ML18033B737
| ML18033B737 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry  |
| Issue date: | 06/10/1991 |
| From: | Kellogg P, Patterson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18033B734 | List: |
| References | |
| 50-259-91-17, 50-260-91-17, 50-296-91-17, NUDOCS 9106270078 | |
| Download: ML18033B737 (17) | |
See also: IR 05000259/1991017
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323
Report Nos.:
50-259/91-17,
50-260/91-17,
and 50-296/91-17
Licensee:
Valley Authority
6N 3&A Lookout Place
1101 Market Street
Chattanooga,
TN
37402-2801
Docket Nos.:
50-259,
50-260,
and 50-296
License Nos.:
and
DPR-6&
Facility Name:
Browns Ferry Units 1, 2,
and
3
Inspection at Browns Ferry Site near Decatur,
Inspection
Cond cted; April 29, - May 10,
/'
Inspector:
C.
Patterson,
Sensor
Res>dent
Inspector
E. Christnot,
Resident
Inspector
T.
Cooper,
Resident Inspector
Date Signed
Approved by:
Pau
I
TVA eet-'ms,
Projects
ivision
SUMMARY
a
e
signed
Scope:
This special
announced
inspection of the unit separation
program was conducted
to verify that Unit
2 startup
and operation
would not
be
impacted
by the
planned
modifications for Unit 3.
This included
a review of the operational
interface
control,
personnel
access
control,
design
and
modifications,
secondary
containment,
fire
protection,
training,
and
division
of
responsibilities.
Results:
0
The unit separ ati on program
has
been adequately
implemented to suppor t Unit 2
restart. 'he operational
inter face controls
and personnel
access
control
have
been
established.
Mechanical,
and electrical
systems
in Units 1 and
3 needed
to support Unit 2
have
been
uniquely identified.
Boundary isolation valves
910b270078
910b11
ADOCK 05000259
Q
have
been chained
and locked closed.
Plant personnel
have received training on
the
separation
program with additional
training for plait operators.
The
delineation
of responsibilities
and
lines
of
commu'nication
between
the
operating unit and construction unit have been established.
One violation was identified for failure to follow the hold order procedure,
paragraph
3.
The separation
hold or'der tags
were being
hung without first
establishing
the clearance
boundary
and independently verify'ing the boundary.
This is in the reverse
order of the procedure
requirements.
Implementation of
hold orders
is
a
weakness
in the
operations
area.
There is
a lack of
understanding
of the purpose
of a clearance
boundary.
Personnel
sign onto a
hold order without reviewing the specifics of the boundary against the work to
be performed.
In this case
the boundary
was not ever established.
During the inspection, it was identified that sealing of conduit and junction
box in Units
1 and
3 around equipment
needed for Unit 2 operation
had not been
considered,
paragraph
3.
This was
a problem in Unit 2 when spurious actuation
of open
head fire spray nozzles
wet equipment in the reactor building.
Most of
the
open
head
nozzles
were replaced in Unit 2 and components
sealed
because
of
this
concern
or the
environmental
qualification of equipment
program.
The
licensee
sealed
an additional
216
items
in Units 1 and
3 to resolve this
concern.
REPORT DETAILS
Persons
Contacted
Licensee
Employees:
- J.
Bynum', Vice President,
Nuclear Operations
0. Zeringue,
Vice President,
Browns Ferry Operations
- L. Myers, Plant Manager
"M. Herrell, Operations
Manager.
J.
Rupert, Project Engineer
"M. Bajestani,
Technical
Support
Manager
R. Jones,
Operations
Superintendent
A. Sorrell, Maintenance
Manage~
G. Turner, Site Quality- Assurance
Manager
"P. Carier, Site Licensing Manaoer
"P. Salas,
Compliance Supervisor
"J. Corey, Site Radiological Control Manager
R. Tuttle, Site Security Manager
Other
licensee
employees
or contractors
contacted
included
licensed
reactor
operators,
auxiliary
operators,
craftsmen,
technicians,
public
safety officers, quality assurance,
design,
and engineering
personnel.
NRC Personnel
"C. Patterson,
Senior Resident
Inspector
E. Chri stnot,
Resident
Inspector
"W. Bearden,
Resident
Inspector
- K. Ivey, Resident
Inspector
"G. Humphrey,
Resident
Inspector
"Attended exit interview
and Initialisms used
throughout this report
are listed in the
last paragraph.
