ML20129A038

Notice of Violation from Insp on 960916-20.Violation Noted: Noted:Failure to Audit Access Authorization Program within 12 Months of Implementation.Failure to Conduct Audits of Nine Accepted Contractor & Vendor Access Authorization

ML20129A038
Person / Time
Site:	Pilgrim
Issue date:	10/11/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20129A027	List: ML20129A022 ML20129A038 ML20129A044
References
50-293-96-09, 50-293-96-9, NUDOCS 9610220008
Download: ML20129A038 (2)

Text

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NOTICE OF VIOLATION Boston Edison Company Docket No. 50-293 Pilgrim Nuclear Power Station, Unit 1 License No. DPR-35 j During an NRC inspection conducted on September 16-20,1996, violations of NRC ,

requirements were identified, in accordance with the " General Statement of Policy and j Procedure for NRC Enforcement Actions," (60 FR 34381; June 30,1995),' that violation is i listed below:

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A. The Pilgrim Nuclear Power Station Physical Security Plan, issue 2, Revision 11,

- dated December 22,1993, Section 5.1.1, states, in part, that the requirements for ,

j unescorted access shall include conformance to all elements of Regulatory Guide j 5.66 to satisfy the requirements of 10 CFR 73.56. NRC Regulatory Guide 5.66, states, in Section 13.0, paragraph 13.1, that an independent evaluation of the unescorted acesss authorization program and its conformance must be made within 12 months of the effective date of implementation of the access anthorization i program. Thereafter, an independent evaluation must be conducte J at least once l' every 24 months. The utility shall retain all reports of evaluation for a period of F three years. The Code of Federal Regulation,10 CFR 73.56(g)(1), states, in part, 1 that licensee's shall audit its Access Authorization Program witnin 12 months of its i effective date of implementation of this program and at letst every 24 months thereafter to ensure that the requirements of this section are satisfied.

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s l Contrary to the above, during this inspection, it was determined that Boston Edison i Company failed to audit its access authorization program within 12 months of its

implementation (April 27,1992). The first audit of the program was conducted i October 11 - November 19,1993,~19 months after implementation of its program.

l Additionally, as of the date of this inspection, no other audit of the Access j .- Authorization Program had been conducted. Therefore, the requirement to perform j an audit of the program at least 24 months after the audit performed within 12

months of implementation was also not performed.

i This is a Severity Level IV Violation (Supplement Ill).

B. The Pilgrim Nuclear Power Station Physical Security Plan, Issue 2, Revision 11, 3

dated December 22,1993, Section 5.1.1, states, in part, that the requirements for unescorted access shallinclude conformance to all elements of Regulatory Guide

, 5.66 to satisfy the requirements of 10 CFR 73.56. NRC Regulatory Guide 5.66,

states, in Section 13.0, paragraph 13.2, that the utility or its designated

! representative shall conduct annual audits of contractor or vendor access

authorization programs to ensure compliance with these guidelines. Other utilities

may accept the originating utility's audit and need not reaudit the same contractor

or vendor for the same period of time providing the scope of the audit meets the

! minimum auditing criteria contained in Attachment A. A copy of the audit report to

include findings, recommendations, and corrective action must be provided to the F sharing utility. The Code of Federal Regulation,10 CFR 73.56(g)(2), states, in part, j that each licensee who accepts the Access Authorization Program of a contractor or vender shall have access to records and shall audit contractor / vendor programs 9610220008 961011 PDR ADOCK 05000293

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i Notice of Violation 2

every 12 months to ensure that the requirements are satisfied. Licensees may accept audits of contractor / vendor program conducted by other licensees. Each sharing utility shall maintain a copy of the audit report, to include findings, i recommendations and corrective actions.

i Contrary to the above, during this inspection, it was determined that Boston Edison Company failed to conduct audits of the nine accepted contractor and vendor

access authorization programs every 12 months and could not produce a copy of another utility's audit of the same contractor or vendor, f

i This is a Severity Level IV Violation (Supplement Ill).

I Pursuant to the provisions of 10 CFR 2.201, the Boston Edison Company is hereby 1

- required to submit a written statement or explanation to the U. S. Nuclear Regulatory l 1 Commission, ATTN: Document Control Desk, Washington, D.C. 20555 with a copy to the Regional Administrator, Region I, and a copy to the NRC Resident inspector at the facility  :

that is the subject of this Notice, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of

Violation" and should include for each violation

(1) the reason for the violation, or, if contested, the basis for disputing the violation, (2) the corrective steps that have been

taken and the results achieved, (3) the corrective steps that will be taken to avoid further i violations, and (4) the date when full compliance will be achieved. Your response may i reference or include previous docketed correspondence, if the correspondence adequately 4 addresses the required response. If an adequate reply is not received within the time

specified in this Notice, an order or a Demand for Information may be issued to show cause why the license should not be modified, suspended, or revoked, or why such action as may be proper should not be taken. Where good cause is shown, consideration will be 1 given to extending the response time.

Because your response will be placed in the NRC Public Document Room (PDR), to the l j extent possible, it should not include any personal privacy, proprietary, or safeguards information so that it can be placed in the PDR without redaction. However, if you find it necessary to include such information, you should clearly indicate the specific information that you desire not to be placed in the PDR, and provide the legal basis to support your request for withholding the information from the public.

I Dated at King of Prussia, Pennsylvania this 11th day of October,1996 i

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