IR 05000302/1981018

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IE Insp Rept 50-302/81-18 on 810831-0904.Noncompliance Noted:Training Program Did Not Provide Retraining of Security Personnel in Health Physics Requirements
ML20032D299
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 09/18/1981
From: Skinner P, Upright C
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20032D285 List:
References
50-302-81-18, NUDOCS 8111130612
Download: ML20032D299 (6)


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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA ST., N.W., SUITE 3100

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ATLANTA, GEORGIA 30303 SdP 231981 Report No. 50-302/81-18 Licensee:

Florida Power Corporation 320134th Street, South St. Petersburg, Florida 33733 Facility Name: Crystal River 3 Docket No. 50-302

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License No. DPR-72 Inspection at Crystal River site near Crystal River, Florida

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-Inspector:

P. H. Skinner 04te Sighed

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Approved by:

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C. Upriijht, Secti9n/Chie fteVigned Engineering and TMhnica nspection Division SUMMARY s

Inspection on August 31 - September 4,1981 Areas Inspected This routine, unannounced inspection involved 36 inspector-hours on site in the areas of non-licensed training, qualification of personnel, and the non-routine reporting program.

Results Of the 3 areas inspected, no violations or deviations were identified in 2 areas, 2 violations were found in one area (Failure to provide. training, paragraph 5.a, and Failure to properly store quality related records, paragraph 5.b).

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REPORT DETAILS 1.

Persons Contacted Licensee Employees W. Benoist, Catalytic

  • C. Brown, Compliance Supervisor J. Buckner, Sec'irity Of ficer
  • J. Bufe, Compliance Auditor
  • B. Crane, Planning Engineer
  • M. Harmon, Nuclear Operations Administrative Manager W. Herbert, Nuclear Technical Specification Coordinator V. Hernandez, Nuclear Compliance Auditor
  • R. Hobbs, General Physics Corporation W. Hysell, Security Training Coordinator
  • W. Kemper, Nuclear Operations Training Manager
  • K. Lancaster, Senior Quality Auditor
  • J. Lander, Maintenance Superintendent
  • S. Mansfield, Nuclear Technical Instructor
  • P. McKee, Operations Superintendent G. Perkins, Plant Health Physicist
  • D. Poole, Nuclear Plant Manager D. Stevens, Nuclear Technical Instru: tor G. Williams, Nuclear QA/QC Supervisor Other licensee employees contacted included technicians, mechanics, security force members, and office personnel.

NRC Resident Inspector

  • T. Stetka, Senio, Resident Inspector
  • Attended exit interview 2.

Exit Interview The inspection scope and findings were summ rized on Septembar 4, 1981 with those persons indicated in paragraph 1 above. The licensee acknowledgedJthe inspection findings.

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Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (302/79-23-06):

Inadequate retraining program for non-licensed personnel.

The inspector reviewed documentation of the retraining being provided for craftsmen and technicians and concluded that the training is being provided but documentation is not fully implemented.

The documentation is being ccmputerized for more accurate storage and greater flexibility in control of on-the-job training.

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Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptaale or may involve violations or devia-tions. A new unresolved item identified during this inspection is discussed

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in paragraph E.c.

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Non-licer, sed Training (41700)

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References:

(a) AI 200, Organization and Responsibility, dated 4/01 (b) AI 600, Conduct of Maintenance, dated 4/81 (c) AI 1400, Conduct of Training, Revision 6 dated 5/81 (d) ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel (e) Technical Specifications, Section 6 t

(f) MP 601, On-the-Job Training of Maintenance Shop Personnel, Revision 0 dated 12/80 (9) QC 200, Training and Qualification of Nuclear Quality

. Assurance / Quality Control Inspection Personnel, Revision 0 dated 11/79 (h) QC-201, Training of Nuclear Compliance Personnel, Revision 1 dated 7/81 (i) Accepted Quality Assurance Program - Chapter 1.7, FSAR

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The inspector reviewed the training program which provides general employee

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training and retraining for station personnel.

The training program was reviewed to verify that the program complies with commitments and

, requirements contained in references (a) through (i) and that the program covers training in the areas of general station adm'nistrative control, quality assurance policies and procedures, radiological health and safety,

-r industrial safety and first aid, hcuseker: ping and five prevention. and

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protection, emergency plan and procedures, the use of protective clothing,

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and prenatal radiation exposure training for females and supervisors.

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inspector reviewed approximately 50 training records of station personnel, participated in three hours of classroom training and interviewed six I

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individuals (no'n-licensed).

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Based on this review two violations, one unresolved item, and one inspector

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followup item were identified and are discussed in paragraph 4.a through d.

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a.

Failure to Provide Health Physics Retraining for Security Personnel.

