ML20137B019

Responds to NRC Re Violations Noted in Insp Rept 50-298/85-22.Corrective Actions:Individuals Deficient in Emergency Training Suspended from Emergency Planning Responsibilities & Methodology for Training Modified

ML20137B019
Person / Time
Site:	Cooper
Issue date:	09/30/1985
From:	Pilant J NEBRASKA PUBLIC POWER DISTRICT
To:	Johnson E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20137A992	List: IR 05000298/1985022 ML20137B019
References
CNSS850571, NUDOCS 8511260164
Download: ML20137B019 (3)

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COOPER NUCLEAR ST ATioN P.o. box 98 BRoWNVILLE. NEBRASKA 68321 Nebraska Publ.ic Power Distr.ict TE'EesoNE se m-am CNSS850571

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September 30, 1985 u I OCT-7885

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LD Mr. E.11. Johnson, Chief --

Reactor Projects Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive Suite 1000 Arlington, Texas 76011

Subject:

NPPD Response to IE Inspection Report 50-298/85-22

Dear Mr. Johnson:

This letter is written in response to your letter dated September 5, 1985 transmitting Inspection Report 50-298/85-22. Therein you indicated that one of our activities was in violation of NRC requirements.

Following is a statement of the violation and our response in accordance with 10CFR2.201.

Statement of Violation 10 CFR 50.47(b)(15) requires that adequate provisions exist in the emergency plan to ensure that radiolo31cal emergency response training is provided to those who may be called on to assist in an emergency.

Section 8.1.1 of the emergency Cooper Nuclear Plan states that the CNS Emergency Plan Training Program ensures that station personnel, who will be active participants in the emergency organization, are familiar with the contents of the Emergency Plan and Emergency Plan Implementing Procedure (EPIP's) .

Contrary to the above, certain station personnel assigned to the emergency organization had not received appropriate general and specific emergency plan and procedure training, as evidenced by the following:

On July 16-17, 1985, NRC inspectors conducted simulated accident walkthroughs with a Shift Supervisor and a Control Room Supervisor. They were unable to properly use their EPIP's to identify and classify a simulated accident. Further, they did not demonstrate familiarity with the use of emergency notification procedures and offsite notification forms.

This is a Severity Level IV Violation (Supplement VIII) (50-298/85-2201).

f&l4/!&I 8511260164

/ PDR G 851114 ADOCK 05000298 pon y

Mr. E. H. Johnson 7* S:ptember 30, 1985 Page 2 Reason for the Violation A significant contributor to this deficiency is felt to be the training methodology that has been used. It is believed that improved operational response may be achieved by restructuring the training to include more mock scenario participation during the training sessions. Additionally, it is believed that a second contributing reason for this deficiency is related to inadequate emphasis on use of the EPIPs and associated check-lists during classroom training.

Corrective Action Taken and Results Achieved Those individuals found deficient in emergency training were suspended from emergency planning responsibilities. These individuals were given additional classroom study primarily focused on the EPIPs used for accident classification, Emergency Plan implementation, and notification.

More extensive use was made of mock scenarios during these training sessions, including oral discussion and examination. Finally, a walk-through drill was conducted in the Control Room using a mock scenario which required the participants to demonstrate their familiarity with the EPIPs, classification methods, notification and communication equipment, etc.

This additional refresher training, exclusive of the walk-through demon-stration in the Control Room, was subsequently included in requalifica-tion training sessions conducted for licensed shift operating personnel.

Corrective Steps To Be Taken To Avoid Further Violations The methodology for training licensed shift operating personnel has been modified to a) more directly focus on implementation of EPIP requirements required for initial emergency response activities, and b) incorporate on a more extensive basis the use of mock scenarios during the training process which require the participants to use the EPIPs and related checklists and discuss their response actions with the instructor.

Further refinements to the training methodology will be made based upon training session critique comments provided by the participants and industry practices employed elsewhere which are suitable for our needs.

Additionally, more frequent assessments of emergency preparedness readi-ness will be conducted. These will take the form of training exercises which we plan to conduct on a periodic basis throughout the year for selected members of the emergency response organization. Should these exercises result in the identification of deficiencies which can best be corrected by training, supplementary training sessions will be developed and conducted.

Date When Full Compliance Will Be Achieved As noted in the Inspection Report on page 7, immediate corrective action was initiated. Additional classroom and walk-through training was subsequently conducted. The individuals adequately demonstrated their

,,, Mr. E. II. Johnson

. "S:ptember 30, 1985 Page 3 knowledge of their respective emergency planning responsibilities and were allowed to reassume their emergency duties on August 2, 1985.

Cooper Station was in full compliance as of this date.

If you have any questions regarding this response, please contact me.

Sincerely, J. M. Pilant Technical Staff Manager Nuclear Power Group JMP:DLR:PRW:lb