ML20029D652

Responds to NRC 940407 Ltr Re Violations Noted in Insp Rept 50-445/94-09 & 50-446/94-09.Corrective Action:Review of Security Plan & Implementing Testing Procedure

ML20029D652
Person / Time
Site:	Comanche Peak
Issue date:	05/05/1994
From:	Woodlan D TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
TXX-94112, NUDOCS 9405090161
Download: ML20029D652 (3)

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't 3 Log # TXX-94112

,,, , File # 10130 1R 94-09 r --

Ref. # 10CFR2.201 1UELECTRIC May 5, 1994 w m n J.c.uu,Jr.

Gwup % o h nident U. S. Nuclear Regulatory Commission Atto: Document Control Desk Washington. DC 20555 SilB 1EC T : COMANCHE PEAR STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. EO-445 AND 50 446 flRC INSPECTION REPORT NOS. 50-445/94-09: 50-446/94-09 RESPONSE TO NOTICE Of VIOLATION GentIemen:

TU Electric has reviewed the flRC's letter of April 7, 1994, concerning the inspection conducted March 7-11, 1994. This inspection was conducted to examine selected areas and activitles associated with the licensee's physical security program.

Enclosed in the April 7, 1994 letter was a Notice of Violation (NOV). This notice identified a violation regarding inadequate testing of detection aids. The attachment provides TV Electric's response to the Notice of Violation 445/94-09-03; 446/94-09-03.

Sincerely, William J. Cahill, Jr.

By: M D. R. Woodlan Docket Licensing Manager N5H:cle Attachment et: Mr. L. J. Callan, Region IV Mr. L. A. Yandell, Region IV Resident inspectors CPSES

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/9 Attachment to TXX-94112 Page 1 of 2 RE$TATEMEt{I_QF V1Ak6U_Qti (445/9409-03: 446/9409-03)

Inadiqwilfe Test inq of Detectten Aif h License Condition 2.H of the Comanche Peak Steam Electric Station Facility Operating License states, in part, 'TU Electric shall fully implement and maintain in effect all provisions of the Physical Security Plan . . .

previously approved by the Cnmmission . .

Paragraph 7.1.1.1 of the Comanche Peak Steam Electric Station's Physical Security Plan requires both the 'E' field and microwave detection systems to '

detect individuals stepping or jumping in or through the microwaves of "E"  !

field sensing wires. Paragraph 13.6 requires operability and performance testing be conducted in accordance with Regulatory Guide 5.44 which requires testing by jumping.

Contrary to the above, the operability and performance testing conducted by '

the security test group did not test the systems by jumping. In addition, the testing procedure did not provide for implementation of the Physical Security Plan requirements.

RESPORSLIA.ItLL1LQLAURN (445/9409-03: 446/9409-03)

TU Flectric accepts the violation and provides the following information as requested:

1. R3 ason for_ Violttign i

The discrepancy between the Plant Security Plan (PSP) and the testing ,

methodology existed as the result of an interpretation of the PSP  !

statement in section 13.6 referencing the " applicable portions of USNRC  !

Regulatory Guide 5.44...." The design of the Intrusion Detection System, to include the Four Wire Stellar E-Field and the Southwest Microwave equipment, is not conducive to safe testing by jumping. Some i of the vertical applications are twelve feet or more. Jumping in ,

accordance with Reg. Guide 5.44 was not considered to be one of the

• applicable portions" of the regulatory guideline, and therefore not addressed in the testing procedure. l

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At tach <nent to TXX-94112 Nge 2 of 2

2. CErgclive Steos Taken and Ptiults Achieved An assessment of the perimeter barriers and intrusion detection system (comprised of cumulative historic reviews, system tests, and perimeter walkdowns) was conducted, and confirmed previous findings that vulnerability to jumping over and/or around the detection equipment is not a concern for the present detection configuration. Therefore, we plan to continue to test the barriers and detection system as described '

in the security procedure (s).

Based on the above assessment T.U, Electric does not believe that an undetected intrusion could be initiated through or around the barrier  ;

and detection system for the protected area perimeter.

3. Corrective Steps Taken to Avoid Rggurrence i

TU Electric has taken the following actions:

i A review of the Security Plan and implementing testing procedure has resultea in the decision to initiate a 50.54 (p) plan change to describe, in detail, the test methods used at this facility for E" Field and microwave detection systems. This change will eliminate the requirement for testing the two systems by jumping.

4. Date of Full Compliance TV Electric is in full compliance with testing of detection aids requirements as required by the Physical Security Plan with the exception of testing the detection system via jumping.

The Physical Security Plan change will be submitted under 50.54 (p) no later than June 15, 1994.

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