ML20203C073
| ML20203C073 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/16/1998 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-445-97-19, 50-446-97-19, EA-97-468, TXX-98030, NUDOCS 9802250057 | |
| Download: ML20203C073 (6) | |
Text
.__
==
P' 7 Log # TXX 98030
=.
File # 10130 C
C IR 97 19 TUELECTRIC Ref. # 10CFR2.201
- c. u w ry s,ntor uc,Prc,w,n, February 16, 1998
& PrincipalNuclear Oficer U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 i
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50 446 NRC IN:?ECTION REPORT NOS. 50 445/97 19 AND 50 446/97 19 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TV Electric has reviewed the NRC's post Enforcement Conference letter dated-January 16. 1998, concerning the subject inspection conducted during tne period of September 22 25, 1997. Attached to the letter was a Notice of Violation.
l l
TO Electric hereby responds to the Notice of Violation in the attachment to this letter.
Additionally. TU Electric has completed an independent review of the CPSES Emergency P?an as committed in TV Electric's letter TXX 97211 to the NRC dated September 26, 1997.
The results of this review have been documented and are available onsite for your review.
Sincery[y.
C. L. Ter y CLW/c1w
[
Attachment
(
c-E. W. Merschoff, Region IV J. I. Tapia, Region IV T. J. Polich, NRR
/(O Resident Inspectors, CPSES 9802250057 980216
'lti it t INl,III" ' ("lilll'
, ll t
PDR ADOCK 05000445 ll"ll,, ll 1 ll
,..l II G
PDR COMANCilE PEAK STEAM ELECTRIC STATION P.O. Bos 1002 Glen Rose. Teus 76043-1002
=,
Attachment to TXX 98030 Page 1 of 5 RESPONSE TO NOTICE OF VIOLA 1 ION RESTATEMENT OF VIOLATION A (445:446/EA 97 468)
A.
10 CFR 50.54(q) requires licensees to follow and maintain in effect an emergency plan which meet: the standards in 50,47(b) and the requirements of A)pendix E to Part 50.
Licensees are permitted to make changes to t1e plan without Commission ap)roval only if the changes do not decrease the effectiveness of t1e 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 emergen:y response plan must meet the standard of providing that adequate staf'ing for initial facility accident response in key functional areas be maintained at all times, and timely augmentation of response capabilities is available.
Contrary to these requirements, on October 29, 1996, the licensee made changes to its emergency plan, without Commission approval, that decreased the offectiveness of the plan and did not continue to meet Planning Standard 50,47(b)(2),
Specifically, on shift and augmentation capabilities were reduced as follows:
o Adequate staffing for initial response in key functional areas was not maintained when the emergency response e'
'ization no longer included a dedicated communicator to per offsite agency notifications.
o Timely augmentation of response cepabilities was not available when two 40 minute responders, to help the shift technical advisor perform dose assessment and engineering tasks, were
- deleted, o
Timely augmentation of response capabilities 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 on shift resources were not sufficient to perform the monitoring (according to the licensee).
o Timely augmentation of response capabilities was not available when five 40 minute responder:: to help perform station surveys, team coverage, onsite surveys, access control, personnel monitoring, and dosimetry were deleted.
~
Attachment to TXX 98030
age 2 of 5 RESPONSE TO VIOLATION A (445:446/EA 97 468)
TV Electric accepts the violation.
~
1.
Reason for Violation:
The examples cited In Violation A represent changes which may be perceived as reductions in capability, but are changes which TV Electric concluded did not represent a reduction in the effectiveness of the CPSES Emergency Plan.
TU Electric also concluded that these changes as incorporated into the CPSES Emergency Plan, Revision 25, ccatinued to be compliant with the standards of 10 CFR 50.47(b) concerning aaquate onshift and timely augmentation staffing capabilities. The examples cited were either offset by changes that increased the total onshift staffing levels, or were similar to other plan changes that had previously been justified, proposed, accepted and/or impler.ented by other licensees. A detriled explanation of TV Electric's conclusions regarding the cited changes is documented in NRC letter dated November 5, 1997, "Predecisional Enforcement Conference Summary."
l 2.
Corrective actions taken:
Following inspection 445/446 97-19 condacted September 22 25, 1997, TU Electric committed in letter TXX 97211 dated September 26, 1997, to promptly revise the CPSES Emergency Plan, Revision 25, and include corrective actions with respect to Table 1.1 " Staffing Requirements For Emergencies." In the interim period prior to revising the plan, TU Electric imnlemented immediate corrective actions to provide emergency response augmentation staffing levels commensurate with those levels that had previously been committed to in Table 1.1 of CPSES Emergency Plan, Revision 24. The immediate corrective actions taken regarding onshift and augmentation staffing are identified in lett?r T t 97211.
