ML20062J714

Responds to NRC 820610 Telcon Request Re IE Insp Repts 50-327/82-05 & 50-328/82-05.Info Supports Denial of Items B & C

ML20062J714
Person / Time
Site:	Sequoyah
Issue date:	06/25/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20062J676	List: IR 05000327/1982005 ML20062J673 ML20062J714 ML20062J780 ML20062J839 ML20062J885
References
NUDOCS 8208160447
Download: ML20062J714 (32)

Text

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TENNESSEE VALLEY AUTHORITY CH AT TANOOG A, YENN ESSEE 37 401 400 Chestnut Street Tower II June 25, 1982 U.S. Nuclear Regulatory Commission $ ]c Region II c - 0; Attn: Mr. James P. O'Reilly, Regional Administ ator 5 y 101 Marietta Street, Suite 3100 m _4 o Atlanta, Oeorgia 30303

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Dear Mr. O'Reilly:

)

SEQUOYAH NUCLEAR PLANT UNITS 1 AND 2 - NRC-0IE REGION II INSPECTION REPJtT 1_

50-327/82-05 AND 50-328/82 RESPONSE TO VIOLATION o E In accordance with a telephone request from your staff on June 10, 1982, ,,

enclosed is additional information in support of TVA's denial of items -

B and C of the subject OIE Inspection Report.

If you have any questions, please get in touch with R. H. Shell at FTS 858-2688.

Very truly yours, TENNESSEE VALLEY AUTHORITY

. M. Mills, Manager Nuclear Licensing Enclosure ec: Mr. Richard C. DeYoung, Director (Enclosure)

Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission l Washington, DC 20555 i

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8208160447 820809 PDR ADOCK 05000327 O PDR An Equal Opportunity Employu l

J ENCLOSURE SEQUOYAH NUCLEAR PLANT - REQUEST FOR ADDITIONAL INFORMATION CONCERNING NRC-0IE REGION II INSPECTION REPORT NOS. 50-327/82-05 AND 50-328/82-05 Per our phone conversation of June 10, 1982, regarding our responses to items B and C from the referenced inspection report, the attached and below listed additional information is being provided~f6r~your~ ~ '

consideration.

Item B Attached you will find several examples of the annual letter indicating the review and status of the General Employee Training (CET) program.

While this letter addresses the subject in general terms, the review includes GET retraining.

Additional reviews are conducted by the instructors each time they prepare to teach a class. The instructors have detailed knowledge of both the applicable procedures and corresponding GET course. This review is required by AI-14 (pages attached) and documented if the review results in the need for CET retraining.

When significant revisions occur to procedures that affect GET training, CET retraining is initiated. Revisions not affecting CET training are communicated to plant workers in a number of ways. For instance, a worker performing work on safety-related-systems does so with the aid of up-to-date procedures and is, therefore, aware of the current revision.

This is evidenced in part by our SQNP AI-19 (pages attached) which deals with plant modifications. . It states, in part, "All modifications will be worked in the field by way of a workplan as described in this procedure. Work shall not begin until the workplan has been reviewed and approved (PORC if required) except in emergencies, when an AI-9 TACF can be used." A workplan is therein dcscribed as "A detailed written procedure by which work is planned, approved, and performed.

All modifications and construction completion work is performed according to an approved work plan. A work plan basically consists of written work instructions, copies of the implementing documents, design drawings, and tests or inspections to verify satisfactory completion of the work."

t In SQNP AI-21 (attached) there is a similar statement which says "DPS0 personnel at Sequoyah Nuclear Plant shall comply with the instructions in the DPS0 Procedure Manual and requirements of Sequoyah Standard ,

Practice manuals and Administrative Instructions that apply to DPSO work."

Our inspection program is covered by similar requirements. For instance, in SQNP AI-20, it is stated that "All inspection of activities that affect CSSC shall be performed in accordance with approved instructions."

