ML20249B563
| ML20249B563 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 06/18/1998 |
| From: | Oheim H BOSTON EDISON CO. |
| To: | Lieberman J NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| 50-293-98-03, 50-293-98-3, BECO-2.98.083, NUDOCS 9806230306 | |
| Download: ML20249B563 (5) | |
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10CFR2.201 Boston Edlimon Pilgrim tJuclear Power Station Rocky Hill Road Plymouth, Massachusetts 02360 Henry V. Oheim General Manager Technical Section June 18,1998
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BECo Ltr. #2.98.083
- Mr. James Lieberman,
- Director, Office of Enforcement U.S. Nuclear Regulatory Commission
- Attn: Document Control Desk.
Washington', DC 20555 Docket No. 50-293 License No. DPR-35 Reolv To Notice Of Violation (Securitv)
Dear Mr.' Lieberman,
This !etter provides Boston Edison Company's reply to the Notice of Violation and imposition of civil ' penalty contained in the NRC letter from H. J. Miller to L. J. Olivier, dated May 19,1998
' (NRC Inspection Report No. 98-03).. An electronic transfer in the amount of $55,000 has been made for full payment of the civil penalty.
' The causes and corrective actions taken to address specific violations were discussed with the
- NRC staff at the enforcement conference on April 27,1997, and are summarized in Enclosure A,
" Reply to the Notice of Violation".
In addition to the corrective actions discussed in the enclosure, this letter reiterates the following open commitments from the enforcement conference:
A QA surveillance will be performed on assessment aids every six months. This will provide an independent review of the assessment aids. The first surveillance will be performed by October 31,1998. These focused surveillance will continue on a six month frequency until b
determined by: management to be no longer necessary.
_At' that time, evaluation. of assessment aids will revert to normal practice as part of the regularly scheduled QA audits of
. Security.
The security maintenance program will be reviewed and upgraded as appropriate by August 7
31,1998.
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R:sponse to Notice of Viol tion Please do not hesitate to contact me if there are any questions regarding the enclosed reply.
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H.V. Oheim Commonwealth of Massachusetts
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County of Plymouth
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Then personally appeared before me, H.V. Oheim, who being duly sworn, did state that he is Senior Vice President - Nuclear of Boston Edison Company and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and i
belief.
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' Attachments:
Enclosure A: Reply to the Notice of Violation
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U.S. Nuclear Regulatory Commission Af Document Control Desk Washington, D.C. 20555 Director, Special Projects Office, NRR Mail Stop: 14D1 U.S. Nuclear Regulatory Commission -
1 White Flint North 11555 Rockville Pike Rockville, MD 20852 i
Mr. Hubert J. Miller, Region l Administrator U.S. Nuclear Regulatory Commission j
475 Allendale Road King of Prussia, PA 19405 Mr. Alan B. Wang, P;1 grim Project Manager Project Dire:torate 1-3 Office of Nuclear Reactor Regulation l
Mail Stop:. OWFN 1482 U.S. Nuclear Regulatory Commission 1 White Flint North 11555 Rockville Pike Rockville, MD 20852 Senior Resident inspector.
Pilgrim Nuclear Power Station i
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Boston Edison Company -
Docket No. 50-293 Pilgri,m Station.
_ License No. DPR-35 ENCLOSURE A REPLY TO THE NOTICE OF VIOLATION Violation The violation involves multiple examples of equipment failures associated with the protected area. assessment system-.used' by the security personnel to continuously
! monitor and assess the security status at Pilgrim Station.
Admission or Denial of Violation Boston Edison Company concurs that regulatory requirements were not followed as
- stated in the Notice of Violation.
. Reason for ' he Violation t
-The reason for the violation was the failure of management to provide clearly defined expectations for the' quality of assessment aids used by the Central Alarm Station and l..
Secondary Alarm Station Operators (hereinafter referred to as security operators) as documented in problem report 98.0489.
