ML20086S840
| ML20086S840 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 12/23/1991 |
| From: | Spencer J CAROLINA POWER & LIGHT CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9201060025 | |
| Download: ML20086S840 (5) | |
Text
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C9&L Caronna Power & Light Company
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Brunswick Nuclear Project P. O. Box 10429 Southport, N.C.
28461 0429 December 23, 1991 FILE:
B09-13510C 10CFR2.201 V:,
U.S. Nuclear Regulatory Commissioa ATTN:
Document Control Desk Washington, D. C. 20555 BRUNSWICK STEAM ELECTRIC PLANT 4JNITS 1 AND 2 DOCKET NOS. 50-325 AND 50 324 LIC*/.NSE NOS. DPR-71 AND DPR 62 REPLY TO A NOTICE OF VIOLA._T.10E Centlemen:
The Brunswick Steam Electric Plant (BSEP) has received NRC Inspection Report 50-325/91-28 and 50-324/91 28 and ffnds that it does nct contain information of a proprietary nature.
This report included a Notico Of Violation.
Enclosed is Carolina Power & Light Company's response to that Nucice of Violation.
Very truly yours, CV 1
J. 1, Spencer. C nc/a1 Managtr
. swick Nuclear Project Enclosure cc:
Mr. S. D. Ebneter Mr. N. B..Le BSEP NRC Resident Office l
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.9201060023 9i1223 l
PDR ADOCK 05000324
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t VIOLATION 10CFR50.54 (q) requires that Nuclear Power Reactor licensees follow and maintain in effect Emergency Plans which meet the requiremencs of 10CFR50.47 (b).
Technical specification 6.8.1 (e) requires, in part, that written procedures be implemented and maintained for Emergency Plan implementation.
Plant Emergency Procedure PEP-04.3 and Training Instruction T1 306 outline the program for administration of training to the required individuals. Section 6.1 of the Brunswick Emergency Response Plan requires that Emergency Response personnel receive initial and annual retraining.
Contrary to the above, during an inspection of October 7-11, 1991, a number of di.acrepancies were noted.
A total of 93 out of epproximately 740 individuals were identified as not meeting the training requirements for the Emergency Plan.
RESPONSE
I.
Admission or denial of the alleged violation:
CP&L acknowledges the violation in that 93 out of approximately 740 individuals were identified as not currently meeting the training requirements for the Emergency Plan.
II.
Reason for the violation:
As noted in details of this violation, CP&L identified needed improvements in the E.P. Training program during the first quarter of 1991, and an evaluation was initiated to enhance the overall program.
Results of this evaluation would be used to improve training as well as enhance the sch '" ling and tracking system.
In addition, several barriers were placed in the program to minimize the potential for expired training for personnel on the Emergency Response Organization roster. These 5 arriers included:
1.
The Brunswick Training Unit began reporting "no. shows" to individual unit contact schedulers.
2.
Unit Managecs were notified, via memorandum from the Manager of Training, of any failures in E.P. Training.
3.
Emergency Preparedness began a me--%1y aud!c of training records to identify personnel whose training was at or near expiration.
During an NRC inspection on October 7-11, 1991, discrepancies were identified in the Emergency Plan training program. CP&L subsequently audited training records and identified 93 individuals out of approximately 740 as not currently meeting the training requirements.
Barriers #1 and #2 above failed to ensure that "no shows" were rascheduled ' for training.
Barrier #3 had not been conducted as required.
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Following this inspection a root cause investigation was performed which identified the following causes:
1.
Existing training procedures and the absence of an Administrative procedure to define the Emergency Response Organization (ERO) precluded personnel from baing scheduled for E.P. training.
For Exattple:
TI-306 instructions required enhancement for contact schedulers.
T1-306 does not describe a method of reporting "no-shows."
There is no written guidanca for the ust of the NUCLEAR EDUCATION TRAINING SYSTEM (NETS) database as it specifically applies to E.P. training.
The lack of a complete detailed listing of the Emergency
Response
Organization (ERO) added to scheduling difficulties.
2.
There are no criteria to identify an individual as a unit contact scheduler and no set expectations for those individuals, There is a need to improve the accountability of supervisors and subordinates to maintain Emergency Plan qualifications 3.
An informal audit was required to be performed on a monthly basis of +he E.P.
training program.
This audit was not performed uring the period of July 30 through October 1991.
4.
Commitments to nrevious NRC violations were not adequately reviewed and assessed to ensure complete corrective action.
Prior to this inspection in September 1989, an NRC violation identified previous exempics of expired E.P. training.
An IFI was issued during the same inspection to develop a centralized tracking system for E.P, training.
The violation and IFI were closed out by the NRC in March of 1990.
A non-cited violation was issued in February of 1991.
In this
- case, the inspector determined that training qualifications for two randomly selected ERO personnel were delinquent. In the month prior, potential problems in this area were identified with an action plan under development.
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i III. Corrective steps,hici,sh.)ve been taken and results achieved:
A comprehensive audit was completed that idencif.f ed the scope of the training problem.
(October 10 - 15, 1991)
Special classes were conducted on October 10,
- 1991, and e
October 11, 1991, for individuals with expired training.
A comprehensive listing for the ERO was completed on October 16, 1991.
The list contained 749 qualified ERO members.
The E.P. representative responsible for reviewing ERO training records received appropriate disciplinary action.
Regulatory Compliance Instruction- (RCI) 11.0 titled " Emergency Response Organization Additions, Deletions, and Changes" Rev. O, was approved nocembnr 10, 1991. This procedure describes how the ERO will be maintained for the Brunswick Nuclear Project.
This procedure includes a mechanism for notifying the appropriate management of a delinquent individual and removing that individual from the ERO. An individual whose training is expired by 30 days will have his or her security access to the protected area suspended until E.P.
training is current.
RCI 11.0 also formalizes the requirement for conducting a comprehensive audit of the training program on a monthly basis.
These actions will ensure that personnel are retrained in a timely manner.
IV.
Corrective action which will be taken to avoid further violation:
The following corrective actions will be taken to avoid further violation. Although these actions are being performed, the following procedural enhancements will strangthen the program, Training Instruction (TI) 306 will be revised to formalize the e
following:
Definitions of the responsibilities of Emergency Preparedness and Brunswick Training Unit (BTU) personnel.
Methods for reporting "no shows" and " failures" to the appropriate management.
Specific instructions for contact schedulers.
Due date - 2/15/92.
Procedural guidance will be developed for the use of NETS as it applies to E.P. training.
Due date - 3/31/92.
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Date when; full compliance will be achieved:
V.
CP&L is = in full compliance.
Compliance is ensured by-the new i
Regulatory Compliance Instruction (RCI) 11.0 (dated December 10,19'J1) which procedurally establishes and defines the Emergency Response Organizat.on (ERO) and requires the following:
A monthly audit of the training program to identify any individual whose Emergency Plan trainin5 has or is about to expire.
Notification of appropriate management of individuals--
delinquent in Emergency. Plan training.
- Deletion from the ERO of any individual whose Emergency Plan-training has expired.
Suspension of security _ access to. the protected area for r
individuals who fail to correct Emergency Plan training deficiencies in a timely manner.
In addition, enhancements will be forthcoming as delineated in section
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IV of this response to further strengthen our program.
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