IR 05000483/1990007
| ML20012D084 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 03/07/1990 |
| From: | Creed J, Greger L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20012D081 | List: |
| References | |
| 50-483-90-07-EC, 50-483-90-7-EC, NUDOCS 9003260435 | |
| Download: ML20012D084 (14) | |
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li U.S. NUCLEAR' REGULATORY COMMISSION I
REGION III
I Report No. 50-483/90007(DRSS)
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Docket No.' 50-483 License No. NPF-30
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Licensee:
Union Electric Company tE P.O. Box 149-Mail Code 400 St. Louis, MO 63166 Facility Name:
Callaway County Nuclear Power Station, Unit 1
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i Meeting Location:
NRC Region III office, Glen Ellyn, Illinois I
Meeting Conducted:
February 27, 1990
Type of Meeting:
Enforcement Conference
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Reviewed By:
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QaJhes R. Creed, Chief Date Safeguards Section N/indA Umb" 3 /7/9 Approved By:
L Robert Greger, Chief Date
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Reactor Programs Branch F
Meeting Summary Meeting on February 27, 1990 (Report No. 50-483/90007(DRSS))
Subjects Discussed:
Included the specific description of an apparent violation pertaining to some Safeguards Information (SI) security containers not being properly secured, the licensee's perspective of the issue, and corrective actions taken by the licensee to address the issue.
Results:. The disposition of the apparent violation associated with the unsecured 51 containers will be addressed in separate correspondence after NRC, HQ review.
9003260433 900307
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PDR ADOCK 050004G3 e
Q PDC L
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DETAILS
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Enforcement Conference Attendees Union Electric Company (UE)
D. Schnel1~, Senior Vice President, Nuclear L
G. Naslund, Manager, Operations Support
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'J. Laux, Manager, Quality Assurance i
G.-Pendergraff, Superintendent, Security
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Nyclear Regulatory Commission l
C. Norelius, Director, Division of Radiation Safety and Safeguards, Region III A. Gody, Jr., Project Manager, NRR t
i S. Athavale, Acting Project Manager, NRR B. Berson, Regional Counsel, Region III-
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C. Weil, Enforcement Specialist, Region III
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R. Knop, Chief, Reactor Projects Branch 3, Region III L. Greger, Chief, Reactor Programs Branch, Region III c
il. Creed, Chief, Safeguards Section, Region III G. Pirtle, Physical Security Inspector, Region III G. Christoffer, Physical Security Inspector, Region III l
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Enforcement Conference Details
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On February 27, 1990, an enforcement conference was held at the Region III office in Glen Ellyn, Illinois between the individuals listed above.
The enforcement conference was held to discuss an apparent violation d
involving three instances of Safeguards Information (SI) containers not being secured which resulted in inadequate protection of the significant
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SI in the containers.
The 51 included complete copies of the facility security plan, the safeguards contingency plan, training and qualification plan, and other SI documents.
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i The licensee representatives stated that the details of the inspection
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report were accurate, except for one area.
Section S (page 8) of the i
Inspection Report No. 50-483/90004, dated February 16, 1990, stated that the SI account located at the security contractor's Headquarters in
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Jefferson City, Missouri, had been closed.
During the meeting they indicated that the SI account will continue and was not closed.
However, the facility security plan has been removed from that account.
The account does not contain SI that could significantly assist in an act of radiological sabotage or theft of special nuclear material (SNM).
Additionally, the Quality Assurance (QA) department account in the owner
-controlled area may continue to have SI material on a temporary basis (such as draft reprts and audit notes) until that office's functions are moved into the protected area which is anticipated to be about June 1990.
The original inspection report stated that the QA department SI account was closed.
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~Although the licensee representatives agreed that the inspection report j
details were accurate, except as noted above, they did not agree that the j
incidents of.the unsecured SI containers were significant or that the type of SI material in the containers was significant in assisting in an i
act of radiological sabotage.
Factors they identified to support their conclusion included:
the same information could be deduced from other
.l non safeguards information documents (FSAR, etc) within the public domain; the SI documents not adequately secured would not assist in undetected entry into the protected area or defeating perimeter alarm and assessment systems; and the unsecured SI information would not assist an
" insider" because the insider would already be knowledgeable of potential targets.
They also noted that the random nature and the short duration j
of the three incidents also reduced the significance of the issue.
The licensee concluded that the root cause of the incidents was oversight I
or error by personnel who were knowledgeable of the requirements to lock.
the cabinets (cognitive error).
Recently implemented corrective actions
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for SI accounts in the owner controlled area included reducing the volume of safeguards material; segregating security plans into four volumes and storing different volumes in separate containers at most locations; and reducing the quantity of SI material outside of the protected area.
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same type of corrective actions pertaining to auditing SI accounts within the protected area are scheduled to be completed by March 31, 1990.
The policy for control of SI has also been revised to require SI containers to be locked immediately after each entry to the containers.
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Copies of the licensee's briefing slides are attached to provide a broader degree of understanding pertaining to the licensee's perspective
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of the events, their significance, root cause and corrective actions, and actions to prevent recurrence.
