ML20094N584
| ML20094N584 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 03/30/1992 |
| From: | Kovach T COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9204070019 | |
| Download: ML20094N584 (5) | |
Text
_
Commonwealth Edison 1400 Opus Ple::o Downers Grove, lilmois 60515
\\
March 30, 1992 U.S. Nuclear Regulatory Ccomission Washington, D. C.
20555 Attn:
Document Control Desk
Subject:
Braidwood Nuclear Power Station Units 1 and 2 Supplemental Response to Notice of Violation Associated with Inspection Report 50-456/92002; 50-457/92002 HRC Docket Numbers 50-456 and 50-457
References:
(a)
L., R. Gi eger 1 t tr.
o Cordell Reed dated February 7, 19.' n mittu.9 4RC Inspection Report 50-456/92002, 50-45'//92002 (b)
J. Kovach letter to USNRC dated March 6, 1992 iransmitting initial respont to NRC Inspection Repoit 50-456/92002; 50-457/92002 Enclosed is a Commonwealth Edison Company (CECO) supplemental response to the Notice of Violation (NOV) transmitted by the Reference (a) report.
The attached response provides clarification on the reasons for the identified violations and specifias additional interim actions taken. The attached response supercedes and reploces the Reference (b) response.
If there are any questicAs or comments regarding this response, please contact Perry Barnes, Cc>npliance Supervisor, at 708/515-7278.
Sincerely, h.
b F&
T. J. Kovach Nuclear Licensing Manager Attachment cc:
A Bert Davis, Regional Administrator - Region III R. M. Pulsifer, Project Manager, NRR S. Dupont, Senior Resident inspector 9 dodo'7boh 920330 yg_ g PDR ADOCK 0500 6
oi
AITACHMENLA RESPONSE 10 N0ilCE Of V10tATION INSRCJ ION _REPORL450 / 92002 LA 5U 92002 MOLAT10U456L92002-0D 10 CFR Part 50.54(g) requires that a license authorized to possess and operate a nuclear power reactor shall follow and maintain in effect emergency plans which meet the standards in 10 CFR Part 50.47(b) and the requirements of Appendix E to 10 CFR Part 50. fppendix E states that the emergency plan will provide a description of the specialized tialning which emergency response personnel assigned to repnir and damage control teams will receive.
The GSEP, Section 8.2.1, states that emergency response personnel assigned to repair and damage control teams will perform emergency response activities as an extension of their normal duties and will be trained each year as part of their duty specific training.
Contrary to the above, emergency response personnel assigned to repair and damage control teams did not receive specialized emergency preparedness training, relevant to their role in the emorgency response organization, each year as part of their duty specific training.
REASOLEQUllL110LAll0N Commonwealth Edison agrees that the specialized training provided was not fully adequate.
The process in place to implement lesson plan changes was not effective in that no administrative tracking tool was used.
The process relied on the Emergency Preparedness (EP) Trainer to identify and implement the necessary changes.
In early 1990, Nuclear Services Emergency Preparedness (NSEP) identified the need to streamline, standardize, and focus emergency response training at the stations.
Development of a new training system was initiated to include three major elements: (1) a standardized matrix of EP instruction nodules versus director assignments; (2) minimum Technical Knowledge Objectives (TK0s); and (3) Corporate policies for implementation of EP training at the stations.
Guidance was provided to the stations, which addressed a set of i
recommended TK0s for personnel assigned to emargency repair and damage control teams.
Braidwood had not fully incorporated these recommended objectives into the appropriate lesson plans.
2 i
1
Specialized emergency preparedness training for personnel assigned to emergency repair and damage control teams was provided through (1) annual job specift training, (2) Nuclear General Employee Training and (3) Annual Statior Training.
However, it did not include all TK0s
-included in NSEP t' 11 dance Recommendation EPGR-TR-0201 Module S-3.
