ML20116D164
| ML20116D164 | |
| Person / Time | |
|---|---|
| Site: | Davis Besse  |
| Issue date: | 02/04/1985 |
| From: | Williamson J TOLEDO EDISON CO. |
| To: | James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20116D145 | List: |
| References | |
| 1-497, NUDOCS 8504290310 | |
| Download: ML20116D164 (18) | |
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Docket No. 50-346 gyggo License No. NPF-3 Serial No. 1-497 JOHN P. VVILUAMSON l o.,n.n .no ce.an= omw I
[419]25S5225 February 4, 1985 ;
Mr. James G. Keppler, Regional Admininstrator Region III United States Nuclear Regulatory Commission 799 Roosevelt Road Glen Ellyn, Illinois 60137
Dear Mr. Keppler:
In accordance with our commitment to respond in writing to the Systematic Assessment of Licentee Performance (SALP) report, I am pleased to submit this
~ 1etter and its assoc iated attachments.
The number of low ratings given by the NRC to our performance in the operation of our Davis-Besse facility did come as a shock to me personally, as well as our other senior corporate staff and to our Directors. The independent review team of experts retained as direct advisors to me for the last several years had been advising that our performance was generally satisfactory, was indeed improving further and would be rated by them as a B plus compared to the other nuclear stations they inspect and appraise around the country.
However, Davis-Besse is our responsibility. It has always been and still ,is the policy of senior management of this Company to go beyond simply meeting NRC requirements.
In the last few years, we have committed to over $300 million of improvements beyond the $600 million original investment in the station. We do have the best health physics records with the lowest radiation exposure levels in the industry.
Obviously, we can do some things in an outstanding manner. We must, and we will, do all things in that outstanding manner.
For reasons that are now difficult to comprehend, the senior management of Toledo Edison failed to properly interpret adverse signals given to us by NRC Region III and Headquarters personnel. Upon closer reflection, I am convinced that signals for further improved performance were discernible. In their preliminary analyses of the bases for the low SALP ratings given to Davis-Besse, our people thought that several of the low ratings could not be fully justified. While some peripheral arguments can be developed against certain bases for the SALP ratings, I am convinced that your relative assessment of our performance is honest and fair. Therefore, I have chosen not to argue with your assessments, but instead 8504290310 850423 PDR ADOCK 05000346 y- $$
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G PDR THE TOLEDO EDISON COMPANY EDISON PLAZA 300 MADISON AVENUl TOLEDO. OHIO 43652 L
Mr. James G. Keppler Page 2 February 4, 1985 want to devote all of our energy to a program of improvement. I am personally committing this Company to a program that will eventually lead the NRC to rate our operation of the Davis-Besse facility as one of superior quality.
Recovery to a full state of excellence cannot occur in a few weeks or months.
We recognize this and we are prepared for a long-term endeavar. We have made and will continue to make changes that will obviate or eliminate problems that are amenable to quick resolution. But we recognize that the real causes of our inability to achieve excellence are deeper-rooted and will take longer to identify in detail and to remedy in full.
I intend that this Company embark upon a program where strong, unrelenting, critical self-appraisal will become a routine way of life to our operations and support staffs and their managers. We should be the first to detect deficiencies in our own performance.
I know of other utilities that have raised their SALP performance levels substan-tially from one SALP period to the next. We are communicating with them to seek advice and guidance on the best avenues to pursue. We intend also to seek stronger relations with INPO in order to maximize the assistance we can obtain from their expert staff.
Poor communications by ua have shown to be a primary cause of performance problems and evaluations in many instances. I am convinced that significant improvements in our commuaications, both within Toledo Edison and with the NRC, can and must be made in order to achieve our goal of excellence. We are embarking upon a plan that will better our understanding of and our relations with our own staff elements, and with the many levels of the NRC. I want to meet again personally with you soon to further seek your guidance on how best to establish and maintain good communica-tions with the NRC.
The history of this nation's nuclear power industry has shown that attitudinal problems lead inevitably to performance difficulties. I believe our nuclear staf f and canagement have the integrity, talent, and desire to perform well.
Perhaps one reason we have not been able to reach a plateau of excellence is that we have permitted attitude problems to develop in our minds. We intend to critically assess our own attitudes to determine where attitudinal deficiencies have developed and to develop corrections. We have always tried to be strongly pro-safety. If our people have allowed themselves to become strongminded with respect to how things should be done and have not adequately accepted opposing views from within our own staff, from the NRC, and from INPO, then the attitudinal deficiencies which have developed must be eliminated. Safe and efficient operation must not be jeopardized by errant attitudes.
