IR 05000387/1996007
| ML17158B707 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 06/28/1996 |
| From: | Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17158B706 | List: |
| References | |
| 50-387-96-07, 50-387-96-7, 50-388-96-07, 50-388-96-7, NUDOCS 9607080415 | |
| Download: ML17158B707 (11) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Docket Nos.
License Nos.
50-387, 50-388 NPF-14, NPF-22 Report Nos.
50'-387/96-07, 50-388/96-07 Licensee:
Pennsylvania Power and Light Company (PP&L)
Facility:
Susquehanna Steam Electric Station Location:
Berwick, PA Dates:
June 10-14, 1996 Inspectors:
G.
C. Smith, Senior Security Specialist E.
B. King, Physical Security Inspector Approved by:
Richard R. Keimig, Chief Emergency Preparedness and Safeguards Branch Division of Reactor Safety 96070804i5 96062S PDR ADOCK 05000387
EXECUTIVE SUMMARY Susquehanna Steam Electric Station NRC Insp'ection Report Nos. 50-387/96-07, 50-388/96-07 On April 25, 1991, the Commission published the Personnel Access Authorization Requirements for nuclear power plants,
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 reliable, and do not constitute an unreasonable risk to the health and safety of the public, including a potential to commit radiological sabotage.
The licensee's Access Authorization Program was inspected during the period June 10-14, 1996.
It was found to meet the above stated objectiv Re ort Details P8 P8.1 Miscellaneous Security and Safeguards Issues General On April 25, 1991, the Commission published the Personnel Access Authorization Requirements for nuclear power plants,
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 reliable, and do not constitute an unreasonable risk to the health and safety of the public, including a
potential to commit radiological sabotage.
A February 26, 1992, letter from the licensee to the NRC forwarded Revision EE to 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 implemented to satisfy the requirements of 10 CFR Part 73.
An NRC April 15, 1992, letter to the licensee stated that the changes submitted had been reviewed and were determined to be consistent with the provisions of 10 CFR 50.54(p)
and acceptable for inclusion in the NRC-approved security plan.
a
~
Ins ection Sco e
TI 2515 127 This inspection, conducted in accordance with NRC Inspection Manual, Temporary Instruction 2515/127,
"Access Authorization," dated January 17, 1995, assessed the implementation of the licensee's AAP to determine if it was commensurate with regulatory requirements and the licensee's physical security plan.
P8.2 Access Authorization Program and Administration Organization a.
Ins ection Sco e
The inspectors reviewed applicable procedures and conducted interviews to assess the licensee's Access Authorization Program and Administration Organization.
b.
Observations and Findin s
The Pennsylvania Power and Light Company (PPEL)
AAP requirements are contained in two documents.
The Site Access Program Manual, Revision 1, dated Hay 3, 1996, defines the overall requirements for the program.
The fitness-for-duty and behavior observation portions of the AAP are contained in the Fitness-For-Duty Program Manual, Revision 5, dated March 31, 199 The responsibility for implementation of the program is vested in the Site Access Services Supervisor, who reports to the Hanager, Nuclear Security.
The access screening and fitness-for-duty personnel report to the Site Access Services Supervisor.
All access authorization functions are performed in the plant access processing center.
Conclusions The inspectors'eview of the AAP and the Fitness-For-Duty Manuals disclosed that both manuals were comprehensive and contained sufficient detail to provide adequate guidance to implement the AAP in accordance with regulatory requirements.
Further, the consolidation of the access screening and fitness-for-duty functions in one location and under the direction of the Site Access Services Supervisor, who has 14 years experience in station access processing, has resulted in an effective process that allows processing of personnel in a proper and timely manner.
The administration of the AAP is considered a program strength.
Background Investigations
{BI) Elements Ins ection Sco e
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 areas.
Observations Findin s and Conclusions The inspectors reviewed the results of 45 background investigations
{BIs) representing a cross-section of licensee and contractor employees.
The BIs are performed by the licensee's Site Access Specialists.
The scope and depth of the BIs reviewed were found to meet the licensee's program commitments and provided adequate information on which to base a
determination for access authorization.
The 45 BI reports also contained 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 BI, and fulfilled the program requirements to which the licensee had committed.
The inspectors noted that any matter of questionable or suspect information was thoroughly evaluated and documented prior to granting or denying of temporary access.
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 all information received from the U.S, Attorney General.
Among the records reviewed by the inspectors were those of eight individuals whose fingerprint records
e had been returned with derogatory information.
The inspectors determined that the information had been properly evaluated and appropriate action had been implemented as a result of the derogatory information.
P8.4 Psychological Evaluations a.
Ins ection Sco e
The inspectors reviewed the licensee's psychological testing program procedures and interviewed the individuals who administer and proctor the psychological tests.
b.
Observations Findin s
and Conclusions 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 licensee 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 recommendation.
The inspectors determined that procedures were clear and that the proctors demonstrated a sound knowledge of their duties.
The inspectors determined that the licensee's psychological evaluation program was being effectively administered.
P8.5 Behavioral Observation Program (BOP)
a.
Ins ection Sco e
The inspectors reviewed the Behavioral Observation Program (BOP)
training procedures and lesson plans and conducted interviews to determine the effectiveness of the licensee's program.
b.
Observations Findin s
and Conclusions The BOP was reviewed to determine whether the licensee had a training and retraining program 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.
The program was instituted as part of, and is an element in common with, the licensee's Fitness-for-Duty (FFD)
Program.
The inspectors concluded that the training program and lessons plans were adequate to support the 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 the BOP training was further evidenced by the fact that employees had been referred to the employee assistance program and had been FFD for-cause tested as a result of changes in behavior that were identified through the BOP.
