ML20213G975
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| ML20213G975 | |
| Person / Time | |
|---|---|
| Site: | Shoreham File:Long Island Lighting Company icon.png |
| Issue date: | 11/14/1986 |
| From: | Grimsley D NRC OFFICE OF ADMINISTRATION (ADM) |
| To: | Zahnleuter R NEW YORK, STATE OF |
| References | |
| FOIA-86-758 NUDOCS 8611180439 | |
| Download: ML20213G975 (2) | |
See also: IR 05000322/1986010
Text
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' I PART II-RECORDS RELEASED OR NOT LOCATED (Sel checked bones)
No agency records subpect to the request have been located.
No additional agency records subsect to the request have been located.
Agency records subrect to the request that are identifed in Appenda are already avadable for public inspection and copying in the NRC Public Document Room,
1717 H Street, N W., Washington, DC.
Agency records subject to the request that are identified in Appendin are being made avadable for public inspecten and copying in the NRC Pubhc Document
Goom,1717 H Street, N W., Washmgton, DC, in a folder under this FOIA number and requester name.
The nonproprietary vers.on of the proposal (s) that gou agreed to accept in a telephone conversaten with a member of my staff is now bemg made avalable for public inspecten
and coying at the NRC Pubic Document Room,1717 H Street, N.W , Washington, DC, in a folder under this FOlA number and requester name.
Enclosed is informaton on how you may obtain access to and the charges for copying records placed in the NRC Public Document Room,1717 H Street, N.W., Washington, DC.
Agency records subrect to the request are enclosed. Any appletable charge for copes of the records provided and payment procedures are noted in the comments section,
Cecords subsect to the request have been referred taanother Federal agencytesi for revew and dired response to you.
In view of NRC's response to this request, no further acten is bemg taken on appealletter dated
PART ll.A-INFORMATION WITHHELD FROM PUBLIC DISCLOSURE
Certain informaton in the requested records is being with*ield from public disclosure pursuant to the FOIA esemptions described in and for the reasons stated in Part II, sec-
tons B, C, and D. Any released portions of the documents for which only part of the record is bemg withheld are be ng made available for public inspection and copying i.1
the NRC Public Document Room,1717 H Street, N.W., Washington, DC, in a folder under this FOIA number and requester name.
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Re: F01A-86-758
Appendix A
Document Being Placed in the PDR
1. 5/21/86
Shoreham Training and Qualification Audit (23
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UNITED STATES OF AMERICA
NUCLEAR REGULATORY COMMISSION "
FREEDOM OF INFORMATION
Before the Commission ACT REQUEST
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In the Matter of .
. Docket No. 50-322
LONG ISLAND LIGHTING COMPANY .
. October 14, 1986
(Shoreham Nuclear Power '
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Station, Unit 1) .
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MOTION OF GOVERNOR MARIO M. CUOMO, REPRESENTING THE
STATE OF NEW YORK, TO COMPEL PRODUCTION OF AN AUDIT
REPORT ON SHOREHAM PERSONNEL AND MOTION FOR
EXPEDITED CONSIDERATION
SUMMARY
Governor Mario M. Cuomo, representing the State of New
York, hereby requests, pursuant to 10 CFR S2.730 (a) (1986)
that the commission compel Long Island Lighting Company (LILCO)
to -immediately produce an audit report on the training and
qualifications of Shoreham personnel (hereinafter referred to
as the " Audit Report"), which the NRC Staff discussed in NRC
Inspection Report No. 50-322/86-10. The State of New York also
seeks an order from the commission compelling LILCO to
immediately produce all documents created by or for LILCO after
the aQdit which relate to the analysis or resolution of the 35
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audit findings and 19 audit observations noted therein.
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Further, the State of New York requests that the
comrrdssion direct the NRC Staff to immediately produce the
Audit' ' Report and all documents pertaining thereto, including
analyses and resolutions of the 35 findings and 19
observations. Such action is necessary to remedy the NRC
Staff's violation of the Federal Records Disposal Act (44 USCA
S3301 et seq.), and is required by the Federal Records Act (44
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USCA S2901 et seq.) and the Federal Freedom of Information Act
(5 USCA $552). The NRC Staff should also be directed to fully
explain to the State of New York why the Audit Report was
returned to LILCO and not retained in its records, and provide
a list of any other Shoreham-related documents which were
treated similarly.
Because these matters raise serious questions about
LILCO's competency as a low-power licensee and full-power
license applicent, and the NRC Staff's integrity as the
overseer of LILCO's management of Shoreham, the State of New
York respectfully requests that the Commission expedite
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consideration of this motion.
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BACKGROUND
,The State of New York learned of the Audit Report through
NRC~ Inspection Report No. 50-322/86-10 (also referred to as the
" Inspection Report"). The NRC Staff, Region 1, transmitted
this Inspection Report by a cover letter dated June 25, 1986 to
LILCO, Governor Cuomo, the New York State Consumer Protection
Board (CPB) and interested niembers of the public.1/
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The Inspection Report relates' *to a " routine resident
sa fety inspection" conducted by the NRC Staff, Region 1,
between April 16, 1986 and May 31, 1986. The following salient
statement appears on page 12:
[T]he QA Division Manager moved up scheduled
Nuclear Review Board Training Audit and QA
Training Audits to April from their originally
schedules dates. The Training and
Qualifications audit was conducted by a twelve
man audit team that expended over 1,000 man
hours in audit preparation and . conduct. The
audit indicated proper qualification of
personnel with no problems similar to the
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qualification deficiencier identified in the
radiochemsitry [ sic]- area. (See Inspection
Report 86-03 for further details). However,
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the audit report did result in 35 audit
. findings and 19 observations spannTiig III areas
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from program 7 procedure development through
record keeping. As a result of these findings
the audit report recommended further management
attention be applied in the training and
qualification area to assure timely resolution -
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of these audit findings and observations.
[ Emphasis added]
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~1/ The NRC Staff also filed the Inspection Report in tne NRC
l Public Document Room pursuant to 10 CFR S2.790(a) (1986).
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The Inspection Report did not provide any more detailed
information concerning the nature of these audit findings and
observations.
In July 1986, a representative of the State of New York
asked the NRC Staff, Region 1, to provide a copy of the Audit
Report, but the NRC Staff refused to honor the request.-
In a letter dated Augus't 7, 1986 (attached as Appendix A),
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the CPB asked LILCO for a copy of the Audit Report. The CPB
emphasized that since "the Shoreham Nuclear Power Plant is
undergoing low-power testing, it is imperative that all facts
relevant to the training and qualifications of Shoreham
personnel be fully scrutinized."
LILCO responded in a letter of August 21, 1986 (attached
as Appendix B). It stated that a review by the CPB "would not
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be necessary" because the matter allegedly was within the
purview of the NRC Staff, not the CPB.
On September 19, 1986, counsel representing Governor Cuomo
and the State of New York in all of the Shoreham licensing
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proceedings contacted LILCO's counsel to request a copy of the
Audit Report and related documents. This telephone
conversation is described in a letter dated September 18, 1986
(atta'ched as Appendix C) . In that letter, the State of New
York asked LILCO to reconsider its position and produce the
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Audit Report no later than September 22, 1986, and produce
related, derivative documents no later than September 25, 1986.
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In a letter dated September 23, 1986 (attached as Appendix
D) , , LILCO stated that a substantive response would be
forthcoming. However, in a letter dated September 29, 1986
(attached as Appendix E), LILCO failed to comply with the State
of New York's requests for the Audit Report and related
documents. Instead, LILCO invited certain representatives of
the State of New York to attend an oral presentation regarding
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the audit. -
In a letter dated September 30, 1986 (attached as Appendix
F), the State of New York reiterated that an oral presentation
in lieu of actual production o
~f the Audit Report was
unacceptable. Nevertheless, the State of New York again asked
LILCO to reconsider and provide the requested documents no
later than 2:00 p.m. on October 1, 1986. ,
Having received no reply, the State of New York' is now
forced to bring this matter before the Commission and to seek
consideration of this motion on an expedited basis.
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I. LILCO SHOULD BE COMPELLED TO IMMEDIATELY PRODUCE THE AUDIT
REPORT AND ALL RELATED DOCUMENTS
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Inspection Report No. 50-322/86-10 indicates that the .
Audit Report requested by this motion sets forth 35 findings
, and 19 observations. The Inspection Report's discussion of the l
findings and observations is vague, so it is not possible to
discern whether the findin'gs and observations apply to the
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training and qualifications of til Shoreham personnel.
However, it appears that at least some of the deficiencies
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involve training and qualifications of personnel in the
radiochemistry area.
Radiochemistry personnel are crucial to the safe operation
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of Shoreham because they are responsible for monitoring the
levels of radiation throughout the plant. Erroneous data could
lead to incorrect evaluations of plant conditions, which, in
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turn, could lead to significant on-site and off-site adverse
consequences during a radiological emergency. The State of New
York has a right to be informed of such a potentially unsafe
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condition within Shoreham. Accordingly, LILCO should be
compelled to produce the Audit Report immediately so that the
I State of New York can analyze it.
'LILCO's performance in the radiochemistry training and
qualifications area ha's been inadequate during the last year.
Consequently, it has been subject to much review. Briefly,
LILCO's Quality control Division conducted an audit in May and
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June 1985 which resulted in several findings and observations.
The , Quality Control Division sent its audit findings and
observations to the appropriate radiochemistry personnel on
July 15, 1985 and asked for a response before August 15, 1985.
On October 15, 1985, two months after the August 15, 1985
deadline, LILCO's radiochemistry personnel responded to LILCO's
Quality Control Division by assuring it that most of the
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corrective measures would be in place'ty December 31, 1985.
To determine the effect of the corrective measures, *
LILCO's Quality control Division conducted a follow-up audit
during the week of January 13, 1986. The follow-up audit
indicated that corrective measures had not been instituted.
Soon thereafter, LILCO's radiochemistry personnel agreed to
immediately adopt certain corrective training and qualification
procedures described in a Corrective Action Request dated
January 27, 1986. See NRC Inspection Report No. 50-322/86-03,
, at 1, 2. a
The NRC Staff conducted a special inspection of
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radiochemistry operations, referred to as NRC Special
Inspection No. 50-322/86-03, between January 27, 1986 and
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February 14, 1986. The Special Inspection identified a large
numbe'r of deficiencies, which were the subject of NRC
Inspectfon Report No. 50-322/86-03 dated March 14, 1986, an
NRC-LILCO Enforcement Conference on March 20, 1986, and a
Corrective Action Letter (CAL 86-05) dated March 21, 1986.
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The NRC Staff then conducted another inspection between
March 1, 1986 and April 15, 1986, which culminated in NRC
Inspection Report No. 50-322/86-08, dated May 29, 1986. This
report cryptically stated at page 12:
The inspectors are satisfied that the actions
taken by the licensee in retraining and
requalification of Radiochemistry Technicians
are thorough and correct and satisfied the
requirements of CAL 86-05 pertaining to
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technician qualification.
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The NRC Staff conducted the inspection that formed the
basis for NRC Inspection Report No. 50-322/86-10 between April
16, 1986 and May 31, 1986. The number of audit findings (35)
ar.d observations (19) set forth in that report is unusually
high, especially since LILCO's radiochemistry personnel
supposedly had just corrected deficiencies that the NRC Staff
identified earlier in NRC Inspection Report No. 50-322/86-03.
In addition, these problems were widespread. Indeed, the 35
findings and 19 observations spanned "all areas from
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program / procedure development through record keeping."
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(Inspection Report No. 50-322/86-10, at 12)
These facts indicate that the training and qualifications
l of Shoreham personnel could be seriously deficient. It is
imperative that the Audit Report be produced immediately so
that the State of New' York can obtain first-hand information
about the nature and significance of the findings and
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observations, analyze the underlying data, and determine
whether further action by the commission might be required.
LILCO's rejection of our requests for the Audit Report
suggests that LILCO is concealing important information bearing
on the safety of Shoreham. This increases the State of New
York's need to promptly obtain the Audit Report.dI
LILCO's continuing refQsal to provide the Audit Report to
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the State of New York is irresponsible, especially since LILCO
provided the Audit Report to the NRC Staff several months ago.
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For instance, in a September 29, 1986 letter to the State of
New York (Appendix E), LILCO attempted to rationalize its
selective transmission of the Audit Report to the NRC Staff as
follows:
Because the report about which you have
inquired involved Shoreham, we naturally shared
- the results with the NRC,. the agency
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responsible for reviewing nuclear operational
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i l As a result of policy, LILCO does not ,
normally provide information on internal
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reviews to outside groups.
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2/ LILCO's proposal that certain representatives of the State
,of New York attend an oral presentation on the Audit
Report (see Appendix F) is unacceptable. If LILCO is
willing to make an oral presentation regarding the audit,
then LILCO should be willing to release the underlying
documentation --
which presumably will support the
statements made during the oral presentation. Without the
. underlying documents, however, the State of New York has
no basis to verify LILCO's assertions.
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Contrary to LILCO's contention, the State of New York is
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not,en "outside group." The State of New York has a right to,
receive documented information about Shoreham's safety since
the plant is located in New York and a radiological accident
there could have many adverse impacts on New York's residents.
That concern is justifiably heightened by LILCO's obstinance in
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refusing to produce the Audit Report, LILCO's record of
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extensive mismanagement of Shoreham; and the State of New
York's well founded lack of confidence in LILCO.
Moreover, ordinary principles of litigation propriety and
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fair play establish the right of one party in an adversarial
proceeding to secure in a timely manner whatever materials
other independent, nonaligned parties transmit between
themselves. If two independent, nonaligned parties privately
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share factual information, as LILCO and the NRC Staff have done
with respect to the Audit Report, the proper remedy for the
i commission is to order that these two parties produce the
relevant documents. The other parties can then study the facts
and consider on an informed basis whatever action is
appropriate. The Commission should apply this remedy here
l because, as a party in interest in all of the shoreham
licensing proceedings, the State of New York enjoys precisely
the same' party status as the NRC Staff. The State of New York,
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therefore, is entitled to the same materials LILCO gave to the
NRC Staff and the Commission should order LILCO to produce the
Audit Report immediately."s
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LILCO should also be compelled to'immediately produce all
documents related to the Audit Report. Audit findings are
significant because they usually require corrective actions.
Audit observations are significant too because they usually
suggest ways of developing and implementing improvements.
. Indeed, after noting that the Audit Report 1 contained 35
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findings and 19 observatlons, NRC Inspection Report No.
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50-322/86-10, at page 12, stated: -
As i. result of these findings, the audit report
recommended further management attention be
applied in the training and qualification area
to assure timely resolution of these audit
findings and observations.~
Thus, the Audit Report cannot be reviewed in isolation.
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It is essential that the Audit Report be analyzed in
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conjunction with LILCo's follow-up efforts. The State of New
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York, therefore, is entitled to review all documents which show
whether and to what extent LILCO has " applied further
management attention" to the problems described in the Audit
Report,
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and whether and to what extent that attention has
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resulted in " timely resolution" and correction of the audit
findings and observations. Accordingly, the Commission should
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j order LILCO to immediately produce all documents created by or
for L'ILCO after the audit which relate to the analysis or
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resolution of the 35 findings and 19 observations noted in the
Audit Report.
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II.
THE NRC STAFF SHOULD BE DIRECTED TO IMMEDIATELY PRODUCE
_THE AUDIT REPORT AND ALL RELATED DOCUMENTS
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A'. The NRC Staff's Failure To Retain A Copy Of The Audit
Report Is A Violation Of The Federal Records Disposal
Act And Must Be Remedied Promptly.
The NRC Staff's action in returning the Audit Report to
LILCO without retaining a copy (see Appendix G) violated the _
Federal Records Disposal Ac't, 44 USCA 53301 et seq. This Act *
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provides the exclusive means for disposal of federal records.
44 USCA 53314. Records are defined as:
' [A]11 books, papers or pther documentary
material ... made or h eived by an agency of
the United States Gove nder Federal law
or in connastJ,on with the transaction of public
business l andl preserved or appropriate for
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preservation by that agency ... as evidence of
the organization, functions, policies,
decisions, procedures, operations or other
activities of the Government or because of the
informational
(Emphasis Added). data in them ... [44 USCA 53301]
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Under this statutory scheme, each federal agency must compile
lists of records which it wishes to dispose of and submit those
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lists to the Archivist of the United States.M 44 USCA 53303.
The Archivist must then examine the lists. If the records meet
certain criteria, and after the Archivist follows certain
procedures, the Archivist may " empower the agency to dispose of
those' records." 44 USCA S3303a.
3/ The implementing regulations further emphasize
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Archivist's exclusive authority: the
"No records of the
Government shall be destroyed or otherwise alienated from
the Government except in accordance with 44 USC 3314."
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The Audit Report cicarly is a " record" within the preview ;
of , $he Federal Records Disposal Act since the NRC Staff l
received that document from LILCo. (Public Records Disposal
Act, 44 USCA S3301) Indeed, such audit reports are mandated by
the NRC Q Vlations and are an integral part of the licensing
process.
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The need for and purpose of quality assurance audits in
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l the NRC's licensing process is highlighted by Section XVIII of
Appendix B of 10 CFR Part 50. That section provides:
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A comprehensive system of planned audits shall ,
be carried out to verify compliance with all
aspects of the quality assurance program and to
determine the effectiveness of the program ...
Audit results shall be documented and reviewed
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by management having responsibility in the area
audited. Follow-up action, including reaudit
! of deficient areas, shall be taken where '
indicated. (Emphasis Added)
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Section XVII also is relevant. It provides:
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Sufficient records shall be maintained to
furnish evidence of activities affecting
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quality, the records shall include at least the
following: Operating logs and the results of
. ' reviews, inspections, tests, audits, monitoring
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of work performance, and materials analyses ...
Records shall be identifiable and retrievable
... (Emphasis Added)
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Further, Section I provides
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, The quality assurance functions are those of:
(a) assuring that an appropriate quality
assurance program is established and
' effectively executed, and (b) verifying, such
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as by checking, auditing, and inspection that
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activities affecting the safety related
functions have been correctly performed.
- (Emphasis Added)
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The information concerning quality assurance specified in
these regulations must be included in the Preliminary Safety
Analysis Report (PSAR) and the Final Safety Analysis Report
(FSAR), pursus.nt to CFR 550.34 (a) (7) and (b) (6) (ii) . Since the
PSAR and FSAR are mandatory elements of applications for a
construction permit and an operating license, respectively,
audit reports are records " received ... in connection with the
transaction of public
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business and ... appropriate for
preservation." (Public Records Disposal Act, 44 USCA S3301)
This basic fact is not affected by the NRC Staff's action
of returning the Audit Report to LILCO. Once the Audit Report
was received by the NRC Staff, it became part of the NRC's
records. As such, it was exclusively within the Archivist's
control pursuant to the Public Records Disposal Act and could
not be disposed of without authorization by the Archivist. The
NkC Staff, however, apparently did not comply with the statute.
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There is no indication that the NRC Staff placed the Audit
Report on the list contemplated by the statute. Nor is there
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any evidence that the Archivist authorized the NRC Staff to
l dispose of the Audic Report by returning it to LILCO.
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Under these circumstances, the Commission is required by
the Federal Records Act, 44 USCA $2901 et seq., to initiate
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approprfate action to regain possession of the Audit Report.
The Federal Records Act provides:
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The head of each Federal Agency shall notify
, the Archivist of any actual, impending or -
. , , threatened unlawful removal, defacing,
alteration or destruction of records in the
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custody of the agency of which he is the head
that shall come to his attention, and with the
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assistance of the , Archivist shall initiate
action through the Attorney General for the
recovery of records (ne xnows or nas ] reason to
believe have been unlawfully removed from his
agency ... [44 USCA $3106] (Emphasis Added)
In this case, the AudiN Report has been in the possession
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of the NRC Staff but has been unlawfully without authorization
by the Archivist. The Commission is, therefore, obligated by
the Federal Records Act to recover the Audit Report from LILCO.
In this way, the Audit Report can" rightfully be placed in the
NRC Public Document Room (like NRC Inspection Report No.
l 50-322/86-10) and made available to parties in this proceeding l and the public in general. The Commission clearly cannot cite
the NRC Staff's failure to retain the Audit Report as
justification for failing to provide it to the State of New
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B. The Freedom of Information Act Requires That The
Audit Roport Be Provided To The State Of New York
The Freedom of Information Act, SUSCA 5552, requires that
the records of Federal government agencies be made available
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upon request, except l'n the case of certain narrowly construed
exemptions which clearly do not apply here. It is obvious that
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the NRC would be obligated to provide the Audit Report if that
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document were still in its physical possession. The same
resu,1t must apply in this instance, notwithstanding the
subsequent return of the Audit Report to LILCO.
In light of its actions, the NRC Staff must be deemed to
have constructive possession of the Audit Report. The NRC
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Staff took possession of the Audit Report, reviewed it and
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discussed its findings in Inspection Report No. 50-332/86-10.
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As such, the Audit Report is an integral part of the NRC's
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records in the Shoreham licensing proceedings. The NRC has the
general authority to require LILCO to produce any documents
concerning the Shoreham quality assurance including the Audit
Report.1 Horeover,
i the NRC has an affirmative obligation
under the Federal Records Act to reclaim the document from
LILCO. ( g Point II-A _ supra)
Thus, the physical return of the Audit Report to LILCO
j cannot relieve the NRC of its obligation under the Freedom of
Information Act to provide the Audit Report to the State of New
York. If it were otherwise, the
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explicit language and
overriding policy of the Freedom of Information Act could be
frustrated simply by disposing of records concerning
potentially controversial matters. Such a result clearly would
1 I
be un' tenable.
Acdordingly, the Audit Report should promptly be provided
to the State of New York pursuant to the Freedom of Information
Act.
.- i
1/ _See e.g., 10 CFR, Appendix B, SS I, XVII, XVIII.
l
16 . . - . _ . - . _ _ - . _ - - . - . _ _ - . _ . _ -- _.
. _ _ _ . - . - . - . .
.
L' ,
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1
C. The NRC's Regulations Require That The Audit Report
Be Made Available For Copying In The NRC Public
. , , Document Room.
10 CFR S 2.790 (a) sets forth rules for the availability of
,
NRC records. This section provides that certain NRC records
; and documents shall be disclosed and shall be made available
;
for inspection and copying in the NRC Public Document Room,
i
,
'
with certain qualifications', none of which apply to the Audit
Report. The NRC Staff is
; familiar with this requirement
because it placed NRC Inspection Report No. 50-322/86-10, which
discusses the Audit Report, in the Public Document Room
~
pursuant to this provision.
The Audit Report falls within the scope of this regulation
because it is " correspondence to ... the NRC regarding the
issuance, denial, amendment, transfer, renewal, modification,
suspension, revocation, or violation of a license, permit or
order."
As explained in Point II-A supra, LILCO prepared the
i
Audit Report and the NRC Staff reviewed it as part of the
licensing process established under 10 CFR 550.34. The NRC
Staff violated 10 CFR S 2.790 (a) by not treating the Audit
Report as a public record, not placing it in the NRC Public
Document Room, and simply giving it back
'
to LILCO. The
1
commission should take immediate action to rectify this error
-
'
and recall the Audit Report.
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_ _ _ - _ _ _ _ _ _ - _ . . - - - - - .- -.
. . _- _ _ ._
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, important document would not be in the public record and would
not pven be in the NRC Staff's possession.
Second, what are the NRC Staff's procedures in regard to
'
documents received from licensees and applicants? Are those
procedures written or informal? (If there are written
procedures, they should be provided.)
Third, were the esthblished procedures followed with
*
respect to the Audit Report? If they were not, what was the
reason?
Fourth, have there been any other instances in which
documents received from LILCO were' returned? If so, what were
the circumstances and the reasons for such action?
Fifth, to what extent did the NRC Staff utilize the Audit
Report? Did the NRC Staff prepare notes regarding the Audit
Report? Did the NRC Staff utilize .the Audit Report in
l evaluating LILCo's subsequent performance? Any notes or other
NRC Staff records concerning
, i
the Audit Report should be
j provided.
~
I
The State of New York requests that the Commission direct
I
the NRC Staff to respond fully to each of these questions and
provide the information requested therein. It is imperative
i
that'those responses be given promptly.
*
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\ 19 i !
.._. _ __ _
_ ,.___ .._. .___.
.
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E. The NRC Staff Should Be Required To Immediately
-
Produce All Documents Related To The Audit Report.
.. ,
As discussed in Points I supra, it is essential that the
State of New York be provided with all documents related to the
Audit Report, as well as the Audit Report itself. This
necessarily includes relevant documents prepared by and for the
NRC Staff, since that enti'ty relied on the Audit Report to
*
formulate the pertinent evaluations set forth at page 12 of the
Inspection Report No. 50-322/86-10 and is responsible for
reviewing LILCO's follow-up efforts regarding the problems
highlighted in the Audit Report. Indeed, the Audit Report
presumably would be used as a baseline to evaluate future LILCo
performance.
Accordingly, the Commission should direct the NRC Staff to
promptly provide all such documents to the State of New York.
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- - - . - - _ - - - . , _ . - - - _ . - - - . - . . . _ ,___ _. . _ _ _ _ . . . , . , - _ . , - .. . - . - - . - - - _ _ - - - - - - . - - -
.-- .- . - - - _ _ . - _ _ _ _ . .- -
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- III. THE MATTERS RAISED IN THIS MOTION SHOULD BE CONSIDERED
EXPEDITIOUSLY
.,
The matters raised in this motion involve very important
questions about the safety of Shoreham. The unusually high
number of observations and findings noted in the Audit Report
bear this out. LILCO's refusal to produce the document
.
underscores the State of New York's concern that the Audit
Report reflects significant deficiencies in the
i
safety of
Shoreham. Moreover, the NRC Staff's action in returning the
i
Audit Report to LILCO appears irregular and, at a minimum,
requires a full explanation.
t
Both LILCO and the NRC Staff are familiar with the
specific issues raised by this motion. Almost two months have
I
elapsed since the CPB asked LILCO for the Audit Report, and one
! month since counsel representing Governor Cuomo and the State I
of'New York reiterated that request. The NRC Staff has been
cognizant of the State of New York's request for the Audit
Report for much longer -- since early July. Hardship will not
accrue to either LILCO or'the NRC Staff since both parties have
had ample time to gather the relevant documents and to
formulate positions.
i
"Accordingly, the State of New York requests that the
'
matters ' raised in this motion be considered on an expedited
basis, with the period for answers set forth in 10
.
CFR
? 's
21
- - . - - _ - - . .. - . - - . .
*
.
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52.730 (c) (1986) reduced for all interested parties, including
LILC4 and the NRC Staff, to seven days from the date of service
of this' notion, or Monday, October 20, 1986.
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3 , CONCLUSION
-
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The Commission should not allow, LILCO's irresponsible
actions to interfere with the right of the people of the State
!
of New York to be informed of conditions within a resident
I e
nuclear power plant. The Audit Report and related documents
'
should be available to the State of New York, but,
unfortunately, they currently are not.
Accordingly, the Commission should issue an order
compelling LILCO to immediately produce the Audit Report and
all documents created by or for LILCO after the audit which
relate to the analysis or resolution of the 35 findings and 19
observations noted therein. .
-
In addition, the Commission should direct the NRC Staff to
immediately produce the Audit Report and all documents in its
possession pertaining thereto, as well as to the analysis or
! resolution of the 35 findings and 19 observations. The NRC
Staff should also be directed to explain fully why the Audit
Report was returned to LILCO and not included in the public
files', and to provide a list of any other shoreham-related
documents that were treated similarly.
.
.
23
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-- _ - - -- _. ,.- -
____________ __________
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t .
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Since these matters raise serious questions about the ,
compptency of LILCO as a low-power licensee and full-power _
license applicant, and the integrity of NRC Staff as an -
2
overseer of LILCo's management of Shoreham, this motion should "
be granted on an expedited basis. .
"
.n.
.
'
Respectfully submitted, ,,
.
i a 4 >
Fabian G. Palomino
Richard J. Zahnleuter
Spec'ial Counsel to the -
Governor of the State of
New York
Executive Chamber ",
Capitol, Room 229 .
Albany, NY 12224
Attorneys for Governor
Mario M. Cuomo and the
State of New York
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_ _ _ _ . _ . _ _ _ . _ . _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _
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L'* **
u APPENDIX B
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E
g/E_g LONG ISLAND LIGHTING COMPANY .
ExtCUTtyt OFFICES 175 EAST OLD COUNTAY ROAD * HICMSVILLL NEW YoRM IIsol
.
. : - q.o...e-
. . . . .
- - - . --
~ wnec~
...-..m.m ascuma m .
. 10muu nonCTLQ
...
b.. jy . Aew, n. y,
.- S a. @g g tZ'.' " ' .? ? '
.
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August 21, 1986
.. .
gumpygEb E
-
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, . ', g w. :.g;. .q.!.
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- -.
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-
- . .
- - .
?,y . c.
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~..-. .
. . - y
..
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_- .
._ . .
.!. --
_,
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-:x-J .. : . .1.c -
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.-
...'!.4*;,f Y Mr. Richard M. Kessel *
.
' - ~
-
. U.y ' '+.L. Chair and Executive Director
*
*
'.'.f/ .
State Consumer Protection Board '
jay - 99 Washington Avenue .,
. f '. Albany, NY 12210 ,
' ,
-.r.
..
Dear Mr. Kessels
As your Xugu3t 7th letter reflects, the Nuclear
Regulatory Commission has been actively reviewing the training _ .
and qualification of personnel working at Shoreham as pa~rt of--
their statutory responsibility for the regulation of nuclear -l
-
power plants. We believe the Nuclear Regulatory Commission is 9 -*-
fully capable of assessing the adequacy of LILCO's programs in ~-
this area and that a review by the Consumer Protection Board ~~
would not be necessary.
As you know, LILCO has and will ~ continue to cooperate
fully with the State Consumer Protection Board in those areas
.
which fall within its purview. _.
,
._
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Sincerely, ,
. - -
"
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w.. 4 U.S.m -
._
._
1 -
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WJC/dh - . . .
6 C
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....,
.-.
,
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. .ts .
.. **
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,. ,
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.., .
_ _ _ _ _ _ . ,,. . _ . - , . - . _ - _ . -
_ _ - . _ _ _ . . _ _ . , ~ _ . , _ . _ . . .
--12- ---...s- - - = - = A.A -' -. -- - - - - +J2 - - - = ~-a"auaa - - _ _. ---
=-
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, , , APPENDIX C
Sheet 1 of 3 l
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srssr or Nrw you --
,
.
., a, Exrcutivt CHAM 9rR
PAS AN PALOMINO
e... . ,
. .. ,....
.,. September 18, 1986
*
.:.60' -
...
~
i - . .. [
*
,
By Telecop'Ier .
/I
.'s,ly. -
.
.
i .? Donald P. Irwin, Esq.
'
.
Hunton & Williams
*'[ '. e *
P.O. Box 1535 -
r,6- Richmond, Virginia 23212
,
:/ ,
'
.{ . . . , Dear Don:
'-
:
.
Under cover of a letter, dated June 25, 1986, Region I of
; the NRC transmitted Inspection Report No. 50-322/86-10 to my
office and interested members of the public. The report covers
4
j the period between April 16, 1986 and May 31, 1986. The
; following salient statement appears on page 12:
I
[T]he QA Division Manager moved up scheduled
-
i
Nuclear Review Board Training Audit and QA Training
-
'
; Audits to April from their originally scheduled dates.
i
, The Training and Qualifications audit was conducted
by a twelve man audit team that expended over 1,000
} -
man hours in audit preparation and conduct. The
I audit indicated proper qualification of personnel
i with no problems similar to the qualification -
3 deficiencies identified in the radiochemsitry [ sic]
l ) area. (See Inspection Report 86-03 for further
.
.
details). However tha Andit report did result h M
, ' ")f
-
'
AMdit findings And M observations moannina AM AISAE
fIgg croaram/orocedure development throuah record
; keenina. ~ As a result of these findings the audit
report recommended further management attention
*
be applied in the training and qualification area
i ,
.to assure timely resolution of these audit findings #
-
-
and observations. [ Emphasis added]
. .
9 In~ furtherance of' our telephone conversation on the morning ~
of September 18, 1986, I hereby request that the State of New
, l !( York receive in hand a copy of the audit report referred to in '
q the NRC Inspection Report immediately, but in no event later than
j
:4 .* i
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.'*y .
. _ _ _ _ _ __.
__
.. -- .. - -_ .. .. - - - _ .
_ _ . - - _ . - _ - . - . . - _ _ _ _ _ _ _ __ ___
_
** '
g . APPENDIX C
'
.
* Sheet 2 of 3
.
-2-
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*
h' "
the close of business on Monday, September 22, 1986. In
addition, please provide in hand before the close of business on
' Thursday, September 25, 1986 a copy of all documents created by
_ or for LILCO after the audit report which relate to the analysis
...nand resolution of the 35 audit findings and 19 audit
'~ ~ observations.
.: ' .
.b"
*
. As you are aware, the State Consumer Protection Board
9F' requested this same information from LILCO in a letter, dated
. .J 5'? August 7, 1986. Bowever, in a letter, dated August 21, 1986, Mr.
flhE Catacosinos responded, 'We believe the Nuclear Regulatory l
'
.,,.J Commission is fully capable of assessing the adequacy of LILCO's
l'.Q?' . programa in the area and that a review by the Consumer Protection
hp Board would not be necessary." Mr." Catacosinos also pledged to
v' cooperate fully with the State Consumer Protection Board in i
*
those areas which fall within its purview.' .
.
. ,
The State of New York has a right to be informed of
,
conditions, both positive and negative, within all of its
'
resident power plants. Shoreham is no exception. 35 audit
observations and 19 audit findings are unusually high numbers,
particularly since LILCO'<s performance in the radiochemistry area
supposedly has improved since March 1986. The mere fact that
. LILCO has resisted disclosing documents which it already has
^ submitted to the NRC suggests to us that LILCO is concealing
something of importance and increases the intensity of our need
< to obtain the documents promptly. Moreover, as a party in
'.
- interest in the NRC proceedings regarding Shoreham, the State of
J New York has a right to secure in a timely manner f rom LILCO any
( materials that LILCO provides to the NRC Staff, another party to
: the Shoreham proceedings. ,
.
: Your suggestion to the effect that the State of New York
: should agree to withhold the audit report and related documents
,
-
from the State Consumer Protection Board as. a condition to
-
*
receiving such materials is untenable. The government of the
State of New York represents the interests of all its citizens,
including consumers. We will not agree to withhold information
concerning Shoreham from the State Consumer Protection Board.
l . Further, we are not willing to accept an oral presentation '
- concerning the audit report and related documents or an
. inspection ~of these materials by representatives of the State of '
-
New York in lieu of actual production.
-
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s APPENDIX C
.
.
Shset 3 of 3
.
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In view of these considerations, I ask that LILCO reconsider
its position and release its audit report and related documents
in compliance with the terms of this request.
, ,:. . -
'
:- .
; . Ver truly ours
- -
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aH</tO
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2
: #J Richard euter
.i e; '.[ Deputy special Counsel
'
; ,, g :rf to the Governor
! ,-.
_
u t. 2
'!. ' . .
J '
* =
.
.J
-
*
9
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.. 4.. APPENDIX D
. .
.
HUNTON & WILLIAMS
vo7 raar Main sr.scv P.o. son esas
p.
u u w. asesuown,vamonwu soeaa -
-. .. .. .ew . r,
nu, . .. ... ....
.
nus o eo4.vae.eaoo
me s.w.v .
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n,..-.. n L== e 44as: -
. . . . . eu
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.
