IR 05000029/1974003
| ML20031C234 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 05/09/1974 |
| From: | Mccabe E, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20031C227 | List: |
| References | |
| 50-029-74-03, 50-29-74-3, NUDOCS 8110060657 | |
| Download: ML20031C234 (17) | |
Text
{{#Wiki_filter:q- ..... O 'o . , U.S. AT0!!IC E'.ERGY CO:011SSION , , DIRECTORATE OF REGULA'IORY OPERATIONS
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REGION I
' . v . 3 Inspection Report No: 50-29/74-03 Docket No: 50-29 .icsnsee: Yact ce Atemte E1cetric, Company License No: DPR-3 '
20 Turnpiko Rond Priority:
Westboro, inssachusetts 01581 Category: C e . 3 tion: Roue, Massachusetts ype of Licensce: PUR, 600 MWt _ rype of Inspection: Special, Announced. Training b QA
'ata of Inspectic;: April 30 through May 2, 1974 ,, etcs of Previous Inspection: March 11 through 15, 1974 __ f$ f~7#e / d[7/7'[ eporting Inspector: ,- Date ~ , W. A. Ruhlman, Reactor Inspector ' 'ce:mpanying Inspectors: p m,,, , . g [L ' Date },
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. i Jtlier Acconpanying Personnel: Date w .. . .$i? / / ,. i. (, M ' ' / 2/ J ' ,- . .., . .' . + T <cvicuedBy:kE ' , C. !!cCabe, Jr., Senior Reactor Inspector / Date - jj ' . Reactor Operations Branch S, e.
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0 . N SU) MARY OF FINDI!CS i ) (p
1l Enforcement Action - ..,Y None
Licensec Action on Previously Identified Enforcenent Items
Not inspected Unusual Occurrences . None Identified . o Other Sienificant Findings
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A.
Current Findings
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1.
Non-Deficient Areas . The following training areas / programs were inspected with no deficiencies identified.
- . a.
Radiation Protcetion Training (Detail 2b) { ' b.
First Air Training (Detail 2d) ' . c.
Plant Fire Protection Training (Detail 2e(l)) k ' d.
Welder Trairing/Q"211f' cation (Detail 4), et li1c -# Special Training - Auxiliary Operators (Detail 6) ,1$, e.
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Open Iten , The Operator Retraining Program is not required to be, nor is it, fully operational.
Th'_s item will remain open and will be ,' reinspected after the first annual examination has been adminis- . tered and graded.
(Detail 5) d ?? . 3.
Ncv Unresolved Items
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, . $ The following items, based upon codes / standards which have M'? been modified / issued subsequent to the facility license, were J~ .D, - 3 identified as unresolved items.
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Plant Security Training -(Detail 2a) r;3; ' .ly, lP l{# +T
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Quality Assurance Training (Detail 2c) b - c.
OSHA & Plant Safety Standard Training (Detail 2e(2)) ' d.
Instrutant and Control Personnel Training (Detail 4a) , l e.
Maintenance Department Training (Detail 4b) . B.
Status of Previously Unresolved Items The licensee had taken appropriate action to resolve eight (8) of the ten (10) deficiencies in the Quality Assurance Program that were identified in RO Inspection Report 50-29/73-05.
(Detail 7) Manancment Intervicg , The mana3ccent interview was held at th.e site on May 2, 1974 with the
following attendecs: Mr. H. A. Autio, Plant Superintendent Mr. W. G. Jones, Assistant Plant Superintendent g Mr. N. N. St. Laurent, Technical Assis. ant to the Plant Superintendent "g - Mr. J. L. Staub, Technical Assistant ,t - Mr. R. L. Berry, Training Coordinator hip h;j p The Folloying summ rized the items discussed: A A.
,F,ltnt Security Trqintn_g. (Detail 2a) M df B.
Radiation 'rotection Traininn.
(Detail 2b) []. C.
Quality Assurance Training.
(Detail 2c) D.
F_ir'st Air Training.
(Detail 2d) E.
Industrial Safety Traini_ng.
(Detail 2e) n , ,, s, F.
Instrument cn?. Control Personnel Training.
(Detail 3a) $. G.
Maintenance Department Training,. (Detail 3b) 4Q 7.j'I H.
Uc.Jdyr Traininn/Auglification.
(Detail 4) - 1.
Licerned Operator Training /Retrainin3 (Detail 5) ~ @1 L J.
