ML20199H430
| ML20199H430 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 01/28/1998 |
| From: | Zinke G Maine Yankee |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-309-97-08, 50-309-97-8, GAZ-98-07, GAZ-98-7, MN-98-07, MN-98-7, NUDOCS 9802050044 | |
| Download: ML20199H430 (5) | |
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MaineYankee PO. DOX 408
- WISCASSET. MAINE 04578 * (207) 682-6321 i
January 28,1998 MN 98 07 OAZ 98-07 UNITED STATES NUCLEAR REGULATORY COMMISSION Attention: Document Control Desk Washington, D.C.
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References:
(a) License No. DPR 36 (Docket No. 50 309)
(b) USNRC Letter to MYAPCo, dated December 29,1997, Notice of Violations for NRC Inspection Report 50-309 / 97 08
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Subject:
Peply to Notice of Violations Associated with NRC Inspection Report No. 50-309/97-08 Gentlemen:
The attachment to this letter provides Maine Yankee's reply to the Notice of Violations contained in reference (b). Included in this response is the reason for each violation, corrective actions / actions to prevent recurrence and the full compliance date.
Please contact us should you have further questions regarding this matter.
Very truly yours, Y
George %. Zinke, Manage Regulatory Affairs Department Enclosure c:
Mr. Ilubert J. Miller Mr. Ron Bellamy
,j~ {' Ok ' k Mr. Richard J. Rasmussen Mr. Michael K. Webb Mr. P. J. Dostle Mr. Michael T. Masnik Mr. Uldis Vanags
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9902050044 990120 DR ADOCK OSO 3
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}{EPLY TO NOTICE OF VIOLATIONS flotatidn "A'_'
The NRC approved Maine Yankee Atomic Power Station, Physical Security Plan (the Security Plan), Revision 24, dated November 20,1996, Section 6.4.1, states, in part, that "... continuously manned fixed assessment positions are strategically located in the protected area for alann assessment and compensatory measurer for degraded perimeter intrusion detection system (PIDS)...".
Each assessment position is equipped with a device which generates an audible and a visual ahtrm in the event of an intrusion through the PIDS.
Section 1.0 of the Plan states that written procedures shall be established, implemented, and maintained. Additionally, Section 4.3.2 of Security Procedure Number 15 204.1, Revision 1, dated May 9,1997, titled " Assessment Positions", requires that during post tumover, the Assessment Position Officer will verify that no tampering of the reset button associated with the audible alann has occurred.
Contrary to the above, on October 10,1997, a security force member circumvented the re.ct button associated with the audible n' ann in one of the assessment towers. This action limited the ability of the security force member (SFM) to immediately assess a postulated unanticipated intrusion in the protected area. This degraded condition continued for approximately six hours. During that time period,5 additional SFM's failed to perfonn a complete post turnover check, as required by the above referenced procedure.
Mainclankccllesimum Maine Yankee agrees with this violation. The security force member assigned to the assessment position from 0100 to 0200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> on October 10,1997, did place the clip of his personal dosimetry mto the reset button of the PIDS in such a manner that it circumvented the audible alarm.
Subsequently, five additional security force members rotated through this position, and failed to identify the clip in the reset button. The clip was removed from the button at approximately 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br />, by an on coming security force member.
The Maine Yankee conective action process was entered (LB 97 3216). The root cause of this event was un mdividual who violated Maine Yankee procedures by intentionally bypassing an operating security detection system. The next five CT Ms' failure to check the operability of the PIDS was also contrary to the procedure, which requiri hat the alann be checked upon relieving another SFM.
This event is similar to two events which occurred in Aril 5,1991, and March 18,1995. In both events, a security force member placed material into the PIDS in such a manner that it circumvented the audible alann The corrective actions taken in 1991 addressed this action as an act committed b, a single individual to which personnel disciplinary action was taken. In addition a procedure revision was made to include a perimeter alarm test at the beginning of each shill to insm operability.
The corrective actions taken in 1995 included personnel disciplinary actioa, implementation of a spesific training task (Assessment Position Tumover) in the Security Officer Initial Qualification training program, and a change to the Maine Yankee procedures addressing Security Officer duties when assuming an Assessment Position post, i.e. checking for tampering of the PIDS switch.
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!=Mlate Corrective Actions!
The device was removed from the PIDS reset device, and a test of the alami system indicated that the system was functioning properly. The only portion of the alarm system 1 hat had been disabled was the audible alana in t le assessment tower, alamis would still come into the computer system, A review was perfonned of the alann log for the entire time period that the audible alarm was circumvented, to determine if there had been any alanns for which there was no known cause. This i
review indicated that there were no alam,s of unknown cause during that time.
