ML17332B015
| ML17332B015 | |
| Person / Time | |
|---|---|
| Site: | Cook  |
| Issue date: | 11/15/1995 |
| From: | Fitzpatrick E INDIANA MICHIGAN POWER CO. (FORMERLY INDIANA & MICHIG |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| AEP:NRC:1224C, NUDOCS 9511270053 | |
| Download: ML17332B015 (15) | |
Text
PRIC)RI EY
~(ACCELERATED RIDS PROCESSING'~
REGULATORY INFORMATION DISTRIBUTXON SYSTEM (RIDS)
CCESSiON NBR:9511270053 DOC.DATE: 95/11/15 NOTARIZED-YES DOCKET g FACIL:50-315 Donald C.
Cook Nuclear Power Plant, Un-t 1, Indiana M
05000315 50-316 Donald C.
Cook Nuclear Power Plant, Unit 2, Indiana M
05000316 AUTH.NAME AUTHOR AFFILIATION FITZPATRICK,E.
Indiana Michigan Power Co. (formerly Indiana
& Michigan Ele RECIP.NAME RECXPIENT AFFILIATION Document Control Branch (Document Control Desk)
R
SUBJECT:
Responds to violations noted in insp repts 50-315/95-11 50-316/95-11.Corrective actions:contract enployee removed from plant protected area on 950822
& unescorted access suspended
& subsequently terminated.
DISTRIBUTION CODE:
IE01D COPIES RECEIVED:LTR ENCL SIZE-TITLE: General (50 Dkt) -Xnsp Rept/Notice of Vio ation esponse NOTES:
RECIPIENT ID CODE/NAME PD3-1 PD INTERNAL: AEOD/DEIB AE0D~XC.
gPX12 CEPS ER NRR/DRCH/HHFB NUDOCS-ABSTRACT OGC/HDS2 XTERNAL: LITCO BRYCE,J H
NRC PDR COPIES LTTR ENCL 1
1 1
1 1
1 1
1 1
1 1
1 1
1 1
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1 RECIPIENT ID CODE/NAME HICKMAN,J AEOD/SPD/RAB DEDRO NRR/DISP/PI PB NRR/DRPM/PECB OE DIR RGN3 FILE 01 NOAC COPIES LTTR ENCL 1
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N iOTE TOALL"RIDS" RECIPIENTS:
PLEASE HELP L'S TO REDL'CE O'KSTE! CONTAC'I"IHE DOCL'III:4TCONTROI.
DESFK. ROOM Pl.37 (EAT. 304.o083
) TO ELIXII~ATE5'OL'R ~A~II-I:RO~I DISTRIIIL'TIOYLISTS I'OR DOCL'IIL'X'I'SYOL'O~"I'LFI'.ll!
iTOTAL NUMBER OF COPIES REQUIRED-LTTR ~ ENCL
4 if II
Indiana Michigan Power Company PO Box 16631 Coiumbus, OH 43216 INDIANA NICHIGAN POWER November 15, 1995 AEP:NRCr1224C 10 CFR 2.201 Docket Nos.:
50-315 50-316 U. S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.
C.
20555 Gen"lemen:
Donald C.
Cook Nuclear Plant Units 1 and 2
NRC INSPECTION REPORTS NO. 50-315/95011 (DRS)
AND 50-316/95011 (DRS)
REPLY TO NOTICE OF APPARENT VIOLATION This letter is in response to a letter from Mr. G. E. Grant, dated October 16, 1995, that forwarded a notice of apparent violation to Indiana Michigan Power Company.
The notice of apparent violation was the result of an inspection conducted by Mr. J. L. Belanger on September 19, 1995.
The apparent violation is associated with the granting of unescorted access to a contract individual prior to determining that all necessary requirements for obtaining unescorted access had been completed.
A comprehensive review of the apparent violation has been conducted and actions have been taken to prevent recurrence.
Our reply to the apparent violation is attached.
As requested, our response does not include any personal privacy, proprietary, or safeguards information.
Sincerely, SWORN TO AND SUBSCRIBED BEFORE ME E.
E. Fitzpatrick Vice President Notary Public eh 9511270053
'251115 PDR ADOCK 05000315 9
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U.
S. Nuclear Regulatory Commission Page 2
.;"P:NRC:1224C Attachment cc:
A. A. Blind G. Charnoff H. J. Miller NFEM Section Chief NRC Resident inspector
- Bridgman J.
R. Padgett W. T. Russell NRC NRR
ATTACHMENT TO AEP:NRC: 1224C REPLY TO NOTICE OF APPARENT VIOIATION:
NRC INSPECTION REPORT NOS.
50-315/95011 (DRS)
AND 50-316/95011 (DRS)
ATTACHMENT TO AEP: Ni'C: 1224C Page 1
REASON FOR THE APPARENT VIOLATION j3~AKG~OQ As described in our Licensee Event Report (LER) 95-S-001, a
contract employee was in the process of completing requirements (i.e., chemical testing, plant access training, etc.)
necessary to gain unescorted access to the protected/vital areas of the plant.
Prior to granting unescorted access a review of the contract employee's file was conducted in accordance with plant procedures.
All required elements were completed on August 16, 1995, with the
'exception of chemical test results.
During the review process an Access Control Clerk incorrectly documented a
negative chemical test result date, based on chemical test results for an individual with the same last name.
