View source for ELV-01943, Responds to Violation & Proposed Imposition of Civil Penalty in Insp Repts 50-424/90-11 & 50-425/90-11.Corrective Action: Complete Audit of Contents of Safeguards Info Container Performed & Unassigned Safeguards Info Dispositioned

{{Adams
| number = ML20055J442
| issue date = 07/27/1990
| title = Responds to Violation & Proposed Imposition of Civil Penalty in Insp Repts 50-424/90-11 & 50-425/90-11.Corrective Action: Complete Audit of Contents of Safeguards Info Container Performed & Unassigned Safeguards Info Dispositioned
| author name = Hairston W
| author affiliation = GEORGIA POWER CO.
| addressee name = 
| addressee affiliation = NRC OFFICE OF ENFORCEMENT (OE)
| docket = 05000424, 05000425
| license number = 
| contact person = 
| document report number = ELV-01943, ELV-1943, NUDOCS 9008020267
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 16
}}

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Gergo Power Comrc.tv i*,      '''
333 Piedmont Aenue e          Anan Gecwg a 30308                                                                            ;
                , Tenophone 404 526 3195
            .      Mailing Add'er.s 40 invernoan Center Pa4 way                                                                    )
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Birmingham. Alabame 35?ot ietophone 205 868 5581 July 27, 1990              ,,nm,.y.,n ,wrc s43.m W. O. Hairston, til sen.or vce presidem                                                   ELV-01943               ;
Neat Owabons                                                         0522                     !
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V-            Docket Nos.              50-424 50-425                                                                   i Director, Office of Enforcement                                                                   i U. S. Nuclear Regulatory Commission ATTN: Document Control Desk                                                                       ,
Washington, D. C. 20555                                                                           ,
Gentlemen:
                                                                                                            't V0GTLE ELECTRIC GENERATING PLANT REPLY TO NOTICE OF VIOLATION AND                              ,
PROPOSED IMPOSITION OF CIVll PENALTY Pursuant to 10 CFR 2.201, Georgia Power Company (GPC) hereby submits the enclosed information in response to NRC violatica 50-424/90-11 and 50-425/90-11 as-a result of an inspection conducted by Mr. A. Tillman on April 30 - May 1, 1990, in the enclosure, a transcription of the NRC violation precedes GPC's                     i response.                                                                                        -
In addition to the enclosure, a check in the amount of $50,000 is enclosed in responw to the civil penalty.
Please contact this office if you have any questions.
Sincerely, ut. A L U W. G. Hairston,'ll!
WGH,Ill/AFS/gm

==Enclosure:==
Violation Response and Check c(w): Georaia Power Company Mr. C. K. McCoy Mr. G. Bockhold, Jr.
Mr. R. M. Odom                                                                     -
Mr. P. D. Rushton NORMS                                                                              ,
U. S. Nuclear Reaulatory Commission Mr. S. D. Ebneter, Regional Administrator                      f E
Mr. 1. A. Reed, licensing Project Manager, NRR              y    &
f Mr. B. R. Bonser, Senior Resident inspector, Vogtle               4 jgr7 6 h ' c:
9008020267 900727             ,                                          h PDR       ADOCK 05000,4 g Q                         FDv ql              ,

