ML20237C209
| ML20237C209 | |
| Person / Time | |
|---|---|
| Site: | Wolf Creek  |
| Issue date: | 12/07/1987 |
| From: | Chandler L NRC OFFICE OF THE GENERAL COUNSEL (OGC) |
| To: | Murley T Office of Nuclear Reactor Regulation |
| Shared Package | |
| ML20237C190 | List: |
| References | |
| 2.206, NUDOCS 8712210135 | |
| Download: ML20237C209 (4) | |
Text
..
.1 g ue
/
UNITED STATES
[Y
},
NUCLEAR REGULATORY COMMISSION 5
g WASHINGTON, D. C. 20555
\\.... + j/
December 7,1987 MEMORANDUM FOR: 'Thomdf Ei kAu'rlEy,; Directort
,s.
4Of{ ice;of; Nuclear._ Reactor Regulations FROM:
Lawrence J. Chandler Assistant General Counsel for Enforcement Office of the General Counsel
SUBJECT:
2.206 PETITION INVOLVING THE WOLF CREEK GENERATING STATION in a petition dated November 12, 1987, the Nuclear Awareness Network (NAN) has requested, pursuant to 10 C.F.R. 2.206, that the NRC Institute an investigation to determine whether licensees are satisfactorily maintaining security (and control over activities at the site in general) at the Wolf Creek Generating Station (WCGS).
According to NAN, members of the public presently are being exposed to undue radiation when they trespass into WCGS restricted areas to fish in the WCGS cooling lake.
NAN further claims that the easy access to the cooling lake presents an emergency planning concern since unauthorized members of the public might be on site during a radiological emergency, and that this easy access also represents a security breakdown which could be exploited by terrorists.
/
We have enclosed for your use a draft letter of acknowledged and a Federal Register notice.
My office will assist you and your Staff in develoKng a 1
response to the petition.
Please place my office on concurrence for anu correspondence concerning these.petitio j
Lawrence J. Chandler i
Assistant General Counsel for Enforcement Office of the General Counsel
Enclosures:
1.
Draft acknowledgment letter 2.
Federal Register notice 3.
Copy of Petition cc:
W. Olmstead, OGC R. Martin, RIV J. Lieberman, OE CONTACT: Lee Dewey, OGC P'
~
2192-7036 kR F
l
<c-n.
T.,
i Stevi Stephens, Director Robert V.' Eye, Counsel Nuclear Awareness Network 13473 Massachusetts Lawrence, Kansas 66044.
RE:
2.206 PETITION REGARDING WOLF CREEVs GENERATING STATION
DearAf Petitioners:
l This is to acknowledge receipt of your petition dated Novembar 12, 1987 requesting,. pursu' ant;' to 10 l C. F. R.
5 2.206, that the. Nuclear Regulatory Commission institute an investigation -to determine whether security is being satisfactorily maintained at the~ Wolf Creek Generating Station (WCCS) to protect the public from - exposure to radiation and to prevent terrorist
. activities.
. As a ' basis. for your request, you assert that members of the
~
public are presently. trespassing into restricted WCCS areas to fish at the-
-WCGS cooling lake - and that there have been past examples of inadequate l
security at WCGS.
We are evaluating the issues raised in your petition and will respond to
' your request within a reasonable time.
Enclosed for your information is a copy of a notice which is being filed with the Federal Register..
i Thomas E. Murley, Director Office of Nuclear Reactor Regulation
Enclosure:
As stated cc:
Licensee t.
l
[7590-01]
l l
1 NUCLEAR REGULATORY COMMISSION
[ Docket Nos. 50-
]
KANSAS GAS AND ELECTRIC COMPANY, ET. AL.
RECEIPT OF PETITION FOR DIRECTOR'S DECISION UNDER 10 C.F.R. 5 2.206 Notice is hereby given that Ms. Stevi Stephens and Robert V. Eye on behalf of. Nuclear Awareness Network have requested that the Nuclear Regulatory Commission institute an investigation pursuant to 10 C.F.R. 6 2.206 to determine whether security is being satisfactorily maintained at the Wolf Creek Generating Station (WCGS) to protect the public from exposure to radiation and to prevent terrorist activities.
The alleged basis for this requested action is that members of the public are presently trespassing into restricted WCGS areas to fish at the WCGS cooling lake and that there have been past examples of inadequate security at WCGS.
This petition is being handled as a request for action pursuant to 10 C.F.R. 6 2.206 of the Commission's regulations and, accordingly, appropriate action will b^ taken on the request within a reasonable time.
