ML20216A876
| ML20216A876 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 03/10/1998 |
| From: | Murray B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Terry C TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| References | |
| 50-445-97-19, 50-446-97-19, EA-97-468, NUDOCS 9803120354 | |
| Download: ML20216A876 (4) | |
See also: IR 05000445/1997019
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION IV
611 HYAN PLAZA DRIVE, SulTE 400
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art.INGiON, TEXAS 76011 4064
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March 10, 1998
' 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: NRC INSPECTION REPORT 50-445/97-19; 50-446/97-19
Dear Mr. Terry:
,
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Thank you for your letter of February 16,1998, in response to our January 16,1998,
letter and Notice of Violation conceming changes to your emergency plan. We have reviewed
your reply and find it responsive to the concems raised in our Notice of Violation. We will review
the implementation of your corrective actions during a future inspection to determine that full
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compliance has been achieved and will be maintained.
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Sincerely,
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Blaine Murray, Chief
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Plant Support Branch
Division of Reactor Safety
Docket Nos.: 50-445;50-446
cc:
Mr. R4er D. Walker
TU Electric
Regulatory Affairs Manager
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P.O. Box 1002
Glen Rose, Texas 76043
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9803120354 980310
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TU Electric
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Juanita Ellis
President- CASE
1426 South Polk Street
Dallas, Texas 75224
TU Electric
Bethesda Licensing
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3 Metro Center, Suite 610
Bethesda, Maryland 20814
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George L. Edgar, Esq.
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
Honorable Dale McPherson
County Judge
P.O. Box 851
Glen Rose, Texas 76043
Texas Radiation Control Program Director
1100 West 49th Street
John Howard, Director
Environmental and Natural Resources Policy
Omce of the Governor
P.O. Box 12428
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TU Electric
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DISTRIBUTION w/coov of licensee's letter dated February 16.1998:
DCD (IE35)
Regional Administrator
CP Resident inspector (2)
DRS Director
DRS Deputy Director
DRP Director
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DRS-PSB
Branch Chief (DRP/A)
Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
MIS System
RIV File
Action item File (Goines) (98-G-41 )
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DOCUMENT NAME: R:\\_CPSES\\CP719AK.GMG
To receive copy of document, indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy
RIV:PSB
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C:DRS\\PSBn
GMGood:nh (,M(y BMurray JJ
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OFFICIAL RECORD COPY
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TU Electric
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DISTRIBUTION w/cooy of licensee's letter dated February 16.1998:
DCD (IE35)
Regional Administrator
CP Resident inspector (2)
DRS Director
DRS Deputy Director
DRP Director
- DRS-PSB
Branch Chief (DRP/A)
'
Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
MIS System
,
RIV File
Action item File (Goines) (98-G-41 ) -
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DOCUMENT NAME: R:\\_CPSES\\CP719AK.GMG
To receive copy of document, Indicate in box: "C" = Copy without endosures "E" = Copy with enclosures "N" = No copy
RIV:PSB
E
C:DRS\\PSB,.
GMGood:nh @@ BMurray i)
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OFFICIAL RECORD COPY
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Log # TXX 98030
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File # 10130
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IR 97-19
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Ref. # 10CFR2.201
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February 16, 1998
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& PrincipalNuciant Oficer
U. S. Nuclear Regulatory Commission
Attn: Document Control Desk
Washington, DC 20555
SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50 445 AND 50-446
NRC INSPECTION REPORT NOS. 50-445/97-19 AND 50 446/97 19
RESPONSE TO NOTICE OF VIOLATION
Gentlemen:
TU Electric has reviewed the NRC's post Enforcement Conference letter
dated January 16, 1998, concerning the subject inspection conducted
during the period of September 22 25, 1997. Attached to the letter was a
TU Electric hereby responds to the Notice of Violation in the attachment
to this letter.
Additionally. TV Electric has completed an independent review of the CPSES
Emergency Plan as committed in TU 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.
