not installed per the latest design criteria.
l 4.0 FINDINGS 1
(
4.1 Findings on Bending Equipment / Material I
4.1.1 Generic l
Discussion i
The TVA G-29 Process Specification (PS) 4.M.2.1, Revision 7,
Addenda 1, 2, 3 for fabrication and qualification of pipe and tube bends was compared with Section III of the ASME Code, the governing requirements of Nuclear Plant Construction at WBN.
The comparison indicated agreement related to acceptance criteria and methods allowed for qualifyin6 individual bends and production bending processes.
It was l
noted that tubing 1/2"c and less is exempted in PS 4.M.2.1 from the eight percent maximum ovality allowed by ASME and is supported by CNE calculations.
The requirements of the process specification are applicable to construction at other nuclear plant sites.
I The review of the WBN site specific concerns was conducted i
l and findings were evaluated for potential Beneric j
applicability. The site procedure was determined to contain contradictory requirements and a decision to review other i
respective site procedures was made.
The site control nethods j
l for storage and use of bending equipment were determined j
inadequate and site reviews were deemed necessary.
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PAGE 17 0F 43 Discussion (continued)
Implicatier,t from concerns that " Imperial" brand hand-held benders damage copper tubing or that copper material is defective resulted from the wording of the DNE procurement contracts. The contracts did not make a distinction between "hard" ASTM B75 H80 (non-bending quality) or bending quality copper tubing, consequently, bending attempts were performed utilizing hard copper tubing which resulted in cracks or breakage of the tubing. This situation was determined to be generically applicable to other TVA sites.
It was discovered that Imperial Eastman hand held benders as shown la the manufacturers' catalog, were not listed as being acceptable for bending hard copper tubinr,.
The review of the WDN program for evaluation of the quality of installed bends revealed that an extensive evaluation had already been performed. DNE statistical analysis, along with logical reasoning, established acceptable criteria for unit I and unit 2 instrumentation tubing benos.
The results of this evaluation concluded that installed tubing bends are acceptable for their intended service.
l Conclusion l
The roview of the design output procedures cetermined these j
procedures to be adequate in the establishment of acceptance criteria and methods used to qualify bends and/or bending equipment. The subsequent review of tho site proceduros determined procedural inadequacies existed at each site.
The review of eacn site's control program for the storage and use of bending equipment concluded some weaknasses oxisted in this area also. Those occurred because the program lacked adequate controls to ensure the qualification of bending machines and the maintenance of that qualification.
The evaluations of the as-installed tubing bends at WBN formed justification for determining the quality of installed bends at other sites, since negative findings were not substantiated at WBN.
The review of the site programs determined that each site hac experienced procurement problems in which receipt of " bending quality" tubing had not been ensured by the wording of the DNE contracts specifications.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
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3 PAGE 38 0F 43 4.1.2 Site Specific 1
Discussion The findings and conclusions will be discussed for each site, a.
WBN Site procedure WBN-QCP-3.13-5, Revision 2, was unclear and requires clarification for the qualifying processes of bending operations. 'Also, the exemption' allowed.by DNE calculations for ovality of tubing 1/2"c and less is not addressed in the site procedure WBN QCP 3.11-2, i
Revision 7.
]
Discussions with Instrumentation craft ~ personnel and DNC Instrumentation Inspection personnel indicated that the i
I hand made (TVA fabricated) benders were deemed inadequate for producing quality bends.when attempts were made to l
fabricate and install a portion of the unit 2 Radiation Monitoring System tubing.
This had been'roported to the responsible engineering personnel. The bender was repaired at the machine shop and requalified to produce acceptable bonds.
Eending deficiencies were documentod.
on NCR 6276, Revision 3 and NCR 6275, Revision'2, to l
address the quality aspects of the as-installed bends in Unit 1 and Unit 2, including the Radiation Monitoring j
System.The location described in concern IN-85-740-003, describing damaged tubing, was investigated thoroughly to l
determine if damaged tubing was installed, or being stored for installation, in the Radiation Monitoring System. This investigation revealed no evidence which indicated that damaged tubing was installed or stored in this area.
It was noted that a pipe storage rack and evidence of pipe work projects were present, and the potential for tubing to have been storod at this location l
was possible.
Because of this, it was assumed that the l
concerned individual was reporting the location of stored rather than installed damaged. tubing.
Additional field observations were made with-DQA personnel to inspect Radiation Monitoring Stations for damage resulting from bending operations and the findings were consistent with the deficiencies documented on NCR's 6276. Revision 3 and 6275, Revision 2.
No indications of
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WE (continued) l cracks, buckles, grooves, wrinkles, or bulges were discovered during the observations.
Further review of NCR l
6276 revealed that an extensive evaluation of the Unit 1 and l
Unit 2 instrument pipe and tubing fabrication and l
installation program had been performed.
DNE established I
l a bend sampling program for applicable bends in Unit 1 to I
establish criteria for an acceptable level of quality.
The conditions considered affected by the inadequacies of f
control in the tubra bending program were wall thickness
]
reduction, ovality, acceptable bond contour and surface l
condition. A sampling program consisting of random j
selection of 200 bends for inspection included all l
applicable buildings and areas within the plant whore bends exist.
Results of the sampling program indicate statistical acceptance of the entire population of all i
Unit 1 instrument bonds.
Expansion of Unit 1 acceptance i
to include Unit 2 bonds was determined co be a logical pror,rossion frem existing information and data.
!nvostigation datormined initial bending processes in use durint. Unit 1 installation were generally uncontrolled by riant prococuros but 1stor procedures for the control of 4
tonnint, operations woro implementor.
- n general, a:tnour,n no rpec;'ic date exists Wnon Un:t I bencing cporations stopped and Unit 2 bonding operations c:arted, i
plant bond proceduros were in effect for Unit 2.
t Thorofore, Unit I bonding operations may be generally f
viewed as worst-case bonding operations.
!!,o same ovaluation was determitied valid for bending hardware and persennol, concluding that both Unit 1 and 'jni t 2 bonds are acceptable for their intended service.