Copies of the petition ar.
available for inspection in the Commission's Public Document Room,1717 H Street, N.W., Washington, D.C.
- 20555, bec.E Dated at Bethesda, Maryland this _ day of June,1987.
FOR THE NUCLEAR REGULATORY COMMISSION i
Thomas E. Murley, Director Office of Nuclear Reactor Regulation i
4 OFFICE OF THE SECRETARY CORRESPONDENCE CONTROL TICKET PAPER NUMBER:
CRC-87-1310 LOGGING DATE: Nov 16 87 ACTION OFFICE:
EDO AUTHOR:
S.
Stephens AFFILIATION:
LETTER DATE:
Nov 12 87 FILE CODE: ID&R-5 Wolf Creek
SUBJECT:
Inadequate security at the Wolf Creek Generating Station, Burlington Kansas ACTION:
Appropriate DISTRIBUTION:
Docket SPECIAL HANDLING: None NOTES:
Please advise SECY of action taken DATE DUE:
SIGNATURE:
DATE SIGNED:
AFFILIATION:
1 Rec'd Off. EDO Date -
Il 6 7 Time -
3:t (p i
l E DO --- 003299 i
-s.; =
November 12, 1987 nucear owareness networc 1347% massachusetts. lawrence, kansas 66044.(913)749-1640 US Nuclear Reguletory Commission Wasnington, D. C.
a@555 Re:
Inadeauate Security at tne Wolf Creek Generating
- Station, Burlington, Kansas
Dear Commissioners:
On October 4,
- 1987, the Kansas City Star puolished a front page story entitled " Nuclear Fishing?
Anclers want big ones at Wolf Creek."
A copy of the story is attached.
The Kansas City Star report indicates the Kansas Gas and Electric Company (KG&E) fails to maintain acequate security at Wolf Creek to protect the oublic from exposure to radiation.
According to tne stcry, access to the Wolf Creek cooling
- Iake, that contains radioactive effluents cischargec by the olant.
15 an easy matter.
The st ory st at es that, "rn a n y areas are oretected only by weeds or a short marced-wire fence."
It further notes tnat even though it is posted, "all it taWes to get to the lake is determination and perhaos a pair of ooot s. "
Adcationally, it appears trerncers of the puolic routinely e est fish caucht in the radioactive waters.
The story cuotes k r.
Eco
- Rainbolt, wno operates a local cait shop and presumably talgs frequently with local anglers, as saying:
Horest Decole are tne only ones arouound here wno haven' t gotten fash out of that 1ake.
The f i sherrcen eneak in tnere at n i c1h t.
With a full moon, you don' t even reed a l esnt ern... Ever yone I' ve talWec to say t nt=re' s somet h i r,g wrong if you can' t yet some nice catches cut there.
-NAN Would also point out that, accorcing to the s !; O r y, the Coffey County Attorney has never been cresented witn a case of c r ?.ra l n a l trespass on the lakes 7 ore. If trespassing lu a *4 easy and frecuEmt as the story indicates.
"GdE nettne" maintains r e q :.. i r e d oecur1ty nor takes legal actlon against trescasnors to ceter f '.t t u r s t r t's ca ss i n g.
Reccrts of lax security coupled with lacw of prosecution are open Inuitatlons for ccntanved tiaegai trespassing at the ruCADa" faC111ty.
/
- 7m90 sow 17lf
o, AltncuGn the n C W !'
BrorV J O tert L taat 1Gning in
'acio3CC1/e Waters may be " Oer'f ect l y G iA f e, ' we rote tnat
.3 2 P a c 1' v ".ic 1 d e n are routirelt c1GCnargeC lnto the rJ 31 f Cre@R 1ANS.
SeVeral have radioactive half-11ves Hxce20 nr; ten yers, and ooth fritium A ric C o ca l t -58 naVG Oeen CCCeetec i ri ene a re's vegetat1on anc on t ie lakeshore.
As etatec In tne Wo1f Creer Final Env1ronmental Statement, eating fish from the coollrg l e L< e is a ostnway "through which persors "ay ce exposed to radiation originating in a
ruelear power react or.
SUCh eXDoSure r41999 S tir l o us Quest 1Cn3 regar^ din 9 camage to tne ouclic -ealtn at Wolf Creek, and we woula remind you of tne N9C statew nt that:
Excosure to even low leve1s of raclatlon...Is generalAy cellevec to increase the 11xa11hooc of certain cite.?nes anc to increase certain genetic effects. 51rea tnene i
effects may ce evidencec many years a f't er tne exposure, l
tney are classed as long-term realth effeets.
tnese l
Incluce latent cancer fatalities, genetic defects anc l
tnyroic illnesses.--Reactor Safety Stu=y, NUREG 75/314 i
l NAN believes that the situation at Wolf Creek, as reomrted bv the j
r4.ansas Ci t y Star.
warrants N9C set t on.
