ML20005G137
| ML20005G137 | |
| Person / Time | |
|---|---|
| Issue date: | 01/12/1990 |
| From: | Grimes B Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML20005G134 | List: |
| References | |
| REF-QA-99900030 EA-89-244, NUDOCS 9001180182 | |
| Download: ML20005G137 (2) | |
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o-BW/IP International, Incorporated EA-89-244 i
Long Seach, California APPENDIX A t
NOTICE OF VIOLATION During an inspection conducted at the Vernon, California facility on i
September 11-14, 1989, two violations of NRC requirements were identified.
In accorcance with the " General Statement of Policy and Procedures for NRC EnforcementActions,"10CFRPart2,AppendixC(1989)theviolationsare listed below:
1.
Section 21.21 " Notification of failure to comply or existence of a defect," of 10 CFR Part 21 requires, in part, that each individual or other entity subject to the regulations provide for evaluating deviations or informing the licensee or purchaser of the deviation in order that the licensee or purchaser may cause the deviation to be evaluated.
i a.
Contrary to the above, BW/IP could not provide documentation to support their basis for informing TV Electric that a deviation reported to them by TV Electric on June 1, 1989, did not constitute a reportable condition pursuant to the provisions of 10 CFR Part 21.
The deviation concerned improper adjustment height of the check valve swing arm which is considered by BW/IP as a nonpressure boundary item however critical to the overa n operation of the check valve.
Disassembly and reassembly of the swing check valves by Comanche Peak personnel, performed in accorcance with Borg-Warner (presently BW/IP) Procedure No. OMM 1003, dated March 15, 1977, caused the valve disc to sit too low within the valve body which led to excessive backleakage through 13 safety-related swing check valves. On June 9, 1989 BW/IP provided an expanded assenbly manual, BW/IP Operation and Maintenance Instruction OMM 2361, originally dated March 5, 1984, to TV Electric to enhance TV Electric's ability to use manufacturers e
l reconsnended reassembly techniques.
However, no other customers had s
l been made aware of this revision nor had the BW/IP Evaluation Board L
performed an evaluation of the deviation in accordance with BW/IP procedures to support their conclusion that the oeviation was not reportable under 10 CFR Part 21.
-b.
Contrary to the above, at the time of the inspection, BW/IP had not initiated an evaluation of a broken cast swing arm or several other swing arms that were metallurgically testeo and determined to have l
material flaws (hot cracks). These deviations were discovered after i
TV Electric performed hot functional testing at the CPSES in May 1969.
I BW/IP had actual knowledge of these deviations since July)1989 when a copy of a Stone and Webster Engineering Corporation (SWEC technical report was nade available to BW/IP during a SWEC inspection of the Vernon facility.
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9001180102 900112
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BW/IP International, Incorporated Long Beach, California in both cases above, BW/IP failed to notify all affected custoners of the deviation which would have resulted in the filing of a 10 CFR Part 21 report if BW/IP had adequately evaluated the deviation (89-01-01).
These two examples have been classified as a Severity Level 111 Violation
. i (SupplementVII).
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For The Nuclear Regulato Commission n/
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rian K. Grines, Director f
Division of Reactor Inspection and Safeguards Office of Nuclear Reactor Regulation Dated at Rockville,jMa.ry16nd This O day of j f e s w, 1990
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