IR 05000334/1996011

Insp Repts 50-334/96-11 & 50-412/96-11 on 961209-12.No Violations Noted.Major Areas Inspected:Authorization Program & Administration Organization

ML20133A571
Person / Time
Site:	Beaver Valley
Issue date:	12/23/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133A556	List: IR 05000334/1996011 ML20133A552
References
50-334-96-11, 50-412-96-11, NUDOCS 9612310165
Download: ML20133A571 (10)

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U.S. NUCLEAR REGULATORY COMMISSION f

REGION I

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Docket Nos: 50-334 50-412 {

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License Nos: DPR-66 l NPF-73 i

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Report Nos

50-334/96-11 & 50-412/96-11 l

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) Licensee: Duquesne Light Company ,

i Facility: Beaver Valley Power Station, Units 1 & 2 a

j Location: Shippingport, Pennsylvania l

] Dates: December 9-12,1996

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Inspectors: Edward B. King, Physical Security inspector Gregory C. Smith, Senior Security Specialist ,

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Approved by: Richard R. Keimig, Chief Emergency Preparedness and Safeguards Branch Division of Reactor Safety I

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9612310165 961223 PDR ADOCK 05000334 G PDR

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EXECUTIVE SUMMARY Beaver Valley Power Station, Units 1 & 2 NRC Inspection Report Nos. 50-334/96-11 & 50-412/96-11 On April 25,1991, the Commission published the Personnel Access Authorization l Requirements for nuclear power plants,10 CFR 73.56 (the rule), requiring power reactor licensees to implement an Access Authorization Program (AAP) by April 27,1992, and to incorporate the AAP into the licensee's physical security plan. The objective of the rule is )

to provide high assurance that individuals granted unescorted access are trustworthy and i reliable, and do not constitute an unreasonable risk to the health and safety of the public, l including a potential to commit radiological sabotag l The license 3's Access Authorization Program was inspected during the period December 9-12,1996. It was found to meet the above stated objectiv l

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' 1 ReDort Details l f

! P8 Miscellaneous Security and Safeguards issues

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P General On April 25,1991, the Commission published the Personnel Access Authorization

, Requirements for nuclear power plants,10 CFR 73.56 (the rule), requiring power reactor licensees to implement an Access Authorization Program (AAP) by I April 27,1992, and to incorporate the AAP into the licensee's physical security {

plan. The objective of the rule is to provide high assurance that individuals granted l unescorted access are trustworthy and reliable, and do not constitute an l unreasonable risk to the health and safety of the public, including a potential to

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A February 27,1992, letter from the licensee to the NRC forwarded Revision 14 to

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its physical security plan which stated, in part, that all elements of Regulatory Guide 5.66, " Access Authorization Program for Nuclear Power Plants," have been j implemented to satisfy the requirements of 10 CFR Part 73.56. By letter, dated ,

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May 8,1992, the NRC informed the licensee that the changes submitted had been l reviewed and were determined to be consistent with the provisions of 10 CFR

50.54(p) and that the revision, with one exception requiring an editorial change, l would be acceptable for inclusion in the NRC-approved security plan.

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, This inspection, conducted in accordance with NRC Inspection Manual, Temporary l Instruction 2515/127, " Access Authorization," dated January 17,1995, assessed j

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the implementation of the licensee's AAP to determine if it was commensurate with regulatory requirements and the licensee's physical security plan.

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, P8.2 Access Authorization Program and Administration Organization

Inspection Scope q

The inspectors reviewed organizational charts, applit . :# procedures and conducted j

, interviews to assess the licensee's access authorizatiu, program and administrative l organization.

, Observations and Findinos  :

The Duquesne Light Company (DCL) AAP requirements are contained in three

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documents. Security Procedure 2.0, Revision 5, titled " Access Authorization Program," dated January 31,1996, defines the overall requirements of the program. The fitness-for-duty and behavioral observation portions of the AAP are contained in the Nuclear Power Division Administrative Manuals Nos. 2.14 and 2.9, both Revision 0, respectively titled " Fitness for Duty Program for Duquesne Light Employees" and " Fitness for Duty Program for Contractor / Vendor Employees," both dated August 24,1995.

