ML18033B224
| ML18033B224 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 03/09/1990 |
| From: | Liaw B Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML18033B223 | List: |
| References | |
| 50-259-89-16, 50-260-89-16, 50-296-89-16, NUDOCS 9004020075 | |
| Download: ML18033B224 (10) | |
Text
e ENCLOSURE 1
NOTICE OF VIOLATION Tennessee Valley Author ity Browns Ferry 1, 2, and 3
Docket Nos. 50-259, 50-260, and 50-296 License Nos.
DPR-33, DPR-52, and DPR-68 During the Nuclear Regulatory Commission (NRC) inspection conducted the weeks of November 27 and December 11, 1989, violations of NRC requirements were identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR 2, Appendix C (1989), the violations are listed below.
A.
10 CFR Part 50, Appendix 8, "Quality Assurance Criteria for Nuclear Power Plants,"
as implemented by TVA's Topical Report TVA-TR75-1, requires under Criterion XVI, that measures be established to assure that conditions adverse to quality be promptly identified and corrected.
This criterion also requires that the cause of the condition be determined and corrective action be taken to preclude recurrence.
Contrary to the above, for the cases described below, conditions adverse to quality were either not promptly identified or ineffective corrective action was taken to prevent recurrence:
1.
Conditions adverse to quality associated with engineering calculations were identified by TVA during engineering assurance oversight of the plant's Design Basis Verification Program and Condition Adverse to Quality Report (CAQR) BFN880646 was issued on August 4, 1989 to document these deficiencies.
However, corrective actions taken were ineffective in that calculation problems were again identified by TVA during its QA Safety System Functional Inspection dated December 4, 1989 and by the NRC during this inspection.
Recent examples of core spray system (CSS) calculations where errors were identified by the NRC include, (a)
CSS piping, sizing calculation MD-Q2075-87215, Revision 0, (b)
CSS pump net positive suction head and performance calculation MD-Q2075-87258.
Revision 1, and (c) core spray relief valve sizing calculation MD-Q2075-87216, Revision 2.
2.
Conditions adverse to quality associated with the inability to retrieve welding and base material records were identified by TVA on Corrective Action Report (CAR) 87-0050.
However, corrective action taken was ineffective in that welding-related records required to be maintained by General Construction Specification G-27, which included certified material test reports for 4 filler metals and 30 base metals and weld data packages for 12 instrument line socket welds, could not be provided to the NRC even after approximately three weeks of searching.
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System walkdown of the CSS performed by the licensee on November 5, 1989, in accordance with plant procedure, System Engineering Section Instruction Letter (SESIL)-14, did not promptly identify conditions adverse to quality which included
- damaged, loose, and missing hardware.
This is a Severity Level IV Violation (Supplement I) and applies to Unit 2.
B.
10 CFR Part 50, Appendix B, "guality Assurance Criteria for Nuclear Power Plants,"
as implemented by TVA's Topical Report TVA-TR75-1, requires under Criterion V that activities affecting quality be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with these instructions.
Construction installation of safety-related
- hardware, which is a
gA activity, was accomplished as described below:
1.
Drawings 41N734 and 41DS734 required self-locking nuts to be installed on the embedded pump foundation bolts for the CSS and
, residual heat removal pumps.
Contrary to the above, standard heavy hex nuts were installed.
2.
Drawing 48N435 specified structural steel bearing plate anchor fastener details which included installation of bolts, washers and nuts.
0'ontrary to the above, several plate anchor installations for the structural steel framing at elevation 541'-6" did not conform to the drawing requirements in that washers and nuts were missing and several connections were not tight.
3.
Stand-alone guality Information Notice EEB 821222 901 electrical component mounting details, dated February 4, 1983, specified that all component mounting holes be utilized where possible.
Contrary to the above, Agastat relays located in panel 9-32 and identified as 14A-K123B, 10A-K129A, 10A-K130A, and 10A-K131A which are provided with four mounting holes, were missing one or more mounting bolts.
4.
General construction specification G-38, "Installation of Cables Rated Up To 15,000 Volts," and procedure ECI-0-000-LUG-002 require that electrical cable terminations which utilize a mechanical crimp connection be crimped using the proper tools.
Contrary to the above, the termination for the white conductor for cable 2ES3268-II, which supplies power to CSS discharge pressure switch 2-PS-75-35, was not crimped.
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6.
General Construction Specification G-38 and standard drawing E12.5.8, detail B, note 78, require that shield wire be protected from inadvertent grounding.
Contrary to the above, the shield wire internal to flow transmitter 2-FT-75-21 was bare and loose and could have resulted in an inadvertent grounding.
General Construction Specification G-40 requires that a
wire-protecting devices be installed at the end of a conduit run.
