ML20210H206
| ML20210H206 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/02/1987 |
| From: | Halverson R, Joyce J, Stewart D TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML20210F779 | List: |
| References | |
| 80201-SQN, 80201-SQN-R04, 80201-SQN-R4, NUDOCS 8702110394 | |
| Download: ML20210H206 (65) | |
Text
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
SPECIAL PROGRAM 80201-SQN REPORT TYPE REVISION NUMBER:
Element Report 4
TITLE:
PAGE 1 0F 15 Inspection Criteria REASON FOR REVISION:
This report was revised to incorporate corrective action response to CATD 80201-SQN-03.
Revision indicators are not shown as the report was reformatted.
Note:
Sequoyah Applicability Only PREPARATION PREPAD D BY:
R. HALVERSON
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DATE SIGNATURE DATE APPROVED B :
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N/A ECSP M AGER DATE MANAGER OF NUCLEAR DATE POWER CONCURRENCE (FINAL REPORT ONLY)
- SRP Secretary's signature denotes SRP concurrences are in files.
8702110394 870205 PDR ADOCK 05000327 P
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L TVA EMPLOYEE CONCERNS REPORT NUMBER REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
- Element Report 4
TITLE:
PAGE 2 0F 15 Inspection Criteria 1.0 CHARACTERIZATION OF ISSUES 1.1 Introduction The issues described in this Element Report were derived from employee concerns generated as a result of the Watts Bar Employee Conce rn Special Program.
The issues were determined to be applicable to the Sequoyah Nuclear Plant and were investigated and evaluated on that basis.
1.2 Description of Issues The perceived issues reported by concerned employees are:
A.
Vendor welds are substandard.
(JAN-85-001 and JLH-85-005)
B.
Quality Assurance (QA) Program Adequacy.
(XX-85-050-001, XX 050-003, XX-85-102-006, and XX-85-125-006) 2.0
SUMMARY
2.1 Summary of Characterization of Issues The overall issues raised by concerned employees suggest that certain vendor welds made by Southwestern Engineering Company (SECO).and National Valve and Manufacturing Company (NAVCO) are substandard.
The adequacy of the QA program is questioned regarding installation of in s trument compression fittings, visual acceptance criteria which covers the American Society of Mechanical Engineers (ASME),Section II, and TVA's Procurement Program regarding replacement parts for safety nelated equipment.
2.2 Sunsnary of Evaluation Process The Quality Assurance Category Evaluation Group (QACEG) Evaluation consisted of reviewing the appropriate requirements contained in documents such as:
Appendix B to 10CFR50; TVA's Topical Report; Nuclear Quality As surance Manual (HQAM);
ASME Codes; Standards; Specifications; Frocedures ; Instructions; and Repor ts.
In addition, discussions were held with cognizant personnel to gain additional information to aid in this investigation.
2.3 Sunsaary of Findings The conclusions reached as a results of the QACEG Evaluation are:
The issues of vendor welds being sub standard are substantiated.
A total of twenty-four welds made by SECO were identified as requiring Verification of repair work was performed by Quality Control rework.
s
)
i REPORT NUMBER:
TVA EMPLOYEE CONCERNS REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 4
TITLE:
PAGE 3 0F 15 Inspection Criteria Inspectors and documented in a work plan.
Three welds made by NAVC0 were also identified as requiring rework.
A maintenance request was issued and the welds were repaired.
issue of inadequate QA controls is. partially substantiated.
The The QA Program controls for the installation of ins trumen ta t ion compression fittings are inadequate or nonexistent.
The enp loyee regarding the visual examination procedure covering ASME concernsSection II and TVA's Procurement Program allowing safety related parts to be purchased commercially are not substantiated.
2.4 Corrective Action Taken And The Results Achieved To Date Substandard welds made by NAVC0 and SECO have been satisfactorily Verification of repair work was performed by QC Inspection repaired.
and documented. TVA QA performed a survey of other welds made by SECO with no additional adverse findings noted.
Corrective measures regarding instrument compression fitting installation ac tivitie s included:
inspec tion and noninspec tion personnel training; evaluate compression fitting inadequacies for general applicability; and quality control inspection.
Inadequate compre ss ion fitting installation was also reported to the NRC under the rules of 10CFR50.55(e).
TVA transmitted their final response to the NRC in July 1986.
3.0 LIST OF EVALUATORS W. M. Akeley R. D. Halverson J. E. Mann 4.0 EVALUATION PROCESS 4.1 Ceneral Methods of Evaluation Methods of evaluations included reviewing the applicable TVA QA and implementing procedures related to the requirements Program Documentation was reviewed and discussions were held with the issues.
appropriate cognizant personnel.
4.2 Specifics of Evaluation Vendor welds are substandard 4.2.1 Issue -
Reviewed Employee Concern Files including the Con fidential Files for any additional information.
The Confidential Files contained additional in forma tion regarding the identi fication of the specific SECO and NAVC0 welds in question.
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REPORT NUMBER:
TVA EMPLOYEE CONCERHS SPECIAL PROGRAM 80201-SQN REPORT TYPE:
REVISION NUMBER:
Element Report 4
TITLE:
PAGE 4 0F 15 Inspection Criteria Reviewed Maintenance Request (MR) A-561926, dated 11/27/86, utilized in the repair of the NAVC0 welds and work plan 11777 Procedures N-VT-which was utilized to repair the SECO welds.
i 3,
Rev.
4,
" Visual Examiniation";
N-VT-4, Rev.
2,
" Liquid
-Penetrant Examination";
10CFR50.55a " Codes and Standards";
i' ASME Section XI, Division I, IWA 4000, 1980 Edition, Winter
" Rules for Inservice Inspection of Nuclear Power 1981 addenda, Plants Components"; and knerican National Standards Institute (ANSI) B31.7, 1969 Edition, Summer 1970 addenda were reviewed to determine the weld acceptance criteria.
Reviewed ASME Section XI Summary. Report, dated 1/20/86, indicating rework performed - on NAVC0 welds and inspec tions conducted.
Inspected the three NAVC0 Sa fety Injection Welds identified on Drawing A 7257, Rev.
(315D, 315E, and 316A) as 4, Piece Mark 151-134.
4.2.2 Issue - QA Program Adequacy 4
o f TVA's Quality Assurance addresses three areas This issueThe adequacy of the program is questioned regarding:
Program.
l Installation of Instrument Compression Fittings.
1 A.
Visual Acceptance Criteria for ASME Set. tion II.
B.
C.
Procurement of safety related parts.
s Installation of Instrument Compression Fitting Reviewed Employee Concern File including; Confidential Files for any additional in formation pertaining to this conc ern.
NSRS Report I-85-349-SQN (Attachment B) had been issued
- documenting the investigation and findings of this conce rn.
This report was reviewed and its content re-evaluated.
Specifications, procedures.
standard s,
cod es,
- reports, and included in reviewed during this investigation are memorandums the NSRS Report " Documents Reviewed During Investigation I 329-SQN and Re ferences".
f Visual Acceptance Criteria for ASME Section II h
Reviewed Employee Concern Files includ ing the Con fidential additional in formation pertaining to this File for any No additional information was available.
concern.
Reviewed ASME Section II, Parts A, B, and C, 1974 Ed'ition and TVA Procedure BF-16.4, Rev.
O,
" Mater ial, Components, and Spare Parts Rec eip t, Hand ling, Storage, Is suing, Return to i
Storeroom, and Trans fer".
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U; TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 4
TITLE:
PAGE 5 0F 15 Inspection Criteria Held discussion with a cognizant individual from Quality Assurance to determine if TVA has ever established and a Visual Examination Procedure re lated to ASME implemented Section II.
Procurement of Safety Related Parts Reviewed Employee Concern File including the Confidential File No for any additional information pertaining to this concern.
additional information was available.
Reviewed Appendix B to 10 CFR 30; TVA Topical Report, TVA-TR75-1A/R8; Nuclear Quality Assurance Manual (NQAM) Part III, Section 2.1
" Procurement of Materials, Components, Spare
- Parts, and Se rvices";
Division of Purchasing Procurement Manual, Revision 6/21/83; Reg. Guide 1.123, " Quality Assurance Requirements for the Control of Procurement of Items and Services fo-Nuclear Power Plants"; and Sequoyah Nuclear Plant Standard h actice (SQA 45), Rev.
21,
" Quality Control of Ma te rial and Parts and Services".
These documents we re reviewed to determine the requirements and conunitments for the procurement of items.
Held discussions with three cognizant personnel from Power Stores and Quality Assurance on the aspects of this concern.
5.0 FINDINGS 5.1 Findings on Issue - Vendor Welds are Substandard 5.1.1 Discussion As stated in an un-numb ered NSRS "Onsite Employee Concern Impact Evaluation", a survey was performed by a QC Inspec to r, a SECO representative, and the cognizant engineer to identi fy the de fective welds.
A total of 24 welds were identified as requiring rework.
SQN Work Plan 11777 was reviewed and af fected welds were reworked.
Verification of repair work was performed by QC Inspection and documented in the Work Plan.
The un-numbe red NSRS evaluation "Onsite Employee concern Impact Evaluation" indicated that the concerned employee was notified of the repair work and the employee was satisfied.
The three NAVC0 safety injection welds specified in this issue were identified as 315D, 315E, and 316A.
The welds were located in Fan Room fl, Unit 1, near valve 1-63-649 at the ceiling above the ladder access opening.
Several photographs taken by TVA Quality Assurance personnel showing actual were weld conditions.
The welds were determined to be unacceptable
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d TVA EMPLOYEE CONCERNS REPORT NUMBER SPECIAL PROCRAM 80201-SQN REPORT TYPE:
REVISION NUMBER:
Element Report 4
TITLE:
PAGE 6 0F 15 Inspection Criteria
in -that they violated the visual acceptance requirements of N-VT-3.
Maintenance Request A-561926 was generated describing the rework necessary to correct the identified conditions.
Correc tive Action consisted of grinding areas identified as nonde s tructive unacceptable and per forming the necessary examinations (LP '& UT) required for final acceptance in l
accordance with ANSI B31.7,1969 Edition, Summer 1970 Addenda.
Work was completed on January 20,
- 1986, with ANI/ANII concurrence.
As part of the QACEG concern evaluation, an inspector from the TVA Quality Control group and a QACEG Investigator verified weld identification and performed visual inspection of the three welds in question to further substantiate corrective action and the proper closure of the Maintenance Request.
This reverification concluded that all items were acceptable and that rework and reinspections were in accordance with the work instructions specified in the Maintenance Request.
5.1.2 Conclusion This issue is substantiated in that the welds in question were j
determined to be visually unacceptable.
NAVC0 Welds, although visually unseceptable to the requirements of TVA's Procedure N-VT-3, did not require Visual Weld Examination by the Fabrication Code, ANSI B31.7.
- However, the unacceptable conditions were properly identified and corrective action was accomplished in a satisfact6ry manner.
5.2 Findings on Issue - QA Program Adequacy Inst.allation of instrument compression fittings A.
Visual acceptance criteria for ASME Section II B.
C.
Procurement of safety related parts Discussion - Installation of instrument compression fittings l
5.2.1 An NSRS Investigation (I-85-329-SQN, dated 2/11/86) was i
conducted to ' determine the validity of this issue as received Team.
by the Quality Technology Company (QTC)/ Employee Response (ERT).
This report was reviewed by QACEG, its contents re-evaluated, and the report was found to be accurate and factual.
In addition to this investigation, NSRS has conducted two previous investigations of matters closely related to the above concern of record.
Those investigations resulted in specific recommendations from NSRS which were determined to be applicable to this issue.
Those investigations are documented as follows:
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w TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPEt SPECIAL PROGRAM 80201-SQN Element Report REVISION NUMBER:
TITLE:
4 Inspection Criteria PAGE 7 0F 15 Reference 1 NSRS Report No. R-85-02-SQN/WBN presents the results of a special review which was performed to investigate concerns expressed by Crawford Fitting Company.
Those concerns involved po tential misapplication of the Swagelock tube fittings on the Westinghouse designed bottom-mounted incore ins trumen tation system seal tables.
The report presents NSRS recommendation R-85-02-SQN-WBN-01 to NUC PR of fice-wide awareness bulletin on tube fitting maintenance activities.
Reference 2 NSRS Report No. IN-85-795-001; IN-85-795-002 presents the results of an inve st'igation which was conducted regarding two employee concerns pertaining to Watts Bar.
Concern No. IN-85-795-001 stated that compression fittings on instrument tubing are not installed per vendor instructions.
The report contains evidence of potentially significant conditions adverse to
- quality, and NSRS recommendation Q-85-795-001-01 states that an eva luation of this situation should be conducted for generic applicability to all TVA plants.
Re fe rence 1 presented NSRS' recommendation R-85-02-SQN-WBN-01 which addressed the need for increased awareness of the critical and somewhat delicate nature of compression tube fittings in general.
The recommendation specifically encouraged NUC ER to prepare and dis tribute to the nuclear plant s an office wide awareness bulletin or similar mechanism to achieve an increased awareness.
This bulletin was issued September 20, 1985 to the nuclear plants with direction to take the following actions:
Issue the bulletin to employees whose work activities involve tube fittings.
Incorporate the conce rns and policy stated in the bulletin into permanent hazard con trol instructions and p lant instructions as appropriate.
Coordinate with the Nuclear Training Branch and implement training for employees involved in installation and
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maintenance of the tube fittings.
The text of the bulletin contains the following statements:
"Sequoyah has initiated a training class on tube fittings in cooperation with the Power Operations Training Center (POTC)."
"It is P&E (Nuclear) policy that compre s sion-type tube fittings be installed consistent with manu f ac turer 's instructions and that maintenance ac tiv itie s involving these fittings shall not degrade the integrity of these fittings.'
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
' REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 4
TITLE:
PAGE 8 0F 15
-Inspection Criteria Reference 2 presented NSRS' recommendation Q-85-795-001-01 which addressed evidence of a potentially significant condition adverse to quality 'regcrding compres sion fitting inadequacies at Watts Bar (WBN).
The following actions were recommended and the results indicated:
NCR WBM-6278R0 was initiated to document the safety significance of the inadequacy of quality assurance controls on compression fitting installation for tub ing connections.
The NCR states that installations -were discovered at WBN which did not agree with the manufacturer's installation instruction.
The condition was identified as "s igni ficant".
- b. The response to NSRS should include the results of an evaluation of this condition for generic applicability to all TVA plants.
It was dete rmined that this evaluation had not been performed as of January 7, 1986.
