IR 05000285/1998003
| ML20217M601 | |
| Person / Time | |
|---|---|
| Site: | Fort Calhoun  |
| Issue date: | 03/27/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20217M589 | List: |
| References | |
| 50-285-98-03, 50-285-98-3, NUDOCS 9804080139 | |
| Download: ML20217M601 (16) | |
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ENCLOSURE U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
Docket No.:
50-285 License No.:
DPR-40 Report No.:
50-285/98-03 Licensee:
Omaha Public Power District Facility:
Fort Calhoun Station Location:
Fort Calhou * Station FC-2-4 Adm.
P.O. Box 399, Hwy. 75 - North of Fort Calhoun Fort Calhoun, Nebraska Dates:
February 23-27, March 11 and 18,1998 Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment:
Supplementallnformation 9804000139 980327
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PDR ADOCK 05000285 G
PDR u
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,4 2-EXECUTIVE SUMMARY Fort Calhoun Station NRC Inspection Report 50-285/g8-03
- This was an announced inspection of the licensee's physical security program. The areas inspected included access authorization, alarm stations, communications, access control of
. personnel and packages, assessment aids, security program plans and procedures, security event logs, management support, security program audits, and review of previous inspection findings.
Plant Sunoort i
Performance in the physical security area remained at a high level, except for one
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problem noted regarding compensatory measures. Senior management support for the security organization was very good, and security program audits were very thorough
. and excellent quality. Very good radio and telephone communication systems and a
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very good program for searching personnel and packages were maintained.
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Assessment aids provided a high quality and complete assessment of the perimeter detection zones. A very good security event reporting program was in place. The alarm
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stations were redundant and well protected. (Sections S1.2, S1.3, S1.4, S2.1, S3.2, S6.1 and S7.1)
A noncited violation was identified involving the licensee's failure to implement
. compensatory measures for a degrsded perimeter alarm zone. (Section S8.4)
The licensee's Quality Assurance Audit determined that the access authorization
program was only marginally effective. (Section S1.1)
A noncited violation was identified involving the licensee's failure to: (1) verify activities
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during interruptions of employment in excess of 30 days for five individuals, (2) perform an adequate criminal history record check for one individual, (3) verify a military period of service for one individual, and (4) document verification of identity for six individuals.
.(Section S1.1)
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An unresolved item was identified involving a background investigation file. The licensee
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continued wgh its investigation of the file. (Section S1.1)
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-3-Report Details IV. Plant Suonort
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S1 Conduct of Security and Safeguards Activities Sl.1 Access Authorization _
a.
Insoection Scooe (81700-02.01)
The Access Authorization Program was inspected to determine compliance with the requirements of the security plan and Regulatory Guide 5.66. The areas inspected included the review of background investigation files for individuals presently granted unescorted access and forindividuals that have been denied unescorted access. Nine background investigation files were reviewed.
b. -
Observations and Findinas The inspector reviewed records and conducted interviews to determine the adequacy of the program. The inspector also reviewed information conceming the licensee's verification of identity, employment history, educational history, credit history, criminal history, military service, and the character and reputation of the applicants before granting individuals unescorted access to protected and vital areas.
Five of the nine background investigation files had resulted in denial of access. The files were complete and thorough. The licensee's program for denying or revoking unescorted access authorization was good. The inspector reviewed the rationale used by the licensee in its decision for denial. The persons denied accesses were notified of the denial of access and of their right to review and reply to anything in the records used as a reason for the access denial. These persons were also provided with information on the appeal process that was available to them.
(1)
Quality Assurance Audit During this inspection, the inspector reviewed Quality Assurance Audit Report 73,
" Access Authorization / Personnel Access Data System (PADS)," dated September 22,1997. This audit, conducted by the licensee's Quality Assurance Department from August 14 through September 2,1997, identified multiple problem areas and concluded that the Fort Calhoun Access Authorization program was only marginally effective and in need of management attention. The inspector verified that the licensee had completed corrective actions for the identified problems. The following items were identified during this audit:
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-4-Verification of Activities Durina Interruotions of Emolovment
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The Quality Assurance Audit Report identified that the background investigation file for three individuals did not verify activities during interruptions of employment in excess of 30 days.
(2)
Intemal Audit Reoort.
