IR 05000397/1996023

Insp Rept 50-397/96-23 on 961118-22.No Violations Noted. Major Areas Inspected:Engineering & Plant Support

ML20133C911
Person / Time
Site:	Columbia
Issue date:	12/16/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:
Shared Package
ML20133C897	List: IR 05000397/1996023 ML20133C894
References
50-397-96-23, NUDOCS 9701080140
Download: ML20133C911 (15)

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i ENCLOSURE-

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U.S. NUCLEAR REGULATORY COMMISSION REGION IV  ;

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Docket No.: 50-397 j License No.: NPF-21 j Report No.: 00-397/96-23 Licensee: Washington Public Power Supply System i

Facility: Washington Nuclear Project-2 Location: 3000 George Washington Way Richland, Washington Dates: November 18-22,1996 Inspectors: Thomas W. Dexter, Senior Physical Security Specialist Dennis W. Schaefer, Physical Security Specialist l Approved By: Blaine Murray, Chief, Plant Support Branch Division of Reactor Safety Attachment: Supplemental Information

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9701080140 961216 PDR ADOCK 05000397 G PD . -

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l l-2-l EXECUTIVE SUMMARY Washington Nuclear Project-2 NRC Inspection Report 50-397/96-23

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This was a special, announced inspection of the licensee's access authorization program utilizing Temporary Instruction 2515/127," Access Authorization," dated January 17, 199 Enaineerina

• The Updated Final Safety Analysis Report (UFSAR) wording was consistent with the observed plant access authorization practice and procedures (Section E2).

Plant Supoort

• implementation of the access authorization program was effective. The staff were knowledgeable and performed their duties in an excellent manner. Management support for the program was excellent (Section S1.1).

• Background investigations were completed in a comprehensive and thorough manner (Section 1.2).

• An excellent psychological evaluation program had been established. Effective implementing procedures had been developed for the psychological evaluation program (Section S1.3).

• Implementation of the behavioral observation program was excellent. Supervisors and managers had been properly trained on the behavioral observation program requirenents. Individuals had been informed of thei responsibility to report arrests that could affect their trustworthiness (Section S1.4).

• The grandf athering, reinstatement, updating, transfer, and temporary access program elements were properly administered in accordance with rule requirements (Section S1.5).

• A good program for denying or revoking unescorted access was in place. The criteria used by the licensee was appropriate. It was noted that the licensee did not have documentation for notifying individuals denied access (Section S1.6).

• An excellent program was in place to protect personal information from i

unauthorized disclosure. Procedures were in place to ensure that information was

! only released to those staff members with a need for access (Section S1.7).

• The audit of the site access authorization program was timely, however, an inspection followup item was identified involving the licensee's weak audit and the incomplete audit checklist (Section S1.8).

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• An excellent records retention system and supporting procedures were in place to i

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insure that the specified records were retained for the correct period of time. A noncited violation was identified involving incomplete background screening prior to ,

the completion of suitable inquires being submitted (Section S1.9). l l

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r Report Details Ill. Enaineerina

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E2 REVIEW OF COMMITMENTS IN THE UPDATED FINAL SAFETY ANALYSIS REPORT (UFSAR)

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, l procedures, and/or parameters to the UFSAR descriptions. While performing the inspection discussed in this report, the inspectors reviewed the applicable portions of the UFSAR that i related to the areas inspected. The inspectors verified that the UFSAR wording was consistent with the observed plant practices, procedures, and/or parameters.

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- IV. Plant SuDDort i

i ACCESS AUTHORIZATION (TEMPORARY INSTRUCTION 2515/127)

On April 25,1991, the Commission published the " Personnel Access Authorization

< Requirements for Nuclear Power Plants," 10 CFR 73.56, requiring power reactor licensee

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to implement an access authorization program by April 27,1992, and to incorporate this

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program into the licensee's physical security plan. The objective of the rule was to provide high assurance that individuals granted unescorted access were trustworthy and reliable, and did not constitute risk to health and safety of the public, including a potential to

commit radiological sabotag 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 access authorization progra S1 Conduct of Access Authorization Program Activities j

S1.1 Access Authorization Program Activities and Organization insoection Scope (Tl 2515/127)

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The inspectors evaluated the access authorization program administration and

implementation through the assessment of management involvement, oversight and support of the program, structure and interf aces of the organization, the authorities

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and responsibilities assigned, and the specialized training and work experience of key program personnel. The licensee's program to determine if a single insider could grant and allow unescorted access into the protected and vital areas was also reviewe . __ _ _- _- _. ___ . . _ _ _ _ _ . _ _ - _ . _ . . -._ _ . _ ._ _ _-

