ML20043B584

Responds to NRC 900423 Ltr Re Violations Noted in Insp Rept 50-483/90-04.Corrective Actions:Security Post Instructions Modified to Require Check of Security Container in QA Area

ML20043B584
Person / Time
Site:	Callaway
Issue date:	05/22/1990
From:	Schnell D UNION ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ULNRC-2214, NUDOCS 9005300249
Download: ML20043B584 (5)

Text

.............,,,y 1901 Chouteau Awnue

, Post 0110 Box 149 St. itus, M:scuo 63166

.314 554-2650 Gyggy Ondd W uu

.Eusenue "ay 22, 1990 f=[n rewer -

E U.S. Nuclear. Regulatory Commission Document Control Desk ,j Washington, D.C. 20555 ULNRC-2214 '

Gentlemen:

REPLY 70-NOTICE OF-VIOLATION INSPECTION REPORT NO.. 50-483/90004.

CALLAWAY PLANT 4 This responds to A. Bert Davis's letter dated April ~23, 1990, which transmitted a Notice of Violation forRevents discussed in Inspection Report--50-483/90004.- Our! response to the violation is presented below.1 None of the material in the responsefis considered-proprietary-by Union Electric Company - q I

Statement of-Violation -

During an NRC inspection conducted on January 22 Sand i February 8, 1990, violations.of NRC requirements >were

. identified.

j In accordance with the " General' Statement of  !

Policy and Procedure for NRC Enforcement- Actions!',- 10CFR i Part 2, Appendix C (1989), the violations are listedt below:

10CFR73.21(d)(2) . requires, in part, that safeguards-information be stored in a locked securityLstorage' '

container while unattended.

The Callaway Physical Security Plan (PSP) and Safeguards  ::

Site Contingency Plan (SCP) are considered safeguards; j information as described in 10CFR73.21(b)(1)(i)  ;

and (b)(1)(viii), respectively.

A. Contrary to the above, from approximately 4:45 p.m.i I October 18, 1989, to approximately 3:00 a.m.,

October 19,-1989, a security storage container l storing copies of the PSP and SCP,' located in the l Quality Assurance office, was unlocked and  !

unattended. I j

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I B. Contrary to the above, from approximately 4:00 p.m., '

December 6, 1989, to'approximately 1:40 a.m.,.

December 7, 1989,.a security storageLcontainer storing copies of the PSP-and SCP, located in the Quality Assurance office, was unlocked and ,

unattendede ,

C. Contrary to the above, from approximately 4:00 p.m.,-

to approximately 6:30 p.m. on December 13, 1989, a i Security storage container storing copies.of'the PSP ,

and the SCP, located-in the Security section office,. .

was unlocked and unattended.-

This is a Severity Level III problem (Supplement III)..  !

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Response

Admission or Denial of the Alleged Violation a Union Electric acknowledges the cited ~ violation itemized .'

as parts A, B, and C. All three instances were identified and documented by Union-Electric and prompt. action was taken in each instance to determineLthat plant security:

had not been compromised.

Reason for the Violation if Admitted r

The cause of each of1the three examples cited.was p personnel error and oversight-on the part.of knowledgeable.

l individuals.

Corrective Steps'That Have Been Taken and the I Results [

Achieved In each of the events, an' inventory.wa'sotaken as soon as a determination was made that safeguards information had been left unattended. These inventories determined.no l documents were missing. No. signs;of tampering with the containers were identified. -Plant incident reports were?

written to evaluate reportabilityLand track corrective-actions for'all incidents.- The persons responsible-for ,

each event received'further training on procedural' requirements. As a result of the:first incident, Security post instructions were modified-to require a check of-the security container in the-Quality Assurance area. This check was effective in identifying the second' incident', i but did not prevent it from occurring. After the'second-and third incidents, signs were developed and posted in  ;

the Quality Assurance and Security areas to' remind, i

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ULNRC-2214 j Pag 3 3- 4

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personnel to lock the safeguards cabinets. These signs werc discontinued in the Quality Assurance arca after the Quality Assurance Department relocated to inside the protected arca on April 30, 1990.

