IR 05000341/1986006
| ML20203P744 | |
| Person / Time | |
|---|---|
| Site: | Fermi  |
| Issue date: | 05/01/1986 |
| From: | Axelson W, Creed J, Pirtle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20203P740 | List: |
| References | |
| 50-341-86-06, 50-341-86-6, NUDOCS 8605080097 | |
| Download: ML20203P744 (12) | |
Text
.
-
-
_- -
-
.
... - _ _ _.
.
.
.
-
.
U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-341/86006(DRSS)
,
Docket No. 50-341 License No. NPF-33 Safeguards Group IV Licensee: Detroit Edison Company 2200 Second Avenue Detroit, MI 48226 Facility Name:
Enrico Fermi Atomic Power Plant Inspection At:
Plant site Inspection Conducted: January 27-30 and March 10-14, 1986 Type of Inspection: Special Physical Security inspector: %A ShD G. L. Pirtle ~
Date Physical Security Inspector Reviewed By:
4%
J R. Creed, Chief Date afeguards Section l
Approved By:
/
[ / [h
-
W. L. Axelsofi, Chief Date Nuclear Materials Safety and Safeguards Branch Inspection Summary Inspection on January 27-30 and March 10-14,1986 (Report No. 50-341/86006(DRSS))
Areas Inspected:
Included management effectiveness of the security program in reference to allegations received by U.S. NRC, Region III.
>
Results: The licensee was found to be in compliance with NRC, requirements within the areas examined.
Two findings of an administrative nature were noted. The job description of the security staff supervisor needs to be revised to include sone responsibilities addressed in the security plan for that position.
Parameters pertaining to report generation from the security computer system need to be established.
860509009, 860502
'PDR ADOCK 05000341 O
. -
.
,.
.., - - _-.. -.
.... - _,, _ _ _.
.-._
--
,
.
.. - - -. _ -. _ - -
.,,
,
.
.
The attachment to this inspection report contains details of a concern pertaining to report generation on the security computer system. The concern is not directly related to any of the allegations, but requires licensee action. The information in the attachment is considered Unclassified Safeguards Information.
_
.
.
-
.
DETAILS 1.
Key Persons Contacted
- F. Agosti, Vice President, Nuclear Operations, Detroit Edison Company (DECO)
- J. Piana, General Director, Nuclear Operations Service (DECO)
W. Hastings, Nuclear Security Director (DECO)
S. Thompson, Assistant Nuclear Security Director / Staff Supervisor (Deco)
W. Hawkins, Chief, Nuclear Security (Deco)
P. Childs, Supervising Engineer, Process Control Computer Division, Electrical System, (DECO)
R. Fitzsimmons, QA Auditor, Security (DECO)
- W. Rogers, Senior Resident Inspector, NRC Region III
- Denotes personnel present during the March 14, 1986 exit meeting.
In addition to the key personnel noted above, the inspector also interviewed other members of the security organization.
2.
Exit Interview (IP 30703)
An exit interview was conducted on March 14, 1986 with the personnel denoted above. The licensee representatives were advised of the general nature of the allegations addressed in Paragraph 4 below. They were also advised that no apparent violations were noted as a result of the inspection pertaining to the allegations.
Two findings of an administrative nature were noted as a result of the inspection. One finding pertained to developing guidelines for reports generated from the security computer system (refer to the attachment to the report for related informaticn). The other finding pertained to revision of the security staff supervisor's job description to include some <pecific responsibilities for that position assigned by the security plan (refer to Paragraph 4.a for related information). The Vice President, Nuclear Operations stated that his staff would address the two findings.
No written material pertaining to the inspection findings was left with the licensee. The licensee representatives were advised that the final inspection report would include the formal perspective of the inspection findings.
3.
Backaround Information On January 16, 1986, U.S. NRC, Region III received a letter containing nine allegaticns and several attachments. The attachments included an organizational chart for the nuclear security organization, three job vacancy announcements, a draft duty description for a Nuclear Security Specialist, and a draft security plan revision which described security responsibilities for various positions within the security organization.