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The responsibility for implementation of the AAP is vested in the Manager of Security. The access screening and fitness-for-duty personnel report to the Supervisor Security Services who reports to the Manager of Security. The access authorization functions are normally performed in the Plant Personnel Access facility. However, during outages, personnel processing is performed in Warehouse

"B" Training facilit i l Conclusions The inspectors' review of the applicable Nuclear Power Division Administrative Manuals and Security Procedure disclosed that the documents were comprehensive and contained sufficient detail to implement the AAP in accordance with regulatory requirement P8.3 Background investigations (BI) Elements Insoection Scope The inspectors reviewed records and conducted interviews to determine the

! adequacy of the program to verify the true identity of an applicant and to develop information concerning employment history, educational history, credit history, criminal history, military service, and character and reputation of the applicant prior to granting unescorted access to protected and vital area Observations. Findinas and Conclusions

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i The inspectors reviewed the results of 53 background investigations (Bis)

! representing a cross-section of licensee and contractor employees. The licensee conducts its own Bis, i.e., does not use the services of a contractor.

l The 53 BI rep, i also catained the information on which temporary access was granted or denied. The records of those abbreviated scope and depth investigations, permitted by the rule, contained information on which to base a determination regarding temporary access pending completion of the full Bl, and fulfilled the program requirements to which the licensee had committed. The inspectors noted that any matter of questionable or suspect information was l thoroughly ' evaluated and documented prior to granting or denying temporary i

acces In accordance with 10 CFR 73.57, the licensee is responsible for initiating criminal history checks on individuals applying for unescorted access authorization, and for considering allinformation received from the U.S. Attorney General. Among the i records reviewed by the inspectors were those of twenty individuals whose i

fingerprint records had been returned with additional information not noted on the original screening application. The inspectors determined that the information had been properly evaluated and appropriate action had been implemented as a result of j the additional information.

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P8.4 Psychologi:al Evaluations Inspection Scope The inspectors reviewed the licensee's psychological testing program procedures and interviewed the individuals who administer and proctor the psychological test > Observations and Findinas The licensee has contracted with a licensed psychologist to provide oversight of the psychological testing program and to perform the requisite evaluations. All individuals seeking unescorted access to the site are required to complete the psychological questionnaire administered by contractor security personnel that have been trained and qualified as examination proctors. The answer sheets for the psychological questionnaire are forwarded to the psychologist for evaluation and, if the need for a clinical interview is indicated, the psychologist conducts the interview and recommends either access or denial to the licensee. In all cases reviewed, the licensee took the psychologist's recommendatio The inspectors found that procedures were clear and that the proctors demonstrated a sound knowledge of their dutie Conclusion The inspectors concluded that the licensee's psychological evaluation program was being effectively administere P8.5 Behavioral Observation Program (BOP) Inspection Scope The inspectors reviewed the Behavioral Observation Program (BOP) training procedures and lesson plans, observed training films and conducted interviews to ensure that supervisors have, and maintain, awareness and sensitivity to detect behavior changes in employees that could adversely affect their trustworthiness and reliability, and to report such changes to appropriate management for further evaluation and action, if deemed necessary. Additionally, the inspectors reviewed training records, selected at random, of supervisory personnel to ensure that the BOP training was being received in accordance with the requirements of 10 CFR 2 Observations and Findinas The program was instituted as part of, and is an elemert in common with, the licensee's Fitness-for-Duty (FFD) Program. Interviews conducted throughout the inspection with various individuals, representative of a cross-section of both supervisory and non-supervisory employees, indicated a knowledge of program requirements. The supervisors interviewed also demonstrated an awareness and sensitivity to detect and report adverse changes in behavior. The effectiveness of l

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the BOP training was further evidenced by employees who had been referred to the employee assistance program and had been for-cause tested under the FFD program as a result of changes in behavior that were identified through the BO c. Conclusion The inspectors concluded that the training program and lessons plans were adequate to support the program. The inspectors also concluded that the BOP training and retraining were effective and that the BOP was being effectively implemente P8.6 Grandfathering, Reinstatement and Transfer of Access Authorization a. Inspection Scoce

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The inspectors reviewed a cross-section of records to evaluate the licensee's

, application of the provisions for grandfathering, reinstatement and transfers of

access authorization b. Observations and Findinas e "Grandfatherina" 3 Included in the records selected at random by the inspectors were records of j

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, personnel who did not meet the criteria for "grandfathering," i.e., those who j did not have uninterrupted, unescorted access authorization for at least '

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180 days on April 25,1991, the date of publication of the NRC's access authorization rul * Reinstatement

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The licensee's criteria for reinstatement of access authorization was reviewed. The criteria provided for reinstatement of unescorted access l authorization if one had been previously granted, that authorization was terminated under favorable conditions no more than 365 days prior to the reinstatement request, and FFD program requirements were me >

• Transfer of Access Authorization The licensee incorporated the provision for the transfer of access I authorization for both receipts into and transfers out of its program. The

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records selected at random for review by the inspectors included several examples of each.

