ML20195C769
| ML20195C769 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 10/20/1988 |
| From: | Richardson S NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20195C765 | List: |
| References | |
| 50-327-88-29, 50-328-88-29, NUDOCS 8811030369 | |
| Download: ML20195C769 (4) | |
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ENCLOSURE 1 i
NOTNE OF VIOLATION l
l Tennessee Valley Authority Docket, Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. OPR-77 and OPR-79 the Nuclear Re Ourin 0,1988 to July hulatory Commission (NRC) inspection conducted from, 1988 June In accordance with the "General Statement of Polic Enforcement Actions," 10 CFR 2, Appendix C (1988), y and Procedure for NRC the violations are listed below:
A.
10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants requires under Criterion 38 that a containment heat removal system be provided to remove heat from the reactor containment. Sequoyah FSAR Section 6.2.2 describes the containment heat removal systems and defines the separate systems which provide this capability.
TVA has provided, in part,inment spray system.for such a heat removal system through the design an conta TVA, in SQN-DC-V-27.5, established the design criteria for the containment spray system.
Section 1.1.2 of that document describes the design concept of the system as an energy / heat removal system for the reactor containment.
Section 1.1 of the document establishes this system as being an engineered safety feature.
Section 3.8.1 states that the containment spray system is an essential system.
10 CFR Part 50, Apaendix B is defined to apply to all activities affecting the safety-relatec functions of those systems associated with nuclear power plants includino such activities as design.
Criterion III, Design Control, of 10 CFR 50~, Appendix 8 requires in part that measures be established to assure that the design' basis for systems under Appendix B be correctly translated into specifications and drawings and further that design control measures shall be applied to such items as the following:
reactor physics, stress, thermal hydraulic and accident analysis.
TVA in Nuclear Engineering Procedure (NEP) 3.1, Calculations, Section 2.2 defines, essential calculations as those which address plant systems whose failure could result in the loss of the ability to place the plant ir, the a)propriate shutdown mode.
Further in Section 3.0. it is stated that eaci release of drawings shall be accompanied or preceeded by epproved calculations and analyses.
Contrary to the above, TVA did not have hydraulic and thermal design calculations for the containment saray system, an essential safety system, which established the design basi s for the pressure and temperature boundaries shown on TVA drawing 47W612-1, flow Otagram Containment Spray System Orawing, Revision 16, dated February 16, 1988.
This is a severity level IV violation (Supplement I) 8811030369 001020 gDR ADOCK 050 7
Tennessee Valley Authority 2
Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. OPR-77 and OPR-79 8.
Technical Specification 6.8.1 requires that rocedures recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be established, implemented and maintained, including administrative i
procedures.
The Technical Specifications are implemented, in pcrt, by l
the Sequoyah procedures listed below:
i 1.
Drawi 48N1231 and TVA Modification and Additions Instruction (M and AI) - 9, Tightening, Inspection, and Documentation of Bolted Connections, establish the bolting, configuration and member size i
for the containment spray heat exchanger 18.
Contrary to the above, between June 20, 1988 to July 1,1988, NRC l
l inspectors determined that six of eight fasteners on containment t
i spray heat exchanger IB were loose with two having only one half nut engagement; one assembly had no washer; and seven fasteners had flat l
1 washers instead of the beveled washers prescribed by M and AI-7.
In i
t addition the mounting feet were fitted with three quarter inch bolts i
instead of one inch bolts.
2.
Drawing H21-417 and H21-402 specifies size 12 and 11 spring can for supports 1-C551-408 and 1-CSH-402, respectively.
Contrary to tho above, a size 9 spring can was installed in each Case.
i 3.
Drawing UE 032-12,50-2 specifies one and one-eighth inch diameter holes for the containment spray pump mounting bracket.
Contrary to the above, prior to June 20, 1988, the mounting bracket I
on the vendor supplied pump assembly was enlarged (slotted) apparently to allow alignment with anchor bolts embedded in the j
concrete fou.1dation pad.
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This is a Severity Level V violation (Supplement I).
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1 C.
Technical Spcification 6.8.1 requires that procedures recommended in
)
Appendix A of Regulatory Guide 1.33, Revision 2, February 1978, be established, implemented and mnintained, including administrative procedures.
The Technical Specifications are implemented, in part, by t
the Sequoyah procedures listed below:
1.