We intend to provide the leadership and the resources needed to elevate performance of our operation of Davis-Besse to a state of excellence. Enclosed with this letter are attachments that respond to specific points addressed in the SALP report.
These are our immediate responses to obvious problems. We have completed many items listed in the SALP review and most others are well underway. The other w_--___-_
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Mr._ James G. Keppler Page 3 February 4,1985 matters that I have discussed in this letter, are, in my mind, the more dominant, more deeply-rooted, and more difficult issues that must and will be resolved. We are committed to a program of critical introspection and assessment to identify attitudinal and communications deficiencies that block the achievement of excellence. Once identified, I am committed to their eradication.
We sincerely seek advice and guidance on how best to resolve our problems. I would appreciate the opportunity to meet with you and with other senior NRC managers, including perhaps the Executive Director of Operations and the Directors of the Offices of Nuclear Reactor Regulations, and Inspection and Enforcement.
With your assistance and forbearance, I am convinced that our Davis-Besse facility will profit from the SALP findings and attain the operating performance we all seek.
Cordially, ga $ V JPW/naf Attachments
ATTAClfIENT I TOLEDO EDISON RESPONSE TO SALP 4 IMPROVING REGULATORY PERFORMANCE IN PLANT OPERATIONS, MAINTENANCE, EMERGENCY PREPAREDNESS, QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS, AND TRAINING Toledo Edison (TED) Corporate and Nuclear Mission Management are committed to achieving significant improvements in regulatory performance at the Davis-Besse Nuclear Power Station Unit No. 1. Actions completed, in progress and planned to improve our regulatory performance in the functional areas of Plant Operations, Maintenance, Emergency Preparedness, Quality Programs and Administrative Controls, and Training are described in Attachment II. Attachment III lists, in tabular format, the SALPs cate-gorized concerns, TEDS specific corrective actions and their associated milestone dates.
In addition to the specific planned corrective actions in each of the five areas discussed in Attachment II and III, Toledo Edison is providing a broader base of actions to further improve its nuclear program through additional management involvement and critical self evaluation.
A task force is being formed to review and advise senior management on the scope and depth of the company's actions. The members will be experienced in utility management, regulatory relations and communications skills.
The members are being selected from the industry as well as from Toledo Edison personnel. Headed by Richard Crouse, Vice President, Nuclear, this group will review and evaluate the individual corrective actions of the company to be sure they are sufficient to significantly improve the current conditions. Through Mr. Crouse this group will report regularly to the Chief Executive Officer their findings and actions.
Site visits by Senior Management have been initiated to provide overview and feedback to the management staff.
To underline our commitment to the operations and training programs these visits will include Plant and 1 raining Center visits.
The Performance Enhancement Program is initiating two key programs to improve the overall quality of Toledo Edison management. These include use of performance measures in conjunction with an expanded Management By Objective program (PEP Implementation Plan A-2(1)) and a Quality Assurance Awareness Program (PEP Implementation Plan D/QA-1). The details of these programs will be discussed with your staff at the planned February 7-8, 1985 PEP review meetings.
The expanded Management by Objectives program is the means by which we can properly assign responsibility for needed corrective actions to achieve excellence. This program also allows us to assign accountability. The expanded Performance Measures program is the management tool by which we will measure our performance toward achieving our objectives and goals.
Additionally, focused management attention is being placed on Toledo Edison's commitment tracking and training schedule compliance. This will improve the direct management support in the commitment and training areas. Through use of these tools, management will hold individuals responsible to ensure that commitments are met.
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ATTACHMENT II IMPROVING REGULATORY PERFORMANCE AT THE DAVIS-BESSE NUCLEAR POWER STATION UNIT NO. 1
- 1. PLANT OPERATIONS A. Areas of SALP Concerns
- 1. Adherence to procedures.
- 2. Review of equipment status changes.
- 3. Recognition of Design Bases requirements.
B. TED Corrective Actions
- 1. Adherence to procedures:
Administrative Procedure AD 1839.00, Station Operations, has been revised concerning the generation and documenta-tion of valve lineup (s). Specifically, this revision provides increased guidance concerning the valve lineup of a system or component being removed from or returned to service. In addition, Plant Procedure PP 1102.01, Pre-start Checklist, was modified to impose increased requirements for valve lineup verifications being conducted following an extended outage. Implementation of these steps will ensure that the system is properly returned to service and is in its correct lineup for operation.
