ML20199D426

Ack Receipt of 960316 & s Transmitting Changes Identified as Rev 15 & 16 to Plant Industrial Security Plan, Submitted Per 10CFR50.54(p).Comments on Subject Plans,Encl

ML20199D426
Person / Time
Site:	Davis Besse
Issue date:	11/14/1997
From:	Creed J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Jeffery Wood CENTERIOR ENERGY
References
NUDOCS 9711200332
Download: ML20199D426 (6)

Text

.-

~

... -. -. - - - -.. - ~ - -

h yf);

l 5.s 1

s Novenber _14,1997 {

d Mr. Johti K. Wood -

L Vice President - Nuclear Davis-Besse Nuclear Power Station

~~

- Centerior Service Company 15501 North State Route 2 -

Oak Harbor,' OH 43449 SUBJECTr i DAVIS BESSE INDUSTRIAL SECURITY Pl.AN (REVISIONS 15 and 16)

Dear Mr. Woods:

This letter acknowledges receipt of your letter dated March 13,1996, which transmitted changes' identified as Revision 15 to the Davis Besse Industrial Security Plan, and your letter -

. dated September 10,1997, which transmitted changes identified as Revision 16 to the Davis l Besse Industrial Security Plan, submitted under the provisions of 10 CFR 50.54(p).

Based on your determination that the changes do not decrease _the overall effectiveness of the plan'and after limited review of the changes, no NRC approval is required, in accordance with

~

10 CFR 50.64(p).. Some observations were noted during our limited review and are addressed e

in the enclosure to this letter. Our observations and your corections were discussed with Mr, G. Skeel and others of your staff on November 6,1997.- Implementation of these changes will be subject to inspection to confirm that the changes have not decreased the effectiveness of the security plan.

f The enclosures to your letters concem a subject matter which is exempt from public disclosure in accorda.,ce with 10 CFR 73.21, and is therefore being withheld from public disclosure, in accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter and the enclosure will be pl aced in the NRC Public Document Room.

Sincerely, Original Sig M By J. Belanger James R.-Creed, Chief Plant Support Branch 1 l

Docket No. 50-346 i

Enclosure:

As stated -

- See Attached List.

j 4

t.

. we c 7.DR ' DOCUMENT NAME: G:DRS\\DAV110 e awi r c.

.umine v emm OFFICE Rill RlllM :

mj x

' Pirtt$

'JCreed G

p-DATE=

11/f3/97' 11/M/97 OFFICIAL RECORD COPY.

s Da 0\\:

m

'C.

. J, K. Wood -

- 2 November 14, 1997 Lbec:.NRR/DRPM/PSGBl NRR Docket File

- CG Case File Nos. W.7035359WAi W7042163WA; 7

SG Inspector File

• Plan

~

f 1

I 1

-ii s

d

\\ f

+

- e y

n v

2

f DAVIS BESSE

.c a-Docket No. 50 346 cc:

1 Mary Ei O'Reilly' Department of Attomey i

Centerior Energy Corporation-

_Attomey General i300 Madiso Avenue General -

Toledo, Oh14T352 30 East Broad Street Columbus, Ohio 43216 Mr. James L Freels -

Manager - Regulatory Affairs Mr. James W. Harris, Director l

Toledo Edison Company._

Divisbn of Power Generation

-. Davis-Besse Nuclear Power Plant =

Ohio Department of Industrial--

- 5501 North State - Route 2

Regulations

Oak Harbor, _ Ohio 43449 P.O. Box 825 Columbus, Ohio 43216 Gerald Chamoff, Esq.

Shaw, Pittman, Potts :

Ohio Environmental Protection Agency and Trowbridge DERR-Compliance Unit-2300 N Street N.W.

