ML20141K425
| ML20141K425 | |
| Person / Time | |
|---|---|
| Site: | Braidwood  |
| Issue date: | 05/21/1997 |
| From: | Pederson C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Stanley H COMMONWEALTH EDISON CO. |
| References | |
| 50-456-97-04, 50-456-97-4, 50-457-97-04, 50-457-97-4, NUDOCS 9705290104 | |
| Download: ML20141K425 (2) | |
See also: IR 05000456/1997001
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May 21, 1997
Mr. H. G. Stanley
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Site Vice President
Braidwood Station
Commonwealth Edison Company
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R.R. #1, Box 84
Braceville,IL 60407
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SUBJECT:
NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-456/97004(DRS);
50-457/97004(DRS))
Dear Mr. Stanley:
This will acknowledge receipt of your letter dated April 28,1997, in response to
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our letter dated April 8,1997, transmitting a Notica of Violation associated with the failure
to evaluate, document, and report to corporate and plant management the adequacy of
interface with the State government. We have reviewed your corrective actions and have
no further questions at this time. These corrective actions will be examined during future
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inspections.
Sincerely,
/s/ Cynthia D. Pederson
Cynthia D. Pederson, Director
Division of Reactor Safety
Docket Nos. 50-456; 50-457
Enclosure:
Ltr dtd 4/28/97 H. G. Stanley
Braidwood to USNRC
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See Attached Distribution
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DOCUMENT NAME: G:DRS\\ BRA 97004.DRS
To receive a copy of this document, indicate in the box: "C" = Copy without
attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy =o
0FFICE
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05/J /97
0FFICIAL RECORD COPY
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9705290104 970521
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ADOCK 05000456
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H. G. Stanley
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May 21,1997
cc w/o enci: T. J. Maiman, Senior Vice President,
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Nuclear Operations Division
D. A. Sager, Vice President,
Generation Support
H. W. Keiser, Chief Nuclear
Operating Officer
T. Tulon, Station Manager
T. Simpken, Regulatory Assurance
Supervisor
1. Johnson, Acting Nuclear
Regulatory Services Manager
Document Control Desk - Licensing
cc w/ encl:
Richard Hubbard
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Nathan Schloss, Economist,
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Office of the Attorney General
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State Liaison Officer
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Chairman, Illinois Commerce Commission
Distribution:
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Docket File w/ encl
Rlli PRR w/enci
J. L. Caldwell, Rllt w/enci
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PUBLIC IE-35 w/ encl
SRis, Braidwood, Byron,
Rill Enf. Coordinator w/ encl
OC/LFDCB w/enci
Zion w/enct
R. A. Capra, NRR w/enci
DRP w/enci
LPM, NRR w/enci
TSS w/enci
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DRS w/enci
CAA1 w/ encl
A. B. Beach, Rlli w/ encl
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Commonwealth liimn Compan)
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April 28,1997
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Document Control Desk
U.S. Nuclear Regulatory Commission
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Washington, D.C. 20555
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Subject:
Reply to Notice of Violation
NRC Inspection Report 50-456(457)/97004
Braidwood Nuclear Power Station Units I and 2
NRC Docket Numbers 50-456 and 50-457
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Reference:
G. E. Grant letter to H.G. Stanley dated April 8,1997, transmitting
Notice of Violation from NRC Inspectian Repon 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
Repon.
Overall, the results from the inspection were positive and indicated that
Braidwood's EP program has been effective. 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.
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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
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Comed's six nuclear facilities will be included as a permanent audit checklist question
in Corporate Emergency Preparedness Audits.
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Document Control Desk
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Page 2
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If your staff has any questions or comments concerning this letter, please refer them to
Terrence Simpkin, Braidwood Regulatory Assurance Supervisor, at (815) 458-2801,
extension 2980.
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ene Stanley
ite Vice Presiden
Braidwood Nuclear Generating Station
Attachment
A.B. Beach, NRC Regional Administrator, Region III
cc:
G.F. Dick, Jr., Project Manager, NRR
C.J. Phillips, Senior Resident Inspector
F. Niziolek, Division ofEngineering, Office of Nuclear Safety, IDNS
c:confidsitevysortesp l 99797039 Ax
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ATTACHMENT 1
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REPLY TO NOTICE OF VIOLATION
VIOLATION (50-456(457)/97nn44 Q
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
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governments and oflicensee drills, exercises, capabilities, and procedures. The results of
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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 resiew 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)
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REASON FOR THE VIOLATION
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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.
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
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be redundant. The audit team felt that each site satisfied this requirement in their site EP
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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
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wording from 10CFR 50.54(t) to evaluate the adequacy of the interface between the
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Station and State and local governments. However, when the audit checklist question and
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method of verification (steps the auditor is to take to answer an audit checklist question)
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for this requirement were written, the full scope of the regulatory requirement was not
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reflected in the method of verification. The requirement to evaluate the interface between
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the Station and State and local governments was replaced with evaluating the adequacy of
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the interface between the Station and a sample of off-site agencies.
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ATTACHMENT 1
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REPLY TO NOTICE OF VIOLATION
VIOL ATION (50-456(457)/97004-01)
CORRECTIVE ACTIONS TAKEN AND RESULTS ACHIEVED
Representatives from the Illinois Department of Nuclear Safety (IDNS) and the Illinois
Emergency hianagement Agency (IEh1A) were called on hiarch 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
interviews.
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ACTIONS TO PREVENT RECURRENCE
A discussion was held with the Audit Team Leader from the Corporate Audit Group to
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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
a.= a permanent audit checklist question in
Corporate Emergency Preparedness Audits. A letter was sent to the Corporate Audit
Group to document the agreement made during the earlier discussion. This letter will be
placed in the audit preparation file at Corporate Nuclear Oversight. Each site remains
responsible for assessing the adequacy of the interface between the station and local
governments.
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A tailgate was conducted with Site Quality Verification personnel regarding the
importance of documentation, including stating regulatory requirements in audit checklist
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questions and in Field hionitoring Reports.
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DATE WHEN COMPLIANCE WAS ACHIEVED
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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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