IR 05000327/1980046
| ML20003F444 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/10/1981 |
| From: | Belisle G, Fredrickson P, Ruhlman W, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20003F436 | List: |
| References | |
| 50-327-80-46, NUDOCS 8104210257 | |
| Preceding documents: |
|
| Download: ML20003F444 (23) | |
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'V 8'p ugg'o, UNITED STATES p
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NUCLEAR REGULATORY COMMISSION
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aE REGION ll
101 MARIETTA ST., N.W., SUITE 3100 e
ATLANTA, GEORGIA 30303
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Report No. 50-327/80-46 Licensee: Tennessee Valley Authority 500A Chestnut Street Chattanooga, TN 37401
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Facility Name: Sequoyah 1
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Docket No. 50-327 License No. DPR-77
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Inspection at Sequoyah site near Chattanooga, Tennessee Inspectors:
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Date Signed
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2 Ao/M P.' E. Fredrickson Di(te ' Signed Y
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W. A. RuhTma f D4te Signed
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P. H. Skinner '
Date Signed Approved by: b Z.!/O 8/
C. M. Upright ectyn Chief, RONS Branch Ortepigned
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SUMMARY
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Inspection on December 4-5 and 8-10,1980 Areas Inspected.
This routine, announced inspection involved 148 inspector-hours on site in the areas of QA pregram review, QA/QC administration; organization and adminis-tration; qualification of personnel; design changes and modifications; test and experiments; procurement; receipt storage and handling; housekeeping and clean-liness; training; requalification training; and central laboratory activities.
Results Of the 12 areas inspected, no violations were identified in 8 areas; 12 apparent violations were found in 4 areas; (Failure to accomplish calibration of nuclear instrumentation under suitable environmental conditions, paragraph 16.a;
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810.4210j$77 l
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Failure to follow training procedures at Central Labs, paragraph 16.b; Failure to establish program to control or monitor central laboratory environment, paragraph 16.c; Failure to obtain corrective action, paragraph 16.d; Failure to take appropriate corrective action on audit findings, paragraph 16.e; Failure to maintain retraining of staff, paragraph 14.a; Failure to perform comprehensive audit of training areas, paragraph 14.c; Failure to maintain weathertight storage, paragraph 12.b; Failure to protect weld end preparations, paragraph 12.a; Failure to perform audits, paragraph 16.1; Failure to maintain training records, paragraph 14.b; Failure to, have cleanliness or housekeeping procedures, paragraph 13.a).
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DETAILS
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1.
Persons Contacted Licensee Employees
- W. Andrews, NCO - QA Staff, Nuclear Power
- J. Ballentine, SNP Plant Superintendent
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C. Brennon, Supervisor-Power Stores Modification
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R. Cantrell, Design Project Manager
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J. Coan, Assistant to DES Project Manager E. Cole, Project Control Engineer
- W. Cottle, SNP Compliance Supervisor
- A. Crevasse, PM0 - QA Manager
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- T. Frizzell, Training
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J. Gaines, Supervisor - Power Stores Unit
- A. Gelston, SNP Compliance
- W. Glassen, OPQA&AS QA Coordinator - SNP
- J. Harltey, Supervisor - Electrical Laboratory
- L. Hebert, OEDC - QA Staff P. Landum, Supervisor - Instrument Mechanic and Calibration
- T. Lee, PM0 - OPQAAS, Audit Section Supervisor R. Lewis, Senior Instrument Mechanic Foreman
- D. Mr. Cloud, SNP QA Supervisor
- I. McLeo, Plant Information Officer
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C. Myers, Head Nuclear Engineer -
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R. Parker, Assistant to the Ma' nager for Plans and Programs B. Patterson, Instrument Engineer
- H. Riley, Public Safety (Power)
S. Stout, Licensing C. Stutz, QA Engineer
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Other licensee employees contacted included technicians, o'perato 2, and
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office personnel.
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NRC Resident Inspector
- S. Butler
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Exit Interview
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The inspection scope and findings were summarized on December 10, 1980, with those persons indicated in paragraph 1 above. The licensee was informed of
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the violations in paragraphs 12.a,12.b,13.a,14.a-c,16.a-e and 16.1; open (
items in paragraphs 5,12.c,12.d 16.f, and 16.g'e licensee acknowledged and inspector followup
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items ia paragraphs 7, 8, 9, 11, 13.b and 16.h. Th the inspection findings.
The following terms are defined and used throughout this report:
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Accepted Quality Assurance Program - TVA-TR75-IA, Revision 4 dated 8/80 CSSC Critica1 Structures, Systems and Components
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DCR Design Change Request ECN Engineering Change Notice FCR Field Change Request GET General Employee Training LER Licensee Event Report M&TE Maintenance and Test Equipment
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NIS Nuclear Instrumentation Systera N-0QAM Nuclear-Operations Quality Assurance Manual NRR Nuclear Reactor Regulation NSRB Nuclear Safety Review Board
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QA Quality Assurance
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QAM Quality Assurance Manager QC Quality Control RCS Reactor Coolant System STEAR Special. Test, Experiments 'and Activities Request 3.
Licensee Action o Previous Inspection Findings Not Inspected.
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Unresolved Items
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Unresolved items were not ide$tified during this inspection.
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5.
QA Program Annual Review (35701)
References:
a.
TVA Topical Report, TVA-TR75-1A, Revision 4 dated August 1980
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Letter, L. Mills to W. Haasrs, dated April 1,1980
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c.
