ML20132G490
| ML20132G490 | |
| Person / Time | |
|---|---|
| Site: | Peach Bottom, Limerick  |
| Issue date: | 12/20/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20132G468 | List: |
| References | |
| 50-277-96-11, 50-278-96-11, 50-352-96-11, 50-353-96-11, NUDOCS 9612260269 | |
| Download: ML20132G490 (6) | |
See also: IR 05000277/1996011
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U. S. NUCLEAR REGULATORY COMMISSION
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REGION l
Docket Nos:
50-277, 50-278, 50-352, 50-353
License Nos:
DPR-44, DPR-56, NPF-39, NPF-85
Report Nos:
50-277/96-11, 50-278/96-11, 50-352-96-08,50-353-96-08
Licensee:
PECO Nuclear
Facilities:
Peach Bottom Atomic Power Station
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Limerick Generating Station
PECO Nuclear Chesterbrook Engineering Information
Center
' Dates:
October 3-November 27,1996
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inspectors:
Gregory C. Smith, Sr. Security Specialist
Nancy T. McNamara, Emergency Preparedness Specialist
Approved by:
Richard R. Keimig, Chief, Emergency Preparedness and
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Safeguards Branch
Division of Reactor Safety
9612260269 961220
ADOCK 05000277
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EXECUTIVE SUMMARY
Peach Bottom Atomic Power Station
Limerick Generating Station
NRC Inspection Report No. 50-277/96-11, 50-278/96-11,
50-352-96-08 and 50-353/96-08
On June 26,1997, the licensee identified that documents containing Safeguards
Information (SGl) were found to be uncontrolled in the Chesterbrook Engineering
information Center and initiated an investigation into the event on June 27,1996. The
scope of the investigation was expanded to include the adequacy of control of SGI at all
PECO facilities including the Limerick and Peach Bottom sites, as additional problems with
the control of SGI were identified. The investigation also included control of SGI that had
originated at PECO but was in the possession of vendors and contractors. The licensee
concluded its investigation on September 9,1996. The investigation found that
approximately 150 documents, primarily consisting of aperture cards, containing SGI had
been stored in an uncontrolled manner at five locations for periods up to about eight years
due to organizational changes, unclear roles and a lack of assigned responsibility for the
program. However, it was determined by the licensee that the uncontrolled SGI did not
constitute the potential to significantly assist an individual in an act of radiological
sabotage.
During the inspection, the NRC monitored the licensee's review and investigation progress
through frequent telephone contacts and meetings. On August 5,1996, during a meeting
at the Chesterbrook information Center, the NRC reviewed the investigation findings to
that point and its short-term corrective actions. On October 3,1996, the NRC initiated an
inspection to review the adequacy of the investigation, the findings and corrective actions
planned and already implemented. The inspectors determined that: (1) the licensee's
investigation was thorough and comprehensive in scope; (2) that as uncontrolled SGI was
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identified, the licensee took positive actions to control the information; (3) the completed
corrective actions were adequate and fully implemented; and (4) long term corrective
actions for later implementation were appropriate. The, inspectors' review of the SGI
documents that were uncontrolled confirmed that the information contained therein would
not have significantly assisted an individual in an act of radiological sabotage. However,
the number of uncontrolled documents, the various locations and the duration that those
documents remained uncontrolled ano accessible to unauthorized persons constitute a
programmatic breakdown in the protection of SGI in accordance with the requirements of
10 CFR 73.21. This was identified as an apparent violation.
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Report Details
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Miscellaneous Security and Safeguards issues
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General
On July 2,1996, the licensee notified the NRC that on June 26,1996, safeguard
information (SGI) was found to be uncontrolled and accessible to unauthorized
personnel at the Chesterbrook Engineering Information Center. The licensee initiated
an investigation into the event on June 27,1996. As additional problems with the
control of SGI were identified during the investigation, the scope of the investigation
was expanded to include the adequacy of control of SGI at all PECO facilities and
vendors who performed security-related work.
The NRC monitored the progress and developments of the investigation through
frequent telephone contacts and meetings with various licensee representatives.
On August 5,1996, an inspector reviewed the licensee's investigation findings up
to that point and short-term corrective actions at a meeting at the Chesterbrook
information Center. The licensee concluded its investigation on
September 9,1996, and, on October 3,1996, the NRC initiated an inspection to
review the adequacy and findings of the investigation and to review completed
corrective actions and those actions still planned for implementation. The NRC
inspection was completed on November 27,1996.
a.
insoection Scone (81810)
The inspectors reviewed documentation of the licensee's investigation,
procedures, and copies of potentially compromised SGl, and interviewed
personnel to assess the adequacy and completeness of the licensee's
investigation and evaluate the effectiveness of corrective actions in the
matter of control SGI at the licensee's facilities and at its vendors.
b.
