ML20086A082
| ML20086A082 | |
| Person / Time | |
|---|---|
| Site: | McGuire, Mcguire  |
| Issue date: | 06/15/1995 |
| From: | Mcmeekin T DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9507030040 | |
| Download: ML20086A082 (6) | |
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. T C MchfrI m L DukeIbwerCompany.
' McGui e Nuclear Generation Department ViceIVesident t
12700flagersFenyRoad(b!G0lVP)
(704)8754800
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(704)8754809Far
. DUKEPOWER
' June 15,1995 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington,D.C. 20555
Subject:
McGuire Nuclear Station, Units I and 2 Docket Nos.50-369 and 50-370 NRC Inspection Report No. 50-369,370/95 10 Violation 50-369,370/95 10-0I and 50-369,370/95-10-02 Reply to a Notice of Violation Gentlemen:
.L Enclosed is a response to a Notice of Violation dated May 18,1995 concerning failure to properly store Safeguards Information when not in use and failure to properly protect Safeguards Information on an automated data processing system.
Should there be any questions concerning this response, contact Randy Cross at (704) 875-4179.
Very Truly Yours, 9tn/Ji T. C. McMeekin Attachment xc:
(w/ attachment)
Mr. S. D. Ebneter Mr. George Maxwell Regional Administrator, Region 11 Senior Resident inspector U. S. Nuclear Reguiatory Commission McGuire Nuclear Station 101 Marietta St, NW, Suite 2900 Atlanta, Georgia 30323 Mr. Victor Nerses U. S. Nuclear Regulatory Commist. ion l.
Office of Nuclear Reactor Regulation L
One White Flint Nonh, Mail Stop 9H3 Washington, D. C. 20555
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" U. S. Nuclear Regulatory Comrnission June 15,1995 i
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A. V. Carr (PBOSE)
NSRB Staff (EC05N)
J. E. Snyder R. J. Deese E. Burchfield (ON01RC)
Z. L Taylor (CN01RC)
' J. M. Frye (ECl2A)
ELL (EC050)
RGC File: Inspection Report K. L Crane T. W. Keener T. W. Godfrey J. S. Thrasher R. E. Eller T. K. McQuarrie (ON0lSC)
W. T. Byers (CN01SC)
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McGuire Nuclear Station Reply to a Notice of Violation Vjolatjanjp-369. 370/95-10-01 10 CFR 73.21 (d) (1) requires, in part, that Safeguards Information while in use shall be under the control of an authorized individual.
10 CFR 73.21 (d) (2) requires, in part, that Safeguards Information be stored in a locked security storage container when unattended.10 CFR 73.2 defines a security s'orage container as a steel cabinet equipped f
with a locking bar and padlock.
Contrary to the above, on February 9 and 15,1995, the licensee found documents marked as being Safeguards Information in unsecured file cabinets, exterior to the protected area, and not under the control of authorized individuals, and, on January 17,1995, unattended Safeguards Information was discovered stored in a steel cabinet that had an unsecured locking bar and padlock.
I This is a Severity Level IV violation (Supplement 111).
Esply to Violation 369. 370/95-10-01 1.
Reason for the violation:
The reason for the violation is inappropriate Action. Personnel responsible for properly controlling Safeguards Information failed to follow work place procedures and/or Nuclear System Directive 206, Safeguards and Information Control. For each event identified in the Notice of ~
Violation, the personnel involved failed to apply the required self-checking steps to ensure the information was properly protected.
2.
Corrective steps that have been taken and the results achieved:
January 17,1995 Event a) Upon discovery, the container was inventoried to account for all documents. The inventory verified that all items were accounted for.
b) Following completion of the inventory, the cabinet was re-locked and the Controlled Access Area (CAA) was inspected to ensure barrier, door and lock imegrity. The inspection verified the integrity of the CAA with no evidence of unauthorized access attempts or entries found.
This corrective action was completed on January 17,1995.
February 9 and 15,1995 Events a) Upon discovery, the drawings were properly controlled. The associated files were inventoried to ensure that no other documents marked Safeguards Information were present. No additional documents mated Safeguards Information were identified.
b) A review detc. mined the drawings did not contain Safeguards Information and the drawings were declassified or properly destroyed. This corrective action was completed by April 6, 1975.
No similar events have occurred since implementation of these corrective actions.
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3.
Corrective stens that will be taken to avoid further violations:
a) Safeguards Information files were relocated from all Controlled Access Areas to inside the site protected area on March 16,1995 to provide additional protection. The only Safeguards Information stored outside the protected area are security drawing archive aperture cards which were moved from the General Office to a GS A approved security container located in the McGuire QA Vault to enhance document controls. This transfer was completed on April 6,1995.
b) To ensure the positive control of Safeguards Information at McGuire, process changes were implemented to limit the number of personnel involved in Safeguards Information work processes and to place tighter controls on document processing and storage. These process changes will be evaluated by site management to determine if long term implementation is necessary. This evaluation will be performed by July 1,1996. Process changes are addressed in Sections 3.c through 3.e below, c) With the exception of the Central Alarm Station (CAS) and Secondary Alarm Station (SAS),
the processing and storage of Safeguards Information inside the protected area is limited to two dedicated work areas. A method was engineered and installed to provide a visual i
indication (blinking light) of an unlocked container and provide a local alarm when the work room door is opened and a container is unlocked. Installation of these visual and audible signals was completed on April 4,1995.
