IR 05000298/1996029
| ML20133F460 | |
| Person / Time | |
|---|---|
| Site: | Cooper  |
| Issue date: | 01/08/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20133F448 | List: |
| References | |
| 50-298-96-29, NUDOCS 9701140192 | |
| Download: ML20133F460 (14) | |
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ENCLOSURE 1 U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
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Docket No.:
50-298 l
License No.:
DPR-46 Report No.:
50-298/96-29 l
Licensee:
Nebraska Public Power District Facility:
Cooper Nuclear Station Location:
P.O. Box 98 Brownville, Nebraska Dates:
December 9-13,1996 Inspector:
Thomas W. Dexter, Senior Physical Security Specialist -
Approved By:
Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment:
SupplementalInformation l
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9701140192 970108
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PDR ADOCK 05000298 G
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j-3-EXECUTIVE SUMMARY Cooper Nuclear Station NRC inspection Report 50-298/96-29 This routine, announced inspection focused on the licensee's physical security program.
The areas inspected included review of commitments in the updated final safety analysis report, records and reports, testing and maintenance, alarm stations and communications, security program plans and procedures, compensatory measur 3s, access control of personnel and packages, personnel training and qualification, raanagement support, security program audit, and review of previous inspection findings.
Enaineerina The Updated Final Safety Analysis Report (UFSAR) was consistent with the
observed plant physical security plan and procedures (Section E2).
Plant Support A very good records and reports program was in place. The security staff was
correctly reporting security events. Analysis of trending information could be improved (Section S1.1).
Security systems were repaired in a timely manner. An excellent testing and
maintenance program was conducted and properly documented (Section 2.1).
Alarm stations were redundant and alarm station operators were knowledgeable of
their duties. Communications capabilities were in accordance with security plan requirements (Section 2.2).
Security plan changes were submitted in accordance with NRC requirements and
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the changes did not decrease the effectiveness of the plans. Security procedures were consistent with the security plans (Section 3.1).
The compensatory measures program was effectively implemented. Security
personnel were well trained on compensatory program requirements (Section 4.1).
An effective program for searching personnel, packages, and material was
maintained. Security personnel operating the equipment were well trained (Section 4.2).
An effective security training program had been implemented (Section 5.1).
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-4-Licensee management support for the security program was very good
(Section 6.1).
The annual security program audit was performance based. The overall quality of
the audit was excellent (Section 7.1).
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Report Details
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Ill. Enaineerina i
E2 Review of Commitments in the Updated Final Safety Analysis Report (UFSAR)
A recent discovery of a licensee operating its facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, l
procedures and/or parameters to the UFSAR description. While performing the inspection l
discussed in this report, the inspector reviewed the applicable portions of the UFSAR that related to the areas inspected. The inspector verified that the UFSAR wording was l
consistent with the observed plant practice, procedures and/or parameters.
IV. Plant Support S1 Conduct of Security and Safeguards Activities l
Sl.1 Records and Reports (81700-02.01)
a.
Inspection Scope I
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.
b.
Observations and Findinas The inspector verified the security event logs from July 1 through December 9, 1996. The records were available for review and maintained for the time required by regulations. The inspector determined that the licensee conformed to the regulatory requirements regarding the reporting of security events. The logs and incident reports were organized in numerical sequence and easy to audit.
The licensee was maintaining records on trending and analysis of problems with door alarms, perimeter intrusion detection alarms and security equipment. Trending was excellent, but detailed analyses of identified problems were not performed in some cases.
c.
Conclusions I
i A very good records and reports program was in place. The security staff was
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I correctly reporting security events. Analysis of trending information needed i-improvement.
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l-6-S2 Status of Security Facilities and Equipment S2.1 Testino and Maintenance (81700-02.07)
l a.
Insoection Scope The inspector reviewed the testing and maintenance program to determine compliance with the requirements of the security plan.
b.
Observations and Findinos l
The inspector determined through interviews with security officers and supervisors
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and a review of records that repairs to security equipment were completed in a
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timely manner. The timely response to repair detection aids, access control equipment, and vital area door locks and closures was instrumentalin the low number of compensatory posting and overtime required of security officers.
On December 11,1996, the inspector observed a security maintenance technician perform functional testing of the portal metal and explosive detectors. The technician performed the tests in accordance with applicable security procedures.
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All equipment performed as required.
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c.
Conclusions l
Security systems were repaired in a timely manner. An excellent testing and l
maintenance program was conducted and was properly documented.
