ML20198P991
| ML20198P991 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 11/05/1997 |
| From: | Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| EA-97-468, NUDOCS 9711120079 | |
| Download: ML20198P991 (39) | |
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,i NUCLE AR FIEGUL ATOi1Y COMMISSION / } Hi tilON IV 84 f,11 R y A N Pt. A/ A Ofit V f, $U115 400 ARLINGTON. I( K AS 700118(64 Novernber 5 .s97 EA 97-468 Mr. C. L. Terry TU Electric Group Vice President, Nuclear ATTN: Regulatory Affairs Department P.O. Box 1002 Glen Rose, Texas 76043
SUBJECT:
PREDECISIONAL ENFORCEMENT CONFERENCE
SUMMARY
Dear Mr. Terry:
This refers to the predecisional enforcement conference conducted in the Rogion IV office on October 31,1997. This conference was convened to discuss apparent violations involving changes to the Comanche Peak Steam Electric Station Emergency Plan. This meeting contributed to a better understanding of the process used to make the emergency plan changes, in accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10. Code of Federal Regulations, a copy of this letter will be placed in the NRC's Public Document Room. Should you have any questions concerning this matter, we will be pleased to discuss them with you. Sincerely, } h. 97111 79 971105 ( V) l PDR A K 05000445 k G PDR Arthur T. Howell til, Director Division of Reactor Safety k Docket Nos.: 50 445; 50 446 License Nos.: NPF 87; NPF 89 -
Enclosures:
- 1. Agenda
- 2. Attendance List
~~j 1 00:4
- 3. Apparent Violations M'[
- 4. Licensee Presentation k,h h,h I
'I y n u,)v w-. Q( f .i
O TU Electric cc: Mr. Roger D. Walker TU Electric Regulatory Affairs Manager P.O. Box 1002 Glen Rose, Texas 76043 Juanita Ellis President CASE 1426 South Polk Street Dallas, Texas 75224 TU Electric Bethesda Licensing 3 Metro Center, Suite 610 Bethesda, Maryland 20814 George L. Edgar, Esq. Morgan, Lewis & Bockius 1800 M. Street, NW Washington, D.C. 20036 G. R. Bynog, Program Manager / Chief Inspector Texas Department of Licensing & Regulation Boiler Division P.O. Box 12157, Capitol Station Austin. Texas 78711 Honorable Date McPherson County Judge P.O. Box 801 Glen Rose, Texas 76043 Texas Radiation Control Program Director 1100 West 49th Street Austin, Texas 78756 John Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711 Ia._
l TU Eler.tric 01SIElllUTION w/ cony.oflacloiuins; DMD (IE 45) Regional Administrator Comancho Peak Resident inspector (2) DRS Director DRS Deputy Director DRP Director DRS PSB (Morray) Branch Chief (DRP/A) Branch Chief (DRP/TSSI Project Er.gineer (DRP/A) MIS System RIV File i DOCUMENT NAML: G:\\ REPORTS \\CP1031MS.GMG To receive copy of document. Indicate in box:"C" = Copy without enclosures "E" = Copy wth enclosures "N" = No copy kSB DD:DRM){ D:DRMB C:PSB /g GMGood:nh J]d.s[r.BMurravdy/M DDCh53iberlain ATHnWell ill (Y / 118/97 / 11/3/97 11R197 11Lt/97 OFFICIAL RECORD COPY
m-l* L u TU Electric 3-DISTRIBUTION Wlcopy olfaclosures; DMB (IE 45) Regional Adrninistrator Comanche Peak Resident inspector (2) DRS Directr,r DRS Depu'.y Director { DRP D!;ector DRS PSB (Murray) Branch Chief (DRP/A) Branch Chief (DRP/TSS) Project Engineer (DRP/A) MIS System RIV File S DOCUMENT N AME: G:\\REPORTSCP1031MS.GMG To receive copy ci document, Indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy RIV:PSD DD:DFik D:DRS(f)S l C:PSB /}r G'.iGood:nh,f!ph /r BMurrayAiM DDCh5inberlain ATHo'w' ell 111 (T / l[118 /97 / 11/3/97 11/h97 11/4/97 OFFICIAL RECORD COPY
. _ ~. l ENCLOSUR: 1 PREDECISIONAL ENFORCEMENT CONFERENCE AGENDA CONFERENCE WITH TU ELECTRIC OCTOBER 31,1997 i NRC REGION IV, ARLINGTON, TEXAS 1. INTRODUCTIONS / OPENING REMARKS....................... JAMES DYER 2. ENFORCEMENT PROCESS........,...,.............. MICHAEL VASQUEZ i 3. APPARENT VIOLATIONS & REGULATORY CONCERNS... DWlGHT CHAMBERLAIN 14. LICENSEE PRESENTATION............................... TU ELECTRIC 5. BREAK (10-MINUTE NRC CAUCUS IF NECESSARY) 6. HESUMPTION OF CONFERENCE 7. CLOSING REM ARKS........................ -...............LIC ENSEE 8. CLOSING REM ARKS.................................... J AMES DYER 1 'r m. \\ 4 4 i 4 f .. _ _ -.. _ _.. ~ - -. _.. _ _ -, - -.. - _
gCLOSt'RE? l PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDANCE l LICENSEE / FACILITY TU Electric Comanche Peak Steam Electric Station DATE/ TIME october 31. 1997. 8:30 a.m. (cso CONFERENCE LOCATION Region IV. Training Conference Room Arlington. TX EA NUMBER EA 97 468 _ LICENSEE REPRESENTATIVES NAME (PLEASE PRINT) ORGANIZATION TITLE (! L, ]T.e4 Y N'.iavir' G1 etunca de'eu9 l'< ct Et'l si.wr sd J k6 LL6 v J.o Nattiwt stataantw deti.6ts,oea;ficewowe (n.R &wws . b o r w u.t. Paar Msuw$ R a p o ra y 4 %,*/ > l r koor N 8' BL .,o, / / %, Tvy 4/6:<3 #c.,, c,,,, &Oav,u td wc ,, n. oom, ~ N -^ - ". ~- ~ 00 ~ W)" "lt, ,g' ] ), f). W,g ;,, ( )VAl t a I 6 &c % EV TLISErwLK l'oAs.$9kMy & n.ut,, Lei 70 ai k E,,u g,c < ok g s< Brei,Ja /% /e v FEMA R VI 4& & Bu..dbe. / o <) MnriIon 3 cobs rcmA PE Vcl O h Spec. J,, J l Oles AVLof Tu aEc rc ) c PCG ceJT G w mm' %kk w secruc-rs oc c ou A m es m-a-.
