ML20210E007

Forwards Addl Info Re Security Event Rept 86-1.Criteria for 10CFR2,App C Re Licensee Identified Violation Met.Corrective Actions Implemented.Notice of Violation Unnecessary.Encl Withheld (Ref 10CFR73.21)

ML20210E007
Person / Time
Site:	Quad Cities
Issue date:	02/27/1986
From:	Farrar D COMMONWEALTH EDISON CO.
To:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
Shared Package
ML20210E000	List: ML20210D997 ML20210E007
References
1351K, NUDOCS 8603270158
Download: ML20210E007 (2)

Text

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) One First National Plaza, Ch cago. litinois

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Address Commonwealth Reply to: 60690 Illinois Post Office Box 767 Edison February 27, 1986 Mr. J. G. Keppler g u Regional Administrator U.S. Nuclear Regulatory Commission h c. .

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em v amn nw Region III . /77 'O N.10 799 Roosevelt Road Glen Ellyn, IL 60137

Subject:

Additional Information Regarding Security Event Report No. 86-1 References (a): Letter from'N. J. Kalivianakis to J. G. Keppler dated January 16, 1986.

(b): Letter from W. L. Axelson to Cordell Reed dated January 31, 1986.

Dear Mr. Keppler:

In response to your letter (Reference (b)), this transmittal provides additional information regarding Quad Cities Security Event Report 86-1. We believe that the following information. supports a determination that this event meets the criteria of 10 CFR 2, Appendix C, Section V.A as a

" licensee identified violation".

Five criteria are identified in 10 CFR Part 2. Appendix C for identifying situations where a notice of violation would generally not be issued. The criteria are as follows:

1. It was identified by the licensee - Our Security Event Report #86-1 documents that the event was discovered by Quad Cities Security personnel.

2. It fits in Severity Level IV or V - Based on the criteria in Supplement III to 10 CFR 2, Appendix C (Severity levels for Safeguards violations),

g 0 rgo we believe this event would be classified as Severity Level V since the event had minor safeguards significance. Our report documents that the Q-alarm capability of the affected door had been verified within two hours L

to o prior to discovery that the door was unlocked. The immediate actions taken promptly corrected the problem and determined that no unauthorized p vital area access had occurred. For these reasons we feel the event y represented minimal significance in terms of actual safeguarding of the oc plant.

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3. It was reported, if required - As documente{ l'n t'he Reference (a) letter and Security Event Report #86-1, the event'was-promptly reported in c a.a accordance with our Security Plan.

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i 4. It was or will be corrected including measures to prevent recurrence, l

f. within a reasonable time - Inunediate corrective actions taken are l documented in the Event Report. In addition, the attachment to this  !

letter describes additional actions we have taken to prevent recurrence j of this type of event. These actions have already been completed and .i j are being monitored to assure their effectiveness. '

1 l 5. It was not 'a violation that could reasonably be expected to have been i prevented by the licensee's corrective action for a previous violation - l

, Although a related event was documented in Security Event Report 85-28 j .(November 25, 1985) we feel that the actions taken at that time were

! appropriate. In the previous event, disciplinary action was taken-i against the individual guard responsible and the event was discussed

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I with other security personnel. These actions were considered sufficient .

) at that time. The occurrence of the event in January prompt'ed a more l 2

detailed review of both events. As a result, our corrective actions j (attached) include more substantial efforts to educate the security j force on this event and the development of specific requirements -

j regarding radio consnunications for door and gate control.

f' We feel our corrective actions regarding the first event were reasonable I based on information available at the time. The second event indicated

a more fundamental problem regarding consnunications which has'now been a

addressed. The actions taken in response to both events were reasonable

! and appropriate, j

l Based on the above discussions, we feel that this event satisfies j the criteria in 10 CFR 2, Appendix C for a licensee identified violation.

Since corrective actions have been implemented, we believe a formal Notice

! of Violation is unnecessary as provided for in the Enforcement Policy.

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i The attachment.to this letter contains Safeguards Information as  :

defined in 10 CFR 73.21 and therefore must be handled and protected .I

accordingly.

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Sincerely, L

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D. L. Farrar i Director of Nuclear Licensing im ~

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