The letter was unsigned, and the identity of the writer was not known as of January 16, 1986.
_
_
_
,
--
--. -_.
-
--
.
. - -.
._
.
.
~
r'
Upon review of the documents, the NRC determined that the documents, collectively, potentially contained Safeguards Information as defined in
'
10 CFR 73.21 in that they identified the number of security officers per shift, certain equipment available for countering threats, and identified law enforcement response agencies.
Since the identity of the person who furnished the documents was unknown, the licensee was advised by the Chief, Safeguards Section on January 17, 1986, prior to an enforcement meeting that the NRC had received dccuments from an unknown source that, in our judgment, contained Safeguards Information. Our concern related to the transmission protection and marking of the information. The licensee was advised that personnel having access to documents which contain potential Safeguards Information should be re-briefed on the required protection for transmitting such documents.
,
I The licensee reviewed their copies of the documents and determined that the documents, in their judgement, did not contain Safeguards Information.
However, to resolve any concern pertaining to the issue, the Director, i
Nuclear Security stated that references to the number of security officers per shift and the type of special equipment available to the security force was deleted in the draft job description for the Nuclear Security Specialist.
The identity of the writer of the letter was determined prior to the initial inspection effort. During the January 27-30, 1986 inspection, the individual was interviewed to clarify the allegations and to determine the distribution of the documents provided to NRC Region III.
The person stated that the documents were sent only to the NRC and no other copies were made. Based on the interview results, the inspector
concluded that the potential Safeguards Information was not compromised.
i Followup inspection effort pertaining to the allegations was initiated
]
during the January 27-30, 1986 inspection effort, and completed during the March 10-14, 1986 inspection.
The individual who provided the information to NRC Region III was briefed on the inspection actions in reference to all of the allegations identified
.
below. The individual stated that the actions appeared adequate and had no other areas that he/she felt warranted further actions by the NRC.
Selected licensee management representatives were briefed on the general nature of the allegations on March 14, 1986 (refer to Paragraph 2).
4.
Allecations/ Concerns (RIII-86-A-0009)
,
f The letter (received on January 16, 1986) by a then unidentif'ed individual indicated that the included concerns were shared by more than just the i
writer of the letter.
The letter stated that the purpose was to explain the concerns "some site personnel have" concerning the operations of the Fermi 2 Nuclear Security Department. The concerns, inspection actions, and conclusions are addressed below:
l
-.
- - - -
. -.---
-
-., - - _ _
. _.
-,
-, - - _,,-
-
_.
.._
.. _.
_
._
,__.
_ _ _ _ _ __
_ _
__
_. _ _ _ _.
l
.
.
,
.
,
.
.
a.
. Concern: The Director, Nuclear Security, has ignored the advise of
'
the site computer specialists pertaining to the number of people generating reports on the security computer system. The Director wants at least fifteen people trained on how to run certain reports using the report. generator.
.
Inspection Actions: The inspector conducted interviews with the
,
Director, Nuclear Security and the Supervising Engineer, Process Control Computer Division (PCCD), Electrical System, in reference to
'
.
the above concern.
The Director, Nuclear Security's position was that he needed a large number of personnel, probably greater than
'
fifteen, trained and capable of generating reports from the security computer system in order to have the capability to respond to security and operational emergencies, and provide information support to;the plant staff, in a timely and effective manner when needed.
' The Supervising Engineer's. PCCD, position was that the number of
,
personnel generating reports was not a significant concern provided the personnel were adequately trained. The current training
'
provided to security force personnel generating reports was
!
considered adequate by both managers.
,
A regulatory concern pertaining to report generation, but not directly related to the above allegation, was noted. Details of this concern are addressed in the attachment to this report and l.
considered Unclassified Safeguards Information, j
. Conclusion: No violations of security plan criteria were noted.
,
Tto number of trained personnel generating reports is not considered a regulatory concern. The need for guidelines pertaining to report generation was noted during the inspection and will be reviewed
i during future inspections (refer to Paragraph f. for a related issue pertaining to use of the security computer system and the attachment to this report for details pertaining to a regulatory concern).