PREDECISIONAL ENFORCEMENT CONFERENCE ATTENDANCE ~ LICENSEE / FACILITY Tu Electric Comanche Peak Steam Elect ric Station DATE/ TIME october 31. 1997. 8:30 a.m. (Cs1) CONFERENCE LOCATION Region IV. Training Conference Room Arlinuton. TX EA NUMBER EA 97-468 _ _ NRC REPRESENTATIVES NAME (PLEASE PRINT) ORGANIZATI' TITLE 6ACclal14,,~> ax e z,< n a c. , a s. a ir a 3e 'n 3he .DK,4 r ~ -%,..M (%, bv/a a n' .hr. Dh, 2>2 % 0l, An)5 blME RM Cbie'0 ?SS 0R9 ET bh,,M- ,v, \\ M (-c % c3 O'fM, 4 \\ Tu i A %- by c/ A ?gbh GEAR-tit d416 F-r Wrnanty T h w cH NR C /MRC/WW /% hh n a %p 4 3% S& 9ttelva.vtJPenn (A ) C c P e n t Pexn / I t.;[ ' I y,. r , L, g'p, .. (,, s y *,, -,<ji; Ik <, o A F<e e_,.t -, NRc R:v hema tu,nt~r in,nm, (%., ,~ t c.h )~ tyd t q as N f-G hbO
e ENCLOSURE 3 APPARENT VIOLATIONS
- PREDECISIONAL ENFORCEMENT CONFERENCE 3
TU ELECTRIC OCTOBER 31,1997 ' NOTE: THE APPARENT VIOLA TIONS DISCUSSED A T THIS PREDECISIONAL ENFORCEMENT CONFERENCE ARE SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED PRIOR TO ANY RESULTING ENFORCEMENT ACTION. i
APPARENT VIOLATION l l 1. 10 CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as c?anged, continues to meet 50.47(b) planning standards and Appendix E requirements. 10 CFR 50,47(b)(2) requires that onshift facility assignments be unambiguously defined, adequate staffing for initial response be maintained, and timely augmentation of response capabilities be rnaintained. 10 CFR 50, Appendix E.IV.A requires that emergency plans describe the organization for coping with radiological emergencies, including definition of authorities, responsibilities, and duties of individuals assigned to the emergency organization. Contrary to these requirements, on October 29,1996, the licensee made changes to its emergency plan without Commission approval that did not continun to meet Planning Standard 50.47(b)(2) or Appendix E.IV.A requirements. Specifically, the description and responsibilities of four emergency response organization positions j were deleted from Revision 25 but remained on the emergency response organization call-out roster: (a) emergency operations facility radiation assessment coordinator, (b) technical support center operations coordinator, (c) operations l advisor, and (d) supporting stair for the logistical support coordinator. I 9 THIS APPARENT VIOLA TION IS SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED
APPARENT VIOLATION ( 2, 10 CFR 50.54(q) tuquires licensees to follow and maintain in effect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continees to meet 50.47(b) planning standards and Appendix E requirements. 10 CFR 50, 6 Spendix E.IV.F.1 requires that emergency plans describe the specialized training and retraining programs for certain categories of emergency response personnel, including fire brigade members and security personnel. Contrary to these requirements, on October 29,1996, the licensee made changes to its emergency plan without Commission approval that did not continue to meet Appendix E.IV.F.1 requirements. Specifically, the description of the fire brigade and security training programs were deleted from Revision 25. THIS APPARENT VIOLA TION IS SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED
APPARENT VIOLATION 3. 10 CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continues to meet 50.47(b) planning standards and Appendix E requirements. 10 CFR 50.47(b)(2) requires that onshift facility assignments be unambiguously defined, adequate staffing for initial response be maintained, and timely augmentation of response capabilities be maintained. Contrary to these requirements, on October 29,1996, the licensee made changes to its emergency plan without Commission approval that decreased the effectiveness of the plan and did not continue to meet Planning Standard 50.47(b)(2). Specifically, onshif t and augmentation capabilities were reduced as follows: The description of the emergency response organization no longer included a dedicated communicator to perform offsite agency notifications. Two 40-minute responders to help the shif t technical advisor perform dose assessment and engineering tasks were deleted. One 40 minute responder to perform offsite monitoring was deleted. As a result, offsite monitoring capabilities would be delayed until the 70-minute responders arrived, since onshift resources were not sufficient to perform the monitoring (according to the licensee). The f ailure to perform offsite monitoring could affect emergency classifications and protective action recommendations (unmonitored releases could not be quantified). Five 40-minute responders to help perform station surveys, team coverage, onsite surveys, access control, personnel monitoring, and dosimetry were deleted. THIS APPARENT VIOLATION IS SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED
APPARENT VIOLATION 4. 10 CFR 50.54(q) requires licensees to follow and maintain in etfect an emergency plan which meets the standards in 50.47(b) and the requirements of Appendix E to Part 50. Licensees are permitted to make changes to the plan without Commission approval only if the changes do not decrease the effectiveness of the plan and the plan, as changed, continues to meet 50.47(b) planning standards and Appendix E requirements. 10 CFR 50, Appendix E.IV.A.8 requires that emergency plans identify the state and/or local officials who would order protective actions. Contrary to these requirements, on October 29,1996, the licensee made changes to its emergency plan without Commission approval that did not continue ta meet g Appendix E.IV.A 8 requirements. Specifically, the identification of the offsite protective action decisionmaker(s) for the ingestion pathway zone was deleted from Revision 25 to the plan. THIS APPARENT VIOLATION IS SUBJECT TO FURTHER REVIEW AND MA Y BE REVISED
