IR 05000327/1982016
| ML20027C305 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/18/1982 |
| From: | Belisle G, Fredrickson P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20027C284 | List: |
| References | |
| 50-327-82-16, 50-328-82-16, NUDOCS 8210150256 | |
| Download: ML20027C305 (12) | |
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- -.s pn Aeg UNITED S1ATES
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- o NUCLEAR REGULATORY COMMISSION l
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101 MAFdETTA ST. N.W, SUITE 3100 I
ATLANTA. GEORGIA 30303
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Report Nos. 50-327/82-16 and 50-328/82-16 Licensee: Tennessee Valley Authority 500A Chestnut Street Tower II Chattanooga, TN 37401 Facility Name: Sequoyah I and 2 Docket Nos. 50-327 and 50-328 License Nos. DPR-77 and DPR-79 Inspection at Sequoyah site near Chattanooga, Tennessee and at TVA offices in Chattanooga, Tennessee
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j [8 d' Z-Inspectors:
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Bdlijle//
fteS'igned
.L T2&L, P.~ E. Fredrickson
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'Dati Signed Approved by:_ NM/
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C. M. Upright,/Kctio hief'
DgteS'igned Engineering 16fpect Branch Division of Engineer ng and Technical Programs SUMMARY Inspection on July 12-16, 1982 Areas Inspected This routine, unannounced inspection involved 70 inspector-hours on site and at TVA headquarters in the areas of licensee action on previous enforcement matters, QA program review, audits, organization and administration, onsite review com-mittee, design changes, calibration, surveillance, maintenance, and licensee action on previously identified inspection findings.
Results Of the ten areas inspected, no violations or deviations were identified in eight areas; two violations were found in two areas (Failure to establish measures to assure conditions adverse to quality are promptly corrected, paragraph 6.a; and Failure to establish measures to assure that Operations Quality Assurance Manual procedures are implemented, paragraph 3.f).
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REPORT DETAILS 1.
Persons Contacted Licensee Employees-
- A. Carver, Nuclear Power Compliance
- A. Crevasse, QA Manager
- R. Hamilton, Nuclear Power Quality Assurance
- M. Harding, Nuclear Power Compliance Supervisor
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R. Large, Supervisor, QA/QC Training Unit
- J. Law, Nuclear Power Quality Assurance
- R. Moore, Operations QA 5;pervisor
- W. Poling, Assistant QA Monager
- D. Romine, Nuclear Power Compliance L. Swain, Supervisor, Engineering Training Section Other licensee.;ployees contacted office personnel.
included technicians, mechanics, and NRC Resident Inspector
- E. Ford '
- Attended exit interview July 13, 1982 at TVA headquaters
- Attended exit interview July 16,.1982 on site.
2.
Exit Interview The inspection scope and findings were summarized on July 13 and 1982, with those persons indicated in paragraph 1 above.
informed of the inspection findings listed below.
The licensee was, the inspection findings.
The licensee' acknowledged Violation 327,328/82-16-01,
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conditions adverse to quality are promptly corrected, paragra
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Violation 327,328/82-16-02,
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that Operations Quality Assurance Manual procedures are im paragraph 3.f.
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Licensee Action on Previous Enforcement Matters a.
(Closed) Violation (327/80-46-05): Failure To Take Appropriate I
Followup Action On Audit Findings.
TVA's response dated March 16, 1981, is considered acceptable by Region II.
The inspector held discussions with Mr. R. Moore, Operations QA Supervisor the corrective actions stated in the response.
, and examined The inspector reviewed LL
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OP-QAP-18.1, Audits, Revision 3, and verified the reclassification of audit findings to either Category A or concerns. QAAS-QAP-3.1, Quality Audit Program also reflects these classifications. A review of audits, as discussed in paragraph 6, verified implementation of these proce-
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dural requirements. The. inspector concludeci that TVA had determined
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the full extent -of the violation, performed the necessary survey and followup actions to correct the present conditions, 'and developed the necessary' corrective-actions to preclude recurrence of similar viola-tions. Corrective actions stated in the response have been imple--
mented.
b.
(Closed) Violation (327/80-46-10):
Failure To Perform Audits. TVA's response dated March 16, 1981, is considered acceptable by Region II.
The inspector held discussions with Mr. R. Moore, Operations QA Supervisor, and examined the corrective actions stated in the response.
The inspector reviewed audits OPQAA-SQ-TS-05 and OPQAA-SQ-8100-TS and verified that audits were performed on the results of actions taken to correct deficiencies at least once per six months.
