ML20070J983
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h sa FLO910A POWER & LIGHT COMPANY February 2, 1976 L-76-43 Mr. Norman C. Moseley, Director, Region II Office of Inspection and Enforcement U.
S. Nuclear Regulatory Commission 230 Peachtree Street, N. W.,
Suite 818 Atlanta, Georgia 30303
Dear Mr. Moseley:
Re:
IE:II:AKH 50-250/75-17 50-251/75-17 Florida Power & Light Company has examined the subject inspection
' report which noted the following items of noncompliance:
A.
" Contrary to Technical Specification 6.13.1.a, a High Radiation area was observed on December 11, 1975 to be improperly barricaded in that drums of radioactive waste in a fenced area outside the auxiliary building were roped off such that the radiation level at the barricade was approximately 200 millirem, whereas the limit is 100 millirem per hour."
B.
" Contrary to 10 CFR 50.54 (i-1), certain aspects of the Licensed Operator Requalification Program have not been performed and/or documented in accordance with the provisions of implementing Administrative Procedure No.
0301."
Our response to each item is as follows:
A.
The subject barricade was expanded outward approximately nine inches further away from the drums.
The radiation levels at the new barricade position were less than or equal to 100 mrem /hr.
The drums are now properly barri-caded.
In addition, the Turkey Point Health Physics Supervisor has instructed Health Physics Department per-sonnel on the importance of adhering to regulations governing the posting of radiation areas.
B.
Four examples supporting this item of noncompliance were listed in the inspection report:
.N 8222go24821130 SCHLISS82-534 PDR M E L PIN G B U l t. D C '. O A I C A
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"w Mr.. Norman C. Moseley, Director, Region II
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Page Two N.,
6 February 2, 1976 c y y
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" Step 8.1 of AP 301 requires a, quiz covering Y'
each lecture and a grade of less than 80%
s requires further study and an addjtiona'l quiz.
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Although the annual lecture series is nearing s
completion, training department records indicate that a number of licensed operator 6s.(12) had-takew only one quiz, and some operators (7) had n'ot taken K"~~
any quizzes.
Although some operators had received
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1 less than 80% on a. quiz,Hno additional quizzes had s
yet~been given.
The' quiz and additional quiz
..c requirements ~ of Ste'p' 8.'l were not being satisfied 'and documen ted. "-
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t Requalification lectu::e periods are scheduled so that each 3
operating shift receives one lecture ssssicin' o.veryllfive [?
weeks.
Quizzes.are scheduled to be given after byery second lecture session.
If an individual' misses a quiz,,
he is rescheduled to take the quiz at some l'ater date, usually on the next regularly-scheduled qu22 day." How.ever,'
conflict between refueling schedules a'nd raqualificatio'n
schedules has caused some requalificatiorclecture periods
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.s, and quizzes to be postponed until after refue, ling.
It is our position that -this does not oppose the intent of' AP 301.
At the time of the I & E inspection, there were some individuals who wgre behind the quiz schedule,.but the
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e Training Department was aware of dt and. plans. hod been Q;'
made to bring all licensed operators up to date with the quiz schedule before the end of the requalification. year (March 31, 1976).
At the present time, sig (ndividuals have not completed s
or scored higher than 80% on all of pheir requalification quizzes.
These individuals l comprise '12% of thp-licensees.
at Turkey Point.
ArrA3ngements have been,madeato ensure that these individuals will be'up to 4 ate with, respect to-the quiz schedule by the end of this requalification year.
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If by that time a licensee is, not 'up to 'dste, he willXnct %
"3 be eligible for licens'ed duties until such time'as he satisfactorily completes,all.Ehquired qu,izzes.
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(2)
" Step 8.2.1 of AP 301 requires all ope.rators~tg e
perform or direct a minimum of'10 reactivity changeEps,.
over a two-year cycle.
Figure 2,
" Log of; Reactivity
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Changes", gives det' ailed instructions and reghires, c
that theso changes be recorded and signed'by a superviser.
Steps 5.3.3 and 5.4.2 require that these logs be kept and maintained.
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Mr. Norman C.
t4oseley, Director, Region II Page Three February 2, 1976 3
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Upon review of these records, approximately one half
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' ', x 'of them were not up to date or blank The reactivity g
log sheet,s were not being kept as required by AP 301."
,x (3P 301'requirps shift personnel to maintain reactivity change log sheeta=in the Shift Supervisor's office.
