ML17229A088

Responds to Violations Noted in Insp Repts 50-335/96-16 & 50-389/96-16.Corrective Actions:Revised Security Procedure 0006125, Reporting of Safeguards Events, & Will Develop Security Event Response Guidance

ML17229A088
Person / Time
Site:	Saint Lucie
Issue date:	10/18/1996
From:	PLUNKETT T F FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
L-96-255, NUDOCS 9610250150
Download: ML17229A088 (13)

See also: IR 05000335/1996016

Text

CATEGORY j.REGULATORY

INFORMATION-

DISTRIBUTION

SYSTEM (RIDS)*ACCESSION'NBR:9610250150

DOC.DATE: 96/10/18 NOTARIZED:

NO FACIL:50-335

St.Lucie Plant, Unit 1, Florida Power a Light Co.50-389 St.Lucie Plant, Unit 2, Florida Power 6 Light Co.AUTH.NAME AUTHOR AFFILIATION

PLUNKETT,T.F.

Florida Power a Light Co.RECIP.NAME

RECIPIENT AFFILIATION

Document Control Branch (Document Control Desk)SUBJECT: Responds to violations

noted in insp repts 50-335/96-16

a 50-389/96-16.Corrective

actions:revised

security procedure 0006125,"Reporting

of Safeguards

Events," 6 will develop security event response guidance.DISTRIBUTION

CODE: IE01D COPIES RECEIVED:LTR

ENCL SIZE: TITLE: General (50 Dkt)-Insp Rept/Notice

of Violation Response NOTES: DOCKET g 05000335 05000389 RECIPIENT ID CODE/NAME PD2-3 PD INTERNAL: ACRS C FIL CENTER NRR DRC HHFB NRR/DRPM/PERB

OE DIR RGN2 FILE 01 EXTERNAL: LITCO BRYCE,J H NRC PDR COPIES LTTR ENCL 1 1 2 2 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 RECIPIENT ID CODE/NAME WIENS,L.AEOD/SPD/RAB

DEDRO NRR/DISP/PIPB

NRR/DRPM/PECB

NUDOCS-ABSTRACT

OGC/HDS3 NOAC COPIES LTTR ENCL 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 D E N T'OTE 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 19 ENCL 19

Florida Power 5 Light Company, P.O.Box 14000, Juno Beach, FL 33408.0420

OCT18$996 L-96-255 10 CFR 2.201 U.S.Nuclear Regulatory

Commission

Attn: Document Control Desk Washington, D.C.20555 Re: St.Lucie Units 1 and 2 Docket No.50-335 and 50-389 Reply to a Notice of Violation NRC S ecial Ins ection Re ort 96-16 Florida Power and Light Company has reviewed the subject Notice of Violation and, pursuant to 10 CFR 2.201, the responses to the violations

are attached.Very truly yours, T.F.Plunkett President Nuclear Division TFP/JAS/EJW

Attachment

cc: Stewart D.Ebneter, Regional Administrator, USNRC Region II Senior Resident Inspector, USNRC, St.Lucie Plant~.,'r j/l~9trr f 0250i 50 5000335 0 96i018 pDR ADOCK 0 6 an FPL Group company

~~L-96-255 Attachment

Re I to a Notice of Violation VIOLATION A: 10 CFR 73.71, Reporting of Safeguards

Events, Appendix G, (a)(3)"Reportable

Safeguards

Events," requires the licensee to report to the NRC within one hour following discovery, followed by a written report within 30 days, events which cause interruption

of normal operations

through tampering with controls including the security system.The licensee's

Security Procedure, SP-0006125, Reporting of Safeguards

Events, Revision 9, dated April 20, 1995, Paragraph 8.2 (I)defines one of those specific events as being a"confirmed

tampering of suspicious

origin with safety or security equipment." Contrary to the above on July 29, 1996, the licensee failed to report the confirmed tampering with security equipment (locks)within one hour to the NRC.This is a Severity Level IV violation (Supplement

ID)RESPONSE: 1.FPL concurs with the violation.

2.REASON FOR VIOLATION The reason for the violation was personnel error in that the event was not correctly identified

as involving tampering.

