ML20155G228
| ML20155G228 | |
| Person / Time | |
|---|---|
| Site: | Sequoyah  |
| Issue date: | 06/13/1988 |
| From: | Gridley R TENNESSEE VALLEY AUTHORITY |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8806170213 | |
| Download: ML20155G228 (5) | |
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TENNESSEE VALLEY AUTHORITY CH ATTANOOG A. TENNESSEE 37401 i'
-5N 157B Lookout Place
'JUN 181988 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D.C.
20555 Gentlemen:
In the Matter of
)
Docket Nos. 50-327 Tennessee Valley Authority
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50-328 SEQUOYAH NUCLEAR PLANT-(SQN) - NRC INSPECTION REPORT NOS. 50-327/87-78 AND 50-328/87-.78 - REVISED RESPONSE TO NOTICE OF VIOLATION Enclosed is my response to K. P. Barr's letter to S. A. White dated May 10, 1988, that requested a supplemental response to violation 50-327, -328/87-78-02. provides my. revised response.to this violation.
contains a list of commitments contained in this submittal. This list of con:mitments supersedes commitments identified in our previous response to violation 50-227, -328/87-78-02.
If you have any questions, please telephone M. R. Harding at (615) 870-6422.
Very truly yours, TENNESSEE VALL AUTHORITY R. G diey, Dir tor Nuclear Licensing and Regulatory Affairs Enclosures cc:
See page 2 1 \\
8806170213 880613 PDR ADOCK 05000327
.Q DCD An Equal Ooportunity Employer L..
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- U.S. Nuclear Regulatory Commission
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Hr. K. P. Barr, Acting. Assistant Director for Inspection Programs TVA Projects Divisio_n U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, NW, Suite 2900 Atlanta, Geor;gia 30323 Ms. S. C. Black, Assistant Director for Projects TVA Projects Division U.S. Nuclear Regulatory Commission One White Flint, North 11555 Rockville Pike Rockville, Maryland 20852 Sequoyah Resident Inspector Sequoyah. Nuclear Plant 2600 Igou Ferry Road Soddy Daisy,' Tennessee 37379 r
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ENCLOSURE 1
. REVISED RESPONSE TO NRC INSPECTION REPORT NOS.-50-327/87-78 AND 50-328/87-78 K. P. BARR'S LETTERS TO S. A.~HHITE DATED MARCH 14, 1988,'AND May 10, 1988 Violation 50-327 -328/87-78-02 "10 CFR 50, Appendix B, Criterion V, the licensee's accepted Quality Assurance Program, and the Nuclear Quality Assurance Manual collectively require that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings and shall be accomplished in accordance with instructions, procedures, or drawings.
Contrary to the.above. prfor to December 14, 1987, the licensee failed to
. prescribe in instructions or procedures the training and qualification requirements for composite crews, in that composite crews were implemented prior to having established training.and-qualification requirements for foremen and general foreman supervising personnel in other crafts, for
-craftsmen performing work outside_of their craft, and for craftsmen performing independent verification outside of their craft.
This is a Severity Level IV violation (Supplement I)."
Admission or Denial of tF leged Violation.
TVA admits the violation.
-Reason for the Violation This violation resulted from a management decision to implement composite maintenance crews without fully assessing the personnel qualification requirements contained in ?.he following:
(1) the Nuclear Quality Assurance Manual-(NQAM), Part III, section 6.1, for craft general foremen, foremen, and the personnel they supervise; (2) the requirements contained in Administrative Instruction (AI) 37, "Independent Verification"; and (3) the commitment to American National Standards Institute (ANSI) 18.1-1971 contained in TVA topical report TVA TR75-1A.
-Corrective Steps That Have Been Taken SQN Standard Practice SQM-70, "Composite Crew Operation," has been created to specify requircu nts for assignment of work to composite crews and for independent' veri'ications performed by personnel assigned to the crew.
SQM-70 also ensures tw only perso:
quallfled and trained to perform a particular
' job are assignr j to do the j.a.
These individuals may be assisted by persons who have expertise in a different craft, bet those assisting will not perform any task for which they have not been specifically qualified and trained to perform.
An NQAM quality notice has been issued clarifying the requirements for foremen supervising composite crews.
The notice states, "Foremen of multiple discipline crews shall have four or more years of experience in one of the crew disciplines and direct access to technical support in other disciplines."
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- Composite crews performing multiple-discipline work on safety-related equipment and features include lead craftsmen for each required discipline other than that of the crew foreman.. The lead craftsmen possess a high school diploma or equivalent, have four or more years of experience in their craf t, and therefore meet the requirements for foremen as specified in ANSI 18~1-1971. The lead craftsmen provide assistance in selecting individuals for work assignments within their craft discipline.
Corrective Steps That Will Be Taken to Avoid Further Violations AI-37 will be revised by June 15, 1988, to clarify the requirements for independent verification.
These requirements ensure that personnel performing independent verification are qualified to perform the work.
Equivalency training similar to the c,*oss-discipline training given to the MOVATS composite crew will be developed for existing composite crews.
Equivalency training will also be developed as additional composite crews are created.
This cross-discipline equivalency training, along with possession of a high school diplomt or equivalent and the requirements stated in the quality notice, constitutes an acceptable method of meeting the experience requirements of ANSI 18.1-1971 for composite crew foremen.
Until equivalency training is developed and implemented for a particular composite crew, lead craftsmen will be assigned to composite crew foreman as previously described in this enclosure.
The NQAM quality notice for SQN will be revised to include discussion on equivalency training for multiple-discipline crew foremen by July 8, 1988.
SQM-70 will be revised to require completion of identified equivalency training for composite crew foremen or assignment of lead craftsmen for craft disciplines outside that of the particular composite crew foremen before allowing a composite crew to perform any work on safety-related equipment or features. The instruction will be revised by July 8,1988.
Date When Full Compliance Will Be Achieved SQN is in full compliance.
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--s-ENCLOSURE 2 List of Commitments
- 1.
SQN will' revise AI-37 to clarify requirements for independent verification by June 15, 1988.
2.
NQAM quality notice for SQN on qualifications for multiple-discipline crew foremen will be revised to include discussion of equivalency training 'squirements by July 8, 1988.
3.
SQM-70 will be revised by July 8, 1988, to require completion of identified equivalency training for composite crew foremen or assignment of lead craftsmen fer craft disciplines outside that of the particular composite crew foreinen before allowing a composite crew to perform any work on safety-related equipment or features.
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