IR 05000382/1997009

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-382/97-09. Implementation of Corrective Actions Will Be Reviewed During Future Insp

ML20149E719
Person / Time
Site:	Waterford
Issue date:	07/14/1997
From:	Howell A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	Dugger C ENTERGY OPERATIONS, INC.
References
50-382-97-09, 50-382-97-9, NUDOCS 9707210029
Download: ML20149E719 (5)

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+...0 AR LINGToN, T E X AS 76011 8064 JUL l 41997 Entergy Operations, Inc.

ATTN: Charles M. Dugger, Vice President Operations - Waterford 3 Entergy Operationa, Inc.

P.O.' Box B I Killona, Louisiana 70066 SUBJECT: NRC INSPECTION REPORT 50 382/97-09 AND NOTICE OF VIOLATION

Dear Mr. Dugger:

Thank you for your letter of June 30,1997, in response to our letter and Notice of Violation dated May 29,1997. We have reviewed your reply and find it responsive to the concerns raised in our Notice of Violation.

We will review the implementation of your corrective actions during a future inspection to determine that full compliance has been achieved and will be maintained.

Sincerely,

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Arthur T. Howell Ill, Director

- Division of Reactor Safety Docket No.: 50-382 License No.: NPF-38 cc:

Executive Vice President and Chief Operating Officer Entergy Operations, Inc.

P.O. Box 31995 (

Jackson, Mississippi 39286-1995 Vice President, Operations Support Entergy Operations, Inc. .

P.O. Box 31995 Jackson, Mississippi 39286 1995 i g{ g g

9707210029 970714 . . . .

PDR ADOCK 05000382 G PDR I

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Entergy Operations, Inc. -2- I l

I Wise, Carter, Child & Caraway P.O. Box 651 Jackson, Mississippi 39205 J

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General Manager, Plant Operations 4 Waterford 3 SES )

Entergy Operations, Inc.

P.O. Box B Killona, Louisiana 70066 '

l Manager - Licensing Manager

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Waterford 3 SES Entergy Operations, Inc.

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P.O. Box B Killona, Louisiana 70066

Chairman l

Louisiana Public Service Commission One American Place, Suite 1630

Baton Rouge, Louisiana 70825-1697 l Director, Nuclear Safety &

Regulatory Affairs Waterford 3 SES

Entergy Operations, Inc.

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P.O. Box B Killona, Louisiana 70066

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William H. Spell, Administrator Louisiana Radiation Protection Division P.O. Box 82135

Baton Rouge, Louisiana 70884-2135 Parish President St. Charles Parish P.O. Box 302 Hahnville, Louisiana 70057 Mr. William A. Cross Bethesda Licensing Office 3 Metro Center Suite 610

. Bethesda, Maryland 20814

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Winston & Strawn i

1400 L Street, N.W.

l Washington, D.C. 20005-3502

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Entergy Operations, Inc. -4-

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E-Mail report to T. Royce (THB)

E-Mail report to NRR Event Tracking System (IPAS)

E-Mail report to Document Control Desk (DOCDESK)

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Regional Administrator Resident inspector DRP Director DRS-PSB Branch Chief (DRP/D) MIS System Project Engineer (DRP/D) RIV File Branch Chief (DRP/TSS)

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DOCUMENT NAME: R:\_WAT\WT709ak.twd To receive copy of document, Indicate in box: "C" = Copy without enclosures "E" = Copy with enclosures "N" = No copy SPSS:PSB lE C:PSB aE D:DRP _

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.. Po. Box B Killona, LA 70066 41504 739 6242

, Early C. Ewing,111 t e Safety & Regulatory Affa,rs

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• \ I[OW PR June 30,1997

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U.S. Nuclear Regulatory Commission ATTN: Document Control Desk l Washington, D.C. 20555

Subject

Waterford 3 SES Docket No. 50-382 i License No. NPF-38

NRC Inspection Report 97-09 Reply to Notice of Violation Gentlemen:

In accordance with 10CFR2.201, Entergy Operations, Inc. hereby submits in Attachment 1 the responses to the violations identified in Enclosure 1 of the subject

! Inspection Report.

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According to the notice of violation, our response may reference or include previous docketed correspondence, if the correspondence adequately addresses the required response. Security Incident Report SIR 97-S01-00, which was submitted to the NRC on May 19,1997, meets that criterion and adequately addresses violation 9709-01.

