ML20107C482
| ML20107C482 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 01/29/1985 |
| From: | Hufham J TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8502210334 | |
| Download: ML20107C482 (3) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOGA, TENNESSEE 37401 400 Chestnut Street Tower II 65 ffB 4 BLRD-50-438/81-28, BLRD-50-439/81 g ya 8, 1985 29 3
U.S. Nuclear Regulatory Commission Region II Attn:
Mr. James P. O'Reilly, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear 'Mr. O' Reilly:
l BELLEFONTE NUCLEAR PLANI UNITS 1 AND 2 - INCONSISTENT ESTABLISHENT OF INSPECTION PROGRAM - BLRD-50-438/81-28, BLRD-50-439/81 REVISED FINAL l
REPORT The subject deficiencies were initially reported to NRC-0IE Inspector P. A. Taylce on March 24, 1981 in accordance with 10 CFR 50.55(e) as NCR BLN NEB 8103 This was followed by our interim reports dated April 12, June 9, and December 15, 1981; February 26, April 12, July 20, and December 29, 1982; and April 22 and September 30, 1983 as well as our final report dated June 20, 1984. Enclosed is our revised final report for Bellefonte.
If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
Very truly yours, TENNESSEE VALLEY AUTHORITY-
.W.
'f njaer L censing Regulations oc (Enclosure):
Mr. Richard C. DeYoung, Director Office of Inspection and Enforceme1t U.S. Ntelear Regulatory Commission Washington, D.C.
20555 Records Catter Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 8502210334 850129 DR ADOCK 05000438
'ORCIAE COPf, g
PDR l
An Equal Opportunity Employer
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.Q ENQ 03URE JS BELLEFONTE NUCLEAR PLANTS UNIT 1 AND 2
- 3NCONSISTENT ESTABLISIDENT OF INSPECTION PROGRAM NCR BLN NEB 8103 10 CPR 50.55(e) y REVISED FINAL REPORT Description of Deficiency Before January 16, 1979, TVA's Office of Engineering (OE) Quality Assurance 0
Procedure (QAP);0E-QAP 10.0, Revision 0, required that the Office of Construction (OC) be responsible for providing construction inspection requirements.- On January 16,1979, OE-QAP 10.0 R1 was issued to require that
- the OE supply inspection requirements to OC. Subsequently, OE-QAP 10.0 R1 was superseded by the 0E QA Program Requirements Manual (PRM) which also mquired xthat:0E supply inspection requiremmts to OC.
In', actual practice, OE has. specified certain. inspection requirements (both generali and specific) to OE both before and since January 16, 1979, and OC has implemen_ted the requimmets; however, OE has failed to develop a comprehensive, L'
documented program to implement the OE PRM requirement. Therefore, OE's program i
did not_ ensure that adequate inspection requimments were supplied to OC.
As a result, it is possible that,there are safety-mlated components / systems which
-have rot been adequately inspected by OC.
This deficiency was brought about by a new requirement that was not moognized as a significant change from past practice.
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' Safety Implications
'Since OE had failed - to develop a documented program which wauld consistently establish inspection requirements of activities affecting quality for OC, there could have been components in essential safety-related systems that had been
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. adequately inspected. Therefore, TVA did not have adequate assurance that these components were ' rot defective and could not have failed, (with maulting.
multiple-failures of safety-related systems). - Such a condition-could, if left
. uncorrected, jeopardize the safe operation of the' plant.
l Corrective Action-i
. As a result of the '0E Action Plan for Quality Improvement,' OE ' action V-1, Review'of Process for Conveyance of Design Requirements," the following actions b
.are complete as noted for each:
l-1_.
Requirements Control and Use of the Construction Requirements Manual (CRM)
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A.
OE has taken responsibility for the CRM for;Bellefonte Nuclear Plant'
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(BLN) by issuance of 0E Engineering Procedure (EP) 3.53, j
- "Construetion Requirements Manual Preparation, Review, Approval, J
Issue, and Revision." The CRM for BLN was issued March 30,' 1984.
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OE-EP 3 53, dt; fining tha OE responsibilities for tha CRM, wts
_ is:;ued July 20, 1983.-
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OE has prepared a listing of the types of design documents that transmit safety-related requimments to OC and TVA's Office of. Nuclear Power (NUC PR). This list was checked,
-finalized, and. included in-the CRM. The CRM has been distributed to OC and NUC PR.
This list will also be contained in Interdivisional Quality Assurance Procedure ID-QAP 2.8," Requirements Control Program."
- 2.
In accordance with OE-EP 3 53, OE is now reviewing and approving the BLN quality control procedures (QCPs) listed in the CRM. The inspections performed before the implementation of EP 3.53 are judged to have been adequate based on the 100-percent review of QCPs by the onsite QA organization' per ' Quality Assurance Staff Procedure (QASP) 18.2 and Construction: Quality Assurance Procedure (CQAP) 7.09. The review process described in these procedures included' consideration of the design -
requirements applicable to the procedure under review. In addition, the construction engineering and quality control personnel.have completed a historical myiew of site procedures to ensure that all pertinent technical
. requirements were met. Any deficiency or problem encountered during the OE review is/will be documented, evaluated, and resolved with OC.
Any new or revised OC procedures which are referenced in the CRM as being the implementing procedum for an OE-specified inspection and mlated acceptance criteria are also myiewed by OE per EP 3.53
. 3 OE responsibility in the PRM under establishment of inspection program, 10QPR-1 was changed to read " Establish inspection and related acceptance criteria for inspections which are required by OE," on revision 2 issued January 11, 198 3
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'i. OE-EP -3.0!I, "0ES Construction Specification-Preparation, Review, and Approval," and OE-EP 3.53 defines-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, " Control of the Identification of Structures, Systems, and Components within the Scope of the Licensed Quality Assurance Program for TVA Nuclear Plants."
B.
ID-QAP 2.8," Requirements Control Program."'
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