ML20101F183
| ML20101F183 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 06/17/1992 |
| From: | Tuckman M DUKE POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| NUDOCS 9206240324 | |
| Download: ML20101F183 (7) | |
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) rt SC 2fi.T g;.y;,77 3 r;t; / 3 g DUKCPOWER June 17, 1992 U.S. Nuclear Regulatory Commission Washington, D.C.
20555 Attention: Document Control Desk
Subject:
Catawba 11uclear Station Docket lios. 50-413 and 50-414 tiRC Inspection Report lio. 50-413,414/ 92-12 Reply to tiotice of Violation Enclosed is the reply to 11otice of Violation 50-413, 414/
92-02-01 and 92-12-02, issued May 19, 1992.
These violations concerned the failure to report, in the Safeguards Event Log, unlocked vital area doors and an inadequate departmental directive that would have led to certain events not being reported in the Safeguards Event Log.
The practices cited as violations have been in ef fect at our three nuclear stations for several years.
I sincerely appreciate the additional guidance but I do not conclude that this represents a decline in security program oversight or the overall performance level of security at Catawba.
If you have any questions concerning this reply contact David Smith at (803) 831-3000, ext 2076.
Very truly yours, b1 M.S. Tuckman, Vice President Catawba Generation Department DNS/RES92-12
.xc:W/ Attachment S.D.
Ebneter Regional Administrator, Region II
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i CATAWBA NUCLEAR STATION REPLY TO NOTICE OF VIOLATION 50-413 AND 50-414/92-12-01 AND 92-12-02 The following 2 violations were identified during an inspection on April 13-16, 1992.
Violation A:
10 CFR Part 73.71 and 10 CFR 73, Appendix G, II, require, in part, "Any failure, degradation or discovered vulnerability in a safeguards system that could have allowed unauthorized or undetected access to a Vital area had compensatory measures not been established," to be recorded within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and submitted in quarterly logs.
10 CFR 73.55(b) (3) (i) requires written security procedures be implemented.
The licensee's Nuclear Generation Department Directive No.
3.7.1 (S) " Reporting and Trending of Safeguards and Security Events" (Revision No. 3 dated January 1, 1992) states, in Paragraph 1.0 Purnose, "The purpose of this directive is to describe the safeguards reportability requirements of 10 CFR 73.71..." and requires, in Paragraph 5.1.2,
" Events Reported in Quarterly Log... any failure or degradation of a security system or discovered vulnerability in a system that could have allowed unauthorized or undetected access to the vital area shall be reported in the safeguards event log".
The Directive goes on to give an example of a loggable event as a vital area door found unlocked (Enclosure 2, page 20).
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J Page 2 50-413 and 414/92-12 Reply Contrary to the above, the licencoe has not been reporting in its quarterly logs the failure or degradation of its security system, in that, events of vital area doors being found in the unlocked condition are not logged.
This is a Security Level lv violation (Supplement III).
Reason for the Viqlation:
The reason for the violation is one of interpretation.
Catawba has never considered a controlled access door or alarm door found to be unlocked, subsequent to a security officer's response to an alarm, an event requiring a Safeguards Event Log entry.
In every case when an alarm is received, associated with an unlocked door, a security officer was dispatched.
The officer ensures no forceable entry had occurred, assessed the area for unauthorized personnel, ensured the door was secure and cleared the alarm.
Catawba security management considered this action as a normal and proper part of alarm response and logging the door status as a degradation or vulnerability was not considered to be within the scope or purpose of the Event Log entries.
Alarm occurrences in which the alarm could not be cleared or the door would not relock, would be considered a failure or i
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Page 6 50-413 and 414/92-12 Reply Corrective Actions Taken and Results Achieved:
As an immediate corrective action Catawba Security amended a copy of NGD Directive 3.7.1 (S) requiring that events, such as those included in the Notice of Violation, be recorded in the Safeguards Event Log at Catawba.
This amended copy of_the directive was placed in the CAS and 1
the Security Shift Supervisors instructed in its use.
Because this Directive is a departmental directive, copies of the changes to the directive were sent to McGuire and Oconee-Security and Licensing Services at the General Office.
All' parties were made aware of the inspection results.
Corrective Actions Taken to Avoid Further Violations:
Based upon guidance and recommendations received during the June 5, 1992 meeting at Region II offices, Atlanta, GA, the Nuclear Generation Department Directive 3.7.1 (S) will be reviewed and revised.
The revised directive will incorporate logging requirements based'on the guidance received in reference to the interpretation of Appendix G II (b) as it pertains to deviations from Security plan commitments.
Date of Full Compliance:
The-NGD Directive will be revised and implemented by August 1,
1992.
Page 4 50-413 and 414/92-12 Rep 3y Violation B:
10 CFR Part 73.71, Appendix G, II (b) states, in part,
" Events to be... submitted in Quarterly Log... Any other committed act not previously defined with the potential for reducing the effectivenrss of the safeguards sy' v that committed to in a licensed physical
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.he above, Department Directive 3.7.1 (S), as le
.bove in Violation A, is inadequate in that it exempts the licensee from submitting in its quarterly logs those regulatory failures which reduce the effectiveness of the safeguards system below that committed to in its Plans with respect to failing to test communications equipment, failing to qualify officers, failure to medically test officers and failure of alarm stations.
These regulatory failures had the potential for reducing overall effectiveness of the security program.
This is a Severity Level IV violation (Supplement III).
E_eason for the violation:
The reason for the violation was based upon Duke Power Company's interpretation of 10 CFR 73.71 Appendix G II (b) which states "Any other threatened attempted or committed act not previously defined in Appendix C with the potential for reducing the effectiveness of the safeguards system l
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below that committed to a licensed physical security or contingency. plan or the actual condition of such reduction in effectiveness."
Duke Power Company's interpretation of events referenced-in section II -(b) was that these events must be precipitated by a deliberate act or reduce the effectiveness of the safeguards system below that committed to in the security plan such that unauthorized or undetected access could be allowed.
This interpretation was the rationale from which the Nuclear Generation Department (NGD) 3.7.1 (S) directive for reporting security' events was based.
The majority of events listed in the Notice of Violation were not considered deliberate acts or events which reduced the effectiveness of the safeguards system but rather as administrative errors or omissions.
These would include the failure to test communication equipment, failure to qualify officers and the failure to medically test officers.
The remaining item, failure of alarm stations, was not considered an event that significantly decreased the effectiveness of the safeguards system due to having a backup alarm station which would receive and assess all i
alarms.
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Page 3 50-413 and 414/92-12 Reply degradation which would warrant compensatory measures and subsequently be recorded in the Safeguards Event Log.
In addition, any other condition involving the failure or malfunction of a door, or-the component of a door, which could have allowed unauthorized or undetected access would have been recorded in the Safeguards Event Log.
Corrective Actions Taken:
On April 16, 1992 instructions were given to all Security Shift Supervisors to immediately begin recording, in the Safeguards Event Log, doors discovered to be unlocked as a result of alarm response.
Subsequent reviews of the Safeguards Event Log verified these type of events are being logged.
Corrective Actions Taken to Avoid Further Violations:
1 The corrective actions taken should avoid further i
violations.
i-Date of Full Compliance 1 Catawba was in full compliance on-April 16, 1992.
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