L-97-319, Responds to Violations Noted in Insp Repts 50-335/97-11 & 50-389/97-11.Corrective Actions:Implemented New Set of Maint/Training Policies,Issued Interim Controls Ltr Stating Mgt Expectations & Revised Procedure Adm 08.02
| ML17229A556 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/19/1997 |
| From: | Plunkett T FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-335-97-11, 50-389-97-11, L-97-319, NUDOCS 9712240082 | |
| Download: ML17229A556 (5) | |
Text
c:CATEGORY 1 REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)
ACCESSION NBR:9712240082 DOC.DATE: 97/12/19 NOTARIZED: NO FACIAL:50,-335 St. Lucie Plant, Unit 1, Florida Power 8 Light Co.
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- 50-3'89 St. Lucie Plant, Unit 2, Florida Power
& Light Co.
AUTH.NAME AUTHOR AFFILIATION PLUNKETT,T.F.
Florida Power
& Light Co.
RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)
DOCKET N 05000335 05000389
SUBJECT:
Responds to violations noted in insp repts 50-335/97-11 50-389/97-11.Corrective actions:implemented new set of Maint/Training policies, issued interim controls lte stating mgt expectations
& revised procedure ADM 08.02.
DISTRIBDTIOE CODE:
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TITLE: General (50 Dkt)-Insp Rept/Notice of Violation Response NOTES:
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N NOTE TO ALL "RIDS" RECIPIENTS:
PLEASE HELP US TO REDUCE WASTE. TO HAVE YOUR NAME OR ORGANIZATION REMOVED FROM DISTRIBUTION LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)
ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED:
LTTR 20 ENCL 20
December 19, 1997 L-97-319 10 CFR $2.201 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555 Re:
St. Lucie Units 1 and 2 Docket Nos. 50-335 and 50-389 Reply to a Notice of Violation By Florida Power &Light Company (FPL) letter L-97-291, dated December 10, 1997, FPL responded to violations A, B, and C of'the subject inspection report. In a telephone conversation with Kerry Landis, Region IIBranch Chief, on December 10, 1997, FPL was granted an extension for the response to violation D. FPL committed to respond to violation D on or before December 23, 1997..
FPL agrees that administrative procedure ADM08.02, Conduct of Maintenance, Revision 15, was weak in that itcould have permitted de facto job task qualification, in lieu offullqualification, under the established systematic approach to training for Maintenance job task qualification.
Nonetheless, FPL has not identified any occurrences ofviolating or circumventing the systematic approach to training by Maintenance personnel in the field based upon a review of work control and corrective action documents, and interviews with Maintenance supervisors. Plant procedure ADM08.02 has been revised to address the weakness. However, FPL believes that sufficient training and qualification records are, and have been, maintained for all personnel participating in the plant's training programs since plant procedure ADM08.02 was not intended to be used to conduct training and establish personnel qualifications.
Please contact us with questions on the enclosed violation response.
Very truly yours, Thomas F. Plunkett President Nuclear Division TFP/JAS/EJW Attachment
< g>I cc:
Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St. Lucie Plant 97i2240082 97i2i9 PDR ADQCK 05000335 8
PDR an FPL Group company llllllllllllllllllllllllll IIIIIIIIIIII
I, L-97-319 Attachment Pug&
10 CFR 50.120(b)(1) requires, in part, that training programs for instrument and control technicians, mechanical main'tenance personnel, and electrical maintenance personnel be established, implemented and maintained using a systems approach to training as define'd in 10 CFR 55.4, including, in part, an evaluation oftrainee mastery based on learning objectives describing desired task performance.
10 CFR 50.120(b)(2) requires, in part, sufficient records of trainee evaluation, including trainee mastery ofdesired task performance, be maintained by the licensee to maintain program integrity and that sufficient records be available for NRC inspection to verify the adequacy of the program.
Contrary to the above, as ofOctober 3, 1997, ADM-08.02. Revision 15, "Conduct of Maintenance," was inadequate in that itfailed to implement a systems approach to training for electrical, mechanical and instrument and control personnel by allowing the evaluation of trainee mastery without established specifications and objective-based evaluation criteria as required by the systems approach to training. In addition, ADM-08.02, Revision 15, "Conduct of Maintenance," did not contain the provision for documenting task qualification evaluations as required by a systems approach to training, This is a Severity Level IVviolation (Supplement I).
1.
FPL concurs with the violation.
2.