J Accordingly, the docketed information in SIR 97-S01-00 provides the response for

violation 97-09-01. Attached for your review is a copy of SIR 97-S01-00.

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Reply to Notice of Violation (IR 97-09)

- W3F1-97-0173 Page 2 4- June 30,1997

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Should you have any questions concerning this response, please contact me at (504) 739-6242 or Tim Gaudet at (504) 739-6666.

Very truly yours, c

f M i E.C. Ewing Director Nuclear Safety & Regulatory Affairs i

ECE/GCS/tjs

- Attachment i cc: E.WcMerschoff (NRC Region IV) .

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C.P. Patel (NRC-NRR)

l' J. Smith N.S. Reynolds NRC Resident inspectors Office l

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W3F1-97-0173

'g Page 1 of 8 ATTACHMENT 1

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ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN

ENCLOSURE 1 OF INSPECTION REPORT 97-09 i

l VIO' LATION NO. 9709-01

. Waterford 3 Physical' Security Plan, Revision 17, dated August 1996, Chapter 2, paragraph 2.3.1, " Personnel Screening and Access Authorization," states, in part, c "Entergy Operations, Inc., Waterford 3, commits to Regulatory Guide 5.66, Access l Authorization Program for Nuclear Power Plants dated June 1991. All regulatory

elements have been implemented to satisfy the requirements of 10 CFR 73.56. " In addition paragraph 5.2.1," Personnel Access Authorization," states, in part,

" Unescorted access into the protected area is limited to those individuals who meet-l 1 the Entergy screening requirements and who have a legitimate reason for entry. . . . !

j Authorizations for unescorted personnel access to the protected area are issued by )

i the General Manager, Plant Operations, his designee, or Duty Plant Manager (s), l 3 after a reason for entry has been established."

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Attachment NUMARC 89-01, to Regulatory Guide 5.66, June 1991, paragraph 3.0,

" Responsibility," states, in part, "The final granting and controlling of unescorted

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access authorization is the responsibility of the utility. Each nuclear utility will inform L contractors and vendors of the existence of the these guidelines and of the necessity l to follow these guidelines."

Waterford 3 Procedure OM-106," Unescorted Access Authorization Program,"

i Revision 2, April 28,1996, paragraph 5.8 states, inl part, "All company officers, directors, managers, superintendents, supervisors and their appointed designees are responsible for: Taking appropriate action to ensure that individuals under their authority with unescorted access . . . .who no longer need unescorted access, have their unescorted access terminated . . . ."

Site Directive W2.102, " Employee Termination and Resignation Practices," Revision 1, April 29,1994, paragraph 4.3 states, in part, "The Director, General Manager-Flant Operations and/or concerned Manager or Supervisor is responsible for:

ensuring that information pertaining to the reason and condition associated with all terminations and resignations is relayed to the Waterford 3 Security Superintendent prior to or concurrently with the employee's departure from the plant site."

Contrary to the above, on April 18,1997, the licensee determined that the Waterford 3 Security Superintendent had not been notified prior to or concurrently with the departure from the plant site of approximately 10 contract employees. Active badge / key cards were available to those employees who no longer had a need for unescorted access into the protected area.

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W3F1-97-0173

Page 2 of 8

This is a Severity Level IV violation (Supplement 111)(382/9709-01).

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RESPONSE  !

(1) Reason for the Violation

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The^ reason for this violation has been pisio0sydocketedLi6Waterford O's letter W3F1-97-0098, dated May 19,1997. That letter transmitted Security incident Report (SIR) 97-S01-00.

(2) Corrective Steps That Have Been Taken and the Results Achieved

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The corrective steps that have been taken have been previously docketed in Waterford 3's letter W3F1-97-0098, dated May 19,1997. That letter i transmitted Security Incident Report (SIR) 97-S01-00. l

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(3) Corrective Steps Which Wi!! Be Taken to Avoid Further Violations I

j The corrective steps which will be taken to avoid further violations have been i

previously docketed in Waterford 3's letter W3F1-97-0098, dated May 19, !

1997.

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(4) Date When Full Compliance Will Be Achieved The corrective actions taken place Waterford 3 in full compliance. The remaining action in SIR 97-S01-00, to revise the procedure providing guidance to plant personnel on the proper in-processing and out-processing of individuals and the correct use of the AAR, will be completed by October 31, 1997.

