IR 05000267/1985028: Difference between revisions

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{{Adams
{{Adams
| number = ML20207L621
| number = ML20207B228
| issue date = 01/08/1987
| issue date = 07/07/1986
| title = Ack Receipt of 861204 Ltr Informing NRC of Steps Taken to Correct Violations Noted in Insp Repts 50-267/85-28 & 50-267/85-32
| title = Discusses Insp Repts 50-267/85-28 & 50-267/85-32 on 850930- 1004 & 851118-22,respectively & Forwards Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $65,000.Encls Withheld (Ref 10CFR73.21)
| author name = Gagliardo J
| author name = Martin R
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
| addressee name = Williams R
| addressee name = Walker R
| addressee affiliation = PUBLIC SERVICE CO. OF COLORADO
| addressee affiliation = PUBLIC SERVICE CO. OF COLORADO
| docket = 05000267
| docket = 05000267
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = NUDOCS 8701120274
| document report number = EA-86-081, EA-86-81, NUDOCS 8607170457
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| document type = CORRESPONDENCE-LETTERS, NRC TO UTILITY, OUTGOING CORRESPONDENCE
| page count = 1
| page count = 3
}}
}}


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=Text=
=Text=
{{#Wiki_filter:7
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JAN 8 1987
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It T 1986 Docket No. 50-267 License No. DPR-34 EA 86-81 Public Service Company of Colorado ATTN: R. F. Walker, President P. O. Box 840 Denver, Colorado 80201-0840 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORT NOS. 50-267/85-28 AND 50-267/85-32)
In Reply Refer To: _ _
This refers to two inspections conducted on September 30 - October 4, 1985 (Inspection Report No. 50-267/85-28) and on November 18-22,1985(Inspection Report No. 50-267/85-32) at the Ft. St. Vrain Nuclear Station, Platteville, -
    *
Colorado. During these inspections the NRC determined that there were several instances where the protection afforded protected and vital area barriers was j inadequate. An enforcement conference to discuss these matters was held on January 6,1986 at the Region IV Office in Arlington, Texa Violation I.A involves a physical access control problem which potentially allowed unauthorized and undetected access into protected.and vital areas from the owner controlled area. This violation appears to have existed for some time. The causes of this violation apparently include construction deficiencies which resulted in the inadequate installation of protective barriers and failure of the startup testing / surveillance program to identify these deficiencie '
Docket: 50-267/85-28 & 85-32 Public~ Service Company of Colorado ATTN: Robert 0. Williams, Jr.
Violation I.B involves the failure to provide adequate detection and response capabilities for a portion of the protected area barrier. The cause of the violations appears to be a lack of management attention to the status and maintenance of the security system. The NRC is particularly concerned because the violation involving the degraded protected area barrier may have existed since 1984. Specifically, it appears that since about August 1984 the primary intrusion detection system was inoperable, requiring compensatory measure Closed circuit television (CCTV) was used as the compensatory measure and a design defect in its coverage capability was only discovered during the NRC inspection. Yet, opportunities to discover the defect were available, for example, through security audits which were performed during the intervening time. This is especially significant because it appears that no design changes were made to the CCTV system since November 198 Violations II.A-H in the enclosed Notice have been categorized as Severity Level IV or V violations and have not been assessed e civil penalt CERTIFIED MAIL RETURN RECEIPT RE0 VESTED sya Wmiyg BbO71704S7 BbO707 7 UM szpgUIo2 TH'C?o.?st 779y*
i'MgggyOc0?7 DR ADOCK 0500  c..IS
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      $1


Vice President, Nuclear Operations P. O. Box 840 Denver, Colorado 80201-0840 l
_ - - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _
 
t
==Dear Sir:==
.
Thank you for your letter of December 4,1986, by which you informed us of the new completion dite for the Security Equipment Reliability Program.
,
Public Service Company of Colorado -2-The NRC is concerned that the existence of multiple security violations with differing root causes indicates weaknesses in the management oversight and control of the physical security program at Ft. St. Vrai Therefore, to emphasize the need for increased management attention to the implementation of the physical security program, I have been authorized, af ter consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of Sixty-five Thousand Dollars ($65,000) for Violations I. A and B. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C (1986) (Enforcement Policy), Violation I.A has been categorized at a Severity Level II and Violation I.B has been categorized at a Severity Level III. The base civil penalties for Severity Level II and III violations are $80,000 and $50,000, respectively. The NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstance In this case, the base civil penalty for each violation was reduced by 50 percent because of your prior performance which involved no escalated enforcement actions in the security area over the past several years. However, further mitigation is not warranted because of the multiple examples of the violations identified, the duration of one of the violations, and the significance of the one Severity Level II violatio You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement The material enclosed contains Safeguards Information as defined by 10 CFR 73.21 and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended. Therefore, the material will not be placed in the Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as reqJired by the Paperwork Reduction Act of 1980, PL 96-51


