ML20236K727
| ML20236K727 | |
| Person / Time | |
|---|---|
| Issue date: | 10/24/1986 |
| From: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | Heltemes C NRC OFFICE FOR ANALYSIS & EVALUATION OF OPERATIONAL DATA (AEOD) |
| Shared Package | |
| ML20236K265 | List:
|
| References | |
| FOIA-87-377 NUDOCS 8708070233 | |
| Download: ML20236K727 (9) | |
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UNITED STATES
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ARLINGTON, TEXAS M011 OCT 2 ? 1986 i
MEMORANDUM FOR: Clemens J. Heltemes, Jr., Director Office for Analysis and Evaluation l
of Operation Data j
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FROM:
Ro^oert D. Martin, Regional Administrator
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SUBJECT:
INPUT TO THE ABNORMAL OCCURRENCE REPORT TO CONGRESS I
In accordarse with your October 8,1986, memorandum on the Abnormal Occurrence Report to Congress for the third quarter of calendar year 1986, we have reviewed AE00 proposals and activities in this region for deportability.
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In accordance with AEOD's proposal, we have enclosed draft input on " Generic Security Violations at Several Nuclear Power Plants."
In addition, we have
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enclosed draft input on " Inadequate Access Control and Physical Barriers at the i
River Bend Station."
l Our coments on other issues noted in your memorandum are given below.
l 1.
" Alleged Violation at Pathfinder Mines Corporation" - The final I
disposition of the enforcement action taken against Pathfinder Mines Corporation was a Notice of Violation that contained a Severity Level III J
problem. A civil penalty was not imposed in lieu of a fine paid by the licensee to the State of Wyoming. We, therefore, recomend that this l
l issue not be included in the report to Congress.
2.
" Exposure to Radiographic Personnel due to Management and Procedural f
Control Deficiencies" (A0 85-17) - The licensee, Western Stress, requested
{7 and received termination of its NRC license on April 30, 1986. A closeout inspection was performed by Region IV personnel who found no items of f
noncompliance. For the reasons discussed in my July 30, 1986, memorandum to you, we recomend that an update on this matter to the report to Congress not be made at this time.
3.
"Rupturo of a Uranium Hexafluoride -Cylinder and Release of Gases" (A0 86-3) - We understand that AEOD has requested from NMSS a writeup on significant actions regarding the Sequoyah Fuels Corporation. We expect that writeup to include (a) the licensee's request to perform limited opgrations;)(b) the issuance of the October 2,1986, Order Modifying Licea'se; (c the issuance of the October 14, 1986, Notice of Violation and Proposed Imposition of Civil Penalties; and (d) the issuance of the October \\1 6, Director's Decision Under 10 CFR 2.206.
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N Clemens J. Heltemes, Jr., AE00 !
For inclusion into the report to Congress on AD 86-3, we are providing the following paragraph.
A special team inspection conducted July 28 through August 1, 1986, (NRC
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Report 40-08027/86-08 dated September 4, 1986) resulted in closing out 22 l
of the 23 itens identified as either apparent violations, deviations, or open items in NRC Inspection Report 40-08027/86-02 dated May 9, 1986. One l
item, apparent violation 40-08027/86-02/13, was not closed out and will remain open pending restart to allow the licensee to complete on-the-job
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l training of operators and walk down evaluations of modified plant equipment. Additionally, 12 allegations were reviewed and no violations or deviations were identified.
Any questions on our input may be directed to Dale A. Powers at FTS: 728-8195.
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l-i obert D. Martin Regional Administrator
Enclosures:
As stated cc w/encls:
P. Bobe, AE0D R. Bangart, RIV 1
W. Fisher, RIV L. Yandell, RIV g.
J. Everett, RIV v
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Generic Security Violations at Several Nuclear Power Plants Date and Place - By letters of July 7, 1986 (Refs. 1, 2, and 3), the NRC issued l
to both Kansas Gas and Electric Company (KG&E), licensee of the Wolf Creek l
Generating Station, and Public Service Company of Colorado (PSC), licensee of I
the Fort St. Vrain Nuclear Station, a Noti:e of Violation and Proposed Imposition of Civil Penalties, and to Arkansas Power and Light Company (AP&L),
licensee of Arkansas Nuclear One facility, a Notice of Violation for identified deficiencies in plant physical barriers.
