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i W. P. Ellis. Raforcement Coordinator Offies of Imepection and Enforeement. SQ JCP&L (CESTER CREEK) -
PROPOSED CIVIL FEMALTY Raelmeed are a proposed latter to che Ha===
and proposed Notice of Viol. ties. Both have been revised in menordance with the esaments in our July 3 memo.
We have again shown a se distribution es was done on our original pro-posal, dated April 25, 1975. JCF&L is another liesasee for which NRC has committed to provide A. Z. Reisman with correspondence.
(For your information there are six licensees with operating reactors in this category.)
A revised Not. ice of Proposed Imposition of Civil Penalties is not in-cluded. The only change necessary is to correct the dollar amount to
$31,000.
Eldon J. Brunner, Chief Reactor Operations Branch
Enclosures:
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As Stated l
ect F. A. Dreher j
bec: E. Brunner D. Caphton E. Greenman E. McCabe' G. Snyder R. Glasscock W.P.
I Bruner:ny Greenman Caphton McCabe 0
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7 1/9 73 9604230040 960213 PDR FOIA DEKOK95-258 PDR
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Decket No. 50-219' -
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Jersey Central Power and Light Campsey I
Attenties: Dr. S. Bertmoff President I
Madison Agames at Pomek Bori Reed l
Morristema, New Jersey 97960 i
samtimment l
This refers to the taspection esaduated en March 10-14, 1975 by Messrs.
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, Greemmen, Glasocock and Smith of our Regies I office in King of i
Prussia, Poemsylvania, et year Oyster Creek Neelear Generating Station.
of activities authorised.by NBC Lisease No. DPR-16, and to the discussions of our findiass held by Mr. Brunner and other members.ef the Region I office with Mr. Fimfrock and other members of your staff at the conclusion j
of the taspection.
Based on the results of this inspection it appears that certain of your activities were not conducted in full compliance with 10tC requirements i
as set forth in the Notice of Violation, enclosed herewith as Appendix 2
A.
Tha. Items of Noncompliance identified in Appendix A are the result i
of failure to imp 1===mt the Operatimaal Quality Assurance Plan (FSAR A==mamant 71) submitted to the NRC as your means of meeting Appendix B, 1
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10 CFR 50 requirements by your letter, dated March 22, 1973, as aupple-i mented and revised by submittal of FSAR h t 71, Revision 1, dated December 19, 1973 and FSAR Amendment 71, Revision 2, dated October 1, 1974.
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During this inspection, apparent items of acacompliance with 10 CFR 50, i
Appendix B, Criteria II, V, VI, VIII, and IVI were identified, with i
several of these also being contrary to the Oyster Creek Taehnical Specifications. These, when viewed collectively, show a breakdown in management and procedural controls with respect to quality assurance j
implementation. Specifically, in the Notice of Violation, failure to esoply with Criteries II is demeestrated by Iteen 5 and 10. Failure to esafers to Criterien III, Design Control, is documented in Item 9.
Failure to comply with Criterica V is apparent by inadegente =a=8et-j trative sentrols ever plant operations,==i=*a===*a, and record eentrol as demonstrated in Itase 6, 7, 11 and 12. Failure to imp 1 - t the Deeumont Centrol requiremmats of Criterian VI is demeestrated la Items 1, 2 and 3.
Failure to identify and sentrol materials la escordamee with criteriam VIII is demonstrated by Item 13. Failure to implement i
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the Test control requirements of Criterian II is shown by Item 4.
Failure j
to semply with meneenfermanos requirements of Criteries 17 is desamented j
in Item 8.
Failure to implement peroommel traintmp and classification requirements is demonstrated by Item 14.
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With respect to Itas 1 is the Estime af Violation (Appendix A), F S C l
rarier of eight examplas of serveillasse procedures uns esmpleted prior j
to the and of the inspection em Marek 12, 1975. Alas, prior to esmple-tien of the inspectiam, the liasmose's Procedure 102, dimb te refer-i emoed in Item 15 of Appendix A, was asemptably rarised to indiente esist-I tes training Praettees. The limammed operators /anstar operatore referred j
to in Item 14 of Appendiz A received and seesessfully passed the assaal eneminatises prior to the sempletian of the inspecties. Commequently, j
you need not reply to these speciffs citations in your response to this letter. However, please disemos, in your reply, the actions taken with respect to the above matters to assure future compliance with the regulatory requirements.