Contrary to the above, conduit wire protec'tion bushings were missing on the conduit junction boxes for panels 25-1 and 25-60 associated with end-devices 2-PS-75-7 and 2-PS-75-16.
7.
8.
Drawing 47W600-46 specified that the floor anchor bolts for floor-mounted instrument racks be 3/4-inch in diameter.
Contrary to the above, all TVA-constructed instrument panels inspected, which included panels 2-25-217 and 2-25-180, were mounted with 1/2-inch-diameter bolts.
Interpretation of radiograph procedure BF-15, Revision 2, which was in effect at the time of construction, requires that the weld and affected base metal meet applicable codes as to wall thickness and weld defects.
Contrary to the above, radiograph film was evaluated and accepted by the reviewer which included unacceptable base metal wall thickness at weld DSC-2-04 and unacceptable weld defects on weld TSC-2-421.
This is a Severity Level IV Violation (Supplement I) and applies to Unit 2.
C.
Technical Specification (TS) 6.8. 1 requires that procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February
- 1978, be established and implemented.
These requirements are implemented, in part, by compliance with the Browns Ferry procedures listed below:
Design procedure NEP 3.2, "Design Input," requires that the design output implement the design input, and deviations must be documented.
Marathon terminal block vendor's instruction (design input) contained in equipment qualification (Eg) binder BFN 2Eg-TBK-002, specifies termination requirements for certain wire sizes.
Contrary to the above, Design Change Notice (DCN) W0482 A (design output) which involved changing wire size from AWG-10 to AWG-4 for motor-operated valve 2-FCV-75-23 did not implement or evaluate the manufacturer's requirement for terminations.
This installation resulted in physical damage to the terminal board and could have resulted in loss of function.
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2.
3.
General Construction Specification G-38 specifies the requirements for cable installation and modifications for safety-related equipment to ensure that the component is capable of performing its function.
Contrary to the above, inspection of containment electrical. penetra-tion "EB" and its associated junction box revealed
- that, Raychem splices were improperly installed, bend radii of electrical cables were violated, and cables were not identified.
Site Director Standard Practice (SDSP)
- 16. 16, Revision 3, "Material Issuance and Return," controls the issuance of material for work on environmentally qualified equipment and requires the proper execution of Material Requisition Form 575.
Contrary to the above, the Form 575 associated with the replacement of a non-EQ terminal board with an EQ terminal board per Work Plan (WP) 2643-89 for devices 2-PS-75-7 and 2-PS-75-16 was annotated as non-EQ and the qualification of the replacement part was indeterminate.
4 ~
5.
WP 2541-88 provided instructions for the removal of wiring to motor-operated valve (MOV) 2-FCY-75-25.
Plant procedure SDSP 8.4, Revision 18, "Modification Work Plans," requires that all work necessary to implement the design change be specified in the work plan.
Contrary to the above, completed WP 2541-88 did not provide explicit instructions for the removal of abandoned unsealed conduit after wiring was removed from environmentally qualified MOV 2-FCY-75-25.
This'ction resulted in negating the EQ of the valve.
WP 2541-88 required that electrical grounding straps be installed across non-conductive flexible conduit.
Contrary to the above, no grounding straps were installed across the non-conductive flexible conduit for valves 2-FCV-75-23 and 2-FCV-75-25, even though the WP was signed off as complete.
This is a Severity Level IV Violation (Supplement I) and applies to Unit 2.
D.
TS 6.8.1 requires that procedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2. February
- 1978, be properly established through technically adequate procedures.
Contrary to the above, core spray Operating Instruction (OI)-75, Revision 14, was not properly established in that the procedure directed postaccident valve manipulation that could have resulted in accident water being diverted to areas outside the contained volume.
2.
Contrary to the above, Surveillance Instruction (SI)-4.5.A.1.D(1) was not properly established in that the acceptance criteria for the
s l
C system flow values were not supported by calculations and did not ensure that the TS requirements were met.
This is a Severity Level IV Violation (Supplement I) and applies to Unit 2.
Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit a
written statement or explanation to the Nuclear Regulatory Commission, ATTN:
Document Control Desk, Washington, DC 20555, with a copy to the Associate Director for Special Projects, Office of Nuclear Reactor Regulation, and a copy to the NRC Resident Inspector, Browns Ferry, within 30 days of the date of the letter transmitting this Notice.
This reply should be clearly marked as a
"Reply to a Notice of Violation" and should include:
(1) admission or denial of the violation, (2} the reason for the violation if admitted, (3) the corrective steps which have been taken and the results
- achieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION Dated at Rockvi lie, Maryland this 9th day of March 1990.
B.
D. Liaw, Director TVA Projects bivision Office of Nuclear Reactor Regulation
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