ML20031A771

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Responds to NRC Re Violations Noted in IE Insp Repts 50-280/81-20 & 50-281/81-19.Corrective Actions:General Order 13,re Designated Vehicles,Reviewed & Corrected. Disputes Noncompliance Item a
ML20031A771
Person / Time
Site: Surry  Dominion icon.png
Issue date: 09/03/1981
From: Leasburg R
VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19303A176 List:
References
487, NUDOCS 8109250397
Download: ML20031A771 (4)


Text

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V:IHOINIA 1$LECTH1C AND l'OWHH COMPANY n acianoNu, VIHOINIA 20 2C21

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,c September 3, 1981 H. II. Ls Amai:no Vice Pusanor er Ners.uAm oramations Mr. James P. O'Reilly, Director Serial No. 487 Office of Inspection and Enforcement N0/RMT:acm U. S. Nuclear Regulatory Commission Docket Nos. 50-280 Region II 50-281 101 Marietta Street, Suite 3100 Lie nse Ncs. DPR-32 Atlanta. Georgia 30303 DPR-37

Dear Mr. O'Reilly:

We have reviewed your letter of August 4, 1981 in reference to the inspection conducted at Sur., Power Station between July 6-10, 1981 and reported in IE Inspection Report Nos. 50-280/81-20 and 50-281/81-19.

Our responses to the specific infractions are attached.

In reference to the telecon of September 4, 1981 between H. C. Dance of your staff and E.

R.

Smith, Jr.,

the submittal date of this response was extended from September 3, 1981 to September 4, 1981.

Under the provisions of Section 2. 790(d '-

Part 2, Title 10, Code of Federal Regulations, the Virginia Electric and Powe-Campany considers the infot. nation in the a t t a e'..ed pages to be proprietaty and therefore, exempt from public disclosure.

The information contained in the attached pages is true and accurate to the best of my knowledge and belief.

Very truly v. e

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d Attachment City of Richmond Commonwealth of Virginia Acknowledged before me this J day of

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Notary Public

Commission expires: 4-N

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SEAL cc: Mr. Steven A. Varga, Chief Operating Reactors Branch No. 1 Division of Licensing 8109250397 810916 PDR ADOCK 05000280 0

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Attcchment 1

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RESPONSE TO NOTICE OF VIOLATION APPENDIX A INSPECTION AND ENFORCEMENT NRC COMMENT:

A.

10 CFR 73.55(c)(3) requires that the isolation zones shall be maintained in outdoor areas adjacent to the physical barrier at the perimeter of the protected area and shall be of sufficient size to permit observation of the activities of people on either side of that barrier in the event of its penetration.

10 CFR 73.55(c)(4) requires that all exterior areas within the protected area shall be periodically checked to detect the pitsence of unauthorized persons, vehicles, or raterials.

Paragraph 3.1.2 of the approved physical security plan states, " Protected area barrier fencing is installed... cad is clear of objects that could prevent assessment of security c9atingencies for a distance of at least twenty feet inside, to at least 20 feet outside the protected area."

Contrary to the above, on July 8,1981, two large wood :n crates were observed within the isolation zone approximately 15 feet from the pro-tected area fence on the inside of the protected area. The f. solution zone violation was reported by security personnel on July 7, 1971.

How-ever, corrective action had not been initiated.

This is a Severity Level VI Violation (Supplement III.F).

RESPONSE

1.

Admission er denial of the alleged violation (s).

The alleged violation is not denied.

2.

The reason for the violation, if admitted.

The two wooden crates, located in the isolation zone, did not prevent assessment of Security contingencies. Three sides of the crates were

.n the visual observation range of two Defensive Positions, DP1 and DP2.

The ccr. tractor supervisor, who had the crates placed in the isolation zone had been contacted by Security on July 7, 1981 and he stated that the crates could not be moved until July 8, 1981.

3.

The corrective steps which have been taken and the repults achieved.

Beginning on July 7, 1981, and as noted in the Security Shift Blotter, Defensive Position #1, on each shift, was instructed to increase and to maintait increased surveillance of the area until the crates were removed. The crates were removed on July 6, 1981.

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The corrective actions which will be taken to avoid further violations.

Markers have been made on fences and buildings which readily denote the twenty foot Isolation zone boundaries and which assist Security Personnel in determining the isolatior tone boundaries. The Security Force has been instructed to 3<-re vigar.;usly enh rce the requirements of the Secur.ity program which should minimize the need to provide compensato'.y measures for avoidable degradation to the isolation zone and has been instructed to take immediate compensatory actions for unavoidable violstions or to report the violation to higher authority.

5.

Darc when full compliance will be achieved.

Full compliance was achieved on September 3, 1981.

NRC COMMENT:

B.

10 CFR 73.55(d)(4) requires that designated licensee vehicles shall be limited in their ute to onsite plant functions and shall remain in the Protected Area except for operational, maintenance, repair, security and emergency purposes. The licensee shall exercise positive control over all such designated vehicles to assure that they are used only by authorized persons and for authorized purposes.

Paragraph 13.12 of the approved physical Security plan states, " Records of designated vehicles authorized unescorted access to the Protected Area are mainrained by the Station Security Supervisor on the resignated Vehicle List (Gene *;al Order Number 13). Data recorded includes make, model, license number, registered owner, period of authorization, authority and date, and signature of authorizing authority.

Contrary to the above, on July 8, 1981, a Chevrolet Van, license number 29564 bearing VEPCO vehicle no. 2799 was observed within the Protected I

Area.

Review of the current General Order Number 13, Designated Vehicles, l

revealed that VEPCO vehicle no. 2799 was described as a 1979 Dodge Pick-up truck with license no. TC 17493. The Chevrolet van was not included in General Order Number 13.

This is a Severity Level VI Violation (Supplement III.F).

RESPONSE

1.

Admission or denial of the alleged violation.

The facts as stated are correct. The description of VEPCO Company, l

vehicle number 2799 on the current General Order Number 13, Designated Vehicles, was inaccurate.

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Attcchment

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2.

The reasons for the violation, if admitted.

The:e was a transcription error in compiling the Designated Vehicle List.

Although the written description of the vehicle was incorrect, the vehicle had been a designated vehicle since September 1980, and was readily ecognized by members of the Security Force as a designated vehicle. The vehicle was thoroughly searched by a Security Force Member prior to the vehicle being granted access to the Protected Area and, the vehicle was operated by an individual who had been authorized unescorted access to the Protected Area.

3.

The corrective steps which have been taken and the results achieved.

The Ger.eral Order Number 13, Designated Vehicles, was reviewed and corrected as required.

4.

The corrective steps which have been taken to avoid further violations.

The responsibility for monthly review of General Order Number 13, Dee'inated Vehicles, has been delegated to a Security Shift Supervisor.

Prior to being granted unescorted access to the Protected Area, each designated vehicle will be described by the Searching Officer to the CAS Operater, who will verify the description with that recorded on the Designated Venicle List.

5.

The date when full compliance will be achieved.

Full compliance was achieved on or about July 9, 1981.

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