Discussions with instrumentation inspection personnel indicated that problems had been identified in Unit ? of t
the Radiation Monitoring System relating to the improper
! ~.' ?
bond radius of 1" o.d. and 1-1/2" o.d. tubing. The I
applicable drawings specified a minimum bend radius of 20 i
inches and NCR 0797, Revision 0 and NCR 6822, Revision C, j
documented 14 inch radius installed bends for Unit 2.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
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REVISION NUMBER: !3 PAGE 20 0F 43 a.
WBE (continued)-
A review of the site program for the storage and use of bending equipment was performed by reviewing the craft control log.
Four specific hand made benders were j
indicated to be located on Elevation 729 in the Turbine j
Building.
Investigation _ revealed these benders were not at this location but had been moved during clean-up operations to an outside storage yard and subsequently
)
)
damaged.
Impilcations that " Imperial" benders damage copper tubing, or that copper tubing is defective, was l
researched. A review of the " Imperial" catalog revealed i
that hand held benders are not suited for bending hard copper tubing.
It is noted that DNC reports for the concerns for this issue were incorrect in indicating
" Imperial" hand held benders were acceptable for bending hard copper tubing. -The DNE original procurement specifications for copper tubing were inadequate by not specifying " Bending Quality" in the description given in the Bill of Materials.
"Nonbending Quality" material was supplied by vendors, but was in compliance with the' specifications givon in the procurement documents.
l There is no discernible difference in appearance between hard and soft copper.
Difficulties were. encountered during bending operations when "Nonbending Quality" material was used.
Cracks and breakage were inadvertently attributed to " bad material or benders."
l This interpretation was confirmed by DNE Codos anci Standards personnel, Subsequent purchase orders, as noted in the bill of material, are of " Bending Quality" which indicates this condition was properly corrected by DNE and JNC.
Observations made with Instrumentation Engineering and Quality Assurance personnel, and discussions with craftsmen performing bending operations, provided objective evidence that " Imperial" brand benders produced quality bonds wnen used with Bending-Quality copper tubing.
Conclusion The issue of Dending Egt.ipment/ Material, which involved perceived probicms of damage to copper tubing and
TVA EMPLOYEE CONCERNS REPORT NUMBER:
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3 PAGE 21 0F 43 Conclusion (continued) 1" o.d. and 1-1/2" o.d. stainless stoel tubing, I F:-
is valid.
I The WBN site procedure WBN-QCP 3.13-5, Revision 2, was unclear as to the qualifying process of bending operations and requires revision.
In addition, the exclusion in site proceduro WBN-QCP 3.11-2, Revision 7 of the exemption allowed by DNE for ovality of tubing 1/2"o and less may cause unwarranted inspection rejections.
(CATD 10700-WBN-01)
The concern that the TVA fabricated bonders for 14" and 20" radius bends damage Radiation Monitoring tubing wac determined to affect 1"4 o.d. and 1-1/2"4 o.d.
stainless steel tubing.
The bending deficiencies on the Rediation Monitoring System are adequately documented on NCR's 6276 Revision 3, 6275 Revision 2, 6797 Revision 0, and 6822 Revision 0, which include other unit I and unit 2 deficiencies on tubing bends. Those NCR's accurately address previous problems with. tubi.ng deficiencies, resulting from problems with bonding activities, except for addressing ir. proper bond radil on installed unit 1 Radiation Monitoring Tubing.
NCR W409-p was initiated on 05/09/86 to document this condition.
The review of the control program for the storage and use of bending equipment determined the program to be inadoquate.
Benders wore not at the locations specified in the control log and present prucedures do not specify the methods to use when bonding equipment is determined to be no longer suitable for service.
Copper tubing material specifications were reviewed and revealed that the potential existed for hard copper tubing to have been acquired and subsequently utilized in bonding attempts.
Hard copper tubing is not " bonding quality" and will break or crack when bonding attempts are made. Therefore, since no reports of copper tubing ruptures during construction hydrostatic testing or system operations have been documented, it is concluded that defective hard copper tubing material is not installed.
Copper tubing is subject to installation on non-QA (nonsafety-related) and non-essential control air systems, thereforo, providing no safety functions.
TVA EMPLOYEE CONCERNS REPORT NUMBER:
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3 PAGE 22 0F 43 Conclusion (continued) i l
l Further observation of the use of " Imperial" hand held bender:
revealed acceptable bends are produced when the proper copper tubing material is used.
The conclusions reached by DNE for NCR 6276 states that the level of quality of installed Unit 1 and 2 instrument tubing bends is acceptable.
A review of the sampling program revealed extensive inspections had been performed to establish I
criteria for an acceptable level of quality for approximately 14,991 total rends. The evaluation, except for the improper bend radii for Radiation Monitoring Tubing noted above, fully addresses the inadequacies of the instrument tube bending program and esaluates the quality of installed bends for both i
units.
b.
BFN Discussion I
The problems potentially generic to BFN as a result of the WBN review on Bend,ng Equipmont were reviewed.
l A roview of the site implemented procedures used for bendir.t operations was conducted, including the control program for I
the storage and use of benders. The potential that hard copper tubing raay have been inadvertently used in bending operations was reviewed. Corrective Action Report (CAR)85-081 had been generated questioning the qualification of a bender associated with a work plan.
Conclusion A review of the site procedure, discussions with quality assurance personnel, and review of CAR 85-081 revealed the following:
(1) no verification method was established to ensure qualified benders (suitable for the intended purpose) are selected prior to use, (2) no verification is performed which would detect damaged or defective equipment, (3) although not a design output requirement, no inventory or controls existed to detect or document where benders were used in order to identify suspect tubing should problems be encountered with a particular bender.
It is concluded that the site program i
m t
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1 PAGE 23 0F 43 i
4 I
Conclusien (continued) is inadequate to ensure the maintenance of the j
qualification ar,d control of bending machines through
{
inspection activities.
It should be noted that should a j
manufacturer change the design of a particular bender and
{
the qualification is questioned, re-qualification is mandated per design output documents (i.e., GCS G-29).
The review of drawing 47BM600 sheet 3 of 7 Revision 0 specifies tubing to be seamless copper, hard, ASTM B88 or ASTM B75.
Hard drawn (H-80) copper tubing is specified I
i in ASTM B75 and is not bending quality.
The material I
procurement specifications should be revised to add
" Bending Quality" to the material description en all future purchase requests.
f e.