Program Description
Browns Ferry Unit 2 is being returned to service after
a six year
shutdown
following extensive modification work.
Similar modifications
ar'e
planned
for Unit 3
and eventually Unit 1.
Since all three units are physically
adjacent
and operationally interdependent,
the licensee
established
a Unit
Separation
Program.
This program established
the controls
necessary
to
operate Unit 2 while working
on Unit 3 with Unit
1 in layup.
The program
is
defined
in
procedure
SSP-12.50,
Unit
Separation
for
Recovery
Activities.
This
procedure
contains
the
personnel
access
control
and
system
operation
interface control.
The personnel
access
control consist
of physical
and administrative
measures
to restrict Unit
2 operating
spaces
from Unit 3 recovery personnel.
This 'consists
of barriers,
unique
badging
and posting of signs.
The
System
Operational
Interface
Control
consists
of color coded interface drawings,
colored tape,
signs
and tags,
and hold orders.
3.
Operation Interface Control
a
~
Boundary Establishment
The inspector
reviewed the system interface boundaries
to verify the
boundaries
were adequately
established.
The
licensee
established
the
separation
boundary
by using
as the
bases
the
Unit
2
safe
shutdown
analysi s
boundary
surrounded
by
additional operational
boundaries.
The safe
shutdown
boundary review
was
performed with Bechtel
assistance
and included
a review of the
essential
calculation
for those
applicable
systems.
Some of thi s
review
was
previously
addressed
in
IR
91-06.
Additional
items
reviewed
were
FSAR Chapter
14,
Appendix
R
Shutdown
Analysis
and
Unit 2 Dependency Matrix.
No additional
items were identified by the
FSAR Chapter
14 or Dependency Matrix.
The Appendix
R review revealed
that the Unit 3
DGs were needed for safe
shutdown if a fire occurred
in the Unit
1
and
2
DG building.
However,
the Unit
3
are
required
by TS to support
common equipment.
The inspector
cross-referenced
the list of safe
shutdown
systems to
the list of systems
needed
to support Unit 2 operation listed in'SP-
12.50.
The Fire Protection
system
was not listed in SSP-12.50.
The
licensee
stated this
system is already
red color coded
and required
by existing
TS.
The inspector
agreed
there
was
ample justification
for removing this
from the list'.
The inspector
questioned if the
electrical
components
in Units
1
and
3 were adequately
sealed
from
spurious
actuation
of
the fire protection
system.
A previous
violation for, this concern,
87-33-01,
was identified.'nit
2 fire
protection
systems
were
upgraded
and
most
open
head
spray
nozzles
replaced or removed.
The
same
upgrades
were not performed in Units
1
and 3.
The licensee
reviewed the separation
drawings
and issued
FDCN
to
DCN H0397
on
May 10,
1991, to seal
an additional
216 items.
This
sealing
would be completed before restart of Unit 2.
The inspector
noted that
FSAR Appendix
F, "Interfacing Systems"
had
not been reviewed.
The licensee
reviewed the Appendix and identified
no additional
items that were not previously addressed.
The
inspector
concluded
the boundaries
were adequately
established
'nd
concerns
resolved.
0
Clearance
Boundary
The inspector
reviewed the following hold orders for separation:
3-91-95
Unit 2/Unit 3 Electrical Interface Separation
1352 Tags
3-91-96
Unit 2/Unit 3 Mechanical
Interface Separation - 714 Tags
1-91-66
Unit 1/Unit 2 Mechanical
Interface Separation
-444 Tags
1-91-67
Unit 1/Unit 2 Electrical Interface Separation - 1223 Tags
The hold orders
were denoted
as
90 to
95% complete
on the plan of the
day.
The
inspector
questioned
why the
hold orders
were
not
1005
completed'he
clearance
sheet,
form SDSP-216,
was reviewed
and the
signatures
for
clearance
boundary
established
and
independent
verification were not signed.
The personnel
preparing
the hold order
were questioned.
There
was
some confusion whether the hold order had
been
issued
or
released.
However,
the. hold order tags
were
being
,placed
on equipment in the plant.
