ML20137J525

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-461/96-16 & in Response to

ML20137J525
Person / Time
Site:	Clinton
Issue date:	03/26/1997
From:	Caldwell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Connell W ILLINOIS POWER CO.
References
NUDOCS 9704040053
Download: ML20137J525 (2)

See also: IR 05000461/1996016

Text

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March 26, 1997

Mr. W. Connell

Vice President

Clinton Power Station

Illinois Power Company

Mail Code V-275

P.O. Box 678

Clinton, IL 61727

SUBJECT:

NOTICE OF VIOLATION (NRC INSPECTION REPORT 50-461/96016(DRS))

Dear Mr. Connell:

This will acknowledge receipt of your letter dated March 3,1997,in response to our letter

dated February 4,1997. This letter transmitted a Notice of Violation associated with our

identification of your failure to properly control some types of packages and implement

personnel access authorization to a vital area at your Clinton Nuclear Power Station.

During a telephone call on March 19,1997, Dennis Smith of your staff, clarified your

response and explained the root causes of the violations. They included examples of weak

procedures, weak oversight activities, and a lack of understanding in properly

implementing some specific security requirements. The information provided in your

corrective steps clearly and adequately addressed those root causes. We request that

future responses include your description of root causes.

We have reviewed your corrective actions and have no further questions at this time.

These corrective actions will be examined during future inspections.

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Sincerely,

/s/ G. C. Wright (for)

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James L. Caldwell, Director

Division of Reactor Projects

Docket No. 50-461

License No. NPF-62

Enclosure:

Ltr dtd 3/3/97 W. Connell

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Clinton to USNRC

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See Attached Distribution

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DOCUMENT NAME: G:DRS\\CL1032(o7.DRS

To receive a copy of this document, indicate in the box: "C" = Copy without

cttachment/ enclosure "E" = Copy with attachment / enclosure "N" = No copy

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cc w/o encl: P. Yocum, Plant Manager,

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R. Phares, Manager, Nuclear Assessment

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P. J. Telthorst, Director - Licensing

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cc w/ encl:

Nathan Schloss, Economist,

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Office of the Attorney General

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K. K. Berry, Licensing Services Manager

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General Electric Company

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Chairman, DeWitt County Board

State Liaison Officer

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Chairman, Illinois Commerce Commission

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Docket No. 50-461

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U.S. Nuclear Regulatory Commission

Washington, D. C. 20555

Subject:

Reply to Notices of Violation Contained

in Inspection Report 50-461/96016

Dear Sir or Madam:

The attachments to this letter contain the Illinois Power (IP) response to the two

violations of Nuclear Regulatory Commission (NRC) requirements documented in NRC

Inspection Report 50-461/96016. IP admits that both violations occurred. The first

violation describes a failure to maintain proper control of factory sealed packages that

entered the protected area. The second violation describes the failure to ensure only

those contractors with a work-related need to enter the vital area of the screenhouse

were given access to that area.

Attachment A of this letter contains the response to the failure to properly

maintain control of factory sealed packages. Attachment B contains the response to the

failure to ensure that only those contractors with a work-related need to enter the

screenhouse vital area were given access to that area. IP is confident that these

responses address the concems identified in these violations.

Sincerely yours,

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Wilf d Connell

Vice President

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Attachments

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NRC Clinton Licensing Project Manager

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NRC Resident Office, V-690

Jtegional Administrator,"RegionIII,41SNRC- -

Illinois Department ofNuclear Safety

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ATTACHMENT A

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Page 1 of 2

Response to Notice of Violation 50-461/96016

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The Notice of violation states in part:

"Section 3.2.2.1.1 of the approved Clinton Security Plan allows that packages and

material sealed in the manufacturing process be permitted into the protected area without

search, but requires they be stored in a locked area until open.

Contrary to the above, on December 18,1996, the inspector identi6ed that some factory

sealed packages were permitted access into the protected area without search and were

routinely not stored in a locked area until opened."

