IR 05000327/1989026
| ML19332C759 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 11/09/1989 |
| From: | Daniels T, Raynard Wharton Office of Nuclear Reactor Regulation |
| To: | |
| Shared Package | |
| ML19332C755 | List: |
| References | |
| 50-327-89-26, 50-328-89-26, NUDOCS 8911280516 | |
| Download: ML19332C759 (6) | |
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UNITE 38TATES
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NUCLEAR REGULATORY COMMIS$lON s
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TVA PROJECTS DIVISION
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Report Nos.:
50-327/89-26 and 50-328/89-26 i
i Licensee:
Tennessee Valley Authority i
6N 38A Lookout Place 1101 Market Street Chattanooga, Tennessee 37402-2801 Docket Nos.:
50-327 and 50-328 i
License Nos.:
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Facility Name: Sequoyah Units 1 and 2
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Inspection Conducted: October 23 1589 throug,h October 27, 1989 Inspector:
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Rdf Whatte, Quality Operations Engineer Date
Approved by:
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Tom Daniels, Allegittion Coordinator Date Associate Director for Special Projects Office of Nuclear Reactor Regulation SUWARY Scope:;
This special announced inspection was conducted in the area of allegation followu to establish validity and to verify corrective actions that have
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been i lesented for those determined to be valid.
The basis for this inspection was various allegations received by the NRC.
Results:
No violations or deviations were identified as a result of~this inspection.
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One open item was identified and one previously reported unresolved item was noted in the report,
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Several allegation evaluations were completed as discussed in the report.
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REPORT DETAILS
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1.
Persons ContactedW
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Licensee Employees
- J. LaPoint, Site Director
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P. Wallace Site Programs and Support
M. Bruzynolis, Licensing J. Proffitt, Licensing
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T. F11ppo, Quality Assurance
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T. Pitts, NLRA/Chatt i
- J. Holland, Site Programs
- J. Boyles, ECP/SNP J. Pleva ECP/Chatt
- S. Crowe, NQA
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- T. Galbreth, ECP i
- M. Cooper, Licensing
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and othcr personnel of the plant staff.
NRC Employees
D.' Loveless, Resident Inspector i
- R. Wharton, Allegations Coordinator i
2.
Allegations-
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a.
OSP 88-A-0007
(1) An allegation was received by the NRC staff which stated:
i TVA does not reviet; contractor personnel certifications and qualifications until after the work has been perfomed.
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(2) This allegation was substantiated. The licensee had conducted an
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audit of onsite contractor' performance, No. 52A88809, and issued
CAQR SQA880262809 as a result. The audit specified numerous instances where contractors had provided services but objective evidence or records of certification, qualification and/or training l
could not be provided. The CAQR identified a failure to implement quality assurance requirements for the control of site service contractors. The NRC inspector reviewed the CAQR and determined that the corrective action and recurrence control were adequate
and appropriately addressed the concerns of the allegation. This allegation is considered resolved.
b.
OSP 89-A-0009
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(1) An allegation was received by the NRC staff which staced:
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Safe rigginfi practices are not being followed and chain ri being used ' n lieu of the wire rope types (come-a-longs)..gging isMultiple
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foremen are causing industrial safety problems. The General Foreman i
interrupts lifting operations and takes control as the signal man j
for the crane operator.
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(2) This allegation was not substantiated. The concern with industrial l
rigging practices is an Occupational and Health and Safety (OSHA)
i issue and does not fall within the scope of nuclear safety t
requirements. However, the NRC inspector's review of this issue noted an approved procedure that addresses rig Standard Practice SQM 31 Inspection, Testing,ginti practices, Ma' ntenance, and Operation of Nuclear Plant Cranes and Hoisting and Rigging Equipment, Revision 7 dated April 7, 1989. Additionally, all certified crane
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operators were required to satisfactorily complete the rigging l
course, MTS 037.002, by May 26, 1989. The course reinforced the practices and requirements established in the revised procedure.
This allegation is considered resolved.
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c.
