ML19343C576

Responds to NRC 810213 Ltr Re Violations Noted in IE Insp Rept 50-327/80-46.Corrective Actions:Keithly 602 Electrometer Use re-evaluated,personnel Qualification Records Updated,Procedures Revised & Insp Procedure Updated

ML19343C576
Person / Time
Site:	Sequoyah
Issue date:	03/16/1981
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 8103240535
Download: ML19343C576 (19)

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s-ENN ESSEE '/ .'.L I -

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400 Chestnut Street Tower II March 16, 1981 9 W N

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Mr. James P. O'Reilly, Director Office of Inspection and Enforcement D g Illi L, - t M/lg ~c> 3 U.S. Nuclear Megulatory Co W asion i ._

Region II - Suite 3100 "f 101 Marietta Street g "'TMT* '

Atlanta, Georgia 30303 A

Dear Mr. O'Reilly:

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SEQUDYAH NUCLEAR PLANT UNIT 1 - NRC-OIE REGION II INSPECTION REPORT -

50-327/80 RESPONSE TO VIOLATIONS The subject letter dated February 13, 1981, cited TVA with 12 violations.

TVA received an extension to the twaponse deadline during a telephone conversatics with J. Crienjak on March 10, 1981. Enclosed are our

. responses to those violations.

If you have any questions, please get in touch with D. L. Lambert at PTS 857-2581.

To the best of ry knowledge, I declare the statements contained herein are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY L. M. Mills, Manager Nuclear Regulation and Safety Enclosure oct Mr. Victor Stello, Director (Enclosure)

Office of Inspection and Enforcement g 0.;@i U.S. Nuclear Regulatory Commission 9 Washington, DC 20555 3 II 8103240635 -

ENCLOSURE SEQUOYAH NUCLEAR PLAhT RESPONSE TO VIOLATIONS 50-327/80-46 50-327/80-46-12 L

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Violation 327/80-46-01 10 CFR 50, Appendix B, Criterion II requires that activities affecting quality shall be accomplished under suitable enviranmental conditions and shall take into account the need for special controls. The accepted QA program (17.2) requires that the program shall comply with the requirements of 10 CFR 50, Appendix B and (17.2.11) that test program procedures shall include, as necessary, environmental conditions.

Contrary to the above, activities affecting quality were not accomplished under suitable environmental conditions nor did three test procedures

'specify required environmental conditions in that the use of the Keichley Model 602 electrometer was permitted when environmental conditions exceeded 60-percent relative humidity. The TVA Central Laboratory calibration sheet specifically states that readings are only valid for environments of less than 60-percent relative humidity. Specifically:

1. IMI-92-SRPC, Source Range Proportional Counter Testing, Revision 1 dated April 3,.1980, does not include a requirement to check or record the relative humidity. This test procedure was used on January 9, 1980 and February 6, 1980, and the relative humidity on both of these days was in excess of 60-r9tcc - for each recorded period (every three hours, starting at 1:00 a.m.). The humidity data was provided by the Environmental Data and Information Service of the National Oceanic and Atmospheric Administration.

2. _IMI-92-IRIC, Intermediate Range Compensated Ion Chamber Testing, Revision 0 dated April 3, 1980, does not include a requirement to check or record the relative humidi'y. The only data sheets for this test were dated January 14, 1980; the relative humidity on that date was greater than 60-percent before 10:00 a.m. and after 7:00 p.m.; no time for conducting the test is documented.

3. IMI-92-PRIC, Power Range Uncompensated Ionization Chamber Testing, Revision 1 dated March 19, 1980, does not include a requirement to check or record the relative humidity. This test procedure was used on January 9, 17, 26, and May 14, 1980, and the relative humidity on each of_these days was in excess of 60 percent for each period recorded.

Admission of Violation The alleged violation occurred as stated.

Reason for Violation Plant procedures did not implement the requirement.

Corrective Steps Which Have Been Taken

1. Further evaluation was performed to determine if other CSSC activities required the use of Keithly 602 electrometers. No other activities were found.

2. The activities involving the use of Keithly 602 electrometers were evaluated to determine if retesting is required. These instruments are used in the leakage current test to determine if a detector is defective before final installation. kn e months of satisfactory operation have adequately demcastrated preger detector operation.

