ML15261A306
| ML15261A306 | |
| Person / Time | |
|---|---|
| Site: | Oconee, Mcguire, Catawba, McGuire  |
| Issue date: | 01/31/1994 |
| From: | Stohr J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Tuckman M DUKE POWER CO. |
| References | |
| EA-93-311, NUDOCS 9402090090 | |
| Download: ML15261A306 (33) | |
Text
Docket Nos. 50-269, 50-270, 50-287 50-369, 50-370, 50-413, AND 50-414 License Nos. DPR-38, DPR-47, DPR-55 NPF-9, NPF-17, NPF-35, AND NPF-52 EA 93-311 Duke Power Company ATTN: Mike Tuckman, Vice President Nuclear Production Department P. 0. Box 1007 Charlotte, NC 28291 Gentlemen:
SUBJECT:
ENFORCEMENT CONFERENCE
SUMMARY
(NRC INSPECTION REPORT NOS. 50-269, 270 AND 287/93-32, 50-369 AND 370/93-31, AND 50-413 AND 414/93-35)
This letter refers to the Enforcement Conference held at our request on January 13, 1994. This meeting concerned activities authorized for your Oconee, McGuire, and Catawba facilities. Your presentation was beneficial in clarifying the reasons for the problems in your Safeguards Information Program and giving us an understanding of your commitments for corrective actions to preclude recurrence, and your evaluations of the level of compromise and mitigating factors dealing with the failures to protect Safeguards Information. A list of attendees, conference summary and a copy of your handout are enclosed. We are continuing our review of these issues to determine the appropriate enforcement action.
Clarifications and corrections to Inspection Report Nos. 50-296, 270, and 287/93-32, 50-369 and 370/93-31, and 50-413 and 414/93-35 are identified in. Our records have been changed to reflect the clarifications and corrections.
In accordance with Section 2.790 of the NRC's "Rule of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.
Sincerely, 9402090090 940131 J. Philip Stohr, Director PDR ADOCK 05000269 R APIR Division of Radiation Safety and Safeguards
Enclosures:
(See page 2)
Duke Power Company 2
Enclosures:
- 1. List of Attendees
- 2. Conference Summary
- 3. Handout cc w/encls:
Duke Power Company ATTN: Mr. J. W. Hampton' Vice President Oconee Site P. 0. Box 1439 Seneca, SC 29679 Duke Power Company ATTN: Mr. T. C. McMeekin Vice President McGuire Site 12700 Hagers Ferry Road Huntersville, NC 28078-8985 Duke Power Company ATTN: Mr. D. L. Rehn Site Vice President Catawba Site 4800 Concord Road York, SC 29745-9635 M. E. Patrick Compliance Duke Power Company P. 0. Box 1439 Seneca, SC 29679 G. A. Copp Licensing -
ECO50 Duke Power Company P. 0. Box 1007 Charlotte, NC 28201-1007 R. 0. Sharpe Compliance Duke Power Company 12700 Hagers Ferry Road Huntersville, NC 28078-8985 R. C. Futrell Compliance Duke Power Company 4800 Concord Road York,.SC 29745-9635 (cc w/encs cont'd -
See page 3)
Duke Power Company 3
(cc w/encls cont'd)
A. V. Carr, Esq.
Duke Power Company 422 South Church Street Charlotte, NC 28242-0001 County Supervisor of Oconee County Walhalla, SC 29621 Robert B. Borsum Babcock and Wilcox Company Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, MD 20852 J. Michael McGarry, III, Esq.
Winston and Strawn 1400 L Street, NW Washington, D. C. 20005 Office of Intergovernmental Relations 116 West Jones Street Raleigh, NC 27603 Max Batavia, Chief Bureau of Radiological Health South Carolina Department of Health and Environmental Control 2600 Bull Street Columbia, SC 29201 Manager, LIS NUS Corporation 2650 McCormick Drive Clearwater, FL 34619-1035 Karen E. Long Assistant Attorney General N. C. Department of Justice P. 0. Box 629 Raleigh, NC 27602 Dayne H. Brown, Director Division of Radiation Protection N. C. Department of Environment, Health & Natural Resources P. 0. Box 27687 Raleigh, NC 27611-7687 (cc w/encls cont'd -
See page 4)
Duke Power Company 4
(cc w/encls cont'd)
A 3 1 19 County Manager of Mecklenburg County 720 East Fourth Street Charlotte, NC 28202 T. Richard Puryear Nuclear Technical Services Manager Carolinas District Westinghouse Electric Corporation 2709 Water Ridge Parkway, Ste. 430 Charlotte, NC 28217 Dr. John M. Barry, Director Mecklenburg County Department of Environmental Protection 700 North Tryon Street Charlotte, NC 28203 North Carolina MPA-1 Suite 600 P. 0. Box 29513 Raleigh, NC 27626-0513 Richard P. Wilson, Esq.