NCR WBN-6278R0 received engineering review by OE in accordance with the an requirements of OEP-17, paragraph 3.2; OE has not performed an evaluation for generic implications of the condition to Sequoyah and Browns Ferry.
- c. NCR WBN-6278R0 direc ted that Office of Engineering (OE) eva luate compression fitting installation to determine the need for possible TVA process specification revisions.
As a result, OE developed a pr? cess speci fication ' 3.M.13.1 for installation and inspection of compression fitting joints in mechanical tub ing sy s tems.
This specification is applic able to all TVA projects.
Advance copies were distributed to all plant sites on January 2,1986.
SQN DCU will route a copy to the SQN Modifications Branch for review.
- d. NCR WBN-6278R0 direc ted that OE provide analyses for certain compression fitting connections to determine the acceptability of these installations although leak tightness is achieved.
These analyses were per formed by TVA's Singleton Materials Engineering Laboratory, and the results of the testing program l
are documented (Re ference Attachment C).
The results provide technical information concerning the reliability and safety of compression fittings which may not have been installed with the manu f ac ture r's recommendations but which achieve leak t i gh tne s s.
On August 19, 1985, the Power Operations Training Center (POTC) established an initial tube fitting training program in cooperation with SQN.
This p rogram is intended to provide individuals who install tube fittings with the necessary r
information to properly install tube fittings to ensure a leak-
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l TVA EMPLOYEE CONCERNS REPORT NUMBER:
REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 4
' TITLE:
PAGE 9 0F 15 Inspection Criteria proof, mechanically sound tubing connection.
The course material covers the most commonly used brands of tube fittings.
Criterion II, requires that struc ture s, systems, and components covered by the QA program be identified:
Instrument sensing lines in sa fety-related systems have been identified in the QA programs for design and construction (Ref. Construction Specification N2G-877 " Identification of Structures, Sy s tems, and Component s covered by the Sequoyah Nuclear Plant QA Program") and for the operation phases of SQN (Ref. SQA-134, " Critical Structure, Systems, and Component s List").
10 CFR Part 50, Appendix B, Criterion II, also requires that the QA program provide control over activities affecting the quality of the identified structures, sy stems, and components to an extent consistent with their importance to safety:
The procedure which provided programmatic QA controls of activities during the construction phase of SQN is identi fied in DEDC-Q AP-2.0.
However, lower-tier inspection procedures applicable to instrument sensing lines did not include provisions for quality control inspection of compres sion fitting installation activities.
c The procedu re which provides progransnatic QA controls of maintenance activities during the operational phase of SQN is identified in NUC PR QA Manaual Part II, Section 2.1.
- However, lower-tier SQN instructions applicable to instrument sensing lines do not include provisions for quality control inspection of compression fitting installation or maintenance activities.
Repaired instrument sensing lines are inspec ted by quality control personnel for cleanliness and leakage after reassemb ly.
Lower-tier SQN instructions (MI-1.9, revision 7, " Bottom Mounted Instrument Thimble Tube Retraction and Reinsertion", and MI-1.10 revision 3,
"Incore Flux Thimble Cleaning and Lubrication")
applicable to instrument thimble tubes d_o, include quality control hold point provisions for mechanical verification and signoff, as well as cleanliness checks.
10 CFR Part 50, Appendix B, Critierion II, also requires that the QA program provide for indoctrination and training of personnel performing ac tivities a f fec ting the quality of the identified structures, systems, and componenLa as necessary to assure that suitable proficiency is achieved and maintained:
The programmat ic training requirements applicable to the construction phase of SQN were established.
The implementing a
1 TVA EMPLOYEE CONCERNS REPORT NUMBER SPECIAL PROGRAM 80201-SQN REPORT TYPE:
REVISION NUMBER:
Element Report 4
TITLE:
PAGE 10 0F 15 Inspection Criteria doucument, QC-4,
(" Quality Control Instrumentation") contained modules for quality control inspec tor certification but not modules for training of personnel involved in installation' of compression tube fittings.
The inspector certification modu le for instrument lines and loops had not been implemented by the time SQN construction was completed.
The programmatic training requirements applicable to the operational phase of SQN are established by NUC PR QA Manual, Part III, Section 6.1.
Training requirements for training personnel are addressed in this procedure.
The lower-tier SQN instruction AI-14
(" Plant Training Program") which implements this procedure addresses maintenance personnel training also, including personnel whose job function involves the installation of compression-type fittings on instrument sensing lines.
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listed for these personnel do not cover tube Howeve r, the courses fittings even though the o f fice-wide bulletin previously discussed directs plant management to " implement training for eg ioyees involved in installation and maintenance of tube fittings."
Sequoyah Manuals SMI-1-68-20 and IMI-118 are exang le s of SQN maintenance instructions which involved compression-type fitting specify personnel training requirements.
installation but do not Instruction MI-1.9 involves the installation of compression-type fittings on the instrument thimble tubes and does not specify that "all personnel working on tube fittings should have had the tube fitting class."
However, even this instruction does not cirerly establish the training as a requirement.
SQN management is consnitted to the trainirJ of these personnel (e.g., Mechanical Test Unit); however the applicable instructions do not formalize the requirement.
In addition, the NUC PR Inspector Training Manual establishes the training Quality These requirements for quality control inspector certification.
requirements do not include instruction in inspection of installation of compression-type fittings.
- However, quality the tube control inspection is required in MI-1.9 "to verify that fittings are properly tightened."
10 CFR Part 50, Appendix B, Criterion V, requires that activites a f fecting quality be prescribed by documented in struc tions,
procedures, or drawings.
The above paragraphs address several instructions and procedures applicable to activities affecting the quality of in s trument sensing lines.
In addition to these documents, SQN engineering drawings and construction specifications essentially prescribed the only requirements pertaining to instrument sensing line installation and quality requirements.
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d REPORT NUMBER:
TVA EMPLOYEE CONCERNS 80201-SQN SPECIAL PROGRAM REPORT TYPE:
REVISION NUMBER:
Element Report 4
TITLE:
PAGE 11 OF 15 Inspection Criteria instruction / guidance
'Ihese documents contain very little specific for compres sion-type fitting installation.
- However, this situation has improved with the development and distribution of Process Specification 3.M.13.1, Revision 0,
dated December 9,
- 1985, "Speci fication for insta11stion and inspection of compression fitting joints in mechanical tubing systems."
I-85-329-SQN provided four recommendations regarding NSRS Report installation of compression fittings.
They were, I-85-329-SQN-01, evaluate compression fitting inadequacies of NCR WBN-6278 for I-85-329-SQN-02, provide Noninspection generic applicability;I-85-329-SQN-03, provide Inspection Personnel Personnel Training; Training; and I-85-329-SQN-04, provide site requirements for Quality Control Inspections.
NCR WBN 6278 was I-85-329-SQN-01 indicated that SQN response to reviewed for generic applicability for all. compression fitting The installations within the scope of the Watts Bar QA Program. (SCR) further stated that a Significant Condition Report is sued.
The SCR response SCR 6278-S R0 (identical to NCR WBN 6278) was form goes into more detail, particularly in the generic condition area.
I-85-329-SQN-02 indicated that plant maintenance SQN response to personnel responsible for installation and maintenance of compression-type fittings attended a formal training course, Power Operations Training "Given by the Nuclear Training Branch,the plant QA Staff is working with Center (POTC)."
In addition, plant management to determine if the training requirements need to be incorporated into the applicable plant procedures.
I-8 5-329-SQN-03 states that the Quality Control identified in the SQN response to (QC) inspectors attended the training course to being assigned verification response to 'I-85-329-SQN-02 prior This training provides for compression-type fittings.
for the QC inspectors to perform the required ac tivities suf ficient guidance verification activities.
SQN response to I-85-329-SQN-04 states that plant QC inspectors currently performing inspections on the compression fittings during maintenance and modifications when required by the are upper-tier appropriate work instructions.
However, 'there is no or site requirement to perform these inspec tions, and these activities will be included in SQN Work Instructions at the discretion of the QA Staff.
Inadequate Compress ion Fitting Insts 11ation was reported to the the rules of 10CFR50.55 (e)
Nuclear Regulatory Commission underTVA transmitted their final resp via NCR 6278.
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TVA EMPLOYEE CONCERNS REPORT NUMBER:
-REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:-
Element Report 4
- TITLE:
PAGE 12 OF 15 Inspection Criteria July 30, 1986 (L44 860730 816 Attachment C).
This response included a description of TVA's evaluation process-and the i
results.
A sample inspection.of compression fittings identified discrepancies in the following areas:
tubing cuts not deburred; tubes no t bo t tomed out inside the fittings; nuts were not i
properly ~ tightened; and ferrules we re either unidenti fiable,
missing, or reversed.
TVA's corrective actions included a Laboratory Testing Program to determine the long term affeet on installed instrument systems with the above noted discrepancies.
Af fected drawings, process specification, and instructions and procedures were, or are being revised to prevent recurrence of this problem.
5.2.2 conclusion Critierion X of 10CFR50, Appendix B requires that a program for inspection of activities af fecting quality be established 1
and executed to verify conforma.ce with the prescribed requirements for accomplishing the activity.
The employee concern is sub stantiated because this investigation has revealed that quality assurance program controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10CFR50, Appendix B,
relative to compression fitting installation.
This condition existed during the construction phase and has existed in the operational phase of SQN.
I 5.2.3 Discussion - Visual Acceptance Criteria for ASME Section II Concern of record indicates the visual examination procedure which covers ASME Section 11 is very nonspecific.
Based on review of pertinent documents and discussions ' with cognizant i
personnel, it was concluded by this investigation that TVA does not have a visual examination procedure that pertains to ASME Section II.
5.2.4 Conclusion This issue is not sub stantiated.
ASME Section II has no visual examination requirements for a
fabricator and/or installer.
l 5.2.5 Discussion - Procurement of safety related parts Concerned employee states that the TVA System Procurement 4
Manual allows procurement of IE, safety related NSSS and hold l
devices to be purchased commercially, and not through qualified suppliers because they are part of a larger component.
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REPORT TYPE:
SPECIAL PROGRAM 80201-SQN EEVISION NUM3ER:
- Element. Report TITLE:
4 Inspection Criteria.
PAGE 13 0F 15 NOTE: The concern refers to " hold" devices. It is assumed that this is a misspelling and 'that the CI is referring to equipment used in Class 1E application ( device as a whole which requires qualification by the supplier or maniacturer.)
During the investigation, it was determined that there is no TVA System Procurement Manual as noted in the concern.
There o
is a Division of Purchasing Procurement Manual, Revision June 21, 1983, which re ferences the Nuclear Quality Assurance Manual for quality requirements.
The governing directive is the Nuclear Quality Assurance Manual (NQAM), Part III, Section 2.1,
" Procurement of Materials, Components, Spare Parts, and Se rv ic es".
Lower-tier documents are Sequoyah Nuclear Plant Standard Practice (SQA 45),- Revision 21, June 23,
- 1986,
" Quality Con trol of Material and Parts and Se rv ices",
and Watts Bar Nuclear Plant Administrative Instruction, AI-5.1, Revision 19, March 26,
- 1986,
" Materials Procurement and Control." These directives require that:
Items which are QA Level I must be procured from suppliers who have a QA Program approved - by Division of Quality Assurance, Procurement Evaluation Branch (DQA PEB).
QA Level II items m_aal require the supplier have an approved QA program which conforms to the original requirements.
For QA Level II and III items that require a Certificate l
of Conformance (COC), the vendor shall be required to have a DQA PEB approved COC program that meets the requirements of NQAM Appendix E, Attachment 6, Part III, Section 2.1 (QA Requirements for a Certificate of Conformance Non-ASME Code Items and Small Products).
For all QA Level II and III items, the vendor shall be required to furnish a completed copy of Appendix D (Changes / Substitutions for QA Level II and III Items),
or the suppliers own certificate which provides the information requested, when the item offered is not identical to the contract requirements.
Suppliers of equipment used in Class 1E application (device as a
whole which requires qualification by supplier or manfac ture r) to include electrical wire and cable shall be required to have a QA program which conforms to the applicable portions of ANSI N45.2 or 10CFR 50, Appendix B.
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SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 4
TITLE:
PAGE 14 0F 15 Inspection Criteria Suppliers of commercial-grade equipment that has been qualified for Class 1E application of TVA (replacement be identical to equipment qualified) shall equipment must comply with the QA program requirements for a Certificate of Conformance.
Suppliers of standard design, commercial grade replacement parts (subcomponent, assembly, or module) inside equipment used in a Class 1E application (device as a whole which to the requires qualification), as a minimum shall attest in-kind replacement requirements of the contrac t by completed copy of Appendix u
furnishing a
(Changes / Substitutions for QA Level II and III Items) or the supplier's own certificate which provides the information requested when the item is not identical to the contract requirements.
5.2.6 Conclusion Based on review of the above documents and discussions with cognizant personnel, this concern, as written, canno t be 4
substantiated.
As noted in the Sununary of Findings, adequate controls are in ef fect that preclude procurement of sa fe ty related material from unapproved suppliers.
It should be case known to specific noted that the concern re fer s to a 4
Quality Technology Corporation (QTC) and withheld to maintain confidentiality.
This case was unobtainable during the investigation therefore the details could not be verified.
5.3 Corrective Actions Substandard welds made by SECO have been satis factorily repaired.
i per formed by QC Inspection and i
Veri fication of repair work was documented in SQN Work Plan 11777.
NAVC0 welds which were visually unacceptable to TVA's Procedure N-VT-3 were reworked and documented on Maintenance Request A-561926.
A Corrective Action Tracking Document (CATD) 80201-SQN-01 (Attachment D) was issued to the Of fice of Nuclear l
Power (ONP).
The CATD identified that although the SECO welds were inspection performed on other welds made repaired, there was no sample The SQN Site Director responded to this CATD on October 20, i
by SECO.
i, 1986.
The response stated that SECO performed work at Sequoyah only once.
Sequoyah Modifications requested that Sequoyah Quality a survey.
This survey was conducted by Quality As surance perform l
Assurance with the participation of a SECO repre senta tive, and documented on In-plant Survey Checklist 21-85-5-021.
De ficient welding was identified and corrected by TVA.
