ML20078P637
| ML20078P637 | |
| Person / Time | |
|---|---|
| Site: | Fort Saint Vrain |
| Issue date: | 09/23/1983 |
| From: | Gahm J PUBLIC SERVICE CO. OF COLORADO |
| To: | Jay Collins NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| Shared Package | |
| ML20078P611 | List: |
| References | |
| P-83310, NUDOCS 8311080134 | |
| Download: ML20078P637 (3) | |
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5e 16805 WCR 19 1/2, Platteville, Colerado S0651 i
September 23, 1983 Fort St. Vrain Unit No. 1 P-83310 r
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>,l Mr. John T. Collins, Regional Administrator OCT 4 23
'l U. S. Nuclear Regulatory Commission i
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SUBJECT:
I & E Inspection Report 83-20
REFERENCE:
NRC Letter dated September 6, 1983
Dear Mr. Collins:
This letter is in response to the Notice of Violation received as a result of the inspection conducted at Fort St.
Vrain during' the period July 26-29, 1983.
The following response to the item contained in the Notice of Violation is hereby submitted:
Security Program Audit 10CFR73.55(g)(4)
- states, in part,
. The results of the review audit and evaluation along with recommendations for corrections and improvements, if any, shall be documented, reported to the licensee's plant management and to corporate j
management at least one level higher than having responsibility l
for the day to day plant operation.
The Fort St.
Vrain Physical Security Plan, Section 14.1.5 states, in part, "
Audit reports and/or findings are distributed to the appropriate Fort 5t.
Vrain management personnel responsible for program implementation, Vice President Electric Production and to the membership of the Nuclear Facility Safety Committee...."
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8311080134 831028 PDR ADOCK 05000267 0
PDR l
. Contrary to the above, the inspector reviewed Quality Assurance Audit, OAA-1601-82-01, dated July 30, 1982, and could find no evidence as to the results of this audit being distributed "to corporate management" or to the "Vice President Electric Production."
This is a Severity Level IV Violation (Supplement III.D.3).
(1) The corrective steps which have been taken and the results acnieved:
An audit distribution matrix was developed and utilized beginning April 8, 1983.
A revision to procedure 0-18, OA Monitorina and Audit Program, effective June 24, 1983, specified submittal of audit reports to the Vice President, Electric Production.
Results of all audits performed subsecuent to this time have been reported to the Vice President, Electric Production.
It should be noted that the Quality Assurance Audit 0AA-1601-82-01 was reviewed in meeting number 86 of the Nuclear Facility Safety Committee (NFSC) en August 12, 1982.
Page 7 of the minutes of that meeting contains the following:
"QAA-1601-82-01 (Security) was completed and the audit report issued following the post-audit meeting held on July 2,1983.
Seven CAAR's resulted from this audit; one on deficient personnel files, and six were written on ' safeguard' items."
The Vice President, Electric Production is the NFSC Chairman. A copy of the audit report was sent to the Manager, Nuclear Production Division who represents corporate management one level higher than having responsibility for the day to day plant operations.
(2) Corrective steps which will be taken to avoid further violations:
The corrective steps which have been taken and the results achieved represent the ccrrective action necessary to avoid further violations.
No further corrective action is anticipated at this time.
L.
3 (3) The date when full compliance will be achieved:
Full compliance was achieved prior to the July 26, 1983 inspection.
This matter was discussed with the Inspector, and the appropriate information was presented to her prior to the exit interview.
As indicated in the response (1)
- above, the condition was identified and corrected by the licensee prior to the NRC citation.
On that basis, we believe that there are mitigating circumstances, and that a Severity Level V violation may be warraated but a Severity Level IV is not.
Should you have any further questions, please contact me at (303) 785-2223, extension 350.
Very truly yours, Wh 6lv
[
D v'J. W. Gahm J
Quality Assurance Manager JWG:cr i
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