.
ma, .. . . .. . . . . , a w
' ' ' * * * * vi a m....u.,
..
September 23, 1986 . ....
...,,,,,,,,,,,
. , , .
,r vi. ... ,u. . us vs .... m
m . . .u.u me . . .....u. .
.. . na ==
..c, . ,... !
Richard J. Zahnleuter, Esq.
Deputy Special Counsel to -
the Governor BY TELECOPIER
State of New York -
Executive Chamber
Albany, New York 12224
.
. Dear Rick
~
LILCO is currently reviewing your letter of the 18th. I
will be back to you with a substantive response as soon as
possible.
*
Sincerely yours,
.
.
.
Donald P. Irwin
, 91/730 -
.
.
. . J
.
-
e
-
o g
.. ......- ..... ww. vv
i * gpp .g
,
. Sheet 1
j . . *
Huwrow & Wzz.I.zAxs
.
.
vot caer ma sea.cv p.o. so. isas
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n. , . 4.n*.'" ../. * " . . . . * .
- -w .
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""*"". .. September 29, 1986 n a - .. ..... .
. . ., n,. . . . .
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. . . .
. . _
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.
. ..) - _ ,
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. .... a3 r
..g ,-
Richard J. Ishnleuter, Esq. '
l Deputy.special Counsel to the Governor ; . . -
.
State of New York ,
-
By Telecopier ...~
/ Executive Chamber -
.
j Albany, New York 12224, ..
..
LILCO QA Audit
"
*
Dear Ricks -
On Friday, September 26, LILCO made a public statement con-
cerning the LILCO Quality Assurance audit that was the subject of
, your September 18 letter. The company noted that as a matter of
policy, LILCO's organization includes quality assurance and '
auditing teams which regularly conduct reviews and evaluations of
personnel, procedures and operations. LILCO insists on having a
highly skilled and well-trained work force and constantly strives
to improve the Company's performance. The internal quality
,
.
assurance and auditing reviews, such as the audit of training ~
activities requested by your letter, are part of LILCO's ongoing
effort to achieve self-imposed high standards of excellence.
Because the report about which you have inquired involved
Shoreham, we naturally shared the results with the NRC, the
agency responsible for reviewing nuclear operational and safety -
matters.
~
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<**
-
'f APPENDId
H UNTON & WII.I.IAM S ,
Sheet 2j
.
.h :
Richard J. Sahnleuter, Esq. ;
'
September 29, 1986
Page 2 <
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As a matter of policy, LILCO does not normally provide
information on internal reviews to outside groups. ,But since New
York State has expressed an interest in this particular report,
.... the company announced on Friday that it would be happy to meet
..
,
with state representatives to review 'the findings of the audit '
f. team. We think the meeting would be most productive if state
-
^^ employees actively involved with other operating nuclear power .
plants in New York State are in attendan~ce. Please let me know
at your earliest convenience who will participate in the review .
.
for the state so we can arrange a mutually convenient time. ,
-
_
-
_
sincerely yours,
, 91/730 Donald P. Irwin
.
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,
APPENDIX F
. .
9 % -)@b
** * ' STATE or New Yonx
Executive CHAMerR '
FABIAN PALOMINO '
s w e.un m m.own.,
,
_
September 30, 1986
.
By Telecopier -
Donald P. Irwin, Esq. ..
Hunton & Williams
P.O. Box 1535
Richmond, Virginia 23212 -
Dear Don: _. . *
1986. This is in response to your letter to me of September 29,
'
Unfortunately, your lette'r misses the point. The State of
New York simply wants a copy of the same radiochemistry training
and qualifications audit report which LILCO selectively provided
i to the NRC Staff, another party in the Shoreham licensing
.
proceedings, several months ago. We are not interested in
listening to
receiving an oral
a copy presentation
of the by LILCO
actual, relevant in lieu of immediately
documents.
If I do not receive these documents in hand by 2:00 p.m. On
October 1,1986, the State of New York will ask the Commission to
compel LILCO to produce the requested documents forthwith.
.
Ver ruly ours
y /l 0 E
j) y ft- Oh* kV
.
" Richard J J euter
- Deputy Special Counsel e
to the Governor
.
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:
May 21, 1986 NRB-C-86-40
J. L. Smith
W. E. Steiger
E. J. Youngling
B. R. McCaffrey
K. R. Lewis
V. L. Elefante
Shoreham Training and Qualification Audit
Reference:
NRB Audit NB-86-01 Personnel Qualification &
Training of Plant Staff Personnel
QA Audit QS-86-03 Corporate Nuclear
Training-Support Departments
The above referenced audits were conducted concurrently to
assure that an overall assessment of traininE and qualification
activities was accomplished. The audits, for the purpose of
this report, were treated as a single audit. The audit was
conducted by a combined internal and external team of 12
i
personnel which included specialists in qualification and
training from Cygna Energy Corporation and Operations Analysis
Corporation (OAC). The audit preparation and conduct required
in excess of 1000 manhours to complete.
The audit indicated proper qualification of personnel with no
indication of problems similar to those which recently existed
in the radiochemistry area. In addition, LILCO has established
the position of Director of Training, responsible for all
nuclear and fossil training activities reporting directly to the
Executive Vice President.
The audit resulted in 35 Audit Findings and 19 Observations.
Areas of concern spanned program / procedure development and
implementation through record keeping. As a result of the scope
of training and qualification activities, several Audit Findings
will require a joint Plant Staff-Training response. All audit
responses must include the proposed corrective and preventive
actions, as well as the actual or estimated completion dates for
these actions. In addition, it is requested that written
responses be provided to Observations 2 and 16 by Mr. J.L. Smith
and Observation 13 by Mr. W.E. Steiger.
It is strongly recommended that management attention be applied
to the training and qualification area. This is to assure
- timely resolution of the Audit Findings and Observations, as
well as, elimin~ation of their root causes.
___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ . _
.
NRB-C-86-40
g , Page -2-
-
:
Please submit all responses to Mr. J. A. Notaro, Quality
Assurance Department Manager, by June 13, 1986.
(
l
4 N}
Pg Af Kubinak, Cglirman
Nudear Review Board
JAN/rg
Attachment
cc: Messrs. J. W. Dye, Jr. H. Chau
J. D. Leonard, Jr. W. J. Tunney
J. A. Notaro L. F. Britt
L. J. Calone J. P. Morin
E. B. Perino R. Cutmann
R. J. Cardella J. J. Jones
J. A. Scalice C. A. Daverio
( D. D. Terry M. C. DeGennaro
J. F. Schmitt A. R. Muller
L. W. Levin C. K. Seaman
R. A. Loper S. J. Stratis
R. M. Kascsak Ms. P. Sitler
J. A. Rigert Q41.1.13
E. P. Stergakos NRB File
i
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[[M9 QUALITY ASSURANCE DEPARTMENT
NB-86-01
-
. AUDIT REPORT AUDIT NO. QS-86-0.3
PAGE I OF 35
AUDIT OF: Personnel Qualifications & Training of DISTRIBUTION
Plant Staff and Support Organizations g
-0
LOCATION: Shoreham Nuclear Power 'Itation (SNPS) fett
AUDIT DATES: April 7-16, 1986
AUDITORS: See Attachment 1
.I Purpose
The purpose of this audit was to examine the overall status
and performance of LILCO Personnel Qualification and
Training of Shoreham plant and appropriate support
organization personnel. Qualification and training
requirements, including review and evaluation thereof, have
been established in the Final Safety Analysis Report (FSAR),
Technical Specifications, NOC Policies, NRB Charter and the
LILCO Quality Assurance Program.
II. Scope
Two audits were conducted simultaneously to fully address
Personnel Qualification and Training. Specifically, the two
audits conducted were:
1. NRB Audit NB-86-01: Personnel Qualification &
Training of Plant Staff Personnel
2. QA Audit QS-86-03: Corporate Nuclear Training -
Support Departments
This report reflects the results of both audits as a
single, overall evaluation.
l
Discussions were conducted with Department / Division
Managers and Section Heads who have responsibilities for
training, qualification and certification of personnel.
Review and performance based evaluation of programmatic
commitment, development and implementation was conducted at
all organizational levels,
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NB-86-01
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AUDIT REPORT AUDIT NO. QS-86-03 _
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Sixty five personal interviews were conducted by the audit
team to validate, confirm and enhance the audit results.
Records required by programs, policies, procedures and/or
instructions were examined. Findings from previous audits
were reviewed to assess performance and effectiveness of
previous corrective actions, and to further evaluate
unfavorable trends identified in the 1985 fourth quarter QA
Trend Analysis Report.
The following program elements were audited for managerial,
professional / technical, technician, mechanics, operators and
consultant personnel for which qualification and training
requirements are specified:
*
Management Controls
*
Personnel Selection
*
*
Qualifications
Training (Programs, Policies, Procedures, Requirements,
Schedules, Performance)
*
Licensing
*
Certification
*
Retraining
*
Relicensing
*
Recertification
*
Documentation and Records
*
Facilities .
In addition, the audit scope included investigations made
to determine compliance with recent management directives;
,
specifically, VPN086-48, " Training and Qualification
l
Records" dated 3/3/86 from J. D. Leonard, Jr., Vice
President - Nuclear Operations and PM DIR 86-003, " Plant
Manager Directive for Improving Administrative Controls Over
Personnel Training and Qualification Programs" dated 3/3/86
from W. E. Steiger, Plant Manager.
Plant Staff (NB-86-01)
I - i
The specific sections / disciplines and training programs for
l '
which these elements were audited included Licensed
Operators, Non-licensed Operators, Reactor Engineering,
Shift Technical Advisors, Compliance, Instrumentation and
Control, Computer, Radiochemistry, Health Physics, Radvaste,
Maintenance (Mechanical, Electrical and Welding),
Hodification Engineering, Plant Management, Technical Staff
and General Employee Training.
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AUDIT REPORT AUDIT NO. QS-8 6-03
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Support Organization (QS-86-03)
The specific support organizations for which training
programs were audited to the applicable elements included
the Nuclear Operations Support, Nuclear Engineering,
Purchasing, General Services (Production Training Center)
and Information Systems Departments.
III Audit Conclusion
Based on a review of educational and experience
backgrounds, individuals assigned to, or in support of, the
Shoreham Nuclear Power Station are considered to be
competent, knowledgeable and appropriately qualified.
However, important elements of the qualification and
training program as they apply to Plant Staff and support
organizations are not effectively implemented.
The principal areas of concern indicated by the audit
q results are:
1. Program
Although a " draft" Administrative Training Manual does
exist, without a formally " approved" program document
there exists a lack of uniform implementation of ,
requirements identified in NOC Policy 21, the FSAR, ANSI
Standards, etc.
2. Procedures
a) There are no programs or procedures for training of
Management / Supervisory personnel or Engineers in Training
(EITs). In addition, no procedure clearly defines
requalification requirements for non-licensed personnel,
b) Procedures have not been issued by the Nuclear
Training Division for implementation of administrative
controls for training.
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. 3. Records
Training records are not in conformance with related
i procedures. In general, the quality of training records
is poor, specific information is difficult to retrieve
and there is a lack of consistency between organizations
regarding the type of training records developed.
However, it should be noted that various organizations
did take immediate action to correct specific
deficiencies identified during the audit.
4 Qualifications
Individuals were determined to be qualified although
programmatic deficiencies were identified.
5. Training
Except for training such as General Employee Training
(GET), the responsibility for personnel training is
divided between various user organizations and the
Training Division. The separation of training
responsibilities is not understood and this has
contributed to the confusion in definition, records,
qualification, training schedules, etc.
6. Management Controls
The absence of systematic controls and lack of effective
implementation in conjunction with identified
deficiencies and inconsistencies, indicate a previous
lack of management attention to training and
qualification. This situation can be improved by
establishing a clear definition of responsibilities, and
!
providing an effective management information system
which will provide the tools necessary for control and
follow up.
7. Facilities / Resources
d) It appears that the resources (instructors and
trainee time) allocated to training are not
commensurate with the existing training needs for
non-licensed programs such as those for equipment
operators, radwaste, technicians, maintenance and
engineering personnel.
.
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b) The training facilities themselves are marginal.
There is no evidence of effective noise, temperature,
or lighting control for the present on-site training
facilities.
8. Attitude of Users
There was a perceived organizational attitude that
qualification and training requirements are adequate when
minimum regulatory requirements are achieved.
9. Interviews
Sixty-five individuals, (29 Plant Staff and 36 Support)
were selected at random and interviewed by the audit
team. The sample included a cross section of Department
Managers, Division Managers, Section Heads,
Professional / Technical personnel, technicians, mechanics
and operators.
t-
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The general consensus among those interviewed was:
a) There exists a lack of clear direction associated
with the training program effort.
b) Specific guidelines are needed for requalification
training.
c) Additional training is needed for plant specific
systems.
d) Licensed personnel receive special training
attention,
e) Non-licensed personnel would like more training.
f) There is a weakness in cooperation between
departments.
g) There is a lack of effective communication between
training and the various user organizations.
h) Prcfessional/ Technical personnel would like more
l specific technical training.
1) Managers would like the Company to institute an
effective Corporate Management training program.
IV Conduct of Audit
i
The audit plans and checklists prepared for this audit were
discussed at a pre-audit conference on April 7, 1986.
. Participants in that conference, identified on Attachment 1 l of this report, were advised of the purpose and scope of the
i
audit.
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.
The audit was conducted in accordance with the audit
checklists. Specific conditions observed as a result of
discussions with cognizant personnel and reviews of
documentation are identified on these checklists which are
included in Attachment 2.
Daily meetings were held by the audit team with
representatives of the audited organizations to discuss
potential Audit Findings and Observations.
Audit conclusions, findings, and observations were
discussed with key LILCO personnel in a post-audit
conference on April 15, 1986. Participants in that
conference are identified on Attachment 1. Additional
post-audit discussions were held with Plant and Department
Managers on April 15 and 16, 1986.
V Findings
(. There were 35 Audit Findings identified, (i.e. Audit
Findings #1 to #15 identified as part of Audit NB-86-01 and
#16 to #35 identified as part of Audit QS-86-03). These
Audit Findings require corrective / preventive actions by the .
responsible organizations. Audit Response Forms are
provided in Attachment 3 of this report.
There were 19 Observations which include comments and/or
suggestions from the Audit Team (i.e. Observations #1 to #16
identified as part of Audit NB-86-01 and #17 to #19
identified as part of Audit QS-86-03). Although
Observations normally do not require formal responses, it is
requested that responses be provided for Observations No. 2,
13 and 16.
Audit Finding No. I
QA Manual, Section 2, para. 2.3.4, requires that programs
be established for indoctrination, training and, if
appropriate, certification of personnel performing or
verifying quality-affecting activities. Further, Section
17, para. 17.3.2b, requires that measures be established to
assure that sufficient records are generated and maintained
to furnish evidence of the satisfactory comp.letion of
quality-affecting activities. Such records include evidence
of training and qualification of personnel.
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1. SP 21.006.01, " Station Operator Training and
Qualification Program", Rev 6, para. 8.1.1.4, requires
that qualification in the turbine building, reactor
building, control building and yard shall be in
accordance with the SNPS Operator Qualification Guide as
supplemented by the SNPS Equipment Qualification Guide.
Paragraph 8.1.3.3 requires, for each replacement
Equipment Operator (EO), completion of the EO
Qualification Guide for a given area prior to being
recommended for qualification in any area and
documentation on the Qualification Forms in Appendix
12.2.
Contrary to the above requirements, the following
deficiencies were noted in the training records of persons
assigned to work as Equipment Operators:
a) A significant number of pages in each of 4 EO
Qualification Guides were not signed by a Watch
Engineer,
b) In 19 instances the evaluator had not signed items
of the EO Equipment Qualification Guides.
c) In 5 instances an item was missing from the
individuals records.
d) In 133 instances the signature of the training
section representative was missing.
l !
e) Generally, on-the-j ob training is not specifically
performed or documented.
(Reference Checklist A-16 and 19(b and c))
2. The area qualification certificates for 6 operators
licensed in 1985 indicate that they were qualified in
the yard, turbine building, reactor building, control
building and the radwaste building.
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Contrary to the requirements of SP 21.006.01, Rev. 5,
para. 8.2.3.1, there was no objective evidence of such
qualifications having been completed, i.e., there were
no completed License Qualification Guides for any area
other than the reactor building section of the
Qualification Guide.
(Reference Checklist A-8(b))
3. Forty-four Health Physics work activities were
reviewed. The following four items were found to be
indicative of the need for further documentation due to
the lack of obj ec tive evidence that the subject work was
covered by supervision:
a) Instrumentation Calibration work performed on
12/5/85 by a technician who became qualified on
2/24/86.
b) Internal / External Dosimitry work performed on
4/20/85 by a technician who became qualified on
7/8/85.
c) Respiratory Protection work performed on 12/18/85
by a technician whose certification for that work
expired on 11/17/85. ,
d) Instrument calibration work performed on 2/22/86 by
a technician who became qualified on 2/24/86.
(Reference Checklist D-4 and 13)
Audit Finding No. 2
SP41.Oll.01, "I6C Technician Qualification Program", para.
8.2.4 and SP31.001.01, " Training and Qualification of
Maintenance Personnel", para. 8.2.4, allow individuals to be
qualified by one of several ways such as past experience,
vendor supplied training or on-the-job training. The
procedures require documentation to support this
qualification. Documentation includes either detailed
resumes, vendor supplied documentation, or on-t he-j ob
training records (SPF41.011.01 and SPF31.001.01) which
clearly identify acceptance criteria.
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Contrary to the above, personnel in the I6C Section and the
Maintenance Section were qualified without adequate
supporting documentation. The SPF forms, required by
procedures, were not fully completed; there was no objective
evidence of completed vendor supplied training courses, and
the resume / job applications did not adequately reflect past
experience.
(Reference Checklists C-2, 3(d) and E-2(c))
Audit Finding No. 3
SP 12.003.01, " Personnel Qualifications and
Responsibilities", requires certification of personnel for
their assigned positions. PM DIR 86-003, dated 3/3/86,
requires such certification prior to assignment.
Contrary to these requirements, there were deficiencies
noted in the certification of individuals for their
positions, as follows:
a) There were no Engineer position certifications for 2
Performance Engineers.
b) The certification of a Radwaste Operator was changed by
lining out Radwaste Operator and writing in " Nuclear
Staff Specialist (Radwaste)". This change was initialed
and dated by someone who was not authorized to certify
the operator.
c) The certification dated 3/27/85 for 1 radwaste operator
shows his position as " equipment operator". This
certification must be updated to show his current
position.
d) There is no certificate of completion in i HP
Technician's training file for Phase III, BWR Training.
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e) In addition, SP 41.011.01, "I&C Technician
Qualification Program", para. 5.1, specifies that an I&C
technician shall be a high school graduate or equivalent
and have three years of experience as an I&C
technician. One of the three years may be satisfied by
related technical training. Contrary to this, of 6
folders reviewed for I&C technicians, 3 did not contain
objective evidence of a high school diploma or
equivalent to support their position certification.
(Reference Checklists B-15, C-3(a), D-2, 4 and E-2(a))
Audit Finding No. 4
SP 21.006.01, " Station Operator Training and Qualification
Program", Rev 5, para. 8.2.3.1, provided for waiving
training requirements for Equipment Operators, but did not
provide for waiving training requirements for licensed
operators.
i.
Contrary to this, the Area Qualification certificates for 6
operators licensed in 1985 contained the waiver " Qualified
by virtue of completion of the cold license training
program".
(Reference Checklist A-8(a))
l Audit Finding No. 5
In PM DIR 86-003 dated 3/3/86, items I and 3 require that:
1) Section Heads shall develop for all operators,
mechanics, technicians and clerks a qualification
matrix. This matrix shall be based upon the Section's
Training and Qualification Procedure, cross reference
the individual to the area of qualification and list the
date qualificatien expires.
3) Training and Qualification matrix charts shall be
posted in the foreman's offices, watch engineer's/ watch
supervisor's office and shop areas (i.e., machine shop,
I&C shop, HP access area, M&TE shop, radiochemistry
laboratory, control room, etc.) so as to be easily
available for use by both the first line supervisor and
the individual worker.
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Contrary to the above:
a) Matrices for Maintenance Division (I6C and Maintenance
Sections), did not include the qualification expiration
date.
b) The Matrix for the Maintenance Section was not posted
in the watch engineer's/ watch supervisor's office and
shop area as required,
c) Matrices for the I6C, Maintenance and HP Sections
contained errors.
(Reference Checklists D-1(j2), 13, C-4, E-2(c) and C-1)
Audit Finding No. 6
SP 12.014.02, " Training and Qualification Folder", Revision
4, requires that individual training and qualification
folders for licensed personnel (SRO and RO) contain drill
participation documentation, completed requalification
requirements, and training performance evaluations (drill
scenarios). For non-licensed personnel, the training record
must include documentation of all training received at SNPS,
and performance evaluations.
Contrary to the above, the drill participation
documentation, completed requalification requirements and
l training performance evaluations (drill scenarios) were not l maintained in the individual training and qualification '
folders but were maintained in the requalification program
files. -
In addition, training as required by NRC Bulletin 79-19,
" Packaging of Low-Level Radioactive Waste for Transport and
Burial", was not included in individual Radwaste Operator
training folders; evidence of BWR Chemistry training
, required by FSAR Section 13.2, para. 13.2.1.2.2.1, was not l
in the HP supervisor's folder; and the training requirements
of FSAR Section 13.1, para. 13.1.3.10, for the HP Engineer,
were not clearly correlated with his experience record.
(Reference Checklists A-9(d, e, f), D-1(e3), 2, 4, 5, 7(i),
7 (j ) , 8 and E-4)
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Audit Finding No. 7
SP 12.014.02, Appendix 12.2, requires that the Training
Folder include a resume or employment application.
VPN086-48, dated 3/3/86, requires qualification and training
records to be updated and maintained.
Contrary to these requirements, training folders did not
have current resumes, as typified by the following:
a) Resumes for 4 out of 6 operations personnel reviewed
were not up to date in that they did not reflect the
individuals' present job assignments.
b) Personnel Folder of an Assistant Engineer in I&C
(Engineer in Training) did not contain a resume or
employment application.
c) Resumes for 3 out of 3 Radwaste Operators reviewed had
out of date or undated resumes in their training files.
d) Resumes for 2 Radiochemistry personnel were out of date
or were not consistent with the position certification.
e) Resume for 1 Engineer, Compliance, was not in the
training file.
(Reference Checklists A-9(a), B-16, C-3(f) and D-4, 7(g),
8)
Audit Finding No. 8
SP 12.003.01, para. 8.1.7, states in part "... each
designated individual shall be administered an eye
examination on a yearly basis. ...".
Contrary to the above, there were deficiencies in the
records as follows:
a) Personnel were recertified prior to receipt of the eye
examination documentation required for recertification.
b) Personnel certification records incorrectly indicated
that recertification was performed on the date of their
eye examination.
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[[S[9 OUALITY ASSURANCE DEPARTMENT
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AUDIT REPORT AUDIT NO. QS-86-03 i
PAGE I3 OF 35
. c) A review of qualification and training folders for I&C,
Computer, Maintenance, and Radiochemistry Section
personnel revealed that the length of time from the
"Date of Visual Examination" to supervisor sign-off was
inappropriate and varied significantly.
d) One mechanic's eye examination and certification lapsed
in March of 1986.
(Reference Checklists C-3(b). D-4, 8, 12, and E-5, 10)
Audit Finding No. 9
ANSI N18.1-1971, " Selection and Training of Nuclear Power
Plant Personnel", Section 5.3, states "A suitable training
program shall be established for managers, supervisors,
professional, operators, technicians, and repairmen to
properly prepare them for their assignments; ...".
Contrary to the above:
a) A training program for management, supervisory and
technical / professional personnel was not available.
b) Individuals were assigned as " Engineer in Training"
without the benefit of a formal training program which
would clearly identify responsibility, authority and
acceptance criteria. Additionally this program would
assure that safety related tasks are accomplished under
the supervision of a qualified individual.
(Reference Checklists B-6(1), 7(c), 14, 18(c), 19(c), 20,
C-1(a-d), D-6, 7(g), 8, E-1 and F-10)
Audit Finding No. 10
The QA Manual, Section 5, requires that activities
affecting quality be accomplished in accordance with
documented instructions and procedures.
Contrary to this requirement, procedures related to
training were deficient in that they lacked information or
contained inaccurate information which precluded effective
accomplishment of training activities; this was illustrated
by the following:
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. a) SP 12.014.04, " Training Responsibilities", defines
responsibilities for training that are now the
responsibility of the Nuclear Training Division per NOC
Policy 21, para. 4.2.5(A). Since SP12.014.04 describes
responsibilities that no longer apply to the Plant
Staff, the procedure should be deleted.
b) SP 12.014.02, " Training Supervisor" should be " Training
Administrator",
c) SP 12.014.06, " Operations Training Specialist" should
be " Operations Training Supervisor".
d) SP 12.014.07, " Nuclear Plant Training Supervisor"
should be " Operations Training Supervisor".
e) SP 41.011.01, SP 31.001.01, SP 21.006.01 and SP
C1.0ll.01 all reference or specify compliance with SP
12.014.01. However, SP 12.014.01 was deleted without
any action to revise the aforementioned procedures (e.g.
delete outdated references, incorporate appropriate
requirements for final status of training records).
f) SP31.001.01, para. 8.2.7, requires the Maintenance
Engineer to specify training requirements for Storeroom
personnel. However, the Maintenance Engineer no longer
identifies training requirements for Storeroom personnel
because they were transferred to the Nuclear Operations
Support Department. The procedure should therefore be
revised to reflect this organizational change.
(Reference Checklists A-10, 15(c, d, e, f), B-19(b), C-8
and E-7)
Audit Finding No. 11
FSAR Section 13.2, para. 13.2.1.2.1.3, states
"Requalification training for I&C personnel will consist of
refresher training associated with the GET and individual
study" (as described in subparagraphs 1-3). The paragraph
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further requires " supervisory review of the individual study
program".
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Contrary to the above, no objective evidence could be found
in the Station Procedures that an " individual study program"
exists.
(Reference Checklist C-3(e))
Audit Finding No. 12
SP 41.011.01 and SP C1.0ll.01, para. 8.3.1 through 8.3.6,
require personnel to participate in on going Refresher
Training. The refresher training is to be administered via
classroom training, tailboard sessions and the Required
Reading Program.
Contrary to the above, there was no objective evidence that
"tailboard sessions" were being conducted by the I&C and
Computer sections as required.
(Reference Checklist C-3(e))
Audit Finding No. 13
SP 41.011.01, para. 8.2.2, states " Technicians shall be
qualified on safety related systems and equipment listed in
Appendix 12.1 in order to independently perform testing or
troubleshooting associated with the system or equipment".
SP 41.011.01, para. 8.2.3, states "A technician qualified
to work on the equipment listed in Appendix 12.1 may be
,
assigned work on that equipment independent of the system-in
i which the equipment is located". I '
SP 41.011.01, para. 8.4.1, states "A record chall be
maintained for each technician indicating qualification
status, (i.e. SPF 41.011.01-1)". A note further states
l
"This record shall indicate the basis used for qualifying
i
the technician and shall be signed by I&C supervision or by
j the Training Section".
Contrary to the above, Appendix 12.1 (SPF 41.011.01-1) was
not being utilized as required in that:
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a) The clerical staff of the Nuclear Training Division was
incorrectly signing "for" on the qualification summary,
b) The qualification summaries for some individuals were
incorrect due to clerical errors.
(Reference Checklist C-3(d))
Audit Finding No. 14
NOC Policy 21, para. 4.1.4, requires that each department
' define, maintain current, and document the training needs of
it's organization.
Contrary to this requirement, SP21.006.01, Rev. 7, does not
identify, for Radwaste Operators, the frequency for
continuing training and retraining or how this is e
documented; does not contain provisions on relieving persons
from duty following an unsatisfactory evaluation of
proficiency; or identify the use of the annual evaluation as
the basis for training or retraining. In addition, the
procedure does not specifically address training needs for
Radwaste Operators who were hired before January 1, 1986.
(Note that SP 21.006.01, Rev 7, applies to persons hired
after 1/1/86.)
(Reference Checklist D-1(h3), 1(j 3), 1(k3) and 4)
Audit Finding No. 15
SP 12.014.02, " Training and Qualification Folder", para.
8.2.2, requires training performance evaluations to be
maintained in the training and qualification folders for
personnel not required to be licensed (Appendix 12.2, item
3).
Contrary to the above, personnel training and qualification
folders do not contain training performance evaluations for
the Maintenance, Modification, I&C, and Computer Section
personnel. In addition, the procedure does not define
" training performance evaluation."
(Reference Checklist C-2 and E-3)
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Audit Finding No. 16
NOSD Procedure 17 " Training of NOSD Personnel", para.
6.1.1, states in part, "The Training needs of an individual
are to be based upon an evaluation of the maj or tasks the
individual is expected to perform for the position he is
assigned...". Further, para. 6.1.3, states "The task list
for each existing position shall be submitted to the Nuclear
Training Division".
Contrary to the above, no obj ective evidence was found that
the Nuclear Emergency Preparedness Division had completed
the required task lists for each individual, and transmitted
them to the Nuclear Training Division.
Prior to the completion of the audit, the Nuclear Emergency
Preparedness Division developed task lists for all personnel
and transmitted them to the Nuclear Training Division. This
Audit Finding is therefore closed.
(Reference QS-86-03 Checklist Attributes 18, 19, 33)
Audit Finding No. 17
Memorandum VPN086-48, " Training and Qualification Records",
issued by J.D. Leonard on 3/3/86, required all departments
within the Office of Nuclear Operations to bring their
training records immediately up to date, and to transmit
l them to the Nuclear Training Division for inclusion in each
individuals file.
Contrary to the above, it was noted during the audit that
records for some individuals in the Nuclear Services,
Nuclear Emergency Preparedness, Nuclear Financial Services,
and the Nuclear Contracts and Control Divisions of NOSD had
, '
not been transmitted to the Nuclear Training Division as
required.
Prior to the completion of the audit, the cited records
, were assembled by the affected divisions and transmitted to l the Nuclear Training Division. This Audit Finding is l therefore closed. l (Reference QS-86-03 Checklist Attributes 18, 21, 28, 34) ! l
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OUALITY ASSURANCE DEPARTMENT
NB-86-01
AUDIT REPORT AUDIT NO. QS-86-03
PAGE 18 OF 35
Audit Finding No. 18
QA Manual, Section 17, para. 17.3.2b, states in part, ,
" Measures shall be established to assure that sufficient
records are generated and maintained to furnish evidence of
the satisfactory completion of quality-affecting
activities. Such records include... evidence of training and
qualification of personnel...".
NOSD Procedure 17 "Trr.ining of NOSD Personnel", para. 5.2,
states " Division Managers are responsible for the
determination of training requirements for each position in
their division and the training needs of the individuals
assigned to a position. These shall include retraining
requirements".
Contrary to the above, there is no objective evidence on
the NOSD training needs matrices to show that the division
managers have made these determinations. Moreover, there is
no method or provision stated in NOSD-17, or included on the
needs matrix form itself, for the managers to sign / initial
and date in order to substantiate the record and show
evidence of their actions.
(Reference QS-86-03 Checklist Attributes 17, 18)
/.u d i t Finding No. 19
NOSD Procedure 17, " Training of NOSD Personnel", para. 5.3,
states "The Nuclear Training Division Manager ensures the
adequacy of training, maintenance of training records and
overall coordination of all training of NOSD personnel".
Contrary to the above, 11 discrepancies were identified as
a result of comparing the NOSD Procedure Program Training
File information to the information contained in the
individual training folders for 6 of 12 Nuclear Licensing
and Regulatory Affairs Division personnel reviewed. These
discrepancies involved incorrect dates of attendance and/or
training not received.
Prior to the completion of the audit, the cited
discrepancies were corrected by the Nuclear Training
Division. This Audit Finding is therefore closed.
(Reference QS-86-03 Checklist Attributes 18, 28, 33)
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QUALITY ASSURANCE DEPARTMENT
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NB-86-01
AUDIT REPORT AUDIT NO. Qs-86-03 ,
PAGE 19 OF 35
Audit Finding No. 20
Purchasirg Department Procedure QP-3, " Indoctrination and
Training of Purchasing Department Personnel", para. 4.2,
states "The Manager, Purchasing Department, will establish,
in writing, the minimum indoctrination and training
requirements". Paragraph 4.4 states "The Purchasing
Department Training Coordinator shall assure that
individuals meet the established requirement and shall
notify the Manager, Nuclear Procurement Division, of the
completion of indoctrination and training of individual
personnel".
Contrary to the above, there was no objective evidence that
required personnel had received training in accordance with
the requirements specified in the " Purchasing Department
Buyer Training Program" issued in August, 1985.
Additionally, there was no objective evidence that the
Training Coordinator had notified the Manager, Nuclear
f. Procurement Division of the completion of indoctrination and
training of individual personnel.
Prior to the completion of the audit, the Purchasing
Department Training Coordinator reviewed the status of
personnel training, identified the individuals requiring
training and initiated the Buyer Training Program. In
addition, by memorandum dated 4/14/86 the Training
Coordinator advised the Nuclear Procurement Division Manager
of the completion of indoctrination and training of
individual personnel. This Audit Finding is therefore
closed.
(Reference QS-86-03 Checklist Attributes 29a, 32a)
Audit Finding No. 21
Purchasing Department Procedure QP-3, " Indoctrination and
Training of Purchasing Department Personnel", para. 4.8,
states "The Purchasing Department Training Coordinator shall
on a quarterly basis, report the progress of the
department's training to che Corporate Nuclear Training
Coordinator".
Contrary to the above, there was no objective evidence that
progress reports for the 3rd or 4th quarters of 1985, or the
1st quarter of 1986 had been submitted.
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AUDIT REPORT AUDIT NO. QS-86-03
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PAGE OF
. Prior to the completion of the audit, the required progress
reports were transmitted to the Nuclear Training Division.
This Audit Finding is therefore closed.
(Reference QS-86-03 Checklist Attributes 3a, 31)
Audit Finding No. 22
NOSD Procedure 17, para. 6.4.1.11, requires Training
Program Files to contain a log which records the dates and
times for each occasion a Training Program is conducted.
Contrary to this requirement, no logs were found in any of
the NOSD Procedure Training Program Files for NOSD
Procedures 3, 4, 5, 6, 6.1, 6.2, 6.3, 7, 11, 24, 25, 27, 29,
29.1, 29.2, 29.3, 30, 30.1 and 35.
Prior to the completion of the audit, a log was developed
by the Nuclear Training Division to address the above
requirements. This Audit Finding is therefore closed.
(Reference QS-86-03 Checklist Attributes 18, 26, 33)
Audit Finding No. 23
NOSD Procedure 17, para. 6.4.1.lg, requires a Grade
Reporting Sheet in each Training Program File.
l Contrary to this requirement, Grade Reporting Sheets were
not found in the NOSD Procedure Training Program File for
NOSD Procedures 25, 27, 29, 29.1, 29.2, 29.3, 30 and 35.
Additionally, Grade Reporting Sheets for NOSD Procedure 4
and 6.3 were incomplete.
l l Prior to the completion of the audit, the Nuclear Training
Division corrected the Training Program Files to include
completed Grade Reporting Sheets. This Audit Finding is -
therefore closed.
(Reference QS-86-03 Checklist Attributes 18, 26, 33)
.
