ML20203D112
| ML20203D112 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/10/1997 |
| From: | Gordon Peterson DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-413-97-12, 50-414-97-12, NUDOCS 9712160112 | |
| Download: ML20203D112 (11) | |
Text
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r-Duke Power Company j
A l* Ewo %v r
hv I Catauss Nwlear Station e
esa s.,c.,.,
4800 Concord Road York. SC 29745 j
3 Cary R. Peseteoa (803) 8314251 omct Vue hesident (803) 831-3426 fax December 10, 1997 U. S. Nuclear Regulatory Commission
~-ATTN:
Document Control Desk Washington, D.C.
20555
Subject:
Duke Energy Corporation Catawba Nuclear Station Dockets 50-413 and 50-414 Reply to Notice of Violation (NOV)
Inspection Report 50-413, 414/97-12 Attached is Duke Energy Corporation's response to the three Level IV violations cited in Inspection Report 50-413, 414/97-12 dated November 10, 1997. These violations were identified during inspections conducted August 31, 1997 through October 11, 1997.
Commitments contained in this document are those listed under Section 3 of each response.
If there are any questions concerning this response, please contact K.
E. Nicholson at (803) 831-3237.
Sin 'r ly, YM G.-R.
Peterson
\\ KEN: RESP 9712. DOC 1
xc:
L. A. Reyes, Regional Administrator
{h P.
S. Tam, ONRR D. J. Roberts, SRI 9712160112 971210 PDR ADOCK 05000413 0
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CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VICLATION 413, 414/97-12-02 i
4 Notice of Violation Technical Specifica tion 6.8.1
- requires, in part, that written procedures shall be established, implemented and maintained for applicable procedures in Appendlx A to regulaCory Guide 1.33.
Quality Assurance Program Requirements (Operations), Revision 2, 1978.
Appendix A specifies procedures for Security and Visitor I
Control.
Duke Energy Corporation Procedure Nuclear System Directive 218 of t
Volume 2,
requires management, in the Nuclear Policy Manual case of involuntary and voluntary termination, to be responsible for verbally notifying, site security and/or site s taffing contacts to delete a terminated individuals' security badge.
For involuntary terminations, security is to be notifled prior to the termination / discharge or simultaneously with
-the termina tion / discharge.
Catawba Nuclear Station Security Procedure Number 208, Badging OEficer/Speciallst, Revision 29, paragraph 6, requires badges to j
be destroyed and unassigned through the appropriate security computer, upon receipt of a' Security Badge Transaction Request.
Contrary to the above, the licensee failed to follow procedures for security badge access control as evidenced by the following:
- 1. On September 9, 1996, security failed to destroy and unassign the access badge of a
voluntarily (favorably) terminated individual.
No protected or vital areas were accessed.
- 2. On September 26,
- 1996, one individual was voluntarily (favorably) terminated, and the responsible manager failed ta notify security.
No access to the protected area was gained.
- 3. On October 24, 1996, vendors failed to notify security of the voluntary (favorably) termination of four individuals.
There was no access to the protected or vital area after their termination.
l-
- 4. On November 13, 1996, a. site manager failed to notify security of the voluntary (favorably) termination of an individual.
There was no access to the protected or vi tal areas after termination.
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CATAWRA NUCLEAR STATION
]
REPLY TO NOTICE CF VIOLATION 413, 414/97-12-02 b
E. On January 31, 1997, a vendor failed to notify security of a i
1 -
voluntary (favorably) termination of two individuals.
No I
protected areas were accessed.
- 6. On April 24, 1997, security failed to destroy and unassign the access badges of.two voluntarily (favorably) terminated i
. individuals.
No-protected or vital areas were accessed.
1
- 7. On June 20, 1997, one individual was voluntarily (favorably) terminatcd, and the responsible' manager failed to notify security.
No access to the protected area was gained.
This is a Severity Level IV violation (Supplement III).
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CATAWBA PUCLEAR STATION l
REPLY TO NOTICE OF VIOLATION 413, 414/97-12-02 1.
Reason for Violation Duke Energy Corporation accepts this violation.
This violation is attributed to ineffective corrective actions that address human performance issues.
Personnel were not properly terminating security badges due to ineffective process management and lack of personal accountability.
In 1996, Catawba Security had identified an adverse trend j
based on the results of monitoring and trending.
This information was communicated to Duke's General Office and a Problem Investigation Process (PIP) 0-G96-0332 was initiated to track the implementation of corrective actions at each of the three company nuclear sites.
Although corrective actions were implemented te address human performance issues, these were not effective in achieving a satisfactory level of improved human performance.
2.
