ML20210U918
| ML20210U918 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 09/15/1997 |
| From: | Mecredy R ROCHESTER GAS & ELECTRIC CORP. |
| To: | NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-244-97-08, 50-244-97-8, NUDOCS 9709220154 | |
| Download: ML20210U918 (5) | |
Text
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ROQt[S!IR GAS ANDEllCTRICCCt/DCATCN
- 89[ASTAVENUC, ROCHESTER, N Y 14649 0001 AREA CODE 716 546-2700 ROBERT C. MECREDY vu em.o.n, Hster opeu+om September 15, 1997 Director, Office of Enforcement U.S. Nuclear Regulatory Commission
~ ATTN:
-Document Control Desk Washington, D.C.
20555
Subject:
-Reply to a Notice of Violation NRC Inspection Report No. 50-244/97-08, dated August 15, 1997 R.E. Ginna Nuclear Power Plant Docket No. 50-244 Gentlemen:
Rochester Gas and Electric (RG&E) provides this reply within 30 days of the date of the letter which transmitted the Notice of Violation.
Within the Notice of Violation, it was also required that the-civil penalty be paid within the same time as provided for. the response.
A check, payable to the Treasurer of the United States in the amount of $55,000, was mailed on Friday, September 12, 1997 During an NRC Inspection conducted from May 27-30,
- 1997, for which an exit meeting was conducted on May 30, 1997, potential-violations of NRC requirements were identified.
In accordance with the
" General Statement of Policy and Procedure for NRC
- Enforcement Actions, " NUREG-1600, the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the
~ Atomic Energy Act of 1954, as amended (Act), 42 U.S.C.
2282, and 10 CFR 2.205.
The particular violations and associated civil penalty are set forth below:
License Condition
.E(1) of License Number DPR-18 for the Ginna-facility, requires that the Licensee maintain' in effect and fully implement all provisions of the security
. plan.
The R. E. Ginna. Nuclear. Power Plant Physical Security Plan, R e v i's i o n - L, dated March 13, 1996, Section 3.2.5,
" Vehicle
___ Denial,"~ states, in-part,
" Vehicle Barriers have been deployed-in~ strategic areas outside the outer isolation zone to prevent.the malicious use of a vehicle to gain entry to the protected and vital areas."
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Page 2 Contrary to - the above, on May 27, 1997, the NRC observed that the vehicle barriers deployed outside the outer isolation zone would not prevent the malicious use of a vehicle to gain entry to the protected and vital areas, as evidenced by
- the following examples, each of which constitutes a separate violation.
1.
Three openings existed in the vehicle barrier which were 1
large enough for a
vehicle-to pass through.
Specifically, there was a 14-foot opening between the end of the barrier and the cliff on the northwest corner of the barrier; there was an 8-foot opening between the barrier and the cliff on the northeast corner of the barrier; and there was an 8-foot opening in the barrier on the west (sic)-side of the security building.
2.
Approximately 1200 feet of the vehicle (sic) was bollards and cable.
The cable was secured to bollards that were approximately 300 feet apart.
Between the
- bollards, the cable was supported by support posts.
The cable was secured to the posts with nylon ties.
The nylon ties could be easily removed with hand held tools such.as pliers, which would result in the cables being laid on the ground, thereby negating any benefit of the cable as a barrier, and allowing vehicles to get through.
(1) admission or denial of the alleged violation:
Rochester Gas &
Electric Corporation (RG&E) accepts the violations.
We acknowledge that there were inadequacies in the - vehicle barriers deployed outside the outer isolation zone, including an opening on the east (not west) side of the security building, to prevent the malicious use of a vehicle to gain entry to the protected and vital areas.
(2) the reasons for the violation if admitted, and if denied, the reasons why:
RG&E performed a thorough root cause evaluation of the cited violations and determined that the errors occured because of the following reasons:
a.
The-three-openings in the vehicle barrier system (VBS) were a - result of an imperfect interpretation of NRC requirements.
-The RGEE VBS design did not consider a slow moving vehicle as a threat.
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C Page 3 b.
