ML20133E811: Difference between revisions
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| number = ML20133E811 | | number = ML20133E811 | ||
| issue date = 04/02/1984 | | issue date = 04/02/1984 | ||
| title = Advises That Concerns Expressed in Ofc of Investigations 840224 Memo Re Util | | title = Advises That Concerns Expressed in Ofc of Investigations 840224 Memo Re Util Concerning Licensee Actions & Programs to Satisfy NRC Requirements & FSAR Commitments for Nonlicensed Personnel Focus on Different Issues | ||
| author name = Verrelli D | | author name = Verrelli D | ||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) | ||
Latest revision as of 01:44, 10 August 2022
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\ . . . . . ./ APR 0 2 S84 gn APR -3 pg is 03 MEMORANDUM FOR: Robert H. Burch, Investigator, Office of I g g q-THRU: R. C. Lewi s, Director, Divi sion of ProjeEGN..,R'esttfeW n;n.'N T.
Programs (DPRP)
FRON: D. M. Verrelli, Chief, Project Branch 1, DPRP
SUBJECT:
" CASE NO. RII 84A 0023" Your memorandum dated February 24, 1984, sumarized concerns expressed by a Confidential Source (CS) that the statements contained in MP&L letter AECM-84/0100 dated February 11, 1984 are deceptive. The concerns e'xpressed in your memorandum are focused on training of mechanical maintenance personnel, whereas the MP&L letter focuses on licensee actions and programs to satisfy NRC requirements and FSAR com.mitments for non-licensed personnel. There is a distinct dif ference between these and licensee procedures which are over and above regulatory requirements. As I best recall from your initial briefing, the concerns by the CS were more along the lines of competence of certain mechanical maintenance supervisors, inadequate records and falsified data.
p I. REGULATORY REQUIREMENTS ISSUES N"I (1) The CS stated that Mechanical Maintenance personnel have not received
" Fire protection and fire fighting organization training."
A regional-cased inspector conouctec a review of the Grand Gulf fire protection program in mid-1983. The results are documented in Inspection Report No. 83-26.
As stated therein, the licensee's fire brigade is constituted only of operations personnel. Organization and training have been adequately accomplished. Regional-based inspectors have also reviewed the portions of the licensee's Emergency Plan as related to fire protection. As indicated therein, there is no licensee commitment for fire pr:tection training of mairterance pe sonrel. Neve-the'ess, a re:ent inspe: tion was concu:ted by the Senior Resicent Inspe:to c.- ng an emergency drill at Grand Gulf. The inspection included a review of licensee internal procedures and training records for Mechanical Maintenance. Our finding is that the licensee violated his procedure for fire protectior training and a Notice of Violation will be issued (IR 84-07). Licensee management has been asked to address appa ent discrepancies in training records.
(2) The CS took exception to the statement that "speciali:ed traininc for maintenance. . personnel" is being concucted f During the period January 17-20, 1984, a regional based inspe: tor 1
( conducted an assessment of non-licensed personnel training at the Grant.
Gulf facility. The results are documented in Inspection Report 50-416/84-02.
8508080025 050801 PDR ADOCK 05000416 l 0 PDR Ep !cJ ..
APR 0 21984
< l Robert H. Burch 2 1
l As a follow-up to this ef fort a regional-based supervisor reviewed ,
during the week of February 20, 1984, maintenance and training department records of vendor schools' training. The findings support a conclusion that FSAR commitments have been met. Specialized vendor training has been provided in the areas of Diesel Generator sets; control rod drives and instrumentation.
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In this regard, at the meeting of January 30, 1984, Region II management asked the licensee what assurance we have that when
- maintenance is being performed which requires specialized training, that at least one of the individuals on the crew had received it. The licensee stated that this was a line responsibility, and that no policy
- statement had been issued. We related to the licensee that this was not adequate. Accordingly, subsequent to the meeting, MP&L issued the two Grand Gulf memoranda attached to your memorandum. Thus we do not find the licensee's actions to imply that they were in place at the time of the meeting.
Further, in regard to " sufficient" numbers of personnel who have completed the various training programs, this is a judgment and is not inspectable.
II. ADEQUACY OF CONTROLS OF MAINTENANCE ACTIVITIES We continue to be concerned over the adequacy of maintenance supervision and
, staf f at the Grand Gulf f acility. This was a functional area rated as a Category 3 during the last SAlp evaluation. This area will be reviewed during another Operational Readiness Inspection to te completed during the first week in April 1984. We will advise you of our fi,ndings.
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Da id M. rrelli i cc: C. A. Julian i
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i Q RESULTS OF INTERVIEW WITH EDDlE LEE HENh!NGTON ON MARCH 26, 1984 AS PREPARED BY ROBERT H. BURCH On March 26, 1984, Eddie Lee HENNINGTON was interviewed at his residence by Investigator Robert H. Burch. HENNINGTON, who resides at advised he has been employed at the Mississippi Power and Light Company's (MP&L) Grand Gulf Nuclear Plant (GG) as a Mechanical Maintenance Supervisor since March 1981. He advised that prior to working at GG he was employed in a similar position for five years at Virginia Electric and Power Company's Surry Nuclear Power Plant. He said he is retired fron the U.S. Navy where he served in the nuclear surface program.
