IR 05000305/1993018

Insp Rept 50-305/93-18 on 930823-31.Apparent Violation Being Considered for Escalated Enforcement Action.Major Areas Inspected:Review of Circumstances Involving Inadequate Storage of Safeguards Info at Licensee Corporate Ofc

ML20149D471
Person / Time
Site:	Kewaunee
Issue date:	09/09/1993
From:	Belanger J, Creed J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20149D453	List: IR 05000305/1993018 ML20149D450
References
50-305-93-18, NUDOCS 9309210047
Download: ML20149D471 (6)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-305/93018 Docket No. 50~-305 Licensee: Wi;consin Public Service Corporation  :

Po;t Office Box 19002 Green Bay, WI 54307-9002 Facility Name' Kewaunee Nuclear Power Plant Inspection At Corporate Headquarters, Green Bay, Wisconsin Inspection Conducted: August 26, 1993, onsite August 23-25,30-31 1993 in Region III Office Inspector: 3m k 9!7!93 ames L. Belanger Date 6nior Physical Security Inspector >

Approved By: hu James E Creed, Chief Date (Sp'eguardsSection f

Inspection Summarv

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Inspection On Auaust 23-31. 1993 (Report No. 50-305/93018(DRSS))

Areas Inspected: Included a review and discussion of circumstantes involving a licensee identified incident of inadequate storage of Safeguards Information at the licensee's corporate offic Results: Based on the results of this inspection, one potential violation was identified regarding failure to adequately secure some significant Safeguards Information. The licensee identified attd the violation and logged it in their safeguards event log. The ease of which the open container could be located and identified was somewhat difficult. The licensee was able to account for all of the documents and believes that the Safeguards Information was not compromise l I

9309210047 930910 PDR ADOCK 05000305 4

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M PORT DETAILS j l

1. Key Persons Contacted

• R. Pulec, Nuclear Licensing and Systems Superintendent, Wisconsin Public Service Corporation (WPSC)

• R. Draheim, Assistant Manager, Nuclear Projects, WPSC

• D. Molzahn, Assistant to Nuclear Licensing, WPSC

• D. Nalepka, Security Director, Kewaunee Nuclear Plant, WPSC L. Molzahn, Drawing Control Clerk, WPSC P. Finemore, Risk Assessment Engineering Supervisor, WPSC

• Denotes those present at the Exit Interview August 26, 1993 2. Entrance and Exit Interviews  ; At the beginning of the inspection, Mr. D. Nalepka, Security Director, and other staff members were informed of the purpose of this inspection, its scope, and the topical areas to be examine The inspector met with the licensee representatives, denoted in Section 1, at the conclusion of the onsite inspection activitie A general description of the scope and conduct of the inspection was provided. Briefly listed below are the findings discussed during the exit intervie The inspector described a potential escalated violation involving a failure to adequately secure Safeguards Information. The inspector noted that the licensee identified that the security storage cabinet within the corporate headquarters which contained significant Safeguards Information was left unlocked and unattende The licensee initiated corrective action, as described in Section 4 of the Report Details, to prevent recurrenc Licensee management agreed with the facts presented by the inspector regarding the unsecured container. They emphasized that the event was identified by the licensee, properly logged, and that corrective action was immediately implemente On August 30, 1993, the Kewaunee Security Director was contacted to obtain information on previous loggable events relating to unsecured and unattended Safeguards Informatio On August 31, 1993, a telephone interview was conducted with'the corporate employee who had an opportunity to identify the even . - - . . - - _ . - . -

• Prooram Areas Inspected (MC0601):

Listed below are the areas which were examined by the inspector within

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the scope of these inspection activities. These areas were reviewed and evaluated as deemed necessary by the inspector to meet the specified j

" Inspection Requirements" (Section 02) of the applicable NRC Inspection Procedure (IP) and appropriate NRC regulations. Only those areas in ,

which findings were identified are discussed in subsequent report sections. Sampling reviews included interviews, observations and :

document reviews. The depth and scope of activities were conducted as :

deemed appropriate and necessary for the program area being inspecte Number Proaram Area and Inspection Reouirements Reviewed 81038 Records and Reports: (02) Reports of Physical Security Events 81810 Protection of Safeauards Information: (01) General; (02)

Access to Safeguards Information; (05) Storage; ,

(07) Reproduction Protection of Safeauards Information (IP 81810): One potential ,

violation was identified and is described below:

On July 6, 1993, the Assistant to the Nuclear Licensing and Systems Superintendent, upon reporting to work at approximately 7:30 a.m., found his Safeguards Information container-unlocked and unattended. The licensee later determined that the security container was in this condition from approximately 1:00 p.m., July 1,1993, to approximately 7:30 a.m., July 6,1993 (a period of four days and eighteen and one half hours). This was a potential violation of 10 CFR 73.21(d)(2) which requires unattended Safeguards Information to be stored in a locked security storage containe The office of the Assistant to the Nuclear Licensing and Systems Superintendent is located in the Nuclear Division Office Building, one of three separate buildings of the corporate complex that are interconnecte The corporate offices are located in downtown Green Bay, Wisconsi Wisconsin Public Service Corporation is the sole occupant of the buildings. Access to the complex during non-working hours is gained through entrances which are key".ocked. A contracted security force provides roving watchman patrols of each floor during .off-hours. The '

security container is physically located on an inside wall of the office and is not visible from outside the office are '