Assistant Attorney General S. C. Attorney General's Office P. 0. Box 11549 Columbia, SC 29211 Michael Hirsch Federal Emergency Management Agency 500 C Street, Sw, Room 840 Washington, D. C. 20472 North Carolina Electric Membership Corporation P. 0. Box 27306 Raleigh, NC 27611 Saluda River Electric Cooperative, Inc.
P. 0. Box 929 Laurens, SC 29360 County Manager of York County York County Courthouse York, SC 29745 Piedmont Municipal Power Agency 121 Village Drive Greer, SC 29651 bcc w/encls:
(See page 5)
Duke Power Company 5
JAN 3 1 1994 bcc w/encls:
NRR/DRIS/SB L. A. Wiens, NRR V. Nerses, NRR R. E. Martin, NRR W. Miller, RH M. S. Lesser, RH R. Watkins, RH A. R. Herdt, RH Document Control Desk (RIDS IE04), 016 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 610 Seneca, SC 29678 NRC Resident Inspector U.S. Nuclear Regulatory Commission 12700 Hagers Ferry Road Huntersville, NC 28078-8985 NRC Resident Inspector U.S. Nuclear Regulatory Commission Route 2, Box 179-N York, SC 29745 J. Lieberman, OE RII:DR DRSS RII:DRSS RI D P RII:DRSS MASYK:JC MCGUIRE COLLINS ER MALLETT 01/?\\/94 014 L/94 01/4+/94 01/, 4/94 0 1 / 0 94 ICS RIDORA C
EVA It,\\f94 01/;//94
ENCLOSURE 1 LIST OF ATTENDEES U. S. NUCLEAR REGULATORY COMMISSION Region II C. Evans, Regional Counsel B. Mallett, Deputy Director, Division of Radiation Safety and Safeguards
- 0. Masnyk, Safeguards Specialist L. Reyes, Deputy Regional Administrator B. Uryc, Acting Director, Enforcement and Investigation Coordination Staff R. Watkins, Project Engineer L. Watson, Enforcement Specialist Office of Enforcement R. Rosano, Enforcement Specialist Office of Nuclear Reactor Regulation N. Ervin, Reactor Security Specialist L. Wiens, Project.Manager, Project Directorate 11-3 DUKE POWER COMPANY Corporate P. Coliainni, Licensing Engineer S. Coop, Licensing Manager R. Eller, Security Specialist M. Tuckman, Senior Vice President, Nuclear Generation Oconee S. Benesole, Compliance Manager J. Bryan, Security Engineer B. Dolan, Safety Assurance Manager J. Hampton, Vice President T. McQuarrie, Security Manager McGuire T. Godfrey, Security Support Supervisor Catawba
ENCLOSURE 2 ENFORCEMENT CONFERENCE
SUMMARY
An Enforcement Conference was held on January 13, 1994, at the Region II Office to discuss the failures to protect Safeguards Information at the Oconee, McGuire, Catawba, and Duke General Office facilities.
The Deputy Regional Administrator expressed concern with the licensee's failures to protect Safeguards Information and invited the licensee to share their understanding and assessment of the incidents. The Acting Director of the Enforcement and Investigation Coordination Staff explained the enforcement process and those portions of the policy pertinent to this conference. The Deputy Director for the Division of Radiation Safety and Safeguards recapped the NRC's understanding of the apparent violations and the regulatory requirements.
Licensee officials provided a briefing outlining their understanding of the events, the root causes for the violations, proposed and implemented corrective measures, and their evaluation of the extent of compromise of Safeguards Information. This briefing is contained in Enclosure 3 to this Summary. The licensee also offered the following clarifications, corrections, and comments on Inspection Report 50-269, 270, and 287/93-32, 50-369 and 370/93-31, and 50-413 and 414/93-35 as follows:
The last paragraph on page 3 of the report discusses the fact that Catawba drawings were loaded to the Computer Assisted Drafting System (CADS) Network but were not available at the time of the inspection. The licensee emphasized that these drawings were never available to Network users. The licensee further clarified the first paragraph on page 4, in that Safeguards Information is no longer stored at the Wilkinson Boulevard Storage facility.
