ML20148F700
| 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: |
| 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
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NUCLEAR REGULATORY COMMISSION
REGION ll
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101 M ARIETTA STREET, N W.
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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
Chattanooga, TN 37402-2801
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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
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/.B.'BradygrojectEngineer
Date Signed
Team Members:
G. Hunegs
Approved by-
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F. R. McC~oy, Chief, Sequoyah Inspection
TatVSigned
- ' Programs Section
Division of TVA Projects
SUMMARY
Scope: This announced inspection was conducted in the area of restart Employee
Concerns received by the NRC.
Results:
Violations identified during this inspection include:
a
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,
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Appendix B,
Criterion V for failure to prescribe in instructions or
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procedures the training and qualification requirements for composite
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crews.
Composite crews were implemented prior to having established
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
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PDR ADOCKO5000327
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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
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- 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
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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
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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.
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),
and the case file for 213.2. Element report 213.2 addressed
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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
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of the deviations to the preoperational tests for these nine systems.
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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.
The inspector discussed the restart test program with members of the
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licensee's staff.
The restart test program ruiewed the basle
functions of the FSAR chapter 15 systems.
They then reviewed tha
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surveillance program to determine where these functions art r.ested.
If the surveillance program did not test these functior.5, a review cf
the preoperational test program was conducted.
If noitber *he
surveillance test program or the preoperational test program tested
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the function, a test was developed to test the function pi-for to
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Sequoyah Unit 2 restart.
NRC inspection report 327,328/ 87-30
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:
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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)
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
of AI-12 for determining significance. The criteria relates te t',5
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design basis and is identical to the requirements concerniig
reportability in
paragraph
(a).(2).(ii).
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
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have decreased this gap; however, the QA organization is being usert
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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
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of SQ-CAR-86-046 which had previously identified several pieces of
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
program pill be started in April 1988.
In addition, a long term PM
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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
enhance the Interact. ion of the test director requiremEfets with the
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actud perfortuange 01 the tests.
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
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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
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items. Some items will appear on both the restart and the non-restart
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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
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
five person signature block form which stated that the issue had been
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closed prior to the revision of the instruction.
It appeared that
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.
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g.
Nonlicensed Operator Overtime (0SP-87-A-0034)
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 Generic Letter 82-12 "Nuclear Power Plant Staff Working Hours" dated
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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
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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
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Operations was in compliance with Generic Letter No. 82-12 and that
efforts were being made to reduce overtime for AU0's.
TVA's ECP determined that the response was acceptable and closed out
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
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inspector did not find any in.iication that individuals who did not
want to work overtime had been harassed.
However, there were
problems noted with the authorization process for exceeding overtime
limits.
Administrative Instruction (AI)-30, Rev.10, dated January 5,1988
"Nuclear Plant Conduct of Operation", Section 23 "Plant Staff
Overtime Limits" required Plant Manager or Plant Superintendent
authorization to exceed the overtime limits specified in AI-30.
The
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
< 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
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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
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crews, and personnel records.
In addition, the inspector conducted
interviews with plant personnel.
The inspection focused on whether
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the individuals performing, supervising, and independently verifying
work done by composite crews were adequately qualified for these
responsibilities.
Sequoyah is committed in the FSAR to ANSI 18.1-1971, "Selection and
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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
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foilows:
Technicians in responsible positions shall have a minimum of two
years of working experience in their specialty. These personnel
should have a minimum of one year of related technical training
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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
reactor trips or inadvertently placing safety-related equipment in an
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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
places on independent verification activities.
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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)
Subcategory Report 71700, "Personnel Qualifications." No NRC Safety
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Evaluation Report (SER) was written on MP 71700 because the MP
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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
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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
acknowledged that general foremen do not always satisfy the NQAM and
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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
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craf t foremen not having four years experience in the craf ts they
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,
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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
waiver process, records not being maintained in accordance with
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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
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to measure their ability to independently perform the waived tasks.
A high percentage of the craftsmen failing the questionnaire said
that they had limited or no knowledge of the task for which their OJT
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was waived and were not qualified to independently perform the
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specific task. Some were not aware that they had been given waivers
for these tasks until after the fact.
As had been previously noted
in MP 71700, it was documented in the NMRG report that the NQAM and
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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
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direction.
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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
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qualification records existed, as well as the level of personal
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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
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
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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
'
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
member of the appropriate craf t, composite crew members of ten worked
,
in pairs consisting of two different crafts. The second individual,
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!
of a different craft, would frequently sign the independent
4
verifications of work performed by his partner.
During discussions
i
of completed work packages, several individuals acknowledged that
they frequently signed independent verifications of steps which they
could not have performed themselves.
Some work items listed on the
!
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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
j
were not qualified to perform the steps, did consider themselves
'
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
,
reassure the inspector, stated, "I go along with my buddy (of another
1
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.
The failure to prescribe composite crew training and qualification
i
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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