ML20197J881
| ML20197J881 | |
| Person / Time | |
|---|---|
| Site: | Waterford  |
| Issue date: | 12/14/1998 |
| From: | Ewing E ENTERGY OPERATIONS, INC. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 50-382-98-16, W3F1-98-0202, W3F1-98-202, NUDOCS 9812160019 | |
| Download: ML20197J881 (3) | |
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Killona. LA 70066 -
Tel 504 739 6242 Early C. Ewing, til I
Director.
afety & Regulatory Affairs W3F1-98-0202 A4.05 PR I
r December 14,1998 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk
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Washington, D.C. 20555
.l Su'oject:
Waterford 3 SES
- Docket No. 50-382 I
License No. NPF-38 Supplemental Response to Apparent Violation in Inspection Report No. 50-382/98-16 Gentlemen:
On December 7,1998, during a telephone conversation between Dwight Chamberlain of your staff and Entergy's Early Ewing, the need for additional actions to address the Apparent Violation in Inspection Report No. 50-382/98-16 was discussed. Accordingly, this letter provides the supplemental response as committed during that telephone conversation.
This original response to the Apparent Violation was submitted to you in the atta :hed Waterford 3 (W3) letter W3F1-98-0187, dated November 25,1998. The apparent violation was a failure to adequately protect and control safeguards information outside the plant protected area. The corrective actions to reduce the likelihood of recurrence of the event were:
- 1. Revice Site Procedure W5.503, Handling of Safeguards Information, to requi e that the name of everyone who is cleared to view and process safeguards information is placed on the Safeguards information 4%g Authorized Users List. The List would be maintained and control 3d by security.
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- 2. Place the Safeguards Information A.: horized Users List on site security's L
web page. This would allow all plant personnel to easily determine who has access to safeguards information.
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Supplemental Response to Apparent Violation in inspection Report No. 50-382/98-16 W3F1-98-0202 Page 2 December 14,1998 As discussed in the telephone conversation, Entergy has decided to take additional actions to further enhance the handling of safeguards information at Waterford 3.
l These actions are:
- 1. A cover page will be placed on safeguards documents (i.e. procedures, plans, responses to NRC issues, etc.) delineating the proper handling of safeguards information. As a minimum, the cover sheet will require that the attached document.shall not be left unattended or under what circumstance an unauthorized person may have access to it.
2.' Security will notify all Safeguards Information Authorized Users whenever Site Procedure W5.503, Handling of Safeguards Information is revised.
This will ensure that appropriate personnel are cognizant of changes that may affect the method that safeguards documents are handled.
- 3. Security will compare their method of handling safeguards information with plant administrative services. Handling methods will become consistent where appropriate.
The above enhancements, as well as the corrective actions documented in attached letter W3F1-98-0187 will be completed by January 31,1999.
l Please contact Early Ewing at (504) 739-6242 or E.G. Beckendorf at (504) 739-6340 should you ha're questions regarding this response.
1 Very truly yours, l
E.C. Ewing Director l
Nuclear Safety & Regulatory Affairs ECE/GCShtk l
Attachment cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
J. Smith, N.S. Reynolds, NRC Resident inspectors Office l
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Killona. LA 70066-0751 Tel 504 739 6660 Charles M. Dugger ce P esoent. Ocerat ons W3F1-98-0187 A4,05 PR November 25,1998 U.S. Nuclear Regulatory Commission ATTN: DocumentControlDesk Washington, D.C. 20555 Subject-Waterford 3 SES Docket No. 50-382 License No. NPF-38 Response to An Apparent Violation in Inspection Report No. 50-382/98-18 Gentlemen:
I Entergy, Waterford 3, hereby submits the response to the apparerd violation regarding failure to +f+;CV protect and control safeguards information outside the plant protected area. This response is submitted per your letter dated October 27,1998.