The fourth paragraph on that same page states that significant Safeguards Information for the McGuire facility was compromised. The licensee stated that they felt this was mitigated by the fact that the information dealt with an area that was manned by Security personnel twenty-four hours a day, therefore, the information compromised could not be used to defeat the security systems involved. The third paragraph on page 5 states "Also, the licensee is not sure of the numbers, if any, of floppy disks that were given out that contained Safeguards Information." The licensee wished to go on record stating that there was no reason to suspect a problem in this area. An apparent violation was discussed in the second paragraph on page 9. This was attributed to the Oconee facility, in fact it occurred at the McGuire facility.
The licensee was advised that their comments would be noted in this Summary.
They were told that the apparent violations would be subject to review and that they would be advised of the outcome of the NRC's deliberations by separate correspondence.
ENCLOSURE 3 DUKE POWER COMPANY ENFORCEMENT CONFERENCE SECURITY JANUARY 13, 1994
DUKE POWER COMPANY ENFORCEMENT CONFERENCE ATTENDEES CORPORATE MIKE TUCKMAN SR VICE PRESIDENT NUCLEAR GENERATION SKIP COPP LICENSING MANAGER RON ELLER SECURITY SPECIALIST PAUL COLAIANNI LICENSING ENGINEER OCONEE JiM HAMPTON VICE PRESIDENT OCONEE Tom MCQUARRIE SECURITY MANAGER BRYAN DOLAN SAFETY ASSURANCE MANAGER STEVE BENESOLE COMPLIANCE MANAGER JAY BRYAN SECURITY ENGINEER McGUIRE TERRY GODGREY SECURITY SUPPORT SUPERVISOR CATAWBA JIM ROACH SECURITY MANAGER
DUKE POWER COMPANY ENFORCEMENT CONFERENCE JANUARY 13, 1994 AGENDA INTRODUCTION JIM HAMPTON OVERVIEW OF SI PROGRAM SKIP COPP CAD EVENT SKIP COPP ONS UNSECURED SI CONTAINERTom McQUARRIE MIsc EVENTS SKIP COPP
SUMMARY
SKIP CoPP CLOSING REMARKS MIKE TUCKMAN
SI PROGRAM OVERVIEW THE SAFEGUARDS INFORMATION (SI) PROGRAM ESTABLISHES ADMINISTRATIVE CONTROLS FOR THE PROTECTION OF SI AGAINST UNAUTHORIZED DISCLOSURE AS SET FORTH IN 10CFR73.21 THE PROGRAM IS GOVERNED BY NUCLEAR POLICY MANUAL, NUCLEAR SYSTEM DIRECTIVE 206 "SAFEGUARDS AND INFORMATION CONTROL" (NSD 206)
AN INFORMATION HANDBOOK ENTITLED "PROTECTION OF SAFEGUARDS INFORMATION" IS PROVIDED TO ALL SI USERS DURING INITIAL AND BI-ANNUAL REFRESHER TRAINING.
TOPICS COVERED DEFINITION OF SAFEGUARDS INFORMATION RESPONSIBILITIES OF SITE SAFEGUARDS ADMINISTRATORS AND SITE DOCUMENT CONTROLLERS SAFEGUARDS ACCESS PREREQUISITES CLASSIFICATION AND MARKING DOCUMENT STORAGE ESTABLISHING A CONTROLLED ACCESS AREA TRANSFER OF SAFEGUARDS INFORMATION ELECTRONIC DATA PROCESSING REPRODUCTION OR DESTRUCTION LOSS OR COMPROMISE EMPLOYEES' RESPONSIBILITIES
CAD SYSTEM EVENT DESCRIPTION DRAWINGS WITH SI WERE ARCHIVED (COPIED) TO NON-SI TAPES.
THIS APPARENTLY OCCURRED STARTING IN 1978 AND WAS NOT DISCOVERED UNTIL 1993 WHEN A NON-SI TAPE WAS LOADED TO THE NETWORK FILE MANAGER AND AN SI DRAWING WAS ACCESSED WITH THIS SYSTEM.
ROOT CAUSE INADEQUATE WORKPLACE PROCEDURES FOR HANDLING DRAWINGS CONTAINING SI INFORMATION.