Tnerefore, we nave filer l
a c.:. 2 4 6 Petitton recuestIng a
ful1
.Investigatlen, W1t*
appronrlate enforcement, finec anc corrective actien, if reecec.
l Considering the Herlouru cef'iciencies colnted out by the nOWSCaOer, WE POC u SG t.
Inat N RC o T f 1 C l a l *> H X p e d i t e act106 Un the Cetition.
Failure t o e >< c l u c e cei. ca l e from restricteo are zc enere ekDeGure !3 rac13 tion Can occur "naGeG Very '5Criou3 JD11C hea t9 CuG3tionG.
ACcit10n311V.
P G dt ) 3 failure t o,Ma l r.131 n
'leCur t y GCelously 1MOeGes its dO 111T y to 9V?CUate areAG U"C : " O ' i" O D I 3 t in a r a c l o l O g i r. e 3 ty'r E-e p e nc V.
A Croy of U r. e D La t i t I c h *i % attJcheC.
SiPCerelV, f
, hvi
- i Law stev1 somncne. a re=t-
.: /
DEFORE THE UNITED STATES NUCLEAR REGULATORY ComM]SSION PETITlON PUR5UANT TO 10 CFR PART
- 2. E106 l
l l
1.
Tne Petitioner, Nuclear Awareness twetoWrk (NAN),
is a not-for-profit organization basea in
- Lawrence, Kansas.
NAN in Concerned witn.
Inter alia, tne safe and lawful operat2on of the I
Wolf Creek Generating Station (WCG5).
2.
WCGS is operated oy the Wolf Creek Nuclear Operating Corporation, a
licensee of the Nuclear Regulatory Commission (NRC).
3.
On October 4,
1987 the Kansas City 5 tar published a story on page one entitleo " Nuclear Fishing?" and subtitleo "Anniers Walit Tne Big Ones At Wolf Creek."
A Copy of this story is attached hereto, made a part hereof and i s marked as Exhabit 1.
l l
4 Tne story referenced in paragraon 3
inalCaten tnat l
Incivicuals are penetrating the WCGS site bouncary a n;i fishing in the WCGS Cooling lake.
An indivicual indentified in tne story as Bob Rainbolt is quoted as fol1ows "The finhermen sneaR in there I
at nignt. With a full ro oc n, you don' t need a lantern...Everyone l've talked to says t here' nomet h i ng wrc ng if you Can' t cet some nice Catches out there."
5.
The st ory ret'erenced in paragraph 3 also states that signs are posted stating that the area is oravate property and that no trescansing is allowed.
However,, the story further states that "all it takes to get to the lake is c et erra 10a t i on and O tv rh e ps a
pair of boots.
Many areas are protected only Oy wenCs or a snort barbeO~ Wire tenCU."
6.
Pursuant to NRC reculationc set fortn at 10 CFR Dart 73.40(a) tne 11Cencee is recurrea to estaotish and usintain a
sVSteM designed to
" provide DnyBiCal protection 419 a i n st radiolop1 Cal GaDot BGe "
at sites where 1 Censed activitaen are 4
Conducted.
'7.
Pursuant to NRC reculation set fortn at 19 CF" part 73.6D(C) licensees are reCuireC to " to] erre l t only eutnericea OCt1Vitles and Cond3tions witn1h Drotected areas.
Ihlb FGDu}atlon alsC reCulres 31Censees to ett abllSh i.1 )
LC]ontroin and procedureG that estaD11th Current GCneCuler of author 12rd a C t 1 V i t l etl and Conc 1 t l on's in C G f 1 neti areEL' f ' ( 1 i) (b] Ounder l e% to define arean within wh1Ch the a u t rior 12 Pd a c t.1 v j t l e t and Conc 1 t 1 ons nre perm 1tted:
and '(111)LD3etUCt1on and ' O r v e 1 i i B Yic e s u b fa y C t er3s and procedures To 01sCover arG EsceSG U r.J. u t " o r~ 1 :" C C B C t i V 1 t 1 E? G and Conc 1t1onC and Cor1Mun t Ca t O t "i c'l so Ihat r o u D on E L-Can be suCn as t o 9,t C '7 tne actIVltv or CCerect the cond 1 t I Cme >
ts Gat 1GTy the Q fe n e r a l p u r,< - m a.c.c - oa_,uctive or par t z2. a ca..
