ML20148F700

Insp Repts 50-327/87-78 & 50-328/87-78 on 871214-18 & 880202-04.Violations Noted.Major Areas Inspected:Restart Employee Concerns Received by NRC

ML20148F700
Person / Time
Site:	Sequoyah
Issue date:	03/11/1988
From:	Brady J, Mccoy F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20148F630	List: ML20148F626 ML20148F670 ML20148F700
References
50-327-87-78, 50-328-87-78, NUDOCS 8803280261
Download: ML20148F700 (14)

See also: IR 05000327/1987078

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. UNITED SVATES

/ NUCLEAR REGULATORY COMMISSION

[N 'o,$ REGION ll

, S ,j 101 M ARIETTA STREET, N W.

• 2 ATL ANTA, GEORGI A 30323

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Report Nos.: 50-327/87-78 and 50-328/87-78

Licensee: Tennessee Valley Authority

6N38 A Lookout Place

1101 Market Street

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Chattanooga, TN 37402-2801

Docket Nos.: 50-327 and 50-328 License Nos.: DPR-77 and DPR-79

Facility Name: Sequoyah 1 and 2

Inspection Conducted: December 14 - December 18, 1987 and

February 2 - February 4, 1988

Team Leader: /AgaM .3 [?[F8 '

/.B.'BradygrojectEngineer Date Signed

Team Members: G. Hunegs

Approved by- $

F. R. McC~oy, Chief, Sequoyah Inspection

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TatVSigned

8[

- ' Programs Section

Division of TVA Projects

SUMMARY

Scope: This announced inspection was conducted in the area of restart Employee

Concerns received by the NRC.

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Results: Violations identified during this inspection include:

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Violation 327, 328/87-78-01, which is a violation of Technical

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Specification (TS) 6.8.1 for failure to adequately implement the

requirements of AI-30 and AI-2 for control of operator overtime. Examples

were noted where plant manager authorization was not obtained to exceed

specified overtime limits and where the deviation forms were not forwarded  :

within one working day after the deviation occurred. -

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Violation 327, 328/87-78-02, which is a violation of 10 CFR 50, .

Appendix B, Criterion V for failure to prescribe in instructions or l

procedures the training and qualification requirements for composite l

crews. Composite crews were implemented prior to having established J

training and qualification requirements for foremen and general foremen

supervising personnel in other crafts and for craftsmen ' performing work

and independent verification outside of their craft.

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8803280261 880314  !

PDR ADOCKO5000327 l

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REPORT DETAILS

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1. Licensee Employees Contacted

• S. Smith, Plant Manager

• J. Anthony, Operations Group Manager

J. Boyles, Employee Concern Site Representative

• R. Briggs, Lead Materials Engineer

T. Howard, Quality Surveillance Supervisor

• G. Kirk, Compliance Licensing Manager

• D. Kunsemiller, SAL Closure Project Manager-

• C, Landstrom, Compliance Licensing Engineer

• J. Miller, Assistant Maintenance Manager ,

• R. Olson, Modifications Manager >

G. Roberts, Manager Power Stores I

• B. Willis, Operations Plant Superintendent

Other licensee employees contacted included technicians, operators, shift

engineers, and engineers.

• Attended exit interview

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2. Exit Interview j

The inspection scope and findings were summarized with the Plant Ms?f,ger

and members of his staff on February 4,1988. The licensee acknov :dged

the inspection findings and did not identify as proprietary any of the

material reviewed by the inspectors during this inspecti'n. During the

! inspection frequent discussions were held with the Plant Manager and other

managers concerning the inspection findings.

3. Licensee Action on Previous Eni;rcement Matters (92702)

This area was not addressed in this inspection.

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4. Review of Employee Concerns

a. Test Deficiencies (OSP-86-A-0138)

The inspector reviewed ECTG element reports 213.2(B) and 204.4(B),

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and the case file for 213.2. Element report 213.2 addressed

deviations to preoperational tests. A selective review was conducted

on nine systems which constituted a "stratified" sample of the work

of the various design discipline teams. The review included a review

i of the deviations to the preoperational tests for these nine systems.

! The review identified that the test deviations were not always

properly dispositioned; however, none were identified that had plant

safety implications. The inspector noted that some of these

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discrepancies were outstanding until as late as 1986. Element report  !

