IR 05000324/1979022

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IE Insp Repts 50-324/79-22 & 50-325/79-22 on 790607-08. Noncompliance Noted:Failure to Follow Procedure TI-200, Paragraph 7.b
ML19275A700
Person / Time
Site: Brunswick  Duke Energy icon.png
Issue date: 07/05/1979
From: Jenkins H, Kuhlman W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19275A677 List:
References
50-324-79-22, 50-325-79-22, NUDOCS 7910180137
Download: ML19275A700 (8)


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Report Nos. 50-324/79-22 and 50-325/79-22 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, North Carolina 27602 Facility Name:

Brunswick Steam Electric Plant, Units 1 and 2 Docket Nos.56-324 and 50-325 License Nos. DPR-62 and DPR-71 Inspection at Brunswick Site near Southport, North Carolina Inspectors:

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W. A. Ruhlman Date Signed

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b*I'1-]l H. Jenkinsf Date Signed

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Approved ty:

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W. A.

hlman, Acting Section Chief, RONS Branch Date Signed SUMMARY Inspection on June 7-8, 1979 Areas Inspected This routine, announced inspection involved 23 inspector-hours onsite in the areas of non-licensed personnel training and retraining, licensed operator requalification training, licensee response to IE Bulletins 79-08 and 79-10.

Results Of the three areas inspected, no apparent items of noncompliance or deviations were identified in two areas; one apparent item of noncompliance was found in one area (deficiency - failure to follow procedure TI-200, Paragraph 7.b).

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DETAILS 1.

Persons Contacted Licensec Employees

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  • D. Allen, Quality Assurance Supervisor
  • K.

Enzor, Administrative Supervisor

  • C. Gibson, Technical and Administrative Supervisor
  • M. Jones, Project Engineer
  • E. Norwood, Training Coordinator
  • D. Novotny, Plant Security Specialist
  • J. Powell, Security Chief (Burns Security)
  • C. Rose, Jr., Operational Quality Assurance Specialist
  • A. To11ison, Jr., Plant Manager Other licensee employees contacted included craftsmen, technicians, operators, mechanics and office personnel.

Other Orgar ;zations NRC Security Inspectors

  • K. Besecker, Security Inspector (Exit only)
  • C. Perny, Security Inspector (Exit only)
  • Attended exit interview.

2.

Exit Interview The inspection scope and findings were sumarized on June 8, 1979, with those persons indicated in Paragraph I above. Dates for the completion of action on Open Items were given as stated in the cppropriate paragraphs of this report by the Plant Manager.

With respect to the item of noncompliance discussed in Paragraph 7.b, and the unresolved items discussed in Paragraphs 6.b, 6.c, and 6.d, the Plant Manager acknowledged the inspectors' findings.

3.

Licensee Action on Pret tous Inspection Findings Not inspected.

4.

Unresolved Items Unresolved items are matters about which more information is required to s.etermine whether they are acceptable or may involve noncompliance or deviations.

New unresolved items identified during this inspection are discussed in Paragraphs 6.b, 6.c, and 6.d.

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Open Items

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Open items, as utilized it. this report, are items for which corrective action has been established and completion dates have been assigned.

Further evaluation is required before a finding of acceptable implementation can be made.

Open items are discussed in Paragraphs 6.e, 7.c, 7.d, 8.b, and 8.e. identified during the 6.

Training and Retraining Programs: Non-licensed Plant Personnel References:

a)

TI-101, Related Technical Training and On-the-Job Training Revision 1, dated 2/77for Instrumentation and Control Technicia b)

TI-012, Related Technical Training and On-the-Job Training for Mechanics, Revision 0, dated 2/77 c)

TI-300, General Employee Training, Revision 2, dated 1/78 d)

TI-301, New Employee Oriectation Program, Revision 4, dated 2/78 e)

TI-001, Brunswick Plant Training, Revision 1, dated 10/77 f)

TI-100, Retraining and Replacement Training for Non-licensed Operating Personnel, Revision 1, dated 3/77 g)

QAI-1, Qualification of Inspection Personnel, Revision 2, dated 6/76 h)

QAI-2, Training Requirements for BSEP QA Surveillance Personnel, Revision 0, dated 9/75 i)

TI-104, Related Technical Training and On-the-Job Training for Auxiliary Operators, Revision 0, dated 10/77 Review Conducted a.

