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{{#Wiki_filter:CATEGORYj.REGULATORY
{{#Wiki_filter:CATEGORY j.REGULATORY
INFORMATION
INFORMATION
DISTRIBUTION
DISTRIBUTION
SYSTEM(RIDS)~~~'ACCESSION
SYSTEM (RIDS)~~~'ACCESSION
NBR'.9805050266
NBR'.9805050266
DOC.DATE:
DOC.DATE: 98/04/28 NOTARIZED:
98/04/28NOTARIZED:
YES FACIL:50-335
YESFACIL:50-335
St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&, Light Co.AUTH.NAME AUTHOR AFFILIATION
St.LuciePlant,Unit1,FloridaPower&LightCo.50-389St.LuciePlant,Unit2,FloridaPower&,LightCo.AUTH.NAMEAUTHORAFFILIATION
PLUNKETT,T.F.
PLUNKETT,T.F.
FloridaPower&LightCo.RECIP.NAME
Florida Power&Light Co.RECIP.NAME
RECIPIENT
RECIPIENT AFFILIATION
AFFILIATION
Document Control Branch (Document Control Desk)DOCKET 05000335 05000389 SUBJECT: Responds to violations
DocumentControlBranch(Document
noted in insp repts 50-335/98-01
ControlDesk)DOCKET0500033505000389SUBJECT:Respondstoviolations
notedininsprepts50-335/98-01
&50-389/98-01.Corrective
&50-389/98-01.Corrective
actions:terminated
actions:terminated
accessauthorization
access authorization
forbothindividuals
for both individuals
&temporarily
&temporarily
suspended
suspended terminations
terminations
of access authorization
ofaccessauthorization
in plant s badging ofc.DISTRIBUTION
inplantsbadgingofc.DISTRIBUTION
CODE: IE04D COP1ES RECEIVED:LTR
CODE:IE04DCOP1ESRECEIVED:LTR
,.ENCL SIZE: TITLE: Safeguards
,.ENCLSIZE:TITLE:Safeguards
Inspection
Inspection
Rpt/NOVResponse(50DKT)-Publicly
Rpt/NOV Response (50 DKT)-Publicly
Available
Available NOTES: G RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: ACRS NRR/DRPM/PERB
NOTES:GRECIPIENT
IDCODE/NAME
PD2-3PDINTERNAL:
ACRSNRR/DRPM/PERB
NUDOCS-ABSTRACT
NUDOCS-ABSTRACT
RGN2FILE01COPIESLTTRENCL1111111111RECXPIENT
RGN2 FILE 01 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 RECXPIENT ID CODE/NAME GLEAVES,W NUDOCS FULLTEXT OE DIR COP1ES LTTR ENCL 1 1 1 1 1 1 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:
IDCODE/NAME
PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION
GLEAVES,W
REMOVED FROM DISTRIBUTION
NUDOCSFULLTEXTOEDIRCOP1ESLTTRENCL11111111EXTERNAL:
LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 11
NOAC11NRCPDR11NOTETOALL"RIDS"RECIPIENTS:
PLEASEHELPUSTOREDUCEWASTE.TOHAVEYOURNAMEORORGANIZATION
REMOVEDFROMDISTRIBUTION
LISTSORREDUCETHENUMBEROFCOPIESRECEIVEDBYYOUORYOURORGANIZATION,
CONTACTTHEDOCUMENTCONTROLDESK(DCD)ONEXTENSION
415-2083TOTALNUMBEROFCOPIESREQUIRED:
LTTR11ENCL11
   