ENCLOSURE 4 -.-..~~-.--t g-- - ~ ~ - - - CPSES' ~ ~ ~ Ilistory of E-Plan Change Emergency Planning December,1995 craded Exercise Predecisional Enforcement cooa perrormance l Conference seircritique identified the need ror I improvement q Disciission Topics We needed to do something Different < History of Emergency Plan Change Development of an Enhanced Emerge _nci l < Four Proposed Violations Response Greanization (ERO) f (Category 1 Items) Evaluated all existing ERO positions < Discuss Category 2 Items Created Enhanced ERO l ~ / e e...-e.- -.s.4 History (continued) History (continued) Enhanced ERO Required E-Plan Revision Activities to Revise the Emercency Plan l l . New positions identified Reviewed entire E-Plan (Rev. 24) against . Selected positions identified for deletien or 10CFR50.47(h),10CFR50 Appendis E, FSAR, and Commitment Database (this l relocation l review performed to serify completeness) Activities Required for Enhanced ERO Reformat to match NUREG 0654 l Diside expertise to create 3 response teams Remove Redundant /Unnecessarv Detail . Train ERO members in new positions . Esercise each team prior to effectise date , gesis, E. Plan, Procedures, and Position g. l Assistance Documents (PADS) l
.. ~ ~, i I 4 4 i Ilistory (continued) llistory (continued) i i Ai tKiiisinfluenctne 30.54i1 ReTiew (continiiidj l Activities influencine 50.540 Review i -. NEI White Paper presented to the NRC l Attended meetings of the NEI j Emergency Response Task Force I three members of hi; staff l i 1 NEI Task Force recognized the need -. NEI White Paper to be resiewed in parallel mith j l for a consistent application of using desciopment oran NRC position 4 j l I 10CFR50.549 to make changes to the - NRC EP Position paper #4 resersed for 50.549 Emergency Plan guidance i i' Draft NEi White Paper developed NEI White Paper presented to Industry at aunual NEI Information Forum .W 6 llistory (continued) IIistory (continued) CPSES Use of NEI 50.580 Guidance Use of NEl~50.5in Guidance (continuedi~ ~' i l NEI White Paper criteria was applied in E-Plan - 2. Does the change result in the loss of ability to j Resisiog 25 resiew t'three Question 9 meet any of the standards or applicable I. Does the change decrease the effectis eness of the plan requirements described in IOCFR50.47(b) and (d) or j resulting in the loss of reasonable assurance that any NRC appros ed alternatise to those standards j adequate protection can and will be talsen in the es ent of and requirements? s radiological emergency as required by 10CFR50.47(a)? Response to first question: Response to second question-i Based on the justifications of each indisidual E-Plan - Resision 25 to the Emergency Plan w as compared. I change in Resision 25.there was no decrease in effectis ecess which would has e resulted in a loss of section by section, to the requirements of reasonable assurance that the health and safety of 10CFR50.47(b) and (d) and no desistions were i noted. the public would be protected. 1 F
j Ilistory (continued) Ilistory (continued) Use of NEI 50.54o Guidance (continued) . A key po. t in the NFI gu. dance n, that i m i
- 3. Does this change delete or contradict alternative methods from NRC Guidance any regulatory requirement?
Publications (n hich specifically includes j f NUREG-0654) may be implemented b5 using the 50.54q review without prior f Response to third questm. n: Ilased on the justifications of each NRC Approsal j individual E-Plan change in Revnion During the resien process. CPSES 25, there n ere no regulatory periodically contacted NEl for NRC requirements that this revision feedback on the NEI White Paper contradicted or deleted l 9 Y /0I, IIistory (continued) llistory (continued) f E Pliii Chance Process IGPlan Chance Process (continue <0 ~~ l Each E-Plan change package was prepared by - Changes were approsed by the Emergenes l an individual knowledgeabic in the subject Planning Manager i i matter - Changes were independently resiewed by Change packages were created from the CPSES Regulatory Affairs and all comments j l review of each section of the E-Plan against resolved prior to submittal to the Station j the regulations and applicable guidance Operations Resiew Committee (SORC) documents - Changes reviewed and approved by the SORC An independent Technical Review was One SORC comment was to increa e the performed by an individual knowledgeable in proposed Tchte 1.1 RP staffing on-shift. This the subject matter was incorporated in resision 25 j // /2-
I~-- - ~. - _, _ -.... _,,..., _ _.,,. .i j f IIistory (continued) llistory (continued) l l ~1 i Chrdifoloey 5 ~ Plan Chance - Post Implementation l - 10/95 - Initial SEI Task Force meeting -. Changes n ere revien ed by the 12/95-Graded Emergency Enercisc Operations Review Committee - 12/95 - Commenced E-Pisu resiew 8 CPSES representat.ives presented a Ow6 - Dram m r Wuw i summary of the niajor changes to the 04/96 - NE: u hite rapec presented to NRR l NRC Regional EP Inspector . o3,96. NEI w hite rapec presented to industry l -. 06/96 - Created enhanced ERO Volunteered to travel to Washington to l ~ 08/96 - 50RC appros ed E-Plan changes make presentation to NRR reviewer - 09/'5 - Exercised each ERO team f Kept in contact with the Regional EP - 10s E-Plan Rn. 25 errutiu & sutuniued to s ur Inspector on the status of Revision 25 __- 12/96 - Presentation to Regionsi EP Inspector - _... - -. - ~ _ - I3 N l ilistory (continued) Proposed Violation Number One ! TIIETAILURETO DESCRIBETIIE ~ Chronolocy EMERGENCY RESPONSE 01/97 - E-Plan submitted to NRR from Region av 01/97-Self assessment of stie E. Plan ORGANIZATION l 02/8 7 - Scheduled 827P s EP inspection at CPSES Since issuance of Unit I Operating 1.icense and 05/97 - Second % hite Paper presentation to industry approval of E-Plan in SSER 22 (1990), CPSES 05/97 - SAMG Demonstration at CPSES lias aot described all ERO positions in the 07/97 - Graded Emergency Exercise Ernergency Plan. (E-Plan unresolied item) - Revision 25 changes were a logical extension of 09/97 - Conference calls discussing E-Plan rnision the previously apprmed practice that only 09/97 - Reactive Inspection of E-Plan resish " selected key positions had to be described in the -.10/*7 - Inspection Report issued E-Plan (i.e. not all positions) 10/97 - E-Plan Herision 26 effectise ._ _. J /f
