ML20044E552
| ML20044E552 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 05/03/1993 |
| From: | Graham P GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20044E550 | List: |
| References | |
| RBEXEC-93-214, NUDOCS 9305250149 | |
| Download: ML20044E552 (5) | |
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GiiLF STATES IJTIL:T!ES CDMPAArY k" /C May 3.1993 IGG-38.441 File Nos. G9.5. G15.4.1 RBEXEC-93-:;4 U.S. Nacicar Regulatory Commission Remon IV r
611 Ryan Plaza Dr:ve. Suite 200 Arlington. TX 76011 Gendemen:
River Benc 52non - Unit i Doexet No 40 259/oLOS Pursuant to 10CFR2.20L this iener provices Gulf States Utilities Company 3 iGSE:
response to tne Notice of Violanons for NRC Inspection Report 50 25S,93-08.
~.:e nspecnon was concuctec by Messrs. T W. Dexter anc A.B. Earnest on Maren 5-!:.
1993 of acuvines authonzec by NRC Opemung License NPF-J7 for Ris er Benc Sunen.
Unit !
GSU's reply to tne v!oinuons are provicea m tne atmenments.
Should you have any quesnons. please contact Mr. D.N. Lordng at 150 1351 -;;5T Sincere!v.
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P. D. Graham r
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Anacn. ment
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cc-U.S. Nuclear Regulatory Commission Document Control Desk Washington. D.C. 20555 NRC Resident Inspector P.O. Box 1051 St. Francisville. LA 70775 9305250149 930519 PDR ADOCK 05000459 G
i ATTACIDIENT 1 REPLY TO NOTICE OF VIOLATION (458/9308-01)
LEVEL IV REFERENCE Notice of Violation - 12tter from L.J. Callan to P.D. Graham dated April 2.1993.
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VIOLATION Failure to Maintain Kevcard Accountability I
The Introduction Section of the Physical Secunty Plan states that security procedures orovide the detailed instructions necessary to implement the plan.
Security Position Instruc: ion. Pmcedure SPI-12. paragraph 3.2.4(1) states. in part. "Supemse j
the inventory of all KCs fKeycards) and VKCs (Visitor Keycards) as follows:' Paragmon 3.2.4(1)(i) states. "Using the SUPI console. log out KCs displayed as (in] the PA but in tne rack. Prepare a SECFM 115. Security Incident Recon."
i Contrary to the above. the inspectors identi5ed that on August 24,1992. and Maren 1.1993.
l keycards were displayed as being in the protected area when in fact. the badges were in Ice i
security badge racks. The keycard inventog did not identify the discrepancy in the keycara accoumability program.
5 REASON FOR VIOLATION 1
The senior access control supervisor (SACS) failed to ensure that a pmper kevcara manuai inventory accountability was inidated and conducted in accordance with his secunty position instruction (SPI-12). In delegating the keycard accountability duties to the access control ofEcers j
'vho actually perform the keycard accountability task. the SACS failed to directly oversee the task being performed and failed to recognize that the security position instmetions (SPI-4) for the access contml of5cers did not contain guidance on performing the task. i.e. the implementing procedures were silent on how to perfonn keycard accountability. This activity had been l
perfonned by ' access control officers through experience.
This event was caused by an inadequate procedure. Failure by the SACS to ensure that the keycard accountability was I
performed is considered human error and a lack of attention to detail.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIETTE l
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Implementing Pmcedure 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 oeen 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 proper manual keycard accountacility at the end of the day. The SPI also speciEes that once the keycard manual accountability
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is performed, the ofncers are to switch roles and perform a second keycard i
accountability check.
CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS All secunty opentions supenisors and access control of0cers have been retramea on Ine reviseu security position instructions and the imponance of performing a correct keycard accountaottity.
Secunty procedures and SPIs are being reviewed by the secunty operations supernsors ana officers to identify areas where additional information or clarincation is reuuired. This review is to be completed by April 1.1994 l
DATE WHEN FULL COMPLIANCE MTLL BE ACHIEVED F
Compiiance has been achieved.
