ML20042B701
| ML20042B701 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 03/17/1982 |
| From: | Cantrell F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20042B702 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737 NUDOCS 8203250549 | |
| Download: ML20042B701 (4) | |
See also: IR 05000327/1981042
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Tennessee Valley Authority
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Gentlemen 1:
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Subject: Report Nos fiQ-327/81-42,and 50-328/81-52
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Thank you for your letter of March 4,1982, informing us of steps you have
taken to correct the violation concerning activities under NRC Operating
License Nos. DPR-77 and DPR-79 brought to your attention in our letter of
February 4,1982. We will exmine your corrective actions and plans during
subsequent inspections.
We appreciate your cooperation with us.
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Sincently,
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F. S. Cantrell, Acting Chief
Reactor Projects Branch 1
Division of Project and Resident
Programs
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H. J. Green, Director of Nuclear
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G. G. Stack, Project Manager
C. C. Mason, Plant Superintendent
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J. F. Cox, Supervisor Nuclear
Licensing Section
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H. J. Burzynski, Project Engineer
H. H. Culver, Chief, Nuclear Safety
Review Staff
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NRC Resident Inspector
Document Management Branch
State of Tennessee
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TENNESSEE VALLEY AUTHORITY
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March 4, 1982
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U.S. Nuclear Regulatory Commission
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Attn: James P. O'Neilly, Regional Administrator
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Atlanta, Georgia 3030
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Dear Mr. O'Reilly:
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SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC/0IE REGION II INSPECTION FSPORT
50-327/81-42 AND 50-328/81-52 - RESPONSE 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. Mills, Manager
Nuclear Regulation and Safety
Enclosure
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Mr. Richard C. DeYoung, Director (Enclosure)l/
Office of Inspection and Enforcement
U.S. Nuclear Regulatory Commission
Washington, DC 20555
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An Equal Opportunity Employer
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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 4,1982
Item A - (327/81-42-02 and 328/81-52-03)
13 CFR 50, Appendix B, Criterion II requires in part that the
licensee..." shall provide for indoctrination and training of personnel
performing activities affecting quality at; necessary to assure that
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suitable proficiency is achieved and maintained..." The Operational
QA Manual, part III, section 6.,
paragraph 1.5.1 also addresses the
general aspects of training. Administrative Instruction, AI-14, " Plant
Training Program" implements these requirements, AI-14, paragraph II. A.3
states in part..." Employees shall be evaluated for comprehension of the
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 (GET) classes were thought to be understood and had never
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
a.
Rules for seating and testing during GET classes have been
established and distributed (by plant management) to all section
supervisors and are repeated before each GET session so that all
plant personnel have become familiar with them. These include:
(1) Spaced seating.
(2) No talking except with instructor.
(3) All tests taken independently.
(4) Disciplinary 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
ser.sion.
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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.
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d.
An investigation which included examination of available
evidence and personal interrogation of instructors who conducted
other training during the current schedule of GET classes
produced no evidence that the observed conduct was indicative of
ths 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 manimum of 30 days.
f.
Before each schedule of classes, the training officer is
counseling each designated GET instructor on class conduct and
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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
a.
Plant management will continue to make all plant personnel
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 develop various versions of GET tests to
make management proctoring unnecessary.
e.
The training officer will continue to counsel designated GET
instructors on class conduct and examination integrity.
5.
Date When Full Compliance Will Be Achieved
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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, implemented and maintained covering activities including
safety-related annunciator response.
Contrary to the above, System Operating Instruction, SOI 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
SGI 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 7 Violation (Sopplement I.E.).
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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 conditica
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 imnediate 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 for operation since each of the
containment penetrations providing direct access from the
containment atmosphere to the outside atmosphere was closed.-
Immediate and correct responses to alarms were stressed to
operations personnel as outlined in the appropriate SOIs.
4.
Corrective 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.
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