The response went on to is therefore concluded that the inspection / review ef fort did say, "It include the majority of welding performed by SECO with repairs being warrented".
l completed accordingly; thus, no additional surveys are QACEG concurs with this response and considers the issued closed.
i r
e u
TVA EMPLOYEE CONCERNS REPORT NUMBER REPORT TYPE:
SPECIAL PROGRAM 80201-SQN REVISION NUMBER:
Element Report 4
TITLE:
PAGE 15 0F 15 Inspection Criteria Nuclear Sa fety Review Staff (NSRS) investigation of instrument compression fitting installation activities was documented in NSRS l.
l Report I-85-329-SQN.
This report provided four recommendations which included evaluate compression fitting inadequacies fo r general applicability ; inspection and noninspection personnel training; and Quality Control Inspection.
Inadequate compression fitting installation was also reported to the Nuclear Regulatory Commission under the rules of 10CFR50.55 (e) via NCR 6278.
TVA transmitted their final response to the NRC on July 30, 1986.
These recent actions have been taken by SQN management and others to improve the controls in the area of compression fitting ins tallation.
However, QACEG has issued a Corrective Action Tracking Document (CATD) 80201-SQN-02 (Attachment E) on September 12, 1986, which identifies the lack of training requirements in various procedures.
The SQN Site Director responded on October 20,
- 1986, conunitting revision to Administrative Instruction (AI) 14 to include re ference to tube fitting class MTU-lMT-28.
QACEG also issued CATD 80201-SQN-03 (Attachment F) identifying that TVA's conunitment to the NRC of developing Proc edure MAI-29,
" Instrument Tube Fitting and Installation" and issuing it by August 15, 1986 has not been accomplished to date.
The SQN Site Direc tor responded on January 24, 1987 (RIMS E03 870123 802) indicating that the SQN Modification Group has the responsibility to initiate MAI-29 and the estimated completion date is March 9,1987.
Attachment A,
identified the concerns as potentially sa fe ty-i significant or s a fe ty-re la ted.
QACEG evaluation concludes that only concerns J AN-85-001 and XX-85-050-001 we re potentially sa fe ty-
. s ignificant.
However, corrective measures, as described in this report, have and are being taken.
6.0 ATTACIMENTS i
A.
Employee Concern Program System (ECPS) 1.is t of Employee Conce rn l
In formation B.
NSRS Report I-85-329-SQN Final Report for NRC Open Items WBRD-50-390/85-43, WBRD-50-391/85-42 C.
D.
CATD 80201-SQN-01 E.
CATD 80201-SQN-02 F.
CATD 80201-SQN-03 J
I i
i-
ATTACHMENT A Prgo 1 of 2 33 lEFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 2REQUENCY
- REQUEST OFFICE OF NUCLEAR POWER RUN TIME - 17:46:58 NP - ISSS - RUM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 01/28/87 EMPLOYEE CONCERN INFORMATION DY CATEGORY / SUBCATEGORY iTEGORY: QA QA/QC PROGRAMS SUSCATEGORY: 80201 BASIS OF INSPECTION S
1 REPORT APPL H
2 SAF RELATED SUB R PLT 3 FIND CLASS HISTORICAL CONCERN CONCERN NUM3ER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION
=__
=.
==_= -
__ =_
IN 052-00401 QA 80201 N HBN 1N Y H Y QTC THE BASIS OF ACCEPTANCE FOR A HANGER INSTALLATION T50064 2 NA SR NA SR HHICH DEVIATES FROM SPECIFICATION, DESIGN OR PROCE 3 NA NA DURAL REQUIREMENTS IS NOT REFERENCED OR DOCUMENTED ON THE Q.C. INSPECTION REPORT. THEREFORE, FOR A THIRD PARTY, IT HOULD BE QUESTIONABLE AS TO HHAT A CCEPTANCE CRITERIA HAS USED BY Q.C. TO ACCEPT THE INSTALLATION. C/I DID NOT PROVIDE ANY ADDITIONAL INFORMATION. NO FOLLOH-UP REQUIRED.
IN 347-00601 QA 80201 N HBN 1N Y N Y IN-85-347-006 QTC NO INSPECTION CHECKLISTS TO PERFORM INSPECTIONS.
T50024 2 NA NO NA NO INSPECTION IS DONE TO DRAHINGS.
BOTH UNITS 3 NA NA JAN-85-001 01 QA 80201 N SQN 1N N Y N OECP HELDING PERFORMED BY SECO (OUTSIDE CONTRACTOR) ON 2 NA NA SR NA MSR TUBE BUNDLE REPLACEMENT MODIFICATION IS SUBSTA 3 NA NA E HA NDARD.
SLAG NOT REMOVED, PIPING NOT ALIGNED PROPE RLY, HELDS NOT CLEANED UP, TUBING NOT INSTALLED PR OPERLY, ETC.
JLH-85-005 01 QA 80201 N SQN 1N N Y N DECP THIS CONCERN WAS NOT DOCUMENTED PER SQA166 BUT HAS 2 NA NA SS NA BEEN INCLUDED IN THE EMPLOYEE CONCERN LOG.
THREE 3 NA NA E NA SAFETY INJECTION HELDS ON NAVC0 SPOOL PIECES DISP LAYED EXCESSIVE OVERLAP, ARC STRIKES, UNDERCUT HEA VE HIDTH, AND RUST. THESE HELDS HOULD NOT MEET CU RRENT ACCEPTANCE CRITERIA.
XX 050-00101 CO 17300 S SQN 1Y Y Y Y I-85-329-SQN QTC INADEQUATE QUALITY ASSURANCE CONTROLS HERE APPLIED T50096 2 SS SS SS SS TO THE INSTALLATION OF INSTRUMENT TUBING COMPRESS 3D A D D ION FITTINGS AT SEQUDYAH. NO FURTHER INFORMATION 02 QA 80201 S SQN 1N N Y N AVAILABLE. NO FOLLOH UP REQUIRED.
2 NA NA SS NA 3 NA NA E NA 03 QA 80202 S SQN 1Y Y N Y 2 SS SS NA SS 3
NA XX 050-00301 CO 17300 S BLN 1Y Y Y Y QTC INADEQUATE QUALITY ASSURANCE CONTROLS ARE APPLIED T50096 2 SR SR SR SR TO THE INSTALLATION OF INSTRUMENT TUBING COMPRESSI 3D A D D ON FITTINGS AT BELLAFONTE.
NO FURTHER DETAILS AVA 02 QA 80201 S BLN 1N N Y N ILABLE.
HD FOLLOW UP REQUIRED.
2 NA NA SR NA 3 NA NA E HA 03 QA 80202 S BLN 1Y Y N Y 2 SR SR NA SR 3
NA
ATTACHMENT A Pege 2 of 2
- EFERENCE
- ECPS120J-ECPS121C TENNESSEE VALLEY AUTHORITY PAGE 34 2EQUENCY
- REQUEST OFFICE OF NUCLEAR P0HER RUN TIME - 17:46:58-
.NP - ISSS - RUM EMPLOYEE CONCERN PROGRAM SYSTEM (ECPS)
RUN DATE - 01/28/87.!
EMPLOYEE CONCERN INFORMATION BY CATEGORY / SUBCATEGORY TEGORY: QA QA/QC PROGRAMS SUBCATEGORY: 80201 BASIS OF INSPECTION S
1 REPORT APPL H
2 SAF RELATED SUB R PLT 3 FIND CLASS HISTORICAL CONCERN CONCERH NUMBER CAT CAT D LOC BF BL SQ HB REPORT ORIGIN CONCERN DESCRIPTION
=_
_ _ _ _ _.. __--------______-_--_= ------------------
DC 102-006 01 QA 80201 S BFN 1N N Y N QTC BROHN'S FERRY: THE VISUAL EXAMINATION PROCEDURE HH T50172 2 NA NA SR NA ICH COVERS ASME SECTION II IS VERY NON SPECIFIC.
3 NA NA A NA NUCLEAR P0HER DEPT. CONCERN. CI HAS NO ADDITIONAL 02 QA 80202 S BFH 1Y Y N Y INFORMATION.
NO FOLLOH UP REQUIRED.
2 SR SR NA SR 3
NA DC 125-006 01 QA 80201 S NPS 1N N Y N QTC KNOXVILLE - THE TVA SYSTEM PROCUREMENT MANUAL ALLO T50221 2 NA NA SS NA HS PROCUREMENT OF IE, SAFETY RELATED, NSSS AND HOL 3 NA NA A NA D DEVICES EQUIPMENT TO BE PURCHASED COMMERCIALLY, 02 QA 80202 S NPS 1Y Y N Y NOT THROUGH QUALIFIED SUPPLIERS, BECAUSE THEY ARE 2 SS SS NA SS PART OF A LARGER COMPONENT.
(NAMES / DETAILS TO THE 3
NA SPECITIC CASE ARE KN0HN TO QTC AND WITHHELD TO MA INTAIN CONFIDENTIALITY).
NUCLEAR P0HER CONCERN CI HAS NO MORE INFORMATION.
8 CONCERNS FOR CATEGORY QA SUBCATEGORY 80201
ATTACHMENT B
.Tv n sa. tis sgsi t:p-wp s.es:
9 UNITED STATES GOVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY H. L. Abercrombie, Site Director, Sequoyah Nuclear Plant TO: R. W. Cantrell, Manager of Engineering, W12A12 C-K K. W. Whitt, Director of Nuclear Safety Review Staff, E3A8 C-K FROM:
((g } } jQ86 DATE:
NUCLEAR SAFETY REVIEW STAFF INVESTIGATION REPORT TRANSMITTAL
SUBJECT:
I-85-329-SON Transmitted herein is NSRS Report No.
Subject OUALITY ASSURANCE CONTROLS / COMPRESS' ION FITTING INSTALLATION h
XX-85-050-001 Concern No.
ViaITS 6 and associated prioritized recommendations for your pyllQQfy,,3 action / disposition.
- .tr$ 13'bd f
4 It is requested that you respond to this report and the attached E d'$d
- 28. 1986.
id-ycu-ha ve any Priority 2 [P2) recommendations by February 31 attelephonehh231-questions, please contact W. D. Stevens p
s WW Nb# A""
Recommend Reportability Determination: Yes
~
k irector, NSRS/Desit, nee
~
WDS:GDH Attachment cc (Attachment):
W. C. Bibb, SQN W. T. Cottle, WBN James P. Darling, BLN R. P. Denise, LP6N40A-C G. B. Kirk, SQN D. R. Nichols, E10A14 C-K QTC/ERT, Watts Bar Nuclear Plant Eric Sliger, LP6N48A-C J. H. Sullivan, SQN 455U
- u. n....r..r..
os.. n.....tr c...:. nt- -
n
- e c.
n.
~
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TENNESSEE VALLEY AUTHORITY NUCLEAR SAFETY REVIEW STAFF NSRS INVESTICATION REPORT NO. I-85-329-SQN EMPLOYEE CONCERN: XX-85-050-001 QUALITY ASSURANCE CONTROLS FOR COMPRESSION FITTING
~
SUBJECT:
INSTALLATION DATES OF SEPTEMBER 18 - OCTOBER 8, 1985 INVESTICATION:
A Od STICATOR:
DATE' R. E. MCCLURE A[~7e d ub INVESTIGATOR:
DATE W. R. SIMONDS d!8[e 2
M REVIEWED BY:
DATE M. W. ALEXANDER g w)
=
APPROVED BY:
DATE U. D. STEVENS A
w0 3P Mr*
i-I G
I:
~
v I.
I>
I.
BACKCROUND investigation was conducted to A Nuclear Safety Review Staff (NSRS) determine the validity of an expressed employee concern as received by The the Quality Technology Company (QTC)/ Employee Response Team (ERT).
concern of record, as summarized on the Employee Concern Assignment stated:
Request Form from QTC and identified as K1-85-050-001,
[
" Inadequate' quality assurance controls'were applied to the i
I installation of instrument tubing compression fittings at Sequoyah."
In addition to this investigation, NSRS has conducted two previous j
investigations of matters closely related to the above concern.of Those investigations resulted in' specific recommendations from record.
NSRS which were determined to be applicable to this employee concern.
Those investigations are documented as follows:
L NSRS Report No. R-85-02-SQN/WBN (Ref. 1) presents the results of a l.
A.
special review which was performed to investigate concerns expressed Those concerns involved potential by the Crawford Fitting Company.
misapplication of the Swagelock tube fittings on the Westinghouse designed bottom-mounted incore instrumentation system seal tables.
f The report presents NSRS recommendation R-85-02-SQN/WBN-01 to NUC PR l
for the preparation and distribution to the nuclese plants of an office-wide awareness bulletin on tube fitting maintenance activities.
NSRS Report No. IN-85-795-001; IN-85-795-002 (Ref. 2) presents the B.
results of an investigation which was conducted regarding two Concern No.
employee concerns pertaining to Watts Bar.
y stated that compression fittings on instrument tubing IN-85-795-001 are not installed per vendor instructions. The report contains evidence of a potentially significant condition adverse,to quality,
~
~
and NSRS recommendation Q-85-795-dD'l-01 states that an evaluatken-of
~
this situation should be ccnducted for generic applicability to all TVA plants.
l II.
SCOPE The scope of the investigation is defined by the concern of record.
Since previous NSRS investigations involved matters closely related A.
to this concern, the results of those investigations were included as appropriate in the findings of this investigation.
Reviews of regulations, specifications, and other pertinent docu-ments were performed to identify requirements, commitments, and B.
programmatic controls applicable to the concern of record.
Cognizant personnel were interviewed to help establish the manner in which compression-type fittings have been installed at SQN.
i I.
t 1
I
s/
'III.
SUMMARY
OF FINDINGS LA.
Requirements and Commitments '
1.
-10 CFR Part 50, Appendix B Criterion II, " Quality Assurance Program" a.
Celterion V, " Instructions, Procedures, and Drawings" b.
i
'l
- Cri.terion X, " Inspection" c.
l 2.
Topical Report TVA-TR75-1, Revision 8 Section 17.1.2.3, " Indoctrination and Training" a.
Section 17.1.5, " Int;tructions, Procedures, and Drawings".
b.
1 Section 17.2.2.3, " Indoctrination and Training" c.
Section 17.2.5, "Ir.structions, Procedures, and Drawings" d.
Section 17.2.10. " Inspection" e.
.OEDC Quality Assurance Manual for Design and Construction 3.
OEDC-QAP-2.0, " Quality Assurance Program," Revision 1 a.
QAS-QAP-4.1, " Quality Assurance Indoctrination and b.
Training," Revision 0 4
CONST-QAP-2.02, " Quality Assurance Items," Revision 0
?..
c.