~
i.
, n f.s.
Pursuant to NRC r eg ul at ions set forth at 10 CFR Part 73.45(f) licensees are recuired to restrict access to protected areas and to have in place a system designed and rn a l n t a i ntid for tne purpose of detectino and respond 1r.g to any unauthortred penetration of the protected area.
Pursuant to NRC regulations set forth at 10 CFR Part 73.2(q) s
" protected area" as defined to meer "an area encompasses ey anysical carriers and to which access is controlled."
10.
Pursuant to NRC regulations set forth at 10 CFR Part
- 73. 2 ( f) (i) " physical barrler" rnean s "(.F2ences constructed of No.
11 American wire gauge, or heavier wire fabrJc, cooped by three st" ands or more of barbed wire or similar raa t er i a l on brackets angled outward cetween 30 cegrees and 45 degrees from the
- vertical, witn an overall height of not less than eicht
- teet, includino the barced tocolng."
11.
pursuant to NRC regulations pet forth at 10 CFR Part 50.47 and Appendix E,
the licensee is requirec to establish and maintain adequate emergency plans and conduct periodic exercises to test and evaluate the efficacy of any emergency plan in the event of a radiological emergency.
12.
Pursuant to NRC regulations set forth at 10 CFR Part 100.3(a)
" exclusion area" in defined in pertinent part as follows:
" Exclusion area means that area surrounding the
- reactor, in whicn tne reactor licensee nas the authority to determine all activities including exclusion or removal of personnel and procerty from tne area."
13.
Pursuant to NRC regulations set forth at 10 CFR Part 20,3(a) (14)
" restricted area" is def1ned in pe-tinent part as follows:
"any arca access to whicn is controlled by the licensee for purposes of prot ect i on of individuals from exacsure to radiation and radioactive materials."
14.
According to WCGS Technical Specif2 cations set fort; at uectlon S.1,1 and i11ustrated by t3 cure S.1-1 the
' e x c 1 u s i on-restricted area is a 1200 meter radius circle centered arounc Unit I containment."
15.
The WCGS Tecnnical Baccifications as set fortn at Section 5.1. 3 provice in certinent part tnat
'LT]he UNRESTRICTED AREA coundary may coincice with the Exclusion (fenrec) Area a p u n a a r y.,
as definea in 10 CFR 100.3(a),
out the iJNREST R I C TED AREA coen not incluce areas over water boc a tet.
C
C, l
J 3 7. '. I.t.
16.
Petitioners ~recuests that the Commission a'nd staff t'a ke administrative notice cf other security problems at WCGS includ-Ing but not limited t o' the Report to Congress on Abnormal Occurrences,
-July-September 1986, pp.9-10, NUREG' 0090.
This report indicates t h'at the subject breakdown. in security at
.WCGS was a' serious failure to comply with'NRC regulations. pert aini ng-serious failure t er comply with NRC regulations; foertaining to physical barriers.
A copy of the pertinent part of this report' is attached hereto, made a part hereof.and is marked Exhibit'2.
17.
Petitioner requests that the' Commission and staff 'take administrative notice of the findings in the NRC report entitled
" Trends and-Patterns Analysis of the Operational Experience of Newly -Licensed United. States Nuclear Power Reactors",
- August, 1986, AEOD/P604.
At page 13 of this report it is noted that WCGS experienced an above average number'of security-events beginning six.to ten months:after issuance of full power license.
A copy of the pertinent part of thin report is attached-hereton, made a part hereot-ad is marked' Exhibit 3.
18.
Petitioner requests that the Commission and staff take administrative notice of the NRC Information Notice Number 87-27 dated June 10, 1987 entitled " Iranian Official Implies Vague Threat to:U.S.
Resources" that alerts licensees of nuclear power reactorssto potential attacks from terrorits.
19.
The pattern of 10 CFR Part 73 security. breakdowns at WCGS.
coupled. witn the'recent above-mentionec.Information Notice and the apparent easy access to the cooling lake creates a si t uat ion which-may be exploited by terrorists.
The penetration of tne WCGS. site boundary represents e serious breakdown of perimeter security at :the facility.
Petitioner requests that' the NRC investigate this matter and determine whether the provisions of 10 CFR~Part 73 are adequately est ablished and implemented by the licensee.
20.
