IR 05000305/1993020
| ML20057E341 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 09/30/1993 |
| From: | Belanger J, Creed J, Snell W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20057E335 | List: |
| References | |
| 50-305-93-20-EC, NUDOCS 9310120041 | |
| Download: ML20057E341 (26) | |
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION III
I Report No. 50-305/93020(DRSS)
Docket No. 50 305 License No. DRP-43 Licensee: Wisconsin Public Service Corporation Post Office Box 19002 Green Bay, WI 54307-9002 Facility Name: Kewaunee Nuclear Power Plant t
Meeting Conducted:
September 23, 1993 Meeting At: Telephone Conference Call
Type of Meeting:
Enforcement Conference Inspection Conducted: August 26, 1993, onsite
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August 23-25, 30-31, 1993 in Region III
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.9 /3cL91 Inspector:
L.9elanger Date Senior Physical Security Inspector
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ReviewedBy:pJamesRFCreed, Chief Date
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Safeguards and Incident Response Section Approved By:
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William Snell, Acting Chief Date ~
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Reactor Support Programs Branch
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Meetina Summary t
Enforcement Conference on September 23. 1993 (Report No. 50-305/93020(PRSS))
Areas Discussed:
Included a review of the apparent violation identified during a reactive inspection conducted on August 26, 1993, at the licensee's corporate office in Green Bay, Wisconsin, and reviewed on August 23-25, 30-31, 1993, in the Region III office. Corrective actions taken or planned by the licensee were discussed. The. enforcement options pertaining to the apparent
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violation were also discussed with the licensee. The licensee summarized the event, their evaluation, corrective actions and security significance of the event.
Results: The licensee agreed with the apparent violation. The licensee concluded that the event did not pose a significant threat to the health and safety of the public because the potential for compromise was low and the significance of the information available was limited.
9310120041 931001 f
PDR ADDCK 05000305 t
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DETAILS
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Persons Present Durina Telephone Conference Call
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WISCONSIN PUBLIC SERVICE CORPORATION - KEWAUNEE NUCLEAR PLANT K. Evers, Manager - Nuclear Plant Support Services
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R. Pulec, Nuclear Licensing and Systems Superintendent i
M. Marchi, Plant Manager D. Molzahn, Assistant to Nuclear Licensing C. A. Schrock, Manager - Nuclear Engineering D. Nalepka, Security Director, Kewaunee Nuclear Plant J. Fletcher, Kewaunee Operations Supervisor
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L. Molzahn, Drawing Control Clerk
NRC Reaion III
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W. L. Axelson, Director, Division of Radiation Safety and Safeguards J. L. Belanger, Senior Physical Security Inspector P. Pelke, Enforcement Specialist
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NRC 0FFICE OF NUCLEAR REACTOR REGULATION R. Laufler, licensing Project Manager 2.
Enforcement Conference
A telephonic enforcement conference call was held between Region III and the licensee at the Kewaunee Nuclear Plant on September 23, 1993.
This
.l conference was conducted as a result of the findings of an inspection conducted at the corporate office on August 26, 1993, in which an apparent violation was identified involving unsecured documents containing significant Safeguards Information at the corporate office on July 6, 1993. This finding was in apparent violation of 10 CFR Part 73.21.
The inspection findings were documented in NRC Inspection Report No. 50-305/93018 and transmitted to the licensee by letter dated September 10, 1993.
The purpose of this conference was to:
(1 discuss the apparent violation, causes, and the licensee's corre)ctive actions; (2) determine if there were any escalating or mitigating circumstances; and (3) obtain any additional information which would help determine the appropriate enforcement action.
In advance of the telephone call, the licensee provided a written description of the event which led to the violation, its root cause, i
corrective actions and security / safety significance of the event.
