ML20053A868

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Corrected IE Insp Repts 50-327/82-04 & 50-328/82-04 on 820206-0305.Noncompliance Noted:Failure to Comply W/Tech Spec 3.1.3.3 & to Perform 10CFR50.59 Safety Evaluation for Sys Mod
ML20053A868
Person / Time
Site: Sequoyah  Tennessee Valley Authority icon.png
Issue date: 04/05/1982
From: Butler S, Ford E, Quick D
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20053A829 List:
References
50-327-82-04, 50-327-82-4, 50-328-82-04, 50-328-82-4, NUDOCS 8205270373
Download: ML20053A868 (10)


See also: IR 05000327/1982004

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UNITED STATES .

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NUCLEAR REGULATORY COMMISSION

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REGION II

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101 MARIETTA ST., N.W., SUITE 3100

ATLANTA, GEORGIA 30303

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Report Nos. 50-327/82-04 and 50-328/82-04

Licensee: .Tenncssee Valley Authority

.500A Chestnut Street

Chattanooga, TN 37401

Facility Name:

Sequoyah t4] clear Plant

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Docket Nos. 50-327 and 50-328

License Nos. DPR-77 and DPR-79

Inspection at Sequ

h site near Soddy Daisy, Tennessee

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In'spectors :

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'Date Signed

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Approved by:

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Quick, S(ction Chief, Division of

Da te' Signed

Project and Resident Programs

SUttilARY

Inspection on February 6 - !! arch 5,1982

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Areas Inspected

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This routine, unannounced inspection involved 197 inspector-hours on site in the

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areas of Operational Safety Verification, Independent Inspection Effort, General

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Employee Training, Inspection of Till Action Plan Requirements, Unit 2 Startup

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Testing and. Licensee Action on Previous Inspection Findings.

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Of the six areas inspected, no violations or deviations were identified in 'five

areas; two violations were found in one area (327/82-04-01, 328/82-04-01 Failure

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to comply with technical specification 3.1.3.3 and 328/82-04-02 Failure to

perfonn a 10 CFR 50.59 safety evaluation for system modification).

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DETAILS

1.

Persons Contacted

Licensee Employees

C. C. Mason, Plant Superintendent

J. E. Cross, Assistant Plant Superintendent

P. R. Wallace, Assistant Plant Superintendent

J. M. ficGriff, Assistant Plant Superintendent

J. W. Doty, liaintenance Supervisor (ft)

W. A. Watson, Maintenance Supervisor (E)(I)

B. ft. Patterson, flaintenance Supervisor

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L. ft. Nobles,0perations Supervisor

W. H. Kinsey, Results Supervisor

R. J. Kitts, Health Physics Supervisor

J. T. Crittenden, Public Safety Service Supervisor

R. L. Hamilton, Quality Assurance Supervisor

M. R. Harding, Compliance Supervisor

W. M. Halley, Preoperational Test Supervisor

J. Robinson, Outage Director

Other licensee employees contacted included field services craftsmen,

technicians, operators, shift engineers, security force members, engineers,

maintenance personnel, contractor personnel and corporate office personnel.

Other Organizations

C. R. Stahle, Licensing Project Manager, NRR

E. G. Adensam, Chief, Licensing Branch #4, NRR

  • Attended exit interview

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2.

Exit Interview

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The inspection scope and findings were summarized with the Plant

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Superintendent and/or members of his staff on February 24 and March 5,1982.

The violations against Units 1 and 2 were discussed and the licensee

acknowleded.

During the reporting period, frequent discussions are held

with the Plant Superintendent and his assistants concerning inspectien

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findings.

3.

Licensee Action on Previous Inspection Findings

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(Closed) 327/81-07-01, 81-07-02, 81-07-03 The inspector reviewed the

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licensee's response to the Notice of Violation dated June 17, 1981 and finds

it acceptable.

The implementation of the detailed corrective action was

initially verified and the inspector continues to monitor the licensee's

performance in these areas periodically.

These items are closed.

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(Closed) 327/81-12-01 The inspector reviewed the licensee's response to the

Notice of Violation dated April 17, 1981 and implementation of corrective

action and finds them acceptable. This item is closed.