Since
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C. L. Ter y
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Attachment
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E. W. Henchoff. Region-IV
J. I. Tapia. Region IV
T. J. Polich. NRR
Resident Inspectors. CPSES
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98-0820
COMANCHE PEAK STEAM E1.ECTRIC STATION
P.O. Boa 1002 Glen Rme. Texas 76043 1002
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Attachment to TXX-98030
Page 1 of 5
RESPONSE TO NOTICE OF VIOLATION
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 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 e:sergency
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 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 effectiveness 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:
Adequate staffing for initial response in key functional areas
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was not maintained when the emergency response organization no ,
longer included a dedicated communicator to perform offsite
agency notifications.
Timely augmentation of response capabilities was not available
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when two 40 minute responders, to help the shift technical
advisor perform dose assessment and engineering tasks, were
deleted.
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Timely augmentation of response capabilities was not available
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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).
Timely augmentation of response capabilities was not available
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when five 40 minute responders to help perform station
surveys, team coverage, onsite surveys, access control,
personnel monitoring, and dosimetry were deleted.
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Attachment to TXX 98030
Page 2 of 5
RESPONSE TO V70LATION A
(445:446/EA 97-468)
TU Electric ' accepts the violation.
1.
Reason for Violation:
The examples cited In Violation A represent changes which say be perceived
as reductions in capability but are changes which TU Electric concluded
did not represent a reduction in the effectiveness of the CPSES Energency
Plan.
TU Electric also concluded that these changes as incorporated-into
the CPSES Emergency Plan. Revision 25, continued to be compliant with the
standards of 10 CFR 50.47(b) concerning adequate onshift and timely
- avgsentation 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 implemented by other licensees. A detailed
explanation of TU Electric's conclusions regarding the cited changes is
documented in NRC letter dated November 5.1997. "Predecisional
Enforcement Conference Summary."
2.
Corrective actions taken:
Following inspection 445/446 97-19 conducted September 22 25, 1997
TU Electric consitted 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. TV
Electric implemented insediate corrective actions to provide emergency
response augmentation staffing levels consensurate with those levels that
had previously been committed to in Table.l.1 of CPSES Emergency Plan.
Revision 24. The insediate corrective actions taken regarding onshift and
augmentation staffing are identified in letter TXX 97211.
Subsequent 1r TU Electric revised the CPSES Energency Plan. Table 1.1 in
Revision 2f which became effective October 15. 1997. Revision 26 was
submitted to the NRC by TU Electric letter TXX 97225 dated October 22.
1997. Changes incorporated into Table 1.1 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 docur;ented and are available
onsite for review.
Tlj Electric intends to consider the expectations conveyed in NRC
Inspection Report No. 50 445/97 19: 50 446/97 19. NRC actions regarding
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Attachment to TXX 98030
Page 3 of 5
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 approval.
4.
Date when full compliance achieved:
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TU Electric is in full compliance. Corrective actions to address the cited
examples were completed October 15, 1997, in association with the
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effective date of the CPSES Emergency Plan. Revision 26.
RESTATEMENT 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
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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
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1s available.
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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.
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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 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 licensee
made the following changes to its emergency plan without Commission
approval that did not continue to meet Planning Standard
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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
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Standard 50.47(b)(2) and Appendix E.IV.A requirements.
Specifically. the description and responsibilities of the
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Attachment to TXX 98030
Page 4 of 5
following four emergency response organization positions were
deleted from Revision 25 but remained on the organization
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chart and emergency response organization call out roster: a)
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emergency operations facility radiation assessment
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coordin9 tor. 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.IV.F.1 requirements.
Specifically, the description
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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 frca Revision 25 to the plan.
RESPONSE TO VIOLATION B
(445:446/EA 97 468)
TU Electric accepts the violation.
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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
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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 ressectively. A detailed explanation of TU 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:
TU 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 Electcic 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
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Attachment to 110C-98030
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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.
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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
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emergency planning at other licensees, and any related future guidance
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published by the NRC prior to making changes to the CPSES Emergency Plan
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without prior NRC approval.
TV Electric considers the administrative error associated with cited
change 3 to be an isolated case. This error and management expectations
on self checking have been discussed with appropriate personnel.
4.
Date when full compliance achieved:
TU Electric is in full compliance.
Corrective actions to address the
cited changes were completed October 15, 1997, in association with the
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effective date of the CPSES Emergency Plan, Revision 26.
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