IR 05000498/1997015: Difference between revisions

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{{Adams
{{Adams
| number = ML20140A904
| number = ML20199L863
| issue date = 06/03/1997
| issue date = 11/28/1997
| title = Insp Repts 50-498/97-15 & 50-499-97-15 on 970505-09. Violations Noted.Major Areas Inspected:Routine,Announced Insp Focused Upon Specific Areas of Licensee Physical Security Program
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/97-15 & 50-499/97-15 on 970603
| author name =  
| author name = Murray B
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name =  
| addressee name = Cottle W
| addressee affiliation =  
| addressee affiliation = HOUSTON LIGHTING & POWER CO.
| docket = 05000498, 05000499
| docket = 05000498, 05000499
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-498-97-15, 50-499-97-15, NUDOCS 9706050083
| document report number = 50-498-97-15, 50-499-97-15, NUDOCS 9712020138
| package number = ML20140A879
| title reference date = 07-02-1997
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 11
| page count = 4
}}
}}


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=Text=
=Text=
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  . /  5 NUC1.C AR REGUL ATORY COMMISSION j    umoN iv
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i November 28', 1997 William T. Cottle, Group Vice -
President, Nuclear Houston Lighting & Power Company i
P.O. Box 289 Wadsworth Texas 77483 SUBJECT: NRC INSPECTION REPORT 50-498/97-15; 50-499/9715 I
 
==Dear Mr. Cottle:==
Thank you for your letter of July 2,1997, in response to our letter and Notice of Violation dated June 3,1997, We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a
          :
future inspection to determine that full compliance has been achieved and will be maintained.
 
Sincerely,
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          '
Blaine Murray, Chief Plant Support Branch c    Division of Reactor Safety Docket Nos.: 50-498;50-499 License Nos.: NPF 76; NPF-80
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cc:
Lawrence E. Martin, General Manager Nuclear Assurance & t.icensing Houston Lighting & Power Company    '
P,0. Box 289 Wadsworth Texas 77483     [
Mr. J. C, Lanier/Mr. M. B. Lee City of Austin Electric Utility Department 721 Barton Springs Road Austin. Texas 78704
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l ENCLOSURE 2   !
 
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Houston Lighting & Powst Company  . 2
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Mr. K. J. Fiedler/Mr. M. T. Hardt City l-ublic Fervice Board      !
P.O. Box 1771 San Antonio, Texas 78296        ,
Jack R. Newman, Esq.        ;
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Morgan, Lewis & Bocklus-1800 M. Street, N.W.


U.S. NUCLEAR REGULATORY COMMISSION i
Washington, D.C. 20036 5869-      ,
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Mr. G. E. Vaughn/Mr. C. A. Johnson .
. Central Power & Light Company -
P.O. Box 289 MailCode: N5012
  ' Wadsworth, Texas 77483


==REGION IV==
INPO Records Center        <
Docket Nos.: 50-498 50-499 License Nos.: NPF-76 NPF-80 Report No.: 50-498/97-15 50-499/97-15 Licensee: Houston Lighting & Power Company Facility: South Texas Project Electric Generating Station, Units 1 and 2 Location: FM 521 - 8 miles west of Wadsworth Wadsworth, Texas Dates: May 5-9,1997 Inspector: Thomas W. Dexter, Senior Physical Security Specialist j Plant Support Branch  !
700 Galleria Parkway Atlanta, Georgia 30339 5957
l Approved: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety l
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ATTACHMENT: Supplemental Information l
Dr. Bertram Wolfe
.15453 Via Vaquero Monte Sereno, California 95030 Bureau of Radiation Control State of Texas        '
1100 West 49th Street Austin, Texas 78756 Mr. Glenn W. Dishong Texas Public Utility Commission 7800 Shoal Creek Blvd.


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Suite 400N Austin, Texas 787571024 John Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711 Judge, Matagorda County        l Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414 n
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9/06050083 970603 PDR ADOCK 05000498 G  PDR .-.


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  ' Houston Lighting & Power Company.   - - 3-Licensing Representative        -'
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    -2-l   EXECUTIVE SUMMARY South Texas Project Electric Gererating Station, Units 1 and 2  ,
Houston Lighting & Power Company-Suite 610        l Three Metro Center        1 Bethesda, Maryland 20814 Rufus S. Scott, Associate General Counsel        i Houston Lighting & Power Company      l P.O. Box 61867
NRC Inspection Report 50-498/97-15;50-499/97-15 This routine, announced inspection focused upon specific areas of the licensee's physical security program. These areas included review of records and reports, testing and maintenance, detection aids - protected area, compensatory measures, access control of personnel and packages, management support, and review of previous inspection finding Plant Sucoort
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* Two violations were identified involving (1) the failure to secure a vital area door and (2) failure to revoke a badge following the failure of a fitness-for-duty test. The security staff was correctly reporting security events. A very good records and reports program was in place (Section S1.1).
Houston, Texas 77208 -       ;
Joseph R. Egan, Esq.       ;
Egan & Associates, P.C.       :
  ~ 2300 N Street, N.W.