(Closed) 327/81-?3-02,328/81-28-02 The inspector reviewed the licensee's

response to the Notice of Violation and deviation dated September 28, 1981

and implementation of corrective action and finds them acceptable.

These

items are closed.

(Closed)

328/81-38-01, 81-38-02, 81-38-03, 81-38-04, 81-38-05 The

inspector reviewed the licensee's response to the Notice of Violation dated

October 30, 1981 and implementation of corrective action and finds them

acceptable.

Violation 328/81-38-03 was withdrawn.

These items are closed.

(Closed) 328/81-42-01, 81-42-02, 81-42-03 The inspector reviewed the

licensee's response to the Notice of Violaticn dated November 16, 1981 and

implementation of corrective action and finds them acceptable.

These items

are closed.

(Closed) 327/81-39-01, 81-39-02, 328/81-48-01, 81-48-02, 81-48-03 The

inspector reviewed the licensee's response to the Notice of Violation dated

February 19, 1982 and implementation of corrective action and finds them

acceptable.

These items are closed.

(Closed) 327/81-07-05 The inspector reviewed the licensee's response to

this unresolved issue and determined that the licensee has increased

emphasis on maintenance of in plant telephones used by operations personnel.

The inspector continues to periodically check the operability of telephones

throughout the plant and has not detected any significant problems.

In

addition the licensee has obtained additional hand held two-way radios for

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use by operators in communicating with the control room.

The inspector

discussed the use of radios with various operations personnel and the

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general consensus is that the ability to communicate with the control roaa

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has been significantly improved.

This unresolved item is closed.

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(Closed)

327/81-07-06 The inspector has reviewed the licensee's response

to this unresolved issue and determined that the licensee has clarified the

operators authority to limit access of nonessential people to the control

room. This authority appears to be understood by operations personnel.

The inspector observes access control in the control room on a periodic

basis. Although there have been instances when an excessive number of

people were in the control room this appeared to be due to shif t turnover

and craft personnel attempting to get work authorized.

In general, access

control to the main control room has significantly improved.

This

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unresolved iten is closed.

4.

Unresolved Items

Unresolved items were not identified during this inspection.

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5.

Operational Safety Verification

The inspector toured various areas of tN plant on a routine basis

throughout the reporting period.

The following activities were

reviewed / verified:

a.

Adherence to limiting conditions for operation which were directly

observable from the control room panels.

b.

Control board instrumentation and recorder traces.

c.

Proper control room and shift manning.

d.

The use of approved operating procedures.

e.

Unit operator and shift engineer logs.

f.

General shift operating practices.

g.

Housekeeping practices.

h.

Posting of hold tags, caution tags and temporary alteration tags,

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Personnel, package, and vehicle access control for the plant protected

area.

j.

General shift security practices on post manning, vital area access

control and security force response to alarms.

k.

Surveillance, startup and preoperational testing in progress.

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flaintenance activities in progress.

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Health Physics Practices.

During the reporting period Unit 2 developed significant steam leakage in

the West Main Steam Valve room adjacent to the reacter building.

The steam

leakage did not appear to present an operational problem however the

inspector reviewed the situation to detennine if the excessive steam leakage

was having any adverse impact on safety-related equipment located in the

area. The inspector toured the area, monitored parameters on the main

control panel which are instrumented in the area and questioned various

Unit 2 operators to detennine if they had experienced any loss of cuntrol or

indication of equipment or instrumentation located in the steam valve room.

The inspector did not detect any adverse affect on equipment or instru-

mentation. On February 11, 1982 during a tour outside the Unit 2 reactor

building the inspector noted that portable pumps were in place outside the

West flain Steam Valve Room and were pumping condensate from the steam

leakage out to the yard drainage system.

After questioning various licensee

personnel, the inspector determined that the floor drains in the valve room

had been blanked because the room normally drains to the floor drain

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collecting tank in the auxiliary building which has to be processed as

contaminated waste water.

The licensee detemined that the condensing steam

leakage from the main steam systea was not contaminated and could be

discharged directly to the yard drainage system. They considered nomal

sampling of steam generators and continuous monitoring of steam generator

blowdown for radioactivity adequate monitoring of the water to prevent

uncontrollable discharge of contaminated waste water.

