View source for TXX-9309, Responds to NRC Re Violations Noted in Insp Repts 50-445/92-50 & 50-446/92-50.Corrective Actions:Mgt Issued an Instructional Directive Stressing Need to Comply W/ Procedural Guidance Re Behavioral Observation Training

{{Adams
| number = ML20128N450
| issue date = 02/18/1993
| title = Responds to NRC Re Violations Noted in Insp Repts 50-445/92-50 & 50-446/92-50.Corrective Actions:Mgt Issued an Instructional Directive Stressing Need to Comply W/ Procedural Guidance Re Behavioral Observation Training
| author name = Cahill W
| author affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000445, 05000446
| license number = 
| contact person = 
| document report number = TXX-93092, NUDOCS 9302230240
| title reference date = 01-20-1993
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 3
}}

=Text=
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February 18, 1993 Group Vice President U. S. Nuclear Regulatory Commission Attn:
Document Control Desk Washington, DC 20555

==SUBJECT:==
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NCS. 50-445 AND 50-446 NRC INSPECTION REPORT NO. 50-445/9250; 50-446/9250 RESPONSE TO NOTICE OF VIOLATION REF:
TV Electric letter logged TXX-93088 from W. J. Cahill, Jr., to NRC dated February 10, 1993 Gentlemen:
TV Electric has reviewed the NRC's {{letter dated|date=January 20, 1993|text=letter dated January 20, 1993}}, concerning the inspection period of October 22 through December 18, 1992. This inspection covered activities authorized by the NRC operating license NPF-87 and construction permit CPPR-127. Attached to the {{letter dated|date=January 20, 1993|text=January 20, 1993, letter}} was a Notice of Violation (NOV).
TV Electric hereby responds to the Notice of Violation (445/9?50-04) in the attachment to this letter.
Sincerely, 8
William J. Cahill, Jr.
NSH/tg Attachment c-Mr. J. L. Milhoan, Region IV Mr. L. A. Yandell, Region IV Mr. B. E. Holian, NRR Mr. T. A. Bergman, NRR f(
Resident Inspectors, CPSES (2) i i 90' gSW 220000 40[ sp f
.9302230240 930218
't PDR ADOCK 05000445
\\
Q PDR 400 N. Otive street LB. 81 Dallas, Texas 75201

.=
Attachment to TXX-93092 Page 1 of 2 HQllCE OF VIOLATION 445/9250-04 446/9250-04 License Condition 2.H of the CPSES, Unit 1, facility Operating License states, in part, "TU Electric shall fully implement and maintain in effect all provisions of the Physical Security Plan... previously approved by the Commission...."
Paragraph 3.1 of the licensee's Physical Security Plan states, in part.
"CPSES has established and maintains an access authorization program with the objective of prov Ming high assurance that the individuals granted unescorted access to
> Protected and Vital Areas are trustworthy and reliable and do not pa e a threat to commit radiological sabotage.
In order to evaluate eligibility and support the above requirements, the access authorization program complies with the following: 10 CFR 73.56, Regulatory Guide 5.66, and 10 CFR 26."
10 CFR 26.22(a)(4) and 73.56(b)(2)(i) require, in part, that licensees train supervisory personnel in behavioral observation techniques for detecting degradation of performance, impairment, and changes in employee behavior which, if left unattended, could lead to acts detrimental to public health and safety.
Licensee Procedure STA-910, paragraph 6.1.1, states that all TV and contractor employee supervisors shall receive initial and annual recurring training in behavioral observation.
Contrary to the above, on October 27, 1992, it was determined that 20 contractor supervisors had not received initial behavior observation training and that 21 contractor supervisors had not received annual recurring behavior observation training.
ESP 0 HSE TO NOTICE _OF VIOLATION (445/9250-04)
(446/9250-04)
TU Electric accepts the violation and the requested information follows:
1.
Reason for the Violation A review of procedures, associated records and the relevant computer data base was performed by TU Electric. This review concluded that anomalies in the computer coding caused some supervisors who had received initial behavior observation training to be dropped from annual 2

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9 Attachment to TXX-93092 Page 2 of 2 requalification training. Additionally, the rapid management changes in the Unit 2 organizations which were a result of_ destaffing as Unit 2 construction completion was achieved, contributed to this_ condition.
2.
Corrective Steps Taken and Results Achieved Upon discovery of these issues a deficiency document was issued to document the cause and corrective actions. Additionally, TV Electric has conducted special training sessions for the supervisors and managers (including foremen and general foremen), who had not previously received behavioral observation training and/or who had not received requalification training.
3.
Corrective Steos Taken to Avoid Recurrence TV Electric management issued an instructional directive stressing the need to comply with procedural guidance regarding behavioral observation training and requalification.
Moreover, referenced letter to the NRC provided detail of management actions regarding Fitness for Duty.
4.
Date When Full Compliance Will be Achieved TV Electric is in full compliance.}}