Corrective Actions Taken and Results Achieved An Access Control Daily Process Checklist was developed and implemented.
This
- requires, in part, a
review of the deletion file printout once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift and a review of the badge expiration printout once per 12 hour1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> shift.
This checklist provides a
means to ensure activities associated with badge review and removal are being conducted and that there is adequate communication between the off-going and on-coming security shifts.
This checklist will be utilized until confidence is gained to ensure activities necessary for effective access control are being performed.
The time of printing and frequency of reviewing badge expiration information was changed.
This printout was 4
previously printed only at the beginning of each month and reviewed daily for expired badges.
This led to security personnel either not checking the printout or missing badge numbers which needed to be deleted.
This monthly printout did not reflect any badges due to expire that had been added subsequent to the monthly printout.
This process was revised to require a daily printing of the report and a daily review of this rcport.
This change, in conjunction with the Access Control Checklist, ensures that a - current copy of the Badge Expiration Printout is re/iewed at least twice daily.
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CATAWBA NUCLEAR STATION REPLY TO NOTIC3 CF VICLATION 413, 414/97-12-02 Nuclear System Directive (NSD)
- 218, Nuclear Access Authorization
- Program, was revised 09/16/97 to clarify responsibilities for making access restriction notifications to Security.
4 NSD 216 incorporates a simplified notification process to notify site security of the need to restrict unescorted access when personnel are terminated.
A dedicated telephone line (a common extension number at all three nuclear sites) has been established in Security and will be staffed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> a day. This extension will be used to notify Security of terminations and other badge restrictions.
Training was provided to badge sponsors on the requirements of the revised NSD 218.
Badge sponsors, as defined by NSD 105, Control of Non-Assigned Individuals and Organizations, are those individuals designated by site management to authorize unescorted access.
3.
Corrective Action to be Taken to Avoid Future Violations A single point of contact (SPOC) position within Human Resources will be created to handle all (including vendor) personnel terminations.
This commitment will be tracked in PIP 2-C97-3662 and assigned to Human Resources to be completed by 06/30/98.
Specific language will be included in standard vendor contracts to detail the vendor's obligation to comply with Duke Energy's badge termination process.
This commitnient will be tracked in PIP 2-C97-3662 and assigned to Purcharing to be completed by 01/01/98.
Accountabilities for those personnel involved with notifications and other actions involved in the badge termination process will be c2early identified and communicated.
This commitment will be tracked in PIP 2-C97-3662 and assigned to Work Control to be completed by 06/30/96.
The-Plant Access Training (formerly General Employee Training) manual will be revised to include the process used to delete security badges. This commitment will be tracked in PIP 2-C97-3662 and assigned to Training to be completed by 03/31/98.
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CATAWBA NUCLEAR STATION REPI.Y TO NOTICE OF VIOLATION i
413, 414/97-12-02 A standardized badge termination process will be implemented for vendors and temporaries which includes a
specific checklist describing supervisory and job sponsor responsibilities for out-processing terminations.
This commitment will be tracked in PIP 2-C97-3662 and assigned to Work Control /In-Processing to be completed by 01/01/98.
4.
Date of Full Compliance Duke Energy Corporation is now in full compliance with Technical Specification 6.8.1 in that procedures NSD 218 and Security Procedure 208 are being properly followed.
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CATAWBA MUCLEAR STATION o,
REPLY TO NOTICE OF VIOLATION 413, 414/97-12-03 i
Notice of Violation 10CFR 73.55 (d)
(8) states to the offect that access control
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devices used to control access to protected and vital areas must be controlled to reduce the probability of compromise.
Duke Energy Corporation Nuclear Security and contingency Plan, Revision 6,
Chapter 6.
" Access "
Paragraph 6.3, provides that protected area badges shall remain within the protected area.
4 Duke Energy Corporation Nuclear Policy Manual - 2, Nuclear System Directive: 217, Nuclear Security Program, Revision 2, Paragraph 217.5.3.1, states to the etfect that badges shall remain within the protected area except when under the control of site security personnel.
Further, it requires security badges be dropped into the chute located at the exit turnstile prior to leaving the facility.
I Nuclear Sca tion Security Procedure No.
- 208, Revision 29, Paragraph 3.1.4, requires that prior to exiting the prctected area, all badges shall be placed in the drop chute at the badging office.
Contrary to the above, the licensee failed to follow Nuclear.
Station Security Procedure Number 208 on five occasions between the dates of January 6,
1997 and August 22,
- 1997, when the licensee failed to control protected area access badges were i
taken outside the protected area.
This is a Severity Level IV violation (Supplement III).
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CATAWBA NUCLEAR STATION REPLY TO NOTICE CF VICLATION 413, 414/97-12-03
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i 1.