204.4 did not address any of the issues of interest for this concern. I

The inspector discussed the restart test program with members of the i

licensee's staff. The restart test program ruiewed the basle l

functions of the FSAR chapter 15 systems. They then reviewed tha j

surveillance program to determine where these functions art r.ested.  :

If the surveillance program did not test these functior.5, a review cf I

the preoperational test program was conducted. If noitber *he

surveillance test program or the preoperational test program tested i

the function, a test was developed to test the function pi-for to 1

Sequoyah Unit 2 restart. NRC inspection report 327,328/ 87-30 l

discusses the NRC review of the scope and implementation of the  :

restart test program.

NRC inspection report 85-45 reviewed the previint~ve maintenance

program (PM) at Sequoyah. The report noted that fer the review of

completed PMs conducted, there appeared to be discreparmas .uch x

missing data in blanks that required data or info,mation. Adurther

review of this issue in inspection report M-18 'evealed ther the

review of these items was accomplished prior to QA rcview and did not

reflect acceptance of the .PM by TVA. TVA addressed Phventive

Maintenance (PM) in NMRG Report R-86-02-NPS ia ut. in 1986. This wa: ,

reviewed in NRC inspection report 87-15. Yne NMRG ida tified severd

components important to safety that were not cwereo > -prmtrLive

maintenance. In addition, the NMRG identiftw that, .aaragement

approvals had not always been obtairied for we.hert, ext 1nsions or

deferrals. TVA has begun a complete review and comp: ster?zatior, of ,

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their PM program to insure all equiprtent th6t repoires FM rerei.es

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b. CAQRDeterminationAsSignificant(OSP-87-A0062)

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The inspector discussed the licensee's CAQR program, as it relates to

defining a CAQR as significant, with the licensee's QA department end

the Plant Operations Review Staff (PORS). The licensee described

some of the problems that have occurred in the CAQR process over

determining whether a CAQR is significant. There was a difference of

opinion between DNE and PORS over the criteria in paragraph 4.12.3.8

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of AI-12 for determining significance. The criteria relates te t',5

design basis and is identical to the requirements concerniig

reportability in 10 CFR 50.73 paragraph (a).(2).(ii). DNE

interpreted design basis to mean any design criteria or statement

contained in a design document. P0RS interpreted this to mean or.ly

items that were directly involved in determining the design bas.s of

the plant. There have been discussions between DNE and P0RS wrii3 i

have decreased this gap; however, the QA organization is being usert i

to resolve the determination when DNE and PORS come to an impasi.e. QA  !

appears to be doing an adequate job in this function. Two CAQRs that

were at an impasse have been broken loose by QAs resolution (one ih

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favor of P0RS, the other in favor of DNE), while an additional one is

in the determination process at QA.

c. Storage of Equipment (0SP-86-A-0058)

The inspector discussed the on-site storage of equipment with

licensee Power Stores personnel. The licensee identified that a new

program was being implemented for the storage of equipment outside

the power stores building. This new program started in July 1987 and

will complete January 1988. The inspector toured- all the on-site ,

warehouse facilities including those covered by the new program. The

inspector was provided a CAQR which identified that the storage for

service level I and II protective coatings was inadequate. The

inspector verified that a new building was in the process of being

constructed which will provide adequate storage conditions. The

inspector determined that periodic inspections of the storage

locations were conducted as required. The inspector was shown a copy l

of SQ-CAR-86-046 which had previously identified several pieces of i

equipment in the warehouse that were not covered by a preventive

maintenance program. The corrective action for that CAR was to

review all equipment in the warehJse to identify any that are not

covered under a PM progrt. that should be. This has not been

completed yet. The inspector was informed that a new computerized PM

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program pill be started in April 1988. In addition, a long term PM

review program had been initiated in response to NMRG

recommendations. The inspector determined that with the exception of

the items above, the licensee's new program meets the requirements of

ANSI 45.2.2 for storage of material. '

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d. Test Directors (OSP-87-A.-0068)

The inspector reviewed Administrative Instruction AI-47, revision 1,

titled Conduct of Testing along with Surveillance Instruction

SI-275.1, revision 10. The inspector's review was intended to

identify if a conflict could exist between these two instructions as

they relate to the actions of the test director. The inspector noted

that the Surveillance instruction did not reference AI-47.

