ML20199A635

Responds to NRC Re Violations Noted in Insp Repts 50-010/97-17,50-237/97-17 & 50-249/97-17.Corrective Actions: Security Organization Identified Responsible Owner of Bldg & Secured Bldg by Locking Doors.Commitments,Listed

ML20199A635
Person / Time
Site:	Dresden
Issue date:	10/30/1997
From:	Jamila Perry COMMONWEALTH EDISON CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-010-97-17, 50-10-97-17, 50-237-97-17, 50-249-97-17, JSPLTR:-97-0187, JSPLTR:-97-187, NUDOCS 9711180048
Download: ML20199A635 (7)

Text

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Dresden Gencr: ting St:ti<m 5 6C North Drrvien Road Morris, IL 60150 Tri H15912-2920 e*

October 30,1997 JSPLTR: 97-0187 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk -

Washington, D. C. 20555

Subject:

Dresden Nuclear Power Station Units 2 and 3 Reply to a Notice of Violation; Inspection Report 50-10/237/249/97017.

NRC Docket Numbers50-010. 50-237. and 50-240

Reference:

John A. Grobe letter to J. S. Perry, dated October 1,1997, transmitting NRC Inspection Report 50-10/237/249/97017 and Notice of Violation The purpose of this letter is to provide Comed's reply to the Notice of Violation transmitted by the above reference. Specifically, the violation resulted from the failure to control scaled packages within the controlled area. This was identified as a repeat of a similar violation which occurred in August 1996. The corrective actions from August 1996 have been reviewed in light of the current violation. Reasons fbr the ineffectiveness of the initial corrective actions as well as additional actions to prevent recurrence are discussed in the altshment.

The referenced NRC letter also identified three non-cited violations which related to ineffective perfbrmance on the part of the Security Staff. Actions to address inefibetive perfonnance are also documented in the attachment.

Five commitments are included in the attachment to address the violation and ineffective perfbrmance:

• The Trend Investigation to explore the occurrences ofimproperly controlled material, that have been identified since August 8,1997, will be completed by November 28, %t 1997. NTS Item 237-230-97-00400 $

• The Security Organization will implement random material control inspections by

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i November 28,1997. NTS Item 237-100-97-01701 A I {

• The Security Organization will implement the new " Supervisor Observation / Interview Program" by January 5,1998. This program will be used to identify and correct potential perfonnance issues. NTS Item 237-315-97-09001C Pd"M G

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4 USNRC October 30,1997 JSPLTR 97-0187 Page 2 of 2

• DAP 13 09 will be revised to include a specific section which defines proper receipt and control of unsearched material. This revision will include the creation of the form to be utilized to document the issuance and receipt of material. This revision will be provided to all Station departments to familiarize and coach their personnel on the requirements. This will be completed through the use of required reading material (tailgates) by December 12,1997. NTS Item 237-100-97-0170111

. The feasibiiity of developing a method that would require all material to be delivered and received through the warehouse will be completed by April 15,1998.

NTS Item 237-100-97-01701C This response contains no proprietary or safeguards information. If there are any questions concerning this letter, please refer them to hir. Frank Spangenberg, Dresden Station Reguhaory Assurance hianager, at (815) 942-2920 extension 3800.

Sincerely,

. Ytephga 'e ry te Vice President Dresden Station Attachment ec: A. Bill lleach, Regional Administrator, Region 111 C. Kliller, Acting Branch Chief, Division of Reactor Projects, Region Ill J. F. Stang, Project hianager, NRR (Unit 2/3)

K. Riemer, Senior Resident inspector, Dresden Office of Nuc' car Facility Safety - IDNS File: Numerical

HESPONSE TO NOTICE OF VIOLATION NRC INSPECT!ON REPORT 50-010/97017; 50 237/97017; 50-249/97017 Vininfion This violation, as written in the NRC inspection report, contains Safeguards Information which will not be included in this response. The violation is related to unsearched material that was stored in an unsecured building, within the Protected Area.

Reason for Violation Commonwealth Edison acknowledges the violation which resulted from the failure to continuously control material within the Protected Area. The analysis did conclude that the material was properly controlled, when originally received. It was stored in an area staffed by personnel familiar with the material, and the area was locked when unoccupied. Ilowever, during a clean up of the area, control of the material was relinquished to a contractor individual who was either unaware of the requirements of Dresden Administrative Procedure (DAP) 13-09

" Vehicle / Material Access Control" or failed to adhere to them. The material was moved to a building that was not always locked since various departments used the building on a routine basis. The contractor individual, to whom control of the material was relinquished, is no longer working within the Commonwealth Edison system and the Security Organization could not determine his location. For this reason, the Security Organization was unable to conduct an interview with this person to determine if he was aware of the requirements of the DAP. Four other individuals involved with the unscarched material were inter iewed by the Security Organization. Two of these individuals stated that they were aware of the requirements of the DAP, one stated that he was somewhat aware and one stated that he was not aware.