Letter, W. Haass to L. Mills, dated August 13, 1980
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The licensee had made one change to the accepted QA Program since the previous (December 1978) inspection in this area. This change was reviewed to assure that the requirements of 10CFR50, Appendix B, and the accepted QA Program were being met. As a result of this review, one open item was identified. The licensee was notified by reference c. of NRR acceptance of TVA-TR75-1A Revision 4.
The licensee is currently incorporating changes required by reference c.
into their quality assurance manuals.
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changes are targeted to be completed by March 31, 1981, with changes to plant procedures implemented 45 days later.
Until Revision 4 is fully incorporated, this item is open (327/80-46-15).
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QA/QC Administration Program (35751)
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a.
N-00AM, Appendix A, Parts I-IV l
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SQA-45, Quality Control of Material and Parts and l
Services, dated 9/80 c.
N-0QAM, Part III, Section 2.0, Procurament of Materials, Components, and Spare Parts, Revised 11/80
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d.
N-0QAM, Part III, Section 8.0, Operational Quality Assurance Manual - Preparation, Maintenance, and Imple-mentation, Revised 11/79 The inspector reviewed the licensee's program documents, references a.-d.,-
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to verify that they define the structures, systems, components and acti-
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vities to which the program applies and that procedures exist for making changes to these documents. The inspector also reviewed the program to i
assure that administrative controls for QA Department procedures, inspection and audit activities, and manuals exist to provide the following:
review and approval prior to issuance, methods and procedures for changes and revisions, and mqthods and controls for distribution and recall.
Based on this review, no violations or deviations were identified.
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Organization and Administratig,n1(36700)
References:
a.
Technical Specification, Section 6.2.2, Unit Staff and Section 6.3, Unit Staff Qualifications b.
Sequoyah Letter, Subject: " Plant Organization -Sequoyah Nuclear Plant", dated 9/80.
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c.
Proposed Technical Specification Change, " Technical i
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Specification Revision - Plant Organization", dated 10/80.
i The inspector verified that the ansite organizational structure conformed to the Technical Specifications and also that any changes to the organizational structure have been reported to the NRC as required. The inspector reviewed reference c. as compared to the existing organization and also reviewed reference b. which reccgnized the existing organization, but also prepared for the possible future reorganization. Based on this review, one inspector followup item was identified. The Technical Specification change proposed by the licensee has been submitted by the plant but has not been forwarded to NRR. Pending the Technical Specification change being submitted to NRR, this item (327/80-46-23) will be reviewed as an inspector followup item.
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Qualification of Personnel (36701)
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References:
a.
Technical Specification, Sectica 6.3, Unit Staff
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Qualification
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b.
QA-SIL-10.6, Inspections - QC Inspector Certification, Revision 0 dated 11/80 c.
DPM No. N75C01, Qualification and Certification Program for Nondestructive Examination Personnel, Reviseh 7/77 d.
QA-SIL-10.1, Inspection - Material Receipts, Revision 3 dated 10/80
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H-00AM, Part II, Section 5.3A, Training and Certif t- - ',
cation Program for QC Inspectors, dated 10/80
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N-0QAM, Part II, Section 5.3, Maintenance and Modifica-tions Inspection Program dated 10/80
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AI-20, Inspection Program, Revision 5 dated 9/80
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The inspection consisted of ascertaining whether the licensee has a QA program relating to qualification of personnel that is in conformance with regulatory requirements and licensee commitments. The inspector verified
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that qualifications had been e,s'tablished for personnel in the onsite organ-
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ization. The inspector reviewed the qualification of the plant superinten -~
dent, the assistant superintendent, the maintenance, operations and results (
supervisors, the QA staff supervision, 4 reactor operators, 3 electricians, 3 mechanics and 2 inspectors. Based on this review, one inspector followup item was identified.
Using references b.,
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and f., the inspector determined that no system
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exists at present for the " testing, evaluation" of personnel attending
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training courses in preparation for certification as QC or receipt inspectors as required by ANSI 45.2.6-1973, paragraph 2.2.
However, based on a review of the N-0QAM by the licensee in response to open item 327/78-I 39-01, a new addition to the N-0QAM, reference e., has been added. This l
section satisfies the evaluation requirements of ANSI N45.2.6. The imple-mentation date for this section is January 1,1981, for new certifications and July 1, 1981, for recertifications. The implementation of this program will be reviewed at a later inspection and thus is identified as an inspector followup item (327/80-46-22).
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Design Changes and Modifications (37700, 37702)
References:
a.
N-0QAM, Part II, Section 3.2, Plant Modifications:
After Licensing, Revised 1/80 b.
N-0QAM, Part II, Section 3.2A, Core Component Design Change: Af ter Licensing, Revised -10/80
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AI-19 (Part III), Flant Modification: After Licensing, Revision 3 dated 4/80 d.
TVA-TR75-1A, Quality Assurance Program for Station Operation, Revision 4 dated 8/80 e.
AI-9, Control of Temporary Alterations and Use of the Temporary Alterations Order, Revision 9 dated 5/80 l
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N-0QAM, Part II, Section 6.4, Temporary Conditions for Special Test, Revised 10/80 g.