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Attachments:
As stated.
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DESCRIPTION OF EVENTS
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FIRST EVENT 10/18/89 QA AUDITOR FAILED TO LOCK CABINET - SELF IDENTIFIED
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DURATION 4:45 P.M. TO 3:00 A.M.
(10 NRS, 15 MIN)
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CABINET AND CONTENTS CNECKED BY QA AND SECURITY
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NO EVIDENCE OF THEFT, LOSS, OR COMPROMISE
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IR 89-379 GENERATED BY SECURITY AND OPERATIONS
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10/19/89, 3:47 A.M.
0A ENGINEER. RESPONSIBLE FOR CABINET ARRIVED
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APPROXIMATELY 5:00 A.M. TO EXAMINE THE CONTENTS
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CONTENTS
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SECURITY PLAN AND PROCEDURES
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INCIDENT REPORTS
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QA AUDIT AND SURVEILLANCE REPORTS, INCLUDING
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TARGET ANALYSIS NRC INSPECTION REPORTS
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I & C TRAINING MANUAL - 1986
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SECOND EVENT 12/06/89
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CLERK IN QA DEPARTMENT FAILED TO LOCK CABINET
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DURATION 3:30 P.M. TO 1:40 A.M. (10 HRS, 10 MIN)
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DISCOVERED BY WATCHMAN ON PATROL
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CABINET AND CONTENTS INSPECTED BY SECURITY
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IR 89-428 GENERATED BY SECURITY AND OPERATIONS
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12/06/89, 2:24 A.M.
QA SUPERVISOR ARRIVED APPROXIMATELY 3:30 A.M. TO
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EXAMINE THE CONTENTS
NO EVIDENCE OF THEFT, LOSS, OR COMPROMISE
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-o CONTENTS SAME AS FIRST EVENT
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THIRD EVENT 12/13/89
SECURITY ADMINISTRATIVE SUPERVISOR FAILED T0
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LOCK CABINET
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o DURATION 4:00 P.M. TO 6:40 P.M. (2 HRS, 40 MIN)
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DISCOVERED BY WATCHMAN ON PATROL o
CABINET AND CONTENTS CHECKED BY SHIFT SECURITY
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SUPERVISOR, SSS CONFERRED WITH ASSISTANT SUPERINTENDENT, SECURITY, BY TELEPHONE g
CABINET SECURED
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o IR 89-433 GENERATED BY SECURITY AND OPERATIONS
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12/13/89, 7:30 P.M.
o CABINET CONTENTS INVENT 0RIED BY SECURITY
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l ADMINISTRATIVE SUPERVISOR
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CONTENTS OF CABINET:
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SECURITY PLAN AND PROCEDURES
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o POST INSTRUCTIONS
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DEPARTMENT CORRESPONDENCE FILE
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BLANK EQUIPMENT TEST FORMS
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SECURITY SIGNIFICANCE OF EVENTS O
NO EVIDENCE OF THEFT, LOSS, OR COMPROMISE
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NO EVIDENCE ANYTHING REVIEWED OR COPIED
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g INFORMATION AVAILABLE WOULD NOT ASSIST IN
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DEFEATING ANY ALARM OR ASSESSMENT SYSTEMS INFORMATION WOULD NOT ASSIST IN ENTERING THE
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PROTECTED AREA UNDETECTED o
SOME INFORMATION COULD ASSIST AN INDIVIDUAL
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ONCE INSIDE THE PROTECTED AREA OR A VITAL AREA o
VITAL EQUIPMENT LOCATIONS CoULD BE
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GENERATED
DOORS TO VITAL AREAS USING PUBLICLY
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AVAILABLE TARGET ANALYSIS DOCUMENTS
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POST INSTRUCTIONS o
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NO INDICATION OF PROGRAMMATIC BREAKDOWN REGARDING
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o CONTROL OF 7
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ROOT CAUSE AND CORRECTIVE ACTIONS o
EVENT 1 (10/18/89)
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REQUEST FOR CORRECTIVE ACTION INITIATED I
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o INCIDENT REPORT INITIATED
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t ROOT / CONTRIBUTING CAUSES
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P COGNITIVE ERROR
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INDIVIDUAL WORKING LATE TO MEET AUDIT OBJECTIVES
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l REMEDIAL ACTIONS
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l INVENT 0RIED CABINET (10/19/89)
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SECURITY PATROLS INSTRUCTED TO CHECK QA SGI
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l CABINET (10/19/89)
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EXTENDED AUDIT (10/19/89)
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!O ACTION TO PREVENT RECURRENCE
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PLACE SAFEGUARDS REMINDERS AT BUILDING EXITS i
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EVENT 2 (12/06/89)
INCIDENT REPORT INITIATED y
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ROOT / CONTRIBUTING CAUSES
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COGNITIVE ERROR
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e INVENT 0RIED CABINET (12/07/89)
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COUNSELED CLERK INVOLVED (12/07/89)
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e DISCUSSED AT CLERK STAFF MEETING (12/07/89)
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o ACTIONS TO PREVENT RECURRENCE
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PLACED SAFEGUARDS REMINDERS AT BUILDING EXITS o-
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EVENTE3 :(12/13/891 of
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INCIDENT REPORT INITIATED
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-ROOT / CONTRIBUTING CAUSES
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COGNITIVE ERROR-
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REMEDIAL ACTIONS
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. INVENT 0RIED~ CABINET (12/14/89)
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COUNSELED THE INDIVIDUAL.
