ML18033B392
| ML18033B392 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 05/31/1990 |
| From: | Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B375 | List: |
| References | |
| NUDOCS 9006210270 | |
| Download: ML18033B392 (10) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 SAFETY EVALUATION REPORT BY THE OFFICE OF NUCLEAR REACTOR REGULATION EMPLOYEE CONCERNS SUBCATEGORY REPORT E-C-40700
'IPROCEDURAL CONTROL" TENNESSEE VALLEY AUTHORITY BROMNS FERRY NUCLEAR POMER PLANT DOCKET NOS.
50"259 50"260 AND 50-296 I.
SUMMARY
OF ISSUES The Procedural Control subcategory addresses the adequacy of procedures governing material control functions.
To aid in the evaluation effort, the 18 concerns assigned to the subcategory were grouped into 12 issues pertaining to; (1) heat code as used for material control during construction, (2) heat code as used for material control during operation, (3) change of heat
- numbers, (4) use of non-code material, (5) material upgrading/reclassification, (6) invalidated heat numbers for structural steel, (7) material received by inappropriate personnel, (8) warehouse access control, (9) verification of a material discrepancy, (10) the adequacy of a search for defective material, (11) the adequacy of. procedures governing storage and tracking of instrumentation materials, and (12) the adequacy of controls on the purchase and handling of nondestructive examination materials.
II.
EVALUATION TVA has evaluated the twelve issues identified above and concluded that eight of these issues were not factual nor a problem for the Browns Ferry Nuclear Plant (BFN).
For the other four issues that were determined to be factual TVA has issued Condition Adverse to guality Reports (CARR) and Corrective Action Tracking Documents (CATO) to track and resolve that problem.
The results of the TVA's evaluation of each issue follows:
1.
Heat Code as Used for Material Control Durin Construction This issue was found to be factual at TVA's Matts Bar, Sequoyah, and Bellefonte Nuclear Plants.
The issue was not factual at BFN but some concomitant issues were found.
At BFN, traceability of Code or Record Material was found to meet the codes and standards to which BFN was committed, through construction.
Four discrepancies were found during this evaluation as follows:
a.
General Electric Design Specification
- 22A1406, R2, took exception to the Nuclear Code Cases of USAS B31.1.0 for Power Piping.
This is in direct conflict with the BFN FSAR and 10CFR50.55a.
NDE requirements for pipe forgings were unclear because bills of material specified identical mark numbers for both forgings requiring additional NDE (PT or MT) requirements and forgings requiring no 90062l0270 900531 PDR ADOCfC 05000259 P
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additional NDE requirements.
These forgings were specified to have PT and MT tests performed as indicated on the principal piping contract and/or TVA bills of material.
c.
Installed 2-inch piping was found to not meet the brittle fracture requirements of AEC Criterion 35:"
ASTM A-106 without impact testing was installed instead of ASTM A-333 which required impact testing.
d.
Installed 6-inch piping was found to not meet the brittle fracture requirements of AEC Criterion 35.*
ASTH A-106 without impact testing was installed instead of ASTM A-133 which required impact testing.
Five CATDs were initiated for the identified deficiencies for this issue.
Corrective actions to resolve these deficiencies are as follows:
o Accept as is.
The Construction of BFN was underway before 10CFR50.55a (and predecessor documents) was issued.
This document was a compila-tion of industry codes and standards.
GE design was supplemented with state-of-the-art technology surpassing the Code Cases.
The subject of (AEC Question
- 4. 1.3) (p. Q4.1.3-1/4. 1.3-2) will be included in the BFN FSAR, with reference to GE Design Specifications supplementing the B31. 1 Code in significantly greater detail and using much more up-to-date technology than the Nuclear Code Cases.
This is addressed by CAQRBFF870088 and CAQRBFF870089.
(CATD 40700-BFN-01) o DNE (Knoxville) is to provide a matrix of material NDE requirements on the basis of design commitments.
ONE (site) is to prepare a
detailed plan to review material documentation to establ,ish a high level of assurance of the adequacy of TVA Class A, B, C, D and E
forgings.
Any discrepancies will be identified and resolved via CAQRs.
(CATDs 40700-BFN-02 and 03).
o The installed ASTM A-106 steam drain piping is subjected to temperatures well above the nil ductility transition temperature and does not exhibit brittle fracture.
The FSAR does not require impact tests for material less than 1/2 inch thick (nominal wall thickness).
Because the installed pipe nominal wall thickness is 0.344 inches, no impact testing is required.
The material is accept-able as installed and three drawings will be revised denoting the acceptability of the ASTH A-106 material.
(CATO 40700-BFN-04).
II o
The installed piping is ASTM A-106 without impact testing.
The BFN FSAR clarifies the brittle fracture control requirements in AEC Cri-terion 35.*
Impact tests are not required for material with a nominal pipe size of 6-inch diameter and less, regardless of thickness, there-fore the use of ASTH A-106 Grade B without impact testing is acceptable for this application.
Furthermore, since the location and environment t
"AEC Criterion 35 is now General Design Criterion 31 of 10 CFR Part 50 Appendix A.
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of this piping indicates that it is subjected to temperatures well above the nil ductility transition temperature, the ASTM A-106 material will not exhibit brittle fracture.
To provide clarification of the design requirements for materials, affected drawings will be revised to allow the use of ASTM A-106 Grade B as an alternative to ASTM A333 Grade 1.
This is being accomplished under PIRBFNNEB8709.
(CATO 40700-BFN-05).
