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| {{Adams
| | #REDIRECT [[IR 05000445/1997019]] |
| | number = ML20216A876
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| | issue date = 03/10/1998
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| | title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-445/97-19 & 50-446/97-19 Issued on 980116.Implementation of Corrective Actions Will Be Reviewed During Future Inspections
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| | author name = Murray B
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| | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
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| | addressee name = Terry C
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| | addressee affiliation = TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC)
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| | docket = 05000445, 05000446
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| | license number =
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| | contact person =
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| | document report number = 50-445-97-19, 50-446-97-19, EA-97-468, NUDOCS 9803120354
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| | title reference date = 02-16-1998
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| | document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
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| | page count = 4
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| }}
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| See also: [[see also::IR 05000445/1997019]]
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| | |
| =Text=
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| {{#Wiki_filter:'
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| UNITED STATES
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| NUCLEAR REGULATORY COMMISSION i
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| 5 j REGION IV f
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| $ g 611 HYAN PLAZA DRIVE, SulTE 400 {
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| art.INGiON, TEXAS 76011 4064 j
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| %,***** ,d
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| March 10, 1998
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| ' EA 97-468
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| Mr. C. L. Terry
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| TU Electric
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| Group Vice President, Nuclear
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| ATTN: Regulatory Affairs Department
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| P.O. Box 1002
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| Glen Rose, Texas 76043
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| SUBJECT: NRC INSPECTION REPORT 50-445/97-19; 50-446/97-19
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| Dear Mr. Terry: ,
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| I
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| Thank you for your letter of February 16,1998, in response to our January 16,1998, I
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| letter and Notice of Violation conceming changes to your emergency plan. We have reviewed
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| your reply and find it responsive to the concems raised in our Notice of Violation. We will review
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| the implementation of your corrective actions during a future inspection to determine that full j
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| compliance has been achieved and will be maintained. i
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| l
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| Sincerely, {
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| Blaine Murray, Chief
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| l'j
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| Plant Support Branch
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| Division of Reactor Safety
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| Docket Nos.: 50-445;50-446
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| License Nos.: NPF-87; NPF-89
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| cc:
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| Mr. R4er D. Walker
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| TU Electric
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| Regulatory Affairs Manager
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| '
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| P.O. Box 1002
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| Glen Rose, Texas 76043
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| b!!{ !{!lllk!b,!!{l h!!!
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| 9803120354 980310
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| POR ADOCK 05000445
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| G PDR
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| *
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| ,
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| ,
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| TU Electric -2-
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| Juanita Ellis
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| President- CASE
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| 1426 South Polk Street
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| Dallas, Texas 75224
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| TU Electric
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| Bethesda Licensing
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| '
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| 3 Metro Center, Suite 610
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| Bethesda, Maryland 20814
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| l
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| George L. Edgar, Esq.
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| Morgan, Lewis & Bockius
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| 1800 M. Street, NW
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| Washington, D.C. 20036
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| G. R. Bynog, Program Manager /
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| Chief Inspector
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| Texas Department of Licensing & Regulation
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| Boiler Division
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| P.O. Box 12157, Capitol Station
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| Austin, Texas 78711
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| Honorable Dale McPherson
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| County Judge
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| P.O. Box 851
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| Glen Rose, Texas 76043
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| Texas Radiation Control Program Director
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| 1100 West 49th Street
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| Austin, Texas 78756
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| John Howard, Director
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| Environmental and Natural Resources Policy
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| Omce of the Governor
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| P.O. Box 12428
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| Austin, Texas 78711
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| *
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| 9
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| ,~
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| f
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| TU Electric -3-
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| DISTRIBUTION w/coov of licensee's letter dated February 16.1998:
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| DCD (IE35) l
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| Regional Administrator I
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| CP Resident inspector (2)
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| DRS Director
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| DRS Deputy Director
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| DRP Director i
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| DRS-PSB
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| Branch Chief (DRP/A)
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| Project Engineer (DRP/A)
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| Branch Chief (DRP/TSS)
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| MIS System
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| RIV File
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| Action item File (Goines) (98-G-41 )
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| .
