ML19325F080
| ML19325F080 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 10/20/1989 |
| From: | Gooden A, Rankin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19325F076 | List: |
| References | |
| 50-324-89-31, 50-325-89-31, NUDOCS 8911130341 | |
| Download: ML19325F080 (13) | |
See also: IR 05000324/1989031
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UNIT E) STAT E S
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NUCLEAR REGULATORY COMMistlON
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101 MARIETT A STREET. N.W.
ATLANT A, GEORGI A 30323
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OCT 311989
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Report Nos.: 50-325/89-31 and 50-324/89-31
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Licensee: Carolina Power and Light Company
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P. O. Box 1551
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Raleigh, NC 27602
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Docket Nos.: 50-325 and 50-324
License Nos.:
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Facility Name: Brunswick 1 and 2
Inspection Conducted:
tember 18-22, 1989
Inspector:
O.
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, /o - 2.o- 8 9
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A. Gooden
Date Signed
Accompanying Personnel:
M. Stein
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J. Will
Approved by: M
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W. Rankin, Chief
Date 5'gned
Emergency Preparedness Section
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Emergency Preparedness and Radiological
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Protection Branch
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Division of Radiation Safety and Safeguards
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SUMMARY
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Scope:
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This special, announced inspection of the licensee's emergency preparedness
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program included a review of the following areas:
corrective actions in
response to deficiencies identified during exercises and real events involving
offsite notifications from the Control Room; training;(EAL) pendent program
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audits; augrentation staffing; emergency action level
flowchart; dose
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projection; and Emergency Plan implementation in response to the loss of
offsite power (Unit 2, June 1989); and observation of the licensee's actions
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in response to Hurricane Hugo and the loss of annunciators.
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Results:
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Within the areas reviewed, two violations were identified:
(1) Failure to
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provide follow-up notifications to State / local agenc!es from the Control Room
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in accordance with Plant Emergency Procedure (PEP)-02.6.21 (Paragraph 4); and
(2) Failure to provide emergency response training to personnel in accordance
with PEP-4.3 and Training Instruction (TI)-306 (Paragraph 6).
The inspection
indicated that the licensee had taken appropriate action (subsequent to the
June 1989 loss of offsite power event) to ensure that Control Room Personnel
provide followup notifications to offsite authorities when required. However,
8911130341 891031
ADOCK 05000324
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as evidenced by inconsistent responses during the interviews with Control Room
personnel, a fundenental misunderstanding existed regarding the use of the
three part memo for follow up notifications and the philosophy regarding the
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tine interval (60 minutes) between the initial notification and the follow-up
notification nessage.
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The inspector noted the following actions in response to Hurricane Hugo and the
lossofControlRoomannunciators(Unit 2):
The event classification was appropriate for both Hurricane Hugo
(Notification of Unusual Event) and the loss of annunciators (Alert),
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Both events were promptly classified, and offsite notifications were made
in a timely manner.
Follow-up notifications were made from the Control
Room and Technical Support Center (TSC) in accordance with procedures.
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Actions were observed in response to Hurricane Hugo to be in accordance
with Abnormal Operating Procedure (AOP) 13.0; and in response to loss of
annunciators, actions were in eccordance with A0P 29.0.
In response to the Alert declaration involving the loss of annunciators,
the TSC was activated within 60 minutes of the event declaration.
Onsite protective actions for both events were appropriate.
Repair personnel were prompt in returning the annunciators to service.
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REPORT DETAILS
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Persons Contacted
Licensee Employees
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D. Barbee Shift Technical Advisor
- C. Blackmon, Manager, Operations
K. Chism, Shift Foreman
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- K. Enzor, Manager, Regulatory Compliance
M. Foss, Shift Operating Supervisor
- J. Harness Plant General Manager
- B. Houston, Specialist. Emergency Preparedness
L. Johnson, Shif t Operating Supervisor
R. LaBelle, Shift Operating Supervisor
W. Link, Shift foreman
C. Mabry, Shift Technical Advisor
W. Noland, Shift Technical Advisor
J. Reinsburrow, Shif t Foreman
M. Schall
Shift foreman
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J. Simon, Shift Operating Supervisor
R. Tart, Shift Operating Supervisor
R. Zuffa, Shift Technical Advisor
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Other licensee employees contacted during this inspection incitded
engineers, operators,
security force members, technicians, and
administrative personnel.
NRC Resident Inspector
- W. Ruland
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- Attended exit interview
2.