   
FloridaPower5LightCompany,6351
Florida Power 5 Light Company,6351
S.OceanDrive,JensenBeach,FL34957April28.l998L-98-10810CFR52.201U.S.NuclearRegulatory
S.Ocean Drive, Jensen Beach, FL 34957 April 28.l 998 L-98-108 10 CFR 52.201 U.S.Nuclear Regulatory
Commission
Commission
'Attn:DocumentControlDeskWashington,
'Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to a Notice of Violation NRC Ins ection Re ort 98-01 EA 98-064 Florida Power and Light Company (FPL)has reviewed the subject Notice of Violation and, pursuant to 10 CFR$2.201, the responses to the violations
D.C.20555Re:St.LucieUnits1and2DocketNos.50-335and50-389ReplytoaNoticeofViolation
are attached.The violation resulted from the failure to remove the access authorization
NRCInsectionReort98-01EA98-064FloridaPowerandLightCompany(FPL)hasreviewedthesubjectNoticeofViolation
of favorably terminated
and,pursuantto10CFR$2.201,theresponses
contract employees.
totheviolations
FPL has concluded that the failure was not programmatic
areattached.
in nature and resulted from human error.However, FPL understands
Theviolation
the significance
resultedfromthefailuretoremovetheaccessauthorization
of the violation in that an unauthorized
offavorably
person, as defined in our Physical Security Plan, gained access to the site's protected area.FPL has taken comprehensive
terminated
contractemployees.
FPLhasconcluded
thatthefailurewasnotprogrammatic
innatureandresultedfromhumanerror.However,FPLunderstands
thesignificance
oftheviolation
inthatanunauthorized
person,asdefinedinourPhysicalSecurityPlan,gainedaccesstothesite'sprotected
area.FPLhastakencomprehensive
corrective
corrective
actionstoresolvetheidentified
actions to resolve the identified
condition,
condition, and has reviewed the event for generic implications.
andhasreviewedtheeventforgenericimplications.
We are confident that our corrective
Weareconfident
actions will prevent recurrence.
thatourcorrective
Please contact us with questions on the enclosed violation response.Very truly yours, Thomas F.Plunkett President Nuclear Division TFP/JAS/E JW Attachment
actionswillpreventrecurrence.
cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St.Lucie Plant'ir805050266
Pleasecontactuswithquestions
'ir80428 PDR ADOCK 05000335 8 PDR an FPL Group company
ontheenclosedviolation
response.
Verytrulyyours,ThomasF.PlunkettPresident
NuclearDivisionTFP/JAS/E
JWAttachment
cc:RegionalAdministrator,
USNRC,RegionIISeniorResidentInspector,
USNRC,St.LuciePlant'ir805050266
'ir80428PDRADOCK050003358PDRanFPLGroupcompany
   