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Washington,- D.C. 20037        -
Security personnel had an excellent knowledge of testing procedures concerning the access control equipment. All access control equipment functioned as required (Section S2.1).
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* Very good progress had been accomplished in completing the installation of their new perimeter intrusion detection system (Section S2.2).
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* The compensatory measure program was effectively implemented. Security personnel were well trained on the prograrn requirements (Section S4.1).
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* A very good prograrn for searching personnel and vehicles was maintained (Section S4.2)
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  * An effective security training program had been implemented. Medical examinations for security officers were thorough and well documented. Facilities and firing range were excellent (Section 5.1).
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* Senior managernent support for the security organization was strong. The security program was implemented by a well trained and highly qualified staff. The morale of the security officers was very good (Section 6.1).
Houston Lighting & Power Company  -4-Distribution w/coov of licensee's letter dated July 2.1997:
DCD (IE04)
Regional Administrator South Texas Resident inspector DRS Director DRS Deputy Director      .
        '
DRP Director DRS PSB Branch Chief (DRP/A)      l Project Engineer (DRP/A)
Branch Chief (DRP/TSS)      l Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22)    l Leah Tremper, OC/DAF/LFARB (MS: TWFN 9 E10)    l MIS System      ;
RIV File        l R. Bachmann, OGC (MS: 15 B-18)
PSB File (Hodges)
DOCUMENT NAME: G:\ REPORTS \ST715AK.TWD To receive copy of document indicate in boa:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:DRS 7th E C:DRS/P$ll TWDexter:nh'  BMurray%(/
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11(f/97  11b/97 OFFICIAL RECORD COPY i
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Houston Lighting & Power Company  -4    i Qiginbution w/ cony of licensee's letter dated July 2.199L DCD (IE04)
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Regional Administrator South Texas Resident inspector DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/A)
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Project Engineer (DRP/A)
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Branch Chief (DRP/TSS)
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Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22)
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Leah Tremper, OC/DAF/LFARB (ME; TWFN 9 E10)
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MIS System        ,
i Report Details
RIV File R. Bachmann, OGC (MS: 15 B-18)
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PSB File (Hodges)
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IV. Plant Support i
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DOCUMENT NAME G:\ REPORTS \ST715AK.TWD      ,
S1 Conduct of Security and Safeguards Activities    l t
To receive copy of document. Indicate in box:"C" Ogy without enclosures "E" = Copy with enclosures "N" = No copy RIV:DRS '7tf) E C:DRS/FM]
S Records and Reports (81700-02.01)   .
l- TWDexter:nh' BMurray%Q      .
I Inspection Scope i
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The inspector reviewed safeguards event logs and security program condition  i reports to determine compliance with the requirements of 10 CFR 73.21(b) and (c), ,
l 116(/97  11 6/97 OFFICIAL RECORD COPY l          ,
10 CFR 26.73, and the physical security plan,    j l
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J Observations and Findinas    j l
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The inspector reviewed the security event logs and security program condition  )
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reports from October 1,1996, through April 30,1997. The records were available ]
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for review and maintained for the time required by regulations. The i. spector :
determined that the licensee conformed to the regulatory requirements regarding the l reporting of security events. The logs and condition reports were organizeri in j numerical sequence and easy to audit. The following two events were specifically l reviewed in detail,    j
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  * Uncompensated Vital Area Door in Access Mode  l
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l Licensee Condition Repo'rt 97-6585 identified that on April 2,1997, at approximately 6:44 a.m. an alarm station operator d;scovered that a vital area door had been left in the access mode (the lock alarm and the balance magnetic switch alarm were taken out-of service) without being controlled by the security system or by an armed security officer referencing an access authorization list. The door alarm had been inactivated at 7:06 a.m. on April 1,1997, so it could be blocked open for painting work in the vital are A compensatory officer was posted at the door. At 5:08 p.m. the workers left the area. The compensatory officer secured the door and called the central alarm station operator to reactivate the alarm on the door. The officer claims he receised an acknowledgement from the station operator, .
carded out from the area and waited to ensure there were no alarms on the door. When he did not hear a call for an alarm on the door he departed the area. However, it appears that the alarm station operator did not place the vital area door back in the alarm mod .- . . - -


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.          4 Houston Lighting & Power Company.  - 4-l Distribution w/cooy of licensee's !stier dated Jutv 2.1997:
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DCD (IE04)
Regional Administrator
' South Texas Resident inspector DRS Director DRS Deputy Director
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DRP Director DRS PSB        -
Branch Chief (DRP/A)        !
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Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22)
Leah Tremper, OC/DAF/LFARB (MS: TWFN 9 E10)      l MIS System        !
RIV File R. Bachmann, OGC (MS: -15-B-18)
PSB File (Hodges)        ;
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DOCUMENT NAME: G:\ REPORTS \ST715AK.TWD To receive copy of document, Indicate in boa:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:DRS 'Ith - 'I - C:DRS/Fl@f  f    i TWDexter:nh'  BMurray%$-
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11/f!97  11h/97 OFFICIAL RECORD COPY l
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l-4-l The licensee's immediate compensatory actions were io search the vital area ;
for any fore;gn materials or objects and then test and secure the door alar However, the licensee had not developed long-term corrective actions.