On August 17,
- 1995, the contract employee was granted unescorted access to the plant.
On August 22, 1995, while attempting to provide the Medical Review Officer (MRO) with information necessary for the MRO to contact the contract
- employee, the Access Control Supervisor determined the contract employee had been granted unescorted access prior to the completion of chemical testing requirements.
On August 22,
- 1995, the MRO verbally reported positive test results for THC at 50ng for the contract employee's test collected on August 16, 1995.
(Written documentation was provided the following day.)
DISCUSSION The Access Control Clerk incorrectly identified the contract employee as having been tested and reported as negative for chemical substances.
The clerk failed to properly use information (i.e., social security number and first name) provided to prevent misidentification.
As a result of this failure, the contract employee worked with unescorted access status in the plant protected/vital areas from August 19 through August 22, 1995.
While in the plant, the contract employeeworked as a general laborer moving equipment into containment and did not supervise other personnel.
The contract employee did not perform work on safety related equipment.
Work was accomplished in teams with direct supervision.
The contractor's supervisor provided documentation that the employee did not display character traits or behavior patterns adverse to the goals of the unescorted access authorization program.
4
ATTACHMENT TO AEP:NRC: 1224C Page 2
Although the contract employee was granted unescorted access to the plant protected
- area, activities performed did not result in a significant safety concern nor did the activities pose a significant hazard to the health and safety of the general public.
The inspection report transmittal letter referenced a similar event.
(EA 95-002) in which another individual was granted unescorted access which was later determined to be inappropriate.
Although results for each event were similar, in that a person was granted unescorted access and should not have been, the circumstances leading to and the cause of the events were uniquely different.
The first event (EA 95-002) identified a possible programmatic error in the review and ad)udication process, while this event was the result of a clerical oversight.
CONCLUSION
'he reason for the apparent violation was the failure to review all pertinent information prior to granting unescorted access in accordance with 10 CFR 73.56(b)(3), resulting from an oversight on the part of the access control clerk.
Although there was no specific written guidance given to the clerk which required verification of all provided identifying information on the specimen log report prior to documenting negative test results on the access processing
- form, management expectations were that all identifying information was to be verified to ensure that the negative test results were for the current individual on the access control processing form.
2.
CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS CHIEVED On August 22, 1995, the contract employee was removed from the plant protected area and unescorted access was suspended and subsequently terminated.
A review of work activities was promptly initiated.
The review of activities, which was completed on August 23,
- 1995, determined no aberrant behavior was observed and that the contract employee did not work on any safety related systems.
A review was conducted between August 23,
- 1995, and August 28, 1995, to assure that negative chemical test results were received prior to granting unescorted
1
ATTACHMENT TO AEP:NRC: 1224C Page 3
access for 964*
persons during the period June 15, 1995, through August 25, 1995.
No additional discrepancies were noted.
3.
A review was also conducted between August 25,
- 1995, and September 8,
- 1995, to assure that plant access training was completed prior to granting unescorted access for 1,059*
persons during the period June 15, 1995, to September 6, 1995.
No discrepancies were noted.
3.
CO ECTIVE STEPS
~VI
~IO WI L E
AKEN TO AV D
As an enhancement, a revision was made to 12 PMP 2060 ACS.002 (Access Authorization Program)
Attachment D
(Access Processing Form) requiring verification by the individual completing the review that the name, social security
- number, and dates correctly identify the individual, and verification/validation of entries by the signature authority prior to approval.
This procedure revision was approved October 19, 1995.
Subsequent to the approval of the procedure revision all access control personnel were trained on the use and completion of Attachment D.
2.
The access control clerk was counseled as to the necessity of verifying all identifying information for eacn required element prior to an individual being granted unescorted access.
A letter documenting the access control clerk's understanding of this necessity was placed in the employee's departmental personnel file.
3.
Meetings between management and access control personnel were held to discuss the event and to emphasize the necessity of verifying all identifying information for each required element prior to granting access.
4.
ATE WHEN LL CO LIANCE WAS ACH EVED Full compliance was achieved on August 22,
- 1995, when the contractor was removed from the protected/vital areas and unescorted access was suspended.
These numbers (964, 1,059) reflect the number of personnel processed throush the dotes identified for the Unit 1 refuelin6 oute6e.
The in-processin6 started on 6/15/95.
0 l
('
ATTACHMENT TO AEP NRC 1224C Page 4
CLARIFICATIONS The following discussion is intended to clarify certain items in the NRC's October 16, 1995, letter and attached notice of apparent violation.
(Cover letter, third paragraph, second sentence):
"The violation involved a contractor inappropriately being grante" un~ corted access to the plant's protected and vital areas after testing positive for a controlled substance."
The contract employee was inappropriately granted unescorted access prior to completion of all necessary requirements for obtaining unescorted acces~.
The individual subsequently was determined to have tested positive for a controlled substance.
2.
(Inspection Summary, Results Paragraph): "Specifically, an individual was inappropriately granted unescorted access after testing positive for a
controlled substance."
The clarification presented above also applies to this item.
3.
(Inspection
- Summary, Results Paragraph):
"The individual gained access to the protected area and vital area August 18 and 22, 1995."
The contract individual did not gain access until August 19,
- 1995, and entered each cb'-.
through August 22, 1995.
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