View source for 0CAN109402, Forwards Response to Violations Noted in Insp Repts 50-313/94-16 & 50-368/94-16.Corrective Actions:Description of Condition Involving Individuals Placed Into Quarterly Safeguards Event Log on 940425

{{Adams
| number = ML20078B873
| issue date = 10/20/1994
| title = Forwards Response to Violations Noted in Insp Repts 50-313/94-16 & 50-368/94-16.Corrective Actions:Description of Condition Involving Individuals Placed Into Quarterly Safeguards Event Log on 940425
| author name = Mims D
| author affiliation = ENTERGY OPERATIONS, INC.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000313, 05000368
| license number = 
| contact person = 
| document report number = 0CAN109402, CAN109402, NUDOCS 9410270201
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE
| page count = 5
}}

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                                                                                           >  w-October 20,1994 OCAN109402 U. S. Nuclear Regulatory Commission Document Control Desk Mail Station Pl-137 Washington, DC 20555

==Subject:==
Arkansas Nuclear One -- Units 1 and 2 Docket Nos. 50-313 and 50-368 License Nos. DPR-51 and NPF-6 Reply to a Notice of Violation                  ,
inspection Report 50-313/94-16; 50-368/94-16 l
l Gentlemen:                                                                                          )
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Pursuant to the provisions of 10CFR2.201, attached is the reply to the notice of violation          l identified in the subject inspection report.
Should you have questions or comments, please call me at 501-858-4601.
Very truly yours, bMgNC.Y!)6 Dwight C Mims Director, Licensing DCM/tfs 9410270201 941020 3                                                                             '
DR ADOCK 0500

      . U.S.NRC
  . October 20,1994 OCAN109402 Page 2 cci   Mr. Leonard J. Callan Regional Administrator U. S. Nuclear Regulatory Commission Region IV                                    .
611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 NRC Senior Resident Inspector                .
Arkansas Nuclear One -- ANO-1 & 2 Number 1, Nuclear Plant Road Russellville, AR 72801 Mr. George .Kalman NRR Project Manager Region IV/ANO-1 U. S. Nuclear Regulatory Commission NRR Mail Stop 13-H-3 One White Flint North 11555 Rockville Pike Rockville, MD 20852 Mr. Blaine Murray Chief, Facilities Inspection Programs Branch U. S. Nuclear Regulatory Commission Region IV 611 Ryan Plaza Drive, Suite 400 Arlington, TX 76011-8064 I
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Attachment to                                                                               l p
. OCAN109402 Page1of3 NOTICE OF VIOLATION During an NRC inspection conducted on April 18-22, 1994, a violation of NRC requirements was identified. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10CFR Part 2, Appendix C, the violations are listed below:
License Condition 2.D (Unit 1) and License Condition 2.c(4) (Unit 2) of the licensee's facility operating license DPR-51 and NPF-6 require that the licensee fully implement and maintain the Commission approved Physical Security Plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).
10 CFR Part 73, Appendix G, il(b) requires that any other committed act not previously defined in Appendix G with the potential for reducing the efTectiveness of the safeguards system will be logged in a safeguards event log within 24 hours of discovery.
The opening paragraph of Attachment 3 to Security Procedure 1043.040, Revision 19, dated November 3,1992, provides examples of events that can be logged. Paragraph 6 of Attachment 3 to Security Procedure 1043.040 states, in part, that incomplete records or falsification of a minor nature, does not require a 1-hour report.
Contrary to the above, the inspectuc determined during the inspection conducted April 18-22,1994, that the licensee failed to log three incidents when they were notified on October 13, 1993, November 8,1993, and February 18, 1994, that self-screening contractor employees had falsified criminal history, employment information, and fitness-for-duty information.
This is a Severity Level IV violation. (Supplement 111) (313/9416-04; 368/9416-04).

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..       OCAN109402 Page 2 of 3 Response to violation 313/9416-04: 368/9416-04 (1) _R_gason for the violation Arkansas Nuclear One (ANO) acknowledges that derogatory information received concerning the three individuals was not entered into the Quarterly Safeguards Event Log within twenty-four hours of receipt.
Information concerning falsification or omission of derogatory information from access authorization documentation at another licensee facility was received following satisfactory termination of all three individuals from ANO. One individual had not falsified or omitted information used for granting access to ANO, and the incident about which ANO received notification occurred after he had left ANO. The other two individuals had been granted unescorted access to ANO based upon NUMARC 91-03 or INDEX electronic transfer from another licensee. Upon receipt of the derogatory information, in each instance ANO took administrative action to ensure that future unescorted access would not be authorized until satisfactory resolution was obtained.
The root cause of failing to place receipt of the derogatory information into the Safeguards Event Log has been determined to have been a cognitive error on the part of Access Authorization and Plant Security personnelin their failing to recognize the           ;
conditions as meeting any regulatory or procedural requirement for an event to be logged.
A contributing factor for this condition was a weakness in communication between Access      '
Authorization personnel who received the information and Plant Security personnel who were responsible for determining reportability of conditions related to security.             i (2) Corrective stegs taken and retulLs achieved A description of the condition involving the three individuals was placed into the Quarterly Safeguards Event Log on April 25,1994.                                                       '
i As stated in ANO's {{letter dated|date=June 7, 1994|text=June 7,1994, letter}} (OCAN069403) requesting clarification of              j requirements for logging and reporting access authorization concerns, subsequent to the NRC access authorization inspection ANO implemented what was believed to be a conservative interpretation of those requirements. ANO committed to logging within twenty-four hours receipt of derogatory information if the individual does not have a current authorization for unescorted access and reporting within one hour when unesconed access authorization is active. The NRC response dated September 16,1994, was received. The guidance contained in that letter appears to be inconsistent with the basis upon which this violation was issued. A telephone call was conducted on October 5, 1994, to obtain additional NRC clarification and a basis for the September 16,1994, NRC letter. Even though the call proved enlightening, it did not resolve the potential conflict with the basis for the NRC violation. Further correspondence requesting clarification is

  ,,. Attachment to
-       OCAN109402 Page 3 of 3 being prepared to request response to the ANO questions not addressed by the NRC on the October 5 call. ANO will continue the committed approach to logging and reporting of receipt of derogatory information until the recent NRC guidance, as clarified by future communications, has been incorporated into ANO procedures.
Plant Security personnel responsible for determining reportability of access authorization conditions were provided specific training on reporting requirements and material to assist them in identification of the appropriate criteria for logging or reporting.
The checklist used by access Authorization personnel to notify Plant Security when denying or revoking security access has been modified to prompt consideration ofissues related to reportability. Future notifications of access authorization conditions willinclude an initial reportability recommendation. To assist in making such recommendations, specific training was provided to Access Authorization personnel.
(3) Cprrective steps that will be taken to prevent fuither violations The NRC response to ANO's {{letter dated|date=June 7, 1994|text=June 7,1994, letter}}, as clarified by future communications, will be incorporated into ANO procedures, as appropriate, within thirty days of ANO's determination that satisfactory resolution of access authorization reporting requirements has been attained.
(4) Date when full compliance will be achieved Compliance with the concern identified by the NRC was satisfied on April 25,1994, when the condition was logged. Adoption of the interim guidance described above is believed to establish compliance for decisions regarding reporting or logging of future similar conditions, n
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