Raason for violation l
Duke Energy Corporation accepts this violation.
This violation was a result of human performance failures which occurred when personnel failed to turn in their security badges prior to leaving the I.;otected area.
A contributing factor was the vulnerability of a component of the badge detection system utilized at Catawba.
The purpose of the badge detection system is to provide an audible alarm if a badge is being removed from the protected area.
This detection and alarm system serves only as a reminder to persennel leaving the protected area to turn in their badge.
It is known that the sensor coils utilized in the - badges could become degraded over time if bent or broken and may not alarm the detection system at the exit point.
These coils are checked, identified, and repaired or replaced on a periodic basis. The condition of the sensor coil does not affect controlled access door (CAD) access.
it was decided that the present badge detection system would not be replaced because a new badging system was scheduled for implementation in June, 1997.
This biometric system was not implemented as originally scheduled due to a software delivery delev, and is now scheduled for implementation in
- March, 1998.
The biometric system will utilize a picture identification badge in conjunction with the individual's hand-geometry to grant access into and out of the protected area.
The identification badge will be retained by the employee when they exit the protected area.
2.
Corrective Actions Taken and Results Achieved l
Equipment has been installed to assist plant personnel in performing security badge return.
This system utilizes a motion-activated programmed message playback system at the exit turnstiles which reminds personnel to return their security badge.
The pre-programmed message has instant playback capability which does not require a set time for reset and playback of the recorded message.
This system is utilized in addition to the existing badge detection system as an added self-check reminder for plant employees exiting the protected area.
This equipment will remain in service until the biometric system is fully implemented.
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CATAKBA NUCLEAR STATION REPLY TO NOTICE OF VICLATION 413, 414/97-12-03 j
3.
Corrective Action to be Taken to Avoid Future Violations The current badging system will be converted to a bicmetric system. This commitment will be tracked in PIP 2-C97-3662 and assigned to security to be completed by 03/31/98.
4.
Date of Full Compliance Duke Energy Corporation is now in full compliance with the requirements of 10CFR 73.55 (d) (8) by properly controlling access badges.
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l CATAWBA NUCLEAR STATION i
REPLY TO NOTICE OF VIOLATION 413, 414/97-12-04 4
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Notice of Violation 10CFR 73.71 requires licensees subject to the provisions of 10CFR73.SS to maintain a current log and record the safeguards evencs described in paragraph II (a) and (b) of Appendix G to 3
Part 93 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery by a licensee employee.
Appendix G to Part 73, paragraph II (a),
requires that any failure, degradation, or discovered vulnerability in a safeguards system that could have allowed unauthorized or undetected access to a protected area be recorded within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery in the safeguards event log.
^
1 Contrary to the
- above, failures, degradation or discovered vulnerabilities in safeguards systems that could have allowed unaJthOrl:ed or undetected access to a protected area Were not being recorded.
Specifically, Duke Energy Corporation Nuclear Security Manual, Repot:.ing and Trending of Safeguards and Security
- Events, Fevision 11, Appendix E,
inappropriately provided an exception to 10CFR. 73, Appendix G,
in that it authorized the licensee to not report in the safeguards event log security badges available for issue to an individual whose access should have been restricted (under favorable conditions) and was identi fied and deleted during the licensee's 31-day review.
This is a Severity 1,evel IV vialation (St:pplement III).
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CATANBA NUCLEAR STATION g
RCPLY TO NOTICJ CF VICLATION 413, 414/97-12-04 1.
Reason for Violation Duke Energy Corporation accepts this violation.
This violation occurred as a result 'f incorrect logging guidance incorporated into the Duke Nuclear Security Manual Directive, Reporting and Trending of Safeguards and Security Events.
2.
Corrective Actions Taken and Resulto Achieved Security now logs each instance in the Safeguards Event Log whereby a
security badge for a
favorable, voluntary termination is not restricted within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as required by the Nuclear Access Program and reflected in NSD 218.
3.
Corrective Action to be Taken to Avoid Future Violations The Nuclear Security Manual Directive, Reporting and Trending of Safeguards and Security Events will be revised to require logging of this type event if the badge is not terminated within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for a
favorable, voluntary termination as required in NSD 218, Nuclear Access Program.
This commitment will be tracked in PIP 0-C97-3662 and be assigned to Security to be completed by 02/01/98.
4.
Date of Full Compliance Duke Energy Corporation is now in full compliance.
Catawba currently logs those badge termination events which occur that are not jn compliance with its Nuclear Access Program.
Catawba has established 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> as the appropriate time for deactivation for voluntary separation since no time period is delineated in 10CFR 73 for badge deactivation.
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