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ACTIONS TO PREVENT RECURRENCE
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PLACED SAFEGUARDS REMINDER AT SECURITY
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BUILDING EXIT
.o INSTRUCTED SECURITY: PATROLS TO CHECK ALL SGI
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CABINETS DAILY BETWEEN 3:30 P.M. AND 4:00 P.M.
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SUBSEQUENT ACTIONS F
TO PREYENT RECURRENCE
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ASSESSED CONTENTS OF SAFEGUARDS CABINETS LOCATED
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OUTSIDE THE PROTECTED AREA
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Q REDUCED NUMBER OF SAFEGUARDS STORAGE LOCATIONS
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OUTSIDE. PROTECTED AREA
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QA ~ CABINET (EXCEPT IN-PROCESS QA/NRC MATERIAL)
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TRAINING CENTER CABINET
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MAINTENANCE TRAINING CENTER CABINET
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ONLY REMAINING SAFEGUARDS STORAGE LOCATIONS OUTSIDE
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PROTECTED AREA ARE CORPORATE, SECURITY AND BURNS o
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REDUCED VOLUME OF SAFEGUARDS MATERIAL
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ELIMINATED 75% OF CORPORATE SAFEGUARDS MATERIAL
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REDUCED NUMBER OF SECURITY PLAN COPIES
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C SEGREGATED SAFEGUARDS MATERIAL
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SEPARATED SECURITY PLAN INTO 4 VOLUMES
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O STORING PLAN, PROCEDURES AND DRAWINGS IN
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SEPARATE CABINETS REMOVED CONTINGENCY.AND TRAINING QUALIFICATION
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cx PLANS FROM CORPORATE COPY OF SECURITY PLANS o
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REVISED POLICY ON HANDLING SAFEGUARDS
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O RE-SECURE CABINET IMMEDIATELY AFTER EACH ACCESS
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PATROLS MAY BE DISCONTINUED AFTER CONFORTABLE
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WITH THE NEW POLICY o
o ASSESS CONTENTS OF SAFEGUARDS CONTAINERS LOCATED
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INSIDE PROTECTED AREA TO BE COMPLETE BY MARCH 31, 1990 o
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QA REVIEW 0F L
SECURITY AUDIT FINDINGS l
L APA-ZZ-00515 PROVIDES GUIDANCE FOR DETERMINING
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- o-LEVELS OF. SIGNIFICANCE FOR REQUESTS FOR i
CORRECTIVE ACTION (RCA's)
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- o PROCEDURE INCLUDES COMPARISON OF THE EVENT TO
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10CFR2, APPENDIX C, INCLUDING SUPPLEMENTS l
i-SIGNIFICANCE LEVEL IS REVIEWED BY THE
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FOR EVENT 1, THE
SUPERINTENDENT, GA WAS ALSO CONSULTED L
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I PROCEDURE REQUIRES EVALUATION FOR POTENTIAL
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REPORTABILITY-UPON DISCOVERY OF AN RCA CONDITION o.
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IF POTENTIALLY REPORTABLE, AN INCIDENT REPORT
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(IR) IS GENERATED o
ALL 3 EVENTS WERE DETERMINED NOT TO BE
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REPORTABLE OR LOGGABLE o
FOR DEFICIENCIES IDENTIFIED BY OTHERS AND
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ADDRESSED ON AN IR, NO RCA NEED BE ISSUED BY QA O
(EVENTS 2 AND 3)
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CLOSING REMARKS
!o-CONTROL OF SGI IS AN IMPORTANT RESPONSIBILITY
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UE DOES HAVE AN AGGRESSIVE ATTITUDE TOWARD SECURITY
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AND AN AGGRESSIVE AUDIT PROGRAM
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e COMPREHENSIVE AUDIT OF CONTROL OF SGI IN
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OCTOBER, 1989 REVEALED NO PROBLEMS EXCEPT THOSE INVOLVING THE ONE QA AUDITOR
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ALL EVENTS SELF-IDENTIFIED AND DOCUMENTED
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TAKING COMPREHENSIVE ACTION TO MINIMIZE
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O OCCURRENCE AND SIGNIFICANCE IF WE HAVE FUTURE EVENTS NEW POLICY ON IMMEDIATE CLOSURE OF CABINETS
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NO INDICATION OF A BREAKDOWN OF PROGRAMMATIC
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CONTROLS REGARDING SGI
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- O NO EVIDENCE OF THEFT, LOSS, OR COMPROMISE
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NO INFORMATION TO SIGNIFICANTLY AID AN INDIVIDUAL
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!O IN BREACHING PROTECTED AREA
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