RBG-23047, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-73.Corrective Actions:Review of All Radiation Protection Technician Qualifications Begun & Procedure RSP-0003 Will Be Revised by 860321

Responds to NRC Re Violations Noted in Insp Rept 50-458/85-73.Corrective Actions:Review of All Radiation Protection Technician Qualifications Begun & Procedure RSP-0003 Will Be Revised by 860321

ML20210C686
Person / Time
Site:	River Bend
Issue date:	01/28/1986
From:	William Cahill GULF STATES UTILITIES CO.
To:	Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20210C669	List: IR 05000458/1985073 RBG-23047, Responds to NRC Re Violations Noted in Insp Rept 50-458/85-73.Corrective Actions:Review of All Radiation Protection Technician Qualifications Begun & Procedure RSP-0003 Will Be Revised by 860321
References
RBG-23047, NUDOCS 8603260098
Download: ML20210C686 (6)

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GULF STATES UTILITIES COMPANY RIVER BEND STAT 60N POST OFFICE BOX 220 ST FRANCISVILLE. LOUISIANA 70775 arf A CODE 504 635 6094 348 8651 January 28, 1986 RBG- 23047 File Nos. G9.5, G15.4.1 Mr. Robert D. Martin, Regional Administrator U.S. Nuclear Regulatory Conunission Region IV 611 Ryan Plaza Drive, Suite 1000 Arlington, Texas 76011

Dear Mr. Martin:

River Bend' Station - Unit 1 Refer to: Region IV' Docket No. 50-458/ Report 85-73 This letter responds to the Notice of Violation and Notice of Deviation contained in ~ NRC I&E Inspection Report No.

50-458/85-73. The inspection was conducted by'Mr.'H.D. Chaney during the period October 28 through November 1, 1985 of activities authorized by NRC Operating License NPF-40 for River Bend Station Unit No. 1.

Gulf States Utilities Company's (GSU) response to the Notice of Violation- 85-73-01, " Failure to Provide Training" and 85-73-02, " Failure to Maintain Training Records", and _ Notice of Deviation 85-73-03, " Training of Senior Radiation Protection Technicians", are provided in the enclosed attachments. This completes GSU's response to the Notice of Violation and Notice of Deviation.

Sincerely,

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e W. J. Cahill Jr.

Senior Vice President River-Bend Nuclear Group WJC JK/EMC/je Attachments g@ B OMM T;L

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. . s Attachment 1 RBG-23047' January 28, 1986 NOTICE OF VIOLATION LEVEL IV REFERENCE Notice of Violation - J. E. Gagliardo letter to W. J. Cahill, Jr.

dated December 30, 1985.

A. FAILURE TO PROVIDE TRAINING ,

REASON FOR VIOLATION The NRC inspector determined on October 31, 1985, that- eight designated Senior Technicians had not been provided training courses as requireC ,Section I.B.11 of. Attachment 3 to RSP-0003.

The Radiation Protection Technician (RPT) On-The-Job-Training (OJT) Training / Qualification Program was phased in during initial approval of Radiation Protection procedures and program development. Qualification. cards, standards, and consequently, the RPT_ Qualification Matrix (Attachment #3 to RSP-0003), were developed in parallel. During the end of the 1st quarter 1985 and thru the 2nd quarter, an emphasis of RPT qualifications for those designated ANSI technicians began.

Not all qualification cards, including Item I.B.ll, Drywell Entry, were finalized at this time. Consequently, when the Drywell Entry Qualification . Card was completed and qualification began, those ANSI RPT's who had completed their qualification earlier were inadvertently overlooked.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A review of all RPT qualifications has begun. Those qualifications not completed have been identified and progress is being made to complete these qualifications as soon as possible. Emphasis and first priority are the ANSI designated technicians.

CORRECTIVE STEPS WH7.CH WILL BE TAKEN TO AVOID FURTHER VIOLATION The River Bend Station Tt'aining Department and the Radiological Programs Department have begun discussions on improving the RPT OJT Program. A review by the Training Department of the Qualification Matrix, Cards, and Standards-is scheduled to begin February 1986 and be completed by approximately May 1986. An RPT Foreman will be assigned to coordinate with the Training Department and implement-appropriate changes to the OJT Program. This individual will also be directly responsible for ensuring that RPT

y. j Attachment 1 (cont ' d. ) Page 2 RBG-23047 January 28, 1986

-qualifications are maintained as ." outlined in Station Operating Procedures.