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Corrective Actions Taken to Avold Further Violationi
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- 1. Employment of the individual who bypassed the PIDS audible alann was tenninated.
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- 2. The five security force members who followed on shift were disciplined appropriately.
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- 3. A briefing was provided to all security force members concerning attention to detail and i
adherence to Maine Yankee Procedures.
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- 4. The procedure was changed to require that a PIDS test be conducted hourly to insure proper operation of the system, (This was previously required only on taking over the assessment position.)
Full Co==Hace Date:
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Full compliance was achieved on October 10,1997, at or about 0700 hours0.0081 days <br />0.194 hours <br />0.00116 weeks <br />2.6635e-4 months <br />, when the on-coming security force member removed the clip from the PlDS reset button.
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Ylulation "H" Techniciil Specifications, section 5.8.2.f. required written procedures for fire protection program implementation. The Maine Yankee procedure,19 5, impainnents to Fire Pistection Systems, section 4.2.1, required compensatory measures to be established for impainnents to fue protection plan fire protection systems. Maine Yankee implemented a roving fire watch program as a compensatory measure for degraded fac protection plan fue protection systems.
Contrary to the above, the instnictions for implementation of the roving fire watch program implemented by Maine Yankee were not documented by.rocedures, instead, Maine Yankee used a training lesson plan and a series of memos to implement the program. Inadequate implementation of the roving fire watch program resulted in several instances of rounds not being performed.
Maine Yankte.Runomsl Maine Yankee agrees with this violation.
On June I and 2,1997, Maine Yankee Security personnel observed that some fire watch personnel had not been seen making their tours within the plant. Further investigation revealed that some of the required fire watch tours were missed, but were signed off as completed, and that several tours exceeded the minimum time interval between inspections.
As immediate corrective actions, plant support management instituted a review of fire watch records to verify that there were no obvious problems. The requirements and significance of conducting the fire watches was re-iterated to all incividuals involved in fire watches. Maine Yankee expanded the scope of reviews to include all personnel involved with performing fire watches, in order to detennine the extent of this discrepancy, in response to the results of these reviews, Maine Yankee tenninated the involved em aloyees and placed the fire round responsibilities with Security. These corrective actions climinated t ie problems with fidsification oflogs.
A few days later, a review of Fire Watch Logs identified discrepancies from June 5 9,1997 that involved areas inspected out of sequence and exceeding the minimum time between tours. The root cause evaluation fbr these problems found that inadequacies existed in training, shift turnovers and management oversight. In addition to the corrective actions discussed above, the following corrective actions were then implemented:
A program was started which required supervisors to conduct periodic field perfonnance checks of the fire watch areas to verify that personnel were properly perfonning the required watches.
Supervisory oversight of the fire watch turnovers was added, along with a system to track the shillly activitica of fire watch personnel.
The training lesson plan (FP 1 8.1) was modified to include detailed infonnation on management's expectations on fire watch requirements, log keeping activities, and specific warnings as to the seriousness of records falsification.
Subsequently, the NRC identified that poor procedures contributed to inadequate implementation of the roving fire watch program and issued the notice of violation. Procedure 19-5 is an administrative procedure used toyrovide overall guidance for implementing a fire watch program as compensation for a degraded tire protection system. It did not provide step by-step instruction for physically perfonning a fire watch round. Maine Yankee identified problems in the iniplementation of the fire watch progmm prior to the NRC Notice of Violation. The root cause analysis perfonued at that time led to corrective actions that improved the implementation of the fire watch program, but did not include changes to the procedure.
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l Inunedlaie Corrective Actionat Niaine tankee implemented the immediate corrective actions discussed above. In addition, Procedure 19 5, impainnents to Fire Protection Systems, has been revised to incorporate the instructions contained in lesson plans and memos into the procedure. This provides instructions for implementing the compensatory measure fire watches when the fire protection system is impaired.
Corrective Actions Taken to Avoid Further Violatlemt i
Maine Yankee believes that the corrective actions taken will prevent recurrence.
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Full C-H==ce DAlti f
Full compliance was achieved on January 28, 1998 when the changes to Procedure 19 5, i
Impainnents to Fire Protection Systems, are approved by PORC. Partial compliance was achieved on June 26,1997 when all of the immediate corrective actions discussed above were completed.
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