ML20203L051
| 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
.
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
Er.alosure:
Evaluat' ns and Conclusions
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cc w/ enc 1:
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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(cc w/ encl cont'd)
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
Distribution w/ encl:
M. Shymlock Rll
D. Trimble. NRR
J. Lieberman. OE
B. Summers. OE
J. Colev RII
R. Aiello. RII-
'J. Lenahan. RII
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E. Testa. RII
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D. Thompson RII
PUBLIC
NRC Resident Inspector
U. S. Nuclear Regulatory Conrission
8470 River Road. SE
Southport NC 28461-
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Robert P. Gruber
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Exec. tive Director
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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
Southport. NC 28461
Distribution w/ encl:
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J. Lieberman OE
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J. Coley, RII'
R. Aiello, RII
J. Lenahan RII
E. Testa, RII
D. Thompson, RII
PUBLIC
NRC Resident Inspector
U.- S. Nuclear Re'gulatory Commission-
8470 River Road. SE
Southport. NC- 28461
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Robert P. Gruber
Executive Director
Public Staff NCUC
P. O. Box 295c0
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. J. Box 1525
Wilmington, NC 28402
William H. Crowe, Mayor
City of Southport
201 E. Moore Street
Southport, NC 28461
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PUBLIC
NRC Resident Insp ctor
U. S. Nuclear Re ulatory Commission
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8470 River Road SE
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Robert P. Gruber
Executive Director
Public Staff NCUC
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P. O. Box 29520
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Raleigh NC 27626-0520
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Public Service Comission
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State of South Carolin-
P. O. Box 11649
Coluncia. SC 29211
,
Jerry W. Jones. Cha
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Brunswick County /
Comissioners
F. O. Box 249
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Bolivia. NC
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Emergency Man gement Coordinator
New Hanover
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NC 28402
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201 E.
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EVALUATIONS AND CONCLUSION
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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).
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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
,
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
'
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
,
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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