ML20133F665
| ML20133F665 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/07/1997 |
| From: | Hebert J Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| JRH-97-06, JRH-97-6, MN-97-06, MN-97-6, NUDOCS 9701140318 | |
| Download: ML20133F665 (6) | |
Text
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a MaineVankee
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REllABLE ELECTRICITY SINCE 1972 329 BATH ROAD + BRUNSWICK, MAINE 04011 a (207) 798-4100 January 07,1997 MN-97-06 JRH-97-06 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C. 20555
References:
a)
License No. DPR-36 ( Docket No. 50-309 )
b)
USNRC Letter to MYAPCo dated December 08,1996, Notice of Violations for NRC Inspection Report 50-309/96-12
Subject:
Reply to Notice of Violations Associated with NRC Inspection Report No. 50-309/96-12 l
Gentlemen:
The attachments to this letter provides Maine Yankee's reply to the Notice of Violations contained in Reference (b). In attachments "A & B", we have restated the violations, provided our response and have addressed our actions taken and planned to prevent recurrence. Also included, in attachment "B", is Maine Yankee's response to section S t. l.c, of Reference (b), pertaining to the narrow scope of previous corrective actions.
Please contact us should you have any further questions regarding this matter.
Very truly yours, x% k-James R. Hebert, Manager Licensing & Engineering Support Depanment JVW/ jag d
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Attachments c:
Mr. Hubert Miller
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Mr. J. T. Yerokun Mr. D. H. Dorman
' Mr. Patrick J. Dostie i
Mr. Uldis Vanags 9701140318 970107 PDR ADOCK 05000307 G
PDR l
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e ATTACHMENT "A" i
j Violation "A" Technical Specification 5.8.a], states in part that, Monitoring, Sampling and Analysis of radioactive I
gaseous effluent is in accordance with 10 CFR 20.106 and with the methodology and parameters in the Off-Site Dose Calculation Manual. The ODCM requires process system operability.
Contrary to the above, on October 4,1996, Maine Yankee personnel disabled the Primary Vent l
Stack Air Particulate and Gas Monitoring system making it inoperable for a period of approximately one hour due to a deficient procedure and/or operator error when the normal primary vent stack sampling system was returned to service without the iodine and paniculate filter cartridges installed thereby rendering the system inoperable.
i Maine Yankee Response:
I On October 1,1996, the primary vent stack (PVS) high range paniculate, gas, halogen, and particulate filters were taken out of service to allow station Instrument and Controls (I&C) technicians to repair the PVS air particulate detector (APD). Alternate sampling was invoked to compensate for the loss of halogen and particulate filters. This consisted of removing the normal halogen and particulate filters and operating an attemate filter cartridge. The normal station practice is to remove the filters from the normal cartridge and reinstall them in the alternate cartridge.
On October 4,1996, the normal sampling system was returned to service in accordance with procedure 1-12-8," Primary Vent Stack Air Particulate and Gas Monitor" The procedure did not specifically direct operators to reinstall the filters from the alternate cartridge into the normal canridge. The error was discovered by Chemistof personnel checking the normal lineup. The normal PVS sample system operated without halogen and particulate filters for 49 minutes.
Immediate Corrective Actions:
The halogen and particulate filters were removed from the alternate cartridge and placed in the normal canridge. A Temporary Procedure Change was written on October 4,1996, to ensure that j
Chemistry has installed the halogen and paniculate filters in the norrnal filter housing when shifting from auxiliary PVS sampling to normal PVS sampling.
Corrective Actions Taken to Avoid Further Violation:
The Temporary Procedure Change was incorporated into Procedure 1-12-8 during PORC meeting 96-076 on November 7,1996. Procedure 1-12-8 was reviewed in its entirety.'Whereas the procedure is adequate to prevent a reoccurrence, further enhancements are being made to the procedure.
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ATTACH MENT "B" Violation "B" The NRC approved Maine Yankee Security Plan and 10 CFR 73.21.d(2) require in part, that while unattended, Safeguards Information shall be stored in a locked security container.
Contrary to the above, on October 17, 1996, Safeguards Information was left unattended for approximately two hours on a desk in the security office inside the protected area.
Maine Yankee Resnonse:
The event description cotatituting the above violation is correct. The type of Safeguards Information (S.I.) that was left unattended normally is transported by Security Officers, wearing it around their neck, to the weapons room, inventoried by a supervisor and placed in a safeguards locker. In this case the destination was to the Administrative Secretary for destruction, the officers did not deliver them in a red envelope as the procedure states, and the material was not readily identifiable on the desk when the secretary left for the day.