,
b.
Concern: Responsibilities for certain positions on the security
'
staff have just been consolidated and already existed and were not
,
rewritten as requested by the NRC. The allegation addressed positions such as Security Specialist, Shift Lieutenant, Nuclear Security Coordinator, and Contract Security Officer Coordinator.
f Inspection Actions: During the November and December 1985 inspection, the report noted a lack of clear definition of responsibilities for
'
primary security staff members.
(Section 6.b.(2) of Inspection Report No. 50-341/85047(DRSS).)
Although not specifically identified in the t
,
report, primary staff members were understood to mean the positions of i
Director, Nuclear Security, Staff Supervisor, Supervisor of Background Investigations, and Chief, Nuclear Security.
These positions were-discussed with the Director, Nuclear Security during the inspection
+
effort and subsequent to the inspection.
i The inspector reviewed the draft written job descriptions for the four positions noted above against responsibilities addressed in the
,
most recent change to the security plan. The security plan does not
,
4 e. i -
-y-.-.
,.
v,-,.4
.,--n.,,-,,..ymym
.,-_c--..,-~,,.,,v_y-v
,,w,-..m--+
.,,m..
m,.,_-,---,-.,-,.,-r-,w.w.-.,
e,w_.--,
-
.
,.
,
.
.
specifically require job descriptions to be prepared for the staff positions noted above since their broad responsibilities are addresstd in the security plan itself. The inspector determined that the written job description for the staff supervisor did not include monitoring of staff functions for audit responsibilities, and preparation and revision of appropriate security, training, and contingency plans. The job description was revised during the inspection to address the two areas noted above.
Review and approval of the revised job description will be monitored during future inspections (341/86006-01).
Conclusion: No violations of security plan criteria were noted.
The job descriptions, as revised, appeared adequate and addressed NRC concerns noted during the November and December 1985 inspection.
Review and approval of the revised Staff Supervisor job description will be monitored. Job descriptions for Security Specialist, Shift Lieutenant, Nuclear Security Coordinator, and Contract Security Officer Coordinator have not been a regulatory concern during past inspections, and these descriptions were not required by the security plan.
c.
Concern: The Director, Nuclear Security gave the impression he was embarrassed to be associated with the Security Department and this has contributed to the recent drastic decline in department morale.
An interview with the individual that identified the concern to NRC Region III showed that the person formed the conclusion primarily based upon attendance at a meeting with several members of various departments (e.g., nuclear training).
Inspection Actions: The morale of the security organization has been monitored during inspections conducted in November and December 1985 and in January 1986. During these time periods, interviews with members of the security organization, to include the contract security force, ranged from security officers, supervisors, and managers of the licensee's and contract security force. The inspections concluded that the morale of the uniformed force appeared adequate.
However, the morale of the primary security staff working within the administrative staff, to include personnel below supervisor level, appeared low and required attention and action by the licensee's management. This concern was noted during a previous NRC inspection (Section 4.c of Inspection Report No. 50-341/86004(DRSS)).
Future inspections will continue to monitor this issue until it is resolved.
An interview with the Director, Nuclear Security showed that he
- hought the morale of the primary security staff was adequate as
.
of the time of an enforcement conference held in Region III on January 17, 1986. During that meeting, the NRC Region III security staff noted a concern pertaining to the morale of the primary security staff.
Subsequent to that meeting, the Director, Nuclear Security had concluded, based upon additional observations and
_
-
'
.
.
..
inquiries, that the primary security staff's morale warranted additional attention and effort.
The Director, Nuclear Security also stated that he has never been embarrassed to be associated with the Security Department and could find no reason for someone coming to such a conclusion.
He said he has been disappointed with the enforcement problems identified during the November and December 1985 security inspection effort.
Conclusion: The morale of the uniformed force appears to be adequate.