OSLT-2, Licensed Operator and Senior Operator Review of
Facility License Changes and Revision to the Facility Standard Technical Specifications, dated 5/80
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Interdivisional Quality Assurance Procedures Manual dated 9/79
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SWP-EP 43.05, Engineeing Change Notice Procedure, Revision 4 dated 11/73
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EN DES-EP 4.02, Engineering Change Notices - Handling, Revision 9 dated 9/79
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ENDES-ER.jiO3,FieldChangeRequests, Revision 4 dated
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EN DES-EP 4.18, Design Change Requests (DCR's)
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Processing, Reviewing and Approving, Revision 2 dated 9/80 DeteFmination of
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EN DES-EP 2.03, Modifications
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i Unreviewed Safety Quastions, Revision 2 dated 5/79
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EN DES-EP 3.01, Design Criteria Documents - Preparation, Review and Approval, Revision 4 dated 11/80 The inspector reviewed the licensee's procedures for conducting the design change program (DCR's, FCR's and ECN's) to determine that the following had l
been accompitshed: procedures and responsibilities for design control have l
been established; administrative controls for design document control have been established; responsibilities have been assigned in writing to assure
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implementation of the design control program; administrative controls and responsibilities have been established to assure design changes are incor-porated into plant procedures, operator training and the updating of drawings; controls have been developed that define channels of communication between design organizations; administrative controls require that design documentation and records are available which provide evidence that the design and review process was performed; controls require implementation of approved procedures; procedures require post modification testing be
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performed per approved instructions and the results evaluated; and controls of similar scope and content have been established for temporary alterations (jumpers and lifted leads).
The following plant modifications were reviewed to verify implementation of established controls:
ECN L-5187 Remove RCS Water Solid Hi Pressure Alarm from PS-68-68A and Connect New Pressure Switch, completed 6/80.
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ECN L-5074 Change Out Five Obsolete International Nuclear Safeguards Corporation Restraints with Pacific Scientific Company Restraints, Completed 9/80 ECN L-5239 Post Accident Cables, Completed 10/80
,.7 ECN L-5133 Change Instrument Setpoints, completed 3/80 ECN L-5153 Rulocate Instruments and Handswitches on Control Board, Completed 3/80 ECN L-5142 Rgl'ocate Gage PdI-30-151, completed 9/80 As the results of this review, one inspector followup item was identified.
Reference a. and c. define terms used in conjunction with the design change
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program. Definitions common to both documents ' clude design change request, field change request, work plhn and outstanding work item list. There is --
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sufficient variation between definitions to be confusing.
Until these definitions are clarified and consistent, this is identified as inspector followup item 327/80-46-19.
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Test and Experiments Program (37703)
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References:
a.
N-00AM Part II Section 4.6, Special Tests, Experiments,
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or Activities, dated 3/79 b.
SQA-100, Special Tests, Experiments or Activities, dated 9/80 The inspector verified the following aspects of the test and experiments program:
that a formal method has been established to handle all requests or proposals for conductir.g special tests involving safety-related com-ponents; that special tests will be performed in accordance with approved procedures; that responsibilities have been assigned for reviewing and approving special test procedures; that a system, including assignment of responsibility has been established to assure that special tests will be reviewed; that responsibilities have been assigned to assure a written safety evaluation required by 10CFR50.59 will be developed for any special test to assure that it does not involve an unreviewed safety evaluation or
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change in Technical Specifications; and that responsibility has been assigned to assure that any special test will be reported to the NRC in a timely manner as required by 10 CFR 50.59.
The inspector reviewed five special tests completed in 1980. The following tests were reviewed to verify the aspects previously mentioned:
STEAR-3, Special Test #3, Natural Circulation with Loss of Pressurizer Heaters.
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STEAR-13, Unit #1, Feedwater and Steam Generator Piping Monitoring to Determine Propensity for Nozzle Cracking During Low Flow Conditions STEAR-16, Testing of Transformers Supplying Vital Busses per Regulatory
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STEAR-17, Acquiring Vibration and Dynamic Pressure Data During Testing of Auxiliary Feedwater Suction Piping STEAR-18, Operation of Rod Control System for Testing During Mode 5 No violations or deviations were identified.
11. Procurement (38701)
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N-0QAM, Par't III, Section 2.1, Procurement of Materials,~
References:
a.
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Components and Spare Parts, dated 4/79 b.
SQA-45, Quality Control of Material and Parts and Services, dated 9/80 c.
TI-32, Changing QA Levels and Descriptions of Quality f
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Assurance Materials and Spare Parts, Revision 6 dated
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AI-7, Recorder Charts and Quality Assurance Records, Revision 17 dated 9/80
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The inspector reviewed the licensee's procurement program with respect to l
selected elements of the accepted QA Program, which commits to Regulatory Guide 1.123 (Revision 1), July 1977, which endorses ANSI N45.2.13-1976. The l
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for the preparation, review, approval and revision of procurement documents.
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procurement documents of several safety-related items and verifying that i
they were prepared in accordance with administrative controls, that they were purchased from qualified vendors and that they required the vendor to
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supply appropriate documentation of quality. The specific items selected were the following:
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i Contract Number Quality Level 78P87-249423
As a result of this review, one inspector followup item was identified.
During a rev.iew of reference d., the inspector observed that procurement records are maintained in temporary storage for a period of two years. The accepted QA Program, which takes exception to ANSI N45.2.9 for temporary storage, commits to three months maximum temporary storage with any exceptions listed in the N-0QAM. The N-0QAM has no list and most records indexed in reference d. have the two year retention time for temporary
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'7 storage. This problem was also identified by the licensee in QC Survey 16-80-1, Item No. B.8 and documented in Corrective Action Report 16-80-156, dated 12/2/80. Adequate response, prompt corrective action and licensee followup will be reviewed at a later inspection. This problem area will be carried as inspector followup item 327/80-46-21.
