ML20062J673

Ack Receipt of 820601 & 25 Ltrs Re IE Insp Repts 50-327/82-05 & 50-328/82-05.Corrective Actions Re Violation a Will Be Examined at Later Date.Violation B Designated Unresolved Item.Response Requested within 20 Days

ML20062J673
Person / Time
Site:	Sequoyah
Issue date:	08/09/1982
From:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Parris H TENNESSEE VALLEY AUTHORITY
Shared Package
ML20062J676	List: IR 05000327/1982005 ML20062J673 ML20062J714 ML20062J780 ML20062J839 ML20062J885
References
NUDOCS 8208160436
Download: ML20062J673 (4)

See also: IR 05000327/1982005

Text

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N 0 9 1982

Tennessee Valley Authority

ATTN: Mr. H. G. Parris

Manager of Power

500A Chestnut Street Tower II

Chattanooga, TN 37401

Gentlemen:

Subject: Report No

7/8

and 50-328/82-05

This is response to your letters dated June 1 and 25,1982 in which you discussed

certain violations brought to your attention in the Notice of Violation with our

letter of April 20, 1982.

Your actions to correct Violation A and to prevent its recurrence will be

examined during future inspections of your program.

Your denials of Violations B and C have been evaluated by our staff as shown in.

the enclosure to this letter.

For the reasons presented in the enclosure, we

have concluded that Violation B should be withdrawn and designated an unresolved

item pending further NRC inspection.

However, we have also concluded that

Violation C is valid as stated in the Notice of Violation enclosed with our

letter of April 20, 1982. Therefore, as required by 10 CFR 2.201, please submit

to this office, within twenty days of the date of this letter, a written response

including corrective steps which have been taken for Violation C, corrective

steps which will be taken to avoid further violations, and the date when full

compliance will be achieved.

In accordance with 10 CFR 2.790(a), a copy of this letter and its enclosure will

be placed in the NRC Public Document Room.

The response directed by this letter is not subject to the clearance procedures

of the Office of Management and Budget as required by the Paperwork Reduction Act

of 1980, PL 96-511.

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Should you have any questions concerning this letter, we will be glad to discuss

them with you.

Sincerely,

Richard C. Lewis, Director

Division of Project and

,

Resident Programs

Enclosure:

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(See Page 2)

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Tennessee Valley Authority

AUG 0 9 1982

2

Enclosure:

Evaluation

of Licensee Response

cc w/ enc 1:

H. J. Green, Director of

Nuclear Power

G. G. Stack. Project Manager

C. C. Mason, Plant Superintendent

J. F. Cox, Supervisor, Nuclear

Licensing Section

M. J. Burzynski, Project Engineer

H. N. Culver, Chief Nuclear

Safety Review Staf f

bcc w/o enc 1:

NRC Resident Inspector

Document Management Branch

State of Tennessee

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Enclosure

Evaluation of Licensee Response

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1.

The licensee denied Item B of the Notice of Violation which stated that

retraining had never been conducted and provided evidence to support the

contention that such training had been conducted.

In retrospect, Region II

believes that the citation was not clearly articulated and thus implied a

,

scope beyond what was intended.

Specifically, the violation related to

substantive changes which had been made in the quality assurance program

through Revision 4 to the approved program (TVA-TR75-1A) which affect the

following General Employee Training (GET) segments:

The course objective of GET 4 is to familiarize personnel with the

a.

purpose and meaning of QA/QC, the TVA organizations having QA/QC

responsibility, and the objectives and methods of implementing the

total QA program.

Revision 4 to TVA-TR75-1A modified existing

,

responsibilities

and

added

new

responsibilities

for program

implementation.

b.

The course objective of GET 5.1 is to familiarize personnel with

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requirements for preparation, review, approval, distribution, and

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revision of plant documents.

Revision 4 modified various respon-

sibilities and controls regarding procedures,

instructions, and

drawings.

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c.

The objective of GET 14.1 is to familiarize personnel with the

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procurement of materials, components, and spare parts and with

preparation of purchase requests. Revision 4 modified responsibilities

for the determination of type and extent of supplier evaluations, for

inspection and surveillance at vendor facilities, and for receipt

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inspections.

It should also be noted that procedure AI-14 which implements Section 17.2.2

,

of the approved QA program requires the assistant plant manager to evaluate

,

the GET program annually and recommend any required retraining.

The

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documents provided by the licensee in their response indicates that the most

recent evaluation of the GET program performed by the Assistant Plant

Manager was conducted in November 1980 and that evaluation did not appear to

address retraining.

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Notwithstanding the above, and in view of both the ambiguity of the

violation and the information submitted by the licensee regarding other

segments of the GET retraining program, we conclude that the violation

should be withdrawn and designated an unresolved item pending further NRC

'

inspection in this area.

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DB 0 9 C82

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Enclosure

2

2.

The licensee denied Item C of the Notice of Violation stating that they

,

believed their program which includes training of engineers and general

,

foremen in the QA requirements and the instruction of temporary employees to

always follow appropriate procedures when performing quality-related work

'

ensures compliance with the intent of 10 CFR 50, /ppendix B, Criterion II.

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The licensee further stated that temporary craftsmen are trained to follow

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procedures and the quality-related work they do is performed in accordance

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with written approved procedures or instructions containing appropr"te

quality control holdpoints for inspection.

Finally, the licensee stated

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that the cognizant engineer reviews the completed work to ensure that all

required inspections and holdpoints have been observed and completed.

With regard to the assertion that temporary employees work under the

supervision of engineers and general foremen who have been trained in QA

requirements, it should be noted that the inspection disclosed that two of

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six outage foremen and nine engineers and supervisors in the outage group

had received some, but not all, of the training specified in administrative

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instruction AI-14.

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The licensee has established an excellent training program for permanent

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craftsmen at the Sequoyah site to ensure their knowledge of the

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adminisrative, quality, and safety aspects of their assigned position. In

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that outage craftsmen perform essentially the same function as permanently

.

assigned craftsmen, it is appropriate and necessary that they receive the

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same training. The latest industry standard on this subject, ANS 3.1-1981

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supports the position that temporary employees must be trained in all areas

where their activities could affect the quality of an operating nuclear

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power plant.

Moreover, Procedure N79A7, Nuclear Plant General Employee

.

Training Program, in the Division of Nuclear Power Procedures Manual

specifically includes temporary and field services personnel in the training

program.

Finally, tne licensee's contention that outage craftsmen are instructed to

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follow procedures which contain appropriate instructions and holdpoints for

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inspection and that their work is inspected and reviewed, is not persuasive.

The same is true of permanently assigned craftsmen and the licensee has not

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argued, nor would the NRC accept, that such limited training would satisfy

the intens of Criterion II of 10 CFR 50 Appendix B.

Likewise, the NRC does

not accept the premise that quality can be inspectea or audited into the

work; the primary responsibility for quality must be placed on the

'

individual performing the activity af fecting quality and that individual

must be trained to carry out that responsibility.

Therefore, we conclude that the violation is valid as written in the Notice

of Violation.

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