Energency Detection and Classification (82201)
Pursuant to 10 CFR 50.47(b)(4) and 10 CFR Part 50. Appendix E. Sections
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IV.B and IV.C. this program area was inspected to determine whether the
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licensee used and understood a standard emergency classification and
action level scheme.
The inspector retiewed the lict:rsee's classification procedure (PEP-2.1,
Initial Emergency Actions).
The event classifications in the procedure
Fere consistent with those required by regulation.
The classification
procedure did not appear to contain impediments or errors which could lead
to incorrect or untimely classification.
In addition to PEP-2.1, the
licensee's energency action levels (EALs) were flow charted to aid
personnel in emergency classification.
Comparison of the EAL flow-charts
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with the EAL description in Brunswick's PEP-02.1 and hUREG-06L4 showed
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that use of the flow-charts would result in the proper classification.
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Selected EAls specified in the classification procedures were reviewed.
The reviewed EALs were consistent with the initiating events specified in
Appendix 3 of NUREG-0054.
The inspector noted that sone of the EAls were
based on parameters obtainable from control room instrumentation.
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The inspector verified that the licensee's notification procedures
included criteria for initiation of offsite notifications and for
development of protective action recornendations (PARS). 'the notification
procedures required that offsite notifications be made promptly after
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declaration of an emergency.
The responsibility and authority for classification of enertency events
and initiation of emergency ection were prescribed in licensee procedures
and in the Emergency Plan.
Interviews with selected key members of the
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licensee's energency organization revealed that these personnti understood
their responsibilities and authorities in relation to accident
classification, notification, and PARS.
Walk-through evaluations were conducted with various personnel involved in
the event classification, offsite notific6 tion, and PARS.
Personnel
assigned to five of the six Control Rote shifts were interviewed.
Interviewees included the Shift Operations Supervisor, Shift Feeman,
Shift Technical Advisor, and the Production Assistant (who function; as an
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Energency Communicator).
The inspector also interviewed individuals
designated as Offsite Connunicators in the TSC and the Emerge. icy
Operations Facility (EOF).
The scenario postulated the approarn and
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arrival of Hurricare Hugo.
All interviewees properly classified the
hypothesized accident situation presented to them, and appeared to be
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familiar with the appropriate classification procedures.
With the
exception of the Control Room shift that was in training at the time of
the inspection, interviewees experienced a slight delay in classifying the
event.
This delay may have been caused by wording in the EAL pertaining
to hurricanes which required the operators to consult the facility Final
Safety Analysis Report.
The delay was not significant enough to consider
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the response as unaccepteble.
The response by remaining personnel was
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effective in event detection, classification, and notification.
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No violations or deviations were identified in this program area.
3.
ProtectiveActionDecision-Making (82202)
Pursuant to 10 CFR 50.47(b)(9) and (10) and 10 CFR Part 50, /.ppendix E.
Sect hn IV.D.3, this area was inspected to determine whether the licensee
had 24-hour-per-day capability to assess and analyze emergency conditions
and make recommendations to protect the public and onsite workers, and
whether offsite officials had the authority and capability to initiate
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prompt protective action for the public.
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The inspector discussed responsibility and authority for protective action
decision-making with licensee representatives and reviewed pertinent
portions of the licensea's Emergency Plan and procedures.
The Plan and
procedures clearly assiqned responsibility and authority for accident
assessment and protectivo action decision-making.
Interviews with members
of the licensee's emergency organization revealed that these personnel
understood their authorities and responsibilities with respect to accident
assessment and protective action decision-making.
Although the walk-througt scenario did not require PARS to reduce
radiological consequences, operators were questioned regarding procedures
to follow and considerations to be taken into account in making such
recommendations.
Personnel interviewed appeared to be cognizant of
appropriate onsite protective measures and aware of the range of pars
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appropriate to offsite protection.
Personnel interviewed were aware of
the need for timeliness in naking initial PARS to offsite officials.
No violations or deviations were identified.
4.
Notification and Communication (82203)
Pursuant to 10 CFR 50.47(b)(5) and (6) and 10 CFR Part 50, Appendix E,
.Section IV.D. this area was inspected to determine whether the licensee
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was maintaining)a capability for notifying and communicating (in the event
of an emergency among its own personnel, offsite supporting agencies and
authorities, and the population within the EPZ.
The inspector reviewed the licensee's notification procedures.