The penetration of the WCGS site boundary an above-cescriced may indicate the inability of the licensea to control activities within the rest ri ct ed or exclusion area as defined at 10 CFR fart 20.3(14) and/or 10 CFR Part 100.3(a) and as described in WCGS Technical Specifications at section 5.1.1, Figure 5.1-1 and section 5.1.3.
Petioner requests that the NRC investigate,
this issue and determine whether the licensee is able to maintain /
the integrity of its restricted and/or exclusionary zones.
21.
The penetration of the WCGS site bouncary and the presence of individuals on the snoraline or in the WCGS cooling lake may represent a condition that requires changes in tne licensee's 10 CFR Part 50.47 and Appendix E
emergency p1ans.
Petiticner
'reauests tnat the NRC investigate this issue and determine s
whether the licensee's emergency a n rj evacuation olans include j adequate provisions for notif'1 cation and evacuation of all '
Individuals present insice the site boundary includano those along the shoreline or on the surface of the WCGS coolino lake.
3
~
),,
EE.
' WHEREFORE, Petitioner respectfully requests pursuant to 10 CFR.Part 2.206 that-an investigation by the NRC be corr.menced to determine wnether the licensee authorized'to' operate the WCGS is in compliance with the regulations set forth at 10 CFR Part 73, 10 CFR Part 20.3(14),
10 CFR Part 100.3(a) and Technical Specification 5.1.1 and 5.1. 3, and 10 CFR Part 50.47 and Aprendix E, and/or other regulations aoplicable to unauthorized penetration of the WCGS site perimeter.
23.
WHEREFORE, if upon invesitqation and analysis the NRC
' determines that the licensee is in violation of any or all of the above-cited regulations and/or Technical Specifications anc/or other applicaule regulat ions or Technical Specifications that
+;,
appropriate-enforcement and corrective actions be commenced in order to assure.that the licensee is operating.the facility in a
safe and lawful manner.
Respectfully submitted,
/
Robert V.
Eye Counsel for NAN 1347 1/2 Massachusetts Lawrence, Kansas 66044 I
i k
j I
r.
CERTIFICATE OF MAILING certify that a true and correct copy of the above anc requested on tnea I
hereby U. S. mail return receipt was sent by j Vth day of Nov era brar, 1987 to the following:
foregoing i
Director, Nuclear Reactor Regulation Reguletory Corcmission U. S.
Nuclear Washington.
D. C.
20555 and SafeguarOG Nuclear Materials
- Director, Regulatory Commission U. S.
Nuclear D. C.
20S55 Washington, for Ooerations Director Regulat ory Comrai ns i >n U. S.
Nuclear Washingt on, D. C.
20555
)
I Robert V.
U. y 0 Counsel +~ c e NON 1347 1/2 Fassacnute t t n 6tiO4 4 Lawrence. Kansam 5
. Yhe KanNas City Star, Sunday, October 4,1987 Nuclear fishing?
i
_a e Topew Kansas Anglers want big ones at Wolf Creek.
u-ence E ByRick Montgomery
$)
n f
iM stan ww utility that opened a public fishing park on one of its nuclear cooling ponds last urlington, Kan.-Oh, to fish on E
9 I'(y can move around in water that the lakeshore at the Wolf Creek N'*
Anglers o ea te a'asas dream
\\
best suits them," Monzingo said. "In the Nhw Burlington of this. Word has it that deep in the winter, some may prefer the warmth of nuclear power plant's cooling lake the water discharged from the plant. In the summer, they may go to the other are the really big ones. Millions of them.. Batches of basa, caches of end, near the intake screens.
catfish, wall-to-wall walleye.
The result can make a sportsman's j
Stories are told of fishermen on stomach growl.
midnight missions, how they sneak
' Monsters of the deep onto plant property, find a cozy spot x
< in the sunficwers and cast out into the A 21-pound striped bass recently was sky-blue waters of the nuclear age, pulled from the Wolf Creek lake by the Wolf Creek Atomic fishing,if you will.
plant's environmental research team, Nuclear Plant But you can't.
said Ronn Smith, nuclear information
.L
_r f
As the Wolf Creek Nuclear Operat-supervisoratWolf Creek.
[n]
ssefore that, members of the Kansas e
ing Corp. sees it, the 5,000-acre, man..
chapter of the American Fisheries Soci-N made reservoir and the fish in it -
belong to the plant. State conserva.
ety were invited to tour the plant and Ia tion officials would like to make a check out the methods used to catch and i
'. J -
deal with the utility to open the lake study fish. Their jaws dropped when E
9
- e g 95 miles southwest of Kansas City to they saw a net pulled from the lake, WOLFV
/
public fishing. Utility officials say packed and squirming-CREEK I w
f they aren't opposed to the idea, but "Those of us familiar with what's LAKE
^
'd they're concerned about plant securi-down there were not surprised at nil,"
(
i
J ty and evacuation plans.
