IR 05000348/2012008
| ML13043A033 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 02/08/2013 |
| From: | Lynch T A Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| EA-12-240, IR-12-008, NL-13-0208 | |
| Download: ML13043A033 (9) | |
Text
Thomas A. Lynch Southern NuclearVice President -Farley Operating Company, Inc.Farley Nuclear PlantPost Office Drawer 470Ashford, Alabama 36312Tel 334.814.4511Fax 334.814.4728February 8, 2013 SOUTHERNCOMPANYDocket Nos.: 50-348 NL-13-020850-364U. S. Nuclear Regulatory CommissionATTN: Document Control DeskWashington, D. C. 20555-0001Joseph M. Farley Nuclear Plant, Units 1 & 2Response to Apparent Violations inInspection Report 05000348, 364/2012008: EA-1 2-240Ladies and Gentlemen:By letter dated January 9, 2013, the Nuclear Regulatory Commission (NRC) staffnotified Southern Nuclear Operating Company (SNC) of two apparent violationsconcerning fire watch patrols at Joseph M. Farley Nuclear Plant (FNP).SNC accepts the violations and, pursuant to the provisions of 10 CFR 2.201,submits its response to the violations as an Enclosure to this letter.The individuals responsible for these violations were knowledgeable of theprocedural requirements and responsibilities for performing fire watch patrols andacknowledged that they did not adequately perform their assigned patrols andfalsified the records associated with these patrols. While this incident thereforeresulted from willful violations of site procedures, requirements and expectations,the incident was self-identified and immediate corrective actions were taken.SNC has confidence that the thorough corrective actions taken, as described inthe Enclosure, obviate any need for escalated enforcement in this matter.This letter contains no NRC commitments. If you have any questions, pleasecontact Doug McKinney at (205) 992-5982.
Sincerely,T. A. LynchVice President -FarleyTAL/DWD/
Enclosure:
Response to Apparent Violations inInspection Report 05000348, 364/2012008; EA-12-240 U. S. Nuclear Regulatory CommissionNL-13-0208Page 2cc: Southern Nuclear Operatinq CompanyMr. S. E. Kuczynski, Chairman, President & CEOMr. D. G. Bost, Executive Vice President & Chief Nuclear OfficerMr. B. L. Ivey, Vice President -Regulatory AffairsMr. B. J. Adams, Vice President. -Fleet OperationsMr. C. R. Pierce, Regulatory Affairs DirectorRTYPE: CFA04.054U. S. Nuclear Requlatory CommissionMr. V. M. McCree, Regional AdministratorMs. E. A. Brown, NRR Project Manager -FarleyMr. P. K. Niebaum, Senior Resident -FarleyMr. J. R. Sowa, Senior Resident -Farley Joseph M. Farley Nuclear Plant, Units 1 & 2EnclosureResponse to Apparent ViolationsinInspection Report 05000348, 364/2012008; EA-12-240 EnclosureResponse to Apparent Violations inInspection Report 05000348, 364/2012008; EA-12-240Restatement of Violation 050000348, 364/2012008-0110 CFR 50.48, Fire Protection, requires that a licensee must have a fireprotection plan that, in part, outlines the plans for fire protection, firedetection, suppression capability, and limitation of fire damage. SiteProcedure FNP-0-SOP-0.4 requires that hourly fire watches be conductedfor degraded fire barriers or increase in combustibles in an area. Contrary tothe above, from September 2011 through December 2011, roving fire watchpatrols assigned to monitor specific fire protection (FP) areas with degradedbarriers for indication of the presence of a fire, in the non-radiologicalportions of the plant, failed to conduct hourly fire watch patrols as required byFNP-0-SOP-0.4. For administrative tracking purposes, this issue will betracked as apparent violation (AV), AV 05000348, 05000364/2012008-01:Failure to Perform Required Fire Watches.Southern Nuclear Operating Company (SNC) does not contest the violation.1. Reason for the Apparent ViolationContractor personnel who were assigned to perform hourly fire watch patrolsdeliberately violated procedures and management expectations on multipleoccasions by not completing all portions of their assigned patrols and thenentering false records of fire watch patrol performance into the plant'sEnterprise Shift Operations Management System (ESOMS), the electronicrecord keeping system used to fulfill the procedural documentationrequirement.An investigation of this incident was undertaken through the corrective actionprogram. The incident was determined not to have resulted from insufficientpre-job briefing; inadequate, incorrect or unclear procedures; or inadequateknowledge or training. The requirements for conducting fire watch patrolsand creating proper documentation were clearly communicated to andunderstood by the fire watch personnel, thus the failure to properly performhourly patrols and the falsification of patrol records were not the result of anyprocess or procedure failures. The incident was characterized as a "recklessviolation of procedures as well as management expectation."2. Corrective Steps Taken and Results Achieved; Including Control ofContractor ActivitiesA contractor supervisor noted the presence of a fire watch patroller at alocation and time inconsistent with the hourly fire watch patrol route assignedto that individual. Review of security badge (card key) access recordsindicated that discrepancies existed between the patroller's actual location inPage 1 of 6 EnclosureResponse to Apparent Violations inInspection Report 05000348, 364/2012008; EA-12-240the plant and the location where the patroller should have