ML20077Q265
| ML20077Q265 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 08/14/1991 |
| From: | Spencer J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| B9-13510C, NUDOCS 9108210151 | |
| Download: ML20077Q265 (5) | |
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Cp&L i
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Carolina Power & LigM Company manan==maanammansmemwmam Brunswick Nuclear Project l
P. O. Box 10429 l
Southport, N.C.
28461 0429 August 14, 1991 FILE:
B09 135100 10CrR2.201 I
U.S. Nuclear Regulator Commission ATTN: Document Contro Desk Washington, D. C. 205$5 l
BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50 325 AND 50 324 LICENSE NOS. DPR 71 AND DPR.62 i
REP 13 TO A NOTICE OF V101AT1Q3 Centlemen:
The Brunswick Steam Electric Plant (BSEP) received NRC Inspection Report
$0 325/91-12 and 50 324/91 12 and found that it did not contain information of t
a proprietary nature. The report included a Notice Of Violation.
Carolina Power 6 Light Company denied the Notico Of Violation by letter dated May 31, 1991, on the grounds that the inaccurate information cited as the cause of the violation was not " material". The NRC rejected this dental by [[letter::05000325/LER-1991-015-01, :on 910612,CRD Hydraulic Control Unit Declared Inoperable.Caused by Simultaneous Inoperability of Two CRD Hydraulic Control Units.Unit Accumulator Recharged W/ Nitrogen & Repaired|letter dated July 12, 1991]].
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Enclosed is Carolina Power and Light's response as requested in the NRC letter
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rejecting the original denial.
Please note that the original ptoposed 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of simulator training per quarter
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per licensed operator is now recognized by CP&L as being unreasonable due to t
other training commitments and constraints and the enclosed response hereby i
clarifies the intent of-the originni commitment.
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Very truly yours, g
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S encer C idral Manager I
Brunsw!bk Nuclear Project l
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l; En:losure cc:
Mr. S. D. Ebneter
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Mr. N. B. Le h3EP NRC Resident Office
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I 9108210151 910814 O-PDR ADOCK 05000324
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BRUNSWICK STFJJi ELECTRIC PIANT, UNITS 1 6 2
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NRC DOCKET NOS. 50 325 & $0 324 5
OPERATINC LICENSE NO. DPR 71 6 DPR 62 PEPLY TO NOTICE OP V101ATION.
V101ATION:
10CTR50.9 (a) in "Information provided to the Cormaission...
I by a licensee... part requires that:shall be cornplete and accurate in all material respects".
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Contrary to the above, inf ormation provided to ths SRC in tha licensee's monthly status report on the Brunswick Inter, rated Action Plan (IAP) was inaccurate in that it showed actions concerning IAF iterns were completed while, in fact, they were not completed in accordance with the referenced commitment:
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IAP item D33.h committed the licensee to in.*rease the number of simulator hours to a minimurn of 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per grerter per licensed operator, This i
action was targeted for in.pleuentation by September 30, 1990, and is shown i
as cornple t e on the licensee's inonthly status report on the Brunswick 1
Integrated Action Plan dated April 30, 1991. Review of this commitment i
determined that training instruction TI 200 had been revised to require j
that each operator receive 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> of simulator tirne each year in lieu of J
16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per quarter, as committed. Additionally, review of the operator i
simulator ti;ne for the fourth quarter of 1990 determined that the operators had not received 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of simulator titue during the quarter.
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IAP item D33.p committed the 11censee to conduct an inde evaluation, prior to the 1990 examinations (now 1991 examinations) pendent
, usint personnel who are not directly conducting traininr, of IDR readiness, and incorporate a requirement for the independent evaluations of the 14R and IILC examination readiness into Brunshick Training Instructions. This item was to be co.upleted by January 31, 1991, and is shown as complete on the licensee's monthly status on the Brunswick Integrated Action Plan dated April 3,
1991. Independent evaluations, by personnel other than those conducting IDR training, of LOR and Ill.C examination readiness had not Nen conducted as of April 5, 1991, and na procedural requirements _for these i
evaluations had been established.
i This it, a severity level IV violation.