_Special Trainir - Auxiliar,y Operators.
(Detail 6) (jp
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Previously Unresolved Items - Quality Assurance.
(Detail 7)
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Inspection Docuentation i.
The inspector noted that the licensee documented the results of the , inspection and the manar,ement interview for internal use.
The in-spector stated theit the official statement of the results of the inspection sould be contained in the inspection report.
The licen-
see acknowleJged this information.
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. . .t , - DETAILS . 1/ . 'd 1.
Persons Interviewed On Site T d Yanke-Atomic Elcetric Company y
Mr. H. A. Autio, Plant Superintendent Mr. R. L. Berry, Training Coordinator - Mr. W. D. Billings, Chemistry and Healt'1 Physics Supervisor .
- i Mr. E. G. Bolognani, Maintenance Clerk I'
Mr. R. L. Boutwell, Engineering Assistant Mr. R. P. Danck, Operations Supervisor . Mr. R. E. Durfey, Engineering Assistant P Mr. M. W. Ebert, Plant Re: etor Engineer I Mr. J. A. Flanigan, Plant I!calth Physicist Mr. R. A. Her:cg, Shif t Supervisor Mr. 'J. G. Jones, Assistant Plant S,uperintencent . Mr. P. E. Laird, Maintenance Supervisor Mr. E. A. Miles, Technical Assistant e Mr. R. C. Pettengill, Control Room Operator , Mr. E. H. Pierce, Control Room Operator Mr. L. L. Reed, Quality Control and Audit Coordinator Mr. N. N. St. Laurent, Technical Assistant to the Plant Superintendens Mr. J. H. Shippec. Instrument and Control Supervisor hr. J. L. Staub, Technical Assistant Mr. R. H. Strecter, Scorekeeper 2.
Cencral Employee Training
The inspector reviewed the training provided for regular employees - with respect to the pcrtinent requirements delinceted in 10 CFR 19, F ANSI N18.1 - 1971 and Criterion II of Appendix B to 10 CFR 50.
The following, oased spon discussiens held with and records furnished by licensee representatives, surxnarizes the inspector's findings.
a.
Plant Security Training Ncv employces receive this training as part of the indoctrin~ atlon required by the GENERAL PLA"T TRAINING FOR NEW CfPLOYEES - . M[ procedure.
All plant employees receive a rinimum of one (1) haur of train!.ng, on an annual basis, to satisfy the CENERAL PLANT TRAINING PROGRA'I requirement in this area.
]n (1) Both the initial indoctr: nation and the periodic lectures ~ j include the following:
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1-0: (a) Site Security Plan ,
(b) Security Responsibilities for Plant Personnel O (c) Emergency Security Procedures - - (d) Plant Controlled Access Arcos , 1[ (2) Participation in and subject matter covered during both
the initial indoctrination and the periodic Icetures are recorded an'd filed.
' (3) When scheduled, the periodic Icctures cover the same l' subject in two (2) Icctures scheduled on different dates / times to allow all personnel to attend.
Operations Department personnel who f ail to attend either of the two , schedulec lectures, are scheduled to attend similar i 1cetures given as part of the Rocctor Operator Retraining Program. Current practices neither identify nor. reschedule - non-operations departme,nt personnel.
(4) The curtant training program does not provide any annage-ment system whereby the effectiveness of the training is evaluated.
Licensee representatives stated that new program requirements would be incorporated to ensure that personnel from all de- , partments would be made aware of the information disseminated i at Icetures which they failed to attend, where regt. ired.
In ~ addition, the representatives srated that a method of evt.u-ation voulgl be developed, incori orated into the program, and imple=ented to provide management with reasonabic assurances that the training presented was effective.
This item is unresolved pending program cianges incorporating the licensee's ccmitments.
b.
Radiation Protection Training New employees receive this training as required by the GENERAL PLANT TRAINING FOR NEW E.MPLOYEES procedure.
All plant employees t are required by the GENEPdL PLANT TRAINING PROGRAM to receive a' minimum of three (3) hours of training in this area annually.
