ML20236Q946

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Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-312/98-02
ML20236Q946
Person / Time
Site: Rancho Seco
Issue date: 07/15/1998
From: Scarano R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To: Ferreira R
SACRAMENTO MUNICIPAL UTILITY DISTRICT
References
50-312-98-02, 50-312-98-2, NUDOCS 9807210145
Download: ML20236Q946 (4)


See also: IR 05000312/1998002

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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REGION IV

611 RYAN PLAZA DRIVE, SUITE 400

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AR LINGTON, TEXAS 76011-8064

Julyt15,1998

Richard Ferreira, Assistant General Manager

Energy Supply and Chief Engineer

Sacramento Municipal Utility District

6201 'S' Street

Sacramento, California 95852

SUBJECT: NRC INSPECTION REPORT 50-312/98-02

Dear Mr. Ferreira:

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Thank you for your letter of June 30,1998, in response to our June 3,1998, letter and

Notice of Violation. We have reviewed your reply and find it responsive to the concerns raised in

our Notice of Violation. We will review the implementation cf your corrective actions during a

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future inspection to determine that full compliance has been achieved and will be maintained.

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Sincerely,

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Ross A. Scarano, Director

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Division of Nuclear Material Safety

Docket No.: 50-312

License No.: DPR-54

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Thomas A. Baxter, Esq.

Shaw, Pittman, Potts & Trowbridge

2300 N. Street, N.W.

Washington, D.C. 20037

Jerry Delezinski, Licensing Supervisor

Sacramento Municipal Utility District

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Rancho Seco Nuclear Generating Station

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14440 Twin Cities Road

Herald, Califomia 95638-9799

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Sacramento Municipal Utility District

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Cindy Buchanan, Site Document

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Control Supervisor

Sacramento Municipal Utility District

Rancho Seco Nuclear Generating Station

14440 Twin Cities Road

Herald, Califomia 95638-9799

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Sacramento County

Board of Supervisors

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700 H. Street, Suite 2450

Sacramento, California 95814

Ms. Helen Hubbard

' P.O. Box 63

Sunol, California 94586

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Dana Appling, General Counsel

Sacramento Municipal Utility District

6201 'S' Street

P.O. Box 15830

Sacramento, California 95813

Mr. Steve Hsu

Radiologic Health Branch

State Department of Health Services

P.O. Box 942732

Sacramento, Califomia 94234

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Sacramento Municipal Utility District

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DISTRIBUTION w/coov of licensee's letter dated June 30.1998:

DCD (IE01)(IE04)

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MMessier, OC/LFDCB (4503)

SSBajwa, NRR/DRPM/PDND (11B20)

GHMarcus, NRR/DRPW/PDill-3 (11E2)

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SHWeiss, NRR/PDND (11B20)

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LLWheeler, NRR/DRPM/PDND (11B20)

RFDudley, NRR/DRPM/PDND (11B20)

Elaine Koup NRR/DRPM/SGB (MS:OWFN 11E-22)

Ellen Poteat, OCFO/LFARD, (MS: TWFN 9310)

BMurray, DRS/PSB

LLHowell, DNMS

CLCain

DBSpitzberg

FAWenslawski, WCFO

MRShaffer

JVEverett

MIS System

NMSB2

RIV Files - 4th floor file room (Part 50 Docket)

DRS Security File (Hodges)

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DOCUMENT NAME: R:\\_RS\\RS802AK.DWS

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To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

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Sacramento Municipal Utility District

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DISTRIBUTION w/ copy of licensee's latter dated _ June 30.1998:

DCDM(IE04)*

EWMerchoff, RA

MMessier, OC/LFDCB (4503)

SSBajwa, NRR/DRPM/PDND (11820)

GHMarcus, NRR/DRPW/PDill-3 (11E2)

WDReckley, NRR/ADPR/CBLA (12D22)

SHWeiss, NRR/PDND (11B20)

LLWheeler, NRR/DRPM/PDND (11B20)

RFDudley, NRRiDRPM/PDND (11820)

Elaine Koup NRR/DRPM/SGB (MS:OWFN 11E-22)

Ellen Poteat, OCFO/LFARD, (MS: TWFN 9310)

BMurray, DRS/PSB

LLHowell, DNMS

CLCain

DBSpitzberg

FAWenslawski, WCFO

MRShaffer

JVEverett

MIS System

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RIV Files - 4th floor file room (Part 50 Docket)

DRS Security File (Hodges)

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DOCUMENT NAME: R:\\_RS\\RS802AK.DWS

