IR 05000382/1999008
| ML20209H711 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 07/12/1999 |
| From: | Good G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Dugger C ENTERGY OPERATIONS, INC. |
| References | |
| 50-382-99-08, 50-382-99-8, EA-99-104, NUDOCS 9907210048 | |
| Download: ML20209H711 (4) | |
Text
SUBJECT:
NRC INSPECTION REPORT 99-08
Dear Mr. Dugger:
Thank you for your letter of Jun3 3,1999, in response to our May 3,1999, letter, and Notice of Violation. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.
Sin ely,
,
t
.
Gail M. Good, ief f
Plant Support Branch Division of Reactor Safety i
Docket No.:
50-382 License No.: NPF-38 (
cc:
j Executive Vice President and Chief Operating Officer Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 i
j 9907210048 990712 PDR ADOCK 05000382 G
PDR I
'
.
.
~.
Entergy Operations, Inc.
-2-Vice President, Operations Support Entergy Operations, Inc.
P.O. Box 31995 Jackson, Mississippi 39286-1995 Wise, Carter, Child & Caraway P.O. Box 651 -
Jackson, Mississippl 39205 General Manager, Plant Operations Waterford 3 SES Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70066 Manager - Licensing Manager Waterford 3 SES-Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70066 Chairman Louisiana Public Service Commission One American Place, Suite 1630 Baton Rouge, Louisiana 70825-1697 Director, Nuclear Safety &
- Regulatory Affairs Waterford 3 SES Entergy Operations, Inc.
P.O. Box B Killona, Louisiana 70066 -
Ronald Wascom, Administrator Louisiana Radiation Protection Division P.O. Box 82135
'
Baton Rouge, Louisiana 70884-2135 Parish President.
St. Charles Parish P.O. Box 302
. Hahnville, Louisiana 70057 Winston & Strawn 1400 L Street, N.W.
Washington, D.C. 20005-3502 t
f i
)
.
..
.
Entergy Operations, Inc.
-3-DISTRIBUTION w/coov of licensee's letter dated June 3.1999:
DMB (IE04)
Regional Administrator
- WAT Resident inspector DRP Director DRS Director Branch Chief (DRP/D)
Project Engineer (DRP/D)
Branch Chief (DRP/TSS)
RITS Coordinator RIV File DRS Action item File (99-G-0079)(Goines)
DOCUMENT NAME: R:\\_WAT\\WT908AK.ABE To receive copy of document, indicate in bar: 'C' = Copy without enclosures *E' - Copy with enclosures *N" = No copy lRIV:PSB AE C:DRS\\P/SB,
,,
,
l ABEarnest:@' GMGoo@
l07///99 07/7 99 OFFICIAL RECORD COPY
.
.. -...
~
.
'
- ,
l t
,,
Entergy Operations, Inc.
-3-DISTRIBUTION w/ copy of licensee's letter dated June 3.1999:
Regional Administrator -
-
WAT Resident inspector DRP Director DRS Director Branch Chief (DRP/D)
Project Engineer (DRP/D)
Branch Chief (DRP/TSS)
RITS Coordinator RIV File DRS Action item File (99-G-0079)(Goines)
t t
' DOCUMENT NAME: R:\\_WAT\\WT908AK.ABE To receive copy of document, Indicate in box: 'C' = Copy without enclosures *E' = Copy with enclosures *N' = No copy RIV:PSB Ai - C:DRS\\RSD, l
,,
,
ABEarnest:6-GMGoo@
07N/99 07/'J99 OFFICIAL RECORD COPY
,, p rs n 0 o
- >
i
~
.,
.
Entergy
!?=?::
=
Tet 504 739 0600 Charles v.ce p.e3 de.- Ce.-v haTarMrd 3 W3F1-99-0095 A4.05 PR J~
.[L.
i June 3,1999
'
i
i & JJN 8 1999 U.S. Nuclear Regulatory Commission i
j
'
" ~ ~ ~ '
ATTN: Document Control Desk
i
,
.,
Washington, D.C. 20555 I
!i._..
.. _
!
Subject:
Waterford 3 SES i
Docket No. 50-382 License No. NPF-38 Response to an Apparent Violation in Inspection Report 50-382/99-08 Gentlemen:
In accordance with your letter dated May 3,1999, Entergy Operations, Inc. hereby j
submits under affidavit the response to Apparent Violation 50-382/99-08 identified in j
the subject inspection report.
