ML20115F915

Provides Response to Re Violations Noted in NRC Insp Repts 50-352/96-03 & 50-353/96-03.Corrective Actions: Comprehensive Review Performed & Verified No Other Safeguards Info Stored on Lan

ML20115F915
Person / Time
Site:	Limerick
Issue date:	07/15/1996
From:	Walter MacFarland PECO ENERGY CO., (FORMERLY PHILADELPHIA ELECTRIC
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9607180156
Download: ML20115F915 (3)

Text

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WIltar G. MacFar8and,IV, P.E.

Vice President A Limerick Generating Station )

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PECO NUCLEAR eem en-ov %ev PO Box 2300 l

i A UNir or PECO EMRcy Sanatoga, PA 19464 0920 l 610 718 3000 Fax 010 718 3008 Pager 1800 672 2285 #8320 July 15,1996 l

Docket Nos. 50-352 50-353

! License Nos. NPF-39 l NPFa5 l

! U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555 i

SUBJECT:

Limerick Generating Station, Units 1 and 2 l Response to An Apparent Violation NRC Inspection Report Nos. 50-352/96-03 and '

50-353/96-03 This letter provides PECO Nuclear's response to an apparent violation for Limerick Generating Station (LGS), Units 1 and 2, that was contained in your letter dated June 13,1996, which forwarded the subject NRC Inspection Report.

The apparent violation concerns improper control of safeguards information in that an electronic copy of the LGS Physical Security Fian was discovered on the PECO Energy Company local area computer network (LAN). The reason for the apparent violation, the immediate corrective steps taken, and the corrective .

steps taken to avoid future violations were previously described in a Special Report that was submitted to the NRC by letter dated May 13,1996, pursuant ,

l to the requirements of 10CFR73.71(a)(4). Compliance was achieved on April 11,1996, when the computer file containing the copy of the Physical Security Plan and the associated system recovery backup file were deleted.

Overall, LGS has implemented an effective Security program as evidenced by l our positive relationship with the NRC over the past two years. This apparent violation was non-willful in that it was caused by an inadvertent error while i typing a proposed revision to the LGS Physical Security Plan.

i The apparent violation was identified by a LGS licensed operator, who is l l; authorized to review safeguards information, before the problem resulted in an TEDI ' o 4 96o7180156 96o715 '

i PDR ADOcK 0500o352' i G PDR 1

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l Docket Nos. 50-352 and 50-353 July 15,1996 Page 2 i

i everJ mf any adverse consequence. In addition, prior opportunities to identify the problem were unlikely considering that the name of the file on the LAN did i not indicate any relationship to safeguards information, and LAN users typically  !

store information on their own data drives rather than the applications drive l where the subject file was located. For these same reasons the probability of individuals purposely accessing the file was extremely low.

The corrective actions in response to the apparent violation were prompt and

! comprehensive. Upon discovery, immediate actions necessary to restore safety l and compliance with NRC requirements were taken. When the licensed ,

l operator discovered the file, the LGS Security Section was immediately notified. l PECO Energy computer personnel were then contacted. The file was immediately encrypted so the information could not be read, and was subsequently deleted. A comprehensive review was performed and verified that no other safeguards information was stored on the LAN. In addition,

, precautionary measures involving a heightened state of LGS security were

! taken. Regarding actions to prevent recurrence, the generation and revision to safeguards information maintained by the LGS Security Section are now performed on a designated stand-alone PC that is controlled by the LGS Security Section. Also, the LGS Security Section secretary was retrained on the requirements and procedures for control of safeguards information prior to being allowed access to any additional safeguards information. With respect to generic implications, this event was reviewed by the Nuclear Security Section at PECO Nuclear Headquarters and the Security Section at Peach Bottom Atomic Power Station for applicability of similar actions.

l During preparation of this response to the apparent violation, a separate issue concerning the control of drawings containing safeguards information was identified at an offsite PECO Energy Company location and notification was made to the NRC on July 2,1996, in accordance with 10CFR73. A followup notification was made to the NRC on July 10,1996, based on updated l information from the ongoing investigation of this other issue.

As a result of these combined issues, the overall control of safeguards

! information is currently being evaluated. The NRC will be notified of the results l of this evaluation in a Special Report that is scheduled to be submitted to the i NRC by August 1,1996.

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Docket Nos. 50-352 and 50-353 July 15,1996 Page 3 If you have any questions or require additional information, please contact us.

Ve truly yours, r i

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NwxkjbW}

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m cc: T. T. Martin, Administrator, Region I, USNRC j N. S. Perry, USNRC Senior Resident inspector, LGS

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! COMMONWEALTH OF PENNSYLVANIA  :

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SS COUNTY OF MONTGOMERY  :

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W. G. MacFarland, being first duly sworn, desposes and says:

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That ha is Vice President of PECO Energy Company; that he has read the attached response to an Apparent Violation for Limerick Generating Station, Units 1 and 2, and knows the contents thereof; and that the statements and matters set forth l

l therein are true and correct to the best of his knowledge, information and belief.

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b) 72 ech ) Y TAM d -

l Vice Pres.i dent f-l Subscribed and sworn to before me this 15% day of o 1996.

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! Notary Public i

' Notariint Seal Demis P. Wesley, Notary PikAc UmerickTg.,phangpnery County W Commssion Expres Aprs 7, tw7 j h. Wee Assooanon at Nobnes 4