ML20198R657
| ML20198R657 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 01/16/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20198R621 | List: |
| References | |
| 50-445-97-19, 50-446-97-19, EA-97-468, NUDOCS 9801230372 | |
| Download: ML20198R657 (3) | |
Text
c NOTICE OF VIOLATION TU Electric Docket Nos. 50-445;50-446 Comanche Peak Steam Electric Station License Nos. NPF-87; NPF 89 EA 97-468 During an NRC inspection conducted on September 22-25,1997, violations of NRC requirements were identified in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," NUREG-1600, the violations are listed below:
A.
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, in part, that the onsite emergency response plan must meet the standard of providing that adequate staffing for initial facility accident response in key functional areas be maintained at all times, and timely augmentation of response capabihties is available.
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, onshift and augmentation capabilities were reduced as follows:
Adequate staffing for initial response in key functional areas was not maintained when the cmergency response organization no longer included a dedicated communicator to perform offsite agency notifications.
Timely augmentation of response capabihties was not available when two 40-minute responders, to help the shift technical advisor perform dose assessment and engineering tasks, were deleted.
Timely augmentation of response capabihties was not available when 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).
Timely augmentation of response capabilities was not available when five 40-minute responders to help perform station surveys, team coverage, onsite surveys, access control, personnel monitoring, and dosimetry were deleted.
(01014)
This is a Severity Level N violation (Supplement Vill).
9001230372 900116 PDR ADOCK 05000445 G
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B.
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 tu 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, in part, that the onsite emergency response plan must meet the standard of providing that facility assignments be unambiguously defined, adequate staffing to provide initial facility accident response be maintained in key functional areas at all times, and timely augmentation of response capabilities is available.
10 CFR Part 50, Appendix E.IV.A requires that emergency plans describe the organization for coping with radiological emergencies, including definition of authonties, responsibilities, and duties of individuals assigned to the emergency organization.
10 CFR Part 50, Appendix 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 secunty personnel.
10 CFR Part 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 the following changes to its emergency plan without Commission approval that did not continue to meet Planning Standard 50.47(b)(2), or the requirements of Appendix E:
1.
Changes involving the description of emergency response organization members did not continue to meet Planning Standard 50.47(b)(2) and Appendix E.IV.A requirements. Specifically, the description and responsibilities of the following four emergency response organization positions were deleted from Revision 25 but remained on the organcation chart and emergency response organization call-out roster: (a) emergency operations facility radiation assessment coordinator, (b) technical support center operations coordinator, (c) operations advisor, and (d) supporting staff for the logistical support coordinator.
2.
Changes involving the description of the emergency response organization training program did not continue to meet Appendix E.lV.F.1 requirements.
Specifically, the description of the fire brigade and security training programs were deleted from Revision 25.
3.
Changes involving the description of offsite decision makers did not continue to meet Appendix E.IV.A.8 requirements. Specifically, the identification of the offsite protective action decision makers for the ingestion pathway zone was deleted from Revision 25 to the plan. (01024)
This is a Severity Level IV violation (Supplement Vill).
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Pursuant to the provisions of 10 CFR 2.201, TU Electric is hereby required to submit a written -
statement or explanation to the U.S. Nuclear Regulatory Commission, ATTN _:: Document Control ~
.j Desk, Washington, D.C; 20555 with a copy to the Regional Administrator, Region IV,611 Ryan Plaza Drive, Suite 400. Arlington, Texas 76011, and a copy to the NRC Resident inspector at the facility that is the subject of this Notice, within 30 days of the date of the letter transmitting.
i this Notice of Violation (Notice). -This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation:_ (1) the reason for the violations, or, if contested, l
the basis for d;sputing the violation (2) the corrective steps that have been taken and the results
- achieved, (3) the corrective steps that will be taken to avoid further violations, and (4) the date j
when full ccmpliance will be achieved. Your response may reference or include previous docketed emespondence,'If the aorrespondence adequately addresses the required response,
- if an adequate reply is not received within the time specified in this Notice, an orde_r or a Demand for Information may be issued as to why the license should not be modified, suspended, or revoked, or why such other action as may be proper should not be taken Where good cause is shown, consideration will be given to extending the response time /
Because your response will be placed in the NRC Public Document Room (PDR), to the extent
- possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your i =
response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you.must specifically identify the portions of your response that you seek to have withheld and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards informstion is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.
Dated at Arlington, Texas this 16 day of January 1998 t
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