A contributing

factor to the error was inadequate

procedural

guidance.The security event reporting procedure in use on July 26, 1996, did not provide a clear definition

of tampering nor clear guidance for making reportability

determinations

for tampering events.On July 26, 1996, glue was discovered

in the lock core of an entry door to the Unit 2 Control Element Drive Mechanism Control System (CEDMCS)room.Further inspection

revealed that several padlock/door

lock sets (a total of eleven locks)on both units had been similarly vandalized.

The affected locks were determined

not to adversely impact plant operations

or the Physical Security Plan.Based on this determination, it was incorrectly

interpreted

that this event did not constitute"tampering" as described in St.Lucie Plant Security Procedure No.0006125,"Reporting

of Safeguards

Events." The procedure required

~~~~L-96-255 Attachment

Re 1 to a Notice of Violation"confirmed

tampering of suspicious

origin with safety or security equipment" to be reported as a Safeguards

Event.Failure to identify this incident as"tampering

with security/safety

equipment" resulted in utility personnel not reporting the incident to the Nuclear Regulatory

Commission (NRC)within one hour, as required.3.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED The event was reported to the NRC in Licensee Event Report 96-S01 on September 11, 1996, in FPL's 30 day report on the discovery of additional

tampering of key-locked switches on August 14, 1996.CORRECTIVE

STEPS TO AVOID FURTHER VIOLATIONS

A.Security Procedure No.0006125,"Reporting

of Safeguards

Events" was revised to clarify the definition

of"tampering" and the reportability

determinations

for similar events.B.Security event response guidance will be developed to provide for actions in response to an event that resulted from, or is suspected to have resulted from, deliberate

or malicious acts directed against plant safety or security equipment.

This action will be completed by October 31, 1996.5.Full compliance

was achieved on September 11, 1996 with the completion

of Item 3 above.VIOLATION B: Technical Specification 6.8.1.a requires that written procedures

be established, implemented, and maintained

covering the activities

recommended

in Appendix A of Regulatory

Guide 1.33, Revision 2, February 1978.Appendix A, paragraph l.c includes administrative

procedures

for equipment control.Administrative

Procedure No.2-0010123,"Administrative

Control of Valves, Locks and Switches," Revision 73 implements

this requirement

with respect to administratively

controlled

keys.Step 8.2.1 of this procedure states in part that cubicles containing

critical controls in remote locations shall be locked and the keys maintained

under Administrative

Control.Contrary to the above, on August 19, 1996, keys used for the control of Power Operated Relief Valves V1474 and V1475 located in the 2A and 2B electrical

penetration

rooms respectively, were located in the unlocked cubicles which house

L-96-255 Attachment

Re I to a Notice of Violation these switches.This is a Severity Level IV violation (Supplement

I)RESPONSE: 1.FPL concurs with the violation, as clarified below.2.REASON FOR VIOLATION Re uirements Step 8.1.2.of Administrative

Procedure (AP)No.2-0010123,"Administrative

Control of Valves, Locks and Switches," states, in part, that: A valve, switch or fuse is placed under Administrative

Control by: A.Physically

locking the valve or switch Step 8.2.1.of AP No.2-0010123 states, in part, that: Cubicles and racks containing

critical instrumentation

and controls shall be locked and the keys maintained

under administrative

control.~Back round The power operated relief valve (PORV)electrical

isolation switches are used to electrically

isolate PORV operation from the control room in the event of a fire requiring reactor shutdown and evacuation

of the control room.The electrical

isolation switches are located in the electrical

penetration

room and are key locked switches housed in protective

boxes.Since the electrical

isolation switches themselves

are key locked, the protective

boxes in which the key locked electrical

isolation switches are housed are not required to be locked in accordance

with AP No.2-0010123.

The keys used for the electrical

isolation of the PORVs require administrative

control in accordance

with AP No.2-0010123.

Maintaining

the keys for the PORV electrical

isolation key locked switches in the unsecured switch boxes violated the administrative

control requirements

of AP No.2-0010123.

L-96-255 Attachment

Re 1 to a Notice of Violation Discussion

The cause of the violation was inadequate

administrative

controls to ensure adequate key accessibility

and while, at the same time, maintaining

key control.The development

and review of the original procedures

for control room inaccessibility