This is
a violation
TS Section 6.8. 1 concerning
procedures.
SDSP-
14.9,
Equipment
Clearances,
Section
6.3,
requires
a
clearance
boundary
be established
and independently verified before the hanging
of hold order
tags.
This violation is identified
as
VIO 259,260,
296/91-17-01,
Failure to Follow Hold Order
Procedure.
The licensee
issued
PRD to correct this problem.
Additionally the inspector
reviewed
hold order 0-91-160.
This
was
for Unit
1 loads
not required for Unit 2 Cycle
5 operation.
A hold
order
0-91-161
was
in place
because
of
and
separation
concerns
related
to other
plant equipment.
The concerns
would
be
resolved
by modification
once
the respective
unit
was
returned
to
service.
The
common accident
signal
was disabled
by a
DCN.
This would prevent
Unit
1 or Unit 3
LOCA signals
from actuating Unit 2 equipment.
This
was previously reviewed in IR 90-23.
The inspector
questioned
the operational
scheme for tagging boundary
breakers
and valves.
For valves the boundary valves
had both
a hold
order tag
and orange
and black tag.
The valves were tagged
closed to
prevent
fluid flow.
Electrical
breakers
remain
closed
allowing
current flow but,
were
labeled with an
orange
and black tag.
The
licensee
stated
this
method
was
explained
in
the
separation
procedure.
The
inspector
concluded
although this
w'as inconsistent
the procedure
explanation
was adequate.
Tapes
and Labeling
During the drawing walkdowns,
the
use of the orange colored tape
and
labeling of electrical
panels
was inspected.
In general,
the
use of
tape
or labels
was
found to adequately
denote
systems
required for
Unit 2 operation
which were not physically located
in Unit 2.
The
following minor items were identified:
1.
Tape
was
found
on
the Unit
3
DG exhaust
lines
which
was
a
possible fire hazard.
The licensee
removed
=-the tape
on May 1,
1991.
2.
Tape
was
found
on
a Unit 3 control
bay chiller but the chiller
was
abandoned
equipment.
The
licensee
removed
the
tape
on
May 1,
1991.
3.
In Unit
2
on the
4160
shutdown
board
C, there were labels for
the
breaker
control
power
on
the
boards.
The
inspector
questioned
why the labeling was in Unit 2.
The licensee
removed
the labels
on May 1,
1991.
CARR
BFP
910129
was
issued prior to the beginning of the inspection
stating
that
the
tape
used
for marking
the
interfaces
was
not
procured
under
required specifications.
Per
the specifications
.he
allowed halogens is 1000
ppm for use
on corrosion resistant
metals,
while the tape
used
contains
about
85,000
ppm.
The specifications
requires
that all
tape
be
removed
before
returning
a
system
to
operation,
contrary
to
the
intended
purpose
of the
tape.
The
licensee
is
removing
the
tape
from the
stainless
steel
piping,
cleaning
and testing
the piping,
and
then will sleeve
the pipe and
retape
the sleeve.
This will resolve
the
problems with the
halog'en
content of the tape
and the removal
requirements,
since the tape will
be
on the sleeve,
not on the piping itself.
d.
Separation
Drawings
The inspector
reviewed
and walked down the following drawings:
10-45E614-5
120V AC/250Y
DC Valves and Misc.
Wiring Diagram
120V AC/250V DC Valves and
Misc.
1-45E1647-1
Wiring Diagram Unit Control Board Panel 9-9,
Cabinet
1,
1-45E614-9
1;45E701-3
0"15E500-2.
3-15E500-3
Wiring Diagram
Misc.
Wiring Diagram
120V AC/250V DC Valves and
BDl RPS
PWR Single Line
Key'iagram of Standby
Systems
Key Diagram of Normal
and Standby Auxiliary
Power System
.
