W3P86-1925, Response to NRC Re Violations Noted in Insp Rept 50-382/86-10.Corrective Actions:Request for one-time Exemption to 12-month Requirement for Security Program Audit Submitted on 860616

Response to NRC Re Violations Noted in Insp Rept 50-382/86-10.Corrective Actions:Request for one-time Exemption to 12-month Requirement for Security Program Audit Submitted on 860616

ML20210C283
Person / Time
Site:	Waterford
Issue date:	08/08/1986
From:	LOUISIANA POWER & LIGHT CO.
To:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
Shared Package
ML20210C229	List: IR 05000382/1986010 W3P86-1925, Response to NRC Re Violations Noted in Insp Rept 50-382/86-10.Corrective Actions:Request for one-time Exemption to 12-month Requirement for Security Program Audit Submitted on 860616
References
W3P86-1925, NUDOCS 8702090359
Download: ML20210C283 (2)

Text

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ATTACHMENT TO W3P86-1925 Page 1 of 2 I

RESPONSE TO VIOLATION 8610-01 (1) Admission'or Denial of Violation LP&L admits that the February 1986 Security audit did not include the

" testing and maintenance program" and "commaitments established for response by local law enforcement authorities" required by 10CFR73.55(g)(4).

i (2) Reason for-the Violation

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In 1986, LP&L decided to divide the annual Security audit into three (3)

.~ scheduled audits to be conducted through the year. This approach would allow for more frequent QA contact with the Security organization, more timely feedback to management, and generally provide better coverage of the

.~ , Security Program areas required by 10CFR73. The first audit under the new three-audit approach was conducted in February 1986 (SA-W3-QA-86-08) and it did not include testing and maincenance of equipment and local law

. enforcement agreements. .

Agreements with Local Law Enforcement Agencies (LLEAs) were reviewed during the Emergency Plan audit conducted in June 1985 (SA-W3-QA-85-23) and also during the Emergency. Plan audit conducted May 19 through June 13, 1986 (SA-W3-QA-86-21). Additionally, they have been reviewed during the Hardware / Maintenance Security audit currently in progress.

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Maintenance of security equipment was ,not specifically audited in February; however, the corrective maintenance procedure, UNT-5-002 which is the procedure used for corrective maintenance of plant equipment, including security equipment was audited in April 1985 and December 1985. These audits are documented in reports SA-W3-QA-85-05, " Corrective Maintenance" and SA-W3-QA-85-53A, Maintenance of EQ Equipment.

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(3) Corrective Actions That Have Been Taken On May 16, 1986 a letter (W3P86-0082) was sent to the NRC requesting a limited one-time exemption to the 12-month requirement for the Security Program audit. The letter explains the new system of having 3 audits '

instead of one as stated in item (2) above.

As stated in item (2) above, agreements with LLEAs were reviewed during the Emergency Plan audits and the audit of security hardware now in progress.

Agreements with the St. Charles Sheriff's Office, the State Police and the Coast Guard have been verified and they are current. Communications and interfaces with LLEAs are also being audited during the current audit (SA-86-0305.1).

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' RESPONSE TO VIOLATION 8610-01 ATTACHMENT TO W3P86-1925 Page 2 Page 2 of 2 (3) Corrective Actions That Have Been Taken (Continued)

Testing and Maintenance procedures of security equipment are currently ,

being audited (SA-86-030B.1 audit), and results are satisfactory to date.

This audit is one of the 3 security audits and is scheduled to be conducted every 12 months in July. A technical specialist was used during the audit.

(4) Corrective Actions That Will Be Taken The three annual security audits are documented in the Two-Year schedule which has been approved by the Safety Review Committee on April 29, 1986.

From now on, implementation of the three audits in a 12-month basis as required'by procedure QAP-305 will preclude recurrence of the problema.

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m (5) Date When Full Compliance Will Be Achieved Corrective actions will be completed when the Hardware / Maintenance Security audit now in progress is completed. Estimated date for issue of the audit

, report is August 30, 1986.

