IR 05000266/1997007

Ack Receipt of 970604 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-266/97-07 & 50-301/97-07 Issued on 970505.NOV Re Failure to Properly Search Vehicle & Implement Security Compensatory Measure

ML20148N069
Person / Time
Site:	Point Beach
Issue date:	06/20/1997
From:	Grobe J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Patulski S WISCONSIN ELECTRIC POWER CO.
References
50-266-97-07, 50-266-97-7, 50-301-97-07, 50-301-97-7, NUDOCS 9706260041
Download: ML20148N069 (1)

Text

. _ . . .__ _ _ . . _ - -

'

l June 20, 1997

! Mr. S. A. Patulski

'

l Site Vice President Point Beach Nuclear Plant Wisconsin Electric Power Company 6610 Nuclear Road Two Rivers, WI 54241 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORTS NO.

50-266/97007(DRS); 50-301/97007(DRS))

Dear Mr. Patuiski:

This will acknowledge receipt of your letter dated June 4,1997, in response to our letter dated May 5,1997, transmitting a Notice of Violation associated with the identification of your failure to properly search a vehicle and implement a security compensatory measure in a timely manner at your Point Beach Nuclear Plant.

We have reviewed your corrective actions for the specific violations referenced above and your analysis of why previous corrective actions for similar violations were not totally effective. We have no further questions at this time. These corrective actions will be examined during future inspections.

Sincerely,

/s/ John Jacobson (for)

John A. Grobe, Acting Director l

Division of Reactor Safety Docket No. 50-266 Docket No. 50-301 l Enclosure: Ltr 6/4/97 S. A. Patulski

! Wisconsin Electric to US NRC l cc w/ encl: R. R. Grigg, President and

'

Chief Operating Officer, WEPCo A. J. Cayia, Plant Manager Virgil Kanable, Chief, Boiler Section Lb

, Cheryl L. Parrino, Chairman,

'

Wisconsin Public Service Commission f State Liaison Officer

! i Distribution:

l 8"ga, Docket File w/ enc! Rlll PRR w/encI Rlli Enf. Cocrdinator w/enci

l 8 PUBLICLO? w/enci SRI, Pt. Beach w/enct TSS w/enct

!

g$ OC/LFDCB w/ encl LPM, NRR w/enci CAA1 w/enci !g DRP w/ encl A. B. Beach, Rlli w/ encl ev DRS w/encI J. L. Caldwell, Rllt w/ encl i 253076 lll.llll,lllll.lilljlliljlllllf i i l. lfil.ll:

'

8[8 DOCUMENT NAME: G:DRS\ pol 97007.TY To receive a copy of this document. Indicate in the box "C" = Copy w/o attach /end "E" = Copy w/ attach /end "N" = No copy

, gh OFFICE Rlll:DRS lg Rill:DRP lg Rill:DRp. lU Rlli:DRS _l DATE 6/jf97 Barge $Lk WgG7 6/p/97)

[

6b/97 OFFICIAL RECOF,D COPY l

,.,

-

'.

L

' Wisconsin

'

' Electnc POWER COMPANY l Point Beach Nuclear Plant (414) 755-2321 i

6610 Nucleor Rd.. Two Rivers. WI 54241

.

NPL 97-0328 10 CFR 2.201 I June 4,1997 l l

Document Control Desk U. S. NUCLEAR REGULATORY COMMISSION l Mail Station PI-137 i Washington, DC 20555 l l

Ladies / Gentlemen: 1 I

DOCKETS 50-266: 50-301 REPLY TO A NOTICE OF VIOLATION NRC INSPECTION REPORT NOS. 50-266/97007 (DRS) AND 50-301/97007 (DRS)

POINT BEACH NUCLEAR PLANT. UNITS 1 AND 2

!  !

In a letter from Mr. John A. Grobe dated May 5,1997, the Nuclear Regulatory Commission forwarded the results of a physical security inspection at our Point Beach Nuclear Plant conducted between March 31 and April 10,1997. This inspection report included a Notice of Violation that identified two violations of NRC requirements.

We have reviewed the Notice of Violation and, pursuant to the provisions of 10 CFR 2.201, have prepared a writter. response, which is included as an attachment to this letter.

We believe that tne attached reply is responsive to the Notice of Violation and fulfills the requirements identified in your May 5,1997, letter.

!

If you have any questions or require additional information regarding this response, please contact me.

!

l

Sincerely, f W n-Scott Site Vice President Attachment FAF/ lam

)

cc: NRC Regional Administrator NRC Resident Inspector ,

l ygjfpjg - t, A subsx/wyofHhvnsin Ene&v Comornon S$

_

-. . - _ . .- . _ _ - _ _ - .. . - -

-

. . l

.