, (1) The indoctrination of the new employees covers: . ... (a) Basic Radiation and Contamination Control ~ a-(b) Use and Carc of Dositetry Devices
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_ _ _ M b [l-6- . ,7 r MU { (c) Use and Care of Survey Instruments "' (d) Use of Respirators - (e) Use of Protective Clo hing (f) Entrance to and Exit from the Control Area - (g) Tour of the Control Atea , !; (h) Use of the Vapor Container Personnel Hatch During Vapor Container Integrity (i) Radiation Alarm Systems and Emergency Plan Training
- (j) Health Physics Manual and Forms l (2) The training Icetures for the annual training are required to cover the Accident Eccrgency Plan and the Radiation Protection Manual. The two identical lectures given in , the month of April, 1974, are typical and are given here as an exampic of the scope and content of these lectures.
(a) 10 CFR 19, Parts 19.11, 19.12, 19.13, 19.14, 19.15 - r and 19.16 ., , ) (b) Personnel Radiation Exposure Limits ~ (c) Film Badges and Dosimeters (d) Access to the Control Area , (c) Radiction Work Permits (f)~ Access to Radiation and High Radiation Areas (g) Protective Clothfng (h) Respiratory Protective Devices (i) Access to the Vapor Container ~ (j) Smoking and Eating Regulations (k) Persennel Contamination - (1) Contaminated Lavatory Use
(m) Exit from the Control Area 'g (n) Injuries and Emergencies (3) Participation in and subject matter covered during both i ' the initial indoctrination and the periodic lectures are - recorded and filed.
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(4) Lecture attendance is reviewed and a determination is l made of the names of persons that did not attend either - Iceture.
Based on the number of people thus determined, either another lecture is scheduled or smaller / individual lpp
sessions are given to casure that all required personnel $i [i;EE ' receive the reqaired training.
M (5) The effectiveness of the training given is evaluated in . discussions ht !d at the end of the Icetures f or this pur- - g% 32g pese.
In addition, a program of monitoring individual exposure records has been implemented to verify practical ff e g -,,-, y, - -. _ -,, - __ , ,y .
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p . ' application of training aircd at reducing exposure. This ' ., department will also adopt, according to the Health ,
Physicist, an additional method, currently under develop-y~ acnt, for use in evaluating the other ocneral employee g ',. training areas.
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The inspector had no further questions in this area.
c.; [ c.
Quality Assurance Training , 2... , .. The GENERAL PLANT TRAINING FOR NEW EMPLOYEES precedure also requires training in Quality Assurance (Q/A).
In addition, . ,
the GENERAL PLNIT TRAINING PROGRAM stipulates that a mininum of three (3) hours of training will be given annually.
(1) Both the initial indoctrAnation and the periodic training - lectures cover: r (a) Quality assurance Procedures (b) Workmanship, Documentation, Personnel Attitudes .. Toward Quality Assurance
(c) Quality Assurance Manual ~ ' ' > (d) Company * Policy Towards Qulaity Assurance e ' ( 's (2) Participation in and subject matter covered during both
' initial indoctrination and periodic lectures are recorded
D and filed.
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(3) All personnel that fail to attend the Icetures are not k identified and rescheduled.
(4) The training given in this area is not evaluated to . determine its effectivcaess.
Licensee representatives stated that new program requirements would be incorporated to ensure that required personnel from f all departments either attend the lectures or receive the information disseminated at the Icetures. They also stated th'at a method of evaluation would be developed, incorporated ?, as a program requirement, and implemented to provide nanage-g, ment with reasonabic assurances that the training presented gt' was effective.
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In I addition, all of the regular guard force personnel have re-ceived this training and certification.
Since certification '
. expires after three years, recertification training is an on-i going program.
d+ 'd The inspector had no further questions in this area.
{ e.
Industrial Safety Training In addition to the training given to new employces as required by the NEW EMPLOYEE TRAINING procedure and the minimum of ten (10) hours of lectures requi, red for plant personnel under the - GENERAL PLANT TRAINING PROGRAM, regular Plant Safety Meetings are held monthly.
(1) Plant Fire Protection Training Fire Protection training is required by both the procedure ' for new employees and the one for annual training of all employees.
In addition to the lectures given, which are documented for both subject matter and attendance, the s ' plant has sponsored a one (1) day Fire Protection and f Control course taught by a vendor of extinguishers and
fire control apparatus.
It was also noted that over one-d half of the local volunteer fire department, including h the Chief and Deputy Chief, are employed as regular
members of the plant staff. A documented fire drill was furnished which indicated not only a blov-by blow descrip-tion of the events that took place but also indicated ' management review to evaluate the effectiveness. Another j firc dri11 was scheduled for after the refueling outage, w The inspector had no further questions in this aren.
e (2) OSHA & Plant Safety Standard Training ?[[b' Training in these two (2) areas is also required'by both {- the new coployee and the annual retraining procedures.