CAD SYSTEM EVENT BACKGROUND THE COMPUTER AIDED DRAFTING (CAD) SECTION:
LOCATED IN THE DUKE POWER COMPANY GENERAL OFFICE PROVIDED AUTOMATED DRAFTING SERVICES FROM 1975 THROUGH 1991 WORKED WITH NUCLEAR PLANT SECURITY DRAWINGS FROM 1976 TO 1991 DIGITIZED EXISTING HAND DRAWN PLANT DRAWINGS SAVED THE DIGITIZED DRAWING FILES ON 9-TRACK TAPES FOR ARCHIVING RETRIEVED AND REVISED ARCHIVED DRAWINGS TO INCORPORATE PLANT CHANGES ARCHIVED ELECTRONIC DRAWING FILES ON 9-TRACK TAPES ARCHIVED SAFEGUARDS INFORMATION FILES ON SECURITY 9-TRACK TAPES STORED SECURITY 9-TRACK TAPES IN APPROVED SAFEGUARDS INFORMATION CONTAINERS
CAD SYSTEM EVENT THE CAD SECTION WORK FLOW PATH:
A) DRAWING BROUGHT TO CAD AREA.
B) THE JOB FORM WAS COMPLETED WHICH INCLUDED:
- JOB PRIORITY
- ARCHIVE TAPE NUMBER (IF DRAWING FILE ALREADY EXISTED)
- SECURITY WRITTEN IN COMMENTS BLOCK C) JOB ASSIGNED TO GRAPHICS OPERATOR.
D) GRAPHICS OPERATOR CREATED THE DIGITIZED DRAWING, OR COPIED EXISTING DRAWING FILE FROM ARCHIVE TAPE AND MADE CHANGES.
1975-1984 E) GRAPHICS OPERATOR PLOTTED DRAWING AND ARCHIVED NEW DRAWING FILE.
F) DRAWING WITH JOB TICKET GIVEN TO CAD CHECKER.
G) AFTER FINAL CHECK, DRAWING WAS PICKED UP.
AFTER 1984 E) GRAPHICS OPERATOR PLOTTED THE DRAWING.
F)
DRAWING WITH JOB TICKET GIVEN TO CAD CHECKER.
G) AFTER FINAL CHECK, DRAWING WAS PICKED UP.
H) CAD CHECKER INFORMED THE CAD FILE MANAGER OF WHICH FILES TO ARCHIVE AND THE CAD FILE MANAGER COPIED THE DRAWING FILES TO ARCHIVE TAPES.
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CAD SYSTEM EVENT REASON FOR OCCURRENCE CAD JOB PRIORITY UNTIL 1979 THERE WERE ONLY JOB PRIORITY CODES 1-RUSH, 2-NORMAL, AND 3-NO RUSH.
JOB PRIORITY 4-SECURITY WAS ADDED IN 1979.
THE LACK OF A RUSH JOB PRIORITY FOR SECURITY JOBS LED TO NUMEROUS INSTANCES OF SECURITY JOBS BEING PROCESSED UNDER JOB PRIORITY 1-RUSH, AND LOSING THIS BARRIER IN CONTROLLING SAFEGUARDS INFORMATION FILES.
INADEQUATE WORKPLACE PROCEDURE ARCHIVING SUBSEQUENT REVISIONS OF A DRAWING FILE TO THE SAME ARCHIVE.TAPE WAS PART OF CAD WORKPLACE PROCEDURES.
THIS WAS CARRIED OUT WITHOUT REGARD TO THE JOB PRIORITY CODE.
STARTING IN 1984, A FULL TIME CAD FILE MANAGER WAS ASSIGNED TO RETRIEVE AND ARCHIVE ALL DRAWING FILES.THE PROCESS OF TELLING THE CAD FILE MANAGER WHICH FILES TO ARCHIVE WAS NOT CONTROLLED BY WORKPLACE PROCEDURE, CHANGED OVER TIME, AND DID NOT ALWAYS INDICATE WHICH FILES WERE TO BE TREATED AS SAFEGUARDS INFORMATION.
CAD SYSTEM EVENT IMMEDIATE CORRECTIVE ACTION ALL UNCONTROLLED SAFEGUARDS INFORMATION ELECTRONIC FILES WERE EITHER DESTROYED OR SECURED.
SECURITY FORCE PERSONNEL AT ALL SITES WERE INFORMED AND INSTRUCTED TO MAINTAIN AN ENHANCED AWARENESS OF THE SPECIFIC SYSTEMS INVOLVED.
LONG TERM CORRECTIVE ACTION SELF ASSESSMENT CONDUCTED TO THOROUGHLY REVIEW:
WORK PROCESSES OF ALL DUKE POWER COMPANY GROUPS WORKING WITH ELECTRONIC SAFEGUARDS INFORMATION FILES TO ENSURE APPROPRIATE HANDLING THROUGHOUT ALL WORK PROCESSES.