DATE WHEN FULL COMPLIANCE WILL SE ACHIEVED A review of the current matrix to determine completeness of ANSI technician qualifications will La performed. Those qualification cards which axe approved will be completed by February 28, 1986.

A revision to RSP-0003, " Personnel Qualification for the Radiation Protection Section", to delete those qualifications already covered by other qualification cards or those that are no longer required. Will be completed by March 21, 1986.

A review by the Training Department of the RPT OJT Qualification Program will be completed by May 2, 1986.

Appropriate changes recommanded by the Training -Department will be-incorporated by September 5, 1986.

The appropriate finalization of RPT's qualification program will'be accomplished by January 16, 1987.

B. FAILURE TO MAINTAIN TRAINING RECORDS REASON FOR VIOLATION The NRC inspector determined on October 31, 1985 that the Qualification Matrix for eight Senior Radiation Protection Technicians had not been updated for periods in excess of 8 months.

Changes in management responsibility and personnel, coupled with clerical staff changes and lack of training, caused this oversight.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED As . stated in Item A, a Radiation Protection Foreman will be assigned to implement the RPT Qualification Program, and this individual will be responsible for ensuring that the Qualification Matrix is maintained as outline in the Station Operating Procedures.

. . V Attachment 1 (cont ' d. ) .Page 3 v RBG-23047 January 28, 1986 CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The PRT Foreman will be directly responsible for ensuring the Qualification Matrix is updated. Appropriate training of-clerical staff =will avoid further errors associated with the'

, Qualification Matrix.

DATE WH2N FULL COMPLIANCE WILL BE ACHIEVED

, The Radiation Protection Foreman will be assigned by January; r

31, .1986. -The appropriate clerical staff will be fully indoctrinated.by February 14, 1986.

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Attachment 2 RBG-23047 January 28, 1986 NOTICE OF DEVIATION

REFERENCE:

Notice of Deviation - J. E. Gagliardo letter to W. J. Cahill, Jr.

dated December 30, 1985.

IDENTIFIED DEVIATION The NRC Inspector determined on October 31, 1985 that only one out of eight Senior Radiation Protection Technicians had received the specified training.

CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED An initial review of the ANSI Technicians qualification was performed by the Radiation Protection Group. It was determined, on an individual basis, that prior experience and the completion of a Radiation Protection on-the-job t;aining system qualification card was sufficient to meet the intent of the FSAR with regard to Systems Training. No waiver. of training was completed during this initial review. Consequently no documentation of this evaluation appears in the qualification folder. The Radiation Protection Group will perform another evaluation of the ANSI Technicians experience and based on this review will either a) schedule the Technicians for Systems Training or b) complete a waiver of training as described in RBS FSAR, Section 13.2.1 and submit the waiver to the training file.

CORRECTIVE STEP ( WHICH WILL BE TAKEN TO AVOID FURTHER DEVIATIONS The procedure which provides guidelines for Radiation Protection training, RSP-0003, will be revised to incorporate the use of the waiver form to document any waiver of training -based on experience.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The review of Radiation Protection Technicians prior experience and the applicable waiver will be completed by March 7, 1986.

Those ANSI Radiation Protection Technicians who do not have sufficient prior BWR experience to fulfill the requirements will be scheduled and complete the General Systems Training before December 31, 1986. RSP-0003 will be revised by March 21, 1986.

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UNITED STATES OF ANERICA NUCLEAR REGULATORT C00 MISSION STATE OF LOUISIANA 5 PARISH OF WEST FELICIANA 5 In the Matter of $ Docket Nos. 50-458 CULF STATES UTILITIES COMPANY l (River Bend Station, Unit 1)

AFFIDAVIT W. J. Cahill, Jr., being duly sworn, states that he is a Senior Vice President of Culf States Utilities Company; that he is authorized on the part of said Company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.

- A Cahill, Jr. [ '

Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this 2Pf4 day of 1nda r-(/ ,19d.

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Abh l .N .W oanW.Middlebroohs

/NotaryPublicinandfor West Feliciana Parish, Louisiana My Commission is for Life.

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