ML20032B448
| ML20032B448 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 09/01/1981 |
| From: | Bemis P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20032B442 | List: |
| References | |
| 50-321-81-20, 50-366-81-20, NUDOCS 8111050553 | |
| Download: ML20032B448 (9) | |
See also: IR 05000321/1981020
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA ST., N.W. SUITE 3100
ATLANTA, GEORGIA 30303
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Report Nos. 50-321/81-20 and 50-366/81-20
Licensee: Georgia Power Company
270 Peachtree Street
Atlanta, GA 30303
Facility Name:
Hatch 1 and 2
Docket Nos. 50-321 and 50-366
Inspection at Hatch site near Baxley, Georgia
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Inspector:_P. R. Bemis
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Dpte 41gned
Approved by:[/[d
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1.
C. M. Upright' Sec
n Chief
D ee
igned
Engineering
spe
on Branch
Engineering and Technicai Inspection Division
SIJMMARY
Inspection on July 9-13, 1981
Areas Inspected
This special, una.,nounced inspection involved 56 inspector-hours on site in the
areas of personnel qualifications; organization and administration; onsite
review; training; requalification training; surveillance; nonroutine reporting;
and mitigating core damage training.
Results
Of the eight areas inspected, no violdtions or deviations were identified in six
dreas; two violations Were found in two areas (Failure to implement the required
requalification training for licensed operators and senior operators
para-
graphs 5, 9.b and 9.e; Failure to provide and maintain records of personnel
training
paragraphs 9.a, 9.c, and 9.d).
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REPORT DETAILS
1.
Persons Contacted
Licens< ? Imployees
- S. Baxley, Superintendent of Operations
- C. Belflower, QA Site Supervisor
- C. Coggin, Superintendent Engineering and Services
- T. Green, Assistant Plant Manager
- M. Manry, Plant Manager
- D. Moore, Supervisor - Nuclear Training
- T. Wilkes, Nuclear Security Supervisor
Other licensee emplo. vees contacted included technicians, operators, mechan-
its, security force membr es, office personnel, supervisors, and shift
supervisors and foremen.
NRC Resident Inspector
- R. P. gers
- Attended exit interview -
2. Exit Interview
The inspection scope and findings were summarized on July 12, 1981 with
those persons indicated in paragraph 1 above. The licensee acknowledged the
inspection findings.
3.
Licensee Action on Previous Inspection Findings
Not ir.spected.
4.
Unresolved items
Unresolved items are matters about which more information is required to
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determine whether they are acceptable or may involve violations or devia-
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tions. New unresolved items identified during this inspection are discussed
in paragraph 9.f.
5.
Personnel Qualification Program (36701)
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References:
(a) Technical
Specifications,
section 6,
Administrative
Controls
(b) ANSI N18.1-1971, Selection and Training of Personnel for
Nuclear Power Plants
(c) Regulatory Guide 1.8, Personnel Selection and Training
(d) FSAR 13.1.3, Qualification Requirements for Nuclear
Plant Personnel
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The ins 9ector reviewed the licensee's administrative controls to ensure that
minimum educational, experience and qualification requirements have been
established in writing and meet the requirements of the licensee's commit-
ments to references (b) and (c) above. The inspector reviewed the qualifi-
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cations for the following positions and the individuals occupying the listed
positions:
Plant Manager, Assistant Plant Manager, Superintendent of Operations,
Operaticns Supervisor, Shift Supervisor, Shift Foreman, Superintendent
of Plant Electrical Services, Plant Engineers, Shift Technical
'dvisors, Nuclear Tra ,ing Supervisor, Superintendent of Maintenance,
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Maintenance Supervisor, Maintenance Foreman, Health Physics-Radio-
chemist, Health Physics Supervisor, Chemistry Supervisor, Senior
Quality Control Specialist, Plant Operators and Selected Plant
Cra'tsmen and Technicians.
Based on this review one item contributing to a violation was identified.
Figure 6.2.2-1 in reference (a) requires plant operators to hold an NRC
reactor operator's license. The inspector found that one individual who had
been removed from license duties due to failing his annual requalification
examination had worked in a licensed capacity prior to completing the
requirements for having his license reinstated.
Serving in a licensed
capacity after an individual has been removed from licensed duties
constitutes one example of a violation (321/81-20-01; 366/81-20-01). Other
examples are given in paragraphs 9b and 9e.
6.