Discussions with licensee personnel involved with the long term

surveillance instruction upgrade program revealed that AI-47 was

already being added as a reference for many of the instructions as

they are revised. Licensee personnel had already identified the

addition of AI-U as & reference ta be a go0J practice. The

inspectar did ncs identify any obvidus conflicts between the two

m csdares. Hovever, the addition of AI-47 as a reference should

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enhance the Interact. ion of the test director requiremEfets with the

actud perfortuange 01 the tests.

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e. 416 Rod C(.wtrol

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The inspector.< reviewed the Employee Concerns subcategory report for

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Sequoyah an welding (50300). In addition, the inspectors discussed

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weld rod control at Sequoyah with licensee DNE personnel and reviewed

Sequoyah instruction M&AI-5 titled Welding Material Control and

Welder Certification Procedures. The inspectors toured all spaces at

Sequoyah where weld rod is issued to verify that M&AI-5 was-being

properly implemented. In addition, the inspectors discussed weld

rod co,ntrol-with Hartford Steam Boiler Inspectors located at Sequoyah

and reviewed their inspection reports that pertained to weld rod

control. The inspectors concluded that the weld rod control program

at Sequoyah is being adequately implemented.

f. SAL Item Closure (0SP-87-A-0111)

The inspectors reviewed the SAL closure process with licensee SAL

representatives. SAL item 982 was checked for actual status and was

found to be restart complete. A copy of the associated CAQR was sent

to the OSP technical staff to review the evaluation of restart

complete for adequacy. The licensee explained that the categories

for the SAL process include open, closea, and restart complete. The *

licensee explained that it is possible to have a restart complete

item and yet not have all portions of the item complete. For

example, a CAQR for an item can not be signed off as closed until the ,

entire issue of the CAQR is complete. However, the SAL item

associated with the CAQR could be restart complete if the portions

that were designated as required for restart, based on the restart  ;

criteria contained in SQA 190 Attachment A, had been completed.

There were several lists that tracked SAL items. A specific SAL list

could be generated from the computer in addition to a P-2 schedule

list. Both lists could be tracking the same items. Both_ lists can

be specifically generated for either restart items or non-restart ,

items. Some items will appear on both the restart and the non-restart '

list if only a portion of the item required completion prior to

restart. It is possible to look at a restart complete list and

assume that items are complete when they are in fact only restart

complete (especially true with P-2 schedule). Unless the person

looking at the list knows exactly which list is being used, the exact

status of an item could be misinterpreted.

The inspectors reviewed approximately 10 SAL items of which half were

restart complete and the other half were closed. There were several

instances noted where the five signature blocks on the SAL closure

form, SQA 190 Attachment B, were signed off by the same person.

These cases were ones where action was completed prior to issuance of l

the revision to the SAL instruction that contained the five signature

block form. In these cases a stamp had been used on the top of the l

five person signature block form which stated that the issue had been <

closed prior to the revision of the instruction. It appeared that l

the SAL closure personnel had reviewed the corrective action closure

documents from the associated departments (attached to a memo in the

SAL folder stating the closure of the item), inserted the new closure

form, and then signed all five blocks signifying that all

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documentation was present and that the process was complete. Since

an auditable path existed in the SAL closure file and the auditable

documents were properly signed and closed, the inspectors did not

think this practice jeopardized the validity of the closure.

. g. Nonlicensed Operator Overtime (0SP-87-A-0034) l

TVA's Employee Concern Program (ECP) reviewed the subject of

excessive overtime being performed by nonlicensed operators. Based

on their review, it appeared that overtime limits specified in NRC l

Generic Letter 82-12 "Nuclear Power Plant Staff Working Hours" dated i

June 15, 1982, were exceeded on at least 56 occasions from January 1 ,

to May 3, 1987. As TVA's ECP staff considered the concern to be l

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management and personnel related, the preliminary review was

forwarded to the Site Director on May 26, 1987 for resolution.

The Plant Manager's response, dated July 15, 1987, stated that i

Operations was in compliance with Generic Letter No. 82-12 and that I

efforts were being made to reduce overtime for AU0's.

TVA's ECP determined that the response was acceptable and closed out I

the concern on July 17, 1987.

The inspector reviewed the ECP summary, Plant Manager's response,

associated records and interviewed several licensed and nonlicensed

operators. During the past year, a significant amount of overtime was

worked by some Sequoyah Auxiiiary Unit Operators (AVO). The ,

inspector did not find any in.iication that individuals who did not I

want to work overtime had been harassed. However, there were l

problems noted with the authorization process for exceeding overtime

limits.