- * " ~
CONST-QAP-2.07, " Qualification / Certification of.. Inspection.
d.
~~
.., Examination, and Testing Personnel," Revision 3 i
i CONST,QAP-10.01, "In'spection," Revision 2 e.
Sequoyah Nuclear Plant General Design Criteria No..SQN-DC-V-3.0, 4.
"~he Classification of Piping, Pumps, Valves, and Vessels,"
Revision 1 Sequoyah Nuclear Plant Construction Specification No. N2M-865, 5.
" Field Fabrication, Assembly Examination, and Tests for Pipe j
Duct Systems," Revision 3 Sequoyah Nuclear Plant Construction Speelfication No. N2C-877, 6
" Identification of Structures, Systems, and Components Covered i
{
by the Sequoyah Nuclear Plant Quality Assurance Program."
Revision 5 2
4
%.Y 4
a NUC PR Nuclear Quality Assurance Manual 7.
10/12/84 Part II, Section 2.1, " Plant Maintenance," Re, vision a.
Part III, Section 6.1, " Selection and Training of Personnel b.
for Nuclear Power Plants," Revision 10/12/84 B.
Findings i
Reference 1 presented NSRS' recommendation R-85-02-SQN/WBN-01 which addressed the need for increased awareness of the critical 1.
and somewhat delicate nature of compression tube fittings in The recommendation specifically encouraged NUC PR to general.
prepare and distribute to the nuclear plants an office-wide awareness bulletin or similar mechanism to achieve an increased This bulletin was issued September 20, 1985 awareness.
(Ref. 39), to the nuclear plants with direction to take the-following actions:
Issue the bulletin to employees whose work activities i
i o
involve them with tube fittings.
Incorporate the concerns and policy stated in the bulletin o
into permanent hazard control instructions and plant instructions as appropriate.
Coordinate with the Nuclear Training Branch and implement training for employees involved in installation and o
maintenance of the tube fittings.
The text of the bulletin contains the following statements:
Sequoyah has initiated a training class on tube fittings in o
+..
cooperation with the POTC.,
It is P&E (Nuclear) policy that compression-type tube
~
f d -fittings be installed consistent with manufacturer's l
instructions and that maintenance activities involving these j
fittings shall not degrade the integrity of these fittings.
Reference 2 presented NSRS' recommendation Q-85-795-001-01 which addressed evidence of a potentially significant condition 2.
adverse to quality regarding compression fitting inadequacies at The following actions were recommended and the Watts Bar (WBN).
results indicated:
WBN CONST should initiate an NCR documenting this condition--
ASME Significant NCR WBN-6278R0 (Ref. 21) was initiated to a.
document the safety significance of the inadequacy of i
quality assurance controls on compression fitting The NCR states that installation for tubing connections.
installations were discovered at WBN which did not agree The with the manufacturer's installation instructions.
condition was identified as "significant."
tw The response to NSRS should include the results of an b.
evaluation of this condition for generic applicability to all TVA plants--it da's determined that this evaluation had NCR W8N-6278R0 not been performed as of January 7, 1986.
' received an engineering review by OE in accordance with the requirements of OEP-17 (Ref. 36) but contrary to OEP-17, paragraph 3.2, OE has not performed an evaluation for generic implications of the condition to Sequoyah and Browns Ferry, NCR WBN-6278R0 directed that OE evaluate compression fitting installation to determine the'need for possible TVA process c.
specification revisions. As a result, OE developed a for installation and process specification (Ref. 27) r inspection of compression fitting joints in mechanical This specification is applicable to all TVA tubing systems.
Advance copies were distributed to all plant,
projects.
sites on January 2, 1986. SQN DCU will route a copy to the SQN Modifications Branch for review.
NCR WBN-6278R0 directed that OE provide analyses for certain 1
I d.
compression fitting connections to determine the accept-ability of these installations although leak tightness is These analyses were performed by Singleton achieved.
Materials Engineering Laboratory, and the results of the The testing program are documented in references 30 and 31.
results provide technical information concerning the reliability and safety of compression fittings which may be installed inconsistent with the manufacturer's recommenda-tions but which achieve leak tightness.
a i
the Power Operations Training Center (POTC) 3.
On August 19, 1985, l
established an initial tube fitting training program (Ref. 28) in cooperation with SQN..This_ ;progran is intended to provide individuals who install tube fittings with the necessary --
v idformation to properly install tube fittings to ensure a The course leak-proof, mechanically sound tubing connection.
material " coversthe most commonly used brands of tube fittings.
10 CFR Part 50, Appendix B, Criterion II, requires that l
structures, systems, and components covered by the QA program be 4,
I l
Instrument sensing lines in safety-related systems identified.
l have been identified in the QA programs for design and construc-tion (paragraph III. A.6) and for the operation (Ref. 8.c) phases I
of SQN.
t 10 CFR Part 50, Appendix B Criterion II, also requires that the i
QA program provide control over activities af fecting the quality 5.
of the identified structures, systems, and components to an extent consistent with their importance to safety.
l f
l 4
~
I
+
s The procedure which provided programmatic QA contro However, lower-tier inspection procedures paragraph III.A.3.a.
applicable to instrument sensing lines (Ref. 35) di installation activities.
I The procedure which provides programmatic QA contr However, lower-tier SQN identified in paragraph III.A.7.a.
instructions applicable to instrument sensing lines (Ref. 8.a-d) do not include provisions for quality control inspection of compression fitting installation or maintenance activities.
Repaired instrument sensing lines,are inspected by Lower-tier SQN instructions applicable to instrument thimble tubes (Refs. 8.e-f) do include quality control hold point provisions for mechanical verification and signoff, as well as cleanliness checks.
10 CFR Part 50, Appendix B, Criterion II, also requires that the QA program provide for indoctrination and training of personnel 6.
performing activities affecting the quality of the iden suitable proficiency is achieved and maintained.
The programmatic training requirements applicable t The implementing document (Ref. 20) contained modules for quality control inspector certification but no modules The inspector certification module for instru-ment lines and loops had not been implemented by the time SQN tube fittings.
construction was completed.,__,,_
The programmatic training requirements applicable to theTraining operational phase of SQN are established by III. A.
The' lower-tier SQN instruction (Ref. y.a) which implements this procedure addresses maintenanc procedure.
i the installation of compression-type fittings on instrume sensing lines.
do not cover tube fittings (e.g., Ref. 28) even though the i
office-wide bulletin discussed above (Ref. 39) directs plant management to " implement training for employees involved in installation and maintenance of tube fittings."
f f
5
/
O i
4 References 8.b and 8.d are examples of SQN maintenance instructions which involve compression-type fitting installation t
Reference but do not specify personnel training requiremen,s.
8.e involves the installation of compression-type fittings on the instrument thimble tubes and does specify that "all personnel working on tube fittings should have had the tube fitting class" (presumably a reference to the program in Ref.
However, even this instruction does not clearly establish 28).
the training as a requirement.
SQN management is apparently committed to the training of these phesonnel (e.g., Mechanical Test' Unit); however, the applicable In addition, instructions do not formalize the requirement.
reference 22 establishes the training requirements for quality control inspector certification. These requirements do not include instruction in inspection of installation of
.However, quality control inspection compression-type fittings.
is required in reference 8.e "to verify that the tube fittings are properly tightened."
10 CFR Part 50. Appendix B, Criterion V, requires that 7.
activities affecting quality be prescribed by documented The above paragraphs instructions, procedures, or drawings.
address several instructions and proesdures applictble to activities affecting the quality of instrument senning lines.
In addition to these documents, SQN engineering drawings (e.g.,
Refs. 24.a-h) and construction specifications (III.A.5 and 6) j essentially prescribed the only requirements pertaining to instrument sensing line erection and quality requirements until l.
These documents contain very little specific recently.
instruction / guidance for compression-type fitting installation.
i However, this situation has improved with the development and distribution of reference 21.
i ibles
,C,riterion X requires that a program for inspection of act v 8.
affecting quality be' established and executed to verify conformance with the prescribad requirements for accomplishing the activity. Refer to paragraph III.B.5 above for findings i
related to this requirement, l
i IV.
CONCLUSIONS AND RECOMMENDATIONS A.
Conclusion The employee concern is substantiated because this investigation has l
revealed that quality assurance controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10 CFR 50, This Appendix B, relative to compression fitting installation. co l
i However, recent actions have been the operational phase of SQN.
taken by SQN management and others as described above to improve the l
controls in the area of the employee concern.
6 i
I
'=+ ~~.- - - -n.w,_.,, _ _,,,
l
%e B.
Recommendations I-85-329-SQN-01, Evaluate' Compressl6n Fittinz Inadequacier of_
1.
NCR WBN-6278 for Generic Applicability This recommendation is being reiterated from Q-85-795-001-01 previously identified in the original NSRS report (Ref. 2) since the actions taken by P&E (Nuclear) did not completely address Specifically, this recommendation as described in III.B.2.b.
NCR WBN-6278R0 has not been evaluated for generic applicability The NCR was transmitted to og on to all TVA nuclear plants.
for' review. However, the review Shptember 9, 1985 (Ref. 38),
did not include an evaluation for generic applicability as A.1though the findings presented required by OEP-17 (Ref. 36).
in III.B.4-8 strongly indicate the applicability of NCR WBN-6278R0 to SQN, the final determination must be performed by Therefore, NSRS recommends that N.R C
OE as described in OEP-17.
WBN-6278R0 be evaluated for applicability to all TVA nuclear plants and that the results of this evaluation be documented and The response distributed as required by established procedures.
to NSRS should include a statement of why the generic (p2]
applicability evaluation was not performed.
I-85-329-SQN-02, Noninspection Personnel Training 2.
As described in III.B.6, SQN management is apparently committed to training personnel involved in installation and maintenance However, several applicable SQN of compression-type fittings.
instructions do not formalize or clearly establish the personnel NSRS recommends that SQN instruc-tralning as a requirement.
tions applicable to the installation and maintenance of compression-type fittings be revised to establish training of (P2]
personnel as a requirement as described in reference 39.
. ~~.-......
~~
J-85-329-SQN-03, Inspection Personnel Training 3.
NSRS recommends that tr'aining on compression-type fittings be developed and implemented for quality control inspectors at This training should provide specific instruction on the inspection methodologies for verification of the quality of SQN.
(P2]
safety-related applications of compression-type fittings.
1-85-329-SQN-04, Quality Control Inspection 4.
NSRS recommends that requirements be established and implemente conduct random sample inspections of compress These inspections should be designed installation activities.
to verify and document that these activities are performed in Inspections could be accordance with prescribed requirements.
performed after installation but prior to hydrostatic testing.
(P2]
7 I
J w
DOCUMENTS REVIEWED IN INVESTIGATION 1-85-329-SQN AND REFERENCES Special Review of Manufacturer Identified Potential Misapplication of Swagelock Tube Fittings at Westinghouse Reactor' Seal Tables - NSRS 1.
Report No. R-85-02-SQN/WBN Compression Fittings on Instrument Tubing - NSRS Report No.
2.
IN-85-795-001; IN-85-795-002
~
Swagelock Report on Imitation and Interchange - 1984 3.
0202.15 and 0202.16 " Instrument Mechanics 4.
NUC PR Area Plan Procedure Training" NUC PR DPM N77A12, " Requirements for Repair and/or Replacement of 5.
Nuclear Power Plant Process - Control Instrumentation" Swagelock " Cold Book" - Tube Fitting and Installation Manual 6.
Westinghouse Installation and Standards Manual, Instrumentation and Control Standards, Section 3.0, " Pressurizer Sealed Reference Leg 7.
Level System," Revision 8/11/71 8.
Sequoyah Instruction Manuals AI-14. " Plant Training Program " Revision 30 a.
SMI-1-68-20. " Repair Leak in Tubing Fitting 1-VLV-68-442A,"
b.
Revision 1 SQA-134. " Critical Structure, Systems, and Components (CSSC) List "
~~ -
c.
Revision 7 IMI-118 " Filling of Sealed Instrument Systems Backfilling, Venting, d.
and/or Flushing of Instrument Sensing Lines," Revision 5 MI-1.9,'" Bottom Mounted Instrument Thimble Tube Retraction and e.
Reinsertion," Revision 7 MI-1.10, "Incore Flux Thimble Cleaning and Lubrication," Revision 3 f.
NUC PR Nuclear Quality Assurance Manual 9.
10/12/84 Part II, Section 2.1, " Plant Maintenance," Revision a.
Part III, Section 6.1, " Selection and Training of Personnel for b.
Nuclear Power Plants," Revision 10/12/84 8
I
OEDC Quality Assurance Manual for Design and Construction
'10.
OEDC-QAP-2.0, " Quality Assurance Program," Revision 1 a.
QAP-QAP-4.1, " Quality Assurance Indoctrination and Training,"
b.
Revision 0 CONST-QAP-2.02, " Quality Assurance Items," Revision 0 c.
CONST-QAP-2.07, " Qualification / Certification of Inspection, d.
Examination, and Testing Personnel," Revision 3 CONST-QAP 10.01, " Inspection " Revision 2 e.
11.
MEDS Search on CONST QA Training Requirements 12.
10 CFR Part 50, Appendix B Criterion II, " Quality Assurance Program" a.
Criterion V, " Instructions, Procedures, and Drawings" b.
Criterion X, " Inspection" c.
ANSI Standard N45.2-1971, " Quality Assurance Program Requirements for 13.
Nuclear Power Plants" ANSI Standard N18.7-1976, " Administrative Controls and Quality Assurance 14.
for the Operational Phase of Nuclear Power Plants" ANSI Standard N45.2.11-1974, " Quality, Assurance Requirements for the 15.
Design of Nuclear Power Plants"
- ANSI Standard N45.2.6-1978, " Qualifications of Inspection, Examination, 16.
and Testing Personnel for Nucleac_P.ower Plants" Topical Re[ ort TVA-TR75-1; 17.1.2.3; 17.1.5; 17.2.2.3; 17.2.5; 17.2.10 17.
Revision 8 Sequoyah Nuclear Plant Cencral Design Celteria No. SQN-DC-V-3.0, "The 18.
Classification of Piping, Pumps, Valves, and Vessels," Revision 1 Sequoyah Nuclear Plant Construction Specifications 19.
N2M-865, " Field Fabrication, Assembly Examination, and Tests for Pipe a.
and Duct Systems," Revision 3 N2G-877, " Identification of Structures, Systems, and Components b.
Covered by the Sequoyah Nuclear Plant Quality Assurance Program,"
Revision 5 CONST QA Training Program Plan Program No. QC-4, " Quality Control -
l 20.
