L-87-362, Responds to NRC Re Violations Noted in Insp Repts 50-250/87-25 & 50-251/87-29.Util Withholding Payment of Proposed Civil Penalty Until Notified of Resolution of Access & Search Issues.Security Plan Mgt Being Improved
| ML20237H304 | |
| Person / Time | |
|---|---|
| Site: | Turkey Point  |
| Issue date: | 08/26/1987 |
| From: | Woody C FLORIDA POWER & LIGHT CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE) |
| References | |
| EA-87-098, EA-87-98, L-87-362, NUDOCS 8709030203 | |
| Download: ML20237H304 (4) | |
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AUGUST 2 6 1987 L-87-362 10 CFR 2.201 Director, Office of Enforcement k
U. S. Nuclear Regulatory Commission Atin: Document Control Desk Washington, D. C. 20555
Dear Sir:
Re: Turkey Point Units 3 and 4 Docket Nos. 50-251 and 50-251 EA 87-98 (Inspection Reports 87-25 and 87-29)
Florida Power & Light (FPL) has reviewed the NRC letter dated July 28, 1987 which forwarded a Notice of Violation (NOV) and Proposed imposition of Civil Penalty (EA 87-98). This NOV was based on issues presented in NRC Inspection Reports 87-25 and 87-29. Our response in accordance with 10 CFR 2.201 is provided in the attachment which contains safeguards information exempt from public disclosure it, accordance with 10 CFR 73.21.
Our management review of the security program at Turkey Point has identified arcos where performance improvements are needed. Some weaknesses exist in our approved security plan and its implementation procedures. FPL recognizes the need for a strong security program, and has recently presented a description of our plan for a broad based upgrade of the security area in a meeting with Region 11 management. Our plan includes such items as a detailed self assessment by FPL Quality Assurance of the security plan and implementing procedures and its compliance with current regulatory positions, an upgrade of security facilities, and improvements in contractor security force shift staffing to improve supervision.
Our review of the NOV and the circumstances surrounding the two issues has provided the basis for our response in the attachment. We have determined that the facts presented regarding the access issue are substantiated.
Our performance on that occasion did not meet our standards and we have concurred with the presented finding. FPL is of the view, however, that the facts associated with the access matter indicate a deficiency more appropriately categorized as severity Level IV. We also consider that the corrective actions stated in our response will reduce the likelihood of similiar problems in the future. Further, we are of the opinion that our programmatic corrective actions will address security in a general sense to upgrade this functional area.
8709030203 870826 DR ADOCK 0500 O
ENCLOSURE CONTAINS SAFEGUARDS INFORMATION. UPON SEPARATION, 7601 THIS PAGE IS DECONTROLLED.
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SAFEMA27e8 IsFORIMTION U. S. Nuclear Regulatory Commission L 87-362 Page two FPL has conducted a careful review of the NRC approved Turkey Point Security Plan and the circumstances surrounding the vehicle search issue.
Although improvements in the specificity of the Security Plan are warranted to remove questions regarding requirements, we do not concur that a finding is justified in this instance.
Our security personnel were complying with implementing procedures and these procedures were in compliance with the intent and the specific language of the Security Plan. The basis for our conclusion and the interim actions we have taken until this item can be resolved are presented in the at tachment.
Because we believe the access issue is more appropriately a Level IV violation and because we do not concur with the finding for the search issue, we are withholding payment of the proposed civil penalty until we are notified of the resolution of these issues. We would request that the assignment of the Severity Level til to these combined issues be reconsidered. We undectand that the civil penalty has been assessed equally between the two issues. We would hope that following your review of the circumstances regarding the access and search issues, you would agree that a severity Level IV violation for the former issue and no finding for the latter issue is appropriate. Based on the foregoing and our further explanation in the Attachment, reconsideration of the combined Level 111 assessment seems appropriate. FPL will promptly remit any civil penalty following disposition of our request.
FPL has recognized the need for increased management attention in the area of security and has initiated actions to improve this functional area. We are also working to improve implementation of the Security Plan at the operational level and to emphasize the importance of attention to detail insofar as matters of security are concerned.
Should there be any questions on the information presented here or in the attachment, piease contact us.
We look forward to working with the NRC Staff as we progress through our stated enhancements.
Very truly yours, wh
. O. Woo Group Vi
- resident Nuclear Energy COW /SDF/gp Attachment Dr. J. Nelson Grace, Regional Administrator, Region 11, USNRC cc:
Senior Resident inspector, USNRC, Turkey Point Piant ENCLOSURE CONTAINS SAFEGUARDS INFORMATION. UPON SEPARATION, THIS PAGE IS DECONTROLLED.
- ci/02i/2 SAFEMMDS INFORMATION
STATE OF FLORIDA
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C. O. Woody being first duly sworn, deposes and says:
That he is a Group Vice President of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.
(0 Add CO. Woody Subscribed and sworn to befere me this cR6 day of cazd
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