ML20101F825
| ML20101F825 | |
| Person / Time | |
|---|---|
| Site: | Browns Ferry, Sequoyah, 05000000 |
| Issue date: | 10/22/1984 |
| From: | Mills L TENNESSEE VALLEY AUTHORITY |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20101F783 | List: |
| References | |
| GL-84-14, NUDOCS 8412270317 | |
| Download: ML20101F825 (5) | |
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- TENNESSEE VALLEY AUTHORITY ~-
CH ATTANOOGA, TENNESSEE 374ot 400 Chestnut Street Tower II M OCT26 all: g5 r
October 22, 1984 U.S. Nuclear Regulatory Commission Region II ATTN: James P. O'Reilly, Regional Administrator 101 Marietta Street, NW,. Suite 2900 Atlanta, Georgia 30323
Dear Mr. O'Reilly:
Enclosed is our response to R. 'C.
Lewis' September 21, 1984 letter to
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H. G. Parris transmitting IE. Inspection Report Nos. 50-259/84-24,
-260/84-24, -296/84-24, -327/84-18, -328/84-19 for our Browns Ferry and Sequoyah Nuclear Plants which. appeared to have been'in violation of NRC regulations.- We have enclosed our response to the Notice of Violation and the Notice of Deviation. If you have any questions, please call Jim Domer at FTS 858-2725 regarding Browns Ferry and Ralph Shell at FTS 858-2688 regarding Sequoyah.
To the best of my knowledge, I declare the statements contained herein are complete and true.
Very truly yours, TENNESSEE VALLEY AUTHORITY MWR L. M. Mills, Manager Nuclear Licensing Enclosure i
8412270317 841120
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gDRADOCK 05000259 PDR An Equal Opportunity Employer
'6 RESPONSE-NRC INSPECTION REPORT NOS.
'50-259/84-24, 50-260/84-24, 50-296/84-24, 50-327/84-18, AND 50-328/84-19 R. C. LEWIS'S LETTER TO H. G. PARRIS DATED SEPTEMBER 21, 1984 RESPONSE TO NOTICE OF VIOLATION Item 1 - (259, 260, 296/84-24-01) 10 CFR 50, Appendix B, Criterion V, states that activities affecting quality shall be prescribed by documented instructions and procedures of a type appropriate to the circumstances and shall be accomplished in accordance with these procedures and instructions.
Contrary to the above, training activities prescribed in Browns Ferry Standard Practice BF 4.8 were not accomplished in accordance with BF 4.8, in that:
a.
An individual not licensed as a Senior Reactor Operator taught systems to Assistant Unit Operators in a Hot License Reactor Operators class.
A Unit Operator, who transherred from the Sequoyah Nuclear b.
a.
Plant, did not complete the Plant Familiarization Program as specified for job classifications assigned to a new plant.
c.
Several auxiliary watch station examinations were not conducted by two or more qualified operators as indicated by examination documentation.
This is a Severity Level IV violation (Supplement I) applicable to Browns Ferry Units 1, 2, and 3 only.
1.
Admission or Denial of the Alleged Violation TVA admits the alleged violation as stated.
2.
Reasons for the Violations a.
A reactor operator acted as an instructor because an interpretation of the section titled " Instructions for Operator Training" of Standard Practice BF 4.6, page 9, permitted him to act as an instructor. This section of the Standard Practice requires the instructor to be certified in the techniques of instruction and he must hold or have held an NRC license on the operating plant to which they are assigned. Additional requirements for instructors are imposed in Standard Practice BF 4.8 on page 27. This requirement stipulates that an instructor shall have demonstrated competence by successful completion of a senior operator examination. The procedure is deficient because the requirements on page 27 should have also been listed under the requirements for operator instructors on page 9 of the Standard Practice.
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-L. b. = The Standard-Practice 4.8 requirement regarding administration of the Plant Familiarization Program (PFP) is optional for assistant unit' operators (AUOs) transferring from other nuclear plants. The PFP is required only for student IV. operators.
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- c. - the examiners ' failed to complete the required documentation upon
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completion of the'AUO watch station examinations.-
3 Corrective Steps Which Have Been Taken and Results-Achieved Upon being made aware of the requirements imposed by'BF 4.8, page a.
27 the Operations Training Supervisor imposed the restriction that only a senior reactor operator may act as an instructor.
b.