Instrumentation " Revision 2 9
i i
i
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~
v WBNP-CONST ASME Significant Nonconforming Condition Report (NCR) No.
21.
WBN-6278. Revision 0 NUC PR Quality Control Inspector Training Manual 22.
ANSI Standard B31.7-1969, " Nuclear Power Piping" 23.
Sequoyah Nuclear Plant Mechanical Instruments and Controls Drawings 24.
47B001-15. " Mechanical Branch Valve Connection Seismic Support,"
a a.
Revision 2 LIW6001133,'" Mechanical Instruments an'd controls," Revision 8 b.
47W600-1, " Mechanical Instruments and. Controls," Revision 12 c.
d.
47W813-1, " Flow Diagram Reactor Coolant System," Revision 25 47W555-1, " Mechanical CVCS - Chemical Control and Makeup Piping,"
e.
Revision 13 j
47W600-24, " Mechanical Instruments and Controls," Revision 16 f.
47W600-18. " Mechanical Instruments and Controls," Revision 6 g.
47W600-16, " Mechanical Instruments and Controls," Revision 4 h.
i 25.
Swagelock Tube Fitting Catalog C-983 26.
Parker CPI Catalog No. 4230 January 1977 l
Process Specification 3.M.13.1 (RO), " Specification for Installa-27.
tion and Inspection of Compression Fitting Joints in Mechanical i
Tubing Systems," General Construction Specification C-29M.-
i December 9, 1985 1
MTU-MMT-28$'"InitialTubeFittingTraining,"NuclearTrainingBranch*
28.
Power Operations Training Center, Revision 1 SQN Corrective Action Tracking ~ Report, CATS No. 85219, May.23, 1985 29.
Memorandum from W. H. Childress to R. M. Jessee, " Watts Bar Nuclear 30.
Plant - ASME Significant Nonconformance Report (NCR) 6278R1 -
Laboratory Testing," dated December 6, 1985 (B46 851206 001) i i
Memorandum from W. H. Childress to R. M. Jessee, " Watts Bar Nuclear 31.
Plant - ASME Signlficant Nonconformance Report (NCR) 6278R1 -
Laboratory Testing - Supplemental Data " dated December 17, 1985 (B46 851212 001)
Memorandum from H. C. Parris to C. Wadewitz, " Requests for 32.
Investigation / Evaluation," dated August 15, 1985 (Col 850827 005) i i
10 d
- ~ _.. -. -,. _ _
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v Memorandum from James P. Darling to K. W. Whitt, "Sequoyah (SQN) and a
Watts Bar (WBN) Nuclear Plants - Spe:ial Review of Manufacturer-33.
Identified Potential Misapplication of Swagelock Tube Fittings at Westinghouse Reactor Seal Tables - NSRS Report No. R-85-02-SQN/WBN,"
dated May 6, 1985 (L44 850426 807)
SQN Workplan Specification WP No. 10721, February 1, 1984 4
34.
CONST-SNP Inspection Instruction No. 85 " Installation V 35.
Sampling Lines, Control Supply Meaders and Signal Lines," RO Office o'f Engineering OEP-17. " Corrective Action," Revision 2 36.
Memorandum f rom Cuenter Wadewitz to K. W. 'Whitt, " Watts Bar Nuclear Plant - Request for Investigation / Evaluation," October 1, 1985 37.
l Memorandum from Cuenter Wadewitz,to J. W. Co'an, " Watts Bar Nuclear Plan b
9,
- ASME Significant Nonconformance Report 6278RO," dated Septem er 38.
1985 Memorandum from W. T. Cottle to Those listed, " Tube Fitting Awareness 20, 1985 (L29 850909 817) 39.
and Initial Training," dated September 4
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s-T W & CS t VA.$U UNITED STATES GOVERN 3 TENT Memorandum TENNESSEE VALLEY AUTHORITY
- R. K. Seiberling, Manager of Nuclear Manager's ' Review Group (NMRG),
- H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant DATE
- April 18, 1986
,g.. [
SUBJECT:
NUCLEAR SAFETY REVIEW STAFF (NSRS) INVESTIGATION REPORT NO. I-85-329-SQN,
" QUALITY ASSURANCE CONTROLS / COMPRESSION FITTING INSTALLATION"
References:
1.
Memorandum f rom K. W. Whitt to R. W. Cantrell and me dated February 13,1986, " Nuclear Safety Review Staf f Investigation Report Transmittal" 2.
Memorandum from J. P. Vineyard to II. B. Rankin dated March 28, 1986, "Sequoyah Nuclear Plant - Potential Generic Condition Evaluation" (B25 860328 005) (copy attached) 3.
Memorandum from John A. Raulston to Those listed dated February 25,1986, " Potential Generic Condition Evaluation" (B45 860225 259) (copy attacned)
Attached is my response to !!SRS Report No. I-85-329-SQN.
QR.aA
- 11. L. Abercrombie PRW:GBK:RCB:DR APR > ;! '80 Attachments 8
cc (Attachment;),:
Employee Concern F4.les, RES, ONP, SB-2, Sequoyah J. L. Itamilten, QA, O&PS-3, Sequoyah
-j f r
not.,3 T. L. Ilughes, ONP, 0&PS-3, Sequoyah f
wh.tt
,f L. L. McCormick, ONP, SB-2, Sequoyah 2 25
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COORDINATED: Q A/ J Lila mil ton, Re gula to ry E nginee rin g/ LLMcGe rmf
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SQN Response to I-85-329-SON-04 The plant QC inspectors are currently performing inspections on the compression fittings during unintenance and modifications when required by the appropriate work instructions. However, there is no upper tier or site requirement to perform these inspections, and these activities will be included in SQN work instructions at the discretion of the Quality Assurance Staf f.
t e
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NUCLEAR SAFETY REVIEW STAFF REFORT No. I-85-329-SQN NSRS REPORT NO. I-85-329-SQN Concern
" Inadequate quality assurance controls were applied to the installation tubing compression fittings at Sequoyah."
of instrument Conclusion The employee concern is substantiated because this investigation has revealed that quality assurance controls for SQN were nonexistant or inadequate to comply with the applicable criteria of 10 CFR 50, Appendix This condition existed B, relative to compression fitting installation.
during the construction phase and has existed in the operational phase However, recent actions have been taken by SQN management and of SQN.
others as described above to improve the controls in the area of the employee concern.
Recommendations 1-85-329-SQN-01, Evaluate Compression Fitting Inadequacies of NCR 1.
WBN-6278 for Generic Applicability This recommendation is being reiterated from Q-85-795-001-01 pre-viously identified in the original NSRS report (Ref. 2) since the actions taken by P&E (Nuclear) did not completely address this recommendation as described in III.B.2.b.
Specifically, NCR WBN-6278R0 has not been evaluated for generic applicability to all The NCR was transmitted to OE on September 9, TVA nuclear plants.
1985 (Ref. 38), for review. However, the review did not include an evaluation for generic applicability as required by OEP-17 (Ref. 36). Although the findings presented in III.B.4-8 strongly indicate the applicability of NCR WBN-6278R0 to SQN, the final determination must be performed by OE as described in OEP-17.
Therefore, NSRS recommends that NCR WBN-6278R0 be evaluated for applicability to all TVA nuclear plants and that the results of this evaluation be documented and distributed as required by estab-lished procedures. The response to NSRS should include a statement (P2) of why the generic applicability evaluation was not performed.
2.
I-85-329-SQN-02, Noninspection Personnel Training As described in III.B.6, SQN management is apparently committed to training personnel involved in installation and maintenance of compression-type fittings. Heucver, several applicable SQN formalize or clearly establish the personnel instructions do not NSRS recommends that SQN instructions training as a requirement.
applicable to the installation and maintenance of compression-type fittings be revised to establish training of personnel as a require-ment as described in reference 39.
(P2) o
J 3.
I-85-329-SQN-3, Inspection Personnel Training NSRS recommends that training on-compression-type fittings be developed and implemented for quality control inspectors'at SQN. This training should provide specific instruction on the inspection methodologies for verification of the quality of safety-reJated applications of compression-type fittings.
(P2) 4.
I-85-329-SQN-04, Quality Control Inspection NSRS recommends that requirements be established and implemented in applicable SQN instructions that quality control inspectors conduct random sample inspections of compression-type fitting installation activities. These inspections should be designed to verify and document that these activities are performed in accordance with prescribed requirements. Inspections could be performed af ter installation but prior to hydrostatic testing.
(P2)
SQN Response to I-85-329-SQN-01 NCR WBN-6278R1 was transmitted to SQN Engineering Project (SQEP) by reference 3.
A request was made to perform a review and determine applicability to SQN by reference 2.
The NCR was then forwarded to the SQN Regulatory Engineering Section for distribution to the appropriate site sections and inclusion in the operating experience review (OER) program for any generic applicability. It appears that the need for a generic review of NCR WBN-6278R0 was inadvertently overlooked in September 1985.
SQN Response to I-85-329-SQN-02 The plant maintenance personnel responsible for installation and main-tenance of compression-type fittings attended a formal training course, MTU-N&E-28, " Initial Tube Fitting Training," given by the Nuclear Training Branch, Power Operations Training Center (POTC). In addition, the plant Quality Assurance Staf f is working with plant management to determine if the training requirements need to be incorporated into the applicable plant procedures.
SQN Response to I-85-329-SQN-03 The SQN quality control (QC) inspectors attended the training course identified in the response to I-85-329-SQN-02 prior to being assigned verification activities for compression-type fittings. This training provides suf ficient guidance for the QC inspectors to perform the required verification activities.
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. mm uwrTED STATES 00VERNMENT l
Memorandum Tramn VAu2Y AUTHORTTY B45
'860225 259 i
To Those iteted I*O M 8
John A. Rautaton, Qite t sucleer Engineer, V10 C126 C-E FEB 251985 86030550672 @h j,
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SUsJECT:
FUTENTIAL CINE 11C CDEDITION EVALCATION a
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The attached document, OC BC2 627811, describee a condition adverse to quality
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which wee identified at Wette Bar Nucteer Plant. Please examine the attached to j
l determine if thle condition existe in your area of responsibility. The botton l
portion of thle form should be coupleted and thle memorandum tttorned to me within two weeks of the above date. Thould this condition be found to esist la J
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I your area of responsibility, et:e generation of a probten identification report or M
e signific a nt condition report per ?fF-17 le required within two weeks of the 1
above date.
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Memorandum TFMESSEE VAUEY AUTHORTTY B26 '86 0 20 6~ ~ 017 J. C. Standifer, Projoot Manager, Watta Bar Engineering Project, O
P-104 38-t (3)
Cuenter Wadevita, Project Manager, Watts Bar Nuclear Plant OC FROW h
t)ATr.
February 5,1986 W ATTS BAR NUC1 EAR PLANT - A3ME SIGNIFICANT NONC0KTORMANCE REPCRT 6278 El arturcr:
Attached for your review and approval of disposition is NCR 6278 El which we consider to be significant. Please approve and return with attacheJ fora (s) for our document ion purposes.
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D. W. Wilson, DSM, VBN-NUC PR RC 14 napootor, WBN-EUC PR lhp_.&~ [ !
Principally, prepared by R. A. Aikene,'en l 2l 02/06/86 - JCSiMCE DATE REC' JFC ACTION REQ p
l IMS C-E J. C. 1.ana, B1 IN 775-C DATE DUE -
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31 VDsDCA Consp res sic' fittings f or tubing connections have 88Aa88 U.
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agree with manuf acturer's installation J--
ins t ruc tions. These discrepancies are as 7I L.
fallows:
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- a. Tube cuts cot deburred
- b. Tube not bottomed out in fitting (See attached continuation page I
e Aapes =t case:
"i t ng join hwr no a ted to e e or p I
Pressure testing.
Easponsible Organ (sation 17U/02 Dee _bOM L waans, O Dam, f-fd f4 Aacro d,
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toose su mus Decas samast Deficiency 1 - VSE OC and NUC F1 shall establish measures for documented trata-ing of their respective craf t personnel involved with compression fitting Inspect drain connections to the closed drain system which do ins talla tion.
require bydrostatic testing and are subjecta J to potentially radioactive manufacturer's not service. These inspections shall be in accordance with t Dame
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==== mean T W M W A44 Vatte Ear Nuc Plant esmanus Description continuada LA 2
- c. kt not completely covering threads
- d. Miseing f atrule
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- e. taversed ferrule
- f. thidentifiable ferrule j
Engineering drawings 47V600 series and 47BM600 serine spazify Deficiency II:
t-Id the use of either an Imperial-Kas'tman (I-E) 783-FSS or a Parkar Bannafin CPI T182-SS 1/2 to 1/4 inch tube end reducer (ik 2SA), but should specif y only the use of.1-R reducer.
The reducer cornects to a Dragon pensi isolation valve (Mki)
The Parker tube end reducer is e hard I
with an I-E ficting.
is not meterial which is machined for a Parkar ferrule and Because of the designed to be used with the I-E f errule.
hardasse and the machined groove, the I-g ferrule does nots 3
basard.
Apparent Cause continued:
Deficiency Ils tre r in the 47BM600 drawings allowing the use of incompatible fittings.
y Correction Method continued 3
Deficiency Is instructione to verify proper tube debarring, tightening requirements, and ferrule type and orientation.
All eye'tems subjected to hydrostatic testing or posumstic I
~-
although lash tightness is achieved.
h indicate testing have been verified with leak ti@t joints whic adequata joint makeup for pressure retention.