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i Observations and Findinas

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Responsibility for overall management of the Access Authorization Program was assigned to the security programs manager. The supervisor of Safeguards and investigations (or designee) was responsible for making a final determination for granting individuals unescorted access.

i The inspectors interviewed program administrators and site representatives and

determined that they were knowledgeable of program responsibilities and performed

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their duties in an excellent manner. The inspectors reviewed the utility's access

{ authorization program procedures and noted that they were concise and contained i the guidance necessary to implement the program.

j The inspectors determined by a review of the procedures anri interviewing access

personnel that a system was in p! ace that prevented a single insider from allowing

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an unauthorized person unescorted access into the protected and vital areas.

4 The inspectors conducted interviews with access authorization program staff and

termined there was excellent management support for the program.

l l Conclusions i Implementation of the access authorization program was effective. The staff were

knowledgeable and performed their duties in an excellent manner. Management i support for the program was excellent.

f S1.2 Background Investigations Elements i

Insoection Scoce (Tl 2515/127)

i The inspectors reviewed records and conducted interviews to determine the i adequacy of the program. The inspectors also reviewed information concerning the I licensee's verification of identity, employment history, education history, credit l

history, criminal history, military service, and the character and reputation of the applicants, before granting individuals unescorted access to protected and vital i areas.

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Observations and Findinas i

i The inspectors verified documentation in 60 background files including ten files l

provided by self-screening contractors and determined that all elements of a

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successful background investigation were completed in accordance with the i physical security plan and regulatory requirements. The inspectors verified that, j when the licensee reviewed perio& of employment and unemployment, they also specifically verified employee activntes during periods of unemploymen J

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l d Conclusions l

Background investigations were completsd in a comprehensive and thorough l manner in accordance with regulations, the physical security plan, and procedural >

requirement .

S1.3 Psychological Evaluations Inspection Scope (Tl 2515/127)

The inspectors reviewed the licensee's program for administering psychological tests and the methodology for evaluating the results prior to granting individuals unescorted access authorizatio ]

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The licensee administered psychological tests to all individuals requesting  ;

unescorted access into the protected area. The inspectors confirmed by observation and interviews that personnel taking the test were positively identified and that the test was proctored to prevent compromise. A contractor evaluated the tests and a psychnlogist was at the site during testing of large numbers of individuals to conduct oral interviews when necessary. The inspectors determined that the psychologist had developed proper standards for use in reviewing test result 'The licensee was aware of NRC information notices addressing access authorization concerns in the area of psychological testin Conclusions The licensee's psychological evaluation program was excellent. Effective implementing procedures had been developed for the psychological evaluation l progra S1.4 Behavioral Observation Program a, insoection Scope (Tl 2515/127)

The licensee's behavioral observation program was inspected to determine whether supervisors and managers were trained to detect and report changes in behavior that could adversely affect trustworthiness and reliability, and that employees were aware of their responsibility to report all arrests to the licensee, Observations and Findinas The inspectors verified the effectiveness of the continual behavior observation program procedures and the associated training lesson plans. The procedures covered all of the program elements in a clear and effective manner. In addition, i

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the inspectors interviewed six licensee supervisory and management level personnel, one contractor supervisor, and a plant training instructor. All the supervisory and management personnel interviewed had been trained in behavioral observation. From the interviews, it was apparent that an excellent behavioral observation program had been implemented and that training and annual retraining were on-going and effectiv Paragraph 9.0 of the appendix to Regulatory Guide 5.66 (NUMARC 89-01) states, in part, individuals with unescorted access authorization must be notified of his/her responsibility tc report any arrest that may impact upon his/her trustworthines The inspectors determined, by interviewing several individuals with unescorted

access into the protected area, that the licensee had notified individuals of their l responsibility to report all arrests that could affect their trustworthiness.

