ML20134E755
Text
_.
January 31, 1989 AMENDMENT Docket No. 55-20551 Mr. Jimm P. Coh.
__7
.-.a Pursuant to the Atomic Energy Act of 1954, as amended, the Energy Reo Act of 1974 (Public Law 93-438), and subject to the conditions and limitatio incorporated herein, the Nuclear Regulatory Commis controls of the Georgia Power Company, Vogtle Electric Generating Plant Hos. I and 2, Facility Docket Hos. 50-424 and 425.
55-20551. The effective Your t.icense No. is SOP-20461-1 and your Docket No. isamended effective the date o 16, 1988, date of your license is Septemberletter, and unless sooner terminated
)
September 16, 1994.
Your license is subject to the provisions of Title 1 as if fully set forth herein.
While perfoming licensed duties, you shall observe the operating procedures and other conditions specified in the facility license.
The issuance of this license is based.upon examination of your qualifications, including the representations and information contained in your application for this license.
A copy of your license has been made available to your management.
FOR THE NUCLEAR REGULATORY COMMISSION (original signed by C. A. Julian)
Caudie A. Julian, Chief Operations Branch Division of Reactor Safety cc: Georgia Power Company wwmation in this record was deleted ATTH: Supt. Nuclear Trainin9 in accordance with the freedom of Information Vogtle Electric Generating Plant Act, exemptions 6
P. O. Box 1600 F01A. 8 Y ? #
Waynesboro,GA 30830 RII R'!!
RII R
/
CAJulian Sk JA idsen p /p/89
//J//89 unro e
01/27/89 ei y/89
/-
g 10 g 1 960827 KOHN95-211 PDR
i ENFORCEMENT
- AND INVESTISATION COORDINATION STAFF 1
REGION II
\\
l R_EFERENCE PACKAGE EA ve-2.2 9 i
VOG TL E ELECTRIC GENERATING PL. AN T Information in this record was deleted in accordance with thye F eedom of Information Act, exemptions _ >
F0IA._fl_7-//__
0 v
I 4
REFERENCE DOCUMENT CHECKLIST REGION II ENFORCEMENT AND INVESTIGATIONS COORDINATION STAFF ENCIOSURES EA 90-129 GEORGIA POWER COMPANY VOGTLE ELECTRIC GENERATING PLANT
[_!_) Documentation Quality Control Checklist
[b]NRCInspectionReportorotherdocumentationofthefactsof 50-424,42Sl90-f fSEE Also MUEEG-84to)
[ 3_] Licensee Event Report or other deficiency reporte
[_ ] Applicable Tech Specs along with bases
[_] Applicable license conditions
[_] Applicable licensee procedures or extracts
[_] Copy of discrepant licensee documentation referred to in citations such as NCR. inspection record, or test results
[_] Extracts of pertinent FSAR' or Updated FSAR sections for citations involving 10 CFR 50.59 or systems operability
[_] Enforcement conference briefing packages
[I] Enforcement conference summaries and handouts
[ __ ] Referenced ORDERS or Confirmation of Action Letters
[k] Most current SALP report summary page and applicable report sections
(_] Other miscellaneous documents A.
B.
C.
ENFORCEMENT COORDINATOR:
BRUNO URYC, Jr.
(FTS 841-4192)
t i
I I
\\
t l
1 I
I l
r l
l REFERENCE PACKAGE R1 EA NO.90-129 RII NO.
RII-90 K-0; I
ENCIDSURE NO.
i I
t
(-.___.
4 6
ENFORCEMENT AND INVESTIGATION COORDINATION STAFF REGION II REFERENCE PACKAGE EA 90-188 GEORGIA POWER COMPANY VOGTLE ELECTRIC GENERATING PLANT Information in this record was deleted m accordance with theJreedom of Information Act, exem3 tion) -
F0lA-
'/', -- Z //
/
i
)
_ REFERENCE DOCUMENT CfTCKLIST REGION II ENFORCEMENT AND INVESTIGATIONS COORDINATION STA ENCIDSURES EA 90-188 GEORGIA POWER OOMPANY VOGTLE ELECTRIC GENERATING PLANT
[1]
Documentation Quality Control Checklist
[2]
NRC Inspection Report or other documentation of the facts of the case: 50-424,425/90-27
[3]
Licensee Event Report or other deficiency reports A) 90-03S-01, B) 90-07S-00, C) 90-085-00
[ ]
Applicable Tech Specs along with bases
[ ]
Applicable license conditions
[ ]
Applicable licensee procedures or extracts
[ ]
Copy of discrepant licensee documentation referred to in citations such as NCR, inspection record, or test results
[ ]
Extracts of pertinent FSAR or Updated FSAR sections for citations involving 10 CFR 50.59 or systems operability
[ ]
Enforcement conference briefing packages
[4]
Enforcement conference summaries and handouts
[5]
Referenced ORDERS or Confirmation of Action Letters
[ ]
Host current SALP report summary page and applicable sections report
[6]
Other miscellaneous documents: EA 90-090 W/ LICENSEE RESPONSE ENFORCEMENT OOORDINATOR:
BRUNO URYC, Jr.
(FTS 841-4192)
A i
)
l i
1
'1 i
4 4
i, i
1 l
f I
j i
i 5
l 4
i 8
i a
a 1
REFERIDiCE PACKAGE RII EA NO.90-188 RII NO.