been if properlyperforming the assigned fire watch patrols. Immediately after identifyingthese inconsistencies, an investigation was initiated into the conduct of allcontractor personnel performing fire watch patrols. SNC Site Managementwas also promptly notified of the incident. It was confirmed that certain firewatch personnel had failed to properly perform hourly patrols in accordancewith the procedures and their training, and had falsified fire watch records.SNC implemented the following corrective actions:a) Immediately upon learning of the fire watch irregularities, thecorrective action program was entered and an investigation was begun toidentify and assess the causes and extent of the problem.b) An Extent of Condition review was performed to determine whether theincident was isolated to one individual or involved multiple personnel.This assessment reviewed badge access records and fire watchperformance records for all personnel assigned fire watch duties,including former fire watch personnel who were under consideration forreturn to fire watch duties.c) As the Extent of Condition review identified individuals with suspiciousdiscrepancies in their fire watch records, they were immediately placedon administrative leave. Interviews were conducted with theseindividuals and upon confirmation of misconduct they (a total of sixcontractor employees) were terminated.Additional corrective actions to strengthen control of contractor activities aredetailed in Item 3 below.3. Corrective Steps to be Taken to Avoid Further Violationsa) The contractor conducted a stand down with all fire watch personnel toensure performance expectations were clearly understood. The SNCFire Protection Administrator provided training guidance and pre-job briefinformation to be used by all fire watch personnel and is nowaccompanying new personnel on patrols to certify their readiness beforethey are released to perform fire watch duties independently.b) SNC has engaged in active contractor oversight and control to validatethe consistent performance of the required fire watches by:1. Daily verification of the qualification for personnel performing firewatches2. Performing unscheduled, random observations of fire watch patrols3. Access verification through periodic review of security badge accessrecords for personnel performing fire watch patrols4. Routine review of ESOMS log entries documenting fire watch patrolsPage 2 of 6 EnclosureResponse to Apparent Violations inInspection Report 05000348, 364/2012008; EA-12-2405. Issues impacting the performance of fire watch patrols aredocumented in the corrective action program to ensure a formalevaluation of identified issue(s).The above actions ensure SNC is actively overseeing the contractor'sactivities to improve the consistency, quality and sustainability of fire watchoversight. While these actions are currently being performed due to directedexpectations, they will be proceduralized and a monthly recurring action toperform and document the fire watch audit function will be established.c) To strengthen contractor performance and oversight within the SouthernNuclear Fleet the following processes have been implemented:1. The SNC training matrix for supplemental (contractor) personnel hasbeen amended to include "Engaged Thinking Worker (SOER 10-2)"training and "Engaged Thinking Supervisor (SOER 10-2)" training forsupplemental workers and supervisors, respectively.2. The procedure for control of supplemental personnel has beenmodified to strengthen oversight of supplemental personnel bystrengthening the duties, qualifications and responsibilities of the SNCpersonnel responsible for oversight of contractor activities.4. Date When Full Compliance Will Be AchievedSNC is in full compliance. Based on corrective actions and reviewscompleted, SNC has determined that fire watches are being adequatelyperformed and accurately documented.Page 3 of 6 EnclosureResponse to Apparent Violations inInspection Report 05000348, 364/2012008; EA-12-240Restatement of Violation 050000348, 364/2012008-0210 CFR 50.9(a), Completeness and Accuracy of Information, states, in part,that information required by the Commission's regulations, orders, or licenseconditions to be maintained by the licensee shall be complete and accuratein all material respects. Farley Administrative procedure FNP-0-AP-39, "FirePatrols and Watches," Section 5.4, "Hourly Fire Watch Patrols," states:"Document the performance of the fire watch in accordance with formssimilar to Figures 1 as applicable." Contrary to the above, from September2011 through December 2011, the licensee maintained records of hourly firewatch patrols that were not complete and accurate in all material respects.Specifically, fire watch patrol documentation as required by FNP-0-AP-39annotated that hourly fire watches were completed when in fact such firewatches had not been performed. The hourly fire watch patrol data ismaterial to the NRC in that it provides sufficient evidence of compliance withregulatory requirements. For administrative tracking purposes, this issue willbe tracked as apparent violation (AV), AV 05000348, 05000364/2012008-02:Falsification of Records.Southern Nuclear Operating Company (SNC) does not contest the violation.1. Reason for the Apparent ViolationContractor personnel who were assigned to perform hourly fire watch patrolsdeliberately violated procedures and management expectations on