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12.
Receipt, Storage and Handling (38702)
References:
a.
N-0QAM, Part III, Section 2.2, Receipt Inspection, Handling, Storage of Materials, Components and Spare
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' Parts,-dated 4/79
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AI-11, Material-Receipt Inspection, Revision 11 dated 8/80 c.
AI-13, Nonconforming Items, Revision 14 dated 8/80 o
The inspector reviewed ~the licensee's program for the receipt, storage and
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handling of equipment and material with respect to selected elements of the i
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licensee's accepted QA Program, which commits to Regulatory Guide 1.38, March 16, 1973, which endorses ANSI N45.2.2-1972. The inspection was to verify that administrative controls had been established concerning receipt inspection of safety-related materials, preparation and retention of required documentation, control of acceptable noncomforming and conditional
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release items and control of items in storage.
Implementation of the program was reviewed by selecting several safety-related items in storage and verifying document and item control to be in accordance with the pro-i gram. The specific items selected were the following:
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Item Contract Number 1" Weld Neck Flange 78P87-249423
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Fluid Valve Stem 78PA2-249421
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3/8" S.S. Tube 79P88-272956
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l Fluid Filter Element 80P34-308623 Slip On Flange 79P88-280009
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As a result of this review, two violations and two open items were identi-fied as discussed in paragraphs 12.a - 12.d.
a.
Failure to Protect Weld End Preparations During the tour of the Modification Outage Warehouse, the inspector noted that several stainless steel elbows and tees stored under ECN L5009 did not have protective caps or plugs over the weld end preparations. Both reference a. and b. require that " caps and plugs should be used to... protect threads and weld end preparationsi" The inspector did not notice any observable damage to the weld end prepara-tions.
This failure to follow procedures is a violation.
(327/80-46-09).
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Failure to Maintain Weathertight Storage
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While inspecting warehouse 0B-3, the inspector observed several water leaks in the roof of the warenouse.
Several cardboard packing' con-tainers with quality level 2 and 3 insulation and filters (TIIC Nos.
ATL-288A and AND-938R) were soaked from the water leakage.
The at :epted QA Program, Section 17.2.13 requires that measures shall be established,to control the storage of material and equipment to prevent damage. The Program also commits to ANSI N45.2.2-1972 which requires that filters and insulation be stored in an enclosure that is weather-tight. This failure to properly store quality items is a violation
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(327/80-46-08).
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c.
Incorporate AI-11 Requirements for Modification Outage Warehouse
Reference b. is used for receipt, handling and storage of quality
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items, but appears to be specifically directed toward the permanent storage building. The Modification Outage Warehouse utilizes reference b. for daily operation, yet several storage points, such as eating
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areas and storage areas for storage level _A items (ANSI N45.2.2-1972)
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are not addressed in. reference b.
The licensee has committed to a
completion date of March 31, 1981, for updating reference b. to take
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into account the configuration of the Modification Outage Warehouse.
Until this update has been completed and revieweo, this item is open i
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Reevaluation of Storage Crf teria for Equipment Requiring Rotation or l
Meggering l
In Table 17.2-5, of the licensee's accepted QA Program, TVA commits to compliance with the requirements of ANSI N45.2.2-1972.
Paragraphs 6.4.2(7) and 6.4.2(6) require, respectively, that storage maintenance programs shall assure that rotating equipment is manually rotated and that electrical equipment is meggered; currently TVA does not have a
. When the inspector program in use to accomplish these objectives.
reviewed this area in the licensee's procedure (reference b.), he
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identified a limitation with respect to application: paragraphs 4.2.e
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and f state that these controls will be applied only if recommended by the manufacturer or the originator of the requisition. The inspector also reviewed purchase orders and found that manufacturers are not
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l specifically requested to identify components which should be meggered or rotated in storage; however, storage requirements are an attribute
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i to be considered by the requisition originator when preparing a pur-chase order.
During subsequent discussions of the matter, the l
inspector acknowledged the licensee's statement that all equipment (e.g., clock motors, fractional horse power motors) would not ' require I
routine meggering or rotation; the licensee agreed that the current
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definitions might be more restrictive than intended by the Standard.
Based on this discussion, the licensee stated that this aspect of
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j storage would be reevaluated by March 31, 1981, to determine if
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additional criteria or less restrictive definitions of applicability-
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are necessary.
Untti this evaluation has been completed and the results have been evaluated by the NRC, this item (327/80-46-17) is open.
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13. Housekeeping and C1eanliness Control (54701)
References:
a,I SQE-7, Cleanliness Control for Piping Systems, dated l
9/80 b.
SQA-66, Plant Housekeeping - Solid Waste Management,
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dated -12/.7.9'.-
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SQM-46, Housekeeping Programs for Safety-Related System Maintenance, dated 2/80 d.
DPM N74A17, Housekeeping in Nuclear Power Plants, I
revised 9/80
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The inspector reviewed the licensee's housekeeping and cleanliness program i
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to verify whether the licensee is implementing adequate controls to assure
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i the quality of safety-related systems is not degraded.
As the results of this review, one violation and one inspector followup item were identified as discussed in paragraphs 13.a and b.
a.
Failure to Follow Procedure Criterion V and Section 17.2.5 of the accepted QA Program require that
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activities affecting quality shall be prescribed in procedures and
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accomplished in accordance with those procedures.
