IR 05000272/1980012
| ML18085A355 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 05/23/1980 |
| From: | Brunner E, Devlin J, Martin W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML18085A354 | List: |
| References | |
| 50-272-80-12, NUDOCS 8012090545 | |
| Download: ML18085A355 (5) | |
Text
\\~
.*
/\\'
.. e U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report N /80-12 Docket N '---'--
Safeguards Group
><.
License N DPR-70 Priority ----
Category C *.
---
Licensee:
Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101 Facility Name:
Salem Nuclear Gene-rating Station, Unit No. 1 Meeting At:
Salem Nuclear Generating Station Meeting Conducted: __ A_.p_r_i_l _1_8""",_19_8_0 _____________ _
Type of Meeting:
Enforceme
,,..--,
~---------------___,._
Ins pee to rs ~-*-,;< :;;:_:-~'-'"'-'!~=:-.....,;-~-=,-.,--=----=--.....,....,--..--=-
J es W. Devlin, Chief, Security and Investigation Section, Safeguards Branch
/)
.
El n J. Brunner, Chief, Reactor Operations and Nuclear Support Branch Approved by: ~~-c-~-'----.,._...;;-Jd.....,,.~,......,-,___.~-**-'t'"""'-_* _" __
Walter G. Martin, Chief, Safeguards Branch Meeting Summary:
sfa3~
ciate Enforcement Meeting April 18, 1980 (Meeting Report Number 50-272/80-12)
A mandated meeting was held with the licensee pursuant to an Order Modifying License Effective Immediately to discuss, inter alia, the adoption and imple-mentation of modifications to License No. DPR-70, issued as part of an Enforce-ment Letter dated March 20, 1980, and proposed corrective action to the items of noncomplianc Also discussed was the Auxiliary Feedwater Pump Discharge Valve prob 1 e Results:
The procedure adopted and implemented in response to the modification in Part III-A of the Order did not meet the requirement of the Order; therefore, from approximately March 20, 1980, date of receipt of the Order, until April 14, 1980, at which time the need for the provisions of the Order were eliminated, the licensee is deemed to have been in apparent noncompliance with the Orde Region I Form 12 (Rev. April 1977)
~
DETAILS
- Attendees Public Service Electric and Gas Company F. Schneider, Vice President, Production F. P. Librizzi, General Manager, Electric Production H. Heller, Manager, Nuclear Operations H. Midura, Station Manager P. Moeller, Staff Engineer J. M. Zupko, Jr., Chief Engineer T. Lesh, Security Supervisor NRC Region I Office of Inspection and Enforcement B. H. Grier, Director, Region I E. J. Brunner, Chief, Reactor Operations and Nuclear Support Branch L. J. Norrholm, Senior Resident Inspector, Salem J. VJ. Devlin, Chief, Security and Investigation Section, Safeguards Branch Purpose of Meeting Order Modifying License Effective Immediately This meeting was held pursuant to the Order Modifying License Effective Immediately, hereafter referred to as the Order.Section III B of the Order required that 11The licensee shall meet with a senior management official of the Office of Inspection and Enforcement on April 18, 1980.
The purpose of this meeting was to discuss the specific modifi-cations to License No. DPR-70 which required the licensee to implement written security procedures requiring the continuous visual surveillance of all interface doors leading to vital areas in Unit 1; review of existing security procedures and controls and the submission of the written procedures and the results of the review to the Director of Region I by April 18, 198 By letter dated April 16, 1980, with attachment, received at Region I on April 17, 1980, the licensee responded to the Orde Review of Response to Civil Penalties In addition, the licensee 1s proposed corrective actions relative to the four items of noncompliance which constituted the basis for the Notice of Proposed Imposition of Civil Penalties, contained with our letter of March 20, 1980, were reviewe By letter dated April 14, 1980, the licensee responded to the Notice of Violation and it was determined that the proposed corrective actions to Items 1, 2 and 4
..