Observations and Findinas
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The results of the licensee's investigation were documented in issue Evaluation
Report 10005855, dated October 17,1996. The inspectors' review of the
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licensee's evaluation report disclosed that the investigation team comprised
personnel with quality assurance, engineering, root cause analyses, and security
expertise. The inspectors determined that the investigation was very
comprehensive, thorough and self-critical. The licensee was particularly proactive in
reviewing the initial findings and expanded the scope of the review to include the
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adequacy of control of all SGl at PECO facilities and vendors when indications of
additional potential problems were identified and that the licensee took positive
actions to control any SGI that was identified as being uncontrolled. The scope of
the licensee's investigation included interviews with contractors, visits to vendor
offices, and the review of corporate and site (Peach Bottom and Limerick) files,
films, drawings, training and safeguards procedures. The licensee identified 150
findings and initiated 122 action items that were entered into the licensee's tracking
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system. At the end of this inspection, 75 of the 122 action items, had been closed.
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All the action items were given the highest priority level (Category l} that required
evaluation and approval by senior management and review boards.
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The findings of the licensee's investigation included the following:
Approximately 150 documents (primarily aperture cards of equipment
drawings, but also including film cartridges and hard copies of drawing
change information) containing SGI had been stored uncontrolled and
accessible to unauthorized personnel at 5 different locations for periods of up
to approximately 8 years.
Uncontrolled aperture cards marked SGI were identified as being stored at
the PECO Chesterbrook office.
Uncontrolled aperture cards marked SGI were identified as being stored at
the Plymouth Service Building.
The uncontrolled aperture cards that were stored at the Plymouth Service
Building had been moved to that location in June 1996, from the PECO main
office in Philadelphia where they had also been stored in an uncontrolled
manner.
Film cartridges that contained SGI, but were not marked as such, were being
stored at the Chesterbrook and Limerick facilities in an uncontrolled manner.
Uncontrolled drawing change paper, microfilm and modification information
containing SGI were identified at the Peach Bottom facility.
Six vendors were identified that processed SGl. Of the six that processed
SGI, two vendors were found to still have SGI in their possession. The
responsibilities for handling and storing SGI were reviewed with these
vendors by the licensee.
The breakdown in the process to control SGI properly began approximately 8
years ago and went undetected by the licensee as a result of organizational
changes, unclear rolls and a lack of assigned responsibility for the program.
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It appeared to the inspectors that when nuclear management was moved from the
licensee's corporate headquarters in Philadelphia, PA to the PECO Nuclear
headquarters (Chesterbrook), Wayne, PA, control of SGI was relegated to the Peach
Bottom and Limerick Nuclear Station security managers for site-specific control.
The SGI under the control of the corporate security function was overlooked as no
one was assigned responsibility for it.
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Some of the licensee's planned corrective actions were: (1) training for
handling SGI will be provided on a annual basir.; (2) the process for handling
and distributing SGI will be stand::rdized between Limerick, Peach Bottom
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and PECO corporate offices; (3) a review of all common security procedures
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by an independent contractor vdll be conducted for compliance to
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regulation , and (4) future venco* contracts willinclude a statement
escribing the vendor's responsitilities for handling controlling and storing
SGl, Additionally, until all corrective actions have been implemented, all SGI
processing will be done by only one individual and any information that
potentially contains SGI will be reviewed and distributed with supervisory
sign-off and approval.
The evaluation report also addressed corrective actions that included the
revision of Procedure SEC.C-4, Rev. 2, " Control of Safeguards Information".
The inspectors reviewed a copy and determined that the procedure was very
detailed regarding the responsibilities and handling of SGI and addressed
findings from the investigation report. The procedum also described a new
position titled Safeguards Administrator. This positi.)n has been filled with a
knowledgeable individual who will be dedicated tc the safeguards
information program and will be responsible fo: providing safeguards training,
conducting periodic audits of storage locatior.s, performing self-assessments
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and recommending any necessary programmatic changes. The inspectors
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considered th;s to be a good initiative to strengthen the oversight for the SGI
prop, ram.
The inspectors interviewed the security system engineers from Limerick and
Peach Bottom who had reviewed the potentially compromised SGI and made
the determinations that the uncontrolled SGI would not significantly
contribute to an act of radiological sabotage. The engineers stated that they
used the criteria described in 10 CFR 73.21 and guidance from NUREG-0794
- Protection of Unclassified Safeguards Information, dated August 1981 for
making these determinations. The inspectors reviewed 120 of the SGI
aperture cards to independently evaluate whether the information would
significantly contribute to an act of radiological sabotage.
c.
Conclusion
The inspectors determined that the licensee identified the failure to control
SGl, took prompt and comprehensive actions to investigate the problems,
and developed and implemented an effective corrective action plan. The
inspectors concurred with the licensee in the determination that the
uncontrolled SGI would not have significantly contributed to an act of
radiological sabotage. However, the number of uncontrolled documents at
the various locations and the duration that those documents remained
uncontrolled and accessible to unauthorized persons constitute a
programmatic breakdown in the protection of SGI and is contrary to the NRC
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requirements contained in 10 CFR 73.21. This is an apparent violation.
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PARTIAL LIST OF PERSONS CONTACTED
PECo Nuclear
D. Meyers, Director Site Support , Peach Bottom Atomic Power Station (PBAPS)
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R. Kinard, Manager, Security and EP, PBAPS
A. S. MacAinsh, Manager Support Services
P. Supplee, Supervisor Protection Services
H. Owrutsky, System Engineer, PBAPS
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J. Spenelli, System Engineer, Limerick Generating Station (LGS)
M. Karney, Manager, Security and EP, LGS
NRC
N. Perry, Sr. Resident inspector, LGS
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