IR 05000445/1997017

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/97-17 & 50-446/97-17
ML20212B637
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 10/22/1997
From: Tapia J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Terry C
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
50-445-97-17, 50-446-97-17, NUDOCS 9710280159
Download: ML20212B637 (4)


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SUBJECT:

NRC INSPECTION REPORT 50 445/97 17;50 4'//97 17

Dear Mr. Terry:

Thank you for your letter of October 17,1997, in response to our letter and Notice of Violation dated Septernber 19,1997. We have reviewed your reply and find it resporsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actlans during a future inspection to determine that full compliance h::a been achieved and will be malotained.

Sincerely, osep 1. Tapia, Chief Project Branch A Olvision of Reactor Projects Docket Nos.: 50-445 50 446 License Nos.: NPF 87

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NPF 89 I

cc:

Mr. Roger D. Walker TU Electric Regulatory Affairs Manager P.O. Box 1002 Glen Rose, Texas 7t1043

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TU Electric-2-s Juanita Ellis President. CASE 1426 South Polk Street Dallas, Texas 75224 rU Electric Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814

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George L. Edgar, Esq.

Morgan, Lewis & Bocklus 1800 M. Street, NW Washington, D.C. 20036 G. R. Bynog, Program Manager /

Chief Inspector Texas Department of '.lconsina & Regulation

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Boiler Division

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P.O. Box 12157, Capitol Station Austin, Texas 78711 Honorable Dale McPherson County Judge P.O. Dox 851 Glen Rose, Texas 76043 Texas Radittlon Control Program Director

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1100 West 49th Street Austin, Texas 78756 John Howard, Director Environmental and Natural Resourcas l'olicy

Office of the Governor P.O. Box 12428

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Austin, Texas 78711

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TU Electric 3-OCT 2 21997 bcc to DCD (IE01)

bec distrib. by RIV:

Regional Administrator Resident inspector (2)

DRP Director DRS-PSB Branch Chief (DRP/A)

MIS System t

Project Engineer (DRP/A)

RIV File Branch Chief (DRP/TSS)

i DOCUMENT NAME: R:\\_CPSES\\CP717AK.HAF To receivs copy of document. Indicate in box: "C" = Copy wthout enclosures "E" = Copy with enclosures "N" = No copy RIV:PE:DRP/A

_, y/ f DRP/h RAKopriva;dif yP JITapia MSj 10cz /97 10/3 ff97i MFICIAL RECORD COPY i

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o-e TU Electdc-3-OCT 2 21997 bog W d 'OE01 Tiff)

bec distrib. by RIV:

Regional Administrator Resident inspector (2)

DRP Director DRS-PSB Branch Chief (DRP/A)

MIS System Project Engineer (DRP/A)

RIV File Branch Chief (DRPfrSS)

DOCUMENT NAME: R:\\_CPSES\\CP717AK.HAF To tnive copy of docurwnt, ladicate in box: "C" = Copy without enclosures "E" = Copy with endosures "N" = Na copy E.:i)E:DRP/A

, pf.C:DRP/Q RAKopriva;dit pF' JITapia W.j 10dL/97 10/3ff97

@FICIAL fifCDITD COPY

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Log.# TXXi97217

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IR 97-17 nlELECTRIC'

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October 17, 1997 i

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U; S. Nuclear Regulatory Commission Attn: -Document Control Desk Washington. D.C.

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SUBJECT:

COMANCHE PEAK' STEAM ELECTRIC STATION (CPSES)

DOCKET N05. 50 445 AND 50-446-NRC INSPECTION REPORT NOS, 50-445/97-17: 50-446/97-17 RESPONSE TO NOTICE OF VIOLATION

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Gentlemen:

TV Electric has reviewed the NRC Inspection Report and attached Notice of Violation dated _ September 19. 1997, concerning the inspection conducted by G. E. Werner. Acting Senior Resident insper. tor. H. A. Freeman Resident

. Inspector. R. L. Nease. Technical Assistant. Division of Reactor Projects.

W. C, Sifre. Resident Inspector. South Texas Project and W. J. Wagner.

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~ Reactor Inspector. Division of Reactor Safety during the period of July 20 through August 30, 1997. This letter responds to part C_of the Notice of

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Violation related to the Physical Security Plan Parts A and B will be responded to separately in TXX-97220.

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>r The Notice of Violation part C describes a'fa11ure to follow Security Plan

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requirements used to ensure adequate lighting of structures. The

.information provided herein, does not contains Safeguards Information as r

defined in 10CFR73.21. TV Electric's response is attached.

