ML20210E007

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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:
References
1351K, NUDOCS 8603270158
Download: ML20210E007 (2)


Text

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( v}{ N Commonwealth Edison

) One First National Plaza, Ch cago. litinois (j] Address Reply to: Post Office Box 767 Chicago. Illinois 60690 February 27, 1986 Mr. J. G. Keppler u

g Regional Administrator h

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(yea U.S. Nuclear Regulatory Commission

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Region III 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 we believe this event would be classified as Severity Level V since the 0 rgo event had minor safeguards significance.

Our report documents that the Q-alarm capability of the affected door had been verified within two hours L

prior to discovery that the door was unlocked. The immediate actions to o taken promptly corrected the problem and determined that no unauthorized vital area access had occurred. For these reasons we feel the event py 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

-a c and Security Event Report #86-1, the event'was-promptly reported in c a.a accordance with our Security Plan.

SECURITY MARKING DOES NOT APPLY WHE!T THIS LETTER IS SFP.8R.*."'E' F9CM "'? $?7 CSUEE MAR 0 31985

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

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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

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are being monitored to assure their effectiveness.

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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 -

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 I

with other security personnel. These actions were considered sufficient

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at that time. The occurrence of the event in January prompt'ed a more detailed review of both events. As a result, our corrective actions j

2 (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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