l Proposed Violation Number One (continued) Proposed Violation Number One (continuedf I The Revision 25 description changes were (EOF) Rad Assessment Coordinator incorporated to provide a consistent les el of . Rysibilitin muiM & & m* detailin the descriptions of key facility Coordinator contained in the E-Plan to whom t P"5iti""5 this person directly reports l . Only key facility positions responsible for I Table 1.1 functions were to be described .This position is show n on the EOF organisation i. chart contained in the E-Plan. Tha would i . The four example ERO pos.tmns cited in the preclude ch,m,inatmg th,is posit,on and [ , r inspection report as hau.ng their description .rcu rns ent.ing tise M34q process since such j and resIionsibilities deleted from the E-Plan climinatwn would still require an E-Plan i, are discussed in the following slides. /7 / r' 5 f l l Proposed Violation Number One (continued) Proposed Violation Niember One (continued) Operations Advisor TSC Operations Coordinator This position is an assistant position for the TSC This position is located in the Control Room and Stanager. This position relays direction to and communicates with the TSC Operations receis es information from, the Control Hr>om. The Coordinator. The Operations Adsisor is not TSC Ops Coordinator is not described in the plan [ described in the plan since his only l j since his only responsibility is to communicate. responsibility is to communicate This position is shown on the TSC organization -This position is shown on the control room chart contained in the E-Plan. This would organization chart contained in the E-Plan. I his l f I preclude eliminating this position and would preclude eliminating this position and l l l circumsenting the 50.54q process since such circumsenting the 50.54q process since such elimination would still require an E-Plan change elimination would still require an E-Plan change 20 m-
t Proposed Violation Number One (continued) Proposed Violation Number Ot>-(continued) Followine is a discussion of the other tmsiemns IIIe Supportine Staff for the Locistical citetiin the report j Support Coordinator (LSC) The other ERO positions referenced in the The support stafT for the LSC was not described inspection report l(OSC)in-plant team comm., i in the text of Emergency Plan Resmon 24 EP AdsisWTSQ qiwig m mW i status board keepers, and administratise support j t These positions are shown on the EOF personnell were not identified as key positions j organisation chart contained in the E-Plan.This and did not need a specific descrip* ion l would preclude eliminating these positions and circumsenting the 50.54q process since such Of these positions, administralise suppora was the ! elimination would still require an E-Plan only position that had a description that nas i remos ed. The engineering team still has a f change description in the E-Plan Al 2 1. 1 Proposed Violation Numher One (continued)I Proposed Violation Number One (continued)
SUMMARY
~~- Summary of position descriptions cited: Tbe E-Plan was resiewed and approsed in SsER 22. All j P6sE5n NeWIIF "M3 "* 5 " 3 ERO positions were not described and all positions =cre l W5 ~~ 'C not shown on the ERO organiistion charts at that time. 'crrRAc lt> T5CUpi C66TWY~~~ K5 "U l he les el of detail en the E-Plan's organization charts w as f3, . [ y$ ~ JU not changed from resision 24 to 25. A change to the ERO organization charts requires an E-Plan change which m g ygg No No ho 40 turn requires a 50.54q resiew no NO No EN9" ..g3 vg3 u3 A 50.54q resiew was performed and no decrease in effectis eness was determined. T his determinatic.i was 5tRGBa r - tc - - No N N based on the similar lesel of organiistional description that had been approsed in SSER 22 and the belief that Recorders ~ NO NO NO only key positions needed to be described in the plan. f %d"*
- i
e ~ ~ ~ s f Proposed Violation NumherTwo ' l Proposed Violation Number Two (continued) TIIE FAILURE TO DESCRIBE TIIE l Procedure TRA-105 EmeNe'ncy Preparedness f EMERGENCY RESPONSE Training, has been referenced in section 13 of ORGANIZATION TRAINING PROGRAM the E-Plan since resicw and apprmalin SSER, } 22 r. Prior to Rev. 25 of the E-Plan,Section 13, Rad. -. All E-Plan implementing procedures, which Emergency Response Training, had only two changes s". ice the issuance of an Operating License include TRA-105, receise an.setisit) screening and since resiew and approvalin SSER 22: both to verify that procedures meet the were editorial (title changes) requirements of CPSES Licensing liasis Documents (LIIDs). If a procedure change i No other training details w cre deleted from Section j screening identified an impact on the E-Plan, 13 of the E-Plan prior to resision 25 (this aspect of Section 13 was left open by the inspection report) then a 50.54q resiew is performed. l
- 26 L
1 I Proposed Violation Number Two (continued) Proposed Violation Number Tuo (continued) During the revision process of the -SectLn 13 of the E-Plan states " Personnel l E-Plan, TRA-105 was reviewed and assigned to the on-site emergency response l determined to meet the requirements organization receise training to qualify I of both E-Plan Revisions 24 and 25. them for their respective positions." -Section I of the E-Plan describes The ERO security and fire brigade training programs are bounded by resporsibilities to be performed by a j other regulatory requirements and functional group, w hich in conjunction l nith section 13, defines globally n hat ty pe 3 implemented by other programs and of training ERO members receive l procedures at CPSES. I l i i _27_ 4g l
{ -- - ~ = -. -., -. ? Proposed Violation Number Two (continued), Proposed Violation Number Two (continued) { -. Resision 24 of the E-Plan referenced i Since there is no specific regulatory guidance for Appendix E as there is other training programs that actually ( for 50.47(h) (NUREG-0654) industry perform the security and fire l ) { precedent influenced our decision for protection training making this change 'I.hese other trammg programs were We benchmarked the E-Plan against removed based on duplication within i other E-Plans to determine if our other CPSES Licensing Basis l changes met previously accepted Documents and because they were f plans and they did adequately covered by global training statement l b _ _, _. _ _ __ _ _ ~ 1 Proposed Violation Number Two (continued) . Proposed Violation Number Three!