S2.2 Alarm Stations and Communications (81700-02.06)
a.
Insoection Scone l
The inspector observed the licensee's central and secondary alarms i
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stations to determined if they met the requirements of the physical security plan, b.
Observations and Findinos l.
The inspector confirmed the redundancy and diversity of the alarm stations. Action j
_ by one alarm station eperator could not reduce the effectiveness of the security I
systems without the knowledge of the other alarm station operators. The central and secondary alarm stations were bullet resistant. The inspector determined that the alarm station operators were knowledgeable of their duties.
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Communications capabilities were also verified to determine compliance with the requirements of the security plan. The areas verified included the operability of both radio and telephone systems and the capability to effectively communicate both telephonically and by radio with the locallaw enforcement agencies. The inspector monitored radio communications conducted among security officers inside the plant protected and vital areas.
c.
Conclusions Alarm stations were redundant and alarm station operators were knowledgeable of their duties. Communications capabilities were in accordance with security plan requirements.
S3 Security and Safeguards Procedures and Documentation S3.1 Security Proaram Plans and Procedures (81700-02.03)
a.
Insoection Scooe The licensee's physical security plan and several implementing procedures were reviewed to determine compliance with the requirements of 10 CFR 50.54(p),10 CFR 50.90, and 10 CFR 73.55(b)(3).
b.
Observations and Findinas The inspector verified, from a review of security plans and procedures and interviews with licensee security personnel, that changes to the licensee's Security, Contingency, and Training and Qualification Plans, as implemented, did not decrease the effectiveness of the respective plans. The inspector also confirmed that the licensee had established a system to ensure that revisions to the plans were incorporated into procedures. Procedure changes were in agreement with the security plan requirements. An effective management review process for procedure changes was in place.
The inspector reviewed several of the licensee's security procedures and determined they were consistent with the security plan requirements.
c.
. Conclusions Security plan changes were submitted in accordance with NRC requirements and the changes did not decrease the effectiveness of the plans. Security procedures were consistent with the security plans.
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S4 Security and Safeguards Staff Knowledge and Performance S4.1 Compensatory Measures (81700-02.07)
a.
Inspection Scope The compensatory measures program was inspected to determine compliance with the requirements of the physical security p;an. The areas inspected included deployment of compensatory measures and the effectiveness of those measures.
b.
Observations and Findinas The inspector confirmed that the licensee deployed compensatory measures in a manner consistent with the requirements in the security plan. The inspector determined through observation and interviews of security personnel that the security personnel assigned to compensatory posts were properly trained for those duties.
c.
Conclusion The compensatory measures program was effectively implemented. Security
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personnel were well trained on the program requirements.
S4.2 Access Control of Personnel and Packaaes (81700-02.05 a.
inspection Scope The access control program for personnel and packages was inspected to determine compliance with the requirements of the security plan.
b.
Observations and Findinas The inspector observed in processing of individuals on December 10 and 11,1996, and determined that the licensee properly controlled personnel access to the protected area. The protected area access control equipment was functional and well maintained. The inspector observed the x-ray machine search of hand carried packages at the primary access point and determined that security personnel were efficient and well trained. The inspector also observed personnel processing j
through the metal and explosive detectors and determined that most plant employees were familiar with the proper procedures for passing through the detectors.
c.
Conclusions An effective program for searching personnel, packages, and material was maintained. Security personnel operating the equipment were well traine.
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SS Security and Safeguards Staff Training and Qualification S5.1 Personnel Trainina and Qualification (81700 02.08)
a.
Inspection Scop.e The security training program was inspected to determine adequacy and compliance with the requirements of the NRC-approved Training and Qualification Plan.
b.
Observations and Findinos The security organization conducted all required training in accordance with their approved security, training, and contingency plans. The inspector confirmed that the training was conducted every twelve months by security shif t supervisors and security trainers assigned to the shifts. The records of nine security personnel were inspected to insure the licensee was in compliance with the training plan commitments. The records were current and easy to audit.
c.
Conclusions An effective security training program had been implemented.
S6 Security Organization and Administration S 6.1 Manaaement Support (81700-02.01)
a.
Inspection Scope Management support for the physical security program was evaluated.
b.
Observation and Findinas Management support for the security program was very good. The inspector interviewed security officers on two of the shifts and determined from their comments that licensee management of the security organization was very good and responsive to concerns. Security facilities were well maintained. Security officers were recently provided with new equipment belts that were more comfortable to wear, c.
