ML20113A164
| ML20113A164 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 06/18/1996 |
| From: | Carns N WOLF CREEK NUCLEAR OPERATING CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| WM-96-0073, WM-96-73, NUDOCS 9606240143 | |
| Download: ML20113A164 (3) | |
Text
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W$LF CREEK NUCLEAR OPERATING CORPORATION
\\
Ned S. " Buzz
- Carns Chairman, President and Chief Executive Offcer June 18, 1996 WM 96-0073 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk l
Mail Station P1-137 i
Washington, D.
C.
20555
Reference:
Letter dated May 25, 1996, from T.
P. Gwynn, NRC, to N. S. Carns, WCNOC
Subject:
Docket No 50-482: Response to Notice of Violation 50-482/9610-01 Gentlemen:
)
J This letter transmits Wolf Creek Nuclear Operating Corporation's (WCNOC) response to Notice of Violation 50-482/9610-01.
This violation concerns the failure to use the operable taut-wire intrusion detection system on the l
protected area barrier inside the warehouse cargo access portal when the portal was open for cargo access.
Instead, WCNOC posted a member of the security force at the warehouse cargo search area.
WCNOC's response to this violation is in the attachment.
This letter and its attachment contain no safeguards material.
If you have any questions regard 3ng this response, please contact me at (316) 364-8831, extension 4100, or Mr. Terry S. Morrill at extension 8707.
Very truly yours, j
~)
,=
240079 Neil S. Carns NSC/jad Attachment cc:
L. J. Callan (NRC), w/a W. D. Johnson (NRC), w/a J.
F. Ringwald (NRC), w/a J. C.
Stone (NRC), w/a f
9606240143 960618 PDR ADOCK 05000482 G
PDR P O Box 411/ Burhngton, KS 66839 / Phone (316) 364-8831 An Equal Opportunity Employer M/F/HC/ VET
9 Attachment to WM 96-0073 Paga 1 of 2 Reply to Notice of Violation 50-482/9610-01 i
Violation 50-482/9610-01:
Failure to use taut-wire intrusion detection system.
" Barrier Intrusion Detection System 6
License Condition 2.E of the Wolf Creek Generating Station Facility Operating License dated June 4,
1985, requires that the licensee fully implement and maintain in effect all provisions of the Commission approved physical security
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plan, including amendments and changes made pursuant to the authority of 10
)
CFR 50. 90 and 10 CFR 50. 54 (p).
Paragraph 3.8.3.b of the physical security plan requires use of a taut-wire intrusion detection system on the protected area barrier within the warehouse cargo access portal when the portal is open for cargo access.
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Contrary to the above, on May 2, 1996, the inspector determined that from mid-1993 to May 1996 the licensee failed to use the operable taut-wire intrusion j
detection system on the protected area barrier inside the warehouse cargo
)
access portal when the portal was open for cargo access.
Instead the licensee posted a member of the security force at the warehouse cargo search area.
This is a Severity Level IV violation (Supplement III) (482/9610-01)"
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I Ed=4maion of Violatigni Wolf Creek Nuclear Operating Corporation (WCNOC) acknowledges and agrees that a violation of License Condition 2.E of the Wolf Creek Generating Station (WCGS) Facility Operating License, dated June 4,
1985, and Paragraph 3.8.3.b of the WCGS Physical Security Plan, occurred between mid-1993 and May, 1996, when security personnel failed to use the taut-wire detection system.
Reason for Violations Root Cause:
The root cause of this violation is cognitive personnel error.
In April, 1993 WCNOC implemented a security procedure change, which deleted the requirements to test and use the taut-wire detection system.
This change was based on the establishment of an administrative requirement to post a member of the security force in the warehouse cargo bay during cargo receipt.
WCNOC j
established this administrative control in 1990 in response to a potential j
degraded condition' associated with the taut-wire barrier (see contributing
]
factor statement below).
The individual who performed this procedural revision failed to perfonn an adequate review of the regulatory and WCGS Physical Security Plan requirements and the established administrative controls.
This failure resulted in the deletion of the procedural requirements to use and test the taut-wire system as specified in the Physical Security Plan.
l Atkachmen,t to WM 96-0073 d'
Pag 4 2 of 2 Contributing Factor:
In 1990 WCNOC security personnel determined that the physical barrier in question was potent ~ ally degraded.
Upon identification of the condition, WCNOC security personnel implemented administrative controls ' requiring the barrier be posted during cargo receipt.
Subsequently, security personnel initiated the established programmatic controls (work control and design change processes) to have the potential degraded condition evaluated and corrected.
These programmatic controls failed to resolve the concern.
Failure to obtain resolution of the concern ultimately resulted in a long-term work-around. The inadequate programmatic controls, in place in 1990 have been replaced.
The current work control and design change processes utilized at WCNOC will assure potentially degraded conditions are evaluated and corrected in a timely manner.
Corrective Steps Taken and Resulta Achieved 1 The taut-wire detection system was tested and returned to service on May 3, 1996.
The applicable procedures were revised to include the requirements for testing and usage of the taut-wire detection system.
Security personnel, who perform regulatory screening activities for program changes, will receive counseling and re-training from management.
This counseling will insure management's expectations regarding attention-to-detail and personnel accountability are clearly understood.
This action will be completed by June 30, 1996.
The applicable security procedure will be revised.
The revision will ensure that compensatory measures that may be long term are evaluated in a timely manner to determine: 1) the need to provide enhanced management attention to the problem resolution process, 2) the need to report the condition to the Nuclear Regulatory Commission, and 3) the need to implement Physical Security Plan changes.
The procedure revision will be completed by July 31, 1996.
Date When Full Connliance Will Be Achievedr Full compliance with the above noted requirements has been obtained and all corrective actions to prevent recurrence will be completed July 31, 1996.
Additional Information Pertainincr To the Taut-Wire Detection Systemt j
l The taut-wire detection system is being evaluated to determine the adequacy of the system to perform its intended function.
WCNOC is continuing the practice of stationing a member of its security force at the cargo bay during cargo receipt. WCNOC has initiated this evaluation (in accordance with its approved l
corrective action programs) to determine if enhancements of this barrier are needed. WCNOC expects this evaluation will be completed by November 15, 1996.
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