Nature and Probable Consequences - The July 7, 1986, letters identified serious failures of the licensees to comply with NRC regulatory requirements pertaining to physical barriers. In the most serious example, it was determined at the Wolf Creek Generating Station that multiple uncontrolled access paths existed from the Owner Controlled Area (OCA) into the Protected Area (PA) and in two instancesintoVitalAreas(VAs). This condition was identified by the licensee as part of a quality assurance surveillance followup and confirmed by i
a Region IV safeguards specialist during reactive inspection 50-482/85-44 l
(Ref.4). At the Fort St. Vrain Nuclear Station, NRC inspectors identified during routine inspection 50-267/85-32 (Ref. 5) two uncontrolled access paths from the OCA to the PA and VA.
In this situation, each access hao a barrier installed, but each was evaluated to be inadequate and not capable of preventing an intruder from defeating it easily. At the Arkansas Nuclear One facility, NRC inspectors identified during routine inspection 50-313/85-26; 50-368/85-27 (Ref. 6) one uncontrolled access path from the OCA to the PA. The barrier inside the PA had been secured at one tinue but was found broken at the l
I time of the inspection and routine surveillance patrols had failed to discover this condition.
f In all three examples, conditions existed whereby an intruder could have
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cbtained unauthorized and undetected access into protected and/or vital areas from the OCA. It appeared from the inspections and review of licentee records that the conditions had existed at all three plants for a minimum of six to seven months.
s Cause or Causes - The cause of these occurrences was a failure in management J
control.~At the Wolf Creek Generating Station and the Fort St. Yrain Nuclear Station, this included design oversight during the system planning stages, construction deficiencies, and the failure of the startup testing / surveillance program to identify these deficiencies. At Arkansas Nuclear One, management oversight failed to ensure that adequate surveillance patrols were performed to identify such conditions. Another related cause at the Wolf Creek Generating Station was the failure of management to provide coordination among the various organizational entities which may affect facility security.
N Actions Taken to Prevent Recurrence l
Licensee - In each case identified, the licensee took immediate corrective action to post compensatory guards and install appropriate barriers. At Arkansas Nuclear One, the barrier inside the PA was reinstalled, and a routine surveillance was initiated to check this and other similar barriers. At Fort St. Vrain Nuclear Station, the affected piping was secured with adequate barriers and a routine surveillance was initiated to ensure that no degradation to these and similar barriers had occurred. The Wolf Creek Generating Station installed acceptable barriers where required and initiated a complete walkdown of the PA and VA to identify all possible points of vulnerability. This work is being conducted by a KG&E Security Passive Barrier Task Force that was formed to review all penetrations in passive barriers to assure that no further problems exist. Details of this activity are contained in NRC Inspection Report 50-482/86-03(Ref.7).
All licensees have modified engineering / design change procedures to ensure that i
security system requirements are considered as part of any overall plant changes that could impact the safeguards program / systems.
NRC - On the date that the Wolf Creek Generating Station identified this condition, Region IV initiated calls to all the Region IV licensees and to the other NRC regions to alert them to the generic implications of this finding.
Enforcement conferences were held at the Region IV office on November 25, 1985, with KG&E and January 6,1986, with PSC to discuss these issues and the corrective actions undertaken by the licensee. Specific corrective actions described by the licensees and evaluated by the NRC are contained in a KG&E j
letter (Ref. 8), a PSC letter (Ref. 9), and an AP&L letter (Ref.10). The NRC issued an Inspection and Enforcement Information Notice No. 86-33 (Ref.11)
I that was issued on September 19, 1986, to further inform licensees of these events.
The NRC has inspected each of these sites since the violations were identified
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and is continuing to review the licensees' corrective actions to assure that l
all of the issues are satisfactorily resolved.