Reference b.
requires that each section supervisor shall establish appropriate controls to meet the requirements of this standard.
Procedures and instructions for housekeeping practices...snall be prepared and issued as required. Each section supervisor has not established appropriate controls to meet the stated requirements of reference b.
This is a violation (327/80-46-12).
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Plant Tour Observations
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During a plant tour the inspector noticed the following problem areas:
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- Water on floor in Battery Rooms 1 and 2
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- Water on floor in cable spreading room
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- Water on floor in area of motor driven auxiliary feed pumps
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- Water leakirg from auxiliary building sprinkler suppression system l-into barrel marked contaminated waste.
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Until corrective action is taken and these areas reinspected, these items are designated in.pector followup item (327/80-46-20).
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14.
Nonlicensed Personnel Training (41700)
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References a.,
Technical Specification 6.4, Training
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FSAR 13.2.2, General Employee Training c
AI-14, Plant Training Program, Revision S, dated 10/80
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Quality Assurance Section Instruction Letter Number
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18.1, Rev,1,sion 4 dated 11/80
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The inspector reviewed the training program which provides GET for both
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licensed and non-licensed personnel. The GET program was reviewed to verify i
that:
the program complies with commitments (references a.
through d.
above); that the program covers training in the areas of administrative controls and procedures, radiological health and safety, industrial safety,
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security procedures, emergency plan and quality assurance training, formal
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technical training commensurate with job classification, fire fighting f
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training and pre-natal radiation exposure training for females and super-
visors; and audits conducted by the licensee in the areas of general employee training and documentation of training records were adequate. The inspector reviewed approximately 80 training records of the unit operating i
personnel and interviewed eight persons (four licensed and four non-
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licensed). Quality Assurance Audits OPQAA-SQ-79-06 and OPQAA-SQ-80-02 and compliance surveillance 2-79-2 dated 12/11/79 which provided audits of the GET program were also reviewed.
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As a result of this review, the inspector identified three violations as j
discussed in paragraphs 14.a-c.
a.
Failure to Conduct Retraining and Replacement Training Technical Specification 6.4.1 requires that a retraining and replacement training program for unit staff shall be maintained under the direction of the Assistant Plant Superintendent. This program is described in reference
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c.
Retraining of the unit staff is not being maintained as described in reference c., in that:
(1)Section III, page 46, item (22) requires fire brigade member refresher training for maintenance craftsmen be performed every 12 months. A
maintenance craf tsman (steamfitter) received fire brigade training initially on 3/8/78 and has not received retraining (based on document review and interview) as of 12/10/80; a period of 33 months.
(2)Section III, page 46 requires retraining on Plant Tur <eillance Test Program (item 11) and Control of Measuring and Test Equipment (item 13)
to be conducted biannually.
A maintenance craftsman (boilermaker)
received initial training on item 11 on 2/26/76 and on. item 13 on 2/2/76.
Based on documentation review, he has not received the
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required retraining as of 12/4/80, a period of over 4 years.
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(3)Section III, page 83 requires retraining on Clearance Procedures (item 10), Adverse Conditions and Corrective Action (item 11), Plant'Sur-veillance Test Program (item 12), and Control of Measuring and Test Equipment (item 14) to be conducted biennially. Based on documentation review and personal interview, a QA Supervisor received initial train-ing for itep 10 on 12/5/77, item 11 on 7/29/77, item 12 on 11/14/77, and item 14 on 11/14/77. He has not received retraining in these areas as required; a period of 3 years.
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The above examples are typical, not all inclusive. This failure to conduct retraining is a VTolation (327/80-46-06).
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b.
Failure to Maintain Records of Training and Qualifications Technical Specification 6.10.2.g, requires that the records of training and qualification for current members of the unit staff shall be retained.
Records of training and qualifications for three current
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members of the unit staff were not available. Specifically:
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c (1) The records of two Senior Reactor Operators, currently members of the unit staff, did not contain evidence of completion of licensed operator training nor did they contain any indication or evalu-ation which would indicate that the required records were available at some other location.
(2) The computer record for a radchem technician, currently a member of the unit staff, indicated that none of the required reference
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c. training had been completed.
The training folder for this individual indicated that ; curity training (one of twenty
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required training areas) had been completed at Browns Ferry Nuclear Station.
The above examples are typical, not all inclusive.
However, all examples including those cited above were for personnel temporarily assigned to the Sequoyah unit staff. Reference c. details how records
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requirements of Technical Specification 6.10.2.g are to be implemented and makes record keeping requirements (I.F.1 and II.F.5) applicable to temporary employees.
The inspector verified with the resident inspectors at Browns Ferry and Watts Bar Nuclear Stations that the personnel reviewed above were trained and the training records at those sites contained training documentation.
This failure to maintain records of training and qualificatiFn is a violation. The inspector determined that the required training had been performed and only documentation was inadequate. (327/80-46-11)
c.
Failure to Perform Comprehensive Audit in Areas of Training
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10CFR50, Appendix B, Criterion XVIII, requires a comprehensive system of planned and periodic audits to be carried cut to verify comp 1.iance with all aspects of the quality assurance program. The accepted QA Program, Sec, tion 17.2.18 requires that audits shall be conducted to ensure compliance with training requirements. Comprehensive audits of training were not conducted in that:
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(1) Audit OPQAA-SQ-79-06 conducted August 8-10, 1979, reviewed the training area with respect to the plant training program and only determined that one area of training (QA/QC training as set forth
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in DPM N75A1) was inadequate, when in fact, at the time of the
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audit approxim'ateli' 50% of the plant staff were delinquent in -'
retraining or lacking initial training.