5
0-45E710"4
Key Diagram Instrumentation
and Controls,
and
AC Power System
3-45E3647-1
Wiring Diagram, Unit Control Board,
Panel 9-9, Cabinet
1
1-47E814-1
3-45E779-20
2-45E779-18
Flow Diagram Core Spray System
Wiring Diagram 480V Shutdown Auxiliary Power
Schematic
Diagram
Wiring Diagram 480V Shutdown Auxiliary Power
Schematic
diagram
1-47E1847-1
Mechanical
I&C Flow Diagram Control Air
System
3-47E861-1
Flow 5 Control
Diagram Diesel Starting Air
System Diesel
Generator
3A
1-47E813" 1
2-47E811-1
1-47E858-1
3-47E850-1
Flow Diagram Reactor
Core Insolation Cooling
System
Flow Diagram Residual
Heat
Removal
System
Flow Diagram
RHR Service Water System
Flow Diagram Fire Protection
and
Raw Service
Water
3-47E858-1
3-47E844-3
Flow Diagram
RHR Service
Water
System
Flow Diagram
Raw Cooling Water
The
inspector
walked
selected
systems
down to assure
the
proper
isolation
of
boundary
valves
on
interfacing
systems.
Valves
identified on drawings
as
boundary isolation valves
were
inspected.
All of the identified valves
had
a hold tag
hung
on them, they'had
been
chained
in the required position,
and
they
had
the
required
orange
and black sign
hung
on the valve,
per procedure
12.50,
identifying
the
valve
as
necessary
for Unit
2
operation.
The
boundary
system
piping
was
properly
marked with orange
tape,
as
required
by the procedure.
The inspector
reviewed
12.50
and the list of designated
drawing
locations did not contain the centralized
The licensee
placed
a set of critical drawings in CECC.
An inspector verified the
drawings were in place
on May 10,
1991.
4.
Per sonnel
Access Control
a
~
Physical Barriers
.The inspector
examined the physical barrier program being implemented
to
separate
Unit
3 activities
from Unit 2.
At the
time of the
inspection,
the
barriers
had
been
fabricated,
and
were
being
installed.
Hard hats
were being issued to Unit 3 workers that are .dissimilar to
any other
hardhats
in
use
at
the site.
A light blue
hard . hat
signifies that the worker is assigned
to Unit
3
and is not 'exempt
from the Unit 2 ac'cess
control restrictions.
The licensee
procedure,
SSP 12.50,
requires that
a list of exempt
personnel
who are
allowed
to freely travel
between Unit 3 and Unit 2 be developed.
Non-exempt
personnel will be required to obtain
an orange
and black
access
badge prior to entering
Unit 2
from Unit 3.
Before
these
badges
can
be issued,
the person
must be qualified through experience
or training to perform the required
work on Unit 2.
The licensee
procedure
requires
that Unit
3 work control
and the job supervisor
are responsible
for assuring
that
each
individual requi red to enter
Unit 2 is qualified.
Access
to the Unit
3 reactor
building will be
through
the
same
airlock being
used for access
to the Unit 2 reactor building, until
the secondary
containment isolation separation
is completed.
At that
time barriers will be placed to prevent
access
to unit
3 through the
airlock.
The equipment airlock will be used for Unit 3 access after
the separation.
Access Control
The inspector interviewed security
management
concerning
the measures
being
taken to implement .the
access
control
program for Unit
3 and
Unit 2.
The security force has
been
prepared for the
implementation
of the
separation
program.
They
have
received
the
same
general
employee
training
as
the
plant
personnel
and
are
familiar with
requirements
for the unit separ'ation.
0
Unit
3
recovery
personnel
must
meet
the
vital
area
access
requirements
before
being
issued
a badge,
but their badges will be
distinctively marked,
with either
a blue dot or
a blue stripe,
to
differentiate
them from the unit 2 work force.
For Unit 3 personnel
found in Unit 2 without the proper authorization,
security plans to
consider
the 'incident
as
a security violation, to
be dealt with as
such.
The inspector
reviewed
and observed
the licensee's
design
and modification
activities involved with the unit separation
program.
This consisted of a
review of drawings,
DCN, associated
FDCNs,
and the Support to Frontline
Dependency Matrix.
The observations
consisted of completed work and work
activities in the field.
Dependency Matrix
'he
inspector
reviewed the
dependency
matrix in relationship to the
scope
of the electrical
system
separation
boundary.
The inspector
noted
the matrix did not list any Unit 3
RMOV Board 480V AC or 250V
OC; listed Unit
RMOV 480V AC Boards
1A, B,
C, and
E; listed all
4
KV
shutdown boards; listed all, except
3D,
4KV Unit Boards;'did
not list
the
Unit 3,
4KV Tie
Board;
and listed
various
other electrical
boards.
