ML20134N893
| ML20134N893 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/18/1997 |
| From: | Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Beard P FLORIDA POWER CORP. |
| References | |
| EA-97-012, EA-97-12, NUDOCS 9702250023 | |
| Download: ML20134N893 (45) | |
Text
l February 18, 1997 EA'97-012 i
Florida Power Corporation I
Crystal River Energy Complex Mr. P. M. Beard Jr. (SA2A)
Sr. VP. Nuclear Operations ATTN: Mgr.
Nuclear Licensing 15760 West Power Line Street Crystal River. FL 34428-6708
SUBJECT:
MEETING
SUMMARY
- PREDECISIONAL ENFORCEMENT CONFERENCE CRYSTAL RIVER 3 - DOCKET NO. 50-302
Dear Mr. Beard:
I This refers to the meeting on February 14. 1997, at the Region II office in I
Atlanta, Georgia. The purpose of the meeting was to discuss apparent violations regarding security program deficiencies identified in a recent NRC inspection.
It is our opinion. that this meeting was beneficial to our understanding of the issues.
Enclosed is a List of Attendees. NRC's presentation material, and Florida i
Power Corporation's presentation material.
1 In accordance with Section 2.790 of NRC's " Rules of Practice." Part 2, Title 10 Code of Federal Regulations, a co)y of this letter and its enclosures I
will be placed in the NRC Public Document Room.
Should you have any questions concerning this meeting, please contact Mr. K. Landis at (404) 331-5509.
i Sincerely.
Original signed by Johns P. Jaudon Johns P. Jaudon, Director -
Division of Reactor Safety J
Docket No.
50-302 License No.
DRP-72
Enclosures:
1.
List of Attendees 2.
NRC Presentation Material 3.
FPC Presentation Material 9702250023 970218 PDR ADOCK 05000302 G
\\\\ 19 6,
FPC 2
cc:
J. Cowen. Vice President Nuclear Production (SA2C)
FPC. Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 B. J. Hickle. Director Nuclear Plant Operations (NA2C)
FPC Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 D. Kunsemiller. Director (SA2A)
Nuclear Operations Site Support FPC. Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 R. Alexander Glenn. Corporate Counsel FPC MAC - ASA P. O. Box 14042 St. Petersburg. FL 33733-4042 Attorney General Department of Legal Affairs The Capitol Tallahassee, FL 32304 Bill Passetti Office of Radiation Control Department of Health and Rehabilitative Services 1317 Winewood Boulevard Tallahassee. FL 32399-0700 Joe Myers. Director Div. of Emergency Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee. FL 32399-2100 Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness. FL 34450-4245 Robert B. Borsum Framatome Technologies 1700 Rockville Pike. Suite 525 Rockville. MD 20852-1631
i 1
5 j
FPC 3
I Distribution w/encls:
i l
L. Raghavan, NRR i
B.-Crowley, RII e
J. Lieberman, OE i
B. Uryc, RII l
OE EA File (Attn: B. Summers OE) t PUBLIC NRC Resident Inspector
(
U.- S. Nuclear Regulatory Commission 6745 N. Tallahassee Road j'
Crystal River, FL 34428-f 1
1 I
i l
l t
1 4
i i
I i
1 l'
f i
I i
i i
t i
t f
SEND TO PUBl1C 00CtMENT R00M7 YES NO l
- [
OFFICE g\\
)
l
$!GNATURE l M f
i 4
NAME llen Klar d DATE 02 / l [ / 97 Mb / 97
/ 97 l 02 /
/ 97 02 /
/ 97 02 /
/ 97 02 /
/ ES l NO
[YES)
NO YES NO YES NO YES N0 YES NO l 5
i COPY?
UFFICIAL%.KUKU LUFY
% LPt.hl NAMi G:\\CKY5I ALWtt ilNU\\CKhuM2.14
~j i
l t
I
l LIST OF ATTENDEES
.i FLORIDA POWER CORPORATION R.' Anderson. Senior Vice President I
P. Beard. Senior Vice President. Nuclear Operations
'J. S. Campbell. Security Supervisor-J. W. Campbell. Assistant Plant Director D. Kunsemiller. Director. Nuclear Site Services K. Lancaster Manager Nuclear Projects i
J. Baumstark. Quality Programs
'G. Halnon. Assistant Director. Nuclear Site Support D. Watson. Security Manager 1
NUCLEAR REGULATORY COMMISSION J
E. Merschoff. Acting Deputy Regional Administrator. Region II (RII)
J. Jaudon. Director. Division Of Reactor Safety (DRS). RII P. Fredrickson. Chief. Special Inspections Branch K. Landis. Chief. Branch 3. DRP. RII A. Boland. Enforcement Specialist. EICS. RII L Stratton. Safeguards Specialist i
D. Thompson Safeguards Specialist B. Uryc. Director. Enforcement and Investigations Coordination Staff (EICS).
j RII i
C. Evans. Regional Counsel RII j
S. Cahill. Senior Resident Inspector, Crystal River. RII t
i l
i j
1 i
~.
