ML20090H678
| ML20090H678 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/06/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9203160205 | |
| Download: ML20090H678 (4) | |
Text
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[ _ ].1400 or,ua Place
\\v oowners Grove, Illhols 60515
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March 6,1992 U.S. Nuclear Regulatorv Commission
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Washington, DC 20555' Attention: Document Control Desk
Subject:
Braidwocd Nuclear Power Station Units 1 and 2 Response to Notice of Violation Inspection Report Nos. 50-456/92002; 50-457/92002 NRC Docket Numbers 50-456 and 50 457 g
Reference:
L. Greger letter to C. Reed dated February 7,1992 transmitting NRC Inspection Repen 50-456/92002;50-457/92002 Enclosed is Commonwealth Edison Cornpany's (CECO) response to the Notice of Violation (NOV) which was transmitted with the referance letter and inopection Report. The NOV cited two Severity Lovel IV violations requiring a written response. The violations concerned the failure to revise GSEP lesson plans within the required timeframe, and the failure to provine tra:ning in emergency response to repair and damage control teams. CECO's response is provided in the attachment. If your staff has any questions or comments concerning this letter, please refer them to Denise Saccomando, Compliance Engineer at (708) 515 7285.
Very truly yours, d [.
T.J. Kovach Nuclear Licensing Manager Attachment cc:
A. Bert Davis, NRC Regional Administrator - Rill R. Pulsifer, Projdwood Senior Resident inspector ect Manager - NRR S. Dupon'. >. :-
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ATTACHMENT RESFONSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT i
504 56/92002;457/92002 i
ylOLAI1ON (456/92002-01) 10 CFR Part 50.54(q) rer uires that a licensee authorized to possess and operate a nuclear power reactor s 1all follow arid maintain !n effect emergency plans whicn meet the standards in 10 CFR Part 50.47(b) and ine requirements of Appendix E of 10 CPR Part 50. Appendix E states that the emergency plan will provido a description of the specialized training which emergency resense personnel assigned to repair and damage control teams will receive. The GSEP, Section 8.2.1, states that emergency response personnel assigned to repair and damage t,ontrol teams will perform emergency response activities us an extension of their normal duties and will be trained each year as part of their duty specific training.
Contrary to the abc,'e, einergency response personnel assigned to repair and damage control teams did no, receive speciai; zed emer0ency preparedness training, relevant to their role in the emergency response organ!zation, each year as part of their duty specific training.
BEASQNfRR.IBE_VIOLAllON Emergency plan training was given in three separate and distinct groupings.
- 1) All persons with unescorted access to the protected area received training on their required actions in the event of an emer0ency. This was provided during Nuclear Station General Employee Training (N-GET). 2) All CECO stat'on employees, including te 3 air and damage control teams, received training on the following topics annually in acdition to N GET: the purpose and scope of the emergency plan, the purpose of event classification, types of classifications, emergency facilities, the purpcse of protective action recommeridations for the off site aublic, protective measures for the onsite worker, and the reasons for exercises and c nils. 3) Those persons with specific Technical Support Center, Operational Support Center, or Control Room responsibilities during an emergc,ncy, received annual job specific training.
Commonwealth Edison acknowledges that the repair and damage control teams did not receive training en the specific objectives issued by Nuclear Services l
Emergency Preparedness (NSEP)in October 1991. The Emergency Preparedness trainer did not update the lesson plans with these specific objectives; therefore the NSEP guidance documents were not fully implemented.
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L COBBEGTIYCEIE P_S_TAKEN AN CLB ESULTS. REC EtVE D The Emergency Preparedness trainer involved has been reassigned. The l
new trainer is aware of the requirement to update lessons plans to reflect changes in the NSEP guidance documents.
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A review of all GSEP training lessen plans is in proqress, This re_ view will identify those lesson plan changes that must be made to refIect the objectives contained in the NSEP guidance documents. The lesson plan review is expected to be completed by March 20,1992. Thos3 lesson plans requiring changes will be revised by I
April 30,1992.
Th9 annual tralning conducted for all CECO station employees has been j
revised to incorporate the cbjectives of module S-1 as described Iri the NSEP guidance document.
1 The annual trainir:g conducted for repair and damage control teams has been revised to incorporate the objectives of module S4 as desenbod in the NSEP guidance document. Tra;ning on these new objectives is expected to be completed by August 31,1992.
COR BEGINEEIE ESlAKEN _TQMQlp.EURTB EBXlouaTION Future changes to GSEP training requirements will be tracked to complellon i
[
usin the trainin department change tracking system. This will ensure that the
.requ roment will e met.
l DATE_WHEliEUkkCOM ELIAN C E_WILLB EAC HIEV E D The repair and damage control team annual training has been revised. Full compliance will be achieved with the com aletion of the training foi-those teams, which is expected to be completed by August 31,1992.
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e VIOLATlON (45G/92002-02) 10 CFR Part 50.54(q) requires that a licensee authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet thu standards in 10 CFR Part 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. The Generating Station Emercency Plan (GSEP), Section 8.5.7, stat 9s that Emergency Plan implementing Procedures and corresponding lesson plans chall be developed consistent with the GSEP within 4 months of any GSiP revision.
Contrary to the above, lesson plans corresponding to the GSEP were not revised within four months of the revision of the GSEP. The GSEP was revised in March 1991, and as of January 1992, relevant lesson plans had not been revised to be consistent with the current GSEP revision.
REASONEOBlhE_VIOLAllON Some of the GSEP lesson plans were revised prior to the issuance of revision 7 of the GSEP manual to include the additional requirements to be imposed by revision
- 7. Af ter revision 7 was issued, cartain requirements of revision G were no longer j
appropriate. The lesson plans were not updated to delete these requirements.
1 Required changes to the training programs were not effectively tracked to completion.
Station procedures wore promptly revied io reflect revien 7 of the GSEP manual. The actual training was conducted using the most current revisions of the station procedures.
CORRECTIVE.SIEPfLTAKEN ANDEESULTS ACHIEVED A review of training lesson plans is in progress. This review will identify lesson plan changes that must be made to reflect the most current revision of the GSEP manual. The lesson plan review is expected to be completed by March 20,1992.
Lesson plans requiring changes are expected to be reviced by April 30,1992.
RO.RBEClLVE_SIEES TAKEN_TORD.lD_EUBIHEB.MOLAllRN I
Upon issuance of revisions to the GSEP manual Nuclear Services Emergency Preparedness (NSEP) issues a letter highlighting that the changes made may require revisions to station procedures and lesson plans within four months in accordance with GSEP Section 8.5. NSEP will continue to request that each Station review the GSEP revision and appropriately revise their station procedures and lesson plans to incorporate necessa y changes.
Braidwood Station will begin tracking the review ar.d updating of lesson plans via the training department change tracking system to ensure the revision process is tracked to completinn.
RATE.WHEN.EULLCOM ELI AN C E_WlLL B E AQ HI EV E ('
Full compliance will be achieved with completion of the revised training lesson plans which is expected to De completed by April 30,1992.
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