ML20141E104
| ML20141E104 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 06/16/1997 |
| From: | Durr J NRC (Affiliation Not Assigned) |
| To: | Kenyon B NORTHEAST NUCLEAR ENERGY CO. |
| References | |
| 50-245-96-09, 50-245-96-9, 50-336-96-09, 50-336-96-9, 50-423-96-09, 50-423-96-9, NUDOCS 9706300221 | |
| Download: ML20141E104 (3) | |
See also: IR 05000245/1996009
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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WASHINGToW, D.C. 20666-0001
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June 16, 1997
Mr. Bruce D. Kenyon
President and Chief Executive Officer
Northeast Nuclear Energy Company
P. O. Box 128
Waterford, Connecticut 06385-0128
SUBJECT:
COMBINED INSPECTION 50-245/96-09;50-336/96-09;50-423/96-09
Dear Mr. Kenyon:
This letter refers to your April 4,1997 correspondence, in response to our February 24,1997
letter.
Thank you for informing us of the corrective and preventive actions documented in your letter.
These actions will be examined in a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
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lpacque P. Durr, Chief
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Special Projects Office
Office of Nuclear Reactor Regulation
Docket Nos. 50-245;50-336;50-423
cc:
N. S. Carns, Senior Vice President and Chief Nuclear Officer
M. H. Brothers, Vice President - Millstone, Unit 3
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J. McElwain, Unit 1 Recovery Officer
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M. BoM;ng, Jr., Unit 2 Recovery Officer
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D M. Goebel, Vice President, Nuclear Oversight
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J. K. Thayer, Recovery Officer, Nuclear Engineering and Support
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P. D. Hinnenkamp, Director, Unit Operations
F. C. Rothen, Vice President, Work Services
J. Stankiewicz, Training Recovery Manager
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R. Johannes, Director - Nuclear Training
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NBC HLE CINTER COPY
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9706300221 970616
ADOCK 05000245
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Mr. Bruce D.' Kenyon
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cc w/cy of Licensee's Response Letter:
L. M. Cuoco, Esquire
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J. R. Egan, Esquire
V. Juliano, Waterford Library
J. Buckingham, Department of Public Utility Control
S. B. Comley, We The People
State of Connecticut SLO Designee
D. Katz, Citizens Awareness Network (CAN)
R. Bassilakis, CAN
J. M. Block, Attorney, CAN
S. P. Luxton, Citizens Regulatory Commission (CRC)
Representative T. Concannon
E. Woollacott, Co-Chairman, NEAC
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Mr. Bruce D. Kenyon
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Distribution w/cv of Licensee's Response letter:
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Region I Docket Room (with coov of concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
FILE _ CENTER [NRR]inith'Oriainaf conc 6henceg
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NRC Resident inspector
M. Kalamon, SPO, RI
W. Lanning, Deputy Director of Inspections, SPO, RI
D. Screnci, PAO
W. Travers, Director, SPO, NRR
S. Reynolds, Technical Assistant, SPO, NRR
D. Screnci, PAO
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Inspection Program Branch (IPAS)
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Northeast
R 4 Fury Rd. (Rom 1Mataform E85
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uclear Energy
mustone Nuden Pour Stadon
Northeast Nuclear Energy company
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P.o. Box 128
Waterford, cT 06385-0128
(203) 447 1791
Fax (203) 444-4277
The Northeast Utilities System
APR - 4 197T
Docket Nos. 50-245
50-336
50-423
B16316
Re:
U.S. Nuclear Regulatory Commission
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Attention:
Document Control Desk
Washington, DC 20555
Millstone Nuclear Power Station, Unit Nos.1,2, and 3
Reply to Notice of Violations
NRC Combined insoection 50-245/96-09: 50-336/96-09: 50-423/96-09
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In a letter dated February 24,1997,W the NRC transmitted the results of an inspection
conducted at the Millstone Station. On December 31,1996, the NRC completed an
inspection at the Millstone site. Based on the results of this inspection, the NRC has
determined that three violations of NRC requirements occurred.
