IR 05000344/1989008

Discusses Safeguards Insp Rept 50-344/89-08 & Security Insp Rept 50-344/89-02 & Forwards Notice of Violation Re Safeguards Info Protection & Firearms Training Adequacy.Encl Withheld (Ref 10CFR2.790)

ML20247M604
Person / Time
Site:	Trojan File:Portland General Electric icon.png
Issue date:	07/27/1989
From:	Scarano R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V)
To:	Cockfield D PORTLAND GENERAL ELECTRIC CO.
References
EA-87-277, EA-89-082, EA-89-82, NUDOCS 8908020160
Download: ML20247M604 (4)

Text

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SAFEGl!ARDS INFORMATION

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$ REGION V

% f 1400 MARIA LANE, SUITE 210

%' - g' . WALNUT CREEK, CALIFORNIA 9480F4333

JUL 2 7'1989 Docket No. 50-344 L

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. License No. NPF-1 L: EA 89-082 L

= Portland General. Electric Company ATTN: Mr. Da'vid W. Cockfield-Vice President, Nuclear 121 S. W. Salmon Street Portland, Oregon 97204 Gentlemen:

SUBJECT: NOTICC OF VIOLATION (NRC INSPECTION 50-344/89-02)

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Thi_s letter refers.to.two inspections. The first was a special inspection conducted from March 28 through April 5, 1989, at the Trojan Nuclear Plant

- concerning multiple. failures between November 1,1988 and April 3,1989 to properly protect Safeguards Information. The results of the inspection were reported in NRC Inspection Report No. 50-344/89-08, provided to you by letter

, dated April' 18, 1989. The second was~a security team inspection conducted from March 28 through Apri1~20, 1989, which reviewed the Trojan security progra The results of the inspection were reported in NRC Inspection Report N /89-02, provided to you by letter dated May 5,.198 We' discussed the apparent violations, their causes, and your corrective actions with you during an Enforcement Conference held at Region V on May 10, 1989. A

. sumary of the Enforcement Conference (NRC Inspection Report No. 50-344/89-15)

was sent to you by letter dated June 6, 198 Violatior. A set forth in the enclosed Notice of Violation involves your protection of Safeguards Information and Violation B involves the adequacy of your. firearms training for armed members of the security force. The examples

. described in Violation A of the enclosed Notice resulted from inadequate implementation of your new procedure for the protection of safeguards infonnation. These violations are of particular concern to the NRC because they are similar to a violation documented in NRC Inspection Report N /88-45, dated November 2,1988, which resulted in a Severity Level IV

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violtcion being issued on December 30, 1988 (EA 88-277).

During the Enforcement Conference you described the substantial expansion of your program for the protection of safeguards information. At that time, we requested th t you also consider protection needed for nontraditional media forms such as computer disks and internal nonvolatile computer memory. In your

' response to this letter, please advise us of the measures taken to accomplish such protectio *

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Portland General Electric Company -2- JUL 2 71989

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Violation B of the Notice involves failure of several members of the security organization to demonstrate their proficiency in weapons qualification when asked to do so by an NRC inspector. We have considered your position, as expressed at the Enforcement Conference on May 10, 1988, i.e., that this finding is not a violation of your Trojan Nuclear Plant Security Force Training and Qualification (T&Q) Plan. In taking this position, you stated that the T&Q Plan requires only that the individuals be able to demonstrate their proficiency before being assigned to shift and that maintenance of that proficiency is not required by the wording of the T&Q Plan. Although Paragraph 2.1 of that Plan refers to qualification " prior to actual duty assignment".

Paragraph 3.0 of the T&Q Plan requires that security personnel be trained and proficientintheuseofassignedweapns[emphasisadded]. These paragraphs were written to comply with % CFR 73.55(b)(4) which requires, upon the request of an authorized representative of the Commission, that the Licensee shall demonstrate the ability of the physical security personnel to carry out their assigned duties. Upon the request of an NRC inspector, five of the nine individuals tested coulil not demonstrate their firearms qualifications, including some individuals who scored well below the minimum qualifying scor Your interpretation that all that is required is passing a test at the

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completion of training is unacceptable and is inconsistent with the clear intent of 10 CFR 73.55(b)(4) to have qualified security guards at all time This appears to be more than an isolated deficienc The inspection report also described several other weaknesses in the implementation of your T&Q Plan. These weaknesses related to attendance at training sessions, conduct of drills and weapons firing, and the absence of any training in the use of batons assigned to the members of the security forc These findings are of concern because, although they may not be violations at this time, they may result in security officers not maintaining proficiency at their assigned duties, which would be a violation. The present citation involving weapons qualification reminds us that barely passing an annual test may not ensure continued proficiency, just as the conduct of training designed to attain mere compliance may not guarantee a security force capable of protecting the plant in accordance with the general performance objectives of 10 CFR 73.55(a). These findings will be examined during future inspection You are required to respond to this letter and should follow the instructions i specified in the enclosed Notice when preparing your response. In your j response, you should document the specific actions taken and any additional j actions you plan to prevent recurrence. Your response to violation A should ;

address why this corrective action should be more effective than that taken in j response to the December 30, 1988 citation. After reviewing your response to i this Notice, including your proposed corrective actions and the results of {

future inspections, the NRC will determine whether further NRC enforcement j action is necessary to ensure compliance with NRC regulatory requirements, j i

In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2 j Title 10, Code of Federal Regulations, a copy of this letter will be placed in 1 the NRC Public Document Roo ]

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In accordance with Section 2.790(d) of the NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, documentation of the findings of your safeguards and security measures are exempt from public disclosure; therefore, l

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Portland General- Electric Company -3- M 2 7 1939

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the enclosed Notice of Violation will not be placed in the Public Document Room and will receive limited distributio We have determined that the enclosure so designated contains Safeguards Infomation and therefore is subject to the controls of 10 CFR 73.21. In accordance with 10 CFR 73.21, safeguards activities and security measures are exempt from public disclosure. Therefore, the enclosures to this letter with the exception of the report cover page, which presents a nonexempt summary, will not be placed in the NPC Public Document Room. In your response to this letter and Notice, you should place all Safeguards Information in an enclosure so as to allow your letter (without the enclosure) to be placed in the Public Document Roo The responses directed by this letter and the accompanying Notice are not subject to the clearance provisions of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, P.L. 96-51

Sincerely, G2 A a- 3ot R. rano, Director Division of Radiation Safety and Safeguards

Enclosure:

Notice of Violation

REGION RPate/ dot- MMendonca

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