RII-90-E-041 I
ENCIDSURE NO.
-18 m
1 l
1 l
l i
REFERENCE PACKAGE RII EA NO.99-188 RII NO.
RII-90-R-e41 INCIDSURE NO.
f ueHTED STATES l
p ee:g*g NUCLEAn nEGULATOnY COMMIS$10N l*
f RE08001 M j
-p"
}
g 101 MARIETTA STREEY.NN.
l ATLANTA, GEORGI A 30323 f
OCT &$ 1990 l
i l _
Docket Nos. 50-424, 50-425 License Nos. NPF-68, NPF-81 i
i j-Georgia Power Company ATTN: Mr. W. G. Hairston, !!!
Senior Vice President -
Nuclear Operations j
l P. 0. Box 1295 Biriningham, AL 35201 l
l l
Gentlemen:
i
SUBJECT:
NRC INSPECTION REPORT N05. 50-424/90-27 AND 50-425/90-27 d
l This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by i
A. Tillman on October 16-17, 1990.
The inspection included a review of l
activities authorized for your Plant Vogtle.
At the conclusion of the i
inspection, the findngs were discussed with those members of your staff identified in the enclosed Inspection Report.
I Areas examined during the inspection are identified in the report.
Within these areas, the inspection consisted of selective examinations of procedures i
and representative records, interviews with personnel, and obc.rvation of l
activities in progress.
The inspection findings indicate that certain activities appeared to violate NRC requirements. The apparent violation described in the enclosed Inspection Report is under consideration for escalated enforcement action. Accordingly,a Notice of Violation is not being issued at this time.
Please be advised that the characterization of the apparent violation described in the enclosed Inspection Report may change as a result of further NRC review.
An enforcement conference to discuss this apparent violation has been scheduled for November 13, 1990.
The purpose of this conference is to discuss the apparent violation, its cause and safety significance; to provide you the opportunity to point out any errors in our inspection report; to provide an opportunity for you to present your proposed corrective actions; and to discuss any infomation that will help us detemine the appropriate enforcement action in accordance with the Enforcement Policy.
You will be advised by separate correspondence of the results of our deliberations on this matter. No response regarding the apparent violation is required at this time.
In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
fjQQy
l 007 2 9 W 2
Georgia Power Company l
1 1
Should you have any questions concerning this letter, please contact us.
Sincerely.
J. Philip Stohr Director Division of Radiation Safety and Safeguards
Enclosure:
Inspection Report cc w/ enc 1:
R. P. Mcdonald Executive Vice President-Nuclear j
Operations Georgia Power Company t
P. O. Box 1295 Birmingham,AL 35201 C. K. McCoy Vice President-Nuclear l
Georgia Power Company P. O. Box 1295 Bimingham, AL 35201 W. B. Shipman General Manager - Nuclear Georgia Power Company P. O. 1600 Waynesboro, GA 30830 J. A. Bailey Manager-Licensing Georgia Power Company
)
P. O. Box 1295 Birmingham,AL 35201 D. Kirkland, III, Counsel Office of the Consumer's Utility Council Suite 225, 32 Peachtree Street, NE Atlanta, GA 30302 Office of Planning and Budget Room 6158 210 Washington Street, SW i
Atlanta, GA 30334 (cc w/ enc 1 cont'd - See page 3)
OCT s me Georgia Power Company 3
(cc w/enci cont'd)
Office of the County Comissioner Burke County Comission Waynesboro, GA 30830 l
Lonice Barrett, Commissioner
]
Department of Natural Resources 205 Butler Street, SE, Suite 1252 i
Atlanta, GA 30334 Thomas Hill, Manager Radioactive Materials Program Department of Natural Resources 878 Peachtree St., NE., Room 600 Atlanta, GA 30309 Attorney General 4
l Law Department
~
132 Judicial Building Atlanta, GA 30334 State of Georgia i
i o
l 3'
o unsTE3 STATES
[
nee NUCLEAR REGULATORY COMMISSION p
'g nEoion se f
101 MARIETTA STREET.NN.
g ATLANTA.GEoA01 A 30323 i
I i
Report Nos.: 50-424/90-27 and 50-425/90-27 i
)
Licensee: Georgia Power Company P.-0. Box 1295 i
Birmingham, AL 35201 1
Docket Nos.: 50-424 and 50-425 License Nos.: NPF-68 and CPPR-109 l
. Facility Name: Vogtle 1 and 2 1
i l
Inspection Co ted: October 16c17 1990 h)
'kt
)$l/1Al
/8f hd Inspector:
' Det 51 A.*T1 He3p, 5ggufNs 'IhIpectW Approved by:
N, N
[6 2/ 9p D.
L. McGuire. Chief Utte p gned i
Safeguards Section 4
l Nuclear Materials Safety and Safeguards Branch Division of Radiation Safety and Safeguards i
l SUMARY Scope:
This special announced inspection was conducted in the area of Physical Protection of Safeguards Information in response to a licensee-identified and reported Safeguards Event.
Results:
J In the area inspected, an apparent violation of regulatory requirements relating to the failure to provide adequate protection for safeguards material i
was confirmed.
s Inspection results revealed continuing problems in the licensee's Safeguards Information Program, both at the Vogtle site and corporate office in Birmingham, Alabama.
