ML20040C582
| ML20040C582 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Hartsville, Phipps Bend |
| Issue date: | 01/18/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 10CFR-050.55E, 10CFR-50.55E, NUDOCS 8201290044 | |
| Download: ML20040C582 (3) | |
Text
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l TENNESSEE VALLEY AUTHORITY C.NRC Rr n ;
CHATTANOOG A TENNESSEE 374on
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January 18, 1982 2;e J AM 20 AS.40 HTRD-50-518, -519, -520, -521/81-04 (j
PBRD-50-553/81-06, -554/81-04 cn
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Mr. James P. O'Reilly, Regional Administrator 4/
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Dear Mr. O'Reilly:
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HARTSVILLE find PHIPPS BEND NUCLEAR PLANTS - COMPLETION OF AS-BUIL DRAWINGS - HTRD-50-518, -519, -520, -521/81-04 AND PBRD-50-553/81-06, -554/81-04 The subject deficiencies were initially reported to NRC-0IE, Region II, Inspector R. W. Wright on.Tanuary 22, 1981, as NCR's HTN-M80-10 and PBN-M80-10, deficiency Nos. 13, 14, and 21.
The final report on deficiency No. 13 was submitted o-1 April 1, 1981.
In compliance with paragraph 50.55(e) of 10 CFR Part 50, we are enc 1csing the fourth interim report on deficiency No. 14 and the final report on deficiency No. 21.
A 16-day extension was discussed with and approved by F. S. Cantrell on December 2, 1981; a 14-day extension was approved by Ross Butcher on
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December 23, 1981.
In addition, a five-day extension was discussed with C. Burger on January 14, 1982. We anticipate transmitting an additional report on or before March 31, 1982.
If you have any questions, please call Jim Domer at FTS 858-2725.
Very truly yours, TENNESSEE VALLEY AUTHORITY O!.h, -
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L. M. Mil s,[ Manager Nuclear Regulation and Safety Enclosure cc:
Mr. R. C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 Ig GL\\l COPV hoffg Jg O
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ENCLOSURE HARTSVILLE AND PHIPPS. BEND NUCLEAR PLANTS COMPLETION OF AS-BUILT DRAWINGS / DESIGN CONTROL AUDIT M80-10 DEFICIENCIES 14 AND 21 HTRD-50-518, -519, -520, -521/81-04 PBRD-50-553/81-06, -554/81-04 10CFR50.55(e) REPORT NO. 4 (INTERIM)
DEFICIENCY 14 Description of Deficiency The requirements as stated-in the Interdivisional-Quality Assurance Procedures (ID-QAP) 6.1, R0, and 2.2, R3 call for as-constructed drawings to be complete on or before transfer of these systems to NUC PR and preoperational testing. Contrary to these requirements, GE/ C. F. Braun contracts call for the as-built drawings to be completed after the 300-hour test. Also, contrary t a 10CFR50, Appendix B, ' Criterion XVI,
" Corrective Action," the Nuclear Engineering Branch failed to promptly identify and docament these nonconforming conditions.
The cause of this deficiency was the lack of an adequately defined as-l built drawing program.
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Interim Progress l
Meetings have been held with Design and Construction personnel, and the types of drawings to be as-built have been defined.
Additionally, TVA is investigating, both with GE and internally, the possibility of initiating a unit-unique as-built drawing' program. This unit-unique as-built program would supply a drafting service which would provide formally issued as-constructed drawings.' These drawings would-the' be formally updated and revised as construction reports field changes.
We anticipate transmitting an addit'onal report on or before March 31, 1982, which will addresc further resolution of this concern as well as i
implementation dates for corrective action.
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_2 DEFICIENCY 21 Description of Deficiency Contrary to ANSI N45.2, "QA Frogram Requirements," some design changes as identified on Field _ Change Requests (FCRs) for General Electric are not I
incorporated into drawings until "as-constructed" drawings are completed i
after the-300-hour test. Therefore, the Design Project Organization personnel are not performing their activities per current drawings. The cause of this deficiency was determined to be the lack of a GE/C. F.
Braun program to address the incorporation of FCRs/NCRs into design drawings.
Safety Implications The Design Project Organization could be_ performing activities with drawings that are not current. This could result in errors in reviewing future changes in documentation leading to a situation which could affect the safe operation of the plant.
Corrective Action C. F. Braun has prepared a FCR/NCR log listing all FCRs/NCRs which will be incorporated into design drawings either during normal progressive updating (those STRIDE FCRs and NCRs which identify design errors) or during the as-built program (those FCRs or NCRs which do not identify design errors in STRIDE). This listing will be consulted and updated when processing new FCRs or NCRs to determine if there are any outstanding STRIDE or TVA cq-built FCRs/NCRs associated with the document being changed.. If so, the FCR/NCR will be reviewed to determine if the previous changes affect the current changes. This procedure will assure a complete design verification to the latest construction status, thereby meeting the requirements of ANSI N45.2, "QA Program Requirements."
Additionally, C. F. Braun will retroactively implement the program to ensure previously approved FCRs/NCRs were processed correctly with the as-constructed status at the time of their processing. TVA will verify implementation of C. F. Braun's corrective action by a future QA audit.
The above actions complete resolution of this deficiency and finalize TVA's response on this matter.
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