ATTN: Zack A. Clayton Washington, D.C. 20037 P. O. Box 1049 -

Columbus, OH 43266-0149 Mr. Robert B. Botsum Babcock & Wilcox -

State of Ohio Nuclear Power Generation Division Public Utilities Commission 1700 Rockville Pike, Suite 525 -

180 East Broad Street Rockville, Maryland 20852 Columbus, Ohio 43266-0573 Resident inspector Mr. James R. Williams

' U.S. Nuclear Regulatory Commission State Liaison to the NRC 5503 N: State Route 2 -

Adjutant General's Depariment Oak Harbor, Ohio 43449 Office of Emergency Managemt Agency 2855 West Dublin Granville Road Mr. James H. Lash, Plant Manager Columbus, Ohio -43235-2206 Toledo Edison Company Davis-Besse Nuclear Power Station President, Board of County 5501 North State Route 2-Commissioners of Ottawa County n_

Oak Harbor, Ohio '43449

- Port Clinton, Ohio 43452--

Robert E. Owen, Chief.

Roy P. Lessy, Jr., Esq.

L Bureau of Radiological Health s Andrew G. Berg, Esq.

Service Akin, Gump,. Strauss, Hauer & Feld,-

- Ohio Department of HeaMh, L.L.P.

P

-. O. Box 118' 1333 New Hampshire Avenue, N.W.

Columbus, Ohio 43266-0118

- Suite 400

~

~

Washington, D.C. 20036 5

'k

~

_ -.., ~ _.-_

- ~. -.

N 4,

COMMENTS ON INDUSTRIAL SECURITY PLAN REVISIONS 15 AND 16 Chanter SAGliOD Comments (REVISION 15) 1 l 1.2.3 -

The description for the Supervisor-security support is incomplete and too broad to be meaningful. Significant operational security program responsibilities identified in the previous plan revision were appropriate.

1 1.4.1.7 This revision changed the method of testing response force members to the same level as for other armed personnel without providing justification in the log of revision submitted with the plan changes. The previous plan revision allowed alternate methods only for other armed personnel.

Al' hough this practice may be acceptable, the change was not addressed in the Log of Revisions.

1 1.4.2 This revlalon deleted the requirement that unarmed security officers have no physical handicaps which would prevent them from performing security duties. This deletion violates requirements for secunty officers identified in Section I.A.2 of Appendix B to 10 CFR Part 73.

1 1.4.2.2 Clarify if ' items 1-3" mean only items 1 and 3, or items 1 through 3.

1 Note:1.4.4 This revision changed duty qualifications for response force members in reference to waapon qualifications. Although the pactice may be acceptable, the rationale for 'he change was not addressed in the revision log submitted with the change. The revision log noted only " editorialized note."

9 I

i

6 l

I 2

1 1.4.8 The last paragraph of this section states '

weapons, etc "should" be stored under lock and ;<ey. Correctiva actions in LER 94-S01-00, dated April 8,1994, stated that, among other actions, unassigned revolvers were locked within tne armory safe and a two man rule was implemsrited.

1 1.6.2.2 The justification in the log of revision for this change refers to the screening criteria form for Nuclear Security and security Officer duties. Although the change may be acceptable, the screening criteria fomi addressed certain posts only within the P6rsonnel Processing Facility and not the post addressed in Section 1.6.2.2.

3 3.1 See comments about the vehicle barrier system in Inspection Report No,50-346/57010, dated October 11,1937.

)

3-3.3.1.4 Attemate entry through a gate in the

)

protected area requires an armed officer to be present when the gate is opened.

3 Section 3 General Observation: In reference to your changes pertaining to not arming certain security posts, it is assumed that the personnel are not response force members, if they are response force members they must be able to meet their response force commitments regardless of the post they are assigned. If being armed continuously while on a post is necessary to fulfill the response force duties, then they must be armed.

3 3.3.2.4 See above comments for Section 1.6.2.2.

The Screening Criteria Form does not address vehicle search officers.

3 3.3.2.S Altemate entry through a gate in the protected area requires an armed officer to be present when the gate is opehed.

3 12 12.6.1 This revision was not identified in the Log of Revisions.

NOTE:

Documented reasons for regulatory issue changes in future plan revisions should be more detailed in reference to actual changes being made.

(REVISION 16) 3 3.1 See Inspection Report No. 50 346/97010 for issues pertaining to the VBS.

5 5.2.2 Intrusion detection systems are required to have line supervision regardless of the protection provided for the security cabinets.

m____ _. _ _

~

-"'--