Additional considerations:

Source Range: Is a proportional counter that detects a definite pulse per count and discriminates against low level voltages.

Power Range: High leakage current would be negligible at higher reactor powers and channel deviation with flux maps would indicate a defective detector at the lower power levels.

Intermediate Range: Would be most affected at the lower power levels, however, overlapping by the source and power range channels provides the neces-sary assurance of proper operation on each reactor startup.

Under these circumstances, it is our position that retesting of the excore detectors is unnecessary.

Corrective Action Which Has' Been Taken To Avoid Further Noncompliance Instructions IMI-92-IRIC, IMI-92-IRIC, and EMI-92-PRIC were revised to incitde a humidity requirement .before performing tests in the future.

Additionally, a tag has been placed on the meters to indicate that the calibration is not valid when the relative humidity is above 60 percent.

Other test instruments have been evaluated by the central lab to determine any unusual operating requirements, and no additional instruments have

'been identified.' The central laboratories have issued an instruction letter to identify any instrument where caution should be exercised -

d'aring use. A caution label will be attached to those instruments during use.

Date When Full Compliance Will Be Achieved The deficiency has been corrected and we.are now in compliance.

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f Violation 327/80-46-02 10 CFR 50, Appendix B, Criterion V and Section 17.2.5 of the accepted QA program require that activities affecting quality shall be prescribed in procedures and accomplished in accordance with those procedures.

1. Procaduce 102, Inspection, Maintenance and Calibration Personnel Qus;ification, Revision 0, dated March 13, 1979, requires that:

(II.3.A) the capabilities and proficiency of personnel shall be determined by suitable performance demonstration, including oral review of performance; and, (II.5.3. A(3) and (8)) the qua13'ication of personnel shall be documented in an appropriate form that includes the level of capability and the date of qualification and qualification expiration.

Contrary ,to the above, the oral reviews were not conducted or documented, and the documented training did not specify either the level of capability or the date of qualification / qualification expiration.

2. Procedure 202, Measuring and Test Control, Revision 1, dated April 7, 1980, requires (VI.5.A) that periodic training shall be administered to those performing calibrations.

Contrary to the above, periodic training is not scheduled or carried out on a regular basis and, when conducted, is not documented.

Admission of Violation The alleged violation occurred as stated.

Reason for Violation

.There was a lack of supportive-documentation for pers'nnel o qualification.

The procedure which has been prepared on " Personnel Qualifications" was very awkward to implement and did not provide for an ongoing working file; therefore, the QA records were incomplete.

Corrective Steps Which Have Been Taken Personnel qualification records have been updated to meet QA requirements.

Corrective Action Which Has Been Taken To' Avoid Further Noncompliance The procedure has been revised to meet QA requirements and also to provide working support documents.

Date When Full Compliance Will Be Achieved We are now in full compliance.

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Violation 327/80-46-03 10 CFR 50, Appendix B, Criterion II requires that activities affecting quality shall be accomplished under suitably controlled conditions such as environmental conditions. The accepted QA program, Section 17.2, states that the TVA QA program complies with the requirements of Appendix B.

Section 17.2.2 of the accepted QA progres states that the requirements of these Appendix B criteria shall be implemenced through written procedures and instructions. Procedure 202, Measuring and Test Control, Revision 1, dated April 7, 1980, requires (VI.6. A) that the laboratory shall be maintained with adequate temperature controls and (VI.7.A) that working areas (other than the Standards Laboratory) shall be maintained at a temperature of 73 F i 9 F.

Contrary to the above, activities affecting quality may not be accomplished under suitably controlled environmental conditions in that no program or system or. procedures have been established to ensure that the required temperature range is attained and maintained or verified or documented prior to commencing safety-related calibration activities.

Admission of Violation The alleged violation occurred as stated.

Reason for Violation Assumptions had been made that the. temperature span of 73 F i 9 F was well within the personnel comfort range and continuous monitoring in less critical areas of the lab was- not considered to be necessary.

'- Dae more critical. areas were and are monitored during times of test.

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Corrective Steps Which Have Been Taken Recording monitors have been placed to continuously monitor building temperature.