The
procedures were consistent with the emergency classification and EAL
scheme used by the licensee.
The inspector determined by review of
applicable procedures and by discussion with licensee representatives that
adequate procedural means existed for alerting, notifying, and activating
emergency response personnel. The procedures specified when to notify and
activate the onsite emergency organization,
corporate support
organization, and offsite agencies.
The content of initial emergency
messages was reviewed and appeared to meet the guidance of NUREG-0654,
Sections 1.E.3 and II.E.4.
The inspector conducted a very detailed review of the performance by the
Control Room staff in the area 01 notification (initial and follow-up
messages) in view of past performances during exercises.
The review
included walk-throughs
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personnel
assigned
communicatior s
responsibility, training, performarce during past drills / exercises, and
performance during real events.
Based on walk-throughs, the operators
understood the necessity to make their initial County and State
notifications within 15 minutes following the declaration of an emergency.
However, interviewees expressed no urgency regarding the initial
notification to the NRC in view of the notification procedure allowance of
60 minutes.
Further, the operators acknowledged the necessity to make
follow-up notifications to offsite authorities (State / local) immediately
if major changes took place, but indicated a lack of concern for other
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follow-up notifications (i.e. no major ctanges) until close to the 60
minutes time limit. Section 6.3.3 of PEP-02.6.21 (Emergency Communicator)
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provides for the use of a three-part memo or notebook paper for follow-up
notification when the use of the prescribed notification form (exhibit
2.6.21-1) is not appropriate.
Control Room personnel gave various
interpretations for the use of these alternate forms of documentation:
(1) used only if there was no change in plant status; (2) inadequate
number of lines on the notification fonn for explanation' of changes in
plant status; (3) alternate forms should not be used at all; and (4) used
to make the 60 minute time limit.
The inspector detendined during
walk-throughs and discussions that the follow-up notification form did not
provide sufficient space for explanation and the three part memo was not
formalized as an exhibit to the procedure. In addition, the walk-throughs
disclosed a misunderstanding on the part of Operators' and communicators'
regarding follow-up notifications being made in a timely manner not to
exceed 60 minutes.
A licensee representative indicated that actions had
been initiated with the offsite euthorities to devise an acceptable
follow-up notification form.
Further, the licensee committed to conduct
additional training regarding the notification time limit and the
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follow-up notification form once the form was completed.
The inspector
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indicated that this matter would be considered as an Inspector Follow-up
Item (IFI) for review during a subsequent inspection.
IFI (50-325, 324/89-31-01):
Revision of follow-up notification form ana
conduct of additional training regarding the timeliness of the follow-up
message notification form.
The
inspector reviewed licensee documentation dated July 21, 1989, that
detailed an Unusual Event declaration made on June 17, 1989, due to a loss
of power to 'Jnit 2 (discusced also in NRC Report Nos. 50-325,324/89-12).
According to documentation, the initial nntifications from the Control
Room to the offsite authorities was done in accordance with procedures.
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However, following the initial notifications (at 9:10 p.m.), the licensee
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did not make follow-up notifications for more than two hours (11:15 p.m.).
According to PEP-02.6.21 (Emergency Communicator, Rev.17, dated April 3,
1989), Section 6.3.1, follow-up notifications should be ma% at 30 to
60 minute intervals or as required by changing conditions.
During a
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confirmed fire event on April 27, 1989, which was declared as an Alert
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(based on a fire potentially affecting safety related equipment), and was
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1mmediately downgraded to en unusual event, State and ccanty agencies were
notified of the Alert but a follow-up message regarding event
de-escalation to an Unusual Event was not provided.
In both events,
Control Room personnel failed to follow procedures governing notificatien
(PEP-02.6.21) requirements.
Procedural nonconformance was identified by
the licensee during both events, and a nonconformance report was issued.
Other examples that were noted where follow-up notifications did not occur
from the Control Room included the Calendar Years 1987, 1988, and 1989
exercises.
The ir.spector was provided documentation to show that actions
were taken to resolve the above findings and hopefully prevent recurrence.
Actions that were taken by the licensee involved training of all
Operations personnel.
Included in the training out-line was a discussion
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of the Site Emergency Coordinator (SEC) and the Emergency Comunicator
Functions; offsite notification requirements; revicw of past events (both
exercises and real event) with highlights of any concerns or improvements
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in the area of notification; and finally, a review of procedural changes
involving follow-up notification requirements and maintaining a log of
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emergency activities.
