ML20003F439
| ML20003F439 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 02/13/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20003F436 | List: |
| References | |
| 50-327-80-46, NUDOCS 8104210250 | |
| Download: ML20003F439 (7) | |
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APPENDIX A NOTICE OF VIOLATION Tennessee Valley Authority Docket No. 50-327 Sequoyah I License No. DPR-77 As a result of the inspection conducted on December 4-5 and 8-10, 1980, and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October.7,.1980),
the following violations were identified.
A.
10 CFR 50, Appendix B, Criterion II requires that activities affecting quality shall be accomplished under suitable environmental conditions and shall take into account the need for special controls. The accepted QA..
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Program requires (17.2) 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 accompN hed under suitable environmental. conditions nor did three test procee i
specify required
- environmental conditions in that the use of the Keituley l
Model 602 Electrometer was permitted when environmental conditions exceeded 60% relative humidity. The TVA Central Laboratory calibration sheet specifi-cally states that readings are only valid for environinents of less than 60%
l relative humidity. Specifically:
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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% for each period (every three hours, starting at 1:00 a.m.) recorded (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 humidity. The only data sheets for this test were dated January 14, 1980; the relative humidity on that date was greater than 60% 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 l
each of these days was in excess of 60% for each period recorded.
This is a Severity Level V Violation (Supplement I.E).
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Appendix A Docket No. 50-327 Notice of Violation License No. DPR-77 B.
10 CFR 50, Appendix B, Criterion XVI and Section 17.2.16 of the accepted QA Progt9.s requires that conditions adverse to quality shall be identified and corrected.
Section 17.2.16 specifically requires that procedures for corrective action shall include provisions to assure 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 December 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 requirements. This item was reinspected on.the same dates as item B02 above with the same result. Again, correct'ive action was not obtained nor was the item-
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escalated to a. Category A item within nine months as required.
This is a Severity Level V Violation (Supplement I.E).
C.
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 Program states that the requirements of these Appendix B criterie shall be implemented through written procedures and instructions.
Procedure 202, Measuring and Test Control, Revision 1, l
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 t 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 assure that the required temperature range is attained and maintained or verified or documented prior to commencing safety-related calibration activities.
This is a Severity Level V Violation (Supplement I.E).
Appendix A Docket No. 50-327 Notice of Violation License No. DPR-77 D.
10 CFR 50, Appndix B, Criterion V and Section 17.2.5 of the accepted QA Program require that activities affecting quality shall be prescribed in procedrares and accomplished in accordance with those procedures.
1.
Procedure 102, Inspection, Maintenance and Calibration Personnel Qualification, 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. 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.
Contrary to the above, the oral reviews were not conducted or documented,j, /
and the documes.ted training did not specify either the level of capa-bility or the da te of qualification / qualification expiration.
2.
Procedure 202, Measuring and Test Control, Revision 1, dated April 7, 1980, requi'res (VI.5. A) that periodic training shall be administered to those performing calibrations.
Contrary t the above, periodic training is not scheduled or carried out on a regular basis and, when conducted, is not documented.
This is a Severity Level V Violation (Supplement I.E)
E.
10 CFR 50, Appendix B, 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. The accepted QA Program further requires (Table 17.2-5) that TVA shall comply with i
Paragraph 4.5.1 of ANSI N45.2.12, Draft 3, Revision 4.
That paragraph requires that the audited organization shall review and investigate any i
I 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 organization 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.
Mussel 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.
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Appendix A Docket No. 50-327 Notice of Violation License No. DPR-77 l
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, B05, B07, B08, B09 and Bil; and CH-8000-02-B01.
i 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.
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This is a Severity Level V Violation (Supplement I.E).
F.
Technical Specification 6.4.1 requires that a retraining and replacement This program is accomplished by AI-14, Plant Training ' /
program for unit staff be maintained under the direction of the Asaistant.
~ Plant Superintendent, Program, Revision 9, dated October 29, 1980.
i 1.
AI-14,Section III, page 46, item (22) requires that fire brigade i
member refresher training for maintenance craftsmen be performed every 12 months.
Contrary tN the above, a maintenance craftsman (steamfitter) received i
fire brigade training initially March 8, 1978, and has not received l
retraining as of December 10, 1980.
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2.
AI-14,Section III, page-46 requires retraining for maintenance craftsmen on Plant Surveillance Test Program (item 11)'and Control of Measuring j
and Test Equipment (item 13) to be conducted biennially.
Contrary to the above, a maintenance craftsman (boilermaker) received initial training in these areas in February 1976 and has received no retraining as of December 4,1980.
j 3.
AI-14, Section'III, page 83 requires retraining for QA supervisors on j
Clearance Procedures (item 10), Adverse Conditions and Corrective Action (item 11), Plant Surve'illance Test Progrca (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 Deceeber 5, 1977; item 11 on 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, i
1980.
This is a Severity Level V Violation (Supplement I.E).
G.
10 CFR 50, Appenuix 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 anurance program. The accepted Quality Assurance Program, Section 17.2.18 states that audits shall be conducted to ensure compliance with training requirements.
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Appendix A Docket No. 50-327 Notice of Violation License No. DPR-77 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% 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% of the plant staff were delinquent in retraining or lacking.
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initial training.
j This is a Severity Level V Violation (Supplement I.E).
H.
10 CFR 50, Appendix B, Criterion XIII and Section 17.2.13 of the accepted
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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.
l Contrary to the above, measures were not established to control storage of materials in that quality identified filters and insulation were stored in warehouse OB-3, with several water leaks in the roof, causing soaking of the packing containers.
t This is a Severity Level V Violation (Supplement I.E).
I.
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 i~n 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 weld 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.
This is a Severity Level V Violation (Supplement I.E).
J.
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 occuring in methods of operation that effect nuclear safety.
l
Appendix A Docket No. 50-327 Notice of Violation License No. DPR-77 Contrary to the above, audits are not performed on methods of operation that effect nuclear safety. This was determined by direct questioning of licensee personnel.
r This is a Severity Level V Violation (Supplement I.E).
K.
Techni:al Specification 6.10.2.g requires that records of training and qualifications for current members of the unit staff be retained, AI-14, j
Plant Training Program, Revision 9, dated October 29, 1980 provides-require-l 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 available.
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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.
This is a Severi'dy Level VI Violation (Supplement 1.F).
L.
10 CFR 50, Appendix B, Criterion V, and Section 17.2.5 of the accepted QA Program require that act,ivities affecting quality shall be prescribed in procedures and accomplished ini 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.
This is a Severity Level VI Violation (Supplement I.F).
Pursuant to the provisions of 10 CFR 2.201, Tennessee Valley Authority is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including:
(1) admission or denial of the alleged violations; (2) the reasons for the violntions if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5)
i Appendix A Docket No. 50-327 Notice of Violation License No. DPR-77 the date when full compliance will be achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
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