ML20059A901
| ML20059A901 | |
| Person / Time | |
|---|---|
| Site: | Dresden  |
| Issue date: | 12/22/1993 |
| From: | Farrar D COMMONWEALTH EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9401030195 | |
| Download: ML20059A901 (3) | |
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N Comm:nwealth Edison
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1400 Opus Place 7
Downers Grove, Illinois 60515 December 22,1993 U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Document Control Desk
Subject:
Dresden Nuclear Power Station Units 2 and 3 Response to. Notice of Violation; Inspection Report 50-10/93003; 50-237/93025; 50 -
249/93025 NRC Docket Numbers 50-10,50-237 and 50-249
Reference:
John B. Martin letter to Mike J. Wallace, transmitting Inspection Report 50-10/93003; 50-237/93025; 50-249/93025.
Enclosed is Commonwealth Fdison Company's (CECO) respon e to Notice of Violation-contained in Inspection Reports 50-10/93003 and 50-237(249)/93025 as requested in the referenced letter.
Although Dresden Station does not conte 3t the violation, CECO is concerned that this enforcement action may set the precedence that any firearm facsimiles (wood, plastic, etc.)
which enter the protected area undetected, will result in escalated enforcement. To protect against this possibility would place unnecessary financial burden on the licensee with minimal increase in security protection. CECO welcomes the opportunity to further discuss this matter.
If your staff has any questions concerning this letter, please refer them to Sara Reece-Koenig, Regulatory Performance Administrator at (708) 663-7250.
Sincerely, r.
D. Farrar Nuclear Regulatory Services Manager attachments cc:
J. B. Martin, Regional Administrator Region III J. F. Stang, Project Manager, NRR -
M. N. Leach, Senior Resident Inspector, Dresden k:rpa:inspts:dresden:vio93025,wpf:1 e
9401030195 931222 I
PDR ADOCK 05000010 Ef)T G
PDR i.
.e ATTACHMENT BESPONSE TO NOTICE OF VIOLA UQM NRC INSPECTION REPORT 50-10/93003; 50-237/93025; 50 249/93025 VIOLATIQE; Amen <lment 42 and 38 of facility operating license numbers DPR-02, DPR-19, and DPR-25 '
require that the licensee have and maintain a Station Security Plan.
Technical Specification 6.2.A requires written procedures to be implemented covering the Station Security Plan.
Section D.1 of Security Post Order No.1, Revision 13, dated January 1993 which implements the Station Security Plan requires, in part, the security officer to visually examine the contents of all packages that are conveyed through the x-ray machine, and to control and assure the physical search of any packages containing items which, viewed on the x-ray monitor, are unidentifiable or seem suspicious. This type of item is termed an " indiscernible mass".
Contrary to the above, on August 16,1993, at approximately 6:55 a.m., a security officer did not adequately examine, control and assure the physical search of a package containing an indiscernible mass when viewed on the x-ray monitor prior to its entry inte the protected area.
This indiscernible mass was a facsimile of a firearm.
REASON FQB VIOLATION:
I A review of this incident indicates that DAP 13-07, Personnel A ccess Control, requires that "all search and ingress operations must be performed as specified by Security Post Order No.1". The Security Post Order clearly describes the security officer's responsibilities for inspection and search of an item classified as an indiscernible mass.
A root cause evaluation of the event assessed training, procedures, equipment, and human factors. All training and procedures correspond with the search requirements described within Security Post Order No.1. Security tested the x-ray unit based on established procedures, An " equipment malfunction" was not a factor in the event. A re-creation of the event, conducted using the actual device, revealed that the " facsimile" firearm appeared as an
.l indiscernible mass when processed through the x-ray unit. Thus, the physical search l
requirements should have been applied by the security officer. Non-compliance with
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proc <
91 requF nents occurred due to an isolated personnel error; the security officer failed to idehtify the item as an indiscernible mass.
j While the admission of the facsimile firearm on-site represents an isolated security failure, j
there was no significant opportunity for exploitation of the object. The safety significance 1
was minimal because there was clearly no malevolent intent on the part of the individual that introked the facsimile firearm to the protected area. The event was deemed non-reportable and har died as a loggable event; this conclusion is consistent with guidance in generic letter 91-03 ?cporting of Safeguards Events" 1
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d A TTACilMENT RESEQNSE TO NOTICE OF VIOLATION NRC INSPECTION REPORT 50-10/93003; 50-237/93025; 50 249/93025 CORRECTIVE STEPS TAKEN AND RESULTS ACIIIEVED:
When notified that a " facsimile". firearm had been introduced to the protected area, Security supervision immediately relieved the officer involved with the event from all security duties.
Prior to returning to duty, the officer involved with the event, was re-trained and re-evaluated on the operation and procedures governing the x-ray pcsition. A comprehensive investigation was conducted. Based on the results of the investigation, it was concluded that the event was caused by an isolated personnel error.
CHRRECTIVE STEPS TAKEN TO AVOID FURTIIER VIQLATION:
The root cause for the event was not immediately discernable; therefore, the following corrective actions were taken:
1.
The event details were disseminated to the other five Commonwealth Edison sites verbally on August 18,1993, and a follow-up letter dated August 24, 1993 was issued.
2.
To assure that workers understand the expectation regarding security events, a tailgate article focusing on the timely reporting of security events was supplied to station employees on August 25,1993.
3.
The entire guard force was proficiency tested on the operation of the x-ray unit; the testing was completed with 100 percent accuracy on August 23,1993.
In a continuous effort to improve, Security applied positive enhancements to the existing x-ray drill program. Enhancements to the unannounced drill program include a variation of the
" role-players" used, and a temporary increase in drill frequency. The drill frequency was returned to nonnal on October 31,1993. The unannounced x-ray drills will continue to be conducted with the role-player enhancement at the nonnal frequency.
Security conducted a survey of ten nuclear facilities for different techniques of x-ray evaluation; this was completed on September 02,1993. In comparison, the x-ray evaluation process used at Dresden Station was equal, or superior to the methods used at the facilities surveyed. Consequently, no additional enhancements were made to the existing x-ray evaluation process.
RATE WIIEN FULL COMPLIANCE WILL IIE ACIIIEVED:
Dresden was in full compliance on August 17,1993 when proper x-ray unit operation was verified, and the officer involved in the event was removed from the position of x-ray operator.
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