Reference:
Inspection Report 91-12 l.f I
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- RESPONSE TO VIOIATION:
Admission ot Denial of Violat32Di CP6L admits that incorrect status was provided for Integrated Action Plan (IAP) items D33 b and D33.p.
REASON FOR VIOLATION:
The violation occurred because of a failure to properly scrutinize the information provided for incorporation into the monthly IAP ntatus report due to the perception that the item was an internal commitment and the Level I item was the firm commitment.
It should be noted that the status of the Level I action-item D33 was accurately reported as incomplete during the inspection and remains I
as such. The status of associated Level II items D33.b and D33.p were reported i
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as complete and in fact were not, however, this did not impact the reported status of the Level 1 item D33.
CP6L acknowledges that this perception was in error with respect to IAP item D33 and corrective a$tions have been taken, j
i Rockrround Informa112D
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The NRC Diagnostic Evaluation Team (DET) Report for the Brunswick Nuclear Project was issued on August 2,1989. In September 1989, CP6L provided its response to
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the report.
The response, entitled the "Inte combined i
actions resulting from both the DET Report and CP& grated Action Plan",
L initiat.ives. CP&L committed to provide the Commission with a periodic status report of the IAP items listed.
To accomplish the IAP actions each item was broken down into smaller steps. The original actions stated in the IAP are considered " Level I" and constitute CP6L's commitments in response to the DET. The smaller steps are considered " Level II" items and are internal projects required to support the completion of the Level I IAP item.
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In April and May o'f 1990, the licensed operator requalification (ISR) training program was rated by the NRC as unsatisfactory based on a 35 percent pass rate i
during the LOR examinations. Consequently, CP&L shut down both units and the NRC l
issued a Confirmation of Action Letter (CAL) requiring the NRC Regional l
Administrator's approval for restart.
Interim and lon6 term actions were initiated to correct the deficiencies noted during the LOR examinations.
The long term corrective actions were incorporated into a new "D33" IAP item.
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item D33 states:
i Implement Nuclear Services Department Licensed Operator Training i
Improvements IAP D33 consists of items "D33.a" through "D33.s" (ie; 19 items).
Items D33.a
.through D33.s were subsequently handled as though they were IAP Level 11 internal projects which were required to meet the overall Level I item. This resulted in a failure to properly scrutinize the information provided for-incorporation into the monthly report due to the perception that the item was an internal commitment l
and the Level I item was the firm commitment. Ilowever, IAP items D33.a through D33.s are in fact commitments made in response to the-CAL.
Actions have been
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taken which will ensure the IAP item status is accurately reported.
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4' 1Ap item D33,b This item states:
Increase the number of sinnulator training hours to a minimum of sixteen hours per quarter per licensed operator, and assess the impact of this change on the adequacy of training staffing levels.
The administrative action taken to resolve this item was to require that each operator receive 64 hours7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> of simulator training annually.
This had been incorporated into the appropriate procedures and was reported as cotoplete in the toonthly 1AP status; however, this action did not rer,olve the item as stated.
As stated in the violation, during the fourth quarter of 1990 the operators did not receive 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> of simulator time. Adequate simulator time was unavailable during this period duu to a simulator outage which was required to prepare for the sinnulator certification and the 1991 LOR training that began January 7,1991.
It is worth noting that from a " performance based" outlook that some operators roccived as rouch as 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> of simulator training in the fourth quarter of 1990 and that a minimum of 127 hours0.00147 days <br />0.0353 hours <br />2.099868e-4 weeks <br />4.83235e-5 months <br /> of siinulater training was conducted for active licensed operators frorn June 1990 through May 1991, resulting in a quarterly average of better than 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.