- Corrective Action Which Has Been Taken To Avo'.d Further Noncompliance Laboratory instructions have been revised to provide for a corrective action procedure should any indication of temperatures outside the. allowable range be observed.

Date When Full Compliance Will Be Achieved .

The deficiency has been corrected and we are now in compliance.

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Violation 327/80-46-04 5

10 CFR 50, Appendix B, Criterion XVI and Section 17.2.16 of the accepted QA program requires that conditions adverse to quality shall be identified and corrected. Section 17.2.16 specifically requires that proc?dures for corrective action shall include provisions to ensure correction of adverse conditions. Procedure QAAS-QAP-3.1, Quality Audit Program, Revision 5, dated August 20, 1980 requires (6.7.3) that if a category B finding is not closed within nine months of the date of the audit report, it shall be escalated to a category A finding.

Contrary to the above, conditions adverse to quality were not corrected in that two category B items were identified in an audit conducted on April 17-18, 1979, and the items remain uncorrected and were not escalated to category A items 20 months later in Dece=ber 1980. Specifically:

1. Item CH-7900-01-B02 identified that Central Laboratory activities affecting quality were not always prescribed by documented instructions.

"The item was reviewed on September 24, 1979, December 20, 1979, May 5, 1980, July 24, 1980, and October 31, 1980. Each time it was documented that the item remained uncorrected and the item was not escalated to a category A item nor was corrective action obtained within nine months as required.

2. Item CH-7900-01-B03 identified that Central Laboratory procedures do

.not contain some QA program document control require =ents. This item was reinspected on the same dates as ites B02 above with the same result. Again, corrective action was not obtained nor was the item escalated to a category A item within nine months as required.

Admission of Violation The alleged violation occurred as stated.

Reason for Violation Category B items were considered minor in nature but did require that corrective action be taken. The escalation of items from B to A was a new practice and at the time of the subject review these ite=s were not escala*.ed due to a failure to follow procedures. It is believed that the unusual practice of' categorizing ite=s caused the failure to follow the procedures.

Corrective-Steps Which Have Been Taken Procedure QAAS-3.1 was revised and issued on December 8, 1980, to remove category B findings from the audit program. From that point in time,;all deficiences are identified as category A findings and require a written response from the audited organization. -This eliminates the need for escalation of future audit-findings from category B to category A. Also procedure OP-QAP-18.1 has been revised te eliminate category'B. findings and is presently being circulated for signature. This procedure is expected to be issued by March 31, 1981.

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4 f- Corrective Steps Which Will Be Taken To Avoid Further Violations The procedures indicated in item 3 above have been reemphasized to all OPQA auditors.

Date When Full Compliance Vill be Achieved i'

t= Full compliance vill be achieved March 31, 1981.

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Violation 327/80-46-05 10 CFR 50, Appendix V, Criterion XVIII requires that audit results shall be documented and followup action taken where indicated. The accepted QA program (17.2.18) requires that audits identify program weaknesses and nonconformances and that corrective action shall be documented. T'e accepted QA program further requires (Table 17.2-5) that TVA shall .omply with Paragraph 4.5.1 of ANSI N45.2.12, Draf t 3, Revision 4. That paragraph requires that the audited organization shall review and investigate any adverse findings and shall respond to the audit report within 30 days giving the results of the review and investigation along with proposed corrective action.

Contrary to the above, audit results were not documented and followup actions were not taken in that the audited orSanization did not respond in writing within 30 days to items that were violations of program requirements.

Specifically:

1. Sequoyah did not respond to items SQ-8000-01-B01, B02, and B03; SQ-8000-02-B01; SQ-8000-03-B01; SQ-8000-05-B01; and JA-8000-05-B02.

2. Muscle Shoals did not respond to items MS-80TS-01-B01 and B02,

3. Central Laboratory did not respond to items JA-8000-01-B01, JA-8000-04-B01, and B02.

4. The Division of Nuclear Power, various offices in Chattanooga, did not respond to items CH-7900-01-B01 and B02; CH-7900-06-B01; CH-80SP-02-B01, B04, 305,.B07, B18, B09 and B11; and CH-8000-02-B01.

Additional items were not included, although other items were also not responded to by the audited organizations. The above examples were selected because no responses had been received as of December 10, 1980, and the identified items also remained uncorrected or the corrective actions had not been verified.