To receive copy of document, indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy

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OFFICIAL RECORD COPY

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SACRAMENTO MUMCIPAL tmuTY DISTRICT O P. O. Box 1583o, Sacramento CA 95852-1830, (916) 452-3211

AN ELECTRIC SYSTEM SERVING THE HEART OF CALIFORNIA

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MPC&D 98-102

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June 30, 1998

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U. S. Nue:t:ar Regulatory Commission

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Attention: Document Control Desk

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Washington,DC 20555

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Docket No. 50-312

Rancho Seco Nuclear Station

License No. DPR-54

DISTRICT RESPONSE TO NRC NOTICE OF VIOLATION 50-312/9802-01

Attention: Document Control Desk

In NRC Inspection Report 50-312/98-02, the Sacramento Municipal Utility District

(the District) received a Notice of Violation related to activities conducted at the

Rancho Seco Nuclear Station. In accordance with 10 CFR 2.201, the District

provides the enclosed response to Notice of Violation 50-312/9802-01.

Members of your staff requiring additional information or clarification may contact

Jerry Delezenski at (916) 452-3211, extension 4914.

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Sincerely,

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Steve J. Redeker

Manager

Plant Closure & Decommissioning

cc w/ Encl:

E. W. Merschoff, NRC, Arlington, Texas

D. Dudley, NRC, Rockville

W~-I743

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ResDonse to NRC Notice of Violation 50-312/9802-01

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NRC Statement of Violation:

10 CFR 73.56(b)(2)(i) requires, in pan, that the licensee provide high assurance that

individuals granted unesconed access to protected areas are tmstwonhy and reliable. In

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this regard, the licensee's program for granting unescorted access authorization to the

plant's protected area must include a background investigation, including information

concerning an individual's criminal history.

License Condition 2.C.(3) of the licensee's facility operating license requires, in part, that

the licensee maintain in effect and fully implement all provisions of the physical security

plan approved by the Commission and all changes and amendments made pursuant to the

authority of 10 CFR 50.54(p) and 10 CFR 50.90.

Section 5.1.2.2 of the licensee's physical security plan states, in part, that," Personnel

authorized unesconed access to the protected area shall meet all requirements of the

Access Authorization Program which meets all elements of Regulatory Guide 5.66 to

satisfy the requirements of 10 CFR 73.56."

Paragraph 7.1 of the Appendix to Regulatory Guide 5.66 dated June 1991 (NUMARC 89-

01) requires, in pan, that a licensee review and consider all information obtained during a

background investigation and base its decision to grant unesconed access authorization

upon the results of this review.

Paragraph 7.la of the Appendix to Regulatory Guide 5.66 dated June 1991 (NUMARC 89-01) requires,in pan, that in making a determination of trustworthiness and reliability,

that the licensee consider the willful omission or falsification of material information

submitted in support of a request for unescorted access authorization.

Contiary to the above, on May 20,1998, the inspector determined that the licensee failed

to: (1) review and consider all information obtained during a background investigation;

and (2) consider if available criminel history information had been willfully omitted or

falsified from the individual's personnel security questionnaire. Specifically, on May 11,

1998, the licensee received criminal history (misdemeanor conviction) information from

the state of California that had not been included on an individual's personnel security

questionnaire. As of May 20,1998, licensee management had not reviewed this criminal

history infonnation, nor determined if this information had been willfully omitted by the

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individual from his personnel security questionnaire.

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This is a Severity Level IV violation (Supplement III).

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Resnonse to NRC Notice of Violation 50-312/9802-01

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District ReSDonse:

Admission or Denial of Violation

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The District acknowledges that it did not review state of Califomia criminal history

information for the subject individual from May 11,1998, to May 20,1998.

Reason for Violation

Distdct Security did not perform a more timely review of the individual's state of

California criminal history information because District Security office staff did not

forward the criminal history information to District Security supervision as is typically

done. Instead Security office staff placed the state of Califomia criminal history

information into the individual's badge information folder without District Security

supervision review.

The District believes District Security would have reviewed the state of California

criminal history information after District Security received the subject individual's FBI

criminal history information. In accordance with District access authorization

procedures District Security evaluates relevant background infonnation collected in an

individual's badge infonnation folder before the District grants permanent protected area

unescorted access authorization. District Security needed the outstanding FBI criminal

history info;mation before District Security could upgrade the subject individual from

temporary to permanent protected area unescorted access authorization. District receipt

of the FBIinformation would have prompted a review of the individual's badge

information folder, which contained the state of California criminal history information.

