ML20236C995

Responds to NRC 870904 Enforcement Action EA-87-100 Re Violations Noted in 871001 Insp Rept 50-424/87-55.Corrective Actions:Civil Penalty Fee Paid & Mgt of Security Program Enhanced W/Changes in Mgt,Personnel & Training.Fee Paid

ML20236C995
Person / Time
Site:	Vogtle
Issue date:	10/21/1987
From:	James O'Reilly GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM), NRC OFFICE OF ENFORCEMENT (OE)
References
EA-87-100, SL-3303, NUDOCS 8710270438
Download: ML20236C995 (7)

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Georgra Powe Company 333 Piedmon' Avenue 4tlanta, Georgia 30308 Teleptione 404 526-7851 b f a 4545 Atlanta. Georgia 30302

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SL-3303 0533m X7GJ17-V120 October 21, 1987 Director, Office of Enforcement U. S. Nuclear Regulatory Commission ATTN: Document Control Desk g ..

Washington, D.C. 20555 "

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NRC DOCKET 50-424 3g OPERATING LICENSE NPF-68 i REPLY TO NOTICE OF VIOLATIQE >@

C Gentlemen-In accordance with the provisions of 10 CFR 2.201, Georgia Power Company (GPC) submits herein its response to NRC Enforcement Action letter EA 87-100 dated September 4, 1987 and NRC inspection report 50-424/87-55 dated October 1, 1987. The subject NRC letter and inspection report concerned inspections conducted on March 9-13, March 23-27, April 22-24, April 29-May 3, May 12-15, June 22-24, July 20-24, July 28-29, August 5-6, September 8-11, and September 21, 1987, at the GPC corporate offices in Atlanta, Georgia, and at Plant Vogtle (VEGP).

The inspections included a review of security violations identified and reported by the NRC Region II staff as well as those identified and reported by GPC. As a asult of these inspections, failures to comply with NRC security requirements were alleged to have occurred.

Prior to GPC's planned submittal of the response to NRC Enforcement Action letter EA 87-100 on October 5,1987, NRC, Region II, contacted GPC on September 30, 1987, and requested that GPC address in its response several additional violations which were identified and reported by GPC.

These additional violations are contained in NRC Inspection Report 50-424/87-55 dated October 1, 1987.

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[JEDN SEPARATION THIS PAGE IS DECONTROLLED 1 U. S. Nuclear Regulatory Commission October 21, 1987 Page Two The violations described in the referenced Notice of Violation and in the Inspection Report are considered significant because they identify a pattern of weaknesses, particularly in earlier operations, in the VEGP Physical Security Program. However, we wish to note that no actual security threats occurred as a result of these weaknesses or during a period of noncompliance.

Inadequate management attention to the security program is the major contributor to each of the identified problems. This is attributed to an initial lack of nuclear management experience in the security area. The problem of inexperience was amplified by management's failure to include physical security preparedness in our readiness review program for Vogtle Unit 1. To help preclude similar problems from recurring at Vogtle Unit 2, physic &1 security is now a significant part of the readiness review program for Unit 2. Also, as the scope of the management problem became more apparent to GPC, corporate managers were directed to attend more closely to the safeguards program at VEGP and to assist site management by both personal observation at the facility and by appropriate participation in daily activities at the plant. Plant management's heightened concern with these issues was demonstrated by continuous involvement. in the details of everyday security and by holding problem-solving meetings on practically a daily basis until September, 1987. This involvement of corporate and site management, coupled with the acquisition of new and experienced supervisory staff members as quickly as qualified persons could be identified and offers extended, improved the quality of day-to-day supervision.

In July, 1986, the security program status at Plant Vogtle was recognized as having significant deficiencies. In order to assure long term elimination of these problems, the following actions had been initiated or completed by the end of 1986:

1. The nuclear security organization was totally transferred to the Nuclear Operations Department.

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U. S. Nuclear Regulatory Commission October 21, 1987 Page Three

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2. An experienced nuclear security professional was assigned to Plant Vogtle as the site nuclear security manager, and the incumbent was transferred;

3. A total retraining effort was initiated;

4. A team was organized to implement and expedite proper completion of construction and testing;

5. The security force was re-organized to establish job duty specialization;

6. A procedure upgrade program was initiated;

7. A member of the corporate nuclear security staff was assigned to Plant Vogtle on a full-time basis; and

8. A number of significant security system changes were initiated, l including repositioning the perimeter alarm system, the '

perimeter closed circuit television (CCTV) system, and the addition of a second (i.e., nuisance) fence. '

Hith the issuance of the operating license in January 1987, the need for full operational capability of VEGP's Security Department personnel and security related equipment was immediate. In regard to equipment, although a program of testing had been conducted, deficiencies either unidentified or underestimated became clearly apparent. In order to increase the reliability of this equipment, GPC initiated a task force of vendors, engineers, and security specialists to address this problem.