The use of nylon ties on the cable bollard post was a result of f ailure to incorporate developing NRC guidance into the VBS design, c.
A third root cause was also found common to both of the two cited violations.
The VDS design was processed as a
non safety-related modification, which did not require independent review.
Even though 10CFR50 Appendix B criteria does not apply to the VBS, elements of the Appendix B design control process would have g
helped ensure NRC regulatory requirements were properly implemented.
(3) the corrective steps that have been taken and the results achieved:
a.
Installation of additional barriers in the areas where the openings existed, such that all openings are within the specified guidance provided by NUREG/CR-6190 and NRC Regulatory Guide 5.68.
b.
Temporary replacement of the nylon ties with metal clamps, which included measures to prevent removal of nuts with simple hand tools, c.
Subsequent installation of welded steel plates at every other post to provide additional assurance that hand tools cannet remove cables from their post.
d.
Implementation of a
weekly VBS inspection by the security force.
These inspections have not detected any further deficiencies, e.
A quarterly Engineering Inspection checklist which clearly identifies VBS design features that are suscepti-ble to degradation and tamperir.g with a corrective action process and acceptable compensatory measures.
This results in programmatic controls to encure deficiencies are detected and corrected in a timely manner by RG&E personnel, f.
Training of engineering and security personnel regarding the VBS has heightened awareness of core VBS issues, and has laid a foundation for future formal classroom
- training, g.
Revised -Nuclear Interface Procedure IP-DES-2 (Plant Change Process) to require all changes which change USNRC commitments to use the design verification process as described by ANSI N-45.2.11.
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A-l sampling review of ~ plant change design criteria; to assess proper identification of design --input-' require-1 ments.
The assessment found no inadequacies.
(4) the1 corrective steps that will be taken to avoid further l
violations:-
a.-
Classroom training of engineering personnel using the VBS event as a case study to review -the need' for proper.
design inputs-and verification of. inputs and outputs.
This training will be completed by October 17,-1997..
b.
A review of the training needs'for appropriate; nuclear personnel will be conducted by the appropriate curriculum committees.
This review will be performed by December 31, 1997, c.
A review of security system design basis requirements to identify any potential-area of concern has been completed.
The identified issues are being tracked by the Ginna Station-corrective action process.
1 d.
Improvements identified as a result of the Plant Change Procer s self-assessment P 4ve - been implemented, which strengthens the Modification turnover process.
e.
Perform an external assessment of non safety-related modification design-criteria adequacies by December 31, 1997.
f.
Management expectations-have. been enhanced for reporting.
-1 security problems requiring the ACTION report process to be used.
(5)- the date when full compliance will-be achieved:
Full compliance was achieved on August 8,-
1997, when all hardware changes to the-bollard and Jersey Barrier features were completed and interim security compensatory measures were removed.
d 4
Page 5 RG&E also wishes to correct a statement made in the subject August 15, 1997, letter.
It was stated (on page 3) that RG&E would resubmit to the NRC the summary description of the Design Basis Explosio? Evaluations to specify the actual stand-off distances used in the calculations."
RG&E did not calculate the actual stand-off distances, but performed Design Basis Explosion calculations at distances well within the VBS to ensure that proper protection would be afforded to the required safe shutdown equipment.
This information and methodology was provided in the summary description transmitted to the NRC in a letter from RG&E (Mecredy) to the NRC, dated August 4, 1997.
Very truly yours, l
f) 'f,.,/
j"l Jca s.&
/'i Robert C. Mecredy Subscribed and sworn to before me on this 15th day of September, 1937.
MW NelelyIdEC h$9EhdNOWM Notary Public g ggggg M gw p fllhl9 9 41Fl500815s xc:
Director Special Projects Office NRR U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Mr. Guy S.
Vissing (Mail Stop 14B2)
Project Directorate I-1 U.S.
Nuclear Regulatory Commission Washington, D.C.
20555 Regional Administrator, Region I U.S. Nuclear Regulatory Commission Region I 475 Allendale Road King of Prussia, PA 19406 Ginna Senior Resident Inspector