OSP 89-A-0020
(1) An allegation was received by the NRC staff which stated:
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i-CAQR SQP-88-06-12 was not properly (timely) resolved with respect to the operability determination. Additionally FSAR Section 7.7.1.3.3isnotconsistentwithtechnicalspecIficationsor operations procedure, 501-55-1M4-XA-55-48, for boron addition.
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i (2) This allegation was substantiated. During the inspection, the subject CAQR was reviewed for appropriate corrective action, root cause analysis, recurrence control, and timeliness. The root cause of the i
adverse condition was that the licensee had failed to establish a program for FSAR updates initiated by procedure revisions until
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1987. As a result, previous procedure revisions were not always
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L reflected in FSAR updates. The corrective action was to submit a i
change request for the FSAR, CRFSAR No. SOEP-EEB-89-0 4 dated March 6, 1989.
Recurrence control had been addressed by the
issuance of Standard Practice SQA 180, " Amending the Sequoyah l
Updated Final Safety Analysis Report (FSAR)" on September 1,1987.
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The current revision to SQA 180 is Revision 2, dated August 12, 1988.
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The CAQR was not initially responded to in a timely manner as evidenced by RIMS No. 513881219809 which escalated the CAQR 880612
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for management attention. However, due to the generic implications
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of the adverse condition, the CAQR had to be evaluated for other TVA facilities. The tieneric evaluation process did lengthen the resolution
period. The NRC 'nspector determined that the CAQR was adequately,
resolved. This allegation is considered resolved.
d.
OSP 89-A-0021 (1) An allegation was received by the NRC staff which stated:
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The contractors that are writing / revising procedures are not fulfilling administrative requirements regarding long-tenn L
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cosmitments. The TVA personnel responsible for reviewing the
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procedures are not allowed to make changes or corrections.
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(2) This allegation was substantiated. During the review of this issue the NRC inspector conducted interviews with the alleger, Site.
j ram manager and staff, and licensing personnel. As Procedures Progornation obtained from the interviews, the ins sector
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a result of in l
reviewed procedures and documentation which indicated the pro)1em l
- with long-term commitments has not been completely addressed.
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Additionally, the inspector noted procedure reviewer coments s
that did not get incorporated into revised (enhanced) procedures.
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Administrative Instruction AI-4, " Preparation, Review, Approval
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and Use of Site Procedures / Instructions," establishes administrative
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requirements for identifying, referencinglresents in AI-4 regarding and susmarizing long-term commitments in site procedures. The regu long-tern commitments are in partial response to reportable occurrence i
SQRO-50-327/87013 Revision 1 dated July 15, 1987.
The licensee initially identified the issue, not referencing long-I term connitments, as an audit deviation and subsequent CAQR, SQA-860001D01.
In response to the CAQR, which was closed in June
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1988 a program was developed and verified as functional for
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identifying and incorporating long-term commitments in site
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procedures.
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A recent audit deviation, CAQR SQA890384913, closed September 18, 1989, described the same adverse condition; however, it was interpreted
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as an inadequately implemented program. The licensee has determined that both CAQRs identified isolated cases and therefore, a generic applicability review was not required. The corrective action
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addressed only the deficient procedures denoted in audit sample.
The licensee explained that a procedure enhancement effort is ongoing and has yet to utilize the matrix which has been developed
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for cross-referencing individual plant procedures to-various source documents (commitments). The inspector's review of the subject CAQRs,
other deficient procedures, and proposed-licensee improvement has determined that the procedures enhancement program has not been adequately implemented. The licensee had previously identified problems with appropriate commitments being incorporated into site
l procedures and has a proposed improvement plan. A more structured
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i-plan to utilize the matrix needs to be developed and complete
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L implementation of the procedure enhancement program needs to be L
verified. This issue will be considered an open item (50-327/89-26-1).
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The allegation is considered resolved.
e.
OSP 89-A-0046
i; (1) An allegation was received by the NRC staff which stated:
i Materials Receipt managers had instructed power stores personnel I
to violate procedures for transferring material and receipt inspectiontoexpediteuseofthatmaterial(drivebelts).