There were no changes made to the licensee's training procedures since the last inspection of this area.

maintaining the implementation of the licensee's commitments were: Area to (1)

General employee training for new employees (2) General employee retraining (3) Temporary employee training (4) On-the-job training for:

personnel; and technical staffauxiliary/ craftsmen; technicians; QA/QC The inspector reviewed training records for two individuals in each category above to verify that the described training program was provided.

The inspector interviewed one employee from each category above to verify that which was documented in the training records.the individual actually received

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As a result of this review, three unresolved items (Paragraphs 6.b, 6.c, and 6.d) and one open item (Paragraph 6.e) were identified.

b.

Inadequate Definition of Non-licensed Personnel Training Guidelines The training program for non-licensed personnel was identified as being

- inadequate in that established guidelines and procedures did not direct the training program to a definitive completion. ANSI N18.7-1976, as committed to by CP&L's accepted QA Program, Paragraph 3.3 states:

" Provisions shall be made for indoctrination and training of those personnel in the owner organization performing activities affecting quality to assure that suitable proficiency is achieved and maintained

." Furthermore, TI-101 and TI-102 require submission of reports

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from supervisors of Mechanical and I&L Maintenance indicating completion of Task Analysis Sheet items.

Based upon personal interview of shop foremen, the inspector identified no participation by supervisory per-sonnelin completing the above mentioned reports. The Training Coordinator produced some reports made by departmental training personnel, but stated that the requirements for completion of a Task Analysis Sheet item were undefined; therefore, not utilized to direct departmental supervision in the requirements necessary for individuals to achieve proficiency upon a given subject. This same deficient item was identified by licensee audit, item OQAT.-79-2.

Until the training plan for maintenance personnel is revised to estab-lish specific training objectives and each item's completion requirements are clearly defined, this item (324-325/ 79-22-02) is unresolved.

c.

Lack of a Specific Training Plan For Electrical Maintenance During his review of the referenced procedures, the inspector identified the lack of a training plan for electricians.

Presently, the newly created electrical classification is being included in I&C maintenance training which covers some relative items, but does not specifically address a training plan for electricians.

Until the licensee develops, reviews, and approves a training plan for electricians, this item (324-325/79-22-03) is unresolved.

d.

Incomplete QA/QC Departmental Tr."ning The inspector reviewed the QA/QC Departmental training plan and reviewed the records for each individual. Based upon his review the inspector identified three areas in which training or documentation was being neglected as require _d by QAl-1, QAI-2, and QAI-3. These areas are:

Docementation of indoctrination of two new personnel was incomplete

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Personnel employed since 6/76, 9/76 and 3/77 have not completed

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reading requirements which should only take a maximum of 1 year by procedure to complete.

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Two personnel did not receive job performance evaluations on the

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two year required frequency.

These items have been previously identified by the licensee as audit item OQAS-37, dated January 23, 1979.

-Until the QA/QC Department implements the training plan documented in procedures QAI-1, QAI-2 and QAI-3, this item (324-325/79-22-04) is unresolved.

e.

Inadequate Documentation of Measures to Ensure Timely Corrective Action The inspector identified an incomplete method for ensuring that items identified by licensee audit were being acted upon promptly and correctly.

There were no audit items outstanding. The inspector reviewed the area with the QA Supervisor and determined that the projected method of ensuring prompt corrective action on audit findings appeared adequate.

Until the licensee documents the measures necessary to ensure timely corrective action as orally described to the inspector, this item (324-325/79-22-05) is open. The Plant Manager committed to completion date of June 15, 1979, for this item.

7.

Licensed Operator Requalification Training References:

a)

TI-200, Brunswick Plant Operator Retraining Program, Revision 3 dated 10/2/78 and Appendix A dated May 23,

1974 a.

Review Conducted There were no changes made to the lice 2e's requalification program since the last inspection of this area The implementation of the accepted requalification training program was reviewed to assure the licensee has: prepared a schedule for conducting lectures; prepared lesson plans or equivalent for three lecture topics reviewed; included material in the requalificatica lecture series on subjects identified as deficient by evaluation of the annual examinations. The inspector determined which licensed operators:

failed all or portions of the annual examinations; received unsatisfactory performance evaluations; did not perform licensed duties for a period of four months or longer.