Our response includes e previously docketed submittal (Letter WF1-99-0079 dated April 22,1999 as Attachment 2), and a summary (Attachment 1) of our review of the corrective actions described in the inspection report. This summary confirms, with one clarification, the described corrective actions. Attachment 2 addresses the reason for the violation. Attachments 1 and 2 address the corrective actions taken and planned to be taken to avoid further violations. Full compliance will be achieved j
by June 18,1999, at which time all planned corrective actions wlIl be completed.
- bbb0
,
f-b
,
f. e O g
%-%,.MV NCM~'Wg
.,
.
. ',
I Response to an Apparent Violation in Inspection Report 50-382/99-08 W3F1-99-0095 Page 2 June 3,1999 if you have any questions concerning this response, please contact Early Ewing at (504) 739-6242.
Very truly yours,
,
,
.,I l l
- Vice President, Operations Waterford 3 CMDIGCS/rtk Attachrnents cc:
E.W. Merschoff(NRC Region IV)
C.P. Patel (NRC-NRR)
?JJ Smith : 'F
-
'N.S!Reynolds NRC Resident inspectors Office l
.
)
.
.
,
. ",
'
.-
UNITED STATES OF AMERICA NUCLEAR REGui.ATORY COMMISSION in the matter of
)
)
Entergy Operations, incorporated
)
Docket No. 50-382 Waterford 3 Steam Electric Station
)
AFFIDAVIT Charles Marshall Dugger, being duly sworn, hereby deposes and says that he is Vice President Operations-Waterford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Response to an Apparent Violation in Inspection Report 50-382/99-08 that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
)
g
,
y
)
s
/1%Lil
/
Charles Marshall Dugger O'
Vice President Operations-Waterford 3 STATE OF LOUISIANA
)
) ss PARISH OF ST. CHARLES
)
Subscribed and sworn to before me, a Notsry Public in and for the Parish and State above named this
> 9 day of b Am. a
,1999.
y
.
wi
'
-
Notary Public My Commission expires dI~Y
.
l i
]
.
.
,
p.
,
Attachmsnt 1 to
.
VV3F1-99-0095
/
Page 1 of 2 ENTERGY OPERATIONS, INC. REVIEW SUMMARY OF THE CORRECTIVE ACTIONS CORRECTIVE ACTION 1 DOCKETED IN INSPECTION REPORT 50-382/99-08 The licensee's corrective actions included immediate retraining and counseling of the access authorization personnel who were involved in the failure to review and consider the information.
REVIEW SUMMARY Entergy confirms the occurrence of retraining and counseling of the access I
authorization personnel who were involved in the failure to review and consider the information. The individuals involved were interviewed and expectations were reinforced regarding the appropriate actions that should have been taken during their review, in addition, the Site Human Performance Coordinator debriefed the individuals involved in the failure. These actions were completed on March 31,1999.
CORRECTIVE ACTION 2 DOCKETED IN INSPECTION REPORT 50-382/99-08 All licensee access authorization personnel were retrained prior to the completion of the inspection.
REVIEW SUMMARY Entergy confirms that the licensee access authorization personnel were retrained prior to the completion of the inspection. A memo dated March 31,1999, was written and distributed to section personnel concerning the expectation to review all information contained in a folder prior to signing it.
CORRECTIVE ACTION 3 DOCKETED IN INSPECTION REPORT 50-382/99-08 The licensee also planned to brief and train all Entergy access authorization personnel on the incident during annual training.
REVIEW SUMMARY Entergy confirms that the Entergy access authorization personnel will be briefed and trained on the incident during annual training. The upcoming training is scheduled for June 18,1999.
. _.
,
-
.
Attachm::nt 1 to
,
VV3F1-99-0095
,
-
Page 2 of 2 CORRECTIVE ACTION 4 DOCKETED IN INSPECTION REPORT 50-382/99-08 Prior to the end of the inspection, the licensee initiated a revision to Entergy Corporate Security Departmental Procedure CS-DP-104, Revision 0, to strengthen the requirements involving the review of all background information.
