ML20215J558

Notice of Violation from Insp on 861201-12 & 870112-23

ML20215J558
Person / Time
Site:	Sequoyah
Issue date:	04/24/1987
From:	Ebneter S NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20215J544	List: IR 05000327/1986068 ML20215J541 ML20215J558
References
50-327-86-68, 50-328-86-68, NUDOCS 8705080092
Download: ML20215J558 (5)

Text

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o ENCLOSURE 1 I

NOTICE OF VIOLATION Tennessee Valley Authority Docket Nos. 50-327 and 50-328

Sequoyah Units 1 and 2 License Nos. DPR-77 and DPR-79 The following violations were identified during an NRC Safety Systems Outage

, Modifications Installation Inspection at Sequoyah Unit 2 during December 1-12,

1986 and January 12-23, 1987. The severity levels were assigned in accordance ,

i with NRC Enforcement Policy (10 CFR 2 Appendix C). Enforcement Actions.

, Section references are to the detailed inspection report.

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! 1. Criterion IV of 10 CFR 50, Appendix B, as implemented by TVA Nuclear

! Quality Assurance Manual (NQAM) Part 1, Section 2.4, Revision 0, states, ,

) in part, " Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are a

necessary to assure adequate quality are suitably included or referenced i

in the documents for procurement of material, equipment, and services...."

Contrary to the above, the licensee failed to assure that applicable ASME

~ Code requirements were included in the procurement of specific safety-l- related Code class equipment installed in Unit 1 and 2 prior to and during

~ this outage. In particular

a. Isokinetic probes, which are used to collect post-accident air samples, and which should have been purchased to ASME Code Class 2,.

were in fact purchased to non code requirements, thereby eliminating il

' requirements for certified material test reports (CMTRs), and other quality verification (Section 2.1.1.3).

b. A cavitating venturi, which is located at the discharge of Auxiliary Feedwater Pump 2A-A, and which is required by the purchase specifica-tion to have an ASME Code N stamp, in fact does not have an ASME 3 Code N stamp and has no documentation indicating that it was purchased to ASME Code requirements (Section 2.1.1.2).

c. A stainless steel spiral threaded insert, which is installed in the primary side head of a Unit 2 steam generator, and which should have been purchased to ASME Code Class 1 requirements, was in fact purchased to non-code requirements, with no safety review or other quality verification (Section 2.1.1.1).

This is a Severity Level IV violation (Supplement II).

i j 2. Criterion XV of 10 CFR 50, Appendix B, as implemented by TVA NQAM Part I, Section 2.15, Revision 1, states, in part, " Measures shall be established i to control materials, parts, or components which do not conform to

' requirements in order to prevent their inadvertent use or installation."

t Contrary to the above, the inspection team identified cases in which nonconforming materials were issued and installed in plant safety-related

) applications. In particular:

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a. Of 145 diesel generator foundaticn anchor bolts review:d by the inspection team, 144 had no material certifications as required by the applicable safety classification and the material specification (Section 2.1.3.1).

b. The majority of the nuts and bolts used as fasteners for the battery racks in Battery Rooms 1, 2 and 5 did not have vendor markings or grade classifications, and were not traceable to material identifica-tions (Section 2.1.3.1).

c. Required material traceability documentation could not be found for a large number of other installed items, which are listed in Table IV, and which include safety injection pump casing bolts, an auxiliary feedwater pump discharge flange, battery room anchor bolts, Steam Generator #4 anchor bolts, valves, snubbers, test flanges, and various bolting materials (Sections 2.1.3.1 and 2.1.3.2).

d. For one case, based on a limited sample, the internal wiring in a limitorque valve operator was found to be not qualified to Class 1E requirements (Section 2.4.9).

This is a Severity Level IV violation (Supplement II).

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3. . Criterion VIII of 10 CFR 50 Appendix B, as implemented by TVA NQAM Part 1,

. Section 2.8, Revision 0, states, in part, " Measures shall be established for the identification and control of materials, parts, and components,

... these measures shall assure that identification of the item is maintained by heat number, part number, serial number, or other appropriate means...."

Contrary to the above, the inspection team found that:

a. Since May 1986, 308 and 308L weld rods could not be distinguished from each other in the weld rod ovens at Unit 2 (Section 2.1.4.1).

b. A number of weld records did not provide adequate traceability of the weld metal to CMTRs; specific examples are listed in Section 2.1.4.2 and Table IV.

c. A number of items from Power Stores lacked proper material certifications or qualifications; these included disc nuts for 16 inch Walworth valves, Limitorque gear clutches, Chicago Fluid Power solenoid material, and Target Rock solenoid valve material (Section 2.1.2.2)

This is a Severity Level IV violation (Supplement II). l l

4. Criterion VII of 10 CFR 50 Appendix B, as implemented by TVA NQAM Part 1, i Section 2.7, Revision 0, states, in part, " Measures shall be established l

' to assure that purchased material, equipment, and services... conform to the procurement documents.... Documenting evidence that material and equipment conform to the procurement requirements shall be available at the nuclear power plant... prior to installation or use of such material and equipment."