Administrative Instruction (AI)-30, Rev.10, dated January 5,1988 l

"Nuclear Plant Conduct of Operation", Section 23 "Plant Staff

Overtime Limits" required Plant Manager or Plant Superintendent l

authorization to exceed the overtime limits specified in AI-30. The l

inspector found that AI-30 was not' being followed in that numerous

cases were noted where the Plant Manager or Plant Superintendent

acknowledged af ter the fact that overtime limits were exceeded but

did not authorize deviations to AI-30 overtime limits prior to their

occurrence. The inspector identified to the licensee that the

purpose of these limits was to ensure that upper level plant

management was aware that an individual would exceed the number of

hours that are considered to be the safe working limit and personally

authorize this occurrence. AI-30 also requires that AI-2, Appendix

C "Deviation From Plant Staff Overtime Limits" be forwarded to the

Plant Manager no later than the next work day. This was not always

followed. Some examples of not forwarding the required form within

the next work day are as follows:

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AI-30 Overtime Limits Date Forwarded To -

That Were Exceeded Date Exceeded Plant Manager

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Feb. 11, 1987 Mar. 7,-1987

< 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> off May-20, 1987 May 24, 1987

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> May 20, 1987 May 24, 1987

(total of 32 hours3.703704e-4 days <br />0.00889 hours <br />5.291005e-5 weeks <br />1.2176e-5 months <br />)

> 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> in 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> Jul. 29, 1987 Aug. 15, 1987

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< 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> off Nov. 18, 1987 Nov. 27, 1987

The failures to get plant manager or plant superintendent

authorization to exceed overtime limits and the failures to forward

the required form within the specified period of time are considered

failures to adequately implement Administrative Instructions AI-30

and AI-2. This is considered a violation of Technical Specification 6.8.1 for failure to establish, implement, and maintain written

procedures and is identified as Violation 327, 328/87-78-01.

h. Composite Crews (0SP-86-A-0081)

The inspector reviewed the applicable regulatory requirements, the

Employee Concerns Program subcategory repor' lat addressed composite

crews, the NMRG report on composite crews, relevant corporate and

plant procedures, existing Sequoyah Quality Assurance (QA) audits

, related to composite crews, work packages performed by composite

crews, and personnel records. In addition, the inspector conducted

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interviews with plant personnel. The inspection focused on whether

the individuals performing, supervising, and independently verifying

work done by composite crews were adequately qualified for these

responsibilities.

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Sequoyah is committed in the FSAR to ANSI 18.1-1971, "Selection and

Training of Nuclear Power Plant Personnel". The qualification

requirements for craft foremen and general foremen are addressed in

ANSI 18.1 under the heading "Supervisors Not Requiring AEC Licenses".

The Nuclear Quality Assurance Manual (NQAM) Part III, Section 6.1

implements the ANSI 18.1 requirements, which are reiterated in the

NQAM as follows:

The general foremen and foremen of skilled craf ts shall have a

high school diploma or equivalent and have completed four or

more years of experience in the craft he supervises.

The ANSI 18.1 requirements for the qualifications of technicians and

' repairmen are provided in Section 4.5 of the standard and are as

foilows:

Technicians in responsible positions shall have a minimum of two

years of working experience in their specialty. These personnel

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should have a minimum of one year of related technical training

in addition to their experience,

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Repairmen in responsible positions shall have a minimum of three

years in one or more crafts.

Training requirements for electrical and mechanical craftsmen are

covered in Part III of the NQAM, which is implemented by

Administrative Instruction AI-14, "Sequoyah Site Training Program",

Revision 38. Each of these documents refers to TVA Nuclear Power

Policy Procedure 0202.08, "Electrical and Mechanical Maintenance

Craf tsman Training Program" for detailed specification of training

requirements. In addition to the prior experience requirements,

Procedure 0202.08 requires that an initial training program be

completed before individuals independently perform maintenance on

safety-related systems or components. TVA has performed a Task

Analysis on the work performed by the major maintenance craf ts, and

has identified the level of training required to perform each task.

Those tasks which require skills beyond those normally considered

within the skill of the craftsmen who have completed the initial

training program are identified in a task matrix. Cognizant

maintenance supervisors are required to ensure that individuals are

not allowed to work independently or be assigned lead responsibility

for tasks in which they are not qualified to perform. The Sequoyah

maintenance training program is further described in separate

Maintenance Section Instruction Letters for each section.

