ML20066C507
| ML20066C507 | |
| Person / Time | |
|---|---|
| Site: | Calvert Cliffs  |
| Issue date: | 01/03/1991 |
| From: | Schwartz G BALTIMORE GAS & ELECTRIC CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| EA-90-186, NUDOCS 9101100208 | |
| Download: ML20066C507 (5) | |
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- s BALTIMORE GASAND ELECTRIC CHARLES CENTER
- P.O. BOX 1475
- BALTIMORE. MARYLAND 21203 1475 l
(301) 234-5000
.1-January 3,19 PA %186 U. S. Nuclear Regulatory Commission 1
Washington, D.C. 20555 ATTENTION:
Document Controf Desk SUHJECT:
Calvert Cliffs Nuclear Power Piant -
Unit Nos.1 & 2; Docket Nos. S317 & $0-318 Reply to Notlec of Violation and Proposed Imposition of Civil Penalty NRC Inspection Report Nos.50-317S0 28 and $318S0 28 REI'ERENCES:
(a) Letter dated: December 5,1990, U.S. Nuclear Regulatory Commission
Dear Sirs:
Reference (a) forwarded Nucicar Regulatory Commission (NRC) Region i Notice of Violation and Proposed imposition of Civil Penalty ($12,500) based on NRC 1nspcetion Report Nos.50 317N0 28 and 50 318/428, dated December 5,1990. The violation involved a failure of Nuclear Security Personnel to properly scarch, using metal detectors, for a fificen minute period on the morning of September 11,19)0.
l The Baltimore Gas and Electric Company (BG&E) accepts the violation and the proposed civil penalty. Our response to the Notice of Violation is provided in an enclosure to this letter. Also enclosed is llG&E Check No.
190461 in the amount of $12,500.
Should you have any further questions regarding this matter, we will be pleased to discuss them with you.
VeryTruly Yours,
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G. Dowll Schwartz, Jr.
Vice President GeneralSenicca Dhision STATE OF MARYLAND:
TO WIT:
CITY OF BALTIMORE:
Mr, G. Dowell Schwartz, Jr., being duty sworn states that he is Vke Presloont of the Baltimore Gas and Electric Company, a cor.
potation in the State of Maryland; that he provides the foreg* sing response for the purpose therein tot forth; that the statements made are true and correct to the best of Ms knowledge,information and belief; and that he was authorized to provide the g
response on behalf of said corporation.
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Document Control Desk January 5,1990 l
Page 2 EA 90-186
Enclosures:
(1) Response to Notice of Violation and Proposed imposition of Civil Penalty (NRC Inspection Report Nos. $0-317fX)-28 and 50-31M)0-28)
(2) DG&E Check No.190M61 cc:
D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T, Martin, NRC L E. Nicholson, NRC R. I. McLean, DNR 1
Document Control Desk January 5,1990 Page 3
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G. V. McGowan C.11. Poindexter i
J. A.Tiernan/A.J.Slusark l
M.J. Micrnicki-W. R. Corcoran.
C.11. Cruse /P. E. Katz R. C. DeYoung R. M. Douglas /R. F. Ar.h R. P. licibel/T. N. Pritchett C. P. Johnson
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L B. Russell /J. R. lemons G. L Adams (2)
A.B. Anujo J. E. Baum i
G. L Bell J. J. Connolly R. E. Denton G. L Detter G.J. Falibota L D. Graler D. V. Graf R. R. Keimig L S. Larragoite B. S. Montgomery P. A.Pieringer M. L Stone J. II. Walter R. C. Dernoga L P.Gibbs
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i ENCLOSURE (1)
Response to Notice of Violation and Proposed Itnposition of Civil Penally NRC Inspection Report Nos.50 317/90 28 and 50 318/90 28 1.
Description and Cause of the Event At approximately 6:00 a.m. on September 11,1990, three of the four metal detectors in the Security Process-ing Facility began experiencing constant spurious alarms. By 6:15 a.m., the back up of personnel waiting to be processed into the plant reached a significant level due to the delays caused by these alarms. One of the security officers notified the Nuclear Security Supenhor of the problem, who then directed that personnel be permitted to pass through the me al detectors without hindrance and without employing appropriate compensatory measures.
