IR 05000458/1993008
| ML20044E549 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/19/1993 |
| From: | Callan L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Graham P GULF STATES UTILITIES CO. |
| Shared Package | |
| ML20044E550 | List: |
| References | |
| NUDOCS 9305250144 | |
| Download: ML20044E549 (3) | |
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utslTED STATES o
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NUCLEAR REGULATORY COMMISSION
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R EGION IV
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611 RYAN PLAZA DRIVE, SUITE 400
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ARLINGTON, TEXAS 76011-8064
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MAY I 9 SE Docket:
50-458 License: NPF-47 Gulf States Utilities ATTN:
P. D. Graham
Vice President (RBNG)
P.O. Box 220 St. Francisville. Louisiana 70775 SUBJECT:
RESPONSE TO NRC INSPECTION REPORT 50-458/93-08 Thank you for your letter of May 3 1993, in response to our letter ana Notice of Violation dated April 2. 1993. We have reviewed your reply and finc 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.
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L. J. Crllan Director DivisiopofRadiationSafety and Fafeguards CC:
Gulf States Utilities ATTN:
J. E. Booker, Manager-Nuclear Industry Relations P.O. Box 2951 Beaumont. Texas 77704 Winston & Strawn ATTN: Mark J. Wetterhahn. Esq.
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1401 L Street, N.W.
Washington, D.C.
20005-3502 9305250244 930519 PDR ADOCK 05000458 G
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Gulf States Utilities-3-l
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'bcc to DMB (IE04) w/ copy of licensee's letter dated May 3.1993:
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J. L. Milhoan
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B. Murray, DRSS/FIPS i
A. B. Earnest, FIPS
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DRP Section Chief, DRP/C
Project Engineer, DRP/C l
Section Chief, DRP/TSS
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Resident Inspector (2) - River Benc Senior Resident Inspector - Cooper Senior Resident Inspector - Fort Calhoun
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MIS System i
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FIPS File RIV File
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Lisa Shea. RM/ALF. MS: MNBB 4503 E. Baker. NRR Project Manager (MS 13 HIS)
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J. L. Milhoan B. Murray, DRSS/FIPS A. B. Earnest, FIPS DRP Section Chief, DRP/C Project Engineer. DRP/C Section Chief, DRP/TSS DRS Resident Inspector (2) - River Bend Senior Resident Inspector - Cooper Senior Resident Inspector - Fort Calhoun MIS System FIPS File RIV File Lisa Shea, RM/ALF, MS: MNBB 4503 E. Baker. NRR Project Manager (MS 13 H15)
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REPLY TO NOTICE OF VIOLATION (458/9308-01)
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LEVEL IV
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REFERENCE Notice of Violation - Letter from L.J. Callan to P.D. Graham dated April 2.1993.
l VIOLATION Failure to Maintain Keveard Accountability
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The Introduction Section of the Physical Secunty Plan states that security procedures provice l
the detailed instructions necessary to implement the plan.
Security Position Instmetion. Procedure SPI-12. paragraph 3.2.4(1) states, in pan. "Supemse
the inventory of all KCs (Keycards) and VKCs (Visitor Keycards) as follows: Paragraon
3.2.4(1)(i) states. "Using the SUP1 console. log out KCs displayed as [in] the PA but in tne rack. Prepare a SECFM i15. Security Incident Report."
Contrary to the above, the inspectors identified that on August 24.1992, and Maren 1.1993.
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keycards were displayed as being in the protected area when. in fact. the badges were in tne security badge racks. The keycard inventorv did not identify the discrepancy in the keycaro
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accountability program.
REASON FOR VIOLATION t
The senior access control supervisor (SACS) failed to ensure that a proper keycaro manual
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inventory accountability was initiated and conducted in accordance with his security position instruction (SPI-12). In delegating the keycard accountability duties to the access control officers who actually pedorm the keycani accountability task. the SACS failed to directly oversee the task being performed and failed to recognize that the security position instructions (SPI-4) for the access control officers did not contain guidance on performing the task, i.e. the implementing procedures were silent on how to perform keycard accountability. This activity had been performed by access control officers through experience.
This event was caused by an
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inadequate procedure. Failure by the SACS to ensure that the keycard accountability was perfonned is considered human error and a lack of attention to detail.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
Implementing Procedure PSP-4-300 has been revised to incorporate the requirement to perform keycard accountability.
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The senior access control supenisor's security position instruction (SPI-12) has been revised to include the following:
"The Senior Access Control Supervisor shall conduct and document a pre-accountability brie 5ng prior to the accountability being initiated."
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The access control officers' security position instruction (SPI-4) has been revised to include the details necessary on how to conduct a pmper manual keycard accountability at the end of the day. The SPI also specines that once the keycard manual accountability is performed. the officers am to switch roles and perform a second keycard accountability check.
I CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER TTOLATIONS All secunty operations supervisors and access control of5cers have been retramea on tne revisea security position instructions and the importance of performing a correct keycard accountability.
Security procedures and SPIs are being reviewed by the security operations supenisors and officers to identify areas where additional information or clari5 cation is required. This review is to be completed by April 1.1994.
j DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Compliance has been achieved.
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ATTACIBIENT 2 REPLY TO NOTICE OF VIOLATION (458/9308-02)
LEVEL IV REFERENCE Notice of Violation - I.etter from L.J. Callan to P.D. Gmham dated April 2.1993.
VIOLATION Failure to Maintain Uninterruptible Power to the Security Systems Paragraph 7.5 of the Physical Security Plan recuires that ecurity equipment be furmsnea unintermptible power from buses that are also backed by standby diesei genemtors.
Contrary to the above, the inspectors identiDed that from July 22 until August 4.1992. the uninterruptible power supply system was in manual bypass, thereby, eliminatmg umntermpuble power for the system.
REASON FOR TIIE VIOLATION During the course of Refueling Outage 4. in the above desenbed July,1992 time frame. the Electrical Maintenance Depamnent (EMD) performed mamtenance work orders on Secunty s unintermptible power supply (UPS) system. Security management was not officially nottDec l
that the security UPS system was taken out-of-service. The EMD was working on the invener I
and was changing out battery cells in the direct current (de) power source. all of which is pan of the UPS power supply system serving the secunty system loads with normal power.
In order to ensure personnel safety while maintenance personnel were working on the system.
the normal power (including the UPS system) was de-energized. To provide the secunty system loads with power during the maintenance period, the manual bypass switch was switched to the I
altemate source of power. While the power supply system was in this configuration. River Bena Station (RBS) was in noncompliance with the Physical Security Plan (PSP) since the PSP has no pmvision for maintenance of the power supply system. However, maintenance of the system must be performed to prevent degmdation of the equipment.
At the time that maintenance was being performed. Security's centnl alarm station (CAS) was aware that the work was being performed and that the UPS was de-energized. When the power supply was shifted to manual bypass an indicator light was illuminated on the CAS board. This is the normal configuration for maintenance on all RBS inverters including safety related
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systems. However, the full extent of the work and the length of time the UPS would be offline were not apparent to Security at the begmmng of the maintenance period.
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As a result of this incident. it was also determined that no list of the major electncal loads for security equipment had been identified to Security or Operations. Consequently, Opentions dic'
not know that Security needed to be informed when Opentions was pmparing to tag out the UPS
power supply system.
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Inadequate procedures and a lack of communications are root causes of this event.
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CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED _
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This event was self-identified by GSU personnel. When Security realized the unusual length of
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time involved with the maintenance of the power supply system. personnel from Security and EMD met and discussed being in noncompliance with the PSP and how the maintenance activity j
could be promptly performed. Improved communications and notifications needed durmg future j
maintenance periods was also discussed. Security management initiated a condition recon tCR l
92-0651) to address the situation and to ensure that Secunty would be made aware of future I
maintenance acuvity involving the power supply system. Licensing personnel notuied NRC l
Recion IV inspection personnel by telephone on August 4.1992. that RBS was ooeratmg m the
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alternate power supply configuration.
i As a result of this event. Design Engineering provided Security and Operanons with a tist of the various sources of power and major loads for security egmpment. Security requested that
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Operations take acuon necessary to ensure Security is properiy noti 5ed prior to taggmg out or
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working on power supply equipment.
Operations has incorporated this informauon into i
procedure OSP-0019 " Electrical Bus Outages ' to ensure that Security is noti 6ed prior to :aggmg l
secunty power supply equipment out of service. Information has also been incorporated into t
security procedures to ensure that when the notification is made to Security, the alarm station
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operator will take necessary compensatory measures.
These actions will ennance l
communications and heighten awareness of being without the CPS system which will mmimize downtime of the UPS system.
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FUTURE STEPS TO BE TAKEN TO AVOID FUTI'RE VTOLATIONS
As future maintenance activities are performed. Security management will monitor the activity l
to ensure that communications have taken place between departments so that Secunty is aware of the full impact of the maintenance and that proper compensatory measures are taken.
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During the next submittal of a PSP revision, a statement clarifying the power supply requirements during maintenance on the UPS system will be added in the text.
l DATE CORRECTIVE ACTION WILL BE COMPLETED
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Full compliance was achieved on August 4,1992. Traimng on procedure changes. additional corrective actions to provide for Security contingencies involving power supply outages. and the
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revision of the PSP will be completed by May 30,1993.
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