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South Texas Project Physical Security Plan, Revision 7A, dated January 14, 1997, Chapter 4, paragraph 4.4, " Vital Area Access - Personnel," states, in part, " Access to Vital Areas shall be controlled by the security system or by an armed security officer referencing an access authorization list. Personnel ,
 
entry / exit is documented for all vital area access except the control room." +
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The licensee's failure to control a vital area door in the access mode, between the i afternoon of April 1,1997, and the morning of April 2,1997, is a violation of its I security plan (50-498;-499/9715-01).
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Houston Lighting & Power Company  -4-Distribution w/cooy oljicensee's letter dated July 2.1997:
DCD (IE04)
Regional Administrator South Texas Resident inspector DRS Director DRS Deputy Director DRP Director DRS PSB Branch Chief (DRP/A)
Project Engineer (DRP/A)
Branch Chief (DRP/TSS)
Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22)
Leah Tremper, OC/DAF/LFARB (MS: TWFN 9 E10)
MIS System RIV File R. Bachmann, OGC (MS: 15 B 18)
PSB File (Hodges)
DOCUMENT NAME G:\ REPORTS \ST715AK.TWD To receive copy of document. Ind6cate in box:"C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy RIV:DRS 'ith E C:DRS/@ f TWDexter:nh'  BMurrayEf
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11/f/97  11b/97 OFFICIAL RECORD COPY
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* Failure to inactivate Badae - Fitness-For-Duty Failure  !
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Licensee Condition Report 97-0165 identified that on February 5,1997, i while a licensee fitness-for-duty department employee was imputing drug l test results into a computer data when the individual noted that a contract ,
employee, who had failed a for-cause alcohol test on February 3,1997, had I not had his badge revoked. The department employee completed a condition l report and notified security to revoke the badge in the security compute !
l The licensee's investigation determined that the employee's supervisor had maintained control of the empicyee's security badge and that the employee had not entered the protected are j i
The licensee's corrective action involved the project engineering supervisor i discussing the importance of the line of communication and the procedure requirements for badge transactions. However, the inspector determined ,
that the following licensee's security plan and procedures were not l
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implemented:
South Texas Project Physical Security Plan, Revision 7A, dated January 14, 1997, Chapter 4, paragraph 4.2, states, in part, "If a person is terminated ,
for-cause, that individual's access is revoked and his/her assigned badge is j deactivated through the security computer system prior to or simultaneously i with notification of termination."   l l
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July 2,1997 ST Ill-AE 5683  '
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File No.: G02.04.02 '
South Texas Project Procedure OPGP09-ZA-0002, " Fitness For Duty Program," Revision 7, dated October 24,1996, paragraph 6.11, " Confirmed
10CFR2.201  .
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STI 30326871 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington,DC 20555 South Texas Project Units I and 2 Docket Nos. STN 50-498 and STN 50-499 Reply to Notice of Violation 97.1102 South Texas Project has reviewed Notice of Violation 9715 02, dated June 3,1997, and submits the attached reply. The events described in the Notice of Violation did not have an adverse effect on the health and safety of the public, if there are any questions regarding these replies, please contact Mr. S. M. licad at (512)
Positive Test Results," states, in part, "A ' Confirmed Positive' notification  l l  letter (Form 2) is delivered to the department manager, or designee, notifying  )
972 7136 or me at ($12) 972 8757.
l  them the individual is denied site access. The HL&P employee will be  !
terminated . . . Notification of the above positive test results shall be made  l using the guidelines contained in OPGP03-ZX-0002, Condition Reporting  i Process."


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J. J. Sheppard Assistant to Executive Vice President and General Manager, Nuclear
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South Texas Project Procedure OPGP03-ZX-0002, " Condition Reporting Process," Revision 13, dated September 12,1996, paragraph 4.1,
WEM/wem        g Attachment: Reply to Notice of Violation 9715 02
   " Condition identification," states, in part, "For conditions where security concerns are obvious or perceived, contact Plant Protection immediately and deliver the CR form to Plant Protection, or if database. entry was made, promptly in form the Security Force Supervisor of the Condition Report number."
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  ,, ,a Ellis W.Merschoff    Rufus S. Scott Regional Administrator, Region IV  Associate General Counsel    .l,iy U. S. Nuclear Regulatory Commission  llouston Lighting & Power Company    <
611 Ryan Plaza Drive, Suite 400   P. O. Box 61067    . , ;. ,
Arlington.TX 76011 8064  Ilouston. TX 77208    'f
  'ihomas W. Alexion    Institute of Nuclear Power Project Manager, Mail Code 13113  Operations Records Center U.S. Nuclear Regulatory Commission  700 Galleria Parkway Washington, DC 20555-0001  Atlanta, G A 30339 5957 David P. Loveless    Dr. Dertram Wolfe Sr. Resident inspector    15453 Vh Vaquero c/o U. S. Nuclear Regulttory Commission  Monte Sereno,CA 95030 P. O. Box 910 Day City TX 77404 0910  Richard A.Ratliff Dureau of Radiation Control J. R. Newman, Esquire    Texas Department ofIlealth Morgan, Lewis & Dockius  1100 West 49th Street 1800 M. Street, N.W. Austin, TX 78756-3189 Washington, DC 200V,.5869        '
J. R. Egan, Esquire H. T. liardt/W. C. Gunst  Egan & Associates, P.C.
 
City Public Service    2300 N. Street, N.W.