SUMMARY
ON-SlilFT STAFFING AND TIMELY AUGMENTATION CAPAlliLITIES WERE TRA-105, Emergency Preparedness Training,is REDUCED the implementing procedure for the training of the ERO. TRA-105 did not have to be modified in In revision 25 of the E-Plan: conjunction with E-Plan Revision 25. Section I of the E-Plan in conjunction with The on-shift manning was increased i section 13, defines globally what type of training The @ minute respomiers wcre either assigned to, sn ERO member will receive. During the July 23, <m-shift, appropriately justified as to why the 1997, Graded Exercise only one Weakness was p sition could be eliminated,or apprnpriately identified which is a demonstration of the Justitied delaying the response until 70 minutes efTectiveness of the current training program. 1 l a 1
. - - - - ~ - -~m..____.-., Proposed Proposed I Viciation Number Three (continued) Violation Number Three (continued)I; ras # us a r, e= =.a.,,,,ggwa gm;;= y TIE riII5Wiiig slides discuss sliENRC's concerns on Table 1.1 of E-Plan Revision 25
- 7*,", ?""** C '"'"'
lf W ~' ~ ~ '!I romer -{lrg.a.>s vcn ! : PN 6]E -Isst!E 1; Mosing the 40 minute responding Tsah m Tsc owcac) communicator to an add..inonal dual function suppa,t ~-W MTCI~ % --- ji M EW**** E 5I' sits son,.ys "na,q-communicator on-shift 06 w Tedi w. ISst'E 2: Mosing the functioni/respons.hilit.ies of ,3g g g l t cens m ly w w --w-- . j she 40 minute responding core / thermal h draulic 3 l surv ys engineer and dose assessor to the STA Isst:E.,; Mosing the 40 minute responding off-site (',3 kM*~"~^ ~~~ niir pn>isitres-nas y wrm py gg monitor to the 70 minute responders Iss0E 4: Mosing the functions / responsibilities of g{ i co,cos r cina.n isc g,,c,,,,,, g the 40 minute responding protectise measure RP T m l techs to the on-shift RP techs. J i Proposed PHip5El i Violation Number Three (continued)- Violation Number Three (continued)' ISSUE I ISSUE I The on-shift communicator position was otification of the NRC is required within increased from one dual function position to two 60 minutes and can he performed by either, dual fimetion positions by moving the 80 minute commumcator depending on competing i 4 i ~ ! responder on-shift priorittes This provides higher assurance that the 15 Ilaving two communicators on-shift better ' minute notification requirements will be assures that all communication f satisfied requirements are met uith the on-shift staff One communicator notifies the state, f acal and reduces augmentatiots need until the 70 l governments and make other Ioeal notifications,! w hile the other communicator notifies the NRC f minute responders arris e 3g j 35 1
y- ~ b i l l'roposed Proposed Violation Number Three (continued)' Violation Number Three (continued). gg g g g __ _ ISStiE I The STA position has changed since 1980 w hen ~j ~3 NUREG-0654, Rev. I was published. Changes Ilaving two communicators on-shift was allow the STA to take on some additional believed to be an enhancement. One of responsibilities such as core / thermal hy draulic engineering and dose projections the two on-shift communicators is Licensed operator Training has impros ed actually dedicated and E-Plan Revision '""" ""'"""'"**'*'"k""*d*'""# 26 reflects ihis. performance { plant monitoring prosides the operators with I instantaneous status of all the nsjor plant 53 stems j including the criticalsafety functions l 37a 3gl i l'roposed Proposed Violation Number Three (continued): Violation Number Three (continned)' ISSUE 2 ISSUE 2 The STA's training requirements include core S,esere Acc, dent Management Guidelines were l i and thermal hydraube engmeering eseloped to gise guidance to both on-shift l A better understanding exists for the esents "".d augmentation staff for methodologics to leading up to and including the core melt nununue die conmguences of an nent that is l j sequence at TMI.The understanding is utside the design basis l documented in NUREG-1465 At CPSES all of the STAS are 1.icensed Senior l The endorsed practice of using plant condition l Reactor Operators which adds to STA Protective Action Recommendations (PARS)is expertise and performance monitoring j documented in the NRC's Reponse Technical capabilities l l Manual (RTM) m ,e m 4m,
r 7 i Proposed Proposed. _. _ _ _ _ _ _ - -.. j Violation Number Three (continued) Violation Number Three (continued)l ISSUE 2 l ISSUE 2 In the early sequence of an esent, the STA's prmided additional confidence of the acceptability >j { I Review of similar plan changes by other utilities irimary function is to monitor critical safety j of our changes. These submittals included Soth functions, maintain an independent review of unplemenued plans amt requesu for pHw activities being taken to mitigate the event, and approval but all came to the same cemc)au,on of nn assist the Shift Manager decrease in effectiseness Core / thermal hyd raulic engineering The pres ious slides justify reassigning Ihe 40 responsibilities were reassigned to the STA minute resp (mder's responsibilities fer since this responsibility is consistent nith the core / thermal hydraulic engineering to the on-shift j STA's primary function and training STA and long term to the 1SC Engineering Team ' __ __ _. __ _3 - ~ -~ Proposed Proposed l Violation Number Three (continued): Violation Number Three (continued)' I l ISSUE 2 f55UE 2 Dose projections are performed by the STA During the first 70 minutes of an esent, the { I l as time is available as discussed in a letter Control Room operaton would still be within from TU Electric (TXX-95212) to the NRC the Emergency Operating Prwedures - Operators would not he at the point w here CPSES has a plant conditions PAR flow mdependent recommendations concerning core l chart that allows the Shift Manager to l damage mitigation would be sought determine an initial PAR hased on l l I radiation monitors, core temperature, The STA is expected to have hufficient time to reactor n ater level, and status of provide oversight of the critical safety functions ~ l containment integrity and perform dose projections,if requim! l l l 44i j N3 l =