The extensive corrective actions implemented by the 4
licensee in response to previously cited violations concerning the protection of safeguards material have not been effective in precluding recurrence of similar violations.
This progransnatic problem continues to be attributable prirearily to personnel error and failure to adhere to procedural requirements.
l JWhUt*#
v 1
REPORT DETAILS 1
1.
Persons Contacted Licensee Employees
- H. Eeacher, Senior Engineer, Technical Support, Vogtle Electric and Generating Plant (VEGP)
- S. H. Chestnut Manager, Technical Support, VEGP
- C, L. Christiansen, Safety Audit and Engineering Department, VEGP
- E. M. Dannamiller, Manager, Nuclear Security, VEGP 2
- T. Greene, Assistant General Manager-Support, VEGP
- W. C. Guthie, Nuclear Security Specialist, VEGP
- K. Holmes, Manager, Training and Emergency Preparedness, VEGP
- D. G. Huyck, Supervisor, Security Operations, VEGP i
- W. F. Kitchens, Assistant General Manager-Operations, VEGP l
- R. M. Odom, Supervisor, Plant Engineering, VEGP
- P. M. O'Neil, Security Supervisor, VEGP
- W. 8. Shipman, General Manager - Nuclear, VEGP
- C. Stinespring, Manager, Plant Administration, VEGP
- T. Webb, Senior Engineer, VEGP Other licensee employees contacted during this inspection included engineers, security force members, and administrative personnel.
NRC Resident Inspectors
- B. R. Bonser, Senior Resident Inspector, VEGP
- P. A. Balmain, Resident Inspector, VEGP j
- R. D. Starkey, Resident Inspector, VEGP
- Attended exit interview 2.
Physical Protection of Safeguards Information (81810)
At approximately 10:40 a.m., October 11, 1990, the licensee notified the NRC Operations Center of the discovery of a file folder containing several security training lesson plans, three (3) of which were marked as safeguards information, on a desk in the Security Training Office located in the Field Support Building within the protected area.- It was further reported that the safeguards documents had been left unsecured and unattended. Review of the documents by security management concluded that two of the three documents identified as safeguards material actually contained safeguards information.
It was believed that the remaining document did not contain safeguards information.
As a result of the discovery of the unprotected safeguards material, the licensee initiated an inventory of the Security Training Office area to include file cabinets and desks. During the course of the inventory, an additional 74 documents
_ -. ~. -
h 2
i identified as safeguards information were discovered in a file cabinet within the training office.
Review by security management concluded that l
information contained in the additional 74 documents did not warrant safeguards classification or protection.
The discovery of the additional i
documents identified as safeguards was reported to Region !! via telephone j
by the licensee at 3:13 p.m., October 11, 1990.
16-17, 1990, an onsite review and evaluation During the period of October of the circumstances of the event was conducted by a Region II Safeguards Inspector.
Discussions with security management and interviews of l
personnel assigned to the Security Training Section, along with other j
personnel having knowledge of the event, revealed the following:
10, 1990, during the course of rearranging furniture in the l
On October Security Training Offices located in the Field Support Building within the l
protected area, a security training specialist observed a file folder on a j
desk within the office and attempted, without success, to establish i
ownership of the folder and its contents. Without reviewing the contents j
of the folder, it was left on the desk until approximately 8:30 a.m.,
j October 11, 1990, at which time another training specialist attempted to l
determine the owner of the file folder and contents, but none of the 4
l personnel' present in the Security Training Section acknowledged ownership or awareness of the disposition of the file folder. At that time, the i
l contents of the folder were reviewed and determined to consist of 11 l
security lesson plans, three of which were marked as safeguards i
The three lesson plans marked safeguards infomation, which information.
l were co-mingled with the non-safeguards lesson plans, were entitled:
" Task #2, Security Features," consisting of 10 pages; " Task #3, Site l
l Security Organization," consisting of six pages; and " Task #7, Conducting a patrol," consisting of six pagts.
Review rd the three lesson plans by l
security management personnel concluded that the lesson plans identified l
as Tasks #2 and f3 did, in fact, contain safeguards infomation.
It was l
further concluded that the Task #7 plan, although marked safeguards, did l
1 not contain any safeguards infomation.
As a result of the discovery of the unprotected safeguards material, which j
was inappropriately secured, the licensee initiated an inventory of the J
contents of the Security Training Offices to include desks, cabinets and storage containers.
During the course of the inventory, an additional 74 l
documents entitled " Training Job Task Analyses" and marked safeguards infomation were discovered in a file cabinet within the training office.
I Review of security management personnel detemined that the Job Task j
Analyses were developed as part of a Security Training Project that was i
discontinued in 1988. The documents were retained for possible future use and had been passed between various members of the security management and i
training functions.
Review by licensee security management personnel concluded that the documents did not contain safeguards information.
i Security personnel who had custody of the documents since their develop-l ment was discontinued, allegedly were made aware that the documents did i
e.-
t i
3 4
not contain safeguards information.
However, no apparent effort was made
~
to declassify the documents or secure them in accordance with their clas-
)
sification markings.
1 Interviews with-security management and training personnel and review of relevant documentation revealed that the file folder containing safeguards material discovered on October 11, 1990, was one of five folders containing similar material that were routinely maintained in Safeguards l
Container "C" within the security administrative area.