The above are representative of statements which appear in various section and plant instruction letters.

t Other mechanisms for communicating revisions to plant procedures and revisions to section instruction letters are demonstrated by the following representative samples. The attached SNP ASIL-9 is the formal procedure used by our Health Physics Section. Other sections use less formal routing. For instance, Attachment A is employed by the Instrument Maintenance Section, while the short, less formal, routing slips (attached) are used by our Mechanical Maintenance ,

Section for the same purpose.

On-the-job training, another way in which Sequoyah personnel are made ,

aware of instruction revisions, of ten takes the form of a foreman explaining or pointing out to a craf tsman any changes to procedures before or as part of his assignment of the craf tsman to a given work task. This on-the-job training is not documented. However, such a degree of detail is seldom covered in GET courses. Therefore, retraining in GET would be less effective than on-the-job training in this case.

We believe the above information which was not communicated at the time of the audit shows that Sequoyah personnel are being kept abreast of revisions to procedures which affect their job performance and that reviews are accomplished to determine if GET retraining is warranted when procedure revisions occur.

Item C We have further reviewed 10 CFR 50, appendix B,11 which states in part, "The program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to ensure that suitable proficiency is achieved and maintained." We believe that our program which includes the 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 the above 10 CFR 50, appendix B statement.

AMC:KC Attachments 6/22/82

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, . ,,7sios.v.m y . UNITED STATES GOVERN 3!ENT

' Memorandum TENNESSEE VALLEY AUTHORITY OTo .

J. M. McCriff, Assistant Power Plant Superintendent (Health and Safety),

Sequoyah Nuclear Plant rno33 Larry W. Smith, Training Officer, Sequoyah Nuclear Plant DATE  : April 15, 1982 SUIUECT: CENERAL EMPLOYEE TRAINING PROGRAM A complete audit of the status of the plant training program as of December 1981 has been completed. This audit revealed several areas of deficiency with the training program and, as a result, program modifica-tions have been implemented which will resolve these deficiencies as follows:

1. Certain sections onsite had no mechanism in effect to notify the Training Office of status changes for their personnel so that training requirements could be reviewed. SQA-80 and AI-14 have been revised to correct this. ,

2.

A review of AI-14 disclosed certain items which had not been updated to comply with changes in DPM No. N79A7. These changes have since been implemented by a revision to AI-14.

O 3- s =e 91 t ectie ere 1===1 files though the Training Officer was charged with the responsi-i=8 their ~= 11 1a tr 1=i=8 bility for these files. This was corrected by a revision to .

M p.d. AI-14 which gave the responsibility to these sections.

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The various sections were found to have an average percent of completion of 87,57 per cent for all ,GET courses. A breakdown of these figures by sections is attached.

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, L ry W. Smith

LWS

BHE Attachments

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This was principally prepared by Larry W. Smith.

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, , NIttten STATES GOVERNMENT Memorandum TENNESSEE VALLEY AUTHORITY

s /7s iv To .

J. M. McGriff, Assistant Plant Manager (Health and Safety)

FROM  :

T. O. Frizzell, Training Officer DATE February 20, 1981

SUBJECT:

GENERAL EMPLOYEE TRAINING PROGRAM A complete audit of the status of the plant training program was completed in December,1980. This audit revealed several areas of deficiency with the training system and as a result, major program modifications have been implemented which will resolve those deficiencies. The modifications, which include the development of an entire new training program concept, are summarized as follows.

l. The training requirements for every position at SNP has been reviewed for compliance with controlling documents. The necessary changes have been implemented by AI-14 revision 10.

2. The previous training program deligated to the individual section supervisors the respensibility of administering the required GET training and retraining to his section personnel.