} Conclusions The licensee's behavioral observation program insured that all applicable supervisors and managers had been trained and retrained as appropriate. Individuals had been informed of their responsibility to report arrests that could affect their trustworthiness. Implementation of the behavioral observation program was excellen S Grandfathering, Reinstatement, Updatir3, Transfer and Temporary Unescorted Access Authorization Insoection Scope (Tl 2515/127)

The inspectors reviewed the licensee's program for grandf athering, reinstatement, updating, transfer, and temporary unescorted access to insure compliance with requirements, Observations and Findinas As part of the review activities for the files discussed in Section S1.2, the inspectors determined that employees were granted access in accordance with the regulatory requirements and applicable NRC guidanc The inspectors reviewed 12 transferred accese ' ahorization files of individuals whose original access authorization background investigations were either completed by another licensee or a self screening contractor accepted by another licensee. The files were complete and provided allinformation needed to extend unescorted access to the licensee's f acilit The inspectors reviewed eight files that contained reinstatements of access af ter unescorted access had been terminated for less than 1 year. The licensee conducted employment and " suitable inquiry" inquiries for all periods of time where the individuals did not have unescorted access under an approved access authorization and fitness for duty progra _ _ _ .- -

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8-The inspectors reviewed six update files of individuals whose access had lapsed for a period exceeding 1 year. Over half of the files contained a temporary unescorted access authorization. Overall, the updates were effectively completed with complete background investigations for whatever period of time the employee's access had lapse The inspectors reviewed seven files of individuals that were grandfathered into the

, program in accordance with NRC requirements. The files contained all of the information necessary to validate that the individual met or exceeded all requirement Conclusions

The grandfathering, reinstatement, updating, transfer, and temporary access program elements were administered in accordance with rule requirement Sl.6 Denial or Revocation of Unescorted Access Insoection Scone Ti 2515/127)

The inspectors reviewed the licensee's system for denial or revocation of unescorted access authorization to determine if the licensee had implemented a proper procedure for the review, at the request of the affected individual, of a denial or revocation by the licensee of unescorted access of an employee of the licensee,

- contractor, or vendo Observations and Findinas The inspectors verified that the licensee had implemented a proper procedure for the review, at the request of the affected individual, of a denial or revocation by the licensee of unescorted access of an employee of the licensee, contractor, or vendo The inspectors verified that the rationale used by the licensee in its decision for denial was appropriat However, the inspectors identified two examples in which the licensee was unable to provide documentation which verified that individuals had been informed of the basis for their denial or revocation, and had been verbally advised of their right to have the decision, together with any additional information, reviewed by another designated independent manger of the Supply System who was equivalent or senior to and independent of the individual who made the initial decision to deny or revoke unescorted access authorization. The inspectors verified through interviews that the individuals denied unescorted access had been verbally advised of the above requirement .

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The inspectors reviewed the licensee's file system and procedures to determine whether personalinformation was disclosed to unauthorized persons. File maintenance and access control was also reviewe Observations and Findinas The inspectors interviewed licensee personnel to determine that personal information was protected from disclosure to anyone without a need to know and the authority to have access to that information. The background information files were kept in a secure area with access limited to only those staff members with a need for access. The area was secured by an alarmed door and records were also protected by a fire suppression system. Procedures were in place to ensure that information was only released to those staff members with a need for acces Conclusions An excellent program to protect personal information from unauthorized disclosure was in place. Procedures were in place to ensure that information was released only to those staff members with a need for acces S1.8 Audits Insoection Scope (Tl 2515/127)

The inspectors reviewed the licensee's audit program to determine if audits of the access authorization program were timely and of sufficient depth to detect problem Observations and Findinas The inspectors verified the thoroughness of seven audits of the licensee's access authorization program to determine if proper audits were conducted. The licensee's records included copies of several audits of contractor programs. Some of the audits were performed by other licensees and, according to the regulations, were accepted by the licensee to satisfy their own audit requirements. The licensee retained responsibility for the effectiveness of the contractors' programs and for the implementation of appropriate corrective actions by the contractor . . _ - .. .. . -- .

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l Additionally, the inspectors reviewed the licensee's October 15,1996, audit of the WNP-2 security program. Section 7.0 of this audit included the results of the licensee's bi-annual (every 24 months) audit of its access authorization progra The inspectors determined through an interview with the auditor and a review of this portion of the audit report, that the licensee's audit of the access authorization program was superficial and weak. Upon initiation of the audit, the licensee's investigations supervisor explained the contents of two background investigation files to the auditor. The inspectors determined that over 6,000 background investigation files were available for review. The auditor stated that he did not review any other background investigation files. The auditor also stated that during the audit, he had only reviewed computer listings of names, and associated information, of allindividuals that had been denied or granted unescorted site acces Additionally, the inspectors reviewed the audit checklist utilized during the above audit of the access authorization program. Item 12a of the checklist states, "Is there a procedure (emphasis added) for the review, at the request of the affected l employee, of a denial or revocation by the licensee of unescorted access i l

authorization of an employee, contractor, or vendor?" During the inspection, the inspectors explained to the auditor that Regulatory Guide 5.66 requires more than just insuring that the process for reviewing information related to denials and j