The failure to initiate a proper condition report and a Form 2 is a violation of the security plan and implementing procedures (50-498;-499/9715-02). Conclusions Two violations were identified concerning (1) the failure to secure a vital area door and (2) failure to revoke a badge following the failure of a fitness-for-duty test. The security staff was correctly reporting security events. A very good records and reports program was in plac i S2 Status of Security Facilities and Equipment S2.1 Testina and Maintenance (81700-02.07) insoection Scooe The inspe tor reviewed the testing program for the access control equipment, Observations and Findinas The inspector observed the licensee conducted testing of the explosive and metal detectors and the x-ray machines at the east and west protected area access  ;
P. O. Box 1771    Washington,DC 20037 San Antonio,TX 78296 U.S. Nuclear Regulatory Commission J. C. Lanier/M. D. Lee    Attention: Document Control Desk City of Austin    Washington, DC 20555-0001 Electric titility Department 721 Darton Springs Road Austin,TX 78704 Central Power and Light Company ATIN: G. E. Vaughn/C. A. Johnson P. O. Box 289, Mall Code: N5012 Wadsworth,TX 77483
facilities. A security person working at each facility tested the equipment. Both  j personnel were knowledgeable of the testing procedures and both conducted the  ;
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tests in a similar rnanner. All equipment tested satisfactoril ,
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Attachment i ST llL AE 5683
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nu4 1. Statement of Violation:    9*
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License Condition 2.F of the South Texas Project Unit I, Operating License NPF 76 and Unit 2, Operating License NPF 80, dated March 22, 1988, requires that the licensee l'ully implement and maintain in effect the Commission approved physical security plan, including amendments and changes made purssnt to the authority of 10 CFR 50.54(p).


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South Texas Project Physical Security Plan, Revision 7A, c~ted January 14.1997, Chapter 4, ,
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paragraph 4.2, states,in part *lf a person is terminated for cause, that individual's access is revoked and his/her assigned badge is deactivated through the security computer system prior to or simultaneously with notificatic n of termination."
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I c .' Conclusions Security personnel had an excellent knowledge of testing procedures concerning the  ;
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access control equipment. All access control equipment functioned as require )
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S2.2 Detection Aids - Protected Area (81700-02.04) Inspection Scoce


1 The inspector reviewed the protected area detection aid syste l Observations and Findinos      l
South Texas Project Procedure OPGPO9 ZA-0002," Fitness For Duty Program," Revision 7 dated October 24,1996, paragraph 6.11,' Confirmed Positive Test Results,' states,in part,"A
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  ' Confirmed Positive' noti 0 cation letter (Form 2) is delivered to the department manager, or designee, notifying them the individual is denied site access, The llL&P employee will be terminated... Notification of the above positive test results shall be made using the guidelines contained in OPGPO3 ZX 0002, Condition Reporting Process."
The licensee was in the process of replacing the entire protected area detection aid  l system. The detection systems' capabilities, zoning of the alarm systems, detection !
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system security, and types of detection aids have been changed signific'antl The inspector discussed with members of the security system engineering and  !
  ' installation group the estimated completion time for the perimeter microwave  l
  . system. The licensee expects to have the system tested and turned over to  i security before the end of June 1997. The inspector observed portions of the  ;
installed system on May 7,1997. The detection systems appeared to be well  f designed and should detect an intruder attempting to enter the protected are Conclusions The licensee was making very good progress toward the completion of the installation of their new perimeter intrusion detection aid S4  Security and Safeguards Staff Knowledge and Performance S4.1 Compensatorv Measures (81700-02.07) Inspection Scope    *s
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The inspector reviewed the licensee's compensatory rneasures program. The areas inspected included deployment of compensatory measures and the effectiveness of those measure l l Observations and Findinas The inspector confirmed through a review of condition reports and security event logs.that the licensee deployed compensatory measures in a manner consistent with the requirements in the security plan. The inspector determined through interviews  j of security personnel that the security personnel available for assignment to compensatory security posts were properly trained for those duties. The inspector
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South Texas Project Procedure OPGPO3 7X0002," Condition Reporting Process," Revision 13, dated September 12,1996, paragraph 4.1, " Condition identification," states, in part, "For conditions where security concems are obvious or perceived, contact Plant Protection immediately and deliver the CR form to Plant Protection, or if database entry was made, promptly inform the Security Force Supervisor of the Condition Report number."
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i-7-l also observed security personnel posted on several compensatory posts around the perimeter of the protected area. Personnel appeared to be observant and those that the inspectors interviewed were knowledgeable of their duties and responsibilities, Conclusions The compensatory measures program was effectively implemented. The observed compensatory measures met the requirements in the security plan. Security personnel were well trained on the program requirement S4.2 Access Control of Personnel and Vehicles (81700-02.05) Insoection Scone The access control program for personnel and vehicles was inspecte Observations and Findinas
Contrary to the above, on May 7,1997, the inspector discovered that the licens c had failed to comply with their procedures on February 3,1997,conceming a positive for cause 6tness for-duty test. Specifically, the inspector identified that a condition report and Form 2 were not properly initiated on Febmary 3,1997.
      '
Access control activities were observed at the both security building entrances and at the vehicle positive se feral times during the inspection. Tha licensee properly controlled personnel access to the protected area. The protected area access control equipment was inspected and found to be functionai and well maintained, Conclusions i
A very good program for narching personnel and vehicles was maintaine l S5 Security and Safeguards StaH Training and Qualification SS.1 Personnel Trainina and Qualification (81700-02.08) ]_nspection n Scope The inspector reviewed the licensee's security training and qualification progra Observations and Findinas The security organization conducted all required training in accordance with its approved security, training, and contingency plans. The inspector confirmed, by a review n' .he composite security training records, that the required training was 1 conducted every 12 month The inspector observed security officers during the performance of their duties. All security officers displayed excellent conduct and knowledge of the procedural l requirements.