This effort has been successful and by August, 1987, the systems were operating at an acceptable performance level. In regard to Security Department personnel, security force members experienced in construction security were immediately exposed to the rigors and detail required in an operating nuclear facility. Due to management's failure to fully

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U. S. Nuclear Regulatory Commission October 2i, 1987 Page Four recognize and correct problems in training, testing, procedures, procedure adherenca and initial startup, security personnel performance was not up .to acceptable levels and personnel became frustrated. This problem was more difficult to address than the hardware problem. The combination of qualification weaknesses, poor equipment performance, thanging . organizations, and the strain of startup resulted in difficulties in achieving substantial performance improvements. However, the following actions were successfully taken:

1. The entire security training staff was replaced with  !

nuclear-experienced personnel, and security training was moved l from site training to security control;

2. Procedure training was enhanced;

3. Approximately 20 supervisory, response and training personnel experienced at operating nuclear plants were hired;

4. Forty new GPC nuclear security officers were recruited and were hired;

5. Absenteeism rules were consistently applied and enforced; and

6. Corporate and site management, including senior executive management, held discussions with the entire security force, received their concerns, and acted on them, where possible.

Security administration also did not meet our standards. The following actions were taken to correct these problems:

1. A corporate nuclear security coordinator, whose primary expertise is in administration, was assigned to Plant Vogtle to implement enhanced administrative processes, and to get the existing ones on track and working properly;

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U. S. Nuclear Regulatory Commission October 21, 1987 Page Five

2. An administration specialist was assigned to each shift to coordinate the preparation of reports and records; and

3. Administrative procedures were strengthened to assure that records and reports were being properly handled.

All of the above changes are more clearly delineated in Enclosures (3A) and (3B).

Georgin Power Company believes that the need for corporate and plant management attention to the VEGP Physical Security Program referred to in NRC Enforcement Action letter EA 87-100 was identified in large measure by GPC and that resources were mobilized to ensure that security of the plant was maintained and while major actions were taken to substantially upgrade performance. In addition to the mitigating circumstances described by the NRC in Enforcement Action letter EA 87-100, which recognized GPC's management aggressiveness, other pressures had negative effects on site management. For example, required changes to barriers and detection systems during early startup activities, though necessary, took significant resources away frrn our new program managers during a very difficult period. Also, allegations led to an NRC investigation of considerable magnitude which had a significant psychological impact on all security-related personnel . Plant Vogtle security was truly examined under a " microscope".

Georgia Power Company is committed to compliance with all NRC requirements and will devot9 the resources necessary to achieve that commitment. As an example of that commitment, on Monday, October 12, 1987, and continuing until October 23, 1987, a special team consisting of nuclear security personnel from the Corporate Office, Plant Hatch, and an outside consultant are conducting an Operational Readiness Inspection (0RI) of Plant Vogtle Security. This team is focusing primarily on training, records and reports, discipline, scheduling, supervisory effectiveness, and security officer effectiveness. The purpose of this

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U. S. Nuclear Regulatory Commission October 21, 1987 Page Six inspection is to evaluate the current operational effectiveness of the Plant Vogtle security organization. This inspection is a method to assure ourselves that our plans and programs are properly being implemented at all levels . In the security organization. Georgia Power Company sincerely appreciates recognition by the NRC that aggressive management initiatives have resulted in programmatic enhancements and organizational changes which have produced improved performance.

Georgia Power Company's response to the violations cited in NRC Enforcement Action letter EA '87-100 is provided herein as Enclosure (1) for violations assessed a civil penalty and as Enclosure (2) for those not assessed a civil penalty. In each enclosure, transcription of the NRC violation precedes GPC's response. Enclosures (3A) and (38), provide the details of actions already taken by GPC, in a time sequence, to substantially improve the Vogtle Security Program.

Georgia Power Company believes that the violations which were identified and reported by GPC and discussed in NRC Inspection Report 50-424/87-55, particularly those pertaining to degraded barriers and access control, are similar to those cited in NRC Enforcement Action letter EA 87-100. These violations require corrective actions which are already being implemented. He wish to note that to help preclude additional violations with regard to access control, GPC is already installing additional hardware to ensure occurrences, such as those discussed in the associated inspection report, are not repeated. The corrective actions taken or planned for the alleged violations identified in NRC Inspection Report 50-424/87-55 are discussed in Enclosure (4) to this submittal.

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U. S. Nuclear Regulatory Commission October 21, 1987 Page Seven The information contained in the enclosures is safeguards information and, in accordance with 10 CFR 2.790 and 10 CFR 73.21, should be withheld from public disclosure. The full payment for the proposed penalty is provided in Enclosure (5).

3 A copy of this response if being provided 'to the NRC Region Il office for review. Should you have any questions, please contact this office at any. time.

James P. O'Reilly states that he is Senior Vice President of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company, and that to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

GEORGIA P0HER COMPANY By: m f.gQ200e J es P. O'Reilly Sworn to and subscribed before me this 21st f Oct ber, 1987.

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. Notary I'ubhc. Coweta County Georgia 15' I989 MM'EMPM"P** S'"'

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