ML20070D528
| ML20070D528 | |
| Person / Time | |
|---|---|
| Site: | Seabrook  |
| Issue date: | 07/06/1994 |
| From: | Feigenbaum T NORTH ATLANTIC ENERGY SERVICE CORP. (NAESCO) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NYN-94074, NUDOCS 9407080161 | |
| Download: ML20070D528 (6) | |
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-.hTOrill North Atlantic Energy Service Corporation
. -y P.O. no 300 f((3g{jg Seabrook, Nil 03874 (603) 474-9521, Fax (603) 474 2987 s
The Northeast Utilities Systern Ted C. Feigenbaum i
NYN-94074 Senior Vice President 8.
Chief Nuclear Officer July 6,1994 United States Nuclear Regulatory Commission Washington, D.C. 20555 Attention:
Document Control Desk
References:
(a)
Facility Operating 1.icense NPF-86, Docket No. 50-443 (b)
USNRC Letter dated June 6,1994, " Notice of Violation (NRC Inspection Report No. 50-443/94-08)," J. F. Rogge to T. C. Feigenbaum
Subject:
Reply to a Notice of Violation Gentlemen:
In accordance with the requirements of the Notice of Violation contained in Reference (b), the North Atlantic Energy Service Corporation (North Atlantic) response to the cited violation is provided as Should you have any questions concerning this response, please contact Mr. James M. Peschel, Regulatory Compliance Manager, at (603) 474-9521, extension 3772.
Very truly yours, b
QE y
Ted C. Feigenbaum/
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Unijed States Nuclear Regulatory Commission July 6,1994 Attention: Document Control Desk Page two cc:
Mr. Thomas T. Martin Regional Administrator U.S. Nuclear Regulatory Commission Region i 475 Allendale Road King of Prussia, PA 19406 Mr. Albert W. De Agazio, Sr. Project Manager Project Directorate I-4 Division of Reactor Projects U.S. Nuclear Regulatory Commission Washington, DC 20555 Mr. Antone C. Cerne NRC Senior Resident inspector P.O. Box i149 Seabrook, Nil 03874 s
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North Atlantic July 6,1994 ENCI.OSURE I TO NYN-94074
IEPIN TO A NOTICE Or VIOLATION in a letter dated June 6,1994 [ Reference (b)), the NRC transmitted to North Atlantic Energy Service Corporation (North Atlantic) a Notice of Violation identi0ed by the resident staff during the inspection period of April 12 through May 23,1994. In accordance with the instructions provided in the Notice of Violation, the North Atlantic response to this violation is provided below.
1.
Violation 10 CFR 50, Appendix fl, Criterwn 11 requires that plant workers be provided with indoctrination and training for activities affecting quality as necessary to assure that suitable pro 6ciency is achieved and maintained. Furthennore, Seabrook Station Quality Assurance Manual, Section 2.2 speciGes that support personnel shall meet the requirements of ANSI /ANS 3.1, which requires that maintenance workers receive instructions and demonstrate the performance capability for special complex systems and components.
The training shall be based on a task analysis of the worker's assigned function.
Contrary to the above, on April 10,1994, a maintenance uorker demonstrated neither suitable proficiency, nor performance capability in the conduct of a safety-related activity. The worker improperly operated i
the containment personnel air-lock resuhing in equipment damage and personnel injuries. There was no evidence that Ae maintenance worker had received adequate training for thisjob, which should have been based upon a comprehensive task malysis of all onerational aspects of the assigned functions.
This is a Seserity Lesel IV violction (Supplement I).
II.
Reason for the Violation North Atlantic does not contest this violation. The reason for why a maintenance worker demonstrated neither suitable proGeiency, rior performance capability in defeating the interlocks and opening the containment personnel hatch consists of two components, training and work assignment. These causes are discussed below.
Trainine The maintenance worker who performed this task was qualified under the Job Incumbent Review (JIR) process to perfonn maintenance on the containment hatches, hence no formal training was necessary at the time of the J1R. The J1R process is a mechanism by wnich experienced workers receive qualification for a task based on their education and previous work history. The JIR process is utilized when workers transfer departments new employees are hired, new qualification programs are established, or when tasks are added to existing qualiGeation programs. The JIR process that was in place when the maintenance worker received quali0 cation utilized a Job incumbent Review Committee consisting of a supervisor, training coordinator, and a department supervisor. This committee evaluated a worker's background and work history applicable to a task and compared it to the skills required to perfonn the task as delineated in the task qualification guide. The committee then determined whether the individual possessed the requisite knowledge and skills to perfonn the task, or whether the individual required training to obtain the requisite knowledge and skills. North Atlantic has not ider. tined any deficiencies with the JIR process.