The first violation concerned an unauthorized entry into the Millstone Station protected
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area, demonstrating a failure to comply with security requirements.
The second
violation concerned the failure to perform a comprehensive evaluation and disposition
of regulatory requirements to support recent Millstone site organizational changes. This
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resulted in implementing several organizational changes which resulted in a technical
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specification non-compliance. Lastly, a violation was identified associated with the
failure to calibrate an ionization chamber used to monitor source checking of
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thermoluminescent dosimeters irradiator.
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On bohalf of Millstone Unit No.1,2, and 3, Attachment 1 provides NNECO's responses to
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the Notice of Violations.
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John R. White letter to Bruce D. Kenyon, "NRC Combined Inspection 50-
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245/96-09; 50-336/96-09; 50-423/96-09; and Notice of Violation," dated
February 24,1997.
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0s3422 5 REv. F94
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U.S. Nuclear Regulatory Commission
B16316\\Page 2
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Commitment
The following is NNECO's commitment associated with this response:
B16316-1 NNECO will reorganize the Nuclear Licensing Department into separate
regulatory compliance departments that report directly to the units and one
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corporate nuclear licensing department by April 30,1997.
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Please contact Mr. R. Walpole at (860) 440-2191 should you have any questions
regarding this submittal.
Very truly yours,
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NORTHEAST NUCLEAR ENERGY COMPANY
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ay K. Thayer
Recovery Officer,
Nuclear Engineering and Support
Attachments (1)
cc:
H. J. Miller, Region i Administrator
S. Dembek, NRC Project Manager, Millstone Unit No.1
D. G. Mcdonald, Jr., NRC Project Manager, Millstone Unit No. 2
J. W. Andersen, NRC Project Manager, Millstone Unit No. 3
T. A. Eastick, Senior Resident inspector, Millstone Unit No.1
D. P. Beaulieu, Senior Resident inspector, Millstone Unit No. 2
A. C. Cerne, Senior Resident inspector, Millstone Unit No. 3
W. D. Travers, PhD, Director, Special Projects Office
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Docket Nos. 50-245
50-336
50-423
B16316
Attachment 1
Millstone Unit Nos.1,2, and 3
Reply to Notice of Violations
March 1997
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U.S. Nuclasr Regulatory Commission
B16316\\ Attachment 1\\Page 1
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Restatement of Violation (Violation A)
Unit 1 Technical Specification 6.8.1, " Procedures," requires that written procedures
shall be established, implemented, and maintained covering the activities
recommended in Appendix A to Regulatory Guide (RG) 1.33, " Quality Assurance
Program Requirements (Operations)," dated February 1978.
Section 1.a. of
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Appendix A to RG 1.33 states that administrative procedures should be written to
cover security and visitor control activities.
The " Millstone Nuclear Power Station Physical Security Plan," Sect lon 6.1 " Access
Control," states entry into the Protected Area is authorized only for specifically
approved purposes and only after appropriate searches, identification, and access
authorizations are accomplished.
Section 6.4.1.2 " Authorized Individuals," state =,, in part, that all authorized individuals
must have their identification badge with keycard, as well as have their hand geometry
confirmed to gain access to the Protected Area.
Contrary to the above, on August 5,1996, at about 8:00 a.m., an individual working for
an administrative contractor gained access to the Protected Area (PA) without having
her access authorized or hand geometry confirmed. Specifically, the unauthorized
individual, that had not surrendered her badge and key card upon termination on July
19,1996, arrived at the station to report for a new work assignment. A co-worker used
her own valid key card and hand geometry to allow the unauthorized individual to enter
the PA. The co-worker followed the individual into the PA by keying in a second time.
The two individuals worked in the PA until the end of the day shift, about 3:40 p.m.
This is a Severity Level IV violation (Supplement 111).
Reason for the Violation
Northeast Nuclear Energy Company (NNECO) does not dispute the cited Technical
Specification (TS) violation. The security computer system did not provide adequate
warning of a non-authorized individual attempting to enter the protected area.
