ML20062J673
| ML20062J673 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 08/09/1982 |
| From: | Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Parris H TENNESSEE VALLEY AUTHORITY |
| Shared Package | |
| ML20062J676 | List: |
| References | |
| NUDOCS 8208160436 | |
| Download: ML20062J673 (4) | |
See also: IR 05000327/1982005
Text
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N 0 9 1982
Tennessee Valley Authority
ATTN: Mr. H. G. Parris
Manager of Power
500A Chestnut Street Tower II
Chattanooga, TN 37401
Gentlemen:
Subject: Report No
7/8
and 50-328/82-05
This is response to your letters dated June 1 and 25,1982 in which you discussed
certain violations brought to your attention in the Notice of Violation with our
letter of April 20, 1982.
Your actions to correct Violation A and to prevent its recurrence will be
examined during future inspections of your program.
Your denials of Violations B and C have been evaluated by our staff as shown in.
the enclosure to this letter.
For the reasons presented in the enclosure, we
have concluded that Violation B should be withdrawn and designated an unresolved
item pending further NRC inspection.
However, we have also concluded that
Violation C is valid as stated in the Notice of Violation enclosed with our
letter of April 20, 1982. Therefore, as required by 10 CFR 2.201, please submit
to this office, within twenty days of the date of this letter, a written response
including corrective steps which have been taken for Violation C, corrective
steps which will be taken to avoid further violations, and the date when full
compliance will be achieved.
In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosure will
be placed in the NRC Public Document Room.
The response directed by this letter is not subject to the clearance procedures
of the Office of Management and Budget as required by the Paperwork Reduction Act
of 1980, PL 96-511.
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Should you have any questions concerning this letter, we will be glad to discuss
them with you.
Sincerely,
Richard C. Lewis, Director
Division of Project and
,
Resident Programs
Enclosure:
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(See Page 2)
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8208160436 820809
PDR ADOCK 05000327
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Tennessee Valley Authority
AUG 0 9 1982
2
Enclosure:
Evaluation
of Licensee Response
cc w/ enc 1:
H. J. Green, Director of
Nuclear Power
G. G. Stack. Project Manager
C. C. Mason, Plant Superintendent
J. F. Cox, Supervisor, Nuclear
Licensing Section
M. J. Burzynski, Project Engineer
H. N. Culver, Chief Nuclear
Safety Review Staf f
bcc w/o enc 1:
NRC Resident Inspector
Document Management Branch
State of Tennessee
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Enclosure
Evaluation of Licensee Response
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1.
The licensee denied Item B of the Notice of Violation which stated that
retraining had never been conducted and provided evidence to support the
contention that such training had been conducted.
In retrospect, Region II
believes that the citation was not clearly articulated and thus implied a
,
scope beyond what was intended.
Specifically, the violation related to
substantive changes which had been made in the quality assurance program
through Revision 4 to the approved program (TVA-TR75-1A) which affect the
following General Employee Training (GET) segments:
The course objective of GET 4 is to familiarize personnel with the
a.
purpose and meaning of QA/QC, the TVA organizations having QA/QC
responsibility, and the objectives and methods of implementing the
total QA program.
Revision 4 to TVA-TR75-1A modified existing
,
responsibilities
and
added
new
responsibilities
for program
implementation.
b.
The course objective of GET 5.1 is to familiarize personnel with
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requirements for preparation, review, approval, distribution, and
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,
revision of plant documents.
Revision 4 modified various respon-
sibilities and controls regarding procedures,
instructions, and
drawings.
t
c.
The objective of GET 14.1 is to familiarize personnel with the
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procurement of materials, components, and spare parts and with
preparation of purchase requests. Revision 4 modified responsibilities
for the determination of type and extent of supplier evaluations, for
inspection and surveillance at vendor facilities, and for receipt
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inspections.
It should also be noted that procedure AI-14 which implements Section 17.2.2
,
of the approved QA program requires the assistant plant manager to evaluate
,
the GET program annually and recommend any required retraining.
The
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documents provided by the licensee in their response indicates that the most
recent evaluation of the GET program performed by the Assistant Plant
Manager was conducted in November 1980 and that evaluation did not appear to
address retraining.
L
Notwithstanding the above, and in view of both the ambiguity of the
violation and the information submitted by the licensee regarding other
segments of the GET retraining program, we conclude that the violation
should be withdrawn and designated an unresolved item pending further NRC
'
inspection in this area.
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DB 0 9 C82
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Enclosure
2
2.
The licensee denied Item C of the Notice of Violation stating that they
,
believed their program which includes training of engineers and general
,
foremen in the QA requirements and the instruction of temporary employees to
always follow appropriate procedures when performing quality-related work
'
ensures compliance with the intent of 10 CFR 50, /ppendix B, Criterion II.
,
The licensee further stated that temporary craftsmen are trained to follow
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procedures and the quality-related work they do is performed in accordance
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with written approved procedures or instructions containing appropr"te
quality control holdpoints for inspection.
Finally, the licensee stated
,
that the cognizant engineer reviews the completed work to ensure that all
required inspections and holdpoints have been observed and completed.
With regard to the assertion that temporary employees work under the
supervision of engineers and general foremen who have been trained in QA
requirements, it should be noted that the inspection disclosed that two of
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six outage foremen and nine engineers and supervisors in the outage group
had received some, but not all, of the training specified in administrative
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instruction AI-14.
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The licensee has established an excellent training program for permanent
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craftsmen at the Sequoyah site to ensure their knowledge of the
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adminisrative, quality, and safety aspects of their assigned position. In
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that outage craftsmen perform essentially the same function as permanently
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assigned craftsmen, it is appropriate and necessary that they receive the
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same training. The latest industry standard on this subject, ANS 3.1-1981
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supports the position that temporary employees must be trained in all areas
where their activities could affect the quality of an operating nuclear
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power plant.
Moreover, Procedure N79A7, Nuclear Plant General Employee
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Training Program, in the Division of Nuclear Power Procedures Manual
specifically includes temporary and field services personnel in the training
program.
Finally, tne licensee's contention that outage craftsmen are instructed to
'
follow procedures which contain appropriate instructions and holdpoints for
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inspection and that their work is inspected and reviewed, is not persuasive.
The same is true of permanently assigned craftsmen and the licensee has not
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argued, nor would the NRC accept, that such limited training would satisfy
the intens of Criterion II of 10 CFR 50 Appendix B.
Likewise, the NRC does
not accept the premise that quality can be inspectea or audited into the
work; the primary responsibility for quality must be placed on the
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individual performing the activity af fecting quality and that individual
must be trained to carry out that responsibility.
Therefore, we conclude that the violation is valid as written in the Notice
of Violation.
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