ML20092M736
| ML20092M736 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 06/20/1984 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8407020375 | |
| Download: ML20092M736 (2) | |
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' *.p TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 37401
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400 Chestnut' Street Tower II E JUN 25 Pl2 :'(1 June 20,1984 BLRD-50-438/81-28, BLRD-50-439/81-31 U.S. ~ Nuclear ' Regulatory Commission l
Region II Attn: 1 Mr. James P. O'Reilly, Regional Administrator-j 101 Marietta Street, NW, Suite 2900 i
Atlanta, Georgia 30323 l
Dear Mr. O'Reilly:
f BELLEFONTE NUCLEAR PLANT UNITS 1 AND 2 - INCONSISTENT ESTABLISHMENT OF f
' INSPECTION PROGRAM - BLRD-50-438/81-28, BLRD-50-439/81 FINAL REPORT
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.The subject deficiencies.were initially reported.to NRC-0IE Inspector P. A.- Taylor on March 24, 1981 in accordance with 10 CFR 50.55(e) as
'WBN NEB 8108-and BLN NEB 8103
.This.was followed *by;our-interim reports l
dated. April 12, June 9, and December 15, 1981; February 26, April 12, l
July 20,;and December 29, 1982; and April 22 and September 30, 1983. Our final l report for Watts Bar was submitted on September 30, 1983 Enclosed
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nisjour final-report for Bellefonte.
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' If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
Very truly yours,
[
TENNESSEE VALLEY AUTHORITY DS h
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..M. Mills, Manager
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Nuclear Licensing :
Enclosure t
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oc (Enclosure):
' Mr. Richard C. DeYoung, Director j
Office of Inspection and Enforcement j
- U.S. Nuclear Regulatory Commission l
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Washington, D.C.
20555 i
' Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway,' Suite 1500 l
Atlanta, Georgia. 30339 -
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l 8407020375 840620 i
PDR ADOCK 05000439 gpl y -
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L 1983-TVA 5OTH ANNIVERSARY i
An Equal Opportunity Employer
m ENCLOSURE
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.BELLEFONTE NUCLEAR PLANTS UNIT 1 AND 2
-INCONSISTENT ESTABLISHMENT OF INSPECTION PROGRAM NCR BLN NEB 8103 10 CFR 50.55(e)
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FINAL' REPORT t
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, Description of Deficiency j
LBefore January 16, 1979, TVA's Office of Engineering Design and Construction (OEDC) Quality. Assurance Procedure (QAP) OEDC-QAP 10.0, Revision 0, required that the Division' of Construction (CONST) be responsible for providing construction ' inspection mquirements. ; On January 16, 1979, OEDC-QAP 10.0 R1 l
uwas issued ' to mquire that the Divison of Engineering Design (EN DES) supply
-inspection requirements to CONST. Subsequently,.OEDC-QAP 10.0 R1 was
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superseded by the OEDC.QA Program Requirements Manual (PRM) which also 1
required.that EN DES supply inspection requirements to CONST.
In actual ~ practice, EN DES has specified certain inspection requirements
. (both general and specific). to CONST both before and 'since January 16, 1979, i
and CONST.has implemented the requirements; however, EN DES has failed to develop a comprehensive, documented program to implement the OEDC PRM requirement;. Therefore, EN DES's current. program does not ensure that adequate inspection requirements are or have been supplied to CONST. As a i
result, it' is possible that them are safety-related components / systems which
~have no.t been adequately inspcoted by CONST. This deficiency was brought about by a new requirement that was not moognized as a significant change 5
I
_ from past prac tice.
Safety Implications Since EN DES had failed ' to develop a documented program which would consistently establish inspection requirements of activities affecting quality for CONST, there could be components in essential safety-related systems that have not been adequately inspected. Therefore, TVA did not have adequate assurance that these components were not defective and could not have failed, (with resulting multiple failures of safety-related systems).
Such a condition-could, if left uncorrected, jeopardize the safe operation of the plant.
Corrective-Action-As a result of the OEDC Action Plan for Quality Improvement, EN DES action V-1, " Review of Process for. Conveyance of Design Requirements,"
the following actions are complete as noted for each:
1.
Requirements Control.and Use of the Construction Requirements
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Manual (CRM)
A.
EN DES has taken responsibility for the CRM for Bellefonte Nuclear Plant by issuance of EN DES Engineering Procedure (EP) 3.53, " Construction Requirements Manual, Preparation, Review,
,.Appecval, Issue, and Revision." The CRM for Bellefonte was issued March 30, 1984.
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EN DES-EP 3.53, dsfining tha EN DES responsibilitics for the CRM, was issutd July 20, 1983.
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EN DES has prepared a listing of the types of design documents that transmit safety-related requirements to CONST and TVA's Division of Nuclear Power (NUC PR). This list was checked, finalized, and included in the CRM which was developed in accordance with EN DES-EP 3 53 The CRM has been distributed to CONST and NUC PR.
This list will also be contained in Interdivisional Quality Assurance Procedure ID-QAP
' 2.8," Requirements Control' Program."
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. 2.
In accordance with EP 3.53, EN DES is now reviewing and approving l
the Bellefonte Quality Control Procedures (BLN QCP) listed in the CRM. All inspections performed before this problem was idettified are Judged to be adequate since the procedures that governed the inspection will now have EN DES approval. Any deficiency or problem encountered during the EN DES review is/will be documented, evaluated, and resolved with CONST. Any new or revised CONST procedures which are referenced in the CRM as being i
the implementing procedure for an EN. DES-specified inspection and related acceptance criteria are also reviewed by EN DES per EP 3 53 3
EN DES responsibility in the PRM under establishment of inspection program, 10QPR-1 ynus changed to read " Establish inspection and related acceptance criteria for inspections which are required by l
EN DES," on revision 2 issued January 11, 1983 1
4.
EN DES-EP 3 04,'"EN DES Construction Specification-Preparation, Review, and Approval," and EN DES-EP 3 53 define the method for writing, revising, and implementing future construction specifications.
5.
TVA issued the following interdivisional QA procedures when implementing the above CRM program:
-A.
ID-QAP. 2.7, "Q List."
B.
ID-QAP 2.8, " Control of design requirements for installation."
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