During this inspection, the inspector also reviewed the licensee's internal audit of access authorization files dated December 9,1997. This comprehensive corrective-action audit, conducted by the Security Department from November 3-21,1997, included a 100 percent review of active background investigation files for individuals granted unescorted site access. The audit was performed in response to previous NRC (access authorization) enforcement actions and the above Quality Assurance Audit had been designed to identify and prevent recurrence of previously identified violations and noncited violations.
This audit identified the following failures regarding the implementation of the Appendix to Regulatory Guide 5.66 (NUMARC 89-01):
(1)
Failure in 1989 and 1991 to verify activities during interruptions of employment in excess of 30 days for two individuals.
(2)
Failure in 1990 to perform a proper criminal history record check via submitting a legible fingerprint card for one individual.
(3)
Failure in 1991 to verify a military period of service by receipt of Form DD-214 for one individual.
(4).
Failure in 1991 and 1992 to document the verification of identity for six individuals.
Additionally, during the intemal audit, the security department identified that the background investigation record for an individual included a notation that the educational institution had been unable to verify his claimed education and that this matter had not been previously adjudicated by the licensee. During the inspection, the licensee stated that, as a result of the audit, this matter was under investigation. The licensee's adjudication of the individual's claimed education is an unresolved item pending review by the licensee (URI 50-285/9803-01).
During the inspection, the inspector verified the licensee's corrective actions for the items identified during the Quality Assurance Audit and the intemal audit.
License Condition 2.C of the licensee's facility operating license requires, in part, that the licensee maintain in effect and fully implement all provisions of the commission-approved physical security plan, including amendments and changes made pursuant to the authority of 10 CFR 50.54(p).
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-5-Section 6.0 of the licensee's physical security plan states, in part, that,
" Individuals requiring unescorted access to the protected and vital areas of Fort Calhoun Station shall be authorized such access in accordance with Regulatory Guide 5.66, June 1991, and its appendix, which satisfies the requirements of 10 CFR 73.56."
Section 6.2.1 (Employment History) of the Appendix to Regulatory Guide 5.66 (NUMARC 89-01) requires, in part, that activities during interruptions of employment in excess of 30 days be verified.
The Appendix to Regulatory Guide 5.66 (NUMARC 89-01) addresses the following requirements:
Section 6.2.1 (Employment History) requires, in part, that activities during
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interruptions of employment in excess of 30 days be verified.
. Section 6.2.3 (Criminal History) requires, in part, that a criminal history
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record check through the Federal Bureau of Investigation be performed.
Section 6.2.4 (Military Service) requires, in part, that a military period of
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service within the last 5 years be verified through the National Personnei Records Center by receipt of a Form DD-214.
Section 6.2.6 (Verification of Identity) requires, in part, that identity be
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verified.
The licensee's failure to: (1) verify activities for five individuals during interruptions of employment in excess of 30 days, (2) perform an adequate criminal history record check for one individual, (3) verify a military period of service for one individual, and (4) document the verification of identity for six individuals is a violation of Section 6.0 of the physical security plan. Portions of this violation were similar to previous enforcement actions identified in NRC -
Inspection Reports 50-285/97-08 and 50-285/97-12, however, all portions of this violation occurred prior to these enforcement actions. Further, this violation was identified as part of corrective actions for previously issued violations and noncited violations. Therefore, this nonrepetitive, licensee-identified and
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corrected violation is being treated as a noncited violation consistent with
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Section Vll.B.1 of the NRC Enforcement Policy. (50-285/9803-02)
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During the exit meeting on February 27,1998, the inspector identified the above
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issues as part of an unresolved item. On March 11,1998, Mr. D. Schaefer (NRC inspector) telephonically notified Mr. G. Cavanaugh, licensing engineer at Fort Calhoun Station, that the unresolved item had been dispositioned. On March 18, 1998, Mr. J. Till, licensing manager at Fort Calhoun Station, identified to Mr. B. Murray of this office that the corrective-action internal audit had it been completed prior to the quality assurance audit would have identified all of the enforcement items in the quality assurance audit. As a result, the problems
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0-6-identified in the quality assurance audit and the internal audit were dispositioned
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as part of the licensee's corrective actions for previous enforcement actions.