Theurer said.
,g "a
f Scientists at the plant are studying The utility stocked more than 6 mil-g f
the options. Little progress toward an.;
lion fish in the late 1970s and early 1980s y
p 7
agreement has been made in the last to control the growth of smaller nui-g Burlington ;
i sance fish. In 1986 alone, researchers at
{w
,Y three years In that tNne, big fish stocked by the.
Wolf Creek pulled out almost 3,000
, 4
'T*#
I pounds of fish samples. Often the scien-utility have only gotten bigger, feast.'
ing on little fish that otherwise would, tists rely on an electric charge to stun y
9 3
stannao the fish, causing them to float to the r
multiply and gum up the works of the-
's bar e p edator-prey rela.
A co ple of whoppers have even been there's something wrong if you can't get tionship," said Mih Theurer, fisher--
mounted in the offices of the plant's some nice catches out there. I say you les division chief for the Kansai environmental staff.
open 'er up."
State conservation officials fear the The plant has security guards on a 24-Department of Wildlife and Parks.
{
lake is becoming overpopulated with hour basis, but keeping a close eye on a s
! "The top predator isn't allowed outI each passing day.
lake that spreads for miles has proved I there, and that's man "The fishing? Oh yeah, it'd be' "You're eventually going to have di-difficult. Coffey County Attorney Steve cream'"
minishing numbers and increasing Boyce said he has never been presented
+
weight," Theurer said. "They're going to a case of criminal trespassing on the The eating? Perfectly s a f e,',
eat themselves out of house and home."
lakeshore, which could result in a one-researchers say.
Just as the coolantin a car radiatof But Wolf Creek officials aren't yet year sentence.
doesn't flush through the pistons, wa-ready to turn their lake into a fishing Wolf Creek spokesman Smith said a hole.
plant committee is studying the public ter from the reservoir never comesin contact with radioactive equipment.
Signs saying " Private Property-No fishing option "more seriously now than It's simply used to cool the steam that Trespassing" are posted around the in the past....But questions are still area, but all it takes to get to the lake is out there."
j drives a turbine that turns an electric determination and perhaps a pair of What if a nuclear emergency oc-generator Then the water is returned to the. l boots. Many areas are protected only by curred, for example? Could the plant weeds or a short barbed-wire fence, alert a lake full of anglers in 15 l
lake, about 35 degrees warmer than 1)
Bob Rainbolt, owner of Rainbolt & Son minutes-f ast enough to satisfy the Nu-l was when pumped into the plant.
u The fish seem to like this range g Bait Shop in Burlington, said: " Honest clear Regulatory Commission?
people are the only ones around here And what about the gizzard shad?
temperatures.
who haven't gotten fish out of that lake.
That's a nuisance fish, capable of Theres nothing special about the "The fishermen sneak in there at bunching up in large numbers and clog-water that makes fish thrive, but there is !
night. With a full moon, you don't need a ging the intake screens through which
, lantern....Everyone I've talked to say 530,000 gallons of cooling water are h o go,se r i ogist r Co monwealth Edison Co., an Illinois-based Exhibit 1
pumped every minude.
\\
? " / jf 'h@W,'. ",3k.. S ' %"'gh,;V -.
?
c
,4
., b
. Nhg,,.,
"They can literally sh the plant c.'
1 P
$ Q
(.
u
/
c down," Smith said.
y that context, utility officials say, a 'g g - #['@' '
b,4 The lai ger fish eat the giznrd shad. In iA'
~
i-p
- pn
- p
- i DA largemouth bass or a black bullhead can n'
be regarded as maintenance equipment. I (p ' M['g' ' gN I* d A
~
~
i 3
iT.
k
., 3 "They do a good job for us," Smith said.
"They're not even on the payroll."
H l
P Which leads utility officials to pose
-i this argument: We wouldn't consider JN F'
T
, letting everybody fool around with, say,
%c,.' ?f b I
+
. s.
J c-
~ &.
h
'?
f' our reactor cavity seal rings. Why must we give them access to our fish?
V h.g
?
,{_
Sirons on the water
- 4 l.
- y~
, J f' (l have been pulled from public ponds at P
4 But some of the biggest fish in Illinois 1~'
.a y
'~
'a'
%" s.