(2) Compitance Audit - Inplant Survey Checklist No. 2-79-2, conducted
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on November 12, 1979, reviewed the training area, specifically implementation of AI-14, and determined that no deficiencies were
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found.
Reference d. requires that personnel performing a survey r
shall observe activities to a sufficient extent to permit-valid
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observation.
At the time of this survey, as with the audit previously mentioned, 50% of the plant staff were delinquent in retraining or lacking initial training.
This failure to perform a comprehensive audit is a violation (327/80-46-07).
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15.
Licensed Operator Requalification Training (41701)
References:
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Technical Specification 6.4, Training b.
FSAR 13.2.6, Retraining for Operators
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AI-14, Plant Training Program, Revision 9 dated 10/80
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The implementation of the accepted requalification training program was reviewed to verify that the licensee has prepared a schedule for conducting lectures and prepared lesson plans or equivalent for training lectures presented.
The inspector revit2ed the following areas:
retraining con-ducted in 1980; copies of annual written examinations and the individual's
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response; documentation of attendance at required lectures; documentation of required control manipulations; documentation of completion of required procedure reviews; and the records of eight licensed operators.
Dis-crepancies observed during this review are discussed in paragraph 14 b.
As a result of this review no additional violations (other than that described in paragraph 14.b) were identified.
16.
Central Laboratory Activities (92706)
p The activities of the Central Laboratories, the calibration facility for non-radiological M&TE, were reviewed with respect to the requirements of the quality assurance program necessitated by the interface and support of the TVA nuclear facilities. Records for three current employees were selected and reviewed to assure that specified training requirements had been com-pleted and documented; interviews were then conducted with each of the three employees to verify that the documented training had been received and that other Program requirements had been implemented. QA audits'(76-SP-6, 76-1,
77-1, 77-SP-7, 78-1, 79-01, 79-04 and 8000-04) were reviewed for the last five years to determine if identified problems were being corrected, i
Laboratory environmental contrdls and data presentation to the nuclear facilities were also reviewe'd.' As a result of the above inspection, six ~
violations, two open items, and one inspector follevup item were identified
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as discussed in paragraph 16.a - 1.
a.
Failure to Accomplish Calibration of Nuclear Instrumentation Under Suitable Environmental Conditions and Inadequate Calibration Procedures
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Leakage current measurements on all three ranges of nuclese instrumen-i
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tation are measured using an electrometer.
The instrument used (Keithely, Model 602) is calibrated by the Central Laboratory; the data sheet issued contains a statement that, " Readings (are) valid for environment of less than 60% relative humidity only." Three procedures which require the Keithley 602 are used on CSSC systems (Nuclear Instrumentation System - NIS) at Sequoyah: IMI-92-SRPC, Source Range i
Proportional Counter Testing, Revision 1 dated 4/3/80; IMI-92-IRIC,
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Intermediate Range Compensated Ion Chamber Testing, Revision 0 dated 4/3/80;; and, IMI-92-PRIC, Power Range Uncompensated Iunization Chamber Testing, Revision 1 dated 3/19/80. None of these procedures contain a
l precaution to use the instrument only when the relative humidity is
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less than 60% and none require that relative humidity be measured or recorded. After obtaining a daily measurement of the relative humidity l
I in the Sequoyah area from the National Oceanic and Atmospheric Admin-l istration station at Lovell Field, data sheets from the above three tests were reviewed. The inspector found that for some period during
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all of the days, and for the entire period of several of the days on
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which data were recorded, the relative humidity exceeded 60%.
The
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Source Range tests on 1/9 and 2/6/80 and the Power Range tests on 1/9, 1/17,1/26 and 5/14/80, were all conducted when the Lovell Field data for the entire day (taken at three hour intervals from 1:00 a.m.) were above the 60% relative humidity value. The Intermediate Range data were only taken once, on 2/14/80 -- the relative humidity was greater than 60% that day before 10:00 a.m. and after 7:00 p.m.; the time the data were taken is not given.
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These examples of inadequate environmental control of measurements which could affect the safety related functions of NIS channels is combined with the inadequate calibration procedures (which failed to specify the required controls) to constitute a violation (327/80-46-
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b.
Failure to Follow Training Procedures l
Procedure 102, Inspection, Maintenance, and Calibration Personnel Qualification, Revision 0 dated 3/13/79, requires that: (II.3.A) the capabilities. and proficiency of personnel shall be determined by suitable performance demonstration, including oral review of per-formance; and (II.S.A (3) and (8)) the qualification of personnel shall be documented in an appropriate form that includes the level of
capability and the date of qualification and qualification expiration.
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In addition, Procedure 2.02, Measuring and Test Control, Revision 1 dated 4/7/80, requires - (VI.5.A) that periodic training shall be
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administered to-those performing calibrations. The above requirements are also included in the accepted QA Program through the commitment to
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comply with ANSI N45.2.6.
Records reviewed showed that level of capability and date of qualifi-
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cation and qualification expiration were not included 'since they had t
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expired in July 1979. While the licensee'_s records did not contain the
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levels of capability or the period of qualification /date of expiration, they did contain data which would properly support the required certi-fication. The evaluation was performed, but not documented as required.
