ML20203L051

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-324/97-12 & 50-325/97-12 Issued on 971208.NRC Considered Basis for Util Denial of Violation E & Concludes That Violation Occurred

ML20203L051
Person / Time
Site:	Brunswick
Issue date:	02/13/1998
From:	Mallett B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Hinnant C CAROLINA POWER & LIGHT CO.
References
50-324-97-12, 50-325-97-12, EA-98-057, EA-98-57, NUDOCS 9803050316
Download: ML20203L051 (9)

See also: IR 05000324/1997012

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February 13, 1998

EA 98 057

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Carolina Power .1d Light Company

ATTN: Mr. C; S, Hinnant

Vice President

Brunswick Steam Electric Plant

P._0. Box 10429

Southport, NC 28461

SUBJECT:

NRC INSPECTION REPORT NOS. 50-325/97 '

.10 50-324/97-12

4

Dear Mr. Hinnant:

,

Thank you for your response of January 7,1998, to our Notice of Violation

-issued on December 8, 1997, concerning activities conducted at your Brunswick

,

,

facility. We have examined your response and found that it meets the

'

requirements of 10 CFR 2.201.

In your response, you admitted Violations A-D and denied Violation E.

>

After careful consideration of the basis for your denial of Violation E, we

'have concluded.-for the reasons presented in the ^nclosure to this letter,

,

that the violation occurred as stated in'the Notice of Violation. Therefore,

in accordance with 10 CFR 2.201(a) please submit to this office within 30

days of the date of this letter a written statement describing steps which

have been taken to correct Violation E and the results achieved, corrective

'

steps which will be taken to avoid further violations, and the date when full

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compliance will be achieved.

We will examine the implementation of your actions to correct Violations A-D

during future-inspections.

We appreciate your cooperation.in this matter.

Sincerely.

( Original signed by B. Mallett )

Bruce-S. Mallett

Deputy Regional Administrator

Docket Nos. 50-323 50-324

License Nos. 'DPR-71. DPR-62

Er.alosure:

Evaluat' ns and Conclusions

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Director

Site Operations

Brunswick Steam Electric Plant

Carolina Power & Light Company

P. O. Box 10429

Southport, NC 28461

J. J. Lyash, Plant Manager

Brunswick Steam Electric Plant

Carolina Power & Light Company

P. O. Box 10429

Southport. NC 28461

D. B. Alexander. Manager

Performance Evaluation and

- .atory Affairs

OHS 7

Carolina Power & Light Company

412 S. Wilmington Street

Raleigh. NC 27601

K. R. Jury, Manager

Regulatory Affairs

Carolina Power & Light Company

Brunswick Steam Electric Plant

'

P. O. Box 10429

Southport. NC 28461-0429

Wtiliam D. Johnson

Vice President & Senior Counsel

Carolina Power and Light Company

P. O. Box-1551

Raleigh, NC 27602

Mel Fry, Acting Director

Division of_ Radiation Protection

N.~C. Department of Environmental

Commerce & Natural Resources

3825 Barrett Drive

Raleigh NC 27609-7721

Karen E. Long

-Assistant Attorney General

State of North Carolina

P, 0. Box 629

Raleigh. NC 27602

(cc w/ encl-cont'd - See page 3)

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CP&L

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Robert P. Gruber

Executive Director

Public Staff NCUC

P. O. Box 29520

Raleigh NC 27626 0520

Public Service Commission

State of South Carolina

P. O. Box 11649

Columbia. SC 29211

Jerry W. Jones. Chairman

Brunswick County Board of

Commissioners

P. O. Box 249

Bolivia. NC 28422

Dan E. Summers

Emergency Management Coordinator

New Hanover County Department of

Emergency Management

P. O. Box 1525

Wilmington, NC 28402

William H. Crowe. Mayor

City of Southport

201 E. Moore Street

Southpor+, NC 28461

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PUBLIC

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U. S. Nuclear Regulatory Conrission

8470 River Road. SE

Southport NC 28461-

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P. O. Box 11649

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Jerry W. Jones Chairman

Brunswick County Board of

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P. O. Box 249

Bolivia, NC 28422

Dan E. Summers

Emergency Management Coordinator

New Hanover County Department of

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P. O. Box 1525

Wilmington, NC 28402

William H. Crowe, Mayor

City of Southport

201 E. Moore Street

Southport. NC 28461

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Executive Director

Public Staff NCUC

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Raleigh, NC 27626-0520

Public Service Commission

State of South Carolina

P. O. Box 11649

Columbia. SC 29211

Jerry W. Jones. Chairman

Brunswick County Board of

Commissioners

P. O. Box 249

Bolivia, NC 28422

Dan E. Summers

Emergency Management Coordinator

New Hanover County Department of

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P. J. Box 1525

Wilmington, NC 28402

William H. Crowe, Mayor

City of Southport

201 E. Moore Street

Southport, NC 28461

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EVALUATIONS AND CONCLUSION

,

On December 8, 1998, a Notice of Violation (Notice) was issued for five

violations identified during a routine NRC inspection.

Carolina Power & Light

Company (CP&L) responded to the Notice on January 7. 1998.