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revocations is in place. Regulatory Guide 5.66 requires that the audit evaluate the licensee's conformance to the published guidelines for denials and revocation These guidelines require that each permanent employee of a utility whose employment is or will be terminated as a direct result of a denial or revocation of unescorted access authorization will: (1) be informed of the basis for lenial or revocation of authorization for unescorted access; (2) have the opportunity to provide any additional information; and (3) have the decision, together with any )

additionalinformation, reviewed by another designated manager of the utility who is l

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equivalent or senior to and independent of the individual who made the initial decisien to deny or revoke unescorted access authorization. Thus, the licensee's audit checklist for the access authorization portion of the 1996 audit was incomplete and did not insure that the licensee's program for denials or revocation of unescorted access authorization met the regulatory requirements. The results of the inspectors' review of licensee denial and revocation records is discussed in paragraph S1.6 above. The weak audit of the access authorization program and incomplete audit checklist is considered an inspection followup item (IFl 50-397/9623-01).

The inspectors also reviewed the 1994 audit of the access authorization program, ;

and interviewed the auditor. The inspectors verified that a sufficient number of background investigation files had been thoroughly reviewed. The 1994 audit was indepth and comprehensiv i l

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-11- Conclusions The licensee's audit of the site access authorization program was timely, however, an inspection followup item was identified involving the weak audit and incomplete audit checklis S 1.9 Records Inspection Scoce (Tl 2515/127)

The inspectors reviewed the licensee's records to insure that adequate access authorization records were retained for the appropriate tim Observations and Findings The inspectors determined that the licensee's procedure for records retention correctly identified the required records and retention times for the records. All required documents supporting the final granting of unescorted access to an individual were in the fil The licensee's current Physical Security Plan, paragraph 3.3.1, " Personnel Reliability," states, "All elements of Regulatory Guide 5.66, " Access Authorization Program for Nuclear Power Plants," have been implemented to satisfy the requirements of 10 CFR 73.56," Personnel Access Authorization Requirements for Nuclear Power Plants," and applies to all persons who will require unescorted access to the protected and vital area Regulatory Guide 5.66, " Access Authorization Program for Nuclear Power Plants,"

with attached Appendix, " Industry Guidelines for Nuclear Power Plant Access Authorization Programs," paragraph 6.4, states, in part, "A utility may grant temporary unescorted access authorization on an interim basis not exceeding a period of.180 days pending completion of the checks required by the unescorted access program." This 180-day temporary unescorted access authorization may be granted based upon satisfactory completion of the following conditions:

(1) Identity verification through one photo identification (i.e., driver's license, military ID, passport, or similar document).

(2) Passing a psychological evaluation within the past yea (3) Conduct of a credit chec (4) Recommendation of one developed character reference who has had a frequent and direct association with the applican (5) Evidence that a request for a criminal history c'n eck of the individual by the FBI has been submitted to the NR )

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-12-(6) Conduct of an employment check for the past yea The inspectors reviewed the licensee's safeguards events logs and found that the licensee had logged 10 events in which unescorted access had been granted to individuals with incomplete background screening or access had been granted prior to the completion of suitable inquires being submitted. These events were a violation of NRC requirements and the licensee identified these events during an internal audit of their records. The licensee's corrective action in each case was to complete the required screening, verify that the individual would not have been denied access based on the background check informa"on received, and counsel the employee completing the background check on compiiance with the requirements. During the inspection, the adequacy of the corrective actions was discussed with the licensee and, before the end of the inspection, the licensee informed the inspectors that they had revised the background investigation screening log to highlight those specific requirements that must be completed prior to temporary unescorted access being granted. The revision also allowed the reviewer to conduct a quality check for comoliance by a simple review of the completed form. This violation is being treated as a noncited violation consistent with Section Vll.B.1 of the NRC Enforcement Policy (NCV 50-39'7/9623-02).

During the review of the above records the inspectors found that the licensee did i not have security incident reports on file for several events. The licensee had D logged the events and had a copy of the safeguards event log record in the fil The security incident report described the licensee's investigation of the event and the corrective actions taken to prevent recurrence. Prior to completion of the inspection, the inspectors verified that the licensee had implemented corrective actions to ensure that security incident reports were initiated on all access '

authorization program loggable event Conclusions An excellent records retention system and supporting procedures were in place to insure that the specified records are retained for the correct period of time. A noncited violation was identified for incomplete background screening prior to the completion of suitable inquires being submitte V. Manaaement Meetinas X1 Exit Summary The inspectors presented the inspection results to members of the licensee management at the conclusion of the inspection on November 22,1996. The licensee acknowledged the findings presented. No proprietary information was identified.