The analysis of this violation concluded that the initial corrective actions implemented in August of 1996 were not thorough enough to identify all aspects that needed to be addressed. These corrective actions were taken in response to unsearched material (sea vans) that were identified during Nuclear Regulatory Commission (NRC) Inspection 96011. The corrective actions consisted of:

1. The Security Organization conducted tailgate sessions with all Station department personnel informing them of their responsibilities to open, search and properly control materials received from the warehouse. Newspaper articles were also generated to address this same information. Thb was perfonned over a four month period.

2. The Security Organization conducted meetings with the storeroom personnel to emphasize security expectations and elicit feedback on control of factory sealed materials.

Page 1 of 5 JSPl TR: 97-0187 c

3. . The Security Organization performed an effectiveness review to assure that the storeroom

, , personnel were in compliance with the security expectations.

4. The Security Organization condacted a walkdown of the entire Station to identify any improperly controlled material.

The analysis also concluded that there was a lack of ownership by supervisory / management

. personnel who were responsible for controlling the material once inside the Protected Area. This was based on the fact that the supervisors / managers involved in the incident were aware of the requirements of the DAP, but failed to assure that this was communicated to the personnel assigned to perform the clean up of the area.

The original corrective actions did not identify the need to take measures to assure that material, which could not be searched prior to entry, was properly controlled once it was inside the Protected Area. Consideration was not given to identifying all storage areas within the Protected Area, assigning individuals to be responsible for these areas and taking security measures to assure that the areas were continuously properly controlled, This also should have included the development of a method for tracking the issuance and receipt of material. This method would identify issued material, the location and the recipient / responsible individual. This could have been accomplished through ajoint effort between the responsible owners of the areas and the Security Organization.

Although DAP 13-09 does include information pertaining to the proper control of mateil, this infomiation is in a section of the DAP entitled " Point (s) of Vehicular Access." The analy 4 concluded that a section snould have been added to the DAP to specifically address "hlateia..

Control." This would have highlighted the requirements for proper material control and made the information more easily identifiable within the DAP.

Revision 03 was made to Materials Management Memorandum (MMM) 100.41 " Control of Materials Delivered to the Station's Warehouse" on November 8,1996. Training of materials management personnel, who conduct searches of received material, was completed on November 12,1996. At the same time, the use of specially marked tape to indicate material that was searched was implemented. The Security Organization also implemented the use of a stamp to indicate iicms that had been searched. This stamp is used at material access portals.

This revision addressed the expectations for assuring that materials management personnel search items, whenever possible, prior to issuance to other Station personnel, it also addresses the requirements for actions to be taken on those instances when items cannot be searched prior to issuance. Specifically, that " items that cannot be searched will remain in a locked area (warehouse) or locked container or cabinet." It further states that it is the " Store person's responsibility to assure that the receiver understands his responsibility." llowever, MMM 100.41-does not include specific information explaining the " receivers" responsibilities. The Page 2 of 5 JSPI TR: 97 0187

memorandum further cates,"When receiving material from the Warehouse, the receiver is

, ' taking control of the material / package and is required to search for contraband if material / package has not been searched already." This section does not specifically address assuring that materials are stored within a " locked" area, until the time of use.

Although the Security Organization provided initial education on the material control requirements of DAP 13-09 for all Station personnel, this information was not easily identifiable within the DAP. It was determined that had this information been made more readily identifiable, the probability of the contractor employee being aware of his responsibilities for properly controlling the material would have greatiy increased.

The Security Organization also reviewed the three non-cited violations that were described in the report. The concern was that thcre was inadequate personnel performance that demonstrated a lack of appreciation or misunderstanding of basic security practices. To address these concerns, the Security OrgLnization has taken aggressive measures to identify and correct personnel perfomiance. The Security Organization will implement 't new " Supervisor Observation / Interview Program" that will be utilized to identify and correct potential performance problems. The Security Organization will continue to utilize the Station newspaper and mandatory department tailgate notices to further reinforce security aquirements. This will include various security related topics. The Security Organization will conduct a trend investigation to determine if there is proper and sufficient knowledge and compliance with

. security related procedures by the various Station departments that receive and control material.

