ML17299A871
| ML17299A871 | |
| Person / Time | |
|---|---|
| Site: | Palo Verde  |
| Issue date: | 08/22/1985 |
| From: | Van Brunt E ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR |
| To: | Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| References | |
| ANPP-33252-WFQ, NUDOCS 8512130220 | |
| Download: ML17299A871 (12) | |
Text
Arizona Nuclear Power Project P.O. BOX 52034
~
PNOEN IX, ARIZONA85072-2034 U. S. Nuclear Regulatory Commission Region V 1450 Maria Iane, Suite 210 Walnut Creek, CA 94596-5368 ANPP-33252 WFQ/WEI August 22, 1985 Attention:
Mr. R. A. Scarano, Director Division of Radiation Safety and Safeguards
Subject:
Palo Verde Nuclear Generating Station (PVNGS)
Unit 1 Docket No.
STN 50-528 (License No. NPF-41)
Notice of Violation 50-528/85-10/01 Knowledge and Performance of Duties (Training)
Pile:
85-019-026 D.4.33.2
References:
Letter from R. A. Scarano (NRC) to E.
E.
Van Brunt, Jr.
(ANPP),
dated July 8, 1985; NRC Inspection 50-528/85-10
Dear Sir:
- This letter refers to the inspection conducted by Ms.
G.M.
Temple on April 29-May 3 and May 13-17, 1985.
Based on the results of this inspection, one Notice of Violation concerning the failure to provide initial training and annual retraining on emergency preparedness in a timely manner was issued to ANPP as decribed in the reference letter.
Our response to the subject Violation is provided as Attachment A.
Additionly, several programmatic concerns were identified in Section 4 of the inspection report which require resolution.
In response to the Notice of Violation, ANPP commits to do an overall evaluation to determine the scope of Training/Emergency Planning interface problems.
This evaluation will address those concerns.
Please be advised that an extension for our response to the reference letter was granted until August 22, 1985 by Mr. R. F. Fish of your office on August 9, 1985.
Very truly yours, Zz'V-'v~/iz,v E. E. Van Brunt, Jr.
Executive Vice President Prospect Director EEVB/TJB/dim Attachment cc:
A.
C. Gehr E. A. Licitra R. P.
Zimmerman G. M. Temple (All W/Attach.)
ATTACHMENT A E
NRC NOTICE OF VIOLATION 50-528/85-10/01 During an NRC inspection conducted on April 29-May 3 and Hay 13-17, 1985 a
violation of NRC requirements was identified.
The violation involved the failure to train and retrain personnel on emergency preparedness in a timely manner.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2,
Appendix C (1985),
the violation is listed below:
A.
10 CFR 50.54 (q) requires a licensee to follow and maintain in effect emergency plans which meet the standards in 50.47(b) and the requirements in Appendix E of this part.
Section I.F of Appendix E, 10 CFR Part 50, requires initial training and periodic retraining of emergency personnel.
Technical Specification 6.8.1 requires that written procedures for Emergency Plan implementation shall be established, implemented and maintained.
Section 8
of the Palo Verde Nuclear Generating Station Emergency Plan describes the training program.
ANPP Administrative Procedure No. 8N718.04.00, "Emergency Plan Training", has been developed to implement Section 8 of the Emergency Plan.
Attachment 1 to this procedure identifies the initial training requirements for site personnel who occupy emergency organization positions.
Section 4.1.1 of this same procedure identifies basic training and indoctrination requirements to be provided to PVNGS personnel on an annual basis.
Contrary to the above requirements, at the time of the inspection 39 individuals identified as having assignments in the emergency organization had not received full initial training and/or retraining required by their emergency response assignment.
In addition, a
number of PVNGS personnel had not received annual retraining in personnel
- assembly, accountability, evacuation and reassembly which constitutes the basic training and indoctrination.
0214K/0012K
C~
I~
Mr. R. A. Scarano ANPP-33252 ATTACHMENT A Page Thoro
RESPONSE
TO NOTICE OF VIOLATION ANPP reviewed the two instances of failure to train personnel in accordance with procedures and determined that the root cause and required corrective action are different for each case.
Therefore, the two instances are being handled separately.
INITIALTRAINING AND ANNUAL IRAINING OF EMERGENCY RESPONSE PERSONNEL I.
CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED ANPP conducted a
100K review of the personnel that existed on the Emergency Plan Staffing list at the time of the NRC Inspection.
Based on that review, ANPP identified additional deficiencies besides those found by the NRC.
The General Training Department then scheduled and notified Plant Supervisors of course availability.
Through attendence in these courses, all training irregularities identified in section 4 of the NRC inspection report were corrected with the following exceptions:
l.
4(B):
This concern refers to the Surveys
.and Sampling class for the Radiological Protection Coordinator.
This requirement is unnecessary based on the position's responsibilities and duties and has been removed from the ANPP Emergency Plan Training Procedure.
20 4(D'):
One of the individuals identified as STSC Communicators/Operators Personnel has since transferred departments and no longer requires the emergency planning initial overview training.
The additional deficiencies identified by the ANPP reiew have pointed out several problem areas which will require additional evaluation.
These problems will be included in an overall evaluation to determine the scope of the Training/Emergency Planning interface problems.
The paragraph following 4(E) states that an instructor informed students that initial TSC Operations training was not required in order to take Refresher Overview training.