Rowever, of shall provide vibrational asalysis for connectione in which the tube is not bottoemd out in the fitting, nets not f
properly tightened, ferrulee reversed, and deburting was
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Deficiency It k
cs to evaluate compression fitting installation to determine the need for possible T7A process specification revisions.
j Deficiency II:
g Correct drawings to specify the use of only "special-F.astman i
78}-FSS tube end reducer. Inspect panals and replace Parkar
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'O CORRECTIVE ACTION RESPONSE EVALUATION b7d'-38 7" 9
REPORT NO:
SUB3ECT:
0A C0WTR0LS foR Cohn F 9 E_<f/0W FITTINGS INSTAL L ATroN YY-[S"$[E ~$$)
CONCERN NO:
OACCEPT REJECT DNE y (B05 969+04 0 0 2-) to L 3 3 9-SON-0I NWb
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L*NITED STATES GOVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY B05 '86 0 4 0 4 00 2 K. W. Whitt. Director of Nuclear Safety Review Staff E3 A8 C-K TO W. C. Drotleff, Director of Nuclear Engineering, W12 A12 C-K "0M April 7, 1986 DATE
.?!R? REPORT NO. I-85-329-SQN, FINDING I-85-329-SQN-01, " EVALUATE COMPRESSION FITTING INADEQUACIES OF NCR WBN-6278 FOR GENERIC APPLICABILITY"- M j
herhnee: Your memorandum to H. L. Abercrombie and R. W. Cantrell dated February 13, 1986 U$$e reference memorandum under Section IV, " Conclusions and mendations," you addressed four recommendations. They were f f$,", R cca 329-SQN-01, Evaluate Compression Fitting Inadequacies of NCE WBN-6278 for j
1 ic applicability; I-85-329-SQN-02, Noninspection Personnel Training; wt 329-SQN-03, Inspection Personnel Training, and I-85-329-SQN-04, Quality BJN gener wcs I #"
G*ol Inspection. The only recommendation which involves the Division of uclaar Engineering is I-85-329-SQN-01.
DNE has reviewed this recommendation WG and has the following comment:
When NCR WBN-6278 R0 was issued by the Office of Construction, they (OC) rARG Since were not yet following the intent of paragraph 4.5.1.2 of OEP-17.
then, the Office of Construction started following paragraph 4.5.1.2 of OEP-17, and NCR WBN-6278 R1 along with SCR 6278-S R0 (identical to NCR j g g.g The SCR form goes into more detail, WBN-6278 Rl) was issued.
particularily in the generic condition area than the NCR form which was used for NCR WBN-6278 R0.
The "gendric block" on NCR WBN-6278 R0 had been marked "yey" and was justified by saying "this condition is. applicable to all compression fitting installations within the scope of the WB QA program."
i DNEdiUnotreviewNCRWBN-6278ROforgenericapplicabilitybecauseOC However, since NCR WBN-627d R1 and SCR had already indicated it was.
6278-S R0 have been issued, DNE has issued a generic memorandum dated February 25, 1986 (B45 860225 259).
28, 1986, to require assessment of the generic l
OEP-17 was revised on March implicatiens of NCRs/SCRs/ CARS initiated by Construction or Operations and referred to DNE for disposition.
S
. C. Drotleff JFW:WDD:MBP cc: RIMS, SL26 C-K J. A. Raulston, W10 C126 C-K J. C. Standifer, P-104 SB-K J. F. Weinhold, W12 B34 C-K QA Record W. D. DeFord, W12 B32 C-K OE01 - 1685E L
EA 03/12/86 Ruv 11.S. Savines Bonds Regularly on the Payroll Savin;:s Plan i
L44 860730 816 ATTACHMENT c 5080100038 SN 157B Lookout Place 37402-2801 J
Chattanooga, Tennessee s
WBRD-50-390/85-43 WBRD-50-391/85-42 U.S. Nuclear Regulatory Comission Region II Dr. J. Nelson Crace, ReE onal Adelnistrator l
Attention:
101 Marietta Street, NW, Suite 2900 Atlanta, Coorgia 30323
Dear Dr. Grace:
SION WATTS BAR WUCLEAR PLANT (WBN) - UNITS 1 AND 2 - QU
/85 42 -
FITTINGS ON INSTRUMENTATION TUBItiC VBRD-50-390/85 43, WBRD-50-391 FINAL REPORT t
The subject deficiency was initially reported to NRC-Region II Inspec or 1985, in accordance with 10 CFR 50.55(e) as Al Ignatonis on September 24, Previous interim reports were submitted on Oc 1985, and WBN 6278.
Enclosed is our final report.
j January 31 and March 31, 1986.
v Delay in submittal of this report was discussed with Morris Branch on
~3 July 17, 1986.
t If there are any questions, please get in touch with J. A. Mcdonald a N
(615) 365-8527.
Very truly yours, N
TENN SS E V
.Y AUTHORITY N
R. L. Crldley Director Nuclear Safet and Licensing o
Enclosure cc (Enclosure):
Mr. James Taylor, Director OffLee of Inspection and Enforcement U.S. Buclear Regulatory Commission Washington, D.C.
20555 Records Center Institute of Nuclear Power Operations 1100 circle 75 Parkway, suite 1500 Atlanta, Coorgia 30339 RM3:EFF:5CP cc (Enclosure):
R. A. Padde, 9-169 SB-K RIMS _ww AM 72Af J. A. Raulston, W10 C126 C-K
- f. W. Cantrell, BE IN 768-C NRC Resident Inspector, Watts Bar E. R. Ennis, Watts Bar-ONP Cuenter Wadewitc, Watts Bar WU COU R. 3. Kelly, LP AN 45A-C J. A. Mcdonald, Site Lie, WBN-ONP COORDIMATED: DNE/Prahl WBM/Fickey b.c. LSC, LP SN 106B-C
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l ENC 1.OSURE WATTS BAR NUC1. EAR PLANT UNITS 1 AND 2 QUESTIONABt.E COMPRESSION FITTINGS ON INS WBRD-50-390/85-43, WBRD-50-391/85-42 NCR 6278 10CFR50.55(e)
FINAL REPORT Description of Defieloner l
concerns TVA has identified through its employee concern program (map oyee that various IN-85-795-001 and 002) and, subsequently through NCR 6278 R0, i h fitting compression fitting installations were not in accordance w tThese compression manuf acturer's installation reconvnendations.used for inst tions on various systems throughout the plant. compression fitting joints include insta d
with manuf acturer's recomunendations. fittings as well as Imperial Eastma l
107 compression As a result of these employee concerns, a sample inspection of fittings used in instrument or sarpling lines was perf ormed and 60 i
discrepancies identified which fall in the fo11 ewing general categor es:
t inside the tubing cuts were not deburred; tubes were not bottom
- o unidentifiable, missing, or reversed.
J d
and inadequately attributed to inadequate or nonexistent site proce uresThis resulted from inadequ T
trained construction craftsmen.
'q of requirements.
nnel After this sample inspection was completed. WBK maintenance perso i
1 to NCR identitled an additional category which was then incl ih t tubing to N
Imperial-Eastman "HL-Seal" nuts and ferrules as a means to conneeThese 6278.
N instrument panel isolation valves.
(It should be noted that these type with manuf acturer's reconvnendations.
The cause of this installations are not in the ASME code boundary.)
i hich particular condition was determined to be an error in TVA draw ngs w CJ d reducers.
allowed the use of either Parker or Imperial-Eastman tube en Safety laelications i
la general, without adherence to manufacturers' recomunendations du lastallation, compression fittings may not totally seal which would All " closed-ended,". safety-related instrumentation This testing leaking connections.
tubing receives hydrostatic or pneumatic pressure testing. f the eliminatas any concern with the adequacy of the initial seal oHow l plant operation or compression fittings.
adequacy of the seal due to vibration induced during normaEither of th during a seismic event.
l leak. Also, allowing the vibrations to loosen the fittings and deve op a testing burrs in instrumentation tubing would not be detected during pressure t l flow castriction.
and could lead to an accumulation of " crud" and an even dings of d the type of varying degrees depending on the instrument in question ansuc p roblem.
l
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.py f and vent lines, the lines i
In the case of open-ended instrument tubing, dra ns,to inadequate fittings would be are not pressure tested and any leakage dueificant pressure behind it.
i minimal as such leakage would not have s gn gorrective Action identified in Revision 0 A compression fitting testing program for those items This Material Laboratory.
of NCR 6278 was performed at TVA's Singleton due to the presence of i
t program included testing of the ef f ect on flow ra e ith various installation i
s tubing burrs; testing of the integrity of fitt ngs w i i l
by tensile pullout and vibration fatigue tests; and se sm c t
s where The results of these tests showed that for the ins ancettomed defielencies.
tube ends were not deburred, tubes were not bo event tests.
ill be satisfactory even properly tightened, fitting perfonnanes would st integrity. Also, normal though there would be some reduction in fittingleaks in any of the semples tested l" ferrules installed backwards),
operation fatigue testing exhibited no(including Imperial-gastaan r and seismic event testing only produced veryThe seismic tests are conservative in 2 of 47 samples.
the pressure gauges) and are a severe test of fitting integrity.
1, fied ferrules, it was f
7 For fittings with alssing, reversed, or unidenti i ite leak during detentined that a missing ferrule would cause a def n 3
" cpi" fitting, Q
hydrostatic testing; a reversed ferrule would leak if it was a d that the but would not leak if it was a reversed "Hi-Seal" fernale; an rt was probably a g
T unidentified ferrule noted on the nonconformance repot nut tightening. This 4
N reversed ferrule which had been distorted by subsequenhas been found to leak i
specific case was a " cpi" fitting, and this condit onBecause of this TVA has de g
tions, unacceptable during pressure testing.
three particular types of questionable ferrule installa to leakage or 9
N installations would be detected during hydrostatic testin g
h would be no g
driving force to create any significant leakage.
2 these type fittings Overall TVA ha's' determined that it is acceptable to use"as-ot subject to p
.]p pressure tests but could see radioactive service, anOn lines that are panels which may not have been hydrostatically tested.been pressure tested a Q
oubject to pressure testing, those that have already that they will
(
acceptable as their lack of leakage is sufficient assurancelled on unit 2 lines Q
i provide satisf actory service, and those fittings insta he time of normal j
which have not Tot been tested will be replaced at t 7
hydrostatic testing if they leak.
7 re tested j
For those fittings seeing radioactive service in lines not pressu t d and any (e.g., drains) TVA plans to have the connections reinsrec e l
d by fuel discrepant fittings found during this reinspection will be rep aceFor th i
inspect all the panels for safety-related instrumentation for leak ng lood for each unit.
during hot compression fittings during initial heatup for unit 1 and l
functional testing for unit 2.
~
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. With regard to the Parker-Hannifin tube end reducers installed with the Imperial-Eastman "Hi-Saal" nuts and f ermles. TVA has detennined through l
tensile and vibration tests and analysis that fittings with this type discrepancy are functionally reliable and all existing installations are acceptable as-is.
To prevent recurrence of the type problems in revision 0 of NCR 62T8, TVA has revised Construction specification C-29, " Process Specification for Welding.
Hest Treatment, Non-destrtetive Examination and Allied Field Fabrication operations " to detail the requirements for installation, remake and inspection of coerpression fittings. These requirements have been incorporated into the Division of Nuclear Constructions' (NU COM) Quality Control Procedure QCP 3.13-6, " Installation and Inspection of Tubing Instrument Lines," as well 3.13. " Mechanical Tube Fitting Installer as Quality control Instruction (QCI)
Performance Certification," to which applicable NU COM craft have been trained Work on compression fittings which would be done by operations and certified.
personnel will be controlled by MAI-29, " Instrument Tube Fitting and Installation" which is scheduled to be issued by August 15, 1986.
To prevent a recurrence of the type problem identified by revision 1 of this NCR, TVA has revised its applicable drawings through ECN 6313 to specify use N
it is to be of tube end reducers made by the same manufacturer as the fittin6 7
mated with.
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.t u.mTED STATES GOVERNMENT S03 8G1009 805 Memorandum TENNESSEE VALLEY AUTHORITY To W. R. Brown, Program Manager, Employee Concerns Task Group, ONP, Watts Bar Nuclear Plant FROM H. L. Abercrombie, Site Director, ONP, O&PS-4 Sequoyah Nuclear Plant DATE October 20, 1986
SUBJECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK GROUP (ECTG) ELEMENT REPORT 802.01 SQN R1 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated September 12, 1986, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECTG) Element Report 80201-SQN - Inspection Criteria (Sequoyah)" (T25 860916 991)
I acknowledge receipt of your element report and in accordance with your request (see reference). Element Report 802.01 SQN R1 has been reviewed for applicable corrective action.
By this memorandum I am endorsing the site line organization CAPS and attaching these CAPS for your review and concurrence in response to your CATD 80201-SQN-1 and CATD 80201-SQN-2. These CAPS are not restart requirements.
If you agree with the proposed CAPS, please sign the ECTG concurrence space below item 9 on the CAP tracking checklists and return the CAP tracking i
l checklists.
JNLb???
H. L. Abercrombie RCD:JDS:JB:CS Attachments RECEIVED cc (Attachments):
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ATTACHMENT D k
,d ECSP CORRECTIVE Action Tracking Document (CATD)
INITIATION 1.
Immediate Corrective Action Required: /[/ Yes /X/ No 2.
Stop Work Recommended:
// Yes /X/ No 3.
CATD No.
80201-SQN-01 4.
INITIATI0li DATE 1/8/87 5.
RESPONSIBLE ORGANIZATION: Office of Nuclear Power 6.
PROBLEM DESCRIPTION:
/X] QR /;/NQR As identified in this Element Report, vendor welds made by Southwestern Engineering Co. (SECO) were substandard and required rework.
Corrective actions for these welds did not include a sample inspection produced of welds produced by SECO.
NOTE: This CATD was revised to eliminate reference to National Valve and Manufacturing Co. (NAVCO) Welds.
o /
// ATTACHMENTS 7.
PREPARED BY: NAME R. D. Jialverson _ M DATE: 1/8/87 CEG-H / 4 4 # K //kf e /
DATE: 1/8/87 8.
CONCURRENCE:
A 9.
APPROVAL: ECTG PROGRAM MGR:
DATE:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN:
/ / ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONDURRENCE:
CEG-H DATE:
SRP:
DATE:
ECTG PROGRAM MGR:
DATE:
VERIFICATION AND CLOSEOUT l
l l
13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
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Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Number j4iff,4/ f4WE///
Lend Organisation Responsib'le for Corrective A'etion Plan CORRECTIVE ACTION PLAN (CAP) 1.
Does this report require corrective action?
Yes No M (If yes, describe corrective action to be taken, if no, provide justification)
Sct. - MA ckM EA/T" ' T 2.'
Identify any Similar item / instances and corrective action taken.
M v&JE AWatastro N
& se>R' fac ' U w) fEce SW A:a:6 4
3.
Will corrective action preclude recurrence of findings!
Yes No Does this report contain findings that are conditions adverse to 4.
quality (CAQ) as defined by AI-12 or NEP 9.1?
...e Yes No A
5.
If a CAQ condition exists, what CAQ document was initiated!
O 6.
Which site section/ organization is responsible for corrective action?
Coocc1?4 Ar?M (scrMin er tddl) ca.pla w der firy ftemM-7.
Is corrective action required for restart?