Discussion of Violation

District Security completed the required, initial background investigation, submitted

fingerprints to the FBI and the State of Califomia, Department of Justice, and granted the

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subject individual temporary protected area unescorted access authorization on March 12,

1998. District Security performed this activity in accordance with:

1. NRC regulations (10 CFR 73.56),

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Resconse to NRC Notice of Violation 50-312/9802-01

Discussion of Violation (Continued)

2. NRC guidance (Regulatory Guide 5.66),

3. Industry guidance (NUMARC 89-01),

4. NRC approved Rancho Seco Physical Security Plan (RSPSP), and

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5. Rancho Seco Administrative Procedure RSAP-1003.

10 CFR 73.56(c)(2) allows access authorization programs to specify provisions for

granting temporary protected area unescorted access authorization. The District's

temporary access authorization program, as specified in the RSPSP and RSAP-1003,

" Access Screening Requirements," meets the guidance contained in NRC Regulatory

Guide 5.66, " Access Authorization Program for Nuclear Power Plants" and NUMARC 89-01," Industry Guidelines for Nuclear Power Plant Access Authorization Programs."

The District met its procedural requirements and NRC regulations and guidance when it

granted the subject individual temporary protected area unesconed access authorization.

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The RSPSP allows granting individuals temporary protected area unescorted access for

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up to 180 days to permit, in pan, sufficient time to complete the necessary criminal

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history review required for permanent unesconed access authorization. The Rancho Seco

Security computer automatically locks out any individual with temporary protected area

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unesconed access authorization that has not received approval for permanent unescorted

access authorization within the 180-day time limit.

On May 11.1998, District Security received state of California criminal history

information for the subject individual. As of May 20,1998, the District Security

supervision had not n: viewed this state of California criminal history information. This

delay occurred because District Security office staff placed the criminal history

information in the individual's badge information folder instead of routing the

information to District Security supervision for review as is typically done.

District Security completed a review of the state of California criminal history

information on May 21,1998. As of June 30,1998, District Security was still waiting for

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FBI criminal history information so the District could complete its permanent protected

area unesconed access authorization review. The subject individual would not have

reached the 180-day temporary protected area unescorted access authorization limit until

September 8,1998.

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Resoonse to NRC Notice of Violation 50-312/9802-01

Corrective Actions Taken and Results Achieved

When the NRC inspector informed the District that District Security had not yet reviewed

the state of California criminal history information, District Security supervision

immediately initiated the appropriate review. District Security reviewed the state of

California criminal history background investigation information and determined the

individual omitted one 15-year old misdemeanor conviction (soliciting a prostitute) from

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his personnel security questionnaire due mainly to embarrassment. Also, District

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Security determined the individual did not repon other criminal history information that

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should no! have been on his record (i.e., cdminal charges that had been dropped and

never prosecuted).

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District Security completed a review of the subject individual's California criminal

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history information on May 21,1998, determined the individual's personnel security

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questionnaire was not completely accurate, and removed the individual's temporary

protected area unescorted access authorization.

Additionally, based on (1) interviews with the subject individual's Rancho Seco

sup ervisors and (2) the individual's productive, three-plus months work experience at

Rancho Seco, District Security concluded the individual had not exhibited characteristics

that detracted from his reliability or trustworthiness. District Security did not identify any

significant reliability or trustworthiness concerns that would (1) warrant discontinued

employment or (2) prevent consideration for permanent protected area unescorted access

authorization before Distnct Security received and reviewed the individual's FBI criminal

history information.

Finally, the District revised RS AP-1003 to clarify District Security staff responsibilities

regarding the handling and review of criminal history information. This information is

not to be placed in an individual's badge information folder until after appropriate

District Security supervision review. The RSAP-1003 procedure changes will help

ensure more timely District Security review of criminal history information.

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Corrective Actions to be taken to Avoid Further Violations

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In addition to the RSAP-1003 revision, District Security will train the Rancho Seco

Security staff on the RSAP-1003 changes, including the responsibilities and expectations

regarding the proper handling and review of criminal history information. Also, to ensure

continued proper handling and review of criminal history information, District Security

will include this training as pan of the annual Security staff refresher training.

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Resoonse to NRC Notice of Violation 50-312/9802-01

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Date when Full Compliance achieved

District Security updated its review of all information obtained during the subject

individual's background investigation by completing a review of his state of Califomia

criminal history information. Also, District Security considered if criminal history

information had been willfully omitted from, or falsified on, the individual's personnel

security questionnaire. District Security completed these evaluations and achieved full

compliance on May 21,1998.

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