The inspector did not

identify any other potential sources of contaminated leakage in the steam

valve room.

The auxiliary building floor drainage system is described in

the Final Safety Analysis Report (FSAR) and 10 CFR 50.59 requires that

modifications to systems described in the FSAR shall be permitted only after

a documented safety evaluation has been perfomed to determine if the

modification constitutes an unreviewed safety question.

The inspector

considers the blanking of the floor drainage system and redirecting the

water to the yard drainage system a modification requiring a documented

safety evaluation.

In that the licensee did not document their evaluation

prior to modifying the system this constitutes a violation of 10 CFR 50.59

and a Notice of Violation will be issued (328/82-04-02).

The inspector

discussed this matter with Region II management and health physics

specialists who did not object to the licensee's action but did concur that

a safety evaluation should have been perfomed as required by 10 CFR 50.59.

The health physics specialists also recommended that periodic samples be

taken at the point of discharge in addition to the monitoring of the steam

generators for radioactivity.

The licensee was infomed of this and commenced periodic samples of the

waste water and documented their safety evaluation of the modification to

the floor drainage system.

Unit 2 was tripped the same day as part of a

startup test and the steam leakage was repaired.

On February 8,1982 Unit I was restarted after repairs to the damaged

neutral transfomer were completed.

The Unit was taken off the line on

February 9 to inspect a main generator bearing for damage.

During the shut

down a problem was identified with the motor for the #2 Reactor Coolant Pump

(RCP). The unit was cooled down on February 25 to replace the RCP motor and

remains in cold shutdown as of the end of the reporting period.

On February 11, 1982 the inspector observed the calibration of the Unit 2

Axial Flux Difference (AFD) circuitry of power range neutron instrument

N-41.

The calibration was being perfomed in accordance with Technical

Instruction TI-36 and Instrument Maintenance Instruction IMI-99-PR-CAL.

During the calibration, difficulty was encountered in adjusting the

instrument to its full span and the instrument mechanics and the cognizant

engineer determined the problem to be in a potentiometer in the isolation

amplifier. The channel was subsequently repaired and calibrated.

On February 12, 1982, as a result of a construction deficiency report

submitted by another of the licensee's nuclear plants, the inspector

reviewed the potential problem with the Waste Gas System at Sequoyah. The

problem involved a modification to the waste gas vent header radiation

monitoring system which created a potential situation where the waste gas

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decay tank relief valves could be isolated from their relief path to the

shield building exhaust stack. When the inspector verified that the

deficiency existed at Sequoyah he discussed it with the Operations

Superintendent who took prompt action to have the vent isolation valves in

question locked open and caution tagged.

The valves will remain locked open

until a final detennination of the problem can be made by the licensee's

engineering and design group. The inspector had no further questions.

On February 16, 1982 the inspector reviewed the work package of the change

out of the rotating element of the 2AA centrifugal charging pump. The

element was changed out with one for which they had a manufacturer's

developed performance curve (See IE report 328/82-03).

The inspector

reviewed Maintenance Request liR #168088, itaintenance Instruction 111-6.4 and

6.10, Post itaintenance Test SI-40.

The inspector did not note any discre-

pancies.

In addition the inspector compared perfonnance curves for the

replacement rotating element and origiani pump rotating element and agreed

that they compared adequately enough to provide assurance that the pump

could meet technical specification performance requirements. The inspector

had no further questions.

The inspector observed electrical maintenance

personnel trouble shooting Upper Head Injection (UHI) isolation valve

2-FCV-V-87-23.

The valve would not close using the manual control switch in

the main control room. A different closing circuit and solenoid are

involved for closing the value following an accident after the contents of

the accumulator have been injected into the reactor vessel head. The

electricians were using an emergency maintenance request to perform the

trouble shooting and the inspector questioned them to determine if they were

aware of the limitations on the work they could do with a work authorization

which had not had prior quality assurance review and lacked detailed work

instructions. They appeared to be knowledgeable in this area. The problem

with the valve was subsequently traced to a loose connection which was

repai red.

