ML20217G146

Responds to NRC Re Violations Noted in Insp Rept 50-305/98-03 on 980128-0203.Corrective Actions:Controlling & Properly Securing SGI

ML20217G146
Person / Time
Site:	Kewaunee
Issue date:	03/25/1998
From:	Marchi M WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-98-23 50-305-98-03, 50-305-98-3, NUDOCS 9804020213
Download: ML20217G146 (5)

Text

e NRC-98-23 Public Service Corporation

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(a subsidiary of WPS resources corporation)

, 000 North Adams Street PO Box 19002 Green Bay. WI54307-9002 1 800 450 7260 March 25,1998 10 CFR 2.201 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D.C. 20555 Ladies / Gentlemen:

Docket 50-305 Operating License DPR-43 Kewaunee Nuclear Power Plant j Reply _toEotice_of_ Violation InspectionReport38-003

References:

1) Letter from J. A. Grobe (NRC) to M. L. Marchi (WPSC) dated February 23,1998 (NRC Special Inspection Report 50-305/98003 and Notice of Vioiation).

2) ~ . Letter from M. L, Marchi (WPSC) to Document Control Desk dated February 19,1998 ( Reportable Occurrence 1998-S02-00).

In reference 1, the Nuclear Regulatory Commission (NRC) provided Wisconsin Public Service Corporation (WPSC) with the results of NRC security inspection activities conducted January 28 through February 3,1998. The inspection was conducted as a follow-up to an incident reported to NRC on January 20,1998.

During the inspection, NRC identified one Severity Level IV violation. The violation was cited due to failure to properly secure Safeguards Information (SGI) outside the protected area. This is contradictory to the requirements of 10CFR73.21(d)(2) and 10CFR73.2.

Attached is our response to the notice. None of the information contained in this response is safeguards related. If you should have any questions with regard to this response, please contact me or a member of my staff.

Sincerely, 3 M qv Mark L. Marchi l

Manager - Nuclear Business Group \}\

9804020213 980325

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- cc: US NRC Senior Resident Inspector /

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l ATTACHMENT 1 Letter from M. L. Marchi (WPSC) to Document Control Desk (NRC)

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Dated i March 25,1998 Re: Reply to Notice of Violation, Inspection Report 98-003 l

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Document Control Desk -

March 25,1998

. Attachment 1, Page 1 NRC_ Notice of Violation 98-003-000 10CFR73.21(d)(2) requires, in part, that unattended Safeguards Information shall be stored in a locked security storage container.

10CFR73.2 stipulates, in part, that a security storage container located in a controlled access area be a steel filing cabinet equipped with a three-position, changeable-combination padlock.

Contrary to the above, on January 20,1998,' the licensee identified that from February 1994 to January 20,1508, unattended Safeguards Information (SGI) was stored outside the protected area in a controlled access area in a steel filing cabinet that was not secured with a three-position, changeabic-combination padlock. This condition existed for four years because two security staff members erroneously believed that the information was not SGI, even though it was properly marked.

_WESC_ Response Wisconsin Public Service Corporation does not contest this violation. Our review of the material revealed that no access information was compromised which precluded the possibility of any individual gaining undetected access to the protected area. We also found that, although some of the material was in fact SGI, and it could have assisted in an act of radiological sabotage, it would not have significantly assisted in such an act. Additionally, since the material was located in the plant security building, there was little likelihood of the material

. being accessed by an unauthorized individual. Therefore, the significance of not having the reg'Ored controls for SGI in this case was limited.

Panaan For Viointion This specific event was caused by security personnel who had responsibility for controlling the material failing to recognize the material as SGI. They believed that the material was not ectually SGI but sensitive security information. It was their understanding that the information was being controlled at a higher level than required.

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Document Control Desk March 25,1998

. Attachment 1, Page 2 Additional details leading to the identification, evaluation, and consequences of this event can

. be found in Licensee Event Report (LER) 1998-S02-00 (ref. 2). The LER was submitted to NRC on February 19,1998.

With regard to NRC's concern for the length of time the SGI materials were not being controlled, we concur that the duration lends sufficient significance to warrant the violation.

However, we believe this incident to be an isolated occurrence and feel that the corrective actions we have taken and those proposed are sufficient to preclude recurrence.  !

Corrective _ Actions i

The immediate corrective actions included:

. Controlling and properly. securing the SGI.

Searching the filing cabinet and all other material in control of the security training department for additional SGI material. None was found.

• Placing Security on heightened awareness and changing a duress code identified in the material. Heightened awareness for the event ended March 17,1998.

. Counseling the individuals involved in this event, and identifying what actions should have been taken and future expectations. A memo was also sent to all SGI custodians with a personal follow-up by the Security Director and the Security Operations Supervisor to discuss the event in detail and verify understanding and commitments of the program.

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Document Control Desk March 25,1998

. Attachment 1, Page 3 Our LER submittal identified that a review of the target set analysis was to be conducted to determine if we could eliminate some target sets. The review has been completed. We detennined that no target sets will be eliminated.

• Corrective actions to be completed include:

1 Revise the procedure for SGI controls to emphasize steps to declassify SGI and more clearly state requirements and expectations of the program (the procedure is currently in the revision process).

Provide additional training to cabinet custodians and personnel who are identified as having the potential of creating or handling SGI from the revised procedure on proper control.

Conduct an independent review of the SGI control program by an outside contractor.

Compliance _ Schedule It is anticipated that all the corrective actions will be completed by mid-1998.