Conclusions Licensee management support for the security program was very good.
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a.
Inspection Scope i
The audits of the security program were reviewed to determine compliance with the requirements of 10 CFR 50.54(p), and the security plan.
b.
Observations and Findinas
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The inspector confirmed that a security program audit was conducted at least every 12 months. The inspector reviewed the 1996 audit report and interviewed the lead auditor. The inspector determined that members of the audit team were
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independent of plant security management. It was determined that audit team
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personnel were well qualified and the audit was performance based. The security department promptly resolved all identified deficiencies / findings. The overall quality of the audit was excellent.
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Conclusions The inspector determined from a review of the audit and interviewing the lead auditor that the annual security program audit was performance based. The overall quality of the audit was excellent.
S8 Miscellaneous Security and Safeguards issues (92904)
S8.1 (Closed) Violation 298/9434-01: Failure to Comolv With Search Reauirements The licensee's security force members failed to physically search computer equipment entering the protected area. During this inspection, the inspector reviewed the licensee's corrective actions. The inspector reviewed documentation that proper search requirements were reviewed with all security personnel on shif t.
The inspector observed security personnel conducting searches of personnel and materials entering the protected area. The inspector also reviewed Security Procedure SP 2.2, Access Control, Revision 12, dated April 11,1996, and Security Procedure SP 2.7, Material Entry and Exit, Revision 9.1, dated April 27,1995.
S8.2 (Closed) Violation 298/9618-01: Physical Protection System Desian The licensee's physical protection system was not adequately designed to protect against the single insider in the design basis threat of radiological sabotage. During this inspection the inspector reviewed Security Procedure SP 2.3, (Central Alarm Station / Secondary Alarm Station) CAS/SAS Duties, Revision 14.2, dated July 24, l
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-11-1996, and interviewed security supervisors and CAS/SAS operators. The corrective actions the licensee had implemented were understood and were being effectively implemented.
S8.3 LQlosed) Violation 298/9618-02: Criminal Historv Checks The licensee identified approximately 10 individuals who had been granted l
unescorted access without a criminal history being completed. During this l
l inspection the inspector confirmed the licensee's corrective actions. The inspector i
interviewed personnelin the access authorization office, and access authorization records on 7 individuals who had been granted a temporary or full clearance for
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unescorted access. The inspector also confirmed that changes had been covered in l
Security Services Procedure SS 3.0, Revision 2, dated December 12,1996 and Security Services Procedure SS 3.1, Revision 1, dated October 8,1996.
S8.4 (Closed) Violation 298/9618-03: References
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l A licensee technician willfully directed two contractor Access Authorization Program Technicians to use listed references provided by applicants as developed references.
The inspector interviewed personnel in the access authorization office, and access authorization records on 7 individuals who had been granted a temporary or full clearance for unescorted access. The inspector also confirmed that changes had been covered in Security Services Procedure SS 3.0, Revision 2, dated December 12,1996.
S8.5 (Closed) Violation 298/9618-04: Military History The licensee identified approximately 5 persons who had been granted unescorted j
access without verifying the applicable military history of the individuals. During this inspection, the inspector reviewed 7 background investigation files and determined that all files reviewed, for individuals with current unescorted access, including military histories, were complete.
S8.6 (Closed) Violation 298/9618-05: Documentation of Deroaatorv information Review The licensee identified, in several cases, that between 1993 and 1995, no interviews had been conducted when derogatory information was discovered during the background investigation. During this inspection the inspector confirmed that the licensee was conducting interviews with individuals when derogatory information was discovered. The inspector also confirmed that this requirements was addressed in Security Services Procedure SS 3.0, Access Authorization Program Procedure, Revision 2, dated December 12,1996.
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S8.7 (Closed) Violation 298/9618-06: Emolovment Verification
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During the latter part of 1995 and early 1996, the licensee identified numerous files in which activities during periods of unemployment in excess of 30 days were not l
verified. During this inspection the inspector confirmed by review of 7 records that
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the licensee verified unemployment periods that exceeded 30 days. The inspector also confirmed that this requirement was in Security Services Procedure SS 3.0, Access Authorization Program Procedure, Revision 2, dated December 12,1996.
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l S8.8 (Closed) Violation 298/9618-07: Uodate investioations l
The licensee identified in late 1995 or early 1996, that updated background l
investigations included only one listed reference and one developed reference, in
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addition, the updated background investigations did not include a review of criminal l
history. During this inspection the inspector confirmed from reviewing records and l
reviewing Security Services Procedure SS 3.0, Access Authorization Program l
Procedure, Revision 2, dated December 12,1996, that the licensee was in l
compliance with regulatory requirements.
