ML20073T055
| ML20073T055 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/30/1994 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-94184, NUDOCS 9407080088 | |
| Download: ML20073T055 (4) | |
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-IR 94-09 Ref.
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1UELLC TRIC June 30, 1994 wmi J.c.huur.
amp m rmidew U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 SUBJECI:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)-
DOCKET N05. 50-445 AND 50-446 NRC-INSPECTION REPORT NOS. 50-445/94-09; 50-446/94-09 SUPPLEMENTAL RESPONSE TO NOTICE OF VIOLATION-REF:
- 1) TV Electric letter logged TXX-94112 from Mr. William J. Cahill, Jr. to the-NRC dated May 5, 1994,-
Response to Notice of Violation
- 2) NRC Inspec on Report 445/94-09; 446/94-09 dated April 7, 1994. Notice ~of Violation 94-09-03
- 3) 1:1 Electric letter logged.-TXX-4007 from Mr. R. J. Gary.
to NRC dated July 15, 1983 4). NRC letter, dated August-10, 1983 Responding to Reference 3.
from Mr. B. J. Youngblood Gentlemen:
During a telephone conversation on May 17, 1994, between TU Electr.ic and your Region IV Staff concerning TU "ectric's response (reference 1) to the Notice of Violation 445 and 446/94 s9-03,-your Staff requested additional information. The information requested is being provided in the attachment-to this letter.
-9407080088 940630 PDR ADOCK 06000445 O
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.s P. O. Box 1002 Glen Rose, Texas 76N3-1002 g
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TXX-94184 Page 2 of 2 The subject violation identified inadequate testing of detection aids associated with the physical security program.
The attachment provides TV Electric's revised, supplemental response to the Notice of Violation.
Sincerely, (f
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f William J. Cahill, Jr.
By:
XM h._W Rogef D. Wal<er Regulatory Atfairs Manager NSH:tg ATTACHMENT cc: Mr. L. J. Callan, Region IV Ms. M. A. Miller, Region IV Resident Inspectors, CPSES
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. Attachment to TXX-94184 Page 1 of 2 1
B ETATEMENT OF VIOLATION (445/S409-03; 446/9409-03)-
Inadeauate lestina of Detection Aids License Condition 2.H of the Comanche Peak Steam Electric-Station Facility Operatina License states, in part "TU Electric shall fully implement and maintain in effect all provisions of the Physical Security Plan...
i previously approved by the Commission...."
I Paragraph 7.1.1.1 of the Comanche Peak Steam Electric Station's Physical Security Plan requires both the "E" field end microwave detection systems to detect individuals stepping or jumping in or_through:the miccowaves of "E" field sensing wires. Paragraph 13.6 requires operability and performance i
testing be conducted in accordance with Regulatory Guide 5.44 wh?ch requires testing by jumping.
l Contrary to the above, the operability and-performance testing condurted 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.
RESPONSE TO THE VIOLATION (445/9409-03; 446/9409-03)
TV Electric provides the following information as requested:
1.
Reason for Violatinn The discrepancy between the Plant-Security Plan (PSP) and the testing methcdology existed as a result of an interpretation of the PSP statement in section-13.6 which refers to referencing the applicable portions of NRC Regulatory Guide 5.44.
The design of the Intrusion Detection System, to include the Four Wire Stellar E-Field and the-
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Southwest Microwave equipment is not conducive to safe testing by.
jumping.
Some of the vertical applications are twelve feet or more.
On Ane 24,1983, Mr. R. Gary, Executive Vice-President of Texas Util_ities Generating Company (now known as TU Electric) corresponded in reference 3 with Mr. Denton (NRC) identifying that during the development and review of the Physical Security Plan (PSP), it was noted j
that the Regulatory Guide 5.44 criteria for jumping in the E-Field was not realistically attainable and testa:De. The letter identified thirteen separate points wnich stated tae reasons not to include the jumping criteria in the PS8'.
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"o Attachment to TXX-94184
'Page 2 of 2 The letter further requested that the NRC evaluate the criteria in question and treat the criteria as a design criteria, rather than a commitment until the issues addressed by TV Electric could be resolved.
On August 10, 1983, Mr. B. J. Youngblood, Chief Licensing Branch, NRC responded to Mr. R. J. Gary in reference 4 with respect to the letter's subject. The NRC concluded that they were in tentative agrcement with TUGCo findings [ realistic, attainable and testable performance criteria versus the wording in Regulatory Guide 5.44} and would forward these concerns to the Regulatory Improvement staff to potentially modify Regulatory Guide (RG) 5.44.
The NRC also agreed with TV Electric's assessment, that the ability to detect jumping would be a-design criteria versus a commitment to perform additional testing utilizing jumping, and that no PSP change was necessary at that time.
As a result, jumping in accordance with RG 5.44 was not considered to be 4
one of the " applicable portions" from the regulatory guideline, based on Lne previous correspondence with the NRC, the criteria was not incorporated into TU Electric's testing procedures. Additionally, no PSP change was initiated to clarify this; because the understanding at that time was that no change was necessary, 2.
Corrective Steos Taken and Results Achieved An assessment of the perimeter barriers and intrusion detection system comprised of cumulative history reviews, system tests, and perimeter walkdowns was conducted. The assessment confirmed previous findings that certain areas are not vulnerable to penetration by jumping.
Various tests were conducted in an effort to determine an alternative methodology to jumping, which TU Electric could use to meat the requirements of paragraph 7.1.1.1 of the PSP.
Currently, 3 mulated jumping test procedures have been identified that test detection capabilities of both microwave and E-field detections systems respective to an individual jumping into or through the identified zones.
3.
Corrective Steos Taken to Avoid Recurrence TU Electric has modified the testing procedure to specify; zones subject to simulated jumping testing, and the methodology by which the tests will be conducted.
4.
Date of Full Comolianc_q TU Electric is in full compliance.
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