The licensee did not contest the violation or the facts pertaining'to the event; however, they requested a clarification to their conclusions as stated in the second to last paragraph of page 4 to the inspection I
report details. The licensee stated that their evaluation of the
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information in the cabinet was not only that the information would not
significantly assist an individual in gaining unauthorized or undetected
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access to the facility, but that the information would also not significantly assist someone in an act of radiological sabotage. The i
inspector agreed that the report details should include this-conclusion and that the statement in the second to the last paragraph of Page 6,
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-(i.e. that the safeguards information stored in the cabinet could significantly assist someone in an act of radiological sabotage)' is incorrect. The licensee also noted a typographical error on page 5 in the list of immediate corrective actions, (i.e. review of microfilm
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cards to ensure that there were no cards missing).
The word " missing" did not appear in the report.
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A copy of the licensee's presentation material is included as Appendix A to this report.
Enclosure: Appendix A - Licensee Enforcement Presentation
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ENFORCEMENT CONFERENCE SEPTEMBER 23,1993 L
INTRODUCTION l
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EVENT DESCRIPTION i
EVENT CHRONOLOGY O
CORRECTIVE ACTIONS SECURITY SIGNIFICANCE MITIGATING FACTORS
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INTRODUCTION This report summarizes the results of the investigation into the July 6,1993 security event in which a file cabinet in the corporate office containing safeguards information was left unlocked and uncontrolled. We acknowledge that a weakness did exist in our control of safeguards information.
This report will review the events surrounding the discovery of the unlocked file cabinet, its security significance, the corrective actions initiated and the mitigating circumstances. In addition, Appendix A to this report provides our analysis of the reportability of this event.
WPSC reviewed the NRC Inspection Report dated September 10,1993 and concluded that
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the report correctly describes: the events surrounding discovery, our immediate corrective
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actions, and the follow-up corrective actions taken or planned. Furthermore, WPSC concurs i
with the inspection report finding indicating the potential for compromise of the safeguards
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information was low. Therefore, the focus of this enforcement telephone conference will be l
to concentrate on the mitigating circumstances involving this event. Specifically, we are
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i prepared to discuss the mitigation factors that should be considered in accordance with i
J Section VI.B.2 of the Enforcement Policy.
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Event Description s
On July 6,1993 a file cabinet containing Security Safeguards Information was found unlocked and uncontrolled. The cabinet is located in the Assistant to Nuclear Licensing and Systems Superintendent's office in Wisconsin Public Service Corporation's corporate nuclear office in Green Bay, Wisconsin. Following the identification of the unlocked cabinet an immediate assessment was performed to:
1) verify that no security safeguards material was missing, and 2) determine the cause of the event and potential corrective actions.
i A review of the cabinet contents indicated that no Security Safeguards Information was missing. The investigation into the event concluded that on July 1,1993 the Nuclear Documentation Clerk had filed several microfilm drawing cards and did not return the O
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locking bar prior to locking the file. The cabinet locking design requires an individual to unlock the combination padlock and to physically remove the locking bar mechanism from j
the file cabinet. In this case the clerk accessed the file, closed the file drawer, and re-locked I
the combination padlock in the eye-bolt. The clerk failed to recognize that the locking bar mechanism had not been installed as required. Upon returning to his office on July 6,1993 the Assistant to Nuclear Licensing and Systems Superintendent immediately identified the improperly controlled cabinet.
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EVENT CHRONOLOGY (~(
The following discussion provides a chronology of the events that occurred following discovery of the uncontrolled file cabinet.
On July 6,1993, the Assistant to Nuclear Licensing and Systems Superintendent
contacted the WPSC Security Operations Supervisor to discuss the event and to determine the appropriate reportability actions. An evaluation was performed to determine whether the event met the threshold of a one hour reportable event in accordance with 10CFR 73.71 and Generic Ixtter 91-03.
