ML20064D254

Responds to NRC Re Violations Noted in IE Insp Repts 50-259/82-27,50-260/82-27 & 50-296/82-27.Corrective Actions:General Employee Training Program & Std Practice Bf 4.5 Revised 821001.Retraining Will Be Completed by 830131

ML20064D254
Person / Time
Site:	Browns Ferry
Issue date:	11/15/1982
From:	Mills L TENNESSEE VALLEY AUTHORITY
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20064D224	List: ML20064D254
References
NUDOCS 8301040603
Download: ML20064D254 (9)

Text

,_ _

l . ,

e TENNESSEE VALLEY AUTHORIT,Yw P.Fd- ,

CH ATT A NGOG A. TENNESSEE 374o'1 -

400 Chestnut Street Tower II oo NOV 19 AB 2*

November 15, 1982' U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303

Dear Mr. O'Reilly:

Enclosed is our response to R. C. Lewis' September 29, 1982 letter to H. G. Parris transmitting Inspection Report Nos. 50-259/82-27,

-260/82-27, -296/82-27 regarding activities at our Browns Ferry Nuclear Plant which appeared to have been in violation of NRC regulations. We have enclosed our response to Appendix A, Notice of Violation.

The GET program and the implementing Standard Practice BF 4.5 were completely revised on October 1, 1982. The revision included the standardization of the GET program, realignment of program requirements and condensing content into six courses, realignment of responsibilities for sections charged with instructional duties, and establishment of administrative controls regarding classroom attendance. In addition, the revised program requires all persons to demonstrate comprehension by satisfactorily passing a written examination for each subject area.

Standardized training modules for each GET course have been prepared.

Personnel assigned to Browns Ferry are being retrained on all required GET courses. To date, approximately 35 percent of assigned plant employees and approximately 17 percent of field services employees have been trained. All persons will be retrained by January 31, 1983 A 17-day extension was discussed with and granted by OIE-NRC Inspector Ross Butcher on October 25, 1982. If you have any questions, please call Jim Domer at FTS 858-2725.

To the best of my knowledge, I declare the statements contained herein i are complete and true.

Very truly yours, TENNESSEE VALLEY AUTHORITY l

M L. M. Mills, Kanager Nuclear Licensing l

8301040603 821202 PDR ADOCK 05000259 0 PDR

• O ENCLOSURE RESPONSE TO NRC INSPECTION REPORT NOS.

50-259/82-27, -260/82-27, -296/82-27 R. C. LEWIS' LETTER TO H. G. PARRIS DATED SEPTEMBER 29, 1982 Appendix A Item A - (259, 260, 296/82-27-03) 10 CFR 50, Appendix B Criterion XVIII requires that a comprehensive system of planned and periodic audits be carried out to verify compliance with all aspects of the quality assurance program. Table 17.2-5 of the accepted QA Program endorses the requirements of ANSI N45.2.12, Draft 3, Revision 4 - February 1974, for auditing of quality assurance programs.

Section 4 3 2 3 of this Standard requires that selected elements of the program be audited to the depth necessary to determine whether or not they are being implemented ef fectively. The accepted QA Program, TVA-TR75-1A Revision 5, Section 17.2.18 states that audits shall be conducted to ensure compliance with training requirements.

Contrary to the above, the training program was not audited to the depth necessary to determine whether or not the program is being implemented effectively in that Audit OPQAA-CH-82TS-01 dated April 12 - May 7,1982, identified only one failure to follow training program procedural requirements when in fact multiple failures existed as identified in Violation B below. This audit stated in the overall assessment section that implementation of the general employee training program was inadequate; however, this was not identified as a finding and as a result the audited organization did not take any action to correct this inadequacy.

This is a Severity IV Violation (Supplement I).

1. Admission or Denial of the Alleged Violation TVA admits the violation.

2. Reasons for the Violation if Admitted Due to workload requirements there was inadequate manpower assigned to the portion of the training audit conducted at Browns Ferry. The scope of the audit included five separate topics. We do not attempt to verify all aspects of a specific area in each scheduled audit.

The objective is to selectively include certain aspects in a particular audit with other aspects to be covered in subsequent audits so that the entire range is covered over a reasonable length of time.

3 Corrective Steps Which Have Been Taken and Results Achieved The need for additional manpower in the Operations Quality Assurance Branch has bcen identified by TVA management responsible for this function. TVA is reorganizing its overall quality assurance program and has already increased the manpower of the Operations Quality Assurance Branch. Upon completion of preliminary training and qualification, this manpower will be available for auditing.

