W3P86-0082, Proposes Changes to Audit & Annual Evaluation Procedures for Security Program.Annual Audit Will Be Separated Into Three Audits:Administration/Program,Hardware/Maint & Contingency Plans & Operations
| ML20198B754 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 05/16/1986 |
| From: | Cook K LOUISIANA POWER & LIGHT CO. |
| To: | Martin R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| References | |
| W3P86-0082, W3P86-82, NUDOCS 8605220117 | |
| Download: ML20198B754 (3) | |
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LOUISIANA / 3178ARONNESTREET
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P. O. BOX 60340 POWER & LIGHT NEW ORLEANS, LOUISIANA 70160 (504)595-3100
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$uNst,yg 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 iudits 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 commitments 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 wishes 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 implemented, this approach will continue to assure that all subject areas g
have been reviewed in a 12-month period.
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PDR ADOCK 05000382
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.Page 2 W3P86-0082 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 commitments until December 1966.
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 managemer.t and in/ ' 71 duals 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
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- system, j
An audit of the physical protection system testing and j
maintenance program, and 1
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, i
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 ths. St.
Chpries Parish Sheriff's Office were reviewed during the Emergency Preparedness audit completed June 1985. Both agreements appea.ted 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 secu,ity 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.
Page 3 W3P86-0082 We believe the proposed approach will continue to meet the requirements in the regulation, psuvida batter feedbek en management, and the effectiveness of the security program will not be decreased during the transition period.
Very truly yours.
K.W. Cook Nuclear Support & Licensing Manager KWC:BGM:ssf cc:
G.W. Knighton, NRC-NRR J.ll. Wilson, NRC-NRR
- NRC Document? Control l Desk.
NRC Resident Inspectors Office B.W. Churchill W.M. Stevenson J.A.F. Kelly
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