IR 05000305/1996012

Insp Rept 50-305/96-12 on 961118-27.Violations Noted.Major Areas Inspected:Access Authorization Program Implementation

ML20133E712
Person / Time
Site:	Kewaunee
Issue date:	01/06/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20133E706	List: IR 05000305/1996012 ML20133E703 ML20133E708
References
50-305-96-12, NUDOCS 9701130126
Download: ML20133E712 (11)

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, U.S. NUCLEAR REGULATORY COMMISSION REGION lil Docket No: 50-305 License No: DPR-43 Report No: 50-305/96012(DRS)

Licensee: Wisconsin Public Service Corporation i

Facility: Kewaunee Nuclear Power Plant ,

Location: RR#1, Box 99 Kewaunee, WI 54216 Dates: November 18 through 27,1996 Inspectors: J. L. Belanger, Senior Physical Security inspector Approved by: James R. Creed Chief, Plant Support Branch 1 Division of Reactor Safety

1 9701130126 970106 PDR ADOCK 05000305 0 PDR

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EXECUTIVE SUMMARY Kewaunee Nuclear Power Plant NRC Inspection Report 50-305/96012 Overallimplementation of the access authorization and vehicle barrier programs at Kewaunee was acceptabl Several positive findings were noted:

e The access authorization staff was qualified, experienced and displayed a sense of ownership and dedication (Section S8.1(b.1)).

e The access authorization / fitness-for-duty staff, functions, records, etc. were centralized in one location making for a more efficient operation (Section S8.1(b.1)).

However, the following concerns were also noted:

e The licensee had not incorporated the description of the as-built vehicle barrier system into the security plan in accordance with regulatory requirement (Section S8.2) l l

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4 Report Details IV. PLANT SUPPORT S8 Miscellaneous Security and Safeguards issues S8.1 Access Authorization Proaram Imolementation (Temocrary Instruction (TI)

2515/127) Insoection Scooe The inspection included an evaluation to determine whether the access authorization (AA) program requirements identified in the Kewaunee Security Manual were adequately implemente The inspectors reviewed records and conducted interviews to verify the adequacy of the licensee's program to verify true identity of an applicant and to develop information concerning employment, education, credit, and criminal histories; military service; and the character and reputation of an individual prior to granting them unescorted access to protected and vital area Areas examined during the inspection included all relevant aspects of the access authorization program as identified in Tl 2515/127. Within these areas, the inspection consisted of a selective examination of procedures and representative records, interviews with personnel, and observations of activities in progress, Observations and Findinas b.1. AA Pronram Administration _and imolementation The licensee committed in their security plan to implement all elements of Regulatory Guide 5.66 dated June 1991 and 10 CFR 73.56 dated April 25,199 The licensee's procedures were thorough to provide guidance to those responsible for implementing the progra Staffing levels were adequate. The Access Authorization Group at the Kewaunee Plant consisted of a Security Administration Supervisor, a full time security specialist and a part time security specialist. The Security Administration Supervisor reported to the Security Director. Staff interviewed were knowledgeable of program responsibilities and procedures. This aspect of the program was a strength. A strong sense of ownership was eviden l The Access Authorization Group was responsible for obtaining and ensuring all required documentation associated with the access authorization process was complete. Any derogatory information discovered during the course of this review was tumed over to the Security Director or designee for immediate revie _ _ . . ._ _ - _ .-.

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Two vendors, a primary and a backup, performed all of the background investigation functions except for four contractors that completed background investigations (Bis) for their own employees. The inspectors reviewed the contracts with the screening vendors and found them to be adequate. The inspector reviewed the licensee's agreoment letters with the self-screening contractors and l found that the self-screeners committed to performing work in accordance with a l specified licensee access authorization p' 7cedur b.2. Backaround Investiaations The inspector reviewed the results of the br.ckground investigations of 20 i personnel. Inspection results showed that the scope and dopth of Bis satisfied NRC l regulatory requirements and provided an adequate level of I ackground information on which to base a determination for access authorization. The Bis covered the specified time period and number of required contacts for each element referenced I above. In those cases whare derogatory information was developed, the licensee reviewed and ovaluated the derogatory information in a timely manne I b.3. Psycholoaical Evaluations The licensee contracted psychological evaluation services to satisfy access authorization requirements. The contracts for the psychological evaluation services were reviewed and found adequat The licensee used the Minnesota Multiphasic Personality Inventory ll for the initial psychological evaluations. The inspectors observed that the MMPI-2 test booklets and answer sheets were maintained in secure cabinets within the records storage l area accessible only by members of he Access Authorization Group. Psychological l tests were adequately controlled, administered, and proctored. If necessary '

followup evaluations were completed, in person, by a state licensed psychologist or psychiatrist licensed to perform such services, b.4. Behavior Observation Proaram (BOP):