Organization and Administration (36700)
References:
(a) Technical
Specifications,
Section 6,
Administrative
Controls
(b) FSAR 13.1.2, Plant Organization
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The inspector reviewed the plant organization structure as described in the
facility technical specifications and the lines af authority and responsi-
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bility. The inspector also reviewed the recent chinge to plant organization
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structure had been reported to the NRC.
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Based on this review, no violations or deviations were identified.
7.
Onsite Review Committee (40700)
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Reference:
(a) Technical Specification 6.5.1, Plant Review Board
The inspector attended a meeting of the plant review board to ensure the
following:
The board was composed of a quorum of members on alternates
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defined in Technical Specifications 6.5.1.2 and 6.5.1.3 and the review
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process and qualifications were satisfied.
Prior to the meeting, the
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inspector informed the board that his participation in no way reflected
approval or disapproval of the decisions made. The inspector alsc reviewed
minutes to previous meetings and frequency of meetings.
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Based on this review an'd meeting attendance, no violations or. deviations
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were identified.
. 8. . Training '(41700)
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References:
(a) Technical Specifications, Section 6.0
(b) ANSI N18.1-1971, Selection and Training of Nuclear Power
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Plant Personnel
(c) Regulatory Guide 1.8, Personnel Selection and Training ~
(d) Regulatory Guide 8.13, Prenatal Radiation Exposure
?) HNP-203, General . Employee Training, Revision I date<t.
2/79
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The inspector reviewed the training program which ~ orovides the . required
trainina for the facility staff personnel. This program was reviewed to
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verify taat: the program complies with commi nents contained in references-
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(a) through (e) above; the' program covers training in the ' areas of admin-
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istrative controls and procedures, radiological'. health and sfaety, indus-
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trial safety, security procedures,- emergency- plan and quality assurance
training, fire fighting training, and pre-natal radiation exposure-training
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for females; and, audits are conducted by the 1icensee in the areas of
general employee training. The inspector reviewed approximately 20 training
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records and interviewed 15 individuals (8 licensed and 7 non-licensed).. The
inspector also attended the general employee training and took the quiz
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which was administered for badging purposes.
Based on this review and attendance at the training, three ' items contri-
buting to one violation and two inspector followup items were identified as
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discussed in paragraphs 8.a - c.
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a.
Security Violation
Three items contributing to one violation were identified. Due to the-
nature of the violation, these items will be discussed in Report
Numbers 50-321/81-19; 366/81-19 and carry the following numt ars for
tracking (321/81-19-01; 366/81-19-01).
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b.
Failure to Teach Industrial Safety in General Employee Training
Reference (b), Section 5.4 states in part that all persons regularly
employed in the nuclear power plant shall be trained in five areas and
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temporary maintenance and service personnel shall also be trained to
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the extent necessary to assure safe execution of their duties.
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One of the areas listed for training, industrial safety, was nG taught'
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in the session attended by the inspector.
Upon discussions with the
Training Supervisor the inspector found that the licensee had realized
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the problem and was in the process of developing the- necessary infor-
mation for instruction in the industrial safety area. This' item will
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be carried as an inspector followup item (321/81-20-04; 366/81-20-04)
until the li.wnsee factors this information into their general employee
training.
c.
Weaknesses in Presentation of Training Material During General Employee
Training
The inspector attended an entire general employee training class and
although the program as a whole was adequate the following weaknesses
were noted and discussed with the Training Supevisor.
(1) During the discussion on dose limits the instructor referred to
the 5(N-18) concept addressed in 10 CFR 20.101(b)(2) as a " banking
system" whereby one could draw on his account to obtain large
amounts of exposure. This banking concept is contrary to industry
philosophy of ALARA.
(2) When the instructors were going over an important concept, which
was also on the quiz, they would make their point by telling the
students that the reason they needed to know this concept was
because they would see it again later that day rather than
addrassing the safety significance.
(3) The slide used for the definition of radiation area and high
radiation area defines these areas in terms caf dose rates which
are contrary to 10 CFR 20.202 which defines these areas in terms
of doses.
(4) When the instructor was teaching the definitions and signs in
10 CFR 20.203 he would linger on the definitions, which were on
the quiz, and skip through the signs which are used to alert
personnel to problem areas.
The Training Supervisar assured the inspector these areas would be
addressed and change as socn as possible. These four items will
collectiv11y constitute an ;nspector followup item (321/81-20-05;
366/81-20 05).
9.