The inspector reviewed proposed audit schedules and verified future audits are planned in this area at required frequencies. The inspector concluded that TVA had determined the full extent of the violation, performed the necessary survey and followup actions to correct the present con-ditions, and developed the necessary corrective actions to preclude recurrence of similar violations. Corrective actions stated in the response have been implemented.
c.
(Closed) Violation (327/80-46-11):
Failure To Maintain-Records Of Training And Qualifications. TVA's responses dated March 16, April 16, and June 30, 1981, are considered acceptable by Region II.
The inspector held discussions with Mr. J. Walker, Shift Engineer Training and Mr. L. Smith, Training Supervisor and examined the corrective actions stated in the responses.
The inspector reviewed the maintenance of both licensed operate r training records and general employee training records.
Training records of Sequoyah licensed operators who are permanently assigned to other sites are maintained in a separate section of the licensed operator training file. A system has been developed to insure that general employees temporarily assigned to Sequoyah from other sites have a training folder, maintained by the training officer, which
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contains records of what general training each employee has received.
The inspector concluded that TVA had determined the full extent of the violation, performed the necessary survey and followup actions to -
correct the present conditions, and developed the necessary corrective actions to preclude recurrence of similar violations.
Corrective actions stated in the responses have been implemented, d.
(Closed) Unresolved Item (327/81-06-02): Annual Supplier Evaluation.
Tne inspector reviewed a draft of QAAS-QAP-3.5, External Quality Audit Program. This procedure delineates administrative controls to be used a
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in the performance of annual supplier evaluations.
The inspector reviewed.results of previously performed supplier evaluations ' and verified that evaluations are being perfnrmed on vendors. supplying safety related items for plant use.
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. (Closed) Unresolved Item (327/81-06-03):
Level II Items Appro ed v
Vendors.
The inspector reviewed a draft of QAAS-QAP-3.5, External Quality Audit Program.
This procedure delineates. the administrative-controls to be used for assuring Level I and Level II purchased items are purchased from qualified vendors.
It also delineates 10 CFR 21 requirements to be followed in purchasing these items. The inspector reviewed Level I and Level II. purchased material and verified -they were bought from qualified vendors and 10 CFR 21 requirements were' adhered-to, f.
(Closed) Unresolved Item (328/81-07-01): Review Of Procedure Format.
The inspector reviewed selected plant instructions to verify that compliance with the N-00AM, Part II Section 1.1, Revised 11/80 had been
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attained by March 1, 1982, as required by the N-0QAM. 'The review determined that normal and fuel-handling instructions had been revised to the required format but the abnormal-operating instructions (A01s)
were in a format similar to the emergency operating instructions (E0Is).
The A0Is had not been revised to the new format.
The inspector observed, however, that the general. purpose of the A01s -
closely resembles that of the E01s and thus the existing format for A01s may not be inappropriate. The procedure formats identified in the N-0QAM are derived from those detailed in ANSI N18.7-1976, which is endorsed by the licensee's accepted QA Program. 'The inspector reviewed the site's method for. either implementing N-00AM requirements or requesting an. exception from these requirements.
This review determined that an organized system has not been established to assure that N-00AM requirements are implemented in required timeframes or, if requirements are objected to by the site, an appropriate exception request is submitted. The absence of such a system-appears to have caused the failure of the A01s to be changed or the N-00AM to be revised.
Maasures have not been established to assure that N-00AM procedures
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are used and integrated into all appropriate plant activities and l
carried out throughout plant life as reouired by 10 CFR 50 Criterion II
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and VI and the accepted QA Program, Sections 17.2.2 and 17.2.6.
Fail-u.*e to establish such measures is a violation-(327,328/82-16 02) which closes this unresolved item for record purposes, g.
(Closed) Unresolved Item (327/81-35-01, 328/81-44-01): Clarification Of Calibration Requirements. The inspector reviewed the listing of measuring and test equipment and conducted interviews with plant personnel concerning the basis for the - two levels of. calibration tolerance.
Selected examples of test equipment met minimum tolerance differentials between installed instruments and first-line calibration standards.
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(Closed) Unresolved I' tem (327/81-37-01, 328/81-46-01):
Fire Rating
- Of Temporary Record Storage Cabinets. The licensee has revised the accepted' QA-Program to require that quality records are stored -in devices which have fire ratings based on the fire load of the storage-area.
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. Unresolved Items Unresolved items were not identified during this inspection.
5.