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P. O. Box 1002 Glen Rose Texas 76M3 0...7 lO200/ 7V-L

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t 7XX 97217 Page 2 of 2 This communication contains no new licensing basis coaaitments regarding CPSES Units 1 and 2.

Please do not hesitate to contact Neil Harris at (254) 897-5449 to coordinate any additional information you may need to facilitate closure of this issue.

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Attachment cc: Mr. Ellis W. Merschoff, Region IV Mr. Joe Tapia, Region IV Resident Inspecto-s

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-Attachment 1-to TXX 97217-

- Page 1 of: 3 :_

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t RESTATEMENT OF THE NOTICE OF VIOLA 110H (50 445/97 17: 50 446/97 17)

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Duringaan NRC~ inspection conducted on July 20 through August 30.1997 : ones

violation of NRC. requirements for security requirements was identified:

-(violation 'C')..

In-accordance with the " General Statement of-Policy and Procedure for-NRC Enforcement Actions." (NUREG-1600), the violation-1s

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. restated below:

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. License Condition 2.H requires the licensee-to fully implement and maintain in effect all provisions of the physical security plan, Physical Security'

' Plan., Revision 27. Section 7.1.3 " Illumination." required at least 0.2

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foot candles of light in the protected area as measured on horizontal ground.

The inspectors determined that the failure to ensure the protected-area is adequately illuminated is a violation of License Condition 2.H (Violation 445(446)/9717 06).

- Contrary to the above, on August 27, 1997, while performing a walkdown of outside spaces within the protected area to verify adequate illumination.

the areas under two trailers and under a vending truck located within-the protected area were not illuminated to at least 0,2 foot-candles.

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During the walkdown of outside spaces located within the protected area.

1the inspectors identified that the undersides;of two material storage

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trailers and a vending-truck appeared to have inadequate lighting.

Security officers in the-secondary alarm station were informed of this concern:and officers were stationed at-the suspect locations.

Measurements-identified that lighting conditions were less than the 0.2 foct-candles required by the Physical Security Plan.

The actual readings were 0.121.

0.116, and 0.133 foot-candles.

The inspectors identified a violation of illumination requirements within the protected area.

Security personnel responded immediately and installed tempora ry - lighting.

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Attachment 1LtoTXX97217L

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Page:2of3

4 REPLY TO NOTICE OF VIOLATIQH (50 445/97 17; 50 446/97 17)

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TU Electric accepts the viciation. An evaluation of the condition concluded that there was no decrease the effectiveness of the security program and did not result-in any uncontrolled-or undetected = access to the

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Protected Area (PA).or Vital Areas (VA), However, the violation is correct

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in that-3. trailers / vehicles lighting ~ levels did not comply with the security plan requirements. The adherence to security plan requirements for these evolutions were.not in accordance with TV Electric's expectations

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and is considered a unacceptable practice.

The information requested is provided as follows:

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Reason for the Violation The trailers identified in the violation were moved to the location south of the maintenance area during the late afternoon on August 27, 1997. Lighting consideration was overlooked by the crews moving the trailers.

A routine pre-dusk walkdown of the protected area by Security failed to identify the )otential need for compensatory lighting.

The evening walkdown )y Security also failed to identify -

a the deficiency.

The vendor vehicle noted is a licensee designated vehicle (LDV) that routinely parks in the same location daily. ~The lignt normally relied upon to illuminate-under this vehicle was out-

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of-service. The routine walkdownr referenced:above also failed to-identify the deficient conditions, b

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Corrective Steps Taken and Results Achieved

= Compensatory officers were initially posted in both areas until

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' temporary lighting could be placed. After lighting was in place, each of the affected areas were measured for illumination levels to (;.

ensure adequate lighting. The inoperative light for the LDV was returned to service, which provided the required illumination for the

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vehicle. Security personnel initiated Security Field Report 0720-97-

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to document the discrepancy.

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-Corrective Steps Taken_to Avoid Further Violation-

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I The lighting survey procesps have been modified to use calibrated

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light meters to. assure luminance in accordance witt Security Plan.

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L requirements if questionable areas of light intensity are identified.

<The surveys will continue to be annotated in the patrol journals.

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Attachment 1 to TXX 97217-Page 3 of 3 3.

- Corrective Steps Taken to Avoid Further Violation (cont.)

Additional light surveys may be conducted per the direction of the Security Shift Supervisor if deemed _ necessary.

The Security staff has been sensitized to the cause of, and corrective actions.for this notice of violation.

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Date of Full Compliance TV Electric is in full compliance at this time. '

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