ML20099K460

Responds to NRC Re Violations Noted in Insp Rept 50-285/92-12 on 920526-29.Corrective Actions:Use of Courier to Transport Safeguards Matl Between Company Site/Stations & Use of New Colored Inner Envelope for Drawings Instituted

ML20099K460
Person / Time
Site:	Fort Calhoun
Issue date:	08/21/1992
From:	Gates W OMAHA PUBLIC POWER DISTRICT
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LIC-92-284R, NUDOCS 9208260151
Download: ML20099K460 (3)

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e e Omaha Public Power District 444 South 16th Street Mall Omaha, Nebraska G8102-2247 402/636-2000 August 21, 1992 LIC-92-284R U. S. Nuclear Regulatory Commission ATill: Document Conttol Desk Mail Station Pl-137 Washington, DC 20555

References:

1. Docket No. 50 285

2. Letter from NRC (J. L. Mllboan) to OPPD (W. G, Gates) dated July 22, 1992 Gentlemen:

SUBJECT:

NRC Inspection Report No. 50-285/92-12 Reply to a Notice of Violation (NOV)

The subject report transmitted an NOV resulting from an NRC inspection conducted May 26-29,1992 at the fort Calhoun Station. Attached is the Omaha Public Power District response to this NOV.

If you should have any questions, please contact me.

Sincerely, AV N N ~

W. G. Gates Division Manager Nuclear Operations WGG/grc Attachment c: LeBoeuf, Lamb, Leiby & MacRae J. L. Milhoan, NRC Regional Administrator, Region IV R. P. Mullikin, NRC Senior Resident inspector S. D. Bloom, NRC Acting Project Manager 9200260151 920021 PDR ADOCK 0D00028S 0 PDR

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Attachment LIC-92 284R Page 1 REPLY TO A NOTICE OF VIOLATION ELOLAIl0B During an NRC inspection conducted on May 26-29, 1992, a violation of HRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2 Appendix C, the violation is listed below:

10 CFR 73.21 Safeguards In(formation shalld) states, in part, be under thethat, while of control in use, matter containing an authorized individual, and, while unattended, shall be stored in a locked security storage container.

Contrary to the above, between approximately April 30, 1992, and May 13, 1992, a copy of the Fort Calhoun Station physical security plan, which onntains Safeguards Information, was neither under the control of an authorized individual at all times nor was stored in a locked security storage ::ontainer when unattended. Specifically, the information was left out du:ing the entire period in a secretarial area in the company's corporate office building in Omaha.

This is a Severity Level 111 violation.

OPPD RESPONSE A. Ibg Reason for the Violation

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Omaha Public Power District (OPPD) admits the violation occurred as stated. The root cause, as determined by completion of a Human Performance Enhancement System (HPES) evaluation, was failure to follow procedural guidance for oper transmittal, receipt and storage of Safeguards Information ( ), as detailed in procedure N00-QP-14, Protection of Safeguards 1 ormation. This occurred during distribution of a revision of the Fort Calhoun Station (FCS) Site Security Plan.

Through investigation, OPPD determined the following:

e The Site Security Plan revision was transmitted to the corporate office location on or about April 28, 1992, e The package was improperly addressed.

e The package was received by an individua; that was not- an Si coordinator and was improperly handled and stored by this-individual, e A contributing cause to this incident was that the Site Security Plan Distribution List was not a controlled document, i

Attachment

. LIC-92-284R Page 2 B. Corrective Steps That Have Been Taken and thg_Egiults Achieved A comprehensive investigation of this incident was completed to determine the cause and corrective actions. The results were documented in Human Performance Enhancement System Report No.92-018.

OPPD has reduced the number of Site Security Plan copies maintained to eliminate individuals / offices without a valid requirement. The Site Security Plan Distribution List was revised and now is maintained as a controlled document. Additior. ally, the list now contains only names of Si coordinators or alternates.

Although N00-QP-14 was adequate to control SI materials. OPPD determined that parts of the procedure were not followed. To assure future compliance with applicable requirements, OPPD has revised N00-QP-14 to include enhanced control of SI material during use and transmittal. These controls include requirements for:

• Use of a courier when transmitting S1 material between company sites / stations; e Use of a red and white cover sheet whenever Si material is outside an authorized container, to better identify this material during use; e Use of a new brightly colored inner envelope or, for drawings, colored 51 stickers when transmitting S1 material between 51 coordinators, for more obvious identification of this material when the outer envelope or wrapping is removed; e Use of a suspense file to verify receipt of SI material and insure return of the signed receipt form when SI material is transmitted _

between SI coordinators; e Annual rebriefing and recertification of all SI cleared personnel.

S1 qualified personnel have been retrained and recertified on proper handling of Si materials.

C. Corrective Steps That Will Be Taken_to Avoid Further Violationt No additional corrective actions are considered necessary.

D. Date When full Compliance Will Be Achieved OPPD is currently in full compliance w'th the regulatory requirements pertaining to this violation.

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