Yes No ><
(This determination is to be made using the " Criteria for Determination of Rectart Items" in accordance with the Nuclear Performance Plan, Volume 2.)
8.
P2 zone number for restart corrective action? Zone 9.
Estimate completion date for corrective action.
Completed By
/
Nm+ I te
/#-Af%
Approved By
%JNhm Date in-2-@f ECTG Concurrence Date SRP Concurrence Date CAP CLOSURE 10.
Was your corrective action initiated and completed in accordance with step 1?
Yes No 11.
If step 10 is no, describe the corrective act. ion taken.
12.
Is the corrective action implementation complete!
Yes No 13.
Is the corrective action documentation closed!
Yes No 14.
What documents were used to implement the corrective action!
Completed By:
Date Verified By:
Date ECTG Closure:
Date
~
Continued on back page
Attachment T
Reference:
ECTG Report CAT D 80201-SQN-1 (T25 80916 991)
In reference to the ECTG report effort, it should be noted that both concerns investigated (JAN-8-001 and JLH-85-005) were:
1.
Specific to a referenced location job or 2.
Investigated by the site manager for whom the concerned individual reported his concern.
3.
The concerned individual in both cases was satisfied with the response.
Additional comments are provided for each concern.
Concern JAN-85-001 Contrary to the investigator's report, SECO does not reference Sentry Equipment Corporation but references work performed by Southwestern Engineering Company (SECO). SECO has performed work at Sequoyah only once, with that occurring between September 1985 and November 1985. The concern was received November 26, 1985. Sequoyah Modifications requested that Sequoyah QA perforn a survey on the referenced work.
This was accomplished by QA and documented on an in-plant-survey checklist (21-85-5-021). Additionally, a SECO QA representative returned to Sequoyah to participate in the evaluation. Deficient welding was corrected by TVA and a warranty clais.was submitted for processing.
It is therefore concluded that the inspection / review effort did include the majority of welding performed by SECO with repairs being completed accordingly; thus, no additonal surveys are warranted.
Concern JLH-85-005 The review of this concern included a discussion with an individual (L. G. Herbert) who was the cognizant construction inspector during the time that NAVCO')iping was received onsite at Sequoyah.
He stated that a similar concern was expressed in 1976 to the visual adequacy of NAVC0 welds. This concern was satisfied by reviewing radiography film of the potential worse-case basis. The effort concluded that although the welds were not ground flush or at least smooth, as was the TVA practice, the welds were satisfactory (passed X-ray criteria).
Reference memorandum from L. G. Herbert to J. L. Hamilton dated May 29, 1986.
Sequoyah has recently completed a study on welding which was performed by contractors, TVA weld project personnel, ANIS, QA organizations, and others. This effort included a review of field welds performed both by TVA and contract suppliers. The conclusion reached by these parties was that Sequoyah welding practices were acceptable. Reference Welding Task Force Report L44 860207 800 and later revisions.
n i
(
Many cf ths NAVC0 wilds havs bssn insprctsd as ptrt of tha in-ssrvice-inspection program required by Section II of the ASME Code. Others will be inspected as the program (SI-114) continues through the plant life.
These inspections have yielded no evidence of an abnormal rejection rate in NAVC0 welding.
Based upon these efforts, it is concluded that no justification exists for additional surveys.
DA:GDL 10-1-86 0212M b
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UNITED STATES GOVERNMENT
^
NCMOTdMdMM
. TENNESSEE VALL$Y AUTHORITY John L. llamilton, Jr.', Supervisor, Quality Engineering / Quality Control, To ONP, Sequoyah Nuclear Plant FROM 4
Leo G. liebert, Quality Assurance Evaluator, DNQA, WBN, ONP, DATE
- May 29, 1986
SUBJECT:
WELD RADIOGRAPil REVIEW f=
This memorandum is in response to 'our conversation on April 17 and May 23, 1986 regarding a review of weld radiographs at NAVC0 Corporation, Pittsburgh, Pennsylvania.
In early 1976, March / April, verbal concerns were expressed by the craft welders at Sequoyah Nuclear Plant in r.egards to the poor visual appearance of NAVC0 spool piece welds; yet the Construction Quality Control inspectors were rejecting welds that appeared' to have a higher standard of quality.
b
+
Arrangements were made with Mr. Robert Jackson.of NAVC0 for me to review radiographs at their facility. A walk-through, utilizing construction management, was made; welds were selected on a worse-case basis; and photographs were taken to allow'NAVC0 personnel to understand our concern.
I made a trip to Pittsburgh, Pennsylvania and reviewed the radiographs of the selected welds; even though the velds did have a poor visual appearance, all radiographs reviewed did meet the appropriate quality standards.
For
' record purposes, it should be noted that at the time of this action, I was a certified Level III in RT, PT, MT and UT in accordance with SNT-TC-1A.
9 I am certain that correspondence was written concerning this, situation and the visit to NAVCO, but due to organizational changes and the time frame involved, I do not know if it could be retrieved.
IfIcanbe.of$urtherassistance,pleasedonothesitatetocallmeat Knoxville extension 6863 or Watts Bar extension 3516.
SQN StTE QUALITY MANAGER'S OFFICE
. Leo G. Hebert LGH:FC JUN 0 2'86 l
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j ATTACHMENT E
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ECSP CORRECTIVE Action Tracking Document (CATD)
INITIATION 1.
Iunnediate Corrective Action Required:
/Y/ Yes // No 2.
Stop Work Recommended:
// Yes /X/ No 3.
CATD No.
80201-SQN-2
- 4. 71HITIAT10N DATE 9/12/86 5.
RESPONSIBLE ORGANIZATION: Office of Nuclear Power 6.
PROBLEM DESCRIPTION:
/X/ 'QR /[/ NQR Concern XX-85-050-001 (Findings Section) indentities the lack of
+
~
specific training requirements in the following documents:
QC-4 Revision 2, " Quality Control Instrumentation" -- No modules for training.
AI-14, Revision 30, " Plant Training Program" -- Courses listed do not include tube fittings.
MI's' SMI-1-68-20, Revision 1, and IMI-ll8, Revision 5, -- Do not specifiy personnel training requirements.
NUC PR Ouality inspector Training Manual - No instructions in insoection of installation of compression type fittings.
/ /ATTAClu1ENTS
_m 7.
PREPARED BY: NAME R. D. Halverson M
DATE: 9/////W 8.
CONCURRENCE: CEG-H
'/-(C//V/~ - /--
DATE: 9V2-PG 9.
APPROVAL: ECTG PROGRAM MGR:
DATE:
CORRECTIVE ACTION 10.
PROPOSED CORRECTIVE ACTION PLAN,:
Scv AT7ygehsc
///ATTAGlu1ENTS p 3, rf f
11.
PROPOSED BY: DIRECTOR /MGR: ~/ft/uz///////Z/r#
DATE:///#/#
12.,
CONCURRENCE: CEG-ll DATE:
SRP.:
DATE:
ECTG PROGRAM MGR:
DATE:
VERIFICATION AND CLOSE0UT 13.
Approved corrective actions have been verified as satisractorily implemented.
SIGNATURE TITLE DATE f.
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e' t
V Page 1 of 2
~
Corrective Action Plan of Employee Concern Investigation Tracting Checklist CMV[#
- 2. //.J'#A/
~Z ECTG Report /CATD Number Lead Organization Responsible for Corrective Action Plan C oW-rT.
CORRECTIVE ACTION PLAN (CAP) 1.
Does this report require corrective action?
Yes V No (If yes, describe correc ve action to be taken, if no, provide justification) k enod
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2.
Identify any similar item / instances and corrective action taken.
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3.
Will corrective action preclude recurrence of findings! Yes AC No 4.
Does this report contain findings that are conditions adverse to cuality (CAQ) as defined by AI-12 or NEP 9.1?
Yes No k 5.
If a CAQ condition exists, what CAQ document was initiated!
c // 4-6.
Which site section/ organization is responsible for corrective action?
317E 77 w // M Reno /
AGc
/$WJa.)
C8 sf.T~W 7.
Is corrective action required for restart!
Yes No )(
(This determination is to be made using the " Criteria for Determination of Restart Items" in accordance with the Nuclear Performance Plan, Volume 2.)
8.
P2 zone number for restart corrective. action! Zone
///A7 9.
Estimate completion date for corrective action.
A f /A Completed By dd M.ex-Date
/e-/-B6 Approved By R M&.,1 Date
/0 74.
ECTG Concurrence Date SRP Concurrence Date CAP CLOSURE 10.
Was your corrective action init. lated and completed in accordance with step 1?
Yes No 11.
If step 10 is no, describe the corrective action taken.
t i
12.
Is the corrective action implementation complete?
Yes No 13.
Is the corrective action documentation closed?
Yes No 14.
What documents were used to implement the corrective action?
l Completed By:
Date Verified By:
Date ECTG Closure:
Date Continued on back page
m
~.
Rsfersncs: CATD 80201-SQN-2 All instrumentation attached to the RCS is restricted by special 3/8-inch transition couplings, thus restricting the amount of leakage to that which the charging system is capable of normally making up.
All instrumentation attached to other systems important to safe operation of the plant are provided in redundancy (Trains A and B).
Based upon these facts, I conclude that a break in the line or a defective tube-fitting would not create an unsafe nuclear operating condition.
Sequoyah safety procedure' ( AI-3) requires personnel working on systems or system components to obtain appropriate hold orders on clearances.
In addition, a recent study completed by Singleton Laboratory (F01 851211 601) in response to employee concerns at Watts Bar Nuclear Plant concluded that improperly installed fittings would not be a problem if they did not leak and that leaking, fittings would be repaired before an unsafe condition would exist.
It is therefore concluded that if existing procedures are followed, the potential for personnel injury is minimum.
Appendix B of 10CFR50 requires procedures and inspection programs be established and executed for work on safety-related equipment. The level of detail is not stated.
Sequoyah performs all CSSC work in accordance with written procedures (specifically work requests and workplans) which appear to meet Criterian V requirements. The level of detail is determined by the complexity of the task which may generate specific instructions such as MI's, SMI's, etc.
Additionslly, all of the work documents are reviewed by QA for adequacy and adherance to applicable requirements including the establishment of QC hold points which seems to meet Criterian X requirements.
It should be noted that neither Criterian V or X specifically states the level of detail of instructions or that specific QC hold points be established. These determinations are the responsibility of the utility in accordance with applicable codes, etc. I therefore conclude that Sequoyah is in compliance with these requirements.
l In response to the specific problems addressed by the investigators, the following comments are provided:
1.
QC 4 is an instruction utilized by the Construction organization during the construction phase of the plant. It has not been used at Sequoyah for several years and never by Nucl, ear Operations.
Therefore, no corrective action is required.
2.
AI-14 does not list all courses required or taught at Sequoyah. The original intent of this instruction was to address minimum training requirements for employees at Sequoyah.
Additional requirements were implemented through the initiative of plant supervisors in response to conditions adverse to quality, and other directives such as the referenced memorandum from W. T. Cottle. These requirements were initiated administratively by memorandum as was the case in the l
0..
D d
W. T. Cottla memorcndua.
AI-14 is currcntly being ravis:d with additional reference to tube-fitting class MTU-MMT-28 referenced.
The estimated completion date is December 8, 1986, per discussion with Doug Bateson, Sequoyah Training Officer.
3.
Personnel training requirements are not placed in procedures on a general basis. Reference to AI-14 or section requirements are sufficient to address this. Therefore, no revisions are necessary.
4.
The QA supervisor (John L. Hamilton) for engineers and inspectors responsible for review of work documents and inspection activities has directed his representatives to insure,that requirements are placed in maintenance requests and workplans to use only qualified, trained, maintenance personnel for tube-fitting installation and that inspectors assigned to the related inspection activities are trained in tube-fitting practices.
Approxlmately ten QC inspectors have attended MTU-MNT-28 to date. The mechanical inspector training class will be revised to include tube-fitt,ing inspection criteria and additional inspectors certified as they return to the Power Operations Training Center for recertification.
DA:GDL 10-1-86 0210N
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Page 42 of 62 Rev. 50 Appendix H PLANT INSTRUCTION REVISION REQUEST ROUTING
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_ Responsible Supervisor /Date Approved
/
'_ Originatorts Supv./Date Approved Np.
- 2. Administrative Services - Date Received Approved Ns.
Adm Sys, WPU Supv
- 3. SI Scheduler (sis Only)- Date Reviewed Approved
)
4 Plant Instruction Revision Request (To be filled out by originator of revision request and routed to appropriate section supervisor.)
}
Originator ed3 Te#WO Date [8'[ -8I, Instruction No.
MZ- [
Title
/Y4/Adpf d7M73~ --
L Page Numbers Affected
~T, 28
~ MATS #
CATS #
0 CAR #
THIS REVISION IMPLEMENTS SOURCE DOCUMENT:
(NQAM, Area Program, etc.)
I Summary desp,ription of Revision (If possible, marked up pages on latest revision should be attached). Mf47
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SQNP
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AI-14 f
Page 28 of 50 Revision 33 II. TRAINING OITTLINES (continued)
F.
SPECIALIZED TRAINING (continued)
Those portions dealing with the SQN response are discussed in greater detail. Addionally, the plant's Implementing
_ f Procedures are addressed and summarized during the training.
l Sufficient training must be given to those individuals who are designated in the Implementing Procedures as being re-sponsible for performing various functions during an emer-f gency.
c.
REFERENCE-TVA-REP d.
RESPONSIBILITIES-The SQN Project Engineer (REP) or a designated alternate shall be responsible for administering this training.
l fL DOCUMENTATION-A training roster will be completed and provided e.
to the SQN Training Office for all persons successfully complet-ing REP training.
A f.
RETRAINING-Annually g.
TRAIN Code - REP 6.
HEALTH PHYSICS SCIENTIFIC AIDE AND TECHNICIAN QUALIFYING PROGRAM.
PURPOSE-The objective of these HP training programs is to
~
a.
ensure a fully qualified HP staff is maintained to assist in the safe operation of TVA's Nuclear Plants. In achieving this objective, TVA complies with NRC regulations.
l b.
SCOPE-The positions covered by this training include HP
- scientific aides, dosimetry engineering aides, HP technician trainees, HP technicians, and contract HP technicians.-
c.
REFERENCE-PMP 0202.12 d.
RESPONSIBILI1Y-The HP section supervisor for coordinating the training required for the HP staff and ensuring staff members maintain appropriate qual'ifications.
DOCUMENTATION-The associated training documentation will be e.
maintained at the POTC as described in the HP administrative section instruction letter (HP ASIL) -3.
f.