focused only on the ability of the operators to carry out their shutdown functions.

The review was not sufficient

in that, while the procedure assured the accessibility

of keys post-control

room evacuation, it did not ensure that the keys were maintained

under adequate administrative

control.Operating procedure ONOP 2-0030135,"Control Room Inaccessibility," stated that a backup set of the PORV electrical

isolation switch keys are located in the switch boxes in the electrical

penetration

room (one set of keys is also maintained

in the locked key box on the remote shutdown panel).Maintaining

a set of keys in the switch boxes was intended to ensure that the keys were accessible

to support control room evacuation.

Procedure AP No.2-0010123, in step 8.1.2.A, lists one means of administrative

control for switches to be the physical locking of the switch.Placing the keys inside the unsecured switch boxes, in accordance

with ONOP 2-0030135, violated the administrative

control requirements

of AP No.2-0010123.

3.CORRECTIVE

STEPS TAKEN AND THE RESULTS ACHIEVED A.The Unit 2 PORV electrical

isolation switch keys were removed from the unsecured switch boxes.Control of the PORV electrical

isolation switch keys was assigned to a utility nonlicensed

operator, the senior nuclear plant operator (SNPO).B.The requirement

for the PORV electrical

isolation switch keys to be kept in the unsecured switch boxes was deleted from ONOP 2-0030135.

This action was completed by August 29, 1996.CORRECTIVE

STEPS TO AVOID FURTHER VIOLATIONS

A.Physical custody of the PORV electrical

isolation switch keys was assigned to the SNPO, who maintains them on the watchstanding

shift key ring.This was done to ensure both the control of the keys as well as their availability

to operate the switches in a timely manner, if required.This resolves the previous conflict between the operating procedure and administrative

procedure.

The chain of custody for the keys is maintained

by the SNPO acknowledging

custody of the keys, via his signature, on Check Sheet 2, Nuclear Plant

L-96-255 Attachment

Re I to a Notice of Violation 0 erator/SNPO

Turnover Check Sheet of AP No.0010120, Conduct of~Oeretioos.

B.Procedures

AP No.1-0010123 and AP No.2-0010123 (for Units 1 and 2, respectively)

will be revised to add to each procedure a list of key rings and keys held by each watchstander.

This will also ensure the periodic performance

of a key inventory.

The procedure revisions will be completed by October 31, 1996.C.The potential for additional

previously

unrecognized

procedural

conflicts in Unit 2 procedures

AP No.2-0010123 and ONOP 2-0030135 concerning

key and lock control was reviewed and no additional

conflicts were identified.

D.The potential for previously

unrecognized

procedural

conflicts in Unit 1 procedures

AP No.1-0010123,"Administrative

Control of Valves, Locks and Switches," and ONOP 1-0030135,"Control Room Inaccessibility," concerning

key and lock control was reviewed and no additional

conflicts were identified.

E.Programmatic

improvements

to the St.Lucie Plant's administrative

control of keys will be made.The changes being considered

include: 1)Stricter shift controls and accountability

for keys checked out by the operating crew during the operating shift;2)A review of the key control log at shift turnover meetings to confirm shift to shift control of administratively

controlled

keys;3)Changes to the Operations

and Security procedures

to define actions and notifications

to be taken in the event of loss of control of administratively

controlled

keys;and, 4)The establishment

of a site-wide numbering system for controlled

keys to ensure better response to missing or lost key events.The evaluation

and implementation

of changes determined

to be required will be completed by November 29, 1996.The quality of St.Lucie Plant procedures, and revisions to those procedures, as well as the quality of procedures

being developed to implement plant process

L-96-255 Attachment

Re 1 to a Notice of Violation improvements, are the focus of management

attention and action.In order to ensure that plant procedures

are of consistent

quality, St.Lucie Plant has formed the Procedures

Development

Group within the Information

Services Department.

It is intended that this group will ultimately

be responsible

for the development

of, and revisions to, plant procedures.

The focused accountability

for the development, maintenance, and administration

of plant procedures

will help to ensure that procedural

conflicts such as the one identified

by this violation will be prevented from occurring for new procedures, and systematically

identified

and corrected, if present in existing procedures.

5.Full compliance

was achieved on August 29, 1996, with the completion

the actions identified

in Item 3 above.