Content of and attendance at lecturet covering theue ~ h, w suljects is documented but not evaluated.
Consistent with ~ the licensee's co:riituents in the areas of Plant Security ptg and Quality Assurance Training (Detail 2a'& 2c), represent-M8 Mh J ?ahh w
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atives stated that program changes would be initiated to j eliminate the noted deficiencies.
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This item is unresolved pending impicmentation of the
licensce's commitmenta.
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Non-Li:ensed Techniciar/ Repairman Training . . The inspector reviewed the training provided for Instrument and
Control (I&C) and Plant Hechanics Electrical and Mechanic' with - y respect to the portinent requirements of ANSI N18.1 - 1971, ANSI ' N45.2.6 - 1973 as modified by Regulatory Guide 1.58, and Criterion II of Appendix B to 10 CFR 50.
The following summarizes the inspector's , findings.
_ , a.
Instrument and Control Personnel Traininc, . Based on the review of licen'ee furnished documents and dis-s
cussion held with the I6C Supervisor, currently: _- W (1) Training is conducted in this department in accordance E,1 i with a licensee approved Administrative Procedure titled
INITIAL A!D REVIEW QUALIFICATION TRAINING OF ISC PERSONNEL.
lh - (2) The training procedure requires and documents that initial- [ ly, and on an annual basis after qualification, the fol-e lowing subject areas are covered.
$ ' M (a) Plant Administrativoi Procedures k$ (b) I&C Department Administrative Proc'edu os y (c) Plant Technical Specification (pertinent to I&C) g (d) Plant Final Safety Analysis Report (pertinent to V* I6C) (c) ISC Dept. Instrument Changes (f) Plant Abnormal Occurrences (pertinent to I&C)
(g) Plant Information Reports (pertinent to I&C) 7= (h) Safety Related System Classification ? (i) I6C Work Log Book $ (j) Parts Requisitioning and Procurement Procedures Y (k) I6C Department Work Procedures y
(1) Plant Design Changes and Modifications (pertinent to fi I&C) h (m) Areas covered in the General Plant Training Program (3) In addition, the initial qualification card requires both ~ %)
training anl demonstration of knowledge on seventy-six (76) separate systems, instruments or pieces of equipment.
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3):.; ,k < y . S (4) Rotation of work assignments is donte to ensure that all - personnel qualify on all equipment. This on-the-job + ' ( rotation is accomplished by review of the I&C Work Log Book,.and assignment of jobs based upon that review.
C This proces' is not required by the program and is not documented by other than entry in the I&C Work Log.
. 8) Qualification Tests have been administered in some cases . and where completed, they are graded and filed. Although '. these tests do in fact form the basis for certification and promoti a, there is no formal certification require- + ments stipulated in clic, program.
The licensee representative acknowledged the inspector's con-cerns and stated that the Training Program was currently being reviewed for compliance with the new (late 1973) ANSI standard (N45.2.6) and that changes to the program required by that
- , standard had not yet been made. The licensee stated that when ,' these changes had been incorporated, the inspector's concerns would be clininated.
A This item is unresolved pending changes to th'c program to in-corporate the requirements of ANSI N45.2.6 - 1973.
n , l_ ' - b.
Maintenance Department Training ~ Discussions held with and documentation furnished by the ce Maintenance Supervisor and ocmbers of his staff indicate that ST currently, there is a documented training effort in progress sfj_ to train and upgrade Plant Mcchanics Electrical and Mechanical.
$ The following summarizes the inspector's findings.
% W2 (1) Current training in this department exists because of the d direction of the Maintenance Supervisor, it is not required b by a documented program.
A program incorporating current N standards was in various stages of completion but has - been delayed because of requirements placed on the depart-r ment in preparing for the upcoming refueling outage.
A g documented program, similar in scope and content to the Q IEC program, will be ap;iroved tentatively by August 30, $M - 1974.
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(2) Documented training exists in the following areas: $ .p - (a) Department personnel have participatcI in on-site h.
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' pump packing school taught by the packing vendor.
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[ (b) Personnel are qualified to perform ultra-sonic, dye penetrant and X-ray examination and testing in accordance with applicable codes and standarda.
f (c) Personnel are trained, examined and certified qualified to operate lift trucks, portable cranes. Yard and
Turlane Hall Overhi.ad Cranes.
