IR 05000352/1986019

Partially Withheld Physical Protection Insp Rept 50-352/86-19 on 860916-19 (Ref 10CFR73.21).Violation Noted: Surveillance for Certain Isolation Zones & Portions of Protected Area Barrier Impaired

ML20214U995
Person / Time
Site:	Limerick
Issue date:	11/25/1986
From:	Bailey R, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214U956	List: IR 05000352/1986019 ML20214U954 ML20214U963
References
50-352-86-19, NUDOCS 8612090480
Download: ML20214U995 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-19 Docket N License N NPF-39 Licensee: Philadelphia Electric Company 2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Limerick Generatino Station, Unit 1 Inspection At: Limerick, Pennsylvania Inspection Conducted: September 16-19, 1986 Date of Last Physical Security Inspection: July 1-3 and 7-11.1986 Type cf Inspection: Routine,1)nannounced Physical Protection Inspector:

g J. Bailey, p ysic G hity Inspector

//- M -8 6 date Approved by: w //-M-Sd Kefmig,' Chief eguards Section, date vision of Rgdiati Safety and Safeguards Inspection Summary: Routine, Unannounced Physical Protection Inspectio September 16-19, 1986 (Inspection No. 50-352/86-19)

Areas Inspected: Status of Inspector Follow-Up Items; Psychological Testing Program; Management Effectiveness; Security Program Audit; Records and Reports; Testing and Maintenance; Physical Barriers (protected and vital); and Assessment Aid Results: The licensee was a compliance with NRC requirements in the areas examined, except as follows: surveillance for certain isolation zones and portions of the protected area barrier was impaire ggg $$ 2 G

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DETAILS Key Persons Contacted G.M. Leitch, Superintendent, Nuclear Generation J.F. Franz, Manager, Limerick Generating Station R.F. Weindorfer, Director, Nuclear Security J.A. Basilio, Administrative Engineer F.J. Larkin, Nuclear Security Specialist C.R. Endriss, Regulatory Engineer P.R. Supplee, Administrative Assistant J.J. McElwain, Quality Assurance Auditor V. A. Warren, Technical Engineering R.J. Cobb, Program Manager, Yoh Security, In E.M. Kelly, NRC Senior Resident Inspector The inspector also interviewed other licensee personnel and Yoh securit personne . MC 30703 - Exit Interview The inspector met with the licensee representatives listed in paragraph 1 on September 19, 1986, and discussed the scope and results of the inspectio No written material was provided to the licensee during this ins 9ectio . MC 92702 - Status of Inspector Follow-up Items (Closed) Inspector Follow-up Item 50-352/85-42-01: Include the Safeguards Information Protection Program in the annual security program audit. The inspector observed that the Safeguards Information Protection Program was ,

included in the annual audit and had been reviewed by the Quality Assurance Division (QA). The inspector observed that immediate corrective action was taken on one finding concerning the use of an unapproved security containe (Closed) Inspector Follow-up Item 50-352/86-06-01: Review of fuel floor barrie The inspector observed that the fuel floor barrier was adequate, manned and met its intended purpos . MC 92706 - Independent Inspection Effort During this inspection, the inspector reviewed the Philadelphia Electric Company psychological testing program for employees, prospective employees and contractor employees who require unescorted access to protected and

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i vital areas at the Limerick facility. The inspector determined that the licensee uses the services of contract psychologists. The inspector f -d that the purpose of the program was to establish a systematic method for processing em31oyees, prospective employees and contractors for

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psychological testing. The licensee's program also includes a continual

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observation program for the evaluation of any licensee employee or contractor employee wno exhibits unacceptable behavior. The inspector found that the program consists of the following key elements:

Use of licensed psychologist to score and interpret the long form of the Minnesota Multiphasic Personality Inventory (MPI)

Use of clinical interviews by a licensed psychologist for those individuals who fail any portion of the MPI

Retest /re-examination and appeal policy and procedures The inspector interviewed the Nuclear Security Specialist who stated that other indicators of suitability for employment and work, e.g., background investigations, medical examinations, criminal, and character reference checks, are used to supplement the psychological evaluations for those individuals requesting unescorted acces During discussions with licensee representatives, the inspector determined that there were different scoring ranges used to evaluate PECO employees

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~ and contractor employees. PECO employees are held to stricter scori ranges than are contractor employees. The inspector inquired into why there is this difference. The licensee representatives stated that they would discuss this matter with their contract psychologist to determine the significance of this difference, if any. (Inspector Follow-up Item (IFI) 50-352/86-19-01). MC 81020 - Management Effectiveness

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During this inspection, the inspector found that several improvements for contract security personnel had been implemented by the contractor in an effort to enhance employee morale. In addition, the licensee had undertaken several initiatives to provide additional management oversight of the contractor. The inspector will review the results of these during subsequent inspection .The inspector discussed some of the generic findings from the NRC Regulatory Effectiveness Review program currently underway so that the

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licensee could benefit from the findings at facilities already reviewe The licensee's representatives stated that they would consider those j findings during the implementation of the Limerick security progra . MC 81034 - Security Program Audit The inspector reviewed the results of the licensee's annual audit of the security program that had identified several deficiencies. The inspector observed that corrective actions were taken promptly on those findings.,

The inspector observed that the corporate and onsite security management staffs were currently coordinating their written responses to the audit findings. (Inspector Follow-up Item (IFI) 50-352/86-19-02).

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d On July 23,1986, the licensee made a telephone notification to NRC stating that they had found a sub-contractor who had failed to comply with

PECO procedures for background screening of employees for unescorted

access to. protected and vital areas. At that time, a Quality Assurance (QA) audit was initiated to investigate the background' screening program

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' of all sub contractors utilized by the involved prime contractor. During this inspection, the inspector reviewed the results of the audit and determined that unescorted access was immediately withdrawn from other l sub-contractors who had failed to comply with all of the licensee's required procedures. These contractors were prohibited access to the site. The licensee had since published revised background screening 4-procedures for all contractors. A licensee representative informed the inspector that the screening programs for new contractors will be audited

by QA prior to allowing their employees unescorted access to the site.

I 7 MC 81038 - Records and Reports

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The inspector reviewed various reports and records including, but not limited to, computer input authorization records, key control records, security shift accountability records, annual security program reports,

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shift assignment records, psychological evaluation records, and records on administering the psychological testir.g program. All reports and records were complete, properly maintained and readily accessibl . MC 81042 - Testing and Maintenance The inspector conducted a selective review of maintenance procedures and i

records and determined that the program assures that security related

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' equipment is properly maintained to meet the required performance objectives. Corrective maintenance is generally conducted in a timely manne ,

I MC 81052 - Physical Barriers (Protected Area)

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The inspector determined by observation that the licensee was maintaining

! the physical barriers surrounding the protected area in accordance with the NRC-approved physical security pla . MC 81054 - Physical Barriers (Vital Areas)

The inspector determined by observation that the licensee was maintaining the physical barriers surrounding the vital areas in accordance with the NRC-approved physical security plan.

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11. MC 81066 - Assessment Aids Tills FCC9APH CONTAINS SAFEGUARDS INFO.li1AI:0M A:!D iS tiOT FOR PUBLIC DISCLOS'JPI,IT IS lil!ENTIONALLY LEFT BLAN The inspector cited this as a violation of NRC requirements and the NRC approved security plan. (50-352/86-19-03).