Inventory records reflected that all five folders were accounted for during an inventory of l
the safeguards container on July 13, 1990. Accountability records for the i
container did not reflect that the folder and contents in question had i
i been signed out since the July 13, 1990 inventory. Four security training
{
i personnel and the security specialist responsible for changing security J
i locks, keys, and combinations were the only personnel with access to the 1
safeguards container.
The combination to the container was changed October 2,1990, following reassignment of the former Security Training i
Coordinator on September 18, 1990.
l Security management personnel and the four security training specialists, all of whom had access to the safeguards container, denied having any l
knowledge as to when or by whom the folder containing the safeguards l
was removed from the safeguards container and subsequently left materia unattended and unprotected within the training office.
Two of the training specialists expressed the view that the folder had been removed l
from the container by someone having access for some work-related purpose and failed to return it or secure it. Two of the training specialists had i
been away from the training office for several days prior to the week of 8-12, 1990.
There was no evidence of any training related October j
activity during the period following the inventory of the safeguards container on July 13, 1990, that would have involved or necessitated use of the safeguards material in question.
Based on the foregoing, the j
i period of tune in which the safeguards documents remained unsecured and unattended could not be established. It was determined that access to the training office in which the material was discovered during non-regular l-l hours required access through two locked doors, each of which contained a large glass window.
Authorized personnel were routinely present in the training office area during duty hours.
y l
Review of licensee Safeguards Event Reports and Quarterly Log for 30, 1990, revealed the occurrence of an additional July 1-September i
licensee-identified and reported event relating to the failure to provide adequate protection for safeguards information in accordance with regulatory and procedural requirements.
On August 29, 1990, a safeguards container was found unsecured and unattended in the Southern Company Services, Inc. Vogtle Project Engineering Support Office document file room, Birmingham, Alabama, for a j
period of time exceeding one hour. Entry to the area where the safeguards i
i-4 1
i i'
i container was located was reportedly secured for all but approximately 10 j.
minutes of the time that the container was open and unattended.
During j
the' remaining 10-minute period, the area was occupied by an employee who was properly cleared, but had not been granted access authorization to
)
safeguards information. The unsecured safeguards container was discovered at 12:50 COT, August 29, 1990, and was telephonically reported to the NRC l
Operations Center at 3:13 CDT that date.
The Security Incident Report of l
the event prepared by the Vogtle security staff, dated August 31, 1990, and the subsequent Licensee Event Report, LER 90-075, dated September 25, j
1990, did not include an inventory or identify specific safeguards documents contained in the safeguards container. However, the reports did reflect that an immediate audit of the container contents determined that no safeguards documents were missing.
The LER did note that the Vogtle Project Corporate Office Manager of Licensing reviewed the document j
control logs and inspected the contents of the container and deemed the contents of the unsecured and unattended ufeguards information container l
as significant relative to assisting a person in undetected or i
unauthorized access to a vital or protected area.
The Security Incident i
Report of the event, transmitted telephonically to the NRC Operations j
Center, described the event as an unsecured safeguards container that had l
significant design documents enclosed.
On October 17, 1990, the licensee notified Region II of the discovery at 5:30 p.m., October 16, 1990, of two outdated elementary drawings of the Vogtle Security Power Supply System and the Vogtle emergency diesel l
i generator that were determined to contain safeguards information and were not appropriately marked or secured.
The drawings were discovered in a j
stick file located in the Southern Company Services, Inc. Vogtle Project Engineering Support Office, Birmingham, Alabama.
Review by the licensee concluded that the safeguards material contained on the drawings was not significant and the event was logged on the Vogtle Quarterly Safeguards i
l Event Log.
i On October 22, 1990, the licensee telephonically reported to Region II the discovery of four documents identified as safeguards information in a desk j
4 in the Security Training Office.
The safeguards material was discovered j
by corporate investigators engaged in an investigation of the Safeguards Event of October 11, 1990.
The discovered material consisted of one security job task analysis, similar to those previously discovered, and three security drill scenarios, none of which had reportedly been used for i
training purposes. Review of the material by licensee security management i
personnel concluded that the documents did not contain safeguards information.
t j
Subsequent review, by Region II security management, of randomly selected l
copies of the security job tasks analyses discovered in the Security Training Office by licensee personnel on October 11, 1990, resulted in agreement with the licensee's conclusion that the security job task
h 5
l l
i analyses did not contain safeguards information and were inappropriately 4
marked.
i In response to previously' cited violations for failure to adequately j
control and protect safeguards infomation, two of which were significant and resulted in civil penalties that occurred in October 1989 and j
April 1990, extensive corrective actions were implemented by the licensee, i
including the following:
Additional training for personnel responsible for controlling l
safeguards material.
Limiting the number of personnel with access to safeguards information.
l Inventory of safeguards containers and establishing access logs.
1 Review and disposition of archived security records.
)
Reduction of offsite safeguards containers maintained by licensee j
i I
contractors.
Revision of Safeguards Information Control Procedure to incorporate Letter of Instruction for proper handling of safeguards documents to i
be used with each safeguards docisment.
Handling and control of safeguards material incorporated into General Employee Training.
Individually addressed letters to employees requiring l
refamiliarization with safeguards document control procedures and certification in writing by employees of a search and return of any safeguards documents found at home or in working files that were i
i uncontrolled.
l Special emphasis on safeguards information control in annual audits by the Vogtle Project Safety Audit and Engineering Review Department.
