IR 05000295/1989035
| ML20005E711 | |
| Person / Time | |
|---|---|
| Site: | Zion File:ZionSolutions icon.png |
| Issue date: | 12/28/1989 |
| From: | Christoffer G, Creed J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20005E710 | List: |
| References | |
| 50-295-89-35, 50-304-89-31, NUDOCS 9001100169 | |
| Download: ML20005E711 (6) | |
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V ; L..'S. INUC LEARMEGU LATORY COMMI S S I ON i
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,9 iREGION-III-
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50 304'89031(DRSS).-
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Reports: Noi 50-295/89035(DRSS)';t
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. O censesiNo.1DRP 39;;;DRP-48'
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LCommonwealth Edison Company
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Post 0ffice Box 767a
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lChicagotILT60690'.
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iFacility_Name:. Zion. Nuclea'r? Station ~, Units.11and'2'
[InspectionAt: Zion' Station and-NRC~ Region III!0ffice Q'
Inspection:. Conducted: [0ctober13-November 9,1989:
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l Inspector: _
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'-G. M. Christoffer FF
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Physical' Security ~ Inspector ug.c... ;
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R. Leemon Date Resident. Inspector
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- App'ro'ved 'By:
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' J. 'R. Creed, Xhgef Date
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Safeguards-Section.
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Inspection Summary j
. Inspection between October'13 and November 9,-1989 (Reports
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'No. 50-295/89035(DRSS); No. 50-304/89031(DRSS))
- i Areas Reviewed: Licensee's actions regarding damage caused by potential d
~ tampering with a printed Lcircuit board and the potential tampering d
demonstrated ~ by a loose vent plug -on.1LT-502. Rosemount Transmitter.
Results: 'The licensee was in compliance with NRC requirements in the areas
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inspected.
The licensee was responsive to NRC concerns. The licensee's I
- investigation showed that an unknown person intentionally damaged a printed
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. circuit board, which had no effect on plant operation. The loose vent plug
did not represent tampering.
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DETAILS.
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Key-Persons' Contacted
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LIMadditiontothekeymembersofthetlicensee's'stafflistedbelow/
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1the inspectorsLinterviewed other lic'ensee employees and members of.the:
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.securityforganization. = The asterisk (*)- denotes;those presentiduring
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y 1the" telephone'. exit. interview conducted on-November 9,'1989.-
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- R.' Budowle,DServices: Director, CECO
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j T. Joyce, Zion l Station Manager,_. Commonwealth _' Edison' Company (CECO'_
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- W. ' Stone, Regulatory Assurance. Supervisor,- CECO
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>T. : Satsef ski... Regulatory Assurance', CECO!
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.M.HPeterson, Regulatory Assurance, CECO
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. F. Willaford, Corporate Nuclear. Security Administrator,. CECO i
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- R. Smith, Station: Security Administrator,' CECO j
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- J. Gilmore, Quality First, _ CECO
't R. Leemon,' Resident Inspector,.USNRC, Region'III
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- A. M. Bongiovanni, Resident Inspector, USNRC,rRegion:III~
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Entrance' and Exit Interviews (IP 30703)
. At the beginning of the inspection,'Mr._ T. Joyce of the licensee's
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staff was informed of_the purpose of this visit and the functional
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areas to'be examined.
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The' inspector telephonically contacted the licensee representatives
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-denoted in Section 1 at the conclusion of the inspection on
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November 9, 1989. A general description oflthe scope of-the
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inspection was provided. Briefly listed below are the' findings q
discussed during the exit interview. The details of these findings
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are referenced, as noted, in this report.
Included below is a statement' provided by or describing licensee management's response to each finding.
-(1) The licensee acknowledged the inspector's comments that NRC Region III ;oncurred with the licensee's conclusion that the unprotected printed circuit board was intentionally cut but that there was no evidence to indicate any malicious attempt to affect safe plant operations.
(2) The licensee acknowledged the inspector's comments that NRC Region III concurred with the licensee's conclusion that the loose vent plug did not occur as a result of equipment
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tampering, but that it could probably have been caused by previous improper maintenance or normal operations activities.
We also concurred with their decision to retract the one hour telephone call to the NRC regarding this event.