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Attachmsnt to !

W3F1-97-0173

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l l ATTACHMENT 1 ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-09

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VIOLATION NO. 97'19-02

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! Waterford 3 PhysicaiSecurity Plan,' Revision 17, dated August 1996, paragraph 5.2.2 states, in part, "A list of personnel authorized unescorted access to the

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protected and vital areas is located at the Primary Access Point for use by the

. security department and is reviewed by cognizant supervisors / managers every 31

days and updated as applicable."

i j Waterford 3 Procedure OM-110," Continual Behavioral Observation Program,"

! Revision 0, March 31,1995, paragraph 6.2.3a. states, in part, "Each month, an i unescorted access verification report is generated by the site access or security

section and provided to the cognizant department heads. The purpose of the report

{- is to verify that individuals with current unescorted access continue to have a valid l need for unescorted access." -

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Contrary to the above, on April 23,1997, the NRC inspector identified that on

April 1,1997, a contractor supervisor signed a 31-day access review record, which was not updated as applicable. Specifically, the record had approximately four individuals listed who had not used their unescorted access in excess of 30 days and -

two individuals who had been terminated several days prior to the required review.

None of these individuals continued to require unescorted access into the protected !

area.

This is a Severity Level IV violation (Supplement Ill) (382/9709-02).

RESPONSE (1) Reason for the Violation The root coues of the violabon is failure to follow procedsre. An EOl contractor superviscr failed to review and validate the continued need for unescorted access for individuals reporting to him, and he failed to ensure that the individual (s) was covered under an approved Continual Behavioral Observation Program (CBOP). Corporate procedure OM-110," Continual Behavioral Observation Program" requires those actions.

Access Authorization personnel monthly review of the 31 day Access Verification Report indicates that the above event is an isolated occurrence.

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Attachm:nt to W3F1-97-0173

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(2) Corrective Steps That Have Been Taken and the Results Achieved I

~ l The EOl contractor supervisor involved with this event has been counseled. j i

(3) Corrective Steps Which Will Be Taken to Avoid Further Violations l l

Waterford 3 believes that the above listed corrective action is adequate to l

preclude further violations of this type. '

(4) Date When Full Compliance Will Be Achieved l Waterford 3 is in full compliance.

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Attachm:nt to W3F1-97-0173

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ATTACHMENT 1 l ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN

ENCLOSURE 1 OF INSPECTION REPORT 97-09

VIOLATION NO. 9709-03

4 Waterford 3 PhysicaiSecurity Plan, Revision 17, dated August 1996, Chapter 5, paragraph 5.2.1, Personnel Access Authorization states, in part," Unescorted access

into the protected area is limited to those individuals who meet the Entergy screening

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rsquirements and who have a legitimate reason for entry". . .

! Authorizations for unescorted personnel access to the protected area are issued by j the General Manager, Plant Operations, his designee, or Duty Plant Manager (s),

4 after a reason for entry has been established."

i Attachment NUMARC 89-01, to Regulatory Guide 5.66, June 1991, paragraph 3.0,

! " responsibility," states, in part, "The final granting and conirolling of unescorted i access authorization is the responsibility of the utility. Each nuclear utility will inform

contractors and vendors of the existence of the these guidelines and of the necessity to follow these guidelines."

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Security Procedure PS-011-107, Badge / Key Card Assignment and Control, Revision

10, February 16,1995, paragraph 5.2.1 states, in part, ". . . photo badge / key cards shall be assigned to individuals by a badging and in-processing administrative 5 specialist after the following criteria have been met: 1. A supervisor requests that the individual be authorized unescorted access. . . In addition paragraph 5.10 states, in i part, the secunty department must be notified whenever. . . the access authorization

of the assigned person is terminated."

[ Contrary to the above on April 23,1997, the NRC inspector identified that on March

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25,1997, a photo badge / key card had been assigned to a contractor employee who

had been terminated four days earlier, March 21,1997, by the contractor and, j therefore, did not have a legitimate reason for entry.

This is a Severity Level IV violation (Supplement 111)(382/9709-03).

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! RESPONSE F

l (1) Reason for the Violation mw~ ~

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causes'of the vlotationme w' administrative are inadequate

!' IfalliiIf5Mfo#66fpriidedure. Controls were not in place to preclude unqualified

) individuals from obtaining approved Area Access Request (AARs) forms that i

are needed for unescorted access to the protected area. AAR forms were

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Attachment to W3F1-97-0173 .