As a result of the corrective actions implemented, several unsecured and, in some instances, improperly marked safeguards documents were identified l
or located and returned to appropriate control or secured. These results l
were documented in Licensee Event Reports dated May 25, 1990, and August 22, 1990. However, the corrective actions to date have failed to correct the continuing progrannatic problem and preclude the recurrence of The i
violations concerning the protection of safeguards information.
l violations discussed in this report occurred after the licensee's date of commitment for completion of corrective actions in the related area, or were not associated with any ongoing corrective action for previously i
cited violations.
i
.~
3 l.
6 4
1 i
that safeguards infonnation be 10 CFR 73.21(a) requires, in part, protected against unauthorized disclosure.
/
10 CFR 73.21(d)(2) requires, in part, that while unattended, safeguards i
j infonnation shall be stored in a locked security storage container.
t The licensee's Administrative ~ Procedure No. 00650-C. Safeguards Information Control Figure 4 i.etter of Instruction, specifies that when not in use, safeguards information shall be stored in a steel cabinet with j
a locking bar and a U. S. General Services Administration (GSA) approved padlock or in a GSA approved security container.
Failure to properly secure safeguards material is an apparent violation of regulatory requirements and the licensee's Administr l
j relating to the protection and control of safeguards information as50-i described in Inspection Report Nos.which resulted in the assessment of civil j
50-424/90-11 and 50-425/90-11, penalties in the amounts of $7,500 and $50,000, respectively (50-42 and50-425/90-27).
3.
Exit Interview j
17, 1990, with The inspection scope and results were summarized on October The inspector described the areas those persons indicated in paragraph 1.
inspected and discussed in detail the inspection results listed below.
Dissenting conments were not received from the licensee.
The licensee was informed that an apparent violation of regulatory l
requirements relating to unsecured and unattended safeguards materia It was noted that identified and reported by the licensee, was confirmed.
the violation was repetitive and similar in nature to previous violations cited for failure to adequately protect safeguards inf i
reported events relating to inadequate protection fo l
The licensee was further infonned that results of the inspection would be subjected to review by Region !! management for assessment of severity categorization, and the licensee would be appropriately informed.
I a
d j
v.-
4 REFERENCE PACKAGE.HI!
RII-90-K.e4:
ENCwsonE NO. 5A_.
Geces a po*e* C:~:a..
333 P esmeer A.ese A::aata Geor;a 30308 Teieceoae aca $26 3595 Malag Accress a0 inveraess Cenie' Parmaav Pos O:e Boa 1295 i
8.em.egeam Aianama 35201 Te eoacae 205 868 558' l
August 22, 1990 W. G. Heirsten. HI Sen.of V ce Ptes oe-:
Nuceear Oce*a* cas ELV-02022 0552 Docket No.
50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C.
20555 Gentlemen:
V0GTLE ELECTRIC GENERATING PLANT LICENSEE EVENT REPORT APPARENT PERSONNEL ERROR LEADS TO UNSECURED SAFEGUARDS INFORMATION l
In accordance with 10 CFR 73.71, Georgia Power Company hereby submits the enclosed revised report for an event which occurred on April 25, 1990.
This revision is submitted to report the results of corrective action taken to avoid future safeguards information control incidences and to report two events which occurred prior to the original reported event, but were not discovered until the corrective action for the April 25, 1990, event was initiated.
Sincerely, t.1}.
lb W
W. G. Hairston, III WGH,III/AFS/gm
Enclosure:
LER 50-424/1990-035-1 xc: Georcia Power Comoany Mr. C. K. McCoy Mr. G. Bockhold, Jr.
Mr. R. M. Odon Mr. P. D. Rushton NORMS U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. T. A. Reed, Licensing Project Manager, NRR Mr.B.R.ponser,SeniorResidentInspector,Vogtle P
40Satcw%K
l J
u..uct....e ov6 to.v co s o.
e o.. se.
Y to co et, we. v e asta..t.o ev.o.. e..
EZ."",'iU8.'o'.'EEw".c"N.s','I ".*voE.'. ""ofei LICENSEk EVENT REPORT (LER)
O!,"d'?.".'.' "o'3*.!"o'*.*:.'. "*" a'.'
?. "f.M ?"
- ,?.Z'a
- O ".'o* ;'r':Is.*'JJa"A.a".'"
J oo....
V0GTLE ELECTRIC GENERATING PLANT - UNIT 1 ei,ioieioi4 i 2,4 i jo,j o i 7
,,<,,..n, APPARENT PERSONNEL ERROR LEADS TO UNSECURED SAFEGUARDS INFORMATION fit L. s.e 1
o,
.,=,6.v.u o6.....
o.n r.n,,,
..cmv....=
ooc..v - -...
am;; -
=
o.,
VEGP - UNIT 2 o is to ioiei 4: 2,5 4;
1 l
0%
2l5 9 0 9l0 0l 3 l S 0 l1 iO ]8 2l2 9l0 e isio ic i o, i i
.- on t.o poet
?-rt.. eu u t to v
.nou......vu oe w ce. t,c.=e
...= -
x n,..
i op.uve m,m.=,.
'== a' 1
m m.
j m.,m.=,
rui n
.o.
am n,
g B3 m
in...
um =>
u rm.=,.->
1 g.yj,g j
n.,
i i
=,=....
mm, in.
n==
n
.n.
.,=u.,
. m.
n..
