ML20127B210
| ML20127B210 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 04/29/1985 |
| From: | Gucwa L GEORGIA POWER CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.5, TASK-2.B.4, TASK-TM 1594N, NED-85-322, NUDOCS 8506210383 | |
| Download: ML20127B210 (7) | |
Text
Georgia Pcmer Company 333 Piedmont Avenue At!anta. Georgta 30308 Telettme 404 $26 6526 Ma bog AMress-Post Off-ce Box 4545 Attanta, Georg:a 30302 Georgia Power 35 MM 7 A9:57 boap xtear Engineenng and Cruef Wctea Enginmr NED-85-322 1594N April 29, 1985 U. S. Nuclear Regulatory Commission
REFERENCE:
Office of Inspection and Enforcement RII: RCW Region II - Suite 2900 50-321/50-366 101 Marietta Street, N. W.
IER 85-07 Atlanta, Georgia 30323 ATTENTION: Dr. J. Nelson Grace GENTLEMEN:
Georgia Power Company hereby provides the following information in response to the alleged violations cited in NRC I&E Report 50-321/85-07 and 50-366/85-07 dated April 1,1985.
The subject violations were identifled during the NRC inspection conducted at Plant Hatch by Mr. K. E. Brockman, Mr. D.
P. Falconer, and Mr. K. Poertner of your staff on February 5-7, 1985.
Violation 1:
10 CFR 55.10(d) reouires that each application for an operator license shall contain complete and accurate disclosure as to all matters and things reouired to be disclosed. Application is made utilizing NRC Form 398.
Contrary to the above, the licensee submitted two applications for Senior Operator licenses which contained inaccurate information.
a.
One application for an initial license re-examination stated that the applicant had previously been examined by the NRC in Ouly 1984; in actuality, the applicant was previously examined in Septenber 1984 This inaccuracy dtd not affect the candidate's eligibility.
b.
One application for a license renewal stated that between Septenber 1981 and December 1981, the applicant participated in a Shift Technical Advisors' (STA) training program which included four weeks of simulator training.
In fact, the applicant did not receive simulator training until May 1982, and it consisted of 14 days of instruction.
This training met the reouirements of all licensing regulations.
This is a Severity Level IV violation (Supplement I).
1 l
321 g/
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y Georgialbwer b U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 April 29, 1985 Page Two Resoonse To Violation 1:
Adm'ssion or denial of alleoed violation: The violation is denied.
i Rationale for denial:
The information supplied in the application for an initial license re-examination and in the application for license renewal was inaccurate, but the inclusion of such information in the applications did not violate 10 CFR 55.10(d).
10 CFR 55.10(d) states, in part, that the application "shall contain complete and accurate disclosures as to all matters and things reouired to be disclosed" (emphasis supplied).
10 CFR 55.10(a), together with Form 398, establish these " matters and things" which are reouired to be disclosed. The specific item of information supplied which is alleged to constitute a violation, i.e., the date of the previous examination, does not appear to be "reouired to be disclosed" by Form 398 or 55.10(a).
Significantly, the omission of any specific date of prior examination would not, have made Form 398 incomplete or violate 55.10(d).
The information was provided in accordance with the verbal reouest of the MRC's Examining Branch to provide as much administrative 1y helpful information as possible.
As recognized by the ~ Notice of Violation, this inaccuracy did not affect the candidate's eligibility.
With respect to Item ib, the STA simulator training did not affect, and was not reouired for, the candidate's eligibility for i
'(
license.
Again, the supplied information was not "recuired to be disclosed", but simply was gratuitously made to assist NRC administraticr..
Although perhaps subject to misinterpretation, the statement alleged to be inaccurate correctly states that the applicant participated in a STA training program.
However, the particular applicant did not complete the four week simulator training (i.e., half classroom, half simulator manipulations) in this program.
- Instead, the applicant completed full-time simulator Aanipulations (i.e., no classroom) for 14 days in May, 1982.
The 14 days of simulator manipulations are at least eouivalent to four weeks of half-day simulator manipulations.
With regard to both Items la and Ib, a Severity Level IV Violation as contemplated in examples set forth in 10 CFR 2 Appendix C, Supplement I reouires, relative to these occurrences, a " failure to meet regulatory reouirements that have more than minor safety are environmental significance. "
In light of the Notice's i
N-
GeorgiaPower d U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 April 29, 1985 Page Three acknowledgement that 1) the inaccuracy on the re-examination application did not affect the candidates eligibility, and 2) the training of the applicant did meet the reouirements of all licensing regulations, the precondition of "more than minor safety significance" cannot credibly be contended to exist. At most, the f
inaccuracles, referred to as " discrepancies" in the Inspection Report (see page 5), are of a minor nature resulting from good i
faith efforts to supply information in addition to that which is "recuired to be disclosed."
Actions Taken:
Notwithstanding the denial, we have taken the following actions.
The responsible individuals have been instructed regarding accuracy in license applications.
Additionally, a more detailed review of the applications will be L
conducted by supervisory personnel.
The erroneous exam date on the re-examination application has been corrected.
Action to l
clarify the license application statements was completed on April 18, 1985.
In processing future applications, notwithstanding GPC's sincere desire to accommodate the Examining Branch's reouest for non'recuired information to ease its administrative
- burden, information which is not recuired by either 10 CFR Section 50.55 or Form 398 will not be included in routine application submittals in order to assure bur ability to effectively control our record e
keeping programs.
Violation 2:
The Nuclear Regulatory Commission Order to Georgia Power Company dated July 10,
- 1981, reouires that the licensee implement the reouirements of MJREG-0737, Items I.C.5 and II.B.A.