If there are additional delays or any change to the March 31, 1987, completion date, please advise us as soon as possible.
Sincerely, Original ofgned by(
Robert D. Martin Robert D. Martin Regional Administrator Enciosure:
Notice of Violation and Proposed Imposition of Civil Penalties cc:    $NNDC Colorado Radiation Control Program Director m .7fI?lTlm r:mt&.:.;


ORIGINAL SIGNED BY:
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J. E. Gagliardo, Chief Reactor Projects Branch cc:
  .       l i Public Service Company of Colorado - 3-    l l
J. W. Gahm, Manager, Nuclear Production Division Fort St. Vrain Nuclear Station 16805 WCR 19 Platteville, Colorado 80651 L. Singleton, Manager, Quality Assurance Division (same address)
l DISTRIBUTION
Colorado Radiation Control Program Director Colorado Public Utilities Commission bec to DM8 (IE04)
bec distrib. by RIV:
RP8  DRSP Resident Inspector R. D. Martin, RA Section Chief (RPB/A)  RSB Section Chief (RSB/ES)  R&SPB MIS System  RSTS Operator RIV File  Inspector Section Chief  W. L. F,i her R. L. Bangart  '
RIV:EP SPS C:EP& P,S C:R&SP :R 8 A C:RPB }
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    /q /86 8701120274 870108    0 PDR ADOCK 05000267    1 G  PDR    )(!


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bec w/o encl:      .
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SECY      I CA JMTaylor, IE JLieberman, ELD LCobb, IE FIngram, PA JCrooks, AE00 BHayes, OI      /
16805 WCR 19 1/2, Platteville, Colorado 80651 December 4, 1986 Fort St. Vrain Unit No. 1 P-86640 f- ._ _
SConnelly, 0IA DNussbaumer, OSP H. Denton, NRR
_i Regional Administrator  . ,4 Region IV    ,L U. S. Nuclear Regulatory Commission 611 Ryan Plaza Drive, Suite 1000 j)i ') DEC l l1986 - .
      [[/,T 1 I I IE:ES File IE:EA File      k BSummer , IE (ltr hd)
  . Arlington, Texas 76011  LLJ Attention: Mr. J. E. Gagliardo, Chief Reactor Projects Branch Docket No. 50-267 SUBJECT: Security Equipment Reliability REFERENCE: PSC Letter, Williams to Director Office of Inspection and Enforcement Dated August 5,1986(P-86471).
DCS bec w/ encl:
 
JAxelrad, IE Enforcement Officers RI, RII, RIII, RV J. Gibson, SSPD/NRR RBurnett, NMSS    -
==Dear Mr. Gagliardo:==
        ^
In response to a Notice of Violation resulting from I&E Inspections 85-28 and 85-32 (Reference 1), PSC advised the NRC that we would develop a program to determine root causes and trend security system equipment inoperability. PSC originally projected this project to be
DESIGNATED ORIGINA RIV Distribution w/ encl:
R. Martin, RIV EP&SPS Certt:1ed ty kb j' Zja.:N2 RIV Security Files DPowers RIV Distribution w/o encl:
Div. Director (DRSP) C. Wisner g
Div. Director (URSS) R. Doda J. Gagliardo, RPB    pW IE:ES R RA  E
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complete by October 1, 1986.
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PSC has started collecting the data necessary to determine the causes and to establish a trend analysis program. However, in order to implement a truly effective program, PSC believes additional enhancements are needed. Therefore, PSC proposes a revision to the target date for complete implementation of this program to March 31, 1987. This will provide PSC sufficient time to develop and implement an effective security system equipment monitoring program.
C gl o AP es a  TIO.' T IIS ai /dci s/ / / 4./ R A / '7 / 9 (I' ACE IS D07avna &
 
Should you have any questions, please contact Mr. M. H. Holmes (303) 480-6960 for further information.
 
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P-86640 -2- December 4, 1986
 
Sincerely, J.W. Gahm Manager, Nuclear Production Fort St. Vrain Nuclear Generating Station JWG:DCG/mit
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}}
}}

Revision as of 19:19, 27 December 2020

Discusses Insp Repts 50-267/85-28 & 50-267/85-32 on 850930- 1004 & 851118-22,respectively & Forwards Notice of Violation & Proposed Imposition of Civil Penalties in Amount of $65,000.Encls Withheld (Ref 10CFR73.21)
ML20207B228
Person / Time
Site: Fort Saint Vrain Xcel Energy icon.png
Issue date: 07/07/1986
From: Martin R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Walker R
PUBLIC SERVICE CO. OF COLORADO
References
EA-86-081, EA-86-81, NUDOCS 8607170457
Download: ML20207B228 (3)