Requalification . aining (41701)
References:
(a) Technical Spe :ifications, Section 6.4, Training
(b)
10 SFR 55, Appendix A, Requalification
(c) ANSI N18.1-1971, Selection and Training sf Nuclea- Power
Plant Personnel
(d) Regulatory Guide 1.8, Personnel Selection and Training
(e)
FSAR 13.2, CoNuct of Operation
( f) HNP 200, Licensed Plant Personnel
Training and
Retraining, Revision 6 dated 1/81
(g) Quality Assurance Manual, Revision 35 dated P/81
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The inspector reviewed:
the licensee's prepared schedule for conducting
lectures; the licersee's prepared lesson plan for three lecture topics; and
the licensee's inclusion in the requalification program of deficient areas
identified by evaluation of the most recent annual examinations.
The
inspector determined which licensed operators:
failed all or portions of
the annual examinations; received unsatisfactory performance evaluations;
had not performed licensed duties for a period four months or longer. The
inspector verified the completion of appropriate follow through action for
each of these individuals. The inspector reviewed the training records of
12 NRC Licensed Reactor Operators and Senior Reactor Operators to verify
that they included:
copies of annual written examinations and the indi-
vidual responses, documentation of attendance at all required lectures,
documentation of the required control manipulations, the results of per-
formance evaluations, documentation of required additional training to
satisfy deficient performance, mcumentation of completion of required
procedure reviews and/or self-study. Additionally, the inspector inter-
viewed ten SR0 licensed individuals to verify that the training records
reflect the actual training received.
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Based on this review, five items contributing to two violations and one
unresolved item were identified and discussed in paragraphs 9.a-f.
Failure to Document Removal or Reinstatement of License Privileges to
a.
Licensed Shift Personnel.
Reference (f), Section 3.a requires . licensed personnel who score less
than 70% in any section or 80% overall on the annual requalification
exam to be removed from licensed duties. Referer.ce (g), Section 17.2
states in part that measures shall be established to assure records are
maintained to provide documer+rry evidence and that these records
include qualifications of personnel and these records shall be retriev-
able.
Contrary to the above, when the inspector reviewed the resu:ts of the
1980 requalification examination and found 12 people who had either
made less than 80% overall or 70% in one or more sections, the licer.ase
could only produce documentation in three cases where training hac
notified operations that the individuals had to be removed from
licensed duties. The inspector reviewed the operating logs to deter-
mine if the nine individuals in question had been removed from shift
licensed duties.
Based on tne review of the logs, it could not be
determined that the individuals were removed from licer;ed duties.
Based on the review of the licensee's records, no records could be
produced to show where licensed personnel are removed from licensed
duties when reouired. This failure to document removal from licensed
duties contributes to a violation (321/81-20-02; 366/81-20-02). Other
examples ara given in paragraphs 9c and 9d.
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b.
Failure to Meet Requirements of Agproved Requalification Program
References (a) and (b) requires the licensee to meet the requirements
of their accelerated requalification program.
Reference (f) which
implements the approved program, requires that individuals who make
less than 70% in any section or 80% overall attend an accelcrated
requalification lecture for the affected sections and pass an exami-
nation on that section.
When the inspector reviewed the means by which the licensee was meeting
this requirements, the licensee was found to be deficient in the
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following three areas:
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(1) The licensee was taking credit for R0-level examinations .< hen the
individual failed a SRO Jection of the examination
(2) The licensee took credit for an examination given by a vendor to
an RO upgrade class to meet the criteria for SR0s who had failed
certain sections. The inspector determined that only 30% of the
questions were SR0 level
(3) The licensee took credit for lectures and examinations given to
individuals prior to the annual requalification examination being
graded.
The three areas collectively contribute to an item of violation
(321/81-20-01; 366/81-20-01). Other examples are given in paragraphs 5
and 9e.
c.
Failure to Store QA Records in Qualified Containers
The licensee's Quality Assuance Manual, Section 17.2 requires in part
that those records defined as QA records be stored in facilities which
are constructed, located and secured to prevent destruction of the
records through fire, flooding, theft, and deterioration by temperature
and humidity conditions.
Records of personnel qualifications QA
records.
When the training department writes a memc to operations which requires
an individual to be removed from licensed duties, this memo is being
stored in the Training Supervisor's desk.
This failure to meet the
storage requirements for QA records contributes to a violation
(321/81-20-02; 366/81-20-02). Other examples are given in paragraphs
9a and 9d.
d.
Failure to Maintain Adequate Records for Requalification Program
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Attendance
Reference (A) requires reference (b) to be followed.
Reference (b),
Section Sa, requires in part that documentation of any additional
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training administered in areas in which an operator or senior operator
has exhibited deficiencies shall be maintained.
