ML20024F542

Responds to NRC 830607 Ltr Re Violations Noted in IE Insp Repts 50-348/83-13 & 50-364/83-11.Corrective Actions:Change Made to FNP-O-AP-45 to Specify Criteria for Individual to Participate in Accelerated Training

ML20024F542
Person / Time
Site:	Farley
Issue date:	07/06/1983
From:	Clayton F ALABAMA POWER CO.
To:	Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20024F518	List: ML20024F537 ML20024F542
References
NUDOCS 8309090464
Download: ML20024F542 (8)

Text

a Mailing Addre:s s Aiabama Power Company 600 North 18th Street Post Office Box 2641 Birm.agham. Alabama 35291 Telephone 205 7834081 y g g C "' !$II .,,,

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F. L. ClayInn, Jr.

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,,,sm, m , ,soem July 6, 1983 Docket No. 50-348 Docket No. 50-364 Mr. R. C. Lewis U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Suite 3100 Atlanta, GA 30303

SUBJECT:

J. M. Farley Nuclear Plant NRC Inspection of April 25-29, 1983 and May 2-6, 1983 RE: Report Numbers 50-348/83-13 50-364/83-11

Dear Mr. Lewis:

This letter refers to the violations in the subject inspection re-port which states:

"As a result of the inspection conducted on April 25-29 and May 2-6,1983, and in accordance with the NRC Enforcement Policy, 47 FR 9987 (March 9,1982), the following violations were identified.

A. 10 CFR 50 Appendix B, Criterion V and the accepted Quality Assurance Program (FSAR Chapter 17) require activities affect-ing quality to be prescribed by documented instructions, proce-dures, or drawings, of a type appropriate to the circumstances.

Instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplish-ed.

Contrary to the above, documented prredures implementing the licensed operator requalification program do not contain appro-priate measures for determining that important activities have been satisfactorily accomplished in that:

8309090464 830901 PDR ADOCK 05000348 G PDR

Mr. R. C. Lewis July 6, 1983 Page Two -

1. Section C.2 of Encicsure 1 to the March 28, 1980, letter from the Director of the Office of Nuclear Reactor Regula-tion specifies acceptance criteria for requiring a' licensed individual to participate in an accelerated requalification-training. Although Farley' Nuclear Station is. conforming to these requirements, tnsy are not prescribed in documented instructions.

2. Section C.3 of Enclosure 1 to March 28, 1980, letter dis-cussed above identifies reactivity control manipulations -

that are required to be incorporated into a licensee's re-qualification program. He~asures have not been incorporated into the requalification program to assure that these re-

,quirements are met. As a result, one required manipulation has not been performed by various licensed personnel as ~

described in Violation B.

3. 10 CFR 55, Appendix A, Section 3.d. requires each licensed operator review' the contents of all abnormal and eme . ancy procedures on a regularly scheduled basis. Measure . ave not been established to assure that these requirem,1 ;s are performed. In addition, the frequency fo'r accomplishing '

this 'requirenent has not been established.

4. 10 CFR 55.31(e) requires'that if a licensed individual has not-been actively per. forming the functions of an operator or senior operator:for a period of four months or longer, t he shall demonstr'a te to the Commission that his knowledge and understanding of facility operation and administration

-are satisfactory prior to resuming licensed duties. Al-though no licensee was identified that had performed the functions ~of a licensed operator in violation of this re-quirement, measures have not been established to formally document the removal and reinstatement of personnel who are subject to this requirement."

Admission or Denial The above violation occurred as described in the subject report.

Reason for Violation This violation was due to procedural inadequacy. Qualitative and quantitative acceptance criteria for. the licensed operator' requalifica-tion program were not contained in FNP-0-AP-45 (Farley Nuclear Plant Training Plan) or FNP-0-M-15 (Master Training Plan) as follows:

. s Mr.R.C. lewis July' Page Tr.ree6, 1983

1. Criteria for requiring a licensed individual to participate in accelerated raqualification training were not qualitatively or

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quantitatively specified in programmatic documents.

1 2. All reactivity control manipulations specified by Harold Denton's letter dated 3/28/80 were not incorporated into the

-' . i requalification program (i.e., loss of instrument air).

3. Programmatic documents did not specify that each licensed operator periodically review the contents of all Abnormal and

' Emergency Procedures on a regularly scheduled basis, measures to specify how to accomplish the requirement or the time frame for the periodic review.

4. Measures had not been established to formally document removal or reinstatement requirements for personnel who had not been performing the functions of an operator or senior operator for a period of 4 months or longer.

Corrective Action Taken and Results Achieved Corrective action and results achieved for this violation are as follows:

1. A change was made to FNP-0-AP-45 to quantitatively specify the criteria for a licensed individual to participate in accelerated requalification training.

. 2. The Operations curriculum guide and the individual record of reactivity and control manipulations form have been revised to incorporate all required control manipulations.

3. A change was made to FNP-0-AP-45 to specify that all Abnormal and Emergency Procedures would be reviewed on a two-year cycle.

u The Operations curriculum guide and the individual record of reactivity and control manipulations form were changed to include the procedure review during a simulator retraining.

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4. A change was made to FNP-0-AP-45 to formally document removal

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and, reinstatement requirements for personrel who have not per-Jh forced \the functions of an operator or senior operator for a I '

peridi of four months or longer.

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Corrective Steps Taken to Avoid Further Violations

.c See above. All corrective action was completed by May 6,1983.