, This required all plant sections to have training outlines

{d on each of the GET courses that pertained to the section employees. As verified by training records, most sections were negligent in conducting Eroup training sessions due to

., .~ ~ ' jf4j,.h, .y .the plant work load or a failure to adequately analyze the

- W m %,m vsection personnel's training needs. This problem has been 7 .ggm f ~ resolved by the initiation of a new program which assigned h x ,, to specific sections the requirement of presenting to all SNP personnel the GET course which is most closely related to the assigned section's primary area of responsibility. A routine schedule of presentations has been developed which will give all section supervisors the opportunity of having their l section personnel trained in a timely manner.

l 3 No time limit was established for the co=pletion of GET training.

AI-14 revision 10, now stipulates that all plant employees must complete the required GET training within six months after assignment to SNP. The newly developed routine schedule l of GET course presentations was based on this six month time l limit.

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4. A problem existed in the timely establishment of training records for new plant personnel and the requesting of training records from the permanent duty station of temporary personnel.

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," . 2 J. M. McGriff, Assistant Plant Manager (Health and Safety)

February 20, 1981 GENERAL EMPLOYEE TRAINING PROGRAM '

By March 31, 1981, the training records of plant personnel which are currently maintained by the plant's Master Files, will be relocated to the training office. A check-in procedure which routes all new and temporary personnel through the training office will allow the immediate establish-ment of training files.

5. The current computer system, " TRAIN", which is utilized to document the training status of plant personnel, is in the i process of being completely redeveloped so that it can more adequately process personnel training information. The current system requires the processing of key punched cards which results in an approximate 2 week lag from time of training to time of documentation. The new system will allow the updating of training records through a computer terminal.

This elicates the errors associated by incorrectly punched cards, and allows the immediate., processing of training data.

The 'new system will also enable the training office to acquire computer printouts of personnel who are required to attend a particular course of instruction. The current program q just yields a printout listing the employees current training status.

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6. The training information associated with each GET course E e has been presented. completely reviewed to ensure up-to-date insturctions MC~I ~are being Each GET course now has an approved U

.my .

N" Y*]tiaining outline with audio-visual aides and a written exam-

' ination which must be successfully completed by each class attendee.

b 7. AI-14, " Plant Training Program", has been completely revised to implement the above dictated program changes and to include all recently established sections and positions under the Training requirements portion of the document.

8.

The GET training classes GET-1, " Industrial Safety Orientation",

and GET-4, " Introduction to Quality Assurance / Quality Control",

were previously scheduled for presentation when requested by a plant section supervisor. These two classes are now presented on a weekly basis as are GET-2, " Health Physics Orientation" and GET-3, " Plant Security and E=ergency Plans".

Since, January, 1981, a major portion of this new plant training concept has been utilized at SNP. Following are the statistics on the GET courses which have been presented since the new rotating schedule of classes was implemented. Each of the listed classes were presented at q

V 1 east ten times during a one week period. Two of those classes were scheduded at 7:00 AM for night shift personnel, and two classes were ,

conducted at 4:00 PM for evening shift personnel.

o 4

N dGES OF SNP' -

SICTICW 2IRSOEEL ATTriDr;G LISTHD COUREES JANUARY 1,1981 TO FZ3RUARY 20,'1981 4

GET GET GET SECTION 5.1 & 5.2 6 8 Averare Adninistrative 74 42 100 72

Health Physics 8h 95 83 88 Public Safety 89 73 100 88 .

Modification Store -

_ Room 60 100 80 Safety Enzineering 100 100 100 100 Instrumentation Maintenance 92 i' l 75 97 88 Ocerations 60 100 100 i 87 i

( Power Stores

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Plant Services 100 100 84 pf, e,. ,.,3 3 os NN5'M 'Results 86 77 100 88 L Medical h2 60 N/A 51 I l Staff 50 75 50 so l

DPSO 80 100 100 og Outare h2 *+

53 h8*

Electrical Maintenance 100 100 i 50 8h l

Mechanical Maintenance 60 70 'i 64 65 Quality Assurance 100 100  !

75 92 L Management Srvs.  !

