ML20137K348
| ML20137K348 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 12/27/1985 |
| From: | Harrington W BOSTON EDISON CO. |
| To: | Murley T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| 85-229, NUDOCS 8601240014 | |
| Download: ML20137K348 (6) | |
Text
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BOSTON EDISON COMPANY B00 EDYLETON STREET BOSTON. M ASSACHUSETTs 02199 i
WILLIAM t?. HARRINGTON December 27, 1985 x............,
BECo t cr. #85-229
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Dr. Thomas E. Murley Regional Administrator U. S. Nuclear Regulatory Commission 631 Park Avenue King of Prussia, PA 19406 License No. D9R-35 Docket No. 50-293
Subject:
Plan and Schedule of Security Program Improvements
Dear Sir:
In accordance with our letter to Mr. J. Taylor dated November 27, 1985, attached please find a plan and schedule of Security Program Improvements for Pilgrim Nuclear Power Station. As stated in Attachment 2 of our November 27, 1985 letter, the planned improvements demonstrate a continued commitment for aggressive management of our security program. The plan includes a schedule for program improvements in the areas of management oversight, self audits, corrective actions system, regulatory requirements analysis and training.
A separate schedule for planned corrective action addressing compensatory measures on loss of the security computer is included as Attachment 2.to this letter. This information is also submitted in accordance with our November 27 letter (Attachment
- 4) and includes a schedule of proposed actions to improve the reliability of the security computer and standardize the reporting of security events.
Progress reports of the security program improvements will be developed on a routine basis. As discussed with Mr. Joyner of your staff, these progress reports will be forwarded to our Senior Resident Inspector, Dr. M. McBride.
Should you have any questions or concerns in regard to this letter, please contact me directly.
Very truli
- yours, M
W. D. Harrington Attachments cc:
Mr. J. Taylor, Director Office of Inspection and Enforcement U. S. Nuclear Regulatory Commission Washington, D.C.
20555 T. Martin w/a 06012 D
P M. McBride w/a ppR f
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ATTACHMENT 1 Plan and Schedule of Security Program Improvements Increased Management Oversite - Corporate Security Plan to establish a Corporate Security Representative to strengthen the interface between site and corporate security personnel. This individual will be responsible to perform audits in accordance with a structured audit plan, review program document changes, and maintain state-of-the-art knowledge of security methodologies. This change will be reflected in the Corporate Bulletin Book.
Scheduled Planned Milestones Completion Develop job description and approve.
February 1986 Commence hiring process for corporate security March 1986 representatives.
Corporate Security Representative on board.
April 1986 Revise Corporate Bulletin Book B-6 to reflect Complete increased involvement of site security by corporate.
Plan to hire five (5) Boston Edison security supervisors to provide shift coverage of the contract security force.
Scheduled Planned Milestones Completion Develop job description and approve.
January 1986 Commence hiring process for Boston Edison site February 1986 security supervisors.
First additional Boston Edison site security April 1986 supervisor on board.
Remaining Boston Edison site security supervisors July 1986 on boa rd.
Self-Audits Plan to audit the sections of the security plan on a regular basis such that the entire plan is addressed by corporate security once/ year.
Planned Milestones Scheduled Completion Develop corporato level self audit program February 1986 for the site security plan.
Review and approve audit program.
April 1986 Commence first module of audit program, June 1986
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Page 1 of 3
Plen to est;blish precedures for thm cxisting intsrnal survnillinca offort cnd includ3 thy scheduling of th:sn survaillancos in th9 Master Surveillance Tracking Program.
Planned Milestones Scheduled Completion Develop procedures to formalize existing February 1986 surveillance programs.
Approve and issue procedures.
March 1986 Revise Master Surveillance Tracking Program March 1986 to schedule these surveillances.
Corrective Actions System Plan to develop a proccdure to standardize the reporting of security deviatior.s and to initiate thorough and effective corrective actions. The procedure will include a form for reporting deviations and will require a trend analysis of deviations to identify recurring problems.
Scheduled Planned Milestones Complet'1n Identify and evaluate requirements of the March 1986 corrective action system.
Develop and approve procedure, including form, June 1986 for reporting deviations.
Indoctrination and implementation of process.
July 1986 Perform first trend analysis of deviations to January 1987 identify recurring problems.
Regulatory Requirements Analysis Plan to perform a regulatory requirements analysis of the Nodified Amended o
Security Plan (MASP), Safeguards Contingency Plan, and Training and Qualification (T&Q) Plan vis-a-vis the Code of Federal Regulations. This analysis is to assure that the regulatory requirements are met by existing programs and procedures.
Scheduled Planned Milestones Completion Obtain resources to perform analysis.
January 1986 Determine methodology of performing analysis.
February 1986 Perform regulatory requirements analysis (interim October 1986 milestones have been established for this task and are availuble upon request).
l Revise Boston Edison program documents and Pending results l
procedures as required.
of analysis l
Page 2 of 3 i
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Trnining Plan to evaluate the present approach to training such that:
(1) Security force personnel have a greater sense of awareness of the bases behind their duties (i.e. why they are here).
(2) Security force personnel understand the need to initiate aggressive corrective action and to follow-up thoroughly.
Scheduled Planned Milestones Completion Determine evaluation method.
January 1986 Perform evaluation.
February 1986 Issue report with evaluation results.
March 1986 Revise present approach to training as required.
Pending evalua-tion results Page 3 of 3
r ATTACHMENT 2 Compensatory Measures on Loss of Security Computer A recent concern was raised by our Senior NRC Resident Inspector, Dr. M. McBride, regarding establishment of compensatory measures within 10 minutes if the security computer becomes inoperable. The concern is that in 1985, six security event reports have been filed because full compensatory limits were not established within 10 minutes after loss of the security computer.
As stated in our November 27, 1985 letter, Boston Edison has reviewed the situation and implemented the following corrective actions:
Reviewed and revised the response methodology allowing security personnel to man the required posts within 10 minutes.
Temporarily increased staffing levels as an interim measure to ensure the 10-minute response time can be met.
P.ovided pre-established compensatory zone assignments on each shift in the event the computer becomes inoperable.
Trained security force on the revised methodology of response.
Conducted drills and verified that less than 10-minute response is achieved.
In addition to the completed actions stated above, the following actions are planned; Scheduled Planned Milestones Completion Evaluate the reliability of the security computer.
Complete Develop recommendations for couputer improvements.
February 1986 Decision on optimal recommendation.
March 1986 page 1 of 2
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9; Pltn eto proceduralize tha process of pre-established' compensttory zons assignments.
Planned Milestones Scheduled Completion Revise existing procedure to formalize February 1986 compensatory zone assignments.
Approve and issue procedure.
March 1986 Plan to standardize security event reporting.
Planned Milestone Scheduled
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Completion Revise and approve procedure to standardize February 1986 requirements of security event reports.
Determine feasibility of revising the Contingency Plan.
Planned Milestones Scheduled Completion i
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Evaluate existing security systems to determine February 1986 feasibility of revising the Contingency Plan to include increased response time to computer outages, Submit proposed changes to Contingency Plan for Pending results j
NRC approval, of above evalua tion l
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