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This la a Severity Level IV violation (Supplement !!!)(50-498:499/9715 02).
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!!. South Texas Project Position:
.
South Texas Project concurs that the violation occurred.
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    -8
  * Medical Examinations Medical examination records for 10 armed security officers were reviewe The medical records were complete and indicated that the required annual
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medical examinations were thorough and conducted in a timely manner. The results of the medical examinations were properly documente * Trainina Records Training records for 10 armed security officers were reviewed. The records were complete and all required training was current and conducted within every 12-month period.


  * Trainina Aids and Facilities The inspector verified that the security contractor was providing training videos covering numerous security subjects. The training facility was excellent it was located in a permanent type building adjacent to tha protected area and convenient for personnel to use. The licensee's rebuilt firing range was excellen Conclusions An effective security training program had been implemented. Medical examinations for security officers were thorough and well documented. Facilities and firing range were excellent.
111. Reason for the Violation:
The reason for this violation was a procedure deficiency that did not specify a time requirement to revoke the badge. In addition, the programmatic requirements in effect were not properly integrated.


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S6 Security Organization and Administration a
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S6.1 Manaaement Suocort (81700-02.01) Inspection Scope The effectiveness and adequacy of management support was inspected to determine the degree of management support for the physical security progra *
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' Observations and Findinas l
Attachment i ST IIL AE 5683 r,
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During the last tefueling outage on Unit Two an individual wu preparing to get access to the plant for work. De individual had completed the badging process and retumed to the Central Processing Facility. A station staff employee noticed the smell of what might be alcohol on the worker's breath in accordance with the plant Continual Behavioral Observation Program the worker was taken to Fitness For Duty for a "For Cause Test." nl: test showed an unneceptable level of alcohol present. De worker's Project Menger and Badge Coordinator were notified of the failure, ne Badge Coordinator maintained the worker's access badge in her possession and the worker's employment wu terminated. Contrary to procedural requirements the worker's manager did not complete the required Badge Transaction Form while processing the worker off site. Approximately 36 hours ifler the Fitness For Duty failure, a review of the Fitness for Duty records revealed that the involved worker's badge wu still in an active status. Security wu informed and the badge was revoked.


The inspector determined by discussions with security force personnel that the j security program received strong support from senior management. The inspector determined that the security program was imp lemented by a well trained and highly qualified security staff. All members of the security organization had a clear ,
The Fitness for Duty Procedure required that a Condition Report be written only if the failure was reportable under 10CFR50.26. His event was not reportable under 10CFR$0.26. De Condition Reporting Procedure only required Security be notified if a Condition Report described a Security related event. The involved individuals did not recogae this as a Security related event. ne existing procedural guidance relied upon the process ng of the Badge Transaction Form to result in Security being notified of the Fitness for Duty fal;ure.
understanding of their duties and responsibilities and the morale of the secunty ;
officers was very goo j l Conclusions    ;
j Senior management support for the security organization was strong. The security !
program was implemented by a well trained and highly qualified staff. The morale of the security officers was very goo S8 Miscellaneous Security and Safeguards issues (92904)  ;
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S8.1 (Closed) Unresolved item 498:499/9616-01: Failure to Verifv Criminal History of i Foreian Nationals During the access authorization inspection the inspectors identified two individuals who appeared not to have had their criminal histories checked in their countries of origin. Guidance received from the Office of Nuclear Regulatory Regulation was i that it was expected that licensees would conduct criminal history checks with foreign countries. During this inspection the inspector, with the licensee determined that one of the individuals, although born in Mexico was a United States citize The second individual was a citizen of Mexico and was in the United States on a visa. During the background check the validity of the visa was not checke Subsequent investigation by the licensee determined that the individual has been in the United States for 20 years and learned through the Department of Immigration and Naturalization Services that the visa was valid and current. The licensee had cumpleted all other background screening including a FBI criminal history check prior to granting unescorted access to the individual. This unresolved item is considered close V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on May 9,1997. The licensee acknowledged the findings presente i