4odification and Additions Instruction (M and AI) - 1, Cable Terminations, Splicing, and Repairing of Damaged Cables, implements 1
this Technical Specification requirement for the termination and repair of safety related electrical components.
Section 3.4 of M and 4
AI-7 addresses the minimum training radius values for splices and terminations throu0h the use of outside diameter measurements and j
appropriate calculation data.
Section 5.2 of M and AI-7 addresses j
the repair of damaged cables.
l Contrary to the above, prior to June 20, 1988, motor lead il on flow control valve 1-FCV-72-13 was not trained in accordance with the above referenced calculational method.
In addition, motor leads T1
Tennessee Valley Authority 3
Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. DPR-77 and OPR-79 and T2, and white conductor wire 25 of cable 1A5335 had cable repairs using electrical tape.
2.
Drawing 45N1749-15 implements this Technical Specification require-ment for the landing of green wire 53 and red wire 55 on 1-FVC-72-40.
Contrary to the above, prior to June 20, 1988, both referenced wires were landed incorrectly on terminal 16 of rotor 4 rather than rotor 15.
3.
Standard Practice SQA-66, Plant Housekeeping, implements this Technical Specification requirement in addition to the requirements of the Nuclear Quality Assurance Manual Part II, Section 1.2, Requirements for Housekeeping in Nuclear Power Plants.
Section 5.3.2 of SQA-66 states that if work extends beyond one shift, and is not continuously worked (work will not be resumed for one shift or more) the craftsman shall ensure the work area is left clean.
- Tools, parts, and equipment must be properly identified with area barrier tag or individual pink tags.
It also states that special care shall be taken when opening or disassembling sensitive electrical equipment which may be damaged by dust or moisture.
Contrary to the above, from June 20 to July 1,1988, the components of valves 1-FCV-72-2 and 1-FCV-72-39 were not tagged correctly, nor covered.
These components were stored in an area where penetration seal work was being conducted directly overhead.
4.
Maintenance Instruction MI-6.20, Configuration Control Ouring Maintenance Activities, implements this Technical Specification requirement for the controlled reassembly of safety-related com-ponents. MI-6.20 states that when a configuration change is returned to normal the accuracy shall be verified and documented.
Contrary to the above, from June 20, 1988 to July 1,1988, during an internal inspection of the limit switch component of valves 1-FCV-72-41 and 1-FCV-72-22 loose extraneous material was identi-fled.
The material could Interfere with the proper operation of the component during normal and accident situations.
This is a severity level IV violation (Supplement I).
D, Technical Specification 6.8.1 recuires that procedures recommended in Appendix A of Regulatory Guide L.33, Revision 2, February 1978, be established, implemented and maintained, including administrative pro-cedures.
General Specification G-29, Radiographic Examination of Welded Joints, implements the Technical Specification requirement for weld inspections.
Technical Instruction TI-89, Inservice Testing, required by ASME Section XI, implements ASME Section XI valve testing requirements.
1.
Contrary to the above, TVA procedure G-29 failed to implement ANSI B31.7 weld standard inspection requirements for wall thickness reduction during the qualification of field piping welds.
Tennessee Valley Authority 4
Docket Nos. 50-327 and 50-328 Sequoyah Units 1 and 2 License Nos. DPR-77 and DPR-79 2.
Contrary to the above, TI-89 failed to implement ASME Section XI testing requirements for relief valves 72-512 and 72-513.
This is a severity level IV violation (Supplement I).
t Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is 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 Director, Office of Special Projects, and a copy to the L
NRC Resident Inspector, Sequoyah, within 30 days of the date of t1e letter transmitting this Notice.
This reply should be clearly marked as a "Reply to a Notice of Violation" and should include (for each violation): ' (1) admission or dentel of the violation (2) the reason for the violation if admitted,
- 3) the corrective steps which have been taken and the results Jehieved,
- 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.
If w adequate reply is not received within the time specified in this Notice, an order may be issued to show cause why the license should not be modified, suspended, or revoked or why such other action as may be proper should not be taken.
FOR THE NUCLEAR REGULATORY COMMISSION l
l
,lG.,
lldudiu I
Steven D. Richardson, Director i
TVA Projects Division OfficeofSpecialProjects Dated at Rockville, Maryland this Bo
- day of October 1988
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