Heat Code As Used For Control Durin 0 erations This issue was found to be factual at three
.TVA nuclear sites:
Watts Bar, Sequoyah and Browns Ferry.
The following deficiencies were found to have occurred:
o The TYA Nuclear guality Assurance Manual for all three nuclear sites did not accurately define the requirements for material identification and control procedures necessary to ensure compliance with 10 CFR Part 50 Appendix 8, Criterion VIII, "Identification and Control of Materials,
- Parts, and Components."
o Site procedures did not always provide a positive documented trace-ability path between the material installed and its Certified Material Test Report.
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o The modifications performed on components did not comply with for identification and control cation, erection, installation the critical structures,
- systems, and the requirements of 10 CFR 50 Appendix B, of these components through their fabri-and usage.
o Design and inspection personnel displayed a lack of understanding in the Code of Record requirements for Code material, both in the design/procurement and identification/verification processes at installation.
At Browns Ferry four CATOs were initiated for the identified deficiencies.
The deficiencies were resolved in the following manner:
o There is no procedural inadequacy in SP BF-6. 2 in the area of material verification during weld joint fit-up.
No corrective action is required.
SP BF-A6 dated February 9, 1973, shows the requirements in place for control of materials after issue from Power Stores through installation.
This practice was in use through April 14, 1978.
SP BF-Modification and Addition Instruction 15 dated December 27, 1979, provided for material accountability from the time of material issue until installation.
Ample evidence exists that materials were required to be controlled in a manner to preclude incorrect material from being installed prior to present revision of SP BF 6. 2.
(CATO 40700-BFN-06) o Modifications at Browns Ferry, including the work cited in this CATD 40700-BFN-07, have been performed in a manner that provides adequate material traceability to meet the criteria of 10 CFg 50 Appendix B, Criterion VII and VIII. Material traceability has been/is maintained.
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- However, as a result of this investigation and in order to enhance records retrievability, the set of modifications files presently located in Modifications Fabrication Shop S21 will be secured by Document Control in a manner consistent with lifetime storage require-ments.
(CATD 40700-BFN-07)
A.
Assigning duplicated weld numbers and retrevability of weld documents does not impact on the weld quality.
However, the development and implementation of a weld map program shall address various concerns such as assigning unique weld numbers for modification and maintenance, and improving retrievability of weld documents for new work.
This will be done on BF-CAR-0038.
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B.
No corrective action is required.
Furthermore, pressure-temperature ratings for pipe could be used to estimate a pipe wall thickness as a function of the materials and operating conditions.
The pressure-temperature rating for pipe is based on the minimum wall thickness requirements, and is a convenient design guide to avoid repetitive minimum wall calculations.
The current practice for BFN, relative to weld maps, is fully detailed in Site Director Standard Practice (SDSP)
- 13. 13 and does ensure ongoing control/maintenance for these documents with a cross-reference to the relative work packages.
(CATO 40700-BFN-08)
Due to inconsistency of material non-destructive examination (NDE) requirements in the Bill of Materials, the Division of Nuclear Engineering will provide a matrix of material NDE requirements on the basis of design commitments made for BFN.
This matrix will be used to review Bills of. Material to establish a high level of assurance for adequacy of tubular products in TVA piping classifi-cation A and B.
This corrective action item is already identified in CATO No. 40700-BFN-02 and 40700-BFN-03.
(CATD 40700-BFN-09)
Chan e of Heat Code Numbers
'his issue was found to be not factual at Browns Ferry.
No evidence was found that indicated that 'the issue had occurred.
4.
Use of Non-Code Material This issue was found to be factual at all four TVA nuclear plants.
(The NRC requested TVA to'valuate this issue at all four nuclear plants).
The evaluations were based on the evaluations from "Heat Code as Related to Material Control for Construction and for Nuclear Power" and "Material Upgrading/Reclassification."
Also, the terms "non-code" and "certain areas" had to be defined for each plant site.
The term "non-code" was defined as material that did not meet the site-specific Codes for Record and the term "certain areas" was defined as Code of Record systems at each plant site.
Mhen the evaluations and conclusions of the three issues (as applicable to each nuclear plant) were evaluated collectively, non-code material could have been installed in code systems at all four TVA
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nuclear plants.
No corrective actions were initiated for this issue since the deficiencies identified were already addressed in the three issues used as the basis for the evaluation of this issue.
- Also, CATD 40700-NPS-Ol will cause a program-matic review and revision to TVA's overall material control program.
5.
Material U
radin /Reclassification This issue was found to be non-factual at Browns Ferry.
6.
Invalidated Heat Numbers for Structural Steel This issue was found to be non-factual at Browns Ferry.
7.
Materials Received b
Ina ro riate Personnel This issue was found to be non-factual at Browns Ferry.
8.
Warehouse Access Control This issue was found to be non-factual at Browns Ferry.
9.
Verification of Materials Discre anc t
This issue was found to be non-factual at Browns Ferry.
10.
The Ade uac of Search for Defective Materials This issues was found to be non-factual at Browns Ferry.
11.
The Ade uac of Procedures Governin Stora e and Trackin of nstrumentatson Materia s
This issue was found to be 'non-factual at Browns Ferry.
12.
The Ade uac of Controls on the Purchase and Handlin of Nondesctructive xaminatson Mater>a s
This issue was found to be non-factual at Browns Ferry.
III. CONCLUSION The NRC staff concludes that TVA has adequately addressed the issues raised by the eighteen concerns included in this Materials Subcategory Report.
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