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OUALITY ASSURANCE DEPARTMENT
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AUDIT REPORT AUDIT NO. QS-86-03
PAGE 21
OF 35
Audit Finding No. 24
NOC Policy 21, " Nuclear Training", para. 4.2.6.1, requires
nuclear and non-nuclear departments to define annual
training goals and objectives in accordance with the
training standards, and to provide initial and quarterly
progress status to the Nuclear Training Division
Contrary to the above, NOSD Procedure 17 does not identify
requirements for quarterly status reporting, and NOSD has
not developed annual training goals and objectives or
quarterly reports on the progress of training as required by
this NOC Policy.
(Reference QS-86-03 Checklist Attributes 3a, 16)
Audit Finding No. 25
NOSD Procedure 17, para. 6.4.1.1, requires Training Program
Files to include a log which records the dates and times the
training program was conducted, a grade reporting sheet, a
copy of the written completion e xami n a t ion (s) , a topical
outline and the lesson plan.
Contrary to the above;
a) The Instructor Training Program File had no log sheet,
grade reporting sheet, or examinations.
b) The Storeroom Personnel Training Program File had no
lesson plan, outline, or log sheet,
c) A Training Program File for onsite/offsite Emergency
Preparedness Administration training had not been
assembled.
(Reference QS-86-03 Checklist Attributes 18, 26, 33)
Audit Finding No. 26
NOSD Procedure 17, para. 6.3.2, requires classroom training
to be conducted using lesson plans approved by the Nuclear
Training Division and the cognizant section supervisor.
.
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Contrary to the above, Training Program Files for the
Instructor Training Program and Storeroom Personnel Training
did not have approved Lesson Plans. In addition, the Lesson
Plan for NOSD Procedure 11 training had not been approved by
the Nuclear Training Division prior to training being given.
(Reference QS-86-03 Checklist Attributes 18, 23, 24, 26, 33)
Audit Finding No. 27
NOSD Policy 21, para. 4.2.5, requires the Nuclear Training
Division to provide training, establish and maintain INPO
accreditation, coordinate training activities, develop
training standards and perform other activities associated
with training.
Contrary to the above policy, the Nuclear Training Division
had not issued an administrative training manual or Nuclear
Training Division procedures governing the implementation of
NOC Policy req .rements.
(Reference QS-86-03 Checklist Attributes 2, 35)
Audit Finding No. 26
EPIP-5-4, section 2.0, states that the Nuclear Support
Training Supervisor is responsible for detailed
implementation of the Emergency Preparedness Training
Program, ensuring proper documentation, and approval of
lesson plans and examinations.
Contrary to the above, the Nuclear Training Division files
have either incomplete and/or inaccurate information
concerning Emergency Preparedness Training. This is due to
the fact that the Nuclear Emergency Preparedness Division is
presently performing these activities and not sending
completed information to the Nuclear Training Division.
(Reference QS-86-03 Checklist Attribute 27)
_._ _ _ _ _ _
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Audit Finding No. 29
Memorandum VPN085-183, J.D. Leonard to J.L. Smith, dated
7/26/85, directed that the " Corporate Nuclear Training
Administrative Manual" be withdrawn from use.
PD-SD-Il Rev 0, dated 2/28/84, " Corporate Nuclear
Training", para. 5.2, states "The Corporate Nuclear Training
Administrative Manual shall serve as the complete
description of the Corporate Nuclear Training Program".
Because the Corporate Nuclear Training Administrative
Manual was withdrawn from use as a result of VPN085-183,
PD-SD-Il and it's associated implementing procedures
(SD-II-01 to SD-11-10) are obsolete and should be deleted
from the Nuclear Organization Management Control Program
Manual.
(Reference QS-86-03 Checklist Attribute 2)
Audit Finding No. 30
As referenced in Audit Finding 29, the former " Corporate
Nuclear Training Administrative Manual" was withdrawn from
use. Subsequently, by memorandum from the Nuclear Support
Training Supervisor on 7/31/85 (NTS-85-0192), Department
Managers were advised to utilize NOC Policy 21 until a
revised Nuclear Corporate Training Administrative Manual was
issued.
Contrary to the above, NED Procedure 1.03, Rev 1, 8/10/84,
" Indoctrination and Training of NED Personnel", was not
revised to delete references and actions required by the
former " Corporate Nuclear Training Administrative Manual"
and include the requirements of NOC Policy 21 Rev 1.
Prior to the completion of the audit, NED completed it's
revision to NED Procedure 1.03 to address this finding. Rev
2 was approved 4/16/85. This Audit Finding is therefore-
closed.
(Reference QS-86-03 Checklist Attribute 3b, 33)
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PAGE 24 op 35
Audit Finding No. 31
NED 1.03, Rev 1, 8/10/84, defined a Position Standard in
para. 4.1 as a training document that described the overall
qualifications, levels of knowledge, experience and skills
required for a specific position. Further in para. 6.2 it
required that training requirements be determined for each
individual from a training needs assessment study. This
study was to compare current employee qualifications to the
corresponding position standard.
Contrary to the above, and based on a review of the
training folders of 20 NED individuals, the following was
noted:
a) The Training Needs Matrix for 5 individuals was
completed prior to the Position Standard being
developed.
-
b) The Position Standard, Training Needs Matrix and/or
Training History Record for 7 individuals did not
reflect their current position within NED.
Prior to the completion of the audit, NED reviewed all
training folders and corrected the above deficiencies. This
Audit Finding is therefore closed.
(Referenced QS-86-03 Checklist Attributes 6, 33)
Audit Finding No. 32
General Services Department (Production Training Center)
Procedure WI-R, " Procedure for Welding Instructor
Requirements", Rev 1, para. 8.1, identifies 5 courses that a
welding instructor must complete before or after assignment
to the position. Further, para. 8.3.1 requires that these
courses be completed within the first 24 month time period
of the date of assignment to Mechanic A-1 welding
instruction.
Contrary to the above, no objective evidence was found that
the Mechanic A-1 Welding Instructor had completed 3 of the 5
courses within the required time frame.
l (Reference QS-86-03 Checklist Attribute 53)
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PAGE 25 OF 35
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Audit Finding No. 33
General Services Department (Production Training Center)
Procedure WI-R, " Procedure for Welding Instructor
Requirements", Rev 1, para. 8.4.1, requires that welding
skill competence demonstration requirements be completed by
a Welding Instructor assigned to Mechanic A-1 welding
related job duties prior to the actual assignment date.
Successful completion of 5 tests is required.
Contrary to the above, no obj ec tive evidence was found that
the Mechanic A-1 welding instructor had completed 4 of the 6
required tests prior to instructing a Mechanic A-1 welding
course.
(Reference QS-86-03 Checklist Attribute 53)
Audit Finding No. 34
NOC Policy 21, para. 4.2.6, identifies the specific
requirements that each nuclear and non-nuclear department
shall satisfy in implementing the training for their
personnel.
Contrary to the above, the Information Systems Department
has not developed a procedure for implementing the NOC
Policy requirements.
(Reference QS-86-03 Checklist Attributes 1, 3b)
Audit Finding No. 35
NOSD-17, Section 6.0, identifies specific requirements for
generation of Training Needs Matrices and Task Lists for
NOSD personnel.
Contrary to the above, training folders were found to be
incomplete concerning the above referenced documents for 14
personnel from the Nuclear Training Division. In addition,
the Eme.gency Preparedness Division Training Needs Matrices
did not contain written examination results.
(Reference QS-86-03 Checklist Attribute 3e, 18, 28, 33)
[6@ QUALITY ASSURANCE DEPARTMENT
NB-86-01
AUDIT REPORT AUDIT NO. Qs-86-03
26 35
PAGE OF
Observation No. 1
ANSI N18.1-1971 requires that a training program be
established to develop and maintain an organization fully
qualified to be responsible for operation, maintenance and
technical aspects of the nuclear plant. Furthermore, it
requires that a continuing program shall be used to train
and retrain, as necessary, to assure that personnel remain
proficient. There are many LILCO procedures which provide
for most of the training and retraining requirements for
individual sections or departments. However, there is no
overall Policy / Program document which provides detailed
instructions, guidelines and criteria needed to implement
the requirements of NOC Policy 21, the NRC regulatory
requirements and appropriate industry seandards. Efforts
should be expedited to complete a Training Program
Administrative Manual to control all training for SNPS
activities.
(General Observation)
Observation No. 2
Procedures do not require that there be Radwaste lesson
plans for annual refresher training to fulfill requirements
of NRC Bulletin 79-19. The individual lesson plans do not
specifically reference that Bulletin and it's requirements.
In addition, the lesson plans for Radvaste and HP do not
include requirements for examinations, pass / fail criteria,
or the basis for demonstrating that all of the received
training has been completed. A response to this Observation
is required.
(Reference Checklist D-10(b and c), 11(c))
Observation No. 3
A review of selected maintenance personnel's Training and
Qualification folders against applicable requirements
identified several areas of non-compliance. Further review
revealed the same deficiencies were identified by the
Quality Control Division (QCD) during QC Audit 85-08.
Corrective Action is ongoing for the following QC Audit
Findings which relate to the same items:
_ _ _ _ _ _ - _ - - - _ _ - - _ - _ - _ - _ _ - - _ - _ _ _ - - - - _ _ - - - - - - _ _ - _ _ _ - - - - _ - _ _ _ - _ - _ - _ - _ _ - _ _ _ _ - - - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - _
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a) #12 completion due date of 7/1/86
b) #18 completion due date of 4/15/86 (closed)
c) #20 completion due date of 4/15/86 (closed)
QCD should continue to monitor the progress of Corrective
Action to insure timely completion.
(Reference Checklist E-2(b, c & e))
Observation No. 4
Reg. Guide 1.8, "Per:sonnel Selection and Training",
requires that a qt.211fied individual be designated as
Radiation Protection Manager. SP 12.003.01, Appendix 12.2,
specifies that the Health Physics Engineer is the person who
meets the requirements of Reg. Cuide 1.8. Technical
Specification 6.3.1 specifies that the Health Physics
Supervisor shall meet the requirements of Reg. Guide 1.8,
but the organization chart (Fig. 6.2.2-1) shows only the
Health Physics Engineer. This inconsistency should be
resolved.
(Reference Checklist D-5)
Observation No. 5
There is a signature block on the examination answer sheets
for GET which states that the examinee has not given nor
received help on the test. However, there is no written
policy or other requireuent which states that the examinee
must actually sign the aid disclaimer. Likewise, there is
no policy or procedure for dealing with an unsigned answer
sheet. Furthermore, there are no written LILCO policies,
procedures or guidelines for LILCO personnel to deal
directly with non-LILCO personnel who cheat on an
examination administered by LILCO. It is recommended that
policies be developed to deal with these subjects.
(Reference Checklist F-9)
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AUDIT REPORT AvoiT No. oS-86-03
PAGE 28 op 35
Observation No. 6
In an operating plant, personnel will be required to work
independently in areas where radiation and contamination
exist. Except for licensed operatore, training and
qualification matrices within the control room do not
include a column for self monitoring. The matricea for
equipment operators, radchem technicians, health physics
technicians, radwaste operators, I&C technicians and
maintenance personnel should be reviewed to consider the
need for a column to document self monitoring training.
(Reference Checklist A-25)
Observation No. 7
FSAR Section 13.1, para, 13.1.3.26, Technicians, states
" Technicians will be high school graduates or equivalent.
Technicians in responsible positions shall have a minimum of
, 2 years of working experience in their specialty, (e.g.,
Health Physics, Chemistry, or Instrumentation and
Controls). These personnel should have a minimum of 1 year
related technical training in addition to their experience.
Technicians will have a thorough knowledge of the design and
operation of the equipment related to their field."
FSAR Section 13.2, para. 13.2.1.2.1.2, states in part,
" Personnel assigned as Instrumentation and Control
Technicians possess a minimum of two (2) years experience,
and at lea; one (1) year of technical training related to
instrumentation and control as a prerequisite to their
assignment....".
SP 41.011.01, para. 5.1, states "An I&C Technician shall be
a high school graduate or equivalent and have three years of
experience as an I&C Technician. One of the three years may
be satisfied by related technical training."
SP 41.011.01 does not identify the FSAR requirement of at
least one (1) year of technical training related to I&C as a
prerequisite to their assignment for replacement personnel.
Consideration should be given to revise the procedure or the
FSAR to be consistent.
(Reference Checklist C)
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PAGE 29 OF 35
Observation No. 8
No procedure violations were identified, although SP
61.040.01 has several paragraphs which should be refined to
avoid " training required" verses " training received"
interpretation problems. The following illustrate this
item:
a) The HP Technician Qualification Program classifies a
Level I HP Technician higher than a Level II which is
the inverse of ANSI N45.2.6 classification of
inspector / examiner shich classifies a Level II higher
than a Level I.
b) Functional areas of qualification on the pre-printed
training folder index and tabbed sections do not
correspond one-to-one with functional areas from
Appendix 12.6.
i c) Paragraph 8.5.2 is worded such that the two year
qualification period for the various functional areas or
specific tasks could expire at different times. This
inconsistency may cause unnecessary administrative
complications.
d) Because of the problem identified in item (c) above,
the manner and timing for administering examinations is
not readily apparent in para. 8.6.1.6.
e) The course listing in para. 8.6.1.1 is not directly
correlated to the functional areas in which
requalification is to be completed. This is also
compounded by item (c) above.
, f) The overall training and qualification matrix may I become cumbersome and difficult to manage due to the
large number of specific tasks requiring qualification.
g) The requirements for issuing and updating the
qualification matrix should be incorporated into this
procedure as an aid in maintaining the matrix r.crent.
(Reference Checklist D-2)
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Observation No. 9
Reg. Guide 8.13 " Instruction Concerning Prenatal Radiation
Exposure", requires fertile females (a term applied to all
female employees who may be exposed to radiation hazards)
and their supervisors to receive training on the prenatal
effects of radiation exposure. In addition, SP 12.014.03
requires all individuals receiving this training to complete
and sign an acknowledgement form to indicate that they have
received and understood the training.
Although all 26 prenatal forms reviewed included the
required signature, 11 of the 26 lacked social security
numbers. This hinders positive identification of
individuals with their training records. It is suggested
that these forms be monitored more closely in the future to
include individual social security numbers.
(Reference Checklist F-9(g))
,
Observation No. 10 Security procedures require the Nuclear Training Division to notify Security when personnel have completed GET, or when GET qualifications expire. This is required in order for Security to accurately maintain the unescorted access list for entry into the protected area at SNPS. The Nuclear Training Division is fulfilling this requirement, however, 11 of 50 notifications examined did not include the individual's social security number which hinders positive identification. It is suggested that all GET notifications include individual social security numbers. (Reference Checklist F-9(h)) Observation No. 11 One individual's qualification and training file folder contained 2 medical approvals dated 1/7/85 and 12/16/85 for strenuous activity. Although no procedure violations were noted, the medical approvals differed in date of birth and social security number. It is suggested that all individuals (initiator and recipient) pay closer attention to detail an/ check records to ensure accuracy. (Reference Checklist D-4)
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35
Observation No. 12
SP12.014.07, " Licensed Operator Requalification Program",
para. 8.4.1, requires that the actual performance of all
shift licensed personnel be evaluated annually. The para-
graph further specifies that the evaluations be reviewed by
the Operations Section to identify training needs.
The Nuclear Training Division does not receive training
needs information based on performance evaluations, except
those prepared during simulator training sessions. This
should be clarified in the training program.
(Reference Checklist A-14, 22)
Observation No. 13
The Station commits to NRC Regulatory Guide 1.8 which
governs the qualification of Station personnel concerned
with the day-to-day operation, maintenance and certain
technical services. However, SP12.003.01, " Personnel
Qualifications and Responsibilities", does not clearly
define what positions and/or what circumstances require
qualification to ANSI N45.2.6 (Reg Guide 1.58). It should
be roted, that the procedure aligns fairly well with the
requirements of ANSI N45.2.6, although it is lacking in the
following areas:
a) Activity qualified to perform,
b) Effective period of Certification,
c) Basis used for Certification
Consideration should be given to revising SP12.003.01 to
provide clear guidance for certifying Station personnel to
specific requirements in ANSI N45.2.6, if required. A
response to this Observation is required.
(Reference Checklist D-1(gl & 2), C-3(b) and E-10)
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Observation No. 14
Of 31 16C Technician's folders examined, 11 contained
letters from their supervisor withdrawing or clarifying 22
specific qualification requirements. Qualification
requirements to perform safety related work are identified
on the I6C Technician Qualification Record Summary
(SPF41.0ll.01-1), although there does not appear to be clear
guidance for accomplishing individual qualification based on
on-the-job training, vendor supplied training, or a
combination of both. It is recommended that clearly defined
bases be established for accomplishing this qualification.
(Reference Checklist C-3(g))
Observation No. 15
SP 51.003.01, " Reactor Engineering Personnel Training &
Qualification Program", includes an extensive training and
qualification program for Station Nuclear Engineers (SNEs)
to be effective for replacement personnel after the warranty
run. Current SNEs are qualified to FSAR requirements by
virtue of STA Training (all are qualified STAS).
It is suggested that until SP 51.003.01 is in effect,
qualification of SNEs should specify successful completion
of the STA Program, or qualification to the SP 51.003.01
Program.
(Reference Checklist B-18(a))
Observation No. 16
Based on a review of the training folders and qualification
matrix for selected Radiochemistry Technicians the following
suggestions are made:
-
a) The Station Employee Training Summary for
Radiochemistry Technicians (non-mandatory form)
contained in the training folders should be revised to
reflect Phase 3 training as "BWR Systems Training" to be
consistent with SP 71.006.01, para. 8.3.2.
b) The "BWR" column on the qualification matrix is not
l
required and should be deleted.
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c) SP 71.006.01 should be revised to indicate how reviews
of Non-SNPS training programs for equivalency are to be
performed and documented.
A response to this Observation is required.
(Reference Checklist D-12)
Observation No. 17
The following observations were made as a result of the
review of NED training folders,
a) The NED Training Needs Matrix contains a column titled
"P" which under the original training program required a
" priority" to be assigned to each training need entered
on the matrix. NED has apparently used this column to
record actual training progress by entering a check mark
and/or the date of the training received. It is l
suggested that NED review the Training Needs Matrices
that have been developed to date to eliminate the check
marks and dates.
b) The format for the Position Standards, which is based
on the requirements of the original training program,
identifies Section V as "Special Training and
Qualification". In many cases the Position Standards
identify certain types of specific training which are
not identified on the Training Needs Matrix. It is
suggested that when training outlined on a Position
Standard is deemed to be unnecessary by a supervisor, a
statement to that effect be entered on the matrix
providing justification.
c) In several cases, training received by individuals over
and above that required by the Training Needs Matrix is
identified on the Formal Training History form without
substantiating documentation (certificate, grade sheet,
letter of attendance). Unless the substantiating
documentation can be obtained, reference to this
training should be deleted from the Formal Training
History form. This primarily involves training claimed
by individuals prior to their employment with LILCO.
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d) The Formal Training History form required by the
original training program is included in most NED
folders, however, in some cases a separate form is used
to document training received. In order to be
consistent, it is suggested that only the Formal
Training History form be used.
'
e) Provisions should be established for documenting the
acceptability of completing one course in lieu of
another. i.e. - One NED individual is required to take
BWR Familiarization, however, that person has taken a
one week course presented by General Physics entitled
"BWR Operations Technology Program for Management and
Engineer Personnel". The outline for this General
Physics course should be evaluated to determine if it
meets the requirements of BWR Familiarization and if so
that determination should be documented.
(Reference QS-86-03 Checklist Attribute 6)
(
Observation No. 18
There appears to be a lack of clear definition within the
implementing procedures regarding the application of ANSI
N18.1 requirements for Technical Support Personnel as they
relate to SNPS support organizations (e.g. NED, NOSD, OEA).
Specifically, the applicability of qualification
requirements for the classifications " Engineer in Charge"
and " Staff Specialists" is not addressed.
It is suggested that concise criteria be established in the
programmatic training documents regarding the application of
ANSI N18.1 requirements for support organizations at SNPS.
(Reference QS-86-03 Checklist Attribute 39)
Observation No. 19
In assessing the overall training and qualification
program, attributes not specifically identified as
requirements by LILCO Policy and Procedures were evaluated.
. . - _ - . _ _ . ..
.
'
[[S[9 QUALITY ASSURANCE DEPARTMENT
NB-86-01
.
AUDIT REPORT AUDIT NO. QS-86-03
PAGE 35 OF 35
. Primarily addressed was a comparison of existing training
programs and methods against the criteria set forth by INPO
for accreditation of training programs in the nuclear power
industry. The major attributes of the INPO criteria for
accreditation were identified and reviewed, (Attributes 40
through 51 on the QS-86-03 Audit Checklist). Comments were
developed for each of these checklist attributes. Specific
results of each attribute as " Satisfactory",
" Unsatisfactory" or "N/A" are not appropriate and are not
included on the checklist.
It was determined that although some work remains in
finalizing the specific details for developing an INPO
accredited program, the review of the draft documents
developed (SNPS Administrative Training Manual and Nuclear
Training implementing procedures) indicated that the Nuclear
Training Division was completing this process in an
acceptable manner.
, (Reference QS-86-03 Checklist Attributes 40 through 51)
VI Attachments
1) Audit Participation Summary
2) Completed Audit Checklists
a) NB-86-01 (A through C)
b) QS-86-03
3) Audit Response Forms
a) NB-86-01
b) QS-86-03
_ _. .
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.. . - -
[[d(9 QUALITY ASSURANCE DEPARTMENT yg_86-01
AUDIT REPORT AUDIT NO. QS-86'-03
PAGE I OF 3
Attachment 1: Audit Participation Summary
PERSONNEL CONTACTED: g
E sE
# C Et
Audit Team - NB-86-01: E U EE
J. Neely Audit Team Leader (NPC) X X
F. Duvall Technical Specialist (NRB/OAC) X
J. Morlino Auditor (QSD) X X
R. Christiansen Auditor (NRB) X X
J. McCarthy Auditor (QAD)
R. DeRocher Auditor (QAD)
D. Rorer Auditor (NRB)
Audit Team - QS-36-03:
J. Powers Audit Team Leader (QSD) X X
R. Savage Auditor (QAD) X X
J. Spolizino Auditor (QSD)
S. Volk Auditor (QAD)
W. Rath Technical Specialist (CYGNA) X X
C. Moeller Purchasing, Nuclear Procurement X X X
R. Cardella Purchasing, Nuclear Procurement X X
V. Fallacara SNPS, Operations X X X
C. Daverio NOSD, Emergency Planning X X
L. Calone NOSD, Training X X X
B. Colacchio NED, Engineering Assurance X X X
J. Blas QA, Quality Systems X X
P. Pizzariello SNPS, Maintenance X
D. Terry SNPS, Maintenance X X
T. Cartier SNPS, I&C X X
D. Crocker NOSD, Emergency Planning X X
M. Coppola NOSD, Training X
H. Chau NED, Engineering Assurance X X X
E., Youngling * NED, Manager X X X
M. Verderosa NED, Engineering Assurance X X
K. Rottkamp NOSD, Training X
E. Eisenberg NOSD, Training X X X
R. Glazier QA, Quality Control X X X
.
. - - - - . - - - - - -
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[[M9
~
QUALITY ASSURANCE DEPARTMENT Nn-86 o1
AUDIT REPORT AUDIT NO. QS-86-03
PAGE 2 op 3
Attachment 1: Audit Participation Summary (cont'd),
PERSONNEL CONTACTED: g ,
E sE
R t Et
5 5 E8
C. Seaman QA, Quality Control X
J. Montalto QA, Quality Control X
A. Muller QA, Quality Assurance X
J. Notaro Quality Assurance Dept. Manager X X X
J. Alexander SNPS, Operations X X
J. Smith * NOSD Manager X X X
J. Wynne NOSD, Training X
H. McDaniel NOSD, Training X
A. Burritt NOSD, Training X
S. Sprengle SNPS, Rad Chem X
C. Nikitopoulos SNPS, Rad Chem X
g J. Schmitt SNPS, Rad Controls X
P. Kwaschyn SNPS, Radwaste
-
X
R. Jongbloed SNPS, Rad Chem X
T. Stratton NOSD, Training X
D. Atchison NOSD, Training X
N. Morcos NOSD, Training X
N. DiMascio SNPS, Health Physics X
T. Pulver SNPS, Operations X
M. Holland SNPS, Watch Engineer X
A. Mattessich SNPS, Watch Enginee'r X
W. Steiger* SNPS, Plant Manager X X
T. Powers SNPS, Operations. X
M. Donegan SNPS, Health Physics X
R. Thompson SNPS, Health Physics X
E. Cubeta SNPS, Health Physics X
L. Lewin SNPS, Outage / Modifier. tion X
E. Kope,ienski SNPS, Maintenance X
D. Durand SNPS, Outage / Modification X
W. Maloney SNPS, Computer X
J. Berntson SNPS, I&C X
R.,Wiemann SNPS, I&C X
W. Slivonik SNPS, Maintenance X
j E. Bressler SNPS, Maintenance X
L. Britt NOSD, Licensing X
J. Morin NOSD, Licensing X
I. Toner NOSD, Fuclear Services X
- R. Gutmann NOSD, Nuclear Contracts X
l
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[[b@ '
QUALITY ASSURANCE DEPARTMENT, yg_86-oi
AUDIT REPORT AUDIT NO. QS-86-03
PAGE 3 OF 3
Attachment 1: Audit Participation Summary (cont'd),
PERSONNEL CONTACTED: $
E sE
E t- EM
5 0 EF1
B. Stephens NOSD, Financial Services X
J. Camp NOSD, Training X
J. McCue NOSD, Training X
C. Moore NOSD, Training X
C. Hall SNPS, Operations X
D. Dyroff QA, Quality Control X
K. Lewis Information Systems X
M. DeGennero Information Systems X
R. Miller Production Training Center X
W. Williams Production Training Center X
I * - These individuals were made aware of the
results of the audits through a separate
audit exit held by the QA Department
Manager and members of the audit teams.
!
.
.
t
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- - . _ , _ ,, , _ - _ _ - - . - . _ . - - . - - - _ _ . . . _ . . _ _ _ _ - - - - - _ _ - - - _ - _ - _ , _ _ . . - . - _ _ _ - _ _ _ - , ,
-
NB-86-01
.' '
Audit No. QS-86-03
Attachment 2
a) NB-86-01 Audit Checklist (A through G)
b) QS-86-03 Audit Checklist
>
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. . . _ - . , - _ , -
. _
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_
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pgjO QUALITY ASSURANCE DEPARTMENT
^
AUDIT NO. NH-86-01
AUDIT CHECKLIST ' OF
13
PAGE
Personnel Qualifications
"" "'"'"" "" "" "" **"" " " ***' "
AUDIT OF: LOCATION:
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
Checklist A
Licensed & Non-Licensed Operators
1 SP12.003.01 Verify that personnel in the S The Operations Division organization diagram,
Appendix 12.2 following positions possess dated April 1, 1986, indicates by code (SR0
Appendix 12.3 valid SRO or RO Licenses: or PO) the licensc held by each individual.
a) Operating Engineer - SRO A representative number (13) of individuals
were identified to have their license
b) Watch Engineer - SRO evidence examined,
c) Watch Supervisor - SRO For eleven (11) people, the NRC certificates
were in the possession of the operating
d) Nuc. Sta. Oper. - RO engineer. Copies of the remaining two (2)
licenses were verified in the training files.
c) Nuc. Asst. Sta. Oper - RO
2 SP12.003.01 Verify that the Watch Engineer S The Operating Engineer and two (2) Watch
para. 8.31.8 directs on-the-job training sessions Engineers were interviewed to determine
1
for on-shift licensed personnel the extent of on-the-job training conducted
as follows: under their direction. Both Watch Engineers
direct the following types of on-the-job
a) Senior Reactor Operator on-the- training:
job training (observation or 1. equipment operator qualification guide
discussion) instruction and check off
2. pre-shift briefings, questions and
b) Reactor Operator on-the-job discussion
training (observation or dis- 3. pre-evolution meeting, questions and
cussion) discussion
PREPARED BY -
DATE APPROVED BY DATE APPROVED BY DATE
Signed / approved Audit Checklists are
filed & maintained with OSD
- _ ._ - . _ _
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[#E{O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST ^ PAGE 2 op 13
.
i
i
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
c) Non-Licensed Operator on-the-jot 4. tailboard meetings and discussion on
,
training safety topics
5. discussion of items on the required
reading list
6. conduct " walk-around" informal seminars
or individual discussions of procedures
or actions.
3 SP12.003.01 Verify that the Watch Supervisor S The interviews for item 2 confirmed that
para. 8.32.7 provides assistance to the Watch the Watch Supervisors assisted in the
Engineer for the conduct of train- on-the-job training, particularly the check-
ing for the following personnel: off actions for Equipment Operation Qual-
ification Guides,
a) Senior Reactor Operators Separate interview with Watch Supervisor
! fndicated that training checkouts of
; b) Reactor Operators equipment operators (EO) was assigned to him
j by the Watch Engineer. Examination of
! c) Non-Licensed Operators EO Qualifications Guides confirmed such
performance.
l
{ 4 SP12.003.01 Examine a sample of the documen- S Tailboard meeting subjects are described
; para. 8.31.8 tation for on-the-job training on forms required by Procedure SP12.025.0102.
conducted during 1985/1986 for The form provides for a list of attendees,
the following personnel: Three (3) tailboard meeting forms for
-
March, 1985 were examined.
a) Senior Reactor Operators
Two (2) required reading booklets were
b) Reactor Operators examined (86-18 and 19).
l c) Non-Licensed Operators Seven (7) EO Qualification Guides were
examined to verify documentation of
on-the-job training.
1
. __ __ _ __ ._--.
6
.
.
#gro QUALITY ASSURANCE DEPARTMENT AUDIT NO.
6am.n
AUDIT CHECKLIST A
PAGE 3 OF 13
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
5 SP12.014.06 Verify that provisions for three (3) S The training records of two (2) persons,
para. 8.2.4.1 months of on-the-job training hot Licensed in 1985 were examined.
include:
The training records of M. Dunckley and
a) Two (2) SNPS Reactor Startups S. Lom, Nuclear Assistant Station Operators
were reviewed. These individuals par-
b) Five (5) Reactivity Changes ticipated in a modified cold license
program in lieu of a hot license program,
c) Instruction in day-to-day Reactor startups and reactivity changes
administrative activities were performed on a research reactor and
simulator.
d) Guided self-study of operating Day-to-day administrative instruction was
characteristics, operating conducted at another BWR and to a limited
procedures and emergency pro- degree at Shoreham,
cedures
Training and knowledge demonstration related
e) Demonstration of knowledge and to procedures was conducted during the
familiarity with immediate simulator and observation modules of the
actions of procedures listed on modified cold license program. The modified
FSAR Table 13.5.1-1, Sections cold license program description is con-
j B.3 and B.4 tained in Lom's file and in Dunckly's file. , '
Lom subsequently participated in a license
upgrade training.
,
Descriptions of the modified cold license and
license up grade training exist in the train-
ing file in the training division records.
.
__ _ -__
_
.
[gEfD QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST ^ PAGE '
OF 13
.
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
6 SP12.014.06 Verify the provisions for four (4) S The 1986 hot license program contains pro-
para. 8.2.4.2 weeks of supervised study, visions for " independent review" during the
theory and systems / procedures training.
7 SP12.014.06 Confirm the provisions for a writter S The 1986 hot license program provides for a
para. 8.2.4.2 audit examination to verify elig- one (1) week audit examination.
ibility for licensing.
8 SP21.006.01 Confirm that provisions have been U The training records of six (6) individuals
para. 8.2.3.1 made for the following training were examined. These six (6) individuals
to be completed before a licensed were assigned to assume the duties of Nuclear
operator is qualified to stand watet . Assistant Station Operator in 1985.
;
a) Operator's Qualification Guide, Contrary to the requirement of SP21.006.01,
per Qualification Form Revision 5, para. 8.2.3.1, the completion
Appendix 12.2 of the Operator's Qualification Cuides
,
was waived. (Audit Finding #4)
b) Fire Fighting Training per FSAR Furthermore, the area qualification cards
Section 9.5.1.5 for the six (6) personnel are not supported
by objective evidence of their qualifications
in the Yard, Turbine Building, Control
Buidling or Radwaste Building. (Audit
Finding #1)
c) Emergency Preparedness Training
per EPIP 5.4
i l
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en
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6#p a n;g. r, -o QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST A
PAGE 5 0F 13
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
9 SP12.014.02 The individual training and Reviewed the individual training folders
para. 8.2 qualification folders for licensed for the following SRO and RO licensed
Appendix 12.1 personnel (SRO and RO) contain the personnel
following minimum information: ,
1) K. Rottkamp
2) W. Uh1
3) M. Howley *
4) J. Reid
5) M. Dunckley
6) S. Lom
a) Employment application or resume U a) All folders contain resumes; however,
the resumes for K. Rottkamp, W. Uhl
M. Dunckley and S. Lom do not reflect
the individual's present job function.
(Audit Finding #7)
b) NRC or non-NRC type licenses S b) Yes.
1) SRO dated 3/7/85
2) SRO dated 3/7/85
3) SRO dated 3/27/85
4) R0 dated 3/7/85
5) RO dated 4/8/85
6) RO dated 10/22/85
c) Completion of SNPS training S c) Yes for S. Lom and M. Dunckley through
. requirements per FSAR completion of the Modified Cold License
Section 13.2. Program, and the License Upgrade Program
for S. Lom. All other license holders
completed the Cold License Training
Program. -
1
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K#p;g c o
.a.,n:
QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST A
PAGE 6 op 13
.
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
d) Drill participation documentatfor U Drill participation documentation, completed
requalifications requirements and training
e) Completed requalification requirc -
performance evaluations (drill scenarios)
ments was found to be satisfactory but was
retained in the requalification program file
f) Training performance evaluations not in the individual training and qualifica-
(drill scenarios) tion folders as required. (Audit
Finding #6)
10 SP12.014.04 Verify that the Chief Operating U Interview with the Operating Engineer con-
para. 8.2.2 Engineer evaluates the following firmed that evaluation of training pro-
SP12.003.01 Licensed Operator Training Programs grams for operations personnel is
para. 8.12.3 to provide feedback for improvements accomplished by the review, comment and
to the Training Section approval actions of the Operating Engineer
on lesson plans and examinations.
.
a) SRO Training The title Chief Operating Engineer is
obsolete. Also, SP 12.014.04 should be
deleted because the responsibilities
i b) RO Training related to training are now with the . Nuclear Training Division. i
c) Licensed Operator Requalificatior i (Audit Finding #10)
Training
d) Non-Licensed Operator Training
I
11 SP12.014.07 Select a sample of licensed per- S On-the-job training for licensed
- para. 8.1 sonnel and verify completion of the personnel is comprised of pre-
following elements of the requalif- evointion briefings, shift
ication program: turnover briefings, tailboard
safety training, required reading .
j a) On-the-job training and spontaneous discussions. I
_ _ _ _ - _ _ _ - - _ - - - - - - _ - . _ - _ _ _ - - - - _ _.
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
[n#Ed*O .n .,
AUDIT CHECKLIST ^ PAGE 7 0F 13
#
.
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
l
! b) Annual evaluations Required reading and tailboard
meetings were verified by document
review. Other types of on-the-job
training performance was verified
by interviews. ,
Annual evaluations are performed.
The existence of performance evalua-
tions was confirmed by sighting the
1985 forms. The completed forms are
regarded as confidential.
(See attribute #14)
12 SP12.014.07 Verify the following types of
para. 8.3 on-the-job training for a sample
of SRO license holder and RO
licen e holders:
a) Control Manipulations per S a) Documented on Lt.nerick Simulator
, para. 8.3.1 Drill Participa'; ion Records.