As allowed by your October 27th letter, we have attached our previously docketed Security' incident Report (SIR) 98-S01-00, Waterford 3 letter W3F1-98-0142, to address this icsue. In addition to the corrective actions provided in the SIR, the corrective actions listed below will be performed to further reduce the likelihood of recurrence of the event:
- 1. Site Procedure W5.503, Handling of Safeguards information, will be revised to require that the name of everyone who is cleared to view and process safeguards information be placed on the Safaguards Information l
Authorized Users List. This list will be maintained and controlled by site security.
- 2. The Safeguards tr' formation Authorized Users List will be placed on site security's web page. This will allow all plant personnel to easily determine who has access to safeguards information.
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Response to An Apparent Violation in j
inspection Report No. 50-382/98-16 W3F1-98-0187 i
Page 2 November 25,1998 The above corrective actions will be completed by May 31,1999.
Based on the completion of the corrective actions described in the SIR, Waterford 3 l
is in full compliance.
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We consider this Waterford 3 identified event to be an isolated occurrence, caused
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primarily by one individual's human performance error. Entergy promptly notified i
NRC when this event occurred and perfamled a thorough investigation of this event.
Control of Safeguards Information is of major importance to station personnel. This is evident by the fact no similar event has occurred within at least the last two years.
Entergy believes that the corrective actions taken and planned to be taken, as documented above, are comprehensive and will preclude recurrence.
Please contact Early Ewing at (504) 739-8242 or E.G. Beckendorf at (504) 739-8340 should you have any questions regarding this response.
Very truly yours, C.M. Dugger Vice President, Operations Waterford 3 CMD/GCS/rtk Attachment cc:
E.W. Merschoff(NRC Region IV)
C.P. Patel(NRC-NRR)
J. Smith N.S. Reynolds NRC Resident inspectors Office
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION In the matter of
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Entergy Operations, incorporated
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Docket No. 50-382 Waterford 3 Steam Electric Station
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AFFIDAVIT Charies Mamhall Dugger, being duly swom, hereby deposes and says that he is Vice President, Operations - Wmerford 3 of Entergy Operations, incorporated; that he is duly authorized to sign and file with the Nuclear Regulatory Commission the attached Response to An Apparent Violation in Inspection Report No. 50-382/98-18; that he is familiar with the content thereof; and that the matters set forth therein are true and correct to the best of his knowledge, information and belief.
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Charies Marshall Dugger TT Vice President, Operations Wateiford 3 STATE OF LOUISIANA
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Subscribed and swom to before me, a Notary Public in and for the Parish and State above named this 2 c day of / w <-<~.
4 u.1998.
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Notary Public My Commission expires d d Y.
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Entergy w:a,_
Entergy Operations,Inc.
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Tel 504 739 6242 C. Ewing,111 g..gery a % ws n W3F1-98-0142 A4.05 PR August 17, 1998 U.S. Nuclear Regulatory Commission Attn: Document Controi Desk Washington, D.C. 20555
Subject:
Waterford 3 SES Docket No. 50-382 License No. NPF-38 Reporting of Security Incident Roport Gentlemen:
Attached is Security incident Report (SIR) 98-S01-00 for Waterford Steam Electric Station Unit 3. This report provides details wherein on July 23,1998, the Waterford 3 Physical Security Plan, a safeguards document, was not under positive control of an authorized person at all times. This condition is being reported pursuant to 10 CFR Part 73, Appendix G, Paragraph l(c).
Very truly yours,
/
E.C. Ewing Director Nuclear Safety & Regulatory Affairs ECE/GCS/pic Attachment 4
cc:
E.W. Merschoff (NRC Region IV), C.P. Patel (NRC-NRR),
P.A. Harrell (NRC Region IV), A.L. Garibaldi, J.T. Wheelock - INPO Records Center, J. Smith, N.S. Reynolds, NRC Resident inspectors Office, 0066@1 h.