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l(3)fTheElicensee:acknowledgedthe! inspector'scommentsthat-the
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glicensee took~ measures to increase; security awareness after:
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Lthe security department became aware'of the.two events.
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.(Refer;to Section 3)
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'(4)' The licensee acknowledged.the inspector's comments that the.
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licensee's. investigation of.the' events'could have been_improvedi
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by-broadening the scope of the-investigation.
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- Section_3),
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3.
M'anagement Effectiveness (IP 81020)
On^0ctober 6, 1989,~the licensee made a one hour report to the NRC y
<regarding:the discovery of a damaged Rosemount printed circuit board
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.which was thought to have been caused by tampering,. The circuit board'
was unsecured-and located on a maintenance.~ cart on the=568' level of Unit 1' containment.
It was approximately four inches in diameter and cut
in two places..The board was-used to test.the Rosemount Transmitters in Unit'l_ containment _during'the previous several days at the 568' level and-
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f was observed.'as bei.ng' undamaged at approximately~3:00 p.m; on October 5,--
F-1989, at which time'it was left in a plastic. bag'on the maintenance cart.
.The damaged circuit board was found on October 6, 1989, at approximately 9:00 a.m. by the Instrument Maintenance-(IM) Technician that was working 1.
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The board was not safety-related equipment and it was not
. going to be installed permanently.
The licensee's immediate corrective action was to remove the test circuit-board and begin an investigation. They collected access control and-radiation records to determine who was in the 568' level area during the time that the board could have been damaged. -Three days later, a list
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was compiled of seven contractor health physics personnel who were
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working in the area in which the board was located. Those individuals were interviewed by the Station Security Administrator (SSA) and the Corporate Security Director to_ determine if they had information that might-be relevant to the circumstances surrounding the incident. The results of the interviews indicated that no one admitted knowing who damaged the board or when it occurred.
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The next day, the circuit board was sent to a forensic test lab for analysis to determine what kind of equipment was used to damage the board. The test results received on October 11, 1989, indicated that t
the board was cut with a pair of wire -cutters, similar to those found next to the circuit board on the :M cart.
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Additionally on the same day, the Quality Assurance (QA) personnel were instructed to watch for signs of tampering in containment or other areas of the plant.
QA conducted an inspectic of containment and observed no damage. The security firewatch patrol in containment was instructed to be observant for suspicious activities or equipment tampering.
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m lAs.a~ result:of the; interview and test results-of-the previous day, a.one
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' hour! report was'made on October 12.,'1989, to the NRC regarding potential-
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b tampering.with the 1LT-502 Rosemount transmitter vent' plug. ' The
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" significance, of this'information was that-the plug was located five 'to N
eight feet from-the cut circuit board, i
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That'samelday,:the-li.censee discussed the two incidents at a meeting,
=between CECO and c'ontractor supervisors. The supervisors were told to s
inform theirL personnel of; the inciden.ts. l All contractor employees were J
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' asked to provide-any information that might be relevant'to the
circumstances surrounding the-incidents.. Also, a second security patrol;
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was assigned inside containment to watch for' equipment: tampering.
Corporate security management' determined that' ten percent of the. individuals that were in containment during the time'the'b'oard was damaged should be?
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interviewed..This resulted in corporate security investigators conducting interviews of 31 out of 293 p'ersons. At.this time,:the licensee-
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interviewed only those IM persons who.were in' containment during the time in question. The. interviews resulted in no additional information. The i
interview results' indicated-that no one. admitted-knowledge of who had caused the-damage 'to the circuit board or loosened the vent plug'. The-i licensee concluded that an unknown person' cut the circuit board for unknownLreasons.
On the same day, the licensee nanagement representative-
and the NRC inspectors discussed the licensee's actions regarding the situation. The plant manger.made the decision to have a walkdown conducted'
of Unit 1 containment.
During the backshift on October 13, 1989, IM personnel performed a walkdown of.the southeast.and southwest quadrants of the 568' level of Unit 1 containment to check instruments for damage or leakage. No
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evidence of tampering was discovered during this walkdown.
On October 16,19L9, the corporate security representative detailed to Zion'became involved in the investigation and the licensee began research on the maintenance history ~for Rosemount transmitters.