'
b) Cognizant of design, procedural S b) Modification, procedure and license
and license changes per para. changes are inc.luded in both the k
j 8.3.2 required readiig training and in
scheduled requalification training
1) cross job training classes.
2)on-shift discussion
3) plant drills
.
!
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# gg'O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
4Lann
AUDIT CHECKLIST A PAGE 8 OF 13
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
13 SP12.014.07 Verify that unsatisfactory plant S Yes. Drill performed 5/24/85 had all per-
para. 8.3.2.3 drills have been reviewed by the sonnel satisfactory except S. Lom who
training supervisor or designee. was found unsatisf actory (Drill 85-3).
This matter was reviewed and signed by
K. Rottkamp (Note: this occurred before
S. Lom was licensed). Drill 21, Rev. 1,
performed at Limerick simulator 10/1/85, was
found unsatisfactory due to the dissim-
ilarities between Limerick and Shoreham.
This drill was signed by J Wynne and
different drill substituted on 10,'3/85.
14 SP12.014.07 Verify that actual performance of S Subparagraph 4.c of 10CFR55, Appendix A
para. 8.4.1 all shift licensed personnel is requires systematic observation and
evaluated annually. evaluation of licensed personnel.
Such evaluations may be part of the
indicated need for accelerated
requalification. Para. 8.4.1 is the
SNPS implementation of this requirement.
The training division does not receive
the training needs information based on
the operations section review of shift
licensed personnel performance evalua-
tions, except those prepared during
] i
simulator training sessions.
(Observation #12)
,
Backup licensed personnel are evaluated
as part of drill participation docu-
mentation.
_ - _ _ _ _ __ . - _
_
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6#v(E g*O
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST ^ PAGE 9 0F 13
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
15 Section 2.0 of each of the follow- The Training Division Simulator Operations
ing station procedures assigns Superviror indicated that the position titles
an individual to assume particular specified for items c, e and f below are
responsibilities associated with incorrect. The correct titles are indicated
the procedure. below.
Verify that the designated indi-
vidual assumes, understands and
executes the specified responsi-
bility.
SP12.003.01 a) Plant Manager - insure personnel S a) The Plant Manager issued a memorandum
fulfill qualifications and main- on March 3. 1986 requiring each plant
tain responsibilities, staff section to develop and maintain
a training and qualification matrix.
SP12.014.01 b) Training Supervisor - implemen- N/A b) SP12.014.01 was deleted on Nov. 15. 1985
tation of procedure. as the result of closing Finding No. 10
of NRB Audit B-85-1.
SP12.014.02 c) Training Supervisor - assure U c) Position Title should be Training
, '
implementation of procedure Administrator. (Audit Finding #10)
requirements.
SP12.014.04 d) Operations Managers - ensuring U d) This procedure prescribes responsi-
adherence to procedure require- bilities for the Operations Manager
ments. and Chief Engineers. These positions
are not active positions at SNPS.
(Audit Finding #10)
SP12.014.06 e) Operations Training Specialist - U e) Position Title should be Operations
ensuring proper implementation of Training Supervisor. (Audit
procedure requirements. Finding #10)
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[gEg QUALITY ASSURANCE DEPARTMENT AUDIT NO. .
AUDIT CHECKLIST ^ PAGE 10 OF 33
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS '
3
SP12.014.07 f) Nuclear Plant Training Supervisor U f) Position Title should be Operations
ensuring proper implementation of Training Supervisor. (Audit
procedure requirements. Finding #10)
SP21.006.01 g) Operating Engineer - ensuring S The Operating Engineer initiates revisions
proper implementation of procedure to the procedure to ensure that procedure
requirements. requirements and programs are compatible.
The most recent revision (No. 7) was
issued on Feb. 27, 1986.
16 SP21.006.01 Qualification in turbine, reactor, U The area qualification certifications of ,
para. 8.1.1.4 and control buildings and yard six (6) Equipment Operators indicated
shall be in accordance with SNPS qualification for Yard, Control Building
Operator Qualification Guide, as Reactor Building and Turbine Building,
supplemented by the SNPS Equipment Examination of the Qualification Cuides
Qualification Guide. supporting the certification revealed
that in four (4) instances the cognizant
Verify the process used to deter- Watch Engineer did not sign a significant
mine that an individual is qual- number of Qualification Guides.
ified is in accordance with the (Audit Finding #1)
guides.
17 SP21.006.01 Verify that replacement equipment S EO folders checked for B. Dennison,
,
para. 8.1.3.1 operator candidates have documented D. Jenkins, T. Litts and H. Pierce.
evidence of the following qual- /
ifications;
l
l a) High school diploma or equivalent a) All had High School diploma.
.
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST A
PAGE 11 OF 13
.
.
NO. REFERENCE ATTRIBUTES S t) N/A OBSERVATIONS / COMMENTS
b) High degree of manual dexterity b,c.d) No documented evidence of this
except:
c) Mature judgement 1) eye exam
2) physical exam
l d) Ability to train and accept 3) completion of required training courses l responsibility (interviews and 4) successful careers in the Navy '
exams.) 5) Qualification Guides
18 SP21.006.01 Verify that repincement equipment N/A Selected same 4 as per above.
(Rev. 6) operators without prior nuclear HP training not required for Jenkins/Litts/
para. 8.1.3.2 experience obtain 2-4 weeks of Dennison as they attended Naval Nuclear
HP/ power plant indoctrination Power School and served accordingly.
while assigned to the training
coordinator.
19 SP21.006.01 Verify that prior to assignment to Selected same 4 as per above:
(Rev. 6) the turbine, reactor, or control
para. 8.1.3.3 building, each replacement equip-
ment operator has successfully
completed the following require-
ments:
a) Ceneral empicyee training. S All had completed CET & CET Requal.
hetween 1/16/86 and 2/13/86.
b) EO Qualification Program as doc- U Refer to attribute 16 of this checklist
,
umented on Appendix 12.2 forms, and Audit Findings #1.
c) Completion of one (1) month of U On-the-job training is not specifically
on-the-Job training. is not specifically performed or
documented. (Audit Finding #1) .
. _ - __ -- _ -_
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6a#;gg*O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
.n
AUDIT CHECKLIST ^ PAGE 12 op 13
.
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
d) Fire fighting training per S All had completed fire fighting
FSAR Section 9.5.1.5. training in mid 1985.
20 SP21.006.01 Verify that any vaistrs of replace- N/A No waivers granted for the 11 Equipment
(Rev. 6) ment equipment operator training Operators that went on the job in 1985.
para. 8.1.3.6 reqitirements are approved by the
operating engineer. ,
21 SP21.006.01 Verify that the following refresher N/A This attribute not addressed during the
(Rev. 6) training is completed annually by audit. Replacement equipment operators
equipment operators: reviewed under attribute #19.
a) General employee training.
b) Firefighting training.
,
c) Emergency preparedness training.
22 SP21.006.01 Verify that the Supervisor of Equip- S Performance evaluations for Equipment
(Rev. 6) ment Operators annually evaluate Operators are conducted in the manner
para. 8.1.4.2 the Equipment Operators. described for attribute 14.
(Observation #12)
23 Audit Report Verify that the following audit
! NRB B-85-1 findings have been satisfactorily l resolved:
a) Finding 10 - references to FSAR S It was confirmed that procedure SP12.014.01
and Reg. Cuide 1.8. was deleted on November 15. 1985.
.
_ _ _ _ _ _ _ _
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Man #pg (. ,Ox
QUALITY ASSURANCE DEPARTMENT
..
AUDIT NO.
AUDIT CHECKLIST A PAGE 13 0F 13
.
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
b) Finding 11 - training records S It was confirmed that procedure SP12.014.06
as required by SP12.014.06. was revised (Rev 2) on October 23, 1985 to
add a provision for special programs
approved by the NRC.
24 SP12.003.01 Identify and record the names of N/A A list of instructor names was provided to
training instructors who conducted the QS-86-03 audit team.
courses for each discipline iden-
tified in Checklist A. Coordinate
this information with the auditors
performing audit QS-86-03.
25 W.E. Steiger, Does the Qualification S The qualification matrix established for
Memo PM Matrix for Operations operations is up to date and reflective
DIR 86-003 personnel meet the of requalification dates. The only
dated 3/3/86 requirements of refer- exception noted during the review was
, enced memo and is it that the matrix for equipment operators did
reflected in the not include a block for "Self Monitoring"
training files? qualification. All of the 4 EO folders
reviewed had certifications therein for
"Self Monitoring". (Observation #6)
!
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a
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST a ' 22
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PAGE OF
Personnel Qualifications Shoreham Nuclear Power Station
AUDIT OF: *nd Traininn LOCATION:
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
Checklist B
Reactor Engineering, STAS and
Compliance Engineers
1. Tech Spec Are there enough Shift Technical S Five assigned STA's and 5 certified
Table 6.2.2-1 Advisors (STAS) designated in backup STAS.
writing to provide shift coverage
required for conditions 1, 2 or 3.
2. SNPS SSER 1 Are there enough STAS, or backup STAS S
p. 22-4 in training, to assure a continuing
supply of qualified STAS for
replacements due to vacations,
promotions, transfers, and
terminations?
3. Examine the training and qualification S See Table B-1, and QCD Audit # QC-86-02,
records of each STA and STA candidate item #3 and Table A, (QA Audit of Reactor
and complete Tabic B-1. Engineering conducted 3/7-14/86).
4. SNPS SSER 1 Are STAS assigned duties which enhance S
p. 22-4 their ability to perform their STA
responsibilities?
5. SNPS SSER 1 Verify that STA involvement in S
p. 22-4 day-to-day operation of the plant
as part of their normal duties
will not interfere with the STA's
ability to assume the emergency
RTA vnle-
PREPARED BY DATE APPROVED BY DATE APPROVED BY DATE
Signcd/ approved Audit Checklists are
filed & maintained with OSD
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
6. SP 51.006.02; Does the STA Training program includc See NRB Audit B-85-1. Item E-8, NRB Audit
FSAR Sec 13 all of the elements specified in of personnel Qualifications and Training
SP 51.006.02 and FSAR Sections conducted 5/13/85-7/25/85. There has been
13.1.3.27, 13.2.1.2.8 and 13.2.1.2.9, no significant change in the STA Training
including: Program, relative to Items (a) through (g)
below
a) Specializied training in:
1) Thermohydraulics; S
2) Heat transfer; S
3) Transient & accident analysis. S
b) Basic Theory:
1) Basic fundamentals of nuclear S
and reactor engineering;
l
2) Radiation protection; S
3) Thermodynamics; S
4) Heat transfer; S
5) Principles of fluid mechanics. S
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c) Plant-specific station nuclear
l engineer theroretical training, j including:
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[#EJO QUALITY ASSURANCE DEPARTMENT
AUDIT CHECKLIST "
AUDIT NO.
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
1) Five veck CE Station Nuclear S
Engineer Training course;
2) Reactor physics; S
3) Thermal hydraulics; S
4) Core power response; S
5) Core flow determination; S
6) Thermal limits; S
7) Process computer; S
8) PCIOMR implementation; S
9) Initial fueling; S
10) Refueling outages; S
11) Startup testing; S
,
12) Power distribution control; S
,
.
13) Fuel exposure and isotopic S
i content; l
14) Fuel cycle length predictions; S
15) Fuel discharge requirements; S
16) Mid course examinations; S
_ _ _ _ -_-_-. ____ - -.
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
17) Final' examination; S
d) Plant systems / procedures training,
including:
1) Nuclear steam supply systems S
and their operation;
2) BWR steam cycle systems and S
their operation;
3) Station general operating S
procedures;
4) Written examinations. S
'e) Station general administrative
procedures, including INPO
recommendations such as:
1) Safe operation; S
2) Plant shutdown; S
3) Equipment clearance and tag S
out;
.
4) Shift turnover; S
5) Cognizance of plant status; S
6) Technical specification S
compliance status.
.
4
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
f) Plant accident / transient analysis
training, including a four week
simulator training course which
covers:
1) Basic plant operations; S
2) Plant startup and shutdown; S
3) Accident and transient S
scenarios on the simulator;
4) Classroom technical S
examination of accident
and transient scenarios;
5) Written examinations; S
6) Oral examinations. S
i
g) Simulator control manipulations,
involving:
1) Plant or reactor startup; S
,
2) Plant shutdown; S
i
3) Manual control of feedwater S
during startup and shutdown;
.
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[/E,{O QUALITY ASSURANCE DEPARTMENT AUDIT NO. ,
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AUDIT CHECKLIST a PAGE 0F
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
4) Power change greater than 10% S
due to changes in control rod
position or changes in
recirculation flow;
5) Loss of coolant; S j
6) Loss of core coolant flow or S
loss of natural circulation;
7) Loss of all feedwater. S
h) Mitigating core damage training,
including:
1) Core cooling mechanisms; S
2) Heat sources; S
3) Adequate core cooling; S
4) Recognition of inadequate S
core cooling (degraded core);
5) Recognition of accidents; S
6) Identification of transients; S
7) Core damage mitigation S
through use of emergency
procedure guidelines;
.
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44a:(Eg*O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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l NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
8) Recovery from degraded core S
condition;
9) Use of fixed /movabic nuclear S l
instruments; l
10) Degraded core effects on S
coolant chemistry;
11) Process instrument response; S
*
12) Corrosion effects; S
13) Sources of gas generation; S
14) Accident environment dose S
determination.
1) Management / Supervisor skills U There is no Management / Supervisor
training, including techniques Skills Training Program,
associated with: (Audit Finding #9)
1) Leadership;
2) Motivation;
3) Problem solving; ,
4) Decision making;
5) Organizational management
under stress;
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e
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pgg"O ,
QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST PAGE
' OF
17
Personnel Qualifications SW Ndm Pm SWu
nd Training
AUDIT OF: LOCATION:
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
Checklist C
Computer and Instrumentation
and Control Personnel
1. ANSI N18.1 Verify that the Shoreham Training A program does not exist to govern
(1971), Sec 5; Program includes elements for Activities of the " Engineer In Training."
Tech Spec, selection, initial training, (Audit Finding #9)
para 6.3, 6.4; replacement training and a
10CFR, App B, continuing program of retraining
Criterion 2 for Computer and I&C personnel
in the following positions:
f
a) Managers U a-d) Training program for management and
Supervisory personnel does not exist
b) Engineers; for any Divisions in the Shoreham
c) Supervisors; Peration Department. (Audit Finding #9)
d) Foremen; *
c) Technicians. S e) Training procedures do exist for the
Computer and I&C Sections.
2. Verify that the program elements U a) The on-the-job performance documentation
have been implemented for the does not contain complete information.
Computer and I&C Sections using (Audit Finding #2)
objective evidence such as,
results of examination and tests, b) Training folders do not contain
certifications, evaluations and on performance evaluations. (Audit
the job performance. Finding #15) %
PREPARED BY -
DATE APPROVED BY DATE APPROVED BY DATE Signed / approved Audit Checklists are filed & maintained with OSD
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# pgg'O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
Kw.n
AUDIT CHECKLIST C
PAGE OF
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
FSAK, para Select a random sample (minimum of See Tables
13.1.2.1.2 3; maximum of 10 with a mean of 20%)
of Computer and I6C Section personnel
responsible to perform work on
selected systems affecting plant
reliability and safety related
systems. By discipline, enter the
individuals names on the appropriate
table, as indicated:
*
Table C-1 - I&C Managers and
Supervisors
*
SP 41.011.01 Table C-2 - I&C Technicians
*
Table C-1 - Computer Engineers
SP C1.0ll.01 *
Table C-3 - Computer Technicians
3. Complete each table to verify that
Computer and I&C Section personnel:
ANSI N18.1- a) Meet the applicable initial U a) Of six folders reviewed, three did not
1971, Sec 4; experience, educational and have objective evidence of a High School
FSAR Sec 13 speciality training requirements; diploma or equivalent. (Audit Finding #3)
SP 41.011.01, b) Are certified in accordance with U b)l) There was a lapse of time between the
para 8.1.1; applicable requirements; expiration date of the certification
SP C1.011.01,
and the supervisor's signature. (Audit
Finding #8)
para. 8.1.2
2) The certificate form does not meet the
requirements of ANSI N45.2.6.
(Observation #13)
3) The date of certification was actually
done at a later time. (Audit Finding #8)
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A g p;g c o QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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AUDIT CHECKLIST C
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
dr 41.U11.01; c) Received required training as S c)l) Neither the job description or needs
SP C1.0ll.01, indicated by the job description assessment are in the training folders,
Sec 8.1 and needs assessment; but does exist as part of the Hay system.
2) Training needs assessment is determined
by holes in the matrix, if the person
is not qualified training is received.
SP 41.011.01, d) Have been qualified by one or U d)l) Objective evidence of completion for
para 8.2.2, more means as specified by the vendor supplied courses missing. (Audit
8.2.4; procedure and includes documented Finding #2)
SP Cl.0ll.01, evidence that all requirements 2) SPF forms not complete.(Audit Finding #2)
para 8.2.1, were met prior to the individual 3) Summary not being utilized as required.
8.2.2 being qualified; (Audit Finding #13)
SP 41.011.01; e) Folders include documentation U c)l) No self study guides (I&C). (Audit
SP C1.011.01, of continuing training and Finding #11)
Sec 8.3 retraining for each of 2) No documentation of tailboards (I&C)
the required disciplines; (Audit Finding #12)
SP 12.003.01; f) Training folders meet the U f) One individual folder did not contain a
SP 12.014.02; additional applicable resume or job application as required
requirements; (Audit Finding #7)
l SP 41.011.01, g) Are restricted from working in S g) Letters are in the file withdrawing '
Sec.8.4; any area if deficiencies in the qualification for individuals.
SP C1.0ll.01, technical knowledge or (See Observation #14)
! Sec 8.4 performance are noted. Verify
records are updated to indicate
current qualifications;
! ANSI N18.1, h) Receive ~a review of their S h) In compliance with the VP, Nuclear
para 5.5 qualification and training Operations and the Plant Manager each
l status to assess the need individual received a review. l for additional training. ! l \
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST C
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
4. SP 41.011.01, Using Table C-2 and C-4 verify that U a) Many errors were found on the I&C and
para 8.4.5; the Call Out Matrix maintained by Maintainence Sections' matrix. (Audit
SP C1.0ll.01, the Computer and I&C Section is Finding #5)
para 8.4.3, current and up-to-date. Compare b) The matrix does not include qualification
8.4.4 personnel folders against the Matrix, expiration date. (Audit Finding #5)
5. SP 12.14.04 Verify that the Computer and I&C
Sections meet their training
responsibilities as follows:
a) Provide the Training Department S a) Training courses have been developed for
with subject matter, new training both sections.
requirements and curriculum input
to be used in the development of
Section Training Programs;
.b) Review and evaluate Section S The sections also developed some of the
Training Programs for content training programs,
and technical accuracy;
c) Assure section personnel attend S c)l) Accomplished thru the use of the
scheduled training sessions. computer printout.
2) Individuals are not allowed to enter
the plant if their GET has expired.
6. SP C1.011.01 Identify types of work being S A sample of PMs, MWRs were selected and
performed by the Computer Section. reviewed to assure that the " Lead Man"
Select a sample of tasks, identify was qualified prior to the date indicated
the responsible personnel and verify on the work document.
l they were qualified / certified prior . .
to the start date.
.
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AUDIT CHECKLIST PAGE OF
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TABLE C-1
Management and Technical Perwmel Qislifications and Training (Checklist Item 3)
NMS #0 TTIUS
Attributes Caputer 6g. Ccrpiter Forerun 16C Asst 6g. I&C bg.
W. M. K11oney S. J. Krupski J. D. Graziano T. K. Carrier .
1. Brployment Application /Restane Y Y N Y
2. Education and Experience Y Y No Restene Y
a. ANSI N18.1 Not Identified Y (4.3.2) Unsat Y
b. FSAR Y (13.1.3.12) Y (13.1.3.24) Unsat Y (13.1.3.9)
c. SP 12.003.01 Y Y N Y
'
3. Initial or Replacanent Training 2 2 2 2
a. ANSI N18.1
b. FSAR Y (13.2.1.2.11)
c. SP 12.003.01
4. Contiruing Training 2 2 2 2
a. ANSI N18.1
b. FSAR ,
c. SP 12.003.01
5. Brergency Training 3 3 3 3
6. Enerwmcy Drill Participation 3 3 3 3
7. Respirator Training SP 62.032.01 N/A (1) N/A (1) N/A (1) N/A (1)
8. QA Training 1/15/76 8/14-16/78 ND 6/19-20/79
,
9. All SN1'S Training (Stamary) Y Y Y Y
(See pg. 9 for Index to Ntsrbers) hter Y-Yes, !Mio, N/A430t Applicable, or a Cmment ramber in the appropriate space.
- - _ - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _
_ - - _ _ - _ _ _ _ - _ - _ _ _ - _ _ _ __ _ _ _ _ _ _ - _ _ _ - _ - __
.
.
v -
#
Aurp;gg'O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
..mw w
*
AUDIT CHECKLIST PAGE OF
,
uwLt. t.-1
Managment and Tecimical Personnel Qualificatirns and Trairdng (Gecklist Item 3)
NAMES #D T1%ES
Attributes Plant Fhg/I&C Instrtunent Fomnan I&C Forenan
M. Villaran R. M. Bmrnun J. M. Cuminghn
1. Biployment Application /Restune Y Y Y
2. Fxfucation and hperience Y Y Y
a. ANSI N18.1 Y Y (4.3.2) Y (4.3.2)
b. FSAR Y (13.1.3.12) Y (3.1.3.24) Y (13.1.3.24)
c. SP 12.0 M 01 Y Y Y
3. Initial c ,,lacement Training 2 2 2
a. ANSI N18.1
b. FSAR
c. SP 12.003.01
4. Contiming T> 41niq 2 2 2
a. ANSI N18.1
b. FSAR
.
-
c. SP 12.003.01
5. Baergercy Training i 1 1
6. Rnergency Drill Participation 1 1 1
7. Respirator Training SP 62.032.01 N/A (1) N/A (1) N/A (1)
8. QA Training 12/2-3/80 1/15/76 1/15/76
9. All SNPS Training (Stmnary) Y Y y
(See pg. 9 for Index to Ntsnbers)
Ehter Y=Yes, N44o, N/A43ot Applicable, or a Comnent rumber in the appropriate space. ,
.
-
Q- -
#
Avpgco OUALITY ASSURANCE DEPARTMENT AUDIT NO.
.a.n w
AUDIT CHECKLIST PAGE OF
.
TABLE C-1 (cont'd)
Managenent and Technical Persmnel Qualificatims ard Training (Diecklist its 3)
NAMFS AfD Tr1US
Attributes Plmt Ehg/I6C Instnanent Forenan I6C Forman
M. Villaran R. M. Brennan J. M. & nningh m
10. Certificatim per SP12.003.01
a. For positim Iovel III Irvel II Icvel II
b. Per ANSI N45.2.6
11. Recertification/ Renewal Unsat Y Y
a. For position
b. Per ANSI N45.2.6
12. File Content per SP12.014.02
a. Training perfonnance evaluation 1 1 1
13. Fitness for Duty N 2/20/85 2/21/85
14. Safety Evaluator Training N N 12/7/84
-
.
1) No objective evidence in file.
2) No evidence of a progran.
3) See QS Audit 86-03, Informatim Not in Folder
l l Pnter Y=Yes, IMb, N/A430t Applicable, or a Cmrent nturber in the appropriate space. I l l
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-
v -
' NINE-OL
#pgco QUALITY ASSURANCE DEPARTMENT AUDIT NO.
Arna.- '
AUDIT CHECKLIST PAGE OF
.
Lu a i;. h ui dj
I&C Technician Qualification and Training (Gecklist Itan 3)
NAMES
Attributes Want, J. Nics, A.
,
5. Drill Participation 6 6
6. Fire Brigade Training N/A (2) N/A (2)
7. Bnernency Training 6 6
8. Respirator Training N/A (2) N/A (2)
9. QA Training N Y (Part I&II 9/4/85)
10. All SNPS Training (Stenary) Y Y
11. Certification per SP12.003.01
a. For position Y Y
h. Per ANSI N45.2.6 Y Y
12. Fecertification/ Renewal (eye exan) 7/22/85 11/08/86
a. For position
b. Per ANSI N45.2.6 (Supv. "ignature) 7/22/85 11/08/86
13. Training per SP41.Oll.01 7 -
-
a. Pneunatic Process Conttul Fxplignent
b. C 91 Process Canputer
,
c. Neutron Monitorir--
d. HPCI/RCIC Controls
e. Mtin Turbine DC X
(See pg.15 for Index of rumbers) Ehter Y=Yes, Mio, N/A43ot Applicable, or a Cmment runber in the appropriate space.
- - - - - - - -- - - - - - - - - - - - - - - - - - - - --- --- _ - -- -- - .
.
v +
p;gg aa.
O. QUALITY ASSURANCE DEPARTMENT AUDIT NO.
I C
AUDIT CHECKLIST PAGE " 0F '
.
.
Im5Lt. U-Z (cont'd)
I&C Technician Qualification and Training (mecklist It m 3)
_ NAMES
Attributes Ward, J. Nics, A.
13. f. Cranes
g. Reactor Protection Systs
h. ETE
INDEX
1. No Evidence of High School Dip 1ma or F 4 uivalent
2. No @jective Evidence in File
3. roes Not Identify
a. Qualified Supervision
b. Duration of TASK
4. No evidence of Miividual Study Progra
5. No evidence of a Training Progre '
-
6. See QS Audit, 86-03; Information Not Includal in Folders
7. Letter frm T.K. Carrier to Delete or Clarify Qualifications of I6C Tedts. (Denoted by "X")
(See pg.15 for Index of rusnbers) Ehter Y=Yes, N=No, N/A44ot Applicable, or a Cament nisnber in the appropriate space.
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. . .. .. ..
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. L ..
"~ ~
pgjO QUALITY ASSURANCE DEPARTMENT AUDIT NO.
'
AUDIT CHECKLIST PAGE 0F
>
Personnel Qualifications Shoreham Nuclear Power Station
and Training LOCATION:
AUDIT OF:
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
Checklist D
Radiochemistry, Radiation Protection.
Health Physics, and Radwaste Personnel
I
1" Steiger memo Is there a comprehensive system in
3/3/86 (PM place for selection, training,
DIR 86-003) qualification, retraining, and
Leonard Memo requalification of personnel
3/3/86 performing activities which affect
(VPN086-48) quality and which provides for:
,
a) Establishment of basic
qualification requirements for
initial assignment to positions;
1) Radiochemistry; S para. 8.2, SP71.006.01, Rev. 8
2) IIcalth Physics; S para. 8.1, SP61.040.01, Rev. 13
3) Radwaste. S SP21.006.01, para. 6.1, references the PSAR
and SP12.003.01 for personnel hired before
1/1/86. Otherwise, para. 8.1.2.1 applies,
b) Establishment 'f initial training
I requirements fully qualify for
assigned pos as;
1) Radiochemistry; S para. 8.3. & 8.4, SP71.006.01, Rev. 8,
2) liealth Physics; S para. 8.3, SP61.040.01, Rev. 13.
PREPARED BY - DATE APPROVED BY DATE APPROVED BY DATE
Signed / approved ?.udit Checklists are *
filed & maintained with OSD
. .
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pgjo QUALITY ASSURANCE DEPARTMENT AUDIT NO. Ns-86-ol
AUDIT CHECKLIST o
PAGE 2 OF 41
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
3) Radwaste. S SP21.006.01, Rev. 7, para. 8.1.2.10 and
8.1.3.1
c) Administration of appropriate
tests, examinations or job
performance evaluations as
evidence of satisfactory
completion of required tr.,ining;
1) Radiochemistry; S Examinations implied by para. 8.3.5,
SP71.006.01, Rev. 8; Evaluations per
para. 8.4.7, SP71.006.01.
2) Health Physics; S para. 8.2.2.3; 8.2.3.3; 8.2.4.2; 8.3.1;
8.3.2; 8.6.1; 8.6.1.5; 8.6.1.6 of
. SP61.040.01, Rev. 13 all deal with
examinations and evaluations.
3) Radwaste. S SP21.006.01, Rev. 7, para. 8.1.2.3
through 8.1.2.7.
,
'
d) Documentation of individual -
qualifications as they relate to
and meet the basic qualification
requirements for assigned
positions;
1) Radiochemistry; S SP71.006.01, Rev. 8, para. 8.2.1
& App. 12.1.
2) Health Physics; S SP61.040.01, Rev. 13, para. 8.1.1.3
& App. 12.1.
. .
_ - - - - - - - _ _ _ - - - - _ _ - _ _ - - _ _ - _ - - - - - _ - - - - _ _ _
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#pgco QUALITY ASSURANCE DEPARTMENT Na-86-01
Kmx AUDIT NO.
AUDIT CHECKLIST D
PAGE 3 OF 41
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
3) Radwaste. S SP12.003.01, Rev. 7, para. 8.1.2.9
& 8.1.3.1.1.
e) Documentation of training and
examination results to support
full qualification of each
individual in assigned positions;
1) Radiochemistry; S SP71.006.01, Rev. 8, para. 8.8
6 Appendices.
2) Health Physics; S SP61.040.01, Rev. 13, para. 8.5
& App. 12.2 through 12.6.
3) Radwaste. U See Supplemental Comment No. 3 for
Table D-3. (Audit Finding #6)
f) Written certification that each
person is fully qualified for
assigned position;
'
1) Radiochemistry; S SP71.006.01, Rev. 8: 8.4.6.2 attests to
task qual.; 8.4.6.3 attests to Div. Qcal;
8.4.6.4.3 attests to backshift .
Qualifica-
tion matrix in use but not formally incor-
porated in procedure.
2) Health Physics; S SP61.040.01, Rev. 13, para. 8.5 6 App. 12.6.
3) Radwaste. S SP21.006.01, Rev. 7, para. 8.1.2.8 and
8.1.3.1.1.
.
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-
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i
pEJO QUALITY ASSURANCE DEPARTMENT AUDIT NO.
Na-86-01 l
AUDIT CHECKLIST n PAGE 4 OF 41
NO. REFE'RENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
~
l
I
g) Written certification for SP12.003.01, Rev. 15, App. 12.4 provides
additional or collateral duties, method for Inspection / Examination
as applicable (e.g., ANSI Certificatior. (N45.2.6).
N45.2.6);
l 1
1) Radiochemistry; N/A No requirement in Radchem Program for
l *
N45.2.6 Cert.; SP12.003.01 does not
l , specify either (para. 8.1.2).
(Observation #13)
2) Health Physics; N/A No requirement in Health Physics Program
for N45.2.6 Cert.; SP12.003.01 does not
specify either (para. 8.1.2).
(Observation #13)
3) Radwaste. S SP21.006.01, Rev. 7, para. 8.1.2.10, Note,
h) Documentation of continuing
training and retraining,
1) Radiochemistry; S SP71.006.01, Rev. 8, para. 8.6.2.
2) Health Physics; S SP61.040.01, Rev. 13, para. 8.6.
3) Radwaste. U SP21.006.01, Rev. 7, para. 8.1.4.3
'
provides for refresher training, but
does not specify the frequency nor
require documentation. (Audit
Finding #14).
I
1
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# pgg'O QUALITY ASSURANCE DEPARTMENT AUDIT NO. NB-86-01
LLann.-
AUDIT CHECKLIST D PAGE 5 OF 41
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
i) Systematic review of personnel
qualification and training statur
to assess need for additional
training, retraining, testing
and recertification;
1) Radiochemistry; S SP71.006.01, Rev. 8, para. 8.6.1,
2) Health Physics; S SP61.040.01, Rev. 13, para. 8.6.I 6 8.7.1.
3) Radwaste. S SP21.006.01, Rev. 7, para. 8.1.4.2.
Steiger memo j) Prompt relief from duty or
3/3/86 (PM provisions for additional
DIR 86-003) supervision for persons whose
para. 5 qualification, training or
certification fail to meet all
current requirements;
1) Radiochemistry; S SP71.006.01, Rev. 8, para. 8.5.6.
2) Health Physics; U SP61.040.01, Rev. 13, para. 8.7.3 and Qual-
ification matrix. (See Audit Finding #5)
3) Radwaste. 11 See Audit Finding #14
l l l l l l l
.
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- . _ _ _ - _ _ -
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
NB-86-01
AUDIT CHECKLIST D PAGE 6 OF 41
-
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
k) Training, retraining, and
re-examination of persons whose
job performance so warrants, or
persons who have not performed
particular activities within
specified time periods.
'
1) Radiochemistry; S SP71.006.01, Rev. 8, para. 8.5.6 & 8.6.1.1.
2) Health Physics; S SP61.040.01, Rev. 13, para. 8.7.3 6 8.6.1.
3) Radwaste. U See Audit Finding #14
2. SP 12.003.01; From the list of personnel U See Table D-1 and related supplemental
SP 12.014.02; designated as fully qualified Health comments. (Audit Findings #3, #6 and
FSAR Sec. 13; . Physics Technicians, randomly select Observation #8)
ANSI N18.1- a minimum of three (3), or 20
1971; percent, up to a maximum of the ten
SP 61.040.01 (10), names and enter them in Table
D-1. Review each person's Training
and Qualification Folder
(SP 12.014.02) for conformance
to the applicable requirements of
SP 12.003.01, ANSI N18.1-1971, FSAR
Section 13, and SP 61.040.01. Make
,
appropriate entries in Table D-1.
3. SP 12.003.01; From the list of personnel N/A NRB Audit B-85-1 Checklist Table D-4
SP 12.014.02; designated as fully qualified and QCD Audit 85-05 included review
SP 71.006.01; Radiochemistry Technicians, and evaluation of Radchem Tech, qual-
FSAR Sec. 13; randomly select a minimum of three ifications and training. At the time
ANSI N18.1- (3), or 20 percent, up to a maximum of this audit , NB-86-01, extensive train-
.
___
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a.ax
QUALITY ASSURANCE DEPARTMENT AUDIT NO.
NB-86-01
AUDIT CHECKLIST D
PAGE 7 T 41
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
1971 of ten (10), names and enter them ing, retraining and record verification
in Table D-2. Review each person's activities were in progress in response
Training and Qualification Folder to NRC Inspections and Findings. There-
(SP 12.014.02) for conformance fore, the specific & detailed record
to the applicable requirements of reviews were not done as specified in
SP 12.003.01, ANSI N18.1-1971, FSAR Table D-2. However, in conjunction with
Section 13, and SP 71.006.01. Make Checklist Item D-12, work records and
appropriate entries in Table D-2. the Control Room Qualification Records
were reviewed against the training
records.
40 SP 12.003.01; From the list of personnel U See Table D-3 and related supplemental
,
SP 12.014.02; designated as fully qualified comments. (Audit Findings #1, 3, 6, 7
FSAR Sec. 13; Radwaste Operators, randomly 8, 14 and Observation 11)
ANSI N18.1- select a minimum of three (3), or 20
1971; . percent, up to a maximum of ten (10),
NRC Bulletin names and enter them in Table D-3.
79-19 Review each person's Training and
Qualification Folder (SP 12.014.02)
for conformance to the applicable
requirements of SP 12.003.01, ANSI
N18.1-1971, FSAR Section 13 and NRC
Bulletin 79-19 Make appropriate
entries in Table D-3.