Admission of Violation The alleged violation occurred as stated.

Reason for Violation The audit program procedures OP-OQAP-18.1 and OP-QAS-3.1 did not '

. require a written response for category B findings because category B findings were considered minor-in nature.

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4 Corrective Steps Which Have Been Taken and The Results Achieved Same as for violation'327/00-46-04.

Corrective' Steps Which Will Be Tak . To Avoid Further Violations Same as for violation 327/ou-96-04.

. Date'When Full Compliance Will be Achieved i

~ Same as for violation 327/80-46-04.

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Violation 327/80-46-06 Technical Specification 6.4.1 requires that a retraining and replacement program for unit staff be maintained under the direction of the Assistant Plant Superintendent. This program is accomplished by AI-14, Plant Training Program, Revision 9, dated October 29, 1980.

1. AI-14,Section III, page 46, ites (22) requires that fire brigade member refresher training for maintenance craftsmen be performed every 12 months.

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Contrary to the above, a maintenance craf tsman (steamfitter) received fire brigade training initially March 8, 1978, and has not received retraining as of-December 10, 1980.

2. AI-14,Section III, page 46 requires retraining for maintenance craftsmen on Plant Surveillance Test Program (ites II) and Control of Measuring and Test Equipment (item 13) to be conducted biennially.

Contrary to' the above, a maintenance craf tsman (boilermaker) received initial training in these areas in February 1976 and has received no retraining as of December 4, 1980.

3. AI-14,Section III -page 83 requires retraining for QA supervisors on Clearance Procedures (item 10), Adverse Conditions and Corrective Action (item 11), Plant Surveillance Test Program (item 12), and Control of Measuring and Test Equipment (item 14), to be conducted biennially.

Contrary to the above, a QA Supervisor received initial training for item 10 on December 5,1977; item 11 cni July 29, 1977; and items 12 and 14 on November 14, 1977. Based on document review and personal

-interview, he has not received retraining in these areas as of December 5, 1980.

Admission of Violation Item 1 -- the alleged violation did not occur as stated.

Item 2 -- the alleged violation occurred as stated.

Item 3 -- the alleged violation occurred as stated.

Reason for Violation Item 1 -- TVA does not require fire brigade me=ber refresher training for

.all maintenance craftsmen. The craftsman identified in the violation was not required to have the firt brigade refresher training. :AI-14,. Revision 9, Section II7., page 46, item (22),

footnote 2, states: "This training wil'. be required of all craf ts foremen and dual-rated foremen." Revision 10 which was issued in AI-14 further. clarifies what training craftsmen are required to have successfully completed.

Item 2 -- AI-14, Plant Training Program, Revision 9,Section I, page 4, item (10.E), delegated to the individual section supervisors the respansibility of administering the required GET training and retraining to their section personnel. Due to the increased plant work load resulting from the unit 1 startup and testing program or a failure to adequataly analyze the craining needs of section personnel, some section supervisors were negligent in implementing the required retraining program.

Item 3 -- This supervisor failed to attend scheduled retraining classes which were conducted within his section.

Corrective Steps Which Have Been Taken Item 2 -- A retraining program has been initiated which assigned to speci-fic sections the requi.ement of presenting to all SNP personnel the GET course or courses which are most closely related to the assigned section's primary areas of responsibility. These presentations are pre-planned classroom sessions scheduled on a biannual basis.

Item 3 -- GET retraining classes were conducted in January 1981 for the Quality Assurance Section personnel. This supervisor attended the required retraining classes-for the referenced courses on

' January 20 and 21, 1981.

Corrective Steps Which Will Be Taken To Avoid Further Violations Item 2 and'3 -- (a) A preplanned routine schedule of GET course presentations has been established.

(b) The training office will notify. each section supervisor of section personnel requiring initial training or retraining in a scheduled GET course prior to the course presentation.

Date When Full Compliance Will Be Achieved Item 2 --. December 31, 1981.

Item 3 -- We are now in full compliance.

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4 Violation 327/80-46-07 10 CFR 50, Appendix B, Criterion XVIII requires a comprehensive system of planned and periodic audits to be carried out to verify compliance with all aspects of the quality assurance program. The accepted Quality Assurance Program, Section 17.2.18 states that audits shall be conducted to ensure compliance with training requirements.

