ML20154D253

Insp Repts 50-327/85-49 & 50-328/85-49 on 851216-20. Violation Noted:Deviations from Documented Requirements Found on Four Seismically Designed Pipe Supports

ML20154D253
Person / Time
Site:	Sequoyah
Issue date:	01/15/1986
From:	Blake J, Liu W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20154D235	List: IR 05000327/1985049 ML20154D230 ML20154D243
References
50-327-85-49, 50-328-85-49, NUDOCS 8603050558
Download: ML20154D253 (12)

See also: IR 05000327/1985049

Text

. .

- .

o UNITED STATES

[Am K8c ,o,*

NUCLEAR REGULATORY COMMISSION

%' 's r . REGION 11

h.I

,b. I

g

101 MARIETTA STREET. N.W.

ATLANTA,GEORGl A 30323

s, m ,.

....+ ,

Report Nos.: 50-327/85-49 and 50-328/85-49

Licensee: Tennessee Valley Authority

6N11 B Missionary Ridge Place

1101 Market Street

Chattanooga, TN 37402-2801

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah 1 and 2

Inspection C ,

.

-

.c mber 16-20, 1985

Inspect r. _.

6

W. Date Signed

Approved by: / f Id

J. J. FI Ke, Section Chief 'Date Signed

.ginfering Branch

,

ivision of Reactor Safety

SUMMARY

! Scope: This routine, unannounced inspection involved 36 inspector-hours on site

! in the areas of licensee actions on previous enforcement matters pertaining to

safety-related cable tray support systems, and safety related pipe support and

restraint systems.

Results: One violation was identified - Inspection and installation problems for

seismically designed pipe supports, paragraph 5.b.

J

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8603050558 060206

PDR

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O ADOCK 05000327

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• P. Wallace, Plant Manager

• H. Rankin, Manager, Design Services

• J. Vineyard, Project Manager, Office of Engineering (0E)

• G. Kirk, Compliance Supervisor

'

• R. Olson, Modification Manager

'

• B. Patter (on, Mainten'ance Superintendent

• S. Cowart, Quality Surveillance Supervisor

• G. Boles, Mechanical Maintenance Supervisor

• C. Johnson, Civil Project Engineer, OE

• D. Craven, QA Staff Supervisor

• R. Birchell, Mechanical Engineer, Compliance

L. Katcham, Civil Engineer, OE

'

Other licensee employees contacted included QC inspectors, craftsmen,

engineers, technicians, security force members, and of fice personnel.

NRC Resident Inspector

• N. Jenison, Senior Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on December 20, 1985, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings listed

below. No dissenting comments were received from the licensee.

(0 pen) Violation 327, 328/85-49-01, Inspection and installation problems for l

seismically designed pipe supports, paragraph 5.b.

(0 pen) Inspector Followup Item 327, 328/85-49-02, Determination of locking

devices for support installations, paragraph 6.a.

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

' l

!

a. (Closed) Violation 327, 328/85-29-01, Inadequate design controls for i

seismically designed cable tray supports. TVA's letter of response ,

dated November 25, 1985, has been reviewed and determined to be '

,

'

_ .. -- ._ _ - - - _

_ ._ _-. ~ . - - _ - - _ - -- - ..- .

. .

,

.. , .

<

2

.

acceptable by Region II. 'The inspector held discussions with ,

i licensee's representatives and examined the corrective actions as

) stated in the letter of response. '

i The inspector concluded that TVA had determined the full extent of the

subject violation, performed the necessary survey and followup actions

to correct the present conditions and developed the necessary

, corrective actions to preclude recurrence of similar circumstances.

The corrective actions identified in the letter of response have been

i implemented,

t

'

b. (Closed) Violation 327, 328/85-29-02, Inadequate design control for

, safety-related cable tray support baseplate installations. TVA's

'

letter of response dated November 25, 1985, has been reviewed and

determined to be acceptable by Region II. The inspector held

i discussions with licensee's representatives and examined the corrective

3

'

actions as stated in the letter of response. The inspector concluded

that TVA had determined the full extent of the subject violation,

i performed the necessary survey and followup actions to correct the

<

present conditions and developed the necessary corrective actions to

preclude recurrence of similar circumstances. The corrective actions

j

'

identified in the letter of response have been implemented.

