ML20138F640
| ML20138F640 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 04/28/1997 |
| From: | Stanley H COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-456-97-04, 50-456-97-4, 50-457-97-04, 50-457-97-4, NUDOCS 9705060019 | |
| Download: ML20138F640 (4) | |
Text
O>mnuinwealth li!non Comp.iny 0
firaidwood Generating Station
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April 28,1997 Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 1
Subject:
Reply to Notice of Violation NRC Inspection Report 50-456(457)/97004 Braidwood Nuclear Power Station Units 1 and 2 NRC Docket Numbers 50-456 and 50-457
Reference:
G. E. Grant letter to H.G. Stanley dated April 8,1997, transmitting i
Notice of Violation from NRC Inspection Report 50-456(457)/97004 During the week of March 3,1997, an Emergency Preparedness (EP) Inspection was conducted. The results from this inspection were documented in the referenced Inspection Report.
Overall, the results from the inspection were positive and indicated that Braidwood's EP program has been efTective. However, a problem was noted related to the Station's failure to document the adequacy of the interface between the State government and the Station. This resulted in a Severity Level IV violation which was transmitted with the Inspection Report.
The concern identified during the audit period was immediately acted upon and an evaluation of the interface between the Station and the State was conducted.
No significant problems were communicated during these discussions.
The following commitment is included in the attached response:
The evaluation of the adequacy of the interface between the State Government and Comed's six nuclear facilities will be included as a permanent audit checklist question in Corporate Emergency Preparedness Audits.
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If your staff has any questions or comments concerning this letter, please refer them to i
Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801, l
extension 2980.
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1 ene Stanley l
ite Vice Presiden i
Braidwood Nuclear Generating Station Attachment f
cc:
A.B. Beach, NRC Regional Administrator, Region III G.F. Dick, Jr., Project Manager, NRR i
i C.J. Phillips, Senior Resident Inspector l
F. Niziolek, Division of Engineering, Oflice of Nuclear Safety, IDNS I
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ATTACilMENT I t
REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(4571/97004-01) 10 CFR 50.54(t) requires that the 12 month review of the emergency preparedness program shall include an evaluation for adequacy of interfaces with State and local governments and oflicensee drills, exercises, capabilities, and procedures. The results of the review, along with recommendations for improvements, shall be documented, reported to the licensee's corporate and plant management, and retained for a period of five years.
Contrary to the above, Site Quality Verification Audit Report QAA-#20-96-05,
" Emergency Plan and Implementing Procedures," dated March 22,1996, the 12 month review of the emergency preparedness program did not include an evaluation of the adequacy ofinterface with the State ofIllinois. (50-456/97004-01 and 50-457/97004-01)
REASON FOR THE VIOLATION A documented evaluation of the adequacy of the interfaces between the State Government and Braidwood Station was not done in the required twelve month time frame. Several opportunities to document this interface were missed during that time period, including two audits of the Emergency Preparedness (EP) Program. Observations made were either not documented or the documentation did not reflect an evaluation of the interface.
i During a Corporate Audit of the Emergency Preparedness Program, QAA # CE 96-03, the audit team was aware of the requirement to evaluate the interface between State and local governments and the nuclear facilities, however the team made a conscious decision not to include this requirement in the audit scope because they believed this review would be redundant. The audit team felt that each site satisfied this requirement in their site EP Audits.
The audit scope for the Braidwood's Site Quality Verification Audit QAA # 20-96-05,
" Emergency Plan and Implementing Procedures," included a review of the adequacy of interfaces with off-site agencies. The audit team's audit preparation notes referenced the wording from 10CFR 50.54(t) to evaluate the adequacy of the interface between the Station and State and local governments. However, when the audit checklist question and method of verification (steps the auditor is to take to answer an audit checklist question) for this requirement were written, the full scope of the regulatory requirement was not reflected in the method of verification. The requirement to evaluate the interface between the Station and State and local governments was replaced with evaluating the adequacy of the interface between the Station and a sample of off-site agencies.
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ATTACilMENT 1 o
- i REPLY TO NOTICE OF VIOLATION VIOLATION (50-456(457)/97004-01)
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED Representatives from the Illinois Department of Nuclear Safety (IDNS) and the Illinois Emergency Management Agency (IEMA) were called on March 6,1997. Individuals from these agencies were asked questions taken from a questionnaire used during the site audit to evaluate the adequacy of the interface between the Station and the State and local governments.
No significant interface concerns were discussed during the phone intersiews.
ACTIONS TO PREVENT RECURRENCE A discussion was held with the Audit Team Leader from the Corporate Audit Group to determine appropriate corrective actions to prevent recurrence. It was decided that the evaluation of the adequacy of the interface between the State Government and Comed's six nuclear facilities would be included as a permanent audit checklist question in Corporate Emergency Preparedness Audits. A letter was sent to the Corporate Audit Group to document the agreeinent made during the earlier discussion. This letter will be placed in the audit preparation file at Corporate Nuclear Oversight. Each site remains i
responsible for assessing the adequacy of the interface between the station and local governments.
A tailgate was conducted with Site Quality Verification personnel regarding the importance of documentation, including stating regulatory requirements in audit checklist questions and in Field Monitoring Reports.
DATE WHEN COMPLIANCE WAS ACHIEVED Compliance was achieved once the adequacy of the interface between Braidwood Station and the State government was determined to be acceptable and this information was properly documented.
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