ML20215C356

Rev 2 to Hanger Insp Documentation

ML20215C356
Person / Time
Site:	Sequoyah
Issue date:	12/05/1986
From:	Chesney J, Owen D TENNESSEE VALLEY AUTHORITY
To:
Shared Package
ML20215C295	List: ML20215C292 ML20215C356 ML20215C394 ML20215C407 ML20215C432 ML20215C447
References
CO11106-SQN, CO11106-SQN-R02, CO11106-SQN-R2, NUDOCS 8612150111
Download: ML20215C356 (8)

Text

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, .4 IVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAN REPORT TYPE: Sequoyah Nuclear Plant Element REVISION NUMBER: 2 TITLE: Hanger Inspection Documentation PAGE 1 0F 6 REASON FOR REVISION:

Revised to incorporate Senior Review Panel and Technical Assistance Staff coments and add concern XX-85-053-001. Revision 1 l

Revised to incorporate Senior Review Panel coments. Revision 2 PREPARATION PREPARED BY:

YA W /2/Skb SIGNATURE TATE l REVIEWS PEER:

M4O w (2_. f-OG SIgMATURE DATE i TAS:

1 SIGNATURE DATE CONCURRENCES CEG- 1 14' I L O f lI h 17 SIGNATURE DATE SIGNATURE

• DATE APPROVED BY:

N/A ECSP MANAGER DATE MANAGER OF NUCLEAR POWER DATE CONCURRENCE (FINAL REPORT ONLY)

• SRP secretary's sl6 nature indicates that SRP files contain documentation of full panel concurrence.

2452T B612150111 861205 PDR ADOCK 05000327 P PDR

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. , i TVA EMPLOYEE CONCERNS REPORT NUMBER: C0ll106-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 2 0F 6 I. INTRODUCTION This report addresses two concerns (XX-85-053-002 and XX-85-053-001) dealing with engineering evaluations on conduit and pipe supports.

This concern is specific to Sequoyah Nuclear Plant (SQN).

II.

SUMMARY

OF PERCEIVED PROBLEM The perceived problems addressed by this report is that engineering evaluations were not performed properly on pipe and conduit supports.

The hardware was not always examined prior to the evaluation. Cases of missing documentation were evaluated away, where 10 percent of the documentation was not found, inspections test were only 4

re-done to the extent necessary to reach 10 percent. The timeframe for this was from 1978 to 1980.

III. EVALUATION METHODOLOGY The evaluation methodology used for this alement was:

A. Reviewed NSRS Investigation Reports I-85-695-SQN and I-85-709-SQN which address the subject concern.

B. The following site procedures were reviewed:

1. Tennessee Valley Authority Sequoyah Nuclear Plant S0P Number 551, Revision 3

2. SNP-Construction Procedure Number P-24 Revisions 1, 2, 3, and 4. " Inspection and Test Status,"

3. SNP-Construction Procedure Number P-8, Revision 13. " Quality Assurance Records" C. Reviewed hanger General Notes and hanger typical drawings.

D. Reviewed documentation for engineering evaluations on pipe supports and conduit supports.

E. Interviewed six individuals involved with engineering evaluations in the subject time frame. (Four Construction engineers, two Quality Control inspectors)

TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAM REVISION NUMBER: 2 PAGE 3 0F 6 IV.

SUMMARY

OF FINDINGS A. The review of NSRS Investigation Reports I-85-695-SQN and I-85-709-SQN revealed that in the subject timeframe construction management revised procedures and instructions to utilize various computer programs as a method of indicating inspection, test, and operating status of plant features.

This allowed engineering evaluations to be performed on inspections completed under previous procedures. These evaluations were based on the guidelines in Standard Operating Procedure (SOP) Number 551, "Past Records Review and Engineering Evaluations."

B. It was determined by reviewing site procedures for the subject timeframe:

1. In 1977 the SQN procedures and instructions were revised to utilize computer programs as the methods of indicating inspection, test, and operating status of plant features.

2. SNP Construction Procedure No. P-8, " Quality Assurance Records" Revision 13, required features that had been completed and inspected by previous procedures to be evaluated in terms of current inspection instructions. Where equivalent activities were performed the responsible engineering unit was to provide written juctification to indicate satisfactory completion of the requirements. When current requirements differed from those in effect at the time of installation the feature was to be evaluated to determined its acceptability. Where evidence of satisfactory acceptance could be shown it was to be documented. When insufficient evidence existed the feature in question was to be noted as nonconforming.

