BSEP-92-0042, Responds to NRC Ltr Re Violations Noted in Insp Repts 50-324/92-28 & 50-325/92-28.Corrective Actions:Two Drawer GSA Approved Vault Was Moved to Area After Concern Was Raised & Safeguards Info Was Relocated to Vault

Responds to NRC Ltr Re Violations Noted in Insp Repts 50-324/92-28 & 50-325/92-28.Corrective Actions:Two Drawer GSA Approved Vault Was Moved to Area After Concern Was Raised & Safeguards Info Was Relocated to Vault

ML20127N250
Person / Time
Site:	Brunswick
Issue date:	11/25/1992
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
BSEP-92-0042, BSEP-92-42, NUDOCS 9212010108
Download: ML20127N250 (8)

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CD&L Carolina Power & Light Company Brunswick Nuclear Project 3 P. O. Box 10429 Southport, N.C. 28461-0429 November 25, 1992 FILE: B09-13510C 10CFR2.201 SERIAL: BSEP-92-0042 U.S. Nuclear Regulatory Comnission ,

ATTN: Document Control Desk Washington, D. C. 20555 BRUNSWICK STEAM ELECTRIC PLANT UNITS 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 REPLY TO A NOTIql OF VIOLATION Gentlemen The Brunswick Steam Electric Plant (BSEP) has received NRC Inspection Report 50-325/92-28 and 50-324/92-28 and finds that it does not contain information of a proprietary nature. This report Aneluded a Notice Of Violation.

Enclosed is Ct.rolina Power & Light Company's response to that Notice Of Violation.

Very truly yours, I h W R. E. Mor n, Interim Site Manager Brunswick Nuclear Project l

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Enclosure Ju0150 cc: Mr. S. D. Ebneter j Mr. R. H. Lo BSEP NRC Resident Office c,

9212010108 921125 f'y\\ \

PDR ADOCK 05000324 , ,

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ENCLOEUPS BRUNSWICK STEAM ELECTRIC PLANT, UNITS 1 AND 2 NRC DOCKET NOS. 50-325 & 50-324 OPERATING LICENSE NOS. DPR-71 & DPR-62 REPLY TO NOTICE OF VIOLATION VIOLATION At A. 10 CFR 73.21(d)(2) requirer that while unattended, Safeguards Information sha'1 ba stored 17 a locked secur!.ty storage container. 10CFR73.2 defines a " Security Storage container" as one of the following repositories:

(1) For storage in ' building located within a protected or controlled accecs area, a steel filing cabinet e, ipped with a steel locking bar and a three position, changeable con'ination General Services Administration (GSt., approved padlock.

(2) A sacurity filing cabinet that bears a Teuc certification Label on the side of the locking drawer, or interior plate, and is marked,

" General Services Ad_ ministration Appre .d Security container" on the

< exterior of the top drawer or door.

(3) A ber.k safe-deposit box.

(4) Other repositories which in the judgement of the NRC would provide comparable physical protection.

The licensee invokes the above requirement by Administrative Instruction AI-120, Protection c' Safeguards Information, Revision O. AI-120, Paragraph 6.11 specifies that safeguards information be stored in an authorized locked security storage container meeting the requirements which are identical to (1), (2) and l (4) above.

c strary to the above, on Septemb9r 16,1992, it hacame apparent that Safeguards Information (i.e. , Security Plan and Procedures) stored in a .cooden cabinet with exposed hinges and locked by a non-GSA approved paalock was in an office not always attended.

This is a Severity Lovel IV violation (Supplement I),

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4 Rif0NSE TO VIOLATIOf(_At Admission er Denig).of Violation Carolina Power & Light (CP&L) admits to the violation, Egigpa_fpr the Violations The lo' ad wooden cabinet referenced in the NOV contained security guard force sontingency weapons as well as safoguards Information (SGI) and is located in a 4ard ready roon . This area is located behind an outer office normally occupied by necurit" personnel. AI-120, referenced in the Motice of Violation, allows for SGI "Contro) while in use". At-120, Section 6.13 states that the primary consideration in limiting access to those who have an established "need to know".

This is supported by NUREG 0794 which states that the requirement in section 73.21(d) is " satisfied if the matter is at. tended by an authorized individual even though th9 information is in fact not constantly being used. safeguards inform.ttion, therefore, within alarm stations, continuously manned guard posts or ready rooms need not be locked in security storage containers."

