ML19320D294
| ML19320D294 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom  |
| Issue date: | 05/09/1980 |
| From: | Daltroff S PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Grier B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| Shared Package | |
| ML19320D281 | List: |
| References | |
| NUDOCS 8007210215 | |
| Download: ML19320D294 (8) | |
Text
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e PHILADELPHIA ELECTRIC COMPANY 2301 M ARKET STREET P.O. BOX 8699 PHILADELPHIA. PA.19101 SHIELDS L. DAl.TROFF etsErn5c1'nE5om May 9, 1980 Re: Docket Nos. 50-277 50-278 Inspection Nos. 50-277/79-09 50-278/79-10 Mr. Boyce H.
Grier, Director Office of Inspection & Enforcement Region I US Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406
Dear Mr. Grier:
Your letter of April 16, 1980, forwarded combined Inspection Report 50-277/79-09 and 50-278/79-10.
Appendix A to your letter addresses three items which did not appear to be in full compliance with Nuclear Regulatory Commission requirements.
Two of these items are categorized as infractions and one item is categorized as a deficiency.
Appendix B to your letter addresses one item which appears to be a deviation from certain qualification requirements committed to in the Final Safety Analysis Report.
Each of these items is restated below with our response.
Appendix A-Notice of Violation A.
Technical Specification 6.4.1 requires a training and retraining program for the facility staff which meets the requirements of ANSI N18.1-1971, Section 5.5.
ANSI N18.1-1971, Section 5.5, requires that a training program be established which maintains the proficiency of the operating organization through periodic training 800721021f5
Mr. Boyce H. Grior Page.2 exercises, instruction periods and reviews covering those items and equipment which relate to safe operation
-of the facility.
' Contrary to the above, the inspector determined that a retraining program for non-licensed operators, QA receipt inspection personnel, reactor engineering personnel, results engineering personnel, health physics and chemistry personnel, maintenance personnel, and instrument-and control personnel had not been adequately established, implemented, and maintained by the licencee.
Response
The present training and retraining program for the facility staff at Peach Bottom Atomic Power Station (PBAPS) maintains the proficiency of the operating organization through instruction and review sessions, exercises, daily work experience, and supervisor assessment of job performance.
Once a year all plant personnel receive General Employee Training (GET) in, or demonstrate their knowledge of, basic inf orma tion on radiation protection, security, evacuation procedures, quality assurance, and safety.
Non-licensed operators, QA receipt inspection personnel, reactor eagineering personnel, results engineering personnel, health physics and chemistry personnel, maintenance personnel, and instrument and control personnel who may be required to wear masks as part of their normal work requirements receive General Respiratory Training (GRT) at least once a year to review respiratory protection procedures and use of respiratory equipment.
Personnel in these groups receive training in their specific areas and gain experience in daily work assignments.
-Following are examples of the training and information that each of these groups receive.
1.
Non-licensed operators a)
Meetings are held at the beginning of each shift to inform the operators of plant status, to review the expected operation for that day, to identify.
i important procedure changes, and to discuss unusual conditions.
b)
Training material is distributed each month to provide'the operators with information that is
- pertinent to plant operations.
This includes
' revised procedures, NRC letters, and new operating information.
A sign-off sheet verifies that operators have received this material.
c)
Emergency plans and. procedures are reviewed annually.
l
t Mr. Boyco H. Grier Page 3 d)
Fire and damage team members receive training and review sessions at least once every two years.
e)
Personnel safety team members receive Red Cross Multi-Media training once every three years and take a yearly proficiency test.
2..
QA receipt inspection personnel a)
Peach Bottom Administrative Procedure A-55, Rev.
O, titled " General Requirements f or QA Procurement and Receipt Inspectors" defines the qualifications for personnel in this group.
PBAPS QA receipt inspection personnel were qualified in accordance with this procedure by March 12, 1980.
(b)
Periodic recertification of PBAFS QA receipt inspection personnel in accordance with ANSI N45.2.6-1973 is required by Procedure A-55 identified in item 2.a.
3.
Reactor engineering personnel a)
Each reactor engineer is involved in sufficient startups to insure that he retains his proficiency in reactor engineering startup activities.