QA Program Review (35701)
References:
-(a) SG-00AM, Part I Section 6.2, Plant Operations Review Committee Charter, revised 3/80 I
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(b) N-00AM, Part'III Section 1.1 Document Control, revised l
2/82 V
(c) N-00AM, Part III Section 3.1, Control of Measuring and
Test Equipment, revised 7/81
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(d) N-00AM, Part III Section 3.2, Control of Installed i
Technical Specification Compliance Instrumentation, revised 11/80
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l (e) N-00AM, Part III Section 4.1, Quality Assurance Records, I
revised 10/81 (f) N-00AM, Part III Section 4.2., Transfer of QA Records from OEDC, revised 10/80 l
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(g) N-00AM, Part III Section 5.1, Auditing of the Opera-tional Quality Assurance Program for TVA Nuclear Plants,
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(h) N-00AM, Part III Section 5.2, Qualification and Certi-
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l fication of Quality Assurance Program Audit Personnel,
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revised 11/81
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(i) N-00AM, Part III Section 7.1, Nonconforming Materials, Parts, or Components, revised 2/82 (j) N-00AM, Part III Section 7.2, Corrective Action, revised j
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The inspector reviewed references (a)-(j) and verified that they met requirements of the accepted QA Program, NRC Regulatory ' Guides, and ANSI Standards endorsed by that program.
No changes have been made to the accepted QA Program since the last inspection in this area in December 1980.
.The. inspector verified that licensee personnel are aware of regulatory
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commitments.
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Within this area, no violations or deviations were observed.
6.
Audits and Audit Implementation (40702, 40704)
References:
(a) N-00AM, Part III Section 5.1, Auditing of the Opera-tional Quality Assurance Program for TVA Nuclear Plants, revised 4/82 (b) N-00AM, Part III Section 5.2, Qualification and Certific: tion of Quality Assurance Program Audit Personnel, revised 11/81 (c) N-QAM, Part III Section 7.2, Corrective Action, revised 6/81 (d) OP-QAP-18.1, Audi ts, Revi sion 3 (e) OP-QAP-16.1, Corrective Action, Revision 0 (f) OP-QAP-17.1, Quality Assurance Records, Revision 0 (g) QAAS-QAP-31, Quality Audit Program, Revision 8 The inspector reviewed references (a)-(g) and verified that they met requirements of the accepted QA Program, NRC Regulatory Guides, and ANSI Standards encorsed by that program. The inspector verified the following aspects of auditing activities:
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Methods have been defined for taking corrective action when defi-ciencies are identified during audits.
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The audited organization is required to respond in writing to audit findings.
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Distribution requirements for audit reports and corrective action responses have been defined.
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Checklists are required to be used in the performance of audits.
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Audits are conducted by trained personnel not having direct responsi-bility in the area being audited.
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The frequency of audits is in conformance w1;5 technical specification requirements.
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The scope of the audit program has been defined and is consistent with technical specification requirements.
Responsibilities have been assigned in writing for the overall manage-
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To verify implementation of these aspects, tne inspector reviewed results of 11 audits conducted during 1981. The inspector verified qualifications of eight lead auditors.
Within this area, one violation was identified.
Audit OPQAA-SQ-81-1 conducted January 7-16, 1981, and issued February 13, 1981, identified as a finding (A1) that all maintenance requests (MRs) are not being reviewed by the plant QA staff prior to issuance as required by N-0QAM, Part II, Section 5.3.
The status of this item on August 11, 1981, was that the N-00AM had been revised but the timeframe for review of MRs was unacceptable.
The status on November 11, 1981, was that the N-00AM had been revised again; however, prcblems are still occurring.
During an IE Inspection conducted November 16-20, 1931, and documented in IE Inspection Reports 50-327/81-37 and 50-328/81-46, the inspector reviewed maintenance activities.
The inspector identified that QA was not reviewing MRs as required. A violation was not issued since this was identified by the licensee during audit OPQAA-SQ-81-1.
The inspector identified this problem as an inspector followup item (327/81-37-03, 328/81-46-03) to verify the licensee's corrective action during a future inspection.
The status on February 25, 1982, indicated that the item had been reviewed by sampling a number of MRs and problems were still occurring.
The item could not be closed.
The corrective action date for completion of this item was given as June 1, 1981, in a response dated March 13, 1981.
Audit OPQAA-SQ-81TS-04 conducted April 13-23, 1981, and issued May 26, 1981, identified as a finding (A05) that Radiological Emergency Plan (REP) reviews are inadequate. This finding contained three details and the status on August 8, 1981, identified that detail 2 had been corrected but no progress had been made on details 1 and 3.
The status on November 24, 1981, identi-fied that considerable errors still existed and the item remained open. The status on February 19, 1982, identified that details 1 and 2 had been corrected but detail 3 remained open.