3. Sequoyah Nuclear Plant S0P No. 551 revision 3 " Review of Past Records" addrerses engineering evaluations. This procedure was initially isa'ied in 1977 and sites three basic methods of performing engince ing evaluations.

a. Evaluation and acceptance of existing record - requires a written, signed evaluation attachment to record.

b. Perform a reinspection and new documentation

c. When a. or b. above will not satisfy requirements, an nonconformance Report (NCR) will be generated.

Revision 2 of this SOP was issued 11/28/78 this revision added a policy statement as attachment" F." This policy statement is shown below.

TVA EMPIhYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 4 0F 6 POLICY STATEMENT Structural Welds Structural welding on miscellaneous steel, protective devices, rapture restraints, and hangers and suppcets has been inspected and documented through the use of individual inspection records, log entcies, notation on the item, and notation on the drawings.

These records are not traceable to specific features or weld joints ,

in all cases as required by the present program and in cases where documentation was not prepared, the record has been obliterated by subsequent painting. The program in effect at that time required verification of welding inspection before painting.

In order to assure the required quality, such welds will be identified in lots and representative samples reinspected for fillet size, length and general appearance. The required II-75 inspections can then be satisfied by the methods described in SNP CP No. I-24.

Expansion Anchors Some anchors are not traceable to a lot. Where this condition exists, areas may be divided into lots, total number of anchors counted, and compared to the records of anchors tested in that area.

If the records show 10% or more of the total anchors have been tested, this is considered satisfactory. If less than 10% of the total was tested, then additional tests should be performed to achieve the 10% minimum.

C. It was found by reviewing the Hanger General Notes and the hanger typical drawings that some supports with bolt anchor installations could have the bolt anchors deleted and be welded. Drawings 47A056-40A, Revision 0, 47A056-3, Revision 0, and 47A053-150, Revision 0 are examples of this type of optional installation.

D. It was found by reviewing the documentation on engineering evaluations for 20 pipe supports and 20 conduit supports in the subject timeframe, that the following was used:

1. The evaluation was based on past documentation. The past documentation meets current requirements. In these cases the past documentation was with the evaluation attachment.

i

TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 5 0F 6

2. The evaluation was based on past documentation. The past documentation does not meet current requirements but is acceptable and satisfies licensing commitments. In these cases the past documentation was with the evaluation attachment.

3. The evaluation attachment contained a statement that indicated the basis for the evaluation was the policy statement on attachment F of S0P Number 551, or referenced a memorandum that was attached. This memorandum contained a statement similar to this policy statement in S0P 551. Past documentation was not always with these evaluations.

E. It was learned from the interviews that in the subject timeframe a group was formed at SQN that routinely performed engineering evaluations according to the procedures. Some of these evaluations were made for anchor installations as shown in C-3 above. These evaluations were made without visual examination of the hanger and examination of the hardware was not required.

CONCLUSION Since this evaluation addressed more than one perceived problem below is a list of perceived problems and findings.

Perceived Problem

1. Engineering evaluation were not performed properly on pipe and conduit supports, the hardware was not always examined.

Finding Engineering evaluations were done in accordance with site procedures. These evaluations were done to verify that the lR2 necessary inspections had been performed. Therefore this is l not a problem.

Perceived Problem

2. Cases of missing documentation were evaluated away, where 10 percent of the documentation was not found, inspections / test were only re-done to the extent necessary to reach 10 percent.

4 TVA EMPLOYEE CONCERNS REPORT NUMBER: C011106-SQN SPECIAL PROGRAN REVISION NUMBER: 2 PAGE 6 0F 6 Finding Evaluations were done for bolt anchor inspections where the anchors were not traceable to a lot based on records showing 10% of the anchors in the area being tested. If less than 10% of the total was tested, then additional tests were performed to achieve the 10% minimum. This was done in accordance with the policy statement in SOP-551 or a similar statement in a memorandum, similar evaluations were used for welds. The adequacy of these evaluations needs to be addressed by line management.

V. ROOT CAUSE Failure to implement a program to adequately control engineering evaluations.

VI. CORRECTIVE ACTION To be provided by line management. CATD l'1106-SQN-01, Revision 1 VII. GENERIC APPLICABILITY Based on the fact that the concerns addressed by this report is site specific and the evaluation identified that this occurred during program changes at SQN that were unique to SQN, there is no generic applicability.

