ML20064H706
| ML20064H706 | |
| Person / Time | |
|---|---|
| Site: | Prairie Island  |
| Issue date: | 03/14/1994 |
| From: | Anderson R 0 NORTHERN STATES POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9403180136 | |
| Download: ML20064H706 (5) | |
Text
Northem States Power Company 414 Nicollet Mall Minneapolis, Minnesota 55401 1927 Telephone (612) 330-5500 March 14, 1994 U.S.
Nuclear Regulatory Commission 10 CFR Part 2 Attn: Document Control Desk Section 2.201 Washington, DC 20555 PRAIRIE ISLAND NUCLEAR GENERATING PLANT Docket Nos. 50-282 License Nos. DPR-42 50-306 DPR-60 Reply to Notice of Violation Contained in NRC Region III Letter, dated February 11, 1994, "Special Nuclear Material Accounting and Security Inspection" Jnspection Reoorts No. 50-282/93022fDPSS) and Eg. 50-306/93022fDRSS)
Pursuant to the provisions of 10 CFR Part 2, Section 2.201, our Reply to Notice of Violation dated February 11,.1994 is provided as Attachment A.
Included within our Reply to Notice of Violation are:
The reason for the violation Corrective steps that have been taken and the results achieved Corrective steps that will be taken to avoid further violations Date when full compliance will be achieved.
We acknowledge the need for management attention to this matter and believe that the attached reply demonstrstes that understanding.
This letter contains no new commitments to the NRC.
j 53 r; rs o o a v v d 4. +)
9403180136 940314
/N l PDR ADOCK 05000282
,U\\
g PDR l
t
Nodhem States Power Company Page 2 of 2 March 14, 1994 Please contact Mel opstad at (612) 337-2038 if you have any questions or wish further information concerning this matter.
Sincerely, 77 h 4
/
por Roger O Anderson Director Licensing and Management Issues c
Regional Administrator III NRC NRR Project Manager Senior Resident Inspector, Prairie Island NRC J.
Silberg Attachment A)
Reply to Notice of Violation
Attachment A March 14,1994 RF, PLY TO NOTICE OF VIOLATION r
Docket Nos. 50 282 and 50-306 y1QLATION:
D uring an NRC inspection conducted between December 13,1993 and January 14, 1094; a violation of NRC requirements was idendfied.
In accordance with the "Ganeral St0tement of P6Hcy and Procedures & NRC Enkcoment Actions," 10 CFR 2, Appendix C (1993), the violation is Aisted below:
10 CFR 73.21(d)(2) states in part, " White unattended, Salleguards information shaW be stored in a locked security storage container".
Contrary to this requirement, on August 19,1993, a copy of the entire plant security plan was left unattended for up to two minutes at the security section within the Nuclear Projects Department Buidding located outside of the protected area.
This is a Severity LevelIV violation (Suppiament Ill).
NSP REPLY TO THE NOTICE OF VIOLATION A strong and direct NSP management involvement resulted from the Safeguards information (SGI) event at Prairie Island. This involvement determined that NSP -
should not only address the root cause for the Prairie Island event, but also should examine their entire SGI program for other -potential weaknesses and institute corrective actions on a broad basis. This examination resulted in significant changes to the NSP SGI program at all locations. The changes demonstrate a determined oversight by NSP management for program compliance as well as a concerted effort by the entire NSP security team to prevent recurrence. Although the changes to the NSP SGI program were system wide, only areas applicable to Prairie Island (site and Corporate interface) are identified within this reply.
REASON FOR THE VIOLATION The root cause determination for the violation was personnel error and inattention to detail in fulfilling individual responsibilities to protect or control SGl.
CBRRECTIVE STEPS THAT HAVE BEEE TAKEN AND RESULTS ACHIEVED The following corrective action has been completed at the Prairie Island Site:
Page 1.of 4
l'nventoried and accounted for all SGI located within the various departments.
Departments both inside and outside the protected area.-
Moved allidentified SGI into the protected area.
Resulted in greater than 85% reduction in locations used for the storage of SGl.
Established a specific minimum number of SGI repositories.
Consolidated the identified SGI in the repositories. These repositories are located:
Within the document control vault within a GSA approved locking cabinet.
Within the Access Coordinator's office within GSA approved locking cabinets.
Within the Security Alarm Stations.
Other areas to be determined that are constantly manned by personnel authorized access to SGl.
Changed combinations on all SGI containers.
Reduced inventories through reviews of current SGI and destroyed any SGI that was redundant or not applicable.
This resulted in a reduction of approximately 75% of retained SGl.
Specifically documented all retained SGI by drawer _for each SGI container.
Established a minimum number of personnel required for access to SGI combinations.
Provided for specific SGI custodians who are knowledgeable of their job requirements and responsible for:
Possessing and controlling combinations for SGI containers.
Maintaining a running inventory of the SGI located within the SGI containers under their control.
Issuing, receiving and cataloging SGl.
Verifying that SGI containers are secured prior to leaving the repository unattended.
1 Established a specific control and dissemination procedure for SGl.
Establishes program guidance.
Establishes program documentation criteria, j
i Separated stored composite security plans and procedures.
Page 2 of 4
.i
l Placed half into separate binders.
Placed each half in separate SGI containers.
Requires a dual failure to fully compromise any of the composite plans or procedures.
Provided a self contained personal computer (PC) and printer in the Access Coordinator's office for composing SGI documents.
Established procedures for pur0 ng backup capabilities on other PC's i
when used to compose SGl.
Provided training and guidance on PC use for SGl.
Required, to the Dreatest extent practical, that the use of SGI be conducted in an established repository.
Removal of SGI from a repository and frorn the protected area requires two person responsibility, sign out and control at all times when outside of the protected area.
Holding supervision responsible and directly accountable for the actions of their subordinates when control of SGI is at issue.
Provided remote GSA approved containers, outside the protected area, for interim, emergency storage of SGI that may be authorized for use, transit or received by mail.
Sensitized the security team and plant staff to the issue.
Staff meetings, labor management meetings and general site meetin0s.
Enhancement recognition within General Employee Training.
Security staff awareness meeting topic.
The following corrective actions were completed at the Corporate Office.
Consolidated areas where SGI materials may be retained.
Greater than 80% reduction in areas.
Transferred all SGI drawings and microfiche cards to the nuclear plant sites.
Established a single restricted access repository for SGl.
Meets the criteria of NUREG 0794,4.1 for SGI controlled access areas.
Card reader and key pad controlled.
Use and review of SGI is restricted to this area with adequate space and furniture required.
Room is protected with a motion detector alarm (volumetric).
Designated specific SGI custodian (s) for the control and account 6hility of SGl.
Page 3 of 4
1 e
Compiled an SGI standard guide.
Used for quick reference of what constitutes SGl.
Consolidated the various NRC guidance documents into a single reference manual.
Reviewed and reduced by approximately 60% retained SGl.
Sensitized entire security team to the issue of SGl.
Management personnel are held accountable for the actions of subordinates relative to the SGI issue.
CORRECTIVELSTEPS THAT WILL BE TAKEN TO AVOID FUR 13ER VIOLATIONS No additional corrective actions are believed to be necessary at this time. The actions described in the preceding section are considered adequate to avoid further violation.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
Page 4 of 4