PFP wilJ not be required for AUOs transferred from other nuclear plants. Actions have been initiated, however, to formalize the break-in period for transfers. A checklist of job tasks will be completed before assuming shift responsibilities.
The examination records have been reviewed and incomplete c.
i documentation noted.
i 4.
Corrective Steps Which Will Be Taken To Avoid Further Violations.
u.
Standard Practice BF 4.8 will be revised to include instructor a.
5 requirements listed on page 27 in the section titled Operator j
Instructors on page 9.
1 1
b.
An Operations Training Section Instruction Letter will be prepared and issued which formalizes and provides a break-in checklist for activities to be accomplished by new operating personnel.
l The examiners will sign documentation as required and examiners c.
will be made aware of the necessity to prepare complete examination -
i documentation. A memorandum will be forwarded to all operating personnel informing them of the need to properly complete documentation.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by November 16, 1984 when changes a.
j to BF 4.8 will have been approved.
i b.
Full compliance will be achieved by November 16, 1984 when form BF-33 will have been changed.
i c.
Full compliance will be achieved by November 11, 1984 when all examination documentation will have been completed and the j
information memorandum forwarded to operating personnel.
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& Item 2 - (327/84-18-01, 328/84-19-01) 10 CFR 55 Appendix A.4(a) states that annual written examinations which determine areas in which retraining is needed to upgrade licensed operator and senior operator knowledge shall be included in the requalification program.
Contrary to the above, a licensee instructor at Sequoyah who is a licensed Senior Reactor Operator and who only taught a portion of the requalification program was exempted from the 1983 Sequoyah annual written examination.
This is a Severity Level IV violation (Supplement 1) applicable to Sequoyah Units 1 and 2 only.
1.
Admission or Denial of the Alleged Violation TVA denies the violation as stated.
2.
Reasons for the Denial TVA's licensed operator requalification training program, as described in Amendment 61 of the FSAR dated May 1979 states, " Training instructors who are licensed are exempt from taking the examination o -
for whf ah they had primary responsibility for administering. A maximum of three licensed personnel may be exempt." In April of 1983 this wording was incorrectly renoved by the FSAR update. However, our detailed requalification training program as outlined by governing procedures has been changed in that it has always allowed for the exemption of three licensed personnel in accordance with the approved FSAR. Operation Section Training Instruction Letter OSLT-1 uses the exact wording as the May 1979 revision to the FSAR. These guidelines have been followed since this May 1979 issue date of the FSAR. This is a practice used by several utilities throughout the industry and has been accepted by NRC.
It is recognized by both TVA and NRC that the present wording in the FSAR of the program is general in nature. NRC had addressed this fact-to all utilities by issuing a Generic Letter (84-14) requiring licensed facilities to provide greater dotail of their retraining programs in their next revision to the FSAR. TVA is now in the process of submitting a more detailed description of the requalification program in accordance with the generic letter.
In the interim, until our response to the generic letter has been approved, all licensed personnel have been required to take the exam. However, our submittal to the generic letter will continue to allow for provisions to exempt licensed personnel meeting the same criteria as used in the past. It is the opinion of TVA that the individual involved did meet the intent of 10 CFR 55, since our program is one that has been previously reviewed by NRC and found acceptable.
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.g., RESPONSE TO NOTICE OF DEVIAITON Item 1 - (259, 260, 296/84-24-02)
Based on the results of the NRC training assessment conducted on July 16-20
- and 24-26, 1984, certain of your activities appear to deviate from your commitments to the commission as indicated below
Paragraph 13 2.1.5 3 of the Browns Ferry Final Safety Analysis Report states that at the time of appointment to the active position, the shift engineer shall have six years of responsible power plant experience.
Contrary.to the above, Browns Ferry Nuclear Plant Standard Practice BF 4.8 states that a Shift Engineer shall have five years of power plant 4
operating experience. Deviation is applicable to Browns Ferry Units 1, 2, and 3 only.
1.
Corrective Action Regarding This Deviation This requirement was subsequently amended to five years, however, the FSAR statement was not collaterally changed. An FSAR change to correct i
this deficiency has been put on the commitment tracking system.
4 2.
Action Taken To Avoid Further Deviations A revision to the FSAR will be submitted during the 1985 annual FSAR update. The revision will relate that a shift engineer shall have five years of power plant operating experience.
3 Date When These Actions Were or Will Be Completed i
The FSAR update is normally submitted during the month of July of each year.
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