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the time of 'the L & E inspection, seven individuals had s
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- blank 1pg sheetq\\on file in the Shift Supervisor's office.
However', all of these individuals were non-shift personnel
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who werc., keeping separate log sheets at their work loca-tions.,s
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,x The react'ivityN1og sheets are used to determine if each s
licenses ha:s, acquired.the necessary reactivity changes
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during the courap of his two year license period.
If he has pot,tsligulatdr time must be purchased to satisfy the necesSc7c irements.
From January, 1975 to January, 1976, th
.ve been over 100 major reactivity changes (startup, snutdowns, and trips).
Assuming each shift shared equally in these evolutions, the number of
,t s. _. c reactivity' changes acquired by each licensee on shift is approxipately 20 during 1975.
Many licensed operators had jogged 10 reactivity changes early in the year but had not bothered to log. subsequent reactivity changes.
These individuals have been requestad to update their reactisity log sheets.
To help ensure that this is accouplished, EurNeillance of Control Room log sheets will be,.'ipereased.
All reactivity change log sheets will be brgbaht up to date,bytthe end of the requalification year (March 31, 197 6)..
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' ". I (3)h* Step 8.2.3Ob'AP301requiresperformanceevaluations
' to be made of licensed operators during simulated or
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ac,tual emergency / abnormal (situations.
These evaluations should normallysbe made by the plant supervisor for his assigned operators and documented s,
'on Figpre 3,'" Performance Evaluation - Abnormal and L
Emergency PrCcedures."
Unsatisfactory performance s
requires,special training sessions followed by a re-evaluation.
Upon review of the evaluation records, the inspector found that the most recent documented operator evaluation'was performed in December,' 1974.
Periogmance evaluations were not being documented as requi qd'by Styp 8.2.3."
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p j Mr. Norman C. Moseley, Director, Region II Page Four February 2, 1976 e
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a Performance evaluation sheets are supposed to be available in the Control Room for use by shift supervisors in evaluating the performance of licensed operators under emergency or abnormal conditions.
It has been determined that, when the 1974 forms were removed from the Control Room for storage in Document Control, no new forms were provided.
1975 operating records have been reviewed and it has been
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documented which licensed operators.were involved in each off-normal occurrence.
The performance of each operator gf has been evaluated by the appropriate shift supervisor.
In add 4hion, the Training Department schedules simulated performdnce evaluations for all licensed operators and,.
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at'the aime of thc(I & E inspection, had scheduled such training for'the last three months of the requalification year (January through March, 1976).
Performance evaluations 4
ard currently 90% complete.and 100% completion is planned-by March 31, 1976.
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e'Per,formance' evalcation sheets the now available in the Shift Supe'rvisor's office for 6se in evaluating operator performance during actual erdergency/ abnormal situations.
Although such sheets were nottavailable in the Control e
Room during 1975, this does not mean that poor performance 4f) wen,t unnoticed.
Such performance receives immediate attention and if necessary special topics are added to the rgqualification lectures to help correct problems.
f (4)' " Step b.2.2 of AP 3'01 requires plant supervisors to discuss applicab]e, plant changes and modifica-tions, abnornal occubrences, FSAR Supp]ements,' technical
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specification change # and procedure revisions with all licensees on their, shifts.
Figure 1,
- iraining i
Report", documents this effort for each item.
The inspector reviewed the licensee's document' control
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records, ion issued,since December,in this area and found that almost a informut 1974 still required review by one or more operators.
All licensees are not being appraised of significant operator related information as required by Step 8. 2.2. "
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The document review process will be changed and AP 301 will be revised to incorporate the change.
The documents discussed above will be filed in each of two binders.
One binder will be maintained in the Control Room and the second binder will be assigned to the Training Department.
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Mr. Norman C. Moseley, Director, Region II Page Five February 2, 1976 Review signature sheets will be kept in the Control
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'l'i Room binder for use in documenting licensee review.
The new review process will be in effect and AP 301 will be revised by April 30,.1976.
In addition, it is planned to have all personnel who are expected to continue as licensed operators satisfy the document review requirements of AP 301 and bring themselves up to date by reviewing all documents which a
they may have missed during the current "equalification r
year.
The projected date for satisfying the review I
requirements is April 30, 1976.
'.o 2,
No proprietary information has been identified in the subject inspection report.
Very truly yours, N
Robert E. Uhrig m
Vice President REU/ MAS /cpc r.
cc:
Jack R. Newman, Esquire
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