ML20150D070

Revised Response to NRC Re Violations Noted in Insp Repts 50-348/88-09 & 50-364/88-09.Corrective Actions: Document Control Personnel Instructed to Maintain Safeguards Containers in Locked Condition Except When in Use

ML20150D070
Person / Time
Site:	Farley
Issue date:	07/08/1988
From:	Hairston W ALABAMA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NT-88-0332, NT-88-332, NUDOCS 8807130283
Download: ML20150D070 (4)

Text

.. -.

. .- s NT 88-0332

• f - Alab+ma Power Comp',ny -

600 North 1Eih Street l Post Offee Box 2641

~ Birmingham, Alabama 35291-0400 Telephone 2052501837

- W. G. Hairston. Ill Senior Vice Preskient Nuclear Operatens Alabama Power the souhem eutre syvem July 8, 1988 Docket No. 50-348 Docket No. 50-364 U. S. Nuclear Regulatory Comission Attention: . Document Control Desk Washington, D. C. 20555  :

SUBJECT:

. Reply to a Notice of Violation J. M. Farley Nuclear Plant NRC Inspection of March 21 - 24, 1988 RE: Report Number 50-348/88-09-01 50-364/88-09-01

Dear Sir:

'Ihis letter refers to the violation cited in the subject inspection reports which states:

"On April 19, 1988, a Notice of Violation was issued for a violation of Nuclear Regulatory Comission (NRC) requirements. Alabama Power Company's (APC) response to the Notice of Violation was provided in a letter dated May 18, 1988. A restatement of the violation, a sumary of the licensee's ,

response, and a sumary of the NRC evaluation and conclusion are set forth below.

Restatement of Violation 10 CFR 73.21(a) requires protection of safeguards information against unauthorized disclosure. Information to be protected includes:

(b)(1)(vii) documents and other matters that contain lists or location of certain safety-related equignent explicitly identified in a document as vital for the purposes of physical protection, as contained in physical security plans; (b)(3)(1) portions of safeguards inspection  ;

reports, evaluations, audits, or investigations that contain details of the licensee's physical security system or that disclose uncorrected defects, weaknesses, or vulnerabilities in the system.

10 CFR 73.21(d)(2) requires that safeguards information shall be stored in a locked security container while unattended. ( ,

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t 1 U. S. Nuclear Regulatory Comission July 8, 1988 Page 2 Farley Nuclear Plant (FNP) Procedure AP-4, dated February 19, 1987, Revision 12, states in paragraph 6.1.1, safeguards information will be '

. stored in a locked security storage container when unattended. -he procedure additionally states in paragraph 6.2.1 that safeguards information is required to be under control of an authorized individual while it is in use to preclude unauthorized disclosure to persons who do not have a need to know.

Contrary to the above, on February 25, 1988, a Region II Nuclear

. Regulatory Comission inspector found a cabinet containing safeguards

~information unsecured and unattended.

Sumary of Licensee's Response We licensee denied that the violation occurred because, the document  ;

control area was attended by authorized personnel at the time in '

questicn; there were no unescorted visitors in the document control area during the time in question; that the inspector entering the document control area unchallenged and unescorted (sic., see note below) was irrelevant and that there was no procedural or regulatory requirement to keep the door leading into the saferoom locked.

I NRC Evaluation of the Licensee's Response We do not take exception with the licensee's statement that there 4 were no unescorted visitors in the document control area during the time in question; that the inspector entered the document control area

> unchallenged and was escorted by a safety Audit Engineering Review

^

(SAER) individual who was authorized in writing to have special access to the area; or that there is no procedural or regulatory requirement to keep the door leading to the room in question in a locked condition.

However, the inspector who identified the violation stated that the document control area was unattended, (other than a supervisor who was in his enclosed office with the door shut) and that there were no other document control personnel in the imediate area. Additionally, the inspector who reviewed the event was told that although visitor personnel were signed in at the owner-conttolled area, they were not continuously escorted while in the service building, and that all 1

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NCyrE Alt hama Power Ccmpany's response stated that the inspector ent > ring the document control area unchallenged was irrelevant because "he was being escorted by an SAER individual who is authorized in writing to have special access to the area."

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e- a U. S. Nuclear Regulatory Commission July 8, 1988 Page 3 cleared Farley Nuclear Plant personnel did not have a need for access to Safeguards Information, nor have a need to know. Therefore, the safeguards safe having been left unattended and unlocked, for a specific period, could have afforded a person without the need to know access to safeguards material.

Nhile reviewing your response, we also noted that you state in FNP-0-AP-72, Protection of Safeguards Information, implementing procedure in paragraph 6.2.1, that, "access to the document control ares is administratively controlled." Based on information from the inspector who identified the violation, there was not a Farley Nuclear Plant employee controlling access to the document control area; therefore, please address in your response to the violation: what administrative controls are used within the document control area.

Conclusion The licensee has not provided any information which was not previously considered; therefore, the violation occurred as stated in the Notice of Violation."

The original Alabama Power Company response stated, in part, "FNP-0-AP-72, Protection of Safeguards Information, Alabama Power company's implementing procedure, states in paragraph 6.2.1 that 'SGI is required to be under the control of an authorized individual while it is in use to preclude unauthorized disclosure to persons who do not have a need to know. 'Ihe requirement for control of SGI is met if the matter is attended by an authorized individual even though the information is not constantly being used.' Paragraph 6.2.3 states that, 'SGI also need not be maintained in locked storage containers while in use if located in protected or controlled access where visitors are escorted. This includes the following ne site locations:

(1) cor. trol rooms, (2) document control offices.'

The room containing the safeguards information in question is located within the document control area which is located in the Service Building within the confines of the FNP controlled area. Access to the Service Building is controlled by (1) security personnel at the owner controlled area gate and (2) security personnel at Central Security Control, where visitors are logged and issued a visitor's badge. Visitors must be authorized to enter the controlled area by an FNP supervisor or above. Access to the document control area is administratively controlled. Special access is authorized for supervisors and above and certain other personnel where routine work functions require frequent access to the area. All other personnel must obtain permission to enter the area behind the document issue counter. Safeguards material is secured when document control is unattended."

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U. S. -Nuclear Regulatory Conmission July 8, 19f3 Page 4 The administrative controls used to restrict access to document control include

(1) posting a list of personnel who have unrestricted access, (2) requiring personnel who do not have unrestricted access to obtain permission prior to entering the area, and (3) escorting visitors within the document control area.

FNP does not have any indication that visitors have been allowed access without an escort or that access to safeguards information has been granted to persons who do not have a need to know.

To' resolve the concerns expressed by the NRC, the following steps were taken:

1. Document control personnel have been instructed to maintain safeguards containers in a locked condition except when in use.

2. Document control personnel have been instructed on the importance of limiting access to safeguards information to only those individuals who have a need to know. .

In addition, FNP-0-AP-72 will be revised to provide guidance for implementing  ;

the above corrective actions. This will ba completed by October 1, 1988.

Affirmation I affirm that this response is true and complete to the best of my knowledge, 1 information, and belief. The information contained in this letter is not considered to be of a proprietary nature.

Yours very troly, W. G. Hairston, III WGWemb f

cc: Mr. L. B. Long Dr. J. N. Grace +

Mr. E. A. Reeves '

Mr. W. H. Bradford l

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