Administrative Procedure AD 1839.00 has been revised to reinforce control and accountability of procedure sign-off by requiring the use of initials rather than a check mark.
Also, the determination that a specific operations procedural step is not applicabic must now be made by a Senior Reactor Operator (SRO) license holder.
TED has increased its efforts to ensure attention to detail by the control room operations staff through: (1) discour-aging the access and limiting the visit duration of non-essential personnel in the control room; (2) encouraging professionalism by the operators; and (3) reducing nuisance alarms. The intent of these actions is to improve attitudes about quality of the work performed and to reduce errors.
An increase in the training of the operations staff has been scheduled for 1985. This training (including admini-strative procedures training) is reflected on the 1985 Master Training Schedule. Further discussion of operations staff training is discussed under Section V, Training, of this attachment. This action will enabic the staff to be more technically knowledgeable and thus improve their support of the operators.
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- 2. Review of equipment status changes:
TED has revised procedure AD 1844.00, Maintenance, to require that an experienced non-shift SRO review all Maintenance Work Orders (MW0s). The SRO reviews the proposed work for potential system operability impacts.
Guidance has been provided so that any proposed change in plant configuration is carefully reviewed for its impact.
This will provide a much improved ability to recognize system operability problems.
- 3. -Recognition of Design Bases requirements:
In addition to the short term measures discussed in Section 2 above, TED will institute a program to perform a system-by-system review of Design Bases contained in the Davis-Besse USAR. This review, a major undertaking, will be performed
.by experienced' individuals familiar with Davis-Besse design, operations or regulatory requirements and utilize external technical support (B&W, Bechtel, etc.) as appro-priate. A task force has been assigned the responsibility for developing a specific action plan for the USAR review.
The schedule for developing the plan, including specific milestone dates, is listed in Attachment III,Section I.3.
This plan, including the system review schedule, will be submitted to the NRC by May 1, 1985.
II. MAINTENANCE A. Areas of SALP Concerns
, 1. Management overview.
- 2. Strengthening of and adherence to procedures.
B. TED Corrective Actions
- 1. Management overview:
The key Maintenance Department Head position, Maintenance Engineer, has been filled with an individual who has the leadership and experience to provide increased management control of maintenance activities.
TED has authorized an increase in 1985.of four (4) additional Maintenance Foremen to provide increased overview of maintenance activities and provide more field supervision-which will lead to improved performance. These positions will be filled by July 5, 1985. In addition, a Corporate Recruiting Task Force has been established to recruit key personnel, one of which is the identified critical position of Lead Instrument and Control engineer.
r A Management by Objectives program to improve account-ability of job responsibilities and defined objectives has been initiated within the Maintenance Department. The MBO program will provide employees with a clear understanding of desired actions and results (i.e., define responsiblities and accountability).
TED has developed a system for the prioritization of non-outage maintenance activities to improve management planning and control. The process is designed to provide for completion of the most important work first and is based on a weighted rating system.
Maintenance has two shifts per day coverage in effect (except for weekends and holidays) and the backshift will be expanded in 1985 to increase the tag-outs being performed to support day shift corrective maintenance and increase backshift surveillance testing.
A quality circle program has been implemented in one of the maintenance areas with favorable results, and has been expanded into five other skill areas. This program provides valuable information about problems and ways to solve those problems from the employees, who may have a better perspective on a problem than management.
- 2. Strengthening of and adherence to procedures:
TED has modified procedures AD 1844.00, Maintenance, AD 1845.00, Changes, Tests and Experiments, and IC 2001.00 Instrument Calibration, to better control nuclear safety-related work. The maintenance procedures have been modified to require use of controlled drawings and vendor manuals in the field. Compliance with these procedures will ensure that field maintenance activities are using the most current and accurate information available. "Information only" vendor manuals may now only be used to assist in the planning, inspection, and monitoring of conditions for informational purposes.
Procedure AD 1845.00 will be modified to ensure all required work is complete for a specific Facility Change Request (FCR) prior to conducting the related testing.
III. EMERGENCY PREPAREDNESS A. Areas of SALP Concerns l
l 1. Emergency Preparedness (EP) QA audit requirements.
- 2. Tracking Emergency Preparedness activities.
- 3. Preparation for and performance of 1985 EP exercise.
( 4. Emergency Preparedness training.