Reference (e) requires a retraining and replacement training program for the facility staff that meets or exceeds the requirements of ANSI N18.1-1971.

Section 5.5 et ANSI N18.1 - 1971 requires a training

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program to be established to maintain the proficiency of the operating

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organization. As part of the inspection in this area, three security

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personnel records were reviewed. Of these none had received retraining

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in the Health Physics area. A discussion with security and training indic'ated that initial training had been accomplished, but a program m

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was not established to ensure retraining in this area to maintain proficiency.

Although no examples outside the security area were identified, a program to ensure all organizations required to operate and maintain the plant such as subcontractors, Florida Power l

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Cooperation (FPC) personnel, vendors. etc. should be formally l

l established and implemented. This failure to provide retraining to security personnel is a violation (302/81-18-01).

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Failure to Properly Store Quality Related Records Reference (i) states that ANSI N45.2.9 - 1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants will be met for storage of quality related records.

Training records required by references (g) and (h) are identified as permanent quality assurance records. Those records are being mantained in non-fire rated cabinets in the Nuclear QA/QC Supervisor and Nuclear Compliance Supervisor office areas.

This violation was also identified during the PAS in pection conducted in February, 1981.

This failure to provide required storage for QA related records is a violation (302/81-18-02).

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Lack of Documentation of Training and Retraining 10 CFR 50, Appendix B, Criterion XVII requires records of qualification of personnel be maintained. The inspector reviewed 45 general employee training records. Twelve of these records indicated that all required training was not being documented. The training was being performed, however documentation was not available to substantiate this training.

Discussions with these personnel determined that the training was attended by tre individuals concerned. The Training Manager informed the inspector that FPC is in the process of transferring documentetion of all general employee training to a microfiche system which will provide required documentation of the training and retraining program.

Previous inspections (Inspection Reports 79-23, 80-30, and 81-02) had identified a lack of on-the-job training and documentation of this training for nonlicensed craft personnel. It appears that training is being provided in this area and some documentation is available to support this finding. This is presently being documented in accordance with requirements contained in reference (f).

Discussions with the Maintenance Superintendent indicated that FPC is in the process of revising reference (f) to incorporate this information into a computer system to more efficiently control and document this requirement.

Based on the inspector's consersations with the Training Manager and Maintenance Superintendent and the commitment to have all training records entered into the microfiche system and this system in e w by r

January 1,1982, this item will be categorized as unresolved p subsequent inspections of this area (302/81-18-04).

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Expiration of Certification of Quality Control Inspectors Reference (g), section 6.3.1 requires successfu' completion of required training be documented on a qualification certificate. Certification forms indicate that the certification remains effective for a period of one year.

A review of three quality control inspectors records indicate this certification had exceeded the one year period without recertification being accomplished.

A discussion with the Nuclear QA/QC Supervisor indicated that these personnel have been actively performing QC inspections and that this was an oversite on the part of the supervisory personnel. This area will be reviewed in a subsequent inspection and is identified as an inspector followup item (302/81-18-03).

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Qualification of Personnel (36701)

References:

(a) Technical Specifications, Section 6.3, Facility Staff Qualification (b) ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel (c) Regulatory Guide 1.8, Personnel Selection and Training, September 1975 The inspection verified by review of administrative controls that minimum educational, experience and/or qualifications have been established for the following plant positions:

Nuclear Operations Superintendent, Assistant Plant Manager, Nuclear Maintenance Superintendent, Chemi stry/ Radiation Protection Manager, Nuclear Technical Services Superintendent, Nuclear Technical Specifications Coordinator, Nuclear Modification Specialist, Nuclear Reactor Specialist and Nuclear Maintenance Staff Engineer.

The inspector also reviewed the qualifications of approximately ten additional personnel in positions below the plant supervisory level.

Based on this review, no viclations or deviations were identified.

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Nonroutine Reporting Program (90714)

References:

(a) CP-111, Procedare for Documenting, Reporting, and Reviewing Nonconforming Operations Reports, Revision 18 dated 7/81 The inspector reviewed reference (a) to verify that administrative controls for nonroutine reporting events meet the following criteria:

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Controls have been established for the prompt review and evaluation of off-normal events to assure identification of safety related events

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Controls have been established for the promot review of planned and unplanned maintenance and surveillance testing activities to assure identification of prospective or actual violations of limiting condition for operation requirements o' the Technical Specifications

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Controls have been established for reporting safety-related events

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internally and to the NRC Controls have been established for completion of corrective actions

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relating to safety-related operating events Controls contain provisions for recognition and reporting of events

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that are covered by 10 CFR Part 21 Responsibility for implementing these administrative controls has been

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established The inspector also reviewed the licensee's program for handling NRC and vendor circulars and bulletins.

Based on this review, no violations or deviations were identified.