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ATTACIDIENT 2 j
REPLY TO NOTICE OF VIOLATION (458/9308-02)
LEVEL IV t
REFERENCE Notice of Violation - Iztter from L.J. Callan to P.D. Graham dated April 2.1993.
VIOLATION I
Failum to Maintain Uninterruptible Power to the Security Svstems Paragnph 'i.5 of the Physical Security P!an recuires that security equipment be fumisnea i
unintermptible power from buses that are also backed by standby diesel generators.
i Contrary to the above. the inspectors identined that from July 22 until August 4.1992. the unintermptible power simply system was in manual bypass. thereby. eliminating unmtermetible power for the system.
REASON FOR THE VIOLATION During the course of Refueling Outage 4. in tne above described July.1992 time frame. tne Electrical Maintenance Department (EMD) performed maintenance work orders on Secunty s
.i unintermptible power supply (UPS) system. Secunty management was not of5cially not15eo that the secunty UPS system was taken out-of-service. The EMD was workmg on the invener and was changing out battery cells in Ine direct current (de) power source. all of which is part-of the UPS power supply system sening the security system loads with nonnal power.
In order to ensure personnel safety while maintenance personnel were working on the system.
I the normal power (including the UPS system) was de-energized To provide the security system loads with power during the maintenance period. the manual bypass switch was switched to the altemate source of power. While the power supply system was in this conficuration. River Bend i
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 j
must be performed to prevent degradation of the equipment.
i At the time that maintenance was being performed. Security's central 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 i
is the normal configuration for maintenance on all RBS inveners including safety related 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 beginning of the maintenance period.
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As a result of this incident, it was also determined that no list of the maior electrical loacs for
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security equipment had been identified to Security or Operations. Consequently, Operations did not know that Security needed to be informed when Operations was prepa ing to tag out the UPS power supply system.
Inadequate procedures and a lack of communications are root causes of this event.
CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED l
This event was self-identified by GSU personnel. When Security reahzed the unusual length of time involved with the maintenance of the power supply system. personnel from Secunty and EMD met and discussed being in noncompliance with the PSP and how the maintenance activity could be promptly performed. Improved communications and notifications needed during future l
maintenance penods was also discussed. Secunty management initiated a condition rescri iCR 92-0651) to address the situanon and to ensure that Security would be made aware of future maintenance acuvity involving the power suppiy system. Licensing personnel nott5ed NRC Repon IV inspection personnel by telephone on August 4.1992. that RBS was operaung in the alternate power supply configumtion.
As a result of this event. Desien Engineenng provided Security and Operanons with a list of the vanous sources of power and major ioads for security equipment. Security requestea that-Opemtions take action necessary to ensure Security is properly notined prior to taggmg out or working on power supply equipment.
Operations has incorpora:ed this informanon into procedure OSP-0019 " Electrical Bus Outages' to ensure that Security is noti 5ed prior to tagging security power supply equipment out of service. Information has also been incorocrated into
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security procedures to ensure that. when the notincation is made to Security, the alarm stauon operator will take necessary compensatorv measures.
These actions will ennance communications and heighten awareness of being without the UPS system which will mmimize
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downtime of the UPS system.
l FUTURE STEPS TO BE TAKEN TO AVOID FUTERE VIOLATIONS As future maintenance activities are performed. Security management will monitor the activity to ensure that communications have taken place between departments so that Security is aware of the fullimpact of the maintenance and that proper compensatory measures are taken.
During the next submittal of a PSP revision. a statement clarifying the power supply
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requirements during maintenance on the UPS system will be added in the text.
i DATE CORRECTIVE ACTION VIILL BE COMPLETED Full compliance was achieved on August 4,1992. Training on procedure changes. additional corrective actions to provide for Security contingencies involving power supply outages. and the revision of the PSP will be completed by May 30,1993.
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