,, 100 100 loo too  ;

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, **, Outage Personnel did not attend

" this class due to the recent increase of their work loads. [

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. .% b J. M. McGriff, Assistant Plant Manager (Health and Safety)

February 20, 1981 GL'ZRAL DiPLOYEE TRAINING FROGRAM

, A total of 301 people attended the GET 5 1 and 5 2 presentations.

e Ten (10) classes were offered during the week of February 2 through February 6, 1981.

GET 8 was presented for the week of February 9 through 13, 1981.

Twelve (12) classes were taught. Three hundred and forty-four (3% )

enployees att-: d this course.

The GET 6 presentations had 288' attendants. Eight (8) classes were held for this course. They were given during the week of February 17 through 20, 1981. At the tine of this report, one class is being

• taught. The personnel in this class are not included in the 288 or in the figures on the chart.

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t*NiTyd STATES GOVERN 31ENT , ,.i N6m07dndMM TENNESSEE VALLEY AUTHORITY To Jere M. Ballentine, Plant Manager, Sequoyah Nuclear Plant t I

' ' fro.TI J. R. Bynum, Assistant Plant Manager (Health & Safety), Sequoyah Nuclear Plant DATE Nove=ber ik, 1980 St*RJ ECT: PLANT TRAINING PROGRAM I have recently completed a through review of the current status of the plant General Employee Training (CET) program. In conducting this review, major emphasis was placed in examining record keeping techniques, administrative procedures, compliance with controlling documents, and in general, the overall effectiveness of our program.

For the most part, I am pleased with the foundation and recent progress made in the area of training but the program's effectiveness can be tremendously improved by your consideration and imple=entation of several basic program changes.

Presently, Administrative Instruction number lh delegates to the individual section supervisor the respon*Jbility of administering the general employee training to his section personnel. Due to the continuing work load within all the sections, and the present influx of personnel, the sections are unable to keep up with the GET training.

To successfully accomplish AI-14 requirements, it would take a person in each section assigned at least 50fo of the time to training within

('"3 that section. I have also discovered that many times the individual

\_/ assigned the task of instructing is neither qualified or prepared to q _.a , -adequately present the training =aterial. Since by definition e =6 * ; (pra'iningmeansnothing=orethanputtingacrossideasorinfor=ation,

(_,,e ggf.lfi: instructing, educating, indoctrinating and advising, it all adds up to nothing if the e=ployee fails' to get the idea. If training is to

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be accomplished efficiently, effectively and with a minimum' of disruption  ;

ye.;;_ _-m us_to normal operations, all training responsibilitias must be centralized

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" ' t'o one office or individual. ~ ,

l The consensus opinion of the section supervisors and the plant training l officer is that a definite need for a permanent GET instructor at Sequoyah exists. I am in co=plete agreement with this proposal and strongly recommend the establishment of a training instructor position at the SE-5 level under the supervison of the plant training officer.

. This individual would have the responsibility to prepare and teach the Gener<1 Employee Training as well as prepare course outlines, quizzes, keep abreast of changes in instructions and lecture to composite groups made up of all sections. This would accomplish three main goals.

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r" 2 Jere M. Ballentine

/' November 14, 1980

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PIMT TRAINING PROGRAM

1. It would assure standardized training is being presented to all plant employees.

2. It would relieve the section supervisors of GET training

. responsibilities and allow them to concentrate more on their section functions.

3 It would vastly improve the quality of training conducted at Sequoyah.

In order to accomplish the task of training individuals in a timely manner, which is one of the obvious failures of the current system, a method must be developed to require the plant employees to attend scheduled training sessions. The method I recommend is to extend the current one day plant orientation training session into a two day period. ' Ibis two day orientation class would consist of the GET training required for all plant employees as stipulated by DR4 No.

N7987. The completion of this orientatio"n should be required prior to the issuance of an unescorted access status at Sequoyah. On day one of the orientation the industrial safety, public safety and health physics classes would be completed. On day two, the quality

. assurance, system of plant instructions, document control, and work request classes would be taken. As previously stated, these courses

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., must be presented to all permanent and temporary personnel at this

" " ' W.",[ plant. The re=ainder of the GET courses, which are position specific, culd be presented on a routine, weekly or monthly basis.

