ML20203C416
| ML20203C416 | |
| Person / Time | |
|---|---|
| Site: | Maine Yankee |
| Issue date: | 02/12/1998 |
| From: | Ronald Bellamy NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | Sellman M Maine Yankee |
| References | |
| 50-309-97-08, 50-309-97-8, NUDOCS 9802250182 | |
| Download: ML20203C416 (3) | |
See also: IR 05000309/1997009
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February 12,1998
Docket No.
50-309
License No.
EA# 98-075
Michael B. Sellman
President
Maine Yankee Atomic Power Company
Baily Point Road
Wicasset, Maine 04578
SUBJECT:
NRC INSPECTION REPORT 50-309/97-08 AND NOTICE OF VIOLATION
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Dear Mr. Sellman:
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This letter refers to your January 28,1998 correspondence, in responso to our December 29,
1997 letter. Thank you for informing us of the corrective and preventive actions documented in
your letter. These actions will be examined during a future inspection of your licensed program.
Your cooperation with us is appreciated.
Sincerely,
Originalsigned byRonald R. Bellamy
Ronald R. Bellamy, Chief
Decommissioning and Laboratory Branch
Division of Nuclear Material Safety
Docket No. 50-309
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OFFICIAL RECORD COPY
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RETURN ORIGINAL TO
9802250182 980212
ADOCK 05000309
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M. Sellman
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Maine Yankee Atomic Power Company
cc:
M. Meisner, Vice President, Nuclear Safety & Regulatory Affairs
51. Fraser, Director- Engineering
J. M. Block, Attorney at Law
P. L. Anderson, Project Manager (Yankee Atomic Electric Company)
L. Diehl, Manager of Public and Governmental Affairs
T. Dignan, Attorney (Ropes and Gray)
G. Zinke, Manager, Regulatory Affairs
W. Odell, Director, Operations
M. Ferri, Director, Decommissioning
M. Lynch, Esquire, MYAPC
P. Dostie, State Nuclear Safety inspector
P. Brann, Assistant Attorney General
U. Vanags, State Nuclear Safety Advisor
C. Brinkman, Combustion Engineering, Inc.
W. D. Meinert, Nuclear Engineer
First Selectmen of Wiscasset
Maine State Planning Officer - Nuclear Safety Advisor
State Pf ar.ning Officer - Executive Department
Friends of the Coast
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M. Sellmtn
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Mrine Ycnkee Atomic Power Company
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Distribution:
Region i Docket Room (with concurrences)
Nuclear Safety Information Center (NSIC)
PUBLIC
NRC Resident inspector
A. R. Blough, DNMS
G. Pangburn, DNMS
R. Bellamy, DNMS
T. Jackson, DNMS
D. Holody, ORM
M. Sartorius, OE
Distribution (VIA E MAIL):
K. Kennedy, OEDO
M. Webb, NRR
- S. Weiss, NRR
J. Hickey, NMSS
L. Pittiglio, NMSS
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M. Callahan, OCA
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D. Screnci, PAO
N.Sheehan, PAO
Inspection Program Branch, NRR (IPAS)
. DOCUMENT NAME: G:\\DNMSOOCWORK\\lNSPLTR\\LDPR36
8994096
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To receive a copy of thle docunient. indicate b the boa: *C' = Copy w/o attach /enci
- E* = Copy w/ tttach/enct . *N* = No copy
OFFICE
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NAME
MRoberts
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RBellamy
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DATE
C2/12/98
02/ /98
02/ /38
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OFFICIAL RECORD COPY
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MaineYankee
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P.O. box 408 * WISCASSET. MAINE 04578 * (207) 882 6321
January 28,1998
MN-98-07
GAZ 98-07
UNITED STATES NUCl EAR REGULATORY COMMISSION
Attention: Document Contid vesk
Washington, D.C.
20555
References: (a) License No. DPR-36 (Docket No. 50-309)
(b) USNRC Letter to MYAPCo, dated December 29,1997, Notice ofViolations for
NRC Inspection Report 50-309 / 97-08
Subject:
Reply to Notice ofViolations 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 contr.ined
in reference (b). Included in this response is the reason for each violation, co.rective actions / actions
to prevent recurrence and the full compliance date.
Please contact us should you have further questions regarding this matter.
Very truly yours,
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George . Zhd:e, Manag
Regulatory Affairs Department
Enclosure
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Mr. Hubert J. Miller
Mr. Ron Bellamy
Mr. Richard J. Rasmussen
Mr. Michael K. Webb
Mr. P. J. Dostie
Mr. Michael T. Masnik
Mr. Uldis Vanags
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REPLY TO NOTICE OF VIOLATIONS
Violation "A"
The NRC-a;> proved 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 alarm
assessment and compensatory measures for degraded perimeter intrusion detection system (PIDS)...".