Admir.istrator-LRPD
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i.....,,,. mammy is.6asi e tvP.wem.a na i oe On July 23,1998, Waterford 3 discovered that the Waterford 3 Physical Security Plan, a safeguards document, was not under positive control of an authorized person at all times. An investigation into the incident revealed that the document was transferred to an unauthorized individual who in tum left the document in the office of an authorized individual. The authorized individual was not made aware that the document was safeguards information; therefore, the document was left in his office unattended from 0900 to 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on July 23,1998. The Security Superintendent was immediately notified of the condition, and compensatory actions were initiated. The event is being reported pursuant to 10 CFR 73, Appendix G,1(c), and a one-hour notification was issued per the same requirement. The apparent cause of this event is Human Error / Inappropriate Action due to transfer of safeguards information not in accordance with the site procedure. The employee involved was counseled on the procedural requirements for control of safeguards documents and had his access to safeguards material removed pending retraining. There was no malevolent intent on the part of any
- s. event did not compromise the health and safety of the public.
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UCENSEE EVENT RE' ORT (LER)
TEXT CONTINUATION FACRJTY NAAE 0)
DOCKET LEt N ISD PAGE 13) lEN Mall N
05000 00 2 OF 5 1
Waterford Steam Electric Station Unit 3 382 98 -- S01 l
inni W more space a requred, une em oop,ee of WC form 366M n 7) l REPORTABLE OCCURRENCE On July 23,1998, the Waterford 3 Phyaical Security Plan (PSP), a safegcrds document, was discovered unattended and unsecured in the office of the Director, l
Nuclear Safety and Regulatory Affairs (NS&RA). This event is being reported pursuant
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to 10 CFR Part 73, Appendix G, Paragraph l(c) as a discovered vulnerability in a j
safeguard system that could allow unauthorized or undetected access to a protected I
area, material access area, controlled access area, vital area, or transport for which j
compensatciy measures had not been employed. On July 23,1998, a one-hour report
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of this event was issued per the same requirement.
INITIAL CONDITIONS i
j The plant was operating in Mode 1, at approximately 99% reactor power, on July 23, f
1998, when the conditbn was discovened.
EVENT DESCRIPTION i
l On July 23,1998, the Waterford 3 Physical Security Plan, a safeguards document, was discovered unattended and unsecured in the office of the Director, NS&RA. The l
revised document was being routed for final approval to allow submittal to the NRC. An l
investigation into the incident revealed that the safeguards document was first retrieved l
from a Security Storage Container at about 0800 houm by a Licensing Engineer (an authorized smployee) engaged in obtaining document final approval. This individual brought the document to a secretary temporarily filling in for the NS&RA Director's secretary. The safeguards nature of the document was noted by the secretary during the package verification process, and the secretary stated that she was not safeguards authorized. The employee engaged in routing the document indicated that based on a "need to know" the secretary could precess the document. This was contrary to Procedure W5.503, Handling of Safeguards Information (SI) which states in Paragraph 5.11.1, " Unsecured Si shall remain under the positive control of an authorized person at all times to preyent disclosure to unauthorized persons." W5.503 further states in w
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LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FAcaJTY NAAS m 00 CWT LEtNu m (W PAGE (3) 8Eg ag ma i
05000 3 OF 5,
Waterford Steam Electric Station Unit 3 382 98 ~
S0i 00 11xT 19 more space se requeed, une endoonal oopone of hRC form 306Al (17)
Paragraph 5.11.3, " Recipients and users of Si shall at all times ensure that the documents are disseminated only on a "need to know" basis to authorized persons and I
shall protect the documents in such a manner as to prevent the disclosure of the i
j information contained therein to individuals without a "need to know"."
The package verification process includes checking the package to assure that the l
cover letter is on the proper letterhead and has a letter number, along with proofreading l
it and verifying inclusion of attachments, etc. After this process was completed, it was l
determined that the Director, NS&RA was on the telephone. After having reasoned that l
the secretary could examine the documents to perform the package verification, it was j
decided at 0820 hours0.00949 days <br />0.228 hours <br />0.00136 weeks <br />3.1201e-4 months <br /> that the folder containing the safeguards document could be left l
with the secretary to present to tho Director at the conclusion of his telephone call. The l
secretary placed the folder containing the document in the Director's in-bar.ket tatween 0820 and 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br />; however, the Director was not made aware that the dccument was safeguards information. The document was therefore left unattended and j
unsecured in his office between 0900 hours0.0104 days <br />0.25 hours <br />0.00149 weeks <br />3.4245e-4 months <br /> and 1400 hours0.0162 days <br />0.389 hours <br />0.00231 weeks <br />5.327e-4 months <br /> on July 23,1998.