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. Finally, the position training ' requirement mu'st be' streamlined to the

=inimum requirements dictated by the controlling DR4. Almost every position covered by AI-14 lists mandatory training which is not considered by the section supervisors to be benificial to their ,

employees. If attendance to a particular class has not been made co=pulsory by the DR4, we should delete it as a requirement.

Training is no longer just a meeting in a classroom or a few words between an instructor and a new e=ployee. It's a full-fledge part of personnel management. With today's emphasis on well trai^ned workers, training costs are necessarily a substantial item in the budgets of all nuclear power facilities. The additional costs of establishing a permanent instructor and making the suggested modifications to the training program will pay off in the form of more efficient employees at Sequoyah.

J6seph R. Bynum(/

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cc: Charles 1.~ Holt, 1670 CST-2C

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• SQNP AI-14 Page 7 of 161 Rev. 14 r-1 A. 3. SCOPE (Continued)

The overall program shall be comprised of preplanned classroom sessions supplemented by on-the-job training in the areas in which the GET relates to some specific job task. Employees shall be evaluated for comprehension of the material presented by the, completion of a written examination. The passing grade on this examination shall be 70%. Failure to demonstrate satisfactory

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proficiency shal result in additional instruction.

u When the number of section employees needing a specific course is -

less than five, the section supervisor may arrange for the emphyee to read the material related to the course. The employee must then be given a written exam by the Training Officer and shall make a

[ grade of 807, before being given credit for completion of the cc:Irse.

• i If an unsatisfactory grade is recorded the employee shall be required to attend a scheduled class on the subject matter.

. The plant GET program as outlined by this section shall be reviewed L

at least annually for completeness by the plant Training Officer.

Temporary personnel who have not received required GET training must work with an employee who has received GET training in the area 4 , . . ~ *-

related to the specific duties of the temporary personnel.

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The General Employee Training Program, which is coordinated by the

plant Training Officer, shall comply with the requirements estelished by DPM N79A7.

l The section supervisors listed in Part I, Section D, shall be i - responsible for the contents of the assigned GET training packe:s and the routine presentation of these packets to all required plant l employees. A schedule of classes, based on plant needs, shall ':e l _

developed by the Training Officer and must be of such a frequen:y as to allow all new plant employees the opportunity to complete the required training within the six month time limit.

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s SQNP AI-14 Page 8 of 161 Rev. 14

5. RESPONSIBILITIES Continued 1

After receiving notification from the training office of a scheduled

- presentation, the sections designated instructor shall comply with the following requirements:

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a. Review all instructions and related material comensurate with the scheduled GET course as well as the entire contents of the L

courses training packet.

b. Prepare a presentation with content commensurate with the f ab -

duties of the personnel to attend.

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c. Submit the written examination to all class attendees and

[ determine which individuals have successfully completed the program of instruction.

d. Hand-out a FEEDBACK SYSTEM form (Appendix E) to all person el attending the class. Explain the purpose of the form and instruct the personnel to send it directly to the plant Training Officer.

e. Forward the class attendance roster and any failed examica: ions

..,to the training office.

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An individual GET training record shall be maintained in the caster j' "'" '

computer printout " TRAIN". Upon completion of all required GET L . . ,. 3,:

• courses (except GET 1, 2, and 3) a TVA form 1453 will be issued documenting completion. When individuals satisfactorily comple:e a j GET training course, the attendance sheet will be completed with all I, pertinent data and forwarded to the Training Of ficer for doc-umentation and the information will be placed on TRAIN. If an individual is transferred prior to completion of the required c:urses, ' '

a TVA form 1453 will be completed and placed in the individual's field training file with only those completed courses showing.

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7. TRAIN CODE The appropriate " TRAIN" codes for the GET classes as well as a j listing of class topics, objectives and contents are provided in t_ the following table:

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