1

4. Unresolved Items

j Unresolved items were not identified during the inspection.

l

j 5. Safety-Related Pipe Support and Restraint Systems

>

a. Review of Work Procedures and Design Documents

The inspector reviewed portions of the following inspection procedures

i and design documents pertaining to safety-related pipe support and

,

restraint systems to determine whether they comply with NRC

i requirements and the licensee's commitments.

1

-

SNP Instruction No. 66, Inspection of Supports, March 1, 1983

i

-

Modifications and Additions Instruction M&AI-9, Inspection of

Bolted Connections, July 5, 1983

1

1 -

Pipe Support Design Manual, Volume 4, Manufacturer's Catalog

Information, April 22, 1983

.

-

] SQN-DC-V-13.3, Detailed Analysis of Category I Piping Systems,

August 13, 1984

l

.

I

O

i

4

i s.

. .

,

.. .

~

3

.

b. Field Inspection of Pipe Sup' ports and Baseplates

The following pipe supports including baseplates were partially

inspected to determine whether they were properly installed and

inspected in accordance with established procedures.

Support Number Piping System

• 1-AFDH-244, Rev. 7 Auxiliary Feedwater

• 1-AFDH-254. Rev. 6 Auxiliary Feedwater

• 1-AFDH-411, Rev. 1 Auxiliary Feedwater

'

• 2-SIH-444A, Rev. 1 -

Safety Injection

1-ERCWH-515, Rev. 3 Essential Raw Cooling Water

• • 1-FS-040, Rev. 4 Fire Suppression

• • 1-FS-045, Rev. 7 Fire Suppression

e

'

• • 1-47A059-14 Rev. O Chilled Water Supply

, ** Indicate discrepancies identified during the inspection.

• • Indicates dead-load supports attached to seismic Class I structures.

The above pipe supports, in general, were installed in accordance with

design documents with the exception of the supports identified below:

(1) Support No. 1-AF0H-244 Rev. 7, pipe clamp bolt on the snubber

side was loose.

(2) Support No. 1-AFDH-254, Rev. 6, jam nut on the structural

attachment side of the sway strut was loose.

(3) Support No. 1-AFDH-411, Rev. 1, item 2 of the vertical rod was

bent.

(4) Support No. 2-SIH-444A, Rev.1, one of the two vertical trapeze

rods was disconnected.

(5) Support No. 1-47A059-14, one of the two vertical trapeze rods was

broken.

(6) Support No. 1-FS-040, Rev. 4, jam nut was loose. i

(7) Support No. 1-FS-045, Rev I

7, jam nut was loose. '

The above items (1), (2), (3) and (4) are seismically designed l

supports; (5), (6) and (7) ate dead-load supports that are attached to i

seismic Class I structures. SNP Inspection Instruction No. 66, '

inspection of supports, requires that installation conforms to

.. _ .-.

. .

,

.. . .

'

4

I

applicable drawings and that all bolts are properly engaged and

tightened. 10 CFR 50, Appendix B, Criterion V, requires that

activities affecting quality shall .be prescribed by documented .

'

instructions, procedures and drawings, and shall be accomplished in

accordance with these instructions, procedures and drawings. Results

of the field inspections indicate that portions of the aforementioned

pipe supports failed to satisfy the licensee's instructions and the NRC

requirements. As a result, these supports may not be able to perform

their intended function as required by the design. This matter is

,

identified as Violation 327, 328/85-49-01, Inspection and installation

'

problems for seismically designated pipe supports.

Within the areas inspected, one violation was identified. -

o .

6. Technical Discussions -

l

a. Locking Device

During the inspection, the inspector noted that many of the installed

threaded fasteners that were utilized in the support installations

'

showed no locking devices. Where pipe clamps were used for snubber or

sway strut connections, only a single nut was installed. The inspector  ;

reviewed volume 4 of the Sequoyah Pipe Support Design Manual. It was '

found that a special instruction was noted on the manufacturer's

I drawing for standard pipe clamps. This special instruction requires

j that all hex nuts be replaced with two jamnuts for nuclear use. The

i second jamnut serves only as a locking device. The inspector held

l discussions with licensee's representatives regarding the above

l concerns. The inspector noted that the office of engineering had not

I informed the maintenance / modification group that a locking device

l should have been used in the support installations. Pending resolution

I with respect to the above concerns between the office of engineering

l and the maintenance / modification group, this matter is identified as

Inspector Fo.;owup Item 327, 328/85-49-02, Determination of locking l

devices for support installations.