521{
l
~
Discussion The probloms potentially generic to SQN as a result of the WS.',' roview on Doncing Rquipment were reviewec.
l Tho ::!o implomonted procedures for bending activities j
a Doon inacequate in that the requirements of the l
l proco:s :pecificatien were not implemented and resulted l
in issuance of CAR SQ-CAR-86-04-017, dated April 10,
- 986.
A roview of the SAR incicateo three non-compliances were documented which related to:
(1)
- otreta:!cn ef tending tools to to used exclusively on stain:ess stoel material. (2) identification of bending i
equipment, (3) process qualification records could not be located.
The corrective actions proposed by the site in response to the CAR provides explicit instructions for segregating bending equipment, but are deficient for qualifying existing benders and bending processes.
It was also determined, through discussions with Quality l
Assurance porsonnel (Modifications and Additions) and l
Gite Servicoc personnel, that no control method was in place to dotect defective bending equipment after initial qualification.
In addi*.lon, controls had not been established to ensure the proper bending tools were selected given the particular task to be performed.
(CATD 10703-SQN-02), (CATD 10703-SQN-01) l l
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i PAGE 24 0F 43 Discussion (continued)
I Discussions with site craft personnel revealed that difficulties had been encountered when bending attempts were made utilizing some copper tubing materials.
Cracking or breakage of the tubing had occurred which required the i
remake of some bends.
A review of the DNE procurement specification 47BM600 Revision 4,
sheet 8 of 73 revealed that hard copper tubing could have been acquired, and subsequently used during bending operations.
l (CATD 10703-SQN-03)
Conclusion i
The incdequacios of the site procedure had been documented on CAR SQ. CAR-86-04-017.
Additional problems with the procedure
)
orist in that no control methods have been established to j
detect damaged or defective bending equipment after qualification has boen achieved and no assurance exists to mandate that the proper bending tool is selected for its intended use.
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\\
l Procuromont Specifications for copper tubing were found inadequate in that " bending quality" tubing was not clear 2y specified by DNE.
I d.
BLN Discussion A roviow of the site implemented procecure revealed compliance with the process specification.
The scope of BNP-QCP-4.3, Revision 13, and BNP-QCP-4.6, Revision 2, are considered inadequato in that no clear distinction exists between l
ossential and nonessential tubing installation criteria.
]
Installation criteria, as established, is related to the seismic qualification of the structure where the tubing is installed rather than the importance of the tubing to nuclear safety. Further investigation determined that craft,
)
engineering, and inspection personnel were applying the respectivo criteria adequately to essential (safety-related) and nonessential (nonsafety related) tubing.
It was noted that soismic category 1(L) supports were inspected and l
documented by engineering personnel instead of QA personnel.
l (CATD 10700-BLN-01) 1 i
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REVISION NUMBER:
3 PAGE 25 0F 43 Discussion (continued)
A review of the control program for the segregation and
)
proper use of the benders was performed.
It was determined that controls were not established which would require bending equipment intended for stainless steel l
applications to be segregated, and precautions to the installer do not exist to ensure the proper bender.is selected.
(CATD 10700-BLN-02)-
Control methods'are not established to identify damaged or defective bending equipment. No recall of bending equipment'is established.for inventory or inspection purposes.
The potential exists that lost.or defective equipment may not be identified. Although not a design requirement, no controls or inventory systems are established to identify.where.a particular bender was used in order to locate _ suspect tubing should qualification of that particular bender be questioned, i
These provisions should be evaluated at the site for
)
incorporation into the control program.
A review of the perceived condition that non-bending quality tubing may have been procured and not uniquely l
identified showed copper tubing was procurred per the requirements of TVA DNE drawing SGM0900-IO-26 sheet 109 and 110 Revision 2.
As a result of the procurement specifications, hard copper tubing ASTM'B75 H-80 could i
have been acquired and'used in bending operations.
DNC j
recognized the deficiency for 1/4" e tubing and reordered bending quality tubing as a result of difficulties encountered when making bends for past installations. Additional revised material specifications for 1/2" o tubing'could not be located.
l However, craft personnel stated the material was 1
re-ordered and problems were no longer encountered.
Conclusion l
The scope of the'BLN site procedure BNP-QCP-4.3, l
Revision 13. should be revised to establish criteria to l
govern the safety-related requirements of the associated tubing, establishing a clear distinction between j
essential (safety-related) and nonessential j
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10700 SPECIAL PROGRAM REVISION NUMBER:
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PAGE 26 0F 43
)
J Conclusion (con:inued)
(nonsafety-related) tubing installation criteria.
The criteria, although considered unclear in the procedure, was properly implemented. The concept of engineering inspection for seismic category 1(L) supports is.not considered consistent with the established QA program at other sites and is questionable regarding it's adequacy.
1
(
The program review determined that the controls for the storage and use of bending equipment are inadequate.
1 Hard copper tubing may have been used, but, as a result of problems encountered, was replaced. However, BLN should investigate all copper tubing procurement specifications (specifically 1/2" $) and verify that' bending quality material is explicitly specified and utilized during bending activities.
4.2 Findings on Cleanliness 4.2.1 Generic Discussion No generic considerations were determined from investigation of this WBN specific concern.
Conclusion Non-Applicable 4.2.2 Site Specific - WBN
)
Discussion A review of the General Construction Specification G-29, PS 4.M.4,1, Revision 4 revealed surface cleanliness requirements for stainless steel tubing was adequate.
The j
specification stated that reasonable caution should be exercised to preclude the contact of any other substance other than approved materials with stainless steel.
Discussion with DNE personnel revealed contact with rust may be detrimental to stainless steel tubing. However, the condition could be corrected by the process described in G-29, PS 4.M.4.1, Revision 9, with prior DNE concurrence.
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l TVA EMPLOYEE CONCERNS EEPCET NUMBER:
- 070, SPECIAL PROGRAM j
REVISION NUMCER:
3 1
PAGE 27 0F 43 Ciscussion (centinued)
A review of the WBN DNC response indicated the concern for inadequacies of storage facilities for bending equipment and the potential for stainless steel contamination was factual.
The response stated that the benders were thoroughly cleaned before bending stainless steel. Also, the bencers have been moved to the Tucbine Building for maximum storage protection and the site procedure QCP 3.13-5 has been revised to include
)
control and storage requirenients for bendin's equipment.