. ~ -.. - _. ~.. -
..... ~..
... ~..
l l
l The apparent violations discussed in this pre-decisional enforcement conference are subject to further review l
and are subject to change prior to any resulting enforcement action.
APPARENT VIOLATIONS VIOLATION A l
Condition 2.D, Physical Protection, of Operating License Number DPR-72 states that Florida Power Corporation shall maintain in effect and fully implement all provisions of the Commission approved Physical-Security, Safeguards Contingency, and Guard Training and Qualification Plans.
Part 1, of the licensee's Physical Security Plan, Revision 6-13, dated June 20,1996, " Introduction," states that written procedures are implemented and maintained to the detailed requirements necessary to implement the Security Plan for plant operations. In addition, Part I also states that the Physical Security Plan states Florida Power Corporation's policy and commitment to meet the requirements of 10 CFR 73.55.
l The apparent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
(ObObORC h
J Th* cpp: rent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
Procedures were not implemented and maintained to the detailed requirements necessary to implement the Security Plan for plant i
operations as exampled by the following:
i l
Site Security Procedure 205, " Alarm Station Operations,"
Revision 13, dated January 14,1994, failed to reflect current equipment and operational instructions for the newly installed security computer system for the Central and Secondary Alarm Station operators. The licensee failed to revise the procedure when the new Temporary Central Alarm Station and the i
Secondary Alarm Station were placed in operation on November 5,1996.
i Site Security Procedure 303, " Compensatory Measures for Pre-Planned Maintenance," Revision 2, dated July 28,1995, failed to establish the requirements that in the event of a vital area door degradation, compensatory. measures will not be reduced in effectiveness as defined in 10 CFR 73.55(g)(1).
f i
The apparent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
. ~..
... - ~..
.. ~..
.. ~... - - -. -. -.. ~.... _ -. - - ~ ~. - ~.. -. ~. - -
I s.
?
The cpparent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to changa prior to any resulting enforcement action.
i i
VIOLATION B i
l i
Condition 2.D, Physical Protection, of Operating License Number DPR-i 72 states that Florida Power Corporation shall maintain in effect and i
j fully implement all provisions of the Commission approved Physical l
i
_,,, Security, Safeguards Contingency, and Guard Training and Qualification t
Plans.
4 i
I Part 1, of the licensee's Physical Security Plan, Revision 6-13, dated June 20,1996, " Introduction," states that written procedures are i
4 implemented and maintained to the detailed requirements necessary to i
implement the Security Plan for plant operations. In addition, Part I s
j also states that the Physical Security Plan states Florida Power l'
Corporation's policy and commitment to meet the requirements of 1
i 4
i i.
t i
1 I
j The apparent violations discussed in this pre-decisional enforcement conference are subject to further review j
and are subject to change prior to any resulting enforcement action.
l The cpp:rtnt viol:tions discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
Security Information Report 10551, dated September 27,1997, "JC 1
j 6000 Alarm Response," an addendum to Site Security Procedure 205,
" Alarm Station Operations," Revision 13, dated January 14,1994, states that the general rule for all alarm station operators will be to respond to all alarms.
Section 6.1.1.1. of the licensee's Physical Security Plan, Revision 6-13, dated June 20,1996, documents that in the event of a partial alarm system failure the following compensatory measures will be taken:
provide continuous surveillance utilizing a dedicated observer monitoring the closed circuit television monitor and increase Protected Area patrols through use of an additional officer, or station a member of the security force at the inoperable alarm location.
)
l l
The apparent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
I
J i
~
Th3 cpptrent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
On November 20,1996, the Central and Secondary Alarm Station Operators failed to respond to an intelligent multiplexer alarm, which resulted in the perimeter intrusion detection system being inoperable for 1
i approximately two hours and 22 minutes. Additionally, the loss of j
protected area intrusion detection alarms was not compensated.
