ML20072R960
| ML20072R960 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 09/07/1994 |
| From: | Horn G NEBRASKA PUBLIC POWER DISTRICT |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NLS940040, NUDOCS 9409130369 | |
| Download: ML20072R960 (3) | |
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NEBRASKA PUBLIC POWER DISTRICT 3
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P. O. BOX 499
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GUY R. HORN Vice-President. Nu&ar (402) 563 5518 J
l NLS940040 September 7, 1994 U. S. Nuclear Regulatory Commission Attention: l>ocument Control Desk Washington, D.C. 20555
Subject:
Reply to a Notice of Violation NRC Inspection Report No. 50-298/94-20 Cooper Nuclear Station, NRC Docket 50-298, DPR-46 Gentlemen:
The Nebraska Public Power District (District) hereby submits its response to the Notice of Violation (NOV) transmitted with NRC Inspection Report No. 50-298/94-20.
This inspection report documents the results of the NRC i
inspection conducted by Mr.
T.. W. Dexter during July 11-15, 1994, on a review of activities authorized at Cooper Nuclear Station (CNS). The NRC identified one violation during its inspection of CNS.
An explanation of the violation and corrective actions taken and planned in response to the violation is presented below.
Statement of Violation Cooper Nuclear Station Safeguards Plan, Revision 30, dated October 28,
- 1993, paragraph 1.2.2,
" Personnel Reliability,"
- states, in part,
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" Effective April 27, 1992, Nebraska Public Power District will adhere to l
the provisions of 10 CFR 73.56,"
" Personnel Access Authorization l
Requirement For Nuclear Power Plants."
All elements of Regulatory Guide 5.66 will be implemented to satisfy the requirements of 10 CFR 73.56.
Paragraph 1.5.1.1 of the Safeguards Plan states, in part, "Only persons having a 'need to enter' the protected and vital areas shall be granted unescorted access."
Access lists approved by the Senior Manager of Site Support or his designee identifying these individuals will be maintained at Access Control, Secondary Alarm Station, and Central Alarm Station.
Access lists will be revalidated and approved at least once every 31 days.
Regulatory Guide 5.66, Section B.3, also addresses the reinstatement of access authorization.
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NLS940040 September 7, 1994 Page 2 Contrary to the above, on July 14, 1994, the inspector identified one individual with a valid keycard that had not used the keycard since December 30, 1993.
The individual had not been under the licensee's Continuous Behavioral Observation Program the entire period and, with a valid keycard on file, the individual could have entered the protected area at anytime of his choosing.
In addition, the licensee informed the inspector on July 20, 1994, that at least 28 additional individuals were identified who also had not been under the Continuous Behavioral Observation Program for 31 days or more.
This is a Severity Level IV Violation (Supplement III) (VIO 298/9420-01).
6.dpission or Denial of the Violation d
The District admits the violation.
Reason for the Violation When the District implemented the requirements of 10 CFR 73.56 and Regulatory Guide 5.66, the correlation between a lapse in unescorted access authorization and unescorted access usage was not recognized.
Previously, if the authorization remained valid and only non-usage had exceeded 31 days, no inquiry was conducted.
g.grrective Steos Taken and the Results Achieved The specific keycards noted in the violation have been inactivated.
The District has approved a Temporary Procedure Change Notice (TPCN) to Procedure 1.1, " Station Security," instructing CNS Security Department to identify and inactivate the keycards that have not been used for more than 31 days.
The TPCN also stipulates that reactivation of the keycard requires that either the individual was under a Continuous Behavioral Observation Program during that period of non-use of his/her keycard or the individual must satisfy Access Authorization requirements.
Correct!ye Steos That Vill Be Taken to Avoid Further Violations CNS Procedure 1.1, " Station Security," is being revised to incorporate the above referenced TPCN.
This procedure revision will be completed by September 30, 1994.
Also, the CNS security computer program will be upgraded enabling CNS to readily identify those individuals whom exceeded the 31 day non-usage keycard period.
NLS940040 September 7, 1994 Page 3 Date When Full Compliance Will Be Achieved
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j The District is currently in full compliance.
Should you have any questions or require additional information, please contact me.
Sine rely, l
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. Horn ~
l V.e resident - Nuclear i
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Regional Administrator i
USNRC - Region IV Arlington, Texas NRC Resident Inspector Cooper Nuclear Station NPG Distribution i
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