ML20062E954

Responds to 781107 NRC Ltr Re Violations Noted in Investigation Rept 50-325/78-29 & 50-324/78-29.Corrective Actions:Improved Admin Controls Over Documentation & Testing of Security Force Training Prog Have Been Implemented

ML20062E954
Person / Time
Site:	Brunswick
Issue date:	11/27/1978
From:	Banks H CAROLINA POWER & LIGHT CO.
To:	Kenna W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20062E948	List: IR 05000324/1978029 ML20062E944 ML20062E954 ML20062E964 ML20062E968
References
NUDOCS 7812130296
Download: ML20062E954 (3)

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1 Caro:ina Powes 41.;cht ( tunr.iny November 27, 1978 FILE: NG-4013(B) SERIAL: GD-78-3100 Mr. W. B. Kenna, Chief Safeguards Branch Nuclear Regulatory Commission Region II, Suite 1217 230 Peachtree Street, N.W.

Atlanta, Georgia 30303 CAROLINA POWER & LIGHT COMPAhT BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-66 RESPONSE TO I&E INSPECTION REPORT 78-29

Dear Mr. Kenna:

In accordance with the provisions of 10 CFR, Section 2.2.1, Attachment A is provided concerning the enforcement item specified in your letter, 50-325/78-29, 50-324/78-29. The information contained in I&E Inspection Report 78-29 and Attachment A is not considered to be proprietary.

Very truly yours,

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H. R. Banks Manager Nuclear Generation JBW/jnh*

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Attachment A Reply to NRC Region II letter: II:MVA 50-325/78-29, 50-324/78-29 Enforcement Item Item A Infraction 10 CFR 73.55(b)(4) states, in part, that a licensee shall not permit an individual to act as a guard unless such individual has been properly qualified and has demonstrated an understanding of the licensee security procedures.

Contrary to the above, the licensee permitted an individual to act as a guard on various security posts beginning October 16, 1978. The final security examination used by the licensee to demonstrate the guard's qualification and understanding of the security procedures was not administered until October 18, 1978.

CP&L Response As stated in the report of investigation, the guard in question did act in various security posts beginning October 16, 1978. Although the individual had completed the training required by ANSI 18.17 and the security plan on October 15, 1978, it could not be demonstrated that he possessed the required understanding of security procedures at the time he was placed on duty as a guard. Procedures for documenting training and qualification have been revised to ensure that a member of the security organization is not placed on duty until the required level of training and qualification has been attained and that such training and qualification is documented. In addition to revising the procedures for documenting training and qualification, additional managerial emphasis has been placed at the Carolina Power &

Light Company and Contractor levels to avoid future noncompliance.

Full compliance was achieved on November 10, 1978.

The concerns expressed in your letter involving the adrinistration of the security force training program are shared by Carolina Power &

Light Company. The following actions have been taken to improve management control of the securi'.y force training and testing program:

1. Administrative controls over testing and documentation have been examined and improvements implemented.

.t . Closer liaison has been attained with contractor management to ensure that contractoral compliance and the commitments of the security plan are being met.

3. An independent investigation of training practices was corducted, this investigation was, in addition to those investigations discussed with the NRC investigators during the course of their investigation.

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4. A CP&L employee has been assigned full-time duties as Security Specialist at Brunswick Steam Electric Plant, with one of his assigned duties being to monitor security organization training.

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