ML20059A391
| ML20059A391 | |
| Person / Time | |
|---|---|
| Site: | Westinghouse |
| Issue date: | 12/22/1993 |
| From: | Fici J WESTINGHOUSE ELECTRIC COMPANY, DIV OF CBS CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EKR93179, NUDOCS 9312300142 | |
| Download: ML20059A391 (5) | |
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EKR93179 Westinghouse Commercial Nuclear y,ju*Na SC 29250 Electric Corporation Fuel Dmston (802 ne 2e10 December 22, 1993 U.S.
NUCLEAR REGULATORY COMMISSION ATTN:
Document Control Desk Washington, DC 20555 SUBJEC'f:
REPLY TO A NOTICE OF VIOLATION
REFERENCE:
NRC Inspection Report No. 70-1151/93-08 Gentlemen:
Pursuant to the provisions delineated in Section 2.201 of the NRC's
" Rules of Practice", Part 2, Title 10, Code of Federal Regulations, Westinghouse herein provides formal response to your letter of November 26, 1993, regarding your Region II Inspector A. Gooden's inspection of the Columbia Fuel Fabrication Facility, conducted during the period October 25-29, 1993.
Appendix A of this document addresses the particular concern expressed in the NRC inspection report cover letter that the corrective actions taken for a previous violation were not effective in preventing a recurrence.
Appendix B provides our response to the violation of NRC requirements specified in the Notice of Violation.
I hereby affirm that the statements made in this response are true and correct to the best of may knowledge and belief.
Should you have any questions, or require additional information, please telephone me at (803) 776-2610.
Sincerely, WESTINGHOUSE ELECTRIC CORPORATION ames A.
Fici, Plant Manager Columbia Fuel Fabrication Facility cc:
U.S. Nuclear Regulatory Commission i
Regional Administrator 101 Marietta Street, N.W.
Atlanta, GA 30323
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A APPENDIX A RESPONSE TO CONCERN In this Appendix, Westinghouse addresses the NRC concern regarding a
previous finding (91-05-01) involving emergency responder
- training, i.e.,
the adequacy and effectiveness of the tracking system for personnel training and qualifications.
The corrective actions implemented following the 91-05-01 violation included developing up-to-date personnel training lists for i
emergency responders such as Emergency Directors, Emergency Coordinators, Regulatory Operations (Health Physics), Medical, Security and Off-site Responders.
When training was performed, these lists -were used to assure that all applicable personnel received the appropriate training.
This was very effective as a tracking mechanism to assure that all responders received the required training.
For the Site Emergency Brigade, a database roster was developed for all members, which included information on training required by the Site Emergency Plan.
This roster was used by the Emergency Brigade Coordinator to document training and to issue disqualification documentation if an Emergency Brigade member failed to attend the minimal training required by the Site Emergency Plan; this was generally effective in tracking Emergency Brigade training.
In retrospect, the generally effective system developed for the Emergency Brigade training and qualifications was flawed in the following areas:
The system for documenting training and verifying that Emergency Brigade members were qualified, relied on verbal discussions between the Emergency Brigade Coordinator (Regulatory Engineer -- Safety) and Emergency Coordinators, Emergency Brigade Leaders and Emergency Brigade members.
For example, new recruits were advised verbally that they could not fully respond to an emergency until they had received the full complement of training. These conditions for responding to emergencies were also reinforced during training sessions and drills.
We now believe that this system should be formalized and tracked to assure understanding by-all parties.
Information regarding the qualifications of Emergency Brigade members was not transmitted to the Emergency Coordinators and Emergency Brigade Leaders, who are responsible for assigning Emergency Brigade members to emergency duties.
We now believe that this should be an integral part of the program.
Non-training aspects such as medical examinations and respiratory protection were not included in the database of information for Emergency Brigade members. These non-i 1
f
i training aspects were being followed by the individual l
departments responsible for implementing them.
We now believe that there should be a single database for this purpose.
j Last, but not least, we failed to incorporate the program into a formal procedure.
A formal procedure would have resulted in a more systematic approach to addressing the prior violation and would have avoided a recurrence.
These weaknesses are addressed by corrective actiens described in Appendix B to this response.
Westinghouse agrees with your expectations that licensees should learn from their past
- failures, and, should take effective corrective actions; and, trust that you concur that the actions
+
contained in Appendix B to this response will help us to meet your expectations. We are very proud of our emergency planning training program, and fully agree with the Inspector's following comments from Inspection Report 93-08:
"With the exception of the violation noted..., the training program for emergency response personnel was considered a program strength.
Both the quantity and quality of drills conducted by the licensee far exceeded any regulatory basis or Plan commitment.
The results of the program enhancement in this area were demonstrated by the prompt and effective response on the part of the emergency organization to the postulated accident j
We believe that the performance-based training program initiated during 1993 is also a program strength; and we plan to continue, and even improve upon this program, during 1994.
Please be assured that the corrective actions outlined in this response will resolve this issue and avoid further recurren'ce.
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APPENDIX B WFSTINGHOUSE RESPONSE TO THE ITEM OF NONCOMPLIANCE IDENTIFIED IN THE NRC NOTICE OF VIOLATION The following information is provided in response to the Inspector's observation that "two individuals assigned to the Emergency Brigade roster had not participated in drills, and documentation was lacking to show that minimal training as specified in Section 7.2.4 of the Plan was completed; and two additional individuals were assigned to the Brigade roster but had not received a 1993 examination for respiratory certification":
I.
ACKNOWLEDGEMENT OF THE VIOLATION I
The violation is essentially correct as stated in the Notice of Violation.
