IR 05000373/1985029

Discusses Special Safeguards Insp Repts 50-373/85-29 & 50-374/85-30,on 850827-28 & 0903-06 & Forwards Notice of Violation & Proposed Imposition of Civil Penalty.Integrity of Badge Sys Inadequate.Encls Withheld (Ref 10CFR73.21)

ML20137A414
Person / Time
Site:	LaSalle
Issue date:	11/08/1985
From:	James Keppler NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:	Oconnor J COMMONWEALTH EDISON CO.
References
NUDOCS 8601140364
Download: ML20137A414 (4)

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Oni L u . - - . . . . . . u t o ed NOV 0 81965 Docket Nos. 50-373; 50-374 Licenses No. NPF-11; NPF-18 EA 85-114 Commonwealth Edison Company ATTN: Mr. James J. O'Connor President Post Office Box 767 Chicago, IL 60690 Gentlemen:

This refers to the special safeguards inspection conducted by D. A. Kers of this office on August 27-28, 1985 and Mr. J. L. Belanger on September 3-6, 1985, of activities at the LaSalle County Station, Units 1 and 2, authorized by NRC Operating Licenses No. NPF-11 and No. NPF-18. The results of this inspection were discussed on September 17, 1985 during an Enforcement Conference between Mr. C. Reed and others of your staff and Mr. A. B. Davis and others of the NRC Region III staf The inspection revealed that you did not adequately protect the integrity of the badge system which could have allowed access into protected and vital I areas of the LaSalle facility. This violation reflects a weakness in fully implementing and maintaining in effect the provisions of your NRC-approved Physical Security Plan. Of significant concern is the fact that the event involved faulty judgment on the part of top level security management at the LaSalle facility. We are also concerned with your improper reporting of the event to the NRC. Although you reported the event to the Resident Inspector and the Region III Office, you did not report the event to the NRC Operations Center in accordance with 10 CFR 73.71(c).

To emphasize the importance of maintaining adequate control over the integrity of your badge system, I have been authorized, after consultation with the Director, Office of Inspection and Enforcement, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of Thirty-seven Thounnd Five Hundred Dollars ($37,500) for the violation described in the enc' d Notice. The violation has been categorized as a Severity Level III violation in accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1985).

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, - - n n rm w Sn. . _ _".ML+- m e- efs Commonwealth Edison Company 2 NOV 0 8 G85 The event could have been categorized as a Severity Level II violation under the Enforcement Polict- in that two of the three elements of access control were inadequate in both the protected and vital areas. However, the possibility of a security compromise was significantly reduced because of the small probability of locating and using the keycards. Therefore, the event which occurred at the LaSalle facility is appropriately classified as a Severity Level III violatio The base civil penalty for a Severity Level III violation is $50,000. The NRC Enforcement Policy allows for reduction of a civil penalty under certain circumstances. In this case, the base civil penalty is reduced by 25 percent because of your prompt and extensive corrective action which included

(1) an intensive effort to recover all improperly discarded badges; (2) posting a security officer at the ingress turnstile to assure proper usage of cards; (3) reviewing 6,000 files to identify rejected badges; (4) identifying and deleting 2,125 badge numbers from the system; (5) revising the procedure for badge issuance and disposal; ard (6) issuing directives to all CECO nuclear stations concerning badge disposal. We consicered reducing the civil penalty by an additional 25 percent. However, no further mitigation is warranted because the violation was caused by actions of plant security management, contrary to security training procedures, and resulted in the badges being potentially available for misuse for approximately two months before the discovery of the improper disposa You are required to respond to this letter and should follow the instructions specified in the enclosed Notic In your response, you should document the specific actions taken and any additional actions you plan to prevent recurrenc You should place all Safeguards Information as defined in 10 CFR 73.21 only in enclosures, so that your letter may be placed in the Public Document Room. 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, with the exception of the cover letter, this material will not be placed in the Public Document Roo Enc 10:Ure containa f{QSI:lFC;mkTIO:1 ntwo tm

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Commonwealth Edison Company 3 NOV 0 8 $85 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 required by the Paperwork Reduction Act of 1980, PL 96-51

Sincerely, Original siped by J.ucs G. Keppler James G. Keppler Regional Administrator Enclosures: Notice of Violation and Proposed Imposition of Civil Penalty Inspection Reports No. 50-373/85029(DRSS); and No. 50-374/85030(DRSS)

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