Wr r
{ Commonwealth Edison's power plants,
(
f including one nuclear f acility.
a' "Let's face it. It's good P.R.," said 7
j Commonwealth Edison spokesman Deb-a m
ble Vestal. "The community helped us d
3 build these plants, so why not give back something?"
td s
'x-At the company's LaSalle Nuclear Generating Station southwest of Chica-5,'
i /
4 I
1
- 15 go, a 2,000-acre cooling take was opened last year as part of a public park. The W-utility installed sirens around the lake to M
e dE1%@W, -
comply with NRC warning regulations M % @Q U '
f and has leased it to the state at $1 per i WP'$dkr,
+
year.
"Before that, we were finding holes
. s Cu
- c.-
s
, cut into our fences by fisherman sneak-
- nim '. w w -
4 l ing in," Monzingo said. "The existence of fish in the lake was creating a security
'E@m problem. We had no way of knowing 9?l' M " A
'C
'/'
"r g
^"#
v' hen people were on our property. Now, Q
the fishermen sign in and are kept in 3
x.
'q
. ig check."
.J e
The Kansas City Power & Light Co.
f M
?
and Kansas Gas and Electric Co., princi-pal owners of the Wolf Creek plant, b
Y'
~
4 5
allow fishing at all their coal-fired I'
j plants where cooling lakes are large j.:.
'.L
~
1 enough.
A i
That includes their conventional plant g ' ^ " ' ',
.4 near La Cygne, where the Kansas De-i partment of Wildlife and Parks and Linn
.i 46,#
M County operate a park. One fisherman J'
~
ye has boasted to a reporter that the fish p
there "are probably the fightingest fish s3
'. 'h
/
I've ever caught."
But then, that's not atomic fishing.
2#
y
/
4 ~
M ** M. h T D",
Y' 4
The word " atomic" changes the game, W,%
1 KCP&L officials said last week. NRC rules apply: Wolf Creek must submit a Dan Haines, an environmental biologist, weighs a bass from the cooling lake at, _
plan that would allow everybody inside the Wolf Creek nuclear power plant. Many of more than 6 million fish stockedin a 10-mile radlus to be notified of a the lake in the la te 1970s and early 1980s ha ve grown large under good nushap within is minutes, fishermen conditions, but fishing is prohibited. A committee is studying the possibility of included.
"A lot of people working here want to public fishing. (special to the Star) fish, too," said Wolf Creek spokesman Smith, and rumors are afloat that the said. "That just wouldn't look good.
aquatic critters will battle it out among utility may combat the growing fish Wolf Creek operates m a public forum."
themselves, waging a Hungriest and-population by opening the lake to em-In the meantime, area fishermen-Meanest-Fish Wins contest.
ployees only. He doubts that will happen.
ratepayers with tackle and appetites-Oh, to catch the winner.
"A fishing lake for executives?" he wait for a decision. And Wolf Creek's
,'j
1 V;fyn'
- 4 -
'WO/.#,fj /20.5 NUREG-0090 Vol. 9, No. 3 i
I l
Report to Congress on Abnormal Occurrences July-September 1986
)
)
U.S. Nuclear Regulatory Commission Office for Analysis and Evaluation of Operational Data l aw !.itw:;y p" *
- coq
\\1CShburn ilniwsity of ynge,;g
)i MAY 121337
%;>c,.,4 d p
DEPOSITony l
)
)
Exhibit 2 l
.I,
(,.J.
maintenance performed on it in January 1986.
It is not certain if the
)
poor connection was the result of thic previous maintenance activity.
I J
1.
Difficulty was encountered during the event in resetting the main steam isolation bypass valves.
The problem could not be recreated during inves-tigation.
The associated Monthly Surveillance Test was perforced successfully.
Following the above, the plant was restarted.
After reaching 20% power on July 11, 1986, the licensee satisfactorily reperformed the Loss of Control Room Functional Test.
Subsequently, the plant reached 100% power and on August 19, 1986, the licensee declared the plant to be in commercial operation.
NRC - The NRC monitored the licensee's corrective actions to assure that they were responsive and satisfactory before permitting the plant to restart.
On November 12, 1986, the NRC forwarded to the licensee a Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $50,000 (Ref. 7).
The first violation pertained to a significant failure in the licensee's design i
control program.
The second violation pertained to the licensee's failure to establish adequate procedures for the Loss of Control Room Test.
The NRC AIT's report was issued on July 25, 1986 (Ref. 8).
This incident is considered closed for the purposes of this report.
- x******
86-17 Significant Safeguards Deficiencies at Wolf Creek and Fort St. Vrain The following information pertaining to this event is also being reported con-
)
currently in the Federal Register.