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Additional Infractions, identified through your internal audit program j
are set out in the Import Details. No additiemal information is re-quired on these items at this time.
l As you are ausre from "Criters; x Deter =4 ming Enforcement Action,"
l which was provided to you by a J.c.ter dated December 31, 1974, the enforcement actions available to the Ceemission in the esercise of its regulatory responsibilities include admi=iatrative actions in the form of written motices of violations, civil monetary penalties, and orders l
perem4=i=g to the modification, suspension or revocation of a license.
j After careful evaluation of the items of moneempliance identified in Appendix A and the results of our inspecties, this office proposes to l
impose civil penalties pursuant to Section 134 of the Atomic Emergy Act of 1954, as amended (4 USC 2282) and 10 CFR 2.205, in the cumulative l
mesunt of Thirty-eme Thousand Dollars ($31,000) as set forth in the
" Notice of L a M Imposities of Civil Pensities"==*1a==d herewith as A pendix 3.
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In additism to the corrective actimen regarding the specifts items i
listed in Appendix A, we are esmeermed about the impiammatariam of year Operatismal quality Assuramme Program with respect to adheressa to NASH 1283, Borisism 1. WARE 1284 and WARE 1309 in meestdames with pages 24 i
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and 24s of your Operatismal Quality h Flam (FSAR Ammedmont 71).
W tly, in year reply, you ehem14 deserthe, in parei-t=r, these astimes taken er plassed to esapletely implement these standsuds, in-
- 1=diep a sehadule for aseamp14=htop the activities.
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Excerpts of serrx;- ' -- = soneerains the development of a quality Assurance program are enclosed as Appendiz C and the history'of faspec-tism fi= dings is -1a=ad as Appendix D.
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Tour reply to this latter will be seasidered in determintas abether'any further enforcement astime, ameh as modifiaaties, suspensima, or revoca-tima of the 11samme, is appropriate.
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Sincerely, i
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5 Donald F. Emoth, Director Office of Inspection j
and Enforcement i
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Enclosures:
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Appendix A, Notice of Violation j
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Appendix B, Notice of Proposed Imposition of Civil Penalties 3.
Appendix C l
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Appendix D, History of Inspection Findings a
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- 1. R. Finfrock, Jr. Vice President-Generation l
A. Z. Roissan, Counsel for Citizens Committee for Protection of the Fa ironment l
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' DRAFT APPENDIX A Jersey Central Power and Light Company Docket No. 50-219 Attention:
Dr. S. Bartnoff License No. DPR-16 President Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 NOTICE OF VIOLATION Gentlemen:
Based on the results of an NRC inspection conducted on March 10-14, 1975, it appears that certain of your activities were not in full com-pliance with NRC regulations and the conditions of your license as indicated below.
Each item is based on requirements of the Oyster Creek Operational Quality Assurance Plan (0QAP) which you submitted to the NRC as implementation of 10 CFR 50, Appendix B - Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants.
Items 1 through 8 are classified as Infractions with items 11 through 15 classified as Deficiencies.
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Criterion VI, Appendix B, 10 CFR 50 requires that safety-related documents be reviewed for adequacy and approved for release by authorized personnel. Technical Specification Sections 6.1.C.l.d, 6.2.D and 6.2.E require Plant Operations Review Committee (PORC) review and Station Superintendent approval of nuclear safety-related plant procedures prior to implementation. The 0QAP,Section V, Revision 0, dated December 14, 1973, makes the oyster Creek Superintendent responsible for ensuring that operation, maintenance, calibration, and testing procedures are prepared, reviewed, approved, and implemented in accordance with the Quality Assurance Plan.
Contrary to the above, procedure review and approval requirements were not met at the site: in that the procedure used on March 12, 1975 to obtain an Air Ejector radioactive Off-Gas sample had not received PORC review and Station Superintend.cnt approval; and in that eight (8) of twenty-five (25) surveillance test procedures sampled were not reviewed by PORC prior to their implementation.
Civil Penalty - $4,000
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Criterion VI,-Appendix'B, 10 CFR 50 requires that safety-related document changes be reviewed and approved by the same organizations that performed the original review and approval unless the applicant designates another responsible organization.
Technical Specification
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- 6.2.F provides that temporary procedure' changes'which do not change.
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the intent of the original procedure may be made under specific.
circumstances which include subsequent review by PORC and approval by the_ Station Superintendent. The 0QAP,Section VI, Revision 0, F
. dated December 14, 1973, requires the Oyster Creek Superintendent
'to provide for the required reviews and approvals of document j
changes.
i Contrary to the above, a temporary change made on January 24, 1974-to Procedure 609, relating to nitrogen pressure requirements for operating containment isolation components, was not subsequently reviewed by PORC and approved by the Station Superintendent.