)
l j
I a
l, I
l
)
4 J
i 1
I 4
(
i i
The apparent violations discussed in this pre decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
- -..,-..~..--
r The apptrant violitions discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
VIOLATION C l
9 Condition 2.D, Physical Protection, of Operating License Number DPR-72 states that Florida Power Corporation shall maintain in effect and fully implement all provisions of the Commission approved Physical 4
Security, Safeguards Contingency, and Guard Training and Qualification i
Plans.
i Section 6.4. of the licensee's Physical Security Plan, Revision 6-13, a
dated June 20,1996, states in part that monitors located in the Central and Secondary Alarm Station will automatically switch to the appropriate camera during a perimeter alarm to immediately display the area in alarm.
From November 5,1996, to December 6,1996, the licensee failed to have a system that would automatically switch to the appropriate camera to display the areas in alarm when two or more perimeter alarms were generated.
i The apparent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
4
-~
-. _.. - ~.
....~.. - _.
The apptrant violations discussed in this pre decisional enforcement conference are subject to further review l
l and are subject to change prior to any resulting enforcement action.
' VIOLATION D L
1 Condition 2.D, Physical Protection, of Operating License Number DPR-l 72 states that Florida Power Corporation shall maintain in effect and l
r
(
fully implement all provisions of the Commission approved Physical l
Security, Safeguards Contingency,-and Guard Training and Qualification Plans.
l Section 3.1 of the licensee's Physical Security Plan, Revision f
l 6-13, dated June :20,1996, states that the Protected Area is located i
within the Owner-Controlled Area and is enclosed by physical barriers.
1 On November 1,1996, for approximately 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 35 minutes, the licensee failed to enclose the Protected Area-in that a physical barrier was not established at the Circulating Water System.
l I
l l
l l
l The epparent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
Th2 (pparent violations discussed in this pre-decisional enforcement conference are subject to further review and are suLbet to change prior to any resulting enforcement action.
VIOLATION E Condition 2.D, Physical Protection, of Operating License Number DPR-72 states that Florida Power Corporation shall maintain in effect and fully implement all provisions of the Commission approved Physical Security, Safeguards Contingency, and Guard Training and Qualification Plans.
Section 2.4.5. of the licensee's Physical Security Plan, Revision 6-13, dated June 20,1996, states in part that security equipment, to include weapons and ammunition is stored in a locked repository within the Protected Area.
From approximately early 1988 to December 18,1996, weapons and ammunition stored within the Protected Area were rot properly secured in a repository. The roof of the repository allowed security equipment to be accessible to plant personnel.
The apparent violations discussed in this pre-decisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
Th3 cpp rint viol 1tions discusazd in this pre-denisional enforcement conference are subject to further review and are subject to change prior to any resulting enforcement action.
VIOLATION F 10 CFR 50.54(p)(2) states that the licensee shall maintain records of changes to the Plans made without proper Commission approval for a period of three years from the date of the change, and shall submit as specified in 50.54 a report containing a description of each changes within two months after the change is made.
The licensee failed to comply with the requirement of 10 CFR 50.54(p)(2) as exampled by the following:
On February 16,1996, the licensee implemented Revision 6-10, of the Physical Security Plan. However, the NRC did not receive notice of Revision 6-10 until May 17,1996, which exceeds two months.
The licensee failed to submit a report of a Physical Security Plan change that deleted the commitment of E-field perimeter intrusion i
detection equipment.
Revision 7-1, dated March 18,1996, of the licensee T&Q Plan was not maintained by the licensee.
j The apparent violations discussed in this pre-decisional enforcement conference are subject to further review l
and are subject to change prior to any resulting enforcement action, j
t i
)
Pre-Decisional Enforcement l
Conference Crystal River Unit 3 NRC Inspection Report 95-18 NRC Region II Offices Atlanta, Georgia February 14,1997
Security Issues Pre-Decisiona.1 Enforcement Conference EE=mmm
'*NNNCM"""
^
Opening remarks Pat Beard Relationship of Apparent David Kunsemiller Violations to MCAP 11 Change Management and Ken Lancaster Upgrade Project Status Incividual Corrective Actions David watson and Results Achieved Jerry Campbell Role of Quality Assessments Jim Baumstark Closing Remarks Pat Beard Florida Power Corp 1
Opening Remarks 2,-q,ygg,___.