Unless new significant information becomes available, this itec is considered closed for purposes of this report.
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References 1.
Letter from Robert D. Martin, Regional Administrator, NRC Region IV, to i
Glenn L. Koester, Vice President - Nuclear, Kansss Gas and Electric Company, forwarding a Notice of Violation and Proposed Imposition of Civil Penalty, Docket No. 50-482, July 7,1986.*
2.
Letter from Robert D. Martin, Regional Administrator, NRC Region IV, to R.
F. Walker, President, Public Service Company of Colorado, forwarding a Notice of Violation and Proposed Imposition of Civil Penalty, Docket No. 50-267, July 7, 1986.*
3.
Letter from Robert D. Martin, Regional Administrator, NRC Region IV, to John M. Griffin, Senior Yice President - Energy Supply, Arkansas Power and Light Company, forwarding a Notice of Violation, Docket Nos. 50-313 and 50-368, July 7,1986.*
4.
Letter from J. E. Gagliardo, Chief, Reactor Projects Branch, Division of Reactor Safety and Projects, NRC Region IV, to Glenn L. Koester, Vice President - Nuclear, Kansas Gas and Electric Company, forwarding Inspection Report No. 50-482/85-44, Docket No. 50-482, April 24, 1986.*
5.
Letter from J. E. Gagliardo, Chief, Reactor Projects Branch, Division of Reactor Safety and Projects, NRC Region IV, to R. F. Walker, President, Public Service Company of Colorado, forwarding Inspection Report i
No. 50-267/85-32, Docket No. 50-267, April 7, 1986.*
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6.
Letter from J. E. Gagliardo, Chief, Reactor Projects Branch, Division of Reactor Safety and Projects, NRC Region IV, to Gene Campbell, Senior g
Management Representative, Arkansas Power and Light Company, forwarding Inspection Report No. 50-313/85-26; 50-368/85-27, Docket Nos. 50-313 and 1
50-368, May 8, 1986.*
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Letter from J. E. Gagliardo, Chief, Reactor Projects Branch, Division of f
Reactor Safety and Projects, NRC Region IV, to Glenn L. Koester, Vice
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President - Nuclear, Kansas Gas and Electric Company, forwcrding Inspection Report No. 50-482/86-03, Docket No. 50-482, June 6, 1986.*
8.
Letter from Glenn L. Koester, Vice President - Nuclear, Kansas Gas and Electric Company, to J. M. Taylor, Director, NRC Office of Inspection and Enforcement, and R. D. Martin, Regional Administrator, NRC Region IV, Docket No.60-482, August 6, 1986.
9.
Letter from R. O. Williams, Jr., Vice President, Nuclear Operations, Public Service Company of Colorado to the Director, Office of Inspection and Enforcement, Docket No. 50-267, August 5,1986.
ss 10. Letter from J. Ted Enos, Manager, Nuclear Engineering and Licensing, Arkansas Power and Light Company, to Mr. J. E. Gagliardo, Chief, Reactor Projects Branch, Division of Reactor Safety and Projects, NRC Region IV, Docket No. 50-313 and 50-368, August 29, 1986.
11.
U.S. Nuclear Regulatory Commission, Inspection and Enforcement Information Notice No. 86-83, " Underground Pathways Into Protected Areas, Vital Areas, Material Access Areas, and Controlled Access Areas," September 19, 1986.*
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Thonsafeguards version available in NRC Public Document Room,1717 H Street, NW, Washington, DC 20555, for inspection and copying (for a fee).
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N Inadequate Access Control and Physical Barriers Date and Place - By letter of August 7, 1986 (Ref. 1), the NRC issued to Gulf l
States Utilities (GSU), licensee for the River Bend Station, a Notice of Violation and Proposed Imposition of Civil Penalties for identified deficiencies in the plant's safeauards program pertaining to access control and l
physical barriers.