The morale of the primary security staff warrants licensee attention and action, and will continue to be monitored during future inspec-tions as followup on a finding previously identified during the January 27-30, 1986 inspection. The low morale of the primary security staff appears to be the result of several complex factors such as changes in priorities and methods of management caused by appointment of a new Director, Nuclear Security in September 1985, demands placed on the security staff due to the recent inspection results, and increased work load and planning effort required of the security staff to resolve compliance concerns identified in recent inspections. The inspection findings concluded that the Director, Nuclear Security was not embarrassed to be associated with his department and therefore this was not a contributing factor to the low morale.
d.
Concern:
The Director, Nuclear Security (DNS) has rewritten the first part of the Security Plan to shift all responsibilities from the Director to the Assistant Director in order to remove himself (DNS) from NRC compliance responsibilities.
Inspection Actions: During the inspection effort conducted in November and December 1985 (Report No. 50-341/85047(DRSS)),the licensee management of the security department was criticized for failure to clearly define security responsibilities for primary security staff members respective positions.
The report noted that the security plan did not address organizational responsibilities for some primary security staff positions and recommended that functional / organizational changes be considered to redefine responsibilities until the identified problems were resolved (Section 6.b.(4) of the above cited report).
The redefinition of responsibilities and functional / organizational changes were submitted to NRC Region III as a change to the security plan in accordance with the provisions of 10 CFR 50.54(p). The changes in the first part of the Security Plan addressed responsi-bilities for key security staff positions that were not included in the previous security plan, such as, the Supervisor, Background Investigation position, and staff supervisory responsibilities for the Assistant Director, Nuclear Security / Staff Supervisor position.
The change did not relieve the Director, Nuclear Security of responsibility for the overall performance of the security organization. The organizational changes and redefinition of security staff responsibilities were reviewed by NRC Region III and determined as adequate to address the concern identified during the November and December 1985 inspection.
.
.
.
.
.
.
._-
_
_ __. _.
'
'
-
c
-
.
1-
.
(
t.
Conclusion: No violations of security plan criteria were noted and no regulatory concerns were identified.
The security plan changes relating to the security organization and redefining of responsi-bilities of some security staff positions were submitted to resolve an inspection finding..These changes do not remove regulatory compliance responsibilities from the Director, Nuclear Security.
e.
Concern: The Nuclear Security Department and the Security System-were being misused. _ Examples were that a patrol officer assigned
'
gate and door checks was frequently used as an errand runner involving other than security responsibilities; and frequent reports were generated for timekeeping verification.
.
Inspection Actions:
Interviews with the individual that expressed
'
the concern showed that the patrol that was allegedly misused was i
the mobile patrol posted within the Owner Controlled Area (OCA).
The security plan (Sections 4.7.1 and 4.7.2) and a security
procedure, NSP 2523 "0CA Patrol Procedure," dated March 3, 1986,
!
'
assigns the OCA patrol to check gates along the Protected Area (PA)
i perimeter at certain intervals during a shift. An interview with the Chief, Nuclear Security showed tnat he was unaware of any occasion within the past three months when the OCA patrol did not l
perform the required number of PA gate checks. The individual that
.
,
expressed the concern to the NRC was also not aware of any occasion I
when the OCA patrol failed to complete the required PA gate checks.
The inspector randomly reviewed the "PA Door / Gate Lock Inspection Forms" for the months of January and February 1986. The forms
<
reviewed by the inspector showed that the required TA gate checks
.
were documented as completed. An interview with the Director, Nuclear Security, showed that the forms documenting completion of the required PA gate checks by the OCA patrol are routinely checked i
by security supervisors and security management had the option and flexibility to use the mobile patrol for other duties as long as the patrol responsibilities, stipulated in the security plan, were being complied with.
In reference to report generation for timekeeping verification, the licensee's security plan does not restrict the type of reports that can be generated by the security computer system.
Review of security event reports showed that no security computer
failures have been caused specifically because of report generation.
Interviews with the Director, Nuclear Security showed that requests for timekeeping verification were not routinely performed but wouid i-be generated if requested by an appropriate level of management.