Administrative Instruction AI-37, "Independent Verification",

requires that independent verification be performed by qualified

individuals, and assigns each section the responsibility for

establishing a minimum qualification level for the individuals

performing independent verifications.

TMI Action Plan, Item I.C.6 (NUREG 0737) required that licensees

review their procedures and revise them, if necessary, to require

independent verification of proper actions when releasing systems and

equipment for maintenance, surveillance testing or calibration, and

subsequent return to service. As a result of a continuing incidence

throughout the industry of errors that resulted in inadvertent

4 reactor trips or inadvertently placing safety-related equipment in an

inoperable status, NRC IE Information Notice 84-51, "Independent

Verification", June 26, 1984, was issued to call licensee attention

to the importance of independent verification. This IE Notice

identified a generic need for improvement in the definitions being

used by licensees for the terms "independent verification" and

"qualified personnel", the clarity of language used in procedures to

clearly specify exactly what personnel must complete before signing

off a section of a procedure, and the importance that management

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places on independent verification activities.

As an example of implementation of AI-37 by individual plant

sections, the inspector reviewed Electrical Maintenance Section

Letter EMSL-E45, "Double Person Verification", Revision 0, approved

May 13, 1985. Included in the specified personnel qualified to

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perform independent verifications of electrical maintenance were

"those persons deemed qualified by the Electrical Maintenance

management". A list of those deemed qualified by management was

required to be documented in a memo to the Maintenance

Superintendent. It was not specified in the procedure upon what

basis management would deem individuals to be qualified. The

inspector also reviewed Maintenance Instruction MI-6.20,

"Configuration Control During Maintenance Activities", Revision 11,

dated May 1987. This procedure stated that verification of accurate

restorations of configuration changes must be performed by

individuals qualified in accordance with AI-37, but did not specify

how the qualification requirements of AI-37 are implemented.

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Composite crews were addressed in TVA Management and Personnel (MP) l

Subcategory Report 71700, "Personnel Qualifications." No NRC Safety i

Evaluation Report (SER) was written on MP 71700 because the MP j

category was not designated as safety related. The inspector

reviewed MP 71700, Revision 4, dated May 1987, and concluded that the

concerns regarding composite crew qualifications had not been

adequately addressed. The only negative findings reported in the j

area of craf t qualifications were that a number of foremen and  ;

general foremen did not posses a high school diploma or the  ;

equivalent, as required by the NQAM and ANSI 18.1. The report I

acknowledged that general foremen do not always satisfy the NQAM and i

ANSI 18.1 requirement to have four years of experience in each craft

they supervise, but the report stated that this "is not a problem."

Also, insufficient justification was provided to support the

conclusions of the report that none of the other issues, such as ,

craf t foremen not having four years experience in the craf ts they l

supervise, could be substantiated. Several of these issues were

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dismissed merely on the basis that the FSAR agreed with ANSI-18.1,

without an audit of the actual implementation of the requirements.

The corrective actions section of MP 71700 stated that the Labor

Relations staff was currently working with the four sites to properly

document the qualifications and experience of the existing craf t

foremen who did not appear to meet the ANSI requirements, with

possible extended programs such as GED preparation and completion, i

The Employee Concerns Program Manager requested that the Nuclear

Manager's Review Group (NMRG) conduct a review of composite

maintenance crews. The review examined composite crew qualifications

and performance at Browns Ferry and Watts Bar between July 31, 1987

and August 21, 1987. The findings were documented in NMRG Report

R-87-04-NPS, "Review of Composite Maintenance Crews at the Browns

Ferry and Watts Bar Nuclear Plants", September 1987. Findings of the

study incl'ded various deficiencies in the process for m ving

On-the-Job Training (0JT) requirements, including inadequate or

improper justifications for waivers which did not comply with the

established waiver process specifications, such as waivers based on

the supervisor just "knowing that he knew how to do it" or the

individual's word that he was qualified. Other identified

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deficiencies included the lack of required qualification cards for

certain required training, waivers made without having performed the

required formal training, insufficient or inadequate auditing of the l

waiver process, records not being maintained in accordance with j

requirements, and records discrepancies. A significant number of

craftsmen who had been wavered on OJT requirements did not

demonstrate satisfactory knowledge on an oral questionnaire designed i

to measure their ability to independently perform the waived tasks. l

A high percentage of the craftsmen failing the questionnaire said  ;

that they had limited or no knowledge of the task for which their OJT 1

was waived and were not qualified to independently perform the i

specific task. Some were not aware that they had been given waivers  !

for these tasks until after the fact. As had been previously noted l

in MP 71700, it was documented in the NMRG report that the NQAM and '

ANSI 18.1 requirements for the education and experience of

maintenance foremen were not being met.