The I
implication in the DNC response that stainless steel pipe would not be contaminated if it came in contact with " rusty' surfaces is considered to be in error, since imp!ngement may occur under these conditions.
It is also noted that certain critical tubing is cleaned to remove surface contaminates before the systems are transferred to operations.
l l
The review of the DNC response addressing the use of Teflon I
tape was evaluated.
Division Procedure Manual (DPM) N73M2 restricts the use of teflon tape to a maximum temperature of 300*F and a maximum radia* ion dose of 10' RADS. The procedt re also states that teflon tape is not for use on l
lines that re-enter the reactor system. The Engineering Requirements Specification Number ER-WBN-EEB-001, Revision 1,
" Instrument and Instrument Lin9 Installation and Inspection, l
reiterates DPM N73M2 restrictions for teflen tape applications.
Type TFE teflon tape is generally used in applications where the temperature is less than 400*F.
When the temperature exceeds 400*F, the physical properties begin to change, thus ellowing the possibility of leakage. Where radiation doses exceed 10' RADS. flourine is released from the tape which I
produces hydrofluoric acid.
Under certain conditions the i
acid could increase the potential for general corrosion and IR3 l
stress corrosion cracking of stainless steel.
This is l
undesirable.
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Conclusion i
J Upper-tier specifications were adequate for determining-the cleanliness requirements for stainless steel'.
The site a
procedure, due to a recent revision, is adequate to ensure proper control and storage requirements for~ bending equipment. The concern on inadequate storage facilities fo.
bending machines and the potential for contamination of stainless steel tubing was factual.
Rust was evident'on bending machines and.could have contaminated stainless steel.
q tubing through contact.
The DNC response showed action was I
completed to correct storage deficiencies and bending machines are cleaned before bending stainless steel.
I Although exception is'taken to the implication in the
]
response that stainless stoel pipe would not be contaminated if it came'in contact with " rusty" surfaces,'this does not alter the conclusion in the report.
The employee's recommendation that the use of teflon tape should be allowed is valid under certain conditions. ' Control measures are necessary and adequate to prevent problems resulting from teflon tape's use in unapproved applications.
4.3 Findings on Venting 4.3.1 Generic Discussion No generic considerations wero determined from investigation q
of this WBN specific concern.
l Conclusion l
Non-Applicable 4.3.2 Site Specific Discussion The perceived problem was that piping / tubing systems were not properly vented before' hydrostatic testing, which may have altered test results.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
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3 PAGE 29 Oi 43 Discussion (continued)
Additional information requested from QTC pertaining to this concern indicated the concern related to the' lack of tho use of high point vents during the instrumentation. hydrostatic
'I tests. WBN site procedure WBN QCT-3.13. Revision 5, was reviewed and venting' considerations were included in the requirements. A sample review of the test documentation showed specifications for venting were contained. Venting.
was provided prior to tecting in the-valve line-up in each hydro package. Venting requirements were displayed on the appropriate drawings within the test package.
Field observations indicated high point. vents were properly installed or that venting could be performed through the process piping system for the instrumentation line involved.
Discussions with instrument craft personnel substantiated j
venting was properly performed.
It was noted that some air 4
could be introduced into the system during the performance of j
the test but.this would not be detrimental to the validity of l
the test.
In certain cases, subsequent venting would.be performed during the testing to "bloed" off entrapped air.
I Conclusion This concern was not factual since reasonable assurance i
exists that adequats venting occurs as a procedural 1
requirement and specifications' exist which allow for venting before and during hydrostatic testing.
4.4 Findings on Routing 4.4.1 Generic Discussion No generic considerations were determined'from investigation of this WBN specific concern.
Conclusien Non-Applicable 4.4.2 Site Specific-WBN I
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a TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION' NUMBER:
3-PAGE 30 0F 43 i
Discussion TVA DNE ECN'5432 was reviewed for the reasoning behind-sealing of six of the Reactor Building raceway floor drains.
The ECN required that the six floor drains in the raceway'
)
that were connected to the floor drain collector header
'inside the cranewall be capped. This capping would prevent l
any water inside the cranewall from getting out into the I
raceway during a LOCA through the interconnected floor drain l
system. The capping modification provided.a " closed" system for the floor drains inside the cranewall that allowed for i
leakage detection for any leakage greater than one gallon per minute.
Instrument panel drains were routed to the capped floor drains, the caps were' drilled and the instrument drain pipes were routed'into the drilled holes. This situation l
caused the generation of NCR 5899. The capped floor drains were repaired and the panel drain lines were correctly rerouted to open floor drains in the Reactor Building raceway I
area. Walkdowns verified this routing.
Discussions with a WBN chemical enginoer revealed no radiological problem with this routing.
Cone)usion i
This concern was not factual as the instrument panel drains were correctly routed to open floor drains. The concerned individual apparently felt that the panel drains were supposed to be routed into the closed drain system. 'This war an incorrect assumption.
J 4,5 Findints on Insta11atien
)
l 4.5.1 Generic Discussion No generic considerations were determined from investigation of this concern.
Conclusion Non-Applicable r
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l TVA EMPLOYEE CONCERNS REPORT NUMBER:
1070%
3 SPECIAL PROGRAM 1
REVISION NUMBER:
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PAGE 31 0F 43 1
4.5.2 Site Specific-WBN i
Discussion j
The DNE criteria for separation distance for instrument lines, Construction Specification N3E-885, Revision 1, was reviewed for separation parameters.
Thi3 specification was intonded to provide guidance fot' the routing and separation of instrument lines to allow for process pipe movements.
including potential pipe breaks.~ Instrument isometric drawings detailing the locations of instrument lines in the Unit 2 South Valve Room were obtained. A walkdown of the i
l instrument' lines in the Valve Room was performed, using N3E-885 for a guide to indicate if a conflict with piping existed. This walkdown revealed four situations where interference, or the potential for interference, exists.
In one case, an instrument line contacted piping, and in other cases the lines potentially entered the area of piping movement from thermal or seismic response.
Documentation was researched and revealed installation.of the instrument lines took place between November, 1984 and March, 1985. An interview with the responsible system engineer revealed he was aware of all four of the potential interference problems, anc that the instrument line on contact with piping was scheduled for rerouting.