1 I
CAUSAL FACTORS The root cause of this event is human error in that the individual routing the document l
failed to transfer the safeguards documents per the procedural requirements of W5.503, Handling of Safeguards information. Contrary to Procedure W5.503 which l
states in Paragraph 5.11.1, " Unsecured Si shall remain under the positive control of an j
authorized person at all times to prevent disclosure to unauthorized persons," the I
safeguards document was not properly handled. Also, the employee involved in the event did not review Procedure W5.503 prior to handling the Si to confirm the document control requirements for sensitive safeguards documents.
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a mRc m m u.s. wucuAR REQULATORY COtseieSSHM l LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FAGJTY W (1)
DOCKET H
LE.R NutSER (6)
PAGE (3) 05000 4 OF S Waterford Steam Electric Station Unit 3 382 l 98 ~
S01 ~ 00 TEXT IN more space is remare$ une ad600nel copee of NMC form 366A) (17}
CORRECTIVE MEASURES
- 1. The Security Superintendent was immediately notified of the condition as required by W5.503.
- 2. Compensatory actions (apprised security personnel for heightened awareness and increased patrols) were initiated by the Security organization to address the potential for compromise of a safeguards document.
- 3. The Waterford 3 Physical Security Plan was compared to its document control copy relative to the correct number and order of pages. The check was satisfactory.
- 4. The Security organization conducted an investigation to reconstruct the sequences of this event.
- 5. The employee involved was counseled on the event, and the procedural requirements for control of safeguards documents were reemphasized to the individual.
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- 8. Lessons teamed from the event were discussed at a Licensing Department meeting to increase staff sensitivity regarding the handling of safeguards information.
- 7. The employee's access to safeguards material was removed pending retraining.
SAFET/ SIGNIFICANCE At the time of this event, the Security Superintendent was immediately notified of the condition. Compensatory actions were at once initiated.
It was determined that during the time the PSP was unattanded in the office of the Director, NS&RA, two employees were working at Seir assigned work stations outside
pel)C FORM 368A U.S. NUCLEAR REGULATORY COS445S40N m
LICENSEE EVENT REPORT (LER)
TEXT CONTINUATION FACIUTY NAM 0)
DOCKET LER NUOMER 16)
PAGE (3) 05000 5
OF 5 Waterford Steam Electric Station Unit 3 382 98 S01 00
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TEXT IN rnore space se requeed. une addooned copies of NRC form 366Al U 1l the office. The employees have Protected Area access. The responsibilities of those employees include scheduling appointments as well as monitoring and assisting other persons coming to the area. They indicated that no unauthorized individual entered the Director's office during the period of time when the PSP was unattended and unsecured. There was no indication that the documents were disturbed, removed, or copied during the time the Director was absent from his office. The document was found in the same location and orientation as originally left.
i The document was inside an unmarked (not stamped " Safeguards Information") green folder which in tum was inside an unmarked blue folder. Because the folders had no typical extemal marking indicating they contained the PSP or SI, a person entering the l
office would not have known about the presence of the safeguards material. Also, the t
inventory and order of pages in the document were checked by security personnel and determined to be unchanged.
Security personnel were apprised of the Si document compromise to heighten security officer awareness, and the frequency of security patrols was increased. No unusual occurrences have been identified by security personnel subsequent to the occurrence of this event. As such, this condition did not compromise the health and safety of the public or plant personnel.
4 SIMILAR EVENTS A review of Security incident Reports dating back to '995 was performed. No similar events have been identified specific to failure to meet the requirements of 10 CFR 73, Appendix G,1(c) regarding the Physical Security Plan.
ADDITIONAL INFORMATION Energy Industry identification System (Ells) codes are identified in the text within brackets [].