Text

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It T 1986 Docket No. 50-267 License No. DPR-34 EA 86-81 Public Service Company of Colorado ATTN: R. F. Walker, President P. O. Box 840 Denver, Colorado 80201-0840 SUBJECT: NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTIES (NRC INSPECTION REPORT NOS. 50-267/85-28 AND 50-267/85-32) This refers to two inspections conducted on September 30 - October 4, 1985 (Inspection Report No. 50-267/85-28) and on November 18-22,1985(Inspection Report No. 50-267/85-32) at the Ft. St. Vrain Nuclear Station, Platteville, - Colorado. During these inspections the NRC determined that there were several instances where the protection afforded protected and vital area barriers was j inadequate. An enforcement conference to discuss these matters was held on January 6,1986 at the Region IV Office in Arlington, Texa Violation I.A involves a physical access control problem which potentially allowed unauthorized and undetected access into protected.and vital areas from the owner controlled area. This violation appears to have existed for some time. The causes of this violation apparently include construction deficiencies which resulted in the inadequate installation of protective barriers and failure of the startup testing / surveillance program to identify these deficiencie ' Violation I.B involves the failure to provide adequate detection and response capabilities for a portion of the protected area barrier. The cause of the violations appears to be a lack of management attention to the status and maintenance of the security system. The NRC is particularly concerned because the violation involving the degraded protected area barrier may have existed since 1984. Specifically, it appears that since about August 1984 the primary intrusion detection system was inoperable, requiring compensatory measure Closed circuit television (CCTV) was used as the compensatory measure and a design defect in its coverage capability was only discovered during the NRC inspection. Yet, opportunities to discover the defect were available, for example, through security audits which were performed during the intervening time. This is especially significant because it appears that no design changes were made to the CCTV system since November 198 Violations II.A-H in the enclosed Notice have been categorized as Severity Level IV or V violations and have not been assessed e civil penalt CERTIFIED MAIL RETURN RECEIPT RE0 VESTED sya Wmiyg BbO71704S7 BbO707 7 UM szpgUIo2 TH'C?o.?st 779y* i'MgggyOc0?7 DR ADOCK 0500 c..IS .

     $1

_ - - _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ t

.

, Public Service Company of Colorado -2-The NRC is concerned that the existence of multiple security violations with differing root causes indicates weaknesses in the management oversight and control of the physical security program at Ft. St. Vrai Therefore, to emphasize the need for increased management attention to the implementation of the physical security program, I have been authorized, af ter consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalties in the amount of Sixty-five Thousand Dollars ($65,000) for Violations I. A and B. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986) (Enforcement Policy), Violation I.A has been categorized at a Severity Level II and Violation I.B has been categorized at a Severity Level III. The base civil penalties for Severity Level II and III violations are $80,000 and $50,000, respectively. The NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstance In this case, the base civil penalty for each violation was reduced by 50 percent because of your prior performance which involved no escalated enforcement actions in the security area over the past several years. However, further mitigation is not warranted because of the multiple examples of the violations identified, the duration of one of the violations, and the significance of the one Severity Level II violatio You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response. In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with NRC regulatory requirement The material enclosed contains Safeguards Information as defined by 10 CFR 73.21 and its disclosure to unauthorized individuals is prohibited by Section 147 of the Atomic Energy Act of 1954, as amended. Therefore, the material will not be placed in the Public Document Roo The responses directed by this letter and the enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as reqJired by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, Original ofgned by( Robert D. Martin Robert D. Martin Regional Administrator Enciosure: Notice of Violation and Proposed Imposition of Civil Penalties cc: $NNDC Colorado Radiation Control Program Director m .7fI?lTlm r:mt&.:.;

f

.        l i Public Service Company of Colorado - 3-     l l

l DISTRIBUTION

bec w/o encl: . SECY I CA JMTaylor, IE JLieberman, ELD LCobb, IE FIngram, PA JCrooks, AE00 BHayes, OI / SConnelly, 0IA DNussbaumer, OSP H. Denton, NRR

      [[/,T 1 I I IE:ES File IE:EA File       k BSummer , IE (ltr hd)

DCS bec w/ encl: JAxelrad, IE Enforcement Officers RI, RII, RIII, RV J. Gibson, SSPD/NRR RBurnett, NMSS -

       ^

DESIGNATED ORIGINA RIV Distribution w/ encl: R. Martin, RIV EP&SPS Certt:1ed ty kb j' Zja.:N2 RIV Security Files DPowers RIV Distribution w/o encl: Div. Director (DRSP) C. Wisner g Div. Director (URSS) R. Doda J. Gagliardo, RPB pW IE:ES R RA E

     #

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