Nature and Probable Consequences - The August 7, 1986, letter identified a I
Severity Level II violation with four examples of inadequate access control, and a Severity Level III violation with two examples of inadequate vital area a
physical barriers. The first violation identified four examples of a failure l
to adequately control the access of personnel to vital areas.
In the most
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serious example, the licensee incorrectly devitalized the plant auxiliary J
building access control system for over 17 hours1.967593e-4 days <br />0.00472 hours <br />2.810847e-5 weeks <br />6.4685e-6 months <br />. The other three examples
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included (1) improperly removing a hatch cover that allowed uncontrolled i
vital-island-to-vital-island access, (2) allowing a vital island door to be unsecured and uncompensated for about 30 minutes, and (3) improperly removing a large concrete floor plug which served as a vital-island-to-vital-island j
barrier.
In all four examples, conditions existed whereby an intruder could I
have obtained unauthorized and undetected access into vital areas from either the protected area or other vital areas.
It appeared from interviews with licensee personnel and a review of maintenance records that the floor plug had been removed for several months.
The second violation identified two examples of inadequate vital area physical l
barriers. Both examples described man-sized openings that had existed since the construction and start-up phase of the facility. This allowed unguarded openings to exist that would have permitted an intruder unauthorized and undetected access into vital areas.
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Details of these six items that constitute the two violations described above
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are contained in NRC Inspection Reports 50-458/86-11 and 50-458/86-17 (Refs. 2
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and 3).
Cause or Causes - The cause of these occurrences was the failure of management i
to exercise effective personnel access control and to recognize and correct i
plant design deficiencies as they related to implementation of the security l
program.
j Actions Taken to Prevent Recurrence i
Licensee - In each example identified, the licensee took innediate corrective a
action to post compensatory guards where required. At the locations where l
uncontrolled access was identified, the licensee secured the area and conducted j
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l a search to confirm that no unauthorized activity had occurred, or conditions existed that would prevent safe plant operation.
In the " devitalization incident," the licensee performance tested all equipment essential for safe shutdown that was not operating during that period. The licensee has revised j
procedures and trained personnel to be aware of the safeguards implications of 1
work performed by maintenance / operations personnel. Markings have been placed j
on all plugs, hatches, etc., that form part of the vital area barrier to alert personnel to notify Security before removal.
The licensee implemented an engineering review and walkdown to identify any barrier openings that existed.
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Acceptable barriers have been installed to prevent unauthorized access through these openings.
I NRC - An enforcement conference with GSU was held at the Region lY office on 1
June 10, 1986, to discuss these mattert and the corrective actions undertaken j
by the NRC are contained in a GSU letter (Ref. 4)y the licensee and evaluated by them. Specific corrective actions described b i
The NRC has inspected the site since the violations were identified and is continuing to review the licensee's corrective action to ensure that the issues are resolved satisfactorily. Unless new significant information becomes available, this item is considered closed for purposes of this report.
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References
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1.
Letter from Robert D. Martin, Regional Administrator, NRC Region IV, to l
William J. Cahill, Jr., Senior Vice President, Gulf States Utilities, Docket No. 50-458, August 7, 1986.*
j 2.
Letter from J. E. Gagliardo, Chief, Reactor Projects Branch, Division of Reactor Safety and Projects, NRC Region IV, to William J. Cahill, Jr.,
Senior Vice President, Gulf States Utilities, forwarding Inspection Report 50-458/86-11, Docket No. 50-485, June 4, 1986.*
3.
Letter from J. E. Gagliardo, Chief, Reactor Projects Branch, Division of Reactor Safety and Projects, NRC Region IV, to William J. Cahill, Jr.,
Senior Vice President, Gulf States Utilities, forwarding Inspection Report 40-458/86-17, Docket No. 50-458, June 4, 1986.*
4 Letter frem W. J. Cahill, Jr., Senior Vice President, Gulf States Utilities, to James M. Taylor, Director, Office of Inspection and Enforcement, Docket No. 50-458, September 5,1986.
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- Nonsafeguards version available in NRC Public Document Room,1717 H Street, NW, Washington,DC20555,forinspectionandcopying(forafee).
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