APPENDIX G 1
m
..n.
m.,m.=n.,
a n mi...
L.C.
. Co f.cf 70. T.
L.. H.,
Tl6;_ _;.. u g.
j
..a
.... Coo.
i i i 6, i3 2,0 l R. M. 000M, NUCLEAR SAFETY AND COMPLIANCE 404 B2 i
i
.o
... o
, o..
-.. <o.. --.......o., o.,
t C.u
. v.T..
Co po
.?
"$$', c
$8 4
C R$
.jg.
l C.v.,
.v.t..
Co po
..t
"$y I
I I I I I I I
i 1 #
I I I 4
i I
I i !
1 I I I
I I I I I I
.....o.....o.,
l
- tm":"
j i...,,,
. _. m cr,..
- o. u n, rl
..,_=,o.,
.=v..c,,i l
On 4-25-90, at 0530 CDT, an engineering supervisor observed an unsecured and l
unattended safeguards cabinet in the Engineering Support Department office area.
This represented a vulnerability in a safeguards system which could have allo.ed l
undetected or unauthorized access to a protected or vital area.
Security was notified at 0535 CDT and an inventory was condur.ted which found no materials i
missing.
An investigation found that a security engineer was the last person known to Al'. hough the engineer feels that he locked the sve have entered the cabinet.
prior to his departure from the plant on the afternoon of 4-24-90, he cannot Oc Furthermore, the only other persons at the plant who knew the lock i
~
certain.
combination stated they had not accessed the cabinet since the previous weet l
Therefore, the apparent cause of this event is cognitive personnel error c
- e part of the engineer in not ensuring the cabinet was secured prier to his leaving it unattended. The engineer has been counseled regarding the impc" c of controlling safeguards documents.
i NfCH v i$ 7y,
.g.,.
..oco.. 0-.., x --
I-
. a..n l
UCENSEE EVENT REPORT (LER)
%'"..8f,.',,T,n" "'.W,, *?'l'.'A',",',",,l;'!
j TEXT CONTINUATION
- il"".'.".%"'.*,'"f *"?.N"**.".!!'c'"',,'!.'.' '".' "Sf2 08 MA '?.".J.E":'.".J8'.a'.*w."ll e?"L'"
- ta W"t" A0eest TA 00W000T eesse G70as, OC 20003
)
tCsket7 asaans all DOCati esueGS A tal LGA ammage 004 paes g3 v.ae
'80Wjd'6 Q'M
)
4
)
VEGP - UNIT 1 o ls ;o lo lo l 4l2 l 4 9l0 0l3l5 01 0l2 or 0 l:
1 J
runt
-me w am. nn 4
l A.
REQUIREMENT.FOR REPORT This report is required per 10 CFR 73.71 (b)(1) and 10 CFR 73 Appendix G, as i
a supplement to a one hour telephone notification.
Safeguards information being left unsecured and unattended represents a vulnerability in a l
safeguards system that could have allowed undetected or unauthorized access i
to a vital or protected area, k
f B.
UNIT STATUS AT TIME OF EVENT l
At the time of the discovery of this event, Unit I was in Mode 1 (power operation) at 83% rated thermal power (RTP). Unit 2 was in Mode 1 at 100%
RTP. There was no inoperable equipment which contributed to the occurrence l
of this event.
1 C.
DESCRIPTION OF EVENT i
On 4-25-90, at 0530 COT, an engineering supervisor observed an unsecured and j
unattended safeguards cabinet in the Engineering Support Department office area. Security was notified at 0535 CDT and an inventory was conducted j
which concluded no materials were missing. During the inventory, miscellaneous safeguards documents, design change packages, design lists and 1
an outdated copy of the Physical Security Plan were found in the cabinet.
The Shift Superintendent was advised and the NRC Operations Center was i
notified of this event at 0632 CDT.
i D.
CAUSE OF EVENT I.
i An investigation found that a Georgia Power Company security engineer was
)
{
the last person known to have entered the cabinet. The engineer was j
l thoroughly knowledgeable of requirements for securing safeguards documents and had recently viewed training on safeguards documents handling. Although t
the engineer feels that he locked the safe prior to his departure from the 4
1 plant on the afternoon of 4-24-90, he cannot be certain. Furthermore, the only other people at the plant who knew the lock combination stated they haa not accessed the cabinet since the previous week.
Therefore, the apparent cause of the event is cognitive personnel error on the part of the engineer j
in not ensuring the cabinet was secured prior to his leaving it unattended.
There were no other unusual characteristics of the work location which i
contributed to the occurrence of this event.
l l
E.
ANALYSIS OF EVENT P
l The unsecured safeguards cabinet was located inside the Protected Area and in the general area of the duty engineer's office. The duty engineer reported no unusual activity in this area during his shift which ended at i
approximately 0200 CDT on 4-25-90.
r 1
a.....our g,-
.a
- No".^,,'.',*,,*u"g".n", "'.'.;"t'/.,,,cy
,g,,.,,,v,g0".'.*,'#,*,'",*.g!,*llU'.Tc**,'!.