Cause
The cause of the unauthorized individual entering the PA was the result of an
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individual's failure to comply with the requirements and conditions of Unescorted
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Access authorization. In addition, the computerized controls for personnel access to the
facility were not adequate to prevent a personnel error of this nature.
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U.S. Nucisar Rcgulatory Commission
B16316\\ Attachment 1\\Page 2
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Contributina Factors
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The individual had previously been authorized unescorted access to Millstone from April
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11,1996, through July 19,1996. The individualwas returning to Millstone on the date of
this event for a different job assignment. The individual still had the security badge from
the previous assignment, which was inactive and unauthorized. Because of the new
assignment at Millstone, the individual assumed that their security badge would allow
access to the station.
When the unauthorized individual attempted to enter the PA, the Millstone Security
Computer System did not identify the keycard as unauthorized because it never received
the keycard number from the hand geometry system. This is because the hand template
had been removed from the hand geometry system. The hand geometry system, not
finding a match, did not transfer a valid key number to the security computer for
processing.
Corrective Steps That Have Been Taken and Results Achieved
The two individuals were immediately taken under Security control and interviewed. PA
access for both individuals was suspended. An accountability of all personnelin the PA
was conducted which verified that everyone was authorized. A transaction. history
review of the authorized individual's badge was conducted and showed that no vital
areas were ' entered. During normal work hours each Security Officer was posted at
each set of turnstiles due to the high traffic. During off hours (backshifts, weekends,
and holidays), when traffic is low, all turnstiles were locked out to in-bound traffic,
except one at each access point. This configuration enabled the access point officers
to stand as the only compensatory measure. The tumstiles were monitored to ensure
that this event would not be repeated until design changes to the security computer
were completed.
An article was published in the station news letters describing the event as "a very
serious breach of station security" and reiterated that any intentional act of allowing
circumvention of physical security directly reflects on the reliability and trustworthiness
of an individual and his or her suitability to maintain unescorted access. NNECO has
implemented a design enhancement for the security system applications software. An
attempt to double key at a site entry key reader will result in an alarm notifying security.
Administrative work practices have been modified so that the last hand template and
name are left in the hand geometry system. Additionally, the entire hand geometry
system data base has been reviewed and missing hand templates were added. Hence,
the hand geometry system will always contain the name and hand template of the last
person issued the keycard. The hand geometry reader will process the previous hand
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U.S. Nuclear Regulatory Commission
B16316\\ Attachment 1\\Page 3
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template allowing the Security Computer System to identify the individualis unauthorized,
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deny access, and report the event to the alarm station.
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Correct 8ve Steps That Will Be Taken
All corrective actions are complete for this issue.
Date When Full Compliance Will Be Achieved
NNECO is currently in compliance for site security control practices.
Restatement of Violation (Violation B)
Technical Specifications Section 6.2.1 "Onsite and Offsite Organizations," states, in
part, that onsite and offsite organizations shall be established for unit operation and
corporate management, respectively. The onsite and offsite organizations shall include
the positions for activities affecting the safety of the nuclear power plant including the
Senior Vice President - Millstone Station (Section 6.2.1.b), and
Executive Vice
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President - Nuclear (Section 6.2.1.c).
Contrary to the above, as of October 1,1996, the onsite and offsite organizations did
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not include the positions of the Senior Vice President - Millstone Station and the
Executive Vice President - Nuclear, for activities affecting the safety of the nuclear
power plant.-
The organizational changes implemented at that time introduced
discrepancies between the titles and functions of the new organization, and the
organization as described in Technical Specifications Section 6, " Administrative
Control."
This is a Severity Level IV violation (Supplement 1).
Reason for the Violation
NNECO does not dispute the cited Technical Specification (TS) violation.
The
management expectations for onsite and offsite organization changes were not
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established.
Cause
The cause of the discrepancies between the titles and functions of the new
organization, and the organization as described in Technical Specifications was
organizational breakdowns.
The root causes included inadequate communication
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within the organization, inadequate attention to emerging problems, and an inadequate
accountability system.
The communication and attention to emerging problems
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U.S. Nucl:ar Regulatory Commission
B16316\\ Attachment 1\\Page 4
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occurred due to poor communications between line management and Nuclear
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Licensing.