~ . _ . _ . . . ._._._____ _._,__.__.__ ._._ _ ___ _..____. <
IV. Corrective Actions:
  .
e Security personnel pmmptly placed the employce's badge on hold when notified the employee um on the denial list. Security personnel revoked the badge about an hour after it was placed on hold.
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ATTACHMENT t
SUPPLEMENTAL INFORMATION    [
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i PARTIAL LIST OF PERSONS CONTACTED  l
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l        I l  Licensee W. Cottle, Executive Vice President and General Manager, Nuclear  ;
i  J. Groth, Vice President, Nuclear Operation P. Arrington, Assistant Licensing Specialist l
J. Drymiller, Supervisor, Security    !
l  M. Hall, Senior Operations Coordinator, Security    j l  S. Head, Licensing Supervisor J. Hinson, Manager, Employee Relations A. Keating, Electrical / Instrumentation and Controls Manager T. Koser, Licensing Engineer L. Martin, General Manager, Nuclear Assurance and Licensing    ;
M. McBurnett, Licensing Director
        '
J. Northrop, Security System Engineer    ,
R. Piggott, Senior Quality Assurance Specialist    l A. Rodriguez, Senior Coordinator, Security    l C. Sanders, Lead Training instructor    :
        '
D. Sheesley, Security Systems Supervisor J. Sheppard, Assistant to Executive Vice President    l
        '
M. Smith, Administrator, Plant Support Quality Fi Timmons, Manager Plant Protection Department P. Travis, System Engineer Supervisor INSPECTION PROCEDURES USED IP 81700 Physical Security Program for Power Reactors IP 92904 Followup - Plant Support LIST OF ITEMS OPENED AND CLOSED Ooen 50-498;499/9715-01 NOV Failure to Properly Secure Vital Area Door 50-498:499/9715-02 NOV Failure to inactivate Badge For Fitness-For-Duty Failure i Closed 50-498:499/9616-01 URI Failure to Verify Criminal History of Foreign National
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e ne Fitness For Duty Program procedure was revised to instruct the Industrial Safety
  .
  & ilealth Division hianager, or designec, to have an individual's access revoked upon verification the individual has a positive Fitness For Duty test result. His change requires the first individual aware of the failure to notify Security prior to any delays, e ne Fitness for Duty Pmgram pmeedure wu revised to instruct the Industrial Safety
    . . -. - .. . .
  & Ilealth Division Manager, or designee, to initiate a Condition Report as a result of a Fitness for Duty failure. The Condition Report would insure that Securay reviewed the event to determine if 10CFR50.73 was app!! cable.
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* Fitness For Duty personnel have been trained on the procedure revisions to the Fitness For Duty Program.
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LIST OF DOCUMENTS REVIEWED South Texas Project Physical Security Plan, Revision 7A, January 14,1997  l l
j Security event logs from October 1,1996, through April 30,1997 condition reports for the I i same period.


*
V, Dste of Full Compliance:
ne South Texas project is in full compliance.


;
South Texas Project Procedure OPGP09-ZA-0002, Fitness For Duty Prcgram, Revision 7, I dated October 24,1996
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South Texas Project Procedure OPGP03-ZX-0002, Condition Reporting Process, 4 Revision 13, dated September 12,1996
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Security Officer Training Records (composite listing)
        - - . _
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Background invest;gation (file) records for two individuals granted unescorted access authorization to the protected area
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Medical Records for ten members of the security organization
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31-Day Access Review Records for January and February 1997   3
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Attachment !
ST IR AE46W3 o' **      Page 3 of 3 VI. AdditionalInformation
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Although the employee's badge had been 1: sued, it was never given to the employee. .m  j . =.
The employte's hedge was in custody of the employce's Badge Coordinator from the
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time it was issued until the employee's access was revoked.


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Latest revision as of 22:17, 7 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-498/97-15 & 50-499/97-15 on 970603
ML20199L863
Person / Time
Site: South Texas  STP Nuclear Operating Company icon.png
Issue date: 11/28/1997
From: Murray B
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Cottle W
HOUSTON LIGHTING & POWER CO.
References
50-498-97-15, 50-499-97-15, NUDOCS 9712020138
Download: ML20199L863 (4)
v • d • e


Text

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i November 28', 1997 William T. Cottle, Group Vice -

President, Nuclear Houston Lighting & Power Company i

P.O. Box 289 Wadsworth Texas 77483 SUBJECT: NRC INSPECTION REPORT 50-498/97-15; 50-499/9715 I

Dear Mr. Cottle:

Thank you for your letter of July 2,1997, in response to our letter and Notice of Violation dated June 3,1997, We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation. We will review the implementation of your corrective actions during a

future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

}*p2 -

'

Blaine Murray, Chief Plant Support Branch c Division of Reactor Safety Docket Nos.: 50-498;50-499 License Nos.: NPF 76; NPF-80

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Lawrence E. Martin, General Manager Nuclear Assurance & t.icensing Houston Lighting & Power Company '

P,0. Box 289 Wadsworth Texas 77483 [

Mr. J. C, Lanier/Mr. M. B. Lee City of Austin Electric Utility Department 721 Barton Springs Road Austin. Texas 78704

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Mr. K. J. Fiedler/Mr. M. T. Hardt City l-ublic Fervice Board  !

P.O. Box 1771 San Antonio, Texas 78296 ,

Jack R. Newman, Esq.  ;

Morgan, Lewis & Bocklus-1800 M. Street, N.W.

Washington, D.C. 20036 5869- ,

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Mr. G. E. Vaughn/Mr. C. A. Johnson .

. Central Power & Light Company -

P.O. Box 289 MailCode: N5012

' Wadsworth, Texas 77483

INPO Records Center <

700 Galleria Parkway Atlanta, Georgia 30339 5957

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Dr. Bertram Wolfe

.15453 Via Vaquero Monte Sereno, California 95030 Bureau of Radiation Control State of Texas '

1100 West 49th Street Austin, Texas 78756 Mr. Glenn W. Dishong Texas Public Utility Commission 7800 Shoal Creek Blvd.

Suite 400N Austin, Texas 787571024 John Howard, Director Environmental and Natural Resources Policy Office of the Governor P.O. Box 12428 Austin, Texas 78711 Judge, Matagorda County l Matagorda County Courthouse 1700 Seventh Street Bay City, Texas 77414 n

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Houston Lighting & Power Company-Suite 610 l Three Metro Center 1 Bethesda, Maryland 20814 Rufus S. Scott, Associate General Counsel i Houston Lighting & Power Company l P.O. Box 61867

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Houston, Texas 77208 -  ;

Joseph R. Egan, Esq.  ;

Egan & Associates, P.C.  :

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Houston Lighting & Power Company -4-Distribution w/coov of licensee's letter dated July 2.1997:

DCD (IE04)

Regional Administrator South Texas Resident inspector DRS Director DRS Deputy Director .