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Conclusions-The licensee's Quality Assurance Audit Report determined that the access authorization program was only marginally effective. A noncited violation was identified involving the licensee's failure to: (1) verify activities during interruptions of employment in excess of 30 days, (2) perform an adequate criminal history record check. (3) verify a military period of service, and (4) document verification of identity. An unresolved item was identified involving the licensee's investigation of a background investigation file.
1.2 Alarm stations a.
Insoection Scone (81700-02.01) -
The alarm stations were inspected to determine compliance with the requirements of the security plan. The areas inspected included the requirements and capabilities of the alarm stations, redundancy and diversity of stations, protection of the alarm stations, and systems security.
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Observations and Findinas The inspector verified the redundancy and diversity of the alarm stations. Action by one alarm station operator could not reduce the effectiveness of the security systems without the knowledge of the other alarm station operators. The central alarm station and secondary alarm station were bullet resistant. The inspector questioned the station operators and determined that they were properly trained and knowledgeable of their duties, c.
Conclusions The alarm stations were redundant and well protected. Alarm station operators were alert and well trained.
~ S1.3 Communications a.'
insoection Scone (81700-02.01)
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Tne communication capabilities were inspected to determine compliance with the j
requirements of the security plan. The areas inspected included the operability of radio J
and telephone systems and the capability to effectively communicate with the local law
-. enforcement agencies through both of the systems.
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Observations and Findinos The inspector verified that the licensee had very good radio and telephone systems capable of meeting all communication requirements of the security organization. The licensee maintained an adequate number of portable radios for use by members of the security organization.' The licensee also had a maintenance program to insure that the batteries for the portable radios remained at maximum operating power.
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Conclusions Very good radio and telephone communication systems were maintained. An adequate number of portable radios was available for members of the security organization.
S1.4 Protected Area Access Control of Personnel and Packsces a.
Insoection' Scoos (81700-02.01)
- The access control program for personnel packages and vehicles was inspected to determine compliance with the requirements of the security plan.
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Observations and Findinos The inspector determined through observations at the primary access facility that the licensee properly controlled access of personnel and packages to the protected area.
-The protected area access control equipment was inspected and found to be functional and well maintained. The inspector also observed use of the X-ray machine and search of packages and material at the primary access facility. The operators were efficient and well trained.
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Conclusions A very good program for searching personnel and packages was maintained.
S2 Status of Security Facilities and Eauspment
- S2.1 Assessment Aids -
a.
insoection Scooe (81700-02.02)
' The inspector reviewed the assessment aids to determine compliance with the physical security plan. The areas inspected included the closed-circuit television monitors located in the alarm stations, b. '
Observations and Findinos The inspector observed the assessment aids during the hours of daylight from February 25-26,1998, and determined that the licensee overall assessment aids system
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-8-was very good. The inspector verified through observation that the fixed closed-circuit television cameras were positioned to ensure proper coverage of the perimeter security alarm zones. Without exception, the camera resolution was excellent. The inspector determined through interviews that licensee technicians provided excellent service support.
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Conclusions Assessment aids provided a high quality and complete assessment of the perimeter detection zones.
S3 Security and 4:afeguards Procedures and Documentation S3.1 Security Proaram Plans and Procedures a.
Insoection Scone (81700-02.03)
The physical security plan and the implementing procedures were inspected to determine compliance with the requirements of 10 CFR 50.54(p) and the physical security plan.
b.
Observations and Findinos The inspector determined that previous plan changes were submitted within the required time frame and changes submitted did not reduce the effectiveness of the plan. The inspector reviewed six implementing procedures for adequacy, ensured that the licensee maintained an effective management system for the development and administration of procedures, and that changes to the procedures did not reduce the effectiveness of the
licensee's security program.
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Conclusions Changes to security programs and plans were reported within the required time frame.
Overall, implementing procedures met the performance requirements in the physical security plan.
S3.2 Security Event Loas a.
Insoection Scnce (81700-02.03)
The inspector reviewed safeguards event logs and security incident reports to determine compliance with the requirements of 10 CFR 73.21(b) and (c),10 CFR 26.73, and the physical security plan.
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Observations and Findinas.