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| DOCUMENT NAME: R:\_CPSES\CP719AK.GMG
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| To receive copy of document, indicate in box: "C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy
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| RIV:PSB E C:DRS\PSBn
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| GMGood:nh (,M(y BMurray JJ
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| OE/1/98 pfD98
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| 3 j' OFFICIAL RECORD COPY
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| .
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| ' 1
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| i
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| c 1
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| TU Electric -3-
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| DISTRIBUTION w/cooy of licensee's letter dated February 16.1998:
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| DCD (IE35)
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| Regional Administrator
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| CP Resident inspector (2)
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| DRS Director
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| DRS Deputy Director
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| DRP Director !
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| - DRS-PSB
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| Branch Chief (DRP/A) '
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| Project Engineer (DRP/A)
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| Branch Chief (DRP/TSS)
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| MIS System ,
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| RIV File i
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| Action item File (Goines) (98-G-41 ) - l
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| !
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| .
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| 1
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| i
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| l
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| DOCUMENT NAME: R:\_CPSES\CP719AK.GMG
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| To receive copy of document, Indicate in box: "C" = Copy without endosures "E" = Copy with enclosures "N" = No copy
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| RIV:PSB E C:DRS\PSB,. 1
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| GMGood:nh @@ BMurray i)
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| DE/2/98 pfD98
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| 3 j' OFFICIAL RECORD COPY
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| .
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| O
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| 4
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| . .
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| Log # TXX 98030
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| f. FFBIO.
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| .=
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| C
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| File # 10130
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| IR 97-19
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| Ref. # 10CFR2.201
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| . - -
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| { 7UELECTRIC
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| ~__f
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| }G[C 1
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| c.s m nery February 16, 1998
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| se,%m
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| & PrincipalNuciant Oficer
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| U. S. Nuclear Regulatory Commission
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| Attn: Document Control Desk
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| Washington, DC 20555
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| SUBJECT: COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
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| DOCKET NOS. 50 445 AND 50-446
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| NRC INSPECTION REPORT NOS. 50-445/97-19 AND 50 446/97 19
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| RESPONSE TO NOTICE OF VIOLATION
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| Gentlemen:
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| TU Electric has reviewed the NRC's post Enforcement Conference letter
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| dated January 16, 1998, concerning the subject inspection conducted
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| during the period of September 22 25, 1997. Attached to the letter was a
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| Notice of Violation.
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| TU Electric hereby responds to the Notice of Violation in the attachment
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| to this letter.
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| Additionally. TV Electric has completed an independent review of the CPSES
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| Emergency Plan as committed in TU Electric's letter TXX 97211 to the NRC
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| dated September 26, 1997. The results of this review have been documented
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| and are available onsite for your review.
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| Since y,
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| f!
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| C. L. Ter y
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| CLW/c1w
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| Attachment
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| l
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| c- E. W. Henchoff. Region-IV
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| J. I. Tapia. Region IV
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| T. J. Polich. NRR
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| Resident Inspectors. CPSES
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| i
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| 98-0820
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| COMANCHE PEAK STEAM E1.ECTRIC STATION
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| P.O. Boa 1002 Glen Rme. Texas 76043 1002
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| Attachment to TXX-98030
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| Page 1 of 5
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| RESPONSE TO NOTICE OF VIOLATION
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| RESTATEMENT OF VIOLATION A
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| (445:446/EA 97-468)
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| A. 10 CFR 50.54(q) requires-licensees to follow and maintain in effect.
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| an emergency plan which meets the standards in 50.47(b) and the
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| 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
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| changes do not decrease the effectiveness of the plan and the plan,
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| as changed, continues to meet 50.47(b) planning standards and
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| Appendix E requirements.
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| 10 CFR 50.47(b)(2) requires. in part, that the onsite e:sergency
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| response plan must meet the standard of providing that adequate
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| staffing for initial facility accident response in key functional
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| areas be maintained at all times, and timely augmentation of
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| response capabilities is available.