It was also learned that the DNE Pipe Rupture Team will perform a complete system by system walkdown and evaluate each potential problem area for separation ecmpliance with Specification N3E-885.
Further investigation produced a memorandum (see Attachment B) oxpressing difficulty in installing instrument lines to the criteria of N3E-885. The momorandum states the specification..
1 is not a workable document and adherence to the separation requirements is impractical if not physically impossible.
In addition, the memorandum concluded, the Unit 1 installation l
program adhered to N3E-885 very loosely, if at all, and with 1
l few exceptions the installation met the requirements of the l
DNE Pipe Rupture Team.
1 l
Conclusion
)
The concern pertaining to the issue of Installation has been i
determined to be factual.
Using the DNE criteria for separation distance for instrument lines, four potential interferences were identified during a walkdown.
I Documentation rovealed the lines were installed prior to the receipt of the employee's concern, providing credibility to I
the conclusion these interferences included the area of concern.
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TVA EMPLOYEE CONCERNS REPORT NUMBERi 10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 32 0F 43 Conclusion-(continued)
Discussions with the system engineer revealed the. conflicts were known and, except for one case, would be evaluated by the DNE Pipe Rupture Team. The referenced memorandum expressed difficulty in utilizing the DNE criteria during installation, and guestioned the need for. adherence due to Unit 1 evaluations. This may explain the concerned employee's indication that the interference was known but installation i
was continued. The reference to rerouting the line later, if j
necessary, was probably referring to the DNE evaluation.
A review of N3E-885 shows the criteria was intended to provide " goals" for separation distances to minimize rework required during the final pipe rupture field evaluation.
The specification states, in part, " failure to meet these requirements does not necessarily mean that pipe rupture i
requirements are violated.
. but... means further detailed evaluation must be made."
The specification requires a field evaluation by DNE to determine acceptability or required rework of the installations.
It is concluded that the interference exists, the interference was probably known during installation, and the I
installation program requires later evaluation of-
)
instrumentation lines, therefore, the concern is factual and no corrective action is required at this time.
4.5.3 Site Specific - BLN The concern XX-85-086-001 was specific to BLN and indicated inadequate controls methods may have resulted in tubing rework due to the frequent instillation of the wrong tubing size. This evaluation addresses the technical aspect of the concern and the remaining portion will be discussed in the ECTG Management and Personnel Subcategory Report MP71700.
This evaluation was performed utilizing two possible interpretations of the term " wrong size." The first was a strict interpretation which indicated the wrong diameter tubing may have inadvertently been installed, and consequently required removal. A review of work.ccr trolling L
documents showed that they contain installation cri 'r ia pertaining to tubing size and are considered adequa, to l
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 33 07 43 4.5.3 Site-Specific-BLN (continued) specify the proper tubing size'for installation.
Interviews conducted with craft, engineering, and inspection personnel-did not reveal deficiencies related to this interpretation.
A review of the inspection rejection trend reports supported this conclusion. The.second interpretation was that " wrong size" was referring to dimensional and/or configuration discrepancies.
Engineering and inspection personnel indicated major rework had been identified in this area..The I
cause of the rework resulted from two DNE Engineering Change Notices (ECN) Numbers 2500 and 1840, issued in 1983.
Further review of the installation procedures revealed the necessary inspections, and verifications to ensure tubing is installed per the latest design criteria, was performed.
No technical deficiency was noted since the situation resulted from changes in the design criteria.
Conclusion Tho cito specific concern at BLN was not technical.ly factual. Although rework was. encountered, no' technical problem existed since the rework resulted from a criteria change issued by'DNE.
5.0 COLLECTIVE SIGNIFICANCE 5.1 Sitnificence of Each Issue 5.1.1 Bending Equipment / Material The significance of this issue resulted from the' program inadequacies discovered during review at each plant site.
Each site had experienced some problems with'the control and storago of bending machines and tne material used. These recurring problems were perce' ved as either non-safety related or.a product of defective work that would be replaced before inspoetien. The ineffectiveness of a program to react to problems encountered, and the resulting employce.
awaroness, caused' technical deficiencies in the bending of instrumentation tubing, control of bending machines, and the material used. The communication process and organizational structure available to identify and correct recurring quality-related problems needs strengthening'so'that the technical adequacy of the nuclear facility is ensured.
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l TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 34 0F 43 5.1.2 Cleanliness l
The findings concluded that TVA had responded to the l
inadequate storage of bending machines ~and to the potential y
contamination of stainless steel. This action was completo q
and acceptable and indicates a positive response'to reported s
problem areas.
The employee's' recommendation to use teflon tape showed that-l management's effectiveness in communicating the design basis for not using teflon tape could'have'been enhanced by
'l utilizing the Employee Involvement Program to pass information on to employees explaining why
{
teflon tape was being restricted at WBN.
5.1.3 Venting i
i The findings substantiated TVA procedures and processes i
effectively addressed potential problems in this area.
l 5.1.4 Routing Instrumont panel' drains were correctly routed to open floor drains. This investigation found a problem had existed and was properly documented and corrected.
j l
5.1.5 Installation i
Although installation interferences existed. DNE's specification provided criteria to address this type of i
situation.
This specification provided as much flexibility during the construction installation as possible, while L
providing a full evaluation upon completion.
I 5.2 Collective Significance of the Subcategory' 5.2.1 Generic
]
l The significance of the issue on Bending Equipment / Material inadequacies results from the findings that each site had experienced similar problems with the control of bending I
machines and the material used, and no program is apparently in place to detect and correct this type of occurrence.- The j
concerns portaining to the copper tubing material and the existing copper tubing installations were deemed to be not safety-related.
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3 PAGE 35 0F 43 S.2.1 Generic (continued)
Significance related to the issues on Cleanliness, Venting, Routing.and Installation was that TVA had responded with effective corrective action to address these situations.
\\
6.0 CAUSE 6.1 Bending Equipment / Material The cause of the problems associated with the control and use of instrumentation tubing bending equipment resulted from inadequate site programs established to ensure proper storage, control, and qualification of the equipment.
The responsible organization is the Division of Nuclear Construction which should establish consistent and effective guidance for correction of this problem area in accordance with ONp's policy to provide centralized direction.
Recurring problem identification and trend recognition were not emphasized in each project's program.