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On February 17, 1982 during a routine tour of the main control room the

inspector noted that individual rod position indication for Unit 2 shut down

control rods did not appear to meet the requirements of technical specifi-

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cation 3.1.3.3 in that two rods in shutdown bank A did not indicate within

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+12 steps of the other rods in the bank. Unit 2 was in mode 3 at approxi-

mately 515 F with the shutdown rods withdrawn. A heatup to normal operating

temperature was in progress. This apparent violation was discussed with the

shift engineer who directed the reactor operator to open the reactor trip

breakers to comply with the action requirements of the technical specifi-

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ca tion.

Subsequent discussion with the operations supervisor about the

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apparent violation revealed that there was considerable confusion regarding

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the requirement of technical specification 3.1.3.3.

On February 18, 1982

the inspectors and the licensee contacted the Office of fluclear Reactor

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Regulation (NRR) and discussed the technical specification with the

licensing project manager and the standard technical specification

specialist. They stated that technical specification 3.1.3.3 requires that

individual rod position indication should indicate within 112 steps of

actual rod position instead of within 112 steps of other rods in the bank in

modes 3, 4 and 5.

Due to the sensitivity of the position indication to

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temperature the indication will only meet the requirement at nomal

operating temperature. The licensee stated that unless at normal operating

temperature they would maintain control rods fully inserted until they

submit and receive approval for a change to technical specification 3.1.3.3.

Based on the interpretation cf f(RR, the licensee has been in violation of

technical specification 3.1.3.3 on both Units at times when shutdown rods

were withdrawn and the plants were not at normal operating temperature. A

notice of violation will be issued against both Units (327/82-04-01,

328/82-04-01).

Region II management was informed of the violation and

related details.

On February 18, 1982 Region 11 concurred with the licensee's plans to

proceed beyond 50% power on Unit 2.

This concurrence was based on periodic

verification of the implementation and effectiveness of the corrective

action outlined in LER SQR0-50-328/81104 as a result of the containment

spray system valve misalignment identified on August 26, 1981.

In addition

the inspector verified implementation of the corrective action stemming from

the violation of the moderator temperature coefficient requirements on

December 21 and 22, 1981.

The licensee committed to have completed

implementation of these actions prior to proceeding beyond 50% power. This

concurrence was documented in a letter to the licensee dated February 18,

1982 from the Region II Administrator.

On February 24,1982 Unit 2 tripped during startup test S/U 9.3 "Large Load

Reduction" from 75% power. The inspector verified that systems operated as

required following the trip and that operators stabilized and maintained the

Unit in accordance with approval procedures.

The flRC was properly notified

per 10 CFR 50.72.

The reactor trip was caused by a turbine trip which

occurred when both main feed pumps (MFP) tripped due to low seal water

pressure during the transient. The licensee checked the adjustment of the

seal water trip setpoints and reported that they were properly adjusted.

In

addition a problem with response of the flFP speed controller was experienced

and the operator took manual control of the pump very early into the

transient. The licensee reported that the speed controller would be

re-calibra ted.

On February 28, 1981 when Unit 2 was restarted the individual rod position

indicator failed on rod it-4 in control bank D.

The Unit was shut down and

had to be cooled down to mode 5 to repair the problem. Unit 2 was restarted

on flarch 3, 1982.

lio other violations or deviations were identified.

6.

Inspection of THI Action Plan Requirements for Unit 2.

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I.C.1

Requirements - Review and revise procedures used for transients and

accidents.

F_indings -Item I.C.1 was previously inspected for Unit 1 and documented in

1&E report 327/80-29. The energency procedures inspected are the same

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procedures used on Unit 2 and no additional inspection is required.

This

item is closed for Unit 2.

I.C.7

Requirements - The licensee shall obtain NSSS vendor review of

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emergency and power ascension test procedures.

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Findings - The inspector previously reviewed documentation from Westinghouse

and the licensee stating that the NSSS vendor had completed review and

comment on the licensee's power ascension test procedures and emergency

operating instructions for Unit 1.

The same procedures are in use for Unit

2 and no additional inspection is required.

This item is closed for Unit 2.

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Requirement - The licensee shall perform low power natural

circulation testing to provide operator training.

Findings - The licensee requested and received permission from the NRC to

delete low power natural circulation testing on Unit 2.

The Unit 2 license

was conditioned to require the licensee to assign an operator with

experience from the Unit i low power test program to each shift on Unit 2

until they reported to the NRC that an acceptable level of operator training

and experience has been attained on Unit 2.