)

b. Bolted Connections for Supports  !

The inspector reviewed Modifications and Additions Instruction M&Al-9,

inspection of bolted connections, paragraph 8.0 of the instruction

,

'

,

states that bolts with washers shall show no visible evidence of slack

l and the bolt shall be verified to be, as a minimum, handtight. There

is no definition given as to what the HANOTIGHT physically means in

,

terms of installation and inspection requirements. The inspector held

l discussions with two QC inspectors and two maintenance / modification

engineers regarding the physical meaning of HANDTIGHT. None of the

l above personnel understood the meaning of HANDTIGHT requirements. This

l indicates that the procedure shows a lack of understanding by the

personnel who are responsible for implementing quality work activities.

Within the areas inspected, no vi.olations or deviations were identified.

l

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ __

_ _ _ . - - _ -

_ _ _ _ _ _ _ _ __ __ _ _ . . - _ _ . _ _

u  :

) .

Tennessee Valley Authority

i ATTN: Mr. Steven A. White

'

Manager of Power and

Engineering (Nuclear)

6N38 A Lookout Place

.

1101 Market Street

Chattanooga, TN 37402-2801

]

I Gentlemen:

SUBJECT: REPORT NOS. 50-327/85-49 AND 50-328/85-49

On December 16-20, 1985, NRC inspected activities authorized by NRC Operating

License Nos. DPR-77 and DPR-79 for your Sequoyah facility. At the conclusion of

i the inspection, the findings were discussed with those members of your staff

identified in the enclosed inspection report.

,

'

Areas examined during the inspection are identified in the report. Within these

areas, the inspection consisted of selective examinations of procedures and

representative records, interviews with personnel, and observation of activities

in progress.

]

4

The inspection findings indicate that certain activities violated NRC require-

ments. The violations, references to pertinent requirements, and elements to be '

included in your response are presented in the enclosed Notice of Violation.

The responses directed by this letter and the enclosures are not subject to the

clearance proceduret of the Office of Management and Budget issued under the

j

Paperwork Reduction Act of 1980, PL 96-511.  !

,

j Should you have any questions concerning this letter, please contact us.

) Sincerely,

I

John A. Olshinski

Deputy Regional Administrator for TVA

I En:losures: (See page 2)

I

l

!

l

1

.

_ .- _. - - _ _ _ . - _.- . ,_

i :

Tennessee Valley Authority 2

'

Enclosures:

i

1. Notice of Violation .

2. Inspection Report Nos. 50-327/85-49

and 50-328/85-49

cc w/encls:

H. L. Abercrombie, Sequoyah Nuclear Plant

Site Director

P. R. Wallace, Plant Manager

, K. W. Whitt, Chief, Nuclear

t

Safety Review Staff

i D. L. Williams, Jr., Supervisor

Licensing Section

'

G. B. Kirk, Compliance Staff Supervisor r

. J. E. Wills, Project Engineer

4 bec w/encis:

'

l Document Control Desk

State of Tennessee

bec w/ enc 1:

i J. N. Grace

H. R. Denton, NRR

H. L. Thompson, NRR

l J. M. Taylor, IE

,

B. B. Hayes, 01  ;

] NRC Resident Inspector '

1

1

l

!

!

l

l

4

! RII RI! RII RII RII

WLiu:bhg JBlake AHerdt AGibson DVerrelli

1/ /86 1/ /86 1/ /86 1/ /86 1/ /86

!

i

.

UNITED STATES

[4080o 'o,'

NUCLE AR REGULATORY COMMISSION

%' ' RE GION ll

E ** O

101 MARIETTA STREET.N.W.

ATLANTA, GEORGI A 30323

gv**.../

Report Nos.: 50-327/85-49 and 50-328/85-49

Licensee: Tennessee Valley Authority

6N11 B Missionary Ridge Place

1101 Market Street

Chattanooga, TN 37402-2801

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah 1 and 2

Inspection Conducted: December 16-20, 1985

Inspector: __

W. C. Liu Date Signed

Approved by:

J. J. Blake, Section Chief Date Signed

Engineering Brarch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection involved 36 inspector-hours on site

in the areas of licensee actions on previous enforcement matters pertaining to

safety-related cable tray support systems, and safety-related pipe support and

restraint systems.

