ML20059M424
| ML20059M424 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 10/15/1993 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC |
| Shared Package | |
| ML20059M374 | List: |
| References | |
| WM-93-0130, WM-93-130, NUDOCS 9311190082 | |
| Download: ML20059M424 (5) | |
Text
.
t pnm W#LF CREEK b
NUCLEAR OPERATING CORPORATIOfI:-
- REGIONIVAnm Neil S " Buzz" Carns October 15, 1993 Chief E=ecuuve Othcer WM 93-0130 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Mail Station F1-137 Washington, D. C. 20555
Reference:
Letter dated September 21, 1993 from L. J. Callan, NRC, to N.
S. Carns, WCNOC
Subject:
Docket No. 50-482:
Reply to Notice of Violation 482/9325-01 Gentlemen:
Attached is Wolf Creek Nuclear Operating Corporation's (WCNOC) " Reply to Notice of Violation 482/9325-01" which was documented in the Reference (NRC Inspection Report 50-462/93-25).
Violation 482/9325-01 concerns the failure to deactivate Automated Control Access Device (ACAD) badges for personnel who no longer needed cr required unescorted access into the protected or vital areas.
2 This letter and the attachment to this letter have been reviewed and it was determined that they do not contain Safeguards Information.
If you have any questions ccncerning this matter, please centact me at (316) 3E4-BB31 ext. 4000 cr Mr. K. J. Moles of my staff at ext. 4565.
Very truly yours.
W Neil S. Carns President and Chief Executive Officer NSC/jan Attachment cc:
J. L. Milhoan 'NRC), w/a G. A.
Pick (NRC), w/a W. D. Reckley (NRC), w/a L. A. Yandell (NRC), w/a 9311190082 931112 PDR ADDCK 05000482 Og
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PO Box 411/ Burbngton. KS 66839 / Phone (3*6) 364-8831 An Ecual c:3portunny Empt yr M OHC/ VET
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l Attachment to WM 93-0130 Page 1 of 4 i
Reply to Notice of Violation 482/9325-01 Violation 482/9325-01:
Failure to deactivate Automated Control Access Device (ACAD) badges for personnel who no longer needed or required unescorted access into the protected or vital l
areas.
Qdi gs :
License Ccnditien 2.E of the Wolf Creek Generating Station (WCGS) Facility Operating License dated June 4,
1985, requires that the licensee fully implement and maintain in effect the Commission approved Physical Security l
Plan, including imendments and changes made pursuant to the authority of 10 CFR 50.54(p).
I Faragraph 1.6.5 of the Physical Security Plan requires, in part, that access i
levels will be reviewed at least every 31 days by a cognizant supervisor or manager and enly those individuals whose specific duties require access to vital areas will be allowed such access levels.
Paragraph 13.7 of the Physical Security Plan requires, in part, that the Manager Security or his designee maintain a list of persons authoriced unescorted access into the protected area.
The list will be maintained in a central file and updated every 31 days by a cognizant supervisor.
Paragraph 6.2.5 ef Administration Procedure 10-015,
" Vital Sector Access Authorization,"
Fevisien 17,
- requires, in
- part, that the cognizant j
manager / supervisor or his designee shall ensure that the personnel within his w0rk gr0ups Only have the acce.s levels required to perform their duties.
Centrary to the above, it was determined that unescorted access to the pr:tected or vital areas for contractor personnel who had terminated their empicyment at the f acility for the period January 1 through August 1,
- 1993, had not been rescinded as required.
An issien of Violation:
W:lf Creek Nuclear Cperating Corporation (WCNOC) agrees that a violation of L ense Cendition 2.E of the Wolf Creek Generating Station Facility Operating L :ense occurred.
Feascn for Violatien:
Frem the period March 2 through May 27, 1993, eleven Performance Improvement Pequests (EIR) were initiated to address the failure to deactivate ACAD badges fer centract personnel who had been terminated.