Subsequently TU Electric revised the CPSES Emergency Plan, iable 1.1 in Revision 26 which became effective October 15, 1997. Revision 26 was submitted to the NRC by TV Electric htter TXX 97225 dated October 22, 1997. Changes incorporated into Table 11 of the CPSES Emergency Plan, Revision 26, address the cited issues and meet the expectations conveyed in NRC Inspection Report No. 50 445/97 19: 50 446/97 19.
3.
Steps to prevent recurrence:
TU Electric has reviewed the CPSES policy, program and available industry guidance for making changes to the CPSES Emergency Plan under the provisions of 10 CFR 50.54(q). The results of this review, including recommendations for improvement, have been documented and are available onsite for review.
TV Electric intends to consider the expectatio.
conveyed in NRC Inspection Report No. 50 445/97-19, 50-446/97 19, NRC actions regarding I
mv
Attachment to TXX 98030 Page 3 of 5 emergency )lanning at other licensees, and any related future guidance published )y the NRC prior to making changes to the CPSES Emergency Plan without prior NRC approval.
4.
Date when full compliance achieved:
l TV Electric is in full compliance Corrective actions to address the cited examples were completed 0 :tober 15,1997, in at,ociation with the effective date of the CPSES Emergency Plan, Revision 26.
RESTATEHENT OF VIOLATION B (445:446/EA 468)
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 to make changes to the plan without Commission approval only if the changes do not decr " 3e 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 resoonse 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 respon:;e 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 authorities, responsibilities, and duties of individuals assigned to the emergency organization.
10 CFR Part 50, Appendix E.!V.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.
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 'icensee code the following changes to its emergency plan without t,ammission approval that did not continue to meet Planning Standard 50.47(b)(2) or the requirements of Appendix E:
1.
Cho, ses 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
Attachment to TXX 98030 Page 4 of 5 following four emergency response organization positions were deleted from Revision 25 but remained on the organization 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 ?ogistical support coordinator.
2.
Changes involving the description of the emergency response organizatico training program did not continue to meet Appendix E iv.F.1 requirements.
Specifically, the descript W of the f Se e igade and security training orograms were deleted from Revision 25, 3.
Changes involving the description of offsite decision makers dio not continue to meet Appendix E.IV.A.8 requirements.
Specifically, the identification of the offsite protective action decision makers for the ingestion pathwa; zone was deleted from Revision 25 to the plan.
RESPONSE TO VIOLATION B (445:446/EA 97 468)
TV Electric accepts the violation.
1.
Reason for Violation:
TU Electric evaluated cited changes 1 and 2 above and concluded that they-were consistent with TV Electric's understanding of the regulations. This conclusion was based, in part, on previous NRC acceptance in SSER 22 of a similar level of detail in the plan's emergency organization description and that training requirements were globally defined in plan sections 1 and 13, res pectively. A detailed explanation of TV Electric's conclusions regarding t1e cited changes is documented in NRC letter dated November 5, 1997, "Predecisional Enforcement Conference Summary.**
With respect to cited change 3. TU Electric made an administrative error during preparation-and issue of Revision 25 that removed the identification of the subject offsite protective action decision maker for the ingestion pathway zone.
2.
Corrective actions taken:
TV Electric has revised the CPSES Emergency Plan to address the cited changes. The CPSES Emergency Plan, Revision 26, was submitted to the NRC by TU Electric letter TXX 97225 dated October 22, 1997. Revision 26 changes incorporated in plan section 1 address cited issues 1 and 3 above regarding emergency organization description and identification of the offsite protective action decision maker for the ingestion pathway zone. A Revision 26 change incorporated in plan section 13 addressed cited issue 2 regarding-the deletion of description of training program requirements for
Attachment to TXX 98030 Page 5 of 5 the fire brigade and security. These changes revise the CPSES Emergency Plan to meet the expectations conveyed in NRC Inspection Report No. 50-445/97 19: 50 446/97 19.
3.
Steps to prevent recurrence:
TU Electric intends to consider the expectations conveyed in NRC Inspection Report No. 50 445/97 19: 50 446/97 19, NRC actions regarding emergency planning at other licensees, and any related future guidance published by the NRC prior to making changes to the CPSES Emergency Plan without prior NRC bpproval.
TV Electric considers the administrative error associated with cited change 3 to be an isolated case. This error and n.anagement expectations on self checking have been discussed with appropriate personnel.
4.
Date when full compliance achieved:
TV Electric is in full compliance.
Corrective actions to address the cited changes were completed October 15, 1997, in association with the effective date of the CPSES Emergency Plan, Revision 26.
I J