LICENSEE EVENT REPORT (LER) l TEXT CONTINUATION m",".,'.*e*.*.'T.8s0 0VDGer.w.esus.GTom. DC W..S 08 es.as.4easearr sec..,
vu... m 6..,,,
wr, a.a. ni a ta,.~.p.* 6
- ';.?,;;
s 0 (7 01 l 5 0l1 0 l3 3
or VEGP - UNIT 1 o ls lo lo lo 141214 9l0 var,,
e w am..,nn
'This information, combined with the undisturbed and fully accounted for nature of the cabinet's contents, provides a degree of confidence that no information was obtained which would allow an unauthorized or undetected entry to a protected or vital area. Furthermore, the security system is designed with alarms and tamper controls which would make unauthorized or undetected access, based on the information available from the cabinet's contents, highly unlikely. Due to these considerations, there was no ativerse impact on plant safety or the health and safety of the public as a result of this event.
F.
CORRECTIVE ACTIONS
- 1. The engineer has been counseled regarding the importance of controlling safeguards documents.
- 2. All safeguards documents found in the cabinet were inventoried, accounted for and returned to Document Control.
- 3. The practice of allowing individual work groups to utilize their own safeguards cabinets (except those in the custody of the Security and Quality Assurance departments) has been discontinued and safeguards documents relocated to a central area in Document Control.
- 4. The feasibility of establishing a safeguards document reading room was evaluated, and the idea will not be pursued at this time.
- 5. Individually addressed letters were sent out requiring a refamiliarization with~ safeguards document control procedures and a certification in writing by employees of a search and return of any l
safeguards documents found at home or in working files which were uncontrolled.
This search by VEGP site and Corporate Office personnel resulted in individuals returning four marked safeguards documents and some unmarked security documents to Document Control for their proper classification and disposition.
These documents consisted of portions of sections of the draft Security Plan, draft Licensee Event Reports, an outdated Security Diesel Generator Loading Calculation, interim boundary requirements memo, Security System component vendor data, generic barrier design criteria, Security System design and construction meeting minutes, acceptance tests, and operational deficiency data.
i i
F
....m.
i
.....m.,
UCENSEE EVENT REPORT (LER)
"N20##"c*oE#,"o"'.U v".#""#,*o'." '."lo' j
TEXT CONTINUATION I "o"#.Z"E='f"T.U"8'.".If.c7'.'l# '"'l'EU Of",Y.'..".7.!lF7.'".Ja'#a"ll'#;,%:"3 'J!a
.,s......,
t=,,;;
ag,e,y 0l7 j
VEGP \\ UNIT 1 o is lo j o j o l4 l 2l4 9l 0 0l1 0 1 4 or 0 ]3 l 5
,en n a.e -,,,m From a review of the subject documents returned, four 1982 i
documents were identified as be'.ng marked safeguards information and had been uncontrolled and unsecured in the j
Corporate Office Engineering and Licensing file room. Of these four marked safeguards documents, only one memo 1
t!tled, " Security Officer Response Time and Probability of interception," was deemed significant. The other documents were determined to be cutdated, or inaccurate with respect to the current security system configuration.
j Ten other documents not marked as safeguards information were reviewed for their proper classification and three j
documents were given the safeguards classification.
These j
three unmarked security documents, which were later classified, consisted of two portions of sections of the i
draft Security Plan and, mean time between failure and mean time to repair data for Security system components.
Although these early 1980's documents were classified safeguards, they were not deemed to be of significance in assisting a person in an act of radiological sabotage or theft of SNM, but could reduce the total effectiveness of the safeguards system below that consnitted to in our Physical Security and Contingency Plan. Therefore, the j
discovery of these newly classified documents will be added
{
to the quarterly security event log.
G. The VEGP Safety Audit and Engineering Review (SAER) Department was j
instructed by management to place special emphasis on safeguards i
information control in their annual audits.
i As a result of this increased emphasis, a recent SAER l
annual audit conducted from July 16-20, 1990, of Southern Company Services (SCS) Inc., one of the Architect / Engineer i
Design Organizations utilized by the licensee, discovered possible programmatic problems with safeguards information control and reportability. The audit revealed inventory log problems and an unsecured safeguards information container incident lasting approximately 25 to 50 minutes on November 29, 1989, which had not been reported to the licensee for reportability due to a lack of procedural
- guidance, i
r
)
i
i j-ur.uct.aa K.sutatonv coa eassa.
,,,,,,,,,,,,,,,3,,,g,,,
c,o.esassa UCENSEE EVENT REPORT (LER) f.Q. '.'!,*c'.f"SE.E"o"'E5'!',/ *NA',*o'.".'.".'s E!.o"s",EU'=""E E"8'eUcO'E'o' '".' "'lNf2 fo TEXT CONTINUATION u
."0..",T '..".'J.,i,'.T*oJ.P ".".f'c?%..*&.. =oc uov.
.c.ut, m
ooca s,.u
. = >
6..
i.,
am e,=,,=
i s
0 l 315 0 l1 0l5 or 0p VEGP ~ UNIT 1 o ls t o lc lo 14 l 214 9 l0
]
verr <, -.
- = e,
am. w m i
i 1
The audit results were o'fficially reported to the VEGP J
Corporate Manager of Licensing on Monday, July 23, 1990, i
and the unsecured safeguards container event, to the best of the individual's invcived memories, was described as follows. On November 29, 1989 an engineer placed some working documents in a safeguards container and locked it j
shortly after regular working hours ended. However, I
approximately 35 minutes later an engineering supervisor l
and designer found the container closed but not locked.