The inspector reviewed the incident Report Log (socurity event log) from April 1,19g7, through February 12,1998. The records were available for review and maintained for the time required by regulations. The inspector determined that the licensee conformed
. to the regulatory requiremente egarding the reporting of security events. The inspector also reviewed eight SecurityJ.ut.Jent Reports. The logs and supporting reports were
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accurate, neat, and contained sufficient detail for the reviewer to determine reportability
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and corrective action taken. The licensee's records included trending and analysis of events.
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Conclusions A very good security event reporting program was in place. The security staff was correctly reporting security events. The security incident reports were accurate and neat.
- 86 L Security Organization and Administration S6.1 lAanagement Support
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In==edian %na (81700-02.06)
.The effectiveness and adequacy of management support were inspected to determine the degree of management support for the physical security program, b. '
Observations and Findings
' The inspector determined by discussions with security force personnel that the secunty program received very good support from senior management. The inspector determined that the security program was implemented by a trained and qualifed security staff. All members of the security organization had a clear understanding of their duties and responsibilities.
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Conclusions Senior management support for the secu*v organization was very good. The security program was implemented by a trained and qualified staff.
. Quality Assurance in Security and Safeguards Activities S7.1 Security Proaram Audits
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- Insoection Scooe (81700-02.07)
The audits of the security program were inspected to determine compliance with the requirements of 10 CFR 50.54(p) and the physical security plan.
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Observations and Findinas The inspector verified that security program audits had been conducted at least every.
12 months as requiredi The inspector reviewed three Quality Assurance Audits listed in the attachment. - The inspector interviewed audit personnel and confirmed that they were -
independent of plant secunty management and plant security management supervision.
'The inspector determined that the audits of the Security Plan and Contingency Plan, the
- Access Authorization / Personnel Access Data System (PADS) System, and the Fitness-for-Duty program were thorough and of excellent quality.
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Conclusions Security program audits were very thorough and of excellent quality.
Miscellaneous Security and Safeguards issues (92700,92702,92904)
i S8.1 ' (Closed) Violation 285/9708-02: Failure to Submit a i anima Emolovee Finaerorint Card During a previous security inspection, the inspector determined that the licensee had
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j failed to obtain a legible fingerprint from an employee. The original fingerprint had been categorized by the FBI as an " illegible print" and was retumed to the licensee. The
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licensee had determined that this fingerprint card was the "best obtainable".and did not submit a second fingerprint card even though this individual had been continuously employed at the plant. During the May 16,1997, exit meeting the licensee stated,that as corrective measures, the employee had recently been refingerprinted. The inspector had
. previously verified the licensee's corrective actions.
During this inspection, the inspector reviewed nine background investigation records for.
Individuals granted unescorted plant access. All records included a legible fingerprint card.
Additionally, the inspector reviewed the licensee's intemal audit of (active) access authorization files dated December 9,1997. The licensee stated that this corrective-action audit had been completed, in part, in response to this earlier violation.
This event is discussed in Section S1.1(b) above.
S8.2 - (Ooen) Insoection Followuo item 285/9712-01: Summary Descriotion of the Measuregjp Protect Aaminst a Land Vehicle Bomb During a previous security inspection, the inspector determined that the installed vehicle barrier system satisfied regulatory requirements. However, the following features were not documented in the licensee's July 31,' :595, summary description of the vehicle barrier system:
The vital areas that are protected by the vehicle barrier system and the minimum
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standoff distance that exist for each of the vital areas.
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-11-That a narrow gravel roadway exists between the chain link fences and the
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Missouri River and that this feature has been analyzed using the Barrier impact Response Model (BIRM) engineering computer program.
That two exterior walls of the security building form part of the vehicle barrier
system.
Dunng this inspection, the licensee's nuclear design engineer discussed with the inspector the revised (draft) calculation of the measures to protect against a land vehicle bomb. The licensee stated that its revised draft summary description of the vehicle barrier system included the above three items and should be completed and submitted to the NRC within 3-4 months. This followup item remains open.
S8.3 (Ocen) Insoection Followuo item 285/9712-02: Summary Descriotion of Bomb Blast Analvsis During a previous security inspection, the inspector determined that the licensee's July 31,1995, summary description of the measures to protect against a land vehicle bomb did not include documentation that the roofs, air intakes, and air exhausts of the required vital area buildings were included in the blast analysis.