Immediate Corrective Actions:
1.
Security mcde an evaluation for compensatory measures and reportability immediately on discovery of the uncontrolled Safeguards Information.
2.
Compensatory measures were implemented until it was determined that the Safeguards Information was not compromised.
Corrective Actions Taken to Avoid Further Violations 1.
Reinforcement training on the handling and transporting of Safeguards Information was provided to all Security Personnel. The annual requirement for this training has been changed to semi-annual. Initial Training Comnleted 11/30/1996 2.
Reinforcement training on adherence to security procedures has been provided and will continue to be reinforced on a quarterly basis. Comoletion ofInitial Training by 1/15/97 3.
Heighten the Security Force awareness that a questioning attitude is always needed and the must maintain a global view of their surroundings. A STAR (Stop, Think, Act, Review)
Program has been initiated. Comoletion by 2/28/1997 4.
Evaluate significant security incidents and corrective actions implemented since 1990 to ensure that they are still applicable, have been implemented uniformly, and have been effective. Review to be comoleted by 2/28/1997 5.
Disciplinary action was administered.
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Full Compliance Date:
Full compliance was achieved on Oct. 17,1996, when the Safeguards Information was properly controlled and compensatory measures were implemented.
Maine Yankees Response to the Trend of Safeguards Information Incidents:
The two reportable items mentioned in the notice to violation (Inspection scope 71750) pertained to drawings found in the 345 Yard Relay House which dated back to the 1979 time frame and a copy of the Security Training & Qualification (T&Q) plan in the corporate office which dated back to the 1981 time frame. Corrective actions taken in regards to these two matters were-l 1.
A thorough review was performed to insure that no funher drawings were uncontrolled. This was completed in July of 1993 with no other uncontrolled drawings being discovered since that review.
2.
A thorough review of all security related correspondence and documentation dated between Jan.1,1976 and December 31,1984 was completed in August of 1996 with no concerns being identified to date.
The loggable events mentioned in the Notice of Violation ( Inspection Scope 71750) involved unsecured and uncontrolled safeguards lockers and information. The long term corrective actions taken to address these concerns are as follows:
NOTE The intent is to reduce the number of safeguard repositories and handlers to the extent possible, understanding that these numbers may change over time.
1.
Reduce the number of safeguard repositories.
As of 9/30/96, 5 of 11 have been eliminated.
Another will be eliminated by 1/31/97.
2.
Reduce the number of personnel handling Safeguards Information.
Security Personnel, rather than Operations Personnel, are now making a
revision changes to the Control Rooms copy of Security Procedures.
(Complete)
Reduced the full time access list to Safeguards Information from 63 - 31.
a This does not include Contract Security Personnel. (Complete)
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o Assign expiration date to individuals who need temporary access to Safeguards Information. (Complete) 3.
Provide semi-annual Safeguards Information handling training to all repository custodians and individuals on the active access list. (Initial Training Completed)
The Contract Security Force is receiving quarterly training.
4.
Review security documents and insure just Safeguards Information is being 1
controlled as Safeguards Information. Completion Date 1/31/97.
i Rewrite security procedures to incorporate lesson plans, Security Operating a
Procedure's (SOP's), performance evaluations and decontrol procedures that do not contain Safeguards Information. Completion Date 1/31/97.
'I Evaluate the need for handling safeguard event logs, daily logs and shift a
schedules as Safeguards Information. Completion Date 1/31/97.
1 Response Matrices will be eliminated. Completion Date 1/15/97.
a 5.
Require repository custodians to have a method of recognizing that their repository j
is open before leaving their work station. Completion Date 1/31/97. (Signs, obstructions, etc.)
6.
Provide an easily identified paper that will be used whenever possible for Safeguards Information to be printed on. Completion Date 1/31/97. (Safeguards Information printed in red as the header and footer and a red stripe on the two remaining borders of the paper.)
7.
All Safeguards Information is being transported / hand carried in a red safeguards envelope. (Malling is still dual envelope process) l l
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Full Comnliance Date:
Full compliance was achieved on October 4,1996, when the halogen and particulate filters were reinstalled in the normal filter cartridge. (The nonnal PVS sample system operated without halogen and particulate filters for 49 minutes.)
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