Contrary to the above,-comprehensive audits of training were not conducted as described below:

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) was inadequate, when in fact 'at the time of the audit approximately 50-percent of the plant staff were delinquent in retraining or lacking initial training.

2. Compliance Audit - Inplant Survey Checklist No. 2-79-2 conducted on November. 12, 1979,_ reviewed the training area, specifically implementa-tion of AI-14, Plant Training Program, and determined that no deficiencies were found. At the time of this survey, as with the audit discussed above, 50-percent of the plant staff were delinquent in retraining or lacking initial training.

Admission of Violation The violation is denied.

Reason The violation s'tated that comprehensive audits of training were not

- conducted. An audit was conducted in August 1979 which reviewed the training program and identified- that 85 percent of the outage personnel and 45 percent ef. the public safety personnel were not included in the program.

The audit further identifiea that plant procedures did not require

- training of craftsmen in the outage section. If considered in the content of_the time frame before receiving an operating' license, it seems that this audit was comprehensive in that it did identify deficiencies in the program that have since been corrected. The' training program at Sequoyah will be audited as scheduled in' April 1981, and this will also

- be a comprehensive audit. Inplant surveys are not considered to be

- audits as defined in 10 CFR 50, Appendix B, Criterion XVIII.

Violation 327/80-46-08 10 CFR 50, Appendix B, Criterion XIII and Section 17.2.13 of the accepted QA program require that measures be established to control storage of material and equipment to prevent damage. The accepted QA program commits to ANSI N45.2.2-1972. Paragraph 6.1.2(3) of this standard states that

- Level C items (i.e., filters, insulation) shall be stored indoors or equivalent with all provisions and requirements as set forth in Level B items except that heat and temperature control is not required. Paragraph 6.1.2(2) requires the enclosure to be weathertight.

Contrary to the above, measures were not established to control storage of materials-in that quality identified filters and insulation were stored in warehouse 05-3, with several water leaks in the roof, causing soaking of the packing containers.

Admission of Violation The alleged violation occurred as states.

Reasons-for Violation-4 Inadequate observation and lack of preventative maintenance on the roof caused the deficiency.

Corrective Steps Which Have Been Taken~and the Results Achieved The filters and insulation were immediately checked and removed from the leakage area. Maintenance Request No. 081885 was initiated to repair the roof.

s Corrective Steps Which Will Be Taken to Avoid Further Violations Short-term prevention will se close observation'of warehouse areas during' rain periods.

Long-term prevention will ' be to build a new permanent varahouse area.

=Date When Full Compliance Will be Achieved-

' Full compliance was achieved December 22, 1980.

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i Violation 327/80-46-09 10 CFR 50, Appendix B, Criterion V and Section 17.2.5 of the accepted QA program require that activities affecting quality snall be prescribed in procedures and accomplished in accordance with those procedures.

Contrary to the above, procedures were not followed in that several stainless steel elbows and tees located in the modification outage warehouse, under ECN L5009, were stored without protective caps or plugs for veld end preparations as required by Procedure AI-11, Material - Receipt Inspection, Revision 14, dated August 1980, Paragraph 4.2a. None of the inspected items had any observable damage.

Admission of Violation The alleged violation occurred as stated.

Reason for Violation The violation was an oversight as the material was received from construction and not through NUC PR storeroom.

' Corrective Step Which Has Been Taken The materials were inspected and properly covered. Caps and plugs were ordered.

Corrective Action Which Has Been Taken to Avoid Further Noncompliance

, Procedure AI-11 was reviewed 'and warehousemen were informed that receipt 2

inspection is _ also applicable -for material received from all sources.

Date When Full' Compliance Will Be Achieved The deficiency has been corrected and'we are now in compliance.

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Violation 327/80-46-10 Technical Specification 6.5.2.8 requires audits to be performed under the cognizance of the Nuclear Safety Review Board (NSRB) at least once each six months. These audits encompass the results of actions taken to correct deficiencies occurring in methods of operation that affect nuclear safety.

Contrary to the above, audits are .7ot performed on methods of operation q that affect nuclear safety. This wts determined by direct questioning of '

licensee personnel.