4 Civil Penalty - $3,000 3
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Criterion VI, Appendix B, 10 CFR 50 requires'that safety-related documents be distributed to and used at the location where the prescribed activity is performed. The OQAP, Revision 0 of December 14, i
1973,Section VI states.that a standard Generation Department pro-cedure for document control includes basic generic controls to be t
incorporated by each manager, that the Generation Department docu-s ment control procedure further requires measures to insure documents are available when required, and that the Oyster Creek Superintendent is responsible for.the implementation of the document control system for documents received or prepared.at the generating station for i
use in administering, operating, testing, maintaining and modifying nuclear safety-related structures, components, and systems.
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Contrary to the above, document control was not provided: in that Generation Department Document Control Procedure 2004, Revision 0, of July 15, 1974,'was not provided until at least three months after the April 1974 date by which the licensee stated, in OQAP Appendix C, that the QA Program implementing procedures should be completed; in that OQAP Appendix C listed Oyster Creek site Document Control Procedure or an equivalent control over as-built drawings j
and site issued documents was not provided as of March 12, 1975; and in that a. set of as-built engineering drawings was not distributed to the licensee's Morristown Plaza Offices where Generation Engi--
neering Department personnel are regularly engaged in decision 4
making engineering work.
Civil Penalty - $3,000 i
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. Criterion XI Appendix B,10 CFR 50 requires establishment of a test program to assure that all testing, including operational testing, required to demonstrate that structures, systems, and componer. :s will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained.in applicable design documents. The OQAP,Section XI, assigns the Oyster Creek Superintendent responsibility: for-the operation and maintenance test programs; for correct and timely performance of required tests utilizing written and approved procedures; and for requiring that results of tests for which he is responsible are documented, reviewed, and approved.
The OQAP,Section XIV, requires: that maintenance testing be conducted in accordance with specifications, maintenance procedures, etc.; that the work
. performance procedures require sign-off to assure that required inspections and tests are performed; that the procedures be pre-pared and approved by the responsible organization; and that the procedures be reviewed and audited by Operational Quality Assurance.
Contrary to the above, written and approved. procedures defining the tests required, the individuals responsible for procedure and test review, and the required test documentation were not provided for routine post-maintenance testing where step-by-step procedures.
are not provided.
Civil Penalty - $3,000 5.
Criterion II, A.,pendix B, 10 CFR 50 requires: that the quality assurance program shall be documented by written policies, pro-cedures, or instructions and shall be carried out throughout plant life in accordance with those policies, procedures, or instructions; and that the program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
The OQAP, Revision 1, dated September 30, 1974,Section II, states that the licensee will utilize the guidance in ANSI N45.2.6-1973.
Articles 3 and 5 cf ANSI N45.2.6-1973 require qualification and certification of Level I, Level II, and Level III Inspection, Exam-ination, and Testing Personnel.
Contrary to the above, site personnel engaged in maintenance testing, examination, and inspection activities did not have the required certification defining levels of capability with the exception of QA auditors and welding and NDE personnel, in that
d t-i persons performing testing following maintenance were not certified as Level I or II, nor were persons interpreting test data certified as Level II as specified by Section 3 of ANSI N45.2.6-1973.
Civil Penalty - $3,000 6.
Criterion V, Appendix B, 10 CFR 50 requires that activities affecting quality be accomplished in accordance with instructions, procedures, or drawings.
The OQAP,Section IV requires that procuremer. docu-ments prepared by or for the Generation Department be approved in accordance with the Generation Department Procedure.
Generation Department Procedure 2001, Administration of Procurement, Revision 1, dated October 4, 1974, Section 3.2.2 requires operational Quality Assurance review of and concurrence with procurement documents.
Contrary to the above, procurement documents for chemicals had not received Operational Quality Assurance review.
Civil Penalty - $3,000 7.
Criterion V, Appendix B, 10 CFR 50 requires that activities affecting quality be prescribed by and accomplished in accordance with instruc-tions, procedures, or drawings which include appropriate acceptan.ce criteria for accomplishment of important activities.
Instruction SQA-1-74-G-004 dated October 31, 1974 makes the QA Specialist responsible for review of daily Job Orders at the start of each shift, for discussing planned activities on QA related jobs, and for logging QA related jobs in the inspection log, including the name of the job or system, the present plans and nature of the work to be done.
The OQAP,Section V, states that the Oyster Creek Superintendent is responsible for ensuring that instructions and procedures are implemented in accordance with the OQAP, and that the Quality Assurance Supervisor is responsible for implementing site quality assurance / control procedures.