5. Reg. Guide Does the designated Radiation S Item 7 on Audit Checklist A from NRB
'
1.8 Protection Manager (RPM) meet Audit B-85-1 verified that the RPM met
the qualification and experience Reg. Cuide 1.8 requirements. The same
requirements for working at a person still has that designation. The
nuclear power plant, as stipulated Tech. Specs. are inconsistent in that
in Regulatory Guide 1.8, i.e.: 6.3.1 specifies that the Health Physics
Supervisor shall meet the requirements of
.
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pgjO QUALITY ASSURANCE DEPARTMENT AUDIT NO. Na-86-Oi j
AUDIT CHECKLIST D PAGE 8 OF 41
.
I
-
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
a) Five years total experience in S Reg. Guide 1.8, whereas 6.12.2 and Fig,
applied radiation protection; 6.2.2-1 refer to the Health Physics
Engineer, (which is the correct title).
b) Three years experience in applied S SP12.003.01, Rev. 15 correctly shows
radiation protection dealing with the HP Engineer as the RPM per Reg. Guide
matters similar to those at 1.8. (Observation #4). Also see Table
nuclear power stations; D-4, Comment 8 and Audit Finding #6
1
6. 10CFR, App. B Is there a training program for U See Audit Finding #9. (No program
l
Crit. 2; management and technical personnel, in place).
ANSI N18.1- and does it meet the requirements
l
1971; specified in ANSI N18.1, FSAR and
I the applicable station procedures? l '
7. SP 12.003.01 Identify management and technical See Table D-4 and related supplemental
. personnel assigned to the following comments,
positions and enter their names and
job titles in Table D-4.
l l a) Rad Chem. Engineer; N/A Jongbloed is acting, pending takeover by l consultant.
b) Nuclear Staff Specialist (s); S See Table D-4.
.
c) Rad Chem. Support Supervisor; N/A See Table D-4. Position not addressed
l in SP12.003.01.
d) Chemical Engineer; N/A Position vacant.
e) Chemist; N/A Position vacant.
f) Rad Chem. Supervisor; N/A Position deleted (SNRC-1245, 4/3/86,Att 2).
i
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#pEco QUALITY ASSURANCE DEPARTMENT AUDIT NO.
Na-86-01
kam.n
AUDIT CHECKLIST D
PAGE 9 OF 41
.
_
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
g) Rad Chem. Operations Foreman; U Only title in use currently is Foreman;
See Org. Chart dated 4/1/86. Also see
Table D-4. (Audit Finding #7, #9)
h) Analytical Services Foreman; N/A Only active Foreman on 4/1/86 Org. Chart
is Varinos. See Table D-4.
1) Health Physics Engineer (s); U See Table D-4, Supplemental Comment 8.
i (Audit Finding #6)
j) Health Physics Supervisor; U See Table D-4 Supplemental Ccmment 7. l
(Audit Finding #6)
k) Alara Engineer; N/A Position vacant.
.1) Health Physics Foreman; S See Table D-4.
m) Radwaste Engineer (s); S See Table D-4.
n) Radwaste Shipment Coordinator. S See Table D-4.
8. SP 12.003.01; Review each person's Training and U See Table D-4 and related supplemental
ANSI N18.1- Qualification Folder for conformance comments. (Audit Findings #6, #7, #8 and #9)
1971; to the applicable requirements of
SP 12.014.02 the FSAR, ANSI N18.1-1971 and the
Technical Specifications, including
certification in accordance with
Appendix 12.4 of SP 12.003.01.
Complete Table D-4
.
__
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__ --
.
U .
v
Ns-86-01
[mwpgc0 QUALITY ASSURANCE DEPARTMENT AUDIT NO. j
AUDIT CHECKLIST o PAGE 10 0F 41
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
9. Record names of the instructors
i used within the past year for the I training, and coordinate verification
of their qualifications with auditors
performing audit QS-86-03.
a) Radiochemistry; N/A a) Contractor personnel; Contractor
course.
b) Health Physics; N/A b) Names furnished.
l
c) Radwaste. N/A c) Names furnished. l
l t0. For each of the following types of
. training, verify that the lesson
plans in use define the purposes,
prerequisites, training objectives, ,
materials to be covered, session j
duration, and examinations to be '
given:
a) Radiochemistry Training; N/A a) Not reviewed,
b) Health Physics Training; S b) See supplemental comments and
Observation #2.
c) Radwaste Training. S c) See supplemental comments and
Observation #2.
*
,
.
- - - - - - - - - - - - - - - -
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- - - - - _ _ - _ - - - - _ _ - _ -
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Ns-86-on
4 4 r / E c, o.-
AUDIT CHECKLIST o PAGE 11 OF 41
,
l
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS l
ll. NOC Policy 21, Verify that lesson plan content
para. 4.2.6.3 has been reviewed and approved
by the appropriate supervisor
from the trainee organization;
1
a) Radiochemistry; N/A a) See comment at Item 10(a) above,
b) Health Physics; S b) Of five lesson plans selected for
review, all were approved by the HP
Eng. (HP-Inst-2, Rev. 2 and HP-Inst-3,
Rev. O, both signed 8/7/85; HP-RC-1,
Rev. 3, signed 11/15/85; HP-RC-5,
Rev. 3, signed 11/4/85; HP-RC-8, l
Rev. 1,' signed 1/9/84
.c) Radwaste. S c) Four lesson plans selected were approved
9 by M. Pechin as the subject matter
expert. Even though he was not
assigned to operations at the time
of signature, this may be considered
acceptable. Also see Observation #2
12. , For the Radiochemistry Section, U See supplemental comments. )
identify types of work currently (Audit Finding #8 and Observation #16)
being performed for which there are
specific classroom or on-the-job
,
training and qualification
l
i
requirements. Examine a sample of
the records maintained for those
types of work and identify individ-
uals who performed such work.
Compare information from work
.
_. . _ . ...m
.I
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. ..
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. . -_ _ _ __ . _ _ _ _ _ _ . _ - - _ _ _
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[/E,C"O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
ns-86-01
AUDIT CHECKLIST D PAGE 12 0F 41
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
records with information from
training records and verify that
personnel are fully qualified for
the tasks performed. (Document
results in supplemental comments to
this checklist.)
L3. For the Health Physics Section, U Records of 44 activities were examined,
identify types of work currently with dates ranging from 4/20/85 to
being performed for which there are 4/9/86, and involving 16 HP Techs.
specific classroom or on-the-job in five types of work (areas).Four
training and qualification (4) activities were found which
requirements. Examine a sample of require further documentation. See
the records maintained for those supplemental comments for additional
types of work and identify details. (Audit Findings #1 and #5)
. individuals who performed such work.
Compare information from work
records with information from
training records and verify that
personnel are fully qualified for
the tasks performed. (Document
results in supplemental comments to
this checklist.)
l4. For the Radwaste Section, S See supplemental comments.
identify types of work currently
being performed for which there are
specific classroom or on-the-job
training and qualification
requirements. Examine a sample of
the records maintained for those '
types of work and identify'
_ _ _ _ _ _
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.
QUALITY ASSURANCE DEPARTMENT N8-86-01
[.#Ed"O
mauraauv AUDIT NO-
AUDIT CHECKLIST D
PAGE 13 OF 41
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
individuals who performed such work.
Compare information from work
records with information from
training records and verify that
personnel are fully qualified for
the tasks performed. (Document
results in supplemental comments to s
'
this checklist.) .
L5. Review the status and responses to QCD is monitoring progress closely.
the following corrective action Radchem personnel appear to be working
items resulting from QCD Audit 85-05 diligently to complete necessary corrective
and provide an evaluation of the action. Specific status as follows:
effectiveness of their resolution:
- ,a) QCD Audit Finding 85-05-43 S a) Finding not resolved; CAR 86-005 issued
to escalate attention to resolution.
Additionally, LDR 86-034 was issued
to document a new problem.
b) LDR 86-034 S
h) Procedure not revised as of 4/11/86 and
SPCN 86-05-93 was still not submitted.
Before the audit report was issued.
Plant Manager approved the revised
procedure to become effective 4/16/86.
c) CAR 86-005 S c) Dated 1/27/86; still open. Extensive
rechecking and verification is underway,
d) QCD Audit Finding 85-05-44 S d) Open since 7/15/85; completion date of
-
3/31/86 not met. Request 3/28/86.from
Plant Mgr.for extension to 4/30/86.
_ _ _ . _ - - _ .
.
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[#EJO -
QUALITY ASSURANCE DEPARTMENT AUDIT NO. Na-86-01
AUDIT CHECKLIST D PAGE 14 0F 41
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
e) QCD Audit Finding 85-05-45 S e) QCD verified satisfactory completion
and closed out 12/30/85.
16 10CFR50 Are training procedures and
Appendix B training materials subject to
Criterion 6,17 appropriate document control
processes, including:
a) Review and approval by S As noted in Item 11 above.
appropriate authority;
b) Review and approval of changes S As noted in Item 11 above.
by appropriate authority;
c) Limited distribution of certain S Examination materials are kept in a
materials to protect the locked file in a locked room. Exams are
integrity of examinations. retrieved and returned to locked storage
when test sessions are done,
l7 10CFR50 Are training records retained in S ANSI N45.2.9 is cited as basis for record
Appendix B permanent plant files for the retention. Active training files are
Criterion 17 specified time? maintained in controlled storage in
training department. Other records are
sent to SR-2 for microfilming and retention.
(Note: verification of storage facility was
beyond the scope of this audit.)
.
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pem n- QUALITY ASSURANCE DEPARTMENT AUDIT NO.
"I
AUDIT CHECKLIST o
PAGE IS OF 'l
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Supplanental Crrrents For Audit Gecklist Itas Indicated:
Gecklist Item 10
a) Imsson Plans were reviewed for five (5) courses OfP-INST-2; HP-INST-3; HP-IC-1; HP-RC-5; HP-EC-8). All had a
defined purpose, training objectives, description of materials covered, and session duration. Four (4) of the
five (5) had prerequisites defined where appropriate; the remaining one OIP-RC-8) should have defined
prerequisites but did not. Nme of the five (5) Irsson Plans contained requirarents or guidelines for
a&dnistering exaninations and none had any criteria for grading or achieving successful empletion of the
training. (& servation #2)
b) Radwaste lesson Plans differ slightly fmn the attributes covered by this question although they contain the
information necessary for the intended purpose. %e purpose is called the " scope"; prerequisites are not
specifically stated; training objectives, materials to be covered x4 session duration are all specified; tut
there is no clear indicatims that exaninations are to be given. Also there is no forml lesson plan for
Bulletin 79-19 Training. (@servation #2)
Gecklist Item 12
a) A review of training folders and the qualification matrix for selected Radiochenistry technicians rewulted in the
following cm ments:
1) Station Ihployee Training Sunmary for Radiochenistry Technicians (non-mandatory form) contained in the -
training folders identifies Base 3 training as "BW1 System Genistry" while the definiticri of Ihase 3
training identified in SP 71.006.01, Rev. 8, para 8.3.2 states "BWR System Training". % e sunmary form in
the training folder should be revised to feflect "BW1 Systens Training" per SP 71.006.01.
2) Ee qualification matrix includes a colum identified as "BWR", the dates that are in this colum are the
sane dates as those in the " Phase III" oclunn, with the following exceptions:
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AUDIT NO.
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PAGE 16 C)F 41
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"BWR DATI?' " PHASE III DNIT'
B. Donegan 09/24/82 09/30/82
M. Juliano 01/27/84 07/01/83
S. Sprengel 02/06/82 03/01/82
SP71.006.01 does not identify requimnents for "BWR" training separate fmn the B'a Systerns training, which
is already identified as Ihase III. It is suggested that a review be mxle of the differences in dates arti
that tha "Ik'R" colten be rernoved fmn the qualification m,trix since it is not required.
3) On the qualification matrix, B. Donegan is shown to have crupleted Ihases I and II on 8/25/82. The
" Completion of Initini Training Ihases" form in the training folder identifies Phases I and II as '7ttiti Arp.
Institute Training" ccmpleted in 8/82. SP 71.006.01 para 8.3.4 allows NTHNPS training progrars similar in
content to those required by the procedure to be substituted provided the Rallochanistry Ihgineer and the
Training Supervisor review the progran and determines it to be equivilmt and acceptable. It is suggested
that the prucedure be revised to indicate how such reviews of similar progrars are to be performed and
doctanented. (See Observation 16)
b) As of 4/14/86, the qualification matrix showed that no Radchem Techs were qualified in any Division (I through V)
and none were qualified for backshift duties. According to the rules alopted earlier this year, all work
requiring qualified Radchem Techs. was to be done under the direct supervision and urrier the responsibility of a
forernen or supervisor. However, based on a sarpling of Radchem work required by Technical Specifications, it was
not clear that such direct supervision had been involved, i.e., the supervisor did not co-sign the worksheets but
only signed as having reviewed ed approved the result. This has been discussed between QW and Radchein '
personnel and Q@ has re ----- 'el action to clarify the significance of the supervisor's siS nature relative to
actual supervision of the work.
c) A general problan exists on Radchen Techs Exanination/ Inspector Certifications (SP 12.003.01), in that the eye
test date and the certification date are not the sane. (See Ax11t Finfing #8).
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hpggo. QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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Geck 11st Itsn 13
Of 44 Health Ihysics work activities reviewed, covering a period from 4/20/85 to 3/1/86, elevm were perfonned and
signed off by persons whose training records did not show evidence of current qualification in the specific work area
involved. Of these, six persons are specifically identified in memos dated 2/20/86 as having perfoured these types of
work under qualified supervision during the period frcra 0/1/85 to 1/31/86, and one was found to be a forann at the time
the work was perfonned. (Forenen are not required to be certified.)
a) h remaining four items which are indicative of the need for further doctnentation, are:
I
1) Instrunentation calibration mrk perfonned on 12/5/85 by a technician who becme qualified on 2/24/86.
2) Internal / External Dosimetry work perfonned on 4/20/85 by a technician who becse qualified on 7/8/85.
3) Respiratory Protection work performed on 12/18/85 by a technician whose certification for that work expired
on 11/17/85.
4) Instrunent calibration work perforwd on 2/22/86 by a technician who becse qualified on 2/24/86.
(See Audit Finding #1)
b) h specific discrepancies described above are as follows, listed by qualification typ:
* .
Instrunentation Repair and Calibration
IZ12-100RM14-5207 calibrated by G. Rice on 10/2/85 (Q12/21/85)
1Z12-1004960%403 calibrated by K. Miles cn 12/5/85 (Q-2/24/86)
IZ12-10am-0324 calibrated by R. Bmner on 2/22/86 (Q-2/24/86)
,
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a.ng'O
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Respiratory Protection
IZ12-1206A-17M inspected by J. Boaz 1/24/86 (Q-2/20/86)
IZ12-12GEA-37M inspected by J. Boaz 1/7/86 (Q4/20/86)
lZ12-120sA-8m inspected by G. Accattato 2/3/86 (qume)
IZ12-120 EA-26PD inspected by A. Nielson 12/18/85 (Qv_xpired 11/17/85)
lZ12-120SCBA-0006 inspected by G. & beta 3/l/86 (QWone)
Intemalchtemal Dosinetry
D001CRB calibrated by S. Klingler 9/6/85 (QWme)
D005CRB calibrated by J. Boaz 10/2/85 ((Mtme)
D0002RY calibrated by D. Bcumer 4/20/85 (Q-7/8/85)
.
It should be noted that prior to the start of this audit, the Health Physics Section determined that unqualified
technicians, who were performing work under the supervision of a qualified tecluticim, were signing work records. The
failure of the qualified technician to countersign the work records was a generic problem for which preventive measures
were prescribed in FM DIR 86-003, dated 3/3/86 (Itan 5). Rirthermore, several handwritten memos were presented which
doctamted records tuviews and verifications, for work ccmpleted between 8/1/85 and 1/31/86, which showed that the work
was performx! under the direction of qualified supervision. Following review of these menoranda, it was observed that ]
five persons, one of whom was a forumm, involved in the eleven work items cited were not specifically covered'by the *
)
nenos.
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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PAGE 19
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41
.
.
1 It is also icportet to note that IDR 86-078, dated 2/24/86, IDR 86-123, dated 3/21/86, and IDR 86-124, dated 3/21/86,
identified similar problems with training records for various HP Technicians. Fb11 inp1mmtation of the qualification
ed training matrix systen instituted by Itf DIR 86-003, dated 3/3/86, is expected to eliminate these types of problems.
However, to the extent that training records deficiencies identified in this audit are not already covered by existing
mrrective action doctanents, further corrective action is required. (See Atxlit Finding #1)
c) 'Nmty-five qualification dates for 16 HP Techs involved in the work smple discussed above were checked against
the Control Rom matrix dated 4/7/86,
1) For Carrtil, the matrix shows the requal, date for Rt! Control as 12/21/87; training records indicate it
should be 2/21/87.
2) For Exx!, the matrix shoe the requal, date for Rad Cmtrol as 12/23/87; training recortis indicate it should
be 12/21/87.
(Audit Finding #5)
Gecklist Item No.14
a) Pive (5) actual Radwaste shipnents have been made in 1986. The records for 86-06 were examined mi it was noted
that an Ehgineer-in-Training had signed off certain checklists from procedure TP R3.713.01 and SP R2.713.30 which
deal with radwaste container control and with handling and storage. 'Ihe TP incorporates a vendor procedure as -
the primary controllirg doctanent. No problem was noted since the checklists signed by the Ehgineer in Training
(HIC Handling and Storage Checklist and HIC log) were to document his actions in signing a radwaste container out
of varehouse for use. This action was countersigned by a GI) inspector. Radwnste managenmt stated that the
functions performed and the activities signed for are primarily administrative and can be done by anyone in the
~
section. Also, the titles used in the vendor procedure are not to be confused with similar position titles
vithin LIIID.
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A#n/E-. g'O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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PAGE 2
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b) Training records were reviewed for Radwaste Operators and the results were documented in Table D-3. In addition,
. the Ralwaste Operator training matrix located in the Control Room was checket" against the varirus qtnlificatim
elenents and dates utilized for Table D-3. Ecsults of those mtrix reviews are also doctsmnted in the
Supplanental Ctanents for Table D-3.
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST PAGE OF
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uuu. u-a (cont;d; -
Health Physics Technician Qualification and Training (Checklist Itmi 2)
.
NME
Attributes
Boaz Miles Pettinari Nielson
13. f. Qualification /Remalification Record Y Y Y Y
-
.
*
.
.
.
Biter Y=Yes, IM30, N/A430t Applicable, or a Cament rmber in the appropriate space.
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.
w w
a
(Ed'"O QUALITY ASSURANCE DEPARTMENT "
. a. AUDIT NO-
AUDIT CHECKLIST o
PAGE
27
0F 'l
.
.
_
Table 1 (cont'd)
Health Physics Technician Qualification and Training (Orcklist Its 2)
Supp1 mental Crrments
1) For Attrilutes 5,6,and 7, there isn't any doctanentation in any of the folders revie.ed. 'Ihese records are ,
located in the progra files; not in individu.u files. (See Audit Finding #6).
2) SP61.040.01, H.P. Tech. Qual. Picy,u-,, classifies a level I higher than a IcVel II. 'Ihis is contrary to ANSI N45.2.6
and could cause confusion (See Observation #8).
3) Fbnctional Areas of qualification on training folder irricx and sections do not correspond with Ebnetional Areas
of qualification frm H.P. Tech. Qualification /Requalification Record, (Appendix 12.6 of
SP61.040.01). (Observation #8)
4) For T. Markey, the training progra records index indicates he cmpleted Ihvie III Cert./BWR Training; hmever, there
is in evidence, (certificate of cmpletion) in his folder. (See Audit Finding #3).
,
.
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_ _ - _ _ _ - - _ _ - - _ - _ - _ _ _ _ - - - _ _ . _ - - - _ - - _
-
v - . .
#pgc QUALITY ASSURANCE DEPARTMENT I
Avn o ;.
AUDIT NO.
AUDIT CHECKLIST D
PAGE 3 0F 'l
-
TABLE D-3
Rachmste Operator & Tecimician Qualification and Training (mecklist Itm 4)
NAMFS
Attributes
Hanberger Wlansky &cihn
1. Hmlovcent Application /Remsne N (10) N (10) N (10)
2. Education & Bcperience - - -
a. ANSI N18.1 N/A N/A *
N/A
b. FSAR 13.1.3.23 H.S.1 yr. Power Plant Y Y Y
c. SP 12.003.01 Y (2) Y.(2) Y (2)
3. Initial or Replacenent Training - - -
a. REI N18.1 (Refers to Licensee Progran) (1) (1) (1)
b. FSAR (No Specific Radwaste Training) N/A N/A N/A
c. SP (1) (9/29/83 Radunste Systens) Y Y Y
d. Training Perfonnance Braluation Cold Lic. 2/11/85 Cold Lic. 2/11/85 (12)
e. Exanination Cold Lic. 2/11/85 Cold Lic. 2/11/85 (12)
4. Retraining - - -
'
a. #GI N18.1 (Refer to Licewee Progran) (1) (1) (1)
b. ESAR (No Specific Radweste Training) N/A N/A N/A
c. SP (1) See Iten 13 See Iten 13 See Iten 13
d. Training Perforence Braluation
e. Wrk Perform nce Evaluation
f. Ex;rtination
Ehter Y=Yer, N No, N/A4bt Applicable, or a Ocunmt mmber in the appropriate space.
______- _ _ _
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Arpggo QUALITY ASSURANCE DEPARTMENT AUDIT NO.
.
AUDIT CHECKLIST D
.
PAGE
33
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4
TABLE D-3 (cont'd)
Radvaste Operator & Technician Qualification and Training (Qiecklist Item 4)
NAMFS
Attributes .
*
Ruberger Wlatsky Mrilan
5. Drill Participation (See 6 & 7 below) - - -
6. Fire Brigade Training (Qtnl. State. & Ihy.) (5) (8) (13)
7. E*rgscf Training (ITD: 86-0147) Y 3/25/86 Y 3/25/86 Y 3/25/86
8. Respirator Training SP 62.032.01 In Prwran File
I '
9. QA Training Y 5/15/85 Y 12/17/80 Y 8/13/81
10. All SNPS Training (Stamary) (4) (4) (4)
11. Certification per SP12.003.01 - - -
a. For positim Y 4/2/86 (11) N (15)
b. Per ANSI N45.2.6 Y Is. I Y la. I (14)
12. Recertification/ Renewal - - -
a. For positim N/A N/A N/A
b. Per ANSI N45.2.6 (6) (9) (14)
13. Training per NRC Bulletin 79-19. Ites 5 & 6 (3) (3) (3) -
a. Selected Procedures (12 hrs.) Not In File Not In File Not In File
b. Ownistry (4 hrs.) Not In File Not In File Not In File
c. Ikg. Transfer, Ship.-Solid Este (24 hrs.) Y Y Y
d. Buninations (3) (3) (3)
e. Designate Persons Resposible (7) (7) (7)
.
Ihter Y=Yes, N43o, N/A=Not Applicable, or a Ocnnent mmder in the appropriate space.
.
__-__ - _ _ - - - - _ - - _ - _ _ _ _ . _ _ _ _ _ - .__
-
v w ,
I
Avg QUALITY ASSURANCE DEPARTMENT AUDIT NO.
-- (O
AUDIT CHECKLIST o
PAGE 32 0F 'l
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.
Table D-3 (cont'd)
Radwaste Operator & Technician Onlification and Training (meck. list Its 4)
Supplemmtal Omnents
1) We current procedure for Radwnste Operator Training is contained in SP21.006.01, Rev. 7. Ikwever, this procedure
applies only to persons hired after January 1,1986. %erefore, there are no cirrparable criteria against which to
audit for those persons who began their qualification process earlier. In addition:
I
a) %ere is no specific frequency stated for continuing training and retraining, and nn'requimnent to doctament
1 such training (Checklist Itm 1-h-3).
b) %ere is no provision to relieve persons fmn duty following an unsatisfactory evaluation of proficiency
,
(Gecklist Its 1-j-3). De training matrix concept could be used for monitoring this but it is not in the
approved procedure.
I c) Rete is no specific provision to use the amual evaluation of Radwnste Operator performnce as the basis for
training or retraining (mecklist Itm 1-k-3).
j (See Audit Finding #14) ,
2) SP12.003.01 treats Equipment Operator and Radwaste Operator the sme, for purposes of initial qualification and
selection.
'
3) Required information on Bulletin 79-19 is in the Progrm Files but is not in the individual training files. (Audit
* -
Finding #6)
4) %ere are several sunmary pages in the training folder which represent duplication.
.
l l l
- - - - _ _ _ - - - _ - - _ _ - - _ - - _ - _-_ _ - _ _ - - - - - - - ._- .
*
~ - .
"
gpgg'O n.uc.w w
QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST o PAGE 33 0F 'l
.
' -
5) Training records show Itaberger's last Fire Brigade qualification notice dated 12/29/83, and the last physical ex m
for strenuous activity dated 1/7/85. The matrix shows new physical due 12/16/86. h Medical Certifications are
inconsistent with regard to his social security ntsnber md birth dates (Chservation #11).
6) Imvel I certification is dated 4/2/86, whereas the eye test is dated 12/16/85 (lknberger). The Control Rocm
matrice correctly shows eye test due date of 12/16/86.
7) There is no informatim in file to indicate that any particular person has bem designated in writing as having
responsibility for " safe traisfer, packaging and transport of low level raficactive material". However, according
to the Radwaste Digineer, SPRI.001.01 so designates those persons by positim title (Dull. 79-19, Itan 3).
8) Last notice of Wlansky's qualification for Fire Brigade is dated 12/29/83; last physical exima for strenuous
exercise is dated 11/27/85. h control Room matrix correctly shows new physical due date of 11/27/86. See
Canent 16 below.
9) Icvel I certification for Wlansky is dated 4/2/86, whereas the eye test is dated 11/27/85. The matrix correctly
: hows the next eye test is due 11/27/86.
10) Restrnes in folder are not up to date (Audit Finding #7):
a. Hmberger's restane is dated 4/13/81
.
b. 21 ensky's restune is not dated.
. .
c. Hocilan's restne is dated 8/17/81 but has a applement which was apparently prepared in 6/83.
11) Form for Wlansky position certification has an undated pen aid ink chg shcwing Radwaste Operator crossed out
and Nuclear Staff Specialist (Radwaste) written in. However, it was later learned thit this appointment was not to
be effective until 4/21/86. '(See Audit Finding #3).
.
.
. _ _ _ __ ._-
.
v v .
I
k.pgc0 QUALITY ASSURANCE DEPARTMENT AUDIT NO.
- - .
AUDIT CHECKLIST o
PAGE 34 OF 'l
l
.
_
12) "Ihe ED area qualification record for Neilan is not ccmplete mr is it readily interpretable. For tle Radwaste
- Building and the Radweste Control Rom, sczne dates have been handwritten in, other dates (all 10/14/83) have been
rubber staped. There is no one-to-one correlation betwen the dates entem! and the 25 item for Radwnste.
i Likewise, there are no initials to identify who checked this person out, h area certificate is dated 10/11/84
and approved 11/20/84. h Control Rom mtrix shows the area certificate dated 11/20/84. (See Axlit Finding #1
for similar types of problens).
13) last notice of qualification for Neilan for Fire Brigade is dated 12/29/83; last physical exm for strermous
activity is dated 11/29/84. Fire Brigade Member Requalification printout for 1984 armi 1985 does not show evidence
of requalification (&cilm). h Control Rom matrix shows the next physical due on 11/29/85. See Comment 16
belcu.
14) meilm was originally certified as Icvel I on 3/20/84, with eye exm dated -9/20/83. Recertification is dated
3/18/85, with eye ex m dated 11/27/85. Matrix shows new eye test due 2/22/86. (See Axlit Finding #8)
15) "Ihere is no position certification in the file for &cilm as a Radwaste Operator. 111s last position certificatico
as F4 uipnent Operator is dated 3/18/85. (See Axlic Finding #3)
1h) According to Cmtrol Rom persomel ext V. Fallacara, Radwaste Operators presently are not required to be qualified
4 for Fire Brigade.
. -
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AIwpg g'O QUALITY ASSURANCE DEPARTMENT '
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AUDIT NO.
AUDIT CHECKLIST D
PAGE 37 0F 'l
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TABLE D-4
P&e._.t and Technical Persmnel Onlifications and Training (Owxklist Iters 7 and 8)
NAMES AND TIRES
Attributes '
i) H.P. Eng. j) H.P. Supv. k) AIARA Eng. (1) HP Forman
N. DiMascio M. Donegan Vacant R. 'Ihmpson
1. 15cloycent Application /Restsne Y Y -
Y
2. Educatim and Experience - - - -
a. ANSI N18.1 Y Y -
Y
b. ESAR N (8) Y -
Y
c. SP 12.003.01 N (8) Y -
Y
3. Initial or Replacenet Training - - - -
a. ANSI N18.1 Y Y -
'l
b. ESAR Y N (7) -
Y
,
c. SP 12.003.01 Y N (7) -
Y
4. Contiming Training - - - -
a. ANSI N18.1 Y Y -
Y
b. ESAR Y Y -
, Y
c. SP 12.003.01 Y Y -
Y
5. Bnergency Training Y Y -
Y
6. B+%--(j Drill Participatim Not In Folders Not In Folders -
Not In Folder
7. Respirator Training SP 62.032.01 Y (Exmption) Y (Exsptim) -
Y
8. OA Training Y Y -
Y
9. All SNPS Training (Stsunary) Y Y -
Y
Ehter Y=Yes, N43o, N/ knot Applicable, or a Carnent rum 6er in the appropriate space.
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g/Eg*O .-
QUALITY ASSURANCE DEPARTMENT AUDIT NO.
i AUDIT CHECKLIST o
PAGE 'l OF 'l
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Table D-4 (cont'd)
Management & Tecimicial Persomel Qualification and Training (Gecklist Itms 7 & 8)
Supplerrental Ccuments
1) ANSI N18.1-1971, para. 4.6.2 identifies Staff Specialists and specifies some general qualification requitwents.
Although the duties of this Nuclear Staff Spechlist do not appear to be related to those identified in the ANSI
Standard, the job title may require clarification to avoid any conflict between the Standard and SP12.003.01.
2) Petricek's restsne dated 3/4/86 is not ccmpleted in that his actual arployer, job titles and job assigments are not
shown for the period frtmi July,1978 to the present. (Audit Finding #7)
, 3) Petricek's folder contains an tmdated certification for the position of thgineer, and a certification as Radchem
Engineer, dated 12/23/84. 'Iherefore, there is no valid certification for the present position, but SP12.003.01
l does rot specify this position.
4) h level III certificate for Petricek is dated 2/25/06 (neming 2/25/86) but the eye exmination is dated 5/31/85.
(Audit Finding #8) .
5) h restre for varinos has a date of 3/4/86 typed onto a zerox copy. h position frun May,1985 to presmt is
j Foremen, Radchem Section. However, his certification (SP12.003.01) for that position is dated 3/1/86. (Audit
Finding #7)
! 6) 'Ihere is no training progran specified for supervisory persomel (Petricek ed Varinos). (Audit Finding #9) '
7) Required training doctanentation is not in Donegan's training folder. (Audit Finding #6)
8) h records for DiMascio's training to satisfy the FSAR requirements for HP Ihgineer are not sufficiently clear to
j support an affirmation determination' that he is fully qualified. (Audit Finding #6)
i
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Men# /g(O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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AUDIT CHECKLIST e ' 16
PAGE OF
Personnel Qualifications
* * " " " ' '
AUDIT OF: LOCATION:
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
Checklist E
Maintenance and Modification
Engineering
1 10CFR App. B Verify that training programs for U There is no objective evidence
Criteria 2 management and technical personnel 'to verify that a training program
ANSI N18.l(1971) are being implemented and meet the exists for:
requirements specified in ANSI a) Management and supervisory
NIS.I. FSAR and the applicable personnel,
station procedures for:
b) Engineers in training. Note there
a) Maintenance are no written guides which define
what tasks they are allowed to
b) Modification Engineering perform or under what type of
supervisi n. (Audit Finding #9)
2 Select a random sample (minimum of
3 maximum of 10 with a mean of 21%)
of A & B Mechanics and Welders who
are designated to perform safety
related activities. Enter the A
& B Mechanics on Table E-1 and the
Welders on Table E-2. Complete the
tables to verify the Mechanics and
Welders; See Tables.
SP31.001.01 a) Meet the applicable initial U a) Minimum Educational and/or prict
Sects. 5.1 & 8.2 experience and educational experience is listed on individual
FSAR 13.1.3.25 requirements. resumes.
ANSI N18.1
para. 4.5.3
PREPARED BY -
DATE APPROVED BY DATE APPROVED BY DATE
Signed / approved Audit Checklists are
filed & maintained with OSD
_- . _ _ _ _ -
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
AUDIT CHECKLIST E
PAGE 2
0F 16
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
b) In two folders there was no evidence
of high school (applications were placed
in files). (See Audit Finding #3)
c) See comment for 2b) below.
FSAR 13.2.1.2.4 b) Participate in the Mechanics U The areas of non-compliance have been
SP31.001.01 Training and Qualification *
identified by QC in QC Audit Finding
Sect. 8.1 Program. 85-08-15. (See Observation #3)
SP31.001.01 c) Are qualified to perform work U a) QC Audit 85-08 identified the same
para. 8.2.4.3 within their job description areas of non-compliance in Findings 12,
when training has been completed 18 and 20. (See Observation #3)
or waived prior to performing
'
activities independently, b) A-1 Mechanic's resume did not contain
adequate information for certification
(GREYTAK). (Audit Finding #2)
f
c) The training matrix in the foreman's
office contained errors. (Audit Finding
#5)
SP32.001.01 d) Have a training needs survey S Training files contain Training Needs
para. 8.2.4.1 (Appendix 12.6) completed by the Surveys.
Maintenance Engineer to outline
required training.
SP31.001.01 e) Meet the job specific training U The training files for the individuals
para. 8.2.10 requirements (Appendix 12.7 and selected did not contain job specific
12.8) as designated by the Main- requirements as delineated by Appendix 12.7
tenance Engineer or Coordinator. and 12.8. (See Observation #3)
; SP31.001.01 f) Participate in on-going refresher N/A All training has not been completed for the
l Sect. 8.2.11 training and the Required Reading individuals selected for review.
and 8.2.12 List Program. -
_ _
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NB-86-01
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# QUALITY ASSURANCE DEPARTMENT AUDIT NO.
4Lv.(.Ec0
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AUDIT CHECKLIST E
PAGE 3 OF 16
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
SP31.001.01 g) Have been evaluated by written S Verified that the training file for each
Sect. 8.4 examinations, oral examinations individual reviewed, an evaluation had
or practical demonstrations, been conducted in accordance with one
of the three methods indicated.
'
3 SP31.001.01 Verify that Maintenance personnel U Performance evaluations are not included
Sect. 9 & 10 have completed all training required as part of the file. (Audit Finding #15.)
and received a performance evaluation
during their sixth month of training
by the Maintenance Engineer prior
to being assigned to the Maintenance
Staff.
4 SPI 2.014.02 Identify Management and technical U See Tables. (Also see Audit Finding #6
personnel assigned to the following regarding Emergency Training and Drills.)
positions and enter their names and
job titles in Table E-3,
a) Maintenance Engineer
. ,
b) Engineer
c) Maintenance Supervisor
d) Maintenance Foreman
e) Weld Supervisor
.
f) Outage Engineer
g) Modifications Engineer. .
4
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Ada.pgc0 QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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AUDIT CHECKLIST E
PAGE 4 0F 16
.