On October 17, 1989, a computer printout was obtained of the maintenance history on the Rosemount transmitters installed in Unit I containment. Work request (Z85690) for work that had been done on ILT-502 on September 21, 1989, was reviewed. The three individuals identified with the work request were interviewed, i.e', the IM technician that performed the' work, the IM foreman who supervised the technician, and the Quality Control (QC)
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inspector who reviewed the work request package.
The investigation activity finally revealed that the Rosemount transmitter ILT-502 was worked on September 21, 1989.
The work request was to investigate the cause of a high reading and determine if the problem was the transmitter or electronic. The IM technician observed water (a puddle the size of a quarter) standing on the top of ILT-502, around the vent plug.
He did not observe an actual leak and believed that the water had fallen on top of the transmitter from a source above.
He documented this information on the procedure and discussed it with his foreman.
No further action was takan by the foreman or the QC inspector that reviewed the work request package. The technician did not touch the vent plug because it was not required as part of the work performed.
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4 i 0n? ctober?l8,2;1989,3 the licensee obtained a-copy of the Visual Leak
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LExaminatio'n. of Class.I Components -(Reactor Coolant: System Leak Test),
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- TSS/15.G.21, Revision 4i 0ctober-19,~1988.
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'on SeptemberJ7,1989,Lto..look-specifically at ASME' Class 1 Componentsi
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(Reactor Coolant' System), however, any unusual conditions observed,.
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such as-a11eak, on any system or! equipment would have been noted and E-maintenance scheduled.
There was no evidence'of leakage:noted in:this. report concerning)the Rosemount Level Transmitters.
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On.0ctober 18, 1989, the licensee cancelled'the requirement'for'one of l'
s" the-two; security: officers'that.had been assigned,to patrollin Unit;1-containment.
p On.0ctober 23, 1989, the~ security representatives received an evaluation of the~~1LT-502. vent plug, conducted by the TechnicalzStaff/ Electrical.
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Group. The evaluation:was.that a typical: vent plug on the Rosemount_
Transmitter that was tightened " finger-tight," in good condition, with
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no dirt or corrosion products fouling the seating: surfaces,!has a
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g reasonable probability of having a leak rate below the level necessary to.
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influen:e transmitter performance.
~The licensee concluded that the loose vent plug on ILT-502,. Rosemount
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Transmitter was not caused by equipment tampering.
It could have been,
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caused by previous improper' maintenance. There is.information to support
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the: position that the vent plug was only " finger tight" at the time
.l of unit shutdown. --Water was observed around the vent plug during.
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maintenance on September 21, 1989,- which was an indication of a leak at that time. -The amount of water observed on. September 21 and October 2-3, 1989,'was described as a puddle the size of-a quarter. There were~enough
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= corrosion products on top of the transmitter and supporting bracket to
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support the position that water had been present for.an extended period of time'.
Additionally, the evaluation conducted by the Technical Staff supports the position that the system could have sustained a leak rate consistent with a " finger tight" vent plug without influencing the
. transmitter performance.
f On October 24, 1989, the licensee retracted the one hour report,regarding potential tampering of the ILT-502 vent plug.
On October 26, 1989, IM personnel were instructed not to leave safety
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related or environmental qualified (EQ) parts unattended and unsecured in
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the plant.
This action was taken to prevent a similar recurrence of the cut circuit board.
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NRC Evaluation On October 13, 1989, a regional security inspector was dispatched to the site to evaluate and monitor the licensee's investigation of the two events and management's involvement in the situation. The regional
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inspector was assisted by the resident inspector during this inspection.
- Additional, the security inspector monitored the licensee's activities in office on a daily basis.
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- As a result of a combined evaluationiby members of.the' Division-of' Reactor.
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Projects"(DRP):and aLPhysicali-Security Inspectore, we concurred with'.;the:
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a L11c'ensee's' evaluation that:the circuit board was cut by:an unknownfperson1-
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'and,theglooseEvent plug-1LT-502'wasVnot' caused as-a result ofiequipment:
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' tampering.
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- We concluded that the q11censeeEconducted Lan adequate inyest'igationL for-both'
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events,- however, their investigative ~ actions regarding: thelvent' plug could-
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have'been broader.in scope;.The : licensee'took'no action to check'other
lRosemount: Transmitters antil the1NRC-brought thisito their attentio'n. The" p
- licensee wasLslow in reaching' their conclusion that' it;wasLnot equipmen't'
Jtampering.
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