The results of the evaluation, as documented on the Security Event Report, concluded that the event was loggable and would be submitted to the NRC in our next quarterly loggable event report. The event did not meet the threshold requirement for reporting O
since a determination was made that there was no apparent theft or loss of Safeguards Information and the information in the file cabinet would not significantly assist an
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individual in gaining unauthorized or undetected access to the facility, or would not significantly assist an individual in an act of radiological sabotage or theft of special nuclear material.
o On August 3,1993, at 1330 hours0.0154 days <br />0.369 hours <br />0.0022 weeks <br />5.06065e-4 months <br />, during a telephone conversation with a NRC Region III inspector, the WPSC Security Operations Supervisor was discussing various security issues. During the discussion it became apparent that the lack. of control of safeguard information outside the protected area could be considered a sienificant event and one hour reportable.
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e On August 3,1993, at 1425 hours0.0165 days <br />0.396 hours <br />0.00236 weeks <br />5.422125e-4 months <br />, WPSC decided as a conservative measure to
,Q report the event via a one hour notification to ensure proper notification of this event would occur. The notification of this event was made to the NRC headquarters duty officer.
On August 4,1993, at 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br />, WPSC provided an update to the NRC on the e
activities that were initiated in response to this event. These activities included;
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Preparing a formal inventory of all documents in the file cabinet.
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Informing the KNPP security force of the event and placing the force on alert.
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An announcement was made at the plant morning meeting and a request was made that plant personnel also demonstrate heightened security awareness.
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Identifying all security safeguards cabinets to determine whether they are still O
i ecess>rr ee c8 8 8 their cem*i tie.
WPSC was informed that these actions appear appropriate, however, an inspection would be conducted to review the incident.
- On August 6,1993, an internal memorandum summarizing the event was provided to
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the NRC. This summary discussed the loggability, reportability, corrective actions
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and information that would mitigate the consequences of the event (i.e. file cabinet located in an area not visible from the office doorway, file cabinet not labeled as containing safeguards information, the cabinet did have the combination lock inserted
and locked giving the appearance that it was locked to the casual observer, etc).
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On August 6,1993, as an additional conservative measure, all Security Safeguards e
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Information stored at the WPSC Green Bay Corporate offices was removed to within the protected area at the Kewaunee Nuclear Plant pending implementation of corrective action, o
On August 26,1993, a NRC Regional Inspector arrived at the WPSC Green Bay
Corporate Office to conduct a reactive inspection of the reported event. The inspector talked with key personnel to gather information.
- On August 30,1993, notification was made to the NRC headquarters duty officer that
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this event was being withdrawn as a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> event. The WPSC follow-up evaluation confirmed that the original decision to log the event in accordance with 10CFR 73.71 was appropriate.
e On September 2,1993, a phone call was received from NRC Personnel informing WPSC that the Enforcement Board had met and discussed the KNPP potential violation. NRC personnel informed WPSC that an enforcement conference was being scheduled. The purpose of the conference is to discuss the apparent violation, specifically, the mitigating factors of the event. WPSC was also informed that as a result of the information presented before and during the reactive inspection on August 26,1993, a teleconference discussing the mitigating actions was an acceptable alternative to a face to face meeting at Region III headquarters.
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CORRECTIVE ACTIONS O
On July 6,1993, immediately following the discovery of the event, an investigation was initiated to gather information on how long the file cabinet was open, the situation surrounding why it was open and to determine the security significance. The results of this
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investigation led to the following immediate corrective actions.
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Initiated a page by page review of the Security Manual.
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Conducted a review of each file to determine if there was any obvious information missing.
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Completed a review of the microfilm cards to ensure that there were no missing cards.
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Counselled the affected individual on the importance of ensuring the file is locked when left unattended.
The following subsequent corrective actions have been or will be taken as a result of this event:
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On August 3,1993, at 1000 hours0.0116 days <br />0.278 hours <br />0.00165 weeks <br />3.805e-4 months <br />, a training session was presented to the corporate clerical support personnel and drawing control personnel to discuss this evert and to
emphasize the importance of controlling safeguards information.