ALL ASPECTS OF THE SAFEGUARDS INFORMATION PROGRAM AT DUKE POWER COMPANY WITH EMPHASIS ON THE EXPECTATIONS AND GUIDANCE PROVIDED TO INDIVIDUALS ADMINISTERING THE PROGRAM.
THE REPORT OF THIS SELF ASSESSMENT INCLUDES OVER 40 OBSERVATIONS AND.RECOMMENDATIONS.
EACH OF THESE WILL BE EVALUATED AND APPROPRIATE ACTION TAKEN ON EACH ONE.
CAD SYSTEM EVENT SIGNIFICANCE TOTAL OF 96 DRAWINGS (237 FILES) WERE FOUND UNCONTROLLED.
EVALUATIONS OF THE UNCONTROLLED MCGUIRE SAFEGUARDS INFORMATION DRAWINGS DETERMINED THEIR COMPROMISE DID NOT POSE A SIGNIFICANT THREAT TO PLANT SECURITY.
EVALUATION OF THE UNCONTROLLED CATAWBA SAFEGUARDS INFORMATION DRAWINGS DETERMINED SOME DRAWINGS CONTAINED SIGNIFICANT SAFEGUARDS INFORMATION.
FOUR DRAWINGS TOGETHER WOULD ALLOW DETERMINATION OF THE RANDOMIZED WIRING COLOR CODES FOR THE UNITS AND THE ALARM TAMPER OPERATION SCHEME (OPEN OR CLOSE ON ALARM TAMPER). A SAFEGUARD EVENT REPORT WAS COMPLETED AND THE NRC WAS NOTIFIED VIA THE EMERGENCY NOTIFICATION SYSTEM.
EVALUATION OF THE UNCONTROLLED OCONEE SAFEGUARDS INFORMATION DRAWINGS DETERMINED SOME DRAWINGS CONTAINED SIGNIFICANT SAFEGUARDS INFORMATION. THREE DRAWINGS COULD ASSIST IN THE UNDERSTANDING OF THE WIRING OF 2 VITAL AREA DOORS. A SAFEGUARD EVENT REPORT WAS COMPLETED AND THE NRC WAS NOTIFIED VIA THE EMERGENCY NOTIFICATION SYSTEM.
CAD, SYSTEM EVENT AGGRAVATING FACTORS OPPORTUNITIES EXISTED TO IDENTIFY PROBLEM THERE WERE SEVERAL POINTS IN THE CAD WORK PROCESS FOR PERSONNEL TO HAVE IDENTIFIED UNCONTROLLED SAFEGUARDS INFORMATION.
NUMEROUS DRAWING WERE WORKED ON AT DIFFERENT TIMES UNDER BOTH SECURITY AND NON-SECURITY JOB PRIORITY CODES.
SAFEGUARDS INFORMATION ELECTRONIC FILES WERE IMPROPERLY HANDLED IN THE CAD AREA AS EARLY AS 1978 UNTIL THIS DISCOVERY.
INADEQUATE REVIEW AND AWARENESS OF CAD WORK PROCESSES BY SAFEGUARDS DOCUMENT CONTROLLERS No DOCUMENT CONTROLLER REVIEWED THE INTERNAL WORK PROCESSES OF THE CAD SECTION TO ENSURE COMPLIANCE WITH EXISTING DIRECTIVES.
NUCLEAR POLICY MANUAL NUCLEAR STATION DIRECTIVE (NSD) 206 STATES THAT EACH DOCUMENT CONTROLLER IS RESPONSIBLE FOR ENSURING COMPLIANCE WITH NSD 206 WITHIN THE DEPARTMENT/GROUP AND HAS LEAD RESPONSIBILITY IN COORDINATING SAFEGUARDS DOCUMENT CONTROL ACTIVITIES.
CAD SYSTEM EVENT MITIGATING FACTORS HIGHLY IMPROBABLE THAT UNAUTHORIZED PERSON GAINED ACCESS TO THE UNCONTROLLED INFORMATION EACH TAPE HAS OVER 350 FILES AND EACH CARTRIDGE HAS OVER 2000 FILES.
OVER 200 9-TRACK TAPES AND 30 MAGNETIC TAPE CARTRIDGES WERE STORED IN THE CAD AREA.
MOST FILE NAMES ARE IDENTIFIED BY RANDOM ELECTRONIC RETRIEVAL NUMBERS THAT BEAR NO RESEMBLANCE TO THE DRAWING NUMBER.
