ML20245C067

Responds to NRC Re Violations Noted in Insp Rept 50-312/87-02.Cited Violation Improperly Categorized as Violation Iv.Bomb Threat on 861230 Did Not Constitute Sufficient Act Against Plant.Util Actions Did Meet AP.501

ML20245C067
Person / Time
Site:	Rancho Seco
Issue date:	04/03/1987
From:	Julie Ward SACRAMENTO MUNICIPAL UTILITY DISTRICT
To:	Martin J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
Shared Package
ML20245C053	List: ML20245C050 ML20245C067
References
JEW-87-456, NUDOCS 8707010611
Download: ML20245C067 (5)

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SACRAMENTO MUNICIPAL UTILITY otSTRICT O P. O. Box 15830, Sacramento CA 95852 1830,(916) 452-3211 OF CALIFORNIA AN ELECTRIC SYSTEM SERV ($[g GAR dl ll: I 4 APR 0 31987 JEW 87-456 ggg, I

J. B. Martin, Regional Administrator Region V Office of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission 1450 Maria Lane, Suite 210 Walnut Creek, CA 94596 Docket No. 50-312 Rancho Seco Nuclear Generating Station License No. DPR-$4 ,

l RESPONSE TO NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 87-02)

Dear Mr. Martin:

I By letter dated March 3, 1987, the Sacramento Municipal Utility District was transmitted a Notice of violation concerning the failure to properly classify an event on December 30, 1986. In accordance with 10 CFR 2.201, the District provides the enclosed response to the Notice of Violation.

This letter acknowledges the violation cited and describes the District's-intended corrective actions for the event listed in the Notice of Violation.

However, the District believes that the cited violation is improperly categorized as Severity Level IV.

The District considers that the intent of Administrative Procedure AP.501,

" Recognition and Classification'of Emergencies," is to declare an unusual event only if it has been determined that'the act actually threatens ~the safety of the nuclear power plant or site personnel. As the' enclosed response shows, management determined that the December 30, 1986, bomb threat did not constitute a sufficiently explicit act against the plant at.the time, but nonetheless management took actions which fully met the intent of-AP.501.

8707010611 870624 PDR ADOCK 05000312 G PDR DISTRICT HEADQUARTERS [] 6201 S Street, Sacramento CA 95817-1899'

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-J.B. Martin ' - ' JEW 87-456 APR 0 31987 Ambiguities in-AP.501 can be. interpreted as requiring the declaration of an: .i unusual event upon the receipt of a_ny n security event that "causes.the Security:

. Force to. initiate the Rancho Seco Physical Security [PlanJ." Corrective action will be taken to remove the ambiguities ~and clarify the intent of the procedure.

The District considers that the cited Violation is a minor safety concern only and requests that the NRC reevaluate the Severity Level addressed in NRC Inspection Report 87-02.

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Sincerely, I

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I E. Ward Deputy General Manager, Nuclear I l

Enclosure cc: G. Kalman, NRC, Bethesda '

A. D'Angelo, NRC, Rancho Seco INPO i I&E i-

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- ATTACHMENT 1 DISTRICT RESPONSE 10 NRC INSPECTION 87 NOTICE OF VIOLATION NRC Violation As a result of the inspection conducted during the period January 9 through 16, and January 22, 1987, and in accordance with NRC Enforcement Policy, 10 CFR Part 2, Appendix C, the following violation was identified:

A. Rancho Seco Technical Specification 6.8.1(e) requires, in part, that written procedures covering the Emergency Plan shall be implemented.

Procedure AP.bul, " Recognition and Classification of Emergencies,"

requires the Shift Supervisor / Emergency' Coordinator to declare an unusual event upon the receipt'of a security threat that "causes the Security force to initiate the' Rancho Stco Physical Security LPlanj."

Contrary to the above, on December 30, 1986,- the licensee received a security threat (bomb threat) that caused the security force to declare a security alert and escalate security measures without declaring an unusual event.

1his is a Severity Level IV Violation (Supplement VIII).

District Response to Violation

1. Admission or denial of the alleged violation.

The District acknowledges and admits that a violation occurred with regard to the failure tc classify and declare an unusual event resulting from a security alert on December 30, 1986,' pursuant'to AP.501. However, the District denies that the alleged violation is Severity Level IV.

2. Reasons for the alleged violation.

There were three tactors contributing to the alleged violation:

• The degree of activation of the Security Plan was improperly ,

communicated to plant management. ' Although plant management was aware of both the bomb threat and the compensatory actions initiated by Security, management was unaware that a security-alert had been declared.

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'e AP.501 requires a classification of' unusual event upon receipt of a security threat that:"causes the' security; force.to n initiate the >

Rancho Seco' Physical Security." The word:"[planj";after

'" Security" noted in the violation is not in AP.501, and thus leads to confusion, particularly because .some aspects' of the Security-.

Plan are always initiated. .AP. SUI is unclear'about.which aspects of the plan being implemented require that an unusual event be declared. -I"urther,' AP.501. does not provide. adequate guidance in defining what'a security threat is.

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• Plant management did not interpret AP. SUI to require:an Unusual j Event, but did act conservatively to protect' plant employees.-

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3. Reasons for denying the Severity Level of the alleged violation.

'The District considers that the nature and.the extent of'the enforcement action (i.e. , the . severi ty level) overstates . the seriousness of the alleged violation. Evaluation of the December 30, .l 1986, bomb threat.by plant management concluded that the, threat did ]

not warrant declaring an unusual event because: (1) the threat.was. 1 made via a third party notification,-'(2) the. threat was overheard; i I

during a CB radio conversation, (3)'the. individuals were, to:

paraphrase, planning to build a bomb and throw the bomb -over the' .]

fence, and (4) there were no collaborating indicators. A l though - the,' j' Security Plan clearly requires compensatory actions under these . , i circumstances, the District maintains'that AP.501 does not require the l declaration of an unusual event for this~ type of occurrence. . 'j The District acknowledges that compensatory measures'were' initiated to ensure the safety of site personnel. However,- these-measures were  !

precautionary only and not required. j

4. Corrective actions which have been 'takenand results: achieved.- :j 1he Emergency Preparedness Department'has reviewed the event with .l Operations and Security, and has re-enforced-methodologies used in.

classification of Security-related events,

b. Corrective actions which will be taken.

l'he Emergency Preparedness Department will revise AP'. SUI-toLimprove-the process by which Emergency Plan Lvents are recognized'and c lassi fied . 1his revision will be completed by? July 31,L1987. Once.

revised, AP. SUI will be included in the current Emergency Preparedness training cycle. This training cycle is scheduled for completion by .j October 31, 1987.

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w, ,- l 1he Security Department has consnitted to conduct Security Contingency

-... Plan. Training'for Nuclear Operations senior personnel.

6. ' Date when full. compliance will be achieved. ,

.f ull compliance will be achieved at the conclusion'of the current training. cycle on October 31, 1987.

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