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On August 4,1993 the KNPP security force and operations personnel were informed O
that ther sheeid be en a hei htened sense ef awereness dee te the Petenti i
compromise of safeguards information in the corporate office. An announcement was made at the plant morning meeting informing plant personnel of the event and the request that plant personnel also demonstrate the heightened awareness. Security personnel had already been on heightened awareness due to the TMI/World Trade Center events however a re-emphasis was provided specific to the potential l
compromise of Security Safeguards Information.
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The KNPP Security Group immediately contacted all " owners" of cabinets containing i
Security Safeguards Information and informed them of the event. As an immediate contrcl measure the Security Group changed the combination on all the safeguards files and required " owners" to contact security if the file needed to be opened. This action would provide added assurance that security safeguards information cabinets would be properly controlled pending implementation of further corrective actions.
4)
An inventory of all documents in the affected corporate file cabinet was performed and a matrix was developed to document the significance of the information available.
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The Security Group is contacting each owner of files containing Security Safeguards Information. An effort is underway to determine the need in all areas for security safeguards cabinets. If it is determined that the cabinet is for convenience only, efforts will be made to combine / eliminate files to reduce the number of cabinets O
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maintained and therefore reduce the possibility of having uncontrolled documentation.
O r eis errert 8 s ir= 87 reseited i= 18e ree ectie er c dieets.
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WPSC is evaluating the various methods that could be used to better control these l
cabinets. Consideration is being given to developing cabinet access control forms which will require the signature, date and time of individuals accessing cabinets.
i The above mentioned actions have been promptly taken to prevent future occurrence. WPSC
recognizes the need to control safeguards material and is taking every reasonable action to
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ensure that this type of an event does not recur.
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SECURITY SIGNIFICANCE O
WPSC acknowledges the fact that the security container was not secured for a period of approximately 4 days, eighteen and one half hours. The information available in the affected cabinet was significant information however, the information available could act significantly assist an individual in gaining unauthorized or undetected access to the facility or significantly assist an individual in the act of radiological sabotage or theft of special nuclear material. Specific details supporting this position are included in Appendix A to this report.
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The NRC inspection report dated September 10, 1993, summarized many factors that
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resulted in a determination that there was a relatively low potential that the information was actually compromised. In addition, the KNPP security system is designed to prevent an O
individual from defeating the detection system from outside the protected area. Therefore information from the file could not significantly assist an individual in gaining unauthorized
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or undetected access to the facility. Furthermore, the design provides for an additional
detection system (i.e., tamper alarm) such that an alarm would be received in CAS/SAS
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should an attempt be made to defeat the security system.
Since the potential for compromise was low and the significance of the information available was limited, this event did not pose a significant threat to the health and safety of the public.
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MITIGATING FACTORS O
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i 10CFR 2 Appendix C entitled " General Statement of Policy and Procedure for NRC Enforcement Action" describes the NRC enforcement policy and provides details regarding i
violations, civil penalties, and civil penalty adjustment factors. In particular Section VI.B.2
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states "The NRC reviews each proposed civil penalty on its own merits and after considering all relevant circumstances may adjust the base civil penalties shown in Table 1A and IB for
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severity level I, II, and III violations based on an assessment of the following civil penalty adjustment factors." The cited section provides additional detail regarding the civil penalty adjustment factors ar.d the amount of potential adjustment. WPSC has reviewed the enforcement policy and has concluded that the adjustment factors for mitigation have been met for this event and any proposed civil penalty should be totally mitigated. The purpose of O
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this section of the presentation is to document our assessment of each adjustment factor
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independently to determine the appropriate final adjustment factor. Each adjustment factor r
from 10CFR 2, Appendix C, Section VI.B.2 is presented and is followed by the WPSC position. The adjustment factors and the WPSC positions are as follows:
(a)
Identification NRC Policy:
"The base civil penalty shown in Tables l A and IB may be mitigated up to i
50% when a licensee identifies a violation and escalated up to 50% if the NRC identifies a violation."