The cause of the violation was a weakness in administrative procedure ADM08.02, Conduct of Maintenance, which could have permitted de facto job task qualification, in lieu offull qualification, under the established systematic approach to training for Maintenance job task qualification. It should be noted that administrative procedure ADM08.02 was not used to govern training and evaluation functions of the systematic approach to training. Those functions have been, and remain, the responsibility of the St. Lucie Plant accredited training programs, To assign work in the plant, supervisors, foremen, chiefs, and leads use a qualification list, provided by the Maintenance Training organization, that identifies the qualification level of site journeymen. The list is provided so that persons responsible for assigning work are not required to review mastery oftraining objectives for each job. Additionally, plant procedure ADM08.02 provided for the application of supervisory oversight, procedural direction, or work order detail,
L-97-319 Attachment Paga2 as appropriate, to allow persons who were not job task qualified to perform work within their journeyman qualifications. Plant procedure ADM08.02 was never intended to provide direction for evaluating trainee mastery ofobjectives or to contain requirements for documenting task qualification evaluations, as required in a systematic approach to training.
Arecords review ofmaintenance tasks performed and other documentation (e.g., Condition Reports and Licensee Event Reports), in addition to interviews with Maintenance supervisors, revealed no evidence ofcircumvention of the systematic approach to training-based training and qualification requirements. FPL acknowledges that procedure ADM08.02 was weak in its definition of"supervisory oversight."
The requirement to document task qualification evaluations is implemented by plant Quality Instructions and by lower tier plant procedures. Plant procedure ADM08.02 was not intended to satisfy the evaluation and qualification requirements of 10 CFR 50.120 or for documenting task qualification evaluations. Training records, including records ofwritten examinations and task performance evaluations, are properly maintained for each training program participant at St.
Lucie Plant. These records provide the basis for the journeyman qualification lists which are provided to Maintenance supervisors, foremen, chiefs, and leads.
3.
A.
In response to a self-identified need for additional clarification on assignment of work and use of the qualification lists prior to work assignment, the Maintenance Department implemented a new set ofMaintenance ffraining Policies. These policies, among other things, reinforced: 1) the requirement that personnel must be qualified for assignc-'..sks, and; 2) the review and use ofqualification lists by field supervisors prior to assignment ofwork. Maintenance Department heads, supervisors, foremen, chiefs, and leads were provided training on these policies.
As a result, Maintenance personnel are not being assigned to perform work for which they do not have specific task qualifications unless they are working under the direction of a qualified person.
0 B.
In response to an FPL Quality Assurance Department audit finding, on September 30, 1997, the St. Lucie Plant General Manager issued an interim controls letter that clearly stated management expectations that personnel are to be job task qualified prior to performing work independently. The September 30, 1997, letter focused on work assignment for both plant and non-plant personnel and identified that a procedure addressing this subject would be implemented (subsequently implemented as a revision to plant procedure ADM08.02).
I 97-319 Attachment Paga3 4.
A.
Administrative procedure ADM08.02 willbe revised to remove the language that could have allowed personnel to be assigned work based on supervisory oversight.
The revised procedure specifically willrequire that personnel who have not been job task qualified shall work under the direction ofqualified personnel when performing plant maintenance. The procedure willbe issued for use by January 23, 1998, followingcompletion ofpre-implementation training.
B.
A new administrative procedure, ADM22.01, Verification ofTraining/
Certification for Temporarily Employed Personnel, has been developed to provide guidance on the review oftraining and qualifications for temporarily assigned personnel, such as contractors, employees loaned from other departments during outages, and for up relieving personnel during periods such as vacations or illness, as required. This procedure is the result ofextensive benchmarking throughout the industry and represents best industry practice for screening and certifying that temporarily employed personnel meet plant standards for qualification on specific tasks prior to work assignment. Administrative procedure ADM22.01 was recommended for approval by the Facility Review Group and willbe implemented in January 1998 after appropriate pre-implementation training.
C.
The Maintenance Supervisor Training Program willbe revised to reinforce the changes identified in ADM08.02 and the newly issued ADM22.01, as well as to ensure that management policy on use of the qualification lists in assigning work is fullyunderstood by the participants. That training willbe revised by February 28, 1998 (prior to the next class for new supervisors). In the interim, this information willbe provided to incumbent supervisors as continuing training.
5.
Full compliance willbe achieved by January 23, 1998, with the completion of item 4.A.,
above.