Because the findings in the areas of qualification and training were

common to both sites, the NMRG recommended stronger corporate j

direction. 1

The inspector interviewed plant personnel and reviewed plant records

to determine the types and extent of work being performed by

composite crews, and to assess the qualifications of the individuals

performing the assigned tasks. In assessing individual

qualifications, the inspector evaluated whether documented, auditable i

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qualification records existed, as well as the level of personal

competence or ability to perform the particular jobs assigned. The

individuals interviewed by the inspector were either presently or

previously involved with composite crews at Sequoyah, and included

approximately twenty randomly selected craftsmen in various

disciplines plus a number of foremen and managers.

Licensee management identified to the inspector that composite crews

at Sequoyah included a refrigeration crew, a crew for maintenance of

motor operated valves, a night crew for preventive maintenance, a

crew established to support valve alignments and perform plant

cleanup, and crews established on a case-by-case basis to perform

specific tasks. Additionally, the craftsmen reported to the

inspector that on the weekends a number of craf tsmen reported to

foremen of a different craft. This was verified with licensee I

management.

Members of the motor operated valve maintenance crew included

electricians and machinists, who had received documented formal

training on MOVATS. Tasks performed by the other composite crews

were generally less technically complex. All of the individuals

interviewed appeared to have an adequate level of understanding of

the work they had performed, and were confident that all work they

had been involved with h.id been performed properly. A number of work

packages recently completed by the refrigeration and motor operated

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valve crews were discussed in detail with individuals involved in the

work. In all cases, the individuals interviewed demonstrated a good

understanding of the work packages discussed. Some of the

individuals interviewed indicated that some problems had been

encountered when the motor operated valve maintenance crew had first

been formed, but that these problems had been resolved through

additional training and experience.

Although the interviewed personnel were confident that the work they

had been involved in had been performed properly, many still had

reservations about the composite crew concept. The reservations

primarily involved concerns that they might not have adequate

technical supervision when the foreman was of a different craft, and

concerns regarding the complexity of jobs they might be expected to

perform in the future. The inspector noted that many of the

composite crew foremen acknowledged that they did not fully

understand much of the work performed by craf tsmen under them, but

they stated that it did not matter because the craftsmen were

excellent and could be depended upon. Many of the craftsmen and

foremen interviewed saw the role of the foreman as providing

administrative rather than technical supervision. For the motor

operated valve maintenance crew, under an electrical foreman, a

mechanical engineer was available to provide technical support when

needed by the machinists. Members of other composite crews indicated

that when the foreman d'd not understand problems they had

encountered with their work, they went to friends or colleagues.

The inspector questioned the licensee as to whether any problems with

composite crew performance had been apparent from QC inspections or

QA audits of work performed by these crews, and reviewed copies of

the audits related to composite crews. QA/QC had not identified any

significant problems in their inspections.

The interviews revealed that independent maintenance activities in a

particular discipline were normally performed by a member of that

craft, but not always. Although Procedure 0202.08 contains minimum

experience and training requirements for personnel independently

performing maintenance on safety related equipment, the licensee

acknowledged that work outside of a craftsman's discipline could be

independently performed on safety related equipment if the task was

not on the matrix and the crew foreman considered the craftsman able

to do it. Licensee personnel stated that it was the responsibility

of the individual to notify management if he did not "feel

comfortable" about performing an assigned task. No procedural

criteria existed regarding when the training and experience

requirements of 0202.08 could be waived based on the simplicity of a

particular task or the innate ability or confidence of the

individual.