CORRECILVE_ SIEES_I6KE R_ AND_ RE SULIS _ACHI EVED A review of all EP training lesson plans to identify where additional information needs to be provided has been completed.
This review identified those lesson plan changes that must be made to reflect the TL0s contained in Guidance Recommendation EPGR-TR-0201.
Lesson plan changes are expected to befcompleted by April 30, 1992.
The annual training conducted for repair and damage control teams has been revised to incorporate-the TK0s of EPGR-TR-0201 Module S-3.
Approximately 118 of 283 personnel have completed annual training with the updated technical knowledge objectives.
Training for the remaining personnel has been accelerated and is expected to be completed uy August 31, 1992.
As an interim measure, pending completion of acceleraten annual training, tailgate training has been provided to appropriate work groups covering the Module S-3 TK0s.
CORRECI1YLSIEP_S_I6KE_N TO AVQLD_LURUiEfLylOL&lLO11 Braidwood Station will b991n tracking the review and updating of GSEP training lesson plans using the normal Training Department change tracking system.
This_will ensure the revision process and schedule is administratively tracked to completion.
DME3REfLEULLC0tLP11ANCE HILLEEERIEVED Full compilance will be achieved with the completion of the accelerated training for personnel assigned to emergency repair and damage l-control teams, which is expected by August 31, 1992.
l 3
t YI0lAUQU45GL92002-92D 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 pihns which meet the standards in 10 CFR Part 50.47(b) and the requirements of Appendix E to 10 CFR Part 50.
The Generating Station.!mergency Plan (GSEP), Section 8.5.7, states that Emergency Plan Implementing Procedures and corresponding lesson plans shall be developed consistent with the GSEP within 4 months of any GSEP 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.
REASOLEQLIliLVIOLATIDN:
Commonwealth Edison acknowledges the violation.
The process in place to implement lesson plan changes was not effective.
In particular, no administrative tracking tool was used for lesson plan changes.
The process relied on the Emergency Preparedness (EP) Trainer to identify and implement the necessary changes.
A contributor was tha EP Trainer's unfamiliarity with a requirement,-implemented in Sectior. 8.5 of GSEP Revision 7,-to ensure-that lesson plans are developed consistent with the GSEP within 4 months of any GSEP revision.
The training which was provided to station emergency response personnel whose actions are directed by Emergency Plan Implementing Procedures (EPIPs), including Director level positions, was consistent with GSEP Revision 7.
The training provided these individuals was based on and used position-specific EPIPs which had been updated to GSEP Revision 7.
Therefore, the actions of those individuals whose training ws.s in question.would have been directed by Directors whose training was consistent with GSEP Revision 7.
CORR ECIly LSJE P SJAKDLMDJES'JLISlCllI EYED A review of the GSEP training lesson plans to identify where revisions need to be made to bring them into agreement with GSEP Revision 7 has been completed.
Lesson plans which require revision have been identified and appropriate changes are being implemented.
Revisions are expected to be completed by April 39. 1992.
t 4
9 V
CORRECTIVLSTEPLIAKELIO AVOID _ f.URTHER _ VIOLATION Braidwood Station will begin tracking the review and updating of GSEP training lesson plans using the normal Training Department change tracking system.
This will ensure the revision process and schedule is administratively tracked to completion.
Upon issuance of revisions to the GSEP Manual, Nuclear Services Emergency Preparedness (NSEP) will issue e letter highlighting the need to complete changes to station procedures and lesson plans within four nonths in accordance with GSEP Section 8.5.
The issuance of this letter will be included as part of an administrative procedure which is under development by NSEP to provide guidance for the control of GSEP and GSEP Annex revisions (CEPIP 100-04).
The pre:edure is expected to be completed by April 30, 1992.
DAT E AtDL IU LLCOME L I ANCE JI LL B L ACH I E V ED full compliance will be achieved with completion of the revision of the GSEP training lesson plans which is expected by April 30, 1992.
5
-