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Contributino Factors
No additional contributing factors were identified.
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Corrective Steps That Have Been Taken and Results Achieved
The President and Chief Executive Officer has issued a memorandum specifying the
manner in which changes to the organization will be supported and documented. The
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requirement has been established to conduct the reviews required by 10CFR50.54(a),
10CFR50.54(p), and 10CFR50.54(q) to ensure that no degradation has occurred in the
licensee's performance for quality assurance, safeguards contingency, or the site
emergency plans prior to implementing organizational changes. The PTSCR must be
issued to the NRC prior to implementing the organization changes. The management
expectations were met for this violation when a PTSCR was submitted on February 3,
1997.
Corrective Actions That Will Be Taken
The Nuclear Licensing department will be re-organized into separate regulatory
compliance departments that report directly to the units and a nuclear licensing
department that reports to the Recovery Officer, Nuclear Engineering and Support.
Date When Full Compliance Will Be Achieved
NNECO changes to the site organization will be in full compliance after
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implementation of the NRC approved amendments to the Technical Specifications for
Misstone Unit Nos.1,2, and 3.
Restatement of Violation (Violation C)
Technical Specification 6.8.1 requires that written procedures shall be established,
implemented and maintained for activities referenced in Appendix A of Regulatory
Guide 1.33, " Quality Assurance Program Requirements" (Operation), Revision 2,
February 1978 (RG 1.33). Item 8.a. of Appendix A to RG 1.33 recommends, in part,
that procedures for control of measuring and test equipment and for surveillance tests,
procedures, and calibrations be provided to ensure tools, gauges, instrurnents, controls,
and other measuring and testing devices are properly controlled, caliblated, and
adjusted at specified periods to maintain accuracy.
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U.S. Nucl:ar Regulatory Commission
B16316\\ Attachment 1\\Page 5
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Procedure ES #142,"Thermoluminescent Dosimeter Irradiation,"line 2 states," Place a
5% traceable to NIST)
calibrated ionization chamber which is fully charged (accuracy.
in one of the designated locations on the source table. This chamber will be used to
verify the calculated dose rate after the exposure."
Contrary to the above, the licensee did rv use an ionization chamber which had been
calibrated (accuracy * 5% traceable to NIST) to verify the calculated dose rate after the
exposure of thermoluminescent dosimeters to the source of the Shepherd panoramic
irradiator. The ionization chamber which was used (Victoreen Condenser-R Meter) had
not been calibrated since 1988 to verify its accuracy as traceable to NIST.
This is a Severity Level IV violation (Supplement IV).
Reason for the Violation
The
NNECO does not dispute the cited Technical Specification (TS) violation.
Technical Specification 6.8.1 requirement to develop a procedure in accordance with
RG 1.33 was met.
The process was controlled by Procedure ES #142,
"Thermoluminescent Dosimeter Irradiation," as stated by the NOV. The procedure
controls for control of measuring and test equipment used during Thermoluminescent
Dosimeter (TLD) irradiation were not adequate.
Cause
The cause of the non-calibrated ionization chamber during the exposure of
thermoluminescent dosimeters (TLD) was inadequate procedural controls. The
procedure used to control this activity specified the use of calibrated measuring and test
equipment, but failed to specifically identify the calibration period for the ionization
chamber.
Contributino Factors
No additional contributing factors were identified.
Corrective Steps That Have Been Taken and Results Achieved
The ion chamber used during the source checking of the environmental TLD irradiator
has been calibrated. A calibration sticker has been placed on the ion chamber to
identify the date when the calibration will expire. The controlling procedure ES #142,
"Thermoluminescent Dosimeter Irradiation," has been revised to require calibration of
the ion chamber on an annual basis.
A review of the work performed by this
determined that all other test equipment was calibrated.
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B16316\\ Attachment 1\\Page 6
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Corrective Actions That Will Be Taken
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All corrective actions are complete for this issue.
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Date When Full Compliance Will Be Achieved
NNECO is currently in compliance with the requirements of the Station Environmental
Monitoring Program.