ML20077G911
| ML20077G911 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 06/28/1991 |
| From: | William Cahill TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-91231, NUDOCS 9107030149 | |
| Download: ML20077G911 (3) | |
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- 1XX-91231 File # 10130 (IR 91-14) 71/ELEC7RlC Ret. # 100FR2.201
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f tra nsiJn f 0 ',4 f Nf fe.kPlf U. S. Nuclear Regulatory Connission
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Attn:
Document Control Desk
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Washington, D. C.
20555
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SUBJFCT:
COMANCilE PEAK S1EAM ELECTRIC STi
'. 0 t'SES), UNIT 1 DOCKET N0. 50-445 NRC INSPECTION REPORT NOS. 50-445/W -14; 50-146/91-14 RESPONSE TO NOTICE OF V10LAT10ii REF:
NRC Letter from Samuel J. Collins, NRC to W. J. Cahill, Jr.,
TV Electric dated May 31, 1991 Gentlemen:
TV Electric has reviewed the ref erenced letter concerning the inspection conducted by the NRC staff during the period April 10 through May 21, 1991.
This inspection covered activities authorized by HRC Operating License NPF-87 and Construction Permit CPPR-127.
Attached to the referenced letter was a Notice of Violation.
TV Electric hereby responds to the Notice of Violation (445/9114-01) in the attachment to this letter.
Sincerely, der J
William J. Cahill, Jr.
OB/tg Attachments c - Mr. R. D. Martin, iiegion IV Resident inspectors, CPSES (2)
D. D. Chamberlain, Itiv J. II. riitford, HPP
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- x) North otne street Lit 81 Dallas, Texas 75201 ADOCK 05000445
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TXX-91231 w Attachment 1
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Page 1 of 2 HQIIGE OF 110LAT10N (445/9114-01)
Technical Specification 6.8,1 requires that written procedures shall be established, implemented, and maintained covering the applicable procedures recommended in Appendix A of Regulatory Guide 1.33 Revision 2 February 1978.
Section 1 of this appendix includes administrative procedures, Operations Department Administrative Procedure 402. " Operation; Department Key Control." states that operations duty key rings are issued to auxiliary operators (A0s) at the key control facility.
Station Administrative Procedure 905 " Control of Security Keys and Key Card Badges " states that operations shift personnel on duty shall be issued duty key rings for operational use during their shif t,
Contrary to the above, on May 10. 1991, none of the A0s on duty had duty key rings in their possession. These key rings contain keys to security doors for contingency use if security doors need to be opened for operational purposes during a period of security equipment malfunction.
EEif181E TO NOTICE OF VIOLATION (445/9114-01)
TV Electric accepts the violation and the requested information follows:
1.
Rgason For Violation l
The unit and shift supervisors did not adequately emphasize to the operations shift personnel the importance of having the duty key rings in their possessinn, Routine checks were not being made to assur e that the operations shift personnel were picking up the duty key rings, and there was no prescribed method to perform the checks.
In addition. Operations Department Administrative Procedure (ODA-40') did not clearly establish that operations shif t personnel have possession of duty key rings during their shift, 2.
Corrective Steos Taken And Results Achieved Operations department management discussed this issue with shift l
personnel, and emphasized the importance of duty key rings.
Written Operations Shift Orders were issued which stated that it is the responsibility of the shift supervisors to ensure that operations shift
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personnel pick up their duty key rings at the beginning of each shift and turn them in at the end of the shift.
ODA-402, " Operations Department Key Control" has been revised to clarify the responsibilities of the operations shift personnel regarding the duty key rings.
Additionally, STA-905 " Control of Securi ty Keys and Key Card Oddges" wae also reviewed and was deemed to be adequate.
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Page 2 of 2 3.
Cprrective Action 1 Taken to Preclude Recurrenca Shift Supervisors periodically emphasize to operations shift personnel their responsibility to obtain the duty key rings by the start of each shift. Additionally, Site Security has issued a post order which states that the key control facilities operator will contact the operations shift supervisor on his or her shift and provide to the operations shift supervisor the status of duty key rings, that have been issued to the operations shift personnel. This practice will continue until a high level of confidence has been achieved that the keys being picked up.
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pate When full Compliance Will [1g A_qhiftgj full compliance has been achieved.
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