The licensee

admitted Violations A-0. but denied Violation E on the bases that the

established procedural . controls, training, and qualifications of the security

personnel monitoring the Central Access Point at the time of the events were

adequate to detect unauthorized access into the protected area (PA).

The

NRC's evaluations and conclusion regarding the licensee's arguments are as

follows:

Restatement of Violation

Technical Specification 6.8.1.d requires that written procedures shall be

established. implemented, and maintained covering implementation of the

Security Plan.

Physical Security Plan. Revision 1. August 1997, states that a Member of the

Security Force (MSF) located within a bullet resistant structure is

responsible for the final access control function.

Security Instruction. 0S1-05 Security Post Duties. Responsibilities and Patrol

Procedures, defines the responsibilities of the Access Control Person (ACP).

.

Contrary to the above, 0S1-05 failed to adequately define those actions

required for the ACP to control the final access function into the protected

area to prevent unauthorized access.

Specifically. no guidance existed for

controlling a condition on October 3 and again on Octobar 7, 1997 wherein the

ACr> failed to lock down the Protected Area turnstiles or remove the second

individual from the area during a conditio1 which could have allowed an

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unauthorized individual to gain access into the PA.

Summary of Licensee's Pesconse to Violation E

The licensee contends that the procedural controls training, and

qualifications of the security personnel monitoring the Central Access Point

(CAP) at the time of the events were adequate to detect unauthorized access

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into the protected area, and that the security personnel would have responded

had an attempt been made.

The licensee indicated that the procedures

controlling the CAP adequately defined the Final Access Control (FAC)

operator's responsibility in the event an unauthorized individual attem)ted to

gain access.

The licensee interviewed the responsible FAC operators, w1o

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attested that had an individual attempted to gain unauthorized access they

would have locked the full-length turnstiles or requested response from other

MSF. The licensee also credits training provided in November 1996 as

addressing the locking of the full-length turnstile when two individuals were

located between the half-length and full-length turnstiles.

Enclosure

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NRC Evaluation of Licensee's Resoonse

The NRC staff has carefully reviewed the licensee's response and determined

that the procedural requirements did not provide adeguate guidance for the

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situation observed to prevent unauthorized acces3.

Therefore, the Uritten

procedure OSI-5 did not adequately implement this Security Plan access

control function.

The licensee's response did not provide any additional

information that changed the significance or validity of the violation.

The licensee maintains that the procedures were adequate and the FAC operators

acted in accordance with those procedures and training provided concerning

this type situation.. The NRC does agree that the personnel serving as FAC

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operators were qualified to man that station, that training describing this

situation was provided in November 1996, and that 0S1-05 discusses the

responsibility of PA access control to the FAC operator.

However 031-05 did

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not contain actions for the FAC operator to intervene when more that one

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individual was in the area between the full-length and the half-length

turnstiles.

In addition, the training provided was prior to the completion

and site-wide utilizaticn of the Central Access Point in August 1997 and did

not address this situation for the different configuration of the new access

building,

Therefore, considering the failure to address the configuration

change during training and by observations of the situation on October 3, and

7.- 1997 the inspector determined the training provided and procedure were not

adequate to address this event.

NRC's review of the subsequent licensee's root cause analysis, the procedure

revised as a result of the situation identified, and the PNSC meeting notes,

support a finding that the procedural controls and training at the time of the

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event were inadequate.

The licensee's Root Cause Condition Report 97-3964.

Plant Access Turnsti a Area, dated January 6, 1998, for this event stated that

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'the one-half turnsta ies were introduced to enhance access control: however,

this process change was not formally documented in plant procedures Security

personnel instructions or site personnel training guides.

Failure to update

these documents prior to introducing the onc-half turnstiles resulted in plant

personnel not understanding management ex3ectations." The corrective actions

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reviewed by the NRC do not support that t1e procedures or training were.

edequate.

Corrective actions for this event included revision of the FAC

operators lesson plan.and additional training on that plan, revision to

051-05, and an evaluation of the need to change the Initial / Retraining program

E

to incorporate instructions for half-length turnstiles in the Central Access

Building. . A review of OSI-05 revised January 1998 added unauthorized access

'to those situations required for FAC operator action.

Additionally, the Root

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Cause investigator when questioned by the Brunswick Plant Nuclear Safety

Committee-(PNSC) during the December 18, 1997 meeting stated, as recorded in

the PNSC minutes, that the security guards actions were not "what they were

supposed to have done-their training had not been adequate to have them

-control the situation in the right way."

Enclosure

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The violation was issued based on inadequacies in a security procedure as

evidenced by observed security personnel performance.

The NRC is in agreement

with the licensee that no attempt at unauthorized access was made hv the

individuals observed.

The security force had the responsibility tv determine

the individuals authorization prior to the individuals gaining access to the

facility, when confronted with two individuals inappropriately between the

half-length turnstiles and the full-length turnstiles as required by Technical Specification 6.8.1 of the Security Plan. The NRC ins)ection observed that

neither the applicable procedure nor the training on tie procedure adequately

addressed the actual situation where two individuals were between the

turnstiles. Therefore, the NRC has determined that procedural controls were

not adequate to implement the Security Plan when two individuals were in the

area between the half-length and full-length turnstiles.

NRC Conclusion

For the above reasons, the NRC staff concludes that ',ae violation occurred as

stated.

!

Enclosure

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