The licensee does not maintain records showing that operators or senior
operators who are required to attead accelerated requalification
lectures or annual requalification lectures have attended these
required lectures. This failure to maintain records contributes to a
violation (321/81-20-02; 366/81-20-02). Other examples are given in
paragraphs 9a and 9c.
e.
Failure to Make Annual Determination of Licensed Personnel Weak Areas
References (a), (b), and (f) require the licensee to determine annually
the weak areas of licensed operators.
The licensee Jid not make an
annual determination for the 1980 requalificution year, in that, one
set of annual examinations was not graded for three months and one set
was not graded for almost four months after the examinations were
given. This failure to make an annual determination contributes to a
violation (321/81-08-01; 366/81-20-01). Other examples are given in
paragraphs 5 and 9b.
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f.
Failure to Meet NRC Grading Criteria on the Annual Requalification
Examination
Reference (f) which implements the NRC approved requalification program
and NUREG 073'i, item I. A.2.1 which implements the March 28, 1980 letter
from the Director of the NRC Office of Nuclear Reactor Regulation and
has been committed to by the licensee. This requires in part that an
individual making less than 80% overall on his annual requalification
examinatior. has failed the exam. If an individual fails the examina-
tion by making less than 80% overall, he shall take a new examination
to include all sections of the examination. The licensee has inter-
preted this requirement to mean that if an individual makes less than
80% overall he only has to retake these sections where he made less
than 80%. Until this item is reviewed by NRC management, it will be
carried as unresolved (321/81-20-03; 366/81-20-03).
10.
Surveillance (61700'
References:
(a) Technical Specifications, Section 4
(b) HNP 1-3405-0, RCIC Pump Operability, Revision 10 dated
5/81
(c) HNP 1-3405-1, Procedure Data Package
(d) HNP 2-3164-0, RHR Valve Operability, Revision 10 dated
6/81
(e) HNP 2-3164-1, Procedure Data Package
(f) HNP 1-3303-0, HPCI Pump Operability, Revision 11 dated
7/81
(g) HNP 1-3303-1, Procedure Data Package
(h) HNP 1-3316, HPCI Quick Start, Revision 4 dated 5/81
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The inspector witnessed portions of the surveillance testing accomplished by
the referenced procedures.
For the tests witnessed the following was
verified- the test procedure was available and in use; the special test
equipment required by the procedure was calibrated; test prerequisites were
met; system restoration was correct; tests were in conformance with tech-
nical specifications; completed tests were reviewed as required by technical
specifications; tests were performed within the time frequencies specified
by technical specifications; and tests were performed by qualified indi-
viduals.
Based on this review, no violations or deviations were identified.
11. Nonroutine Reporting Program (90714)
References:
(a) HNP 424, Notification of Significant Events, Revision 4
dated 3/81
(b) HNP 425, Deviation Report, Revision 7 dated 2/81
(c) HNP 426, Reactor Scram Report, Revision 4 dated 1/80
(d) HNP 428, Safety Limit Violation Report, Revision 0 dated
2/81
(e) HNP 450, Reportable Occurrance Reports, Revision 5 dated
10/80
(f) HNP 456, Reporting of Defects and Noncompliance,
Revision 4 dated 4/80
(g) QA 05-13, Open Items Control, Revision 6 dattd 10/80
(5) HNP 480, Industrial Sabotage and Unaccounted for Ship-
ments, Loss, Suspected Theft, or Unlawful Diversion of
Special Nuclear Material or Licensed Materials, Revision
3 dated 3/81
(1) HNP 482, Reporting Significant Trends, Revision 0 dated
3/81
The inspector reviewed references (a)-(i) to verify that administrative
controls have been established:
for the prompt review and evaluation of
off-normal events to assure identification of safety-related events; for
prompt review of planned and unplanned maintenance and surveillance testing
to assure technical specification requirements are being met; for completion
of corrective actions; and to insure recognition and reporting of 10 CFR 21
items.
The inspector also verified that administrative controls were
established for prompt review of vendor information that would effect
licensee safety-related equipment.
Based on this review, no violatf ors or deviations were identified.
12.
NUREG 0737 Commitments (92704)
The inspector reviewed the licensee's commitments to NUREG 0737 in the areas
of training of shift technical advisors and mitigating core drmage training
for operations and specialty group personnel. In addition to the
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commitments,
the inspector verified the licensee's development and
implementation of the programs for shift technical advisors and mitigating
core damage.
Based on a review of the licensee's comitments and implementation, no
violations or deviations were identified.