IR 05000458/1993024

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-458/93-24 on 930831

ML20059H642
Person / Time
Site:	River Bend
Issue date:	11/04/1993
From:	Chamberlain D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Mcgaha J GULF STATES UTILITIES CO.
References
NUDOCS 9311100153
Download: ML20059H642 (4)

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UfdliED STATES  :

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[1 k.7d$$i I' ?j REGION IV 611 RYAN P'.AZA DRIVE, SulTE 400 AR LINGTC '), TEXAS 76011-8064 j ( %# jb '

..,+ g4g 4 Docket: 50-458 .

License: NPF-47

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Gulf States Utilities ATTN: John R. McGaha, Vice President'

River Bend Nuclear Group -

l P.O. Box 220 l St. Francisville, Louisiana 70775 l

f SUBJECT: RESPONSE TO NRC INSPECTION REPORT 50-458/93-24 Thank you for your letter of October 8,- 1993, in response to our letter and Notice of Violation dated August 31, 1993. We have' reviewed your reply and-We will find it responsive to the concerns raised in our Notice of Violatio ;

review the implementation of your corrective actions during a future- ,

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i inspection to determine that full compliance has been achieved and will be maintaine

Sincerely,

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bd4 i. bl1 500. D. Chamberlain, Acting Director Division of Radiation Safety and Safeguards l cc:

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Gulf States Utilities

! ATTH: J. E. Booker, Technical Assistant P.O. Box 220 St. Francisville, Louisiana 70775 Gulf States Utilities ATIN: Harold W. Keiser, Senior Vice President P.O. Box 220 St. Francisville, Louisiana 70775

9311100153 931104 i PDR ADOCK 05000458 8 G PDR ^ !n11 -

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Gulf States Utilities -2-Gulf States Utilities ATIN: Michael B. Sellman, Plant Manager P.O. Box 220 St. Francisville, Louisiana 70775 Gulf States Utilities ATTN: James J. Fisicaro, Manager - Safety Assessment and Quality Verification P.O. Box 220  ;

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St. Francisville, Louisiana 70775 Winston & Strawn ATTN: Mark J. Wetterhahn, Es :

, 1401 L Street, l

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I Washington, Gulf States Utilities ATTN: Les England, Director Nuclear Licensing P.O. Box 220 St. Francisville, Louisiana 70775 Mr. J. David McNeill, III William G. Davis, Es Department of Justice Attorney General's Office P.O. Box 94095 i

Baton Rouge, Louisiana 70804-9095 l

l H. Anne Plettinger 3456 Villa Rose Drive Baton Rouge, Louisiana 70806 President of West Feliciana Police Jury P.O. Box 1921 St. Francisville, Louisiana 70775 Cajun Electric Power Coop. In ATTN: Philip G. Harris 10719 Airline Highway P.O. Box 15540 Baton Rouge, Louisiana 70895 Hall Bohlinger, Administrator Radiation Protection Division P.O. Box 82135 Baton Rouge, Louisiana 70884-2135

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Gulf States Utilities -3-bec:to.DMB (IE04) w/copf of licensee's letter date October 8,1993:

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bec distrib. by RIV:

J. L. Milhoan A. B. Earnest, FIPS DRP ,

Section Chief, DRP/C Project Engineer, DRP/C r 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 HIS)

R. A. Scarano, RV/DRSS

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I RIV:FIRd C:FIPS [ ADD:DRSShQ AD:DRSSME l ABEarrjNnh BMurray U CLCain N6DChamberlain it/5/93 Y b/ /93 it/4/93 11 / 4 / 9 3

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bec to DMB (IE04) w/ copy of licensee's letter date October 8,1993:

bcc distrib. by RIV:

J. L. Milhoan 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

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E. Baker, NRR Project Manager (MS 13 HI5)

l R. A. Scarano, RV/DRSS I l

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RIV:FIRd C:FIPS k ADD:DRSS'4Q AD:DRSS01A ABEarr knh BMurray b CLCain "bDChamberlain lI/5 [93 Y h/ /93 y /9 /93 11 / 4 / 9 3

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REGioggy 4 October 8,1993 RBG- 39180 File Nos. G9.5, G15.4.1 i U. S. Nuclear Regulatory Commission Document Control Desk Washington, D. C. 20555 Gentlemen:

River Bend Station - Unit I Docket No. 50-458/93-24 Pursuant 10CFR2.201, this letter provides Gulf States Utilities Company's (GSU) response to the Notice of Violation 9324-02 from NRC Inspection Report 50-458/93-24 and is submitted at this time based on a discussion with Mr. Blaine Murray on September 30,1993. The special inspection was conducted by Messrs. A. B. Earnest, T. W. Dexter, J. Niceley, M. Warren and other personnel from the U. S. Army Special Forces on July 26-30, 1993, of activities authorized by NRC Operating License NPF-47 for River Bend Station - Unit I. GSU's reply I l to the violation is provided in the attachment.

l Should you have any questions, please contact Mr. D. N. Lorfing of my staff at (504) 381-415 I

