ML20032B443
| ML20032B443 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 10/08/1981 |
| From: | Widner W GEORGIA POWER CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20032B442 | List: |
| References | |
| NUDOCS 8111050548 | |
| Download: ML20032B443 (5) | |
Text
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Gec gra Power Cwpany 333 Pedmor:t Awnue i
Acanta. Gemg a 30308 Tek phore 404 526-7025
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Ma hog Addrcss' Post Office Boa 4545 At%,fd. Georg a 30302 il 0 # i i;i
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GeorgiaIbwer W. A. Widner -
er 8, DM N weMm sen Vice Prescent and General Manager F oss.1 and Hydro Gene shon U. S. NtJclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: JP0 Region II - Suite 3100 50-321/50-366 101 Marietta Street, N'll Inspection Report 81-20 Atlanta, Georgia 30303 ATTENTION: Mr. James P. O'Reilly GENTLEEN:
4 Georgia Power Company offers the following.in response to NRC Inspection Report 50-321/81-20 and 50-366/81-20 dated September 8, 1981, concerning the notice of violation for Hatch Unit 3 and Unit 2.
VIOLATION A.
Technical Specification 6.3 requires that the plant staff shall meet or exceed the requirement of ANSI N18.1-1971.
Technical Specification Figure 6.2.2-1 requires certain plant operators to hold an NRC operator license.
10 CFR 55, Appendix A, requires the licensee to follow his WC-approved operator requal!fication program.
1.
ANSI N18.1-1971 requires an operator to hold an NRC operator license before accepting full responsibility for a licensed position.
Contrary to the above, one individual removed from licensed duties during the first week of December 1980 due to failing his annual requalification examination continued performing in a position requiring a license prior to meeting all requirements for the licensed position of January 4,1981.
2.
HNP-200, Licensed Plant Personnel Training and Retraining, Revision 6 dated January 1981, implements 10 CFR 53, Appendix A.
This procedure ~ requires that individuals who fail the annual requalification examination must attend accelerated requalification lectures and be administered an examination in those failed sections.
Contrary to the above, the licensee took credit for attendance at lectures and retake examinations to meet this requirement for the 1980 requalification year in the following unacccptable manner:
a.
Credit was given for. reactor operator level examinations conducted by the plant when the personnel failure was on the Senior Reactor Operator level.
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s GeorgiaPower d U. S. Nuclear Regulatory Commission O'fice of Inspection and Enforcement Atlanta, Georgia 30303 October 8, 1981 Page Two b.
Senior Reactor Operators (SRO) who previously failed their examination were given credit for material presented by a contractor to a
reactor operator upgrade class when approximately 70% of the upgrade examination was not SRO level.
c.
Credit was given to one individual for lectures and examinations before the inoividual's examination papers had been graded.
3.
10 CFR 55, Appendix A, Section 4.a and the licensee's operator requalification program require annual written examinations which determine areas ir, whicn retr. lining is needed to upgrade licensed operator and senior operator knowledge.
Contrary to the above, an annual determination was not made for the 1980 requalification year in that one set of 1980 requalification examinations, even though conducted in a timely manner, were not graded for three months and a second set of 1980 requalification examinations required almost four mm'is for grading.
This is a Severity Level IV Violation (Supplement I.D.).
RESPONSE
Item A.1 a)
Admission or denial of alleged violation:
The violation is
- admitted, b)
Reasons for violation:
The subject individual was not notified of his removal from licensed duties because of insufficient plant administrative controls.
c)
Corrective steps which have been taken:
Administrative controls have been implemented to ensure tnat in addition to Operations supervision, the licensee is also notified of his removal from licensed duties and of his responsibility not to manipulate plant controls until he receives a written requalification statement from the Training Department.
d)
Corrective steps which will be taken:
The preceding action will prevent future violations, e)
Date of full compliance:
Full compliance was achieved on September 30, 1981.
s Georgia Power 1 U. S. Nuclear Regult'Try Commission Office of Inspection and Enforcement Atlanta, Georgia 30303 October 8, 1981 Page Three RESPONSE (Continued)
Item A.2 a)
Admission or denial of alleged violation:
The violation is
- denied, b)
R_eason for denial (item A.2.a ar.d A.2.b):
To be qualified as a e
Senior Operator an individual must have the knowledge of a Reactor Operator.
10 CFR 55 and procedure HNP-200 require the same set of requalification lecture topics for both Senior and Reactor Operators.
