IR 05000354/1986057

Safety Insp Rept 50-354/86-57 on 861201-04.Violation Noted: Failure to Follow Procedure to Authorize,In Writing, Deviation of Acting Chemistry Engineer from Ansi/Ans 3.1-1981 Qualification Requirements

ML20207N080
Person / Time
Site:	Hope Creek
Issue date:	01/06/1987
From:	Kottan J, Pasciak W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20207N067	List: IR 05000354/1986057 ML20207N065 ML20207N076
References
50-354-86-57, NUDOCS 8701130438
Download: ML20207N080 (6)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-354/86-57 Docket N License No. NPF-57 Category B Licensee: Public Service Electric and Gas Company 80 Park Plaza }

Newark, New Jersey 07101 Facility Name: Hope Creek Generating Station Inspection At: Hancock's Bridge, New Jersey Inspection Conducted: December 1-4 1986 _

Inspectors: 'J G- M .

/ r-!67 l J.J Kot an,ifa lation Latbratory Specialist / fate Approved by: ' -

k1b/J h CL A ~

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W.J.PaQiak, Chief Date EffluentV Radiation Protection Section

Inspection Summary: Inspection on December 1-4, 1986 (Report No. 50-354/86-57).

f Areas Inspected: Special, unannounced safety inspection in response to Region I allegation RI-86-A-0130. The. allegation stated that most chemistry supervisors were incompetent and unqualified, and chemistry department training is poor and inadequat Results: One violation was identified-failure to follow a procedure. The allegation was not substantiate DOhkhh0h$54 PDR l

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Details

1. Individuals Contacted i Principal Licensee Employees

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• R. Salvesen, Hope Creek General Manager l E. Galbraith, Acting Chemistry Engineer l

• J. Lovell, Radiation Protection / Chemistry Manager

• P. Krishna,. Assistant to Hope Creek General Manager

• A. Giardino, Station QA Manager A. Garrison, Nuclear Training Supervisor-Chemistry T. Vannoy, Chemistry Senior Supervisor R. Wold, Chemistry Supervisor J. Fortenberry, Chemistry Technician R. Quinn, Chemistry Technician B. Evans, Chemistry Technician L. Wenrick, Chemistry Technician

• denotes those present at the exit interview The inspectors also talked with and interviewed other licensee personnel, including members of the chemistry and training department staff . Organization and Management The inspector reviewed the licensee's organization and management structure with respect to the criteria contained in:

-FSAR Chapter 13, Conduct of Operations-Technical Specifications, Section 6, Administrative Controls-ANSI /ANS-3.1-1981, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants-ANSI N18.7-1976/ANS 3.2, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants-NUREG 0731, Guidelines for Utility Management Structure and Technical Resources (Draft), March 198 The licensee's chemistry department consists of a Chemistry Engineer, Senior Supervisor, Supervisors, and Technicians. The position of Chemistry Staff Engineer is also included in the organization. The Chemistry Engineer is responsible for the operation of the Hope Creek Chemistry Department and reports to the Radiation Protection / Chemistry Manager. Within the Chemistry Department, the Technicians report to the Supervisors, who report to the Senior Supervisor, who reports to the Chemistry Engineer. The Chemistry Staff Engineer reports directly to the Chemistry Enginee .

3 Station Administrative Procedure SA-AP.ZZ-022(Q), Station Organization and Operating Practices, which implements the requirements of Section 6 of the Technical Specifications, requires the Chemistry Engineer to meet the qualifications contained in ANSI /ANS-3.1, 1981, Section 4.4.3. Section 4.4.3 of ANSI /ANS-3.1, 1981 also contains qualification for the individual who temporarily replaces the Chemistry Engineer. In addition, SA-AP.ZZ-022(Q) requires that the Chemistry Senior Supervisor and Chemistry Supervisors meet the qualifications contained in ANSI /ANS-3.1, 1981, Section 4.3.2 There are no qualification requirements in SA-AP.ZZ-002(Q) for the Chemistry Staff Engineer. However, a Chemistry Department administrative procedure, CH-AP.ZZ-014(Q), Chemistry Personnel Qualification and Training, which was written to supplement the station administrative procedurees, requires the Chemistry Staff Engineer to meet the same qualifications as the Chemistry Senior Supervisor and Chemistry Supervisors as stated above. Based on a review of appropriate documentation, as well as discussions with licensee personnel, the inspectors determined that the Chemistry Senior Supervisor and Chemistry Supervisors met the required ANSI /ANS-3.1, 1981 qualification requirements, and, in fact, exceeded the requirements. The Chemistry Staff Engineer met the requirements of CH-A.ZZ-014(Q), and again exceeded the requirements by a wide margi The Chemistry Engineer position is currently vacant and is being filled on an acting bases. The Acting Chemistry Engineer does not meet the qualification requirements of ANSI /ANS-3.1, 1981 for the individual temporarily replacing the Chemistry Engineer. Licensee management stated that they were aware that the Acting Chemistry Engineer did not meet the ANSI /ANS-3.1, 1981 qualification requirements, but that a consultant, who was qualified, was hired to assist the Acting Chemistry Enginee Furthermore, the licensee stated that an evaluation of the Acting Chemistry Engineer by the General Manager to authorize a deviation from the qualification requirements, as required by SA-AP.ZZ-014(Q),

