IR 05000010/1997002

Ack Receipt of 970312 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-010/97-02, 50-237/97-02 & 50-249/97-02

ML20137K231
Person / Time
Site:	Dresden
Issue date:	03/21/1997
From:	Grant G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jamila Perry COMMONWEALTH EDISON CO.
References
NUDOCS 9704040273
Download: ML20137K231 (2)

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l March 21, 1997

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Mr. J. Site Vice President Dresden Nuclear Power Station Commonwealth Edison Company

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6500 North Dresden Road Morris, IL 60450 i SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS 50-010/97002(DRS); l 4 50-237/97002(DRS); 50-249/97002(DRS))

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Dear Mr. Perry:

This will acknowledge receipt of your letter dated March 12,1997, in response to our letter dated February 12,1997, transmitting a Notice of Violation associated with your

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failure to properly imple. ment personnel access authorization to a vital area at your Dresden Nuclear Power Station.

We have reviewed your corrective actions and have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely,

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/s/ Melvyn Leach (for) )

Geoffrey E. Grant, Director Division of Reactor Safety ,

Docket Nos. 50-10; 50-237; 50-249 Licenses No. DPR-02; DPR-19; DRP-25

't i Enclosure: Ltr dtd 3/12/97 J. l

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Dresden to USNRC 4

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See Attached Distribution

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DOCUMENT NAME: G:\DRS\DRE03217.DRS 3' '.

To receive a copy of this document, indicate in the box: "C" = Copy without attachment / enclosure "E" = Copy with attachment / enclosure "N" = No copy 0FFICE RIII e u 6 RII b ///, 9 RIII _

gj RIII lN l NAME TMadd4Jip JCrelF ~ PHiland f1Vr MLeach/GGrant *

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DATE 03/Zo'/97 03/'J6/97 03/ :L f)/97 03/.V /97 0FFICIAL RECORD COPY 9704040273 970321 '

PDR ADOCK 05000010 l G PDR 183.Ill!Epip.ll.N.RNE I

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J. March 21, 1997 cc w/o encl: T. J. Maiman, Senior Vice President,

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Nuclear Operations Division D. A. Sager, Vice President, Generation Support H. W. Keiser, Chief Nuclear Operating Officer T. Nauman, Station Manager, Unit 1 M. Heffley, Station Manager, Units 2 and 3 '

F. Spangenberg, Regulatory Assurance Supervisor 1. Johnson, Acting Nuclear Regulatory Services Manager cc w/ encl: Document Control Desk - Licensing Richard Hubbard Nathan Schloss, Economist, Office of the Attorney General State Liaison Officer Chairman, Illinois Commerce Commission Distribution:

Docket File w/ encl SRis, Dresden, LaSalle, R. A. Capra, NRR w/enci !

PUBLIC AE2R' w/enci Quad Cities w/ encl TSS w/enci OC/LFDCB w/enci C. Pederson, Rlll w/ encl CAA1 w/ encl DRP w/ encl LPM, NRR w/ encl DRS w/enct A. B. Beach, Rlil w/ encl Rill PRR w/enci Rlli Enf. Coordinator w/enci

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, Dreslen Generating Mation 1 6MD) North Drexten Ro.nl i

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Morro. II. G H MI rei siw 62 2<>20 March 12,1997 JSPLTR: 97-0053 I

U. S. Nuclear Regulatory Commission  !

ATTN: Document Control Desk Washington, D. C. 20555

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Subject: Dresden Nuclear Power Station Units 2 and 3 Reply to a Notice of Violation Inspection Repon 50-010,237,249/97002.

NRC Docket Numbers50-010,50-237, and 50-249 Reference: G. E. Grant letter to J. S. Perry, dated February 12,1997, transmitting NRC Inspection Report 50-010,237,249/97002 and Notice of Violation

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The purpose of this letter is to provide Comed's reply to a Notice of Violation transmitted in the reference letter. Specifically, the violation is related to contractor personnel who were granted access authorization to a vital area, even though their work related duties i did not require such access.

