ML20082A227
| ML20082A227 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 10/14/1983 |
| From: | Gerrets T LOUISIANA POWER & LIGHT CO. |
| To: | Madsen G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20082A191 | List: |
| References | |
| W3K83-1563, NUDOCS 8311180088 | |
| Download: ML20082A227 (4) | |
Text
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P OW E R & LIG H T/Waterford 3 SES/P. O. Box B/Killona, LA 70066 October 14, 1983 W3K83-1563 Q-3-A35.02.01 Q-3-A20.27 Mr. C. L. Madsen, Chief Reactor Projects Branch 1, Region IV
-5 ' y E,--
U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000
!s Arlington, Texas 76012 gg4g
Dear Mr. Madsen:
SUBJECT:
Waterford 3 SES Additional Information Requested For USNRC Inspection Report 50-382/83-18 The additional information you requested regarding the Nctice of Violation identified in Inspection Report 50-382/83-18 dt.ted June 30, 1983 is hereby submitted:
1.
What were the circumstances that permitted the assignment of unqualified personnel to do work on safety-related equipment?
The purpose of SAP-20, " Orientation, Training, Qualification, and Checkout of Startup Personnel", qualification is to provide adequate indoctrination and orientation to new personnel arriving and working at Waterford 3 SES.
It is not, the intent of this certification program to provide working level mechanical maintenance theory and practical applications training. Mechanical maintenance theory and practical applications training can and is received and documented in the following ways:
(1) past experience, (2) formal training courses, (3) on the job training, and (4) supervisor surveillance.
The two mechanics involved, Messrs. G. Rogers and A. Sneed both had previous experience at other facilities and at Waterford 3 SES.
Mr. A. Sneed has eight years experience at TVA and two years commercial experience, part of this experience was involved in balancing rotating equipment.
Both technicians had received informal tra_aing at Waterford 3 on vibration test equipment used in field measurements. Therefore, we feel that at the time of this incident, both mechanics were fully qualified to use the vibration monitoring equipment.
8311180089 831110 PDR ADOCK 05000382 G
PDR j
L l
Mr. C. L. Madsen October 14, 1983 W3K83-1563 i
Page 2
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A factor that contributed to the apparent indecisiveness was that the technicians were separated from each other's view by scaffolding and the noise level in the area generated more questions between the two than otherwise might be necessary, i
We do recognize the importance of establishing and maintaining the SAP-20 certification program. All Maintenance personnel providing support to Startup have been verified to be qualified or are completing qualification for Level I and Level II in accordance with SAP-20.
2.
What action, if any, was taken to determine the acceptability of readings taken by the individuals involved in this instance?
Two Startup engineers, Messrs. M. George and J. Burns were present at the time the vibration data in question was recorded. They personally verified the acceptability of the data. Both Startup Engineers are qualified Level II.
In addition, both Startup Engineers have a BS in Hechanical Engineering which includes vibration analysis as part of the
' Standard Mechanical Engineering Curriculum. The data sheet was reviewed and signed as acceptable by the Mechanical' Maintenance supervisor and included in SPO-36-002, Component Cooling Water Flow Balance and Pump Performance Preoperational Test.
In addition, Mr. M. George signed step 3.5.1 (1) of the acceptance criteria and procedure step 7.3.5.3.
3.
Was the vibration information included in the Startup Preoperational Test results?
The vibration information was included in SPO-36-002, Component Cooling i
Water (CCW) Flow Balance and Pump Performance Test, and was signed by the
(
Startup engineer as discussed in response to question number 2.
l 4.
Did the Startup engineer verify the accuracy of the vibration data taken?
Two Startup engineers, Messrs. M. George and J. Burns verified the l
accuracy of the vibration data.
5.
What assurance is there that unqualified personnel have not been used on previous preoperational tests that has caused test results to be invalid or questionable?
p.
?
Mr. G. L. Madsen October 14, 1983 W3K83-1563 Page 3 It is and has been the responsibility of the Maintenance supervisors and Startup engineers to ensure that individuals performing work are capable and competent to perform that work. This is accomplished by either direct supervision or periodic monitoring of work activities. Data sheets are reviewed by the Maintenance supervisors and Startup engineers.
All preoperational test results are reviewed by the Startup engineer, Test Director, Test Results Group and the Joint Test Group (JTC) in accordance with FSAR Chapter 14.
In addition, preoperational tests have been reviewed by QC and QC has identified QC witness / hold points. QC also performs surveillance of selected Startup activities.
The above reviews provide an adequate level of confidence that preoperational test results are satisfactory.
6.
What means do you or plan to have to assure that qualified Maintenance personnel are supplied to the Startup engineer? Is the Startup engineer required to discuss what jobs he has planned for the Maintenance personnel with the Maintenance foreman? If not, how do you assign the proper personnel?
The Startup engineers discuss specific manpower allocations and tasks to be performed with the respective Maintenance supervisors.
In eany cases the Startup engineer requests specific technicians / mechanics by name based on previous experience and past supervision. The Startup engineer and Maintenance supervisors however, retain the responsibility to ensure that work is performed using written approved procedures and by personnel capable of performing the work.
The Unit Coordinator Startup Maintenance reports directly to the Lead Startup Engineer and is responsible for coordinating manpower allocation and for conducting weekly meetings to discuss manpower requirements and required tasks to be performed.
The Startup Manager, Lead Startup Engineer and Maintenance Superintendent have reinstructed supervisors in the importance of utilizing personnel qualified to perform the assigned tasks.
7.
Are contract maintenance personnel included in the qualification and training requirements of SAP-207 If not what procedure covers the training and qualification of these maintenance personnel?
l J
y 7...
Mr. G. L. Madsen October 14, 1983 W3K83-1563 i
Page 4 Contract personnel assigned to maintenance are considered to be the same as regular LP&L maintenance personnel in regard to training and qualification for Startup related tasks. Therefore, these contract personnel are included in the training and qualification requirements of SAP-20.
8.
How are qualifications and training of maintenance personnel monitored (by managenent and/or QA Audits)?
Training of maintenance personnel is verified during the annual Technical Specification required audit of the W-3 Training Program. The next audit is scheduled for February, 1984.
In addition to this audit, training of personnel will be checked on a sampling basis during audits of the Mechanical, I&C, and Electrical Maintenance organizations. These audits are conducted twice a year; one for Corrective Maintenance and one for Preventive Maintenance.
If further information is required for this matter, please do not hesitate to contact me.
Very truly yours, T. F. Gerrets Quality Assurance Manager TFG:WJB:VBR cc:
N. S. Carns, M. J. Wise, J. L. Chapdelaine, P. V. Prasankumar, R. L. Novgrod, Central Records, Nuclear Records