Station Personnel Qualification and Training, was not performed because of the presence of the consultant chemist. The inspector noted that although the consultant chemist was on site, organizational charts did not reflect his presence in the chemistry department management organiza-tion. The Acting Chemistry Engineer was the responsible technical-professional person in the chemistry department. The inspector stated that the failure to authorize a deviation from the qualification require-ments for the Acting Chemistry Engineer as required by procedure SA-AP.ZZ-014(Q) was a violation of Section 6.8 of the Technical Specifica-tions. (354/86-57-01) The General Manager stated that the authorization would be generated as required by procedure SA-AP.ZZ-014(Q). This will document in writing that the Acting Chemistry Engineer possesses the combined education, experience, and managerial competency sufficient to ensure adequate performance of designated responsibilities without de-grading the staff overall qualification ~

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3. Qualification Program The inspectors reviewed the licensee's chemistry technician qualification program with respect to the criteria contained in:

-FSAR Chapter 13, Conduct of Operations-Technical Specifications, Section 6, Administrative Control ANSI /ANS-3.1, 1981, American National Standard for Selection, Qualification and Training of Personnel for Nuclear Power Plants The licensee's chemistry technician qualification program is detailed in procedures CH-Ap.ZZ-014(Q), Chemistry Personnel Qualification and Train-ing, and CH-TP.ZZ-001(Q), Chemistry Department Training Program. These procedures require the chemistry technicians to qualify on specific pro-cedures, apparatus, and systems. In order to qualify in a specific area, the technician must complete both a knowledge requirement, which is dem-onstrated by written and oral exams, and a practical requirement, which is demonstrated by performance, simulation, or discussion as applicable. The Senior Chemistry Supervisor maintains a technician qualification matrix for tracking the progress of each technician through the qualification progra Based on a review of qualification records for selected technicians, as well as interviews with both technicians and supervisors, the inspectors noted the following: Written examinations appear to test the stated knowledge requirements; grading of the exams is consistent and fai . The required knowledge and practical aspects of each qualification area appear to adequately' cover the job task such that the techni-cians can use the applicable procedure to complete a specific job tas . Chemistry technicians stated that the qualification program is adequate for the tasks they are required to perform. All of the interviewed technicians stated that they were not uncertain in performance of their jeb tasks and felt comfortable in performing t isks for which they were qualified.

l Chemistry supervision stated that the qualification program was ad-equate, and the product of the qualification program was a technician who could complete a specific job task using the appropriate pro-cedure The inspectors determined that the chemistry technician qualification program meets the requirements of the licensee's Technical Specifications

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and also meets the licensee's FSAR commitmentss l

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4. Training Program The inspectors reviewed chemistry technician training pregram schedules, lesson plans, training procedures, chemistry personnel training files, including examinations taken, and completed laboratory assignments. The inspectors interviewed Nuclear Training Department personnel responsible for chemistry training; toured the training facilities related to chemistry training including the chemistry laboratory, count room, and classroom; and observed a radiochemistry class in progress in the count room. In addition, the inspectors interviewed selected Hope Creek chemistry personnel including one supervisor and four technician As a result of the document reviews, training facility tours, and personnel interviews, the inspectors noted the following: Chemistry apprentice technician training is 6 months in duration and includes:

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basic math instruments and controls chemistry plant systems electronics Chemistry technician training is 12 months in duration and includes advanced topics in the above listed subject . Chemistry technicians attend 2 weeks of continuing training per yea . Lesson plans and laboratory assignments appear to be complete, detailed, and adequately cover the range of job tasks and systems familiarization chemistry personnel utilize in the fiel . Examinations appear to test the stated lesson plan objectives; grading of exams and labs appear to be consistent and fai . Chemistry training facilities, specifically the laboratory and count room, are well equipped with instrumentation that is the same or similar to that used in the station laborator Station procedures are used in trainin , Chemistry technicians interviewed, stated that training received was adequate for them to feel comfortable in performing their job duties; a few expressed a desire for more systems training and to have systems walkdowns in the plant integrated into the systems trainin Training department personnel indicated that both of these sugges-tions are being implemented for future classe . The supervisor interviewed, stated that he felt chemistry personnel working for him received adequate training and he was comfortable in putting them in the fiel , _ - . - . _ _ ._ __ __ _

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The inspectors determined that training for chemistry technicians is comprehensive and complete and meets the requirements of the licensee's Technical Specifications and also meets the licensee's FSAR commitment , Exit Interview The inspector met with the licensee representatives denoted in Section 1 at the conclusion of the inspection on December 4, 1986. The inspector summarized the purpose, scope and findings of the inspectio >

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