ML20235K504
| ML20235K504 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 09/25/1987 |
| From: | Ebneter S NRC OFFICE OF SPECIAL PROJECTS |
| To: | |
| Shared Package | |
| ML20235K462 | List: |
| References | |
| 50-327-87-52, 50-328-87-52, NUDOCS 8710050118 | |
| Download: ML20235K504 (6) | |
Text
- -_
6 i
ENCLOSURE 1 NOTICE OF VIOLATION TVA Docket Nos. 50-327, 50-328 Sequoyah License Nos. OPR-77, DPR-79 During the Nuclear Regulatory Commission (NRC) inspection conducted on August 3-14 and 19,1987, violations of NRC requirements were identified.
The violations involved:
- 1) failures of the licensee's design control measures to assure that' regulatory requirements and the design basis are properly trans-lated into specifications, drawings, procedures, and instructions and to assure that design changes are subjected to required design control measures and approvals; 2) failures to prescribe and accomplish activities affecting 1
quality in accordance with instructions, procedures, and drawings; and 3) a failure of document control measures to assure that drawing changes are reviewed for adequacy.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:
A.
10 CFR Part 50, Appendix B, Criterion III states that measures shall be established to assure that applicable regulatory requirements and the design besis for those structures, systems, and components to which this appendix applies are correctly translated into specifications, drawings, procedures, and instructions.
In addition, it states that design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design and be approved by the organization that performed the original design unless the applicant designates another res,ponsible organization.
Contrary to the above, prior to the August 1987 NRC ERCW system as-built walkdown inspection, the licensee's design control measures failed to assure that applicable regulatory requirements and the design basis for the ERCW system were correctly translated into specifications, drawings, procedures, and instructions as follows:
1.
The design basis for the ERCW system was not correctly translated into drawings and instructions in that ERCW system drawing 47W845 did not reflect skid mounted valves in the ERCW lines that could isolate ERCW flow to the safety injection pump oil and bearing toolers and to the centrifugal charging pump oil coolers.
.Because of this, the licensee failed to provide any instructions for the initial or periodic alignment of the valves and failed to include the valves in the 31 day alignment verification required by Technical Specifica-tion Surveillance Requirement 4.7.4.a.
Additionally, ERCW system drawing series 47W845 was inadequate in that it did not reflect specified high point vent valves located between the instrument isolation valves and instrument root valves.
2.
The licensee failed to correctly translate applicable regulatory requirements and the design basis into specifications, drawings, 8710050118 870925 ADOCK 050 7
gDR
TVA 2
Docket Nos. 50-327, 50-328 Sequoyah License Nos. OPR-77, DPR-79 procedures, and instructions in that the licensee allowed routing of safety-related cables through undesignated cable trays, without apparent regard to thermal loading, electrical separation, and volumetric tray loading.
An example of this is the routing of cable IPP718B through cable tray NK-B.
3.
The ifcensee failed to properly transfer the design basis and regulatory requirements into specifications in that the design specification for purchase of the ERCW screen wash pump did not spectfy that the pump be an ASME code Class III pump as required by the FSAR nor was action taken to change the design basis when it was determined to purchase non-code pumps.
4.
T9 licenseee failed to aroperly transfer the design basis and regulatory requirements ' nto specifications in that the metal flexible hose on the ERCW inlet and outlet to the diesel generator lube oil coolers was purchased to a design pressure of 100 psi instead of the 150 psi ERCW system design pressure.
Contrary to the above, in plant changes which affect plant design were implemented without design control measures commensurate with the
(
original design and without formal engineering approval.
j i
5.
The licensee failed to take adequate design control measures
(
commensurate with the original design in that the ERCW 2A traveling screen level differential transmitter was disconnected from its level detectors and the inlet level detector was removed from its well without review by any of the licensee's design organizations.
l 6.
The licensee faifed to take design control measures commensurate with the original design in that an ERCW loop cross connect was installed j
between two drain plugs downstream valves 2-67-674A and 2-67-6748 without any formal engineering review or approval.
Because of this, l
the licensee was unable to establish two independent loops of ERCW as l
required by Technical Specification 3.7.4 4
This is a Severity Level IV violation (Supplement II).
B.
10 CFR Part 50, Appendix B, Criteria V states that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with there instructions, procedures, or drawings.
1 Contrary to the above, prior to the August 1987 NRC ERCW system as-built walkdown inspection, the licensee's drawings, procedures, and instructions were not properly prescribed or accomplished as follows:
I 1.
The licensee failed to properly prescribe or accomplish the installation of the ERCW pump house instrument sense line floor sleeve packing in that ERCW instrumentation drawings 17W600-2 and 17W600-3 and drawing 37W206-3 included conflicting requirements for 1
i
TVA 3
Docket Nos. 50-327, 50-328 Sequoyah License Nos. OPR-77, DPR-79 the prescription of the sleeve packing height.
In addition, the
]
licensee failed to properly install the floor sleeve packing in accordance with either drawings 17W600-2 and 17W600-3 or drawing 37W206-3.
2.
The licensee failed to install heat tracing on the RA ERCW pump i
discharge pressure instrument line as required by drawings 17W600-2 and 17600-3.
3.
The licensee failed to adequately accomplish Standard Practice SQA-134 in that the safety-related ERCW screen level differential l
transmitters and level detectors, and the safety-related Ef!CW high i
flow alarm transmitter were not listed on the critical structures I
systems and components (CSSC) list.