Each assessiaent position is eouipped with a device which generates an audible and a visual alarm
in the event of an intiusion through the HDS.
Section 1.0 of the Plan states ti at 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 alarm
has occurred.
Contrary to the above, on October 10,1997., a security force member circumvented the reset button
associated with the audible alarm 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 contmued for approximately six hours. During that time
period ' additional SFM's failed to perform a complete post tumover check, as required by the
above .cferenced procedure.
Maine (ankee Resnonse:
Maine Yankee agrees with this violation. The security force men ber 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 dosimet2y
into 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
hours, by an on coming secu-ity force member.
The Maine Yankee corrective action process was entered (LB 97-3216). The rcot cause of this event
was an individual who violated Maine Yankee procedures by intentionally bypassing an operating
security detection system. The next five SFMs' fa' lure to check the operability of the PIDS was also
contrary to the procedure, which required that the lhtrm be checked upon relieving another SFM.
This event is similar to two events which occurred in April 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 alarm. The corrective actions taken in 1991 addressed this action as an act committed
by 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 shift to insure
operability.
The corrective actions taken in 1995 included persor.nel disciplinary action,
implementation of a specific training task (Assessment Position Turnaver) in the Security Officer
Initial Qualification training program, and a change M the Maine Yankee procedures addressing
Security Officer duties when assuming an Assessment rosition post, i.e. checking for tampering of
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the PIDS switch.
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Immediate Corrective Actions:
The device was removed from the PIDS reset device, and a test of the alarm system indiented that
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the system was functioning properly. The only portion of the alarm system that had been disabled
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was the audible alarm in the assessment tower, alarms would st.ll come into the computer system.
A review was performed of the alarm log for the entire time period that the audible alarm was
circumvented, to determine if there had been any alarms for which there was no known cause. This
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revicw indicated that there were no alarms of unknown cause during that time.
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Corrective Actions Taken to Avoid Further Violation:
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1. Employment of the individual who bypassed the PIDS audible alarm was terminated.
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2. Tew tive security force members who followed on shift were disciplined appropriately.
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A bricGng was provided to all security force members concerning attention to detail r.nd
. aewcme 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
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operation of the system. (This was previously required only on taking over the assessment position.)
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Full Compilance 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
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security force member removed the clip from the PIDS reset button.
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Violation "B":
Technical Specifications, section 5.8.2.f, required written procedures for fire protection program
implementation. The Maine Yankee procedure,19-5, Impairments to Fire Protection Systems,
section 4.2.1, required compensatory measures to be established for impairments to fire protection
plan fire protection systems. Maine Yankee implemented a roving fire watch program as a
compensatory measure for degraded fire protection plan fire protection systems.
Contrary to the above, the instructions for implementation of the roving fire watch program
implemented by Maine Yankee were not documented by procedures. 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 Yankee Response:
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 individuals involved in fire watches. Mainc Yankee expanded the
scope of reviews to include all per .onnel involved with pcrforming fire watches, in order to
determine the extent of this discrepancy.
In response to the results of these reviews, Maine Yankee terminated the involved employees and
placed the fire round responsibilities with Security. These corrective actions eliminated the problems
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with falsification 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 for 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 performance
checks of the fire watch areas to verify that personnel were properly performing the required
watches.
Supervisory oversight of the fire watch turnovers was added, along with a system to track the
shit 11y activities of fire watch personnel.
The training lesson plan (FP-L-8.1) was modified to include detailed information on
management's expectations on fire watch requirements, log keeping activities, and specific
warnings as to the seriousness of records faSification.
Subsequently, the NRC identified that poor procedures contributec'. to inadequate implementation
of the roving fire watch program and issued the notice of violation. Procedure 19-5 is an
administrative procedure used to provide overall guidance for implementing a fire watch program
as compensation for a degraded fire protection system. It did not provide step-by-step instruction
for physically performing a fire watch round.
Maine Yankee identified problems in the
implementation of the fire watch program prior to the NRC Notice of Violation. The root cause
analysis performed 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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Immediate Corrective Actions:
Maine Yankee implemented the immediate corrective actions discussed above. In addition,
Procedure 19 5, Impairments 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 Violation:
Maine Yankee believes that the corrective actions taken will prevent recurrence.
Full Comnilance Date:
Full compliance was achieved on January 28,19'?8 whea the changes to Procedure 19-5,
Impairments to Fire Protection Systems, are approved oy PORC. Partial compliance was achieved
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on June 26,1997 whea all of the immediate corrective actions discussed above were completed.
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