The
inspector
observed
the
electrical
system
boundary
identification tags
on various electrical
boards
such
as
41'60 volt
unit,
common,
bus tie
and
shutdown
boards,
480 volt
common
and
shutdown boards,
480 volt and
250 volt
RMOV Boards,
and
120/208
volt I and
C panels.
The inspector
concluded
from the review,
walkdown,
and followup of
the dependency
matrix versus
the electrical unit separation
boundary
that
no electrical
board
listed
on
the
matrix is
outside
the
electrical unit separation
boundary.
b.
The inspector
noted that the dependency
matrix was
an operator aid in
the control
room.
The matrix references
numerous
notes but the notes
were
not available
to the operator s.
The licensee
made
the
notes
available to the control
room operators
on May 1,
1991.
Design
and Modifications
The
inspector
reviewed,
observed,
and
followed
up
the
licensee
activities
involving modifications for Unit Separation.
The
DCNs
reviewed
were
W16408,
Physical Modificati'on to penetrations,
W16441,
Seal
Unit
3 Stairwells to Refuel
Floor,
W15432,
Emergency
Lighting
for Unit 3 Equipment Airlock; W16576,
Add a Card Reader to Door 25A,
Airlock from Turbine Building to Unit 3 Reactor Building, and W16567,
Install
New Emergency Stairwell.
The inspector
reviewed the various
DCAs associated
with the
OCNs. The'nspector
noted that
OCN W16440,
Masonry
Block Walls
and
Other
Components
of the Unit
3 'Elevator
Shaft,
and
DCN W16532,
Seismic Qualification of Unit 3 Refuel
Flow
Exhaust Ducts,
were not issued at the close of the inspection.
The inspector
observed
in progress field activities included in DCNs
W16567 and
W16576.
These activities involved
WPs 2069-91,
0074-91,
and 0076-91.
The inspector
reviewed the field work completed for DCN
W16567 which involved
WP 2069-91.
The inspector
concluded
from the reviews
and the observations
of the
work activities
that
the
modifications
were
being
installed
in
accordance
with the
DCAs and WPs.
c.
Temporary Alterations
The inspector
reviewed
two TAs.
One TA, involving the connections
to
the
system
from the
Unit
3 containment,
containment
purging
system
and the
HPCI system,
had not
been
approved for installation.
The other TA, designated
TACF 3-91-002-040,
involved the installation
of an expandable
plug between
the Unit 2 and Unit 3 turbine building
station
drain
The
inspector
observed
that this
TA was
installed
and adequately identified.
The inspector
concluded that the
BFN separation
program
as it applied to
the
areas
reviewed
was
being
conducted
in
a
controlled
manner
in
accordance
with procedures.
6.
Secondary
Containment
The
inspector
reviewed
the
separation
plans
associated
with secondary
containment.
Presently four zones,
the three reactor
buildings
and refuel
floor, are treated
as
a
common
secondary
containment.
This will remain in
place
when Unit'
is started.
Several
months after restart Unit 3 reactor
zone will be separated
from the other three
zones.
Several
modifications
are
being
prepared
to
permit
isolation
of
Unit
3.
Some
of
the
modifications necessary
are
as follows:
Rubber boots
on piping penetrations
Reinforce concrete
blocks
on top of elevator shaft
Seal
up elevator cables
and ventilation
Modification to reactor cavity HVAC
A TS change is also required for Unit 3.
TS 3.7.c.2.6.
requires
shu'tting
down all three units if reactor
zone
containment
is lost in any reactor
zone.
These activities wi 11
be followed during
the routine
inspection
program after Unit 2 restart.
7.
Fire Protection
The
inspector
reviewed
the Fire Plotection pre-fire plans
and verified
that the interfaces
between Units
2
and
3
had
been
accounted
for in the
latest revision.
All interfacing
access
areas
between the two units had
been
accounted
for in the revision.
The
access
areas
from Unit
3 into
Unit
2
Reactor
Building
were still listed
as
alternate
access/egress
points, with a note stating that Security would be required to unlock the
doors
between
the two units.
The interfacing doors were only listed as
an
alternative, if the others
could not be used.
e
8.