Reason for the Violation

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The factory-scaled packages contained food items such as candy bars and pota,to chips for

lunch room vending machines. The reason the violation occurred was the personnel

delivering material to the plant in factory sealed packages were(una/vare of the

requirement for controlling these materials once they were allowed into th'ipotected area.

Also, contributing to this violation was that security did not ensure that the proper

controls were followed once the materials were released from the search area. - y

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Corrective Steos Taken and Results Achieved

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Once it was identified that factory sealed materials had been allowed into the protected

area and were not controlled in accordance with Clinton Power Station (CPS) procedure

1032.03 " Incoming Package and Material Control" and the Clinton Security Plan security

force members were instructed on the required controls for factory sealed materials and to

notify security supervision of any materials that were not searched or searchable. This

was done to ensure that proper controls were arranged for the item that was determined to

be exempt from search. This was maintained until all security force members could be

trained on the proper controls for these materials. No further instances of failure to

properly control factory sealed packages have been observed since this problem was

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identified.

Corrective Steos Taken to Avoid Further Violations

CPS procedure 1032.07F006 " Vehicle Operator Briefing Card," and CPS procedure

1032.07F008 " Licensee Designated Vehicle (LDV) Briefing Card," have been revised to

require security supervision to provide special instructions to vehicle operators entering

the protected area with packages that are exempt from search. These special instructions

will include how the packages are to be controlled while they are in the protected area.

Also, CPS procedure 1032.03 " Incoming Package and Material Control," was revised to

provide information on what action to take when items being brought into the plant are

exempt from search requirements through the warehouse transfer cage or the sallyport

vehicle gate,

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A1TACHMENT A

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Page 2 of 2

Date when Full Comoliance Will be Achieved

Illinois Power is now in full compliance with the Clinton Security Plan with respect to

control of factory sealed packages entering the protected area.

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ATTACHMENT B

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Response to Notice of Violation 50-461/96

The Notice of violation states in part:

"Section .l.7.1 of the approved Clinton Security Plan requires that personnel access to

vital areas be based on a work-related need. Section 5.1.1.1 of the approved Clinton

Security Plan identifies the Screenhouse as a vital area.

Contrary to the above, between D-amhar 16, 1996, and January 6,1997, inspector

review of contractor personnel vital area status levels showed forty-one contractor

personnel were granted access to the Screenhouse (vital area) even though their duties

(work-related need) did not require such access."

Reason for the Violatioll

The reason for this violation was the difficulty contract coordinators had in determining

what security access zones individuals would need at the time they were given access. In

order to ensure that contractors would be able to work where needed, many contractors

were given access to the vital area of the screenhouse without a planned work-related

need for access. Contract coordinators did this knowing work was scheduled for the

screenhouse area.

Corrective Steps Taken and Results Achieved

On December 19,1996 the forty-one contract personnel that were identified as not having

a work-related need to access the vital area of the screenhouse had their access to the

screenhouse vital area terminated. Thirty-four other contract personnel had their access to

the vital area of the screenhouse terminated until their work-related need for access to that

area could be determined Also, all personnel that had access u the screenhouse vital area

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were directed to present adequate justification for centinued access to the screenhouse-

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vital area. If adequate justification could not be determNed then the individuals access to

the screenhouse vital area was removed.

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Corrective Stens Taketi to Avoid Further Violations

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Nuclear Support Services (NSS) procedure 3.94 " Access Procesing" will be changed to

require the Supervisor-Security or Supervisor-Personnel Procesdng or their designee's

permission be obtained before individuals are given access to the vital area in the

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screenhouse. The procedure will also be changed to clearly state thd granting access to

vital areas of the plant is based on a work-related need to enter those areas. These

changes to NSS procedure 3.94 will be complete by April 15,1997.

Date When Full Comoliance Will be Achieved

Illinois Power is now in full compliance with the Clinton Security Plan with respect to

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control of access ofindividuals to the vital area of the screenhouse.

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