ML20056C137

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/92-50 & 50-446/92-50 on 921022-1218
ML20056C137
Person / Time
Site: Comanche Peak  Luminant icon.png
Issue date: 03/16/1993
From: Callan L
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: William Cahill
TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
References
NUDOCS 9303300141
Download: ML20056C137 (4)


See also: IR 05000445/1992050

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NUCLEAR REGULM ORY COMMISSION

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Dockets:

50-445

50-446

License: NPF-87

NPF-88

TU Electric

ATTN:

W. J. Cahill, Jr., Group Vice President

Nuci ar Engineering and Operations

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Skyway Tower

400 North Olive Street, L.B. 81

Dallas, Texas 75201

SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-445/92-50; 50-446/92-50

Thank you for your lettei of February 18, 1993, in response to our letter and

Notice of Violation dated January 20,

993. We have reviewed your reply and

find it responsive to the concerns raised in our Notice of Violation. We will

review the implementation of your corrective actions during a future

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inspection to determine that full compliance has been achieved and will be

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maintained.

Sincerely,

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L. J. Ca lan, Director

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Divisiip of Radiation Safety

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TU Electric

ATTN:

Roger D. Walker, Manager of

Regulatory Affairs for Nuclear

Engineering Organization

Skyway Tower

400 North Olive Street, L.B. 81

Dallas, Texas 75201

9303300141 930316

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Bethesda Licensing

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Jorden, Schulte, and Burchette

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ATTN: William A. Burchette, Esq.

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Newman & Holtzinger, P.C.

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Washington, D.C.

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Texas Department of Licensing & Regulation

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G. R. Bynog, Program Manager /

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Chief Inspector

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Boiler Division

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P.O. Box 12157, Capitol Station

Austin, Texas 78711

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Honorable Dale McPherson

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Texas Radiation Control Program Director

1100 West.49th Street

Austin, Texas 78756

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  1. TXX-93092

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File # 10130

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IR 92-50

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Ref.

  1. 10CFR2.201

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February 18, 1993

Cremp Vwe Pressdent

U. S. Nuclear Regulatory Commission

Attn:

Document Control Desk

Washington, DC 20555

SUBJECT:

COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)

DOCKET NOS. 50-445 AND 50-446

NRC INSPECTION REPORT NO. 50-445/9250; 50-446/9250

RESPONSE TO NOTICE OF VIOLATION

REF:

TU Electric letter looged TXX-93088 from

W. J. Cahill, Jr., to NRC dated February 10, 1993

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Gentlemen:

TU Electric has reviewed the NRC's letter dated January 20, 1993, concerning

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the inspection period of October 22 through December 18, 1992. This

inspection covered activities authorized by the NRC operating license

NPF-87 and construction permit CPPR-127.

Attached to the January 20, 1993,

letter was a Notice of Violation (NOV).

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TU Electric hereby responds to the Notice of Violation (445/9250-04) in the

attachment to this letter.

Sincerely,

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William J. Cahill, Jr.

NSH/tg

Attachment

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Mr. J. L. Milhoan, Region IV

Mr. L. A. Yandell, Region IV

Mr. B. E. Holian, NRR

Mr. T. A. Bergman, NRR

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Resident Inspectors, CPSES (2)

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400N.Ouve Street LB.81 Danas. Texas 75201

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Attacnment to TXX-93092

Page 1 of 2

NOTICE OF VIOLATION

(445/9250-04)

(446/9250-04)

License Condition 2.H of the CPSES, Unit 1, 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

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the Commission

. .

Paragraph 3.1 of the licensee's Physical Security Plan states, in part,

"CPSES has established and maintains an access authorization program with

the oDjective of providing high assurance that the individuals granted

unescorted access to the Protected and Vital Areas are trustworthy and

reliable and do not pose a threat to commit radiological sabotage.

In order

to evaluate eligibility and support the above requirements, the access

authorization program complies with the following: 10 CFR 73.56 Regulatory

Guide 5.66, and 10 CFR 26."

10 CFR 26.22(a)(4) and 73.56(b)(2)(1) require, in part, that licensees train

supervisory personnel in behavioral observation techniques for detecting

degracation of performance, impairment, and changes in employee behavior

w h i r.h . if left unattenced, could lead to acts detrimental to public health

and safety.

Licensee Procedure STA-910, paragraph 6.1.1, states that all TU and

contractor employee supervisors shall receive initial and annual recurring

training in benavioral observation.

Contrary to the above, on October 27, 1992, it was determined that 20

contractor supervisors had not received initial behavior observation

training and that 21 contractor supervisors had not received annual

recurring behavior observation training,

RESPONSE TO ROTICE OF VIOLATION

(445/9250-04)

(446/9250-04)

TU Electric accepts the violation and the requested information follows:

1.

Peason for the Violatiqn

A review of procedures, associated records and the relevant computer

data base was performed by TU Electric.

This review concluded that

anomalies in the computer coding caused some supervisors who had

received initial behavior observation training to be dropped from annual

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Attachment to TXX-93092

Page 2 of 2

4

requalification training. Additionally, the rapid management changes in

the Unit 2 organizations which were a result of destaffing as Unit 2

construction completion was achieved, contributed to this condition.

2.

Corrective Steos Taken and Results Achieved

Upon discovery of these issues a deficiency document was issued to

document the cause and corrective actions.

Additionally, TU Electric

has conducted special training sessions for the supervisors and managers

(including foremen and general foremen), who had not previously received

behavioral observation training and/or who had not received

requalification training.

3.

Corrective Steos Taken to Avoid Recurrence

TV Electric management issued an instructional directive stressing the-

need to comply with procedural guidance regarding behavioral observation

training and requalification.

Moreover, referenced letter to the NRC provided detail of management

actions regarding Fitness for Outy.

4.

Date When Full Compliance Will be Achieved

TU Electric is in full compliance.

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