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Contrary to the above, and in spite of the fact that the same issue was identified by TVA approximately one year ago and was cited by NRC in October 1986 (Inspection Report No. 50-328/86-61), the licensee has continued to routinely issue material which does not have the required I certifications (Section 2.1.2.1). l This is a Severity Level IV violation (Supplement II).

5. Criterion V of 10 CFR 50 Appendix B, as implemented by TVA NQAM Part 1, Section 2.5, Revision 0, states, in part, that " Activities affecting l quality shall be prescribed by documented instructions, procedures, or drawings, ... and shall be accomplished in accordance with these instructions, procedures, or drawings."

Contrary to the above, the inspection team identified numerous significant instances in which safety-related equipment was not installed in accord-ance with the instructions, procedures or drawings:

a. Installation of the fifth 125V Vital Battery did not meet the speci-fication and drawing requirements, in that gaps of up to 1/2 inch were found between the poured foundation and the rack structural supports, thereby changing the seismic response of the structure; cable separation violations involving A and B train cables were identified in Battery Board 5; installed lights in Battery Room 5 were found to be standard incandescent fixtures rather than the required vapor / explosion proof fixtures; and intercell connection cables which link Vital Battery Cells 52 and 53 were found to have bend radii less than than required by site specifications (Section 2.4.10).

b. Inspection by the team of the replacement of ERCW pump motor cooling lines found that a pipe restraint on a pump inlet line was assembled such that it acted only in two directions rather than in three as j designed; structural fillet welds for two pumps were stitch welded I rather than continuously welded as specified; and several work activities, such as cutting of a pump discharge line, disassembly of pipe hangers, and removal of a part internal to a pump housing, were accomplished without procedural requirements or proper documentation (Section 2.4.1).

c. A number of electrical installation discrepancies were identified by the team, including loose L-B conduit boxes and loose or broken flexible conduit; transmitter installations with assembly discrepan-cies; loose debris and mold on terminal blocks; rust on seating surfaces; improperly mounted resistors; deficient Raychem splices; l and missing side protective covers on devices in Auxiliary Control l Room panels (Sections 2.4.2, 2.4.3, 2.4.4, 2.4.5, 2.4.6, 2.4.8 and 2.5.5).

d. A number of additional mechanical installation discrepancies identified by the team included missing or inadequate concrete anchor bolt pull test records; locations, configurations and welding details on hangers, braces and support plates which were not in accordance with drawing requirements; a failure to hydrotest newly installed power operated relief valves; an incorrect component

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listed on a weld record; and instellation of a larger coupling and an extra reducer not shown on the drawings on Diesel Generator 1A-2 (Sections 2.3.9, 2.4.7, 2.4.13, 2.4.14, 2.4.15, 2.4.17, and 2.4.18).

This is a Severity Level IV violation (Supplement II).

6. Criterion X of 10 CFR 50, Appendix B, as implemented by TVA NQAM Part I, Section 2.10, Revision 0, states, in part, "A program for inspection of activities affecting quality shall be established and executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures and drawings for accomplishing the activity.

Contrary to the above, the inspection team identified a number of cases in which items which did not meet the purchase order specifications had been signed off as acceptable during receipt inspections:

a. Certified Material Test Reports (CMTRs) involving specific types of weld electrode furnished by ARCOS failed to include mechanical test data as required (Section 2.1.2.5).

b. A normally closed solenoid valve operating at 15.4 watts was ordered; the valve accepted was normally open and operated at 10.5 watts (Section 2.1.2.5).

c. Required impact test results were not included for an accepted five inch stainless steel bar, hardness values required by the specification were not contained in the CMTR for another accepted stainless steel bar, and required bend test results were not included in the CMTR for a one inch carbon steel plate (Section 2.1.2.5).

d. Physically different gaskets for a three inch Masoneilan valve were accepted under the same part number (Section 2.1.2.5).

This is a Severity Level IV violation (Supplement II).

7. Criterion VI of 10 CFR 50, Appendix B, as implemented by TVA NQAM Part 1, Section 2.6, Revision 0, requires that measures be established to control the issuance and distribution of procedures and drawings, and that changes to these documents be reviewed and approved by authorized personnel.

Contrary to the above, the NRC inspectors found that the licensee's  ;

document control procedures were inadequately implemented in some cases i in that:

a. A number of drawings contained inaccurate information and, although some of the errors were found during installation, the drawings were

. not changed by the appropriate change documentation (field change requests or design change requests). Examples are discussed in 1

Sections 2.3.1, 2.3.3, 2.3.4, 2.3.6, 2.3.7, 2.3.11 and 2.3.12 of this report.

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b. A number of codification packages reviewed either did not identify the drawings to be changed, or did not identify or include the applicable drawings for use by construction organizations. In some cases, procedural changes signed-off as complete had not been issued. Examples are discussed in Sections 2.3.2, 2.3.4 and 2.3.8.

This is a Severity Level IV violation (Supplement II).

Pursuant to 10 CFR 2.201, you are required to submit to this office within 30 days of the date of this Notice, a written statement or explanation in reply including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Security of safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790 (d) or 10 CFR 73.21.

FOR THE NUCLEAR REGULATORY COMMISSION

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v Yl Stewart D. Ebneter, Director TVA Projects Division Office of Special Projects Dated this 24th day of April 1987 l

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