~ ..-m.,. l Proposed Violation Number Three (continued)l Proposed Violation Number Three (continued)j j j 1ssgg3 ISSUI I T Off-site monitorine was chanced to r sincie team i In WAS11-1400, Meactor Safety Studv. the composed of two 70 nunute response personnel earliest that a relesse occurs nith off site I conquem is N Im h w j Off-site monitoring is initially perfo.med to e 1 confirm that PARS are sufficsent to protect the g health and safety of the public. This monitoring This agrees nith the information in iask can he accomplished with one field team NUREG-1228. Incident Response to Sescre i Some amount of core damage must he present in Accidents, that the accident ensironment order to hase any significant off-site radiological inside the containment does not challenge its consequences. The NRC's RTAt 96 nasic integrity in most cases for several hc as after ' assumption for initial plant condition PARS is that reactor vessel failure 'I.' '3 3 '"'. * ! * *.'E.. -_ _ _ Mi 44 .me*+.w%'.'+-e$u-.a. -eM4,.., j I'roposed ~~ i Proposed Violation Number Three (continued) Violation Number Three (continued)! ISSi1E 3 ISSUC3~~ Information from the previously discussed ~ U***d 8n the previous informatm, n it NUREG and WASII de~iments is supported in nas beh,ered that deployment of an NUREG-1465, Acciden eurce Terms, w hich off-site monit9 ring team could wmit for refines the source term within containmsnt as the 70 minute responders.The team not occurring instantaneously. Instead it is a could then he dispatched from the EOF i phased release occurring over several hours optimizing the best placement of the The E-Plan estimates that the first field team team can be dispatched within 120 minutes of the emergency which was reviewed and approved in This change has also been approved at other utilities nith similar justification SSER 22 J ~~~~ 47 Mr
a Proposed l Pr opised ~ ~ ~ Violation Number Three (continued)' Violation Number Three (continued)t l 1 ISSUE 4 l ISSUE 4 The two 40-minute RP responders for The five RP 40-minute responders cited in Radi logical Protective Actions, which j the inspection report will be addressed in 8nclu e5 2CCe55 contnil, personnel anonitoring,1 l the following discussion dosimetry, and team cos erage. w ere deleted due to compensating adsances in technologs l The 40 minute RP on-site survey and access process changes { resp. nder was moved on-shift w hich was beli:a. I to be an enhancement as there Dosimetry and access control is a self-sen e l actisity in w hich indisiduals fog in and pick up i was oct one RP Tech required on-shift ~ dosimetry at a computer workstation in revision 24 of the E-Plan l i 60. ~ l I i firoposed _ _ _ i,roposed Violation Number Three (continued), Violation Number Three (continued)' f ~ ~~ ISSUE 4 ISSUE 4 Personnel self monitoring is performed in the Station surveys can be prmided by use of i' th PC m atmn rnonitoring system for i plant at varioo* Iocations allowing mdisiduals to detect contamination; additionally the g Process and area radiation monitors Personne! Contamination Monitors (PCMs) Process monitors measure normal efnuent l provide personnel monitoring at the exit of the release points that are potentially indicative l radiological controlled area and protected area l of a problem or radioactise release and arc Team coverage can be provided by the on-shift l monitored in the control room. They can f e RP staffing and use of technology improvements also be monitored at access control, the (e.g. alarming electronic dosimeters) OSC, the TSC and the EOF i I 5/ 51j l 1
Proposed l Proposed Violation Number Three (continued) Violation Number Three (continued) i ~ ~ ~ ~ ~
SUMMARY
ISSUE 4 Area radiation monitors are located throughout .1he thange, to the minimum staffing table in the E-Plan - the plant in accordance with Reg. Guide I.97, were n t taken lightly. 'Ihe changes resul;ed from j Post Accident Monitoring, to detect any leakage in-depth discussion with site management on Ho. 25 l l of radioactise fluid from containment or from T he philosophy of hasing additional staff on shift to fis a problem before it may escalate to an emergenes mas f sssicms that come in contact with the reactor coolant system beiined to be an enhancement j Area radiation monitors allow the HP Tech to T he adsances in technology and better understanding of l quickly monitor the plant area that a team may core physics allow alternatise methods for meeting the he dispatched to,in order to determine if there is regulatory guid-lines through the 50.54q process without a problem. The RP tech will take actions up to [ prior NHC appros al and including accompanying the team 4 --J 54 ) 68 l Proposed Violation Number Three (continued). Proposed Violation Number Four i i SilM M ARY (continued) TIIE FAILURE TO DESCRillE The decrease in total RP techs in the E-Plan is OFF-SITE DECISION M.\\KER(S) FOR i compensated for by an increase m RP techs { on-shift, advances an technology, process changes and the capability to dispatch a field team within - This was sn administralis e error that 120 minutes using 70 minute responders,such that remosed the whole sentence that contained the effectiseness of the E-Plan as mamtained. ihe State's responsibilities for Protectise i Itating additional stafTon-shift has a higher Actions for the ingestion pathwa3 sone potential for presenting the escalation of the esent. - In the submittal justification it states that the This prevents small esents from becoming large Department of Agriculture nas being esents and supports not needing interim deleted, not time entire sentence l augmentation
,__....s_.._._ l f l*roposed Proposed j i i Violation Number Four(continued) Violation Number Four kontinued) { ~'
SUMMARY
1 There is no impact since the State's - This was an administratise mistake that Emergency Management Plan, which is should have been identified and corrected in ; i e the resiew and approsal process of the approved by FEMA, has the details concerning protective action decision Emergency Plan making outside the 10 mile EPZ - There was no impact since the state's Emergency Management Plan has all the details w hich are required by NUltEG-0654 to be in the State's plan and not in the Licensee's plan l . 5 7-5 2 \\. Category Two items Category Two items (continued) ! AH t ese items were addressed as part of l l l The 19 items identified as Category 2 can the corrective action to the lleactive t i he subdivided into four broad groups Inspection (E-Plan Revision 26) l l Items that did not change from resision 24 to ems wcre in the Man in j j ",p ~ revision 25 (7) l *,mn 24 and were not part of l i Items that nere editorial corrections (4) l revision 25 j i items that needed additional explanation or l I clarification (6) - Group 2 items had the information j available in the plan but it may not l I Items that made reference to information contained in another Licensing Basis have been in the most appropriate l I f location or may have been inconsistent Document (2) b0 l t e