Until recently, approval of such requests was granted by the Chief, Nuclear Security. Current policy required such requests for report generation to be approved by the Director or Assistant Director of Nuclear Security. The Director, Nuclear Security felt that such
,
support was a service the Security Department could provide to the plant supervisors without an adverse impact on security computer l
functions.
Interviews with the Supervising Engineer (PCCD), showed
_
,
.w,
,.,, - -, ~ ~,,,
+
w--
y.,_.
, _
,,,,m--..mfy.,
,,..m,.wo-_.,.__,m,
.-,-,...,,m__
..., _..
y...
..
.___-_~,cr
.,,_ _
-
.-
_. -..
. _..
-.- -
.
__
_ _ _. ~
.
.
,
.
.
!
,. -
that in his judgment, generation of suct reports had little likelihood of interfering with security computer functions; that the
.
most realistic problem would be wear en the printer used to print the
'
reports; and this problem was not considered significant enough to terminate such report generation if plant management felt such reports were necessary.
,
!
Conclusion: No violation of security plan criteria was noted and no regulatory concerns were identified. The OCA patrol was used for duties other than those stipulated in the security plan and procedure, and time verification reports were generated but these i
activities did not adversely affect the level of security provided to the plant. (Refer to Paragraph "a." for a related issue pertaining to use of the security computer system).
f.
Concern: The representative responsible for the Nuclear Security Department's response to the NRC 10 CFR 50.54(f) letter was not assigned to the security department. Administration is running the security department.
Inspection Actions: The inspector interviewed the Director, Nuclear Security pertaining to the preparation of the security response to the 10 CFR 50.54(f) letter sent to the licensee on December 24, 1985.
The Director stated that the response to the letter required primarily a technical writing capability, and he felt that his staff's efforts and time were immediately needed to address and resolve as e,rly as possible the significant enforcement issues identified during the November and December 1985 inspection.
Limited technical expertise was needed for the initial drafting of the letter since it would identify only general guidance and would be followed later by a detailed plan for improving the performance of the security organi-zation.
Interview results also indicated that the initial drafter of the security department's response to the 10 CFR 50.54(f) letter did not have final review or approval authority and that the response was reviewed and concurred with by the appropriate levels of managements within the Security Department prior to submittal to the NRC.
-
The detailed guidance for improvement of the security force performance is being developed through a Performance Improvement Plan. A meeting pertaining to this plan was held in NRC Region III
on February 21, 1986 with the Director, Nuclear Security and
,
appropriate members of his staff.
Extensive discussions pertaining
,
to the Improvement Plan were also held with the Director and Assistant Director, Nuclear Security during the March 10-14, 1986 inspection.
During these meetings, the Director and Assistant Director, Nuclear Security were thoroughly familiar with the objectives, goals, and measurable standards pertaining to the
'
Performance Improvement Program.
In reference to " Administration" running the security department, the inspector noted that both the Security Department and the
,
f
'
f v
,.,.
.,--a..,,..-.
e n,
,
-.e.-.
...-..
..,,_.,---,.._e_,,,,_,...m,
.,,..., _. _ -,, _.,..
,.
,,,
-. -
- - - - -
.,
~.
t
.
.
.
Administration Department report to the General Director, Nuclear Operations Services. The Director, Nuclear Operation Services is in the direct management chain. Administrative positions within the Security Department are clerical in nature _and do not include security operational responsibilities as defined in the licensee's approved security plan. During an inspection in September 1985, it-was noted that administrative responsibilities within the security department should be clarified to assure appropriate administrative support and resolve unclear relationships between security and administrative personnel (Section 5.a of Inspection Report No. 50-341/85044(DRSS)).
Contacts by NRC security inspectors during all inspections since license issuance (March 1985) have shown that security supervisors and managers have caused actions to be taken relating to inspection concerns. Observed actions by administrative personnel were generally limited to administrative or support functions.
Conclusion: No violations of security plan criteria or regulatory concerns were noted.
g.
Concern: The Director, Nuclear Security has made comments that his staff should allow Nuclear Quality assurance auditors to find small problems in order to keep them busy so they do not' find large problems. The implied alleged purpose of this was to interfere with audit activities.