Interviews with supervisors and laboratory personnel indicated that the required periodic training and the oral review of performance were
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neither conducted nor documented.
l Interviews also indicated that the checkout on new procedures is not I
always cor. ducted before allcwing unmonitored performance in that personnel are sometimes given a new procedure (but similar to one which I
they are qualified to perform) and told to perform the procedure and to seek assistance if they have questions. While this practice is not specifically precluded by the procedures, it is also not specifically delineated as acceptable. All cases of "unmonitored" first perfor-mances were notad only in cases of senior technicians and only where l
very similar procedures had been previously performed.
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The three examples of failure to follow training procedures, cul-1ectively, constitute a violation (327/80-46-02).
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Failure to Establish a Program to Control / Monitor Laboratory Environ-ment Procedure 202, Measuring and Test Equipment Control, Revision 1 dated 4/7/80 requires (VI.6. A) that the laboratory shall be maintained with i
adequate temperature controls and (VI.7.A) that working areas (other j
than the Standards Laboratory) shall be maintained at a temperhture of l
9*F.
The licensee does have indicating thermometers and a hygro-
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meter in other working spaces, but these are not recorded, alarmed, or required to be read and documented. Although the required temperature was observed by the inspector on the day of the inspection, the outside i
temperature was also within those limits.
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Since no responsibilities for measurements or recording had been i
established and no documentary evidence was available to substantiate
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compliance and since no procedures _had been documented to follow if l
temperature limits are exceeded, no program to control laboratory
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environment was deemed to exist.
This - failure to establish the l
required program is a violation (327/80-46-03).
d.
Failure to Obtain Required Corrective Action
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t Audit CH-7900-01, conducted 4/17-18/79, identified two' findings which had not been corrected 6F escalated as required. Finding B02 was that -
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activities affecting qualify are not always prescribed by documented instructions at the Central Laboratories; finding 803 was that Central Laboratory procedures do not contain some required document controi measures. These items had both been reinspected on 9/24/79, 12/20/70,
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l 5/05/80, 7/24/80, and 10/31/80:
in all cases, the item remained l
ancorrected. Procedure QAAS-QAP-3.1,- Quality Audit Program, Revision 5'
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dated 8/20/80, required (6.7.3) that if 3 Category B finding is not i
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closed within nine (9) months.of the date the audit report is issued, l
it shall be escalated to a Category A finding (which requires a response and followup).
This failure to follow procedure QAAS-QAP-3.1 is a
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vioTation (327/80-46-04).
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Failure to Take Appropriate Followup Action en Audit Findings The accepted QA Program (17.2.18) requires that audits identify program weaknesses and _ nonconformances.
It further requires that findings shall be documented in the audit report and that corrective action shall be documented.
Table 17.2-5 states that, with certain excep-tions, TVA will comply with the requirements of ANSI N45.2.12, Draft 3, Revision 4.
Paragraph 4.5.1 of the Standard, to which TVA did not
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receive an exception, requires that tha audited organization shall review and investigate any adverse findings and shall respond to the report within 30 days after receipt, giving the results of the review
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and investigation.
The inspector determined that the controlling procedure (QAAS-QAP-3.1, Revision 5) did not correctly translate this requirement in that it allowed for designation of certain violations of established requirements which did not immediately impair the effect-iveness of the program to be classified as " Category B" items. These items were not listed as open items,. and did not require a written response from tne audited crganization. As a result, the requirements of the accepted QA Program were not met for the following items:
CH-7900-01-801 & B02; CH-7900-06-801; CH-80SP-02-B01, 804, 805, 807, 808, 809 and Bil; CH-8000-02-801; JA-8000-01-801; JA-8000-04-801 & B02; JA-8000-05-B02: MS-80TS-01-B01 & B02; SQ-8000-01-801, 802 & B03; SQ-8000-02-801; SQ-8000-03-B01; and SQ-8000-05-5Gl.
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This failure to take required followup action and the failure to have
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an adequate procedure are combined to constitute a violation (327/80 -
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46-05)
f.
Possible Inaccurate Readings on Multi-Scale Instruments
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When multi-scale instruments are calibrated by the Central Labora-tories, linearity (a check of multiple points within the range of the scale for accuracy) is only checked routinely on the lowest scale.
Since, for most common instruments, the shape of the curve produced by these points remains the same on subsequent scales, it is possible for upper range scales to have certain readings out of specified accuracy
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when the endpoints (the only points checked on the upper range scales)
are within specified aEc'urscy limits but above the accuracy value -
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obtained on the lowest scale.
The Supervisor of the Electrical Laboratory acknowledged the possibility that this condition could exist, and would exist under the circumstances postulated above; however, he stated that the Central Laboratories only certified tha calibration of the instrument as stated on the calibration record: no other points are certified. When the inspector discussed this matter
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with Sequoyah QA and instrumentation spe.cialists, he determined that i
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site personnel assume and use instruments certified by the Central Laboratories as if they were accurate on all ranges and all points on j
the range scale.
Since the inspector found no instruments that were out of calibration, but also found that no controls exist to prevent inaccurate (out of tolerance) readings on upper scales of multi-range instruments, no violation is issued. A citation is not considered appropriate at this time based on the lack of specific examples and the commitment by the Supervisor of the Electrical Laboratories to evaluate this area and
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make whatever changes are considered necessary within six months. This l
item (327/80-46-13) is open with a target date for the completion of the evaluation and institution of appropriate corrective action by June 16, 1981. If specific examples are found before this date, this item may be escalated to a viciation.
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g.