Training has determined that an instructor would not be aware of whether someone in Refresher training had been initially trained or not.
To resolve this problem, a screening system is being developed where pre-registered students in any re-training course would have their initial training verified prior to the beginning of said re-training course.
Mr. R. A. Scarano ANPP-33252 ATTACHMENT A Page Three As a precautionary measure, all General Training instructors have been briefed as to their responsibility to ensure that any information which they disseminate concerning training requirements be accurate and according to current procedure.
A major revision to the ANPP Emergency Plan Training Procedure has been completed and approved.
This revision, among other
- things, organizes Emergency Plan training in a manner which allows for easier tracking of completion of course requirements.
This remrganization combines training courses in 'rder to minimize the total number of individual trips to training per year.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The root cause of this violation has been determined to be a system which places the responsibility to ensure training is completed in the hands of individual supervisors, yet does not supply an effective and accurate information system to keep them aware of the initial training and retraining requirements which apply to their personnel and also that no group is responsible to provide an accurate compilation of the personnel qualified to support the Emergency Plan.
An overall evaluation will be coordinated by Training to address the root causes of"the Violation and to identify any additional problems relative to Training/Emergency Planning interface.
ANPP will provide a letter to the NRC by November 1, 1985 which describes the results of the evaluation along with the corrective actions identified and a
schedule for their implementation.
In the interim, Training will provide Emergency Planning with a verified list of personnel who meet the training requirements for Emergency Plan
Response
Personnel.
From this list, Emergency Planning will issue a
Qualified Staffing List for utilization by the supervisors.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on August 1, 1985 with the issuance of a
~lified Staffing List that has been verified as meeting the requirements for Emergency Plan Response Personnel.
Mr. R. A. Scarano ANPP-33252 ATTACHHENT A Page Four ANNUAL RETRAINING ON ASSEMBLY ACCOUNTABILITY ETC.
I.
CORRECTIVE STEPS TAKEN AND THE RESULTS ACHIEVED Implementation of Section 5.4 of ANSI/ANS 3.1-1978 for General Employee Training was reviewed.
The review included the FSAR, Emergency
- Plan, and relevant corporate procedures for Emergency Planning and Training.
The following is a
discussion of that review and the correction actions identified.
A.
FSAR Section 13.2.1.4 provides the implementation of Section 5.4 of ANSI/ANS 3.1-1978.
For
- ANPP, the term "Site Access Training" is synonymous with "General Employee Training".
General Employee Training (G.E.T.)
is required only for personnel requiring unescorted access to protected areas of an operating PVNGS Unit.
Retraining per FSAR 13.2.1.4 is required annually by FSAR 13.2.2.2.1,
- however, a
3 month grace period (extension) is acceptable for Site Access
- Training, Respiratory Protection, Radiological Work Practices, and Emergency Plan Training.
This grace period is discussed in a
memo from the Plant Manager (PVNGS-JRB-M84-587 dated December 18, 1984).
Personnel without updated site access training are not allowed in the protected area.
A FSAR Change No.
2033 has been initiated to allow annual training to exceed twelve months by up to three months.
Emergency Plan Section 8.1.1.1 is being revised in Revision 6
to delete the statement that "each new employee receives general instructions on the emergency plan and supporting emergency procedures."
There is no regu1atory basis for this statement.
This section will be revised to be consistent with the proposed FSAR Section 13.2.2.2.1.
2 ~
Emergency Plan Training Procedure 8N718.04.00 Section 4.1 has been revised to be consistent with the proposed FSAR Section 13.2.2.2.1.
EPIP-36 has been cancelled.
30 The Emergency Planning Department is now required per ANPP Procedure 8N718.04.00, Revision 2
to
- assure, for ANPP employees not part of the emergency response organization and not requiring unescorted
- access, disseminatiozf of information regarding how they will be notified and what their actions will be in an emergency.
I
Mr. R. A. Scarano ANPP-33252 ATTACHMENT A Page Five II.
CORRECTIVE STEPS TAKEN TO PREVENT FURTHER ITEMS OF NONCOMPLIANCE The root cause of this problem has been determined to be an inadequate system for ensuring that Emergency Plan requirements are properly implemented.
Based on this finding, Licensing/Emergency Planning will coordinate an evaluation of a sample of Emergency Plan requirements to determine the scope of the problem.
Appropriate action will be taken based upon the results of this evaluation.
Additionally, semi~onthly meetings between the Training Department and the Emergency Planning Department are being held to improve the coordination of the two departments.
These meetings will be held until such time that the problems are resolved.
Also, in response to comments by the NRC Inspector, Training Department personnel are now copied on all correspondence issued to affected Emergency
Response
personnel concerning approved EPIP revisions or PCNs.
- III. DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 21 The FSAR change will be approved by ANPP by September 7, 1985.
The Emergency Plan will be revised by September 7, 1985.
3 ~
The Emergency Planning Department will develop a
plan and implementation schedule for annual dissemination of information to site personnel concerning
- assembly, accountability, evacuation and reassembly.
This action will be complete by September 7,
1985.
Full compliance will be achieved once the information has been provided to site personnel.
4 ~
Emergency Plan Training Procedure 8N718.04.00, Revision 2,
was revised with an effective date of 7/15/85.
5.
The evaluation of Emergency Plan requirements will be completed by November 1, 1985.
t
~
V k
I