At 6:30 a.m., the spurious alarms decreased to a manageable level and the officers restored the volume on the machines. Normal processing of personnel commenced. During the 15 minute period, approximately 100 person-nel entered the plant.
The root cause of this event can be attributed tojudgement errors committed in part by the Nuclear Security
%penhor, his subordinates, as well as Management in Security. The Nuclear Security Supenhor, who believed ne had the authority, improperly suspended metal detector search requirements. lie did not consult the Security Plan or Procedures when making his decision. The supervisor's poot judgement can be traced to inadequate ini-tial training he received.
The inappropriate actions of the supenhor's subordinates contributed to this event. The security officers notified the supenhor of the problem with the detectors, but failed to take action when they knew their supenisor's decision to suspend searches was incorrect.The officers were adequately trained to respond to events like this, but did not comply with the appropriate procedures after the supenisor made his decision. The officers' failure to comply with the appropriate procedures and to promptly report this cwnt can be attributed to an atmosphere in which the supenisor discouraged the questioning of his directives by his subordinates.
The actions taken by both the Nuclear Security Supervisor and his subordinates can be linked to previous decisions made by Security Manegement. Security Management failed to assess the appropriate level of training the supenisor needed to assume his duties. An initial training program was customized for the supenisor, based on assumptions regarding his security knowledge level at the time, and failed to properly prepare the supervisor.
Additionally, Security Management was aware that communications problems existed between the supenisor and his officers, but did not take corrective actions to reschc the problem.
A contributing cause to this event was the failure of the metal detector alarms.The constant nuisance alarms, received in 75% of the detectors, precipitated the actions taken by the supenisor and his officers.
Corrective Steps Taken and Results Achieved The supenisor imelved with this event has been remond from his position at Calvert Cliffs and transferred to a non supenisory position within another part of the Company. Administrative actions have been initiated for -
the ceher security officers invohrd. Deficiencies related to the event will be reflected in Ihe performance appraisals of allinvohed personnel.
l All security shifts have been advised of the nature and seriousness of this violation. Management's policy of I
strictly adhering to procedures was also restated, along with the necessity to communicate concerns using the BGAE 'Open Door' policy. Post orders have been revised to remove any language that could be misinterpreted j
to allow the wahing of procedures by any security personnel.
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ENCLOSURE (1)
(Continued) l
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Response to Notice of Violation and Proposed imposition of Civil Penalty NRC Inspection Report Nos. 50 317/90 28 and 50-318/90 28 Additionally, all metal detectors have becn replaced with new equipment with a significantly lower false alarm i
rate. The metal detector procedures were also revised to specify exact compensatory measures required for this type of event.
Ill. Corrective Steps Which Will Be Taken to Avoid Further Violations To ensure new supenisors receive an appropriate level of initial training, Security Management will require that more extensive tests are performed to determine the supervisor's needs. Additionally, all Security Supenisors will receive corporate supenisory training that will place more emphasis on basic skills, such as communications and the development of positive relationships with subordinates.
i Security Management will continue to monitor the working relationships maintained by each shift. When situa-tions are noted, such as communication concerns, Security Management will move quickly to resolve the issue. In-i creased follow-up will then occur to ensure the corrective actions are adequate and escalated action will be taken, as appropriate.
Security training in both initial and requalification training programs has been revised toincorporate the 'les-sons learned
- from this event. These ' lessons' include the requirement to comply with procedures and to prompt-ly communicate concerns to management. A positive improvement in communications has already been noted as evidenced by Nuclear Security Officers' willingness to discuss their concerns with management during meetings held eu cach shift.
i The ' lessons' are also being stressed in Company's personnel through the use of communications meetings and media and,in particular, to the personnel at Calvert Cliffs.
An additional corrective step to be taken includes intensifying the use of comprehensive self assessment ac-i thitics. An independent consultant has begun an in. depth assessment of BO&E's Nuclear Security Program. This study will help to identify areas within the security program that need additional improvements.
IV.
Date When Full Compliance Will Be Achieved Full compliance with the Cahrrt Cliffs Security Plan was achieved on September 11.1990 at approximately_
6:30 a.m. when the metal detectors were returned to senice. This event has been incorporated into the Nuclear Security's initial and requalification training programs as a case study. The requalification cycle will be completed by June 1,1991.
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