View source for A97004, Responds to NRC Re Violations Noted in Insp Repts 50-295/97-08 & 50-304/97-08.Corrective Actions:Will Develop Standard Method of Verification for Audits Prior to Next Performance of Each Audit

{{Adams
| number = ML20148F191
| issue date = 05/29/1997
| title = Responds to NRC Re Violations Noted in Insp Repts 50-295/97-08 & 50-304/97-08.Corrective Actions:Will Develop Standard Method of Verification for Audits Prior to Next Performance of Each Audit
| author name = Mueller J
| author affiliation = COMMONWEALTH EDISON CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000295, 05000304
| license number = 
| contact person = 
| document report number = 50-295-97-08, 50-295-97-8, 50-304-97-08, 50-304-97-8, ZRA97004, NUDOCS 9706040144
| title reference date = 04-30-1997
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

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COI11Ed                    i ZRA97004
          - May 29,1997                                                                                             ,
U. S. Nuclear Regulatory Commission Washington, DC 20555 Attention:         Document Control Desk                                                                l

==Subject:==
Commonwealth Edison Reply to Notice of Violation in NRC Inspection Report            I Number 50-295/304-97008; Zion Nuclear Power Station Units 1 and 2; NRC Docket Numbers 50-295 and 50-304

==Reference:==
Letter to J. H. Mueller (Comed) from G. E. Grant (USNRC) dated April 30, 1997, NRC Inspection Repost 50-295/97008, 50-304/97008 and Notice of Violation Gentlemen:
By {{letter dated|date=April 30, 1997|text=letter dated April 30, 1997}}, the NRC cited Commonwealth Edison (Comed) as being in violation of regulatory requirements. This letter and its attachment .i nstitute Comed's reply to       ;
the referenced Notice of Violation in accordance with applicable regulations.
Attachment A to this letter provides the reasons for the violation, the corrective actions taken,       i and the date when full compliance was achieved.
I affirm that the content of this transmittal is true and correct to the best of my knowledge, information and belief. In some instances these statements are not based on my personnel knowledge, but on information furnished by other Comed employees, contract employees and consultants. Such information has been reviewed in accordance with company practices, and I believe it to be correct.
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;                          Should you.have any questions concerning this response, please contact Robert Godley of my                             i
.                        . staff at 847-746-2084 extension 2900.                                                                                  ;
i                          Sincerely,                                                                                                             ;
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2                          J. H. Mueller                                                                                                           !
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                         - Site Vice President-Zion Nuclear Station l
i Subscribed anq sworn to before me, a Nothry Public in and for the State of udiu n U and County of fa3L                             .this 8 9 5    day
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of YMao_                    .1997 Notary Public MA                     i D         '0FFICIAL SEAL"         c                                                   !
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* THERESAI.SIAY-               l                                                    l 0 Notary Public, State ofIllinois j                                              ,     i l[My Commission Expires 7/13/99
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j Attachment
                          ;cc:.      Regional Administrator, USNRC - Region III Senior Project Manager, USNRC - NRR Project Directorate III-2 Senior Resident Inspector, Zion Nuclear Station                                                              i Office of Nuclear Facility Safety - IDNS                                                                       !

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l          ATTACHMENT A to ZRA97004 l          Page 1 of 2 .
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Reniv To Notice Of Violation VIOLATION: 50-295(304)/97008-03 10 CFR 50.54(t), requires inpart, that the annual review of the EPprogram shallinclude .    ,
an evaluation for adequacy of interfaces with State and local governments and of            '
licensee drills, exercises, capabilities, andprocedures.
Contrary to the above, annual reviews of the Emergency Preparednessprogram, containedin Site Quality Verification Audit QAA 22-95 04, " Generating Station Emergency Plan, " datedJuly 28,1995, and Site Quality Verspcation Audit QAA 22            08, " Audit of Generating Station Emergency Plan (GSEP), " datedJuly 25,1996, did not address the adequacy of the offsite interface with the State ofIllinois.
bDMISSION OR DENIAL TO TIIE VIOLATION Comed admits the violation.
REASON FOR THE VIOLATION The reason for the violation was there was no clearly established standard method of verification to ensure correct and consistent translation of the applicable requirements used to develop the SQV Audit. The process allowed each !ead auditor to develop audit questions based on his/her interpretation of the applicable requirements. Approval was then obtained from the Audit Supervisor. This resulted in the requirement to evaluate the interface between the station and state and local governments being incorrectly interpreted and replaced with; verifying the adequacy of the interface between the station and a sample of off-site agencies.                                                                l CORRECTIVE ACTIONS TAKEN AND RESULTS ACIHEVED A review of the GSEP Manual was conducted to identify a comprehensive list of state and local governments which need to be contacted by Zion Station to fulfill the requirement.
The appropriate agencies were contacted and the interfaces were evaluated as adequate.
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* ATTACHMENT A13 ZRA97004 Page 2 of 2 r
            '  Int'rviews e        of Illinois Department of Nuclear Safety (IDNS) and Illinois Emergency Management Agency (IEMA) were conducted by Braidwood SQV on March 6,1997.
l             This interview was conducted to assess the adequacy of the interface with the State of        ;
lilinois and all Comed Nuclear Stations. Zion SQV reviewed the Braidwood interview.
No deficiencies were identified.
l             Zion SQV conducted telephone interviews with the State of Wisconsin on March 25,1997 to assess the adequacy of the interface with the agencies of that state. No deficiencies were identified during that ir,terview.
;             A staff meeting was conducted with SQV personnel regarding the circumstances                  !
l             surrounding this event and the importance of documentation, including stating regulatory
* l             requirements m audit checkhst questions.
The Zion SQV Annual Audit Schedule and Lead Auditor Guidelines for all Zion SQV               l audits were revised to ir:clude specific instructions for ensuring state and local government i agencies are contacted.
The adequacy of the interface between the state and county governments and Comed's six i                                                                                                           '
nuclear facilities has been included as a permanent audit checklist question in Corporate Emergency Preparednes s Audits.
!             CORRECTIVE ACTlONS TO BE TAKEN TO AVOID FURTHER VIOLATIONS l             Zion SQV will develop a standard method of verification for audits prior to the next j             performance of each audit.                                                                     i I                                                                                                            j DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED                                                    l I
l             Zion Station is currently in full compliance.                                                  ,
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1 ATTACHMENT B to ZRA97004                                                                     !
Page1ofI List of Commitments Identified in this Violation Response The following table identifies those actions committed to by Comed in this document.
1 Any other actions discussed is this submittal represent intended or planned actions by       t Comed. They are described to the NRC for the NRC's information and are not regulatory        ;
commitments. Please notify Mr. Robert Godley, Zion Station Reguistory Assurance              l Manager, of any questions regarding this document or any associated regulatory               l commitments.                                                                                 }
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Commit.nent                                                              Committed Date      !
or Outage       '
Zion SQV will develop a standard method ofverification for audits prior  Prior to each audit to the next performance of eac'.i audit.                                    performance k
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