- Quality Assurtace Surveillance Report SP90-017, completed  :

on February 14, 1990, was performed to: identify locations outside the Callaway Plant protected area, including the l Union Electric General Office Building in St. Louis, where i safeguards information.could be reduced or climinated. As >

a result of this curveillance, the number of safeguards I

documents was1 reduced and some safeguards cabinets.at these locations were emptied entirely.u Quality Assurance' [

performed a follow-up-surveillance, SP90-037, on  :

March 27, 1990, to determine the need for safcguards'  : '

information at the various locations inside the protected area. The amount of safeguards information in each  ;

location was generally determined to be appropriate forL l the work activities performed at the location. After review of the surveillance results, several safeguards information accounts were consolidated or climinated.

The Security Plans were segregated among several safeguards storage. containers-at all locations except.

l three locations within the protected area. This action reducos the potential compromise of p? ant security if '

unauthorized personnel were able to obtain the, contents of a single container. The callaway Physical SecurityLPlan, Safeguards Site Contingency Plan, and other safeguards-information were removed from the Quality Assurance-Department security container-outside the protected area and transferred to.other security accounts or destroyed. ,

The-Quality Assurance Department has since' moved back into ~

the protected area and now maintains lno records or document storage containers containing. safeguards information outside the' protected area., The Quality Assurance Department will maintain safeguards.information determined appropriate for work activities at.its current location.

In addition.to these actions, the controlling procedure,  ;

APA-ZZ-00204, " Safeguards Information", has been revised ,

to require safeguards cabinets-in areas not continuously-manned by security or Operations personnel be resecured immediately after removing or returning safeguards information. The applicable requirements of the i

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safeguards control procedure, APA-ZZ-00204=, were covered:

in the 1990 Quality Assurance Department' Retraining a sessions during April and May, 1990.

These actions have been effective in preventing recurrence i of unattended open safeguards containers and in minimizing the amount of safeguards material.

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[ ULNRC-2214' Pcgs ' 4 Corrective Steps That Will Be Taken to Avoid Further Violations Union Electric-has taken the corrective actions necessary.

to avoid further violations.

Date When Full Compliance Will Be' Achieved Union Electric is in full compliance.  ;

If you have any questions regarding this-response.or if- -

additional information is required', please let me-know.

b Very truly=yours,

.O

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• 7 Donald-F. Schnell EMT/ CSP / pas cc: A. B. Davis - Regional Administrator,.USNRC Region III-R. L. Hague --Chief, Reactor Projects Section 3C, USNRC Region III _

1 A. T. Gody, Jr.~--USNRC Licensing Project Manager (2icopies)

Manager Electric Department', Missouri?Public Service Commission B. L. Bartlett - USNRC Senior Resident Inspector Shaw,.Pittman, Potts, & Trowbridge 4

.i STATE OF MISSOURI') -

) Ss ,

CITY OF ST. LOUIS )

Donald F. Schnell, of lawful' age, being first duly sworn upon:,

oath says that he is Senior Vice-President-Nuclear and-an officer of Union Electric Company;.that.he has read the foregoing docu-ment and knows the content thereof; that he has: executed the same for and on behalf of said company with full power and authority to do so; and that the facts therein stated are true:and correct to the best of'this knowledge, information,.and belief.

By

[ Don'ald P..SchneIl i' l Senior,Vice President-Nuclear SUBSCRIBED and sworn to before me this Jf*tlay of [fl4 ,'1990.

/b u A w T l y&, u BARBARA FAF

- NOTARY PUBLIC, STATE OF MISSOURI MY. COMMISSION EXPIRES APRIL 22, 1993 ST. LOUIS COUNTY, t

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