o Carefully reviewed IR 96-18 e No material disagreement with the facts e The apparent violations primarily reflect:
Inadequate change management of the security upgrade project and Lack of understanding of regulatory requirements e Specific cause analyses confirm MCAP ll actions address the broad implications of the apparent violations Florida Power Corp 2
i l
l Opening Remarks
___=. :; m.. a = :.. m...... : ;. ; ;. m = = -. - x_.. _. 1.. :. -.. -.--
. :.:2 2..:.e.u......:
i e Committed to fundamental change j
New management team and j
increased resources
-committed to necessary actions j
to further enhance the security j
program consistent with MCAP l
ll standards l
Adherence to security rec uirements
.is a op 10 s.te i
4 issue i
i 1
i i
i ij j
Florida Power Corp 3
I
l Relationship of the Apparent Violations to MCAP II s, - mggggg _
_ gyggg-e Evaluation of individual apparent violations Problem Reports / Precursor Cards on each Specific Causes were identified e Collective evaluation Formed separate team to evaluate all 7
' issues for common causes and MCAP ll relationship Team found commonality with MCAP ll
-Weak change management of security upgrade project
-Lack of awareness of regulatory requirements o Determined that MCAP 11 broad corrective actions will address these common causes Florida Power Corp 4
I
Security Upgrade Project Change Management
. mygacy,_,_ _ _ _gggggy-rn e Security project started in 1988 as an upgrade to enhance access control, detection capability and lighting e Project has been extended and re-scoped several times Coupled with personnel changes, this has challenged our change management processes o Project near completion - will be completed in 1997 o 5 of 7 issues resulted from the security upgrade project and primarily reflect weak change management Florida Power Corp 5
l Security Upgrade Project Change Management
, _ g g yt; _ _ _ g x g _,_ -
o Change Management Significant Contributors in:
-Design Scope Control
- Ability to control changes to security procedures and the Security Plan
-Resource priority and commitment o Corrective Actions:
Security presence on Design Review Board for security modifications Projects / Modification Review Group changes Revising procedures to include end-user training ario~r to turnover (2/24)
Florida Power Corp
Security Upgrade Project Change Management
- -mm;=r7
__ _;_; = ggrom -
o Expected Results:
Ini':ial design packages will be more complete Im aroved design and ins':allation schedules Im 3 roved site-wide sensitivi':y to aroject status Enlancement ':o our reaciness for turnover i
Florida Power Corp 7
'l CR-3 Security Upgrade Project Status
_,,,_ m c ; _ _ _ m y, _ _
o Completed:
Security Fence Enhancements Nuclear Security Operation Center (Occupied)
Search Area Observation Room (Operational)
Alternate CAS Moved to Permanent CAS Security Compu":er Installed Perimeter Intrusion Detection Connection Florida Power Corp 8
CR-3 Security Upgrade Project Status
___yyr:::1
_:yger o In Progress:
CAS Final close out Access control hardware in vital areas Vehicle Gate / Control and Power Replace Zone 15 E-Field with Microwave Transceiver East Perimeter Fence (PA Boundary)
East Perimeter Intrusion Detection System East Perimeter Lighting Nuclear Security Operations Center Upgrade Complete: 06/97 Florida Power Corp 9
l
Individual Corrective Actions and Results Achieved
_,7gx o Apparent Violation 96-18-01 2 examples of out-dated and inadequate procedures e immediate Corrective Actions Affected procedures administratively supplemented with correct information All Control Complex doors posted as soon as practical (wi':hin 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />)
Florida Power Corp 10
Individual Corrective Actions and Results e
Achieved g-a-annaw
=,n ---
o Additional Corrective Actions Procedure problems fixed.
-Now reflect new system which is fully operational and
-Implements the approved Safeguards Contingency Plan Reviewed all Security procedures
-3 additional procedures are administratively supplemented anc will be revised o Results Achieved After compensatory posting, full compliance with regulation has been maintained Florida Power Corp 11
Indivic.ual Corrective Actions anc. Results Achievec.