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& L1GHT/ 3ir e4RoNNeSTReer e.o.soxe03 0 NEW ORLEANS. LOUISlANA 70160 * (504) 595-3100 NuSNivsN May 16, 1986 W3P86-0082 A4.05 QA Mr. Robert D. Martin Regional Administrator, Region IV U.S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 Arlington, TX 76011

Subject:

Waterford 3 SES '

Docket No. 50-382 License No. NPF-38 One-Time Exemption for Security Program Audit

Dear Mr. Martin:

Louisiana Power & Light Company is proposing to alter the manner in which we meet the annual evaluations and audit requirements of 10 CFR 73.40(d) and 10 CFR 73.55(g)(4) for the Waterford 3 Security Program. It is our intent to separate the topics into three subgroupings and to perform three audits annually vice a single audit. The three' audits would be:

1. Administration / Program - this audit will address the review and audit of the security procedures and practices.

2. Hardware / Maintenance - this audit will address an evaluation of the effectiveness of the physical protection system, including testing and maintenance. Technical specialists from outside LP&L have been used to augment the QA organization in the annual audits, to ensure adequate technical expertise was available to assess effectiveness of the security program. We envision utilizing technical specialists to assist QA on this audit.

3. Contingency plans and operations - this audit will address contingency planning, and a scenario to test the contingency planning. It will

. also include review of conumitments established for response by local law enforcement authorities. We would also anticipate using technical specialists to assist QA in this audit.

These audits will be supplemented by other scheduled audits, unscheduled audits, or activity audits to address activities in process (such as drills) or topics management whhes to have evaluated. We believe this approach not only meets the regulation but will provide better feedback to ,

management than addressing all the subject areas in one annual audit. Once g[-

implemented, this approach will continue to assure that all subject areas have been reviewed in a 12-month period. k 8605220117 N 860516 F g D PDR ADOC 05000382 iGUAL OPPORTUNITY EMPLOYER" F PDR

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. , W3P86-0082 1

In order to implement this approach, LP&L is requesting a one-time exemption of the 12-month interval for two areas covered by the regulation. The last audit of the security program that specifically addressed security maintenance was completed in March 1985. The last audit which included review of local law enforcement agreements was completed in June 1985. We hereby request exemption of the 12-month review of testing and maintenance of security hardware until July 1986 and exemption of the 12-month review of local law enforcement comaiements until December 1986.

Parts 73.40(d) and 73.55(g)(4) of 10 CFR require an evaluation of the safeguards contingency plan (security program) at least once every twelve months by individuals independent of both security management and individuals responsible for implementation of the security program.

LP&L has met those requirements through annual audits performed by Quality Assurance. These annual audits have addressed the specific points in the regulations, namely:

A review and audit of security procedures and practices, .

Evaluation of the effectiveness of the physical protection system,

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An audit of the physical protection system testing and maintenance program, and An audit and test of the safeguards system along with commitments established for response by local law enforcements authorities.

Although'the proposed audit schedule will mean' that the entire Security Program will not receive the planned audit within the 12 months, different parts of the Security Program are still looked at during the year as indicated below.

Security hardware is tested and maintained under the same programs and controls used for safety related equipment at Waterford 3. Our most recent audits of these programs (4/85 and 11/85) have indicated that a satisfactory maintenance program is in place. Letters of agreement with the Louisiana Department of Public Safety (State Police) and the St.

Chpries Parish Sheriff's Office were reviewed during the Emergency Preparedness audit completed June 1985. Both agreements appeared to be adequate and had been updated within the past year. Security Audits performed by LP&L QA in 1984 and 1985 indicated that the security program was consistently being implemented in an effective manner. These audits support our position that the above requested exemption will not be detrimental to our security program.

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, . W3F86-u082 We believe the proposed approach will continue to meet the requirements in the regulation, provide better feedback to management, and the effectiveness of the security program will not be decreased during the transition period.

Very truly yours, 4

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K.W. Cook Nuclear Support & Licensing Manager .

KWC:BGM:ssf

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l cc: G.W. Knighton, NRC-NRR J.H. Wilson, NRC-NRR .

. . NRC Document Control Desk NRC Resident Inspe.ctors Office B.W. Churchill W.M. Stevenson -

. J.A.F. Kelly -

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