The full scope of tasks performed by composite crews could not be

readily determined from the work packages on file because of the

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large number of work packages and because those performed by

composite crews could not readily be sorted out. The inspector

concluded that procedural controls were needed to establish which

tasks craftsmen could perform outside of their documented area of ,

experience and training, and to establish and document their

qualifications to perform this work.  :

Several of the individuals interviewed at Sequoyah had also

participated in composite crews at Browns Ferry or Watts Bar. Some

of these individuals told the inspector of problems and incidents at

those sites involving composite crews. The information conveyed to

the inspector was consistent with the findings presented in the NMRG ,

report. Several individuals also claimed knowledge of craftsmen at '

the other sites being pressured to perform work they were not

properly qualified for, with resulting consequences to equipment and

personnel safety. No similar problems at Sequoyah were identified to

the inspector, j

Although the use of composite crews at Sequoyah appeared to be more l

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conservative and less extensive than at the other sites, the

inspector determined that existing Sequoyah procedures did not

preclude the types of problems .eported at Browns Ferry and Watts

Bar. Both the scope of work performed by the composite crews and the '

qualifications of persons performing the work were controlled by

management discretion on a case by case basis. TVA management stated

to the inspector that Sequoyah planned to expand the use of composite

crews in the future and adhere less to the traditional craft

disciplines as described in the ANSI standards. The inspector

concluded that adequate procedural controls did not exist to ensure

that all maintenance activities would be performed by qualified

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individuals, with documented certification of the qualifications.

Overall, existing procedures pertaining to craft experience,

training, and qualification requirements were oriented toward

traditional jurisdictions and did not adequately cover the use of

composite crews.  !

Although the maintenance activities were usually performed by a

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member of the appropriate craf t, composite crew members of ten worked

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in pairs consisting of two different crafts. The second individual, l

! of a different craft, would frequently sign the independent 4

verifications of work performed by his partner. During discussions I

i of completed work packages, several individuals acknowledged that l

they frequently signed independent verifications of steps which they l

. could not have performed themselves. Some work items listed on the  !

task matrix as requiring special training to perform were being .

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independently verified by individuals not certified on the matrix to  !

perform the task. However, those individuals who stated that they l

j were not qualified to perform the steps, did consider themselves

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qualified to have accurately judged if the step had been performed.

Some of the individuals downplayed the importance of the level of

qualification and the level of independence required to perform

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independent verification. One individual, apparently. intending to

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reassure the inspector, stated, "I go along with my buddy (of another

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craft) but I chn't do anything important. Just carry his tool box or

do independent verifications." Conversations with other licensee

personnel indicated that it was a common and accepted practice for

individuals to sign independent verifications on steps they were not

qualified to perform. The licensee based this policy on the fact i

that the thorough reviews given their procedures decreased the skill

levels required for independent verifications. A member of licensee t

management indicated to the inspector that he would consider a

secretary capable of performing most independent verifications

required at the plant. This attitude is in conflict with the

importance that management should place on independent verification

activities as identified in IE Notice 84-51. This concern was

brought to the-attention of licensee management.

The inspector concluded that the level of qualification necessary for

an individual to perform independent verification outside his craft

was not adequately specified in plant procedures. Inadequate

certifications for individuals performing independent verifications

was identified to the licensee as a potential plant-wide issue and is

not restricted only to composite crews (Inspection Reports 327,

328/87-66 and 88-06).

The inspector reviewed the status of the licensee's corrective

actions regarding the craft foremen and general foremen identified as

not meeting the ANSI-18.1 and NQAM requirements for a high school

dipicina or the equivalent. Progress was demonstrated in this area in

that of the original seven foremen not meeting this requirement,

three had subsequently received a GED. This area met the five

criteria for a licensee-identified violation specified in

i 10 CFR Part 2 Appendix C, Paragraph V.

The inspector reviewed the othe- issues above and determined that

they did no meet the criteria for being licensee-identified as

defined in 10 CFR Part 2, Appendix C, Paragraph V. Although the NMRG

report had identified certain shortcomings in composite crew

implementation corporate wide, adequate actions had not been

initiated prior to the NRC inspection to apply the NMRG findings to

Sequoyah. The licensee evaluations had not identified the need to

procedurally establish qualification levels for performing and

independently verifying tasks outside the accepted skill of the

individual's own craft. Additionally, although TVA was aware that

the foremen of composite crews did not satisfy ,ne NQAM qualification

requirements or the FSAR commitment to ANSI 18.1, actions had not

been taken to either revise the FSAR commitment or document

compliance with it.

i The failure to prescribe composite crew training and qualification

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requirements for foremen and general foremen supervising personnel in

other craf ts, for craf tsmen performing work outside of their craf t,

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and for craftsmen performing independent verification outside of

their craf t is considered a violation of 10 CFR 50, Appendix B,

Criterion V for failure to prescribe activities affecting quality in

documented instructions or procedures and is designated Violation

327, 328/87-78-02.

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