HENNINGTON advised that when he first came to the MP&L/GG facility in March 1981 there was no plant administrative procedure for the Mechanical Maintenance Non-Licensed Training program.< He said that the GG plant did not actually belong to MP&L at that time since Bechtel had not completed the start up program. He said the start up engineers were employees of Bechtel, General Electric, other contractors and MP&L, although Bechtel was responsible for all of the start up activities. HENNINGTON advised that by January 1982, when Administrative Procedure 01-5-04-17 Revision 0, Mechanical Maintenance Training Program was issued, most of the GG systems had been turned over to MP&L. He said the MP&L/GG Training Department was given the responsibility for implementing the Mechanical Maintenance (a)
V Non-License Training Program. He said that MP&L employee Jim JONES was the individual responsible for ensuring that the Practical Factor (PF) Sheets, an attachment to the Administrative Procedure, were distributed to the mecharics for Co*pleticr.
HENNINGTON advised that he first saw the PF sheets in early 1982. He described the PF document as a listing of approximately 40 tasks that each mechanic is required to perforTn as a part of their work assignments. He said this is considered on-the-job training for mechanic personnel.
HENNINGTON said he did not see the Administrative Procedure which implements the PF sheets for a considerable time after he first saw the PF sheets. He stated that PF sheets listing the 40 tasks were given to him in early 1982 for each of the six to eight mechanics in his crew by the Assistant Maintenance Superintendert Billy B00'5. He said BOOTS gave atsclutely nc instructions regarding the com;letior. of the PF sheets arc nc time limit was placed on the completion of these documents. He sa1C the only coninent that he recalled from BOOTS was that the signatures and dates to be placed on the PF sheets by supervisors should be spread over a period of time. He said BOOTS did not elaborate on this remark. HENNINGTON advised that BOOTS gave no further instructions regarding completion of the PF sheets. He said that, in his opinion, BOOTS did not suggest falsifying the PF sheets or completing then "just for the sake of filling in blanks."
He stated that neither BOO'S nor Maintenance Superintendent D. O. STAE:,
made any remarks regarding the corpletion of the PF sheets which he inter-preted as improper or illegal. HENNINGTON stated that, in his opinion, the mechanical maintenance supervisors had to use their own imaginations as to how they were to complete the PF sheets for their mechanics since upper
( "f maintenance management did not provide any instructions or directions regarding completion of this document.
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\s_ / HENNINGTON advised that since he was not given instructions regarding the comple tion of the PF sheets, he and fellow supervisor Bill BRADLEY discussed alternative methods for performing this requirement. He said that he and BRADLEY mutually agreed to allow mechanics in their crews to identify the first date they had performed the tasks listed on the PF sheets. He said he told BOOTS that he intended to complete the PF sheets in this fashion. He said BOOTS responded that he did not care how the PF sheets were completed as long as supervisors felt comfortable that the mechanics could perform the listed tasks. He said BOOTS also told him that every journeyman mechanic should be able to perform all of the tasks listed on the PF sheets. HENNINGTON advised that with this limited guidance from BOOTS and not having seen the Administrative Procedure at the time, he distributed the PF sheets to all mechanics in his crew. He said he told each mechanics to review all of the tasks on the PF sheets and to indicate the date each had perfonned the listed tasks or one similar to it.
HENNINGTON advised that he did not begin work on the PF sheets immediately and estimated that there was a delay of from six months to a year before he seriously began to complete the PF sheets for his crew members. He stated that when he collected the PF sheets from his crew members af ter they had indicated the dates on which they had performed listed tasks he began to satisfy himself that each mechanic could perform the listed tasks. He said he satisfied himself by discussing the tasks separately with each mechanic and required them to verbally explain the manner in which they had performed the tasks. HENNINGTON advised that he did not personally witness the performance of each and every task listed on the PF sheets by his
, mechanics but he satisfied himself that they knew how to perform these tasks through their verbal explanation of each process. He advised that he required each of his mechanics to explain the method of performing the task and the type of equipment used in the process.
HENNINGTON advised that not all of his crew members had performed all of the tasks listed on the PF sheets, however, some members of his crew had performed most all of the tasks listed. He stated he always assigned an inexperienced crew member with an experienced crew member and therefore trained his personnel in this manner to perform the tasks listed on the PF sheets. HENNINGTON advised that because some PF sheet tasks are performed more frequently than others, only about two or three mechanics actually completed all of the listed tasks. He advised that since January 1982 approximately 20 different mechanics have been assigned to his crew and he said he signed and dated some tasks on all of these PF sheets. He explained that he personally witnessed the performance of some of the tasks and he required individual mechanics to verbally explain the accomplish-ments of some tasks before he signed and dated the PF sheets. He reiterated that he was satisfied that each mechanic could perfonn the listed tasks before be signed and dated the PF sheets.