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
S SP12.003.01 Review each person's Training and U a) The certification expiration date in
FSAR Sect. 13 Qualification Folder to verify based on the expiration of the eye
ANSI N18.l(1971) conformance to the applicable exam. In most instanct2 the super-
SP31.001.01 requirements including certifica- visor's signature was beyond the eye
Sect. 8.4 tion in accordance with Appendix exam date. (See Audit Finding #8.)
SP12.014.02 12.4 of SP12.003.01.
SP12.014.05 b) The Outage Engineer and Modification
Engineers' folders did not contain a
position qualification. They were later
placed in the folders by the training
department. (Item closed)
6 SP31.001.01 Select a sample of contract per- N/A This attribute was included in the scope
para. 8.2.3 sonnel assigned to the Maintenance of QC Audit 85-08.
Division and verify the Maintenance
Engineer has received:
a) Written confirmation that per-
sonnel meet the experience
requirements of para. 5.1.
b) Resumes.
7 SP31.001.01 Verify storeroom personnel complete U Storeroom personnel are the responsibility
para. 8.2.7 training required by the Maintenance of NOSD, per SP12.019.05, Rev. 2, Sect. 2.0
Engineer as well as Storeroom with an effective date of 12/18/84. The
Personnel Training Program as out- Maintenance Procedure needs to be revised
lined in SP12.019.05. to reflect actual change. The Maintenance
Engineer stated that he no longer specifies
requirements for Storeroom personnel (Audit
Finding #10)
.
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1
Ev-(MO
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AUDIT CHECKLIST E PAGE 5 0F 16
.
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
8 SP12.003.01 Identify and record the names of N/A Verified that the following instructors'
training instructors who conducted names were listed as giving courses for
courses for each discipline identi- the various disciplines: J. Aratz, J. Gold
fled in Checklist E. Coordinate this J. Custer, R. Zegel, A. Muller, N. Coldstein
information with the auditors per- K. Rottkamp, W. Coughlin, F. Weber,
forming Audit QS 86-03. T. Caputo. Due to priorities during the
audit, this info. was not coordinated with
QS 86-03 audit team.
9 SP12.014.04 Verify the Maintenance and Modifica-
tion Division meet their training
responsibilities as defined:
a) Providing the training department S 1. Requests for required reading.
with required subject matter to 2. Signed lesson plan for Admin.
ensure the Training Program meets procedures.
. all requirements.
b) Review and evaluate training pro- S Procedure SP41.Oll.01 and the FSAR
grams for content and technical are being revised to conform to
accuracy. applicable requirements.
c) Assure section personnel attend S A computer printout is given to the
scheduled training sessions. section head who assures personnel
attend training.
10 SP31.001.01 Identify types of work being per- U a) Selected a sample of MWR's and
formed by the' Mechanics and Welders. verified the individuals were
Select a sample of tasks, identify qualified prior to the MWR
responsible personnel and verify being issued.
they were qualified to perform
assigned tasks prior to the start b) There was a lapse of time after .
date. the eye exam and the supervisor
*
signed the certification. ( Audit
Finding #8)
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
l
* c) Some individuals were certified prior
'I to actual receipt of eye exam
documentation (Audit Finding #8)
d) The Certification form does not meet
all of the 17quirements of ANSI N45.2.6
1973.
.
(See Observation #13)
.
11 For the Modification Section, S
identify types of work that require
, '
specific classroom or on-the-job
training. Examine those records,
identify the responsible
4
individuals and verify they were
j qualified to perform the task
prior to the start of work.
12 10CFR50 Are training procedures and Reference: QS Audit QS 86-03,
Appendix B training materials subject to Attribute #2.
Criterion 6.17 appropriate document control
- processes, including
- a) Review and approval by S
appropriate authority;
i b) Review and approval of changes S
by appropriate authority;
!
c) Limited distribution of certain S
materials to protect the
integrity of examinations. .
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
13 10CFR50 Are training records retained in S All training records are sent to SR2.
Appendix B permanent plant files for the
Criterion 17 specified time?
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- TABE Fel
Maintenance Personnel (Al-B hxhanics) Qualification and Training (Checklist Iten 2)
Attributes
Al Pir_h. B }ixh. B Mech. Al Mech.
J. Castle John A. Noulis Dennis J. E nsch R. Cmytak
1. Hmleyment Application /Resine (welder) (welder)
2. Education H.S. (restsne) Not Indicated In Res. Not Indicated In Ressne H.S. (mstne)
a. ANSI N45.2.6 N/A N/A N/A N/A
b. FSAR N/A N/A N/A N/A
c. SP12.003.01 N/A N/A N/A N/A
3. Initial or Replacanent Training 3 yrs. exp. 3 yrs. exp. 3 yrs. exp. '(resisne) 3 yrs. exp. (resisne)
a. ANSI N18.1 N/A N/A N/A N/A
b. FSAR N/A N/A N/A N/A
c. SP31.001.01 Y Y N/A Y
d. Training Perfonnance LValuation Y Y N/A Y
e. h ation Y Y(welding) N/A Y
j 4. Retraining N/A N/A N/A , N/A _
a. ANSI N18.1 N/A N/A -
N/A N/A
b. FSAR N/A N/A N/A N/A
c. SP31.001.01 N/A N/A N/A N/A
d. Training Perfonnance LNaluation N/A N/A N/A N/A
e. Wrk Perfomnnce Evaluation N/A N/A N/A N/A
f. h ation N/A N/A N/A N/A
,
Ehter Y=Yes, PMb, N/A Not Applicable, or a Ctenent number in the appmpriate space.
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TNUE Fel (cont'd)
Maintemnce Pemannel (Al-B &c!wtics) Qualification and Training (Orcklist Itan 2)
Attributes
J. Castle John A. Naulis Dennis J. u n d R. Creytak
5. Drill Participation N/A N/A N/A
'
N/A
6. Fire Brigade Training N/A N/A N/A N/A
7. L i m .cy Training N/A N/A N/A N/A
8. Respirator Training SP 62.032.01 N/A N/A N/A N/A
9. QA Training Y Y N N
10. All SNPS Training (Simnary) Y Y N Y
'
11. Certification per SP12.003.01 Y Y(welding) Y Y
a. For position Al &ch. &chanic &chanic Al Mechanic
b. Per ANSI N45.2.6 12/21/84 3/10/86 3/10/86 5/31/86
12. Recertification/ Renewal N/A N/A N/A N/A
a. For position N/A N/A N/A N/A
b. Per ANSI N45.2.6 5/31/86 N/A -N/A 3/10/86
*
.
*
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Ehter Y=Yes, N=No, N/A Not Applicable, or a Comnent runber in the appropriate spa .
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TABE E-1
Maintenance Personnel (Al-B Mechanics) Qnlification arvi Training (Checklist Itan 2)
Attributes NAMFS
Al Mech. B Mr ch. B Mech.
1. Hmloyment Application /Reanne H. Sheppani T. Erwin H. Po.y
2. Education H.S. (restene) H.S. (rewne) H.S. (restune)
a. ANSI N45.2.6 N/A N/A '
N/A
l b. FSAR N/A N/A N/A
c. SP12.003.01 N/A N/A N/A
[ 3. Initial or Replacanent Training 3 yrs.(resune) 3 yrs. (restsve) 3 yrs. exp. (restsne)
a. ANSI N18.1 Y Y Y
b. ESAR Y Y Y
c. SP31.001.01 Y Y Y
d. Training Perfonnance Braluation Y Y N/A
e. Examination Y Y N/A
!
4. Retraining N/A N/A N/A
j a. ANSI N18.1 N/A N/A
'
N/A
b. FSAR N/A N/A N/A
c. SP31.001.01 N/A N/A N/A
d. Training Perfonnance Evaluation N/A N/A N/A
e. Work Perfonnance Braluation N/A N/A N/A
f. Examination N/A N/A
'
N/A
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Ihter Y=Yes, N430, N/A=Not Applicable, or a Cminent rusnber in the appropriate space.
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TABE L-1 (cont'd)
Kiintenance Per<xxinel (Al-B Mechanics) Qualification and Training (Checklist Iton 2)
Attributes
II. Sheppard T. Ervin 11. Penny
5. Drill Participation N/A N/A N/A
6. Fire Brig;rle Training N/A S N/A
7. " a-m6cy Training N/A N/A N/A
8. Paspirator Training SP 62.032.01 N/A Y N/A
___
9. QA Training N Y (12/80) N
10. All SNPS Training (Smmary) Y Y Y
11. Certification per SP12.003.01 Y Y (electrical) Y
a. For position Al Mech. B N chanic B Mechanic
b. Per ANSI N45.2.6 Y N Y
12. Recertification/ Renewal N/A N/A N/A
a. For position I 1 1
b. Per /NSI N45.2.6 3/10/86 3/18/86 3/10/86
-
1) No objective evidence in file.
.
Ihter Y=Yes, N410, N/A43ct Applicable, or a Cmment ntrber in the appropriate space.
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TABLE E-2
Maintenance Personnel (Welders) Qualification and Training (Oiceklist Its 2)
Attributes
1. Brployment Application /Restane
2. Education
a. ANSI N18.1
b. FSAR NOTE:
c. SP12.003.01 Welders were selected as part of Al &chanics. A smple of wrk
3. Initial or Replacment Training was selected and verified that they wre qualified to weld to
a. ANSI N18.1 the approved procedures. That, in conjunction with the Al
b. FSAR requirements confirm that individuals designated as w.1ders
c. SP31.001.01 are qualified.*
d. Training Performance Waluation
e. Exanination
4. Retraining
a. ANSI N18.1
'
b. FSAR
c. SP31.001.01
d. Training Performance haluation
e. Work Performance haluation
f. Examination
*See Mechanic Al Table B-1 Requal. Recortis are kept at Ifaupparge-Verified 1st and 2nd quarter qualifications.
.
Ihter Y=Yes, N430, N/A=Not Applicable, or a Omment ntsrber in the appropriate space.
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TABLE E-3
M1nagernent ard Technical Per<mnel Qualifications and Training (Gecklist Item 4)
Attributes
M11nt.Ehg. Ehgineer Weld Supvr. Forman
P. Pizzariello F. Ilubert E. Kopelenski W. Slinonik
1. Sployment Application /Restme Y Y Y Y
2. F2fucation and Ferience Y Y Y Y
a. ANSI N18.1 4.3.2 Y (5.3.3) (4.3.2) (4.3.2)
b. FSAR 13.1.3.7 (13.1.3.18) N/A (13.1.3.24)
c. SP 12.003.01 Apperdix 12.2 Y Y Y
3. Initial or Replacemmt Training N/A N/A N/A N/A
a. ANSI N18.1
b. FSAR
c. SP 12.003.01
4. Continuing Training (2) N/A (2) N/A (2) N/A (2) N/A
a. ANSI N18.1
b. FSAR .
c. SP 12.003.01
5. Bnemency Training (3) (3) (3) (3)
6. Ib ir,a cy Drill Participation (3) (3) (3) (3) -_
1) No objective evidence 2) No Progran 3) No recon! in file 4) Qualification Not in File
in file to verify See QS 86-03
Audit Finding 28
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Ehter Y=Yes, N410, N/h=Not Applicable, or a Ctanent runnber in the appropriate space.
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TABLE Fr3 (cont'd)
Managenent and Technical Personnel Qualifications arul Training (Gecklist Item 4)
Attributes
P. Pizzariello F. Ibbert E. Fopcienski W. Slinonik
7. Respirator Training SP 62.032.01 N/A N/A N/A N/A
8. QA Training Y(3/26/81) Y(12/3/80) Y(1/15/76) Y(12/31/81)
9. All SNPS Training (Stenary) Y Y Y Y
10. Certification per SP12.003.01
a. For position Y No (4) No (4) No (4)
b. Per ANST N45.2.6 Y Y Y Y
11. Recertification/ Renewal Eye Exan 11/8/85 5/31/85 12/13/85 12/13/85
a. For position
b. Per ANSI N45.2.6
12. File Content per SP12.014.02 Y Y Y Y
13. Fitness For Duty 2/21/85 N/A N/A N/A
14. Safety Evaluator N/A N/A N/A N/A
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Biter Y-Yes, N=No, N/A Not Applicable, or a Ctanent mmber in the appropriate space.
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TABLE E-3
&nagement and Tecimical Personnel Qualifications and Training (Owcklist Itsu 4)
Attributes
Outage .Eng. Plan.6 Sch.lhg. Outage / Plan. Ehg. Png.
-
D. Durand D. Durand P. Martim A. Guardino
1. Biployment Application /Remme Y Y Y Y
2. Education and Experience Y Y Y Y
a. ANSI N18.1 N/A N/A N/A N/A
b. FSAR (3.1.3.16) (13.1.3.15) (13.1.3.18) 13.1.3.18
c. SP 12.003.01 (Appendix 12.2) (App e dix 12.2) (Appendix 12.2) Apre dix 2.12
3. Initial or Replacanent Training N/A (1) N/A (1) N/A (1) N/A (1)
a. ANSI N18.1
b. FSAR
c. SP 12.003.01
4. Continuing Training N/A (1) N/A (1) N/A (1) N/A (1)
a. ANSI N18.1
b. FSAR ,
c. SP 12.003.01
5. Bnergency Training Y(9/4/85 8/22/86) Y(9/4/85 8/22/85 (2) (2)
6. Bnergency Drill Participation (2) (2) (2) (2)
1) No Progran requirements 2) No records in file
See QS 86-03
Atriit Finding #28
.
Ehter Y=Yes N43o, N/A=Not Applicable, or a Ccunent innber in the appropriate space.
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TAIRE Fr-3 (cont'd)
Management and Technical Personnel Qulifications and Training (Decklist Iten 4)
Attributes #
D. Durarul D Durand P. M1rtinn Q. 02anlinn
7. Respirator Traintg SP 62.032.01 N/A (1) N/A (1) N/A (1) N/A (1)
8. QA Trainim 3/9/76 3/9/76 3/12/86 2/28/86
9. All SNPS Training (Smmary) Y Y Y Y
10. Certification per SP12.003.01
a. For position Y Y Y Y
b. Per ANSI N45.2.6 No No No Y
11. Recertification/ Renewal (Eye Bran) 2/6/86 2/6/86 No 3/22/85
a. For position
b. Per ANSI N45.2.6 (Supr. Signtr.) N N N 2/20/85
12. File Content per SP12.014.02 Y Y Y Y
13. Fitness For Duty 2/28/86 2/28/86 N/A N/A
14. Safety Evaluator No No N/A N/A
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l Ehter Y-Yes, IM;o, N/A Not Applicable, or a Ccmnent rumber in the appnpriate space.
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1 20
Personnel Qualifications PAGE OF
AUDIT OF: ""d T"*1"i"8 Sho h N M m Po m S W m
LOCATION:
*
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
Checklist F
Management and General Employee
Training
1. SP 12.014.03, Does the SNPS Ceneral Employee
Training Program conform to the
following requirements:
ANSI N18.1- a) ANSI N18.1-1971, Section 5.4:
1971
1) Faergency plans and evacuation S Lesson Plan, Emergency Preparedness for GET
procedures;
2) Radiological health and safety; S Lesson Plans, HP for CET, Levels I & II
3) Industrial safety; S Lesson Plan, Industrial Safety for CET
4) Security; S Lesson Plan, Security Indoctrination, GET
5) Use of protective clothing and S Lesson Plan, IIP for CET, Level II
equipment?
10CFR19.12; b) 10CFR19.12, in accordance with
Reg. Guide the guidelines of Regulatory
8.27 Cuide 8.27, including:
PREPARED BY DATE APPROVED BY DATE APPROVED BY DATE
Signed / approved Audit Checklists are
filed G maintained with QSD
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p 2 20
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
1) Measurement and control of S For Items (1) through (4), Level I provides
exposure to radiation and basic information, Level II provides
radioactive material; greater detail appropriate for entering
and working in radiation areas of the plant.
2) Radiation protection program S
at SNPS;
3) ALARA philosophy and concepts S
at SNPS;
4) Biological effects of S
radiation;
5) Proper response to S Emergency Preparedness, GET
radiological emergencies
and alarms?
10CFR50, c) Indoctrination in Quality S Lesson Plan, QA
App. B, Assu rance ?
Crit. 2
Reg. Cuide d) Instructions for occupationally ' S Prescribed by SP 12.014.03
8.13 exposed female workers and their
supervisors concerning prenatal
radiation exposure?
FSAR 13.2.1.3 e) FSAR Section 13.2.1.3, including: Item e) 1): The number of hours
specified in the FSAR is to be changed.
1) Required number of hours of S Actual hours spent in class is shown on
instruction; attendance lists and was generally about
eleven (11) hours.
2) General descriptions of the S Item e) 2): Lesson plans, plant .
station and facilities; description, GET; and plant
organization for CET.
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
3) Station Security Program and S See Item 1(a)(4) above,
procedures;
i 4) Station Fire Protection S Lesson Plan, Fire Protection, CET
Program, including:
*
Evacuation signals; S
*
Fire and fire hazard S
+ reporting;
*
Fire watch training; S
*
Basic firefighting S
equipment;
10CFR19 & 20 5) Radiological health and safety S See Item 1(a)(2) above
including applicable portions
of 10CFR19 and 10CFR20;
6) Quality assurance; S See Item 1(c) above
7) Industrial health and safety; S See Item 1(a)(2) above
8) Station emergency' plan and S See Item 1(a)(1) above
implementing procedures;
, 9) Documentation of student S SP 12.014.03, Para 8.4.1; objective
performance through evidence examined in program files
administration of written (see table F-1)
examinations?
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
2. SP 12.014.03, Does the General Employee Training
FSAR 13.2.1.3 Program :cquire that all persons
granted unescorted access to the
protected area complete the GET
program requirements (FSAR Section
13.2.1.3), including:
a) LILCO permanent employees; S All are as prescribed in SP 12.014.03.
Additionally, there are CET requirements
b) LILCO temporary employees; S for visitors who may be granted escorted
access to certain plant areas.
c) Contractor employees; S
d) NRC employees? S
3. SP 12.014.03, Verify that the lesson plans for
para 8.10.3 , the CET program currently in use
have been:
^
a) Approved for technical accuracy
by the cognizant Supervisor or
Section Head, including:
l
1) Security; S by Reen, 5/20/83
2) Operations; N/A Training supervisor approved plant
description and plant organization.
3) Fire Protection; S by Quinan, 7/6/85, Rev. 4
4) Emergency Preparedness; S by Crocker, 3/7/86, Rev. 3
5) Quality Assurance; S by Seaman, 1/14/86, Rev.3 .
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b) Health Ynysics. 5 By DiMascio, Level I, Rev. 1, 3/6/85
, By DiMascio, Level II, Rev. 1, 12/30/85 l b) Approved for content by the
Training Supervisor. S All by Rottkamp or Coppola
4. SP 12.014.03 Do the current GET lesson plans S Lesson Plans cover' requirements of para-
conform to the requirements of graphs 8.3 and 8.7, and 8.8.3
SP 12.014.03, for both GET
training and GET requalification?
5. SP 12.014.03; Is there objective evidence that
FSAR Sec. the GET requalification training
13.2.1.3.3 sessions conform to the requirements
for lesson content as specified in:
a) FSAR Section 13.2.1.3; S Test questions cover the subject
,
matter specified.
b) SP 12.014.037 S
6. Does the Training Department have a Schedule for April sent out on 3/11/86,
schedule for the GET program which via NTS-86-128 showing two training dates
shows the dates when training is each for Level I & Level II initial
offered for: training (CET) and seven training dates
each for Level I and Level II GET
a) GET; S requalification,
b) GET requalification? S
7. Is there a mechanism in place to S Responsible supervisors or sponsors are
notify each individual, in advance, notified in advance so that provisions
that GET requalification training can be made for attendance at scheduled
classes or for an exemption examination,
for requalification.
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
must be completed prior to a
particular date in order to retain
, unescorted access to the protected
!
area?
8. SP 12.014.03, Review the Training Department files
para 8.6.2 covering GET for the past year.
Verify that the documentation of
GET classes and GET requalification
classes include:
a) Indication of which lesson plans S Dates of classes can be correlated with
were used for each class; effective dates of lesson plans, all
revisions of which are in file,
b) Names of Instructors; S On each attendance list.
.c) Signed attendance lists; S
d) Individual's test scores. S Instructor transfers test scores from
i
answer sheets on to a summary form which
l 9. SP 12.014.03 From the roster of persons permitted becomes the official record. ! unescorted eccess to the plant,
select 50 names at random and record
them in Table F-1. Review the
training files of these individuals
and complete Table F-1.
a) Record the current qualification S See Table F-1.
or requalification date;
.
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
SP 12.014.03, b) Indicate whether the qualification S See Table F-1 and Supplemental Comments.
para 8.5.1 category is shown, i.e., Protected
Area, Restricted Area,
Radiological Control Area;
SP 12.014.03, c) Verify that test scores, S See Table F-1.
para 8.3.1, including any re-tests, are
8.3.2(c) greater than 70% (70 plus);
SP 12.014.03, d) If person was excused from CET S No request form is required; exemption is
para 8.7, 8.8 class attendance, verify that per SP 12.014.03, para 8.4.1.1. Exemption
the appropriate request form is tests are identified as such and evaluated
in file and properly signed, and against the 80% criterion,
that the challenge test score
is greater than 80% (80 plus);
,e) Verify that the person's signature S' See Table F-1,
appears on the attendance
sheets for all CET classes for
which current qualification or
requalification credit is claimed;
f) Verify that an examination answer S Except See Table F-1 and Supplemental
sheet, signed by the examinee, Comments. (See Observation #5)
is on file to support'the CET
qualification or requalification;
SP 12.014.03, g) Verify that prenatal instruction S See Table F-1, Supplemental Comment 6.
para 8.3.1 acknowledgment form is in file; Also Observation #9,
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AUDIT CHECKLIST PAGE OF
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
h) Verify that there is a written S See Table F-1 and Supplemental
notice to the Security Department Comment 7. Also see Observation #10
indicating that each person has
completed CET, or has or has not
completed CET requalification.
10. 10CFR, App. B Is there a training program for U See Audit Finding #9.
Crit. 2; management personnel, and does it (No Program in place at this time)
ANSI N18.1- meet the requirements specified in
1971; ANSI N18.1, FSAR and the applicable
NOC Policy 21, station procedures?
,
para 4.2.5(A);
i
11< SP 12.014.02 Identify management personnel S See Table F-2.
assigned to the following positions
and enter their names and job
, titles in Table F-2.
i
a) Plant Manger;
b) Maintenance Division Manager;
,
c) Radiation Control Division
Manager;
d) Outage / Modification Division
Manager;
e) Operations Staff Division Manager.
f) Quality Assurance Department
Manager.
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harpg(O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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AUDIT CHECKLIST PAGE OF
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
12. SP 12.003.01, Review each person's Training and S See Table F-2.
ANSI N18.1- Qualification Folder for conformance
1971 to the applicable requirements of
the FSAR, ANSI N18.1-1971 and the
Technical Specifications, including
certification in accordance with
Appendix 12.4 of SP 12.003.01.
Complete Table F-2.
13. Record names of the instructors N/A Names of oeven instructors for GET were
used within the past year for the furnished to QS-86-03 auditors for
training and coordinate verification verification of their qualifications.
of their qualifications with
Auditors performing Audit QS-86-03,
specifically for:
,a) GET; S
b) Management Training. N/A See Item 10 above.
14. Verify that lesson plans for
management training are in use
and that they:
'
a) Define the purposes, N/A See Item 10 above.
prerequisites, training
objectives, materials to be
covered, session duration,
' and examinations to be given;
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b) Have been approved by the N/A See Item 10 above.
appropriate manager from the ,
- trainee organization.
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15 10CFR50 Are training procedures and
Appendix B training materials subject to
Criteria 6,17 appropriate document control
processes, including:
a) Review and approval by S For Items (a) and (b), only one original
appropricte authority; (Rev. 0) Lesson Plan is in use; all
others have been revised one or more times;
b) Review and approval of changes S all have been approved by cognizant
by appropriate authority; section heads per SP 12.014.03, para 8.8.2.
c) Limited distribution of S Examination materials are kept locked up
certain materials to protect when not in use or not attended. Exam-
the integrity of examinations, inations are returned to training files
upon completion of examination sessions.
16 10CFR50 .Are training records retained S Records are sent to SR2. Sample records
Appendix 50 in permanent plant files for (prenatal) were successfully retrieved
Criterion 17 the specified time? from SR2, both hard copy and microfilm,
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TM E F-1
Cmpletion of CET arul Notice to Security (Gecklist Itan 9)
(a) (b) (c) (d) (e) (f) (g) (h)
.CET Qual. . Qual. . Scores . Onllenge Test . Signed . Signed .Prmatal . Security
Nane and Affiliation or Requal. Cat. 70 Plus Requested 80 Plus Attmd. Exm Fom Notice
(IrLIIOD; (> Contractor, etc.) Date Y N Y N Y N NA Y N Y N Y N Y N Y N
i
2. Calone, L.J. L 10/30/85 R 5 X X X X 6 X
17. Tamorski, T.J. L 10/28/85 R 5 X X X X 6 X 7
33. Cilmrtin, B. L 8/29/85 5 X X X 1 X 6 X
78. Reeves, R.B. L 2/20/86 II X X X X X 6 X 7
95. Ibit, A. C' 9/10/85 5 X X X 1 X 6 X
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137. Dimigan, K. L 6/03/85 R 5 X X X 1 6 X
147. Vickers, R.T. C 11/04/85 5 X X X X X X 6 X
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158. Outu nn, R. L 10/10/85 R 5 X X X 2 6 X
206. Ciarmita, M.J. L 8/05/85 R 5 X X X 1 6 X
214. Bemston, J.A. L 2/03/86 R I X X X X X X 7
230. Fitzgerald, R.J. L 2/03/86 R I X X X X 6 X 7
259. Sievers, D.E. C 3/19/86 II X X X X X X 6 X 7
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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AUDIT CHECKLIST F
PAGE 12 op 20
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TABIE F-1 (cont'd)
Cmpletion of CET and Notice to Security (Oiccklist Its 9)
(a) (b) (c) (d) (e) (f) (g) (h)
.CET Qual. . Qual. . Scores . Oiallenge Test . Signed . Signed .Primatal . Security
Nane and Affiliation or Requal. Cat. 70 Plus Requested 80 Plus Attend. Exm Form Notice
(IpLIllD; (> Contractor, etc.) Date Y N Y N Y N NA Y N Y N Y N Y N Y N
295. Parkhurst, S. L 4/01/86 5 X X X X X X X 7
332. Alexander, J.F. L 8/05/85 5 X X X X 6 X
~
336. Hoffman, J.J. L 1/10/86 R 5 X X X X X X 7
365. Carcia. D. L 5/08/85 R 5 X X X 1 6 X
3%. Litts, T.A. L' 1/23/86 R 5 X X X X X X
430. Carrell, K.W. L 9/24/85 5 X X X X X X
449. Iongboat, J. C 5/23/85 R 5 X X X 1 6 X
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466. I a in, L.W. L 10/29/85 R 5 X X X X X 6 X
483. O'Brien, M.F. , Jr. L 5/29/85 R 5 X X X 1 6 X
504. Daves. D.A. L 6/11/85 5 X X X 1 X 6 X
518. Stark, R. L 2/21/86 II X X X X X X X
540. Cmez, F. , Jr. L 2/28/86 II X X X X X X X
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AUDIT CHECKLIST F
PAGE
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OF
20
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TABLE F-1 (cont'd)
-
Gmpletion of CET and Notice to Security (mecklist Iten 9)
!
(a) (b) (c) (d) (e) (f) (g) (h)
.GET Qual. .Qnl. . Scores . Diallenge Test . Signed . Signed . Prenatal . Security
Name and Affiliation or Requal. Cat. 70 Plus Requested 80 Plus Attaid. Fxn Fom Notice
(L=LIIOD; C<ontractor, etc.) Date Y N Y N Y N NA Y N Y N YN Y N Y N
574. Hancock, J.W. L 3/25/86 II X X X X X 6 X 7
'
613. Duprey, R.P. L 10/05/85 R 5 X X X X 6 X
655. Barley, W.H. C 6/28/85 R 5 X X X 1 6 X
I
658. Cox, K.J. C 3/17/86 R II X X X X 6 X 7
667. Lyons, C.E. L' 12/12/85 R 5 X X X X 6 X
,
686. Neville, J.C. C 7/23/85 5 X X X X X 6 X
697. Cianci, R.G. L 11/08/85 R 5 X X X X 6 X
.
.
716. Bisson, J.W. C 12/23/85 R 5 X X X X 6 X
762. Ferraro, D.P. L 10/10/85 R 5 X X X 2 X X
801. Sawa, Z.P. L 9/16/85 R 5 X X X 3 6 X
803. Gung, C.D. L 11/18/85 5 X X X X X 6 X
879. Spindler, K. L 7/01/85 R 5 X X X 1 6 X
i
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QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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AUDIT CHECKLIST r PAGE l' OF 20
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TABLE F-1 (cont'd)
Cmpletion of GET and Notice to Security (Qiecklist Item 9)
I
(a) (b) (c) (d) (c) (f) (g) 01)
.CET Qual. . Qual. . Scores . Ovillenge Test . Signed . Signed . Prenatal . Security
Nxe and Affiliation or Requal. Cat. 70 Plus Requested 80 Plus Attend. Fxw Form Notice
4 (IrLIIOD; C= Contractor, etc.) Date Y N Y N Y N NA Y N Y N Y N Y N Y N
920. Cosgrove, E. L 2/27/86 I X X X 3 X 6 X 7
939. O'Neal. T. L 10/18/85 5 X X X X X 6 X
956. m itehead, C.M. L 7/17/85 R 5 X X X 1 6 X
994. 01nstead, R.J. L 11/14/85 5 X X X X X X
52. & ttieri, J.A. L 2/20/86 R II X X X X 6 X 7
85. Russell, W.B. L 1/16/86 R 5 X X X X 6 X
i
166. Brasen, R.C. L 5/22/85 R 5 X X X 1 6 X
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467. Doroski, C. L 4/16/85 5 X X X 1 X X
621. Kelly, N. L 6/25/85 5 X X X 1 X X
I 689. Finneran, C. C 4/16/85 5 X X X 1 X X
812. Alpers, J. L 7/23/85 5 X X X X X X
j 861. Rodden, S. L 6/03/85 R 5 X X X 1 6 X
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AUDIT NO.
AUDIT CHECKLIST r
PAGE 15
0F 20
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TAlHE F-1 (cont'd)
.
Completion of GET and Notice to Security (Orcklist Its 9)
(a) (b) (c) (d) (c) (f) (g) (h)
.CEFQual. . Qual. . Scores . O nllenge Test . Signed . Signed . Prenatal . Security
Nm e and Affiliation or Requal. Cat. 70 Plus Requested 80 Plus Attend. Exm Fom Notice
(IrLI1OD; O Contractor, etc.) Date Y N Y N Y N NA Y N Y N YN Y N Y N
884. McClintock, T. L 12/20/85 5 X X X X X X
@75. Backus, A. L 10/18/85 5 X X X X X X
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An#;gC,'O QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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AUDIT CHECKLIST 16
.
Supplanmtal Cmments for Table F-1, CET
1. 'Ihere were signed examination answer sheets for CEr in the-training files dating back to Septenber 1985. Training personnel
mported that some of these doctanents am either shredded or sent to SR2. In any case, SP 12.014.03, Section 8.5.1, does not
specifically require retention of the answer sheets, but only requires that the test scores be doctrnented.
2. Considering that answer sheets had been retained from October on, it was noted that the CET requalification answer sheets
for Wtam (10/10/85) and Ferram (10/10/85) were not found. (See note 1 above.)
3. Of the 48 persons whose CEr, answer sheets were tetrieved axi exmined, two had signed only one of their two answer sheets.
A spot check of several groups of answer sheets t=wx! up two additional unsigned answer sheets. Althaty;h lack of sigiature
does not appear to be a widespread pmblan anong CEr exminees, there is no written policy requiring that the examinee
actually sign the aid disclaimer. Likewise, there is no policy or guideline for dealing with an answer sheet for which the
disclaimer is unsigned. (See Observation #5)
4. In the process of reviewing progran files of CET answer sheets, tuo answer sheets, dated 2/3/86, wem found with an
instructor's notation that the two contractor people involved had been observed using notes during the exanination.
Notwithstanding the fact that both persons had signed the disclaimer conceming giving or receiving aid, the test sheets were
marked " Failed cheating on exm". On further checking, new answer sheets, dated 2/27/86, were found for these two people and
-
they were found to have protected area badges listed on the 4/7/86 badge list. Discussions with Training Department mnnagers
brought out that LIILO has policies aid guidelines to mver this type of problen involving LIIID erployees, but does not have
a written policy or guidelines to deal directly with non-LIIID perwinel caught cheatig on an exanination adninistered by
LIIID. (See Observation #5)
5. Qualification category designation is relatively new (1986) and therefore does not appear in the earlier Ctr records. For '
the persons who requalified on 4/1/86, that detail was not yet in the data h,se.
6. Efforts to locate pre-natal forms were primarily limited to those persons newly qualified in GET within the past year. Of
the 26 persons whose pre-natal forms were located,11 could not be correlated directly to tie access authorization list
because there were no social security ntsnbers on the pre-natal fons (i.e. those annotated with both "X" and "6" in Table
F-1). (See % servation #9)
7. Of the fifty (50) persons whose CEr qualification or requalification reports were forvanied to security for unescorted
access m2thorization, eleven (11) were found to lack sufficient information for positive identification and cormlation to
security records, i.e., the social security nterbers were not incitded in the record sent by Training. (See @ servation '
#10)
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Awn.,n OUALITY ASSURANCE DEPARTMENT AUDIT NO.
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Tu n F-z
Kircuit Persmnel Qualificatims and Training (Oeklist Item 11 and 12)
NMf5 AND TrIUS
Attributes a) W. Steiger b) D. Terry c) J. Schnitt d) L. Irvin
Plant M1 nager Kiint. Div. N r. Rad Con. Div. N r. Out/& d Div. N r.
1. P@loyment Application /Restrie Y Y Y Y
2. Education and Experience - - - -
a. ANSI N18.1 Y Y Y (2) Y (2)
b. ESAR Y Y Y Y
c. SP 12.003.01 Y Y Y Y
3. Initial or Replacanent Training - - - -
a. ANSI N18.1 Y Y Y Y
b. ESAR Y Y Y Y
c. SP 12.003.01 Y Y Y Y
4. Contiruing Training - - - -
a. #31 N18.1 Y Y Y Y
b. FSAR N/A N/A N/A N/A
c. SP 12.003.01 N/A N/A N/A N/A
5. Phergency Training (1) (1) (1) (1)
, 6. Bnergency Drill Participation (1) (1) (1) (1)
7. Respirator Training SP 62.032.01 N/A N/A N/A N/A 8. QA Training Y Y Y Y
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9. All SNPS Training (Sumarv) Y Y Y Y
.
Enter Y=Yes, N4b, N/ Mbt Applicable, or a Omment nunber in the appmpriate space.
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AUDIT NO.
'
AUDIT CHECKLIST PAGE OF
uuit.t. r-z (cont;o)
Rw,s_.ut Pernamel Qualifications and Training (Oiecklist Iters 11 and 12)
NAMES AND TrlUS
Attributes a) W. Steiger b) D. Terry c) J. Sclinitt d) L. Icein
Plant Mwiger Kiint. Div. W . Rad Con. Div. Mgr. Out/Hx! Div. Mgr.