This provides on-the-job experience and reinforcement of previous training.
l' b)
Before any unit startup, discussions are held as appropriate to review new procedures or methods which may be pertinent to reactor c.ngineering startup activities.
Unusual conditions and potential problems are discussed to insure a clear understanding of the startup procedure.
c)
Non-licensed reactor engineers participate in a video tape program developed by General Electric Company.
This program provides training and review of BWR systems and technology including automatic depressurization, emergency core cooling, fuel and core configuration, instrumentation, radiation monitoring, and other major systems.
4.
Results engineering personnel a)
All test engineers with one year experience have received or will receive special classroom and simulator training and are qualified as Shift Technical Advisors (STA) based on the present STA
(
. program.
l-
~
Mr.-Boyco H. Grior Pogo 4
~ b)
A meeting is held each normal workday morning to discuss plant status and jo b assignments.
Any special problems and possible solutions are discussed.
c)
Non-licensed personnel participate in the GE BWR video tape program (see item 3.c).
5.
-Health physics and chemistry personnel a)
Philadelphia Electric Company (PECO) health physics technicians can progress through four levels of qualification based on training and plant experience.
Progression from one level to the next requires training, experience, and review of previously taught information and procedures.
b)
PECO chemistry technicians follow the same progression as the health physics technicians for the first two levels of training.
At the third level a technician may specialize in health physics or chemistry and additional training is provided in the area he selects.
c)
Periodic meetings with PECO health physics technicians are held to discuss plant and health physics operations, review problems, and discuss procedural changes.
d) 2outine chemistry supervision meetings are held to discuss plant operations, review problems, assign areas of responsibility, and discuss procedu ral or operational changes.
.e)
Technicians' work is reviewed periodically by health physics and chemistry supervision.
Additional training and retraining are given on an individual basis when deficiencies are identified by this review.
f)
Some non-licensed health physics and chemistry engineers and technical assistants participate in the GE BWR viceo tape program (see item 3.c) 6.
Maintenance personnel a)
Maintenance tradesmen start as Helpers and can progress to Third, Second, and Firs t Class levels.
On-the-job and off-the-job training is included in each classification.
In order to progress from one level to the next, a tradesman must pass a
.a
__-y_
q+_..,r
r a
Mr. Boyco H.
Grior Pcgs 5 qualifying examination which includes both a written test and a skill test.
b)
Maintenance welders who are assigned or could be assigned to Peach Bottom take a requalification test every six months in accordance with Section IX of the ASME Boiler and Pressure Vessel Code, c)
Selected maintenance staff and craft personnel attend seminars and training sessions on specific equipment as needs require.
d)
Maintenance supervising engineers receive fire school training every five years.
e)
Some non-licensed maintenance engineers and technical assistants participate in the GE BWR video tape series (see item 3.c).
7.
Instrument and control personnel a)
Instrument and control (I&C) technicians receive periodic technical proficiency evaluations which rate the individual's technical ability in approximately twenty I&C areas.
Based on these ratings, additional training or work assignments may be directed toward improving an individual's ability in a particular area.
b)
Electric Production I&C engineers have received special classroom and simulator training and are qualified as Shift Technical Advisors.
c)
Non-licensed engineers and technicc1 assistants participate in the GE BWR video tape series (see item 3.c).
The personnel identified above receive frequent training and retraining in the performance of their job assignments.
Supervisor assessment and assistance is an important part of the training and development of the plant staff.
Depending on an individual's work assignments, specific training is pt,vided in areas that.are especially c-itical or infrequently used, such as fire fighting, first aid, emergency plans, radiation protection, safety, and security.
This approach to training meets the requirements of ANSI N18.1 -
1971Property "ANSI code" (as page type) with input value "ANSI N18.1 -</br></br>1971" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Section 5.5 based on our interp retation of this standard.
We have requested an interpretation of the intent of this ANSI standard in a letter to Mr.
H.
J.
Green of the ANS-3 subcommittee.
Should our existing program not meet the intent of
?
Mr.-Boyce H. Grier Page 6 the ANSI' standard, then appropriate modifications will be made to our present training program.