, Attachemnt to NPL 97-0328  !

l DOCKETS 50-266 AND 50-301 i REPLY TO A NOTICE OF VIOLATION l NRC INSPECTION REPORT 50-266/97007 (DRS) AND 50-301/97007 (DRS)

POINT BEACH NUCLEAR PLANT UNITS 1 AND 2 l

l During an inspection conducted between March 31 and April 10,1997, two violations of NRC  ;

l requirements were identified. Inspection Report 50-266/97007 (DRS) and 50-301/97007 (DRS) and the i

Notice of Violation (Notice) transmitted to Wisconsin E!ectric on May 5,1997, provide details regarding the violations.

Section 3.F of Amendments 37 and 42 of the Facility Operating Licenses No. DPR-24 and DPR-27 for l

'

Units 1 and 2, respectively, requires the licensee to maintain in effect and fully implement all provisions of the Commission-approved Security Plans, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).

Violation 1 l

! " Paragraph 6.0 of Section 2.1 of the approved Point Beach Security Plan (PBSP) requires, in part, that an i officer who is not assigned response duties, monitors outages of the intrusion detection system (IDS) by using closed circuit television (CCTV) or being present at the effected IDS alarm zone.

l '

l Contrary to the above, on February 4,1997, for a period of 16 minutes an outage of Zone 10 of the IDS l was not continuously monitored, nor was an officer posted at the effected IDS alarm zone. The operators of the Central and Secondary Alarm Stations failed to ensure that the effected alarm zone was

!

monitored. This event was licensee-identified; however, previous corrective action to similar events did !

i not prevent recurrence. This is a repeat violation (50-266/97007-02; 50-301/97007-02)

This is a Severity Level IV violation (Supplement III)."

Resnonse to Violation i Reason for Violation The event occurred as a result of distractions in a high workload environment. This situation led to the operator's failure to implement procedural guidance and checklists for severe weather compensatory measures. Additionally, central alarm station (CAS) and secondary alarm station (SAS) operators failed to adhere to accepted communications standards, which contributed to the failure to implement appropriate compensatory measures.

.

D I

. _ . _ _ _ _ _ _ _ _ _____._..____. __ _._. _ _ __ _

- -

. ,

,

, Attachment to NFL 97-0328 Page 2 L

l I

Corrective Actions Taken:

A 30-day security Licensee Event Report, LER 266/97-S01-00, was submitted to the Commission on March 4,1997. The report contains details surrounding the event, causes for its occurrence, corrective actions taken, and corrective actions to be taken.

Corrective Action 5 of the Licensee Event Report stated that the CAS operator involved in the event was relieved of CAS/SAS duties. The involved CAS operator is presently participating in a recertification program. Upon successful completion of written and oral examinations, the j CAS operator will resume CAS/SAS duties.

Corrective Action 6 of the Licensee Event Report stated an engineering evaluation of our security system hardware would be completed by September 1,1997. Our efforts to address the immediate Unit 2 restart issues, followed by the restart of Unit 1, have caused us to re-evaluate our ability to complete our engineering evaluation by this date. We now anticipate completion of cur evaluation by October 31,1997. During our recent evaluation of this and previous events, improvement of this equipment has been identified as being an important aspect of our overall corrective action plan. In addition, during our recent visits to other facilities, the need to improve our security system hardwre was reinforced. Our current level of equipment workarounds and the number of alarms experienced by our system was found to be significantly greater than at other facilities.

.

Wisconsin Electric senior management supported the use of a nationally recognized nuclear consultant to conduct a common cause evaluation of these CAS errors. This common cause l

evaluation was completed on May 6,1997. The common cause evaluation considered security personnel errors that have occurred in the past two years. The purpose of the evaluation was to ensure that all reasonable actions that can be taken to reduce performance errors either have been taken or are scheduled to be completed. The evaluation identified the following as potential causes for the CAS errors:

o Human error traps continue to exist for the CAS operators.

.

o The technology, design, and condition of security detection and assessment equipment have increased the workload for the CAS operators. This results from the frequency of nuisance alarms and the requirement to implement workarounds.

o The majority of the program failures occur during storms or inclement weather that present the operators with high workload and time pressure conditions.

< 6 l ,

During high workload and time pressure situations, the cognitive abilities of the CAS l

-

'N operators are stressed to a level that potentially increases the likelihood of errors.

The complete report, which we consider proprietary, is available for review by Commission

! representatives at Point Beach Nuclear Pfar.t.

1 1 a,

l l

.- _ .

-

1 . .