Possible Record Retention inadequacies
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When a piece of MTE is used at Sequoyah, the instrument number is recorded and the procedure, instruction, or surveillance conducted is
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logged.
If that instrument is subsequently found to be out-of-tolerance by the Central Laboratory, the plant is notified, and an evaluation of all uses of the instrument is conducted. Where neces-sary, the tests are rerun with a correctly calibrated instrument.
However, the documentation of usage for a particular piece of MTE is retained, according to current practices, only until the instrument is calibrated by the Central Lab. At Sequoyah, though not required by procedures, the "old" data sheet is retained for one additional cali-bration period.
The Central Laboratory calibrates Sequoyah MTE with their " working -
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standards"; these working standards are in turn calibrated with primary standards. If a working standard is found out-of-tolerance, a computer list of the Sequoyah (and other plants) MTE, calibrated with this standard,- is generated.
The instruments from Sequoyah are then recalled and' recalibrated if necessary. Since the current procedures only require. retention of the MTE usage record until the MTE is i
returned frgm the Central Labs, the above recall would not be effective in identification of plant equipment which had been calibrated with MTE that is later determined to have been designated as "in tolerance" that was in fact "out-of-tolerance".
The inadequacy backs up one
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additional step when primary sources are found out-of-tolerance. As an example, the Keithley 602' instruments (317136 and 435066) mentioned in -
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paragraph 16.a above were reviewed to determine their usage; since the instruments had b.een recalibrated, respectively, in December 1980 and October 1980, their respective usage cards were blank.
Even the additional usage card that is retained (though not required by current t
procedures) was blank since the instruments had been previously recal-ibrated in June 1980. These data agree with the data Theets found i
(because the Senior Technician remembered. the Instrument Maintenance i
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I Instructions that used the instruments) where tne last recorded usage l
was 5/80.
The specific case reviewed by the inspector involved a fairly unique l
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(limited application) instrument, so the lack of a usage record did not l
hinder reconstruction of the instruments' uses.
However, since the potential problem exists, and is not covered by current procedures, future problems could occur. Because past experience has shown that Central Laboratory working standards are rarely found out-of-tolerance (one case so far in 1980 for over 300 items), and because primary l
standards are even more reliable, immediate corrective action to preclude a possible problem is not considered necessary. Therefore, the inspector acknowledgeo the licensee's target date of July 31, 1981, for completion of a joint (Division of Nuclear Power and Central Laboratory) study to evaluate and determine the maxin.um time interval j
for record retention which would assure that a hypothetical out-of-
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tolerance primary standard could be traced to plant usage. Until the area has been evaluated and appropriate procedures have been revised and implemented, this item (327/80-46-14) is open.
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Conflicting Recalibration Due Dates Both the Central Laboratories and the Sequoyah Instrument Shop have a calibration schedule for instruments used on site, but the frequency of
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l calibration on these lists are different.
In general, the dates for recalibration used by the Central Laboratories are more frequeht than the dates used by the site. Since the site I&C Technicians are trained not to use an instrument with a past due calibration date, the date supplied by the Central Laboratories is usually controlling (and was in all cases reviewed by the inspector).
Since all cases reviewed were
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calibrated conservatively, no citation is considered appropriate at
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this time.
However, since a conflict exists and future non-conser-vative cases are possible, this area will be reinspected during a subsequent inspection.
For record and tracking purposes, this is designated inspector followup item 327/80-46-18.
1.
Failure to Parform Audits During dischssions with Chattanooga QA representatives, it was deter-mined that all audits required by Technical Specification 6.5.2.8 were not being performed. Technical Specification 6.5.2.8 requires audits
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to be performed on the res'ults of actions taken to correct deficiencies
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occurring in unit equipse'nt, structures, systems or methods of opera --
tion that affect nuclear safety at least once per 6 months. Audits are not performed on methods of operation that affect nuclear safety such as reviews of LER's, potential reportable occurences, results of surveys of operation and Office of Power Audits that deal with opera-tions. This failure to perform all audits as required by Technical Specification 6.5.2.8 is a violation (327/80-46-10).
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17. -Index of Findings of Inspection Report 50-327/80-45 Item Numbers Item Description Report
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327/80-46 Location VIOLATIONS
Failure to Accomplish Calibration 16.a of Nuclear Instrumentation Under
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Suitable Environmental Conditions l
Failure to Follow Training Procedures 16.b at Central Labs
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Failure to Establish Program to 16.c
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Failure to Obtain Required Corrective
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Action
,[ Failure to Take Appropriate Follow-up 16.e Action on Audit Findings
Failure to Mair.tain Ratraining of Staff 14.a
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Failure to' Perform Comprehensive 14.c
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Audit of Training Areas
Failure to Maintain Weathertight 12.b Storage
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Failure to Protect Weld End 12.a
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Failure to Perform Audits 16.1
Failure to Maintain Training Records 14.b
Failure to have Cleanliness or 13.a l
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OPEN ITEMS
Inaccurate Readings on Multi-Range 16.f Instruments
Record Keeping Inadequacies 16.g
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Updating of QA Manuals
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Incorporate AI-11 Requirements for 12.c
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Modification Outage Warehouse
Reevaluation of Storage Criteria 12.d for Equipment Requiring Rotation
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or Meggering
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.,i-INSPECTOR FOLLOWUP ITEMS
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ConflictiEg Recalibration Due Dates 16.h
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Inconsistency Between N-0QAM and AI-19
20 Plant Tour Observations 13.b l
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Temporary Storage Time for Records
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Implementation of Training Program
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