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L ENCLOSURE V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2                      ,
NRC NOTICE Of VIOLATION 50-424/90-11 AND 50-425/90-11 AND GPC RESPONSE "During the Nuclear Reguld ory Commission (NRC) inspection conducted on April 30- May 1,1990, a violation of NRC requirements was identified.      in accordance with the " General Statemen; of Policy and Procedure for NRC Enforcement                :
Actions," 10 CFR Part 2, Appendix C (1990), the Nuclear Regulatory Commission proposes to impose a civil penalty pursuant to Section 234 of the Atomic fnergy Act of 1954, as amended (Act), 42 U.S.C. 2282, and 10 CFR 2.205. The particular violation and associated civil penalty are set forth below:                             '
10 CFR 73.21(a) requires, in part, that safeguards Information be                ,
protea.ted against unauthorized disclosure.
10 CFk 73.21(d)(2) requires, in part, that while unattended, safeguards information shall be stored in a locked security storage container, t
The licensce's Administrative Procedure No. 00650-C, Safeguards Information Control, figure 4, Letter of Instruction, specifies that when not in use, safeguards information shall be stored in a steel cabinet with a locking bar arx) a U. S. General Services Administration (GSA) approved padlock or in a GSA approved security container.
Contrary to the above, on April 25, 1990, an employee of the licensee discovered a safeguards information storage cabinet containing a) proximately 140 safeguards information documents, including the site P1ysical Security and Contingency Plan, unsecured and unattended.
This is a Severity Level 111 violation (Supplement 111)."
RESPONSE TO NOTICE OF VIOLATION 50-424/90-11 AND 50-425/90-11 Admission or Denial of the 'iiolation:
The violation occurred as stated.
Reason for the Violation:
As stated in the Notice of Violation, plant personnel failed to implement guidance provided in Administrative Procedure 00650-C which resulted in a safeguards information storage cabinet being unsecured and unattended, The reason for the violation was attributed to personnel error.
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          .                                                                                    l ENCLOSVRE (CONTINUED) 4 V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 NRC NOTICE OF VIOLATION 50-424/90-11 AND 50-425/90-11 AND GPC RESPONSE Corrective Steps Which Have Been Taken and the Results Achieved:
The following corrective actions were initiated:
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: 1) A complete audit of the contents of the safeguards information container   i was performed. This audit accounted for all assigned safeguards          1 information documents. The unassigned safeguards information has been properly dispositioned.                                                  i l
: 2) The individual involved with the event was disciplined in accordance       I with Vogtle's Positive Discipline Program.
Additional corrective measures taken not specifically related to the cited        i violation are as follows.
1). An interoffice correspondence was sent to VEGP site and Corporate office  I employees emphasizing the following:
o importance of controlling safeguards information.
l 0 requesting personnel to search and certify that they have no uncontrolled safeguards information material in their personal work   !
areas and homes. This certification was crepleted by VEGP site and    l Corporate office employees on July 5,1996.
o proper method for storing safeguards information, o proper method for mailing and receiving safeguards information, o actions to take if any safeguards information does not meet the criteria established in Administrative Procedure 00650-C, and VNS-AP-26, " Safeguards Information Control."
: 2)   Safeguards information containers on site were centralized to Document c                    Control, Security, and Quality Assurance of fices. These containers were centralized as of May 18, 1990. Corporate office safeguards information containers were already centralized in Corporate Document Control before this violation occurred.
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ENCLOSURE (CONTINUED)
                                                                                                  ~
V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2 NRC NOTICE OF VIOLATION 50-424/90-11 AND 50-425/90-11 AND GPC RESPONSE         i
: 3) A review is being performed of historical records in Corporate office files. To date, four reference documents dated April 1982, have been        !
located which were marked safeguards information and had not been           .
properly controlled. One of these documents is considered to be significant. These documents have now been secured.                         ;
The NRC was notified of this safeguards information control incident on July 23, 1900.
Other items which may be discovered during this on going review of safeguards information control will be reported to the NRC in a supplemental report.                                                        ,
: 4) The VEGP Architect / Engineer Design Organizations were also directed to     '
implement the same interoffice correspondence certifying safeguards information control by their respective employees.
Both organizations reported that the applicable employees had certified that their assigned safeguards information documents were properly controlled and that they were familiar with the requirements for proper handling of safeguards information documents per their      ,
respective safeguards information control procedure.
: 5) Due to our increased sensitivity to safeguards information control after     ,
the cited violation, the VEGP Safety Audit and Engineering Review Department we requested to place special emphasis on safeguards information control in their annual audits,      Therefore, during a recent annual audit of one of the Architect / Engineer Design Organizations utilized by the licenste, possible programmatic problems with safeguards information control and re?ortability were discovered. The audit revealed inventory log pro)lems and an unsecured safeguards information container incident lasting for approximately 35 minutes on November 29, 1989 which had not been reported to the licensee for reportability and security system compromise significance due to lack of procedural guidance. This unsecured safeguards information container event was reported by the licensee to the NRC on July 23, 1990.
The Corrective Steos That Will Be Taken To Avoid further Violations:
The results of these corrective actions have precipitated further review of-safeguards information document control procedures for deficiencies in control or reportability at all applicable offsite organizations.
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I ENCLOSURE (CONTINUED) l V0GTLE ELECTRIC GENERATING PLANT - UNITS 1 AND 2                :
NRC NOTICE OF VIOLATION 50-424/90-11 AND 50-425/90-11 AND GPC RESPONSE       i Results of this review to date have identified several enhancements which are being implemented o   Licensee requirement that offsite organizations add procedural            ;
guidelines to report any suspected compromise of safeguards information to the licensee immediately for determination of reportability. This   I will be completed by September 1,1990.                                    !
o   Licensee direction given to offsite organizations to limit access to       i safeguards information containers. This will be completed by September     i 1, 1990.
                                                                                                     ]
o   Licensee requirement that offsite organizations inventory the contents    l of safeguards information containers and maintain logs of access in the future. This will be complete by September 1, 1990, o   The requirement that offsite organizations assign a Security / Safeguards Information coordinator to be responsible for safeguards information      ,
container logs. This will be complete by September 1,1990.
o   Licensee direction to offsite organizations to develop and implement guidelines to assure "in-progress" security design change request working packages are properly controlled. This will be complete by September 1, 1990.
o   A review of archived security records to verify historical security documents have been properly dispositione:1. This will be complete by October 1, 1990.
A supplementary report will be provided to the NRC by October 31, 1990 summarizing the completion of this review and necessary corrective actions taken.
The Date When Full Comoliance Will Be Achieved:
Full compliance for the noted violation was achieved on April 25, 1990 with completion of the unsecured safeguards information container audit and securing of the container.
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