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Page Four-Date of' Full Compliance May_6, 1983. +

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w "B. Technical Specification 6.4.1 requires a retraining and re-

, placement / training program for the facility staf f to be main-fT tained under the direction'of the Training Superintendent and shall meet or exceed the requirements and recommendations of s * '

- Sectica 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part

+- 55 and tne supplemental requirements specified in Section A and y' _

C of Enclosure 1 of the March 28, 1980, NRC letter to all l ' licensees, aqd shall include familiarization with the relevant

~ operational experience.

1. -Sectionl C.2t of Enclosure 1 requires a licensed individual to[ participate in accelerated requalification if he scores

less than 80%,overall or 70% in a category on the annual requalification examination.

Contrary to the above,9oue to.a mathematical error during the grading process of ,aa examination one individual was given 70% in a category when. nis actual score was 66.7%.

Upon notification of. this- erroi by the inspector, the licensee immediately removed the individual from licensed

_ duties and placed him in an accelerated training status.

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- ' 2. Section C.3 of Enclosure 1 requires that control manipula-

, tions identified in Enclosure 4 of the March 28, 1980,

1. - -letter be: performed as detailed in the enclosure. These -

p / manipulations are required to be performed over a two year

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, 't isContrary to the(above, all required reactivity manipula-

" ,s, tior,'s wsre not accomplished over a two year period. One f w required'ainnipulation? involving loss of instrument air had y: not been performed by aay.of the individuals selected for t a; .,

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"  ; review. Two other personnel had not performec .one other

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' required manipulat' ion ' involving loss of service water."

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u ?QT,htsaboveviolationoccurred'asdescribedinthe[subjectreport.

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This4vi lation was due to personnel error. TechnicalSh>ecification

• - 6.4.1 wiis'not adhered to as follows: :

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Mr. R. C. Lewis July 6, 1983 Page Five

1. An individual was not placed in accelerated training due to a mathematical error in grading of the annual requalification ex-amination.

2. Not all licensed personnel received all required control mani-pulations in accordance with Harold Denton's letter dated March 28, 1980.

Corrective Actions Taken and Results Achieved Corrective action and results achieved for this violation are as follows:

1. FNP-0-AP-45 will be revised to include a technical review and mathematical verification of the grading on all annual license requalification examinations.

2. The vendor providing simulator training was immediately con-tacted and directed to ensure that all required control manipu-lations were being performed and documented. The Farley Plant reference simulator will be on-site and operational during the 3rd quarter of 1983. Subsequently, all required control mani-pulations, including loss of instrument air, will be conducted on the plant reference simulator. During the 1983-84 retrain-ing year, all licensed personnel will complete all control manipulations specified in Harold Denton's 1ctter dated March 28, 1980.

Corrective Steps Taken to Avoid Further Violations See above. All corrective action is scheduled to be completed by June 25,1983 and August 1,1984 for items 1 and 2 respectively.

Date of Full Compliance:

August 1, 1984. This date is necessitated by the time required to complete the next training cycle which will include control manipu-lations involving loss of instrument air.

"C. Technical Specification 6.5.2.10.c requires that audit reports shall be. forwarded to the Senior Vice President and to management positions responsible for the areas audited within 30 days after comp 1.etion of the audit.

Contrary to the above, the following audits were not forwarded to these positions within 30 days after completion of the audit:

I Mr. R. C. Lewis July 6, 1983 Page Six Areas Audited Dates of Audit Date Forwarded I&C STP 2/7 - 2/21/83 3/28/83 Procurement 1/31 - 2/15/83 3/28/83 Plant Operations 1/1 - 1/25/83 3/7/83 FNP Emergency Program 1/3 - 2/1/83 3/7/83 Quality Control 11/22 - 12/2/82 1/5/83 Unit 2 Refueling 10/25 - 12/2/82 1/5/83 Safety Program 10/25 - 12/3/83 1/5/83 Material Control Activities 2/21 - 3/7/83 4/12/83 Environmental Monitoring 2/15 - 3/4/83 4/12/83 These examples are not intended to be all inclusive."

Admission or Denial:

The above violation occurred as described in the subject report.

Reason for the Violation:

This violation was caused by personnel error. The date of the Post Audit Conference marks the completion of the audit. However, a date other than and prior to the Post Audit Conference date was recorded as the audit completion date on a number of audit reports during the past two years.

Corrective Action Taken and Results Achieved:

This error was reviewed with the Lead Auditors on the SSAER staff, and training regarding documentation of audit completion dates was con-ducted for the members of the SSAER staff engaged in auditing.

Corrective Steps Taken to Avoid Further Violations:

See above. All corrective action was completed on June 15, 1983.

Date of Full Compliance:

Full compliance with Technical Specification 6.5.2.10.c was achiev-ed on May 17, 1983 with the issuance of Composite Audit Report No. 83/5.

Af fi rmation:

I affirm that this response is true and complete to the best of my knowledge, information and belief.

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l Mr. R. C. Lewis July 6, 1983 Page Seven The information contained in this letter is not considered to be of a proprietary nature.

. Yours very truly, F. L. Clayto , J r. k k L FLCJ r/KWM:nac/G-16

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Mr. R. C. Lewis July 6, 1983 bc: Mr. J. M. Farley Mr. W. O. Whitt Mr. R. P. Mcdonald Mr. H. O. Thrash Mr. ' 0. D. Kingsley, J r.

Mr. D. S. Mask Mr. J. W. McGowan Mr. W. G. Hairston Mr. W. H. Bradford File: 91A3.27/G-14

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