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DRP Director DRS PSB Branch Chief (DRP/A) l Project Engineer (DRP/A)

Branch Chief (DRP/TSS) l Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22) l Leah Tremper, OC/DAF/LFARB (MS: TWFN 9 E10) l MIS System  ;

RIV File l R. Bachmann, OGC (MS: 15 B-18)

PSB File (Hodges)

DOCUMENT NAME: G:\ REPORTS \ST715AK.TWD To receive copy of document indicate in boa:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:DRS 7th E C:DRS/P$ll TWDexter:nh' BMurray%(/

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Houston Lighting & Power Company -4 i Qiginbution w/ cony of licensee's letter dated July 2.199L DCD (IE04)

Regional Administrator South Texas Resident inspector DRS Director DRS Deputy Director DRP Director DRS-PSB Branch Chief (DRP/A)

Project Engineer (DRP/A)

Branch Chief (DRP/TSS)

Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22)

Leah Tremper, OC/DAF/LFARB (ME; TWFN 9 E10)

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RIV File R. Bachmann, OGC (MS: 15 B-18)

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. 4 Houston Lighting & Power Company. - 4-l Distribution w/cooy of licensee's !stier dated Jutv 2.1997:

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DCD (IE04)

Regional Administrator

' South Texas Resident inspector DRS Director DRS Deputy Director

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DRP Director DRS PSB -

Branch Chief (DRP/A)  !

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Project Engineer (DRP/A)

Branch Chief (DRP/TSS)

Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22)

Leah Tremper, OC/DAF/LFARB (MS: TWFN 9 E10) l MIS System  !

RIV File R. Bachmann, OGC (MS: -15-B-18)

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DOCUMENT NAME: G:\ REPORTS \ST715AK.TWD To receive copy of document, Indicate in boa:"C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy RIV:DRS 'Ith - 'I - C:DRS/Fl@f f i TWDexter:nh' BMurray%$-

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Houston Lighting & Power Company -4-Distribution w/cooy oljicensee's letter dated July 2.1997:

DCD (IE04)

Regional Administrator South Texas Resident inspector DRS Director DRS Deputy Director DRP Director DRS PSB Branch Chief (DRP/A)

Project Engineer (DRP/A)

Branch Chief (DRP/TSS)

Elaine Koup, NRR/DRPM/PSGB (MS: OWFN 11 E22)

Leah Tremper, OC/DAF/LFARB (MS: TWFN 9 E10)

MIS System RIV File R. Bachmann, OGC (MS: 15 B 18)

PSB File (Hodges)

DOCUMENT NAME G:\ REPORTS \ST715AK.TWD To receive copy of document. Ind6cate in box:"C" = Copy without enclosures *E" = Copy with enclosures "N" = No copy RIV:DRS 'ith E C:DRS/@ f TWDexter:nh' BMurrayEf

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July 2,1997 ST Ill-AE 5683 '

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File No.: G02.04.02 '

10CFR2.201 .

STI 30326871 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington,DC 20555 South Texas Project Units I and 2 Docket Nos. STN 50-498 and STN 50-499 Reply to Notice of Violation 97.1102 South Texas Project has reviewed Notice of Violation 9715 02, dated June 3,1997, and submits the attached reply. The events described in the Notice of Violation did not have an adverse effect on the health and safety of the public, if there are any questions regarding these replies, please contact Mr. S. M. licad at (512)

972 7136 or me at ($12) 972 8757.

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J. J. Sheppard Assistant to Executive Vice President and General Manager, Nuclear

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WEM/wem g Attachment: Reply to Notice of Violation 9715 02

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PDR ADOCK 0S000490 0 YDR

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,, ,a Ellis W.Merschoff Rufus S. Scott Regional Administrator, Region IV Associate General Counsel .l,iy U. S. Nuclear Regulatory Commission llouston Lighting & Power Company <

611 Ryan Plaza Drive, Suite 400 P. O. Box 61067 . , ;. ,

Arlington.TX 76011 8064 Ilouston. TX 77208 'f

'ihomas W. Alexion Institute of Nuclear Power Project Manager, Mail Code 13113 Operations Records Center U.S. Nuclear Regulatory Commission 700 Galleria Parkway Washington, DC 20555-0001 Atlanta, G A 30339 5957 David P. Loveless Dr. Dertram Wolfe Sr. Resident inspector 15453 Vh Vaquero c/o U. S. Nuclear Regulttory Commission Monte Sereno,CA 95030 P. O. Box 910 Day City TX 77404 0910 Richard A.Ratliff Dureau of Radiation Control J. R. Newman, Esquire Texas Department ofIlealth Morgan, Lewis & Dockius 1100 West 49th Street 1800 M. Street, N.W. Austin, TX 78756-3189 Washington, DC 200V,.5869 '

J. R. Egan, Esquire H. T. liardt/W. C. Gunst Egan & Associates, P.C.

City Public Service 2300 N. Street, N.W.