INDIVIDUALS IN THE CAD SECTION CAPABLE OF RUNNING THE 9-TRACK TAPE MACHINE OR CARTRIDGE READER WERE ALL CLEARED FOR SAFEGUARDS INFORMATION ACCESS.
THE CAD AREA WHERE THE TAPES AND CARTRIDGES WERE STORED IS RELATIVELY SMALL WITH ONLY A FEW ENTRANCES AND UNAUTHORIZED PERSONS IN THE AREA WOULD BE NOTICED.
THE CAD AREA WAS LOCKED AFTER NORMAL WORKING HOURS.
NO TAPES HAVE EVER BEEN NOTED AS MISSING OR LOST.
ARCHIVE TAPES AND CARTRIDGES WERE USED FREQUENTLY AND STORED SYSTEMATICALLY AND A MISSING TAPE WOULD HAVE BEEN READILY NOTICED.
RETRIEVING DATA FROM THE FILES ON AN ARCHIVE TAPE WOULD TAKE EXPENSIVE SPECIALIZED COMPUTER EQUIPMENT AND SPECIFIC OUT OF DATE SOFTWARE.
NON-SECURITY TAPES WERE ONLY COPIED TO CARTRIDGES STARTING EARLY IN 1993.
CAD SYSTEM EVENT MITIGATING FACTORS COLLEGE STREET COMPUTER CENTER ACCESS TO THE CENTER IS CONTROLLED BY SECURITY GUARDS AND THE INNER AREA WHERE THE CARTRIDGES WERE STORED IS KEY-CARD ACCESS CONTROLLED.
FILE BACK-UP TRANSMISSIONS WERE COMPLETED THROUGH HARD CONNECTED DATA LINKS MAINTAINED BY DUKE POWER COMPANY.
NFM SYSTEM ONLY 15 FILES WERE FOUND ON THE MCGUIRE NFM SYSTEM.
THESE MCGUIRE FILES WERE ACCESSIBLE ON THE SYSTEM LESS THAN FIVE MONTHS.
INFORMATION IN THESE MCGUIRE FILES WAS EVALUATED AS NOT CONTAINING SIGNIFICANT SAFEGUARDS INFORMATION.
UNSECURED CONTAINER 12/06/93 CONTAINER DISCOVERED CLOSED BUT UNLOCKED REVIEW INITIATED WITH CO-WORKER AND DOCUMENT CONTROLLER NO APPARENT TAMPERING CONTENTS INVENTORIED AND VERIFIED SITE SAFEGUARDS ADMINISTRATOR NOTIFIED SECURITY EVALUATION INITIATED REPORTABILITY DETERMINED RESIDENT NOTIFIED ENS NOTIFICATION INTERNAL NOTIFICATIONS SECURITY OFFICERS / MNS / CNS / GO
UNSECURED CONTAINER CONCLUSIONS PERSONNEL ERROR-INAPPROPRIATE ACTION SELF IDENTIFIED PROGRAM REVIEW TRAINING I RE-TRAINING PROGRAM ESTABLISHED CLASS 6 CONTAINER CUSTODIAN / DOCUMENT CONTROLLER ASSIGNED ACCESS LIST ESTABLISHED ANNUAL REVIEW OF CONTAINER INTEGRITY EMPLOYEE IDENTIFIED PROBLEM AND ACTED IN ACCORDANCE WITH TRAINING IMMEDIATE CORRECTIVE ACTION ACHIEVED FULL COMPLIANCE
UNSECURED CONTAINER CORRECTIVE ACTIONS IMMEDIATE CONTENTS INVENTORIED AND LOCKED HEIGHTENED SECURITY AWARENESS INITIATED END OF DAY CONTAINER CHECK SUBSEQUENT NOTICE TO SITE DOCUMENT CONTROLLERS (ACKNOWLEDGEMENT REQUIRED)
PROBLEM INVESTIGATION PROCESS INITIATED CORRECTIVE ACTION PROBLEM REPORT TO MANAGERS OF PERSONNEL INVOLVED OPEN / LOCKED STATUS SIGNS IMPLEMENTED ENTRY / ExIT LOG ESTABLISHED PROPOSED EVALUATE Q.V. ASSESSMENT RECOMMENDATIONS
UNSECURED CONTAINER SAFETY SIGNIFICANCE AGGRAVATING FACTORS SIGNIFICANT SAFEGUARDS INFORMATION LENGTH OF TIME MULTIPLE USERS OF CONTAINER LOCATED OUTSIDE P.A.