REVIEW SUMMARY Entergy did not initiate a revision to Corporate Security Departmental Procedure CS-DP-104, Revision 0. However, Entergy did initiate a revision to procedure Corporate Security Site Procedure CS-WP-AA-101, to strengthen the requirements involving the review of all background information. The revision, which became effective on May 14,1999, emphasizes the need for persons approving unescorted access forms to perform a comprehensive review of allinformation in an applicant's folder and ensure adjudication of any derogatory information.
CORRECTIVE ACTION 5 DOCKETED IN INSPECTION REPORT 50-382/99-08 Finally, the access authorization staff reviewed approximately 800 access authorization files.
REVIEW SUMMARY Entergy confirms that the access authorization staff reviewed approximately 800 access authorization files. A review was conducted to include the backgrounds received on over 800 workers granted access during Refuel Outage 09 in-processing to ensure no other folders included derogatory information that had been overlooked.
The review was completed on March 26,1999, and did not identify any other folders where derogatory information was not adjudicated prior to unescorted access being granted.
,
t
)
e a-9 e
ATTACHMENT 2 TO W3F1-99-0095
.
.
. e
'
'
==Entergy BE::"""
Tel 504 739 6242 Early C. Ewing. til at sa e'y e. m d re, "i is e
W3F1-99-0079 A4.05 PR April 22,1999 U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D.C. 20555 Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Reporting of Security incident Report Gentlemen:
Attached is Security incident Report (SIR) 99-S02-00 for Waterford Steam Electric Station Unit 3. This report describes an occurrence of a contract employee
'
inappropriately being granted unescorted access to the Plant's Protected Area (PA).
This condition is being reported pursuant to Appendix G to 10CFR73(l)c as a failure in our program that allowed unauthorized access to the PA.
Very truly yours, 2>
E.C. Ewing Director, Nuclear Safety & Regulatory Affairs ECE/GCSIrtk Attachment cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
A.L. Garibaldi, P. Lewis - INPO Records Center, J. Smith, N.S. Reynolds, NRC Resident inspectors Office, Administrator - LRPD
-
Q-Q.( e re nCN
-
g
"QUU
-
,
,
A
..
NRC FORA $ 388 U.S. NUCLEAR REGULATORY COteMISSION APPROVED BY OMS NO. 3150-0104 EXptRES Oe/30/2001
'"
'5"".".*n' 52"s&'"g'"""Y N E i*.*.o"n'.\\"7n' $.,'"O'".'a"Ti%
!l*n*a"s*a'" M e O LICENSEE EVENT REPORT (LER)
Nasimasy cansnamen. w
. oc zosso-coofend to m
"
s U,'l,",",,,*E*MYy)d*',,*,,,,,, go,o.< wort (See reverse for required riumber of W
,,
,,,,,,
digits / characters for each block)
eunenny
,one angrney con yd soon.or
,,g FACIUTV NAAE (1)
DOCHET NUteER (21 PAGE (3)
Waterford Steam Electric Station Unit 3 05000 382 1 OF 06 vms.
Centract Employee Inappropriately Granted Unescorted Access to Plant's Protected Area EVE ff BA TE fEl LER **'
1111 A D 3RT DJ.YE(?!
OTtMR sAen imem a IVOLVfD (st W
=
--
PAcatry seAaET DOCKET NUnabfR men on a
u men w
a N/A 0s000 PAcany = Ann oocarri.uiseen
16
99 S02 - 00
22
N/A 05000
-
gpgggygg Tlas --
.-a i AR n' --
i s am 98""A*87 TO YtE ::t
~~== Os 10 f:sR &? fchulr ans or mara) (111 EoOE 198
20.2201(bi 20.2203(e)(2iM 50.73(e>(2His 50.73to)(2)(viii>
potNWt 20.2203(eH1)
20.2203(e)(3Hil 50.73(eH2HN)
50.73(aH2Hx)
LEVE. (10)
20.2203(eH2)(in 20.22cusH3)(wi 50.73(eHa>(iui x
73.75
'
em.
m gg 20.2203(eH2HN)
20.2203(e)(4)
50.73(eH2)(M OTHER gq[
$hh 20.2203(a)(2HiW)
50.36(c)(11 50.73(eH2iM s,
.,y in Am.e, i,.w.
