ML20214R413
| ML20214R413 | |
| Person / Time | |
|---|---|
| Site: | 05000000, Sequoyah |
| Issue date: | 09/12/1986 |
| From: | Rosalyn Jones, Lagergren W TENNESSEE VALLEY AUTHORITY |
| To: | |
| Shared Package | |
| ML082421095 | List: |
| References | |
| 1351T, 307.02-SQN, 307.02-SQN-R01, 307.02-SQN-R1, NUDOCS 8609290168 | |
| Download: ML20214R413 (5) | |
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TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT EMPLOYEE CONCERNS TASK GROUP OPERATIONS CEG Subcategory: Nuclear Power Site Programs and Procedures i
Element: Handling of Safeguards Information f
h Report Number:
307.02 SQN, Revision 1 XX-85-018-001 IN-85-915-003 Evaluator:
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R /,B, Jones
'Dat6 Reviewed by:
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/2//d Approved by:
~W. R. Laghdren
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Revision 1 l
I.
Improper Storage and Control of Safeguards Information
(
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The concerns expressed in this report are:
- 1) a Sequoyah Nuclear Plant I
specific item. dealing with safeguards material being improperly stored I
and controlled; and 2) an employee concern considered generic to SQN that addressed loss of safeguards information.
j II.
Specific Evaluation Nethodology This evaluation addresses two concerns.
4 The employee concerns identified to Quality Technology Company (QTC) are as follows:
A.
XX-85-018-001
" Safeguards information at the Sequoyah Nuclear i
Power Plant is being kept in uncontrolled books and not secured as per TVA policy and/or NRC
{
guidelines."
B.
IN-85-915-003 "A safeguards drawing (45 W 39-4 Revision 10) was lost. An investigation into this lost document 1
stated it was destroyed. There is no objective evidence to support this report."
j Concern XX-85-018-001 was closed by NSRS Investigation Report I-85-135-WBN and evaluation of the concern for SQN is based on a review of the NSRS report and line management response to the NSRS investigation. Evaluation of this concern centered on the validity of i
the employee concern, the adequacy of NSRS recommendations to close out l
the concern, a verification of the line management response to NSRS i
recommendations, and a review and verification of the corrective actions j
that resulted from the investigation.
I Concern IN-85-915-003 was considered as generic to SQN based on the results of an NSRS Investigation I-85-459-WBN at Watts Bar and was i
i evaluated at SQN as an open concern. The ECTG evaluation at SQN was
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based on the associated NSRS report recommendations and the line
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j management responses to the report. Appropriate procedures at SQN were i
reviewed to determine the adequacy of the site procedures and interviews j
were conducted to verify that the program is being properly implemented.
f III. Findings t
Improperly Stored Safeauards Material (Con'cern II-85-018-001)
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NSRS Investigation Report Number I-85-135-WBN substantiated the concern of improperly stored and controlled safeguards material at Sequoyah.
j The investigating team (composed of NSRS. PSS, and QTC personnel) found I
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Revision 1 safeguards documents in a locked PSS office which were not protected or accounted for in a manner that met NRC regulations and TVA policy / procedures.
As a result of the investigation the following NSRS recommended s:tions were taken by line management:
- 1) the safeguards material was immediately transported to a proper storage area before departure of the investigating team; and 2) the Sequoyah Public Safety Service issued Security Degradation / Incident Report Number 85-051-06 and accounted for all safeguards documents. The NSRS investigation determined that the improperly stored documents had not been compromised and Sequoyah Public Safety Services (PSS) subsequently reinstructed all members of the security force on their individual responsibilities involving the safe handling and storage of safeguards material. This action is documented in a memorandum dated September 5, 1985 (Reference 2).
Lost Safeguards Drawing (Concern IN-85-915-003)
Title 10 CFR 73 and NUREG-0794 establish the requirements for the protection of Safeguards Information.
Evaluation of SQN procedures 0401.01 (Reference 5), AI-25, Part I (Reference 7), AI-25, Part II (Reference 8), and Standard Practice SQA-132 (Reference 6) determined that the regulatory requirements are adequately incorporated into the SQN program. Further, evaluator interviews with SQN Security and Document Control personnel confirmed that these personnel have sufficient knowledge of these procedures to implement the program.
The NSRS Investigation Report I-85-459-WBN which was written to address the problem originally at Watts Bar included a recommendation to revise the Document Control Safeguards Document Los to include a reference to the drawing revision and unit applicability as additional information to provide additional controls for traceability beyond that of the drawing number. A review of the Safeguards Log at'SQN determined that this NSES recommendation is also applicable to SQN and at present has not been implemented.
Conclusion NSRS Report I-85-135-WBN adequately addressed Concern 11-85-018-001.
Line management's response was adequate and corrected the deficiencies found during the investigation.
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m Ravisicn 1 Employee Concern XX-85-018-001 was substantiated at SQN. However, adequate corrective action was immediately implemented and resolved the specific concern.
Employee Concern IN-85-915-003 was not substantiated at SQN. A review of SQN safeguards information procedures identified no programmatic deficiencies. However, this evaluation concurs with the NSRS recommendation made at Watts Bar that the Document Control Safeguards Document Log should be revised to include the drawing revision number and unit applicability number on the form. At present, the form used at SQN does not utilize these identifiers.
The concerns addressed in this report have no safety significance at SQN.
IV.
Root Cause Personnel error in not following procedures.
I V.
Generic Applicability Employee Concern XX-85-018-001 is not generically applicable to other TVA plant sites. Based on the findings of this report, SQN safeguards procedures adequately address regulatory requirements for the protection of safeguards information. The incident addressed during this evaluation was not the result of programmatic deficiencies but was an isolated occurrence of personnel not following proceduras.
Employee Concern IN-85-915-003 remains generically applicable to BFN because an adequate evaluation of the BFN Safeguards Information Program has not been conducted to determine adequacy.
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Revision 1 VI.
References 1.
NSRS Investigation Report Number I-85-135-WBN, " Safeguards Information (SQN)"
2.
Memorandum from John S. Rozek to K. W. Whitt dated September 5, 1985, "NSRS Investigation Report Number I-85-135-WBN" l
3.
Code of Federal Regulations, 10 CFR 73 4.
NUREG-0794, " Protection of Unclassified Safeguards Information" 5.
SQN Procedure 0401.01, " Protection of Safeguards Information Within the Division of Nuclear Power" 6.
SQN Standard Practice SQA-132, " Safeguards Information Program" 7.
SQN Administrative Instruction AI-25 (Part I), " Drawing Control After Licensing" 8.
SQN Administrative Instruction AI-25 (Part II), " Revision of As-Constructed Drawings" 9.
NSRS Investigation Report I-85-459-WBN, " Safeguards Drawing Incident" VII.
Immediate or Long-Term Corrective Action Corrective action taken in response to Concern XX-85-018-001 included l
transferring safeguards material to a proper storage location and l
reinstructing all members of the security force on their individual l
responsibilities for the storage and handling of safeguards material.
l No additional corrective action is outstanding.
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The investigation of Concern IN-85-915-001 uncovered traceability l
difficulties in the handling of safeguards drawings.
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