The effective implementation of the BOP is considered a
program strength.
P8.6 Grandfathering, Reinstatement and Transfer of Access Authorization a.
Ins ection Sco e
The inspectors reviewed a cross-section of records to evaluate the licensee's application of the provisions for Grandfathering, Reinstatement and Transfers of Access Authorizations.
b.
Observations and Findin s
o
"Grandfatherin
"
Included in the records selected at random by the inspectors were records of personnel who did not meet the criteria for
"grandfathering," i.e.,
those who did not have uninterrupted, unescorted access authorization for at least 180 days on April 25, 1991, the date of publication of the NRC's access authorization rule.
~
Reinstatement The licensee's criteria for reinstatement of access authorization was reviewed.
The criteria provided for reinstatement of unescorted access authorization if one had been previously granted, and that authorization was terminated under favorable conditions no more than 365 days prior to the reinstatement request, and FFD program requirements were met.
e Transfer of Access Authorization The li,censee incorporated the provision for the transfer of access authorization, both receipts in and transfers out, into its program.
The records selected at random for review by the inspectors included several examples of each.
c.
Conclusions The inspectors determined that the requirements for grandfathering, reinstatement and transfers of access authorizations were being met and that these portions of the AAP were being implemented satisfactorily.
No discrepancies were note P8.7 Temporary Access Authorization a.
Ins ection Sco e
The inspectors reviewed records that included the results of abbreviated scope investigations, which are used as the basis for granting temporary unescorted access authorization, as permitted by the rule.
b.
Observations Findin s and Conclusions The records of the abbreviated scope investigations were determined to contain adequate information (character and reputation from a developed reference, past year's employment history, and a credit check)
on which to base temporary access authorization.
The inspectors noted that, in these 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.
P8.8 Oenia1/Revocation of Unescorted Access a.
Ins ection Sco e
The inspectors reviewed the licensee's provisions for the review of appeals of denial or termination of access authorization.
b.
Observations Findin s and Conclusions The inspectors determined that an individual is informed of the basis for denial or revocation of access authorization, is provided the opportunity to provide additional information for consideration and can have the decision, and any additional information, reviewed by the Senior Vice President-Nuclear and a representative of the corporate legal department.
After that review, the decision on the appeal is final.
The inspectors concluded that this aspect of the program was in accordance with the rule and was being adequately implemented.
P8.9 Audits a.
Ins ection Sco e
The inspectors reviewed the most recent nuclear quality assurance audit of the security and access authorization programs (Audit No.95-105 conducted September 18-November 13, 1995).
b.
Observations Findin s
and Conclusions The inspectors'eview of the audit disclosed that the audit identified one finding associated with the AAP.
Specifically, a review of the licensee's BOP tracking report by the auditors, identified 40 supervisors in the Mobile Work Force who had not received BOP training.
Therefore, the licensee was unable to verify that approximately 844 mobile work force personnel, who maintained access authorization, were
subject to a continual behavioral observation program.
Although the mobile work force personnel had active access authorizations, they had not been onsite.
The inspectors determined, based on discussions with security management and a review of the response to the finding, that the corrective actions, which included termination of the access authorizations for the mobile work force personnel, were effective.
The inspectors'eview concluded that the audit was comprehensive in scope and depth, that the finding was reported to the appropriate levels of management, and that the program was being properly administered.
PS. 10 Record Retention a.
Ins ection Sco e
The inspectors reviewed the onsite record retention program for the AAP records.
b.
Observations Findin s
and Conclusions The inspectors determined that the storage facilities provided adequate security, and that access to those records was adequately controlled to protect personal information from unauthorized personnel.
Records are stored in a locked room, accessible only to authorized personnel.
The inspectors noted that the records were very well organized and complete.
Xl. 1 Exit Interview The inspectors presented the inspection results to members of licensee management at the conclusion of the inspection on June 14, 1996.
At that time, the purpose and scope of the inspection were reviewed and the preliminary findings were presented.
The licensee acknowledged the preliminary inspection findings.
Xl.2 Updated Final Safety Analysis Report (UFSAR) Review A recent discovery of a licensee operating their facility in a manner contrary to the UFSAR description highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR description.
Security requirements are not specifically included in the UFSAR; they are in the licensee's NRC-approved security plan.
While performing inspections discussed in this report, the inspectors reviewed applicable portions of regulatory requirements that related to the areas inspected.
In addition to inspecting the licensee's AAP, the inspectors also reviewed the licensee's Fitness-for-Duty (FFD) random testing program.
The inspectors determined that unannounced drug and alcohol testing was being performed in a statistically random manner so that all persons within a group would have an equal probability of selection and would be immediately eligible for selection for another test.
Random selection records for 1996 were reviewed and the inspectors verified that testing was being performed on weekends, back shifts, and holiday ~
Additionally, the program included for-cause testing, testing for those who are temporarily absent, those with infrequent access, and those who are not available for scheduled testing.
No discrepancies were noted in the FFD random testing progra PARTIAL LIST OF PERSONS CONTACTED Penns lvania Power and Li ht Com an C. Carver, Site Access Specialist C. Caddington, Senior Project Engineer-Licensing R. Ferentz, Security Operations Supervisor G. Kuczynski, Plant Manager J. Keating, Site Access Specialist C.
Lopes, Manager, Nuclear Security A. Papinsick, Site Access Specialist R. Southworth, Site Access Specialist L. Yupko, Site Access Services Supervisor Nuclear Re ulator Commission M. Banerjee, Senior Resident Inspector B. McDermott, Resident Inspector