The inspector has verified

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during periodic control room tours that experienced Unit 1 operators are

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assigned to Unit 2.

This item will remain open until the licensee submits a

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report of the level of Unit 2 operator training and experience and receives

NRC approval.

II.E.1.1 Requirement - Perform Auxilliary Feedwater (AFW) System Evaluation

and modify system if necessary.

Findings - The inspector reviewed the summary of the evaluation of

Sequoyah's AFW system presented in Supplement 2 of the Safety Evaluation

Report. The system was found to be acceptable without modification by the

Office of Nuclear Reactor Regulation since it met the guidelines of NUREG 0737, 0694 and 0578. The inspector verified that the system description

presented by the licensee was accurate and witnessed endurance testing of

AFW pumps performed on both units and AFW water hammer testing performed on

Unit 1 as required by license conditions. This iten is closed for both

Units.

II.E.3.1 Requirement - Provide emergency diesel generator backed power

supplies for pressurizer heaters.

Findings - The inspector verified that the pressurizer heaters are supplied

fran the 6900 VAC Shutdown Boards which are backed by the emergency diesel

generators.

This item is closed for Unit 2.

No violations or deviations were identified.

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7.

Unit 2 Startup Testing

The inspectors witnessed the following Unit 2 startup tests:

S/U-9.1 "10% Load Swing Test" (at 30% power)

S/U-8.3 " Static RCCA Drop and RCCA Below Bank Position Measurement"

(at 50% power)

S/U-1.2A " Shutdown From Outside Control Room" (at 50% power)

TVA-23B Feedwater Thermal Expansion" (at 50% power)

S/U-9.3 "Large Load Reduction Test" (at 75% power)

In each instance the inspector verified proper staffing, use of current

approved procedures, initial conditions, hookup and calibration of test

equipment and preliminary test results.

The problems experienced during S/U

9.3 are detailed in section 5.

The inspector periodically reviews S/U 7.1 "NSSS Startup Sequence" to

determine if testing is being properly completed and reviewed and that

prerequisites are met and proper authorization is received prior to

escalating in power.

No violations or deviations were identified.

8.

Independent Inspection Effort

The inspector routinely attended the morning scheduling and staff meetings

during the reporting period.

These meetings provide a daily status report

on the operational and testing activities in progress as well as a

discussion of significant problems or incidents associated with the start-up

testing and operations effort.

Mr. R. D. Martin, the Region II Deputy Administrator and Mr. D. R. Quick,

Chief of Reactor Projects Section 1A toured the Sequoyah facility on

February 25 and 26.

They met with the resident inspectors to discuss

licensee progress toward resolution of regulatory concerns.

Ms. E. G. Adensam, Chief of NRR Licensing Branch 4 and Mr. C. R. Stahle,

Licensing Project Manager for Sequoyah accompanied Messrs. Martin and Quick.

Mr. Martin addressed an assembly of plant supervisors and middle managers on

the topic of Quality Assurance in its broadest sense: quality workmanship

and professional performance.

He also appraised them of the Regional

assessment of the improved performance at Sequoyah.

The plant staff and management gave a presentation to the assembled NRC

representatives regarding the resolution of past problem areas.

The meeting

concluded with NRC noting that Sequoyah was demonstrating good progress in

procedure compliance, increased direct supervision efforts and effective

management corrective actions.

Caution was urged, however, that these

efforts not be relaxed in order that the plant build a long term record of

achievement.

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9.

General Employee Training (GET)

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During this reporting period the inspector monitored general employee

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classes in the areas of " Adverse Conditions and Corrective Actions",

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" Initiation and Processing of Work Requests", " Clearance Procedures", and

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" Temporary Conditions".

The presentations were appropriate to the subject

matter and proctoring was observed at all sessions attended by the

inspector. This topic was the subject of a Notice of Violation

(327/81-42-02,328/81-52-03) in the report period ending January 5,1982.

This item has received timely and adequate management attention and

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corrective actions appear to have a permanent effect. This area will

continue to be monitored by the inspector. However, due to the present

conduct of the GET program, the inspector considers this item to be closed

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(327/81-42-02,328/81-52-03).

No violations or deviations were noted.

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