Of these eleven PIRs, two were identified as not valid because the responsible manager determined the Individuals still had a valid need for access.
Sevsn of the eleven PIRs were initiated by five separate work groups for failure to notify Security that an individual terminated emplcyment at WCGS.
The remaining two PIRs were initiated as a result of a failure by Security personnel to remove ACAD badges f rem service af ter being notified of ter:.inated employees.
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t Attachment to WM 93-0130 Page 2 of 4 l
During the annual Security and Visitor Control Quality Assurance Audit, t
conducted July 6-29, 1993, the audit team recognized recurring problems cencerning the deactivatien of ACAD badges and that corrective actions were l
not effective in preventing recurrence.
FIR 93-0682 was initiated by the audit t e.am to address this recurring problem.
Corrective actions were l
completed July 27, 1993, and included: 1) surveying other utilities to confirm that a 31 day review of access levels was consistent with good industry practice, 2) revising Form KZF-43 to include the Security Person contacted, 3) l l
revising the 31 day employee list form letter, distributed by the Manager Security, reminding responsible managers and supervisors to complete Form KZF-i 43 for individuals leaving WCGS, and 4) sending copies of PIR 93-06B2 to all I
managers resp:nsible for reviewing the 31 day employee list.
i Cn August 1E, 1993, it was identified that a contract employee's ACAD badge
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remained active even though he had been terminated from the contract company.
l A history of this occurrence is provided, as follows:
Cn recente r 17, 1992, a contract employee who was hired en September 8,
1992 through Applied Pcwer & Associates, left WCGS, and was subsequently terminated frem his employment with Applied Power & Associates.
The l
I responsible WCNOC centact was notified by phone that the individual was no lenger with the ccmpany in January 1993.
At this time the responsible WCNOC manager should have notified Security and Human Resources of the j
termination, in accordance with procedt.re HR-151 Revisien 8,
" Termination j
of WCNOC Employees and Contractor / Consultant Personnel," which includes j
l Form KZF-43, " Contractor / Consultant Personnel Check-out Sheet."
This form I
was net ccmpleted and therefore Security was not notified of the l
termination.
A followup letter was sent to the responsible WCNOC contact by Applied Ecwer & Associates in March 1993.
In accordance with procedure ACM 10-D15 Fevision 17,
" Vital Sector Access Authorization," the Manager Security, er designee, is responsible for submitting to each cognizant manager an employee list for review at least every 31 days.
Each cognizant i
manager / supervisor is responsible for notifying Security of any additions cr deletiens to the employee list.
The employee lists frem March through Jul, 1993, were distributed by the Manager Security and signed by the l
app cpriate WCNOC manager, but the individual who had left the company in l
Decerber 1992 was not identified for removal.
On August 18, 1993, the Individual as randomly selected for Drug and Alechol screening, in accordance with WCNOC Fitness-for-Duty policy. When Human Pesources Access I
Screening personnel were informed that the individual was not available for testing, Security was notified, and they expired the individual's ACAD.
On August 23, 1993, PIR 93-0926 was initiated to document the rect cause and corrective actions associated with this occurrence.
Corrective Steps Taken and Pesults Achieved:
For each PIR initiated cencerning failure to deactivate an ACAD badge, app cpriate steps were taken to confirm if the badge was required to remain active or be deactrvated.
Also, where it was incenclusive if an individual's ACAD was net used frcm the time of termination to the time of discovery, Instrumentation & Centrol (I&C) personnel reviewed ACAD history data to verify the ACAD was not used.
Initial ccrrective actions for PIR 93-0926 included verifying that Security expired the individual's ACAD.
Also, I&C verified that the individual's ACAD was not used af ter the individual lef t the site.
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J Attachment to WM 93-0130 Page 3 of 4 The Vice President Plant Operations discussed the subject of this violation during the August 30, 1993, morning plant status meeting, and reminded attending managers and supervisors of their responsibility to inform Security of all employee terminaticns.