',. Page 6 of 8 being approved without the individuals meeting all the employment and l training requirements.

The individual who was granted unescorted access to the plant protected area following his termination was a conditional employee.' Conditional employees !

obtain full employment status after successfully completing certain training j requirements. The individual did not complete his training requirements, never became. a full time employee and was subsequently torminated. The '

EOl contractor supervisor did not adequately track the employment status of conditional employees and he was not aware that the individual had been terminated. As a consequence, the EOl contractor supervisor failed to follow site directive W2.102, " Employee Termination and Resignation Practices", i section 5.2.7, which states that supervisory / managerial personnel are responsible to ensure that Security is notified of the reason for termination of all personnel from Waterford 3 prior to or concurrently with the employee's j departure from the plant site. l (2) Corrective Steps That Have Been Taken and the Results Achieved The EOl contractor supervisor involved with this event has been counseled l (3) Corrective Steps Which Will Be Taken to Avoid Further Violations

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A procedure will be revised which will provide guidance to plant personnel on the proper in-processing and out-processing of individuals and the correct use

of the AAR.

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(4) Date When Full Compliance Will Be Achieved

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The corrective actions taken place Waterford 3 in full compliance. The

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additional above action to revise a procedure to reduce the probability of recurrence of the violation will be completed by October 31,1997.

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Attachm nt to :

W3F1-97-0173

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i ATTACHMENT 1  !

l ENTERGY OPERATIONS, INC. RESPONSE TO THE VIOLATION IDENTIFIED IN ENCLOSURE 1 OF INSPECTION REPORT 97-09 VIOLATfN NO. 9709-04

- Waterford 3 Physicai Security Plan, Revision 17, dated March 1996, Chapter 10 -

states, in part, " Exterior doors to vital areas utilized for the movement of special equipment during refueling and major maintenance operations are controlled, when.

in use, by security personnel. When frequent access to containment is permitted during refueling or major maintenance, positive access control will be maintained for access from the protected area into containment."

Licensee Administrative Procedure UNT-004-036," Security Requirements for.

Penetrating PA & VA Barriers," Revision 3, January 7,1997, paragraph 4.3, "PA & i VA Barriers," states, in part, "The Security Officer (S. O.) posted for a security barrier ,

penetration or approved activity in an outer isolation zone is responsible for access control to the affected area."

Security Procedure PS-016-101," Security Procedure During Refueling and Major Maintenance Operations," Revision 8, June 19,1996, paragraph 5.2.3 states, in part,  !

"When frequent access to containment is permitted during refueling or major maintenance, positive access control will be maintained from the protected area into '

containment (which is a vital area). If the door at the protected area to vital area barrier is circumvented it must then be posted by an armed security officer who must control entry and exit through the door."

Contrary to the above, on April 23,1997, an NRC inspector, accompanied by a licensee employee, found a security officer posted as a compensatory measure at the open vital area doors inattentive to his duties such that he could not provide positive access control of a vital area used to support the refueling outage.

This is a Severity Level IV violation (Supplement 111)(382/9709-04).

RESPONSE (1) Reason for the Violation

=KRoot CsUisXnifyiiMNdA[tMnss~fonmiisWinveistigalithiseent. The EtesNidetermin5dM E0f650 sew tseipoor work practices. The security.

officer failed to request assistance from co-workers or his supervision when he started to become inattentive. As a result, when the officer became inattentive he was unable to adequately provide positive access control to the vital area.

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Attachmsnt to W3F1-97-0173 7,. Page 8 of 8 Contributing to the violation is an inadequate procedure. Specific guidance is not provided in procedures delineating steps to take when one becomes inattentive. The site contractor's handbook, Wackenhut Corporation. Security Officer Handbcok, section 2.1, " Attention to Duty", states that Security Officers shall demonstrate interest in their work by alertness and attention to duty.

This statement is vague and fails to provide the security officers with guidance on specific actions to take if they feel tired, sleepy, or otherwise inattentive to duty. Also, there is no written guidance or procedure identifying actions supervisors may take to assist the security officers in remaining attentive to duty.

(2) Corrective Steps That Have Been Taken and the Results Achieved The security officer was immediately relieved of duty, and his unescorted access was revoked. The security officer was given a fitness-for-duty test.