The cause of the perceived problems associated with. defective copper tubing resulted from the attempts to bend non-bending quality copper tubing.
The procurement specification implies, by not specifically roguesting " Bending Quality," that hard-drawn tempers as specified in ASTM B75 satisfies the intention of the specifications. Tubing of this temper (H-80) is not bending quality and will break during bending operations.
6.2 Cleanliness Non-Applicable 6.3 Ventirt Non-Applicable 6.4 Routint Non-Applicable 6.5 Installation Non-Applicable
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL. PROGRAM REVISION NUMBER:
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PAGE 36 0F 43 7.0 CORRECTIVE ACTION 7.1 Corrective Action Already Taken or Planned Corrective actions established for the problems related to the i
Bending Equipment / Material and cleanliness issues are as follows:
7.1.1 Site Specific 7.1.1.1 WBN a.
The revision request prepared by Instrumentation Engineering. Unit (IEU) personnel will clarify-paragraph 6.2.6 in sito procedure QCP 3.13-5 concerning the qualifying process of bendinr.
operations.
b.
Nonconformances 6797 Revision 0, 6822 Revision 0, 6276 Revision 3 and 6175 Revision 2 were initiated-by the site to document and correct problems encountered with the control, storage, qualification of bending r.achines, the improper bond radii and quality aspects of installed tubing.
The scope of the NCRs does not adequately et.sure, however, that the improper bond radii for Radiation Monitoring System on i
Unit 1 tubing is included. As a result of the review of this condition, NCR W409-P was l
initiated on 05/09/86 to correct the Unit 1 Radiation Monitoring tubing, c.
Corrective action has been completed for the issue of cleanliness to correct storage deficiencies and the potential-for rust, dirt.
and grease contamination on bending equipment.
This included a revision to the site procedure to include control and storage requirements'for bending equipment, and relocation of bending equipment to improved storage locations.
7.1.1.2 BFN Corrective Action Report 85-081,'noted in the Bending Equipment / Material issue, was previously I
generated to identify deficiencies associated with bender qualification and adequacy of Quality Assurance / Quality Control effectiveness.
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TVA EMPLOYEE CONCERNS REPORT NUMBER: 10700 SPECIAL PROGRAM
. REVISION NUMBER:
3 PAGE 37.0F 43 7.1.1 3 SQN l
Corrective Action Report SQ-CAR-86-04-017 was previously generated in the Bonding Equipment / Material l
issue, to identify deficienclos in the site implemented procedure requirements. Corrective i
l action has been proposed by the site for CATD' 10703-SQN-01 as follows:
1.
Qualify old and now benders per P.S. 4.M.2.1, 24 color code benders to be used on stainless pipe and tubing. 3.
Remove from use all bending shoes for the defective hydraulic benders.
4.
Formally request assistance from site DNE to determine:
a.
Acceptability of corrective actions taken in accordance with CAR 86-04-017.
b.
Any additional corrective action required by DNE.
7.1.2 Generic Non-Appilcable 7.2 Corrective Action Frem CATD's 7.2.1 Site Specific 7.2.1.1 WBN a.
Finding: The Sending Equipment / Material issue
. concluded in Section 4.1.2 that the exemption allowed by.DNE calculations for ovality of tubing 1/2" $ and less is ' not addressed -in the lE3 site procedure,and may cause unwarranted.
inspection rejections.
Proposed Corrective Action:
DNC WBN to address the ovality requirements for 1/2" $ and less diameter tubing in WBN-QCP 3.11-2.
(CATD-10700-WBN-01)
WBN Line Management supplied the following as a Corrective Action Plan in response to CATD i
10700-WBN-01:
Upper-tier document TVA G-79M, l,
(PS) 4.M.2.1 exempts tubing 1/2"0 and less from ovality requirements. The site implementi ;
procedure QCP 3.11-2, Revision 7. Sectiot I.15, Note 2 reflects this in addition attacnment'B, note 7 was'added to. clarify ovality requirements on 1/2"O and smaller tubing.
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' REPORT NUMBER:
10700 SPECIAL PROGRAM l
REVISION NUMBER:
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PAGE 38 0F 43 7.2.1.2 BLN a.
Finding: The Bending Equipment / Material issue concluded in Section 4.1.2 that the scope of l
BNP-QCP-4.3 is unclear as to the criteria relating i
I to the safety-related requirements of tubing.
Also, the concept of engineering inspeotion and l
-documentation is not considered consistent with j
the established QA program at other sites.
Proposed Corrective Action:
Revise the scope of BNP-QCP 4.3 to establish a clear distinction between essential (safety-related) and I
l nonessential (nonsafety-related) tubing installation critoria.
Evaluate the adequacy of
{
origineering inspection and documentation of seismic category 1(L) supports.
(CATD 10700-BLN-01) l DLN Line Management has provided the following
)
as a corrective action for CATD 10700-BLN-01:
We do not agree that the described condition ir, a problom.
The terms "ossential" and "non-essential" deviato from the requirements of I' 4 50 D754, " Design Criteria for the Classification of Structures Systems. and Components covered by the Bellefonte Nuclear plant Quality Assurance Program".
DNE has previously instructed DNC to use the terminology
" seismic Category I" and " seismic Category I (L)"
when mak.ing reference to the classif'. cation of l
instrument tubing.
Since our procedures and.
I design documents are now consistent in the use of this terminology, we recommend the scopo of DNP-QCP 4.3 to remain as is.
The issue of I
inspection and documentation of seismic l
' Category I (L) tubing and supports was. addressed i
by Deviation Report ho D04-S-84-4112-D01.
A-separate procedure BLN QCP-4.6 was developed by BLN and approved by DNE to address the inspection and documentation requirements of seismic Category I (L) tubing and supports. The proa.edure provides for an engineering inspection and the generation of a Life.of Plant inspection record.
Drawing SGB0925-IO-57 was revised to-provide the requirement for inspecticn of those lines and supports designated Category I (L) and, at the time'specified that they would be l
inspected to QCP-4'.6.
Revision 6 of the same 4
drawing removed the reference to the QCP.
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10700 SPECIAL PROGRAM REVISION NUMBER:
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l PAGE 39 0F 43 7.2.1.2 BLN (continued) 1 Discussions with the project DNE perscnnel indicate a willingness on their behalf to accept j
an FCR to the above noted drawing to define the i
inspection requirements as currently understood.