The licensee was informed that in view of the
multiple examples given for repeat failures on the part of Control Room
personnel to provido follow-up notifications to State / local agencies in
accordance with PEP-02.6.21, a violation of Technical Specification 6.8.1.e is iden' .fied.
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Violation (50-325, 324/89-31-02):
Failure to follow PEP-02.6.21
(Emergency Communicator) which implements Section 3.5 of the Emergency
Plan regarding notification and activation.
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Two events occurred during the period of the inspection which afforded the
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inspector the opportunity to observe first hand the licensee's response in
the area of initial and follow-up notifications.
The two events
(discussed in Paragraph 9 of this report and NRC Report Nos. 50-325,
324/89-26) involved a Notification of Unusual Event due to Hurricane Hugo,
and an Alert due to loss of annunicators.
In response to Hurricane Hugo, the licensee was prompt in declaring the
event and making offsite notifications.
Comunications from the Control
Room and TSC to offsite authorities were done in accordance with the
Emergency Comunications procedure.
On September 21, 1989, prior to
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Hugo's arrival, the licensee's TSC was activated for hurricane tracking,
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comunications, damage control, and other actions as warranted.
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continous open line of comunication was established by the licensee with
the NRC.
On an hourly basis until event termination, updates were
provided to offsite authorities (State, local, and Coast Guard).
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During the loss of annunciators, the inspector observed notification frem
the Control Room and TSC. Continous manning of the Control Room Emergency
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Notification System (ENS) was established within 60 minutes of the Alert
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declaration.
Once the TSC was activated, all comunications
responsibility were transferred to the TSC uniti the Alert ;ondition was
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terminated.
A follow-up message was transmitted to the offsite
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authorities following the event downgrade.
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During both events, no problems were noted with the initial or follow-up
notifications to offsite authorities.
All notifications were done within
the time limits specified in PEP-02.6.21.
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One violation was identified.
5.
Shift Staffing and Augmentation (82205)
Pursuant to 10 CFR 50.47(b)(2) and 10 CFR Part 50, Appendix
E,
Sections IV.A and IV.C this area was inspected to determine whether shift
staffing for emergencies was adequate both in numbers and in functional
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capability, and whether administrative and physical means were available
and maintained to augment the emergency organization in a timely manner.
The inspector reviewed the Emergency Plan requirements for on-shift
staffing, the Technical Specification minimum requirements for shift crew
composition, the on-call organization for augmenting the on-shift
organization, the associated call-in procedure, and the results of
periodic augmentation drills.
The Brunswick Emergency Plan specifies that the minimum on-shift staff is
that staff required by Technical Specifications.
However, the minimum
shift crew composition does not meet the staffing levels of NURE3-0737
Supplement I and Table B-1 of NUREG-0654. The minimum staffing discussed
in the Technical Specifications address licensed Operator, Auxiliary
Operators, Shift Technical Advisor, etc; the staffing requirements for
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Health Physics, Chemistry. Mechanical, etc. is not addressed.
In
addition, the station's call list (Appendix A to the PEPS or on-call staff
listing) does not include maintenance, chemistry, and other personnel for
augmenting the 30 and 60 minutes staffing described in NUREG-0654 or 0737.
When records from periodic augmentation drills were reviewed, the results
confirmed that Health Physics, Chemistry, and maintenance personnel were
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not called in to verify augmentation times.
Section 3.0 of the Brunswick
Emergency Plan states that compliance with the requirements of NUREG-0654
Table B-1 has been assured.
Contrary to Section 3.0 of the Emergency
Picn, based on the records review, compliance with Table B-1 of NUREG-0654
had not been demonstrated.
The licensee committed to conducting an
unannounced augmentation drill requiring that personnel travel to the site
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for verification of Table B-1 augmentation requirements.
The inspector
indicated that this matter would be considered an IFI.
IFI (50-325, 324/89-31-03):
Conduct an unannounced drill to verify that
Table B-1 of NUREG-0654 regarding augmentation staffing and arrival times
can be met.
No violations or deviations were identified.
6.
Training (82206)
Pursuant to 10 CFR 50.47(b)(2) and (15),Section IV.F of Appendix E to
10 CFR Part 50, and Section 6.1 of the Emergency Plan, this area was
inspected to determine whether the licensee's key emergency response
personnel and personnel involved in the initial stages of an incident were
properly trained and understood their emergency responsibilities,
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The inspector reviewed Section 6.1.1 o' the Emergency Plan, PEP-04.3
(Performance of Training, Exercises, and Drills), and TI-306 (Emergency
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Plan Training) for a description of the training program and training
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procedures.