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! 5 , Conclusions '

l The inspectors concluded that the requirements for grandfathering, reinstatement a

and transfers of access authorizations were being met and that these portions of the AAP were being implemented satisfactorily. No discrepancies were noted.

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P8.7 Temporary Access Authorization  !

Insoection Scope l

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The inspectors reviewed records that included the results of abbreviated scope investigations, which are used as the basis for granting temporary unescorted

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access authorization, as permitted by the rule.

, Observations, Findinas and Conclusions The records of the abbreviated scope investigations were determined to contain

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adequate information (character and reputation from a developed reference, past year's employment history, and a credit check) on which to base temporary access

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authorization. The inspectors noted that, in those records of abbreviated scope investigation, there were no instances in which rescission of access authorization was necessitated following receipt of the full 5-year investigation.

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P8.8 Denial / Revocation of Unescorted Access Inspection Scope The inspectors reviewed the licensee's provisions for the review of appeals of denial

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or termination of access authorizatio !

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Observations and Findinas i

The inspectors determined that an individual is informed of the basis for denial or i revocation of access authorization, is provided the opportunity to provide additional information for consideration and can have the decision, and any additional i information, reviewed by the Access Authorization Review Committee (AARC),

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which consists of the General Manager-Nuclear Support Unit, Manager of Security, Supervisor Security Services and any additional personnel deemed appropriate by the General Manager. After that review, the decision on the appeal is final.

. Conclusion

The inspectors concluded that this aspect of the program was in accordance with the rule and was being adequately implemente i

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j P8.9 Audits

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i Inspection Scope

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The inspectors reviewed the most recent combined nuclear quality assurance audit i of the security and access authorization programs conducted January 26 -

!- March 11,1996, (Audit No. BV C 96-02).

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! Th'e inspectors' review of the audit report disclosed that the audit identified no deficiencies associated with the AAP portion of the audit. However, a I

recommendation concerning the need to develop a method to ensure that written

summary results of psychological evaluations are received in a timely manner from j the certified psychologist, was made. The AAP portion of the combined audit

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lacked detail in that it was difficult for the inspectors to determine if the audit i review addressed all of the required program elements. To ensure that audit

}_ adequately covered the required areas, the inspectors discussed the audit report

with the audit team leader. Based on those discussions and a review of the audit

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matrices used during the audit, the inspectors were able to resolve the concern. To resolve the inspectors' concern, the licensee stated that future audits of the l program would be conducted separately to ensure that adequate detailis provided in the report.

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i The review concieded that the audit was comprehensive in scope and depth and j that the audit program was being properly administere f P8.10 Record Retention l

! InsDection Scope

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[ The inspectors reviewed the onsite record retention program for the AAP records, i

' Observations and Findinas Records are stored in locked file cabinets, accessible only to authorized personne The inspectors noted that the records were very well organized and complet Cpnclusions The inspectors concluded that the storege facilities provided adequate security, and that access to those records was adequately controlled to protect personal information from unauthorized personne i I

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X1 Exit Interview The inspectors presented the inspection results to members of licensee management at the i conclusion of the inspection on December 13,1996. At that time, the purpose and scope of the inspection were reviewed and the preliminary findings were presented. The licensee l acknowledged the preliminary inspection finding X2 Updated Final Safety Analysis Report (UFSAR) Review

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, procedures, and parameters to the UFSAR description. Since the UFSAR does not specifically include security program requirements, the inspectors compared licensee activities to the NRC-approved physical security plan, which is the applicable documen While performing the inspection discussed in this report, the inspectors reviewed Section 3.2.2 of the Plan, Revision 31, dated July 18,1996, titled, " Vehicle and Cargo i Access Portals and Posts," and observed package and vehicle searches. The review disclosed that package and vehicle searches were being performed in accordance with the Plan and security program procedures.

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j PARTIAL LIST OF PERSONS CONTACTED

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LICENSEE AND CONTRACTOR PERSONNEL

1 j K. Beatty, General Manager - Nuclear Support Unit j M. Johnston, Manager of Security

D. Kline, Director Nuclear Security Operations

N. DiPietro, Supervisor Security Services j R. Hart, Compliance Supervisor

! J. Belfiore, Auditor - Quality Services Unit j B. Zamule, Training System Supervisor G. Edwards, Manager Employee Relations

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G. Fidurski, Site Force Supervisor,' Burns International Security Services (BISS)

j D. Book, Access Coordinator, BISS

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D. Lilley, Access Administrator, BISS i

j U.S. NUCLEAR REGULATORY COMMISSION - REGION I i'

1 F. Lyons, Resident inspector .

j G. Dentel, Resident inspector i,

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