   
St.LucieUnits1and2DocketNos.50-335and50-389L-98-108Page2STATEOFFLORIDA))COUN'IYOFPALMBEACH)ss.ThomasF.Plunkettbeingfirstdulysworn,deposesandsays:ThatheisPresident,
St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 L-98-108 Page 2 STATE OF FLORIDA))COUN'IY OF PALM BEACH)ss.Thomas F.Plunkett being first duly sworn, deposes and says: That he is President, Nuclear Division, of Florida Power&Light Company, the Licensee herein;That he has executed the foregoing document;that the statements
NuclearDivision,
made in this document are true and correct to the best of his knowledge, information
ofFloridaPower&LightCompany,theLicenseeherein;Thathehasexecutedtheforegoing
and belief, and that he is authorized
document;
to execute the document on behalf of said Licensee.7 Thomas F.Plunkett STATE OF FLORIDA COUNIY OF Sworn to and subscribed
thatthestatements
before me this 8W day of I'/, 195&by Thomas F.Plunkett, who is personally
madeinthisdocumentaretrueandcorrecttothebestofhisknowledge,
known to me.Name of N ry Public-S RObl ftl S.ECGnuu,, 1'~: Q=W COMMISSlON
information
f CC633<64 nap.Y:~:o!June 1, 2001"J o"ri80NOEO IHRU TROY fAIH SllRAPCE.uC.Print, type or stamp Commissioned
andbelief,andthatheisauthorized
Name of Notary Public)  
toexecutethedocumentonbehalfofsaidLicensee.
L-98-108 Attachment
7ThomasF.PlunkettSTATEOFFLORIDACOUNIYOFSworntoandsubscribed
P~se I Violation Facility Operating License Nos.DPR-67 and NPF-16, Amendment 151, dated May 16, 1997, require that the licensee shall fully implement and maintain in efFect all provisions
beforemethis8WdayofI'/,195&byThomasF.Plunkett,
of the Commission
whoispersonally
approved physical security, guard training and qualification, and safeguards
knowntome.NameofNryPublic-SROblftlS.ECGnuu,,1'~:Q=WCOMMISSlON
fCC633<64nap.Y:~:o!June1,2001"Jo"ri80NOEOIHRUTROYfAIHSllRAPCE.
uC.Print,typeorstampCommissioned
NameofNotaryPublic)  
L-98-108Attachment
P~seIViolation
FacilityOperating
LicenseNos.DPR-67andNPF-16,Amendment
151,datedMay16,1997,requirethatthelicenseeshallfullyimplement
andmaintaininefFectallprovisions
oftheCommission
approvedphysicalsecurity,
guardtrainingandqualification,
andsafeguards
contingency
contingency
plansincluding
plans including amendments
amendments
made pursuant to the provisions
madepursuanttotheprovisions
of the Miscellaneous
oftheMiscellaneous
Amendments
Amendments
andSearchRequirements
and Search Requirements
revisions
revisions to 10 CFR 50.90 and 10 CFR 50.54(p).Section 13.4.4 of the licensee's
to10CFR50.90and10CFR50.54(p).
Physical Security Plan, Revision 50, dated November 24, 1997, states, in part,"Upon notification
Section13.4.4ofthelicensee's
of the voluntary termination
PhysicalSecurityPlan,Revision50,datedNovember24,1997,states,inpart,"Uponnotification
or the termination
ofthevoluntary
for cause of an individual
termination
orthetermination
forcauseofanindividual
authorized
authorized
unescorted
unescorted
access,thePlantSecuritySupervision
access, the Plant Security Supervision
shallensurethatthekeycardandhandgeometryaccesscapabilities
shall ensure that the keycard and hand geometry access capabilities
areinactivated."
are inactivated." Section 5.3(d)of the licensee's
Section5.3(d)ofthelicensee's
Physical Security Plan, Revision 50, dated November 24, 1997, states, in part,"Only those individuals
PhysicalSecurityPlan,Revision50,datedNovember24,1997,states,inpart,"Onlythoseindividuals
with identified
withidentified
need for access and having appropriate
needforaccessandhavingappropriate
authorization, shall be granted unescorted
authorization,
vital area access." Contrary to the above, on December 31, 1997, plant security supervision
shallbegrantedunescorted
failed to implement Section 13.4.4 of the Physical Security Plan to ensure that a voluntarily
vitalareaaccess."Contrarytotheabove,onDecember31,1997,plantsecuritysupervision
failedtoimplement
Section13.4.4ofthePhysicalSecurityPlantoensurethatavoluntarily
terminated
terminated
individual's
individual's
keycardandhandgeometryaccesscapabilities
keycard and hand geometry access capabilities
wereinactivated.
were inactivated.
Asaresult,oneunauthorized
As a result, one unauthorized
individual's
individual's
unescorted
unescorted
accesstovitalareascontinued
access to vital areas continued in violation of the requirements
inviolation