During this inspection, the licensee's nuclear design engineer discussed with the inspector the revised (draft) calculation of the measures to protect against a land vehicle bomb. The bomb blast analysis included the roofs, air intakes, and air exhausts of the required vital area buildings. The licensee stated that its final review of the revised summary description should be completed and submitted to the NRC within 3-4 months.
S8.4 (Closed) Licensee Event Reoort 285/9714-00: Failure to Imolement Timelv Comoensatorv Measures for a Dearaded Perimeter Alarm Zone
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In accordance with 10 CFR 73.71(b)(1), the licensee telephonically reported to the NRC on August 31,1997 (Event No. 32851) that a portion of the perimeter alarm system had been degraded and that compensatory measures had not been taken within 10 minutes of discovery, On September 26,1997, the licensee submitted its report of this event.
The licensee's investigation determined that at approximately 6:45 a.m., August 31, i
1997, a perimeter microwave security alarm on Zone 2 was received in the central alarm station (CAS) and the secondary alarm station (SAS). The CAS operator: (1) assessed the alarm via closed circuit television (CCTV) determining that the alarm was caused by birds, (2) acknowledged the alarm, and (3) monitored the alarm zone via CCTV.
However, the CAS operator failed to implement compensatory measures within 10 minutes by resetting the alarm. The primary duty of the CAS operator was to monitor the alarm and to reset the alarm as soon as possible. Concurrently, the SAS operator received the security alarm. Also, observed via CCTV that the alarm had been caused by birds, however, failed to realize that the CAS operator had not reset the security alarm for more than 10 minutes. The function of the SAS operator was to provide backup support to the CAS in the event CAS failed to perform its required duties. At 7 a.m.,
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' August 31,1997, a new CAS operator discovered that the Zone 2 security alarm was
"pending" and reset the security alarm. The licensee determined that approximately
.15 minutes elapsed from the time the alarm was received to the time the alarm was reset.. During this period, security perimeter alarm Zone 2 was incapable of receiving and processing additional security alarms. A search of the protected and vital areas was completed. No discrepancies were noted from the search.
The licensee's investigation'deterrr,ined that the root cause of this event was a lack of attention to detail by the CAS and SAS operators allowing the alarm stations to leave Zone 2 in alarm beyond the 10 r,iinute criteria. Additionally, the licensee identified a lack of communication between the CAS and SAS operators on the status of the Zone 2 alarm.- The licensee determined that this event had no impact on nuclear safety and no direct impact on plant reliability, availability or personnel safety.
During this inspection, the inspector reviewed the event and verifMHf that the licensee had completed the following corrective actions:
Reemphasis of the responsibilities of alarm station operators conceming the
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resetting of alarms and a review of the event with the security personnel. Alarm station operators involved in this event were retrained on their duties and responsibilities.
- A memorandum was issued to sergeants and alarm station operators reviewing
the event and reiterating expectations conceming the monitoring and the resetting of alarms, particularly during shift changes.
The security event and the root cause analysis were reviewed with security.
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personnel during general security force meetings.
A security training information notice was issued to review procedures goveming
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response time to alarms and primary responsibilities of the CAS and SAS operators.
Alarm station operators and the shift security supervisor involved in this event
received appropriata disciplinary action.
Section 2.2.4.A.1 of Security Operational Procedure SECOP-31, "CAS/SAS Operating Procedure," requires that the CAS operator respond to protected area perimeter alarms as follows:
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"The CAS operator willinitially assess the alarm using the Closed Circuit
- Television (CCTV) alarm monitors. If a reason for the alarm is immediately observed by CCTV assecament, and is such that a Nuclear Officer response is not required (i.e., animai in zone) and the alarm has returned to normal, the CAS opera'or may acknowled ie and reset the alarm using 'CCTV for the dispatch -
t code and the appropriate cause cure code."
