ML19332E477

Responds to Violations Noted in Insp Repts 50-324/89-31 & 50-325/89-31.Corrective Actions:Audit Initiated to Verify Qualifications of Emergency Response Organization & 1 H Training Session Provided to Emergency Preparedness Staff

ML19332E477
Person / Time
Site:	Brunswick
Issue date:	11/27/1989
From:	Harness J CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-89-1051, NUDOCS 8912070274
Download: ML19332E477 (5)

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Caro!6na Power & Light Company Brunswick Nuclear Project P. O. Box 10429 Southport, NC 28461-0429 November 27, 1989

. FILE:. B09-135100 10CTR2.201 l SERIAL: BSEP/89-1051- j U.S. Nuclear Regulatory Commission.  !

ATrN: Document Control Desk

- k'ashington, DC 20555-  ;

'l BRUNSWICE STEAM ELECTRIC PLANT UNITS 1 AND 2 -j DOCKET NOS. 50'325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 <

RESPONSE TO INFRACTIONS OF NRC REQUIREMENTS .)

j Gentlemen:

The Brunswick Steam Electric Plant (BSEP) has received ISE Inspection Report 50-525/89-51 and 50-324/89-31 and finds that it does not'contain information of a proprietary nature, t

This-report identified two items that appear to be in noncompliance with NRC

• requirementsi Enclosed is Carolina Power & Light Company's' response to this '

violation. ,

Very truly yours, [

I vU$%,LK J. L.~ Harness, General Manager Brunswick Nuclear Project ,

BLH/mcg Enclosure f cc: Mr. S. D. Ebneter [

Mr. E. G. Tourigny BSEP NRC Resident Office [

f 8912070274 891127 h6

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PDR ADOCK 05000324 a PNU

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7 VIOLATION A

10CTRSO.54(q) requires.that nuclear. power reactor licensees follow and I maintain in effect Emergency Plans which meet the requirements of 10CFRSO.47(b). Technical-Specification 6.8.1.e requires, in part, that written procedures shall be implemented and maintained covering the Emergency Plan

implementation.

Section 6;1 of the Brunswick Emergency Plan states the training program ,

'provides -initial training and annuali retraining of the emergency response j organization. The specific _ training' requirements.for emergency response l personnel are defined in Section 3.0 of Plant Emergency. Procedure 04.3, and i Section 4'.0 of Training Instruction ~ 306.  ;

Contrary to the above, individuals were assigned to the emergency organization that were not trained in accordance with Attachment 1 of Training Instruction  ;

306, or Section 3 of Plant Emergency Procedure 04.3. -l

.This is a' Severity Level IV violation (Supplement VIII). 4

RESPONSE

I. Admission or' Denial of the Alleged Violation i CP&L acknowledges.that individuals were assigned to the emergency ,

organization that were not trained in accordance with the stated procedure / instruction.

II. Reason for the Violation Section 6.1.1 of the Brunswick Emergency Plan ensures training of those 3

-individuals who may be called to respond to an emergency at the Brunswick- t plant by providing initial and annual' refresher training and retesting on the scope and content of the plan and procedures which implement the plan.- TI-306, Attachment I, indicates the required training for various emergency response positions.

As indicated above, several individuals have been identified as not having the required Emergency Plan training. A formal program for tracking and scheduling individuals for training was under development but not fully

' implemented. Specific causes for individuals who did not have the }

required training are as follows:  ;

a. Errors in the Training matrix for the STAS (i.e., SEC listed as being required).

b. Recent organization changes in Operations, i

c. Individuals whose training had become overdue.

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i il III. Corrective Steps Which Have Been Taken ,

1.; ~ An Emergency Response Organization audit has been iriitiated to q' determine.' individuals needing training and to ensure that their i training is updated. Each operating shift has been reviewed to j

.i determine that qualified personnel are available'to fill required ]

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emergency response positions.  !

p H 2. - The Specialist - Emergency _Preparednoss is'now receiving'a list from p the Personne1< Department on new employees and transfers within CP&L i O . for purposes of maintaining the tracking. system current.  ;

IV.. Corrective Steps to be Taken and'Date of Full Compliance I E

The Emergency Preparedness personnel, working with'the Brunswick Training l

~ Unit, has identified.a more dependable method of scheduling and tracking-Emergency plan Training and is currently finalizing the program. To U . ensure training is completed as. required, the Brunswick Training Unit will-assume responsibility to schedule and track the Emergency Plan training

=using the Nuclear Education Training System by January 11, 1990. This l'

process will provide se'quential " flagging" of personnel as they approach Lj expiration of current qualification to allow retraining prior to expiration.-

As noted in III.1, an audit has been initiated to verify qualifications'

.for the Emergency Response Organization. By January 11, 1990, the audit i-will be complete and appropriate Unit' Manager's will be notified of personnel in their unit needing training. Training will be conducted as appropriate to ensure the Emergency Response Organization. maintains t desirvd staffing needs.

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y p, VIOLATION B

.10CFR50.54(q) requires that nuclear. power reactor licensees follow and maintain in effect' Emergency-Plans which meet the requirements of 10CFR50.47(b).

Technical Specification'6.8.1.e requires, in part, that written procedures

(_ shall'be implemented and maintained covering Emergency Plan implementation.

L b~ Section 3.5 of the' Brunswick Emergency Plan addresses notification and activation of the on-site and off-site emergency response organization.

Section 6.3 of Plant Emergency Procedure 02.6.21. Emergency Communicator,

@p ' details the Control Room activities regarding notification responsibilities.

E' -~According to Section 6.3.1, follow-up notifications should be made at p 60-minute intervals or more frequently if warranted by changing conditions.

-Contrary to the above, on June 17, 1989, the licensee declared an Unusual L ' Event and made initial notifications to authorities, but failed to make a follow-up notification for two hours.

This'is a Severity Level IV Violation (Supplement VIII).

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RESPONSE

.1. . Admission or Denial of the Alleged Violation CP&L acknowledges that we failed to make timely follow-up notification.

II. Reason for the Violation PEP-02.6.21, Emergency Communicator, details the Control Room activities h

regarding notification responsibilities. According to Section 6.3.1, follow-up notifications shot,1d be made at 60-minute intervals or more fraquently. if warranted by changing conditions.

Contrary to the above, on June 17, 1989, ibe licensee declared an Unusual

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Event and made. initial notifications to authorities but failed to make a

~y follow-up notification for two hours. The Control Room staff did not

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make the notification because they interpreted the procedure step as a suggestion rather than a requirement.

III. Corrective Steps Which Have Been Taken and Results Achieved PEP-02.6.21 has been re"ised to indicate that follow-up notifications "shall" be made at 60- ninute intervals or more frequently if warranted by changing conditions.

A special one-hour training session has been provided to each Operations shift by the Emergency Preparedness staff. The training included a 4 description of the procedure revisions and a review of similar problems in this area during past drills and events. Time was also given to enhance the operator's awareness of actions that would be taken by off-site agencies and the need for timely notifications, i

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