10. Certification per SP12.003.01 - - - -
a. For position Y Y Y Y
b. Per ANSI N45.2.6 Y Exp 10/2/85-11/4/85 Y Exp 2/22/86-3/10/86 Y EXP 12/14/85-2/14/86 Y Exp 7/24/85-11/5/85
11. Recertification/ Renewal - - - -
a. For position N/A N/A N/A N/A
b. Per ANSI N45.2.6 Y Y Y Y
12. File Content per SP12.014.02 Y Y Y Y
t
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.
(1) Information not in individual files; held in Brergency Planrting files; not reviewed in this audit.
(2) Evaluated against Teclutical Manager requirments in ANSI N18.1.
.
Biter Y=Yes, WNo, N/Ar430t Applicable, or a Cmment ntenber in the appropriate space.
.
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_ _ - _ _ _ - - _ __ -_---- - __-- - - _ -- - - - - - - - - - - - . _ _
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# QUALITY ASSURANCE DEPARTMENT AUDIT NO.
Avn(E("O .+
.
F
AUDIT CHECKLIST PAGE OF
.
.
INR.h t-4 (Conthh
Managenent Personnel Qualifications and Training (Qiecklist Iterm 11 and 12)
NAMIS AND T11US
Attributes e) J. Scalice f) J. Notaro
Op. Div. W . QA Dept. W.
10. Certification per SP12.003.01 - -
a. For position Y N/A
b. Per ANSI N45.2.6 Y N/A
11. Recertification/ Renewal - -
a. For position Y N/A
b. Per ANSI N45.2.6 Y N/A
12. File Content per SP12.014.02 Y N/A
,
(1) Information not in individual files; held in Bnergency Planning files; not reviewed in this audit.
.
Ihter Y=Yes, Mio, N/A430t Applicable, or a Crement ntnber in the apptupriate space.
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QUALITY ASSURANCE DEPARTMENT AUDIT NO. NB-86-01
AUDIT CHECKLIST ' 2
PAGE 0F
Personnel Qualifications
AUDIT OF: 8"d Traini"8 LOCATION: Shoreham Nuclear Power Station
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
1 Leonard Memo Verify that the requirements (for U Audit Findings were issued because some
3/3/86 Qualification and Training) as requirements to the Plant Manager's
(VPN 086-48) identified by memos from the V.P. Directive were not implemented,
Steiger Memo Nuclear Operations and the Plant specifically:
3/3/86 Manager have been implemented and
(PM Dir.86-003) by all Shoreham Operations Divisions, a) That all Matrices included the
qualification expiration date,
b) Not all Matrices were located in
the Watch Engineer's Office as
required,
c) Many Matrices contained errors.
(Audit Finding #5)
2 Verify that ongoing Corrective /
Preventive Actions are being imple-
mented in a timely manner to correct
deficient conditions / trends as
identified by the following:
a) Quality Assurance Trend Report S Positive actions have been taken by NOSD
(1st and 2nd quarter) (Reference NOSM-86-0125, dated 3/29/86).
The Audit Findings were categorized into
six (6) areas of concern and resolutions
have been proposed to eliminate recurrence
of the non-compliance.
PREPARED BY DATE APPROVED BY DATE APPROVED BY DATE
Signed / approved Audit Checklists are
flied & maintained with OSD
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AUDIT CHECKLIST C PAGE 2 OF 2
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
b) Corrective Action Requests (CAR) S Verified timely completion of Corrective
(as related to the training and Action for Corrective Action Requests:
qualifications)
a) CAR #4 for Office of Engineering is
closed,
b) CAR #10 for Plant Staff is closed,
c) CAR #5 for Plant Staff is closed,
c) LILCO Deficiency Reports (LDR) S The following LDRs were included in the
research of this audit. LDRs 86-124,
86-028, 86-123, 85-093, 86-034,
d) Audit Reports issued by the QA S Verified ongoing and/or completion of
i
Department Corrective Action:
a) QC Audit QC 86-08
b) QC Audit QC 86-13
c) QC Audit QC 85-05
d) NRB Audit B-85-01
e) Audit Findings (use the QA S Audit Findings identified in Checklist
Open Audit Item Status Listing) item d were verified.
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pEJO QUALITY ASSURANCE DEPARTMENT AUDIT NO.
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Corporate Nuclear Training
AUDIT CHECKLIST P/LGiE C4:
Nuclear Support Department Shoreham Nuclear Power Station
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
l' NOC Policy 21 Verify that department managers U The Nuclear Engineering, "uclear Operations
para. 4.2.3 have defined and implemented the Support, General Services-Production
training needs of their organiza- Training Center (weldirg instructors) and
tion as they directly support the Purchasing Departments have defined and
activitfes associated with SNPS. implemented the training needs of the
personnel in their organizations. However
the Information Systems Department has not
developed a procedure to address training.
(See Audit Finding #34)
2 NOC Policy 21 Verify that the Nuclear Training
para. 4.2.5 Division (NTD) has established a
documented training program to
address the following:
a) Training for licensed opera- N/A The required training for plant staff
tors, non-licensed operators, positions is currently covered by various
STA's, plant engineers, tech- station procedures and was addressed
nicians, mechanics, and other in audit NB-86-01.
required plant positions; '
,
b) Establishment and maintenance U A Nuclear Training Administrative Manual
of INPO accreditation; and NTD Implementing Procedures have been
drafted to address the requirements of
NOC Policy 21, para 4.2.5, however, these
documents have not been issued for imple-
mentation. (See Audit Findings #27 and 29)
.
PREPARED BY -
DATE APPROVED BY DATE APPROVED BY DATE
Signed / approved Audit Checklists are
filed and maintained with OSD
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c) CET, respirator training, on- U Currently there are documented training
site emsrgency planning, safety programs to address the specific items
evaluation training, first aid addressed in this portion of the attribute,
training, and other training however, these areas will also be addressed
which may be established and as part of the SNPS Nuclear Training
conducted for all personnel Administrative Manual and Implementing
associated with the SNPS; Procedures. (See Audit Finding #27)
d) Coordination of all training U See Audit Finding #27
activities for interdepartmental
participation;
e) Development of training programs U See Audit Finding #27
based on the needs within the
Office of Nuclear Operations;
f) Assistance and monitoring of the U See Audit Finding #27
development and implementation
of nuclear training standards,
objectives, and programs within
the nuclear support departments;
g) Maintenance of accurate and U See Audit Finding #27
current records and files
associated with all individuals
who require qualifications /
, certifications and training to
work at/for the SNPS;
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h) Maintenance of a computerized U See Audit Finding #27
training and qualification /
certification program for
satisfying and scheduling
individual personnel nuclear
training;
i) Operation and maintenance of the N/A Nuclear simulator not scheduled for
,
nuclear simulator including all completion until the second quarter, 1987.
simulator hardware and software, Audit of this item not possible at this
control room equipment, labs and time.
equipment.
i 3 NOC Policy 21 ' Verify that nuclear support depart- NOSD Procedure 17, Rev. 2. " Training of t
para. 4.2.6 ments have documented provisions NOSD Personnel", does not contain
for:
provisions for defining annual training
, ' goals and providing initial and quarterly
a) Defining annual training goals U status. (See Audit Finding #24) In
and objectives in accordance addition, the Purchasing Department had
with training standards, and not transmitted quarterly status to the NTD.
providing initial and quarterly (See Audit Finding #21 and Attribute #31)
status to the NTD.
b) Identifying and developing U NED, NOSD, General Services and Purchasing
training programs which qualify have developed and implemented department
personnel to perform designated procedures to address training. Informa-
job functions and responsibil- tion Systems Department has not developed
ities in accordance with train- a procedure. (See Attribute #1 and
ing standards and goals. Audit Finding #34)
,
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NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
NOTE: Only those qualifications NED Procedure 1.03, " Indoctrination and
needed to perform a task at Training of NED Personnel" had not been
the SNPS are required to be revised to incorporate NOC 21, Rev. I
documented; requirements. (See Finding #30)
c) Designating and providing
sufficient time for an indi- U See Attribute 3b.
vidual to interface / coordinate
with the NTD, and to carry out
the responsibilities of the
department in training standards,
training needs, and training,
programs;
d) Maintaining and transmitting to U See Attribute 3b.
the NTD appropriate training
records and documentation
pertinent to training programs
and personnel qualifications /
certifications;
e) Reviewing the qualifications U See Attribute 3b. It was verified during
and training of consultant the audit that the various support depart-
personnel, with appropriate ments are transmitting training information
information transmitted to the on consultants to the NTD, however,
NTD for inclusion into the com- training records for NTD consultants are
puterized training and qualif- not maintained by the NTD. (See Audit
ication/ certification program. Finding #35)
4
.
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4 NOC Policy 21 Verify the NOSD Manager's awareness S Discussion with J.L. Smith, NOSD Manager,
para. 4.2.2 and implementation in monitoring verified his awareness of monitoring
aherence to the corporate adherence to the corporate policy.
policy governing training and
qualification, and participation
in required training by all depart-
ments.
5 NED 1.03 Has the NED DTR prepared a basic S Addressed by NED on a computerized
para. 6.2 training requirement matrix for training matrix.
,
each Division?
i
6 NED 1.03 Verify that training requirements U Twenty of 80 NED personnel folders were
para. 6.2 have been determined for each verified during the audit. It was noted
individual from a training needs that the Training Needs Matrix for 5
assessment study which compares individuals was completed prior to the
! 2
current qualifications of employees Position Standard being developed. In
with corresponding position stan- addition, the training records of 7
dards, individuals did not reficct their current
position / function within NED. (See-
Audit Finding #31 and Observation #17)
7 NED 1.03 Verify that training requirements S Based on a review of the training needs
para. 6.2, for each position is selected determined for NED personnel, the train-
6.2.1, 6.2.2 from, but not limited to, the ing specified was selected from the
following: items identified in this attribute.
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..
a) Courses for unescorted access
within the Shoreham site;
b) Quality Assurance Orientation;
c) BWR Familiarization;
d) SR2;
e) Interdepartmental training;
i '
f) Specific technical and
administrative training
required for the position.
3
8 NED 1.03 Has the DTR identified in a matrix S NED revised the referenced requirement via
para. 6.3 those departmental and divisional Engineering Change Notice 85-024 (6/19/85)
procedures implemented by each to address department procedures only,
individual (technical, administra- LDR-86-125 was initiated by NED against
tive and clerical)? clasr. room training that was not properly
completed by NED personnel. During the
audit it was verified that the matrices
were developed and implemented as required
by the corrective action required by the LDR.
9 NED 1.03 Is each Division Manager aware that N/A Engineering Change Notice 85-024 mentioned
para. 6.3 they must review and approve the above deleted the requirement for
: matrix, and are they accomplishing Division Manager " approval" of the matr,1ces,
this task?
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10 NED 1.03 Verify that the DTR has a clear S A discussion with the DTR addressing the
para. 6.8, 6.11 understanding of the responsibil- responsibilities identified in the
ities for preparing and maintaining attribute verified that the DTR does have
a file of overall department a clear understanding of these
training which contains the annual responsibilities.
department training schedule and
shows training progress?
11 NED 1.03 Does the DTR maintain a file for S Training files are maintained on each
para. 6.10 each individual containing the NED individual. In addition, training
records have been transfered to the
1
training requirements and current
status of training administered. NTD.
i
12 NED 1.03 Verify that the DTR has prepared a S Verified that NED Training Progress Reports
para. 6.12 quarterly training report indicating for the third and fourth quarter 1985 were
training administered during the transmitted to the NTD by the Engineering
quarter and comparisons of training Assurance Division via memo EAD-85-904
progress versus training goals for (4/11/86). First quarter 1986 report was
both the current quarter and the being prepared at the time the audit.
year to date. The report shall
indicate personnel requiring make-up
sessions.
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13 NED 1.03 Verify that the DTR has established S A training program file addressing
para. 6.13 and maintained a Training Program training of NED personnel to NED Procedu'res
file for all courses given by the has been developed and updated as part of
Department. the corrective action required by
LDR-86-126.
14 NED 1.03 Has each NED Division Manager, or S Training matrices for each individual in
para. 6.14 designee, prepared a procedure NED has been developed as required for NED
training matrix for each new member Procedure training. This area was also
of the Division to introduce the updated as part of the corrective action
individual to the NED Procedures required by LDR-86-126.
Manual and is the completion of
this training recorded on the
Employee Training Record?
i ! > 4
15 NED 1.03 Has the DTR provided the QA Manager S The DTR transmitted a list of NED personnel
para. 6.15 with a list of new employees on requiring QA Indoctrination to the QA
an annual basis for attendance in Department on 4/4/86.
QA Indoctrination sessions?
,
16 NOSD 17 Verify that the NOSD Manager has U See Attribute 3a concerning NOSD
para. 5.1 ensured that the individual train- compliance with NOSD-17 on this item.
ing goals for department personnel (See Audit Finding #24) ,
are achieved.
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17 NOSD 17 Verify that Division Managers are U Based on discussions with the NOSD Division
para. 5.2 aware that they must determine Managers they are aware of their respons-
I the training requirements for ibilities in this area, however, there is a
each position in their division provision in NOSD-17 for the Managers to
and the training needs of the substantiate this determination on the
individuals assigned to a position, training needs matrix by signing or
.
including retraining requirements. Initialing. (See Audit Finding #18)
Are they accomplishing these tasks?
18 NOSD 17 Does the Training Division Manager U Numerous discrepancies were identified
para. 5.3 ensure the adequacy of training, during the audit against NOSD training
maintenance of training records and records indicating that the NTD has not *
overall coordination of all train- ensured the adequacy of the training
ing of NOSD personnel? records. (See Audit Findings #16, 17, 18,
19, 22, 23, 25, 26 and 35)
19 NOSD 17 Verify that task lists for each U Task lists were not completed for all
pare. 6.1.3 existing position are submitted to NOSD personnel. Specifically the Nuclear
the NTD. Emergency Preparedness Division had not
developed task lists for their personnel.
(See Audit Finding #16 and Attributes #33,
34 and 36)
20 NOSD 17 Verify that the training needs of U As identified in the comment for Attribute
para. 6.1.4 the individuals have been developed 19, task lists were not completed for all
in accordance with the reference. NOSD personnel. These task lists are a
prerequisite for developing individual
training needs, ,
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21 NOSD 17 Have the training needs of each U Training Needs Matrices had not been trans-
para. 6.1.5 individual been submitted to the mitted by all NOSD Divisions to the NTD
NTD? (See Audit Finding #17 and attributes
#33, 35 and 37)
22 NOSD 17 Have NOSD personnel received S Training needs that have been developed for
para. 6.2 training in the following areas to NOSD personnel do consider these areas.
the extent necessary to perform NOSD-17 procedure does not establish
their job? finite requirements for determining train-
ing needs, but rather, gives suggestive
a) LILCO Policies methods and guidance for accomplishing
this task,
b) NOC Policies
c) NOSD procedures
d) Courses for unescorted access
e) QA Orientation / Indoctrination
f) ALARA
g) Fitness for duty
1
23 NOSD 17 Has classroom training been con- U Lesson Plans were not developed for the
, para. 6.3.2 ducted using lesson plans developed Instructor Training Program and Storeroom l in a format approved by the NTD7 Personnel Training (See Audit Finding #26) t
4
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l 24 NOSD 17 Are the lesson plans approved for U The lesson plans for training to six NOSD
, para. 6.3.2.1 instructional adequacy by the NTD Procedures were reviewed. It was noted that
6
and approved for technical the lesson plan for training to NOSD
accuracy by the cognizant section Procedure 11 had not been approved by the
supervisor. NTD for instructional adequacy prior to the
course being given. (See Audit Finding #26)
25 NOSD 17 Verify that self-paced training S Review of this attribute determined that
para. 6.3.3 has been conducted using guidelines self-paced training has not been performed
approved by the NTD. very frequently. One example of this type
of training on " Fire Protection Self Pack"
was reviewed and found to be conducted
using guidelines approved by the NTD.
26 NOSD 17 Verify that program files have been U Numerous deficiencies were identified
para. 6.4 developed for all NOSD training against the NOSD Program Files (See Audit
programs to include: Findings #22, 23, 25, 26)
a) a program description to include:
1) the intent of the training
2) the target audience
3) the approximate duration of
the training session
4) program completion require-
ments
b) a topic outline for the major
subjects of the program;
.
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!
c) the lesson plans;
d) student handouts, if available;
,
e) visual aids, if available;
f) copies of completion examinations
and answer keys;
j g) a grade reporting sheet; ,
h) daily attendance sheets;
i) a log which records the dates
.
and times for each occasion the
I program was conducted. i
27 NOSD 17 Are these program files being U In addition to the deficiencies identified
para. 6.4.2 maintained by the NTD? in the comments to attribute 26, the NTD
does not maintain the Emergency Preparedness
Training information as required by EPIP 5-4
section 2.0. (See Audit Finding #28)
28 NOSD 17 Are individual training folders U Numerous discrepancies noted in the train-
para. 6.4.3 maintained by NTD for NOSD ing folders for NOSD personnel. (See Audit
; personnel to address the following: Findings #17, 19, 35)
i a) titles and dates of course i attendance; i
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b) completion certificates,
as applicable;
c) certificates or letters docu-
menting training conducted off
site by a vendor.
29 QP-3 Verify that the Department Training
para. 4.5, 4.6 Coordinator is aware of his respon-
4.7 sibilities and is implementing a
training program to address the
following:
a) assigning required reading; U a. The Purchasing Department Training
Coordinator is aware of his respon-
. sibilities. However, he has not
adhered to all the requirements
stipulated in the Purchasing Dept.
Buyer Training Program in that there
was no documented evidence that
personnel had been assigned the
required reading assignments,
delineated in Section II or that
evaluations of personnel had been
performed as stated in Section IV of
the Program. (See Audit Finding #20)
b) assigning newly hired, trans- S b. Personnel are assigned to experienced
i
ferred, and re-assigned individuals.
individuals to work with
previously trained individuals, ,
as necessary;
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c) assuring personnel receive QA S c. Verified that personnel had received
Indoctrination; required training. Five individuals
are scheduled for training on 4/24/86.
d) rescheduling indoctrination / N/A d. To date no substantial changes have
training when substantial occurred.
changes occur in procedures and
- other governing documents, QA
!
audits indicate significant
departures from or misunder-
standings of procedures, or if *
it appears that satisfactory
performance is in doubt.
'
e) defined the annual goals and S e. Verified that annual goals and objec-
. objectives of the program; tives for 1985 and 1986 were prepared
by the Training Coordinator and sub-
mitted to department manager,
f) maintained indoctrination and S f. Verified that for the following
training records; personnel indoctrination and training
.
records were in folders:
t
,
R. Weyer, M. Foley, A. Finley,
R. Matuszenwski, G. Moeller and E. Maksin
g) reviewed the qualifications and S g. Reviewed records of E. Maksin and found
, training'of consultant personnell them to be satisfactory.
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30 QP-3 Verify that the Managers Nuclear S Personnel are assigned to senior buyers
para. 3.3 Procurement, Fuels Purchasing, or expeditors for on-the-job training.
Contracts and Services Division After training period, they are then
are aware that they must assure assigned to do procurements of safety
that personnel cannot perform related materials / services.
nuclear related procurement
activities until they receive the
prescribed indoctrination and
training.
31 QP-3 Has the Department Training U The Training Coordinator did not have
para. 4.8 Coordinator reported on a quar- reports for the 3rd and 4th quarter of
terly basis the progress of the 1985 and the first quarter of 1986.
department training to the (See Audit Finf-:ng #21 and Attribute #3a)
Corporate Nuclear Training
Coordinator?
32 QP-3 Is the Department Training
para. 4.9 Coordinator maintaining indoc-
trination and training files to
include:
a) for individuals performing U Training files contained notification of
nuclear related procurement indoctrination and individual qualification,
functions such records as: however, there were no indication of an
assigned reading list. (See Audit Finding
- notification of indoctrinatfor #20 and Attribute #29a)
- assigned reading lists
- individual qualifications
.
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b) a general indoctrination and S Verified that a general file is being
training file which includes all maintained.
material related to the depart-
ments training program, except
records pertaining to specific
individuals.
33 VPN 086-48 Verify that NED and NOSD have U Deficiencies noted in both NED and NOSD
Item I brought their training records records (See Audit Findings # 16, 19, 22,
immediately up to date. 23, 25, 26, 30, 31, 35)
34 VPN 086-48 After the training records were U To verify this requirement, training records
Item 2 updated, were copies sent to the from all divisions of both NED and NOSD were
NTD for inclusion in each reviewed. Contrary to this requirement,
individual's file? the training records of 4 divisions within
. NOSD did not transmit their records to the
NTD (See Audit Finding #17).
35 VPN 086-48 Verify that the NTD has established U See attribute 2g and Audit Finding #27.
Item 2 provisions for receiving and main-
taining training records from each
department within the Office of
Nuclear Operations,
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36 VPN 086-48 By 3/17/86 and 3/31/86, did NOSD N/A Under the requirements of NED 1.03,
Item 3 and NED report additional qualifica- additional qualifications beyond those
tions by sending copies of the identified in the Position Standards
records to the NTD or by identify- for NED personnel are not required.
Ing "no change" to the NTD NOSD does not establish minimum qual-
Manager? ifications as part of their training
program.
37 VPN 086-48 Are provisions established within N/A The training and qualification card
Item 4 NOSD and NED to send copies of referenced in this attribute are used by
.
an individual's training and Plant Staff personnel and do not apply
qualification card to the NTD at to NED/NOSD personnel.
l the end of each month until the
card is completed?
l
38 VPN 086-48 Are section supervisors aware they S As part of the interviews conducted during
Item 5 should review, with appropriate this audit, selected section supervisors
personnel from the NTD, the contents were queried on their responsibilities re-
of their training and qualification garding this attribute. It was verified that
records, and are they performing they are aware of these responsibilities.
this task?
i
,
39 ANSI N18.1 Determine if the qualification and This attribute was included in the checklist
para. 4.6.1, training of technical support to determine and document the LILCO commit-
'
4.6.2, 5.3.3 personnel at SNPS consider the ment to the cited sections of ANSI N18.1.
I
requirements for the classification As such, an evaluation of Sat /Unsat/N/A is
" Engineer in Chart " and the not applicable. (See Observation #18)
training for " Professional-Technical
j Personnel" and " Staff Specialists" i
in accordance with the
! reference. , i I
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40 Is the Nuclear Training Division (See Observation 19 for Attributes 40 through
organized, staffed, and managed 51)
to facilitate planning, directing, Final staffing of the Nuclear Training
evaluating, and controlling a Division is still in process. This attribute
systematic training process that could not be adequately evaluated.
fulfills job-related training needs?
41 Verify that criteria have been Excellent criteria have been established in
established to assure that the the draft NTD procedure on training in-
training staff possesees the structor qualifications. Current methods
technical knowledge, experience, used for instructor qualification and
and developmental and instruc- development are not documented, however,
tional skills required to fulfill a review of the qualification records on
their assigned duties. 15 instructors resulted in a general
assessment that knowledgable, experienced
instructors are being utilized.
.
i 42 Do the training facilities, equip- Reference materials are readily available.
ment, and materials adequately Classrooms in building 115 are marginal
support training activities? when compared to those commonly in use at
most other Nuclear utilities due to the
lack of effective noise, temperature, or
lighting control.
4
43 Are the tasks required for competent The current method of identifying training
jeb performance identified, docu- needs is for the cognizant department or
mented, and included in the train- division manager to create a list of
ing programs, as appropriate? subjects for which a job incumbent must be
trained. This "needs analysis" is effective
in identifying overall training requirements,
but does not identify the " task analysis"
'
necessary to provide the basis for training.
This will be addressed under the nev
,
. training program.
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;
44 Verify that program content provide The current TNPO accrediatation effort
the trainee with the knowledge and includes a job analysis to provide the basis
skills needed to perform functions for training. This analysis will define the
associated with the position for specific tasks associated with a particular
which training is being conducted: job. Existing training programs will be
evaluated against these tasks and will be
a) does the content of initial revised as necessary to assure training
training prepare the trainee is provided for all critical tasks. It
to perform the job for which should be noted that training for licensed
he or she is being trained? operators is already a task based program.
b) does the content of continuing
training maintain and improve
incumbent job performance?
45 Are the learning objectives that Since the task analyses for the accredita-
identify training content and tion effort are not yet complete, course
define satisfactory trainee per- learning objectives are not specifically
formance derived from job perfor- task-based. A systematic process of program
mance requirements? revision based on the task analysis should
be implemented to bring the Icarning object-
ives in line with the job performance require-
ments. Training Department Implementing
Procedures currently under development,
will provide guidance for this effort.
46 Are lesson plans or other training In order to evaluate this attribute Lesson
guides structured to ensure the Plans (LPs) for Hot License, Equipment
consistent conduct of training Operator, Health Physics and Instrumentation
activities? & Control were reviewed. The lesson plans
evaluated showed a great degree of variation
in how they met the above requirements. Some
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lesson plans were simply photocopics of a
reference text, while others were highly
fornatted and cross-referenced. Two general
trends were observed. 1) Evaluation criteria
are not provided for qualification guides.
2) Never lesson plans are much better than the
, older ones. New training procedures should
, provide acceptable guidance to assure new LPs
and Qual Guides prepared by NTD will provide
a means of delivering consistent training.
47 Is classroom and individual One hot license training session was observed
instruction effectively presented, during this evaluation. The instructor was
and is trainee performance routinely adequately prepared, used appropriate
and consistently evaluated? instructional techniques, and encourged class
,
, participation. Student training materials
!
significantly enhanced the Icarning process.
~l The instructor delivered an excellent training
session.
48 Is in-plant training or on-the-job Current OJT programs show wide variations
training (0JT) effectively pre- in implementation methods and effective-
sented, and is trainee performance ness. See NB-86-01 Audit Checklists
evaluated consistently? for information on OJT.
49 Is simulator training effectively Actual simulator training sessions were not
presented, and is trainee perfor- observed.
mance evaluated consistently?
50 Is laboratory training effectively Actual laboratory training sessions were not
presented, and is trainee perfor- observed. ,
l mance evaluated consistently?
_ _ _ _ _ __
-. _ _.
. _
.
v - .
>
pgjo QUALITY ASSURANCE DEPARTMENT AUDIT NO.
"~""'"'
AUDIT CHECKLIST PAGE OF
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
i 51 Is systematic evaluation of traininF New Training Department Procedures are being i effectiveness and its relation to written to implement a program that will ! on-the-job performance used to provide a systematic evaluation of training.
ensure that the training program Currently, the method of evaluation varies
conveys all required skills and f rom program to program. The evaluation of
1
knowledge? program delivery and incorporation of trainee
feedback is not consistently applied under ,
'
existing procedures and policies. Some
l
programs are routinely evaluated by qualified
j
personnel and trainee feedback is vigorously
solicited. Other programs, however, are
;
subject to little observation and only
j occasionally solicit feedback from the
trainees. It is suggested that the new
,
Training Division procedures for program
,
evaluation and modifications be issued as
soon as possible and be applied to all
programs conducted by the training
organization.
1
i =
.
_----- -- _ --
_ _ _ - _ . _ . . _ _
.
.
v .
v .
(O QUALITY ASSURANCE DEPARTMENT Qs u-03
a,s.aw
, AUDIT NO.
AUDIT CHECKLIST PAGE OF
.
NO. REFERENCE ATTRIBUTES S U N/A OBSERVATIONS / COMMENTS
,
52 Verify that ongoing Corrective / S The status of implementation for ongoing
Preventive Actions are being imple- corrective / preventive action required by
mented in a timely manner to correct LDR's and Audit Findings identified by the
deficient conditions / trends as QA Trend Programs fo- the 4th quarter, 1985,
identified by the following: and 1st quarter, 1986 were reviewed. No
,
specific CAR's applicable to training of the
support organizations included within the
,
a) Quality Assurance Trend Report scope of this audit were noted in the trend
j (1st and 2nd quarter) reports. As a result of the review, the
audit team selected 1 LDR and 4 audit
,
findings to verify that specific actions
!
'
b) Corrective Action Requests (CAR) required are being implemented and are
(as related to training and qual- ongoing.
ifications) LDR-86-125, NED (in process)
Audit 85-02, AF flA and IB, NED (complete)
, c) LILCO Deficiency Reports (LDR) Audit 85-14 AF #4, Purchasing (complete)
Audit QS-85-04, AF #8, ISMP (in process)
, d) Audit Reports issued by the QA
Department
e) Audit Findings (use the QA
Open Audit Item Status Listing)
53 PTC Procedure Verify that welding instructors are U Discrepancies were noted as a result of re-
j WI-R properly trained in accordance with viewing the records of the I qualified
j para. 8.1,8.4.1 the reference. Mechanic A-1 Welding Instructor at the
Production Training Center. (See Audit
Findings #32 and 33)
l
.
4
!
f
-
.
.
.
NB-86-01
Audit No. QS-86-03
,
Attachment 3
,
a) NB-86-01 Audit Response Forms for Audit Findings #1 through 15
b) QS-86-03 Audit Response Forms for Audit Findings #18, 24, 25,
26, 27, 28, 29, 32, 33, 34, & 35.
(Audit Findings #16, 17, 19, 20, 21, 22, 23, 30, & 31 were i
closed during the audit and do not require responses.)
.
i
)
.
.
'
! ! i
! ! ,
-
i l i
) l
:
! i i
, _ _ - _. __ . _ _ . - _ _ _ _ . _ _ _ _ _ _ _ - _ _ _ _ . _ . _ _ . - -
-
[[d,@ QUALITY ASSURANCE DEPARTMENT
INITIAL ISSUE
AUDIT RESPONSE FORM RE-issue
i ORSANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
p%nt sen f f and Waini no IB-86-01 P.D & J.v>L
AUDIT DATE RESPONSE DUE BY:
SENT TO (RESPONSIBLE INDIVIDUAL)
' .E. Steiger & J.L. Srtith (joint response rea'd) 4/7-16/86 6/13/8G
l. AUDIT FINDING NO. 1
Page 1 of 3
See Attached
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
Responsible ihnager Inte RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
Responsible rimager tute RESPONSIBLE MANAGER DATE
lil. RESPONSE EVALUATION RECEIVED DATE REMARKSt
ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SINT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- D AT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REMARKS
O SATISFACTORY
O IJNSATISFACTORYi CAR ISSUED
,
) DATE
C AR NO. .
APPROVED:
'
AUDITOR DATE QUALITY DIVISION MANAGER DATE
- _. ___ _ _ . . _. . _ _ _ - _ _ _ _ _ . . _ _ _ _
- _ . . .._ _ _. _ . . _ _ ___
!
4
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:
i '
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NB-86-01
; .
, Plant Staff & Training
* *
! ) Page 2 of 3
I
'
,
Audit Findina No. 1
.
QA Manual, Section 2, para. 2.3.4, requires that programs
be established for indoctrination, training and, if
f'
appropriate, certification of personnel performing or
verifying quality-affecting activities. Further, Section
j ~
17, para. 17.3.2b requires that measures be established to
assure that sufficient records are generated and maintained
to furnish evidence of the satisfactory completion of
; quality-affecting activities. Such records include evidence
;
of training and qualification of personnel.
t
!
1. SP 21.006.01, " Station Operator Training and
Qualification Program", Rev 6, para. 8.1.1.4, requires
i that qualification in the turbine building, reactor
building, control building and yard shall be in
accordance with the SNPS Operator Qualification Guide as ;
supplemented by the SNPS Equipment Quclification Guide. !
Paragraph 8.1.3.3 requires, for each replacement
l Equipment Operator (EO), completion of the EO
'
s
Qualification Guide for a given area prior to being
l' )
recommended for qualification in any area and
j documentation on the Qualification Forms in Appendix
12.2.
]
- Contrary to the above requirements, the following
l deficiencies. were noted in the training records of persons j assigned to work as Equipment Operators: f[. ' ! l a) A significant number of pages in each of'4 EO l Qualification Guides were not signed by a Watch
- Engineer.
i
i b) in 19 instances the evaluator had not signed items , of the EO Equipment Qualification Guides. l l c) In 5 instances an item was missing from the
individuals records.
j d) In 133 instances the signature of the training
section representative was missing. l
<
l l
- -
l . i l l l
:
! w_ _ _ _ _ _ _ , . . _ _ _ _ _ _ _ _ , _ . . _ ,___ . . __ _ . . _ _-_ . . _
NB-86-01
,
*
Plant Staff & Training
Page 3 of 3 .
e) Generally, on-the-job training is not specifically
performed or documented.
(Reference Checklist A-16 and 19(b and c))
2. The area qualification certificates for 6 operators
licensed in 1985 indicate that they were qualified in
the yard, turbine building, reactor building, control
building and the radwaste building.
Contrar,y to the requirements of SP 21.006.01, Rev. 5,
para. 8.2.3.1, there was no objective evidence of such
qualifications having been completed, i.e., there were
no completed License Qualification Guides for any area
other than the reactor building section of the
Qualification Guide.
(Reference Checklist A-8(b))
3. Forty-four Health Physics work activities were
reviewed. The following four items were found to be
indicative of the need for further documentation due to
) the lack of objective evidence that the subject work was
covered by supervision:
a) Instrumentation Calibration work performed on
12/5/85 by a technician who became qualified on
2/24/86.
4 '
b) Internal / External Dosimitry work performed on
4/20/85 by a technician who became qualified on
7/8/85.
c) Respiratory Protection work performed on 12/18/85
by a technician whose certification for that work
expired on 11/17/85.
! !
d) Instrument calibration work performed on 2/22/86 by
a technician who became qualified on 2/24/66.
.
(Reference Checklist D-4 and 13)
! .
, . - - - -
, . - _ . - _ . - _ . , , - . - __ _ _.- . , , , , , _..,...-_--~.,-.-.__.______y_ _ _ _ _ . . _ _ - . _ __ - , _ , ,,
[[b@ QUALITY ASSURANCE DEPARTMENT
Q INITIAL ISSUE
'
AUDIT RESPONSE FORM O RE-ISSUE
ORCANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Plant Staff and Trainim NE-96-Ol <T _ A X
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
t;.E. Steiger & J.L. Smith (joint response reg'd) 4/7-16/86 6/13/86
1. AUDIT FINDING NO. 2
Page 1 of 2
See attached
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
,
I Fesponsible Ihnager Date RESPONSIBLE MANAGER DATE
11 B PROPOSED PREVENTIVE ACTION COMPLETION DATE
>
Responsible lunager Date RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECEIVED DATE REM ARKS:
ACCEPTABLE: VERIFICATION BY
,
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
O SATISFACTORY l
O UNSATISFACTORY: CARISSUED
) CAR NO. , DATE
-
. APPROVED:
,
AUDITOR DATE QUALITY DIVISION MANAGER DATE
NB-86-01
-
, Plant Staff & Training ~
! Page 2 of 2
Audit Finding No. 2
SP41.011.01, "I&C Technician Qualification Program", para.
8.2.4 and SP31.001.01, " Training and Qualification of
Maintenance Personnel", para. 8.2.4, allow individuals to be
qualified by one of several ways such as past experience,
vendor supplied training or on-the-job training. The
procedures require documentation to support this
qualification. Documentation includes either detailed
resumes, vendor supplied documentation, or on-the-j ob
training records (SPF41.011.01 and SPF31.001.01) which
clearly identify acceptance criteria.
Contrary to the above, personnel in the I&C Section and the
Maintenance Section were qualified without adequate
supporting documentation. The SPF forms, required by
procedures, were not fully completed; there was no objective
evidence of complated vendor supplied training courses, and
the resume / job applications did not adequately reflect past
experience.
(Reference Checklists C-2, 3(d) and E-2(c))
)
e
.
