ML20041D855
| ML20041D855 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/04/1982 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8203090339 | |
| Download: ML20041D855 (4) | |
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TENNESSEE VALLEY AUTHORITY CHATTANOOGA. TENNESSEE 374ot 400 Chestnut Street Tower II 4
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March 4, 1982 NNO 1
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U.S. Nuclear Regulatory Commission g
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Region II
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Attn: James P. O'Reilly, Regional Administrator f
101 Marietta Street, Suite 3100 g/g Atlanta, Georgia 30303
Dear Mr. O'Reilly:
SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC/0IE REGION II INSPECTION REPORT 50-327/81-42 AND 50-328/81,2SPONSE TO VIOLATION The subject OIE inspection report dated February 4,1982 cited TVA with one Severity Level IV Violation and one Severity Level V Violation. Enclosed is our response to the subject inspection report.
If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY L
M s
er Nuclear Regulation and Safety Enclosure cc:
Mr. Richard C. DeYoung, Director (Enclosure)
Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, DC 20555 fyl bl l 8203090339 820304 PDR ADOCK 05000327 An Ec;ual Opportunity Employer G
ENCLOSURE SEQUOYAH NUCLEAR PLANT RESPONSE - NRC INSPECTION REPORT NOS. 50-327/81-42 AND 50-328/81-52 F. S. CANTRELL'S LETTER TO H. G. PARRIS DATED FEBRUARY 1:, 1982 Item A - (327/81-42-02 and 328/81-52-03) 10 CFR 50, Appendix B, Criterion II requires in part that the licensee..." shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained..." The Operational QA Manual, part III, section 6.,
paragraph 1.5.1 also addresses ths general aspects of training. Administrative Instruction, AI-14, " Plant j
Training Program" implements these requirements, AI-14, paragraph II. A.3 states in part..." Employees shall be evaluated for comprehension of the i.
material presented by the completion of a written examination..."
Contrary to the above, a significant number of employees in the observed
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classes were not evaluated for comprehension or suitable proficiency in that casual proctoring invalidated the examinations.
This is a Severity Level VI Violation (Supplement I.F.).
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted Rules for conduct during the testing phase of General Employee Training (CET) classes were thought. to be understood and had hcrer been specified. This led to misunderstanding by instructors and
, other employees on the importance of examination integrity.
3 Corrective Steps Which Have Been Taken and the Results Achieved I
a.
Rules for seating and testing during GET classes have been established and distributed (by plant management) to all section supervisors and are n?peated before each GET session so that all plant personnel have become familiar with them. These include:
1 (1) Spaced seating.
(2) No talking except with instructor.
(3) All tests taken independently.
(4) Discit inary action for offenders.
b.
A representative from plant management is now required to be on hand to assist in proctoring the testing phase of each GET session.
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c.
Rosters for the two GET presentations in which the problem was identified have not been entered into the training records and section supervisors have been notified by the training officer that all persons attending these sessions will be required to retake the respective courses.
d.
An investigation which included examination of available evidence and personal interrogation of ir.structors who conducted other training during the current schedule of GET classes produced no evidence that the observed conduct was indicative of the usual GET sessions. From this, it was decided that there would be no need to repeat training in GET-4, 5, and 6.
e.
To aid in future assessments, all tests are now being retained in the training office for a minimum of 30 days.
f.
Before each schedule of classes, the training officer is counseling each designated GET instructor on class conduct and examination integrity.
g.
As a result of the above actions; _ no observed misconduct has gone unchecked which would tend to compromise the integrity of Sequoyah Nuclear Plant's GET courses.
4.
Corrective Steps Which Will Be Taken To Avoid Further Violations Plant management will continue to make all plant personnel a.
familiar with and enforce the rules for conduct during the testing phase of GET classes, b.
Plant management will continue to require management personnel to monitor the testing phase of GET presentations.
c.
All GET tests will be retained in the training office for a minimum of 30 days to aid in future assessments, d.
In order to eventually eliminate a and b above, plant management is working through the TVA Power Operations Training Center to provide instructors more qualified to properly conduct GET presentation and devalop various versions of GET tests to maka management proctoring unnecessary.
The training officer will continue tc counsel denignated GET e.
instructors on class conduct and examination integrity.
5.
Date When Full Compliance Will Be Achieved Plant management and the training officer took immediate corrective actions upon being notified of these incidents. The program to avoid recurrence is functioning fully at this time. Full compliance was achieved on January 4, 1982.
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Item B (328/81-52-01)
Technical Specification 6.8.1.a requires that written procedures shall be established, imalemented and maintained covering activities including safety-related annunciator response.
Contrary to the above, System Operating Instruction, S0I 55-0-M-12, (XA-55-12D), " Annunciator Response", was not implemented in that on December 15, 1981, the sample pump for monitor 2-RM-90-112 tripped producing an instrument malfunction annunciator. When questioned by the inspector, the unit 2 operators were not aware of the annunciator and no action was taken to correct the problem. Immediate action required by SOI 55-0-M-12 for the 2-RM-90-112 instrument malfunction annunciator included checking the instrument on the panel and dispatching an operator to the monitor to evaluate the problem.
This is a Severity Level V Violation (Supplement I.E.).
1.
Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.
2.
Reasons for the Violation if Admitted The operator placing monitor 2-RM-90-106 in the tripped condition checked control room panel 0-M-12 for alarms before removing the monitor from service for a surveillance test. At the time the check was made, there was no alarm indication and the alarm was not received until after the check was made. Upon receipt of the alarm for monitor 2-RM-90-112, an immediate response was not initiated.
3 Corrective Actions Which Have Been Taken and the Results Achieved An auxiliary unit operator was dispatched to the monitor to start one sample pump on monitor 2-RM-90-112.
The malfunction annunciator was cleared and the monitor was determined to be operable.
Monitor 2-RM-90-106 was returned to service upon completion of the surveillance test. There were no violations of technical specification limiting condition "or operation since each of the containment penetrations providied direct access from the containment atmosphere to the outside atmosphere was closed.
Immediate and correct respons6S to alarms were stressed to operations personnel as outlined in the appropriate SOIs.
4.
Co"rective Steps Which Will Be Taken to Avoid Further Violations The above corrective actions have been taken to prevent further noncompliance.
5.
Date When Full Compliance Will Be Achieved Full compliance was achieved on December 31, 1981 by implementing the corrective action indicated in No. 3 above.