ML20006E864

Suppl Response to NRC 890725 Ltr Re Safeguards Info Violation Noted in Insp Rept 50-305/89-09.Corrective Action: Section V of General Employee Training Manual Security Removed

ML20006E864
Person / Time
Site:	Kewaunee
Issue date:	02/19/1990
From:	Evers K WISCONSIN PUBLIC SERVICE CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
CON-NRC-90-21 NUDOCS 9002260453
Download: ML20006E864 (4)

Text

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NRC-90 i TELECOPlER (4141433-5544; EASYLINK 62891993 t

-- f . , .WISCONSON PUSUC SERVICE CORPORATION 600 North Adams e P.O. Box 19002

• Grean Bay, WI 54307-9002 E

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' February.'19, 1990

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, 1 U. S'.~ Nuclear Regulatory Commission ATTN: Document Control Desk-

_ Washington, D.C.- 20555.

LGentlemen: m ya  ; Docket 50-3051 _

y Operating License'DPR-43 s -Kewaunee Nuclear. Power Plant

' Response to Safeguards Information Violation

References:

.1) . Letter to- C. R. Steinhardt from L. R. Greger dated July 25; 1989

.-2) Letter to Document Control Desk from K. H. Evers dated August 24,-

1989 3)~ Letter to K. H. Evers from C. E.;Norelius dated January 18, 1990- ,

Jln' reference 2,-WPSC providediour response to the Notice of' Violation (violation-

-A); identified inLreference 1. WPSC disputed this violation:and requested that

, , the matter be reviewed by NRC-management:for validity and potential generic

' 5 impact. .In> reference 3'the' NRC responded by stating that. the results of- their: .

,s' , review concluded that the violation was valid. l Consequently, as required by thec  !

provisions of.10 CFR 2.201, Attachment 1 to this. letter provides the. corrective.

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actions WPSC . intends to

take to avoid further violations

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Pi J Sincerely,

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-tc' ih.K.H.Evers

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Manager: -FNuclear Power

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?( l Attach.

< Ecc:- US NRC; Region Ill 1 P Mr. Patrick Castleman, US NRC - w/o attach. ,

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,LDocumentLControl Desk- SEC20.2 c Jebruary 19 1990 Attachment 1. Page 1 Attachment 1 .l

References:

1) Letter to Document Control Desk from K. H. Evers dated '

August ~24, 1989

2) Letter to K._H. Evers from C.-E. Norelius dated. January 18, 1990.

This attachment provides our response to reference 2 concerning the notice of violation (N0V) on~ Safeguards Information'(SI) identified in Inspectio'n Report 50-305/89009. WPSC-initially responded in reference 1 by disputing the viola-tion based on the definition of SI provided in 10 CFR 73.2 and the information. '

contained in various NUREG documents. Subsequent to reference 2 WPSC was pro- '

vided with additional NRC guidance during several telephone conversations with

'J. Creed from NRC Region III. From these discussions WPSC has the following understanding as to what constitutes SI. t l

. Safeguards Information would include documents where general information, a spe'cific piece of equipment or area specific to KNPP is identified and

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i in the same location of the document it is explicitly stated that the general information, equipment or area. is ' vital from the standpoint of physical protection.

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Documents which state that a particular piece of equipment or area at KNPP is vital for the purpose of safe plant shutdown would not be considered safeguards information unless the document also explicitly relates the equipment or . area to the physical protectian of the f acility.

i The'following provides our short term and long term corrective actions to address.this violation, c

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Decument Control Desk

.- February 19, 1990-

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Attachment:

1,-Page 2 g Short' Term Corrective Actions F

As previously stated in reference 1 the known copies of the General Employea Training (GET) Manual remaining in WPSC possession are being treated as

' Safeguards Information unless Section V " Security" has been' removed'from the GET Manual. Furthermore, this interpretation was presented during the recently administered-GET sessions.

Long Term Corrective Action Tne'following long term corrective actions are planned to address this concern.

GET Manual .

Should any additional copies of the General Employee Training (GET) Manual come into WPSC possession, either: 1) Section V " Security" will be -

removed, 'or 2) the manual will be controlled as Safeguards Information.

i Adr.iinistrative Cont'rol Directives (ACDs) q The following ACDs wil1~ be changed to addruts this concern.

ACD 11.9 Security Safeguards Information  !

i This ACD will be changed to provide additional guidance on what constitutes safeguards,information. The change will specifically address the guidance  :

and interpretations resulting from this NOV. ACD 11.9 will be revised prior to the end of June 1990.

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L. Document Control Desk:

L' ,,' February 19, 1990 2 Attachment 1 L Page:3 ACD 2.6 Plant Procedures ,

This ACD will'be changed to incorporate a step requiring procedures to be reviewed against'the guidance of ACD 11 9. ACD 2.6 will be revised prior to the' end of June 1990. Plant procedures will be reviewed against this

,. ACD during their normal review period.

Other Documents

, a lastly, personnel will be informed of the revisions made to ACD 11.9 and-  ;

reminded of their responsibility to review their documents against ACD 11.9 .

during the document's normal review period. Should Si be discovered (by any personnel) in a document outside-of its normal review period, the

.information shall be handled in accordance with the requirements of ACD 11.9.

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