This training program is completely described in HP ASIL -3.
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SQNP AI-14 Page 3 of 50 Revision 33 r-D.
RESPONSIBILITIES (continued) 4 (continued)
~
f (e) Ensuring that all temporary and service personnel under their cognizance are trained to the extent necessary to assure safe execution of their duties
-(for unescorted access, see Appendix B).
f (f) Reviewing the Plant Training Office computer status c
Y program printout of plant personnel issued to the 4
section and report to the Training Office an errors f
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The Health Physics (HP) Supervisor shall be responsible for approving the HP GET plan.
6.
The plant Public Safety Supervisor shall be responsible for providing training and retraining in " Plant Security and Emer-gency Plans" (GET 3.1) and " Drug Awareness" (GET 3.2).
I 1.
7.
The Nuclear Training Branch is responsible ~ for the development and update of the courses in the GET program through the utili-zation of information provided by the plants, the DNQA Quality y
Systems Branch, and other ONP personnel. This responsibility includes ensuring that the course material is in compliance with the various regulatory guidelines which are applicable.
l 8.
When revisions occur to courses under the responsibility of y
the Flant Training Office, Attachment 4 shall be completed.
[
g Any revisions shall be reviewed by the plant Training Officer and the responsible site supervisor for completeness, accuracy, and applicability to Sequoyah Nuclear Plant. When a review discloses discrepancies between the course and Sequoyah plant l
procedures, the Plant Training Office will initiate a formal revision request form.
9.
The supervisors of the sections below listed shall be respon-sible for providing plant specific information for GET training l~
j packets and instructors for the other designated courses. They shall also notify the Training Officer when revisions to docu-ments or plant procedures covered in this training indicate the possible need for revision of GET courses and/or retraining of plant personnel in a particular subject. For all other courses, designated supervisors shall be responsible for the development and maintenance of complete training packets. dach training packet will have as a minimum a training outline, audiovisual l
aids where appropriate, and a written examination covering the g
material. Approval of the packets shall be the collaterial re-sponsibility of the Training Officer and the supervisor of the i
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ATTACHMENT F ECSP CORRECTIVE Action Tracking Document (CATD)
INITIATION 1.
Immediate Corrective Action Required: /_X/ Yes /[/ No 2.
Stop Work Recommended:
// Yes /X/ No 3.
CATD No.
80201-SQN-03 4.
INITIATION DATE 1/8/87 5.
RESPONSIBLE ORGANIZATION: Office of Nuclear Power 6.
PROBLEM DESCRIPTION:
/X_/ QR / /NQR As identified in this Element Report, Attachment C (L44 860730 816), TVA committed to the NRC that " work on compression fittings which would be done by operations personnel will be controlled by MAI-29,
' Instrument Tube ' Fitting and Insta11ation' which is scheduled to be issued by August 15, 1986."
To date, no evidence existe that this procedure has been issued.
A./
// ATTACHMENTS 7.
PREPARED BY: NAME R. D. lialverson M DATE: 1/8/67 8.
CONCURRENCE:
CEG-H 7d/t.fE////v / __
DATE: 1/8/87
/
9.
APPROVAL:
ECTG PROGRAM MGR: ' W/
J0s DATE: t/((/#')
CORRECTIVE ACTION 3
10.
PROPOSED CORRECTIVE'AgTION PLAN:
/ / ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR:
DATE:
12.
CONCURRENCE: CEG-H DATE:
SRP:
DATE:
ECTG PROGRAM MGR:
DATE:
VERIFICATION AND CLOSE0UT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE
. - r
(*NITED STATES GOVERNMENT L
gQ8 &.J0123 802 Memorandtt171 TENNESSEE VALLEY AUTH0l!!TY W. R. Brown, Jr., Program Manager, Employee Concerns Task Group, ONP, To Watts Bar Nuclear Plant H. L. Abercrombie, Site Director, ONP, O&PS-4, Sequoyah Nuclear Plant EnoM January 24, 1987 DATE St* HJ ECT:
SEQUOYAH NUCLEAR PLANT (SQN) - EMPLOYEE CONCERNS TASK UROUP (ECTG) ELEMENT REFORT 802.01 SQN R3 - QUALITY ASSURANCE CATEGORY - CORRECTIVE ACTION PLAN (CAP)
Reference:
Your memorandum to me dated January 15, 1987, " Watts Bar Nuclear Plant - Employee Concerns Task Group (ECIG) Element Report 80201-SQN - Inspection Criteria (Sequoyah)"
(T25 860115 915)
I acknowledge receipt of your element report and in accordance with your request (see reference), Element Report 802.01 SQN R3, Corrective Action Tracking Document (CATD) No. 80201-SQN-03 has been reviewed for applicable corrective action.
By way of this memorandum I am endorsing the site line organization CAP, returning your CATD No. 80201-SQN-03, and attaching the CAP for your review / concurrence. This CAP is not a restart requirement.
If you agree with the proposed CAP, please sign the ECTG concurrence space below item 9 on the CAP tracking checklist and return the CAP tracking checkli s t.
e s
/ Yk M H. L. Abercrombie RCD:JDS:JB:CS "
Attachments RCCEIVED cc (Attachments):
RIMS, MR 4N 72A-C (S02 870121 952)
M '.' D,D7 0571T Eninge: c_m e,r.s Task Duppp*]
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ATTACHMENT F ECSP CORRECTIVE Action Tracking Docunent (CATD)
INITIATION 1.
Immediate Corrective Action Required:
/X/ Yes // No
~
2.
Stop Work Recommended:
/;/ Yes /X_/ No 3.
CATD No.
80201-SQN-03 4.
INITIATION DATE 1/8/87 5.
RESPONSIBLE ORGANIZATION: Office of Nuclear Power 6.
PROBLEM DESCRIPTION:
/X/ QR /;/NQR As identified in this Element Report, Attachment C (L44 860730 816), TVA committed to the NRC that " work on compression fittings which would be done by operations personnel will be controlled by MAI-29,
' Instrument Tube Fitting and Installation' which is scheduled to be issued by August 15, 1986."
To date, no evidence exists that this procedure has been issued.
A _/
// ATTACHMENTS 7.
PREPARED BY: NAME R. D. Halverson NW DATE: 1/8/87 8.
CONCURRENCE:
CEG-H 'AC/dE////v- / -
_ DATE: 1/8/87 9.
APPROVAL:
ECTG PROGRAM MGR:
(/)/vfr/cey2/
- 6i DATE
- ///4///'/
CORRECTIVE ACTION e-10.
PROPOSED CORRECTIVE ACTION PLAN:
,fr <
Corre c 8v1 Ac/sk f/n 7~/prJs**.'.7}sc/
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M ems EJ,h1 A 162 920/3/ DTL.
/ / ATTACHMENTS 11.
PROPOSED BY: DIRECTOR /MGR: //[/A 4
- 12.
CONCURRENCE:
CEG-H
~
'4, DATE: /,2f-/9 DATE:
l SRP:
DATE:
ECTG PROGRAM MGR:
DATE:
VERIFICATION AND CLOSEOUT 13.
Approved corrective actions have been verified as satisfactorily implemented.
SIGNATURE TITLE DATE l
l
(
,b Standard Practica
. Page 9 SQA166 Revision 8 C.
ATTACID4ENT A Page 2 of 2 CAP CLOSURE
- 10. Was your corrective action initiated and completed in accordance with step 17 Yes No
- 11. If step 10 is no, describe the corrective action taken.
- 12. Is the corrective action implementation complete?
Yes No
- 13. Is the corrective action documentation closed?
Yes No
- 14. What documents were used to implement the c'orrective action?
Completed By:
Date Verified By:
Date ECTG Closure:
Date (Step No.)
Description 0206S/mit
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y S02 U61203 994 umrco srrres covennneur
' Memorandum TENNESSEE VALLEY AUTIIOltlTY TO R. C. Denney, Employee Concerns Special Project Manager, ONP, DSC-P, Sequoy'ah Nuclear Plant FROM R. W. Olson, Modifications Manager DNC, SB-2, Sequoyah Nuclear Plant DEC O 31986 DATE
SUBJECT:
SEQUOYAH NUCLEAR PLANT - EMPLOYEE CONCERNS TASK GROUP (ECIG) ELEMENT REPORTS - REPORI 173.04 SQN R2 - REVIEW AND CORRECTIVE ACTION PLAN (CAP)
INITIATION
Reference:
Memorandum from W. R. Brown to H. L. Abercrombie dated November 12, 1986, "Sequoyah Nuclear Plant (SQN) - Employee Concerns Task Group (ECTG) Element Report C017304-SQN -
Construction Category - Corrective Action Plan (CAP)
Rejection Transmittal".u(.I25 861112 993)
In accordance with the revised ECIG element report, I provide the additional response:
1.
A memorandum (S02 861202 827) was transmitted to DNE requesting their evaluation of NCR/SCR 6278.
2.
A procedure will be written defining requirements for installation of tube fittings at Sequoyah.
3.
Retraining requirements will be established on a frequency of one year for Modifications personnel and two years for Maintenance personnel, c
YY 4H
'R. W. Olson LDA:GDL cc:
RIMS, MR 4N 72A-C This was prepared principally by L. D. Alexander.
COORDINATION: Rick Collins, DNE; B. M. Patterson,' Maintenance 0293M r
g e.
Bur l!.S. Sat ines Bonels Re cularly on the Payroll Savines Plan s
r
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G Stand,ard Practica Page 8 SQA166 C
Revision.8 Attachment A Page 1 of 2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist ECTG Report /CATD Number _ / ~) 3, C4 5 9Al 8D Lead Organization Responsible for Corrective Action Plan CoAs s'T Initiation Date
//-/ 3-fflo CORRECTIVE ACTIOE PLAN (CAP)
- 1. Does this report require corrective action?
Yes d No (If yes, describe corrective action to be taken, ~if no, provide justification)
._ War; 1/cao S0Z BY/20s WK
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Identify any similar item / instances and corrective action taken.
~
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- " ' ' ' ~
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- 3. Will corrective action preclude recurrence of findings?
Yes
-M.
No
- 4. Does this report contain findings that are conditions adverse to quality as defined by AI-12 or NEP 9.l?
(CAQ)
YES No
)<
- 6. Which site section/ organization is responsible for corrective action?
bdG k
OfobtFtcone,*s
- 7. Is corrective action required for restart?
Yes No X (This. determination is to be made using Attachment C of SQA166.)
- 8. P2 zone number for restart corrective action?
Zone
- 9. Estimate compl'Etion date for correction action.
5"9-f/ 7 Completed By M /dg M -
Date
/2-T'/4 Approved By XfL / gg m-Date
/ 2_ 'J--W6 ECTG Concurrence Date i
t 0206S/mit
lj Standard Peretica Paga 9 SQA166 C-Revision 8
- ATTACHMDIT A Page 2 of 2 CAP CLOSURE
- 10. Was your corrective action initiated and completed in accordance with step 17
- 11. If step 10 is no, describe the corrective action taken.
Yes No
- 12. Is the corrective action implementation complete?-
Yes No
- 13. Is the corrective action documentation closed?
Yes.
No
- 14. What documents were used to implement the ~orrective action?
c Completed By:
Date Verified By:
Date ECTG Closure:
Date (Step No.),
. Description --- -----.
f(
4se l
L l
0206S/mit l
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- Tvp 6 8 (OS 9 691 (OP W7 7 8(I
'UNITr.D STATES GOVERNMENT h S02* Y. 1299 827 i
Me27torandMM1 TENNESSEE VALLEY AUTHORITY TO D. W. Wilson, Project Engineer, Sequoyah Engineering Project, DNE, DSC-E, Sequoyah Nuclear Plant FROM R. W. Olson, Modifications Manager, DNC, SB-2, Sequoyah Nuclear Plant DEC 0 21986 DATE
SUBJECT:
WATTS BAR NUCLEAR PLANT - OC NCR 6278 RO, R1 (SCR 6278 - SRO) AND ECTG REPORT 173.04 SQN R2 (TUBE FITTINGS)
References:
1.
Memorandum from J. A. Raulston to Those listed dated February 25, 1986, " Potential Generic Condition Evaluation" (B45 860225 259) 2.
Memorandum from W. C. Drotleff to K. W. Whitt dated Apell 7, 1986, "NSRS Report No. I-85-329-SQN, Finding I-85-329-SQN-01, ' Evaluate Compression Fitting Inadequacies of NCR WBN-6278 for Generic Applicability' - XX-85-050-001" (B05 860404 002)
Although there seems to be some confusion and procedural variances in the processing of the subject NCR/SCR, a DNE evaluation is required to satisfactorily resolve this employee concern. This item has been
~
discussed among Larry Alexander of the Modifications Group and Rick.
Collins and Adrian Smith of DNE, Sequoyah.
I request that you perform the requested evaluation and coordinate any corrective action with Larry Alexander (6862). The Modifications Group will support you as required.
Your prompt attention will be appreciated.
hAl Ym R. W. Olson
0292M i
M.
Ruov 11.7. 7arsines Bands Reusularlv on the Payroll Savines Plan
,..te.
r-n-
s Standard Practica P:go 8 SQA166 Revision 8 Attachment A Page 1 o'f,2 Corrective Action Plan of Employee Concern Investigation Tracking Checklist '
ECTG Report /CATD Number
/-[d,C[/'f Lead Organization Responsible for Corrective Action Plan Initiation Date CORRECTIVE ACTION PLAN (CAP)
- 1. Does this report require corrective action?
Yes v'
No (If yes, describe corrective action to be taken, if no, provide justification)
GF GC #
/71* W FGA Gwntr'7ve
.-rE;7< /
A'177/Ok71 N.,..,.
2.
Identify any similar item / instances and corrective action taken, sC A Of. dV
~
No
- 3. Will corrective action preclude recurrence of findings?
Yes
- 4. Does this report contain findings that are conditions adverse to quality (CAQ)
YES No L-as defined by AI-12 or NEP 9.l?
/./tP is responsible for corrective action?
- 6. Which site section/organizationj\\
'/ l.
- 7. Is corrective action required for restart?
Yes No 8'
(This determination is to be made using Attachment C of SQA166.)
- 8. P2 zone numbper for sestart corrective action? Zone
-*//
- 9. Estimate completion date for correction action.
Completed By
,df#[.wh Date
/- 2/-[/ 7 Approved By r/2,1 / '/J Date
/- 7 /- $~7 ECTG Concurrence Date 0206S/mit I