ML20141E104

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-245/96-09, 50-336/96-09 & 50-423/96-09

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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NUCLEAR REGULATORY COMMISSION

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,

Special Projects Office Chief

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

J. McElwain, Unit 1 Recovery Officer ,)}1

M. BoM;ng, Jr., Unit 2 Recovery Officer -

D M. Goebel, Vice President, Nuclear Oversight

J. K. Thayer, Recovery Officer, Nuclear Engineering and Support \

P. D. Hinnenkamp, Director, Unit Operations

F. C. Rothen, Vice President, Work Services

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J. Stankiewicz, Training Recovery Manager {

R. Johannes, Director - Nuclear Training

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9706300221 970616

PDR ADOCK 05000245

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Mr. Bruce D.' Kenyon 2 '

cc w/cy of Licensee's Response Letter:

L. M. Cuoco, Esquire '

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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l. Mr. Bruce D. Kenyon 3

Distribution w/cv of Licensee's Response letter:

Region I Docket Room (with coov of concurrences) i

Nuclear Safety Information Center (NSIC)

PUBLIC

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FILE _ CENTER [NRR]inith'Oriainaf conc 6henceg

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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Northeast R 54 Fury Rd. (Rom 1Mataform E85

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g uclear Energy mustone Nuden Pour Stadon

Northeast Nuclear Energy company ,

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: 10CFR2.201

U.S. Nuclear Regulatory Commission  !

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  !

area, demonstrating a failure to comply with security requirements. The second

violation concerned the failure to perform a comprehensive evaluation and disposition l

of regulatory requirements to support recent Millstone site organizational changes. This {

resulted in implementing several organizational changes which resulted in a technical i

specification non-compliance. Lastly, a violation was identified associated with the

failure to calibrate an ionization chamber used to monitor source checking of l

thermoluminescent dosimeters irradiator.

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On bohalf of Millstone Unit No.1,2, and 3, Attachment 1 provides NNECO's responses to l

the Notice of Violations. l

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W John R. White letter to Bruce D. Kenyon, "NRC Combined Inspection 50- 1

245/96-09; 50-336/96-09; 50-423/96-09; and Notice of Violation," dated

February 24,1997.

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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

l 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, 1

l 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 1

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 ,

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

Access authorization. In addition, the computerized controls for personnel access to the

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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  !

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 I

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

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B16316\ Attachment 1\Page 3

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template allowing the Security Computer System to identify the individualis unauthorized,

deny access, and report the event to the alarm station. f

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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 _

President - Nuclear (Section 6.2.1.c).

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Contrary to the above, as of October 1,1996, the onsite and offsite organizations did

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

( 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

l. 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 I

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occurred due to poor communications between line management and Nuclear l

Licensing.  !

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Contributino Factors

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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

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

1997.

were met for this violation when a PTSCR was submitted on February 3,

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 the

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

calibrated ionization chamber which is fully charged (accuracy. 5% traceable to NIST)

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

A review of the work performed by this

the ion chamber on an annual basis.

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. I

Date When Full Compliance Will Be Achieved

NNECO is currently in compliance with the requirements of the Station Environmental

Monitoring Program.