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| Contrary to these requirements, on October 29, 1996, the licensee
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| made changes to its emergency plan, without Commission approval,
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| that decreased the effectiveness of the plan and did not continue to
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| meet Planning Standard 50.47(b)(2). Specifically. on shift and
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| augmentation capabilities were reduced as follows:
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| o Adequate staffing for initial response in key functional areas
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| was not maintained when the emergency response organization no ,
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| longer included a dedicated communicator to perform offsite
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| agency notifications. l
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| o Timely augmentation of response capabilities was not available
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| when two 40 minute responders, to help the shift technical
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| advisor perform dose assessment and engineering tasks, were l
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| -
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| deleted.
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| o Timely augmentation of response capabilities was not available
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| when one 40 minute responder. to perform offsite monitoring. !
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| was deleted. As a result, offsite monitoring capabilities
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| would be delayed until the 70 minute responders arrived, since
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| on shift resources were not sufficient to perform the
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| monitoring (according to the licensee).
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| o Timely augmentation of response capabilities was not available
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| when five 40 minute responders to help perform station
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| surveys, team coverage, onsite surveys, access control, ;
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| personnel monitoring, and dosimetry were deleted. l
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| Attachment to TXX 98030
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| Page 2 of 5
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| RESPONSE TO V70LATION A
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| (445:446/EA 97-468)
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| TU Electric ' accepts the violation.
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| 1. Reason for Violation:
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| The examples cited In Violation A represent changes which say be perceived
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| as reductions in capability but are changes which TU Electric concluded
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| did not represent a reduction in the effectiveness of the CPSES Energency
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| Plan. TU Electric also concluded that these changes as incorporated-into
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| the CPSES Emergency Plan. Revision 25, continued to be compliant with the
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| standards of 10 CFR 50.47(b) concerning adequate onshift and timely
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| - avgsentation staffing capabilities. The examples cited were either offset
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| by changes that increased the total onshift staffing levels, or were
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| -similar to other plan changes that had previously been justified,
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| proposed, accepted and/or implemented by other licensees. A detailed
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| explanation of TU Electric's conclusions regarding the cited changes is
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| documented in NRC letter dated November 5.1997. "Predecisional
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| Enforcement Conference Summary."
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| 2. Corrective actions taken:
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| Following inspection 445/446 97-19 conducted September 22 25, 1997
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| TU Electric consitted in letter TXX-97211 dated September 26, 1997, to
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| promptly revise the CPSES Emergency Plan. Revision 25. and include
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| corrective actions with respect to Table 1.1 " Staffing Requirements For
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| Emergencies." In the interim period prior to revising the plan. TV
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| Electric implemented insediate corrective actions to provide emergency
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| response augmentation staffing levels consensurate with those levels that
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| had previously been committed to in Table.l.1 of CPSES Emergency Plan.
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| Revision 24. The insediate corrective actions taken regarding onshift and
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| augmentation staffing are identified in letter TXX 97211.
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| Subsequent 1r TU Electric revised the CPSES Energency Plan. Table 1.1 in
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| Revision 2f which became effective October 15. 1997. Revision 26 was
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| submitted to the NRC by TU Electric letter TXX 97225 dated October 22.
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| 1997. Changes incorporated into Table 1.1 of the CPSES Emergency Plan.
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| Revision 26. address the cited issues and meet the expectations conveyed
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| in NRC Inspection Report No. 50 445/97-19: 50 446/97 19.
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| 3. . Steps to prevent recurrence:
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| TU Electric has reviewed the CPSES policy. program and available industry
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| guidance for making changes to the CPSES Emergency Plan under the
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| provisions of 10 CFR 50.54(q). The results of this review, including
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| recommendations for improvement, have been docur;ented and are available
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| onsite for review.
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| Tlj Electric intends to consider the expectations conveyed in NRC
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| Inspection Report No. 50 445/97 19: 50 446/97 19. NRC actions regarding
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| Attachment to TXX 98030
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| Page 3 of 5
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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. ;
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| 4. Date when full compliance achieved:
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| '
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| TU Electric is in full compliance. Corrective actions to address the cited
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| examples were completed October 15, 1997, in association with the i
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| effective date of the CPSES Emergency Plan. Revision 26.