Training
The inspector
observed
the training for unit separation
for the general
employees
and
the
licensed
operators.
The
general
employee
training
consisted
of
a video tape
which stressed
the procedure
requirements
of
licensee
procedure
SSP 12.50, Unit Separation
for Recovery Activities.
Licensed
personnel
received live training *at the beginning of a shift.
The inspector
observed
the training of one'f the operating shifts.
The
training consisted of watching the general
employee training tape
and then
having the instructor discuss
the procedure
12.50 with the personnel.
The training of the operating
personnel
did not include
any information
not provided in the procedure,
such
as the areas
where barriers
would be
erected,
an explanation of the, systems
and
components
chosen
as
boundary
components,
or any basis for the decisions'he
operators
were told that
the Unit 3 recovery
personnel
would be wearing
"unique"
badges,
but the
badges
themselves
were not described
to the personnel.
(}uestions to the
instruct or
were
usually
requesting
more
detail,
such
as
access
requirements
to the Unit 3
and Unit 2 reactor buildings and whether the
orange
tape being
used to mark the
boundary
system piping was acceptable
due to chloride leaching.
4
The operators
were required to successfully
complete
a test following the
training session.
The test consisted of 10 multiple choice questions
and
two short informational questions.
The operators
were allowed to use the
procedure
while taking the test.
Of the four shifts that
had
completed
the
training,
one
person
had failed the test.
This
person will be
required to repeat
the training.
The
inspector
concluded
that
the training
was
adequate
to explain the
separation
program.
The inspector
commented to operations
management
that
operations
personnel
may need
more detail in their training.
9
Oivision of Responsibilities
On
April
18,
1991,
the
licensee
i ssued
a
memor andum'o
delineate
responsibilities
and
lines
of
communications
between
Operations
(Unit 2)
and
BFN Restart
Organizations
(Unit 3).
Operations
is
responsible
for all
operations
and
programs
at
BFN which affect
the
licensing, operations,
and maintenance
of the units.
BFN Restart
provides
service
to
BFN Operations
for implementing modifications to
BFN Units I
and
3 based
on
NRC commitments
and established
criteria using
acceptable
BFN procedures.
The -inspector
concluded that the memorandum,
which would
be placed in a separation
procedure,
clearly defined responsibilities
and
communication
channels.
The
inspector
noted
one
comment
during
the
review of the
hold order
violation discussed
in this report.
Initially the Unit 2 operations staff
stated
that the hold order work was being performed
by Unit 3 people
who
j
e
10.
10
felt the
method
was acceptable.
The inspector
emphasized
that according
to the
memorandum that Unit 2 operations
was clearly responsible.
Exit Interview (30703)
The inspection
scope
and findings were
summarized
on
May 10,
1991 with
those
persons
indicated in paragraph
1 above.
The inspectors
described
the areas
inspected
and discussed
in detail the inspection findings listed
below.
The licensee
did not identify, as proprietary
any of the material
provided to or reviewed
by the inspectors
during this inspection.
There
were
no dissenting
comments
by the licensee.
Item Number
Descri tion and Reference
259,
260,
296/91-17-01
VIO, Failure to Follow Hold Order Procedure,
paragraph
3.
Acronyms and Initial i sms
0
BFP
CAQR
CFR
DCN
FDCN
IR
KV
NRC
RMOV
SDSP
TA
TACF
TS
wp
Alternating Current
Browns Ferry Nuclear Plant
Browns Ferry Plant
Condition Adverse to Quality Report
Centralized
Emergency
Control Center
Code of Federal
Regulations
Design
Change Authorization
Direct Current
Design
Change
Notice
Diesel Generator
Emergency Operating Facility
Field Design
Change
Notice
Fi na 1
Sa fety Ana 1 ys i s
High Pressure
Coolant Injection
Heating, Ventilation,
and Air Conditioning.
Instrument
and Control
Inspection
Report
Ki 1 ovolt
Loss of Coolant Accident
Nuclear Regulatory
Commission
Parts
Per Million
Problem Reporting
Document
Reactor Motor Operated
Valve
Reactor Protection
System
Standby
Gas Trea'tment
Site Directors Standard
Practice
Site Standard
Practice
Temporary Alteration
Temporary Alteration Control
Form
Technical Specification
Violation
Work Plan