The test results were negative.

The Wackenhut Corporation issued a letter to all security officers with specific guidance on actions to take in the event they feel tired, sleepy, or otherwise inattentive to duty.

A security department directive was issued which does the following:

Identifies specific actions for security officer to take in the event they feel tired, sleepy, or otherwise inattentive to duty.

Directs security operations supervision to perform random' positions checks of all response, compensatory, and perimeter positions.

Directs the secondary alarm station to conduct periodic radio checks of all response, compensatory, and perimeter positions.

i (3) Corrective Steps Which Will Be Taken to Avoid Further Violations Waterford 3 believes that the above listed corrective actions are adequate to preclude further violations of this type.

(4) Date When Full Compliance Will Be' Achieved Waterford 3 is in full compliance.

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IMPROPERLY AUTHORIZED INDIVIDUALS GRANTED ACCESS TO THE PROTECTED AREA EVENT DATE (S) LER NUMER (6) REPORT DATE (7)

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E.G. BECKENDORF, SECURITY SUPERINTENDENT (504)739-6340 l COWLEIT ONE UNE FOR EACH COWONENT FAILURE DESCRIGED Si THIS REPORT (13)

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%BSTRACT (Limit to 1400 spaces,i.e., approximately 15 eingle-spaced typewritten knee) (18)

, On April 18,1997, Waterford 3 security personnel determined initially that an unknown

{ number of individuals had been improperly authorized access to the plant protected

! area (PA). All of the individuals had been issued active keycard badges. Security i performed a controlled evacuation of all nonessential personnel from the PA to determine the extent of the problem. The cause of this event is an inadequate work l process in that contractors were allowed to obtain unescorted access to the plant while

! they were conditionally employed prior to completing all requirements for full i employment.

l Fo' lowing an investigation into this event, it was determined that none of the individuals i

entered the PA and there was no malevolent intent to gain entry by the parties involved.

This event did not compromise the health and safety of the public or plant personnel.

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This Security incident Report is being sut'mitted per 10CFR73.71 (c) requirements.

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U.S. NUCLEAR REGULATORY COMMISS40N LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FAC1UTY NAME (1) bOCKET _ LIR NUMHER (6) PAGE (3)

05000 2 OF 4 TERFORD STEAM El.ECTRIC STATION UNIT 3 382 97 Sol "00 tif more space is required. Use additional copies of NRC Form 3664I I I REPORTABLE OCCURRENCE l Due to errors in the process of completing the Area Access " .ms, ten i

improperly authorized individuals could have gained ace ;d Area (PA). This event is being reported pursuant to Apper . tv vven is.1(c) which l states that any failure, degradation, or the discovere erability in a safeguards

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l system that could allow unauthorized access to the p .ted area is reportable. On April 18,1997, a one hour report of this event was isst per the same requirement.

i INITIAL CONDITIONS During this occurrence, Waterford 3 was in Mode 5 (Cold Shutdown). No structures,

systems or components were inoperable that contributed to this event.

, EVENT DESCRIPTION i On April 18,1997, Waterford 3 security personnel determined an unknown number of individuals had been improperly authorized to access the PA. All of the individuals had been issued active keycard badges. This condition was discovered when a contract individualinformed an Entergy Director that she was in possession of an active keycard badge but was not actively working for a contract company. This information was provided to the Security department who began to investigate this matter. Security

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performed a controlled evacuation of all nonessential personnel from the PA to determine the extent of the problem. Further investigation determined that ten contract

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individuals had been improperly authorized to access the PA. None of the individuals i

entered the PA.

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CAUSAL FACTORS A Root Cause Analysis (RCA) team has been formed to investigate this event.

Preliminary results indicate the cause of this event is an inadequate work process in that contractors were allowed to obtain unescorted access to the plant prior to NAC FORM 386A I48til

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U.S. NUCLEAR REGULATORY COWutSSION LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACitJTY NARE (1) DOCKET p

~ ' ~~[GE i3

" TuSE!' " Ele $

05000 2 OF 4 TERFORD STEAM ELECTRIC STATION UNIT 3 362 97 " S01 "00 (11 more space is requored, use additional copies of NRC Form 366Al (17)

REPORTABLE OCCURRENCE Due to errors in the process of completing the Area Access Request (AAR) forms, ten improperly authorized individuals could have gained access into the Protected Area (PA). This event is being reported pursuant to Appendix G to 10CFR 73.71(c) which states that any failure, degradetion, or the discovered vulnerability in a safeguards system that could allow unauthorized access to the protected area is reportable. On April 18,1997, a one hour report of this event was issued per the same requirement. l J INITIAL CONDITIONS i

During this occurrence, Waterford 3 was i,; Mode 5 (Cold Shutdov'n). No structures,

systems or components were inoperable that contributed to this event.

