ML20009D959
| ML20009D959 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/22/1981 |
| From: | Sylvia B VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20009D952 | List: |
| References | |
| 342, NUDOCS 8107240533 | |
| Download: ML20009D959 (3) | |
Text
r-OFFICIAL COPY 2CP
$/h VIRGINIA ELECTRIC AND Powna Cox'PENY Rtciprown,VrararxzA 20261
, '; j u ! '26 3 '.; - 4*
June 22, 1931 Mr. James P. O'Reilly, Director Serial No. 342 Office of Inspection and Enforcement N0/RMT:ms U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7
Dear Mr. O'Reilly:
We have reviewed your letter of May 28, 1981 in reference to the inspection conduct'.:d at North Anna Power Station between April 6 - May 5, 1981 and reported in IE Inspection Report Nos. 50-338/81-13 and 50-339/81-10.
Our respouse to the specific infraction is attached.
We have determined that no proprietary information is contained in the reporta.
Accordingly, the Virginia Electric and Power Company has no objec-tion to these inspection reports being made a matter of pe.ic disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours, s
k
- s. U. %>.
\\
v
's B. R. Sylvia Manager - Nuclear Operations and Maintenance Attachment City of Richmond Commonwealth of Virginia Acknowledged before me this.12 day o
-, 19f_/
b~ (. 7h M '
Notary Public My Commission expires:.4-#6 191 7 cc:
Mr. Robert A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing nio7240533$f,h$8 PDR ADOCK g PDR O
i Att chment
,e Pags 1 y
RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM APRIL 6 - MAY 5, 1981 NRC CottfENT Technical Specification 6.4 requires retraining and replacement training programs be maintained in accordance with Section 5.5 of ANSI N18.1-1971.
Section 5.5 of ANSI N18.1-1971 requires a training program which maintains the proficiency of the operating organization.
Section 5.1 of ANSI N18.1-1971 further identifies the requirement for the training program to provide fully trained and qualified personnel to ensure safe and efficient operation of the facility.
Contrary to the above, replacement and retraining programs were deficient for the operating organization in that:
a.
Unlicensed operators do not receive formal training on systems or proce-dures they use 'in conduct of operations prior to assiirnment as qualified
)
operators.
Additionally, any on the job training received is not speci-fied nor documented.
b.
The engineering staff has no formal training program for development, retraining, or certification of personnel.
l I
RESPONSE
1.
ADMISSION OR DENIAL OF ALLEGED VIOLATION
- The Notice of Violation is not correct as stated.
2.
REASONS FOR THE VIOLATION ANSI N18.1-1971, Sections 5.1 and 5.5, requires a training and retraining program that will provide fully trained and qualified personnel to ensure l
the continued safe operation of the facility. The existing " Step Program" for non-licensed operators including an end-of-step examination, super-visor's appraisal and a productive work evaluation provides for, and documents, this training and retraining.
This program, administered by 1
Station Management and the on-site Training Department, provides for the necessary knowledge and experience level of personnel prior to the j
assignment of specific tasks or responsibilities. Operational experience has verified the acceptability of the present training and retraining program for non-licensed operators.
i However, the training program for Station engineers is not clearly
)
defined and the documentation for specific on-the-job training tasks for non-licensed operators is lacking. We believe that this Notice of Viola-
)
tion was solely based on these problems.
Therefore, our corrective actions will be directly toward the resolution of these NRC identified areas of concern.
Attachment
/*
Page 2 u
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED A task analysis survey which will identify the necessity for qualifica-tion training and retraining in these areas is expected to be completed by December 31, 1981. Until these task analyses are completed and imple-mented, the following actions are being taken.
a.
Non-Licensed Operations Personnel A qualification card system specifying the minimum qualification level necessary for conducting the various non-licensed activities i
in support of station operation is being developed.
These cards will be signed when the person has demonstrated sufficient knowledge and experience to carry out assigned duties. Upon completion of the entire qualification card, the person will then be designated as a qualified operator for that area.
Retraining of qualified non-licensed operators in a particular area will be a continuation of i
experience and knowledge accumulation resulting from on-the -job training as required by the step program. At the end of each step, the operators, will as before, receive a Productive Work Evaluation, a supervisor's appraisal and an end-of-step examination.
b.
Station Engineering Personnel i
All full time station engineers are presently being scheduled for STA training, SRO license training or basic systems training that will meet the minimum qualification requirements of ANSI N18.1.
Retraining of engineers will be consistent with the existing STA and SRO retraining programs until the task analyses ident4.fy specific areas of qualification training and retraining.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The actions described above should preclude further alleged violations.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED
)
This program, as described, for non-licensed operator qualification will be established by August 1, 1981 and will be fully implemented by j
October 1, 1981.
l The engineer's training program has already been initiated.
It is anti-cipated that the minimum qualification training for all station engineers will be defined by December 31, 1981.
1 i
l i
~*~
.h--
T
, *T L.
h :.,...i --.: - - -., - - - - -
,,-,.,,,,...n.
.