As of July 12, 1982, the item remained open.
The corrective action date for th's item was given as November 16, 1981, in correspondence dated November 11, 1981.
Failure to correct audit findings in these two audits is indicative of inadequacies in the licensee's measures to assure prompt corrective action.
Management controls have not been established to address specific actions to be taken if the audited organization's response is late or inadequate or if the audited organization does not complete the corrective action stated in
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their response. Existing procedures do not address how many extension dates can be given to the audited organization if they cannot correct identified problems. Current measures do not require the involvement of higher levels I
of management to as:ure the adequacy and timeliness of corrective actions.
These two examples are representative of the problem and not intended to be all inclusive.
Failure to correct audit findings in a timely manaer and inadequacies in the licensee's management controls indicate that measures have not been estab-lished to assure that conditions aoverse to quality are promptly corrected
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as required by 10 CFR 50 Criterion XVI and the accepted QA program.. Failure
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to establish such measures constitutes a violation (327, 328/82-16-01).
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7.
Organization and Administration (36700)
References:
-(a) N-0QAM, Part III Section 6.1, Selection and Training of Personnel for Nuclear Power Plants,~ revised 1/81 (b) AI-14, Plant Training Program, Revision 14 The inspector reviewed references (a) and (b) and verified that they met technical specification requirements.
The inspector. reviewed qualifica-tions of 32 plant personnel in various supervisory and non-supevisory positions and verified their qualifications were in accordance with technical specification requirements.
Tne inspector verified that licensee's changes to their organization have been reported to the NRC.
Within this area,.no violations or deviations were observed.
8.
Onsite Review Committee (40700)
References:
(a) Accepted QA Program Section 17.2.1.1.9 (b) SQ-00AM, Part I, Section 6.2, Plant Operations Review Committee Charter, Revised 3/80 (c) SQA 21, Plant Operations Review Committee (PORC),
Revision 4 The inspector reviewed references (a)-(c) and verified that they met tech-nical specification requirements. The inspector reviewed the minutes of 26-Plant Operating Review Committee (PORC) meetings conducted from December 1981 thru June 1982 and verified that membership, quorum requirements, and -
qualifications of personnel are in accordance with technical specification requirements.
Within this area, no violations or deviations were observed.
9.
Design Changes and Modifications (37700, 37702)
References:
(a) N-00AM, Part II Section 3.2, Plant Modifications: After Licensing, revised 7/80 (b) N-00AM, Part II Section 3.2A, Core Component Design Change After Licensing, revised 10/80 (c) AI-19 (Part III), Plant Modifications: Af ter Licensing,.
Revision 6 (d) AI-25, Drawing Control After Unit Licensing, Revision 4
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~(e) SQM 1, Sequoyah Nuclear Plant Maintenance Program, revised 12/80 (f) M&AI-3, Revision of As-Constructed Drawings,' Revision.3
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(g) AI-9, Control of Temporary Alterations and Use of the Temporary Alteration Order, Revision 12 The inspector reviewed references (a)-(g) and verified that they. met requirements of the accepted QA Program NRC Regulatory Guides, and ANSI-Standards as endorsed by that program. The inspector reviewed the following aspects of design changes:
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Procedures have been established for control of design and modification -
change requests.
Procedures and responsibilities for design control have-been estab-
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Administrative controls for design document control have been estab-
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lished.
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Administrative controls assure that design changes are incorporated into plant procedures, operator training, and the updating of drawings.
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Controls. have been developed that define channels of communication between design and responsible organizations.
Administrative controls require design documentation and records be
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collected and stored.
Controls require implementation of approved design changes be in
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accordance with approved procedures.
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Controls require post-modification testing be performed per approved test procedures and the results evaluated.
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Responsibility has been assigned for identifying post-modification
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testing requirements.
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Responsibility and method for reporting design changes to the NRC in accordance with 10 CFR 50.59 has been identified.
Similar methods and controls were also verified for use of temporary modi-fications'(jumpers and disconnected leads).
To verify implementation of these aspects, the inspector reviewed six design changes (ECN L5033, L5114, L5268, L5285, L5298, and L5314).
Within this area, no violations or deviations were observed.
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10. - Calibration (56700)
References:
- (a)'N-00AM, Part III, Section 3.2, Control 'of -Installed-
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Technical Specification' Compliance Instrumentation,.
revised 11/80
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l (b) N-00AM, Part III, Section 3.'1, Control of Measuring ~and Test Equipment, revised 7/81
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TI-2, Calorimetric Calculation', Revision 5 (d) TI-10 (Part I), Calibration Program for Measuring and Test Equipment, Revision 20 (e) TI-54, Compliance Instruments, Unit 0, 1, Revision 5
'(f) TI-54.2, Compliance Instruments, Unit 2, Revision 1
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This functional area was reviewed by the NRC resident inspectors during
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routine monitoring of selected activities involving technical specification calibration.
