ML20207J507
| ML20207J507 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 06/16/1986 |
| From: | Pilant J NEBRASKA PUBLIC POWER DISTRICT |
| To: | Gagliardo J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20207J485 | List: |
| References | |
| CNSS865821, NUDOCS 8607290147 | |
| Download: ML20207J507 (3) | |
Text
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CNSS865821 3M@M[W1[2T June 16,1986 I
I JUN 2 01986 Mr. J. E. Gagliardo, Chief Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011
Subject:
NPPD Response to Inspection Report 50-298/86-07
Dear Mr. Gagliardo:
This letter is written in response to your letter dated May 16, 1986, transmitting Inspection Report 50-298/86-07.
Therein you indicated that one of our activities was in deviation of District commitments.
Following is a statement of the deviation and our response in accordance with 10CFR2.201.
Notice of Deviation Inadequate Preventive Actions The response letters CNSS 857490 to NRC Inspection Report 50-298/85-20 and NLS 8400026 to NRC Inspection Report 50-298/83-26 both committed to training of engineering personnel to prevent further violations wherein procedures were not fully implemented.
In deviation from the above, one new site engineer and some senior general office engineers performing i
safety-related work were not documented as having been trained by applicable procedures as committed to in CNSS I
857490.
Additionally, the procedure for training new site l
engineers did not address an applicable procedure (EP 3.3), and not all applicable site and general office engineers were documented as having been trained in the l
applicable procedures as committed to in NLS 8400026.
8607290147 860723 PDH ADOCK 05000298 G
PDR 1
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J. E. 6:gliards -
June 16,1986 Page 2 Reason For Deviation After a review of the training records, the District has determined that a deviation from the commitment made in CNSS857490, does not exist.
The new site engineer noted by the NRC inspector was not a member of the District's staff at the time that the refresher training required by the commitment was conducted.
Furthermore, since the purchase order noted in the violation (for which CNSS857490 was a response) was CNS-generated, the commitments made in CNSS857490 were intended to apply to CNS engineers.
General Office engineers receive related training as part of their existing training program.
Consequently, the District feels that the commitments made in CNSS857490 were met.
However, the need for revising CNS Procedure 0.17,
" Selection and Training of Station Personnel", to reflect continued training in this area was not realized at the time the commitment was made.
This item is now a recognized weakness.
For the case of NLS 8400026, the governing procedures and instructions for design initiation, change, and review are foremost in the training of all District design engineers, prior to starting design work at CNS.
However, the lack of complete documentation of this training, as well as the failure to include Engineering Procedure 3.3 within the training requirements of CNS Procedure 0.17, are admitted and are due to procedural weaknesses.
The Corrective Steps Which Ifave Been Taken And The Results Achieved CNS Procedure 0.17, " Selection and Training of Station Personnel", which includes the required reading list for all new CNS engineers, has been revised to include applicable procedures and instructions for safety-related equipment procurement and for design initiation, change,. and review.
The revised procedure will be implemented for all CNS engineers to insure that the weaknesses noted in the deviation are resolved.
For General Office engineers a review of the General Office NED procedure review log shows that all General Office NED engineers have reviewed the April 2,1986 issue, Revision No. 4, of EP 3.3 as well as the previous revision (Revision No. 3),
therefore, no corrective action is necessary.
Corrective Steps Which Will Be Taken To Avoid Further Deviation A formal training program for CNS engineers is presently being developed as a part of the overall training program upgrade which is in progress.
Activities addressed within this program include procurement of essential (safety-related) equipment and design initiation, change, and review.
Additionally, a comprehensive computerized Training Management System (TMS)
J. E. G:glirrds 6
Juns 16,1986 Page 3 e
is being developed to aid in the tracking and complete documentation of specific training program activities.
Date When Full Compliance Will Be Achieved As stated above, the weaknesses addressed in this Notice of Deviation have.been included in the newly revised CNS Procedure 0.17.
This revision will be implemented for all CNS engineers by July 31, 1986.
The formal training program for CNS engineers is scheduled for accreditation by the Institute of Nuclear Power Operations in October, 1986, with full implementation by January 1,1987.
If you have any questions regarding this response, please contact me.
Sincerely, JUM. Pflant Technical Staff Manager Nuclear Power Group JMP/GRH/EMM/DLR/ya:rs(COMM9) l l
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