CP&L acknowledges that the wording chosen did not accurately reflect their intention to exceed the INPO guideline of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> of simulator training per licensed operator annually, spread out on a periodic basis. The originally proposed 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> per quarter is now recognized by CP&L as being unreasonable, due to other traininr. commitments and constraints, and hereby clarifies the intent of the original commitment.
T1200 (le; Brunswich Plant Operator Retraining Program) has been revised to include the 64 hour7.407407e-4 days <br />0.0178 hours <br />1.058201e-4 weeks <br />2.4352e-5 months <br /> simulator training per licensed operator per year requirement and an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> simulator training minimum per licensed operator per quarter.
D33.p This item states:
Conduct an independent evaluation, prior to the 1990 exarninations, using personnel who are not directly conducting training of the LOR examination readiness, and incorporate a requirement for the independent evaluations of the LOR and Hot License examination readiness into the Brunswick Training Instructions.
The reporting of this item as cortplete was in error as. the requirement for independent evaluations had not been ircorporated into the appropriate procedures, it is worth notin5 that from a "perforrnance based" outlook that the following independent evaluations were performed prior to April 5,1991, contrary to the statement in the violation:
October 1990 - a contractor was obtained to provide CP&L with an independent assessment of operating crew performance examination readiness.
April 3 and 14, 1991 independent evaluations of LOR were conducted.
The NRC evaluation team observed the April 3,
- 1991, independent evaluation.
Additionally, bethe independent evaluations of HLC examination readiness were scheduled to conducted closer to the June 3, 1991, examination veek. To conduct the independent evaluations considerably before the week of the NRC examinations would have provided little useful information. Simulator training
on emergency operating procedures was still in progress; therefore, the innplementation of independent evaluations would not have encompassed the appropriate scope of knowledge and skills needed to evaluate examination readiness. Periodic, independent evaluations were scheduled for coirpletion throughout the simulator training phase from April to May and have been cornpleted. In addition, the independent avaluation for NRC examination readiness was conducted as ocheduled the week of May 20, 1991.
f&l@ECTIVE S_*1TftyillCH HAVE BEEN. TAKEN AND RESULTS ACllIEVED:
D33.b The original intent of this IAP item was to require an annual rainirnum of 64 simulator training hours por licensed operator per year. The IAP Monthly Status Report has been revised to reflect thin under the comments associated with D33.b.
The comments also state the revised inininam requirement of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of sirnulator training per quarter, thur, meetiu6 the original intent of D33.b of ensuring a minimum quarter 1v training requirement. This revision to the IAP item establishes a reasonable goa'l in lieu of other training comrnitments and constraints.
TI 200 has been revised (approved 5/22/91) to incorporate thin quarterly training requirement revision to a ininimum of 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of simulator training per quarter.
D33.p Revisions to Brunswick Training Instructions have been completed to incorporate the requirement for independent evaluations of the Licensed Operator Requalification and llot License examination readiness. Procedures revised include TI 200 T revised 4/11/91), and TM-4.15 (le M 4.07 (ic; Guidelines for Simulator Training,C Style Licensed Operator Development / Administration / Evaluation /of hR Requalification Exams, revised 4/11/91). These procedures establish the Manager of Training as the responsible individual for ensuring compliance with this commitrnent.
The revisions stated above complete the actions required to fulfill IAP action items D33.b and D33.p. These two items are closed.
CORRECTIVE ACTIONS WilICll VILL BE TAKEN TO AVOIILIMRTilER VIOLATIONS.1 CP&L has assigned a full time IAP coordinator to perform IAP administrative duties. This person performs an objective evaluation to verify that sufficient documentation exists when reporting chant,es in the cornpletion and closeout status
-of IAP items prior to revising the toontnly IAP status report.
DATE WilEN FULL COMPLIANCE WILL BE ACllIEVED:
CP&L is in full compliance.
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