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B. TED Corrective Actions
- 1. Emergency Preparedness QA audit requirements:
This SALP concern has been addressed by the development of a process whereby both Emergency Planning and Quality Assurance review the checklist for QA audit requirements prior to audit initiation. This review will be documented in the entrance interview notes.
- 2. Tracking Emergency Preparedness activities:
The Activity Scheduling System is currently under development which will be used to identify, schedule and track required activities, both commitments and routine activities.
Through appropriate use of this system, management can assure all required activities will be completed on time.
Use of the system and its procedures on a trial basis will be done prior to formal implementation. This system will be formally implemented for all future commitments by September 30, 1985.
- 3. Preparation for and performance of 1985 Emergency Preparedness exercise:
A schedule for the next annual EP exercise has been established with the State of Ohio and Ottawa County. Under TED management endorsement, an internal-TED Scenario Development Committee was established in January, 1985 which includes members with technical expertise. These items will improve the timely establishment of exercise objectives and ensure technical accuracy of the exercise scenario. The EDO program is being modified to establish a full-time Emergency Planning Supervisor / Emergency Duty Officer (EDO) position.
This will significantly upgrade the technical experience of the EDO position and will result in improved performance.
- 4. Emergency Preparedness training:
The Emergency Preparedness training format has been improved by including more hands-on training and the 1985 Training Schedule has been prepared for all Emergency Response Programs, both Corporate and Station. This schedule was developed in conjunction with the Nuclear Training Department.
The station schedule has been issued as part of the Nuclear Training Department's Master Training Schedule. Also, controller training classes will be provided for the 1985 annual exercise controllers.
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IV. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS A. Areas of SALP Concerns
- 1. Review of nuclear safety-related temporary facility changes.
- 2. Consistency of design documents with as-built conditions.
- 3. Management overview.
- 4. Quality Assurance effectiveness.
B. TED Corrective Actions
- 1. Review of nuclear safety-related temporary facility changes:
The Station Review Board's (SRB) charter has been modified to require review of Nonconformance Reports (NCR) which constitute nuclear safety-related (NSR) temporary facility changes. The NCR procedure has also been modified so that now all NSR NCRs that are dispositioned "use-as-is", "use-as-is-temporarily", or " repair" require a written Safety Evaluation.
Additionally, the Jumper and Lifted Wire (J&LW) Control procedure, AD 1823.00, has been modified to require a written .cs fety Evaluation for any J&LW that is not remcved from a NSR system when maintenance has been completed.
Compliance with these procedures will provide the required review for changes made to the plant in the cases which didn't fall under the provisions of procedure AD 1845.00, Changes, Tests and Experiments.
- 2. Consistency of design documents with as-built conditions:
An extensive effort was employed during 1983-1984 to assess work completed on all modification work packages released for implementation. Design documents were updated to reflect all work completed. Currently TED is updating design documents as work orders are closed so that the documents proper.y reflect the as-built status of the plant.
- 3. Management overview:
Standing Order 39 has been issued directing the Shift Supervisor to carefully review any changes to equipment status for any potential effects on operability. If a clear determination cannot be made the Shift Supervisor is required to consult Station management for a determination.
Station management personnel can be contacted using
( a paging system, if necessary.
7 A Surveillance Report system has been implemented to identify potential quality concerns.
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QA Audit Finding Reports and Nonconformance Reports authoriz-ing temporary changes are sent to the Station Review Board for their review. The rate of resolution of Audit Finding Reports and Nonconformance Reports are monitored by performance measures to encourage prompt resolution.
Attendance by the immediate supervisor of the audited area is required at QA exit interviews to' ensure adequate management participation. If the supervisor is unable to attend, his supervisor is required to attend. In addition, when the results of the audit warrant, higher level supervisory personnel will attend the exit interview.
- 4. Quality Assurance effectiveness:
The effectiveness of Quality Assurance is being enhanced through increased technical training of auditors (PEP Implementation Plan D/QA-3), the implementation of area-specific QA training for Station and appropriate support personnel, and supplementing audit teams with individuals possessing area-specific technical expertise.
Consistent with INPO recommendations, the expansion of QA coverage into the non-nuclear portions of the plant (Balance of Plant) is being developed. TED will determine an initial list of those Balance of Plant systems and/or components to which a Quality Program should be applied.
The initial list will be completed by August 29, 1985. The requirements of the quality program to be applied to the Balance of Plant systems and/or components will be developed by July 31, 1985.