Appendix A (see Example 8 of "For All Licensees") of this report notes that any substantial breakdown of physical security, such as access control, that significantly weakened the protection against thef t, diversion, or sabotage, can be considered an abnormal occurrence.
Date and Place - On July 7, 1986, NRC Region IV issued enforcement letters containing Severity Level II violations to the licensees of two nuclear power plart stations for serious deficiencies in plant physical barriers.
The li-censees are:
(1) Kansas Gas and Electric Company (KG&E), operator of the Wolf Creek Generating Station, a Westinghouse-designed pressurized water reactor located in Coffey County, Kansas; and (2) Public Service Company of Colorado (PSC), operator of Fort St. Vrain, a General Atomic Corporation-designed high-temperature, gas-cooled reactor located in Weld County, Cclorado.
Nature and Probable Consequence - 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 instances into Vital Areas (VAs).
This condition was identitied by the licensee
)
as part of a quality assurance surveillance followup and confirmed by a Region IV safeguards specialist during reactive inspection No. 50-48P/85-44 (Ref. 9).
At the Fort St. Vrain Nuclear Station, NRC inspectors identifled 9
- b AE00/P604 Trends and Patterns Analysis of the Operational Experience-of Newly Licensed United. States Nuclear Power Reactors August 1986 fn.
t Program Technology Branch Office for Analysis and Evaluation of Operational Data Principal Investigator:
Thomas R. Wolf l
NOTE:
This report documents the results of a study by the Of fice for Analysis and Evaluation of Operational Data.
The findings and recommendations do not necessarily represent the position or requirements of either the responsible progre.m office or the Nuclear Regulatory Commission.
^
,. M --
-g g
1 EXHIBIT 3 Q'
l
[
.~
s
- a. 3 -
,1 r t 3
y-during routine inspection No. 50-267/85-32 (Ref. 10) two uncontrolled access s
g paths from the OCA to the PA and VA.
In this situation, each access had a g,
F barrier installed, but each was evaluated to be insdeg nte and not capable of f
g preventing an intruder from defeating it easily.
\\ f p
In these examples, conditions existed whereby an intruder could have oMahed 10l unauthorized and undetected access into protected and/or yital' areas fro.4 the
//
ii OCA.
It appeared from the inspections and review of licccsee records that the l
conditions had existed at both plants for.a minimum of six tc seven months.
I
}
Cause or Causes - The cause of these occurrences was a failure in management l
control, including design oversight during the system planning stages, con- ) /'
struction deficiencies, and the failure of the startup testing / surveil 7ance prcgram to identify these deficiencies.
Another related cause at the, Wolf D'
Creek Generating Station was the failure of management to provide coordination among the various organizational entities which may affect facility sa:urity. *
[
I Actions Taken to Prevent Recurrence
/
i Licensees - In each case identified, the licensee icok immediate corrective action to post compensatory guards and install appropriate barriers.
At Fort St. Vrain Nuclear Station, the affected piping was secured with adequate bar-riers and a routine surveillance was initiated to ensure that no degraution to these and similar barriers had occurred.
The Wolf Creek Generating Station installed acceptable barriers where required n d initir.ted a complete walkdown of the PA and VA to identify all possible points cf vcintrability.
This work
)
is being conducted by a KG&E Security Passive h rrier Task Force that was
[j formed to review all penetrations in passive barriers to assure that no further problems exist.
I
)
'i otdure; do ensure I
Both licensees have modified engineering / design change p'W any overall plant j
that security syctem requirements are considered ar-part
(
)
changes that could impact the safeguards program / systems; NRC - On the date that the Wolf Creek Generating Station identified this condi-tion, NRC Region IV initiated calls to all the Region IV licensees and'to the other NRC Regional Offices to alert them to the possible generic %plications of this finding.
On July 7,1986, Region IV issued enforcement letters to the licen: lees involved as follows:
a.
A Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $40,000 to KG&T (Re f. 11).
The vinlation was categorized as Severity Level II (on a scale where Severity Levels I and V are considered tne most significant and least significant severity levels).
b.
A Notice of Violation and Proposed Imposition of Civil Penalties in The I amount of $65,000 to PSC (Ref. 12).
The Civil Penalty consisted of "AO,000 '
for the Severity Level II violation and $25,000 for other lett significant violations.
h Enforcement conferences were held at the Region IV office on November'Oi,1985,
'I with KG&E and January 6, 1986, with PSC to discuss these issues and the s h
l 10 t
_