HENNINGTON advised that when the PF sheets were first distributed to the mechanics in January 1982 he was not aware that a " walk through" was required to verify that each mechanics could perform the listed task. He said that superintendents STAER and BOOTS were apparently not aware of this 1
/N requirement either since they did not instruct the first line supervisors
- ( to conduct the verifications in this manner. He advised that because he and BRADLEY had initially agreed, and BOOTS concurred, that mechanics would indicate the date on which they had first performed a task listed on the PF
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sheets, some of the dates they listed were dates prior to their coming to work at the MP&l./GG facility. HENNINGTON advised that as many as one third of the dates initially indicated by the mechanics are dates prior to their employment at the GG facility. He said this situation was first realized in about February 1984 and Superintendent BOOTS instructed all mechanical maintenance supervisors to correct these PF sheet dates and to have them l coincide with the period of time during which each mechanic had been employed by the GG facility. HENNINGTON advised that in February 1984 he l i
corrected some PF sheet dates for mechanics currently assigned to his crew.
He stated that although he did not personally witness all of these tasks,
{ he required each mechanics to again verbally explain the manner in which I each was perfomed. He reiterated that he was satisfied all mechanics were able to satisfactorily perform all PF sheet tasks which he signed and dated. HENNINGTON further advised that the mechanics assigned to his crew had, at one time or another since their employment at the GG facility, perfomed most of the tasks listed on the PF sheets. He stated that the dates he placed on the PF sheets are dates on which he interviewed the mechanics and had them verbally explain the perfomance of the tasks listed on the PF sheets.
HENNINGTON reiterated that he at no time falsified the PF sheets by signing and dating the tasks listed thereon. He stated that when he signed a PF sheet task for his crew members he was totally and completely satisfied that they could perfom the listed task.
HENh!NGTON advised that at no time did superintendents BOOTS or STAER (G'} direct or instruct him to falsify or improperly complete the'PF sheets. He stated he would not have done 50 even if told to complete them in an l illegal manner. He said he did not realize or understand the requirements l of the Administrative Procedure regarding the completion of the PF sheets ,
I until approximately February 1984, at which time he began to correct the i mistakes he had made. HENNINGTON advised that as of the time of his i interview he had witnessed approximately 98 percent of all tasks listed on the PF sheets for each mechanic in his crew. He explained that the only tasks he has not witnessed relate to fork lift training and he said this is accomplished in a specialized school of instruction for operators.
HENNINGTON identified comunica tions problems between maintenance supervisors and superintenderts as a primary cause of the PF sheets issue.
He explained that superintendents rarely, if ever, Oive adequate directions and instructions to supervisors and the supervist s are expected to be knowledgeable of maintenance activities in spite c the failure of super-intendents to keep them apprised of activities. He said maintenance efficiency and morale would improve markedly if superintendents would spend time with supervisors and listen to their complaints and concerns.
j HENNINGTON advised that he is also dissatisfied with the current tagging procedures to isolate a particular valve or components. He stated he has expressed this concern to his supervisors who have shown no interest in changing the present procedures. HENNINGTON explained that the current procedure allows the maintenance employee to tag a component needing
, Q maintenance rather than making the control room supervisor responsible for l
this activity. He said the control room personnel are better acquainted with all of the systems and components than are the maintenance personnel
4 O' and therefore are in a better position to isolate and/or deactivate a particular component that needs repairs. HENNINGTON advised that the maintenance department is not on the distribution list for updated prints and therefore maintenance personnel frequently find themselves working with prints which are out of date or having to locate a current print j before perfoming a particular maintenance function.
HENNINGTON concluded that he is not aware that any maintenance supervisor has falsified PF sheets and further advised he never discussed completion of the PF sheets with any person except Bill BRADLEY. He reiterated that at no time did Billy BOOTS, D. O. STAER or any other Maintenance Super-intendent direct or instruct him to falsify PF sheets or deliberately sign and date these documents without first satisfying himself that the mechanics were able to perform all tasks listed in a satisfactory and safe manner. HENNINGTON declined to provide a sworn statement, citing personal reasons as the basis for his declination.
END OF RESULT 5 OF INTERVIEW WITH EDDIE LEE HENNINGTON ON MARCH 26, 1984 I Robert H.' Burch, Investigator ov
RESULT 5 0F INTERVIEW WITH CHARLES RANDY HUTCHINSON ON APRll I?, 1984 AS PREPARED BY ROBERT H. BURCH Charles Randy HUTCHINSON was interviewed in his office at Mississippi Power and Light Company's (MP&L) Grand Gulf Nuclear Station (GG) on April I?,
1984 by Investigator Robert H. Burch. HUTCHINSON advised that he has been employed with MP&L on the GG project since July 1973. He said he has served in his present job as an Assistant Plant Manager since October 1983.
He advised that as an Assistant Plant Manager he is responsible for the Plant Maintenance Division at the GG facility.