! EVENT DESCRIPTION

l l On April 18,1997, Waterford 3 security personnel determined an unknown number of I individuals had been improperly authorized to access the PA. All of the individuals had

been issued active keycard badges. This condition was discovered when a contract l individual informed an Entergy Director that she was in possession of an active keycard badge but was not actively working for a contract company. This information was l provided to the Security department who began to investigate this matter. Security

! performed a controlled evacuation of all nonessential personnel from the PA to

! determine the extent of the problem. Further investigation determined that ten contract l individuals had been improperly authorized to access the PA. None of the individuals l entered the PA.

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l CAUSAL FACTORS

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A Root Cause Analysis (RCA) team has been formed to investigate this event.

l Preliminary resuits indicate the cause of this event is an inadequate work process in

{ that contractors were allowed to obtain unescorted access to the plant prior to j -

nec mu sona nos j

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.. C Nnc poRhd 3MA U.S. NUCGAR REtULATORY CODASSalch b

LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FACRJTY NAAE (1) DOCKET LER NUM (S) PAGE (3)

MAR R 05 0 [

' WATERFORD STEAM ELECTRIC STATION (JNIT 3 97 -- S01 - 00 TEXT lif more space os requoted. Use addotoonal copies of NRC Form 366A) (17)

completing all requirements for full employment. Any significant changes to preliminary

causal factors and or corrective actions will be submitted as a revision to this Security incident Report. '

The requirements for obtaining unescorted access are completion of General Employee Training (GET) l, a background investigation, Fitness for Duty drug screening, and having a need for plant access. The need for access for an applicant is determined by their supervision and is communicated by the submittal of an AAR to in-processing  ;

personnel. The process that was in place encouraged the expeditious submittal of i

AARs to facilitate the granting of unescorted plant access. AARs were submitted prior to the individual being in a full employment status. Upon receipt of the AAR by in-processing personnel, it was understood that the individual had met the requirement for need for plant access.

All ten of the individuals were conditionally employed by the supervisors because their employment was contingent upon successful completion of GET ll training. Since these individuals were only conditionally employed, there was no need to gain access to the PA. In consequence, unescorted plant access was inappropriately provided to the ten individuals who had completed background checks, successfully completed Fitness for Duty drug screening, completed GET I training, and had AARs submitted without a true need for plant access.

CORRECTIVE MEASURES Keycard badges were inactivated for all individuals identified ~as not fully employed.

An evacuation of the plant of non-essential personnel was performed and their current employment status and need for unescorted access was verified.

Security performed a 100% verification of employment and need for unescorted access for all badged individuals, ac ma seen un

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NRC FORM 364A U.S. NUCLEAR REMULATORY CO644SS60N 030R

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,, LICENSEE EVENT REPORT (LER)

TEXT CONTINUATION FAC1UTY NAAM (1) DOCKET LER NUMR (6) PAGE (31 N (R NUM WATERFORD STEAM ELECTRIC STATION UNIT 3 05 0 W -- S01 -- 00 TEXT (11 more space os reqwred, use additional copies of NRC him 366A) (17)

A letter was issued by the Manager, Materials, Purchasing and Contracts to all Contract Managers emphasizing the importance of not requesting unescorted access for an individual until all company required elements have been satisfied and the individualis fully employed by a contract company.

An interim checklist was created that requires verification of employment status prior to releasing a keycard to the primary access point (PAP).

A procedure will be issued providing guidance to plant personnel on the proper in-processing and out-processing ofindividuals and the correct use of the AAR.

SAFETY SIGNIFICANCE This event did not compromise the health and safety of the public or plant personnel.

With the exception of the need for access due to individuals being conditionally employed, all requirements to gain unescorted access to the PA (i.e. background check, fingerprinting, alcohol and drug testing, and psychological evaluation) were completed.

SIMILAR EVENTS l l

There have been no similar events reported as SIRS at Waterford 3. l

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