ML20235H060
| ML20235H060 | |
| Person / Time | |
|---|---|
| Site: | Limerick  |
| Issue date: | 07/02/1987 |
| From: | Gallagher J PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC |
| To: | Gallo R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| References | |
| NUDOCS 8707140474 | |
| Download: ML20235H060 (3) | |
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PHILADELPHIA ELECTRIC COMPANY 2301 MARKET STREET P.Or. BOX 8699 PHILADELPHIA A. PA.19101 (2151 841 5001 JOSEPH W. G ALLAGHER 2*.1.".!*.'.".*"[..
Ju1y 2, 1987 I
Docket No. 50-352 Inspection Report: 50-352/86-25 i
Mr. Robert M. Gallo, Chief Projects Branch No. 2, Division of Reactor Projects Region I U.S. Nuclear Regulatory Commission ATTN:
Document Control Desk Washington, D.C.
20555 Dear Mr. Gallo Your letter dated June 3, 1987 forwarded Inspection Report 50-352/86-25 for Limerick Generating Station.
Appendix A of your letter addresses an item which does not appear to be in full compliance with Nuclear Regulatory Commission requirements.
The item of concern is stated below, followed by our response.
Violation:
10 CFR 73.21(b) states in part, "The specific types of information, documents, and reports that shall be protected (as Safeguards Information) are as follows:
Written physical security orders and procedures for members of the security organization..."
10 CPR 73.21(e) states in part, "Each document or other j
matter that contains Safeguards Information as defined in paragraph (b) in this section shall be marked " Safeguards Information" in a conspicuous manner to indicate the presence of
. protected information..."
Contrary to the above, on October 10, 1986, the inspector observed a copy of a written physical security procedure for members of the security organization that contained Safeguards Information, which was not marked in a conspicuous manner to indicate the presence of protected information.
This is a Severity Level IV Violation. (Supplement III)
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Mr. Rob 2rt M. Gallo July 2, 1987 Page 2 k
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Response
Admission of Alleged Violations Philadelphia Electric Company ackr.owledges the violation as stated.
1 Reason for the Violation:
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The security instruction involved was a draft Protection Technology Inc. (PTI) security instruction.
Although the employee who distributed the information had been trained regarding the classification of Safeguards Information he did not recognize, in this case, the requirement to classify and control the draft information prior to distribution.
Significance of the Violation:
This violation has minimal safety or security significance.
The draft security instruction involved was located in a folder in a stack on a desk inside an office with limited access, within the protected area.
The draft instruction detailed the security force response in the event of a computer outage and could only be informative in the event of a computer outage.
A computer outage is not readily identifiable outside the protected area.
Corrective Action Taken and Results Achieved:
The subject draft instruction was promptly marked as Safeguards Information and placed under the appropriate Safeguards Information controls.
Other areas where copies of the draft security instruction were distributed were immediately checked and no other instructions were found uncontrolled.
Although these other copies of the draft instruction were not stamped as Safeguards Information, they were stored in locked security storage containers while unattended.
These other copies of the draft instruction were then stamped as Safeguards Information.
At each location, other existing PTI documents were reviewed for proper Safeguards determination.
Where the classification of the documents was uncertain they were forwarded to the newly formed PTI Safeguards Committee for Safeguards determination.
Further, the importance of proper identification and control 1
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Mr. Robart M. Gallo July 2, 1987 Page 3 of Safeguards Information was discussed with Security Force Members at Guard Mount (sec"rity shift turnover).
J Corrective Actions to be Taken to Avoid Future Noncompliance:
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A Protection Technology Inc. Safeguards Committee was formed to review documents generated by PTI for Safeguards
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determination.
PTI security instruction SI-019 " Safeguards Information - Preparation, Distribution and Control", was revised to describe the PTI Safeguards Committee.
All PTI Supervisors were instructed in the handling of Safeguards Information.
Also training in Safeguards Information has been added to the Watchman initial training program and all requalification training programs.
Date Wher. 7ull Compliance Will be Achieved:
Full compliance has been achieved.
If you have any questions or require additional information, please do not hesitate to contact us.
Very truly yours, cc:
Addressee W. T. Russell, Administrator, Region I, USNRC E. M.
Kelly, Senior Resident Site Inspector i
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