The inspector verified the completion of appropriate follow-through action for all or a representative sample of these individuals. The inspector reviewed the training records for six (6) NRC licensed personnel to verify that each included:

copies of annual written examinations and the individual's responses; documentation of attendance at all required lectures; documentation of required control manipulations; the results of performance evaluations; documentation of required additional training to satisfy deficient performance; documentation of completion of required procedure reviews and/or self study. Additionally, 1185 031

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-5-he inspector interviewed three (3) licensed personnel to' verify that the training records reflect the actual training received.

As a result of this review, one item of noncompliance (Paragraph 8.b)

and two open items (Paragraphs 7,c and 7.d) were identified.

b.

~ Failure to Follow Procedure TI-200 As required by Technical Specification 6.8.1, procedures must be written and implemented. During discussions with plant orerators, the inspector determined that Appendix A to procedure TI-200 was not being implemented in the area of requalification lectures. The Appendix requires (page A-1) " formal classroom lectures". During the interview the inspector found that personnel were sometimes given problems to work without any instraction or with no instructor available in place of the required lectures. Subsequent discussions with personnel in the training department revealed that, during the 8 lecture series conducted for the 1978 requalification program, the radiation protection series was conducted with no instructor present for 90% of the time, the general and specific operating characteristics areas were conducted with no instructor present for 50% of the time, and the instrumentation area was conducted with no instructor present for 20% of the time.

This failure to follow procedure TI-200, Appendix A, is an item of noncompliance (324-325/79-22-01).

c.

Updating of TI-200 The current revision of TI-200, Reference (a), does not clearly specify the method and criteria for evaluation of personnel during actual or simulated emergency or abnormal conditions. The licensee stated that TI-200 would be revised by August 1, 1979, to rectify the nonspecific guidance currently used.

Until the procedure has been revised and reviewed, this item (324-325/

79-22-06) is open.

d.

Completion of Grading of Examinations As a result of deficient areas identified on the annual examination, lecture series were conducted in the period September 20, 1978, through October 3, 1978. The end-of-course examinations given had not been graded as of June 8, 1979. The licensee stated that all examinations would be graded by June 15, 1979.

Until the examinations have been graded, this item (324-325/74-22-07)

is open.

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8.

Licensee Response to IE Bulletins 79-08 and 79-10

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Review Conducted The inspectors conducted a review of licensee actions to verify the effectiveness of operator training conducted in response to IE Bulletins 79-08 and 79-10. The inspectors reviewed:

management controls imple-mented to incorporate plant modifications into the operator training and requalification programs; management controls icplemented to incorporate the operational knowledge gained from the Three Mile Island incident into the operator training and requalification programs; management controls implemented to increase the standard of operator knowledge rewired in the area of plant transient responses; management controls implemented to assess the effectiveness of the training conducted, including, but not limited to, auditing of training presenta-tions, examination content, and examination grading. The inspectors interviewed reactor operators and senior reactor operators to establish the operators' subjective evaluations of the effectiveness of training received in conjunction with incidents at the same or other facilities.

As a result of the review, two open items were identified as documented in Paragraphs 8.b and 8.c below.

b.

Dissemination of Information Although the licensee currently has a Night Order Book for passing along pertinent information to operators, no method currently exists for the formal selection of matdial to be included.

Further, no individual (s) is(are) currently assigned responsibilit" for the review of material coming into the plant (LER's, curr.nt expericace reports, NSSS letters, industry publications) from various sources to select material which has significance to oper.tions and other personnel working at Brunswick Steam Electric Plant.

There is also no formal system for d is semina tion of information to non-operations department personnel.

The licensee stated that responsibilities would be assigned, criteria for selection and mechanism for dissemination developed, and written procedures developed to cover this area by September 1,1979.

Until the licensee's actions have been completed and reviewed, item (324-325/79-22-08) is open, this Completion of Training and Evaluation c.

for personnel within 10 days.In complying with IE Bulletin 79-08, the Because information available at that time has subsequently been revised and/or updated, the licensee planneo to conduct additional training in this area.

Because all training had not been given, no evaluation examination had been given as of June 8, 1185 033

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1979. The licensee stated that the required training to update initial information and the evaluation of that training would be completed by September 1,1979.

Until the licensee's actions have been completed and reviewed, this item (324-325/79-22-09) is open.

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