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(2) The allegation was substantiated. During the NRC inspector's review
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of this issue interviews were conducted with Materials and Procurement
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J Services (Power Stores) personnel, Quality Assurance Management, and
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p the CAQR and ECP report associated with the issue. CAQR SQP89327,
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seterial from Bellefonte Nuclear Plant (BLFN) and then issue it
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contrary to established procedures. The material, V. belts, were
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procured (transferred) without the appropriate documentation or l
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approvals. Additionally, four of the V-belts were issued for use
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in a corrective maintenance activity without receipt inspection.
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The corrective actions for this issue were (1) document the procurement material and (3) quest, (2) verify the application of the installed on a purchase re perform receipt inspection on the remaining 8
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V-belts. The recurrence control was a memorandum from the Materials
and Procurerent Manager to his staff re-emphasizing the importance
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of procedural adherence. Based on information reviewed in the CAQR,
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l it appeared to_the inspector that the corrective action and recurrence control were. inappropriate. The inspector held discussions with QA i
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management with regard to a CAQR process that allows a manager to direct the violation of procedures, and then initiate, evaluate, and approve the corrective action to resolve the issue. The inspector also discussed the appropriateness of the corrective action with the i
Site Programs and Support Manager.
It was determined that the CAQR l
did not reflect any plant management decisions or provisions for bypassing procedural requirements. The inspector recommended that l
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some additional recurrence control would be appropriate to adequately
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resolve this condition. The licensee proposed either amending the
closed CAQR or initiating a new CAQR.
Since this issue is similar to an existing unresolved item it will be included in Unresolved
Item 50-327, 328/89-19-02 as modified in Inspection Report
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50-327,328/89-21.
The allegation is considered resolved.
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OSP 89-A-0049
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(1) An allegation was received by the NRC staff which stated:
t QA is leaving fire doors propped open on elevation 734 to " test" the fire watch.
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(2) This allegation was not substantiated.
During the review of this i
allegation the inspector noted an NRC violation 50-327/88-46-01 and 50-328/88-46-01 had been issued for failure to perform required
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fire watch patrols. As part of TVA's resporse to this violation, t
the licensee's personnel (QA inspector) periormed periodic monitoring
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of fire watch personnel and their adherence to hourly route schedules. The monitoring activity did include taping hairs on door edges along fire watch routes.
Based on information obtained during the inspection there was no indication that fire doors were propped open. This allegation is considered resolved.
g.
OSP 89-A-0059 (1) An allegation was received by the NRC staff which stated:
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The portal metal detectors used for entry into the power block (protected area) are set too high and normal passage is inhibited.
(2) This allegation was substantiated. The licensee had increased the sensitivity of the power block metal detectors in response to a
NRC security violation 89-19-02. The violation was issued for
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using a calibratian test source heavier than that required by the
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SQN Physical Security Plan, Section 12.3.2.1. As part of the
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violation response, the licensee also revised the metal detector
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functional test, SI-646. The test requires testing of the j
detectors at three levels; shoulders, waist, and ankles, with an
acceptable detection rate of 1005. The current detection rate
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has been increased from 675, in accordance with recommendations in l
NRC Regulatory Guide 5.7.
Instrument maintenance has advised the
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current sensitivity levels on metal detectors be calibrated to detect the certified test source at all three functional test levels.
The NRC inspector has determined that the sensitivity settings on i
the power block metal detectors are in compliance with NRC
recommendations and licensee commitments. This allegation is considered resolved, t
3.
Exit Interview r
The inspection scope and findings were sumarized on October 27, described 1989 with the personnel indicated in paragraph 1.
The NRC inspector the areas inspected and discussed the status of each allegation reviewed.
Also, discussions were held concerning the need to improve comunications
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between management and staff personnel, especially in the handling of TVA staff concerns by the Employee Concerns Program.
It was noted that excessive manpower and time were being utilized by both TVA and the NRC in order-to solve concerns which were attributable to a lack of adequate
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communications between management and staff. The licensee did not identify as proprietary any of the material provided to or reviewed by the inspectors
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during this inspection..
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