of Section 5.3(d)of the Physical Security Plan between December 31, 1997, and January 2, 1998, and, in fact, the individual
oftherequirements
entered the protected area on January 2, 1998.In addition, on December 31, 1997, plant security supervision
ofSection5.3(d)ofthePhysicalSecurityPlanbetweenDecember31,1997,andJanuary2,1998,and,infact,theindividual
failed to implement Section 13.4.4 of the Physical Security Plan to ensure that a second favorably terminated
enteredtheprotected
areaonJanuary2,1998.Inaddition,
onDecember31,1997,plantsecuritysupervision
failedtoimplement
Section13.4.4ofthePhysicalSecurityPlantoensurethatasecondfavorably
terminated
individual's
individual's
keycardandhandgeometrywereinactivated.
keycard and hand geometry were inactivated.
ThisisaSeverityLevelIIIViolation
This is a Severity Level III Violation (Supplement
(Supplement
III).R~es ense 1.FPL concurs with the violation.
III).R~esense1.FPLconcurswiththeviolation.
2.REASON FOR VIOLATION The cause of the violation was human error in that the individual
2.REASONFORVIOLATION
tasked with deleting the contractor
Thecauseoftheviolation
washumanerrorinthattheindividual
taskedwithdeletingthecontractor
employees'adges
employees'adges
failedtofollowestablished
failed to follow established
plantprocedures
plant procedures
forterminating
for terminating
badges.  
badges.  
/'  
/'  
L-98-108Attachment
L-98-108 Attachment
~Pae23.CORRECTIVE
~Pa e2 3.CORRECTIVE
STEPSTAKENANDTHERESULTSACHIEVEDA.Upondiscovery
STEPS TAKEN AND THE RESULTS ACHIEVED A.Upon discovery on January 2,'1998, the access authorization
onJanuary2,'1998,theaccessauthorization
for both individuals
forbothindividuals
was terminated.
wasterminated.
B.Terminations
B.Terminations
ofaccessauthorization
of access authorization
intheplant'sbadgingofficeweretemporarily.
in the plant's badging office were temporarily.
suspended.
suspended.
C.Asaninterimaction,allaccesstermination
C.As an interim action, all access termination
transactions
transactions
wereaccomplished
were accomplished
inthesecurityoperations
in the security operations
center(Secondary
center (Secondary
AlarmStation)whereanindependent
Alarm Station)where an independent
verification
verification
processexisted.D.Appropriate
process existed.D.Appropriate
personnel
personnel disciplinary
disciplinary
actions were administered
actionswereadministered
to the accountable
totheaccountable
FPL and contractor
FPLandcontractor
employees.
employees.
4.'ORRECTIVE
4.'ORRECTIVE
STEPSTOAVOIDFURTHERVIOLATIONS
STEPS TO AVOID FURTHER VIOLATIONS
A.Thetermination
A.The termination
ofaccessprocesswasreviewedandstandardized
of access process was reviewed and standardized
sothatthebadgingofficeconducted
so that the badging office conducted access termination
accesstermination
in the same manner as the security operations
inthesamemannerasthesecurityoperations
center.The revised procedure specifically
center.Therevisedprocedure
requires that an independent
specifically
requiresthatanindependent
verification
verification
beaccomplished
be accomplished
priortotherequiredtermination
prior to the required termination
time.ThiswasachievedonJanuary5,1998.B.Accessprocessing
time.This was achieved on January 5, 1998.B.Access processing
andbadgingpersonnel
and badging personnel were trained on the new termination
weretrainedonthenewtermination
process discussed in Corrective
processdiscussed
Action 4.A.above.Based on benchmarking
inCorrective
of other licensees, a Physical Security Plan (PSP)change (Revision 51)was made to permit 48 hours for removal of access authorization
Action4.A.above.Basedonbenchmarking
for employee terminations
ofotherlicensees,
under favorable conditions.
aPhysicalSecurityPlan(PSP)change(Revision
Access authorization
51)wasmadetopermit48hoursforremovalofaccessauthorization
foremployeeterminations
underfavorable
conditions.
Accessauthorization
terminations
terminations
underunfavorable
under unfavorable
conditions
conditions
continuetoberequiredtobecompleted
continue to be required to be completed immediately.
immediately.
5.Full compliance
5.Fullcompliance
was achieved on January 2, 1998, with the removal of the access authorization
wasachievedonJanuary2,1998,withtheremovaloftheaccessauthorization
for both individuals
forbothindividuals
involved in the violation as stated in Corrective
involvedintheviolation
Action 3.A.above.
asstatedinCorrective
Action3.A.above.
}}
}}