.-
. - - - . , - - ~ - - -
-- - _ _ _ , _ _ _ - . . - -_. - . - _ _ _ - - . . . , - - . . - _ _ - -..__,_-___-,-
[d,N QUALITY ASSURANCE DEPARTMENT
@ INITIAL ISSUE
AUDIT RESPONSE FORM RE-ISSUE
i ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR: '
P2 ant Staff.and Training tm-p r;-m PC/JVN/TV4
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
-
W.F. stoicer ana .T.T.. mich (4nine rnem,en ' v,v,eas
' '
4/7-16/86 6/13/8G
1. AUDIT FINDING NO. 3
Page 1 of 2
See attached ,
-
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
Fesponsible Manager Date RESPONSIBLE MANAGER DATE
11 B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
l
Responsible fhnager Ente RESPONSIBLE MANAGER Do.TE
Ill. RESPONSE EVALUATION RECElVED DATE REMARKS:
ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- D AT E
AUDIT TEAM LEADER DATE
- IV. VERIFICATION REMARKS:
O SATISFACTORY
UNSATISFACTORY: CARISSUED
l l
) CAR NO. , DATE
'
~
l
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
l
-_
,
-i
<
V
c
NB-86-01
,
,
Plant Staff & Training
-
Page 2 of 2
)
)
.
Audit Finding No. 3
I
SP 12.003.01, " Personnel Qualifications and
Responsibilities", requires certification of personnel for
their assigned positions. PM DIR 86-003, dated 3/3/86,
requires such certification prior to assignment.
Contrary to these requirements, there were deficiencies
noted in the certification of individuals for their
positions, as follows:
'
a) There were no Engineer position certifications for 2
Performance Engineers,
b) The certification of a Radwaste Operator was changed by
lining out Radwaste Operator and writing in " Nuclear
Staff Specialist (Radwaste)". This change was initialed
and dated by someone who was not authorized to certify
the operator.
c) The certification dated 3/27/85 for 1 radwaste operator
shows his position as " equipment operator". This
) certification must be updated to show his current
position.
d) There is no certificate of completion in 1 HP
Technician's training file for Phase III, BWR Training.
e) In addition, SP 41.011.01, "I&C Technician
Qualification Program", para. 5.1, specifies that an I6C
technician shall be a high school graduate or equivalent
and have three years of experience as an I&C
technician. One of the three years may be satisfied by
related technical training. Contrary to this, of 6~
folders reviewed for-I6C technicians, 3 did not contain
objective evidence of a high school diploma or
equivalent to support their position certification.
,
(Reference Checklists B-15, C-3(a). D-2, 4 and E-2(a))
-
[Md8 QUALITY ASSURANCE DEPARTMENT
@ INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
ORGANIZATIOk / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR: .
Plant Staff - 18-86-01 FD/WI
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
W.E. Steiger 4/7-16/86 G/13/86
1. AUDIT FINDING NO. 4
Page 1 of 2
See attached
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
) RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECElVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
O NOT ACCEPTABLE: ISSUED- DAT E
CAR NO.
AUDIT TEAM LEADER DATE
,
IV. VERIFICATION REMARKS:
O SATISFACTORY
O UNSATISFACTORY: CARISSUED
CAR NO. ,
~
DATE
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER
_ _ _ , _ _ _ , , _
DATE
NB-86-01
-
.
Plant Staff
' Page 2 of 2 -
Audit Finding No. 4
SP 21.006.01, " Station Operator Training and Qualification
Program", Rev 5, para. 8.2.3.1, provided for waiving
training requirements for Equipment Operators, but did not
provide for waiving training requirements for licensed
operators.
Contrary to this, the Area Qualification certificates for 6
operators licensed in 1985 contained the waiver " Qualified
by virtue of completion of the cold license training
program".
(Reference Checklist A-8(a))
)
.
l I l l
- _ _ - _ . _ _ _
_ - .-. --_ -
[[d[8 ,
QUALITY ASSURANCE DEPARTMENT
O INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
-
ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITORt '
Plant St-aff . NB-86-01 Jnt4Tw1
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
U.E. Steiger 4/7-16/86 6/13/86
1. AUDIT FINDING NO. 5
Page 1 of 2
See attached
'
11 A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
l l l ! RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECEIVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
CAR NO. ISSUED- DATE
l AUDIT TEAM LEADER DAT E
IV. VERIFICATION REMARKS: -
O SATISFACTORY
O UNSATISFACTORY: CARISSUED
, '
) CAR NO. , DATE
'
APPROVED:
AUDITOR DAT E QUALITY DIVISION MANAGER DATE
. _ .
- - - . . - . - . _
NB-86-01
.
,
Plant Staff
-
Page 2 of 2
Audit Finding No. 5
In PM DIR 86-003 dated 3/3/86, items 1 and 3 require that:
1) Section Heads shall develop for all operators,
mechanics, technicians and clerks a qualification
matrix. This matrix shall be based upon the Section's
Training and Qualification Procedure, cross reference
the individual to the area of qualification and list the
date qualification expires.
3) Training and Qualification matrix charts shall be
posted in the foreman's offices, watch engineer's/ watch
supervisor's office and shop areas (i.e., machine shop,
I&C shop, HP access area, M&TE shop, radiochemistry
laboratory, control room, etc.) so as to be easily
available for use by both the first line supervisor a r. d
the individual worker.
Contrary to the above:
a) Matrices for Maintenance Division (I&C and Maintenance
) Sections), did not include the qualification expiration
date.
b) The Matrix for the Maintenance Section was not posted
in the watch engineer's/ watch supervisor's office and
shop area as required,
c) Matrices for the I&C, Maintenance and HP Sections
contained errors.
(Reference Checklists D-1(j2), 13, C-4, E-2(c) and G-1)
)
[[6(9 QUALITY ASSURANCE DEPARTMENT
@ INITIAL ISSUE
.
AUDIT RESPONSE FORM O RE-ISSUE
ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Traininq tm-86-01 rnt.v:/.Tm
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J.L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING NO. 6
Page 1 of 2
See attached
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
l l
RESPONSIBLE MANAGER DATE Ill. RESPONSE EVALUATION RECEIVED DATE REMARKS:
l
ACCEPTABLE : VERIFICATION BY
l NEW RESPONSE FORM SENT-DATE
D NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
l IV. VERIFICATION REM ARKS:
O SATISFACTORY
O UNSATISFACTORY: CARISSUED
j CAR NO. . DATE
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
NB-86-01
-
Training .
,
Page 2 of 2
Audit Finding No. 6
SP 12.014.02, " Training and Qualification Folder", Revision
4, requires that individual training and qualification
folders for licensed personnel (SRO and RO) contain drill
participation documentation, completed requalification
requirements, and training performance evaluations (drill
scenarios). For non-licensed personnel, the training record
must include documentation of all training received at SNPS,
and performance evaluations.
Contrary to the above, the drill participation
documentation, completed requalification requirements and
training performance evaluations (drill scenarios) were not
'
maintained in the individual training and qualification
folders but were maintained in the requalification program
files.
In addition, training as required by NRC Bulletin 79-19,
" Packaging of Low-Level Radioactive Waste for Transport and .
Burial", was not included in individual Radwaste Operator
training folders; evidence of BWR Chemistry training
I required by FSAR Section 13.2, para. 13.2.1.2.2.1, was not
in the HP supervisor's folder; and the training requirements
of FSAR Section 13.1, para. 13.1.3.10, for the HP Engineer,
were not clearly correlated with his experience record.
(Reference Checklis t s A-9(d , e, f), D-1(e3), 2, 4, 5, 7 (i) ,
7 (j ) , 8 and E-4)
.
d@ QUALITY ASSURANCE DEPARTMENT
@ INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
i ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR: ~
Waining NB-86-01 FD/JN MJVN
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J.L. Smith 4/7-16/86 G/13/86
1. AUDIT FINDING NO. 7 ,
'
Page 1 of 2 -
See attached
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
I RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
4
RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECEIVED DATE REMARKS:
l ACCEPTABLE: VERIFICATION BY t
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REMARKS:
O SATISFACTORY
- O UNSATISFACTORY: CARISSUED
CAR NO. ,
'
DATE
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
- . _ .
NB-86-01
-
-
Training .
Page 2 of 2
Audit Finding No. 7
SP 12.014.02, Appendix 12.2, requires that the Training
Folder include a resume or employment application. -
VPN086-48, dated 3/3/86, requires qualification and training
records to be updated and maintained.
Contrary to these requirements, training folders did not
have current resumes, as typified by the following:
a) Resumes for 4 out of 6 operations personnel reviewed
were not up to date in that they did not reflect the
individuals' present job assignments,
b) Personnel Folder of an Assistant Engineer in I&C
(Engineer in Training) did not contain a resume or
employment application.
c) Resumes for 3 out of 3 Radvaste Operators reviewed had
out of date or undated resumes in their training files.
d) Resumes for 2 Radiochemistry personnel were out of date
) or were not consistent with the position certification,
e) Resume for 1 Engineer, Compliance, was not in the
training file.
(Reference Checklists A-9(a), B-16, C-3(f) and D-4, 7(g),
8)
i 1 i !
-
l ! 1 t
'
I l
[d@ QUALITY ASSURANCE DEPARTMENT
O INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
~
, ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR: '
Pler.t Staff NB-06-01 JAM /JVN
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
W.E. Steiner 4/7-16/86 6/13/8G
l. AUDIT FINDING NO. 8
Page 1 of 2 .
See attached
'
11 A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DATE
li B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
i l
RESPONSIBLE MANAGER DATE
Ill. RESPONSE EVALUATION RECElVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
CAR NO. ISSUED- DATE
AUDIT TEAM LEADER DATE
- IV. VERIFICATION REM A RKS
l 0 SATISFACTORY
O UNSATISFACTORY: CARISSUED
CAR NO. ,
~
DATE
APPROVED:
AUDITOR DATE ~ QUALITY DIVISION MANAGER DATE
-
_ _ _ _ _ - - - -
NB-86-01
,
*
Plant Staff
*
I Page 2 of 2 -
Audit Finding No. 8
SP 12.003.01, para. 8.1.7, states in part "... each
designated individual shall be administered an eye
examination on a yearly basis. ...".
Contrary to the above, there were deficiencies in the
records as follows:
a) Personnel were recertified prior to receipt of the eye
examination documentation required for recertification.
b) Personnel certification records incorrectly indicated
that recertification was performed on the date of their
, eye examination,
c) A review of qualification and training folders for I6C,
Computer, Maintenance, and Radiochemistry Section
personnel revealed that the length of time from the
"Date of Visual Examination" to supervisor sign-off was
inappropriate and varied significantly.
) d) One mechanic's eye examination and certification lapsed
in March of 1986.
(Reference Checklists C-3(b), D-4, 8, 12, and E-5, 10)
!
'
, t I i l ! i
[[4d9 QUALITY ASSURANCE DEPARTMENT
C INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
) W aining im-96-m wvwyw
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J.L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING N O. 9 e1M2 .
See attached
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
) RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DATE
lli. RESPONSE EVALUATION RECEIVED DATE REM ARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
O NOT ACCEPTABLE: CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
O SATISFACTORY
O . UNSATISFACTORY: CARISSUED
-
) CAR NO. , DATE
APPROVED:
~
AUDITOR DATE QUALITY DIVISION MANAGER DATE
-.
NB-86-01
Training
} -
Page 2 of 2 -
Audit Finding No. 9
ANSI N18.1-1971, " Selection and Training of Nuclear Power
Plant Personnel", Section 5.3, states "A suitable training
program shall be established for managers, supervisors,
professional, operators, technicians, and repairmen to
properly prepare them for their assignments; ... ".
Contrary to the above:
a) A training program for management, supervisory and
technical / professional personnel was not available,
b) Individuals were assigned as " Engineer in Training"
without the benefit of a formal training program which
would clearly identify responsibility, authority and
acceptance criteria. Additionally this program would
assure that safety related tasks are accomplished under
the supervision of a qualified individual.
,
(Reference Checklists B-6(i), 7(c), 14, 18(c), 19(c), 20,
C-1(a-d), D-6, 7(g), 8, E-1 and F-10)
)
.
)
'l
-- - - , - - , ,
[[d8@ QUALITY ASSURANCE DEPARTMENT
C INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Plant Staff and Trainino NB-86-OL FD/PC/ JAM
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
W.E. Steicer & J.L. Smith Noint resnonse rea'd) 4 /7-16 /R6 6/13 /8G
1. AUDIT FINDING NO, 10
Page 1 of 2
See attached
'
11 A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
Responsible Ihnager Date RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
Resg>nsible Manager Date RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECEIVED DATE REMARKS:
ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DATE
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
O SATISFACTORY
UNSATISFACTORY: CARISSUED
CAR NO. ..
~
DATE
APPROVED:
_
AUDITOR DATE QUALITY DIVISION MANAGER DATE
NB-86-01
. , Plant Staff & Training
'
i
Page 2 of 2
Audit Finding No. 10
The QA Manual, Section 5, requires that activities
affecting quality be accomplished in accordance with
documented instructions and procedures.
Contrary to this requirement, procedures related to
training were deficient in that they lacked information or
contained inaccurate information which precluded effective
accomplishment of training activities; this was illustrated
by the following:
'
a) SP 12.014.04, " Training Respons. i
n T! es
responsibilities for training that
responsibility of the Nuclear Training
Policy 21, para. 4.2.5(A). Since SP12.01%.
responsibilities that no longer apply to the .
Staff, the procedure should be deleted.
b) SP 12.014.02, " Training Supervisor" should be " Training
Administrator".
} c) SP 12.014.06, " Operations Training Specialist" should
be " Operations Training Supervisor".
d) SP 12.014.07, " Nuclear Plant Training Supervisor"
should be " Operations Training Supervisor".
e) SP 41.011.01, SP 31.001.01, SP 21.006.01 and SP
C1.011.01 all reference or specify compliance with SP
12.014.01. However, SP 12.014.01 was deleted without
any action to revise the aforementioned procedures (e.g.
delete outdated references, incorporate appropriate
requirements for final status of training records).
i
f) SP31.001.01, para. 8.2.7, requires the Maintenance
l Engineer to specify training requirements for Storeroom
personnel. However, the Maintenance Engineer no longer
'
identifies training requirements for Storeroom personnel
because they were transferred to the Nuclear Operations
Support Department. The procedure should therefore be
revised to reflect this organizational change.
(Reference Checklists A-10, 15(c, d, e, f), B-19(b), C-8
and E-7)
)
. _-
6,@ QUALITY ASSURANCE DEPARTMENT
INITIAL ISSUE
i AUDIT RESPONSE FORM RE-ISSUIE
ORGANIZ ATION ACTIVITY AUDITED: AUQJgMgER: gl TOR:
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J.L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING N O. 11
FSAR Section 13.2, para, 13.2.1.2.1.3, states "Requalification training for I6C
personnel will consist of refresher training associated with the GET and
individual study" (as described in subparagraphs 1-3). The paragraph further
requires " supervisory review of the individual study program".
Contrary to the above, no objective evidence could be found in the Station
Procedures that an " individual study program" exists.
(Reference Checklist C-3(e))
~
11 A PROPOSEn CORRECTIVE ACTION COMPLETION DATE
t
RESPONSIBLE MANAGER DATE
PREVENTIVE ACTION COMPLETION DATE
.
RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECEIVED DATE REM ARKS:
ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DATE
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
-
O SATISFACTORY
) UNSATISFACTORY: CARISSUED
CAR NO. DAT E
APPROVED:
,
AUDITOR DATE". QUALITY DIVISION MANAGER DAT E
.. ---
._. __ _
[[bN OUALITY ASSURANCE DEPARTMENT
@ INITIAL ISSUE
>
AUDIT RESPONSE FORM o aEiSsuE
ORMNIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Training NB-86-01 JAM
SENT TO (RESPONS:GLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J.L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING NO 12
SP 41.011.01 and SP Cl.0ll.01, para. 8.3.1 through 8.3.6, require personnel to
participate in on going Refresher Training. The refresher training is to be
administered via classroom training, tailboard sessions and the Required Reading
Program.
Contrary to the above, there was no objective evidence that "tailboard
sessions" were being conducted by the I6C and Computer sections as required.
(Reference Checklist C-3(e))
'
II A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
')
RESPONSIBLE MANAGER DATE
ll6 PROPOSED PREVENTIVE ACTION COMPLETION DATE
.
RESPONSIBLE MANAGER DAT E
Ill. RESPONSE EVALUATION RECElVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
O SATISFACTORY
) O UNSATISFACTORP CAR ISSUED
1 ( CAR NO. DATE - l APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
[[Mj QUALITY ASSURANCE DEPARTMENT
C INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
AUDITOR: -
'
ORCANIZATION / ACTIVITY AUDITED: AUDIT NUMBER:
Training NB-86-01 JAM
AUDIT DATE: RESPONSE DUE BY:
SENT TO (RESPONSIBLE INDIVIDUAL)
J.L. Srtith 4 /7-16 /R6 6/13/0G
1. AUDIT FINDING NO. 13 1M2
See Attached
'
COMPLETlON DATE
ll A. PROPOSED CORRECTIVE ACTION
) RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECElVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
~
O NOT ACCEPTABLE: CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER D AT E
IV. VERIFICATION REMARKS:
O SATISFACTORY
O UNSATISFACTORY: CARISSUED
-
CAR NO. . DAT E
APPROVED:
,
AUDITOR DATE QUALITY DIVISION MANAGER DATE
NB-86-01
-
. Training ~
i Page 2 of 2
Audit Finding No. 13
SP 41.011.01, para. 8.2.2, states " Technicians shall be
qualified on safety related systems and equipment listed in
Appendix 12.1 in order to independently perform testing or
troubleshooting associated with the system or equipment".
SP 41.011.01, para. 8.2.3, states "A technician qualified
to work on the equipment listed in Appendix 12.1 may be
assigned work on that equipment independent of the system in
which the equipment is located".
SP 41.011.01, para. 8.4.1, states "A record shall be
maintained for each technician indicating qualification
status, (i.e. SPF 41.011.01-1)". A note further states
i
"This record shall indicate the basis used for qualifying
the technician and shall be signed by I&C supervision or by
the Training Section".
Contrary to the above, Appendix 12.1 (SPF 41.011.01-1) was
not being utilized as required in that:
a) The clerical staff of the Nuclear Training Division was
incorrectly signing "for" on the qualification summary,
b) The qualification summaries for some individuals were
incorrect due to clerical errors.
(Reference Checklist C-3(d))
I .
[[dS@ QUALITY ASSURANCE DEPARTMENT
Q INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
, ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR: -
Plant Staff and Training NB-86-01 Jvn
AUDIT DATE: RESPONSE DUE BY:
SENT TO (RESPONSIBLE INDIVIDUAL)
W.E. Steiger & J.L. Smith (ioint resnonse rea'd) 4/7-16/86 G/13/86
1. AUDIT FINDING NO. 14 Page 1 of 2
See attached
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
) Responsible Phnager Date RESPONSIBLE MANAGER DATE
11 B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
4
i
Resnonsible runager Date RESPONSIBLE MANAGER DATE
111. RESPONSE EVAL UATION RECEIVED CATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
O NOT ACCEPTABLE: CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER D AT E
IV. VERIFICATION REM A RKS:
C SATISFACTORY
O UNSATISFACTORY: CARISSUED
CAR NO. ,
'
DATE
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
a 4, M J
NB-86-01
,
*
Plant Staff & Training
y Page 2 of 2 -
Audit Finding No. 14
NOC Policy 21, para. 4.1.4, requires that each department
define, maintain current, and document the training needs of
it's organization.
Contrary to this requirement, SP21.006.01, Rev. 7, does not
identify, for Radwaste Operators, the frequency for
continuing training and retraining or how this is
documented; does not contain provisions on relieving persons
from duty following an unsatisfactory evaluation of
proficiency; or identify the use of the annual evaluation
as the basis for training or retraining. In addition, the
procedure does not specifically address training needs for
Radwaste Operators who were hired before January 1, 1986.
(Note that SP 21.006.01, Rev 7, applies to persons hired
after 1/1/86.)
(Reference Checklist D-1(h3), 1 (j 3), 1(k3) and 4)
)
-
e
i
. _ _ . _ _ _ . _ . . . _ _
Md,@ OUALITY ASSURANCE DEPARTMENT
' 2 INITIAL ISSUE
AUDIT RESPONSE FORM O RE-iSSOE
OR5ANIZ ATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Training NB-86-01 JAM
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J.L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING NO. 15
SP 12.014.02 " Training and Qualification Folder", para. 8.2.2, requires
training performance evaluations to be maintained in the training and
qualification folders for personnel not required to be licensed (Appendix 12.2,
item 3).
Contrary to the above, personnel training and qualification folders do not
contain training performance evaluations for the Maintenance, Modification, I&C,
and Computer Section personnel. In addition, the procedure does not define
" training performance evaluation."
(Reference Checklist C-2 and E-3)
'
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
:
)
RESPONSIBLE MANAGER DATE
ll B PROPOSED PREVENTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DAT E
Ill. RESPONSE EVALUATION RECEIVED DATE REM ARKS:
ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
! NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
l l '
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
-
O SATISFACTORY
) O UNSATISFACTORp CAR ISSUED
, CAR NO. DATE l
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
-_ - . __ .__ __ _ _
__ _ - _ _ _ _
[[b(9 OUALITY ASSURANCE DEPARTMENT
@ INITIAL lSSUE
AUDIT RESPONSE FORM O RE-ISSUE
OR3* N12ATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
N05D QS-86-03 J. Powers /R. Savage
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
B. R. McCaffrey 4/7-16/86 6/13/8G
l. AUDIT FINDING NO. 18
Page 1 of 2
See Attached
'
11 A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
)
RESPONSIBLE MANAGER DATE
11B PROPOSED PREVENTIVE ACTION COMPLETION DATE
.
- RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECEIVED DATE REMARKS:
ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM ARKS:
*
O SATISFACTORY
) O UNSATISFACTORp CAR ISSUED
CAR NO. DATE
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
.. _-. - - .
QS-86-03
,
,
NOSD
i Audit Finding 18 -
Page 2 of 2
QA Manual, Section 17, para. 17.3.2b, states in part,
" Measures shall be established to assure that sufficient
records are generated and maintained to furnish evidence of
the satisfactory completion of quality-affecting activities.
Such records include... evidence of training and qualification
of personnel...".
NOSD Procedure 17 " Training of NOSD Personnel", para. 5.2,
states " Division Managers are responsible for the
determination of training requirements for each position in
their division and the training needs of the individuals
assigned to a position. These shall include retraining
requirements".
Contrary to the above, there is no objective evidence on the
NOSD training needs matrices to show that the division
managers have made these determinations. Moreover, there is
no method or provision stated in NOSD-17, or included on the
needs matrix form itself, for the managers to sign / initial
and date in order to substantiate the record and show
evidence of their actions.
(Reference QS-86-03 Checklist Attributes 17, 18)
- --
.- -
'
[[[d9 QUALITY ASSURANCE DEPARTMENT
O INITIAL-lSSUr
AUDIT RESPONSE FORM O RE-ISSUE
ORS *.NIZ ATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
NOSD OS-86-03 J. Powers
SENT TO (RESPONSIBLE INDIVIOUAL) AUDIT DATE: RESPONSE DUE BY:
E. R. McCaffrev. 4 /7-16 /R6 6 /11/R6
1. AUDIT FINDING NO. 24
NOC Policy 21, " Nuclear Training", para. 4.2.6.1, requires nuclear and non-nuclear
departments to define annual training goals and objectives in accordance with the
training standards, and to provide initial and quarterly progress status to the
Nuclear Training Division.
Contrary to the above, NOSD Procedure 17 does not identify requirements for quarterly
status reporting, and NOSD has not developed annual training goals and objectives or
quarterly reports on the progress of training as required by this NOC Policy.
(Reference QS-86-03 Checklist Attributes 3a, 16)
II A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
'
h
RESPONSIBLE MANAGER DAT E-
11 B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
.
i RESPONSIBLE MANAGER CAT E
111. RESPONSE EVALUATION RECEIVED DATE REMARKS:
i
ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REMARKS:
O SATISFACTORY
l ) O UNSATISFACTORP CAR ISSUED
, CAR NO. DATE l APPROVED: 1
AUDITOR DATE QUAllTY DIVISION MANAGER DATE
._
[[[,@ OUALITY ASSURANCE DEPARTMENT
.- @ INITIAL ISSUE
AUDIT RESPONSE FORM O RE-ISSUE
OAGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITORi
Training OS-86-03 R . S ava ge /k'. Rath
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
3. L. Smith 4 /7-16 /A 6 6/13/8G
1. AUDIT FINDING NO. 25
Page 1 of 2
See Attached
ll A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
'
)
RESPONSIBLE MANAGER DATE
11 B PROPOSED PREVENTIVE ACTION COM.PLETION DATE
.
!
- RESPONSIBLE MANAGER DATE
'
111. RESPONSE EVALUATION RECEIVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
j CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
O SATISFACTORY
) O UNSATISFACTORP CAR ISSUED
CAR NO. DATE
-
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
__
QS-86-03
.
, Training
Audit Finding 25 -
Page 2 of 2
NOSD Procedure 17, para. 6.4.1.1, requires Training Program
Files to include a. log which records the dates and times the
training program was conducted, a grade reporting sheet, a
copy of the written completion examination (s), a topical
outline and the lesson plan.
Contrary to the above;
a) The Instructor Training Program File had no log sheet,
grade reporting sheet, or examinations.
b) The Storeroom Personnel Training Program File had no
lesson plan, outline, or log sheet,
c) A Training Program File for onsite/offsite Emergency
Preparedness Administration training had not been
assembled.
(Reference QS-86-03 Checklist Attributes 18, 26, 33)
I
.
.
y -
,
4
e
e
e- - - -
.
'
[[b9 OUALITY ASSURANCE DEPARTMENT
@ INITIAL ISSUE
AUDIT RESPONSE FORM
~
O RE-issue
ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Training OS-86-03 W. Rath
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J. L. Smith 4/7-16/86 G/13/SG
l. AUDIT FINDING NO, 26
NOSD Procedure 17, para. 6.3.2, requires classroom training to be conducted using
lesson plans approved by the Nuclear Training Division and the cognizant section
supervisor.
Contrary to the above, Training Program Files for the Instructor Training Program.and
Storeroom Personnel Training did not have approved Lesson Plans. In addition, the
Lesson Plan for NOSD Procedure 11 training had not been approved by the Nuclear
Training Division prior to training being given.
(Reference QS-86-03 Checklist Attributes 18, 23, 24, 26, 33)
II A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
'
)
RESPONSIBLE MANAGER DATE
il B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
.
l
RESPONSIBLE MANAGER DATE
lll. RESPONSE EVALUATION RECElVED DATE REM ARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
i AUDIT TEAM LEADER DATE
IV. VERIFICATION REM ARKS:
l S ATISFACTORY '
) O UNSATISFACTORY: CARISSUED
CAR NO. DATE
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
l
-
6,@ OUALITY ASSURANCE DEPARTMENT x INITIAL.lSSUE
AUDIT RESPONSE FORM O RE-ISSUE
ORGANIZ ATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Training QS-86-03 R. Savage /J. Powers
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J. L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING N O. 27
NOSD Policy 21, para. 4.2.5, requires the Nuclear Training Division to provide
training, establish and maintain INPO accreditation, coordinate training activities,
develop training stardards and perform other activities associated with training.
Contrary to the above policy, the Nuclear Training Division had not issued an
administrative training manual or Nuclear Training Division procedures governing the
implementation of NOC Policy requirements.
(Reference QS-86-03 Checklist Attributes 2, 35)
*
11 A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
]
RESPONSIBLE MANAGER DATE
11 B PROPOSED PREVENTIVE ACTION COMPLETION DATE
!
RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECEIVED DATE REM A RKS:
ACCEPTABLE : VERIFICATION BY
! NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DATE
~
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
O SATISFACTORY
) O UNSATISFACTORY: CARISSUED
'
CAR NO. DATE
APPROVED:
,
AUDITOR DATE QUALITY DIVISION MANAGER DATE
1
- [[b@ .
QUALITY ASSURANCE DEPARTMENT _
x INITIAL ISSUE
AUDIT RESPONSE FORM Cl RE-ISSUE
ORG.ANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Training QS-86-03 R. Savage
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
3. L. Smith I./7-16/86 6/13/86
1. AUDIT FINDING NO. 28
Page 1 of 2
See Attached
11 A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
'
)
RESPONSIBLE MANAGER DATE
II B PROPOSED PREVENTIVE ACTION COMPLETION DATE
.
RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECElVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
D NOT ACCEPTABLE:
CAR NO. ISSUED- DATE
AUDIT TEAM LEADER DATE
S TISFACTORY
) O UNSATISFACTORY: CARISSUED
CAR NO. DATE
APPROVED:
>
AUDITOR DATE QUALITY DIVISION MANAGER DATE
A _ _ . _ _ _ - - - _ _ . _ . . - _ . _ _ __ . . _ . _
_--- --
.
QS-86-03
.
,
Training
Audit Finding 28 -
Page 2 of 2
EPIP-5-4, section 2.0, states that the Nuclear Support
Training Supervisor is responsible for detailed
implementation of the Emergency Preparedness Training
Program, ensuring proper documentation, and approval of
lesson plans and examinations.
Contrary to the above, the Nuclear Training Division files
have either incomplete and/or inaccurate information
concerning Emergency Preparedness Training. This is due to
the fact that the Nuclear Emergency Preparedness Division is
presently performing these activities and not sending
completed information to the Nuclear Training Division.
(Reference QS-86-03 Checklist Attribute 27)
)
, (
- .+
!
- __. .-.
'
[[439 QUALITY ASSURANCE DEPARTMENT
@ INITIAL JSSUE
AUDIT RESPONSE FORM O RE-ISSUE
ORGANIZ ATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
NOSD QS-86-03 J. Powers
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J. L. Smith 4/7-16/86 6/13/_86
1. AUDIT FINDING N O. 29
Page 1 of 2
See Attached
11 A. PROPOGED CORRECTIVE ACTION COMPLETION DATE
'
h
RESPONSIBLE MANAGER DATE
ll B PROPOSED PREVENTIVE ACTION COMPLETION DATE
.
RESPONSIBLE MANAGER DATE
l 111. RESPONSE EVALUATION RECEIVED DATE REMARKS:
O ACCEPTABLE: VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM A RKS:
O SATISFACTORY
) O UNSATISFACTORY: CARISSUED
CAR NO. DATE
APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
,
QS-86-03
,
*
NOSD
Audit Finding 29 -
Page 2 of 2
Memorandum VPN085-183, J.D. Leonard to J.L. Smith, dated
7/26/85, directed that the " Corporate Nuclear Training
Administrative Manual" be withdrawn from use.
PD-SD-Il Rev 0, dated 2/28/84, " Corporate Nuclear Training",
para. 5.2, states "The Corporate Nuclear Training
Administrative Manual shall serve as the complete description
of the Corporate Nuclear Training Program".
Because the Corporate Nuclear Training Administrative Manual
was withdrawn from use as a result of VPN085-183, PD-SD-Il
and it's associated implementing procedures (SD-11-01 to
SD-11-10) are obsolete and should be deleted from the Nuclear
Organization Management Control Program Manual.
(Reference QS-86-03 Checklist Attribute 2)
)
.
.
w ,,
NN QUALITY ASSURANCE DEPARTMENT
Q INITIAL ISSUE
AUDIT RESPONSE FORM [] RE-iSs0E
OR3ANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Training l
QS-86-03 S. Volk 1
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
J. L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING NO. 32
General Services Department (Production Training Center) Procedure WI-R, " Procedure
for Welding Instructor Requirements", Rev 1, para. 8.1, identifies 5 courses that a
velding instructor must complete before or after assignment to the position. Further,
para. 8.3.1 requires that these courses be completed within the first 24 month time
period of the date of assignment to Mechanic A-1 velding instruction. .
Centrary to the above, no objective evidence was found that the Mechanic A-1 Welding
Instructor had completed 3 of the 5 courses within the required time frame.
(Reference QS-86-03 Checklist Attribute 53)
II A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
'
)
RESPONSIBLE MANAGER DATE
11 B PROPOSED PREVENTIVE ACTION COMPLETION DATE
,
- .
(
1
RESPONSIBLE MANAGER DATE
j 111. RESPONSE EVALUATION RECElVED DATE REM A RKS:
ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM ARKS:
-
O SATISFACTORY
l
) UNSATISP.CTORY: CARISSUED
CAR NO. DATE *
j APPROVED:
AUDITOR 9 ATE QUALITY DIVISION MANAGER DAT E
-
b[89 QUALITY ASSURANCE DEPARTMENT
x INITIAL ISSUr
AUDIT RESPONSE FORM RE-ISSdE
ORSANIZ ATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Training QS-86-03 S. Volk
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
*
J. L. Smith 4/7-16/86 6/13/86
1. AUDIT FINDING NO. 33
General Services Department (Production Training Center) Procedure WI-R, " Procedure
for Welding Instructor Requirements", Rev 1, para. 8.4.1, requires that welding skill
competence demonstration requirements be completed by a Welding Instructor assigned to
Mechanic A-1 welding related job duties prior to the actual assignment date.
Successful completion of 5 tests is required.
Centrary to the above, no objective evidence was found that the Mechanic A-1 welding
instructor had completed 4 of the 6 required tests prior to instructing a Mechanic A-1
welding course.
(Feference OS-86-03 Checklist Attribute 51)
'
II A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
)
RESPONSIBLE MANAGER DATE
11 B PROPOSED PREVENTIVE ACTION COMPLETION DATE
'
l l RESPONSIBLE MANAGER DATE
111. RESPONSE EVALUATION RECElVED DATE REMARKS:
ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
IV. VERIFICATION REM ARKS:
*
O SATISFACTORY
) O UNSATISFACTORP CAR ISSUED
CAR NO. DATE
l APPROVED:
AUDITOR DATE QUALITY DIVISION MANAGER DATE
- - - _ . . .. _.
.6 N QUALITY ASSURANCE DEPARTMENT
G INITIAL.lSSUE
)' AUDIT RESPONSE FORM C RE-ISSUE
ORGANIZATION / ACTIVITY AUDITED: AUDIT NUMBER: AUDITOR:
Information Systems QS-86-03 J. Powers
SENT TO (RESPONSIBLE INDIVIDUAL) AUDIT DATE: RESPONSE DUE BY:
K. R. Lewis 4/7-16/86 6/13/86
1. AUDIT FINDING N O. 34
NOC Policy 21, para. 4.2.6, identifies the specific requirements that each nuclear and
non-nuclear department shall satisfy in implementing the training for their personnel.
Contrary to the above, the Information Systems Department has not developed a
procedure for implementing the NOC Policy requirements.
(Reference QS-86-03 Checklist Attributes 1, 3b)
~
11 A. PROPOSED CORRECTIVE ACTION COMPLETION DATE
RESPONSIBLE MANAGER DATE
ll B. PROPOSED PREVENTIVE ACTION COMPLETION DATE
-
t l !
RESPONSIBLE MANAGER CATE
111. RESPONSE EVALUATION RECElVED DATE REMARKS:
l ACCEPTABLE : VERIFICATION BY
NEW RESPONSE FORM SENT-DATE
NOT ACCEPTABLE:
CAR NO. ISSUED- DAT E
AUDIT TEAM LEADER DATE
l IV. VERIFICATION REMARKS: '
'
.
O SATISFACTORY
- ) O UNSATISFACTORP CAR ISSUED
CAR NO. DATE
APPROVED:
(
AUDITOR DATE QUALITY DIVISION MANAGER DATE
. ~ . - _ , _ _ . - _ _ _ _ - _ _ _ . - - - - - _ _ _
}}