4. Corrective Steps Which Will Be Taken to Avoid Further Violations

a. Manpower sufficient to perforia required audits to the depth necessary will be assigned on future audits.

b. A training audit of the depth necessary will be performed by April 30, 1983

5. Date When Full Compliance Will Be Achieved Full compliance will be achieved on the completion of the training audit April 30, 1983.

Appendix A item n - (259, 260, 204/82-27-01) 10 CFR 50, Appnndix B Criterion V and Section 17.2.5 of the necepted OA Program requires that activities affecting ouality shall be prescribed in procedures and shall he accomplished in accordance with those procedures.

Activities affecting quality were not accomplished in accordance with procedures in that:

1. Standard Practice BF 4.5, Plant General Employee Training Program, dated June 23, 1982, requires that personnel who do not receive retraining have their unescorted access badges pulled. This requirement was instituted as a result of a violation identified in IE Reports 50-259, 260, 296/81-02 dated March 18, 1981. This violation identified that all personnel had not received required general employee. training.

Contrary to tbc nbove, a review of training records of site personnel indicates grenter than 10 percent of these people have not received all required training and have not had their unescorted access badges pulled. This is similar to the violation identified in IE Reports 50-259, 260, 296/81-02.

2. Standard Practice BF 4.5 requires that the outage organization train all outage annual personnel.

Contrary to the atove, of 147 outage annual persornel training records reviewed, a total of 106 of these people had not received all required F.eneral employee training. These records included 13 out of a total 21 general foremen that had not received QA/QC indoctrination or training.

?. Operational quality Assurance Manual (00AM) Part III, Section 6.1, l felection and Training of Personnel of Nuclenc Power Plants, dated June 15, 1981, paragraph 1.9.1 recuires a continuing progrem for training of replacement personnel and for retreining necessary to ensure that personnel remain proficient.

9 Contrary to the above, there are no plant procedural requirements to assure proficiency is maintained in areas of OA/CC indoctrination, standard practices and plant instructions, document control and authorization of work performance, temporary conditions, plant modificationn, and procurement and material control. Petraining is not being provided in these subjects and a method has not been established to determine that proficiency is being maintained in these arens as required by the 00AM.

4. 00AM Part III, Section 6.1 paragraph 1.5.1 requires that training programs be kept up to date to reflect plant modifications and changes to procedures.

Contrary to the above, plant procedural requirements do not specify that the training department receive information on plant modifications oa changes to procedures.

This is a Severity Level IV Violation (Supplement I). The examoles cited above are not all inclusive.

P-1

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. _ Reasons for the Violation if Admitted Prowns Ferry Standard Practice 4.5 governing general employee training (GET) at the time of the audit was inadequate with regards to delegating and implementing responsibilities and requirements.

3. Corrective Steps Fhich Itave noen Taken and the Results Achieved The Drowns Ferry GET progran and Standard Practice BF 4.9 were revised on October 1, 1982 to improve the GET program. This included:

standardization of the program, realigning the program to six courses, obtainine training nodules from the Muclear Training Branch, realigning responsibilities for sections charged with instructional duties, and establishment of administrative controls regarding classroom i attendance. Standard Practice BF 4.R, as revised, still contains I

requirements regarding removing unescorted access status. This will be rigidly enforced after all individuals have had the opportunity to attend required revised training.

4 Corrective Steos Which Will Be Taken To Avoid Further Violations All Browns Ferry personnel (with the exception of operations personnel) are being scheduled by their respective section supervisors to attend required classes in the revised GET program. Operations personnel will receive their GET training along with their scheduled annual retraining.

5. Date Vhen Full Compliance Will Be Achieved Full compliance will be achieved by January 31,19R3 when all currently assigned plant emplovees (except operations personnel) should have received all required GFT training.

Full compliance for operations personnel will he nchieved by December $1}~'

1983 when all annual retraining is complete. Considering the'

~

training and c perience of these personnel, we believe this is an acceptable date.

D-2

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted Browns Ferry Standard Practice 4.5 governing GET at time of audit was inadequate with regard to implementing program responsibilities and requirements.

3. Corrective Steps Which Have Been Taken nnd the Results Achieved The GFT program han heen revised nn stated in Item B-1. All field l' services personnel will be trained on required GET courses. GET classes have been scheduled for each k'onday, Wednesday, and Friday starting on October 8,1982 to accomplish this.

4 Corrective Steps Which Will Be Taken To Avoid Further Violations All field services personnel will be given required revised training.

A Browns Ferry forn BF-54, Individual Training Record, will be maintained to ensure training is accomplished by each individual within

, the prescribed time linits.