-,g m 1 2 _,_ _ a 3 7 e Apparent Violation 96-18-02, Failure to respond to MUX-4 alarm o Identified by Alarm Station Operator (ASO)
-Good questioning attitude by Security Officer and Alarm Station Operator Florida Power Corp 12
Individual Corrective Actions and Results Achieved 7-,-w, e Immediate Corrective Actions Dec!ared Security Emergency Good security response
-immediately compensated in accordance with plan
-promptly reported to NRC within prescribed time Good Maintenance response
-immediately initiated repairs and restored within 30 minutes and prior to report to NRC Florida Power Corp 13
Incivic.ua.. Corrective
~
Actions and Restt.ts Achieved 4 m e = m m m _ _ _,_, g g g g - -
o Additional Corrective Actions Stand down from further work until event understood Each ASO and security officer walked down system to understand configuration Enhanced communication of status of project Reinforced expectations of alarm response and conservative decision making Random sampling of other ASOs quizzed on expectations and alarm response Scenario added to Alarm Station Operator simulator Three ASOs received disciplinary actions Additional ASO training by 3/31 Job Task Analysis being performed for more formalized training program Florida Power Corp 14
IndivicLual Corrective Actions and Results Achieved m._,mmmm-,7 mmmmmm o Apparent Violation 96-18-03 Security system failure to automatically assess more than one protected zone o Immediate Corrective Actions Compensated with patrols for visual assessment o Additional Corrective Actions Software fixed by vendor and tested Video Capture is part of security upgrade for 1997 o Results Achieved System is in full compliance Tested every 7 days Florida Power Corp 15
4 Incividual Corrective 1
Actions and Results i
Achieved i
waamuummmmmm-r
^ wam m m mm -
l o Apparent Violation 93-18-07 and URI 93-18-06 Failure to adhere to 10CFR i
j 50.54(p) for interim changes l
during the upgrade project 4
l e Immediate Corrective i
Actions l
Stopped using interim j
measures Vital doors were posted in
)
accordance with base Security Plan I
j Florida Power Corp 16 i
Individual Corrective Actions and Results Achieved
_ _,g g g g ; _ _ _ y y y m _ _
e Additional Corrective Ac: ions Security Plan has been revised, is being reviewed by PRC, and will be submitted to NRC by 2/26/97 50.54 (p) process now in Al-800 o Results Achieved Procedures are in compliance with the Security Plan i
Florida Power Corp 17
Inc.ivic.ual Corrective Actions anc. Resu.ts Achieved mezz-----.m o Apparent Violation 96-18-05 Inadequate control of arms and ammunition e Immediate Corrective Actions Area posted immediately and arms inventoried Arms and ammuni": ion locked in heavy metal boxes Accitional lock added to inside of door blocking egress Florida Power Corp 18
\\
Incividual Corrective Actions and Results Achieved
--men;
,=can e Additional Corrective Actions Reviewed past inventory records and found no discrepancies Other past QA issues being reviewed for similarjudgment errors e Results Achieved Armory is in full compliance Florida Power Corp 19
Individual Corrective Actions and Results Achieved
__y-gg o Conclusions Management of changes made during the security upgrade project was inadequate Several examples of non-conservative assessments in complying with regulations We believe we never had a significant threat of radiological sabotage
-no degradation existed which was readily exploitable
-Security officers performed expertly during drills Current management responded quickly to concerns and apparent violations Florida Power Corp 20 l
Individual Corrective Actions and Results Achieved
,,,- -, g z u _ _ m g o Apparent Violation 96-18-04 Protected area breach via the Circulating Waterbox manways e Separate from security upgrade and plan issues Plant owns this apparent violation e Detected by security officer on routine rounds Excellent questioning attitude and plant knowledge Florida Power Corp 21 l
DISCHARGE DISCHARGE m
w so-so-h
' C ON a
l
'I I
e9 98 MAIN CONDENSER 3B I
i i
r i
N O
l W
CEBRE RM CGdR5 EH31 FLAPS FLAPS FLAPS (A)(Bh (A)(B)
Tc)(o) cc)(oy e
e
-o o-24" 24" INLET INLET
l NG=;l' e 1=w 3
l i
i l I
i l ' i
(
I I
)lI
(\\
t p
2_
z i,n=1, I
e nc=V hs
.r
- 9 4
4 6
n 3
1 4 I
R 6
e<
k N
1 4
c,.
y h"
- 9 y
?
E.
E a
/
'#,/
"C,b 7
{k h\\
u
,~.-
k a
?
n.: "Mh u.
t
- re M,
Individual Corrective Actions and Results Achieved m u _ _ _ 2,y y e immediate Corrective Actions Security officer posted himself at the breach Walkdown of all vital areas and protected area performed by security Waterbox manways were closed Root cause team established Florida Power Corp 24 i
Incividua~ Corrective Actions and Results Achieved
= =_::__ ___assee - -
e Cause Human errors which caused inadequate work package and emergent work planning Administrative barriers not effective in preventing breaches e Corrective Actions Labels Planner held accountable Lessons learned Physical barriers Further walkdown of waterboxes revealed no other apparent violations of known pathways Florida Power Corp 25
Incivic.ua:. Corrective Actions anc. Resu:.ts l
Achieved m - seen______ sse_=sce=-
O Conclusion Pathway not readily nor likely i
exploitable The waterbox security breach was due i
to a Planner failing to provide adequate instruction in the work l
package for the craft to notify Security before operating the discharge 1
waterbox screens.