$4dNPN 20.2203(eH2HM 50.38(cH2)
50.73(eH2Hvh)
in Nac Fonn seeA i r -- - --acT san Tian tar iim NAan TELEPMosE teuhWER Dusisse A,es comel Dee Childress, Supv, Investigations & FFD (504)-739-6794 enasetsTf amas a mass son a acas - -
. s aa a a== --- -
-asvnasmapany tal
7,8,EI 8Q4EI caust systus esspeleff IsmuncTunst canst sysfus cessenerr umswacTuman jf(
Me y
__
__
esemner p aa unrvu ear vus YSS SWEBEIN (if vos, cornplete EXPECTED SUSMISSloN DATEl.
X EETIMa ASSTRACT (Umit to 1400 spaces, i.e., appronmetely 15 einEie-speeed typewntten lineel (ISI On February 16,1999, Entergy's Access Authorization personnel received derogatory inicrmation on a contract individual who was applying for employment and unescorted access to the plant's protected area (PA). Entergy's Access Authorization personnelinadvertently overlooked the dsrogatory information, and as a result gave temporary unescorted access to the individual. On March 23,1999, the derogatory information was identified and the contract individual's unescorted access was immediately terminated. The cause of this occurrence is personnel error in that three individuals failed to review documentation regarding the contract individual's background investigation. In addition to terminating the contractor's unescorted access, individuals involved with this event have been debriefed concerning work expectations when reviewing records.
Upon discovery of the derogatory information and subsequent immediate termination of the contract individual, a review of the work and work area the individual was involved with was performed by security personnel with no problems or concerns identified. Accordingly, this event did not compromise the health or safe'" of the public or plant personnel.
,
.,M.
,
.
.
"
FORM SetA U.S. NUCLEAR REGULATORY COMMISSION LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FaceITY Maur til DOCKET fil LFR Nuumsat till PAGE f 31
.
u,",,",[f =
ma 05000 OF Waterford Steam Electric Station Unit 3 382
- 502 - 00
06 TtKT flf more space is requeed, use additional copies of NRC form 366A) (17)
REPORTABLE OCCURRENCE On February 16,1999, Entergy received derogatorv information on a contract individual who was applying for employment and unescorted access to the plant's protected area.
Entergy inadvertently overlooked the derogatory information, and as a consequence
.
I gave the individual temporary unescorted access to the protected area. This occurrence was a result of personnel error that allowed an individual with derogatory information to obtain unescorted access to the plant's PA. Accordingly, this event is being reported ' ursuant to Appendix G to 10CFR73(l)c as a failure that allowed p
unauthorized access to the PA.
INITIAL CONDITIONS On February 16,1999, when the derogatory information was received by Entergy and on March 23,1999, when the derogatory information was discovered, the plant was in Mode 5, cold shutdown.
EVENT DESCRIPTION On February 15,1999, a contract employee applied for unescorted access authorization to Waterford 3. The worker had previously obte!ned temporary unescorted access at Waterford 3 within a year and had not gained access at any other nuclear site. Because his only access was at Waterford within one calendar year, he was processed to have his access reinstated. The contractor completed his reinstatement packet as required, and the packet was subsequently tumed over to Corporate Security who reviewed it for completeness and derogatory information.
There was no potentially disqualifying or derogatory information indicated by the contractor in his reinstatement packet. The packet was then faxed to an agency that
,
.
mac menssueuse
.
.
e
?
NRC FORM 3 sea U.S. NUCLEAR REGULATORY COMMIS$10N C18 8 LICENSEE EVENT REPORT (LER)
_
TEXT CONTINUATION FAcatfTY NAME fil DOCKET (2)
LFR Nimrq (q[i pAGE f 3)
.
"E?
E
=
05000 OF Waterford Steam Electric Station (Jnit 3 382
- S02 -
D3
rnxi or mor, space a requires. use assitionet copies or unc form 366A) (17)
conducts background investigations (BI). On the evening of February 16,1999, the BI report was faxed back to Waterford 3.
Included in the BI was derogatory information on the employee that should have precluded him from obtaining unescorted access to the PA. Specifically, the Bl indicated that the individual had failed a drug test at a non-nuclear job site. This information was contrary to what the contracter indicated on his employment reinstatement paperwork when he responded 'No' to the question, " Have you ever tested positive for drugs or alcohol?"
{
i The BI data was entered into the computer on the moming of February 18,1999, and placed into the workers folder. Corporate Security then started to process the folder for access. The Area Access Request (AAR) form was subsequently updated with a certification date, certification expiration date, psychological date, and general employee training date. The folder was then marked indicating that only the results of the site drug test were needed to complete the in processing of the contractor.