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S8.9 (Closed) Violation 298/9618-08:Temocrary Clearances During 1995 the licensee granted back-to-back temporary clearances without
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completing the full background investigations. During this inspection the inspector confirmed by review of 4 records that when temporary clearances were granted the full background investigation was completed.
S8.10 (Closed) Inspection Followuo item 298/9618-09:Reportina Criteria in i
Access Authorization Procedure The licensee's Access Authorization Program Procedure did not provide guidance and reporting requirements for the access authorization program. During this inspection the inspector confirmed that Security Services Procedure SS 3.0, Access Authorization Program, Revision 2, dated December 12,1996, did contain l
instructions on reporting of deficiencies.
S8.11 (Closed) Inspection Followuo item 298/9618-10:In-Death Trainina For Supervisors
_The licensee provided general behavioral observation training to all employees rather
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than in-depth training for supervisors and managers. During this inspection the inspector verified by review of a Nebraska Public Power District Training Work Request that the licensee was reviewing Continuous Behavioral Observation Training exam question and revising them as needed to ensure the exam adequately measures mastery of the learning objectives in the area.
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-13-V. Manaaement Meetinas X1 Exit Meeting Summary The inspector presented the inspection results to members of licensee management at the conclusion of the inspection on December 13,1996. The licensee acknowledged the findings presented. No proprietary information was identified by the licensee.
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ATTACHMENT PARTIAL LIST OF PERSONS CONTACTED
, Licensee l
i L. Bergen, Senior Manager, Safety Assessment and Site Support P. Carlock, Security Operations Specialist P. Graham, Vice President, Energy Supply M. Hamm, Security Manager B. Houston, Manager, Nuclear Licensing and Safety R. Koeppel, Security Operations Supervisor D. Madsen, Senior Licensing Engineer B. Toline, Quality Assurance Audit Supervisor NRC B. Murray, Chief, Plant Support Branch RIV INSPECTION PROCEDURES USED IP 81700 Physical Security Program for Power Reactors
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IP 92904 Followup - Plant Support l
PARTIAL LIST OF LICENSEE DOCUMENTS REVIEWED Coc: * Nuclear Station Plant Access Training Information Manual - GEN 001-02-01, Revision 13.01 Nebraska Public Power District Training Work Request, Number 96-00795 Nebraska Public Power District, Cooper Nuclear Station Safeguards Plan, Revision 34, dated April 18,1996.
Security Services Procedure SS 3.0, Access Authorization Program Procedure, Revision 2, dated December 12,1996 Security Services Procedure SS 3.1, Access Authorization Instruction, Revision 1, dated October 8,1996 Security Procedure 1.6, Firearms, Issuance, Maintenance and Use, Revision 9, dated December 29,1995 Security Procedure 2.1, General Security Duties and Responsibilities, Revision 6, dated July 24,1996 j
Security Procedure 2.2, Access Control, Revision 12, dated April 11,1996
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Security Procedure 2.3, CAS/SAS Duties, Revision 14.2, dated July 24,1996 Security Procedure 2.7, Material Entry / Exit, Revision 9.1, dated April 27,1995 Security Procedure 2.9, Communications, Revision 4, dated April 21,1994 Security Procedure 2.11.2, Equipment Testing - Access, Revision 4.1, dated May 5,1994 Security Procedure 2.12, Records, Reports and Documentation, Revision 7.1, dated August 31,1995 Security Procedure 2.14, Compensatory Measures, Revision 5, dated May 9,1996 Security Event togs covering the period from July 1 through December 9,1996, and Security Incident Reports associated with the logs for the same period.
Training records on nine contract security personnel Access Authorization Records on seven plant personnel ITEMS CLOSE_D_,
Closed 30-298/9434-01 VIO Failure to comply with search requirements.
- 50-298/9618-01 VIO Physical Protection Design System.
50 298/9618-02 VIO Criminal History.
50-298/9618-03 VIO References.
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50-298/9618-04 VIO Military History.
50-298/9618-05 VIO Documentation of derogatory information review.
50-298/9618-06 VIO Employment verification.
50-298/9618-07 VIO Update investigations.
50-298/9618-08 VIO Temporary clearances.
50-298/9618-09 IFl Reporting criteria in access authorization procedure.
50-298/96'l8-10 IFl in-depth training for supervisors and managers.
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