NUREG 0794 continues to say that "Under certain conditions the general control exercised over protected or controlled access areas would be considered to meet this requiremer.t. The primary consideration is limiting access, to those who have a need-to-know.* NUREG 0794 does not state that the area must be "occuoied" at

' all times. Therefore, CP&L interpreted this to mean that since the area has only one entrance which is always " attended" the intent of the guidance was met.

Security personnel are always on the search line and at the badge issue counter which is immediately adjacent to the entranca of the area. Additionally, a window from the Central Alarm Station overlooks the outer of fice area. Therefore, Security officers on duty are aware of anyone who enters the room and access to thin area is limited. Considering the guidance in NUREG 0794 and the fact that the SGI material was locked in a cabinot with weapons, CP&L believed that the intent of '.imiting access to those who had a "need-to-know" was met.

i parrectivo Stele which HMvs Been Taken pnd Results Act'y gfit A two drawer GSA approved vault was moved to tbr area after the concern was raisod and tha safeguards Information was reloem 1 to the vault.

E.grrective Stens Which Will_pe Taken to Avoid Further Violatiorge Mona.

Qate When Full Comollig e Will Be Achieveds i

I CP&L is in full comfl ance.

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d VIOLATION B:

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B. Facility operating licenses DPR-71 and DPR-72 respectively require the i licensee to fully implement and maintain in ef fer:t all provisions of the

{ commission-approved Physical Security Plan.

1 Section 3.2.2.4 of the licensee's Physical Security Plan defines l

l authorised persons as individuals authorized unescorted access to the protected area ar. ' .equired positive control of designated vehicles to

ensure that they are used only by authorized individuals.

Section 4.5 of the Physieni Security Plan requires personnel authorized i entry to the protected or vital areas as Escorted Personnel be escorted in j accordance with security instructions.  !

) Administrative Instruction AI-70, Dasic Security Requirements for CP&L ,

j Employees, Revision 10, implements this requirement. Paragraph 4.18 of A- l l

70 states that it is the primary function of personnel performing escort! j

! duties to maintain positive control over all escorted visitors while within the protected areas normally through visual contact, or not leaving the visitor unattended by remaining in close proximity to the assigned l visitor.

j contrary to the above:

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1. On september 14, 1992, the licensee failed to maintain positive I control of designated vehicles, in that a designated vehicle was j driven by an unauthorized person.

i j 2. While in the protected area on September 15, 1992, a visitor went

, behind a railroad tank car out of sight of the escort and another visitor repeatedly entered and moved a designated vehicle without an escort in the vehicle.

t This is a Severity Level IV violation (Suppler.ent III).

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) ErsPonse TO VIOLATION 11 1 Admission or Denial of violation:

CPGL admits to the violation.

Peason for Violations EXAMPLE 18 On september 14, 1992, a contract fence company arrived at the Brunswick site to replace fence material around the chlorine tank car off-loading area located inside the pt otected area. CPIL Outage Management and Modification (OM&M) had

1anned the job and was responsible for supervision of the evolution.

Since the contractor's vehicle carried needed materials it was necessary to take the vehicle inside the protected area during the work. OM&M personnel requested that CP&L Security designate the contractor's vehicle. This is within the scope of the Security Plan and Security Procedures as long as the driver is an

' authorized" individual. ( An authorized person is one who has unescorted access i.e.; badged individual). security personnel understood that the driver of the vehicle would be the OH&H person requesting the designation when in f act it was intended that the driver would be a working visitor from the contract fence company. Consequently, an unauthorized person drove e designated vehicle inside the protected area.

The cause of the event was a lack of understaniing concerning the use of designatad vehicles and a lack of communication between OM&M personnel requeating the designation of the vehicle and Security personnel granting the request.

EXAMPLE 2:

Since the fence job was scheduled to be completed in approximately ten days, the decision was made to allow the contract fence personnel to work on business visitor badges escorted by a person f rom the OM&M group. For short duration jobs this is an accepted pract. ice and allowed by Brunswick site procedures. An individual with unescorted access may escort as many as five visitors; however, this is not appropriate tor all jobs. In thio event, one o! the working v1 itors was observed out of eight of the escort and another visitor entered the contractor's vehicle and repositioned it inside the protected area without an escort.

Since the cited event, an adverse trend in the escort process has developed.