In this pa:ticular case, the JIR process adequately evaluated that the worker was qualified to perfonn -
maintenance on the containment hatches, however, as described below, the scope of the qualification guide was not updated to redect the new task of operating the air-lock and defeating the interlocks.
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e As stated above, North Atlantic has detennined that a new task was not identified for operating the air-lock and defeating the interlocks. Qualification guides are intended to delineate the knowledge, skills and other qualifications necessary for an individual to successfully complete a task. Maintenance related.
qualification guides are typically created and/or revised at the request of the Maintenance Group. In this particular case, the qualification guide pertained to basic maintenance of the hatch operating equipment.
This task was subsequently proceduralized and its scope was expanded to include defeating the interlocks to open both hatches. Ilowever, this new procedure was not reviewed to determine if the original qualification guide also required revision. llence, a new task was not added to the qualification guide and it was not reviewed for training impact.
North Atlantic has determined that the new job task was overlooked due to inconsistencies in the way maintenance related qualification guides were reviewed and revised, as necessary, to reflect new tasks or task scope modifications, ideally, when procedures are revised, the individual who revises the procedure apprises the training coordinators of the changes, w ho in turn, evaluate the need to revise the qualification c
guides and detennine if any workers require retraining, flowever, this methodology was inconsistently applied by the Maintenance Group.
Work Assienment The work assignment process utilized for this specific activity was not in accordance with the existing North Atlantic program and this contributed to this event. Specifically, this task required a minimum of two workers, yet only one was assigned to perform it. Additionally, this was an infrequently perfonned task with the potential for serious consequences if performed incorrectly, but no experienced workers were assigned to the task. Furthennore, contrary to Maintenance Group expectations for infrequently performed tasks where workers may not be proficient, the supervisor was not on thejob at the start of the task.
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Corrective Actions That llave Been Taken l
1.
Immediately following this event, North Atlantic stopped refueling outage related work and discussed this event with managers and first line supervisors. This discussion re-emphasized the_
3 need to perform tasks correctly and in accordance with procedures. Station managers and
_ supervisors subsequently discussed this event with subordinates.
2.
North Atlantic has temporarily assigned the mechanical, electrical, and I&C maintenance training coordinators to report to one supervisor. This will Nsure consistency in the way procedures, procedure changes, and tasks are reviewed and incocporated, as necessary, into the qualification guides. - This will also add consistency to the communications between the individuals who-develop the procedures and the training coordinators.
3.
North Atlantic has counselled the supervisor and workers directly involved with this event and has -
implemented disciplinary actions as appropriate.
4.
North Atlantic has revised selected management training courses to include a discussion of the -
supe..Tisor's responsibility to carefully consider the individual abilities of personnel assigned to tasks where skill of the worker will play a significant role in the outcome of the task.
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s noted in the original event esnluation, Nonh Atlantic has transferred the responsibility of defeating the imerlocks and opening the containment airlock hatches to the Operations-Deparenent. To facilitate this, a new Operations pro:edure and Job Performance Measure (JPM) l>cvc been written and selected members of the Opetuions D4anmerit haw received training on this evolution.
IV -
Corrective Actions That Will Be Taken North Atlantic wUl iraplement the following corrective actions:
1.
Nonh Atlantic is in the process of reviewing all maintenance procedures and repetitive task sheets (RTSs) to serify that tasks that require training or qualification, have been identined and are ndegately addressed in the qualification guides. This review will be completed by July 8,1994.
Notwithstanding this, during the review process, if critical tasks are identitu 'br which qualification is determined to be inadequate, immediate remedial actions will be taken to ensure that workers can adequately perform the subject task.
2.
The Nonn Atlantic Maintenance Group will subsequently determine which, if any, workers require trairdng or retraining to adequately address the scope of the tasks identiGsd in action IV.1, above.
This evaluatier will be completed by,Iuly 15,1994.
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Qualificaticu guides that need to be developed er revised will be completed by December 31, 1995, or sooner, as necessary to support the qualification of workers. In accordance with the existing program, North Atlantic will ensure that only quali6cd workers are assigned to perform tasks.
4,
.When the lesson plans for the management training courses described in action Ill.4 above have been updated, a rumniary memorandum of the enhancements will be distrib.ted to appropriate; menagers and supervisors. This will ensure that these ideas and concepts are communicated to the management team in an expeditious manner. It is anticipated that this summary memorandum.
will be developed by August 31,1990 V.
Date When Full CoxnnEance Will fle Achieved North Atlantic will achieve fuit compliance by July 15, 1994, when action IV.2 above, is completed.=
- Completion of thi3 action will ensure that only qualified workers weil be assigned to perfbrm tasks that require qualification.
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