In i
i accordance with their procedure, the SCS Project Manager was immediately notified. After a brief surveillance of the container and its contents to ensure no obvious vandalism or theft had occurred the container was secured and a note placed on the container with instructions that no one was to access the contents before an audit could be performed the next morning. The following morning a meeting was held with SCS employees involved in :s_feguards information work to stress the importance of proper l
safeguards information control and to investigate the unse:ured container incident. After the meeting the l
combination of the safeguards container lock was j
immediately changed and the contents audited. The results of the audit found no discrepancies. The results of the i
l investigation by Southern Company Services, Inc. on i
November 30, 1989 concluded the following:
I i
o The maximum time the safe could have been left open and unattended was approximately 25 to 50 minutes.
4 o The audit concluded the safeguards documents logged into the container (three full size mylar drawings), were not missing. Other items in the container which were not logged were historical or current security work in
)
progress and not considered to be safeguards information.
o The location of the safeguards information container was within a records file room with only one access point and this room is located in a controlled access building i
l where there were Vogtle project employees working overtime during the incident.
i No strangers or non-Vogtle project employees were seen I
o j
near the file room or even on that floor during the time in question.
t 1
i
~-
1 1
o.onou.w 2
g, j*
UCENSEE EVENT REPORT (LER) 5.'".'.,'f,*,.*.,*20.3" "'.'3l'*.'n'*.#"".V."o't.,'.".1 TEXT CONTINUATION El".'.".!A.'l',*.O?.I'fi.2i'.".!".c"'.L '"! ".'El5 v
i
.t'.!."'^.'.*."'
- ll".:.'.'".J.a.'.J.'. Caci':v#. E" :
....,,..n oc I
c6Lif,.s.a Hs 0 0s.T s.W.e.a as ggg gg g pagg g "t20."
"'J."O
.a 1
0 l10 l6 or 0 f 0l3lS i
VEGP - UNIT 1 o ls lo lo lo l 4l2l 4 9l 0 verr n-.
c w auwnn Because of the short time frame the safeguards container I
o j
could have been open and unattended, there is a high degree of confidence that no one could have removed the mylar drawings, carried them to another part of the building, made copies and returned the originals to the a
l container without being detected by one of the employees still working on the floor at the time in question.
The Security Manager was advised of the results for corrective actions 5 and 6 (four uncontrolled and unsecured marked safeguards documents in the Corporate j
office and unsecured safeguards container at Southern Company Services on November 29, 1989) and the Shift Superintendent notified the NRC Operations l
Center at 1513 CDT on 7-23-90.
i Because of the results from the initial corrective action and recent audit findings, the following actions were also taken to help prevent recurrence of other safeguards information control incidences.
1 1.
Offsite organizations have enhanced safeguards documents control procedures to include the following:
l o Personnel access to safeguards information containers has been limited to a small number of necessary individuals.
l o The contents of safeguards information containers have been inventoried and logs maintained of future access.
l o Security / Safeguards Information Coordinators have been assigned to be j
responsible for safeguards information container logs.
l o Procedures have been incorporated to assure that "in-progress" security design change request working packages are properly 1
controlled.
2.
Archived security records have been reviewed and properly dispositionec i
l Twelve boxes identified as potentially containing security-related archived files dating from 1978 to the present have been reviewed.
CG i
one page in a single document containing a CCTV camera and environmenti enclosure vendor wiring diagram has been identified as needing classification. This document has been properly controlled and secv c since its classification. This uncontrolled and unsecured document incident will be added to the security quarterly event log since u -.
1
u un.metvu,, :- ---
g, is a"*.il:r#"#,4.## 'J"".*v"..".'"#",'L'*."
UCENSEE EVENT REPORT (LER)
,g g,g,g g g TEXT CONTINUATION 3:' L"3"a",,", %"".a* ",.'".E',Va'a"M""
m -. n, u,,,,,...
" t;'t'
"'J.?.O Y
n==
l Ol 0l 7 or 0 l7 0 l 3l S VEGP - UNIT 1 o lsjololol4 l2l4 9l0 i
_ determined this document could not significantly assist a person in an act of radiological sabotage or theft of SNM, but could reduce the total effectiveness of the safeguards system below that committed to in our-i Physical Security and Contingency Plan.
i The review of archived security records is complete and no other documents marked as safeguards information were discovered uncontrolled
)
since the four documents reported to the NRC on July 23, 1990.
i The number of offsite safeguards container locations has been reduced l
3.
from eight to four by consolidating documents and eliminating the need for containers in Architect / Engineer Design offices in Atlanta, Los i
l Angeles, and two locations in Birmingham.
Further corrective action in progress and scheduled to be completed by September l
1,1990, will require offsite organizations to add procedural guidelines to j
report any suspected compromise of safeguards information to the Corporate Office VEGP Manager of Licensing for reportability determination.
i G.
ADDITIONAL INFORMATION
)
1.
Failed Components:
2 j
Nonc 2.
Previous Stellar Events:
LER 50-424/1988-055, dated 9-6-88.
Corrective actions from the 1988 event, although sufficient for that event, were not adequate to prevent the event that occurred on 4-25-90.
3.
Energy Industry Identification System Code:
Security System - IA
. ~
- + g l
l..
4 I
I l
l i
}
\\
a REFIDUDICE PACKAGE RII RA NO.90-188 RII NO.
RII-90-E-e41 ENCIDSURE NO.
.