VIII. ATTACHMENTS Attachment A - List of Concerns

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. Attechment A C011100-SQN-R1 CATEGORY: PROCESS & OUTPUT SUBCATEGO'Y: R 11100 '

SUPPORT AS-BUILT DOCUMENTATION S GENERIC CONCERN H

SUB R PLT APPL QTC/NSRS PI BB3W INVESTIGATION S CONCERN NUMBER CAT ;b CAT D LOC FLQB REPORT R DESCRIPTIDH XX -E5-053-002 CO- 11100 N SQti N N Y N- I-85-639-SQN T50164 REPORT NO SEQUDYAH- ENGINEERING EVALUATIONS F0 DESIGN REVIEW J'- -. R DOCUMENTATION MISSING ON PIPE SUPP HONCONFORMANCE

- (./. i ' "

ORTS AND CONDUITS SUPPORTS HAS NOT A LHAYS DONE PROPERLYs SOMETIMES THE HVAC REPORTS HARDWARE HAS NOT EXAMINED BEFORE THE

• EVALUATION HAS MADE. EG IN ONE CAS ,

E, THE HRC FOUND A HANGER DOCUMENTED AS BOLTED, BUT IT HAS ACTUALLY HELD ED. (CI HAS NO MORE INFORMATION) UN

~

- IT I- 1978 TO 1980 C0!!STRUCTION/ENGI -

~ NEERINO - AUX, CONTROL & DIESEL GEN XX 053-001 _' BUILDINGS. NO FOLLOHUP REQUIRED. - -

11100 N SQN CO N. NY y I-85-709-SQN T50167 ~ K-FORM SS SEQUDYAH- DOCUMENTATION SAMPLING PLA RECORDS N FOR PIPE SUPPORTS AND CONDUIT SUPP PROCEDURES ORTS /HAS INADEQUATE: PLAN ALLOWED A OPERATIONS CCEPTING SYSTEMS WITH ONLY 10% OF TH SUPPORTS ELECT E ORIGINALLY REQUIRED DOCUMENTATION.

CASES OF MISSING DOCUMENTATION HER

~~

E." EVALUATED" AHAY. IN CASES HHERE 10% OF THE DOCUMENTATION HAS NOT FOU

- ND, INSPECTIONS / TESTS HERE ONLY RE-D <

ONE 10%.TO THE EXTENT NECESSARY TO REACH .

THE CI DOES NOT BELIEVE THIS NAS ADEQUATE, AND MIGHT NOT HAVE MET i NRC REQUIREMENTS.

, , , , 1980. CONSTRUCTION(UNIT 1- 1978 ENGINEERING TO .

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1. PSE Codes .  :

NS - Nuclear Safety Related - .

SS - Nuclear Safety Significant . I,

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NO - Not' Nuclear Safety Related , - -

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ECTG C.3 Attachment A Page 1 of 1 Revision 2 ECSP Corrective Action Tracking Document (CATD)

INITIATION Applicable ECSP Report No: C011106-SON. R1

1. Immediate Corrective Action Required: O Yes pi No

2. Stop Work Recommended: O Yes

3. CATD No. 11106-SON-01, R1

)( No

4. INITIATION DATE 11-20-86

5. RESPONSIBLE ORGANIZATION: SON - ONP

6. PROBLEM DESCRIPTION: )( QR O NQR _ Engineering evaluations performed in accordance with the policy statements on attachment F of S0P 551 or a memorandum with a similar statement need to be evaluated by DNE to determine if these evaluations are acceptable.

7. O ATTACHMENTS PREPARED BY: NAME Donald R. Owen 8.

/ , , ,1 TE: 11-20-86 CONCURRENCE: CEG-H _ Jack L. Howard -7Gkyf f, ' ATE: 11-20-86

9. APPROVAL: ECTG PROGRAM MGR. 6>' DATE:

CORRECTIVE ACTION

10. PROPOSED CORRECTIVE ACTION PLAN:

11. O ATTACHMENTS PROPOSED BY: DIRECTOR /MGR: DATE:

12. CONCURRENCE: CEG-H: DATE:

SRP: DATE:

DATE:

DATE:

DATE:

ECTG PROGRAM MGR: DATE:

VERIFICATION AND CLOSE0UT 13.

Approved implemented.

corrective actions have been verified as satisfactorily SIGNATURE TITLE DATE 2452T

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