ML20214W267
| ML20214W267 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 06/05/1987 |
| From: | Nauman D SOUTH CAROLINA ELECTRIC & GAS CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| NUDOCS 8706150185 | |
| Download: ML20214W267 (4) | |
Text
f' 10 CFR 2, App. C.V.A.
S Electric & Gas Company Den A.
aunwt Columbia. SC 29218 NucL*ar Operations (803) 748-3513 SCE&G ASElRiuSCaste1p
,; eQ June 5, 1987 s,.g r -,
Dr. J. Nelson Grace Region Administrator j
U. S. Nuclear Regulatory Commission Suite 2900 101 Marietta Street, NW Atlanta, Georgia 30323
SUBJECT:
Virgil C. Summer Nuclear Station Docket No. 50/395 Operating License No. NPF-12 NRC Inspection Report 87-12
Dear Dr. Grace:
Enclosed is the South Carolina Electric & Gas Company (SCE&G) response to the violation addressed in Enclosure 1 of NRC Inspection Report 50-395/87-12.
SCE&G is in agreement with the alleged violation, and the enclosed response addresses the reasons for the violation and corrective actions taken to prevent recurrence.
If you should have any questions, please advise.
yer trul rs,
.N nan RJB: DAN /bjh Enclosure cc:
- 0. W. Dixon, Jr./T. C. Nichols, Jr.
G. O. Percival E. C. Roberts R. L. Prevatte
- 0. S. Bradham J. B. Knotts, Jr.
J. G. Connelly, Jr.
Marsh & McLennan D. R. Moore I&E Washington W. A. Williams, Jr.
Document Management Group Managers Branch W. R. Baehr INP0 Records Center W. T. Frady ANI Library C. L. Ligon (NSRC)
NPCF R. M. Campbell, Jr.
File K. E. Nodland J. C. Snelson fff$ $
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ENCLOSURE 1 RESPONSE TO NOTICE OF VIOLATION VIOLATION N0. 50-395/87-12 I.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION South Carolina Electric & Gas Company (SCE&G) is in agreement with the alleged violation.
II.
REASON FOR THE VIOLATION On March 29, 1987, a vital area was temporarily downgraded to a protected area to facilitate maintenance activities in the area.
At 0044 hours5.092593e-4 days <br />0.0122 hours <br />7.275132e-5 weeks <br />1.6742e-5 months <br />, April 2, 1987, a security patrol officer noted that three sections of metal floor grating separating the temporarily downgraded area from an adjacent vital area were not secured.
Although the grating was in place, there existed the potential for unauthorized or undetected access into an area containing vital equipment.
The cause of this event is attributed to personnel error in conjunction with an inadequate security procedure.
The procedure was inadequate in that:
1.
The procedure only requires the identification of affected doors when an area is changed from vital to protected status.
2.
The procedure does not specifically require any evaluation or inspection of barriers other than doors which might impact on adjoining vital areas.
3.
The procedure does not provide adequate guidance for security actions required to change the status of a vital area to a protected area.
Personnel errors were made in that:
1.
While not specifically required by procedure, an inspection or an evaluation of the area affected by the requested change should have been conducted to ensure that the security actions did not adversely impact any other vital area.
2.
While the regularly scheduled security patrols conducted every two hours served to detect any unauthorized personnel in the area, the security officers failed to promptly recognize the unsecured grating.
The consequences of this event were minimal due to the following:
1.
The reactor was defueled and there was no safety significance.
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r 2.
During the period the area was downgraded, access authorization was not altered for the area; consequently, when the doors were secured, access was controlled by the use of cardkeys. Only during those periods when the doors remained open for maintenance activities were the cardkey access requirements relaxed.
3.
The affected areas were patrolled every two hours by security personnel to detect access by unauthorized personnel.
III.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Upon noting the unsecured sections of metal floor grating, the security patrol officer immediately notified the Central Alarm Station and was directed to assume a compensatory post. This post remained in effect until the grating was secured with chains and security locks at 0145 hours0.00168 days <br />0.0403 hours <br />2.397487e-4 weeks <br />5.51725e-5 months <br /> on April 2, 1987. Notification to NRC Operation Center via the Emergency Notification System was made at 1130 hours0.0131 days <br />0.314 hours <br />0.00187 weeks <br />4.29965e-4 months <br />, April 2. 1987, as required by 10 CFR 73.71.
Evaluation of this event indicaced a moderate loss of physical security effectiveness.
IV.
CORRECTIVE ACTION TAKEN TO AVOIO FURTHER VIOLATION On April 6, 1987, a Management Review Board Meeting, chaired by the Vice President Nuclear Operations, was held to review the security incident. The Management Review Board directed that the following corrective actions be taken due to this event:
1.
The applicable procedure will be revised to provide detailed guidance in the following areas:
a.
Both security and engineering personnel will be designated specific responsibilities for evaluation of any area requested to be temporarily changed from a vital to a protected status to ensure that the action is feasible and will not adversely affect the physical security effectiveness of any other vital area.
b.
Instructions and checklists will be developed to implement security actions prior to temporarily changing an area from vital to protected status and returning the affected area to a vital status after the action is completed.
c.
A revision will be made to the security area designation change form to provide a more logical and efficient method of documenting the evaluation of actions required prior to approval of a change in area designation.
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2.
During the next security training cycle, the following topics will be incorporated into the program of instruction:
a.
Review of the incident with all members of the security
- force, b.
Patrol inspection technique and criteria for vital areas and associated barriers as well as other patrol activities specified in security procedures.
3.
Security supervisory personnel will review the incident, the implementation procedures and other programs which involve the removal, restoration, and modification of existing security barriers or installation of new security barriers.
4.
The Security Shift Leader on duty at the time of this event will prepare a lesson plan for presentation to all security personnel which will address:
a.
First line supervisory responsibilities, b.
Accountabilities of security personnel, and c.
Awareness of responsibilities during patrol activities.
5.
A plant modification is to be expedited to permanently secure the grating between these vital areas.
(Action complete May 12.
1987) 6.
An engineering evaluation and plant walkdown to identify similar areas within the plant which could lead to a loss of security effectiveness between adjacent vital areas if one side were downgraded to a protected area will be performed.
Until completion of action items 1, 2, 3, and 4 above no additional vital areas will be downgraded.
V.
DATE OF FULL COMPLIANCE Corrective action addressed in Item 1 above will be completed by July 1, 1987. Corrective action addressed in Items 2, 3, 4, and 6 will be completed by November 1, 1987. The corrective action addressed in Item 5 was completed on May 12, 1987.
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