The site drug test results were received late on February 22,1999, with negative findings. Because the contractor's folder was marked that only the drug test was missing to complete the in-processing, on February 23,1999, the results of the test were documented on the AAR and the contractor's folder was passed on for final signature and unescorted access was granted. An Entergy employee signed the AAR for final signature as required; however, a complete review of the folder was not performed.
,
'
-,..
- - -
.
.
.
e NRC FORM 364A U.S. NUCLEAR REGULATORY COMMISSION OtseII UCENSEE EVENT REPORT (LER)
TEXT CONTINUATION FActLITY MAME fil DOCKET f 26 IIR NNmt ful PAGE f 3)
,
"nN E
=
05000 OF Waterford Steam Electric Station Unit 3 382
- 502 - 00
06 TEXT (N more space is required. use additiornet copies of NRC form 366A) (17)
On March 23,1999, the remaining information needed to grant permanent unescorted access was placed in the worker's folder and processed for signature. Upon review of all the information existing in the folder, it was discovered that the BI reinstatement included derogatory information that was program disqualifying according to Company policy. The worker had not disclosed this information originally when completing his packet. The worker's access was suspended pending verification of this information.
Once the information was verified, the worker's access was denied in accordance with Company policy.
CAUSAL FACTORS A Root Cause Determination (RCD) was performed and it was concluded that the cause of this event was personnel error, in that improper work practices were performed. Current procedures are in place that requires Access Authorization personnel to completely review prospective applicant's pre-access documentation.
However, both of the individuals responsible for the comprehensive review of the contractor's documentation made the assumption that a.eview had been previously performed.
CORRECTIVE MEASURES 1.
Upon discovery of the notification of derogatory information on the individual, the individual's protected area access was immediately suspended. (The individual was working a difierent shift and not in the PA when the discovery occurred.)
I 2.
Once the derogatory information was verified, the individual's folder was processed for denial and his access was. terminated. The worker's supervision
t
. !
ll I
)
_
- - -. -
.
.
'
,
I
,
NRC FORM 30eA U.S. NUCLEAR REGut.ATORY COMMISSION Glsen LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION Facet fTY km* lil DOCKET fil LFR Nwac4 till PAGE f 31
,
"nfinIn" E
05000 OF WaterfOrd Steam Electric Station Unft 3 382
- S02 - 00
06 ivcr or more space is reausred. use additione copina or unc Forrn 366A) (11)
was notified and instructed to perform a review of safety related tasks performed by the individual. The Security Superintendent and additional Plant management personnel were notified. A review of the work and work area the individual was involved with was performed by security personnel with no problems or concerns identified.
_
3.
A review was performed of the background investigation information received on over 800' workers granted unescorted access during outage in processing. A representative sampling of the backgrounds were reviewed to ensure no other folders included derogatory information that was overlooked and therefore not adjudicated properly. This review was completed on March 26,1999, and did not identify any other folders where derogatory information was not adjudicated I
prior to unescorted access being granted.
4.
The individuals involved were interviewed and expectations were reinforced regarding the appropriate actions that should have taken place during their review.
5.
A memo has been written and distributed to all section personnel concerning the expectation to review all information contained in a folder prior to signing the l
J folder, j
i 6.
The Site Human Performance Coordinator also debriefed the individuals involved and Event Situational Data Sheets were completed for each.
.
l
-
.
nu mmmmeine
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ - - - _ _ _ _ _ - - - _-
i
,
.
..a
NRC FORM $ sea U.S. NUCLEAR REQULATORY COMMISSION 01sse LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FAemffY M
- fil DocKFT f 2)
LFR Ntamar4 flIl PAGE (3)
.
"mfa?s E
05000 OF Waterford Steam Electric Station Unit 3 382
~ S02
06
TEXT (If more space k required, use edditional copies of NRC Form 366A) l17l SAFETY SIGNIFICANCE Upon discovery of the derogatory information and subsequent immediate termination of the contract individual, a review of the work and work area the individual was involved with was inspected by security personnel with no problems or concerns identified.
Accordingly, this event did not compromise the health or safety of the public or plant personnel.
SIMILAR EVENTS None
l
'
. -
___________s