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j ATTACHMENT

) PARTIAL LIST OF PERSONS CONTACTED i

Licensee

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g J. Albers, Manager, Nuclear Training W. Bartley, Manager, Quality P. Bemis, Vice President, Nuclear Operations 4 'A. Conner, Security Operations Lead

F. Dehart, Supervisor, Investigations

L. Fernandez, Manager, Licensing

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R. Givin, Security Force Supervisor

- D. Martin, Manager, Security Programs J. Muth, Manager, Quality Services V. Parish, Chief Executive Officer ,

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G. Smith, Plant General Manager

, J. Swaites, General Manager, Engineering

D. Swank, Manager, Regulatory Affairs R. Webring, Vice President, Operations Support l NRC t

D. Powers, Chief, Maintenance Branch, Region IV

! G. Replogie, Resident inspector ,

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! INSPECTION PROCEDURES USED J

Tl 2515/127 Access Authorization J

i T LTEMS OPENED. CLOSED AND DISCUSSED i

Opened

50-397/9623-01 IFl Weak Audit of the Access Authorization Program 50-397/9623-02 NCV Temporary Unescorted Access Granted without Background Investigation Screening Completed

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Closed 50 397/9623-02 NCV Temporary Unescorted Access Granted without Background Investigation Screening Completed

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i LIST OF ACRONYMS USED Continual Behavior Observation Program

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CBOP ,

) FBI Federal Bureau of Investigation MMPI-2 Minnesota Multiphasic Personality Inventory - 2 i

NCV Noncited Violation NRC Nuclear Regulatory Commission i

LIST OF LICENSEE DOCUMENTS REVIEWED l

, Selected Background Investigation Files

General Employee Training Lesson Plan, " Protected Area Access - Initial," Revision 10, dated August 8,1995

Licensee Procedures

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WNP Administrative Procedure Manual GlH 6.3.1, " Unescorted Access Authorization

Program," dated April 26,1996

- WNP Investigations Operating Instruction 1017.2, " Unescorted Access Authorization Program," dated August 28,1995

I WNP Security Operating Procedure 1.3, " Unescorted Access Authorization Program,"

dated February 20,1996 WNP Investigations Operating Instruction 7.4, " Unescorted Access Photo Badges and Keycards," dated May 6,1996 WNP Investigat;on Operating Instruction 7.8, " Access Authorization Exchange," dated September 5,1995 WNP Administrative Procedure Manual GlH 4.2.5," Continual Behavioral Observation Program, dated December 11,1995 WNP MMPI-2 Psychological Testing, " Test Administrator Checklist," dated February 28, j 1995

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i Audit Reoorts WNP-2 Quality Department Audit Report 296-069, "WNP-2 Security Program," dated October 15,1996, (partial) *

WNP-2 Quality Department Audit Report 294-065, "WNP-2 Security Program," (partial) -

WNP-2 Quality Directorate Audit Report 295-092," Supply System Fitness for Duty  ;

i Program," (partial)

Southern Nuclear Operating Company (NEI) Audit Report of Westinghouse Electric '

Corporation, dated September 27,1996,(partial)  ;

Perry Nuclear Plant (NEI) Audit Report of General Electric Company, dated September 18, 1996, (partial)

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r South Carolina Electric and Gas Company (NEI) Audit Report of Bartlett Nuclear Company, E dated April 1,1996, (partial)  !

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! General Electric Company Audit Report CNTR 96-01, of Wackenhut Corporation, dated  !

May 15,1996 General Electric Company Audit Report CNTR 96-03, of The Stress Center, dated July 8,  ;

i 1996 Contractor Procedures (

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, Bartlett Nuclear Inc. Procedure, " Supply Sy<, tem Unescorted Access Authorization l l Program," dated March 9,1992 l

General _ Electric Energy Procedure, " Nuclear Power Plant Unescorted Access Authorization Program," dated April 1993 Institute of Nuclear Power Operations (INPO) Procedure A-3, " Unescorted Access

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Program," dated April 29,1993 l-Westinghouse Electric Corporation Procedure, " Westinghouse Electric Corporation Access Authorization Programs," dated March 6,1992, with Interim Procedure Revision 96-001, l dated January 22,1996' j l

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