Contributing causes were inadequate management' oversight regarding prioritization of i
assessment aid replacement and quality of assessment aid performance. Also, security I
operators-had the perception that on-going maintenance was correcting security equipment problems and, over time, became less sensitive to the degradation of the assessment aids as the aids became maintenance intensive.
Another contributing cause was that security maintenance issues were documented on work lists, and work was performed under a general maintenance request for security.
l The.use of the work list system did not allow for trending of security maintenance issues L
and notification to management of problems with the security equipment.
l Corrective Steos That Have Been Taken and Results Achievej 1:
E When the violations were identified by the NRC Inspector on March 4,1998, immediate compensatory measures were established for the degraded assessment aids. Additional maintenance staff was assigned to security to assist with the repair of the assessment aids. The compensatory measures were individually removed as the equipment in question was restored to newly-defined standards of quality. All compensatory measures were removed by March 11,1998.
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Boston Edison Company Docket No. 50-293
, Pilgri,m Station License No. DPR-35 As the cameras were returned to service the deficiencies in the video capture system were corrected, and the quality and effectiveness of the system was restored.
All deficiencies noted in the original inspection were corrected prior to the NRC Inspector's return on March 11,1998.
The following actions were completed by March 11,1998, to address the root cause of not providing clearly defined expectations for the quality of assessment aids:
Management expectations were reinforced with security personnel through briefings with the Senior Vice President and the Nuclear Services Group Manager.
On-the-job training was provided to the security operators that clearly delineated the expectations for the quality of the assessment aids.
A photo comparison guide was created to establish clear standards. Copies are located in both CAS and SAS.
A CCTV Surveillance System Checklist was established.
This checklist is completed by the security operators and reviewed by supervisors daily. Security supervisors independently complete the checklist on a weekly basis and prepare an assessment report for security management. It is also utilized for prioritizing the following weeks maintenance.
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Additionally, a new training module was created and incorporated into routine training to address expectations for the quality of assessment aids.
To address the management oversight contributing cause, a monthly security assessment report is now prepared and reviewed with the Station Director and the Senior Vice President - Nuclear. This will remain in effect until it has been determined the corrective i
actions have been effective.
Appropriate disciplinary action that dealt with the identified human performance issues was taken prior to March 11,1998.
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Boston Edison Company Docket No. 50-293 Pilgrim Station License No. DPR-35 The following actions were taken to ensure appropriate attention is given to resolution of security maintenance issues in a timely manner.
The station-wide _ Problem Report system is now used to identify security equipment maintenance issues at an appropriate threshold (completed by April 27, 1998). Use of the PR system will allow trending of security issues.
Security maintenance schedu'ing has been enhanced to include the age of open security maintenance items as a factor in prioritization.
At the inspection exit meeting, a commitment was made to return the PTZ cameras used for perimeter and on-site surveillance to service by June 1,1998. This work was completed on May 27,1998.
Also identified during the inspection was the alarm call-up monitor sequence. Although the call-ups met the requirements of the Security Plan, we agreed enhancements were in order. By March 11,1998, the system was reconfigure to provide the ability for manual call-ups, and by April 27,19ES, additional automatic call-ups were provided.
Finally, the effectiveness of our corrective actions was demonstrated during a successful Operational Safeguards Response Evaluation (OSRE) that concluded June 4,1998.
Corrective Steos That Will be Taken to Avoid Further Violations A QA surveillance will be performed on assessment aids every six months. This will provide an independent review of the assessment aids. The first surveillance will be performed by October 31, 1998. These focused surveillance will continue on a six month frequency until determined by management to be no longer necessary. At that time, evaluation of assessment aids will revert to normal practice as part of the regularly scheduled QA audits of Security. [RC98.4001.08]
The security maintenance program will be reviewed and upgraded as appropriate by August 31,1998. [RC98.4001.07]
- Date of Full Como!iance Full compliance was achieved by March 11,1998. The PTZ cameras were returned to service on May 27,1998.
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