SQA-134 Appendix A Part I l
requires safety-related items to be on the CSSC list.
I 4.
The licensee failed to provide any instructions for positioning of valves located in instrument lines downstream of primary root valves.
1 5.
The licensee failed to accomplish electrical equipment and design criteria instruction SQN-DC-V-12.2 in that Beldon Braid sheathed handswitch wiring within portions of the main control panel were not properly installed to prevent touching of cables between divisions.
6.
The licensee failed to adequately accomplish General Construction Specification G-38 in that safety-related cables IPP7188 and IPP7128 were not routed pursuant to cable pull cards or cable schedules.
This is a Severity Level IV violation (Supplement II).
C.
10 CFR 50 Appendix B Criterion VI states that measures shall be established to control the issuance of dccuments. such as instructions, procedures, and drawings, including changes thereto, which prescribe all i
activities affecting quality.
These measures shall assure that documents, including changes, are reviewed for adequacy.
Contrary to the above, prior to the August 1987 NRC ERCW system as-built walkdown inspection, the licensee's document control measures failed to assure proper review for adequacy of ERCW flow drawing 47W845 in that the drawing did not properly reflect the deletion of the 738 and 747 series relief valves located downstream of the ERCW strainers, by ECN 2860.
ECN 2860 was completed in 1980.
This is a Severity Level V violation (Supplement II).
Pursuant to the provisions of 10 CFR 2.201, TVA is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including (for each violation):
(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 at:hieved, (4) the corrective steps which will be taken to avoid further violations, and (5) the date when full compliance will be achieved.
Where good
l l
I TVA 4
Docket Nos. 50-327, 50-328 Sequoyah License Nos. DPR-77, DPR-79 cause is shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REGULATORY COMMISSION O
/
j(khwL
%&)
Stewart D. Ebneter, Director TVA Projects Division Office of Special Projects Dated at Bethesda, Maryland this as^ day of September 1987 1
i l
i I
1 l
I l
l
)
SEP 2 s' ggg7 ENCLOSURE 2
]
OBSERVED WEAKNESSES ERCW A3-BUILT VERIFICATION INSPECTION i
The inspection team observed some -weaknesses in the' areas ~ of conduct of operations, equipment identification,. preventative maintenance, and corrective maintenance activities.
These weaknesses are delineated below and should be addressed in'your response to the enclosed Notice of. Violation.
1.
A weakness was identified in your conduct of operations which we have currently identified as an unresolved item pending completion of enforcement action review.. Specifically, safety-related functions of I
the ERCW system were disabled with temporary measures put in place to compensate. for those fur.ctions.
As noted in the enclosed report, this was done in.some cases without appropriate. review and analysis, i
Additionally compensatory actions were not appropriately specified and controlled in all cases.
To this end, we have concern that your actions did not' address system operation in an accident mode.
Also we are concerned that permanent resolution had not been. implemented -
to resolve problems associated with these safety functions even though some of these problems were identified prior to licensing.
Thirdly, we. are concerned that, without NRC intervention, these conditions would have gone uncorrected.at startup. You should evalu-ate these concerns and in your response address the root causes and generic span-of these concerns and identify necessary corrective actions to resolve the technical concerns as well as prevent recur-rence.
Your evaluation should consider possible weaknesses in your engineering-operations interfaces which may have contributed to a lack of appropriate engineering input to the applied temporary compensatory measures and the prevention of timely permanent resolu-
. tion of problems.
2.
Numerous findings indicate a weakness with your past practices associated with equipment identification.
As noted in the enclosed report, examples of this include the inspection team's observation of many missing, damaged, and incorrect valve, instrument and conduit labels.
It is recognized that TVA has a prcgram in place to identify and correct these types of human factors deficiencies.
In your response you should address when implementation of this program will be completed and what actions have been, or will be instituted to preclude recurrence.
3.
The inspection team identified several conditions that are sympto-matic of a weak preventive maintenance program.
As noted in the enclosed report, these conditions included observed corrosion on pipe sections and components, rusted instrument stands and strainer supports, and water leakage from ERCW strainers.
Additionally, these conditions included the fact that a preventive maintenance program x
, ;c I
.SEP 2.51987
- Enclosure 2 2
i for ' snubber lubrication has not yet' been. implemented.
In.your
. response, you should address how and when your newly developed programs will assure that-plant components,. systems, and structures are not unnecessarily allowed to-degrade with age.
4.
Weaknesses were identified which were indicative of poor maintenance practices in the. restoration'of equipment to operational status after maintenance activities and the apparent inability of the station's
. staff to relate to.the need to repair and correct the damaged equip-ment. = As noted in the enclosed report, examples of this include the team's observation of a bent valve stem, shortened flange studs, broken flex connections on cable conduit, minor wiring and housekeep-ing deficiencies within motor operated valve housings, a broken instrument. bracket, inadequate cleanliness provisions for open instrument ports, damaged armored cables and conduits, and a loosened pipe support locknut.
Many of these deficiencies may demonstrate a short coming in your " skill of the craft" concept as implemented at Sequoyah.
In your response you should address what actions have been or will be. instituted to assure proper maintenance of plant compo-nents, systems, and structures and when these actions will be imple-mented.
'i i
f I
{
a C--_____