Admission of Violation

.o Alleged violation occurred as stated.

Reason for Violation Technical Specification 6.5.2.8 requires that audits encompass the results of actions taken to correct deficiencies occurring in unit equipment, structure, systems, or methods of operation. The methods of operation portion of this requirement had been interpreted to mean those changes in procedures that are required as a result of modifications to plant equipment. This aspect of method of

' operation had been an integral part of the audit program.

Corrective Steps Which Have Been Taken The QA interpretation of this requirement has been modified to agree with the NRC interpretation.

Corrective Steps Which Will Be Taken To Avoid Furthet violations The methods of operation including reviews of LER's, results of surveys of operation, potential reportabic recurrences, etc., will be incorporated as an integral part of the plan: design modification audit scheduled to Se conducted in June 1981,. and every six months thereafter.

Date When Full Compli . 2 Will Be Achieved Full compliance will be-achieved in June 1981. ,

e Violation 327/80-46-11 Technical Specification 6.10.2.g requires that records of training and qualifications for current members of the unit staff be retained. AI-14, Plant Training Program, Revision 9, dated October 29, 1980 provides require-

.ments to accomplish this specification and states that this control is applicable to personnel temporarily assigned to Sequoyah unit staff.

1. Contrary to the above, records of training and qualifications for three current members of the unit staff were not availabic.

2. Contrary to the above, the records of two Senior Reactor Operators currently members of the unit staff did not contain evidence of licensed operator training nor did they contain any indication or evaluation which would indicate that the required records were available at some other location.

Admission of Violation The alleged violation occurred. The above description of the subject violation, as extracted from Appendix A to J. P. O'Reilly's letter dated February 13, 1981, is not consistent with the discussion of the subject violation in inspection. report 50-327/80-46. The following sta-ements address the subject violation as described ia che inspection report.

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Reason for Violation The-training and qualification records of the Senior Reactor Operators were 1ocated at the facility but were filed separately from_ permanent

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_ plant personnel. The two operators were on loan from another plant.

The Radchem technican's training' file t.c4 not been received from his permanent station. He was on a temporary duty assignment from another plant.

- Administrative personnel oversight caused the violation.

Corrective Action Which Has Been Taken The training records for the two Senior ~ Reactor Operators, who are

' temporary members.of the staff, were located at this facility and filed in the. plant master file under a temporary listing. The plant was -

maintaining-training records for temporary personnel in a separate location from the-permanent plant personnel.

The training records for the Radchem technician were requested from his permanent duty station.

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Corrective Action Which Has Been Taken To Avoid Further Noncompliance the chock-in procedure now ensures that all new or temporary personnel check in with the Training Officer so that training records can be established or requested from the permanent duty station.

To ensure that the future training records are obtained and training files are_ established for both permanent and temporary _ personnel, the

- plant's master file training records.are being relocated from the master file to-the direct control of the training officer.

Date When Full Compliance Will Be Achieved We will be in full compliance on or before March 30, 1981.

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Violation 327/80-46-12 10 CFR 50, Appendix' B, Criterion s, and Se< tion 17.2.5 of the accepted QA program require that activities affecting cuality shall be prescribed in procedures and accomplished in accordance with these procedures. SQA-66, Plant Housekeeping - Solid Waste Management, dated December 1979, requires each section supervisor to establish appropriate controls to meet the requirements of this standard. Procedures and instructions for housekeeping practices . . . shall be prepared and issued as required.

Contrary to the above, activities affecting quality were not accomplished in accordance with procedures in that each section supervisor has not established appropriate controls to meet the requirements of SQA-66.

Admission of Violation The alleged violation occurred as stated.

Reason for Violation Failure to implement formal inspection progra= caused the violation.

Corrective Steps Which Have Been Taken and The Results Achieved Informal walk downs are being conducted with acceptable results to maintain plant cleanliness.

Corrective Steps Which Will Be Taken To Avoid Further Violations The requirements'of DPM N74A17 (Revised 9/24/80) will be incorporated into SQA66. The plant superintendent shall designate individuals

. responsible for performing checks _ for specific areas. The criteria for .this check will be defined by a checklist.

,Date When Full' Compliance Will-be Achieved Full compliance for dhis iten will be ' achieved on or before March 30, 1981.

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