l The c uestioning attitude of our roving security officer identified the security i
breach This apparent violation is different i
from t7e security upgrade and plan issues involving change management Florida Power Corp 26
l j
Role of Quality i
Assessments t
\\
\\
..nw z=
_._:.,i.../.a,.:.~,,,.....,.,,:.u,....,,...,.......,.....~.
e Assignment of Auditors l
In-house resources (Quality Assurance, Quality Control, 1
l other site assets)
),
Cooperative Management l
Audit Program resources 1
l Contractor resources l
e Missed Opportunities l
During comp,iance audits Increased use of surveillances
~
i 3
b i
{
Florida Power Corp 27
Role of Quality Assessments
_ -8arasem_ __
xg=
e Enhancements to Program Resul of Oc"ober self-assessment /s':'anc' c own Focus on assessment of issues identified increasec size / expanded backcround ':o staff Deve'oped site ro':ation plan for i/3 of staff Reformattec' err:rances/ exits Florida Power Corp 28
)
l Closing Remarks
~ ;Mi "G% Bis?ffisG&%2.2E%W%i"
,5MMRTMlxtrammaM l
o We have:
l Initiated corrective actions through l
MCAP ll that address the broader l
aspects, and Specific corrective actions to address the individualissues i
Results are being achieved i
o With regard to physical plant security, we believe that no significant threat of l
radiological sabotage existed l
o The Security Plan and its j
implementation have been historically strong and is fundamentally sound j
Florida Power Corp 29 l
k Closing remarks
-wsaeyeg ma g ragg g gggesageggys o Apparent violations do not warrant escalated treatment Apparent violations do not involve a situation where:
- An unauthorized individual could easily gain undetected access
- An unauthorized individual could predictably circumvent the system or defeat a specific zone with a high degree of confidence
- A breakdown in the overall security program existed o Although apparent violations have more than minor safeguards significance, at worst they involve a situation w1ere:
An opportunity existed that could allow unauthorized and undetected access into the protected area but which was neither easily nor likely to be exploitable Management provided inadequate oversight of the upgrade project change. process Florida Power Corp 30 4
4
1 I
J Supplemental Slides 3,
I Florida Power Corp 31
SECURITY PROGRAM APPARENT VIOLATIONS - INSPECTION REPORT 96-18 Apparent Violations Related to Security Upgrade Project Apparent Description Root or Apparent Cause Common Causes and Violation /
MCAP-Il Relationship URI No.
% 18-01 Inadequate Procedures:
Inadequate management of Inadequate oversight and management administrative changes due to security ir.volvement in the change process.
upgrade project Marli 64-ac2)
% I8-02 Failure to respond to an alarm
-Iluman Error Procedure Adherence & change management.
-Inadequate management oversight and nar-ri: 64-aci) training
% 18-03 Security System failure to
- Inadequate planning for upgrade and inadequate oversight and management automatically assess more than incomplete system testing involvement in the change process; lack of one protected zone questioning attitude.
Y Mar-l!: it-RC-i) 96-18-06 Failure to control interim changes
- Inadequate evaluation of interim Inadequate regulatory sensitivity in change (URI) in the security plan during the changes to security plan changes process control upgrade project in accordance war-ri e-Rei).
with 50.54(p):
% 18-07 Failure to submit timely reports:
-Inadequate procedure for control of Inadequate regulatory sensitivity.
- Rev. 6-10 submitted I mo. late security plan change reports per uar-ii e-Roz)
- Removal of E-field and T&QP, 50.54(p)
Rev 7.1 not submitted
- Failure to track and ensure timely reports.
Confusion in relation between Appendix D and 50.54 (p)
Apparent Violations NOT Related to Security Upgrade Pro.iect 96-18-04 Protected area breach via the
-Incomplete Corrective Action
-Weak work control process CWS Waterbox
- Human Performance Error roir nar-iira<nigea as a sir, ror 10 rriority 96-18-05 Access control to Armory
- Physical design weakness Inadequate regulatory sensitivity; questioning
- Inadequate assessment of regulatory attitude; requirements uar-ri <n-Rei).
MCAP II Sections: A: Leadership Oversight and involvement B: Engineering Performance C: Configuration Management and Design Issues D: Regulatory Cumpliance E: Operation Performance m
.