The licensee implemented a training program which assured that all badged personnel had the awareness and sensitivity to detect and report to supervision changes in behavior which adversely reflected upon the individual's trustworthiness or reliabilit l Ten personnel were interviewed. Supervisors and non supervisors interviewed were thoroughly familiar with the objectives of the behavior observation progra l Personnel were familiar with the assistance available through the Employee Assistance Program (EAP) and the avenues available to receive such assistanc The EAP had developed a strong reputation for maintaining confidentiality for services provided. Personnel felt comfortable with approaching their supervisors with problems and also believed that their supervisors were aware of assistance

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i available and the avenues available to receive such assistance. All personnel interviewed were aware of the arrest reporting requirements.

j j The licensee monitored absence from a behavior observation program for more than l 30 days by the manual tracking of badge use. A badge was inactivated if it was j not used within a thirty day period. If the individual was not subject to a behavioral observation program, they are placed in the reinstatement progra b.5. Unescorted Access Authorization - Grandfatherina. Reinstatement. Transfer. and !

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Licensee's access control records were reviewed to determine if they were correctly "grandfathering", reinstating, transferring, and granting temporary access l authorization. The inspector reviewed 20 case files which included the categories

of access authorization noted above. Inspection results showed these provisions l were appropriately utilized by the licensee, i

The licensee also tracked personnel granted temporary access to ensure that the j 180-day time limit for temporary access authorization had not been exceeded.

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Licensee actions concerning decisions to deny unescorted access met program

! requirements and NRC regulatory requirements. Individuals denied access were l j notified of their right to requc o , review.

k The inspector reviewed the case files of the seven individuals denied unescorted access since the program was implemented. Each case file was well documented i

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as to the reason for denial and the results of meetings held with the affected j individual that informed them of the grounds for the denial and provided them the

opportunity to present additional, relevant information and explain the appeal process. Appropriate background and supportive documentation was reviewed

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within each reviewed case file whereby a decision could be rendered based upon the content of the files. The sole appeal case was complete and addressed matters appropriate to the appeal decision, b.7. Protection of Personal Information The licensee implemented an effective system for the protection of personal information to prevent unauthorized disclosure. Access authorization personnel were sensitive to protect private and personal information obtained during the access authorization process. Personnel completed consent forms prior to the initiation of the access authorization proces The inspector observed that records were maintained in filing cabinets secured with GSA approved combination padlocks. Those cabinets were inside a controlled office environment within the owner controlled are I

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b.8. Audits

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The inspector reviewed the audits of the licensee's Access Authorization Program l to determine that the minimum audit requirements were met. The scope of the l audit was appropriate and the audits were properly documente l The inspector confirmed that annual audits were completed for the five contractor / vendors approved by the licensee to complete background investigations for their personnel and of the contractors that perform background investigations and provide psychological services. The audits were performed by Nuclear Energy Institute (NEI). The scope of the audits met the audit requirements in Regulatory Guide 5.66. .The licensee evaluated the audit results and the impact of the audits on their program. In most instances, the licensee found that the results of the audits indicated compliance with the licensee's AA program; audit findings were minor in significance; however, in one instance, the NEl audit results of one self-screening contractor caused the licensee to place the contractor in a probationary status until resolution of the finding b.9. Records The inspector reviewed the licensee's record retention activities to ensure required records were retained for the appropriate time period. The licensee's record retention schedule required that access authorization records, be retained for the duration of the unescorted access authorization, and for a five year period following its termination. The licensee maintained agreements with their contractors that the latter would follow the licensee's p ocedure regarding records retention, Conclusions The access authorization program required by 10 CFR 73.56 was effectively implemente The depth of program knowledge by the AA personnel and the centralization of I AA/FFD program functions were program strength l l

S8.2 Vehicle Barrier System

) Insoection Scooe (Tl 2525/132)

Areas examined included the license 0's provisions for land control measures to protect against the malevolent use of a land vehicle to determine compliance with regulatory and licensee commitment _ _ ._ _ _ _ __ .

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b. Observations and Findinas (1) Vehicle Barrier System (VBS)

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The inspector found that the features and structures that form the VBS met the design characteristics established by the NRC. The vehicle barrier components a 1d the location of the barrier were as described in the summary description of the VBS submitted by the licensee to the NRC on February 28,1995, and subsequently revised by letter dated February 29, 199 A visual walkdown performed by the inspector confirmed that the type of i vehicle barrier described in the VBS summary description had been installed

and that the barrier was continuous. The inspector identified, however, that

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the licensee had not amended their physical security plan to commit to the implementation and use of the vehicle barrier syste On August 1,1994, the NRC amended its physical protection regulations for operating nuclear power reactors,10 CFR Part 73 to modify the design basis threat for radiological sabotage to include the use of a land vehicle by adversaries for transporting personnel and their hand-carried equipment to the proximity of vital areas to include the use of a land vehicle bomb (Section 73.1(a)). The amendments required reactor licensees to install vehicle control measures, including vehicle barrier systems to protect against the malevolent use of a land vehicle.