In addition, selected lesson plans or training modules were
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reviewed, and personnel with the responsibility for conducting the
energency response training were interviewed.
It was determined that the
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licensee maintains a formal emergency training program.
According to a
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discussion with a licensee representative, training modules can be
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completed through self-study and passing an exam. The exams, are formally
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scheduled, and proctored by an instructor following a self study and
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review period.
The licensee's training program did not require practical
training in assigned positions in the emergency response organization.
This approach was noted as promoting the development of a few highly
experienced responders for an on-call position while the remaining (see
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responders for the same position only gain experience as team members
Paragraph 7 regarding dose projection walk-through).
The inspector
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discussed conducting more hands-on or practical training for personnel in
some of the accident assessment areas (eg, dose projection, radiological
monitoring). The licensee did not comit to any action in this regard.
Training records were reviewed for several members of the emergency
organization.
Training records were chosen based on the on-call
Managenent Roster for the period September 15, 1989 to September 21, 1989;
the operations shift schedule for the week beginning September 16, 1989;
and the list of responders in Revision 30 of PEP-Appendix A dated
September 13,1989.
When personnel training records were compared with
position assignments, the inspector noted the following:
One individual
designated as a Production Assistant with
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responsibility as a Control Room Communicator had not received
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Emergency Comunicator or Emergency Plan Overview training as
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specified in TI-306 Attachment 1.
Two individuals designated as Shift Operating Supervisors with
responsibility as Interim Site Emergency Coordinator (SEC) training
had expired.
The annual Emergency Plan Overview training had not
been attended by either individual.
In addition, one of the
individuals failed to complete the annual training on Module EP6002B
entitled Site Emergency Coordinator.
Twelve individuals designated as Auxiliary or Radwaste operators had
either expired training, or failed to attend any of the required
training.
Five of six individuals designated as Shift Technical Advisors had
expired training on Module EP6002B entitled Site Emergency
Coordinator.
In addition to the above training discrepancies involving operations
personnel, three individuals designated as Communicators on the
augmentation staff and one individual designated as the Technical
Assessment Director had not completed annual training on Module EP6C03B
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entitled TSC Operations.
Section 6.1.1 of the Brunswick Emergency Response Plan states that
PEP-04.3 assures training of those individuals who may be called to
respond to an emergency by providing initial training and annual refresher
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training.
This item is identified as a violation of Technical Specification 6.8.1.e.
Violation (50-325, 324/89-31-04):
Failure to provide training to members
of the emergency organization in accordance with PEP-04.3 and TI-306.
As evidenced by the number of individuals with expired training, a
centralized administrative control system for tracking and ensuring that
training is current for emergency response personnel did not exist.
The
licensee agreed that the current practices for tracking energency response
training warrants increased attention.
The licensee connitted to
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implementing an effective tracking system for emergency response training
to ensure that personnel assigned to the emergency organization training
is current and up-to-date during the period of assignnent. The inspector
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identified this item as an IFI for review during a subsequent visit.
IFI (50-325, 324/89-31-05):
Development and implementation of a
centralized tracking system for emergency response training.
The inspector conducted walk-through evaluations with selected key members
of the emergency organization (Control Room Staff and dose projection
personnel).
During these walk-throughs, individuals were given various
hypothetical sets of energency canditions and data involving Hurricane
Hugo and asked to respond as if an emergency actually existed.
The
individuals demonstrated familiarity with emergency procedures and
equipment, and no significant problems were observed in the areas of
emergency detection and classification, notifications, dose calculation,
assessment action (to include plant conditions), and protective action
decision-making.
One violation was identified.
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Dose Calculation and Assessment (82207)
Pursuant to 10 CFR 50.47(b)(9), this area was inspected to determine
whether there was an adequate method for assessing the consequences of an
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actual or potentia' radiological release.
The inspector reviewed the manual and computerized dose projection
procedures, and the basis document for the dose projection methodology to
determine if adequate procedures exist for dose calculation under
anticipated release conditions. No problems were noted.
An irspection and operability check were made of dose projection equipment
and support items used for dose assessment in the Control Room and TSC.
No problems were observed.