Revision as of 16:45, 7 July 2018

Responds to Violations Noted in Insp Repts 50-335/98-01 & 50-389/98-01.Corrective Actions:Terminated Access Authorization for Both Individuals & Temporarily Suspended Terminations of Access Authorization in Plant Badging Ofc
ML17229A707
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 04/28/1998
From: PLUNKETT T F
FLORIDA POWER & LIGHT CO.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-335-98-01, 50-335-98-1, 50-389-98-01, 50-389-98-1, EA-98-064, EA-98-64, L-98-108, NUDOCS 9805050266
Download: ML17229A707 (8)


See also: IR 05000335/1998001

Text

CATEGORY j.REGULATORY

INFORMATION

DISTRIBUTION

SYSTEM (RIDS)~~~'ACCESSION

NBR'.9805050266

DOC.DATE: 98/04/28 NOTARIZED:

YES FACIL:50-335

St.Lucie Plant, Unit 1, Florida Power&Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power&, Light Co.AUTH.NAME AUTHOR AFFILIATION

PLUNKETT,T.F.

Florida Power&Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)DOCKET 05000335 05000389 SUBJECT: Responds to violations

noted in insp repts 50-335/98-01

&50-389/98-01.Corrective

actions:terminated

access authorization

for both individuals

&temporarily

suspended terminations

of access authorization

in plant s badging ofc.DISTRIBUTION

CODE: IE04D COP1ES RECEIVED:LTR

,.ENCL SIZE: TITLE: Safeguards

Inspection

Rpt/NOV Response (50 DKT)-Publicly

Available NOTES: G RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: ACRS NRR/DRPM/PERB

NUDOCS-ABSTRACT

RGN2 FILE 01 COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 RECXPIENT ID CODE/NAME GLEAVES,W NUDOCS FULLTEXT OE DIR COP1ES LTTR ENCL 1 1 1 1 1 1 1 1 EXTERNAL: NOAC 1 1 NRC PDR 1 1 NOTE TO ALL"RIDS" RECIPIENTS:

PLEASE HELP US TO REDUCE WASTE.TO HAVE YOUR NAME OR ORGANIZATION

REMOVED FROM DISTRIBUTION

LISTS OR REDUCE THE NUMBER OF COPIES RECEIVED BY YOU OR YOUR ORGANIZATION, CONTACT THE DOCUMENT CONTROL DESK (DCD)ON EXTENSION 415-2083 TOTAL NUMBER OF COPIES REQUIRED: LTTR 11 ENCL 11

Florida Power 5 Light Company,6351

S.Ocean Drive, Jensen Beach, FL 34957 April 28.l 998 L-98-108 10 CFR 52.201 U.S.Nuclear Regulatory

Commission

'Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 Reply to a Notice of Violation NRC Ins ection Re ort 98-01 EA 98-064 Florida Power and Light Company (FPL)has reviewed the subject Notice of Violation and, pursuant to 10 CFR$2.201, the responses to the violations

are attached.The violation resulted from the failure to remove the access authorization

of favorably terminated

contract employees.

FPL has concluded that the failure was not programmatic

in nature and resulted from human error.However, FPL understands

the significance

of the violation in that an unauthorized

person, as defined in our Physical Security Plan, gained access to the site's protected area.FPL has taken comprehensive

corrective

actions to resolve the identified

condition, and has reviewed the event for generic implications.

We are confident that our corrective

actions will prevent recurrence.

Please contact us with questions on the enclosed violation response.Very truly yours, Thomas F.Plunkett President Nuclear Division TFP/JAS/E JW Attachment

cc: Regional Administrator, USNRC, Region II Senior Resident Inspector, USNRC, St.Lucie Plant'ir805050266

