ML20023C415
| ML20023C415 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 04/27/1983 |
| From: | Hawkins F, Sutphin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20023C399 | List: |
| References | |
| 50-346-83-04, 50-346-83-4, NUDOCS 8305170315 | |
| Download: ML20023C415 (6) | |
See also: IR 05000346/1983004
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION III
Report No. 50-346/83-04(DE)
Docket No. 50-346
License No. NPF-3
Licensee: Toledo Edison Company
Edison Plaza, 300 Madison Avenue
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Toledo, OH 43652
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Facility Name: Davis-Besse 1
Inspection At: Oak Harbor, OH
Inspection Conducted: March 1-4, and 9-11, 1983
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Inspector:
R.' N. Sutphin
M/27/82.
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Approved By:
F. C. Hawkins, Chief
V/27/f2_
Management Programs Section
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Inspection on March 1-4, and 9-11, 1983, (Report No. 50-346/83-04(DE)
Areas, Inspected: Routine, unannounced inspection of licensed operator requal-
ification training; non-licensed training and QA audit program. The inspection
involved a total of 47 inspector-nours onsite by one NRC inspector.
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Results: Of the three areas inspected, one item of noncompliance was identi-
fied in one area.
(failure to follow procedures - Paragraph 2.b(2)
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8305170315 830427
PDR ADOCK 05000346
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DETAILS
1.
Persons Contacted
Toledo Edison Company
T. Murray, Station Superintendent
- T. Powers, Nuclear Training Manager
- J. Syrowski, Operations Training Supervisor (Acting)
- J. Byrne, Quality Assurance
- R.
Peters, Licensing
- S. Uideman, Licensing
W. O'Connor, Operations Engineer Supervisor
J. Faris, Administrative Coordinator
D. Varwig, Training Supervisor
- J. Freels, Nuclear Maintenance Training Supervisor
R. Rutledge, Training Administrative Assistant
NRC
T. Peebles, Senior Resident Inspector
W. Rogers, Resident Inspector
The inspector also interviewed several other licensee employees including
licensed reactor operators and senior reactor operators, instructors,
training staff personnel, technicians and clerks.
- Denotes those present at the exit interview on March 11, 1983.
2.
Program Areas Inspected
a.
Requalification Training For Licensed Personnel
The ceaualification training program was reviewed for compliance
witu lu CFR 50, Appendir A; NUREG-0737; ANSI N18.1-1971; the FSAR;
and Technical Specifications.
(1) Review of Documents
The following documents were reviewed:
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AD 1828.09, Revision 1, 3-31-82
" Senior Reactor
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Operator Training"
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AD 1828.10, Revision 2, 7-27-82
" Davis-Besse
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Operator Training Program"
AD 1828.15, Revision 3, 3-3-82
"Requalification"
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AD 1805.00, Revision 19, 12-22-82
" Procedure
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Preparation and Maintenance"
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Administrative Procedure AD 1828.09, Revision 1, was substant-
ially rewritten.
In the process of rewriting and reformating
the procedure, the three attachments to the previous edition
were deleted. A new form, titled " SENIOR REACTOR OPERATOR UP-
GRADE CHECK 0FF FORM", was developed for use in the Senior Reactor
Operator Training program. However, it was not referenced in
the rewrite, nor included as an attachment to the procedure.
The new form was not identified as a Davis-Besse document, it
was not numbered or dated for revision control and had no refer-
ences to the procedure (AD 1828.09) to which it was associated.
Discussions with responsible licensee personnel indicated that
they were aware of the new form and were properly utilizing it.
The licensee stated that the appropriate procedure revisions
would be made. The inspector has no further questions regarding
this matter at this time.
(2) Review of Requalification Training Records
The training records of three Senior Reactor Operators and two
Reactor Operators were reviewed for compliance with requirements.
No items of noncompliance or deviations were identified.
(3) Training Classes
The inspector attended one class in the Reactor Operator and
Senior Reactor Operator Requalification Program which was con-
ducted in accordance with their Requalification Procedure AD
1828.15. Additionally, several attendees were interviewed.
No items of noncompliance or deviations were identified.
(4) Training Schedules
The inspector reviewed the available schedules associated with
the licensed personnel training programs. They included the
Master Schedule Board and the Operations Section Training
Schedule.
Both of these schedules were in a handwritten format.
The program information on these two schedules at the time of
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this inspection appeared to be adequate for licensed personnel
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training requirements; however, there was no evidence of manage-
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ment review or approval of or commitment to the schedules. The
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licensee agreed to review this aspect of their Training Program
and develop more definitive guidelines. Pending the results
of licensees review and action on the subject of licensed per-
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sonnel training schedules, this will be considered an open item
(346/83-04-01).
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b.
Training For Non-Licensed Personnel
The licensee's Training Program for non-licensed personnel was reviewed
for compliance with the Technical Specifications, the ESAR, and Quality
Assurance Program requirements.
