ML20034C130
| ML20034C130 | |
| Person / Time | |
|---|---|
| Site: | Callaway  |
| Issue date: | 04/23/1990 |
| From: | Davis A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | Schnell D UNION ELECTRIC CO. |
| Shared Package | |
| ML20034C131 | List: |
| References | |
| EA-90-028, EA-90-28, NUDOCS 9005020087 | |
| Download: ML20034C130 (4) | |
See also: IR 05000483/1990004
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April 23, 1990'
Docket No. 50-483
License No. NPF-30
EA No. 90-0?8
Union Electric Company
ATTN: Mr. Dont1d F. Schnell
Senior Vice President - Nuclear
Mail Code 400
Post Office-Box 149
St. Louis, Missouri 63166
Gentlemen:
SUBJECT: .N0TICEOFVIOLATION'(NRCINSPECTIONREPORTN0.50d83/90004(DRSS))'
This refers to the unannounced routine safeguards inspection conducted on
January 22 and February 8,1990, in which the' protection of Safeguards Information
was reviewed at the Callaway County Nuclear Power Station. The inspection
disclosed that on three occasions (October 18, December 6 and December 13,1989)-
containers storing documents containing Safeguards Information were found
unlocked or otherwise unprotected at the Callaway Plant. A copy of the
Inspection Report (Report No. 50-483/90004) was mailed to you on _ February'16,.
1990. An enforcement conference was held with you and other members of your--
staff on February 27,1990, at which time the violations,Jtheir causes, and
your corrective -actions were discussed.
The Safeguards Information stored in both of. the' containers included the complete
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security plan, including locations of vital equipment; and the' security
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contingency plan. Other Safeguards Information.in those' containers-included a
" target analysis" discussing vital ~ equipment and potential vulnerabilities', a
list of the training and qualification of security personnel, and security post
instructions which directed the-response of the: security. force in certain-
situations. The security and contingency plans alone contain information-
which could significantly assist a potential saboteur in an act of radiological-
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sabotage.
Cc11ectively, the failure to protect the security plan, contingency
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plan, " target analysis," security department qualification and training.and
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specific post instructions represents a potentially'significant compromise of;
Safeguards Information which would significantly assist'a' potential-saboteur
in an act of radiological sabotage or theft of special nuclear material.
At the enforcement- conference, the root cause of the_ violations was attributed :
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to the error of individual employees who'were knowledgeable of the requirement
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to store documents containing Safeguards 'Information in a locked container at-
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the close of a business day. The corrective actions following each event'were
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to counsel the employee involved.
In addition, following the October 18,;1989
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event, signs were ordered and, on December 8, 1989, were placed at certain
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locations to remind employees to lock safeguards containers.
Following'the-
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CERTIFIED MAIL
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RETURN RECEIPT REQUESTED
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9005020087 900423
PDR ADOCK 05000483
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Union Electric Company
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April 23, 1990
October 18, 1989 event, a security patrol.was instituted to c' heck security
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containers during off hours.
Corrective actions to prevent recurrence fol. lowing
the Region III inspection included a reduction in the overall: volume of-
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safeguards materials and a reduction in the amount.of-safeguards material stored
outside of the plant protected area. Other corrective actions instituted ~after.-
the Region III inspection included the separation'of the plant's security plan
into four volumes-in order to segregate Safeguards Information.
The'separa. tion
permitted the security plan, procedures, and associated drawings to be stored in
separate cabinets and allowed the contingency plan and training. qualifications
to be removed from some copies-of the security plan'.- The policy for handling
Safeguards Information was also reviewed and now includes a requirement to-
relock the cabinets'as soon as safeguards materials are withdrawn from,-or
replaced in, the cabinet rather than waiting until the end of the-_ business day :
to lock the containers. Additionally, an audit of the Safeguards Information.
stored at locations within the plant's protected area was' accomplished by.
March 31,1990.
At the conclusion of the Enforcement Conference, you brought to our attention a
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recent inspection (50-482/89026) at'the Wolf _ Creek Nuclear. Generating Station in
which sixteen instances of unlocked security containers containing Safeguards-
Information were identified and a Severity Level-IV violation was-issued to the_
Wolf Creek plant.
In reviewing that case, the principal difference is the
significance of-the Safeguards Information involved.
In the Wolf Creek case,.
the information involved in each individual instance would not have significantly
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aided a.-potential saboteur in an act-of radiological sabotage at Wolf Creek.
In -
the present case at Callaway, complete copies of,both. the security and contirigency
plans were in each of the unlocked containers, and possession of-this information-
would significantly assist a potential; saboteur in an act ~of radiological- sabotage
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at the Callaway Plant.
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These violations have been categorized in-~the aggregate at Severity Level III.
In accordance with the " General Statement of. Policy and Procedure for Enforcement
Actions," 10 CFR Part 2, Appendix C (1989) (Enforcement Policy),;a civil penalty
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is considered for a Severity Level III violation.
However, after consultation
with the Director, Office of Enforcement, and'the Deputy Executive Director for-
Nuclear Materials ~ Safety, Safeguards, and _0perations Support, I have' decided that
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a civil penalty will not be proposed in this case. Although a penalty might have
been proposed due to.the multiple examples _ of this violation, this was not done
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because you identified all the violations and because of your good overall
performance.
You are required to respond-to this letter and should follow the instructions
specified in the enclosed Notice of Violation (Notice) when preparing your
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-response. .In your response, you should document the specific actions taken and
any additional actions you plan to prevent recurrence. After reviewing your.
response to this Notice, including your proposed corrective actions.and the-
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results of future inspections, the NRC will determine whether further NRC
enforcement _ action is necessary to ensure-compliance with NRC regulatory
requirements.
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Union Electric Company
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April 23. 19901
In accordance with 10 CFR 2,790 of the NRC's " Rules of Practice," Part 2
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Title 10, Code of Federal. Regulations, a copy of this letter and.its enclosure
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will be placed in the NRC Public Document Room,
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The responses directed by this letter and the enclosed Notice are not subject
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to the clearance procedures of the.0ffice'6f Management-and Budget,.as required-
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by'the Paperwork Reduction Action of 1980, Public Law 96-511'-
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. Sin:erely;
Original 016 nod L5~
-A., Dai:t D vid y
A. Bert Davis.
Regiona1' Administrator-
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Enclosures:
1.
2.
Inspection Report-
No. 50-483/90004(DRSS)
See Attached Distribution
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(Concurrence Received vialFAX-4/19/90).
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April 23; 1990
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G. L.-Randolph, General Manager,
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J. V.ELaux,1 Manager Quality-
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Tom P.-Sharkey,-. Supervising.
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Engineer; Site. Licensing.
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Resident Inspector, RIII-;
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- Resident Inspector,4 Wolf
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Chris R, Rogers,' P.E. .
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Thomas Baxter, Esq.
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J. Taylor. ED0t
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J. Lieberman,-OE
J. Goldberg, OGC
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