Dresden recognizes the significance of this violation and has taken aggressive action to !

preclude its recurrence. The attachment to this letter provides Dresden's reply to the

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Notice of Violation along with corrective actions to preclude recurrence.

This letter contains the following new commitments:

' * Revise Dresden Administrative Procedure (DAP) 13-01 " Station Access" to emphasize the importance of assuring that appropriate status levels are issued to personnel for work related purposes. Additionally, this revision will provide for the assignment of access level to be completed by security badge fabrication personnel.

Therefore, individuals who authorize site access will no longer determine the status level assignment.

. Review existing station access status levels to determine if certain status levels can be

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changed to funher :i.# the access to specific areas of the station. This review will also determine if additional status levels need to be created for specific vital areas.

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t March 12,1997

l e Develop and provide training for all personnel who can authorize station access. This

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training will include the regulatory requirements of 10 CFR 73.55, the Station Security

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. Plan and DAP 13-01 and stress the importance of conducting a more thorough review of status levels during the 31 day access authorization review.

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• Establish a method to conduct random verifications of status level assignments with personnel who can authorize station access to assure appropriate status levels have i been issued

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)- e: Perform an effectiveness review of these corrective actions to ensure regulatory j compliance.

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a i e Since the initial review conducted by the Security organization only encompassed j

i contractor personnel, all personnel who perform the 31 day access authorization

reviews will be required to conduct an additional status level review which will l encompass all Commonwealth Edison and contractor personnel who are badged at the station. This will be done upon completion of the above mentioned training to assure that all personnel who are granted unescorted access have the appropriate status level i required to perform their duties.

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i If there are any questions concerning this letter, please refer them to Mr. Frank j Spangenberg, Dresden Station Regulatory Assurance Manager, at (815) 942-2920, extension 3800.  ;

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Sincerely,

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. Stephen Perry Site Vice President i

L Dresden Station

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l Attachment

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cc: A. Bill Beach, Regional Administrator, Region III

l P. L. Hiland, Branch Chief, Division of Reactor Projects, Region III

! J. F. Stang, Project Manager, NRR (Unit 2/3)

i Senior Resident Inspector, Dresden L Office of Nuclear Facility Safety - IDNS

File

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ATTACHMENT RESPONSE TO NOTICE OF VIOLATION l NRC INSPECTION REPORT {

50-010/97002: 50-237/97002: 50-249/97002

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VIOLATION: l

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E This violation, as written in the NRC inspection report, contains Safeguards Information which will not be included in this response. The violation is related to contractor  !

personnel who were granted access authorization to a vital area, even though their work l

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related duties did not require such access. l

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REASON FOR VIOLATION:

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A review of this violation concluded that the individuals involved in the event were assigned the wrong access level upon initial badging at Dresden. Additionally, some personnel who conduct the 31 day access authorization review were unaware of the requirements of Dresden Administrative Procedure (DAP) 13-01 " Station Access." There were 41 contractor personnel identified who had access to the vital area identified in the

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Inspection Report who did not require access to the area for work related purposes. l There were 10 individuals who perform 31 day access authorization reviews who were  !

responsible for these 41 contractor personnel. Six of these 10 individuals were

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interviewed to determine their understanding of their responsibilities. These interviews verified that two personnel were not adhering to the procedure nor did they fully i understand their responsibilities. They also did not follow the instmetions that are contained within the "Thiny one Day Site Access and Status Level Review" form which is

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j routed to all personnel who conduct the reviews. This form instmets personnel to

" reference DAP 13-01, item #6 " Access Review" for instructions." It further instmets these personnel to review the list of personnel for whom they are responsible, which is attached to the form, and determine that each individual listed has the appropriate status j level.

The Security organization currently conducts a monthly ten percent review of 31 day access review listings, prior to distribution. During this review, some individuals had been identified who did not require the status levels that were assigned to them. These individuals were identified by the fact that the company or employer usually had no need

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for entry to certain areas. In these instances, the status levels were adjusted to an appropriate level. However, it has been determined that this review by the Security organization is not capable ofidentifying which employees of the larger companies need access to cenain areas and which employees do not need the access.