Contrary to the above, twelve safety-related Job Orders issued in February 1975 were not logged as required, and there was no alternate system established to assure that the required QA review of daily Job Orders was accomplished.
Civil Penalty - $3,000
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Criterion XV, Appendix B, 10 CFR 50 requires. establishment of measures to control materials, parts, or components which do not conform to requirements in order to prevent their inadvertent use or installation. The OQAP,Section XV, requires that nonconforming items found during' maintenance or repair work be clearly identified and documented so that appropriate corrective action can be taken, and_that the QA Supervisor notify the Manager-Operational Quality Assurance and-the Oyster Creek Superintendent in the event prompt corrective action is not taken.
Criterion XVI, Appendix B,
'10 CFR 50 requires establishment of measures to assure that noncon-formances are promptly corrected.
The 0QAP,Section XVI, states that corrective action procedures include provisions for determin-ation of suitable corrective action and responsibility for timely disposition and follow-up, and that the Oyster Creek Superintendent is responsible for ensuring that nonconformances are corrected for plant activities involving operation, maintenance and repair.
Contrary to the above, the Condensate Transfer System, identified in the OQAP,' Appendix A,.Section III f, ar a system required to mitigate the consequences of postulated accidents, was returned to service with unresolved nonconformances: in that Nonconformance Report
- 74-052 dated October 25, 1974 on piping joint backing rings had been evaluated as having unacceptable corrective action and remained unresolved as of March 12, 1975;'in that Nonconformance Report #74-053 dated October 24, 1974 concerning an unauthorized joint and weld requirement remained unresolved as of March 12, 1975; and in that Nonconformance Report #75-006 dated March 8, 1975 documented return of the system to service without work completion, without QA release or approval, and without the required hydrostatic test.
Civil Penalty - $3,000 9.
Criterian III, Appendix B, 10 CFR 50 requires establishment of measures: to assure that the design basis, as defined in 10 CFR 50.2, is correctly translated into specifications, drawings, procedures, and instructions; and for the identification and control of design interfaces and for coordination among participating design organ-izations._ The OQAP,Section III, Revision 0, dated December 14, i
1973 states that design control is implemented by Generation
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Engineering Procedures which include design review requirements, internal and external interface control considerations, and appro-priate design bases.
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Contrary to'the above, inclusior, of design bases ~, control of design interfaces, and coordination among participating design. organizations has not-been provided for modifications: in that Procedure 6003, "Modifiertions, Non-Routine Maintenance, and Repair," Revision 0, dated March 7, 1975, had not been implemented as'of March 12, 1975, more.than 10 months after the April 1974 date given in the OQAP, Appendix C, for the completion of the QA implementing procedures; and in that Procedure 6003 does not provide for inclusion of the i -
' design bases or coordination among participating design organi-zations in design review requirements.
i Civil Penalty - $1,000
- 10. ' Criterion II, Appendix B, 10 CFR 50 requires that the quality assurance program provide control over activities affecting quality to an extent consistent with their importance to safety.
Criterion V, Appendix B, 10 CFR 50 requires-that activities affecting quality be accomplished in accordance with prescribed instructions, pro-l cedures, or drawings.
Procedure 105, Maintenance, Repair and Modification Control, Revision 0, dated October 15, 1974, Paragraph 1'
4.1 requires that items which fall under the cognizance of the QA Plan shall be segregated and handled in accordance with Procedure 105.
i Contrary to the above, control over safety-related maintenance was not established: in that maintenance job orders were not identified, I
categorized,' segregated, or logged as being safety-related, thereby providing no categorization of the safety aspects of the job orders to personnel performing or reviewing maintenance; and in that i
specific procedural controls to accomplish.the required segregation and handling were not established.
Civil Penalty - $1,000 11.
Criterion V, Appendix B,10 CFR 50 requires that activities affecting quality be prescribed by and accomplished in accordance with docu-
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mented instructions, procedures, or drawings.
The OQAP, Revision 0, dated December 14, 1973, provides, in Section III, for a System Boundary and Classification Book for expanding the Quality Assurance Systems List (QASL) into-categories of safety classes using Regulatory Guides 1.26 and 1.29 for guidance and specifying the basic codes, standards and regulatory requirements for each cate-gory.
The OQAP, Appendix C, Revision 0, dated December 14, 1973, Preliminary List of Procedures Implementing the Quality Assurance
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Program, lists, as one of the procedures which should be ready and
-issued by April 1974, the System Boundary and Classification Book.