, (d) Personnel are trained, examined, and certified 3' qualified to operate certain machine shop equipment such as: laths, drill presses, shapers, band saws and milling machines.
(3) Qualification tests are administered as follow.;: (a) A pre-employment screening test of one-hundred (100) questions.
. ' (b) Written classification tests made up of both a theo-retical and a practical performance section is , given, graded and ret ined.
- ( (4) Some employees have been involved in preparation and/or ' ' review of maintenance related plant procedures.
(5) Mechanics are given a training manual (136 page o - x , to study for job advancement.
. A , ~ %]Ao (6) Various sections of the plant Safety Manual are reviewed and discussed as well as the training which is required under the General Plant Training Program.
(7) Formal certification, with the required recertification
- f review on a periodic basic as required by current standards:
has not yet been i=plemented.
The licensec representative stated that the documented program cur-g
rently under development vould meet the current requirements of %
ANSI N18,1 - 1971 and ANSI N45.2.6.
M lb , ws This item is unresolved pending the approval and implementation of jf the proposed Maintenance Department Training procedure.
,y . 4.
Welder Traintne /0ualification ?~[h n . U.
The inspector reviewed the liccusee's records with respect to the [QdY pertinent rei;ui rene 's delineated in Section IX of the ASME ELPV Code.
No det iciem :c.. were id6 ntit ied.
The inspector had no further questions in this area.
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Licensed Operator Training /> training s' ~ . The Operator Licensing Branch of the Directorate of Licensing ,. stated, in a letter dated March 28, 1974, that the Yankee Rowe , Requalification Program submitted on December 7, 1973, the additional " information submitted March 20, 1974 and the information furnished by Mr. Eerry of the plant staff cet the requirenents of Section 50.54 (1-1) of 10 CFR 50 and Appendix A of 10 CFR 55.
. [ a.
Retraining Program Review Using the above referenced documents as the basis, the in- ' spector reviewed the licensee's documentation and action in , this area. The following su=marized his findingc.
(1) Sixty (60) lectures in the retraining scrics had been given and documented for content and attendance under the
retraining pre ; ram through Iby 2, 1974.
Of the twenty- . five (25) lic: aned operators at the f acility, thre" (3) % had just been licensed, four (4) attended most of t,he i lectures in the series and eighteen (18) had not attended
any of the lectures.
Since the first annual requalifica- ] tion examination had not yet been given, lecture attendance
is not required.
p (2) The first annual examination, required by the Retraining 3[ , Program, has been prepared and will be given, according to the Training Coordinator, after the up-cocing refueling outage is completed probably by the last week in July.
7, This examination, when grade.d, will fcrm the basis for y lecture attendance and other training mandated by the p% Rcqualification Program.
M (3) Three (3) cxaminati<m had been given as part of the yb evaluation of tht. icu aining Program. Of the four (4) i licensed operators participating in the program, on the
- r first examination (February 1, 1974) two of the four 1:
operators scored Icss than 80% on one or c: ore of the five s sections of the examination; one of the four scored less ([ than 80% cverall.
The'second cxamination (April 5, 1974) 1,Gr
consisted of six (6) sections and three of the four N licensecs scored Icss than 80*' in one or more sections; .h one licensee nade 1 css than 80% overall. The third Q examination also had six (6) sections (April 11, 1974) M ' and three of the four licer secs taking the examination gg scored less than 80% on one or core sections with two of Q the four scoring less than F0% overall.
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' special emphasis being given to the weak areas dizelosed - by the examination. The final examination in this training series is scheduled to be given on May 10, 1974.
iW ~ (4) A Training Coordinator has been assigned to administer ~ the Retraining Program.
Systems and records have been established to require / document the following items: . (a) Review of Emergency / Abnormal Procedures (b) Review of Systems, Procedures, Reports required in . the Progrca (c) Required Reactivity Control Manipulations , (d) Required Operations /On-the-job training s (e) Individual Operator Participation in the Program (f) Quizzes and Examination Results - (g) Review of Changes tp Procedures, Equipment or
Drawings 't (5) By direct questioning of two (2) licensed operators, sel etcd at roadom by the inspector, it was verified that i these two (2) operators were familiar with two (2) pro-cedures, selected at random, for which they had initialed to signify their understanding.