Results: One violation was identified - Inspection and installation problems for

seismically designed pipe supports, paragraph 5.b.

y

- _ - _-. . .__- - -- _-. - -- _ . - -

. .

.

i

'

REPORT DETAILS

i

l 1. Persons Contacted

Licensee Employees

• P. Wallace, Plant Manager

• H. Rankin, Manager, Design Services ,

i *J. Vineyard, Project Manager, Office of Engineering (OE)

• G. Kirk, Compliance Supervisor '

• R. Olson, Modification Manager  ;

• B. Patterson, Maintenance Superintendent

• S. Cowart, Quality Surveillance Supervisor .

,

• G. Boles, Mechanical Maintenance Supervisor

i

• C. Johnson, Civil Project Engineer, OE

j *D. Craven, QA Staff Supervisor

*R. Birchell, Mechanical Engineer, Compliance

i

L. Katcham, Civil Engineer, OE  :

1 Other licensee employees contacted included QC inspectors, craf tsmen,  !

engineers, technicians, security force members, and office personnel.  !

1 l

l NRC Resident Inspector i

I

j *K. Jenison, Senior Resident Inspector

2

1

1 * Attended exit interview ,

1

1 2. Exit Interview

!

! The inspection scope and findings were summarized on December 20, 1985, with

, those persons indicated in paragraph 1 above. The inspector described the

i areas inspected and discussed in detail the inspection findings listed

! below. No dissenting comments were received from the licensee.

4

(0 pen) Violation 327,328/85-49-01, Inspection and installation problems for  ;

! seismically designed pipe supports, paragraph 5.b. ,

l

(0 pen) Inspector Followup Item 327, 328/85-49-02, Determination of locking i

l devices for support installations, paragraph 6.a.

The licensee did not identify as proprietary any of the materials provided

j to or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

a. (Closed) Violation 327, 328/85-29-01, Inadequate design controls for

, seismically designed cable tray supports. TVA's letter of response

,

dated November 25, 1985, has been reviewed and determined to be

,

d

. _ _ - - -- __ . - . _ - - - - . _ - . . _ - . -_ . -

. .

.

2

acceptable by Region II. The inspector held discussions with

I licensee's representatives and examined the corrective actions as

stated in the letter of response,

i

The inspector concluded that TVA had determined the full extent of the

'

subject violation, performed the necessary survey and followup actions

l to correct the present conditions and developed the necessary

corrective actions to preclude recurrence of similar circumstances.

The corrective actions identified in the letter of response have been

I implemented,

b. (Closed) Violation 327, 328/85-29-02, Inadequate design control for

safety-related cable tray support baseplate installations. TVA's

letter of response dated November 25, 1985, has been reviewed and

I determined to be acceptable by Region II. The inspector held I

discussions with licensee's representatives and examined the corrective

actions as stated in the letter of rt:sponse. The inspector concluded

that TVA had determined the full extent of the subject violation. l

'

performed the necessary survey and followup actions to correct the

present conditions and developed the necessary corrective actions to

preclude recurrence of similar circumstances. The corrective actions

identified in the letter of response have been implemented.

4. Unresolved Items  !

Unresolved items were not identified during the inspection.

5. Safety-Related Pipe Support and Restraint Systems

a. Review of Work Procedures and Design Documents

The inspector reviewed portions of the following inspection procedures

and design documents pertaining to safety-related pipe support and  !

restraint systems to determine whether they comply with NRC -

requirements and the licensee's conmitments. {

1

-

SNP Instruction No. 66 Inspection of Supports, March 1, 1983  !

-

Modifications and Additions Instruction M&AI-9, Inspection of

Bolted Connections, July 5, 1983

-

Pipe Support Design Manual, Volume 4 Manufacturer's Catalog

Information, April 22, 1983 ,

-

SQN-DC-V-13.3, Detailed Analysis of Category I Piping Systems, l

August 13, 1984

i

.-. - -. -- . - . _ _ _ _ . . _ . . _ _ - . . _ - .

.

