ML20072C049
| ML20072C049 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 08/05/1994 |
| From: | Olivier L BOSTON EDISON CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 94-083, 94-83, NUDOCS 9408170047 | |
| Download: ML20072C049 (4) | |
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I 10 CFR 2.201 h
Boston Edison Pdgr:m f uckcar Poaer Stahan Porky Hdl Road P!ymoutn, Massachusetts 02360 August 5, 1994 L. J. Olivier BECo Ltr. #94 083 Vice Presed Nurpar (metahons and TMhori [)trector U.S.
Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 License No. DPR-35 Docket No. 50-293 i
Subject:
RESPONSE TO NOTICE OF VIOLATION
Reference:
NRC INSPECTION REPORT NO. 50-293/94-13 Please find enclosed the response to the Notice of Violation contained in the referenced Inspection Report.
Please contact me if there are any questions regarding this response.
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Olivier Enclosure MTL/nas/ Rap 94/NRC94-13 Then personally appeared before me, L.
J.
Olivier, who being duly sworn, did state that he is Vice President Nuclear Operations and Station Director of Boston Edison Company and that he is duly authorized to execute and file the submittal contained herein in the name and on behalf of Boston Edison Company and that the statements in said submittal are true to the best of his knowledge and belief.
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Page 2 Ltr. #94 083 cc:
Mr. Thomas T.
Martin Regional Administrator, Region I U.S.
Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr.
R.B.
Eaton Division of Reactor Projects I/II Office of NRR - USNRC One White Flint North-Mail Stop 14D1 11555 Rockville Pike Rockville, MD 20852 Senior Resident Inspector i
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l ENCLOSURE RESPONSE TO NOTICE OF VIOLATION 1
BOSTON EDISON COMPANY DOCKET NO. 50-293 PILGRIM NUCLEAR POWER STATION LICENSE NO. DPR-35 Notice of Violat_i_gn During an NRC inspection conducted on June 20-24, 1994, a violation of NRC requirements was identified.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C, the violation is listed below:
The Pilgrim Nuclear Power Station Physical Security Plan, dated December 22, 1992, Issue 2, Revision 11, Section 5.3.4, states in part that licensee designated vehicles (licensee-owned or contractor-owned vehicles limited in use to on-site functions) remain in the protected area except for operational, maintenance, repair, security and emergency purposes.
Additionally, Security Plan Section 5.3.4 specifies that all vehicles except licensee designated vehicles shall be escorted while on site.
Contrary to the above, on June 21, 1994, the licensee was not controlling designated vehicles as required, in that several licensee designated vehicles were allowed to remain outside the protected area for other than the specified purposes, with these vechicles nonetheless being granted unescorted access into the protected area.
This is a Severity Level IV violation (Supplement III).
Reason for the Violation This violation was due to several human performance issues.
Primarily, individuals involved did not appreciate the mportance 4
of minimizing the amount of time licensee designated vehicles may remain outside the protected area.
There was also a misunderstanding that it was acceptable for vehicles on this list to remain parked outside the protected area as long as they were on Boston Edison property (especially inside l
the fenced area near the Trash Compaction Facility), since all vehicles are subject to inspection upon entry into the protected area.
Corrective Steps Tak_en and Results Achieved Our immediate corrective action was to review the Licensee Designated Vehicle List and remove from the list any vehicles not in the Protected Area.
Our existing procedures require security management approval to add a vehicle to the list.
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We now require all vehicles on the Licensee Designated Vehicle List to be within the protected area by midnight.
Any vehicle not within the protected area is removed from the list and requires security management approval to be reinstated.
Finally, all levels of security personnel who have responsibility associated with Licensee Designated Vehicles (security guards to management personnel) have been counseled in the requirements for Licensee Designated Vehicles and have been made aware of the new midnight requirement.
Corrective Steps to Preclude Further Violations Requiring the removal from the Licensee Designated Vehicle List of any designated vehicles not within the protected area by midnight coupled with existing security management approval to ad'd or reinstate a vehicle to the list, precludes further Licensee Designated Vehicle violations.
Counseling security force personnel on Licensee Designated Vehicle requirements and their responsibilities in enforcing the requirements also precludes further Licensee Designated Vehicle violations.
We are revising security procedure 2.01 to include the new requirement for Licensee Designated Vehicles to be on-site by midnight.
We have included a review of the Licensen Designated Vehicles in our Self-Assessment for the Security Section.
Date When Full Compliance Was Achieved Compliance was achieved on June 21, 1994 with the removal from the list of any vehicles not within the Protected Area.
The requirement for Licensee Designated Vehicles to be on site by midnight became effective June 22, 1994.
Full compliance has been achieved.
The revision to procedure 2.01 will be completed by November 30, 1994 l
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