QA awareness will be integrated into training. The QA segment of General Employee Training (GET) will be revised to' meet INPO guidelines by February 28, 1985. This GET segment will be expanded into a QA indoctrinatien and training package by May 1, 1985. Also, schedules will be initiated by June 1, 1985 for development of individual training _ plans covering QA requirements appropriate to each Nuclear Program Division and/or Department.
V. TRAINING A. Area of SALP Concerns
- 1. QA program requirements within Nuclear Training.
- 2. Non-operator and operator training and retraining areas.
- 3. Management overview.
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B. TED Corrective Action
- 1. QA program requirements within Nuclear Training:
Nuclear Training procedures, the last of which was approved in December, 1984, have been generated which address QA requirements. A training schedule has been developed and implemented consistent with the 1985 Master Training Schedule. These procedures provide instructions for the accomplishment of the various training functions.
- 2. Non-operator and operator training and retraining areas:
The training staff has been doubled since the summer of 1984. At the end_of January, 1985, the Training staff numbered thirty people. This increase in the Training staff has significantly reduced self-study requirements.
For this remaining self-study, guidance for a systematic program is being provided by Nuclear Training based on each individuals needs.
Measures will be implemented by May 31, 1985 for the improvement of Reactor Operator (RO) and Senior Reactor Operator (SRO) requalification exams. Non-operator training program improvements are being implemented through the use of the Action Status List within Nuclear Training. Thia list provides milestones for accomplishing program improve-ments as they are identified. This list was developed as a management tool.for implementing and tracking training program improvements.
Two Nuclear Training procedures, NSP/NT-007, Training Program Implementation, and NSP/NT-008, Training Program Evaluation, have been implemented which proceduralize the
. analysis of examinations and provide feedback of that analysis into the training programs. The 1985 Requalifi-cation Training Schedule has been developed based on knowledge weaknesses in a particular examination subject area identified through the analysis of the 1984 requalifi-cation exams.
- 3. Management overview:
Nuclear Training procedures will require that vendor lesson plans be reviewed and approved by the Nuclear Training Depart-ment prior to their use. Following completion of each Nuclear Training class provided by a vendor, the class is evaluated by both the students and vendor for the appropriateness of scope and presentation.
A procedure will be developed by April 15, 1985 to provide for an evaluation by the Nuclear Training staff (on a random sampling bas _s) of contractor-delivered training, i.e. by sitting in on the class and evaluating the training.
ATTACHMENT III ACTIONS AND MILESTONE DATES FOR IMPROVING' REGULATORY PERFORMANCE
-SALP FUNCTIONAL AREA: I. PLANT OPERATIONS Area of Milestone
.SALP Concern TED Corrective Action Date
- 1. Adherence to A. Revise Station procedure AD 1839.00 Completed procedures. to govern generation and documenta-tion of valve lineup (s).
B. Modify Plant procedure PP 1102.01 Completed to impose increased requirements for valve lineup verifications following an extended outage.
C. Revise Station procedure AD 1839.00 Completed to reinforce control of operations procedure signoff-by requiring use of initials rather than check marks.
r D. Determination that a specific .
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procedural step is not applicable, must be made by a SRO license holder.
E. Schedule increased training of Completed
' Station staff in 1985.
- 2. Review of equip-A. Require review of all Maintenance Completed ment. status Work Orders (MW0s) by SRO qualified changes. individuals.
-3. Recognition of A. Develop plan for system-by-system 4/15/85
' Design' Bases review of the USAR.
I Requirements.
- 1. Draft plan. 3/22/85
- 2. Management approval of plan. 4/15/85 B. Submit plan and system review 5/1/85 schedule to NRC.
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5 r-SALP FUNCTIONAL AREA: II. MAINTENANCE Area of Milestone SALP Concern TED Corrective Action Date
- 1. Management A. Fill Maintenance Engineer position. Completed Overview.
B. Fill four additional Maintenance 7/01/85 foremen positions.
C. Maintenance Supervisor Management 7/01/85 By Objectives (MBO) program in place (PEP Implementation Plan E/SP-9).
D. Develop a system for prioritization Completed of non-outage maintenance activities (PEP Implementation Plan E/SP-3).
E. Implement the system for 6/01/85 prioritization of non-outage maintenance activities (PEP Imple-mentation Plan E/SP-3).
F. Implement a quality circle program. Completed
- 2. Strengthening A. Modify procedures AD 1844.00, Completed of and AD 1845.00 and IC 2001.00 to better adherence to control nuclear safety-related work.
procedures.