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WPSC Position:
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This event was identified by WPSC personnel on July 6,1993. In accordance
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with WPSC administrative directives a Security Event Report was completed l
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actions taken. WPSC performed an immediate assessment regarding the
reporting of this event in accordance with 10CFR 73.71 and concluded that
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i reporting in the quarterly log report was required.
i Since the event was identified and promptly assessed by WPSC personnel this i
adjustment factor is fully satisfied and supports mitigation.
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i (b)
Corrective Action i
i NRC Policy:
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"The base civil penalty shown in Tables I A and IB may either be mitigated or escalated by as much as 50% depending on the promptness and extensiveness of the licensee's corrective action."
i WPSC Position:
The corrective actions taken in response to this event have been previously i
described in this report. The actions taken were timely and extensive. The
WPSC root cause analysis that was performed did not narrowly focus on the i
one clerical personnel or the one cabinet involved in this event. The root cause evaluation, the implementation of prompt corrective actions, and the
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development of lasting actions that will prevent occurrence of similar
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violations were appropriately comprehensive.
i Above all, immediate corrective action was taken to restore safety and
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compliance once the violation was identified. NRC Region III personnel were kept informed of our progress in addressing this event by frequeni 'elephone communications imtiated by WPSC personnel. NRC action was not required before acceptable licensee action was taken. WPSC recognized at all times that this was a significant event and actively pursued corrective actions.
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The corrective actions taken in response to this event were prompt and
extensive therefore this adjustment factor is fully satisfied and supports O
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(c)
Licensee Performance
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NRC Policy:
"The base civil penalty shown in Tables I A and IB may be mitigated by as much as 100% if the current violation is an isolated failure that is inconsistent with a licensee's outstanding good prior performance."
WPSC Position:
WPSC performance in the area of security has been good and improving.
Significant improvements in the program have been acknowledged by NRC O
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Region III inspection personnel. WPSC currently has no outstanding NRC open items or violations. WPSC management has committed itself to ensuring that the KNPP security program maintains the high standards that WPSC i
expects. The most recent SALP report covering the time frame from March 1,1992 to July 31,1993 indicated improving performance in the area of security and states that the KNPP security program is now considered a strength. All indications are that the program improvements have continued into the current SALP period. We are proud of our program and are therefore
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concerned with the occurrence of this event. We do not feel it is an indication l
of a degrading performance but look at it as an opportunity to strengthen an
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area of the security program to ensure our continued high standards are met.
The fact that the event was immediately recognized and promptly characterized as a potential security violation is a credit to the professionalism and integrity of WPSC personnel and the KNPP security program.
The occurrence of this event is an isolated failure that is inconsistent with WPSC's outstanding good prior performance therefore this adjustment factor is fully satisfied.
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Prior Oooortunity to identify NRC Policy:
"The base civil penalty shown in Tables 1A and IB may be escalated as much as 100% for cases where the licensee should have identified the violation sooner as a result of prior opportunities."
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WPSC Position:
WPSC monitors and evaluates industry events to the extent that they are applicable to KNPP. We are aware of events regarding uncontrolled cabinets in the industry however it has not been a generic issue that occurred repeatedly at WPSC. As mentioned previously we feel this event is an isolated occurrence.
As discussed in the inspection report, a WPSC nuclear department employee did enter the office where the cabinet was located on Thursday July 1,1993 during the time that it was left in its unlocked condition. Interviews that WPSC conducted with the individual concluded that the individual was aware that the cabinet had contained safeguards material however he was also aware that a transition of security responsibilities to the KNPP site was also
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occurring. In addition the cabinet is not marked as a safeguards information
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cabinet. He reasoned that the cabinet no longer contained safeguards material therefore the unlocked cabinet did not seem inappropriate. This individual is j
l not normally involved with the handling of KNPP safeguards information and therefore made an assumption regarding the current status of the contents of the file cabinet.