HUTCHINSON advised that after the recent operator training deficiencies at the facility, which were investigated by the U.S. Nuclear Regulatory Comission, the President of MP&L, Mr. Jack RICHARD requested that GG plant officials conduct a review of non-license training in accordance with the FSAR comitments. He said this study was conducted by him and other GG officials and found that, although the FSAP commits MP&L to the training of employees assigned in the mechanical, electrical and instrumentation and control disciplines, it does not require Practical Factor (PF) sheets or Qualification Cards for maintenance personnel. He stated that he reviewed the requirements of the MP&L/GG procedure entitled Mechanical Maintenance Training Program, 01-5-04-17, in March 1984 after the Senior Resident Inspector (SRI) for the NRC adsised at a March 9, 1984 exit conference that (O
'j an unresolved item would be issued regarding the mechanical Practical Factors sheets. 'He said the SRI indicated he was citing the GG facility for violating its cwn procedure pertaining to PF sheets. HUTCHINSON stated that the GG Plant Manager then directed him to make incuiries regarding this matter ano tc determine the manner in which this plant procedure requirement had been implemented at the facility. He stated ' that the findings of the SRI reflected that one mechanical maintenance mechanic had a date entered on his PF sheet which was prior to the time the mechanic was actually employed by the MP&L/GG facility and said it was his (HUTCHINSON's) understanding that the Plant Manager desired him to deter-mine the reason this incident had occurred.
HUTCHINSON advised that he conducted a very limited inquiry as directed by Plant Manager CROSS and found that Maintenance Mechanics SPADLEY and HANDLEY had been credited with completing a PF task prior to the time they had been employed by MP&L/GG. He stated he reviewed the circumstances of these two instances and detennined they were given credit for the PF tasks because of prior experiences in these tasks at previous employment locations. HUTCHINSON advised that these two individuals told him they understood prior employment experience was acceptable in completing the Mechanical Maintenance PF sheets. HUTCHINSON further advised that he determined Mechanical Maintenance Mechanics were not familiar with the contents of the plant procedure entitled Mechanical Maintenance Retraining and Replacement Training Program. He said he also deterrined that m
Mechanical Maintenance mechanics and supervisors had violated this i procedure by improperly certifying completion of the tasks listed on the PF
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sheets. HUTCHINSON advised that his limited inquiry further disclosed no evidence of a deliberate, willful violation of the plant procedure and that unfamiliarity with the procedure had caused the PF sheets tasks to be rw H)
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certified improperly. HUTCHINSON stated that mismanagement and substandard supervisory controls at the first and second levels of supervision in the mechanical maintenance department had also played a major role in the PF sheet certification problems. He stated that the PF sheet problems indicated a lack of attention to details by these levels of management and a lack of their involvement in the enforcement of the plant procedure.
HUTCHINSON concluded that he did not probe into personality differences between mechanics and supervisors but said some mechanics and first line supervisors have either terminated with MP&L/GG or have been transferred to other divisions within the company because of apparent personality conflicts with Mechanical Maintenance Superintendent Dennis STAER.
END OF RESULTS OF INTERVIEW WITH CHARLES RANDY HUTCHINSON ON APRIL 12, 1984 Robert Hf Burch, Investigath O-od
MDio To: J. E. Cross FROM: L. F. Daughte ry SUM ECT: NRC Exit Meeting M1.nutes 50-416/84-07 IPC: 84/2008 Attached is a copy of NRC Exit Meeting Minutes 50-416/84-07.
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3/12/84 s3 JDB/LTD/j ic cc: R. F. Rogers J. W. Yelverton N
D. L. Hunt Plant File NRC File 84-07 .
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p NRC EXIT MINL*TES 50-416/84-07 l
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Report Number: 50-416/84-07 Date: March 9, 1984 Date of lospection: Pebruary 16 - March 9,1964 ,
Location: Plant Manager's Office i I
Attendees Titles Orgsnization l l
A. G. Wagner Senior Resident Inspector USh*RC I R. T. Roge rs Asst. Plant Mgr. - Ops MP&L i J. W. Telverton Asst. Plant Mgr. - Support MP&L l C. R. Hutchinson Asst. Plant Mgr . - Ma in t . MP&L l L. P. Daughtery Compliance Superintendent MP&L D. L. Hunt Training Superintendent MP&L J. E. Jones Mechanical Training Supv. MP&L Areas Inspec ted During the dates above, the inspector inspected the following areas:
maintenance; surveillance testing; reportable occurrences; Technical Specification reviews; NRC open ite=s; MP&L's Emergency Plan Drill exercise; and PSRC activities.
Results Two (2) Notices of Violation vill be issued and one (1) Unresolved Iten.
Consnents Made at Exit l The resident inspector informed MP&L that Plant _u=4a4 strative Procedure 01-S-04-21 para 6.5.1 required that certain Emergency Preparedness Specialized Training be complete prior to one acting as an Emergency Rasponse Team Member. He further informed MPM., contrary to his review of qualification records of two maintenance personnel which were used as Response Team members during the March 8, 1984 exercise, he found that one member's traf ning had expired and one ===har had never had any EPST. This will be cited as a violation for failure to cou: ply with 01-5-04-21.
The inspector stated that MP&L's Quality Assurance Manual Policy 5 requires that activities affecting the safe operation of GGNS be prescribed and accomplished in accordance with documented instructions and procedures.
However, per his review, he could not find cry "P&L procedure dealing with the temporary assignment,s of personnel as stated in ANSI 18.1 para 3.1.
This will be cited as failure to comply with the OQNt.