The licensee's investigation of the incident showed that on July 1, 1993 a Nuclear Documentation Clerk had filed several microfilm drawing cards and did not return the locking bar prior to locking the GSA approved padlock. The cabinet locking system design requires an individual to unlock the combination padlock and to physically remove the locking bar

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from the cabinet. In this instance, the clerk opened the file, closed the file drawer, and relocked the combination padlock in the eye-bol The clerk failed to recognize that the locking bar had not been inserted l as required. Upon returning to this office on July 6,1993, after having been out of the office during the previous week, the Assistant to the Nuclear Licensing and Systems Superintendent identified the improperly secured cabine The clerk who failed to properly secure the cabinet stated that she was aware of her responsibility to secure the container. She recalled locking the container, but did not recall checking to assure that the bar was in plac During the afternoon that the incident occurred, the Risk Assessment Engineer Supervisor periodically utilized this office because his own office was being occupied. He stated that he recalled seeing the *

locking bar against a wall. He was aware that the Assistant to Nuclear Licensing and Systems Superintendent had previously been involved with -

security at the Kewaunee plant and had stored safeguards information in this container. He also knew that much of the responsibility for plant security had been transferred from the Assistant to Nuclear Licensing and Systems Superintendent to the site Security Director. He assumed that the safeguards information had been transferred to the site and that the cabinet was no longer equipped with a locking bar because the material had been transferred. He also assumed that the cabinet was not locked because the locking bar was not attached. The Risk Assessment Engineer Supervisor's responsibilities did not involve access to safeguards information and was not specifically trained in the company's security directives governing the protection of safeguards information except for general information that is presented during the General .

Employee Trainin The Assistant to Nuclear Licensing and Systems Superintendent discovered the unsecured container at 7:30 a.m. on July 6, 1993. He immediately contacted the WPSC Security Operations Supervisor at the Kewaunee ,

Nuclear Power Plant to discuss the event and determine the appropriate reportability actions. An immediate evaluation of the documents contained in the cabinet was performed to determine if any information was missing and whether the event met the threshold of a one hour reportable event in accordance with 10 CFR 73.71 and Generic Letter 91-03. The evaluation led to the conclusions that there was no apparent loss or theft of safeguards information and that the information in the cabinet would not significantly assist an individual in gaining unauthorized or undetected access to the facility. The licensee '

concluded that the event was loggable and would be submitted to the NRC in the next quarterly loggable event repor t On August 3, 1993 during a telephone conversation with a NRC Region III security inspector, the WPSC Security Operations Supervisor was discussing various security issues. During the discussion, the above incident was reviewed to include the significance of the issue from an

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enforcement perspective because the lack of adequate control of safeguards information occurred outside the protected are Following this conversation, without instruction from the NRC, the licensee conservatively elected to report the event to the NRC under a 10 CFR 73.71 one hour event notificatio The licensee's immediate corrective actions when the event was identified on July 6,1993 included:

• Page by page review of the security manua * Review of each file to determine if any information was missin ,

e Review of microfilm cards to ensure that there were no card . Counselled the document clerk on the importance of ensuring that the file is locked when left unattende ,

Subsequent to the licensee's August 3, 1993 telephone discussion with a Region III security inspector, the licensee initiated the following additional corrective actions:

• Relocated all corporate safeguards information to within the protected area at Kewaune e On August 3, 1993, a training session was presented to the corporate clerical support personnel to discuss this event and to emphasize the importance of controlling safeguards informatio e On August 4,1993 the Kewaunee security force and operations personnel were informed of the event and to increase their security awareness. An announcement was made at the plant morning meeting and a request was made that plant personnel also demonstrate heightened security awareness, e An inventory of all documents in the affected corporate file cabinet for the purpose of developing a matrix to document the significance of the information availabl * Each holder of safeguards information was contacted in an effort to determine the need in all areas for security safeguards files. If it was determined that the file was for convenience only, efforts should be made to combine or eliminate files to reduce the number of files maintained and therefore reduce the possibility of having uncontrolled safeguards information. This effort has resulted in the reduction of cabinet * The licensee is evaluating additional methods that could be used to better control safeguards cabinets. Consideration is being given to developing cabinet access control forms requiring the signature, date and time of accessing cabinet .

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The licensee's inventory results showed that all marked documents .

containing Safeguards Information were located and accounted fo Although, building watchmen during the off hours observed no unusual l activity in the building, they were not required to specifically check the safeguards cabine The inspector reviewed the licensee's investigative results and concluded that the security container was not secured for a period of four days, eighteen and one half hours. Safeguards Information which could significantly . assist someone in an act of radiological sabotage was stored within the security container. However, the potential for -

compromise of the Safeguards Information was low. This conclusion is based on the randomness of the time period the security container was left unlocked. The unlocked security container was not easy to identify ,

because the file cabinet was located in an area of the office not visible from the office doorway and the file cabinet was not labeled as a safeguards information container. Additionally, although the cabinet was not properly secured with a locking bar, the cabinet did have the ,

combination lock inserted and locked giving the appearance that it was locked to the casual observer. Also contributing to the difficulty in locating and identifying the security container was the size of the office buildin Finally, some degree of access control was provided by ;

locked doors and main entrances controlled by receptionist >

Collectively, these factors resulted in the determination that there was a relatively low potential that the information was actually '

compromise !

This finding represents a potential violation of NRC regulations that require that Safeguards Information be locked in a secured container if '

left unattended. The failure resulted from human error (failure to lock j the container). The licensee has taken adequate initial corrective ;

actions that should prevent recurrenc i i-l i

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