ROOM NOT CONSISTENTLY LOCKED UNAUTHORIZED ACCESS CANNOT BE DISPROVED MITIGATING FACTORS NO EVIDENCE OF UNAUTHORIZED DISCLOSURE BUILDING LOCATED WITHIN THE OCA BUILDING ROUTINELY LOCKED AND PATROLLED ROOM NORMALLY OCCUPIED DURING THE DAY SHIFT UNMARKED CONTAINER APPEARED LOCKED NO EVIDENCE OF TAMPERING WITH CONTAINER OR CONTENTS No MISSING DOCUMENTS SECURITY SYSTEM IS COMPLEX REDUNDANCY FIELD ROUTING DIFFICULT TO LOCATE DEFENSE IN DEPTH, P.A. / V.A. I SYSTEMS PROGRAMS ADDRESS OVERT / COVERT ACTS
MISC EVENTS
SUMMARY
UNLOCKED SAFEGUARDS CONTAINERS ONS-3, MNS-O, CNS-0 UNSECURED SATELLITE FILE CONTAINER ONS I&E, 7/9/92 UNSECURED SI CONTAINER ONS SSF COMPUTER RM, 1/18/93 UNSECURED SI CONTAINER ONS SEC ADMIN AREA, 4/26/93 UNSECURED SAFEGUARDS, LEFT IN COPIER ONS-0, MNS-0, CNS-2 SI JAMMED IN COPY MACHINE IN CNS ENG AREA, 8/25/92 SECURITY SHIFT JOURNAL LEFT ON COPIER OUTSIDE CNS CAS, 12/22/92 SAFEGUARD LOST OR MISSING ONS-1, MNS-0, CNS-2 PAGES CONTAINING SI MISSING AFTER CNS PLAN REVISION INSERTED, INVESTIGATION SUGGESTED PAGES SHREDDED, 1/27/93 ONS I&E PROCEDURE LOST DURING ROUTING, 2/23/93 CNS SEC PLAN PAGE MISSING AFTER REVISION INSERTION, 4/27/93. (EVENT DID NOT MEET 73.71 LOGGING CRITERIA)
SI LEFT UNATTENDED ONS-1, MNS-1, CNS-0 ONS SAFEGUARDS DOCUMENTS LEFT UNATTENDED DURING QV AUDIT IN SECURITY ADMIN AREA, 1/20/93 LIST OF COMBINATIONS FOR SAFEGUARDS CONTAINERS IN MNS ENG AREA LEFT UNATTENDED, 11/19/93 (LISTED UNDER ONS IN INSPECTION REPORT)
MISC EVENTS
SUMMARY
SI STORED IN IMPROPER CONTAINERS ONS-0, MNS-0, CNS-1 SI DISCOVERED IN DESK THAT HAD BEEN MOVED FROM GO TO CNS, 8/16/93 SI IMPROPERLY TRANSMITTED ONS-1, MNS-0, CNS-1 CNS DOCUMENT CONTROLLER RECEIVED SEALED PACKAGE OF SI THAT WAS NOT DOUBLE WRAPPED AND GAVE NO INDICATION OF CONTENT, 12/21/92. (EVENT DID NOT MEET 73.71 LOGGING CRITERIA)
SEALED AND MARKED SI PACKAGE WAS MAILED IN INTER OFFICE ENVELOPE THAT DID NOT MEET DOUBLE WRAPPED CRITERIA, 2/11/93.
CO cRRE CT ITTE ACT'ION CJ SUMMVIVAR.Y MvIiSC(ELLANEOUtS ETTEN"I'S 00 07/09/92 ONS UNSECURED CONTAINER 08/25/92 CNS UNCONTROLLED SGI 12/21/92 CNS IMPROPER TRANSMISSION 12/22/92 CNS UNCONTROLLED SGI 01/18/93 ONS UNSECURED CONTAINER 01/20/93 ONS UNCONTROLLED SGI 01/27/93 CNS UNCONTROLLED SGI 02/11/93 ONs UNCONTROLLED SGI 02/23/93 ONS UNCONTROLLED SGI 04/26/93 ONS UNSECURED CONTAINER 04/27/93 CNS UNCONTROLLED SGI 08/16/93 CNS UNCONTROLLED SGI 11/22/93 MNS UNCONTROLLED SGI
MISC EVENTS CORRECTIVE ACTION CORRECTIVE ACTIONS TAKEN WERE SPECIFIC FOR EACH EVENT 11 OF 13 EVENTS WERE LOGGED, ALL WERE TRENDED 3 EVENTS INVOLVED UNSECURED SAFEGUARDS CONTAINERS AS A RESULT OF THESE 3 EVENTS AND THE OPEN SI CONTAINER OUTSIDE THE PA, ADDITIONAL CORRECTIVE ACTION DEEMED NECESSARY.
