ML20006C672

Responds to NRC 891207 Ltr Re Violations Noted in Insp Rept 50-461/89-35.Corrective Actions:Emergency Planning Bulletin Issued to All Emergency Response Organization Members Emphasizing Importance of Attending Required Training

ML20006C672
Person / Time
Site:	Clinton
Issue date:	02/05/1990
From:	Holtzscher D ILLINOIS POWER CO.
To:	Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
References
U-601579, NUDOCS 9002080370
Download: ML20006C672 (3)

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January 5 1990' j;

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Docket No 50 461 -

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-Mr. A.'B.' Davis '

Regional Administrator Region III . . .

U.S.-Nuclear Regulatory Commission U 799 Roosevelt Road

' Glen Ellyn, Illinois 60137

Subject:

LResponse to Notice.of Violation in NRC' Insnection Renort 50-461/89035 dated December 7. 1989 Dear Mr. Davisi

.. This letter provides Illinois Power Company's-(IP's) response to

'the' Notice of ' Violation in NRC Inspection Report 50-461/89035.

l- Attachment A addresses the Notice =of Violation'which concerns-the j . failure to. provide annual retraining for individuals assigned--

responsibilities in the Emergency Response Organization'(ERO).-

IP believes that the information contained-in this letter adequately responds to the Notice of Violation in Inspection Report-50 461/89035..

b Sincerely yours, c,

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D. L. Holtzscher Acting Manager -

Licensing and Safety

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cc: NRC Clinton Licensing Project Manager l NRC Resident Office ),) i Illinois Department of Nuclear Safety ,i 9002080370 900205 PDR '

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Att% hment A Response to Notice of Violation in Inspection Report 50 461/89035 The Notice of Violation states in part:

" ...The Clinton Nuclear Generating Station Emergency Plan, Section 5.4, indicates that the licensee will provide annual retraining for individuals assigned responsibilities in the Emergency Response Organization (ERO). The content of this annual retraining is specified in Emergency Plan Implementing Procedure AP 05. Contrary to the above, two individuals had not received retraining regarding their responsibilities in the ERO for over sixteen months..."

1. Backcround and Cause of This Violation Emergency Plan Implementing Procedure (EPIP) AP.05, " Emergency Preparedness Training Programs", requires that refresher training be given annually (every twelve months) to members of the ERO, but allows a three month " grace period" in which to complete annual retraining.

Training is considered overdue when it is not completed within the twelve months. Training is considered expired when the fifteen month period has elapsed.

During November 13 17, 1989, the NRC conducted an inspection of routine Emergency Preparedness (EP) activities and notea several discrepancies regarding annual retraining of ERO members. J The NRC noted that annual training for two ERO members had expired. EP had previously identified that these two individuals needed training by using manual tracking methods. EP was unsuccessful however in getting these individuals to attend scheduled classes. These individuals and their departments were notified informally that their training had

' expired. This informal practice of notification occurred too late and was therefore ineffective.

In addition, several ERO members were identified as being overdue for training. Although EP knew that some ERO members were overdue for training, EP could not easily identify all ERO members in this category because no automated tracking system was available.

II. Corrective Actions Taken and Results Achieved  ;

EP reviewed the training records for a random sample of another 10% of the ERO members. No additional ERO members were identified as having overdue or expired training.

ERO members known to have overdue and/or expired training were provided the refresher training by December 8,1989.

EP will review the remaining ERO training records to ensure that training has not expired for any other ERO members. This review will be complete by January 12, 1990. If there are additional ERO members whose training has expired, they will be p.ovided refresher training by

.. January 31, 1990.

l An Emergency Planning Bulletin was issued to all ERO members emphasizing the importance of attending required training sessions, l (1)  ;

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Att:4hment A Response to Notice of Violation in Inspection Report 50 461/89035 s

III. Corrective Actions Taken to Prevent Recurrence An automated system for tracking ERO training vill be developed by January 31, 1990. This system will provide the names of ERO members in advance of their required training dates. EP will review the tracking system data to identify if there are any new expirations in ERO training. Any additional ERO members whose training has expired will be provided refresher training by February 28, 1990.

EPIP AP 10, ' Emergency Response Organization Assignments", will be changed to establish a formal process for notifying department managers and department training coordinators, in advance, of those ERO members who need training. This will provide adequate time for the training to be conducted prior to expiration. If after repeated notifications an

ERO member's training expires, the procedure change will require that T the official ERO roster be updated to indicate that the individual is no longer qualified. A Condition Report will also be initiated if any ERO member's training expires. The Condition Report will be assigned to the ERO member's department for corrective action. In addition, the Vice President will be informed if the expired training has an immediate impact on the ERO. This procedure change will be completed by February 28, 1990.

Once the procedure change to EPIP AP.10 is approved and the automated means of tracking ERO training is implemented, the formal process to continuously notify department managers and training coordinators, in advance, of those ERO members who need training will be used to prevent future training expirations.

IV. Date When Pull Comoliance Vill Be Achieved Illinois Power will be in full compliance by February 28, 1990, when the automated tracking system for ERO training will be in p' ace and the formal process of training notifications will be implemented.  ;

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