Inspection Actions: The inspector interviewed the Lead Nuclear Quality Assurance Auditor that conducted the annual security program audit in February 1986. The auditor also conducted past audits of the security program. The lead auditor's position was that neither he nor any member of the audit team expressed a complaint or experi-enced any interference with the planning, scheduling, or conduct of their audit. Security personnel contacted were cooperative with the auditors requests for information and documents, provided information in a timely manner, and assisted in the audit effort in an adequate manner. The lead auditor also stated that the audit planning effort to some extent lessens the capability to " lead" auditors away from areas they intend to audit. The personnel conducting the audit consisted of a experienced 0A auditor and independent security personnel. from another site who were not responsible for the effectiveness of the licensee's security program.
The NQA lead auditor noted that the Director, Nuclear Security expressed strong objections to some of the audit findings after the audit was completed, but the lead auditor did not consider any actions by the Director, Nuclear Security as interfering or disruptive with the actual conduct of the audit prior to the audit result meeting.
The Director, Nuclear Security's position was that his personnel should identify strong points to auditors and inspectors when appropriate, but he had not advised personnel to interfere, disrupt, or knowingly provide incorrect information to auditors.
-
..
.
.
.
Conclusion: No violations of security plan criteria were noted. No-evidence was noted that would indicate that audit activities were deliberately disrupted.
h.
Concern:
Personnel were coached on what to "tell" the NRC in reference to the Nuclear Security's organizational structure and temporary positions on the security staff.
Inspection Actions: During the September 1985 inspection, a concern was noted pertaining to. temporary (acting) assignments for primary staff positions reporting directly to the Director, Nuclear Security.
The inspection report (50-341/85044) did not identify the specific positions but they were discussed with the Director, Nuclear Security.
The primary concern pertained to the Chief, Nuclear Security position which had been manned on a temporary (acting) basis for about two years.
This position has significant responsibilities for day-to-day operation and effectiveness for the uniformed security force.
No assignment preference (acting or permanent) was expressed by the NRC for any staff positions that did not report directly to the Director, Nuclear Security.
During subsequent inspections, the inspector noted that some security staff personnel believed that the NRC request to stabilize assignment applied to all security staff positions. This misinterpretation of the NRC Region III concern was clarified to staff members who inquired about the concern during the inspections.
Positions below the Staff Supervisor; Chief, Nuclear Security; and Supervisor of-Background Investigations could be managed and assigned as the licensee management deemed appropriate.
The licensee advised NRC Region III in February 1986, by letter, that permanent assignments had been made for the Staff Supervisor and Supervisor of Background Investigation positions. A permanent assignment decision for the Chief, Nuclear Security position would be made by May 1, 1986 to enable the licensee's management to evaluate the decision. NRC Region III approved the requested delay in determining a permanent assignment for the Chief, Nuclear Security position until May 1, 1986.
Formal information pertaining to this issue is being provided to NRC Region III by letter. Changes in organizational structure for the Security Department are being addressed in security plan changes in accordance with criteria in 10 CFR 50.54(p) and reviewed by NRC Region III.
During an interview with the Director, Nuclear Security, his position was that his staff was briefed on the NRC concern so they wculd be knowledgeable of proposed actions if questioned by a NRC
'
inspector and to clarify misunderstandings by his staff on the need
,
for permanent assignment positions verus positions that may be used
.
for job enrichment purposes.
-.
... - - -.
.
_ _.
___, _ _ _, _. _, _.
.
_
.
.
.
.
.
Conclusion: No violations cf security plan criteria were noted and no regulatory concerns were noted. Communications between the licensee and NRC Region III in reference to permanent assignment of key security supervisor positions and organizational changes are being conducted by letter or formal security plan changes. Alleged
" coaching" of what to tell the NRC would have little affect on the issue since the concern is being addressed by written correspondence.
Attachment:
Concern pertaining to Report Generation From the Security Computer System (UNCLASSIFIED )
.__
_
._
--