ML20199K886
| ML20199K886 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/24/1997 |
| From: | Hagan J ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-416-97-20, GNRO-97-00115, GNRO-97-115, NUDOCS 9712010226 | |
| Download: ML20199K886 (4) | |
Text
Entergy operations,Inc.
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Tel(01437 6408 Fai (01437 2795 Joseph J. Hogan v ;e heseent
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November 24, 1997 U.S. Nuclear Regulatory Commission Mail Station P1-37 Washington, D.C. 20555 Attention:
Document Contro' Desk
Subject:
Grand Gulf Nuclear Station Docket No. 50-416 License No. NPF-29 Reply to a Notice of Violation Failure to Report Dark Areas in a Temporary Structure Report No. 50-416/97 20, dated 10/31/97 (GNRI-97/00180)
GNRO-97/00115 Gentlemen:
Entergy Operations, Inc. hereby submits this response to Notice of Violation 50-416/97-20-03.
Yours truly, i
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Response to otice of Violation 50-416/97 20-03 cc:
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November 24, 1997 GNRO.g7/00115 Page 2 of 2 cc:
Ms. J. L. Dixon-Herrity, GGNS Senior Resident (w/a)
Mr. L. J. Smith (Wise Carter) (w/a)
Mr. N. S. Reynolds (w/a)
Mr. H. L. Thomas (w/o)
Mr. E. W. Merschoff (w/a)
Regional Administrator U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 400.
l Region IV Arlington, TX 76011 Mr. J. N. Donohew, Project Manager (w/2)
Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Mail Stop 13H3 Washington, D.C. 20555 l
Attachment to GNRO 97/00115 Page1t.17 Notice of Violation 97 20-03 License Condition 2.E of the licensee's facility operating license requires that the licensee fully implement and maintain in effect the Commission approved physical security ) plan, including amendments and changes made pursuant te the authority of 10 CFR 50.54(p.
Part 1 of the licensee's Physical Security Plan, Revision 28, states, in part.
- Station Procedures, available at the Station, provide the detailed instructions necessary to implement the Plan."
Section 7.3 requires that illumination in the protected area be at least 0.2 footcandles measured on a horizontal plane at ground level.
Security Section Procedere 11 S-51 1, " Security Patrol Functicas', Revision 7, Paragraph 6.5.2, requires that security personnel oil patrol check for inoperative lights and " dark" areas in which an intruder could seek concealment. Paragraph 2.7 requires that security section personnel report unusual or degraded condi<lons.
Contrary to the above, as of October 11,1997, security patrols had not reported dark areas in a temporary covered maintenance work area in the protected area. Lighting surveys conducted in the area on October 15,1997, identified that lighting in most of the area was less than 0.2 footcandle.
This is a Severity Level IV violation (Supplement !II) (50-416/9720-03).
l.
Admission or Denial of the Alleged Violation Entergy Operations, Inc. admits to this violation.
II.
The Reason for the Violation,if Admitted This notice of violation cites failure of security patrols to report dark areas in a temporary building within the protected area, and its associated inspection report identifies that some vehicles parked next to the same work area did not have sufficient light under them.
Site procedures require lights to be installed underneath vehicles during the hours of darkness if lighting is less than 0.2 foot-candle power. If implemented effectively, this would have met the intent of the security alan. However, this implementing procedure is sensitive to personnel error and equipm t, failure, such as burned out light bulbs. In this case, the cause was inattention to detail by the recurity patrols, in not promptly identifying and reporting the failure to meet procedural requirements.
Compared with the securdy plan, the security section implementing procedures are relatively restrictive and indexible. The Physical Security Plan, Revision 28, states that shadows cast by objects such as temporarily parked vehicles, building eaves and overhangs are not considered in (the 0.2 foot-candle) criteria if assessment capability is not significantly impaired. The areas are to be evaluated and, if necessary, compensatory c: tion taken. Temporary lighting is mentioned as an example of compensatory action that could be taken if necessary. Our implementing procedure goes directly to a requirement for temporary lighting, although in many cases, the shadows of interest do not significantly impair assessment capability. Thus, a contributing factor is that the security eretion implementing procedure, which appears to
Attachment to GNRO-97/00115 Page 2 of 2
. exceed the Physical Security Plan requirements, in effect, complicates the situation.
This is because many of the areas covered by this paragraph of the Physical Security Plan would be found to not significantly impair assessment capability and thus require no compensatory action. If properly implemented, the Physical Security Plan would ensure our attention would be focused on the cases that significantly impair assessment capability.
The security plan is cilent in regards to the interior lighting levels for buildings within the protected area, temporary or otherwise. Lighting underneath portable or temporary buildings is addressed in Security Section Procedure 11-S-51 1, Security Patrol Functions, Revision 7, Paragraph 6.5.2, which states: ' Security personnel on patrol check for inoperative lights and ' dark" areas in which an intruder could seek concealment and in the case of portable or temporary buildings inside the Protected Area, ensure the structure is lighted underneath with sufficient candle power to prevent concealment of a person or ensure the trailer / building has skirting around it.
- In this case, the structure was constructed on a concrete slab which extended upward from ground level approximately 30 inches with no opening underneath.
We believe we were not required by the security plan or its associated implementing procedures to light the inside of a temporary structure in all cases. Rather, these programs would require an evaluation of the impact of the structure to determine if it significantly impairs assessment capability. However, as the inspector noted, there were several other cases of failure to light under temporarily parked vehicles. Since failure to report and assess these issues does not conform to our security plan or associated implemonting procedures, we do not contest the violation.
Ill.
Corrective Steps Which Have Been Taken and Results Achieved Temporary lightir>g was promptly restored for the parked vehicles as discussed in the inspection report. The temporary building has been removed from the protected area.
Security shift captains have been re-instructed concerning the requirements for, and importance of, checking for lighting deficiencies, reporting, and assessing / compensating questionable areas.
IV.
Corrective Steps to be Taken to Preclude Further Violations Security plan implementing procedures will be reviewed to ensure they appropriately implement security plan requirements. We expect the review to find that more emphasis should be placed on evaluation of potentialimpairment of assessment capability due to shadows cast by objects. The blanket use of temporary lighting in addressing allissues may not be appropriate. The emphasis of any resulting procedure changes will be on more reliably ensuring the requirements of the security plan are met and 'hereby precluding further violations.
V.
Date When Full Compliance Will be Achieved All actions are scheduled to be completed by March 31.199A.