The following items were closed:
NRC Violation 83-43-03 LERs83-143,170, and 190; and 84-001, and 002
O The resident inspector informed MP&L that an unresolved item would be issued based on his review of MP&L's implementation of Plant Administrative Procedure 01-5-04-17. " Mechanical Maintenance Retraining and Replacement Training Program". Based on his reviev, many questions had arisen per-taining to Practical f actors sheets being used to document the implements-tion of this program. The following questions were cited as examples of his concern:
e Numerous sign-of f s had been completed within a short time. (Aa many as 10 in a day.),
e One individual has been signed of f on his Practical Factors Sheet with a date which was prior to his employment with the company, and a credit by exams were not supported by appropriate documentation.
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peass, UN TEo 37 ATEs 8 'g ,UCLE AR REGULATORY COMMisslON 3 , REGION 11 7* 101 M AR IE TT A BT A E E T. N.W.
ATL ANT A. OE 0401 A 30303 Report Hos.: 50-416/84-07 Licensee: Mississippi Power and Light Company Jac Ason, MS 39205 Docket No.: 50-416 License No.: NPF-13 Facility Name: Grand Gulf Inspection a nd Gulf site near Port Gibson, Mississippi Inspector: 'M _ t_ - 3 *,2 3 - h A. Gh / Date Signec Approved by: -
C. A. Julian/ Section Chief n 1 Gate 54gnec N
Division of Project anc Resident Programs
SUMMARY
Inspection on February 16 - Parch 9, 1984 Areas Inspected This routine, announced inspection involved 40 inspector-hours on site in the areas of Operational Safety Verification, Maintenance Observation, Surveillance Observation, Reportable Occurrence, Plant Safety Review Committee Activities, and Emergency Drill Observation.
Results Of the six areas inspected, no violations or deviations were icer.t.fiec in five areas; two apparent violations were found in one area (paragraph 10.c, failure to follow procedure and paragraph 10.d, failure te provide procecure).
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REPDRT DETAILS
- 1. Persons Contacted Licensee Employees l J. Cross, Plant Manager
- R. F. Rogers, Assistant Plant Manager - Operations
- C. R. Hutchinson, Assistant Plant Manager - Maintenance "J. W. Yelverton, Assistant Plant Manager - Support
- J. D. Bailey, Compliance Coordinator "L. F. Daughtery, Compliance Supervi sor "D. L. Hunt, Training Superintendent "J. E. Jones, Training Instructor Other licensee employees contacted included technicians, operators, mechanics, security force members, and of fice personnel.
- Attended exit interview Q 2. Exit Interview V The inspection scope and findings were summarized on March 9, .1984, with those persons indicated in paragraph I above. The licensee acknowledgec the inspection results.
- 3. Licensee Action on Previous Enforcement Matters (Closed) Violation 416/83-43-03: The inspector has reviewed the corrective actions, results achieved and steps taken to avoid recurrence stated in Mississippi Power and Light Company letter AECM-84/0062 dated January 26, 1984 The inspector considers the corrective actions and steps taken to prevent recurrence to be satisfactory; therefore, this item is closed.
- 4. Unresolved Iters '
Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or devia-tions. New unresolved items identified during this inspection are discussed in paragraph 10.e.
- 5. Operational Safety verification The inspectors kept themselves informed on a daily basis of the overall plant status and any significant safety mat *,ers related to plant operations.
Daily discussions were held with plant management and various members of the plant operating staff. .
1 The inspector made frequent visits to the control room such that it was visited at least daily when an inspector was on site. Observations included instrument readings; setpoints and recordings; status of operating systems;
- tags and clearances on equipment controls and switches; annunciator alarms; adherence to procedures; adherence to limiting conditions for operation; temporary alterations in effect; daily journals and data sheet entries; control room manning; and access controls. This inspection activity included numerous informal discussions with ope.rators and their supervisors.
Weekly, when onsite, a selected ESF system is confirmed operable. The con irmation is made by verifying the following; accessible valve flow path alignment; power supply breaker and fuse status; major component leakage, lubrication, cooling and general condition; and instrumentation. .
General plant tours were conducted on at least a biweekly basis. Portions of the control building, turbine building, auxiliary building and outside areas were visited. Observations included saf ety-related tagout verifica-tions; shift turnover; sampling program, housekeeping and general plant conditions; fire protection equipment; control of activities in progress; radiation protection controls; physical security; problem identification systems; and containment isolation.
No violations or deviations were identified in the areas inspec_ted.
. 6. Maintenance Observation During the report period, the inspectors observed the below listed main-tenance activities for procedure adequacy, adherence to procedure, proper tagouts, adherence to Technical Specifications, radiological controls, and adherence to Quality Control hold points.
P41747 24 VDC Relay - Wiring verification M41341 (RWCU) Filter Demineralizer Vessel Tubesheet 'B' -
Leakby inspection No violations or deviations were identified in the areas inspected.
- 7. Surveillance Testing Observation The inspectors observed portions of the performance of the below listed surveillance procedures. The inspection consisted of a review of the procedure for technical adequacy, conformance to Technical Specifications, verification of test instrument calibration, observation on the conduct of the test, removal from service and return to service of the syster and a review of test data.
