ML20150F323
| ML20150F323 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/13/1979 |
| From: | Stewart W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 3--3-A-3, 3-0-3-A-3, NUDOCS 7910050116 | |
| Download: ML20150F323 (4) | |
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September 13, 1979 File:
3-0-3-a-3 Mr. J. P. O'Reilly Director U. S. Nuclear Regulatory Cocsission Of fice of Inspection and Enforcement Suite 3100 101 Marietta Street Atlanta, CA 30303
Subject:
Crystal River Unit No. 3 Docket No. 50-302 Operating License No. DPR-72
- 1. E.Bulletin 79-16
Dear Mr. O'Reilly:
In response to the subject bulletin concerning VITAL AREA ACCESS CONTROLS, the following inforsation is being provided.
Item 1:
Establish criteria for granting unescorted accress to each vital area, which shall be based upon the following:
A screening program meeting ANSI N18.17.
a.
b.
The individual has a valid need for access to the equipment contained in each vital area to which access is authorized.
Valid need is based upon assigned duties requiring the performance of specific tasks upon or associated with speciff; equipment located in each vital area to which access is granted. Valid need to enter one vital area shall not necessarily indicate that the person has a need to enter any other vital area.
i Response 1: Criteria have been established regarding unescorted access to vital areas.
Only personnel who have completed a screening program equivalent to that identified in our Modified Amended Security Plan sections 1.3 and 1.6 vill be granted unescorted access. Each access will be based on a valid r.eed and will be restricted to only those areas specifically associated with the need.
The only exceptions being Operations and Security personnel who will require Qhh access throughout the plant in order to perform their job n m ya
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Mr. J. P. O'Reilly Page Two September 13, 1979 Item 2:
An access list will be established for each area not to exceed 31 days. An individual vill be on the access list only for the duration of the task to be performed.
If an individual has a valid need for unescorted access for a single entry or for intermittent occasions during this period, a separate daily access list shall be prepared.
All access lists shall be approved by the station manager (or equivalent) or his designated representative.
Response 2: Access lists will.be established with a duration not to exceed 31 days as identified in our Modified Amended Security Plan section 5.3.1. 3.
All access lists wi'l be approved by the Plant Manager or his designated representative.
Item 3:
Individuals vill be removed froc ihe ' access list immediately upon te rmination of need.
If an individual has not entered the vital area during the ef fective period of the access list (not to exceed 31 days) the need for access should be reassured prior to extending the authorization. To ensure that these actions are taken, the access list shall be reviewed and reapproved at least every 31 days.
Resposse 3: Individuals will be removed from access lists upon termination of their need for access. To assure that access authorizations are not carried beyond the time frame associated with a valid need, the access list shall be reviewed and reapproved at least every '31 days.
Item 4:
Void access authorizations for all personnel not satisfying the criteria in 1.a and 1.b and where appropriate, reprogram the key card system and reissue key cards that are coded to Laplement the above vital area access authorization prodras.
Response 4: Presently badged personnel who have not completed an ANSI N18.17 type screening program or who do not have a valid need for access to vital areas will not be allowed access until these criteria are met.
. tem 5:
Develop reasonable alternatives so that the number and frequency of access to vital areas can be minimized consistent with safe operations.
Response 5: The number and frequency of acensses to vital areas are presently being ainimized consistent with safe operation cf the plant.
Item 6:
Establish emergency procedures where, during an emergency, additional authorized personnel, neecing criteria in 1.a and 1.b, can move f reely throughout the vital areas with their entry and exit being recorded.
Upon securing from the emergency, the entry / exit record will be reviewed, and normal access control will be reestablished.
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Mr. J. P. O'Reilly Page Three September 13, 1979 Response 6: Emergency Procedures will be established to allow
- authorized emergency team personnel to move freely throughout the vital areas.
Normal access control will be
' reestablished after a review of the entry / exit record and upon securing frcza the emergency.
Item 7:
Prevent tailgating by one or more of the following:
Establish procedures that require authorized personnel a.
to prevent other personnel, including those authorized unescorted access, from tailgating.
Ensure all authorized personnel are trained in the procedure, and establiah a management program that ensures that the procedure is properly performed.
b.
Acquire equipment, such as turnstiles, to prevent tailgating. Ensure that such equipment will not deny access or egress under emergency conditions.
c.
Station a guard, watchperson or escort at the vital area access portal. This alternative would be most f
useful when there is a large number and frequency of access, such as occurs with containment during ref ueling.
d.
By any other means that achieve this objective.
Response 7: Procedures have been established that require authorized personnel to prevent tailgating by other personnel.
This is included in our general employee training which is given annually.
Item 8:
Assign corporate respcasibility for management oversight of VA access control and require personal involvement to ensure that all intermediate levels of management are properly discharging their responsibilities in this regard.
Response 8: The Nuclear Plant Manager is responsible for site security. Any oversight of vital area access controls will be brought to his attention and corrective action vill be taken.
Audits of this activity will be performed by the plant staf f Compliance Section, FPC Quality Program personnel with appropriate corrective action being taken where necessary.
Item 9:
Conduct routine f unctional tests of the electronic access control system, including each key card reader, to verify (i) its operability and proper perfor=ance, and (ii) the accuracy of the data recorded. This test should be incorporated into the seven-day test required by 10 CFR 73.55(g).
Mr. J. P. O'Reilly Page 4 Septe=ber 13, 19 79 Response 9: A weekly (no greater than every 7 days) f unctional test is
-performed on the electronic access control system.
This includes a check for proper perforsance and operability of each key card reader and the accuracy of the data recorded.
Procedures and training required to Unplement the above 9-items are under development. We expect to be in total compliance by January 31, 1980.
Should you have any questions concerning our responses to the above items, please contact this office.
Very truly yours, FI,0RIDA POWER CORPORATION i
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W. P. Stewart Manager, Nuclear Operations WPShewR01 D47 cc:
U. S. Nuclear Redulatory Co=sission Of fice of Ins pection and Enforcement Division of Reactor Operations Inspection Washington, D.C. 20555 NRC Of fice of Inspection and Enforcement Division of Reactor Construction Inspection Washington, D.C. 20555 File Code: 3-0 3