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t-Personnel who conduct the 31 day access authorization review are not provided with formal or informal instruction and the Security organization relied upon the instructions in DAP 13-01 as the only method of assuring that these reviews were properly completed.

Personnel were also unaware of the regulatory requirements of 10 CFR 73.55 and the Station Security Plan for conducting a 31 day access authorization review. Though the instructions on the Access and Status Level Review form direct personnel to determine ;

that each individual listed has the appropriate status level, two personnel who were '

interviewed believed that they were only conducting a review to determine if personnel-still required access to the station, rather than access to specific areas within the station.

These two individuals stated they were also unaware of the various locations that certain status levels allow access, though a form that describes all areas of access accompanies each review. I

I CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED:

The Security organization conducted a review of the fifteen contractor companies that were identified during the inspection to determine how many contractor personnel had status levels that would allow access to the identified area. A total of 41 contractor personnel were identified with access to this area who did not require access for work related purposes. On January 24,1997, access to this area was revoked for these 41 personnel.

The Security organization then conducted a review of all remaining contractor companies l on site to determine if there were any additional contractor personnel who also had status j levels that would allow access to the identified area. An additional 45 personnel who did not require access for work related purposes were identified during this review. On January 29,1997, access to this area was revoked for these additional 45 personnel.

On January 28,1997, the Station Services Director issued a memorandum to all station personnel who conduct the 31 day access authorization reviews. Attached to this ,

memorandum was a copy of the " Thirty one Day Site Access and Status Level Review" l form. Paragraphs two and four of the form were highlighted to emphasize the basis for i unescorted access and status levels as well as assuring individuals have the appropriate 1 status levels. Since the issuance of this memorandum there has been a substantial increase in requests for status level revisions.

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l CORRECTIVE STEPS TAKEN TO AVOID FURTHER VIOLATION:

The Dresden Station Security organization will:

Revise DAP 13-01 " Station Access" to emphasize the imponance of assuring that appropriate status levels are issued to personnel for work related purposes.

Additionally, this revision will provide for the assignment of access level to be completed by security badge fabrication personnel. Therefore, individuals who authorize site access will no longer determine the status level assignment.

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(NTS# 2371009700201 A)

• Review existing station access status levels to determine if certain status levels can be

. changed to funher limit the access to specific areas of the station. This review will also determine if additional status levels need to be created for specific vital areas.

(NTS# 2371009700201D)

• Develop and provide training for all personnel who can authorize station access. This training will include the regulatory requirements of 10 CFR 73.55, the Station Security Plan and DAP 13-01 and stress the importance of conducting a more thorough review ofstatus levels during the 31 day access authorization review. j (NTS# 2371009700201B) 1

Establish a method to conduct random verifications of status level assignments with personnel who can authorize station access to assure appropriate status levels have I been issued. (NTS# 2371009700201E)

Perform an effectiveness review of these corrective actions to ensure regulatory compliance. (NTS# 2371009700201ER)

Since the initial review conducted by the Security organization only encompassed I contractor personnel, all personnel who perform the 31 day access authorization reviews j will be required to conduct an additional status level review which will encompass all  !

Commonwealth Edison and contractor personnel who are badged at the station. This will j

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be done upon completion of the above mentioned training to assure that all personnel who are granted unescorted access have the appropriate status level required to perform their duties. (NTS# 2371009700201C) ~

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DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED

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Compliance with regards to contractor personnel granted unescorted access who did not

require access to the vital area identified in the Inspection Repon for work related ;

purposes was achieved on January 29,1997. This was accomplished when the status levels

of all 86 contractor personnel identified during the Security organization review were

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lowered to a level that would no longer allow access to that area.

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d The completion of the training for all personnel who conduct the access authorization

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reviews and the subsequent status level review of all Commonwealth Edison and  !

contractor personnel who are badged at Dresden Station will be completed by {

July 25,1997. l

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