It is Georgia Power's policy to teach these lecture topics in sufficient depth to cover Senior Operator knowledge.
Both Senior and Reactor Operstors attend the same lectures and receive the same lecture examinations.
Occasionally examinations are labelled by a section number which relates to a training question bank, but this section number does not directly relate to the question level (R0 nr SRO).
Further, question level is not clearly defined in regulations; for example, the Operator Licensing Branch of the NRC has administered almost identical questions to both Senior and Reactor Operator candidates.
Reason for denial (Item A.2.c):
The alleged violation is not contrary to the requirements of 10 CFR 55, procedure HM2-200 or any other requirement.
Before grading the annual examination of the individual in question he received the next quarter's requalification lectures and examinations.
When the annual examination was graded, the results were that he received less than 70% in a section just covered in the quarter's training. Since his quarter's examination resultc were above 80%, another training class in the same subjects were not administered.
Training practice at the plant is to send individuals to retraining classes based on a quarterly training schedule rather than on an "as needed" basis due to the annual examination results.
Sometimes this retraining is attended before the individual's annual examination is graded, and the individual should receive credit for this action and not have to attend duplicate classes.
Item A.3 a)
Admission or denial of alleged violation:
The violation is admitted.
b)
Reasons for violation:
Several annual examinations in 1980 were graded after a substantial time had elapsed due to workload.
l
k Georgia Power h U. S. Nuclear Regulatory Commission Office of Inspection and Enforcenent Atlanta, Georgia 30303 October 8, 1981 Page Four RESPONSE ITEM A.3 (Continued) c)
Corrective actions which have been taken:
Contract instructors have been added to our staff to reduce the workload, and annual examinations are now graded within two months.
d)
Corrective actions which will be taken:
Georgia Power is increasing its training staff and will change its administrative procedures to require that all examinations are graded within two months.
e)
Date of full compliance:
Full compliance will be achieved on Novemoer 15, 1981.
VIOLATION B.
10 CFR 50, Appendix B Criterion XVII requires that sufficient records shall be maintained to furnish evidence of activities affecting quality.
The records shall include qualification of personnel.
It elso requires that applicant to establish requirements concerning record retention and location.
The Quality Assurance Manual (QAM) Section 17.2, Revision 35 dated February 1981 implements this requirement.
1.
The Q44 states that QA records shall be stored in facilities which are constructed, located and secured to prevent destruction of the records through
- fire, flooding, theft and deterioration by temperature or humidity."
Contrary to the above, personnel qualification records in the form of records removing a licensed operator from licensed duties are being stored in the Training Supervisor's desk which does not meet the above criteria.
2.
The QAM requires QA records to be maintained.
Contrary to the above, the licensee could not furnish records on 9 of 12 people which had been removed from licensed duties due to failing the 1980 annual requalification examination.
3.
In addition to QAM Section 17.2 which requires evidence of activities affecting quality,10 CFR 55, Appendix A, Section 5.a and the licensee's approved program require that documentation of any additional training administered in areas in which an operator or Senior Operator has exhibited deficiencies shall be maintained.
Contrary to the above, records were not being maintained to show that operators and senior operators have attended the required accelerated requalification or annual requalification lectures.
This is a Severity Level V Violation (Supplement I.E.).
es GeorgiaPbwer ak U. S. Nuclect Regulatory Commission Office of InsNction and Enforcement Atlanta, Georgia 30303 October 8, 1981 Page Five
RESPONSE
a)
Admission or denial of alleged violation:
The violation is 1
denied.
b)
Reason for denial:
Sufficient records are maintained in secure files to document that:
a.
Personnel are removed from licensed duties as required, and b.
Personnel do attend required lectures.
These records are in the form of individual graded examinations and plant logs.
Annual and requalification examination records are sufficient to verify compliance with training requirements.
Plant logs are sufficient to verify that personnel are not assigned licensed duties.
In addition the records cited in the v'.olation are kept for Georgia Power's convenience and are not requitad to be maintained in stated manner.
If you have any further questions regarding Inspection Report 81-20, please do not hesitate to contact my office.
W. A. Widner states that he is Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief the facts set forth in this letter are true.
GEORGIA POWER COMPANY By:
I W. A. Widner Sworn to nd subscribed efore m this 8th day of October, 1981.
Notary Public. Georgia, State at Large
/ f _ #.
My Commission Expires Sept. 20,1983 Notary Public MJB/mb xc:
M. Manry R. F. Rogers, III
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