.*r--;-
', ___... _
appear to be capable of preventing a recurrent of similar items of noncomplianc The response to Item 3 lacked agreement with the intent of Part III-A(l) of the Order Modifying License Effective
. Immediately and is therefore unacceptabl *
It was agreed that since the protected area was extended to include Unit 2, effective April 14, 1980, thereby abolishing the interface between Units 1 and 2, no further or continuing action was required because this item of noncompliance could not recu Use of Extended Compensatory Measures The question of the continued use of compensatory measures in lieu of using equipment in place, but not yet accepted or operating or in lieu of fully implementing procedures was also discussed. It was agreed that all security related systems would be in operation and utilized and all procedures implemented before fuel core loadin The ex-ception to the use of compensatory measures would be during short periods of time when equipment became inoperable due to breakdown or maintenance outag No long term compensatory measures wi 11 be con-sidered without prior approval from the NRC and approval will only be based on acceptable justificatio Auxiliary Feedwater Pump Discharge Valve Also discussed were the circumstances regarding the finding of the Auxiliary Feedwater Pump (#13 Aux Feed) Discharge Valve in the closed position by the Resident Inspector on April 10, 198 It was agreed that the licensee would conduct an investigation into the event because they were not satisfied with the answers found to date, and would submit a written report of their findings. (For complete details concerning this item, Inspection Report 50-272/80-06) Licensee's Response to Item 3 Concerning Patrols o.f Interface Between Units 1 and 2 The licensee acknowledged the item of noncompliance and provided a response by letter dated April 14, 1980 which was compatable and in direct accordance with the Salem Nuclear Generating Station Physical Security Plan, paragraph 3.1.2. However, in view of Part III-A(l) of the Order, which was issued to the licensee by NRC letter dated March 20, 1980 and which also included the Appendix A, Notice of Violation, a new requirement wa.s established. This new requirement cancelled and superseded the above section of the pla The modification to License No. DPR-70 should have been considered in the response to this item of noncomplianc *
4 Licensee's Implementation of the 110rder Modifying License Effective *
Immediately The Order was issued, in addition to the civil penalty, in view of the particular need to prevent unimpeded and undetected access to vital areas of Unit As emphasized in the Order, there were three occurrences of unmanned open doors and openings and other events in the recent past which demonstrated that the licensee had not adopted appropriate controls to assure that unimpeded entry could not be gained into vital areas of Unit In view of this and pursuant to the Atomic*Energy Act of 1954, as amended, and the Commission's regulations to 10 CFR Parts 2 and 50, License N DPR-70 was modified, to have immediate effect, as follows:
11(1) Written Security Procedures shall be adopted and implemented (a) to require continuous visual surveillance of all interface doors leading to vital areas in Unit 1, and (b) to prohibit passage of personnel through the interface barrier except under emergency condition This requirement will exist as long as the interface serves as the only barrier to the vital areas and also applies to any location throughout the facility at which breach of a single barrier will allow unimpeded access to vital area (2) A detailed review of existing security procedures and controls shall be performed to assure that security procedures and controls will not be compromised by maintenance or other activitie (3) A copy of the written security procedures required by paragraph (1)
above and the results of the review required by paragraph (2) above shall be submitted by April 18, 1980, to the Director of NRC 1s Region I office.
By letter dated April 16, 1980, the licensee submitted a response to the Order but failed to respond to Part III-A(l) of the Orde Item 1 of Part III-A, required:
11 (1) Written Security Procedures shall be adopted and implemented, (a) to require continuous visual surveillance of all interface doors leading to the vital areas in Unit 1, and (b) to prohibit passage of personnel through the interface barrier except under emergency conditions....
In explaining the response, the licensee advised that they interpreted 11continuous visual surveillance** to mean a patrol of the Unit 1 - Unit 2 interface at least once every two (2) hours as is stated in Security Post
..1-.* -
'...,.._
- - - * - -
Order #5 11 Foot Patrol of Vital and Protective Area Interface Between Unit No. 1 and No. 2.
11 The licensee agreed that this interpretation was not appropriate if the condition truly meant full time observ.ation of each door or gate in the interfac The licensee stated that they assumed the con-dition would be satisfied if they returned to the original procedure and did not believe that they would be required to supply 11an army of people".
The licensee 1s interpretation was not correct. It was the intent of the order that guards be placed as necessary so that anyone passing through an interface door would be observe In some instances, a guard would be able to watch several doors from one locatio The NRC letter dated March 20, 1980 which transmitted the Notice of Violation, Notice of Proposed Imposition of Civil Penalties and Order Modifying License Effective Immediately specifically stated, 11This Order requires the adoption and implementation of written security procedures requiring the continuous visual surveillance of all interface doors leading to the vital areas in Unit 1;....
This same requirement was stated in the Orde The subject of continuous patrol vs. continuous visual surveillance was considered in the decision to issue the Order modifying the licens It was concluded that a continuous patrol that is by a dedicated individual with no other duties was not effective in light of enforcement history which shows a failure to lock vital area doors and failure to control access to vital areas has occurred on six different occasion The prin-ciple that doors in vital areas must be locked and alarmed, or guarded, is well established, and for doors other than those in the interface area between Units 1 and 2, the accepted security plan contains the same require-men Acknowledgement is made in the security plan that the interface area was less secure in that there was no protected area and thus no second barrier, yet some of the doors in this interface leading directly from the construction area into Unit 1 vital areas were not required to be alarme A continuous patrol of 30 doors in the Turbine and Auxiliary Buildings, which includes the vital area interface doors in the Auxiliary Building, which was the procedure implemented in response to the Order, results in checking each door once every hou When the licensee 1s history of leaving these doors open is considered, it seems apparent that the level of security controlling the interface area is inadequat For these reasons it was concluded that the licensee should be required to provide at least the same security for the interface doors as is required for other doors into vital areas. This would be attained through implementation of the modification of License No. DPR-70 as stated in Part III-A of the Order. *
The failure on the part of the licensee to comply with this modification is considered to be an apparent item of noncompliance, Violation leve The failure to comply with the Order commenced on or about March 20, 1980, or upon receipt of the Order, to April 14, 1980 when, through implementation of new procedures and controls, the protected area was extended to include Unit 2, and thereby negating the necessity to continue the requirements imposed by the Order.