Contrary to the above,.the licensee failed to implement the
- reou'rements of MJREG-0737 in that:
a.
NUREG-0737 Item I.C.5 reouires that operational experie:ce
,.,7 -
fee &ack be provided to maintenance personnel.
Feedback of
?,e N
operating experience is controlled by procedure FNP-911, 3
r M
i GeorgiaPower A U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 April 29, 1985 Page Four Operating Experience Assessment Report.
The licensee's submittal dated December 15, 1980, responding to NUREG-0737 Item I.C.5 states that "all operating personnel" receive feesack of operating experience and that provisions exist to assure that appropriate personnel are informed, and documents and training programs upgraded.
Contrary to MJREG-0737 Item I.C.5, maintenance personnel are not addressed in INP-911 and, therefore, do not receive operating experience fee & ack as reouired.
b.
NUREG-0737 Item II.B.4 states that the Plant Manager shall receive all the training indicated in Enclosure 3 to H. R.
Denton's March 28, 1980 letter.
Contrary to MJREG-0737 Item II.B.4, the current plant manager has not received the training in mitigation of core damage specified in Enclosure 3 to H. R. Denton's March 28, 1980, letter.
This is a Severity Level IV violation (Supplement I).
L Response To Violation 2a:
Admission or denial of alleged violation: The violation occurred, but not precisely as stated.
Reason for the violation:
Feedback of operating experience to i
j maintenance personnel was not addressed in procedure HNP-911.
However, maintenance personnel were receiving operating experience fee &ack through the same information program implemented for licensed personnel under HNP-911.
The Shift Technical Advisors (STA's) periodically assess, compile, and distribute relevant information to all licensed and operating personnel and training instructors.
Corrective steps which have been taken and the results achieved:
Subject to the Plant Hatch Procedure Upgrade Program, procedure HNP-911, is being revised and reformatted as an administrative control procedure 30AC-OPS-003.
GeorgiaPower b U. S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900
-April 29, 1985 Page Five Corrective steps which will be taken to avoid further violations:
The revised procedure will address maintenance personnel and continue to provide operating experience feedback as reouired.
Procedure 30AC-OPS-003 will be fully implemented by July 31, 1985.
Date when full compliarce will be achieved:
Full compliance will be achieved on July 31, 1985.
Response to Violation 2b:
' Admission or denial of alleged violation: The violation occurred.
Reason for the violation:
The plant manager did not receive the training in mitigation of core damage as per enclosure 3 to H. R.
Denton's March 28, 1980, letter as a result of a misinterpretation of the Unit 2 Technical Specifications.
Plant Hatch personnel misinterpreted the Technical Specifications Figure 6.2.2-1 on Unit Organization to mean that either the Plant Manager or Assistant Plant Manager should meet the recuirements of NUREG-0737 Item II.B.4 since either is reouired to have obtained a Senior Reactor Operator's license.
Corrective steps which have been taken and the results achieved:
The below actions are sufficient to prevent recurrence.
Corrective steps which will be taken to avoid further violations:
The' plant manager will be given the training in mitigation of core damage specified in Enclosure 3 to H. R. Dentons' March 28, 1980 letter.
This training will be completed by August 1,1985.
In addition we will consider seeking either 1) a modification of the Technical Specifications or 2) the clarification of the July 10, 1981 Order to reouire training only for licensed operators in the operations chain from the Manager of Operations down.
Date when full compliance will be achieved:
Full compliance will be achieved by August 1, 1985.
'""5
1 GeorgiaPower d U.' S. Nuclear Regulatory Commission Office of Inspection and Enforcement Region II - Suite 2900 April 29, 1985 Pa0e Six Violation 3:
10 CFR 50 Appendix B Criterion V as implemented by the licensee's accepted QA program, Final Safety Analysis Report (FSAR) Section 17.2.5, reouires that activities affecting ouality shall be prescribed by documented procedures and shall be accomplished in accordance with these procedures.
10 CFR 50 Appendix B Criterion XVII as implemented by the licensee's j.
accepted QA program, FSAR Section 17.2.17, reouires that the licensee shall establish reouirements concerning record retention and that records shall be identifiable and retrievable.
Contrary to the above, as of February 7,.1985, procedures were not in place for the control or retention of training records.
This is a Severity Level V violation (Supplement I).
Response To Violation 3:
Admission or denial of alleged violation: The violation occurred.
Reason for the violation:
The improper control of retained training records was the result of an inadeouate procedure.
Procedure HNP-820, Plant Records Management, defines methods for the collection,
- storage, and maintenance of plant cuality assurance records, but lacked specificity with respect to training records.
Corrective steps which have been taken and the results achieved:
The actions described below are sufficient to prevent recurrence.
Corrective steps which will be taken to avoid further violations:
I Subject to the Plant Hatch Procedure Upgrade Program, Procedure WP-820 is being revised and reformatted as a
cepartment instruction DI-TRN-10-0884. This instruction will include details for the control and retention of training records as reflected in the recuirements of the American National Standards Institute (ANSI) N45.2.9.
,-r
GeorgiaPower d U. S. Nuclear Regulatory Commission
.-Office of Inspection and Enforcement Region II - Suite 2900 April 29, 1985
- Page Seven Date when full compliance will be achieved:
Full compliance will be achieved on July 31, 1985.
Should you have any cuestions in this regard, please contact this office.
Sincerely yours,
/T &
L. T. Gucwa JJB/blm ax: J. T. Beckham, Jr.
H. C. Nix, Jr.
Senior Resident Inspector 4
700773 '.
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