-.i.A i 7 y;:7 4'"E'R,, } Category Two items (continued) v.f ..s : Group 3 items are changes or deletions yf in descriptions or details which possibly O: should have remained in the plan for g 9" clarification. 7 Group 4 items had details removed with sp reference to another Licensing Basis tyJ 21 Document to prevent two documents .. -- s from having different descriptions. gf n. s I' -iT-f ~<', f y.. 'l ' ' p, . f~h.- .j k - ]h (Q'?j,Q f(p (['c _i. v M^ _v 1 l l
i AGENDA I. INTRODUCTION C. L. TERRY II. DISCUSSION OF ISSUES M. R. BLEVINS o History and Background of the Emergency Plan Changes o Potential Violation Number One Failure to Describe the Emergency Response Organization o Potential Violation Number Two Failure to Describe the Emergency Response Organization Training Program o Potential Violation Number Three On shift Staffing and _ Timely-Augmentation Capabilities Were Reduced o Potential Violation Number Four The Identification of the Offsite Protective Action Decisionmaker(s) for the Ingestion Pathway III. ENFORCEMENT DISCUSSION R. D. WALKER IV. CONCLUDING REMARKS - C. L. TERRY
e O ENFORCEMENT POLICY ISSUES
O PROPOSED VIOLATION ONE FAILURE TO DESCRIBE Tile E31ERGENCY RESPONSE ORGANIZATION i. TIIE CPSES F31ERGENCY PLAN AS APPROVED VIA SSER 22 FOR INITI AL LICENSING DID NOT DESCRIBE EVERY POSITION TilAT WAS ON Tile ORGANIZATION CIIARTS, Tile LEVEL OF DETAIL ON TIIE ORGANIZATION CIIARTS CONTAINED IN TIIE CPSES E31ERGENCY PLAN WAS NOT CIIANGED FRO 31 REVISION 24 TO REVISION 25 OF Tile PLAN. j Tile E31ERGENCY RESPONSE ORGANIZATION IS DEFINED VIA TIIE PLAN'S DESCRIPTIVE TEXT AND TIIE PLAN'S ORGANIZATIONAL Cil ARTS. TIIE FOUR POSITIONS IN TIIE VIOLATION RE31AIN ON Tile ORGANIZATIONAL CllARTS IN TIIE EAIERGENCY PLAN. TilESE POSITIONS CANNOT BE DELETEL) WITilOUT A 10 CFR 50.54q ASSESS 31ENT. IT WAS NOT AND IS STILL NOT OUR UNDERSTANDING, BASED ON OUR NRC APPROVED EMERGENCY PLAN AND Tile PLANS AT OTilER LICENSEES,TIIAT ALL POSITIONS ON Tile CALL-OUT ROSTER NEED TO BE DESCRIBED IN TIIE PLAN. A 50.54 (q) REVIEW WAS PERFORMED ON TIIE CIIANGES LISTED IN Tile VIOLATION AND IT WAS DETER 311NED TIIAT NO CIIANGE IN E31ERGENCY PLAN EFFECTIVENESS OCCURRED AS A CONSEQUENCE OF TIIESE CllANGES. Tile BASIS FOR THIS CONCLUSION WAS Til AT THE CIIANGES WERE CONSISTENT WITil: PREVIOUS REVISIONS SIADE TO Tile CPSES E31ERGENCY PLAN UNDER 10 CFR 50.54 (q) TIIAT llAD BEEN REVIEWED AND APPROVED BY Tile NRC STAFF. CPSES'S INTERPRETATION OF Tile NEI GUIDELINES FOR SIAKING CilANGES TO THE E31ERGENCY RESPONSE PLAN VIA 10 CFR 50.54(q). ' DESCRIPTIONS OF E31ERGENCY RESPONSE PLAN ORGANIZATIONS IN TIIE E31ERGENCY PLANS FOR CPSES AND OTHER NUCLEAR FACILITIES. TU ELECTRIC DOES NOT BELIEVE TIIAT TIIE PROPOSED VIOLATION AS DESCRIBED REPRESENTS A VIOLATION OF NRC REQUIRESIENTS
v s PROPOSED VIOLATION T)VO FAILURE TO DESCRIBE Tile EMERGENCY RESPONSE ORGANIZATION TRAINING PROGRAM Tile CPSES EMERGENCY RESPONSE ORGANIZATION TRAINING PROGRAM DID NOT CIIANGE FROM REVISION 24 OF TIIE EMERGENCY PLAN TO REVISION 25 OF Tile EMERGENCY PLAN. IT REMAINS TRAINING ADMINISTRATIVE PROCEDURE TRA-105. SECTION 1 OF TIIE CPSE3 EMERGENCY PLAN IN CON,1 UNCTION WITil SECTION 13 OF Tile CPSES EMERGENCY PLAN ADEQUATELY DEFINES Tile TYPE OF TRAINING REQUIRED FOR EMERGENCY RESPONSE OI'GANI7ATION MEMBERS AND IIAS BEEN EFFECTIVE IN TIIAT TIIE LAST GRADED EXERCISE RESULTED IN ONLY ONE EXERCISE WEAKNESS. TU ELECTRIC BELIEVES TIIAT TIIE EMERGENCY RESPONSE TRAINING PROGRAM DESCRIBED IN REVISION 25 TO TIIE CPSES EMERGENCY Pl AN IS CONSISTENT WITil TIIE DESCRIPTIONS PROVIDED IN Tile EMERGENCY PLANS FOR OTIIER NUCLEAR FACILITIES. TU ELECTRIC BELIEVES TIIAT TRA-105 COULD NOT BE CIIANGED TO REDUCE TIIE EFFECTIVENESS OF TIIE PLAN WITIIOUT AFFECTING EITIIER SECTION 1 OR 13 OF TIIE PLAN AND REQUIRING A 10 CFR 50.54q ASSESSMENT. TU ELECTRIC DOES NOT BELIEVE TIlAT Tile PROPOSED VIOLATION AS DESCRIBED REPRESENTS A VIOLATION OF NRC REQUIREMENTS. t J
PROPOSED VIOLATION T.HREE ON-SillFT STAFFING AND TIA1ELY AUGMENTATION CAPABILITIES WERE REDUCED TIIE CIIANGES TO TIIE MINIMU31 STAFFING TABLE IN THE CPSES EMERGENCY PLAN ARE CONSISTENT WITH EFFECTIVE IMPLEMENTATION AND EFFICIENT MAINTENANCE OFTilE EMERGENCY PLAN, AND WERE BASED ON : PRECEDENTS ESTABLISIIED VIA REVIEW OF STAFFING ASSIGNMENTS APPROVED AT OTIIER NUCLEAR FACILITIES. A PillLOSOPIIY TilAT IS ROOTED IN A CONSERVATIVE APPROACll TO SilIFT STAFFING WilICH ACCOUNTS FOR ADDITIONAL STAFF ON SlH FT.- Tile PRACTICE ACCEPTED BY TIIE NRC AT OTHER = FACILITIES THAT ALLOWS UNDER 10 CFR 50.54q ALTERNATIVE METHODS FOR MEETING REGULATORY GUIDANCE FOR MINIMUM STAFFING VIA CREDITING ADVANCES IN TECHNOLOGY AND THE BETTER UNDERSTANDING OF CORE PHYSICS THAT HAVE OCCURRED OVER Tile LAST 15 YEARS. THE DECREASE IN TOTAL RADIATION PROTECTION TECHNICI ANS IN TIIE PLAN IS COMPENSATED FOR BY AN INCREASE IN TECilNICIANS ON SHIFT, ADVANCES IN TECHNOLOGY, PROCESS CllANGES AND THE CAPABILITY TO DISPATCH A FIELD TEAM WITHIN 120 MINUTES USING 70 MINUTE RESPONDERS, SUCH THAT THE EFFECTIVENESS OF THE EMERGENCY PLAN IS MAINTAINED. TU ELECTRIC DOES NOT BELIEVE THAT THE PROPOSED V10LATION AS DESCRIBED REPRESENTS A VIOLATION OF NRC REQUIREMENTS )
D PROPOSED VIOLATION FOUR FAILURE TO DESCRIBE OFF-SITE DECISION MAKER (S) FOR TIIE INGESTION PATHWAY ZONE. THIS WAS AN ADMINISTRATIVE ERROR TIIAT RESULTED IN NO IMPACT ON ACTUAL EMERGENCY PLAN ACTIVITIES IN AS MUCH AS ALL OF TIIE DETAIL WlIICH IS RECOM:': 32NDED BY NUREG-0654 REMAINS IN THE STATE EMERGENCY RESPONSE PLAN. TU ELECTRIC CONSIDERS THIS VIOLATION TO BE NO MORE TIIAN A LEVEL IV VIOLATION BASED ON ITS SIGNIFICANCE TO OVERALL EMERGENCY PLAN EFFECTIVENESS AND IMPLEMENTATION. t u
O I CORRECTIVE ACTIONS TU ELECTRIC IIAS TAKEN CORRECTIVE ACTION TO ADDRESS EACil OF TIIE PROPOSED VIOLATIONS AND TIIE CATEGORY TWO (NON-CITED) ISSUES VIA REVISION 26 TO TIIE CPSES EMERGENCY PLAN SUBMITTED TO THE NRC VIA LETTER TXX-97225 ON OCTOBER 22,1997. TU ELECTRIC IS CONDUCTING AN INDEPENDENT REVIEW OF REVISION 26 OF TIIE CPSES EMERGENCY PLAN TO ASSURF ITSELF TilAT REVISION 26 OF THIS PLAN MEETS OR EXCEEDS CONSERVATIVE INTERPRETATIONS OF ITS REGULATOI Y REQUIREMENTS AND COMMITMENTS. THIS REVIEW IS BEING CONDUCTED UNDER THE AUSPICES OF THE CPSES OVERVIEW DEPARTMENT SUPPLEMENTED BY OTHER ORGANIZATIONS AND Tile RESULTS OF THIS REVIEW WILL BE FURTIIER REVIEWED BY SOMEONE WITil APPROPRIATE QUALIFICATIONS THAT IS FROM OUTSIDE TIIE TU ELECTRIC ORGANIZATION. TIIESE CORRECTIVE ACTIONS HAVE BEEN DONE, OR ARE IN THE PROCESS OF BEING DONE, WITHOUT REGARD FOR TU ELECTRIC'S POSITIONS AS TO ANY ACTUAL VIOLATIONS OR CONCERNS IDENTIFIED VIA THE NRC INSPECTION IN QUESTION.