Security and Station Organizations continue to conduct audits, self assessments and surveillances in all areas of se- urity which includes the Fitness for Duty and Access Authorization programs.

Corrective Steps Taken and Results Achieved The Security Organization identified the responsible owner of the building. Once the ~sponsible owner was identified, actions were taken to secure the building by locking the doors. The Security Organization reaftimied the responsibilities of proper material control with the building owner. This was done by reviewing and explaining the requirements of Dresden Administrative Procedure (DAP) 13-09 " Vehicle / Material Access Control" with '.he building owner. The issuance of keys to allow entry into the building was limited, to control access. This will assure that the building and the contents are properly controlled by keeping the building locked when not in use. This was completed on August 7,1997.

The identified packages were searched for unauthorized material. No unauthorized material was discovered. This was completed on August 8,1997.

An "Appareni Cause Evaluation"(ACE) was conducted by the Facilities Maintenance Organization. The ACE detemiined that the packages were originally delivered and properly stored in the Contract Maintenance Department (CMD) building. Proper control was lost when the items were moved from the CMD building to the west warehouse storage area during a clean up of the CMD building. The ACE was completrd on August 28,1997.

Page 3 of 5 - JSPLTR: 97-0187 i

s Infbrmation was issu:d to the entire Station through the use of newspaper articles and tailgate

, ' information. This information included personal responsibilities on search requirements, proper control and storage of materials. This was completed on AuguAt 13,1997.

On August 8,1997, the Security Organization implemented patrch that inspect identified storage meas within the Protected Area. These patrols inspect to assure that material is properly stored and controlled. The patrols are conducted a minimum of one time per shift. Since the inception of the patrols, there have betn several documented instances ofimproperly controlled material being discovered by the Security Organization.

The Materials Managenant Organization revised MMM 100.41 to include specific instructions explaining the requirements of the personnel receiving material in accordance with DAP 13 09. ,

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'Ihese instructions will be provided to personnel when they receive unsearched material. Ihis revision was completed and provided to all Materials Management personnel for familiarization and coaching on October 23,1997.

Dttmilve Steps Taktnbhold Fur _tker ViolaMon The Security Org nization is conducting a Trend investigation to explore the occurrences of improperly controlled material that have been identified since August 8,1997. This investigation will consist of observations of material control practices and interviews with Station personnel to determine their awareness of the existing security procedures. Additional corrective actions will be taken to address any weaknesses or deliciencies that are identified The Security Organi7ation will revise DAP 13 09 to include a specific section whit h defines proper receipt and control of unsearched materials. This will include direction for personnel to determine if material has been searched, prior to assuming control of the material. The revision will also include the creation of a fonu that will be utilized to document the issuance and receipt of material that mt be searched until used, as well as assurance that recipients of material are aware of their te sibilities, prior to accepting contrcl of materiais.

The Security Organization will conduct random inspections of stomge areas. These random inspections will be in addition to the cunent patrols / inspections that are being conducted and will include interviews of the personnel who are responsible Ibr the storage areas. This will be peribrmed to assure that the Security Organization provides sullicient overview of the program.

The Security Organization. in conjunction with other Station departments. will explore the feasibility of developing a method that would require all material to be delivered and received through the warehouse. The feasibility of this will be based on the volume of material received at the Station and various types of delivery items (i.e., fuel bundles, contaminated materials, etc.).

Page 4 of 5 Jseule w.ois?

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, Dates Who Full Com.plance will be Achknd

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The Trend Investigation to explore the occurrences ofimproperly controlled material, that have been identified since August 8,1997, will be completed by November 28,1997.

NTS Item 23'i.230 97 00400 The Security Ort;aninition will implement random material control inspections by November 28, 1997. N'lS 1 tem 237-100-97-01701 A The Security Organization will implement the new " Supervisor Observation / Interview Program" by January 5,1998. This program will be used to identify and correct potential performance issues. NTS Item 237 315 97-09001C DAP 13 09 will be revised to include a specific section which defines proper receipt and control .

of unscarched material. This revision will include the creation of the form to be utilized to document the issuance and receipt of material. This revision will be provided to a!) Station departinents to familiarize and coach their personnel on the requirements. This , vill be completed through the use of required reading material (ta:.3ates) by December 12,1997.

NTS Item 237100 97-0170111 The feasibility of developing a method that would require all materiel to be delivered and received through the wmehouse will be completed by April 15,1998.

NTS Item 737100-97 01701C Page 5 of 5 1si LTn: 97.m:1 ,

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