BLN will initiate an FCR by April 15, 1987.
BLN will also revise QCP-4.6 to more clearly state a i
separation between the engineer associated with I
the physical installation and the engineer performing the inspection. The revision to QCP-4.6 shall be ecmpleted by July 15, 1987.
b.
Finding: The bencing Equipment / Material issue i
concluded in Section 4.1.2 that controls at BLN were inadequate by not requiring the segregation of bending equipment intended for stainless steel applications.
proposed Corrective Action:
DNC-BLN to l
" establish controls to ensure segregation of l
bending equipment intended for stainless steel applications and to ensure that the installer j
solects the proper bender."
(CATD 10700-DLN-02)
Line Management supplied the following corrective action in answer to CATD 10700-DLN-02:
A procedure will be established for the purpose of controlling the use of instrumentation tubing bonding equipment.
Included in this procedure will be ir.structions/ precautions to the installer, control of individual bending equipment, and Quality Control verification of compliance to the procedure. This procedure will be submitted for approval by April 1, 1987.
7.2.1.3 SQN l
a.
Finding: No control methods or QA surveillance I
activities have been established to detect damaged or defective bending equipment after l
i qualification has been achieved.
Consequently, damaged or defective bending equipment may remain undetected.
(CATD 10703-SQN-02) l l
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 I
SPECIAL PROGRAM l
REVISION NUMBER:
3 PAGE 40 0F 43 7.2.1.3 M (continued) l Proposed Correctlyn. Action: ' tine Management has i
,,. provided'Th'e7El' lowing; ma reiisio'n to SSMU-5,has
. been iss,ued.;detafiltig requir'ements f or use,
. handligg, tand.quall'ficati of
@endersin
- accordanepith'3-2hP.S.
f2.
Estd,1,r)g tools will h'ceiveheriod A.
1 -in s pe,c~t]. pas.
Damaged 'edols 'wi lle. Lett,ed Ts'"def ective until L v
: A on of adequacy is determined. Benders which cannot be proven acceptable will be destroyed.
1 7.2.2 Generic All findings addressed in this section pertain to the Bending Equipment / Material issue as noted in Section 4.1.2.
a.
Finding: Site procedures for the control and storage of bending equipment were concluded to have procedural inadequacies and/or some program wealtness.
l proposed Corrective Action:
DNC to establish consistent and offective guidance for Construction and Modifications to implomont the requirements for a program for the control I
and storage of bending equipment. This program thould establish controls to ensure the qualification of bending equipment and the maintenance of that qualification, and I
consider an inventory system to identify wnere a particular j
1 bonder was used in order to locate suspect tubing should qualification of that bender be questicned.
Establish controls to identify damaged, defective, or lost benders.
(CATD 10700-NPS-03)
Corporate Management supplied the Corrective Action Plan for CATD 10700-NPS-03 as follows:
for MODS Units: WBN MLAI-30 Revision I contains control requirements for' quellfication and storage of bending equipment. -SQN established controls which require qualification of benders and segregation as required by CATD Nos.
10703-SQN-01 and 02.
BFN MLAI-51 is being initiated to address a program for control and storage of bencing equipment. This instruction will be completed by May 1, 1987. Const Units: WBN QCP 3.13-5 Revision 4 contains program for control and storage of bending equipment. BLN will complete a QCP by June 1, 1987 for controlling and storage of bending equipment.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 1
SPECIAL PROGRAM REVISION NUMBER:
3-PAGE 41 0F 43 7.2.2 Reneric (continued) j
.In addition to the steps outlined above, the entico subject of control and storage of bonding equipment will be addressed as part of'the' Specification Improvement Program.
A technical performance procedure will be written to addrass the subject.
Estimated completion by g
November 1, 1987.
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b.
Finding:
Copper tubing is not properly segregated and-controlled to preclude misapplication as related to
)
bending quality (temper),
j Proposed Corrective Action:
DNC, CNE and ONP to review the prograr., and establish necessary controls to ensure copper tubing is proporly ser,roga, cod,.as related to bending quality (temper), and controlled.to proclude misappilcation.
(CATD 10700-NPE-02)'
/
Tn supplomont the pneumatic pepting f inktalloc tubing at Bollofonto Nuclear Plant. D/CNill rform and document additional tests of the coppe,r be in. process which will includo tho use of throe.61.fferon ender manufacturers (ono of which must be Imperi'al E an) making sample bonde on reprosontative sizes of ava ble.hard copper tubing (ono of which must be 1/2 Inc
'049 wall, hard drawn (H-60) temper tubint)f. Qua i y Control inspectors will monitor the tests andr# rov d4 nformation as to the tubings' accoptaoj11ty ba e ot ra liquid ponotrant examination perfArpbd in the/aroa of.the bend for each sample.
If tho/rgsults,aro'p.csitive,. CNC will in ure.that all craft persondel involved with the' installation of copperarepr'pdr(ytrainedintheprocessofbending o
hard drnwn c'opper an5-segr'egation will not be required.
If the results are* negative, each site will implement a program,tojegregateTheharddrawntempercoppertubing i
end insur'es(hat it is mot used for any installation other R
than straight runs. / f in fact,. segregation becomes I
i nocessary, the shoy,t' term resolution will be implemented by memorandum to the Site DNC management and to the Sito l
Diroctors..The long torm DNC solution will be provided in Instrumentation and Me-hanical Technical Performance Procedures, j
l In addition, if DNE, as a result of responding to CATD
-i 10700-NPS-004, changes the specifications for copper.
tubing on the various Bill of Material, DNC will assure j
that future purchases are.made to.the new specifications.
1 No further. action will be required by DNC as all material is' purchased to the latest revision of the applicable j
Bills of Material.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM l
REVISION NUMBER:
3 PAGE 42 0F 43 1
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c.
Finding: DNE contracts did not ensure that bending
-4"C 4*v "pper.J.uhiag " =c.uarod i
- a..,
,ye.t g ~.... -
p
/6'[O3 g g ~ O.
- ,. p. Pr;oposeti Cogr,ective 'Acttonl: p..
c DNE to review procurement speciYi'ca'tions'f6r' copper tdbTn.