P. O. Box 1771 Washington,DC 20037 San Antonio,TX 78296 U.S. Nuclear Regulatory Commission J. C. Lanier/M. D. Lee Attention: Document Control Desk City of Austin Washington, DC 20555-0001 Electric titility Department 721 Darton Springs Road Austin,TX 78704 Central Power and Light Company ATIN: G. E. Vaughn/C. A. Johnson P. O. Box 289, Mall Code: N5012 Wadsworth,TX 77483

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Attachment i ST llL AE 5683

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  • Page I of 3 ,

nu4 1. Statement of Violation: 9*

License Condition 2.F of the South Texas Project Unit I, Operating License NPF 76 and Unit 2, Operating License NPF 80, dated March 22, 1988, requires that the licensee l'ully implement and maintain in effect the Commission approved physical security plan, including amendments and changes made purssnt to the authority of 10 CFR 50.54(p).

+

South Texas Project Physical Security Plan, Revision 7A, c~ted January 14.1997, Chapter 4, ,

paragraph 4.2, states,in part *lf a person is terminated for cause, that individual's access is revoked and his/her assigned badge is deactivated through the security computer system prior to or simultaneously with notificatic n of termination."

South Texas Project Procedure OPGPO9 ZA-0002," Fitness For Duty Program," Revision 7 dated October 24,1996, paragraph 6.11,' Confirmed Positive Test Results,' states,in part,"A

' Confirmed Positive' noti 0 cation letter (Form 2) is delivered to the department manager, or designee, notifying them the individual is denied site access, The llL&P employee will be terminated... Notification of the above positive test results shall be made using the guidelines contained in OPGPO3 ZX 0002, Condition Reporting Process."

South Texas Project Procedure OPGPO3 7X0002," Condition Reporting Process," Revision 13, dated September 12,1996, paragraph 4.1, " Condition identification," states, in part, "For conditions where security concems are obvious or perceived, contact Plant Protection immediately and deliver the CR form to Plant Protection, or if database entry was made, promptly inform the Security Force Supervisor of the Condition Report number."

Contrary to the above, on May 7,1997, the inspector discovered that the licens c had failed to comply with their procedures on February 3,1997,conceming a positive for cause 6tness for-duty test. Specifically, the inspector identified that a condition report and Form 2 were not properly initiated on Febmary 3,1997.

This la a Severity Level IV violation (Supplement !!!)(50-498:499/9715 02).

!!. South Texas Project Position:

South Texas Project concurs that the violation occurred.

111. Reason for the Violation:

The reason for this violation was a procedure deficiency that did not specify a time requirement to revoke the badge. In addition, the programmatic requirements in effect were not properly integrated.

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Attachment i ST IIL AE 5683 r,

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.. .- Page 2 of 3 .

During the last tefueling outage on Unit Two an individual wu preparing to get access to the plant for work. De individual had completed the badging process and retumed to the Central Processing Facility. A station staff employee noticed the smell of what might be alcohol on the worker's breath in accordance with the plant Continual Behavioral Observation Program the worker was taken to Fitness For Duty for a "For Cause Test." nl: test showed an unneceptable level of alcohol present. De worker's Project Menger and Badge Coordinator were notified of the failure, ne Badge Coordinator maintained the worker's access badge in her possession and the worker's employment wu terminated. Contrary to procedural requirements the worker's manager did not complete the required Badge Transaction Form while processing the worker off site. Approximately 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> ifler the Fitness For Duty failure, a review of the Fitness for Duty records revealed that the involved worker's badge wu still in an active status. Security wu informed and the badge was revoked.

The Fitness for Duty Procedure required that a Condition Report be written only if the failure was reportable under 10CFR50.26. His event was not reportable under 10CFR$0.26. De Condition Reporting Procedure only required Security be notified if a Condition Report described a Security related event. The involved individuals did not recogae this as a Security related event. ne existing procedural guidance relied upon the process ng of the Badge Transaction Form to result in Security being notified of the Fitness for Duty fal;ure.

IV. Corrective Actions:

e Security personnel pmmptly placed the employce's badge on hold when notified the employee um on the denial list. Security personnel revoked the badge about an hour after it was placed on hold.

e ne Fitness For Duty Program procedure was revised to instruct the Industrial Safety

& ilealth Division hianager, or designec, to have an individual's access revoked upon verification the individual has a positive Fitness For Duty test result. His change requires the first individual aware of the failure to notify Security prior to any delays, e ne Fitness for Duty Pmgram pmeedure wu revised to instruct the Industrial Safety

& Ilealth Division Manager, or designee, to initiate a Condition Report as a result of a Fitness for Duty failure. The Condition Report would insure that Securay reviewed the event to determine if 10CFR50.73 was app!! cable.

V, Dste of Full Compliance:

ne South Texas project is in full compliance.

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Attachment !

ST IR AE46W3 o' ** Page 3 of 3 VI. AdditionalInformation

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Although the employee's badge had been 1: sued, it was never given to the employee. .m j . =.

The employte's hedge was in custody of the employce's Badge Coordinator from the

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time it was issued until the employee's access was revoked.

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