d) McGuire Site Directive 954, Safeguards Information Control Process was de xloped to outline the new Safeguards Information work processes. This Directive was approved on April 21,1995.
e) Training sessions were held with Safeguards Information routine users to instruct them on the new processes, re-emphasire employee responsibilities and accountabilities regarding Safeguards Information control and to ensure a clear understanding of the management y
expectation of station personnel to properly control Safeguards Information. These sessions were completed by April 10,1995.
f) Efforts to reduce the volume of documents containing Safeguards Information and to establish controls to minimize future generation were completed on March 31,1995. These efforts included increasing user awareness of Safeguards Information control requirements, thorough document reviews to determine the potential for document declassification and declassification of appropriate documents. These efforts have resulted in a significant l
reduction in documents containing Safeguards Information and a decrease in the number of containers from twenty-eight to eighteen. In addition, ten security procedures and forty-eight engineering drawings were declassified.
4.
Daisy _ hen full compliance will be achieved:
McGuire Nuclear Station is now in full compliance.
2
, o McGuire Nuclear Station Reply to a Notice of Violation Violation 50-369. 370/95-10-02 10 CFR 73.21 (h) permits Safeguards Information to be processed or produced on an automated data processing (ADP) system, provided that the system is self-contained within the licensee's facility and requires the use of an entry code for access to stored information.
Contrary to the above, on March 16,1995, an employee at the McGuire Nuclear Station discovered one engineering drawing marked as Safeguards Information residing in a site automated data processor that was not self-contained and did not require use of an entry code for access.
This is a Severity Level IV violation (Supplement III).
Egply to Violation 369. 370/95-10-02 1.
Reason for the violation:
The reason for the violation is Inappropriate Action. Personnel used inadequate work practices while working with Safeguards Information located on Local Area Network (LAN) connected personal computers. The required self-checking steps were not applied to ensure that information processed / loaded onto the LAN server did not contain Safeguards Information.
2.
Corrective steos that have been taken and the tesults achieved:
a) Upon discovery, the file marked as Safeguards Infonnation was immediately removed from the LAN server and the LAN backup tapes were retrieved.
b) A "Stop Work Notification" for Safeguards Information activities outside the protected area was initiated on March 16,1995 pending investi;;ation of the event and implementation of corrective actions to pre ent recurrence, 4
c) A search of the McGuire LAN and McGuire personal computer hard drives was performed using " wild card" file addresses to determine if other Safeguards Information files were uncontrolled electronically. No additional files were found. This corrective action was completed on March 16.1995.
d) An electronic audit was conducted within the Nuclear Generation Department from April 12, 1995 through May 25,1995 on Local Area Networks and work stations at the General Office and the three nuclear stations to determine if other Safeguards Information files could be found. This search was performed using a " wild card list" of all known filenames for drawings, sketches, and documents containing Safeguards Information. No files containing Safeguards Information were found.
e) Upon implementation of the above corrective actions, the "Stop Work Notification" was discontinued on April 10,1995.
No similar events have occurred since implementation of these corrective actions.
3
i-1,
- - 3.
Corrective stens that will be taken to avoid further violations:
a) All Safeguards Information at McGuire was relocated inside the protected area and the processing of Safeguards Information on personal computers connectable to the LAN was discontinued. his corrective action was completed on March 16,1995. He only Safeguards Information stored outside the protected area are security drawing archive aperture cards which were moved from the General Office to a GSA approved security container located in the McGuire QA Vault to enhance document controls. This transfer was completed on April 6,1995.
b) As addressed in the response to Violation 369,370/95-10-01, Section 3, to ensure the positive control of Safeguards Information at McGuire, process changes were implemented to limit the number of personnel invelved in Safeguards Information work processes and to place tighter controls on document processing and storage. These process changes will be evaluated by site management to determine if long term implementation is necessary. This evaluation will be performed by July 1,1996. Process changes are addressed in Sections 3.c through 3.e below, c) With the exception of the Central Alarm Station (CAS) and Secondary Alarm Station (SAS),
the processing and storage of Safeguards Information inside the protected area is limited to two dedicated work areas. A method was engineered and installed to provide a visual indication (blinking light) of an unlocked container and provide a local alarm when the work room door is opened and a container is unlocked. Installation of these visual and audible signals was completed on April 4,1995.
d) McGuire Site Directive 954, Safcguards Information Control Process was developed to outline the new Safeguards Information work processes. This Directive was approved on April 21,1995.
e) Training sessions were held with Safeguards Information routine users to instruct them on the new processes, re-emphasize employee responsibilities and accountabilities regarding Safeguards Information control and to ensure a clear understanding of the management expectation of station personnel to properly control Safeguards Information. These sessions were completed by April 10,1995.
f) Efforts to reduce the volume of documents containing Safeguards Information and to establish controls to minimize future generation were completed on March 31,1995. These efforts included increasing user awareness of Safeguards Information control requirements, thorough document reviews to determine the potential for document declassification and declassification of appropriate documents. Rese efforts have resulted in a significant reduction in documents containing Safeguards Information and a decrease in the number of containers from twenty-eight to eighteen. In addition, ten security procedures and forty-eight engineering drawings were declassified.
- 4. Date when full compliance will be achieved:
McGuire Nuclear Station is now in full compliance.
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