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Section 2.2.6 of Security Contingency Procedure SCP-04, " Compensatory Measures,"
requires that compensatory measures for unplanned losses and degradations will be in place within 10_ minutes of discovery /
The failure to implement compensatory measures for a degraded perimeter alarm zone within 10' minutes of discovery is a violation of Section 2.2.6 of Security Contingency-Procedure SCP-04. This nonrepetitive, licensee-identified, and corrected violation is -
being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy. ' (50-285/9803-03)
S8.5 (Closed) Information Notice 98-05: Criminal Historv Record Information Information Notice 98-05, dated February 11,1998, was issued to aleit licensees to a recent clarification of the legal constraints associated with Criminal History Record Information from the Federal Bureau of Investigation (FBI). Specifically, the FBI has
- reiterated its position that this information provided by the FBI to the NRC'and its licensees may not be released to third parties, such as contractors.
During this inspection, the licensee indicated that they had received this Notice and had reviewed it for applicability at Fort Calhoun Station. Following their review, the licensee determined that their current practice and procedures were adequate, and additional actions were not needed.
V. Management Meetings XI Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on February 23,1998. The inspector identified, as an unresolved item, the results of the licensee's audits of the access authorization program,
' discussed in Section S1.1 above. The licensee acknowledged the findings presented.
On March 11,1998, the inspector telephonically notified Mr. G. Cavanaugh, Fort Calhoun Station that the unresolved item had been dispositioned. On March 18,1998, Mr. J. Till, Licensing Manager, Fort Calhoun Station, discussed the results of licensee audits of the Access Authorization Program with Mr. B. Murray of this office. Additionally, the added unresolved item was discussed.
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ATTACHMENT SUPPLEMENTAL INFORMATION PARTIAL LIST OF PERSONS CONTACTED Licensee J. Bishop, Acting Manager, Nuclear Assessment J. Chase, Plant Manager S. Gambhir, Manager, Engineering and Operations Support Division D. Gross, Supervisor, Security Training T. Herman, Lead Auditor (Security), Quality Assurance B. Kindred, Supervisor, Security Operations D. Leiber, Supervisor, Security Support Services M. Roberts, Supervisor, Access Authorization Programs H. Sefick, Manager, Security Services W. Woerner, Specialist, Security Systems K. Woods, Nuclear Design Engineer NBC w
W. Walker, Senior Resident inspector INSPECTION PROCEDURES USED IP 81700 Physical Security Program for Power Reactors IP 92700 Onsite Followup of Written Reports of Non Routine Events at Power Reactor Facilities IP 92702 Followup on Corrective Actions for Violations IP 92904 Followup - Plant Support LIST OF ITEMS OPENED, CLOSED AND DISCUSSED items Ooened 50-285/9803-01 URI Licensee investigation of a Background investigation File 50-285/9803-02 NCV Failure to Perform Complete Background Investigations 50-285/9803-03 NCV Failure to implement compensatory measures for a degraded perimeter alarm zone
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Items Closed 50-285/9708-02 VIO Failure to Submit a Legible Employee Fingerprint Card 50-9714-00 LER Failure to implement Timely Compensatory measures for a Degraded Perimeter Alarm Zone 50-285/9805 IN Information Notice: Criminal History Record Information j
ltems Discugged 50-285/9712-01 IFl Summary Description of the Measures to Protect Against a land Vehicle Bomb 50-285/9712-02 IFl Summary Description of Bomb Blast Analysis LIST OF DOCUMENTS REVIEWED
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incident Report Logs from April 1,1997 through February 12,1998 Background investigation records for four individuals granted and for five additional individuals denied unescorted access authorization Audit / Surveillance Reoorts Quality Assurance Audit Report No. 70, " Fitness for Duty," dated February 9,1998 Quality Assurance Audit Report No. 6, " Site Security Plan and Contingency Plan," dated August 12,1997 Intemal Audit of Access Authorization Files (Active Records), dated December 9,1997 lmolementina Procedures Security Administrative Procedure SAP-10," Preparation, Approval and Distribution of Security Plans and Procedures," Revision 3
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Security Administrative Procedure SAP-18, " Security Badge Processing, Control and Accountability," Revision 11 Security Administrative Procedure SAP-30, " Conducting Background Investigations," Revision 8 Security Operating Procedure SECOP-6, " Personnel Access Control," Revision 14
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e-3-Security Operating Procedure SECOP-8, " Access Portal Search Equipment," Revision 9 Security Contingency Procedure SCP-04, " Compensatory Measures," Revision 16 l
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