The inspector requested and observed dose assessment walk-throughs with
one Shift Technical Advisor (STA) and three individuals designated as Dose
Projection Team Leaders (DPTL).
The STA walk-through involved the
performance of initial dose projection f rom the Control Room, and the
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three DPTLs were evaluated based on their ability to acquire
meteorological data and perform dose projections from the TSC using the
computerized and manual methods.
The DPTLs using the manual dose
projection procedure (PEP-03.4.3) were unable to provide dose projection
results within 10 minutes of being provided effluent monitor readings.
Additionally, the DPTLs were not accustomed to correlating dose assessment
results with recommendations to the SEC for PARS or emergency
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classifications.
Though qualified for the DPTI. position by virtue of
training, the interviewees were inexperienced in serving as the DPTL. All
three interviewees had previously performed as dose projection team
members during previous drills and were dependent on the direction of an
experienced team leader.
It was noted that the DPTL function is normally
performed by a more senior person with experience in this position.
Although the licensee's program appears to be adequate, as previously
discussed in Paragraph 6, the licensee was informed that more practical
hands-on training is needed to ensure personnel performance in assigned
areas of responsibility is acceptable.
This item was considered for
improvement.
No violations or deviations were identified.
8.
LicenseeAudits(82210)
Pursuant to 10 CFR 50.47(b)(14) and 10 CFR 50.54(t), this area was
inspected to determine whether the licensee had performed an independent
review or audit of the emergency preparedness program and whether the
licensee had a corrective action system for deficiencies and weaknesses
identified during audits, drills, and exercises.
The inspector reviewed the licensee's procedure and check-list for
conducting audits.
Records for audits conducted in 1987, 1988, and 1989
were reviewed.
In addition, the licensee's program for trecking and
follow-up action on audit, drill, and exercise findings were reviewed.
The licensee's audit program was also reviewed during a previous NRC
inspection and discussed in Report Nos. 50-325,324/89-04.
Based on this
review and the previous referenced report, this area of the licensee's
program aopears to be adequate.
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No violations or deviations were identified.
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9.
Emergency Plan Implementation (93702)
During the period of the inspection, two events occurred which required
Emergency Plan and PEPS implementation.
On September 20, 1989, at
7:50 p.m., the licensee declared an Unusual Event in response to Hurricane
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Hugo; and on September 21, 1989, at 8:47 a.m., an Alert was declared based
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on the loss of annunciators on Unit 2.
In both instances, the event was
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properly classified, and the appropriate actions were taken in accordance
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with procedures.
No problems were noted with the timeliness of initial or
follow-up notifications from the Control Room or TSC.
A more detailed
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description of events and equipment functions or malfunctions will be
included in NRC Report Nos. 50-325,324/89-26.
No violations or deviations were identified.
10.
Exit Interview
The inspection scope and results were surrarized on September 22, 1989,
with those persons indicated in Paragraph 1.
The inspector described the
areas inspected and discussed in detail the inspection results listed
below.
The licensee did not identify as proprietary any of the material
provided to or reviewed by the inspector during this inspection.
In
response to the IFIs detailed in Paragraphs 4, 5, and 6 of the report, the
Plant General Manager made the following commitments:
An acceptable follow-up notification form and the additional training
regarding follow-up notification requirements will be completed by
the end of Calendar Year 1989 (Paragraph 4).
Unannounced augmentation drill will be conducted by March 1990, that
would require augmentation personnel to respond to the plant site
(Paragraph 5).
An effect.ive tracking system for emergency response training will be
developed and implemented by the end of Calendar Year 1989
(Paragraph 6).
There were no dissenting comments regarding any of the inspection
findings.
Item Number
Description / Reference
50-325,324/89-31-01
IFI - Develop an acceptable follow-up
notification form, and conduct additional
training regarding the timeliness of the
,
follow-up message (Paragraph 4).
I
50-325,324/89-31-02
Violation - Failure to provide follow-up
notifications to State / local agencies in
accordance with PEP-02.6.21 (Paragraph 4).
50-325,324/89-31-03
IFI - Conduct an unannounced augmentation
drill to verify that Table B-1 of NUREG-0654
staffing and arrival times can be met
(Paragraph 5).
50-325,324/89-31-04
Violatten - Failure to provide members of
the emergency organization with training in
accordance with PEP-04.3 end TI-306
(Paragraph 6).
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50-325,324/89-31-05
IFI - Develop and implenent an effective
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tracking system for emergency response
training (Paragraph 6).
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