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| RESTATEMENT OF VIOLATION B
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| (445:446/EA 468)
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| B. 10 CFR 50.54(q) requires licensees to follow and maintain in effect
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| an emergency plan which meets the standards in 50.47(b) and the
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| requirements of Appendix E to Part 50. Licensees are permitted to '
| |
| make changes to the plan without Commission approval only if the
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| changes do not decrease the effectiveness of the plan and the plan.
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| as changed, continues to meet 50.47(b) planning standards and
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| Appendix E requirements.
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| 10 CFR 50.47(b)(2) requires. in part, that the onsite emergency
| |
| response plan must meet the standard of providing that facility
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| 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. j
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| 10 CFR Part 50. Appendix E.IV.A requires that emergency plans
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| describe the organization for coping with radiological emergencies. l
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| including definition of authorities, responsibilities, and duties of l
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| individuals assigned to the emergency organization. ]
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| 10 CFR Part 50. Appendix E.IV.F.1 requires that emergency plans
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| describe the specialized training and retraining programs for
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| certain categories of emergency response personnel. including fire
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| brigade members and security personnel.
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| 10 CFR Part 50. Appendix E.IV.A.8 requires that emergency plans
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| identify the state and/or local officials who would order protective
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| actions.
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| Contrary to these requirements, on October 29, 1996, the licensee
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| made the following changes to its emergency plan without Commission
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| approval that did not continue to meet Planning Standard ,
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| 50.47.(b)(2), or the requirements of Appendix E.
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| I
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| 1. Changes involving the description of emergency response l
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| organization members did not continue to meet Planning l
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| '
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| Standard 50.47(b)(2) and Appendix E.IV.A requirements.
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| Specifically. the description and responsibilities of the l
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| Attachment to TXX 98030
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| Page 4 of 5
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| following four emergency response organization positions were
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| deleted from Revision 25 but remained on the organization i
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| chart and emergency response organization call out roster: a) ,
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| emergency operations facility radiation assessment i
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| coordin9 tor. b) technical support center operations
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| coordinator, c) operations advisor, and d) supporting staff
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| for the logistical support coordinator. l
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| 2. Changes involving the description of the emergency response
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| organization training program did not continue to meet
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| Appendix E.IV.F.1 requirements. Specifically, the description
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| of the fire brigade and security training programs were i
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| deleted from Revision 25,
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| 3. Changes involving the description of offsite decision makers
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| did not continue to meet Appendix E.IV.A.8 requirements.
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| Specifically, the identification of the offsite protective
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| action decision makers for the ingestion pathway zone was
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| deleted frca Revision 25 to the plan.
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| RESPONSE TO VIOLATION B
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| (445:446/EA 97 468)
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| TU Electric accepts the violation. i
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| 1. Reason for Violation:
| |
| TU Electric evaluated cited changes 1 and 2 above and concluded that they
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| were consistent with TV Electric's understanding of the regulations. This i
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| !
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| conclusion was based in part, on previous NRC acceptance in SSER 22 of a
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| similar level of detail in the plan's emergency organization description
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| and that training requirements were globally defined in plan sections 1
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| 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
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| identification of the subject offsite protective action decision maker for
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| the ingestion pathway zone.
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| 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
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| 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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| 1
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| Attachment to 110C-98030 {
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| Pa9e 5 of 5 l
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| 1
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| the fire brigade and security. These changes revise the CPSES Emergency l
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| Plan to meet'the expectations conveyed in NRC Inspection Report No. 50- !
| |
| 445/97 19: 50 446/97 19. q
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| l
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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 i
| |
| emergency planning at other licensees, and any related future guidance j
| |
| '
| |
| published by the NRC prior to making changes to the CPSES Emergency Plan
| |
| 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 i
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| effective date of the CPSES Emergency Plan, Revision 26.
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| }}
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