ML20237H813

Notice of Violation from Insp on 870406-17.Violation Noted: safety-related Activities for Verification of as-built Configuration of safety-related Instrument Mountings Not Performed,Per Engineering Calculation Instructions

ML20237H813
Person / Time
Site:	Sequoyah
Issue date:	08/18/1987
From:	Ebneter S NRC OFFICE OF SPECIAL PROJECTS
To:
Shared Package
ML20237H809	List: IR 05000327/1987023 ML20237H806 ML20237H813
References
50-327-87-23, 50-328-87-23, NUDOCS 8708250160
Download: ML20237H813 (2)

Text

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ENCLOSURE 1

. NOTICE OF VIOLATION l 1

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 QA Element Report inspection at Sequoyah Unit 2 during April 6-17, 1987. The severity levels were assigned in accordance with NRC Enforcement Policy (10 CFR 2 Appendix C)

Enforcement Actions. Section references are to the detailed inspection report.

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 ouality 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 activities for verification of the as-built configuration of safety-related instrument mountings were not performed in accordance with the established engineering calculation instructions.

a. Required instruction sign-off steps for performance of walkdown inspection and drawing confirmations were not completed, especially for cases where the installation differed from existing typical drawings.

b. Required documentation of engineering evaluations of installations that differ from typical drawings was not evident.

c. Installations indicated by engineering to be in accordance with existing detail drawings were in error when compared to as-built field sketches and photographs.

d. References to applicable detail drawings on an associated listing of instruments were in error,

e. Sumary and conclusion statements for calculations were in error or misleading in regard to the following:

The conclusion stated that each item on the summary list had been inspected when only 210 of the initial selection of 547 items were determined to be within the scope of the program, and only 98 had inspection data sheets completed and filed with the calculation.

The summary stated that for instruments that did not have an existing mounting detail, a sketch had been " submitted to Civil Engineering Branch (CEB) for seismic analysis to determine the acceptability." Only one CEB calculation could be provided. It was an as-built analysis of two identical instruments for which no detail drawing existed. No one in DNE (electrical of civil) could show that CEB had performed any evaluation of the many remaining installations with field sketches.

The conclusion stated that each item in the summary listing had

" documented, design approved mounting details." Existing documentation does not support this statement.

This is a Severity Level IV violation (4.j and 7.b.(3), 87-23-02).

8708250160 870818 PDR ADDCK 05000327 G PDR

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 including: (1) admission or denial of the alleged violations, (2) the reasons for the violations if admitted, (3) the corrective steps that will be taken to avoid further violations, and (4) 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

~ wg1 c ewart D. Ebneter, Director TVA Projects Division Office of Special Projects Dated this 18th day of August 1987 l

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