1

A 4

5. Date When Full Compliance Will 9e Achieved Full compliance vill be achieved by January 31, 1083 when all currently assigned field services personnel should complete the required revised training.

4 B-3

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for the Violation if Admitted

At the time of the audit, Browns Ferry Standard Practice 4.5, regarding j training, did not recuire retraining in all areas.

i I Correctivo Steps Which Pave Been Taken and the Results Achieved 3

The GET program and Standard Practice 4.5 were revised on October 1, 100?, to require retraining and testing in all GET areas.

4 Corrective Stens Which Will Be Taken To Avoid Further Violations l All assirned personnel (with the exception of operations personnel) are i currently being retrained in the required areas and must demonstrate satisfactory proficiency on a written eyamination. Operations personnel vill reserve their GET training along with their scheduled l annual retraining.

5. Date When Full Compliance Will Be Achinved

Full conpliance will he achieved by January 31, 1983 when all plant

! personne] (except operations personnel) currently assigned will he retrained.

Full _ compliance .for . operations _ p.ersonnel will be achieved by _Decemh.er_$Y,_,

1983 when all annual retraining is complete. Considering the ~

training and experience of these personnel, we S~elieve this is an

~

! acceptable date.

i 1

i i

l l

1 e

i

B4

1. Admission or Denial of the A11eaed Violation TVA denies this portion of the violation occurred as stated. The training office does in fact receive plant memorandums and reading lists of revised standard practices and procedures that could have a bearing on the content of CET course material. However, Standard Practice BF 4.5 was revised October 1,1982 to assign responsibility to the designated sections for GET course presentations for receiving changes to plant equipment, layout, procedures, instructions, and implementation of changes as needed to the GET courses.

Item C (259, 260, 296/82-27-02) 10 CF9 50, Appendix B Criterion II and the accepted OA Program, Section 17.2.2, require a training and indoctrination program to assure that oersonnel responsible for performing qualitv-affecting activities are instructed as to the purpose, scope, and inplementation of the quality assurance program.

i Contrary to the above, a training and indoctrination program has not been provided to assure that all personnel responsible for performing quality-affecting activities are instructed as to the purpose, scope, and implementation of the quality assurance program in that:

1. There are no requirements to train temporary outage craftsmen in the OA program requirements.

2. The training program described in Standard Practice 4.5 allows a period of six nonths to corolete all required general enployee training;

, however, reasures have been provided to assure that craft personnel k have received the required QA indoctrination prior to performing quality-affecting activities.

This is a Severity Level IV Violation (Supplement I).

C-1 1

1. Admission or Denial of the Alleged Violation TVA ndmits the viointion occurred as stated.

2 Peasons for the Violation if Admittad l

l At the time of the audit, Browns Ferrv Standard Practice 4.9 I specifically did not require that all ter.porary outage personnel be l trained in OA requirerents.

I f

l l

l

3 Corrective Steps hich Have Been Taken and the Results Achieved Standard Practice BP h.5 was revised October 1, 10AP to add all temporary field services personnel to GA progran training requirements or to perform work under the direct supervision of OA-trained individuala until such training is complete. ,

4 Corrective Steps Which Will Be Taken To Avoid Further Violations TiPhter administrative controls are being applied to ensure that craftsmen receive necessary training. The Field Fervices training supervisor is scheduling classes to meet this need.

5 Date Phen Full Compliance Will Be Achieved FulJ compliance was achieved on October 1, 1982 when Standard Practice DF 4.5 was revised.

C-?

1. Admission or Denial of the Alleged Violation TVA admits the violation occurred as stated.

2. Reasons for tha Violation if Admitted Inadequate detail within proceduros inhibited meeting the objective of ensuring craft personnel responsible for performing quality-affecting activities were instructad in quality assurance (OA) indoctrination.

3. Corrective Steps Which Have Deen Taken and the Results Achieved

, The revised Browns Feery Ftandard Penetice 4.5 bas included a l requirenent for all craftsnen, site personnel, contractors, and J Construction Services Franch personnel to nttend a PA indoctrination progran prior to performing cuality-affecting activities or to work under the direct supervision of OA-trained individuals until such training is complete.

! 4 Corrective Steos Which Wil) De Taken To Avoid Further Violations All craftenen will be scheduled for OA training classes and tested to demonstrate proficiency.

5. Date Eten Full Compliance Will Be Achieved

! Full compliance will be achieved by January 31, 1993 when all currentiv assigned crnftsnan will have been trained in OA procedures, i

i i

., . - - - - . - -,_--w-,,--y ,-------,-w --. - - - . ,-,,,,-e ,------,,-----,-,-------,--e-.