06-ME-1M61-V-0001, Revision 21, Local Leak Rate Test, Penetration 21, valves E12F0378, E12F107B and E12F0278. -
' 3 06-OP-IP75-V-0011, Revision 21, Standby Diesel Generator Functional Test - Division II.
No violations or deviations were identified in the areas inspected.
- 8. Reportable Occurrence The below listed Licensee Event Reports (LERs) were reviewed to determine if the information provided met NRC reporting requirements. The determination included adequacy of event description and corrective action taken or planned, existence of potential generic problems and the relative safety significance of each event. Additional inplant reviews and discussion with plant personnel as appropriate were conducted for the reports indicated by an asterisk. The following LERs are closed.
LER No. Date Event 83-109 07-27-83 Shutdown Cooling Isolation 83-143 09-28-83 Component Cooling Water Process Radiation Monitor not in operation.
'83-110 10-26-83 RCIC Turbine latch Failure T 84-001 01-03-84 ESF Actuation when battery charger placec in equalize s ,,/ Shutdown Cooling Isolation 84-004 01-14-84 The following LERs remain open with comments as notec.
'83-177 02-13-84 Air Ejector off gas Monitor Inoperative.
The LER is held open pending a determination of the adequacy of the corrective action.
- 9. Plant Safety Review Committee Activities The inspector attended a Plant Safety Review Com.-ittee (PSRC) meeting on March 6, 1984. The minutes of the PSRC meeting heic between Dece-ce- 26, 1983 and Feervary 29, 1984, were reviewed by the inspector. A verification was made to assure that membership composition, meeting frequency, meeting minutes were satisf actory and full agreement was reached on all matters anc that the Tecnnical Specification and Plant Ac-inistrative Protecure 01-5-01-11, PSRC, requirements were met.
No violations or deviations were identified in the areas inspected.
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- 10. Emergency Det11 Observation On March 7,1964, the inspector observed the conduct of a plant emergency drill. The inspector observed the operability of emergency equipment, facility systems, on-site first aid f acilities, various systems and equip-ment used to monitor the release of radioactivity from the plant and the use of various communications. The inspector monitored at various times during the drill, the activities and personnel actions in the control room, technical support center, operational support center and emergency operations facility. Emergency response team training and qualification records were reviewed to ensure that the team members are properly trained and certified. During the above inspection, the fellowing observations were noted:
- a. The shift superintendent instructed the unit operators and drill participants on the conduct of operations during the drill . The operations drill participants were directed to perform all operations and evaluations as directed by the shift superintendent unless directed by a drill observer to simulate the evaluation. This would in effect place the operation of the plant under the direction of an untrained, unqualified crill observer. In addition, directions to the unit p operators were unclear as to how they were to distinguish and from whom directions for unit operations were to be taken. The inspector is concerned that control of plant operations is not well planned in advance and appropriate direction and guidance is not provided by the responsible emergency preparecness personnel. This will be revie ec during subsequent emergency crills. This will be identified as inspector followup item 416/84-07-01.
- b. The inspector noted several instances in which a licensee drill observer was acting as an escort for a visitor and appeared not to have control of the visitor as requi red by plant security instructions.
This matter has been referred to Region II and will be followed up during the next security inspection.
- c. During the review of the training re c o r'd s fo* the res;crse tea-members, the inspector noted that two of the team members cic not have or were not current for the required training. plant Administrative Procedure 01-5-04-21, Revision 3, Emergency Preparedness Trasning Program, paragraph 6.6 requires response technicians to have received EPTS-9, Multi-Media First Aid and EpTS-11, Response Team Training. The failure to have the two response team members properly trained is an i apparent violation and will be identified as violation 416/84-07-02, i failure to follow procedure.
- d. During the review of the training records for the response team leaders, the inspector noted that two of the leaders were not permanent
( supervisors. Upon inquiry, the inspector was informed that the supervisors were mechanics that were temporarily upgraded to ' s u p e r--
visory status. One of the supervisors had been upgraded for approximately one month, the other was a recent upgrade. Plant
5 Administrative Procedure 01-5-04-17, Revision 4, Mechanical Maintenance Retraining and Replacement Training Program, paragraph 6.1.3 describes the Maintenance Supervisor Training Program. The supervisors upgraded did not meet the program requirements. The inspector was informed that upgrading is allowed by AN51-N18.1-1971, paragraph 3.1. 10 CFR 50, Appendix B, Criterion V, as implemented by the licensee's approved QA program MpL-Topical-1A, requires that activities affecting quality be
, prescribed by appropriate procedures or instructions. The failure to prescribe the procedure for upgrading temporary supe'evi sors is an apparent violation and will be identified as violation 416/84-07-03, failure to provide procedure,
- e. During the review of the training records for the response team, the inspector noted that the practical factors cards for the mechanics were not in the training files. These cards are required by Plant Aceinistrative procedure 01-5-04-17, Revision 4, Mechanical Maintenance Retraining and Replacement Training Program. The inspector was subsecuently provided with copies of these cards. It was noted that none of the cards were completed. One of the cards had signatures and dates entered for required tasks that were dated before the person hac been employed by the licensee. The licensee stated that credit for g pric- employment evoerience had been given to this individual . The j ,
inspector is concerned with the qualifications and the process of qualifying the mechanical maintenance personnel for their position.