This discussion was held on the first working day after the security inspection exit meeting.
Letter WO 93-0157 was issued by the Vice President Plant Operations on August 31, 1993, to all Managers discussing their responsibility to exercise appropriate self-checking and attention to detail to ensure that Security is premptly notified whenever employee / contractor access levels change.
As a result of this memo, during review of the subsequent 31 day employee access list, two additional badges belonging to owner employees present on-site for outage related activities only, were deactivated.
Also, several ACAD badges for contractors with infrequent access to the protected and vital areas were identified.
These ACAD badges were either deactivated or expired.
This eliminated the potential for these individuals to gain access if a change in employment was made and WCNCC was not notified.
A computer software enhancement has been initiated to allow monitoring of ACAD badge usage for all ACADs. Any ACAD not used for 31 days will be removed from SAs and will require approval from the user's site contact before being reinstated.
This computer software modification will be operational and implemented by January 1, 1994.
Until the computer software modification is implemented, Security has develeped a process to support the expiration and reissuance of contractor t
ACAD badges for contractors with infrequent access to the protected and vital areas.
This process will reduce the total number of contractor badges and will ensure that contractors with infrequent access to the protected and vital areas have a valid need for unescorted access.
The following process has been develcped and implemented by Security:
- At the beginning of each month, contractor ACAD badges, for contractors with infrequent access to the protected and vital areas, will be identified and the lapel clips will be removed.
- If during the month a contractor, for which the lapel clip has been
- removed, requests his ACAD, a lapel clip will be issued and the contractor will be given his badge.
- Any ACADs that remain at the end of the month with no lapel clip, will be removed from the SAS, expired, and secured in Security Badging.
Those which have been issued a lapel clip during the month will remain in SAS.
The process will be repeated each month.
- ACADs that have been secured in Security Badging will not be issued to the contractor upon request until their site contact states that the centractor has a valid need for unescorted access to the protected and/or vital areas.
=_ -...
Attachment te WM 93-0130 Page 4 of 4 This process will reduce the number of contractor badges that are in SAS, and verify that access is required for centractors whose badges have remained in SAS for a maximum of 61 days (e.g., a badge in SAS requested November 1 would be a :essible to the centractor up until December 31 of that same year), and reduce the total number of active contractor badges.
Corrective steps That Will Be Taken to Avoid Further Violations:
M:st incidents addressed by this violatien occur during or shortly after an j
cutage, when the majority of contractsr support is required.
Therefore, the responsibility for Managers and Supervisors to assure Form KZF-43,
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"Centractor/ Consultant Personnel Check-out Sheet" is completed in a timely manner will be included in the next Refueling Outage handbook.
An announcement will be made during the morning plant status meeting by the Vice President Plant Operations at the start of the next refueling outage, reminding all managers / supervisors of their responsibility to ensure that Form KZF-43 is : mpleted upon termination of contract support.
- Also, for the next refueling
- outage, letters will be sent to managers / supervisors who may be utilizing contract support, reminding them of the requirement to use KZF-43.
l Date When Full Compliance Will Be Achieved:
The actions prescribed for the subsequent Refueling Outage were develeped to I
heighten awareness of this issue when most incidents of this nature occur.
These actions to heighten management awareness and responsibility to complete F:rm K F-4 3 and review the 31 day employee access list, and for Security to manually pull contractor badges, addressed the concerns of this violation.
The ecmputer m:difications identified in response to this violation are censidered an additional backup for assuring ' compliance with the access authorization pregram.
Therefore, full ecmpliance with License cendition 2.E has been achieved.
Actual er Pctential Consequences of This Violation:
A review of ACAD badge usage for badges that remained active after termination l
Of employment concluded that no unescorted access to the protected or vital l
areas cc urred.
Thus, there was no potential for radiclogical sabotage, and there was never a threat to the health and safety of the public.
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