'ir80428 PDR ADOCK 05000335 8 PDR an FPL Group company

St.Lucie Units 1 and 2 Docket Nos.50-335 and 50-389 L-98-108 Page 2 STATE OF FLORIDA))COUN'IY OF PALM BEACH)ss.Thomas F.Plunkett being first duly sworn, deposes and says: That he is President, Nuclear Division, of Florida Power&Light Company, the Licensee herein;That he has executed the foregoing document;that the statements

made in this document are true and correct to the best of his knowledge, information

and belief, and that he is authorized

to execute the document on behalf of said Licensee.7 Thomas F.Plunkett STATE OF FLORIDA COUNIY OF Sworn to and subscribed

before me this 8W day of I'/, 195&by Thomas F.Plunkett, who is personally

known to me.Name of N ry Public-S RObl ftl S.ECGnuu,, 1'~: Q=W COMMISSlON

f CC633<64 nap.Y:~:o!June 1, 2001"J o"ri80NOEO IHRU TROY fAIH SllRAPCE.uC.Print, type or stamp Commissioned

Name of Notary Public)

L-98-108 Attachment

P~se I Violation Facility Operating License Nos.DPR-67 and NPF-16, Amendment 151, dated May 16, 1997, require that the licensee shall fully implement and maintain in efFect all provisions

of the Commission

approved physical security, guard training and qualification, and safeguards

contingency

plans including amendments

made pursuant to the provisions

of the Miscellaneous

Amendments

and Search Requirements

revisions to 10 CFR 50.90 and 10 CFR 50.54(p).Section 13.4.4 of the licensee's

Physical Security Plan, Revision 50, dated November 24, 1997, states, in part,"Upon notification

of the voluntary termination

or the termination

for cause of an individual

authorized

unescorted

access, the Plant Security Supervision

shall ensure that the keycard and hand geometry access capabilities

are inactivated." Section 5.3(d)of the licensee's

Physical Security Plan, Revision 50, dated November 24, 1997, states, in part,"Only those individuals

with identified

need for access and having appropriate

authorization, shall be granted unescorted

vital area access." Contrary to the above, on December 31, 1997, plant security supervision

failed to implement Section 13.4.4 of the Physical Security Plan to ensure that a voluntarily

terminated

individual's

keycard and hand geometry access capabilities

were inactivated.

As a result, one unauthorized

individual's

unescorted

access to vital areas continued in violation of the requirements

of Section 5.3(d)of the Physical Security Plan between December 31, 1997, and January 2, 1998, and, in fact, the individual

entered the protected area on January 2, 1998.In addition, on December 31, 1997, plant security supervision

failed to implement Section 13.4.4 of the Physical Security Plan to ensure that a second favorably terminated

individual's

keycard and hand geometry were inactivated.

This is a Severity Level III Violation (Supplement

III).R~es ense 1.FPL concurs with the violation.

2.REASON FOR VIOLATION The cause of the violation was human error in that the individual

tasked with deleting the contractor

employees'adges

failed to follow established

plant procedures

for terminating

badges.

/'

L-98-108 Attachment

~Pa e2 3.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.Upon discovery on January 2,'1998, the access authorization

for both individuals

was terminated.

B.Terminations

of access authorization

in the plant's badging office were temporarily.

suspended.

C.As an interim action, all access termination

transactions

were accomplished

in the security operations

center (Secondary

Alarm Station)where an independent

verification

process existed.D.Appropriate

personnel disciplinary

actions were administered

to the accountable

FPL and contractor

employees.

4.'ORRECTIVE

STEPS TO AVOID FURTHER VIOLATIONS

A.The termination

of access process was reviewed and standardized

so that the badging office conducted access termination

in the same manner as the security operations

center.The revised procedure specifically

requires that an independent

verification

be accomplished

prior to the required termination

time.This was achieved on January 5, 1998.B.Access processing

and badging personnel were trained on the new termination

process discussed in Corrective

Action 4.A.above.Based on benchmarking

of other licensees, a Physical Security Plan (PSP)change (Revision 51)was made to permit 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> for removal of access authorization

for employee terminations

under favorable conditions.

Access authorization

terminations

under unfavorable

conditions

continue to be required to be completed immediately.

5.Full compliance

was achieved on January 2, 1998, with the removal of the access authorization

for both individuals

involved in the violation as stated in Corrective

Action 3.A.above.