This will be identified as unresolved iter 416/84-07-04, pending further revie,. and inspection by the NRC.
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- TO WHOM IT MAY CONCERN:
I sat down with each of ry crew and talked with each one on Qualification Cards. I was under the impression that we could go back to past experience.
Also before a man was hired at Grand Gulf he had to have 3 years or mere experience to come in as a Junior Mechanic. Therefore, I went back to his past experience as well as work performed at Grand, rulf to fill out my Qualification Cards.
Bill Bradley 3/15/84 O BWSES 636-4254 Bome:
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T _ . . . . . .
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d MEMO TO: File FROM: Ray Handley
SUBJECT:
Mechanical Maintenance Qualification Card Mr. Bradley called me back to his office, to fill out mechanical qualification questions. Questions on some parts like thrust bearings, valves , pu=ps , pump couplings , and alignment of couplings were learned on other jobs, I have had before employment here at GCNS. These were the dates that Mr. Bradley put down on the qualification sheets.
From what I understand now, it seems that he should have left them blank, until 1 perf ormed them here, inf ront of a witness.
It looks to me as there was just a misunderstanding on how to fill the sheets out.
& = / .
Ray Randley 3/16/5' l
L / ', s
-s MAINTENANCE QUAL.. CARD ISSUE
- 1. Regulatorv Commitments FSAR 13.1.3.1 ...GCNS shall meet or exceed requirements of ANSI N18.1-1971.
A review of training records by Maintenance Training Supervisors, Site QA, and Maintenance Superintendents indicates that all of our maintenance per-sonnel in journeyman and supervisory positions have been. properly certi-fied to ANSI N18.1-1971 standards and that the training records accurately document this fact.
- 2. Improper Qual Card Signof f A review was conducted of all maintenance qual. cards including those co=-
pleted and returned to the Training Department.
The only discrepancy discovered was signed of f by his supervisor, B. Bradley.
This card contained signof f s by the supervisor that dated the mechanic 's
- c. employment date with the company.
(g) .
B. Bradley and R. Handley were questioned and both indicated that those signef f s were based on Handley's previous experience. Our progra= allows for credit by previous experience and provides a mechanism in paragraph 6.1.4 of 01-S-04-17 for documentating this. Bradley did not document the credit by previous experience signoffs properly.
A review of Handley's training record reveals that he is properly certi-fled to ANS 18.1 and that he has adequate documented previous experience (Navy Machinist Mate, Carbide Maintenance Man, Shipyard Pipefitter) in his training record to justify the signof f s on the qual. card based on previous experience.
BOTTOM LINE:
The signof f s ja question on Bandley's qual. card taking credit for pre-vious experience were not done in accordance with our procedures.
(See Attached Memo)
O MIMO TO: P. H. Walsh -
Discipline Maintenance Superintendents Discipline Maintenance Supervisors TROM: C. R. Hutchinson
SUBJECT:
Maintenance Qualification Card signef f IPC: 84/2075 Recently during an audit of training racerds it was discovered that a qualification card contained signoff's by a supervisor pre-dating that individual's date of employment with MP&L.
On the surface this would appear to be a fraudulent qualification card signoff, especially to an audit agency. Investigation into this matter has revealed that this was not the case but that credit was being taken p.l for prior experience. This is permissible under our training program, (d however, it seist be done in accordance with our procedures. The purpose of this memo is to re-emphasize these procedural requireme=ts to yeu.
01-S-04-17 Rev. 3 Mechanical Maintenance Retrain 12c and Reelacenent Program states in Para. 6.1.4 "..... credit by evaluation of past l experience is given ...... Experience will be evaluated on a case by case basis by the Training Superintendent. Rased on this evaluation the Training Superintendent any waive specific portions of the individual's training program. When a waiver is granted, the specific sections aff ected on the individual's tradM ng record and/or qualification cards shall be signed by the Training Superintendent with the letters .. . . .CPE adjacent l to his signature and the date". Procedures 01-5-04-18 and 19 for Electrical and Marh=M cal Training Programs contain similar words.
All Maintenance Supervisors and Discipline Superintendents are <iirected to read and thoroughly f amiliarize themselves with the procedures governing Training and Qualification of Maintenance Personnel. These procedures are:
01-S-04-17 Machanical Maintenance Retraining and Replacement Program 01-S-04-18 Electrical Maintenance Training Program 01-S-04-19 I&C Section Training Progra=
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Questions arising from this review and familiarization should be brought to the Maintenance Superintendent for resolution with the training depart-ment.