No attempt was made to evaluate the operators' proficiency; only their familarity with the content of the two (2) procedures selected was , verified.
. This item will rer.ain open until it has been reinspected fol-loving admidistration of the first annual examination.
p 6.
Special Trainint-Auxiliary Operators {.; r Due to the expected increase in the workload of the Health Physics @ R Department during the op-coaing refueling outage, four (4) Auxil-inry Operators were selected and given a special training course to ib' qualify them to aid the Health Physicist.
Documentation furnished by the licensee indicated that the following training has been ('.3) accc=plished.
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Classroon Instruction _ . Ten (10) nours of classroom instruction were given covering ( the following areas.
, g id (1) Yankee Rwe Co=nitment to As Low As Practicable G]h if - a h.
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< (2) Sixteen (16) Adminictrative and Health Physics Procedures (3) Use and Care of Portable Survey Meters (a) Jordan Rad Gun . (b) PIC-6A (c) E-500B
(d) R'1-14 . b.
Practical In-the-field Instruction Practical experience in the field was given which consisted of seven (7) hours of actually. conducting radiation and contcm-ination surveys, taking air sampics and using control point , counting instruments. The surveys were made in various parts
of the Control Area to duplicate conditions to be found during refueling operations.
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Problen Solving /Cr.1.culations Three (3) hours verc devoted to solving typical radiation prob 1cus in the following arcas: (1) Respirator Selection and Fitting (2) Stay Time Calculations (3) Man-Rea Calculations (4) Airborne Activity Calculations , d.
Scif Study - Approximately one (1) hour was devoted to self study which was followad by a question and answer period.
.dN The inspector had no further questions in this area.
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Previously Unresolved Items-Quality Aissurance - M
In the letter dated November 6, 1973, RO:I defined several deficien-y{ x ' cies in the Plant Quality Assurance Procedures for the operations - phase. These items were detai'cd and listed as unresolved in inspection report 50-29/73-05 which accompanied the letter.
In a l'q Ictter dated January 9, 1974 fron Yankcc Atomic Electric Company to b RO:1, steps were defined to solve the deficiencies noted in the report (73-05).
The inspector checked the implementation of the . fih klve steps defined in the letter. The following summarizes his findings. ~ @ (ff %[lr ? a.
Resolved Items - l@! !im $sh On W - _,. _ . - - .. _ . . _ _ y . ' _ _ ...... ...._....1 w_:, ..
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m' g' > Q- - v The actions defined in the letter, when implemented, were - < ' D sufficient to resolve the noted deficiency. The defined
actions.had been implemented for the following items. All . [ " DETAILS" refer to 50-29/73-05.
a-(1) Detail, Paragraph 3 ' (2) Detail, Paragraph 4b and 4e (3) Detail, Paragrapn 5
(4) Detail, Paragraph 6 (5) Detail, Paragraph 6 e M (6) Detail, Paragraph 9 (7) Detail, Paragraph 10 ,
These items are now resolved based upon your corrective actions, b.
Unresolved Items . The action defined its your letter for the following areas was either inappropriate or not yet impicmented and these items are still unresolved for the reasons indicated. Details referenced are from 50-29/73-05.
(1) Detail, paragraph 4a states tnat the procedure for making modifications to safety systems is not clear.
Your action, of extcasively revising AP-0201 was inappro-priate since this action now gives the plant two (2) ,;. proceduren for making a change to safety systems (AP-0200 Xg ~ and AP-0201) and no guidance is provided on which procedure k should now be used.
TF5 , (2) Detail, Paragraph 7 stat"d in part that AP-044 did not y[ j require work and inspection instructions. Your answer states " Procedure No. AP-044, now AP-0212 has been re-T vised to require work and inspection in accordance with reference 4, Departmental Prc,:cdurc No. DP-0600, Material i Handling, Shipping, Packaging, Cleaning, Storage and Preservation."
Your action is considered inadequate in that Departmental b Procedure No. DP-0600 has not yet bu n typed, approved or k; - issued.
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, , Discussions uith and documentation furnished by the plant . Storckeeper did indicate that operations were in fact b 4 being carried out in accordance with ANSI N45.2.2 as mod- " ified . Regulatory Guide 1.38.
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. . ments, according to the draft copy of DP-0600 shown to
the inspector, are the source docu:nents used in the pre-paration of DP-0600.
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. Items 7b(1) and 7b(2) are still unresolved.
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