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. 7-l Contrary _to'the above, required definition of. equipment and' component safety classification has not been accomplished: in that the System
. Boundary and Classification Book was not provided as of March 12, 1975.
Civ11^ Penalty
.$1,000 1
- 12.. Criterion V, Appendix B 10 CFR 50 requires that. activities affecting
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. quality be prescribed by and accomplished in accordance with docu-mented instructions, procedures or drawings. The 0QAP,Section V, states that the Oyster Creek Superintendent is responsible:for en-suring that instructions and procedures associated with operational testing are' prepared, reviewed, approved, and implemented in accord-ance with the Quality Assurance Plan. Technical Specification 6.2.C 1
requires adherence to procedures for maintenance, normal startup, operation and shutdown of all plant systems and components involving nuclear safety.
Contrary to the above,'the diesel fuel inventory log entries which serve to document maintenance of minimum fuel levels were not made as required by Operating Procedure 301 for the period January 6 -
. February 3, 1975; Station Battery "B" discharge test log entries required by Operating Procedure 601 were not made on December 18-20, 1974; and Control Rod Drive System testing log entries required by Operating Procedure 603.3 were not made on January 27, 1975.
Such records of test results are also a requirement of 10 CFR 50, j
Appendix B, Criterion XI.
Civil Penalty - $1,000 13.
Criterion VIII, Appendix B, 10 CFR~50 requires establishment of measures for identification and control of materials, parts and components to assure that identification of the item is maintained
-throughout installation and use. The 0QAP,Section VIII, states that the Oyster Creek Superintendent is responsible for maintaining identification and control of materials, parts, or components received, stored, installed and used at the plant site.
Procedure 3005, Site Material Identification and Control, Revision 0, dated July 15, 1974 requires, in Section 5, that items be classified and tagged as " Released for Use" prior to their installation or use, and that the " Released for Use" tags be removed and returned to Quality Assurance for recording this fact on the Material Identi-fication'and Control Sheet and destruction of the tag.
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L Contrary to the above, identification and. control was not maintained over two of seven safety-related job orders examined, in that
" Released for Use" tags for Job Orders 8648, Core Spray System, and 8626, Fuel Pool Filter, were not on the equipment, not recorded on the Material Identification and Control Sheet, and not available to the inspector, a
Civil Penalty
$1,000 14.
Section 4, Appendix A, 10 CFR 55 requires annual written examinations of licensed operators. The licensee's operator requalification program, approved by Reactor Licensing letter dated November 13, 1974, states that December 17, 1973 is the starting date for the 10 CFR 50.54(1-1).
annual cycle of the requalification program.
requires Commission approval of requalification program changes which decrease the frequency of conduct of parts of the program.
Contrary to the above, written examinations of licensed operators were not given when required: in that none of the twenty licensed operators were given written examinations prior to December 17, 1974.
(All licensed operators were subsequently successfully tested between January 10 and March 13, 1975.)
L Civil Penalty - $1,000 15.
Criterion V, Appendix B, 10 CFR 50 requires that activities affecting quality be prescribed by and accomplished in accordance with docu-mented instructions, procedures or drawings. The OQAP,Section V, states that the Oyster Creek Superintendent is responsible for ensuring that instructions and procedures are implemented.
Procedure 102, Training of Nuclear Generating Station Personnel, Revision 0, dated July 18, 1974, states that site training is conducted in accordance with detailed procedures specified in the Oyster Creek Training Manual, Contrary to the abuve, detailed procedures specified in the Oyster Creek Training Manual were not being used to train non-licensed technicians and repair personnel: in that non-licensed technicians l
and repair personnel training was being conducted to Job Qualification 1
Review Sheets prepared on each individual. This noncompliance was 1-acceptably resolved prior the end of the inspection by n.odification of Procedure 102 to permit use of the Job Qualification Review Sheets.
Civil Penalty
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_9 Other Infractions identified through your internal audit program, and being corrected in a timely manner, are set out in the attached inspec-tion report.
No additional information is needed for these items at this time.
This notice is-sent to you pursuant to the provision of Section 2.201 of the NRC's " Rules of. Practice," Part 2, Title 10,: Code of Federal Regulations. Section 2.201 requires you to submit to this office within twenty (20) days of your receipt of this notice, a written statement or explanation in reply including:
(1) corrective steps which have been taken by you, and the results achieved;- (2) corrective steps which will be taken to avoid further items of noncompliance; and
- (3) the date when full compliance will be achieved.
FOR THE NUCLE'R REGULATORY COMMISSION Donald F. Knuth, Director Office of Inspection and Enforcement O
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