J A
. W C. R. Hu chinson Assistant Plant Manager, Maintenance CHR:gw cc: J. E. Cross J. Jones D. Hunt J. Telverton Plant File 1
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% T M0 TO: R. V. Moosew D. O. St ser E. C. Wilson F RO4 : f. H. Walsh SLE]ECT: Practical factor Sheets IPC-84 !2253 BACvCR00NO:
Training Procedures 01-5-04-17, 01-5-04-18, and 01-S-0.-19 no,e oeen issued to provide experience, formal training, and practical -
f actors records for Mechanical, Electrical, and Instrument Department oersonnel respectively . The above procedures provide general guidelines for the completion and handling of these training records. This memo 111 provide detailed guidelines for the completion and handling of tne Practical f actors Sheets contained in each of the above procedures and will remain in force until superceeded by new revisions to the referenced procedures which contain these same guidelines.
DISCUSSION: Individual practical factor task signoffs may be completeo I by the Maintenance Supervisors under two different circunstances
! s each of which is addressed seperately below. In either case, the date
\ filled in beside the signature block shall be the date that the signa-
\d ture was affixed and the task completed.
C ASE 1: Physical Observation of the Individual Perfonning the Practi-cal Factor Task i
l This case occurs when the Maintenance Supervisor personally wit-ness the task being perfonnanced in a safe and correct manner by the individual to whom credit for the accessful performance of the t ask is to be given. An individual may not receive credit for the oer formance of a practical f actors task while a meseber of a " crew" i unless he personally performed the task while being observed by his I Supervisor. When the Supervisor has witnessed the successful per-formance of a task, the Practical Factors Sheet for the individual ts to be signed of f that same day. Case I is expected to be the normal method for individuals to have their Practical Factors Sheets completed by their Supervisors.
C ASE 11: Credit for Previous Train'ing and Experience Due to the large numbers of incumbent personnel at Grand Gulf, a method has been provided in each of the referenced procedfres to allow credit for previous training and experience obtained both at Grand Gulf and orlor to Grand Gulf. When a Maintenance Supervisor wishes to take credit for previous training and experience, he should generate en IPC
- memo for his superintendent's signature to the Training Superintendent detailing the extent and nature of the pervioue training and experience.
l This memo should contain copies of resumes, transcripts, diplomas, and
- any other documentation which will establish the validity of the ,
, orevious training and experience for which credit la being sought. l OnUy
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= 4 This meno abould further defina exactly which practical factor tasks the previous training and experience is intended to fulfill.
Upon acceptance of the information contained in the memo, the Train-ing Superintendent will sign the practical f actor taska for which the previous training andTheexperience has been memo provided by theaccepted DisciplineinSuper-lieu of physical performance.
intendent will serve as documentation of the previous training and experience accepted by the Training Department and will remain with the Practical Factors Sheet as a permanent record. The date placed by the signatura block shall,be the date that the block was signed indicating acceptance of the previous training and experience by the Training Department.
As detailed above, only Maintenance Supervisors shall witness and give oractical f actor task signof fs for physical performance of the task.
Only the Training Department will give Credit for a practical factor task In no case is a Maintenance Super-by orevious training or experience.
visor to allow credit for a practical f actor task by any other method than that outlined as Case 1.
ACTION: Compliance with this memo is mandatory. Practical Factors Sheet which have been previously completed are to be re-evaluated on a task by task basis and signatures crossed out, initialed, and dated in those cases where the signature was affixed under conditions other than those
\ allowed by this memo. Each Discipline Superintendent is to review the Practical Factors Sheet of each man in his section who has a previously "N) completed or partially completed Practical f actors Sheet with that man's supervisor and sign the Practical f actors Sheet indicating that the above I review has been completed and that the signed tasks remaining on the I Practical Factors Sheet were affixed in accordance with this memo. The date of the Discipline Superinteedent's signature shall be the date that the review took place. All signatures past the review date shall be in accordance with the contente of this memo.
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$NNN F. H. Walsh 1 3/27/84 f
Concurrence: h((/
Training Supt.
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I cc: J. E. Cross
( C. R. Hutchinson i J. W. Yelverton Maintenance Supervisora l
g Plant File f
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t'.ar.ager of Quality Assurance () ---------------------.-..
Chair un, PSRC () -----------.---. ------..
Nuclear Plant Engineering- 0.A.S. () ------------.------------
From: Plant Quality Superintendent Transmittal Date: 3 - IS-N
Subject:
P.C.D.R. ,
File No. 0290/0490/0491/15717 Transmittal No. T 00 '2. f. l
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Instructions:
(% The attached PQDR requires disposition action. Please complete the Disposition Section in accordance with 01-S-03-2 and/or assign the disposition to a responsible party for completion.
() The attached PQDR requires a technical evaluation for safety relatedness and/or NRC reportability under 10CFR50.55(e),
10CFR21 or USNRC Regulatory Guide 1.16. Please evaluate and submit a report for the PQOR file.
() The attached PQOR requires your review. Please expedite and return to Plant Quality.
() For your information. .
() Othe r/ Additional Instructions :
CC: Manager QA -(p PQOR File Supv . Co rp . Reg . Compl . ( )
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Q.A. Ops. Supv. (J)
Asst. Plant Manager (X )M## Other:
Nuclear Plant Manager ()
Compliance Supt. (X )
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$ FOR POTErfIAL REPORTABLE DEFICIENCIES. Concurrence: Y /
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position Action Required From: . DISPOSITION RESPCMSE DOE DATE:
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