The presence of the WPSC nuclear department employee on Thursday July 1, 1993 did present an opportunity to identify the violation earlier. The event would be much more serious if the individual had recognized that the cabinet
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contained safeguards information but then failed to notify appropriate personnel of the situation. In this case, the employee had reasonable basis for assuming that the cabinet no langer contained safeguards information. As an l
l ajditional corrective measure to prevent similar occarrences, this event will be f
discussed during the next available General Sployee Training sessions, j
Special emphasis will be placed on the fact that whenever any potential security situation is present the appropriate security management personnel should be informed to determine whether an unacceptable condition exists.
l The cabinet was left unattended from the afternoon on Thursday, July 1,1993
i until the morning of Tuesday, July 6,1993. Three of the five days (Saturday, Sunday, and Monday) that the cabinet was unattended were not scheduled work days and therefore personnel were not present in the office area to recognize the event. Immediately upon his return to his office on Tuesday
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July 6,1993, the Assistant to Nuclear Licensing and Systems Superintendent
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recognized the event.
l Since this violation was recognized promptly and immediate corrective actions were taken, escalation based on this adjustment factor is not warranted.
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(e)
Multiple Occurrences
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NRC Policy:
"The base civil penalty shown in Table lA and IB may be escalated by as O
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much as 100% where multiple examples of a particular violations are identified t
during the inspection period."
WPSC Position:
There were not multiple examples of unce: trolled safeguard file cabinets identified during the inspection period. This event is an isolated occurrence associated with a single file cabinet. As mentioned previously WPSC's corrective actions have been developed to prevent recurrence of similar violations.
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Since the event did not involve multiple occurrences of a particular violation
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this adjustment factor is satisfied and no escalation is warranted.
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(f)
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IRC Policy:
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"The base civil penalty shown in Tables lA and IB may be echted by as much as 100% to reflect the added technical and/or regulatory significance i
I resulting from the violation or the impact if it remained uncorrected for more than one day. The factor should normally be applied in cases involving particularly safety significant violations or where a significant regulatory message is warranted."
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WPSC Position:
Upon discovery of the violation WPSC immediately took corrective aedons to restore safety and compliance. The identification of the violation occurred promptly and corrective actions were implemented immediately. The significance that the cabinet remained unlocked for more than one day is i
reduced due the fact that event duration included a period of time when the l
l offices were not normally occupied and access to the facility was restricted.
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WPSC recognizes the potential significance of this event and has initiated l
l multiple actions to prevent recurrence. WPSC has taken prompt and extensive corrective actions therefore escalation based on this adjustment factor is not warranted.
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APPENDIX A O
REPORTABILITY DETERMINATION I
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Upon notification of the event the Security Operations Supervisor and Assistant to Nuclear Licensing and Systems Superintendent performed a thorough review of the following i
i documents which define the NRC reportability criteria.
1)
Generic Letter 91-03 This document provides an immediate revision to the current NRC policy regarding prompt reporting of safeguards events, thereby eliminating unnecessary reporting of certain safeguards events and reducing their attendant affect on the NRC Operations Center. Generic Letter 91-03 includes examples of events that do not need to be reported to the NRC within one hour of discovery. The following is an example of one such event:
" Compromise (including loss or theft) of safeguards information that could not significantly assist an individual in gaining unauthorized or undetected access to a facility or would not significantly assist an individual in an act of radiological sabotage or theft of special nuclear material."
Upon review of the information available in the affected cabinet it was concluded that the information itself was significant information however the information available could not significantly assist an individual in gaining unauthorized or undetected I
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access to the facility. Had the file cabinet included any documents that identified known vulnerabilities in the detection systems that were not yet corrected then this information could significantly assist an individual in gaining access to the facility and would therefore warrant I hour reportable. No such information was present in the file.
The KNPP Tactical Response Program (i.e., OSRE) provides procedural direction for the officers to respond to a challenge to the plant's safety equipment. The tactical response procedures were nel stored in the unattended cabinet. The response program keys off of a breach of the protected area barrier. Since we have concluded that the information available could not significantly assist an individual in gaining undetected access to the protected area, the ability to prevent radiological sabotage is also not adversely affected. Even with the information available in the cabinet, detection would occur at the protected area and the tactical response procedures would be immediately implemented. Therefore, the information available in the cabinet would not significantly assist an individual in the act of radiological sabotage or theft of special nuclear material.