O SUPPLESIENT Vlll--EAIERGENCY PREPAREDNESS This supplement provides examples of violations in each of the four severity levels as guidance in determining the appropriate severity level for violations in the area of emergency preparedness. It should be noted that citations are not normally made for violations involving emergency preparedness occurring during emergency exercises. Ilowever, where exercises reveal (i) training, procedural, or repetitive failures for which corrective actions have not been taken,(ii) an overall concern regarding the licensee's ability to implement its plan in a manner that adequately protects public health and safety, or (iii) poor self critiques of the licensee's exercises, enforcement action may be appropriate. A. Severity Level 1 - Violations involving for example: In a general emergency, licensee failure to promptly (1) correctly classify the event,('2) make required notifications to responsible Federal, State, and local agencies, or (3) rmoond to the event (e.g., assess actual or potential offsite t.atsequences, activate emergency response facilities, and augment shift staff.)
A l9 l B. Severity Level II - Violations involving for example:
- 1. In a site emergency, licensee falhare to promptly (1) correctly classify the event,(2) make required notifications to responsible Federal, State, and local agencies, or (3) respond to the event (e.g., assess actual or potential offsite consequences, activate emergency response facilities, and augment shift staff); or
- 2. A licensee failure to meet or implement one emergency planning standard involving assessment or notification.
C. Severity Level III - Violations involving for example:
- 1. In an alert, licensee failure to promptly (1) correctly classify the event,(2) make required notifications to responsible Federal, State, and local agencies, or (3) respond to the event (e.g., assess actual or potential offsite consequences, activate emergency response facilities, and augment shift staff);
- 2. A licensee failure to meet or implement mere than one emergency planning standard involving assessment or notification; or
- 3. A breakdown in the control oflicensed activities involving a number of violations that are related (or,if isolated, that are recurring violations) that collectively represent a potentially significant lack of attention or-carelessness toward licensed responsibilities.
d
O C D. Severity Level IV - Violations involving for example: A licensee failure to meet or implement any emergency planning standard or requirement not directly related to assessment and notification. [60 FR 34383, June 30,1995] _.w
SUMMARY
TU El.ECTitlC DOES NOT llEl.lEVE TilAT TilitEE OF Tile FOUlt PROPOSED VIOLATIONS AllE ACTUAL. VIOLATIONS OF NitC REQUIRE 31ENTS. Tile l'ROPOSED VIOL.ATION REGAllDING Fall.URE TO DESCRillE OFF-SITE DECISION SI A KElt(S) IIAD NO CONSEQUENCES TO CPSES ESIEltGENCY PLAN 131Pl.E31ENTATION OR EFFECTIVENESS AND IS NO MORE TilAN A LEVEL IV YlOLATION. TU ELECTRIC'S CilANGES TO TilEIR EMEltGENCY RESPONSE PROGRAM INITIATED VIA REVISION 25 TO TIIE CPSES EMERGENCY PLAN WERE: WELL TilOUGIIT OUT AND CONSISTENT WITil INDUSTRY GUIDANCE TilAT WE IIAD REASON TO BELIEVE WAS APPROPRIATE. CONSISTENT WITil EMERGENCY PLAN CllANGES IMPLEMENTED TIIROUGilOUT INDUSTRY AT VARIOUS SITES UNDER 10 CFR 50.5 i (y). CAREFULLY REVIEWED TO ASSURE TilAT, CONSISTENT WITil OUR UNDERSTANDING OF TIIE PLANNING STANDARDS, REGULATIONS, AND OUR COMMIT 31ENTS,TIIC EMERGENCY PLAN AS DESCR111ED IN REVISION 25 WAS NOT A REDUCTION IN CPSES EMERGENCY PLAN EFFECTIVENESS. PROPOSED TO MAKE OUR EMERGENCY PLAN IlOTil MORE EFFECTIVE AND EFFICIENT. WE IIELIEVE OUR CilANGES ENilANCED OVERALL PLAN EFFECTIVENESS WillLE PROVIDING LONG-TERM RESOURCE SAVINGS FOR llOTil TU ELECTRIC AND Tile NRC STAFF. Tile CilANGES TO Tile CPSES EMERGENCY PLAN INITIATED VIA REVISION 25 DID NOT IEPRESENT A IIREAKDOWN IN Tile CONTROL OF I lCENSED ACTIVITIES INVOLVING A NUMBER flF ACTIVITIES TilAT ARE.RELATED (OR. IF ISOLATED.TilAT ARE RECURRING VIOLATIONS) TilAT COLLECTIVELY REPRESENT A POTENTIALLY SIGNIFICANT LACK OF ATTENTION OR CAREl.ESSNESS TOWARD LICENSED ACTIVITIES.}}