Sincerely,

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,.$~w James J. Fincare l Manager - Safety Assessment and l Quality Verification ,

l Attachment xc: U. S. Nuclear Regulatory Commission I Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011 l NRC Resident Inspector l

P. O. Box 1051 St. Francisville, LA 70775

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l ATTACIBiENT l Reply to Notice of Violation 50-458/9324-02 l I4 vel IV

REFERENCE Notice of Violation from L. J. Callan to P. D. Graham dated August 31,199 VIOLATION 10CFR73.55(c)(4) requires that detection of penetration or attempted penetration of the protected area shall assure that adequate response by the security organization can be initiate Contrary to the above, the inspectors determined on July 27, 1993, that four zones were defeated during testing of the protected area detection syste REASON FOR THE VIOLATION On July 27,1993 at approximately 0915 hours0.0106 days <br />0.254 hours <br />0.00151 weeks <br />3.481575e-4 months <br />, the U. S. Army Special Forces (ASF)

personnel, as pan of the inspection team, began inspecting the protected area perimeter intmsion detection system (IDS). Four of the 25 zones of the IDS were defeated, each in a different wa The first IDS zone tested was the E-field installed on the primary access point (PAP)

building where the E-field was extended vertically down the side of the building and horizontally 4-6 inches above and along the ground to span the gap between the PAP building and the nearest microwave head. The E-field was defeated by removing eno'!gh u3il beneath the bottom strand of wire to e'3.ow paes=3e et der the. F-field. The reason that the system could be defeated was that there was no design feature to prevent digging beneath the E-fiel The second IDS zone defeated was a microwave zone on the west side of the PAP building. The reason was determined to be that the microwave head was beginning to degrad The third IDS zone defeated was a microwave zone further west of the PAP buildin The zone was defeated with the aid of conduits attached to a wall and a pipe stand to which the microwave was mounted. It was not recognized during a design modification that the conduit along the wall could be used in a manner which could aid an individual in crossing above the detection zon ,

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l The founh IDS zone defeated was also a microwave zone located on the east side of the i

perimeter near the services building. The zone was defeated through use of a metal stand on which the microwave heads were mounted. The metal stand was used as an aid (stepping stone) to jump over the zone and defeat the syste The reason for the third and founh zones being defeated was due to modifications performed on the microwave detection system during the 1991 - 1992 time frame. At that time the microwave zones were completely revamped; i.e., zones were shonened, miemwave heads were relocated, added and stacked. The taller head suppon stands were added to accommodate the stacking of heads and to allow room for head movement and adjustment to get the best detection pattem. It was not recognized ;

during the modification process that the microwave head stmd could be used to defeat l the detection syste !

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l CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS  :

ACHIEVED '

l As each of the weaknesses was identified, compensatory measures were immediately l put into place. Prior to the end of the shift on July 27,1993, the day of discovery, the l subject deficiencies were corrected except the third defeated zone involving the condui '

The conduit used for crossing above the detection zone was rendered unusable the following day when all suppons were removed. Without the suppons, the conduit !

would no longer suppon body weigh The conduit has since been relocated undergroun A concrete vehicle parking bumper weighing about 400 lbs. was placed under the lower E-field wire, preventing an adversary from digging below ground level and forcing him to move higher into the detection zone. After the concrete bumper was installed, Security's testing representative attempted to defeat the system in accordance with Security's tect proceehes and vias unmecessful in defesting ee zone. Vehicle parking bumpers were also placed on a similar E-field zone on the other side of the PAP buildin As stated above on the second zone defeated, it was detennined that a microwave head component was failing. The component was replaced and tested by security technicians in accordance with established security pmcedures. No failures occurre For the above described founh zone that was defeated by using the miemwave head suppon stand as a stepping stone, the excess metal stand was cut and remove Following this, the zone was tested and the system was not defeate i

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i FURTHER STEPS WHICH %TLL BE TAKEN TO AVOID FURTHER l VIOLATIONS

Other IDS zones were examined for similar weaknesses and other micmwave head j suppon stands were identified as having the potential to be used as an aid in defeating i

the IDS system. Those stands ioentified as potentially usable wem reduced to the

, minimum necessary to suppon the head !

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Security will evaluate strengthening its methods for reviewing modifications to ensure j that there is no effect on Security Plan requirement Modifications which are l currently in progress but have not been implemented will be included in this evaluation.

i This evaluation will be comoleted by November 1.199 l

j Security has reviewed their testing pmgram and have determined that no mvision is

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! required. Security will test the IDS in a manner consistent with Regulatory Guide 5.44, RBS Physical Security Plan and security test pmcedures, and within the

} guidelines of the corporate safety manual (Accident Control Manual). Additional j actions taken and planned will funher enhance the overall security pmgram.

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DATE WHEN CORRECTIVE ACTION WILL BE COMPLETED  !

l I j The identified weaknesses were corrected and full compliance was achieved on July 28, I 1993. Compensatory measures were removed at that time.

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