Specif4 cations are to i
le.larify }f bend 4,guf
,,,,t (temper properties) is O
ide s i red.. and..J f..fs P. t D ts.
. bstitut' ion of
.....-....non-ben Ung-qu.al.ity *"hih.unlass.urtique Jidenti fica ti on is utilizec.
(CATD 10700-NPS-04) (CATD 10703-SQN-03)
Corrective action supplied by Corporate Management is as follows for CATD 10700-NPS-04: By March 13, 1987, MEB will prepare a Memorandum for R. W. Cantrell's signature regarding the specification of hard drawn and annealed copper tubing, and the requirement for revision of the cpplicable drawings and bills of materials. This memorandum will be endorsed to DNC and each Site Director with a request for them to provide their craft personnel with training in the discrimination and use of each type of copper tubing.
This CAP will answer CATD 10703-SQN-03 also.
j Evaluate the existing stock of copper tubing at each site and provide disposition of non-bending quality tubing.
d.
Finding: Nonbending quality copper tubing may have been procured and utilized in bonding operations'.
t Proposed Corrective Action:
DNC to advise er,af personnel that non-bending, quality tubing may b w!b"u'ntered and to proper a-tion to take.
(C~.
/0Q,NPS-01)
)
. f *(T. \\
\\
i supp K fdf d Carporhte "anagement',for Corrective CATD s -f g qiD sja's,f,ollows' A
cr.ft pers,onnel
'will bera(et etware' tira*t hard 4 pgr. tet@g.sey exi s t wa,
g p
a f It. heir. lo'c atl ons and pthej.have'pr bonds, thgy, prw~ 'to' no tpat11F ",resptrnsi,'o)1 emsIormi ble DNC engineer.
A memo r a n dum. w in tesyt-t 6 'Till s i t e s t o i n i t i a te a nd insure com'plianc.e'VI~tTi the craft training requirements no%abonI
l 1
I l
TVA EMPLOYEE CONCERNS REPORT NUMBER:
10700 SPECIAL PROGRAM REVISION NUMBER:
3 PAGE 43 0F 43 l
8.0 ATTACHMENTS 8 -.1 Attachment A, Subcategory Summary Table and List of Concernt I
l 8.2 Attachment B, Reference Memorandum on Installation of Instrument Linec
{
l 8.3 Attachment C, List of Concerns by Issue j
i 8.4 Attachment D, List of Evaluators I
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UNitEtt Flylla (.0% 'IP:MlWT ATTACHMD,T ~b
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CWOTdMdUM EUM: V.M.UW m m C '.
Tii M. L. Fayfielc, Freject Encir.ci.r.
...:;e L.r Et.gir.eer;ng Frc;u:t.
- -1.-
SD-F. ( )
l Guenter Wadewitz, Project Mansrar, hstts Lar
- ucicar ?.ar.t SU CCM Ft:oM JUN 2 6 886 s tllu r.cT: WATTS BAR !;UCLEAR PLANT - ROUTIN: AN SETARAT :C INST 2;".ENT L:NES !!;
THE VICINITY CF H GH ENERGY PRC:E;; F:Fil:0 INSILE l.::: CUTSICE CONTA1NMI!!T (CONOTRUCTIC:1 SPECIFICATION N?E-BB5) j An investigation into the field application of N3E-855 separt. tion i
requirements has deter ined tha, this construction specification s l
not a
- workable" docu=ent. For the cajcrity cf installations in the l
reactor building and main stea valve t'cccc, adhe: once to the separttion requirement:: is impractic:1 if net physi:cIly it;occitic.
The specification requires the use cf % ngineering judge:ent" in the l
consideration of " subsequent plausible pipe cove:ents... assu=ing the fer:ation of plastic hinges at creditie locatiens." A telecen J
vith Bobby J. Lancaster (DNE pipc rupture tec=) on Jt.ne 25, 1986, i
confirmed that NU CON field engineering personnci arc not qualified l
nor authorised to assume this re:;cncitility without further ;NE g -)
definition and instruction.
l i
l As stated in the forewcrd of the cutfect cenetructicn specifiestien,
" failure to c:eet these require:ents does mi neces:arily =ean that l
l pipe rupture requirc:ents are viciated." Due to the fact that "it is i
I not necessary that all instru=ent lines be protected frc= All.
potential pipe breaks," a DNE evaluation is required to deterr.ine the instrument lines which must be prctectec from a specific potential pipe break. Therefore, it is futile for NU COM te t.:.te=pt to install instrument lines according to the sept. ration rc:;uirc:cnts which cay not be applicable to a specific '-- -"-- * 'dne incts.11atien.
In conclusion, it should be recogni:ed that the unit 1 DNE pipe rupture fic1d evaluation performed upon completion of instru=ent line l
l installation resulted in minical rewerk. Eenerally requiring only the addition of cupperts and no pipin reverh.
The urit 1 installation program adhered to N3E-685 very acc:cly, if at all, and the recultirc installation, with very few exceptiens, not the requirements of the pipe rupture tea: evaluation.
This fact, in addition to the impracticality of NU CON adherence to the separation requirements, results in the request that DNE pipe rupture evaluation personnel assist HU CON in the initial routing of all safety related instrueent l
lines if "up-front" identification cf potential separation violations I
7 is both necessary and cost effective.
7
/
/
k kh'Ahl,.de.
('
Guenter Wadowit: /
1 I
/JHC:DLD l
4 Tc: RIMS, MR4N72 A-C R. A. Pedde. 9-169 Sh-K f.
PrinM eally nrecared by John M. Camptd ). extensj en 3468.
i
v l
l ATTACHMENT C I
List of Concerns by Issue Issuo Concerns 1.2.1 Bending Equipment / Material IN-85-707-002 IN-85-740-002 IN-85-740-003 IN-85-773-002 IN-85-831-001 1.2.2 Cleanliness WBN-86-052-001 IN-85-447-001 IN-86-289-001 l
l 1.2.3 Venting IN-85-866-002 1.2.4 Routing IN-85-532-002 1.2.5 Installation IN-85-858-001 (BLN Specific) XX-85-086-001 l
l i
I l
l L________
4 4
ATTACHMENT D l
LIST OF EVALUATORS l
Margaret E. Selweski, WBN Henry W. Loftis, WBN, SQN, BFN, and BLN
. _ _ _ _ _ _