ML20128B753
| ML20128B753 | |
| Person / Time | |
|---|---|
| Site: | Bellefonte  |
| Issue date: | 04/25/1985 |
| From: | Hufham J TENNESSEE VALLEY AUTHORITY |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8505280053 | |
| Download: ML20128B753 (3) | |
Text
h TENNESSEE VALLEY AUTHORITY gg hy^%M,Jj CH ATTANOOGA. TENNESSEE 37401 400 Chestnut Street Tower II April 25, 1985 8.
BLRD-50438/81-28, BLRD-50439/81-31
- f78 U.S. Nuclear Regulatory Cmmission Region II Attn:
Dr. J. Nelsen Grace, Regional Administrator 101 Marietta Street, NW, Suite 2900 Atlanta, Georgia 30323
Dear Dr. Grace:
BELLEFWTE NUCLEAR PLANI WITS 1 AND 2 - INCDNSISTENT ESTABLISHENT OF INSPECTIN PROGRAM - BLRD-50438/81-28, BLRD-50439/81 SECOND EVISED FINAL EPORT The subject deficiencies were initially reported to NRC-0IE Inspector P. A. Taylor on March 24, 1981 in accordance with 10 TR 50.55(e) as NCR BLN NEB 8103 This was followed by our interim reports dated April 12, June 9, and Dece.aber 15, 1981 ; Febetary 26, April 12, July 20, and December 29, 1982; and Ap"il 22 and Septanber 30, 1983 as well as our final report dated June 20, 1984.
A revised fimi mport was sulxnitted on January 29, 1985. Enclosui is our second revised fimi report.
If you have any questions, please get in touch with 3. H. Shell at FTS 858-2688.
Very truly yours,
TENNESSEE VALLEY AUTHORITY
/. W. Hufham, Manager Licensing and Regulations Enclosure oc (Enclosure):
Mr. James Taylor, Dimetor Office of Inspection and Enforcement U.S. Nuclear Regulatory Cmmission Washington, D.C.
20555 Records Center Institute of Nuclear Power Operations 1100 Circle 75 Parkway, Suite 1500 Atlanta, Georgia 30339 Y
8505280053 850425 CO PDR ADOCK 05000438 S
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An Equal Opportunity Employer f
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~ENQ 0SURE 3%
- BELLEFmTE NUCLEAR PLANTS UNIT 1 AND 2' INCONSISTENF ESTABLISIDENT OF INSPECfIW PROGRAM BLRD-50-438/81-28, BLRD-50-439/81-31 n
NCR BLN NEB 8103 10 TR 50.55(e)
SECOND REVISED FINAL REPORT 5
Description of Deficiency Bef ore : January.16, 1979, ' TVA's Office of Engineering (OE) Quality Assurance Procedure (QAP) OE-QLP 10.0,, Revision 0, required that the Office of Construction (OC) be responsible for providing construction inspection requirements _.. i on January 16,.1979, OE-QLP 10.0 R1 was issued to mquire that
. thel0E supply inspection requimments to OC.
Subsequently, OE-QLP 10.0 R1 was superseded by the 08 QA Program Requirements Manual (PRM) which also-requimd that OE supply inspection requimments to OC. -
l In actual practice, OE has specified certain inspection requirements '(both i
general and. specific) to OC both before'and since January 16, 1979, and OC has
- implemented the requirements; however, OE has failed to develop a comprehensive, documented program to implement the OE PRM requirement. Therefore, OE 's program
, did not ensure that adequate inspection requimments were supolied td OC'in all
, cases. As a result, it is possible that there are safety-related components / systems which have not been adequately inspected by OC.
This
- deficiency was brotsht about by a new requirement that was not recognized as a significant change from past practice.
Safety Iaplications Since OE had failed to develop a documented program which would consistently establish inspection requirements of activities affecting quality for OC, there could have been components in essential safety-related systens.'that had not been
, adequately. ins pected. Therefore, TVA did not have adequate assurance that these components were not defective and could not have failed, (with msulting multiple failures of safety-related systems). Such a oondition, i f lef t uncorrected, could have jeopardized the safe operation of the plant.
Corrective Action As a result of the OE Action Plan for Quality Improvement, OE action V-1,
" Review of Process for Conveyance of Design Requirements," the following actions p
are complete as noted for each:
9
- 1. ' Requirements Control and Use of the Construction Requirements Manual (CRM)
A.
3 has taken responsibility for the CRM for Bellefonte Nuclear Plant (BLN) = by isstance of OE Engineering Procedure (!!P) 3.53.
" Construction Requimments Manual Pmparation, ' Review, Approval, Issue, and Revision." The CRM for BLN was issued March 30, 1984.
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1-IB.' L 2-EP 3 53,Ldcfining the OE msponsibilities. for tha CRM, was LissuedJuly 20,.1983 1C.
3 h'as prepared a' listing;of the types.of. design documents
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- that transmit sarety-related mquimments to OC and TVA's Ofrice of Nuciear Power (NUC PR). This list,was ' cheoked, finalized, and included in the. CRM.. The CRM has been distributed /to OC and NUC PR.
This list.will also be g
contained in Interdivisional Quality Assurance Procedure ID,
- SP 2.8,"Requimments Control Program."
2.
~In accordance with OE-EP 3.53,~ OE is now reviewing and -concurring with the
- BLN quality control procedures (QCPs) listed in the CRM. The. impactions perfomed before the implementation of EP 3.53 are judged to have,been
. adequate based on the 100-percent review of QCPs by'the onsite E
~
.orenization per Quality Assurance Staff Procedure -(QASP) 4.2 and -
Construction Quality Assurance Procedure (CEP) 7.09. The. review process
. described in these procedures included consideration of the design
. requimments applicable to the procedure tmder 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 problen enootstered during the.0E review is/will be docimented,' evaluated, and resolved with OC.
Any new or revised OC procedures which are referenced in the CRM as being the implementing procedure for an OE-specified inspection and related acceptance criteria are also myiewed by. 0E per EP 3 53
' 3.~
E ' responsibility in the PRM tmder establishnent of inspection program,10QPR-1 was changed to mad " Establish inspection and related acceptance criteria for inspections which are requimd by
< OE," on revision. 2 issued January 11, 1983
- 4. ' 3-EP 3.04, "0ES Construction Specification-P reparation, Review, and Approval," and.0E-EP 3 53 defines the method for writing, revising, and implementing future construction specifications.
5.
TVA issued the following interdivisional QA procedures when Limplenenting the above CRM program:
A.
ID-@P 2.7, "Centrol of the-Identification of Structures,
Systens, and Components within the Scope of.the Licensed
- Quality Assurance Program for TVA Nuclear Plants."
B..-
ID-@P 2.8," Requimments Control Program."
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