'

l

'

Attachment to NPL 97-0328 l Page 3 l

Previous Corrective Actican l We believed that our previous evaluations of similar events and the subsequent corrective actions implemented in response to those events had accurately identified the causes and contributing factors.

One of our identified corrective actions was a focus on reducing CAS operator distractions, but significant changes in the conduct of operations were not adequately considered. Additionally, the number of equipment workarounds resulting from aging security system hardware has been brought to the attention of senior management as a contributing factor to these events. Previously, replacement of security system hardware was maintained as a low priority within our evaluation and modification process.

Corrective Actions to be Taken:

.

LER 266/97-S01-00 describes corrective action commitment.e previously docketed with the Commission.

.

In addition to the connaitments identified in the Licensee Event Report, review of the common cause evaluation is in progress. Corrective actions associated with reducing the high workload and distractions of the CAS and SAS operators are being developed. The review will be completed and an action plan will be developed by June 30,1997.

Changes currently in progress, which will become part of our overall action plan, include adding a CAS/SAS supervisor. This individual will provide overall coordination and direction of CAS/SAS activities. The CAS/SAS supervisor will also prepare for and arrange for security support of plant activities, that currently would be handled by the CAS operator.

On April 2,1997, a plant-wide initiative of reducing the use of Gai-tronics for routine communications was initiated. This reduced use of the Gai tronics system has been successful in reducing the distraction for CAS/SAS operations.

Safeguards Information not necessary for CAS operation will be removed from CAS. Personnel traffic solely for the retrieval of this information will be eliminated, thereby further reducing the number of distractions that have hampered effective CAS operation.

Date Full Compliance Will be Achieved:

Full compliance with NRC requirements was achieved on February 4,1997, when compensatory l measures in response to the intrusion detection alarm zone outage were fully implemented.

!

.. . . . . .. - - - - . _ .- - . . - _ _ - - - - . . . . . - -

-

, .

,

Attachment to NPL 97-0328

.

Page 4

!

l VIOLATION 2

" Paragraph 3.4.1 of Section 2.4 of the approved PBSP requires, in part, that vehicles ,

engine compartment, the protected area. undercarriage, and cargo area searched for unauthorized ma Contrary to the above, on April 3,1997, an NRC inspector observed an inadequate searc The officer failed to search an easily accessible storage compartment located on th vehicle's cab. Previous corrective action to a similar event did not prevent recurren violation (50-266/97-007-03; 50-301/97007-03).

This is a Severity Level IV violation (Supplement III)."

Resnonse to Violation 2 '

Reason for Violation The violation occurred as a result ofinsufficient management oversight to ensure security o performance is consistent and thorough in all assigned duties. )

i Corrective Actions Taken:

.

As noted in the inspection report, when the deficiencies were brought to the attention of the in security officer, the search was adequately completed. The security officer was counseled and received retraining in search techniques. In addition, the security force was briefed on the event

.

Routine security contractor management observation of vehicle searches was initiated. The standards and expectations for vehicle searching is reinforced through observation of th)

As discussed in our reply of January 14,1997, to the first vehicle search Notice of Violat effort between Wisconsin Electric, Schneider National, Inc., and the Wisconsin State Patrol was ,

t undertaken to provide security personnel with " hands-on" training in the searching oflarge, road vehicles. The first of two training sessions was completed in April,1997.

Previous Corrective Actions: t

Corrective action for the previous similar violation did not include management oversight search activities. Prior to this most recent violation, observations of routine daily search activities we (

not conducted and security personnel search activity performance was only measured through th

!

of search-specific drills. Since this violation was identified, fifteen management observations were

[ performed in May, three of which identified deficient search techniques.

i

_

. -- . . - _ - - - . - . - . - . _ _ - - . . - . . . - . - _ - - . . - . . - . - - . - .

'

\ . .

t ' Attaciunent to NPL 97-0328

, Page 5 j i

!

Corrective Actions to be Takem

.

A security officerjob observation program will be developed and imple Our management observations of vehicle search activities will continue th

, .

development of this new program.  !

.

As indicated in our letter to you of May 12,1997, we were unable to co s.surity April 30,1997. personnel in over-the-road vehicle search techniques by our orl The second training session was canceled because of an unavoid emergency that affected the instructor. The second training session is bein; i an ongoing NRC physical security inspection. Our revised corrective actio extended to June 30,1997, in order to ensure that the lessons leamed fro

! factored, as appropriate, into security procedures. That commitment re!

Date Full Compliance was Achieved:

! Full compliance with NRC requirements was achieved on April 3,1997. The!

i actions being taken will enhance our vehicle search program. l

!

t

!

t

!

,

l i

i e

i

!

s