!

l 3

l

!

l b. Field Inspection of Pipe Supports and Baseplates

The following pipe supports including baseplates were partially

inspected to determine whether they were properly installed and

inspected in accordance with established procedures,

j Support Number Piping System

• 1-AFDH-244, Rev. 7 Auxiliary Feedwater

• 1-AFDH-254, Rev. 6 Auxiliary Feedwater  ;

'

• 1-AFDH-411 Rev. 1 Auxiliary Feedwater

• 2-S!H-444A, Rev. 1 Safety Injection

1-ERCWH-515, Rev. 3 Essential Raw Cooling Water

• • 1-FS-Od9,Rev.4 Fire Suppression

1. • 1-FS-045, Rev. 7 Fire Suppression

• • 1-47A059-14, Rev. O Chilled Water Supply

, ** Indicate discrepancies identified during the inspection.

• • Indicates dead-load supports attached to seismic Class 1 structures.

The above pipe supports, in general, were installed in accordance with

design documents with the exception of the supports identified below:

(1) Support No.1-AFDH-244, Rev. 7, pipe clamp bolt on the snubber

side was loose.

(2) Support No. 1-AFDH-254, Rev. 6 Jam nut on the structural

attachment side of the sway strut was loose.

(3) Support No.1-AFDH-411, Rev.1, item 2 of the vertical rod was ,

bent. l

!

(4) Support No. 2-SIH-444A, Rev.1, one of the two vertical trapeze ,

rods was disconnected. j

!

(5) Support No. 1-47A059-14, one of the two vertical trapeze rods was  !

broken. l

(6) Support No. 1-FS-040, Rev. 4, Jam nut was loose.

(7) Support No. 1-FS-045, Rev. 7. jam nut was loose.

The above items (1), (2), (3) and (4) are seismically designed

supports (5), (6) and (7) are dead-load supports that are attached to

seismic Class 1 structures. SNP Inspection Instruction No. 66,

inspection of supports, requires that installation conforms to  ;

I

- -

4

applicable drawings and that all aolts are properly engaged and

tightened. 10 CFR 50, Appendix B, Criterion V, requires tha t

activities affecting quality shall be prescribed by documented

instructions, procedures and drawings, and shall be accomplished in

accordance with these instructions, procedures and drawings. Results

of the field inspections indicate that portions of the aforementioned

pipe supports failed to satisfy the licensee's instructions and the NRC

requirements. As a result, these supports may not be able to perform

their intended function as required by the design. This matter is

identified as Violation 327, 328/85-49-01, Inspection and installation

problems for seismically designated pipe supports.

Within the areas inspected, one violation was identified.

6. Technical Discussions

a. Locking Device

During the inspection, the inspector noted that many of the installed

threaded fasteners that were utilized in the support installations

showed no locking devices. Where pipe clamps were used for snubber or

sway strut connections, only a single nut was installed. The inspector

reviewed volume 4 of the Sequoyah Pipe Support Design Manual. It was

found that a special instruction was noted on the manufacturer's

drawing for standard pipe clamps. This special instruction requires

that all hex nuts be replaced with two jamnuts for nuclear use. The

second jamnut serves only as a locking device. The inspector held

discussions with licensee's representatives regarding the above

concerns. The inspector noted that the office of engineering had not

informed the maintenance / modification group that a locking device

should have been used in the support installations. Pending resolution

with respect to the above concerns between the office of engineering

and the maintenance / modification group, this matter is identified as

Inspector Followup Item 327, 328/85-49-02, Determination of locking

devices for support installations.

b. Bolted Connections for Supports

The inspector reviewed Fodifications and Additions Instruction M&AI-9,

inspection of bolted co.,nections, paragraph 8.0 of the instruction

states that bolts with washers shall show no visible evidence of slack

dnd the bolt shall be verified to be, as a minimum, handtight. There

is no definition given as to what the HANDTIGHT physically means in

terms of installation and inspection requirements. The inspector held

discussions with two QC inspectors and two maintenance / modification

engineers regarding the physical meaning of HANDTIGHT. None of the

above personnel understood the meaning of HANDTIGHT requirements. This

indicates that the procedure shows a lack of understanding by the

personnel who are responsible for implementing quality work activities.

Within the areas inspected, no violations or deviations were identified.