For one of the individuals identifed in the Notice of Violation, a disqualification letter dated August 3, 1993 was written based upon the individual not participating in the required training sessions.
We acknowledge, however, that this individual's name appeared as a qualified Emergency Brigade member on the roster which was in effect at the time.
II.
REASON FOR THE VIOLATION On December 3, 1993, a Root Cause Analysis Team was formed to identify Causal Factors associated with the violation and to r
recommend corrective actions.
The following Causal Factors were identified:
Failure to have a formal procedure for placing Emergency Brigade members on an inactive list if requirements have not been met.
Failure to have a central control for tracking Emergency Brigade training and other qualifications.
1 j
III. IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED i
On November 4,
- 1993, a
letter was sent to Emergency Coordinators and Emergency Brigade Leaders with a revised Emergency Brigade Roster.
The purpose of this roster is to assist these individuals in assuring that only trained a-O qualified personnel respond to emergencies, by referring to the roster before assigning an Emergency Brigade member.
The letter also reminded the Emergency Coordinators and Emergency Brigade Leaders that Emergency Brigade members must also meet other requirements such as treadmill stress tests, pulmonary function tests, annual physical examinations and SCBA training before being assigned to emergency duties.
The roster is divided into two sections:
those who are qualified and their level of qualification (from a Recruit to an Advanced Exterior & Interior Responder), and restricted
i
, personnel who are not approved for-response.
The four individuals referenced in the Notice of Violation have been placed on the restricted list until they can meet all training and qualification requirements.
These actions were successful in documenting qualified Emergency Brigade members and in transmitting this information to those individuals who are responsible for assigning Emergency Brigade members to emergency duties.
IV.
ACTIONS TO PREVENT RECURRENCE 1.
A revised database is being developed which will include all information necessary to cismonstrate that-an Emergency Brigade member i::,
@alified to perform emergency duties.
This database will be transmitted to Emergency Coordinators and Emergency Brigade Leaders initially and quarterly thereafter.
Copies will also be placed on the Columbia Plant Emergency Vehicle and in the Emergency Operations Center.
These actions will be completed by December 22, 1993.
2.
Site Emergency Plan Implementing Procedure CSEP-0015,
" Emergency Brigade Organization", will be revised to reflect the new database, and will provide procedural requirements for future quarterly updates of the database.
This will be completed by January 31, 1994.
V.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance has been achieved.
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APPENDIX B 4
WESTINGHOUSE RESPONSE TO THE ITEM OF NONCOMPLIANCE IDENTIFIED IN THE NRC NOTICE OF VIOLATION The following information is provided in response to the Inspector's observation that "two individuals assigned to the Emergency Brigade roster had not participated in drills, and documentation was lacking to show that minimal training as specified in Section 7.2.4 of the Plan was completed; and two additional individuals were assigned to the Brigade roster but had not received a 1993 examination for respiratory certification":
I.
ACKNOWLEDGEMENT OF THE VIOLATION The violation is essentially correct as stated in the Notice l
of Violation.
For one of the individuals identifed in the Notice of Violation, a disqualification letter _ dated August 3, 1993 was written based upon the individual not participating-in the required training sessions.
We acknowledge, however, that this individual's name appeared as a qualified Emergency Brigade member on the roster which was in effect at the time.
II.
REASON FOR THE VIOLATION On December 3, 1993, a Root Cause Analysis Team was formed to identify Causal Factors associated with the violation and to recommend corrective actions.
The following Causal Factors were identified:
Failure to have a formal procedure for placing Emergency Brigade members on an inactive list if requirements have not been met.
Failure to have a central control for tracking Emergency Brigade training and other qualifications.
t III. IMMEDIATE ACTION TAKEN AND RESULTS ACHIEVED On November 4,
- 1993, a
letter was sent to Emergency Coordinators and Emergency Brigade Leaders with a revised Emergency Brigade Roster.
The purpose of this roster is to assist these individuals in assuring that only trained and qualified personnel respond to emergencies, by referring to the roster before assigning an Emergency Brigade member.
The letter also reminded the Emergency Coordinators and Emergency Brigade Leaders that Emergency Brigade members must also meet other requirements such as treadmill stress tests, pulmonary function tests, annual physical examinations and SCBA training before being assigned to emergency duties.
The roster is divided into two sections:
those who are qualified and their level of qualification (from a Recruit to an Advanced Exterior & Interior Responder), and restricted
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personnel who are not approved for response.
The four individuals referenced in the Notice of Violation have been placed on the restricted list until they can meet all training and qualification requirements.
These actions were~. successful in documenting qualified Emergency Brigade members and in transmitting this information to those individuals who are responsible' for assigning Emergency Brigade members to emergency duties.
IV.
ACTIONS TO PREVENT RECURRENCE 1.
A revised database is being developed which will include all information necessary to demonstrate that. an Emergency Brigade member is qualified to-perform emergency duties.
This database will be transmitted to Emergency Coordinators and Emergency Brigade Leaders initially and quarterly thereafter.
Copies will also be placed on the Columbia Plant Emergency Vehicle and in the Emergency Operations Center.
These actions will be completed by December 22, 1993.
2.
Site Emergency Plan Implementing Procedure CSEP-0015,
" Emergency Brigade Organization", will be revised to reflect the new database, and will provide. procedural requirements for future quarterly updates of the database.
This will be completed by January 31, 1994.
V.
DATE WHEN FULL COMPLIANCE WAS ACHIEVED Full compliance has been achieved.