The inspector reviewed the calibration of safety related components used to perform techncial specification surveill nces (compliance instruments) but not specified in technical specification requirements as L
requiring calibration. Specifically, the inspector looked into the utiliza-l tion of the control room process computer as it is being ' used to verify -
l technical specification surveillances and also the use of other computer oriented surveillance techniques.
The inspector also selected several pieces of mechanical and instrument test equipment to verify that the test I
equipment program is being implemented satisfactorily.
Within this area, no violation or deviations were observed.
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Surveillance (61700)
References:
(a) N-0QAM, Part II, Section 5.1, Inservice Inspection, revised 2/81 o
j (b) N-00AM, Part II, Section 4.5, Plant Surveillance Test j
Program, revised 8/81 l-(c) SQA-41, Sequoyah Nuclear Plant - Surveillance Test Program, revised 12/81 h
(d)- TI-59, Listing of Technical Specification Instruments, j
Revision 1 (e)
SI-1, Surveillan a Program, Revision 7 l
(f) SI-166, Summary of Valve Tests for ASME Section XI, l
Revision 4
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~This functional area was reviewed by the NRC resident inspector during-routine monitoring of selected surveillance ' activities.
The inspector reviewed the references with respect to the technical specification surveillance program and the interface with the calibration of compliance instruments as discussed in paragraph 10.
Within this area, no violations or deviations were observed.
12. Maintenance (62700)
References:
(a) N-00AM, Part II, Section 2.1, Plant Maintenance, revised 8/81 (b) SQM-1, Sequoyah Nuclear Plant Maintenance Program, revised 12/80 (c) SQM-2, Maintenance-Report Handling and History System, revised 6/82 (d) SQM-46, Housekeeping Program for Safety Related System Maintenance, revised 2/80 (e) SQM-57, Preventive Maintenance Program, revised 3/82 (f) SQM-58, Maintenance History Records, revised 7/82 The corrective maintenance portion of this functional area was reviewed by-the NRC resident inspectors during routine monitoring of selected mainte-nance activities. The inspector reviewed the preventive maintenance program and selected several maintenance activities to verify the implementation of the program.
Within this area, no violations or deviations were observed.
13.
Licensee Actions on Previously Identified Inspection Findings (92701)
(Closed) Inspector Followup Item (327/80-46-22): Qualification Of QC a.
Inspectors. The inspector reviewed the QC inspector training program and training and certification records of selected Sequoyah inspectors.
These reviews were conducted at the TVA training center. Interviews were conducted with members of the training staff to identify the extent of the program and the goals and objectives to be obtained.
b.
(Closed) Open Item (327/81-06-05): Conflict Between Office of Power QA l
Procedures. The inspector reviewed OP-QAP-18.1 Audits, Revision 3, and identified that the conflict in the' procedure in question had been clarified.
c.
(Closed) Open Item (327/81-06-06): Distribution Of QA Procedures. The inspector reviewed the distribution list of the N-00AM copies main-tained in master files and verified by a telephone call with the the m._
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TVA headquarters ? document control center that the same controlled copies are maintained at the site, d.
.(Closed) Open Item (327/81-06-07):
Storage of Records.
The site is now is compliance with the N-00AM for-records storage regarding satellite records storage.
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(Closed) Inspector Followup Item (327/81-37-03, 328/81-46-03): _ QA Review Of Maintenance Requests (MRs).
The inspector reviewed audit OPQAA-SQ-81-1.
Finding 5 of.this audit identified that there were considerable delays in reviewing MRs by QA. ~This finding has not been-closed. ' This item is addressed as 'part of a violation discussed in paragraph 6.a of xSis report.
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(Closed) Inspector Fi.'lowup Item (327/81-37-02, 328/81-46-02): Records Receipt System. - A written transmittal log is being maintained for maintenance requests received by document control from quality assur-ance.
The inspector was informed that a program change to enable document control to computer log maintenance request receipts is planned for the near future.
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(Closed) Inspector Followup Item (327/81-37-04, 328/81-46-04): Master Files Record Storage. The inspector reviewed master files to determine that quality records were being properly stored. Also, several docu-ment control and other plant staff personnel were interviewed to verify knowledge of the proper storage and handling of quality records.
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