ML20154J093
| ML20154J093 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 05/18/1988 |
| From: | Mcdonald R ALABAMA POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NT-88-0248, NT-88-248, NUDOCS 8805260169 | |
| Download: ML20154J093 (4) | |
Text
NT-88-0248
. [ ~.
, Alabama Power Company
' 6CD North 18th Strget Post Othee Box 2641 Btrmingham. Alabama 35291-0400 Telephone 205 250-1835 h
Male"Le,,
Alabama Power the soahem ewirc system May 18, 1988 Docket No. 50-348 Docket No. 50-364 U. S. Nuclear Regulatory Comission Attention: Document Control Desk Washington, D. C. 20555
SUBJECT:
Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of March 21 - 24, 1988 RE:
Report Number 50-34P'88-09-01 50-364/88-09-01
Dear Sir:
This letter refers to the violation cited in the subject inspection reports which state:
"During the Nuclear Regulatory Comission (NRC) inspection conducted on
)
March 21-24, 1988, violations of NRC requirements were identified.
In j
accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1988), the violations are listed below:
"10 CFR 73.21(a) requires protection of safeguards information against unauthorized disclosure.
Information to be protected includes: (b)(1)(vii) documents and other matter that contain lists or location of certain safety-related equipment explicitly identified in the documents as vital for the purposes of physical protection, as contained in physical security plans; (b)(3)(i) portions of safeguards inspection reports, evaluations, audits, or investigations that contain details of the licensee's physical security system or that disclose uncorrected defects, weaknesses, or vulnerabilities in the system.
10 CFR 73.21(d)(2) requires that safeguards information shall be stored in a locked security container while unattended.
Farley Nuclear Plant (FNP) Procedure AP-4, dated February 19, 1987, Revision 12, states in paragraph 6.1.1, safeguards information will be stored in a locked security storage container when unattended. The procedure, additionally states, in paragraph 6.2.1, that safeguards information is required to be under the control of an authorized individual while it is in use to preclude unauthorized disclosure to persons who do not have a need to know.
8805260169 880518 PDR ADOCK 05000348 10 0
r U. 'S. Nuclear Regulatory Comission May 18, 1988 Page 2 Contrary to the above, on February 25, 1988, a Region II Nuclear Regulatory inspector found a cabinet containing safeguards information insecure and unattended.
This is a Severity Level IV violation.
(Supplement III)."
Admission or Denial Alabama Power Company denies that a violation occurred.
10 CFR 73.21(d) states "(1) While in use, matter containing Safeguards Information shall be under the control of an authorized individual.
(2) While unattended, Safeguards Information shall be stored in a locked security storage container. Knowledge of lock combinations protecting Safeguards Information shall be limited to a minimum number of personnel for operating purposes who have a "need to know" and are otherwise authorized access to Safeguards Information in accordance with the provisions of this section."
NUREG-0794, Protection of Unclassified Safeguards Information, provides guidance for establishing a protection system that satisfies the requirements of 10 CFR 73.21. Sections 4.1 and 4.2 of NUREG-0794 address the requirement of 10 CFR 73.21(d)(2). Section 4.2 states in part that "Safeguards Information must be under the control of an authorized individual while it is in use in order to limit access to persons who have a need to know. This requirement is satisfied if the matter is attended by an authorized individual even though the information is in fact not constantly being used." Section 4.2 further states that, "Under certain conditions the general control exercised over protected or controlled access areas would be considered to meet this requirement. The primary consideration is limiting access to those who have a need to know. Some examples would be:
An engineering or drafting area if visitors are escorted
- Certain nuclear power plant vital areas such as the control room or security office
- Plant maintenance areas if access is restricted
- Administrative offices such as central records or purchasing if visitors are escorted."
FNP-0-AP-72, Protection of Safeguards Information, Alabama Power Company's j
implementing procedure, states in paragraph 6.2.1 that "SGI is required to
-j be under the control of an authorized individual while it is in use to preclude unauthorized disclosure to persons who do not have a need to know.
The requirement for control of SGI is met if the matter is attended by an authorized individual even though the information is not constantly being used." Paragraph 6.2.3 states that, "SGI also need not be maintained in locked storage containers whiln in use if located in protected or controlled access where visitors are escorted. This includes the following i
FNP site locations: (1) control rooms, (2) document control offices."
l 4
F U. S. Nuclear Regulatoiq/ Comnission.
'May 18, 1988 l
-Page 3 i
I I
The room containing the safeguards information in question is located within the document control area which is located in the Service Building within the confines of the FNP controlled area. Access to the Service Building is controlled by (1) security personnel at the owner controlled area gate and (2) security personnel at Central Security Control, where Visitors must be visitors are logged and issued a visitor's badge.
authorized to enter the controlled area by an FWP supervisor or above.
Access to the document control area is administratively controlled.
Special access is authorized for supervisors and above and certain other personnel where routine work functions require frequent access to the area.
All other personnel must obtain permission to enter the area behind the document issue counter. Safeguards material is secured when document control is unattended.
Alabama Power Company disagrees with this violation for the following reasons:
(1)
The document control area was attended by authorized personnel at the time in question.
(2)
There were no unescorted visitors in document control during the time in question.
(3)
The statement that the inspector entered the document control area unchallenged is irrelevant since he was being escorted by an SAER individual who is authorized in writing to have special access to the area.
3 (4)
There is no procedural or regulatory requirement to keep the door leading to the room in question in a locked condition.
The door is normally locked to ensure that acceptable environmental conditions for that area are maintained.
Reason for Violation i
Not applicable Corrective Action Taken and Results Achieved Not applicable Corrective Steps Taken To Avoid rurther Violations
)
Not applicable Date of rull Compliance Not applicable l
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U. S. Nuclear Regulatory Commission May 18, 1988 Page 4 Affirmation I affirm that this response is true and complete to the best of my,
knowledge, information, and belief. The information contained in this letter is not considered to be of a proprietary nature.
Yours very truly, t).h l R. P. Mcdonald RPM:emb cc:
Mr. L. B. Long Dr. J. N. Grace Mr. E. A. Reeves Mr. W. H. Bradford