Three other events involving working visitors have occurred at Brunswick. One event involved an incomplete transfer of a visitor f rom one escort to another and two events involved visitore being left unattended while inside the protected area. These occurrenceu are partially due to the large number of personnel on

-site at this time and the f act that many personnel were performing work on a visitor badge.

The intent of the escort program is to allow technical vendor representatives, home office contractor visitors, and short term contractors, etc., to have

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escorted short term access to the protected area. Short term is normally seven days or less but generally would not exceed two weeks. During the time of these events this was not the practice. Personnel were working inside the protected area on a visitor badge for extended perirds of time.

Brunswick did not have a specific training program for escorts which was an additional contributing factor. During General Employee Training limited information is disueminated on the escort policy at Brunswick. The policy at the time of these events allowed anyone with unescorted accens to escort up to five visitors inside the protected area.

The reason for the violation is a lack of understanding of " control of visitorn" and the use of designated vehicle 6 inside the protected ares.

Corrective Actions Which Have Been Taken The number of working escorts has been reduced.

Two of the major contractors at the site havo implemented escort training and are qualifying their escorto prior to assigning escort duties.

Corrective Actions Which Will Be Taken to Avoid Further Violati,0.ng:

The Security Instruction, SL 10 Vehicular Traffic and Parking control will be revised to clarify the use of designated vehicles inside the protected area by December 30, 1992.

In lieu of allowing any badged individual to be an escort, the escort process will be revised to require that escorts be designated by a CP&L supervisor by February 15, 1993. Supervisors will be accountable for designating only those individuals f amiliar with site layout, procedures and practices. Additional training will be provided to the designated individuals.

Date When Full Comoliance Will Be Achieved:

CP&L is in full compliance.

ViQtATION C {

i C. 10 CFR 50, Appendix B, Criterion VI, requires that measures shall be established to control the issuance of documents which prescribe all activities af fecting quality and measures shall assure the documents are approved for release.

Record Management Procedure (RMP) 003, Reproduction, Distribution and Accountability of Plant Documents, Revision 48, implements this requirement. Paragraph 3.5 requires that holders of copies of controlled documents maintain these files up to date and current.

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contrary to the above, in september 18, 1992, it was determinod that the operation control Room Production Assistants were disposing of the coretolled copies of d::awings when preliminary drawing revisions were raceived from the Nuclear Engineering Department. This was accomplished prior to issuance of approved drawing revisions.

This is a severity Level IV Violation.

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B*RtMBLik A iEl M_C8 I

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% d,1% b"6 Aa.J#.a.'A Vielation I

e *, t #' that controlled copies of drawings were being disposed of upon r ,w h advance copies of revised drawings from the Nuclear Engineering i @Juw (NED). CP&L requests that this violation be revised to severity Level 1 c based upon it being an administrative error with minor safety or environmental significance.

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Reason for the Violations

A 1988 non conformance, SFR-18-042, identified that as-built piping and instrun.ent diagrams (P&ID's) were not available to operations personnel duting a

the time interval between snodification operability and transmittal of the

, revised, contro11e.1 copy of the P&ID by Document Control. The agreed upori

! corrective action .;is for the Engineering group to provide the revised P&ID to I the modification Responsible Engineer (RE) in parallel with the distribution to

Document Control. The RE would then deliver the drawings to operations to support system operability. The copy provided to operations would be annotated to identify it as an advance copy. The advance copy would subsequently be replaced by the copy issued by Document Control. This process was documented in j operations procedures.

The intent of this proceos was to provide plant operators with revised copies of

as-built documents, which reflect system design / modification (s) changes, in a timely manner. The advance copies were a duplicate of the copy forwarded to j Document control for distribution and were reviewed and approved for release by authorized personnel. However, the advance copies were not " controlled copies" in that they bypassed the Document control administrative process.

Corrective Steps Taken and Resulte Achieved i

( As an interim action, the Operation Control Room Production Assistants were

! directed to attach the. advance copy to the existing controlled copy. The old controlled copy and the c.dvance copy were disposed c.f when the revis;ed control copy was received from Document Conteca.

I As of November 25, 1992, the operation's advance copies are no longer being generated. Document Control is providing distribution, as needed, to support l operability.

I Corrective Steos That Will Be Taken To Avoid Further Violationg l

None.

Date of Pull Comoliance:

CP&L is in full compliance.

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