ML18043A411

Responds to Deficiency Noted in IE Insp Rept 50-255/78-26. Corrective Actions:Audit & Review of Employee Training Records

ML18043A411
Person / Time
Site:	Palisades
Issue date:	12/19/1978
From:	Hoffman D CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
NUDOCS 7901170028
Download: ML18043A411 (3)

Text

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Power company General Offices: 212 West Michigan* Avenue, Jackson, Michigan 49201

• Area Code 517 788-0550 December 19, 1978 Mr James G Keppler Office of Inspection and Enforcement Region III US Nuclear Regulatory Commission 799 Roosevelt Road Glen Eliyn, IL 60137 DOCKET 50-255 - LICENSE DPR PALISADES PLANT - IE INSPECTION REPORT 78-26 Consumers Power Company's response to IE Inspection Report 78-26 is as follows:

Item (deficiency) :

1. Palisades Technical Specifica~ions, Section 6.10.lc requires recor~s of training and qualification for members of plant staff to be retained for five years. Administrative Procedure 13 delineates specific training requirements and records.

Contrary to the above, records of training for severa.::i_ employees did not exist in the following areas:

a. New employee training orientation within two days of employment as required ~y Administrative Procedure 13.1, Section 5.2a.

b. Respiratory protection i~doctrination training for new employees as required by Administrative Procedure 13.l, Section 5.2c.

c. Annual job-related quality assurance instruction and beinnial training in use o-f -forklift, crane safety, sca-ffolding/rigging as required by Administrative Procedure 13.3.3, Attachment 13.3.3.

d. Quarterly job-related Industrial/Fire Safety Training as required by Administrative Procedilre 13.3.6, Attachment 13.3.6.

e. Semiannual site em.e!'gencydrill participation as required by Ad.L:J.inis-tratiYe Procedure 13.4, Attachment 13.4b .

• 7 9 o1 1 7 o o-'..~

DC:C 211918 at I

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Response

Items la, lb, and ld:

Corrective Action Tak.en and Results Achieved: The record of the new employee orientation training was found and has been placed in the employee's training record (Item la). The respiratory protection* indoctrination training and quarterly Industrial Safety/Fire Safety training were rescheduled for the affected individuals and their training records have been updated accordingly (Items lb and ld).

• In addition, the training records of all prant employees were audited to verify that the completion of General Employee ~raining and Special Employee Training has been properly documented. Some discrepancies were noted and will be corrected by February 15, 1979.

Corrective Action to Prevent Recurrence: The two principal causes of this problem are:

• Inadequate audits of training records to detect documentation errors.

• Some training not being conducted as scheduled.

To alleviate the auditing problems, the following courses of action are being considered. Pne will be implemented.

Require the Training Department to periodically conduct audits of training records, or Strengthen existi_ng requirements which have supervisors conducting these audits.

To provide greater assurance that traini_ng will be conducted as scheduled, the existing traini_ng requirements will be reviewed with appropriate levels of supervision. The supervisor's role in assuring that their personnel attend scheduled training sessions will be reiterated.

Date When Full Compliance will be Achieved: The actions described above will be carried out by February 15, 1979.

Response

Item le:

Correction Action Tak.en and Results Achieved: The annual job-related quality assurance training requirement was reviewed, and the determination was made that this training is not necessary. As a result, this training requirement has been deleted.

Forklift, crane safety, and scaffolding/ri_gging training are conducted Company-wide by a single department within the Company. Because of certain programmatic difficulties in establishing traini_ng s.chedules, lesson plans, etc, this training

3 has fallen behind schedule. To partially alleviate this situation one individual temporarily assigned to the plant is being certified to conduct crane safety ti-aining to clear the backlog in this area.

Corrective Action to Prevent Recurrence: The training schedules and lesson plans for the remaim.ng training (forklift and scaffolding/rigging) are near completion, and the backlog is expected to start clearing in early 1979.

Date When Full Compliance Will be Achieved: The backlog in the above training is scheduled to be cleared by June 1, 1979.

Response

Item le:

A.review of the individual's training record was conducted, and documentation of the annual site emergency training was found in the training record. This item appears to have been an error on the part of the inspector. In view of this, and in view of the response to item (a) to correct the generic aspect of this problem, no other action is considered necessary with respect to this item.

David P Hoffman Assistant Nuclear Licensing Administrator CC: Director, Office of Nuclear Reactor Regulation Director, Office of Inspection and Enforcement