It was therefore concluded that this document review supported logging in the quarterly report.
2)
NUREG-1304 This document provided further clarification on reporting criteria via questions and O
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answers. The answer to Questions 2.217.a and 2.2.17.b both support the conclusion k
that I hour reporting of safeguard information is required only if the information could significantly assist in gaining undetected or unauthorized access to the plant.
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The answer to Question 2.2.17.b states:
i if the lost safeguards information could not significantly assist in these acts, the event should be logged and the system failure corrected.
As mentioned above it was concluded that the information could not significantly assist in these acts. This event was logged and corrective actions were promptly
initiated. NUREG-1304 supported the conclusion that reporting in the quarterly log
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was the appropriate action to take.
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3)
USNRC Safecuards Event Analysis Report Third Ouarter 1992 This document provides a summary of the 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> reportable and quarterly loggable events during a given quarter. This document was referenced to determine if it is typical for uncontrolled safeguards information to be logged or I hour reported. Page
i 32 of the document indicates that 31 events involving unattended documents or cabinets had occurred during this quarter and were reponed via the quarterly loggable report. The summary also includes 5 events involving lost information, 3 events of improperly marked information, and 8 events which fall into the "other" category.
i The July 6,1993 event in the WPSC Corporate Office is considered to fall in the first category as unattended information. Our review of the information did not conclude O
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that any information was lost or missing. Even if one assumes that the information
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was lost, the NRC report indicates that logging in the quarterly report is appropriate for these events. We concluded that we were not inconsistent with other utilities in logging the event versus a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report.
The NRC report also included one event involving unattended Safeguards Information documents that was reported via a one hour report. Our analysis of that event
indicates that it was a much more significant event than the KNPP event and involved multiple breakdowns and false assumptions regarding the control of the safeguards information. We concluded that the review of the NRC report also supported our i
decision to report the event in the quarterly log versus I hour report.
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Summary The event was reported via telephone to NRC Operations Center on August 3,1993 as a conservative measure because it was unclear at the time whether this event warranted
reporting because it appeared to be a potential level 3 violation in accordance with enforcement policy 10CFR 2 Appendix C. Supplement III Item C.5 of the enforcement policy provides the following example of events that may qualify for escalated enforcement:
"A failure to protect or control classified or safeguards information considered to be significant while the information is outside the protected area and accessible to those i
not authorized access to the protected area."
The information in the affected cabinet (ie. Security Manual) could be considered significant information and the event itself may well qualify as a severity level III event however the O
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reporting criteria does not automatically require a 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> report for any event that qualifies
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as a level III violation. The reporting criteria requires reponing of safeguard information events that could significantly assist an individual in gaining unauthorized or undetected
access to the plant or significantly assist an individual in an act of radiological sabotage or theft of special nuclear material.
As mentioned in the draft memo that was written to T. Webb from D. Nalepka dated August 6,1993, there were several other mitigating factors (ie. office layout, location of file, cabinet appeared to be locked, etc.) that reduced the significance of this event. It appears that Generic Letter 91-03 was written with the intent of limiting I hour security event notification to those events that require immediate NRC response or action. Examples of events that would warrant I hour notification include but are not limited to: protesters attempting to penetrate the protected area, unauthorized introduction of handgun into the Protected Area, or other events that may generate significant media attention. Security reporting criteria is unique in the fact that events that are not reported via telephone within I hour still are required to be submitted to the NRC in the quarterly loggable report. Therefore, an event such as the July 7,1993 KNPP incident will be reported for NRC review and follow-up as appropriate. This event was not of a level of significance that warranted immediate (1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />)
NRC actier. Or response. Therefore reporting in the quarterly log is appropriate.
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