, In the Public Comment Analysis of the Federal Register Notice published on

August 1,1994, Part 111 (Rule Implementation), Paragraph B (NRC Review and Approval of Submittals), in responding to comments that NRC should review and approve alllicensee summaries, the NRC stated that "All licensees are required to amend their physical security plans to commit to the implementation and use of the vehicle barrier system described by the regulations." Additionally, in Part IV (NRC Inspection), in response to one comment that the NRC should establish procedures to assure compliance with the rule, the NRC again noted that all affected licensees were required to amend their physical security plans in response to this rul The General Performance objective of Part 73.55(a) requires licensee's to establish and maintain an onsite physical protection system designed to protect against the design basis threat as stated in Section 73.1(a), 10 CFR 73.55(a) further states that to achieve this general performance object, the onsite physical protection system must include, but not necessarily limited to the capabilities contained in paragraphs (b) through (h). The licensee did not incorporate the vehicle control measures required by the amended 10 CFR 73.55(c)(7) into the Security Manual contrary to 10 CFR 73.55(a) (VIO 305-96012-01).

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Discussions with lit ense:. management in 'icated that they initially intended to submit a security plan change to incorporate the VBS but decided against ,

it based on their interpretation of the rule. The licensee's interpretation of l

the Rule was that since they were a licensee, and not an " Applicant", the l submission of a Summary Description of the VBS system to the NRC by February 28,1995, and maintained all details of the VBS on site they met regulatory requirements and a plan change was not required. Prior to the l conclusion of the inspection, and after discussing the potential violation with I the inspector, the licensee agreed that their original decision not to submit a I I

plan change was in error and agreed to submit a plan chang (2) Bomb Blast Analysis The licensee confirmed that they used the methodology provided in NUREG/CR-1690 to perform their blast analysis. In analyzing the effects of the design basis bomb on vital equipment and surrounding structures, the licensee's results showed that the distance between the concrete walls which protect vital equipment and where the vehicle would come to rest is greater than the calculated safe standoff distance. Inspector field observations of standoff distances were consistent with those documented in the summary descriptio (3) Procedural Controls The licensee appropriately defined criteria for maintenance, surveillance, and compensating for the VBS system in implementing procedures and maintenance surveillance schedule Discussions with security management confirmed that procedures necessary to safely shutdown the units after a bomb blast were appropriately developed and implemente c. Conclusion The VBS program was consistent with the summary description submitted to the NRC, and adequate procedures addressing VBS maintenance and compensatory procedures were developed and implemented. The failure to amend the physical security plan to include the VBS was a violatio V. Manaaement Meetinos X1 Exit Meeting Summary The inspectors presented a summary of preliminary findings to members of Wisconsin Public Service management at the conclusion of the inspection. The licensee acknowledged the findings presente _ . . _ _ . _ . - _ . _ _ . . _ . _ _ _ . . _ __ . - _ _ _ _ . . ._. _ _ _ . . . .

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The inspectors asked the licensee whether any materials examined during the inspection should be considered proprietary. No proprietary information was identifie I l

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PARTIAL LIST OF PERSONS CONTACTED Wisconsin Public Service Corooration C. A. Schrock, Manager, Kewaunee Nuclear Plant K. H. Evers, Manager, Nuclear Plant Support Services R. P. Pulec, Director, Nuclear Licensing J. Fletcher, Security Director INSPECTION PROCEDURES USED Tl 2515/127 Access Authorization Tl 2515/132 Malevolent Use of Vehicles at Nuclear Power Plants ITEMS OPENED, CLOSED, AND DISCUSSED Ooened 50-305/96012-01 VIO failure to modify Security Plan to include Vehicle Barrier System Closed None Discussed None l

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1 l LIST OF ACRONYMS USED i

AA Access Authorization l Bt Background Investigation ,

CFR Code of Federal Regulation )

DRS Division of Reactor Safety '

! EAP Employee Assistance Program ,

j FFD Fitness-for Outy l

l GNP General Nuclear Procedure i

GSA General Services Administration f'

INPO Institute of Nuclear Plant Operations KNPP Kewaunee Nuclear Power Plant i MMPI Minnesota Multiphasic Personalty inventory 1 NEl Nuclear Energy Institute i PDR Public Document Room

! UFSAR Updated Final Safety Analysis Report l TI Temporary Instruction l VBS Vehicle Barrier System j VIO Violation l l a j

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