multipleoccasions by not completing all portions of their assigned patrols and thenentering false records of fire watch patrol performance into the plant'sEnterprise Shift Operations Management System (ESOMS), the electronicrecord keeping system used to fulfill the procedural documentationrequirement.An investigation of this incident was undertaken through the corrective actionprogram. The incident was determined not to have resulted from insufficientpre-job briefing; inadequate, incorrect or unclear procedures; or inadequateknowledge or training. The requirements for conducting fire watch patrolsand creating proper documentation were clearly communicated to andunderstood by the fire watch personnel, thus the failure to properly performhourly patrols and the falsification of patrol records were not the result of anyprocess or procedure failures. The incident was characterized as a "recklessviolation of procedures as well as management expectation."Page 4 of 6 EnclosureResponse to Apparent Violations inInspection Report 05000348, 364/2012008; EA-12-2402. Corrective Steps Taken and Results Achieved: Including Control ofContractor ActivitiesA contractor supervisor noted the presence of a fire watch patroller at alocation and time inconsistent with the hourly fire watch patrol route assignedto that individual. Review of security badge (card key) access recordsindicated that discrepancies existed between the patroller's actual location inthe plant and the location where the patroller should have been if properlyperforming the assigned fire watch patrols. Immediately after identifyingthese inconsistencies, an investigation was initiated into the conduct of allcontractor personnel performing fire watch patrols. SNC Site Managementwas also promptly notified of the incident. It was confirmed that certain firewatch personnel had failed to properly perform hourly patrols in accordancewith the procedures and their training, and had falsified fire watch records.SNC implemented the following corrective actions:a) Immediately upon learning of the fire watch irregularities, the correctiveaction program was entered and an investigation was begun to identifyand assess the causes and extent of the problem.b) An Extent of Condition review was performed to determine whether theincident was isolated to one individual or involved multiple personnel.This assessment reviewed badge access records and fire watchperformance records for all personnel assigned fire watch duties,including former fire watch personnel who were under consideration forreturn to fire watch duties.c) As the Extent of Condition review identified individuals with suspiciousdiscrepancies in their fire watch records, they were immediately placedon administrative leave. Interviews were conducted with theseindividuals and upon confirmation of misconduct they (a total of sixcontractor employees) were terminated.Additional corrective actions to strengthen control of contractor activities aredetailed in Item 3 below.3. Corrective Steps to be Taken to Avoid Further Violationsa) The contractor conducted a stand down with all fire watch personnel toensure performance expectations were clearly understood. The SNCFire Protection Administrator provided training guidance and pre-job briefinformation to be used by all fire watch personnel and is nowaccompanying new personnel on patrols to certify their readiness beforethey are released to perform fire watch duties independently.b) SNC has engaged in active contractor oversight and control to validatethe consistent performance of the required fire watches by:Page 5 of 6 EnclosureResponse to Apparent Violations inInspection Report 05000348, 364/2012008; EA-12-2401. Daily verification of the qualification for personnel performing firewatches2. Performing unscheduled, random observations of fire watch patrols3. Access verification through periodic review of security badge accessrecords for personnel performing fire watch patrols4. Routine review of ESOMS log entries documenting fire watch patrols5. Issues impacting the performance of fire watch patrols aredocumented in the corrective action program to ensure a formalevaluation of identified issue(s).The above actions ensure SNC is actively overseeing the contractor'sactivities to improve the consistency, quality and sustainability of fire watchoversight. While these actions are currently being performed due to directedexpectations, they will be proceduralized and a monthly recurring action toperform and document the fire watch audit function will be established.c) To strengthen contractor performance and oversight within the SouthernNuclear Fleet the following processes have been implemented:1. The SNC training matrix for supplemental (contractor) personnel hasbeen amended to include "Engaged Thinking Worker (SOER 10-2)"training and "Engaged Thinking Supervisor (SOER 10-2)" training forsupplemental workers and supervisors, respectively.2. The procedure for control of supplemental personnel has beenmodified to strengthen oversight of supplemental personnel bystrengthening the duties, qualifications and responsibilities of the SNCpersonnel responsible for oversight of contractor activities.4. Date When Full Compliance Will Be AchievedSNC is in full compliance. Based on corrective actions and reviewscompleted, SNC has determined that fire watches are being adequatelyperformed and accurately documented.Page 6 of 6