INTERIM CORRECTIVE ACTION
- 1) SIGN ON EACH SI CONTAINER WITH INTERNAL COMBO LOCK TO INDICATE LOCKED/UNLOCKED STATUS OF CONTAINER
- 2) SIGNATURE CARD FOR ALL SI CONTAINERS WHICH ARE ACCESSED BY MULTIPLE USERS LONG TERM CORRECTIVE ACTION
- 3) INVESTIGATE VISUAL INDICATION ON SI CONTAINERS WITH INTERNAL COMBO LOCKS
- 5) REINFORCE EXPECTATIONS REGARDING ACCOUNTABILITY FOR PROPER HANDLING OF SI
CAD SYSTEM EVENT
SUMMARY
- 1) IDENTIFICATION DUKE IDENTIFIED AND REPORTED EVENT TO NRC
- 2) CORRECTIVE ACTION TIMELY, EFFECTIVE CORRECTIVE ACTION WAS TAKEN TO IDENTIFY AND PROPERLY CONTROL FILES
- 3) LICENSEE PERFORMANCE DUKE'S OVERALL PERFORMANCE IN SECURITY HAS BEEN EXCELLENT AS REFLECTED BY PREVIOUS NRC EVALUATIONS AT ALL 3 DUKE NUCLEAR STATIONS
- 4) PRIOR OPPORTUNITY TO IDENTIFY BASED ON THE LENGTH OF TIME THAT THIS SITUATION EXISTED, THIS PROBLEM SHOULD HAVE BEEN IDENTIFIED EARLIER.
- 5) MULTIPLE OCCURRENCES EXAMINATION OF PREVIOUS VIOLATIONS, REPORTED EVENTS AND LOGGED EVENTS REVEALS NO TREND THAT INDICATES THAT THIS IS A RECURRING PROBLEM
UNSECURED SAFEGUARDS CONTAINER EVENT
SUMMARY
- 1) IDENTIFICATION DUKE IDENTIFIED AND REPORTED THE EVENT PROMPTLY TO NRC.
- 2) CORRECTIVE ACTION IMMEDIATE CORRECTIVE ACTION WAS TAKEN TO ASSURE NO SI WAS MISSING AND CONTAINER WAS SECURED.
LONG TERM CORRECTIVE ACTION STILL BEING EVALUATED.
- 3) LICENSEE PERFORMANCE OVERALL PERFORMANCE IN SECURITY AT DUKE POWER HAS BEEN EXCELLENT AS REFLECTED BY PREVIOUS NRC EVALUATIONS AT ALL DUKE NUCLEAR STATIONS.
- 4) PRIOR OPPORTUNITY TO IDENTIFY ALTHOUGH THE CONTAINER WAS NOT LOCKED FOR A PERIOD OF SEVERAL WEEKS, THERE WAS NO NEED TO ACCESS THE CONTAINER DURING THAT TIME AND THE CONTAINER HAD THE APPEARANCE OF BEING LOCKED.
- 5) MULTIPLE OCCURRENCES THREE INSTANCES OF SECURITY CONTAINERS BEING LEFT UNSECURED INSIDE THE PA HAVE OCCURRED IN THE PAST TWO YEARS, HOWEVER, THESE INVOLVED FILING CABINETS WITH LOCKING BARS WHEREAS THE UNSECURED CONTAINER OUTSIDE THE PA HAD AN INTERNAL COMBINATION LOCK.
MISC SAFEGUARDS EVENTS
SUMMARY
- 1) IDENTIFICATION ALL EVENTS WERE IDENTIFIED BY DUKE PERSONNEL.
- 2) CORRECTIVE ACTION WHERE APPROPRIATE, IMMEDIATE CORRECTIVE ACTION WAS TAKEN.
SEVERAL EVENTS WERE CONSIDERED ISOLATED INSTANCES SO NO LONG TERM CORRECTIVE ACTION DEEMED NECESSARY.
- 3) LICENSEE PERFORMANCE DUKE'S OVERALL PERFORMANCE IS SECURITY HAS BEEN EXCELLENT AS REFLECTED BY PREVIOUS NRC EVALUATIONS AT ALL 3 DUKE NUCLEAR STATIONS.
- 4) PRIOR OPPORTUNITY TO IDENTIFY DUE TO THE NATURE OF THESE EVENTS, THERE WAS NO PRIOR OPPORTUNITY TO IDENTIFY THEM.