ML20211P357
| ML20211P357 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 10/17/1997 |
| From: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-445-97-17, 50-446-97-17, TXX-97217, NUDOCS 9710200174 | |
| Download: ML20211P357 (5) | |
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Ref. # 10CFR 73.46(c)(4).
73.55(c)(5)
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October 17. 1997 U. S. Nuclear Regulatory Commi;sion Attn:
Document Control Desk Washington. D.C.
20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 NRC INSPECTION REPORT NOS. 50-445/97-17; 50-446/97-17 RESPONSE TO NOTICE OF VIOLATION Gentlemen:
TU Electric has reviewed the NRC Inspection Report and attached Notice of Violation dated September 19. 1997. concerning the inspection conducted by G. E. Werner. Acting Senior Resident Inspector. H. A. Freeman, Resident Inspector R. L. Neas3. Technical Assistant. Division of Reactor Projects.
W. C. Sifre Resident Inspector. South Texas Project, and W. J. Wagner, Reactor Inspector. Division of Reactor Safety during the period of July 20 through August 30, 1997.
This letter responds to part C of the Notice of Violation related to the Physical Security Plan. Parts A and B will be responded to separately in TXX-97220.
The Notice of Violation part C describes a failure to follow Security Plan requirements used to ensure adequate lighting of structures. The information provided herein, does not contains Safeguards Information as defined in 10CFR73.21. TU Electric's response is attached.
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Q TXA-97217 Page 2 of 2 This communication contains no new licensing basis commitments regarding CPSES Units 1 and 2.
Please do not hesitate to contact Neil Harris at (254) 897-5449 to coordinate any additional information you may need to facilitate closure of this issue,
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NSH:nsh Attachment cc: Mr. Ellis W. Merschoff, Region IV Mr. Joe Tapia. Region IV Resident Inspectors S
. to TXX-97217 Page 1 of_3 RESTATEMENT OF THE NOTICE OF VIOLATION (50 445/97-17; 50 446/97 17)
During an NRC inspection conducted on July 20 through August 30. 1997, one violation of NRC requirements for security requirements was identified (violation 'C').
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," (NUREG-1600), the violation is restated below:
License Condition 2.H requires the licensee to fully implement and maintain in effect all provisions of the physical security plan.
Physical Security Plan. Revision 27, Section 7.1.3. " Illumination," required at least 0.2 foot-candles of light in the protected area as measured on horizontal ground.
The inspectors determined that the failure to ensure the protected arca is adequately illuminated is a violation of License Condition 2.H (Violation 445(446)/9717-06).
Contrary to the above, on August 27. 1997. while performing a walkdown of outside spaces within the protected area to verify adequate illumination, the areas under two trailers and under a vending truck located within the protected area were not illuminated to at least 0.2 foot-andles.
During the walkdown of outside spaces located within the protected area, the inspectors identified that the undersides of two material storage trailers and a vending truck appeared to have inadequate lighting.
Security officers in the secondary alarm station were informed of this concern and officers were stationed at the suspect locations. Measurements identified that lighting conditions were less than the 0.2 foot-candles required by the Physical Security Plan. The actual readings were 0.121.
0.116 and 0.133 foot-candles.
The inspectors identified a violation of illumination requirements within the protected area.
Security personnel responded immediately and installed temporary lighting.
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Att:chment 1 to TXX-97217 Page 2 of 3 REPLY TO NOTICE OF VIOLAUM (50 445/97 17: 50 446/97 17)
TV Electric accepts the violation. An evaluation of the condition concluded that there was no decrease the effectiveness of the security
)rogram and did not result in any uncontrolled or undetected access to the
)rotected Area (PA) or Vital Areas (VA). However, the violation is correct 1n that 3 trailers / vehicles lighting levels did not comply with the security plan requirements.
The adherence to security plan requirements for these evolutions were not in accordance with TV Electric's expectations and is considered a unacceptable practice.
The information requested is prcvided as follows:
1.
Reason for the Violation The trailers ident.1fied in the violation were moved to the location south of the.naintenance area during the late afternoon on August 27, 1997.
Lighting consideration was overlooked by the crews moving the trailers. A routine p'a-dusk walkdown of the protected area by Security failed to identify thr,otential need for compensatory lighting. The evening walkdown by Security also failed to identify the deficiency.
The vendor vehicle noted, is a licensee designated vehicle (LDV) that routinely parts ?n the same location daily.
The light normally relied upon to illuminate under this vehicle was out-of-service.
The routine walkdowns referenced above also failed to identify the deficient conditions.
2 Corrective Steos Taken and Results Achieved Compensatory officers were initially posted in both areas until temporary lighting could be placed.
After lighting was in place, each of the affected areas were measured for illumination levels to ensure adequate lighting.
The inoperative light for the LDV was returned to service, which provided the required illumination for the vehicle. Security personnel initiated Security Field Report 0720 97 to document the discrepancy.
3.
Corrective Steps Taken to A"oid Further Violation The lighting survey processes have been modified to use calibrated light meters to assure luminance in accordance with Security Plan-requirements if questionable areas of light intensity are identified.
The surveys will continue to be annotated in the patrol journals.
4 to TXX 97217 Page 3 of 3 3.
Corrective Steps Taken to Avoid Further Violation (cont.)
Additional light surveys may be conducted per the direction of the Security Shift Supervisor if deemed necessary.
The Security staff has been sensitized to the cause of, and corrective actions for this notice of violation.
4.
Date of Full Compliance TV Electric is in full compliance at this time.
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