(1) Documents Reviewed
AD 1828.03, Revision 5, 9-23-82
" General Orientation
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Training"
AD 1828.03, Revision 6, 2-28-83
" General Employee
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Training"
AD 1828.11 Revision 2, 9-23-81
Maintenance Section
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Training"
AD 1828.04, Revision 3, 8-13-82
" Personnel Training
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Records"
AD 1828.00, Revision 4, 7-30-82
" Personnel Training
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Program"
AD 1828.12. Revision 3, 12-8-82
" Chemistry and Health
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Physics Training"
AD 1828.20, Revision 4, 9-12-82
" Fire Brigade Training"
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Administrative Procedure AD 1828.03 was revised twice in the
last six months. Both revisions were reviewed by the inspector.
The latest revision represented a complete rewrite and a new
title, " General Employee Training." During the revision process,
pages 7, 8, and 9 of the attachments to the procedure were re-
vised without the changes being identified per the requirements
of their Administrative Procedure AD 1805.00.
Although the revision status of the attachments was not properly
identified, the text of each was verified to be correct. Licensee
personnel stated that the revision status of the attachments
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would be corrected. The inspector has no further question re-
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garding this matter at this time.
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No other items of noncompliance or deviations were identified.
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(2) Review of Training Records
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The training records of ten non-licensed personnel were re-
viewed to verify compliance with original training and retrain-
ing program requirements.
Administrative Procedure AD 1828.03, " General Employee Training"
(CET), states that "GET Consists of General Orientation Training
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(GOT) and Radiological Control Training (RCT) ... Personnel
requiring unescorted access to the P-otected Area and any radio-
logically controlled areas must successfully complete the entire
GET program." It states further in 6.2:
" Experienced personnel
may be exempted from receiving specific instruction in General
Orientation and/or Radiological Controls Training. Successful
completion of an examination may be required for each program
for which an exemption is requested prior to approval of the
exemption. A Personnel Training Waiver Form (Enclosure 3) must
be submitted to Nuclear Training for each individual a Toledo
Edison management person requests this exemption for."
Section 7 of the same AD 1828.03 states:
"GOT and RCT qualifi-
cations will expire on the last day of the 12th month following
qualification or requalification. For an individual to retain
unescorted access to the Protected Area and/or radiological
controlled areas, annual requalification is required for GOT
and RCT, respectively."
During the inspector's review of the training records for Chemis-
try and Health Physics personnel, it was determined that two of
the individuals reviewed had not received the required requali-
fication training. The individuals had not received RCT annual
requalification nor had any Wiavers or examinations on file
since August 14, 1980, and March 19, 1981 respectively. This
is considered an item of noncompliance with 10 CFR 50, Appendix
B, Criterion V (346/83-04-02).
A review of records for female employees and an interview with
one female employee determined that they had received the train-
ing on prenatal occupational exposure to radiation required by
NRC Reg. Guide 8.13.
(3) Training Classes
The inspector attended three classes in the non-licensed per-
sonnel training category. They included:
" Fire Watch Qualifi-
cation" per AD 1828.19; " Chemistry and Health Physics - water
treatment" per AD 1828.12; and " General Orientation Training -
annual requalification" per AD 1828.03.
Interviews were con-
ducted with one or more attendees from each class.
No items of noncompliance or deviations were identified.
(4) Training Schedules
The inspector reviewed the available schedules associated with
the non-licensed personnel training programs. They included
the Master Schedule Board, the weekly schedules, and the yearly
program outline for three maintenance areas - Electrical,
Mechanical, and Instrumentation and Controls (I&C).
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The inspector observed that the weekly schedules were published
in a well developed format and distributed to over 50 locations
within the Davis-Besse organization. The longer range schedules
for the non-licensed personnel training program, particularly
in the areas of maintenance training were not as well developed
or as uniform in their contents. The licensee agreed to review
this aspect of their Training Program, along with the similar
review of schedules for the licensed personnel training program,
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and develop more definitive guidelines.
Pending the results of
licensee's review and action on the subject of nonlicensed and
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maintenance personnel training schedules, this is considered an
open item (346/83-04-03).
No items of noncompliance or deviations were identified.
c.
Quality Assurance Audit Program of Training Program
The inspector reviewed the latest Quality Assurance audit of the
Davis-Besse Nuclear Training Programs. The Quality Assurance audit
( Number 834) was conducted between January 25 and February 8, 1982
and addressed compliance with the following training Administrative
Procedures (AD):
AD 1828.03.3, " General Orientation Training"
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AD 1828.13.1, " Administrative and Clerical Personnel Training"
AD 1828.15.2, "Requalification"
AD 1828.20.3, " Fire Brigade Training"
The audit resulted in two findings. Corrective action was completed
in a timely manner.
3.
Open Items
Open items are matters which have been discussed with the licensee, which
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will be reviewed further by the inspector, and which involve some action
on the part of the NRC or licensee or both. Open items disclosed during
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the inspection are discussed in Paragraphs 2.a(4) and 2.b(4).
4.
Exit Interview
The inspector met with licensee representatives denoted in Paragraph 1
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at the conclusion of the inspection on March 11, 1983. The inspector
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summarized the purpose and the scope of the inspection and the findings.
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