B. Modify maintenance procedures to Completed require use of controlled drawings in the field.
C. Modify procedure AD 1845.00 to 3/15/85 ensure that all required work is complete for a specific Facility Change Request prior to conducting the related testing.
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I SALP FUNCTIONAL AREA: III. EMERGENCY PREPAREDNESS Area of Milestone SALP Concern TED Corrective Action Date
- 1. Emergency A. Develop 1984 audit checklist. Completed Preparedness (EP)
QA audit B. Develop 1985 audit checklist. 10/01/85 requirements.
- 2. Tracking Emergency A. Develop Activity Scheduling System. 3/01/85 Preparedness activities. B. Formally implement EP Activity 9/30/85 Scheduling System for future commitments.
- 3. Preparation for A. Establish EP exercise schedule with Completed and performance State of Ohio and Ottawa County.
of 1985 Emergency Preparedness B. Establish Scenario Development Completed Exercise. Committee, with technical expertise.
C. Establish permanent Emergency Duty 3/15/85 Officer position.
- 4. Emergency A. Improve training format. Completed Preparedness training. B. Establish training schedule Completed on 1985 Master Training Schedule.
C. Implement controller training 7/01/85 classes.
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'l SALP FUNCTIONAL AREA: IV. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS 1 Area of Milestone i SALP Concern TED Corrective Action Date l 1. Review of nuclear A. Modify Station Review Board (SRB) Completed safety-related . Charter to require review of NSR temporary facility Nonconformance Reports (NCRs).
changes.
B. Modify NCR procedure to require Completed j- Safety Evaluation for all NSR NCRs dispositioned "use-as-is", "use-
!, as-is-temporarily", or " repair".
4 l C. Modify procedure AD 1823.00 to Completed j require a Safety Evaluation for any J&LW not removed from a NSR system when maintenance is completed.
- 2. Consistency A. Require the updating of design Completed of design documents as work orders are closed.
documents with as-built conditions.
- 3. Management A. Issue Standing Order 39 directing Completed
! Overview. Shift Supervisor to review any changes to equipment status for any potential effects on operability
{ and if necessary, consult with j Station management.
I j B. -Implement a Surveillance Report Completed i system to identify potential quality Concerns.
, C. Implement requirement for performance Completed 7
performance monitoring of NCR resolution.
j D. Require sending QA Audit Finding Completed Reports and NCRs authorizing temporary facility changes to SRB for review.
, E. Implement requirement for performance Completed
! monitoring of the rate of resolution of audit finding reports.
l i F. Require immediate supervisor Completed attendance at QA audit exit inter-views.
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SAI? FUNCTIONAL AREA: IV. QUALITY PROGRAMS AND ADMINISTRATIVE CONTROLS (Continued)
Area of Milestone SALP Concern TED Corrective Action Date
- 4. Quality A. Require increased technical train- Completed Assurance ing for auditors (PEP Implementation effectiveness. Plan D/QA-3).
B. Require supplementing of audit teams Completed with area-specific technical expertise.
C. Balance of Plant Quality Program:
- 1. Determine an initial list of 8/29/85 those Balance of Plant systems and/or components to which a Quality Program should be applied.
- 2. Develop the Quality Program 7/31/85 requirements to be applied to the Balance of Plant systems and/or components.
- 3. Commence implementation of a 8/29/85 Balance of Plant Quality Program.
D. QA Awareness Training
- 2. Expand the General Employee 5/01/85
' Training segment on Quality Assurance into a Quality Awareness indoctrination and training package (PEP Imple-mentation Plan D/QA-1).
- 3. Initiate schedules for develop- 6/01/85 ment of individual training plans covering the Quality Assurance requirements appropriate to each Nuclear Program Division and/or Department.
.SALP FUNCTIONAL AREA: V. TRAINING Area of Milestone SALP Concern TED Corrective Action Date
- 1. 'QA program A. Generate Nuclear Training procedures Completed requirements which address QA requirements, within Nuclear
-Training. B. Develop and implement a training Completed schedule.
'2. 'Non-operator ~A. Reduce significantly self-study Completed and operator requirements.
training and
' retraining B. Provide self-study guidance. Completed areas.
C. Implement measures for the improve- 5/31/85 ment of RO and SRO requalification examinations.
D. Implement an Action Status List for Completed non-operator _ training programs.
.E. Develop procedure to identify Completed deficiencies in licensed operator knowledge and address in requalification training.
~3. . Management A. Develop procedure to provide an 4/15/85
- Overview. evaluation on a random sampling basis of contractor delivered training.
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