B.
Technical Specification 6.5.2.8.d requires audits of the performance of all activities required by the Quality Assurance Program to meet the criteria of 10 CFR 50, Appendix B, shall be performed under the cognizance of the OSRC at least once per two years.
_ Contrary to the above, it was reveale/, that no audits had b2en perf ormed on the Quality Assurance Section, Engineering and Research Department, or its activities.
Response
In August 1979, the Operations and Safety Review Committee (0&SR) delegated the performance of audits of the activities of the Engineering and Research Department Quality Assurance Section (E&R QA) to the Electric Production Department Quality Assurance Division (EP QA).
Audit 79-16, covering E&R QA Section activities, was performed by the EP QA Division and issued to the O&SR Committee on September 11, 1979, at which time full compliance with the Technical Specification audit requirement was achieved.
These audits will continue to be performed by EP QA Division at least once per two years under the cognizance of the O&SR Committee.
C.
Title 10, Chapter 1, Code of Federal Regulations, Part 50, Appendix B, Criterion V, requires activities affecting quality be prescribed by documented instructions and procedures and that these activities be accomplished'in accordance with these instructions and procedures.
The Licensee's Quality Assurance Instruction (QAI),
number 18-6 Rev.
O, Item 6.9.5, requires that when a nonconformance item becomes 30 days overdue the auditing chairman shall prepare a letter requesting the responsible organization to take immediate corrective action Contrary to the above, the Engineering and Research Quality Assurance Department identified a noncompliance, relating to the premature release of a contract to the Franklin Institute and Research Laboratory on August 23, 1978; a nonconformance report vcs issued to the responsible organization by September 6,
- 1978, requesting a response by September 26, 1978; and the response to this nonconformance report was not answered
Mr. Boyco H. Grior Page 7 until January 4, 1979, 96 days after the response deadline.
Response
Engineering and Research Quality Assurance (E&R QA) has taken the i
following steps to prevent recurrence of the cited deficiency:
By memo of July 19, 1979 the Manager, E&R QA notified PECO E&R Division Heads of the necessity for timely responses to audit finding reports.
Quality Assurance Instruction 18-6 was revised on July 29, 1979 to clarify the requirements for follow-up of issued finding reports.
Computerized open finding logs are now used as a monthly reminder of open finding reports; a standardized
-follow-up letter has been provided for routine use; and periodic status reports are now required from the responsible organization when there is a delay in reporting corrective action associated with the finding.
j Quality Assurance Instruction 17-3 was revised on July 27, 1979 to require timely updating of the computerized finding report data base and monthly issuance of open finding logs to the responsible quality assurance enginears.
In a specially called meeting the Manager E&R QA has instructed quality assurance engineers as to the necessity of follow-up of open finding reports as required by the Quality Assurance Instructions.
Since the above steps have been taken there has been improvement in the timeliness of both QA follow-up of open findings and
)
responses by audited organizations.
Appendix B - Notice of Deviation Based on the results of the NRC inspection conducted on March 19-30,'1979, it appears that certain of your j
activities were not conducted in conf ormance with your commitments to the Commission.
l The licensee's Quality Assurance Program, FSAR 17.2, Appendix'A, requires that personnel performing inspection, examination, or testing activities be qualified in accordance with ANSI N45.2.6-1973.
Contrary to the above, the quality assurance inspectors were not qualified to the ANSI N45.2.6-1973.
l
.e Mr. Boyco H. Grior Page 8
Response
A new procedure, Peach Bottom Administrative Procedure A-55, Rev.
O, titled " General RequireLants for QA Procurement and Receipt Inspectors", was approved on August 27, 1979.
Individuals at Peach Bottom perf orming procurement and receipt inspector functions were qualified in accordance wich this procedure by March 12, 1980.
This procedure complies with ANSI N45.2.6-1973 as required by the-PBAPS Quality Assurance Program, FSAR 17.2, Appendix A.
Procedure A-55 ensures that all QA procurement and receipt inspectors are fully qualified to perform their assigned duties, and requires periodic recertification in accordance with ANSI N45.2.6-1973.
Very truly yours,
/
J.
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1 e
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