IR 05000483/1983024

IE Safeguards Preoperational Insp Rept 50-483/83-24 on 831024-31.No Noncompliance Noted.Major Areas Inspected: Status of Implementation,Installation & Operability of Security Program.Details Withheld (Ref 10CFR73.21)

ML20244C790
Person / Time
Site:	Callaway
Issue date:	11/29/1983
From:	Creed J, Pirtle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20082J821	List: IR 05000483/1983024
References
50-483-83-24, NUDOCS 8312020328
Download: ML20244C790 (7)

Text

.

.

U. S. NUCLEAR REGULATORY COMMISSION

'

REGION III

I Report No. 50-483/83-24(DRMSP)

Docket No. 50-483 License No. CPPR-139 Licensee: Union Electric Company Post Office Box 149 - Mail Code 400 St. Louis, MO 63166 Facility Name: Callaway County Nuclear Power Station, Unit 1 Inspection at: Callaway County, MO Region III Office, Glen Ellyn, IL Inspection Conducted: October 24-27, 1983 at Callaway County October'31, 1983 at Region III Office

.

Type of Inspection: Initial Announced Pre-operational Physical Protection Inspection

-

Inspector: n/d444I4t' If, [fN G. L. Pirtle b' Date Physical Protection Specialist Approved By:

J R. Creed, Chief h ffD Date'

afeguards Section Inspection Summary

.

Inspection on October 24-31, 1983 (Report No. 50-483/83-24(DRMSP)

Areas Inspected: This was the first Safeguards Preoperational inspection at the sit It included a review of the status of implementation, installation, and operability of the security program and preoperational testing program for .

security-related equipmen Specifically, the inspection addressed: Security Plan and Implementing Procedures; Security Organization - Management - Personnel; Security Program Audit; Testing and Maintenance; Physical Barriers - Protected Area; Assessment Aids and Acces's Control - Personnel. The inspection involved 26 inspector-hours onsite by one NRC inspector. An additional 8 inspector-hours were completed in the Region Ill offic Results: Based on this pre-operational inspection, three areas of concern and twelve findings were identified. The areas of concern pertained to the licensee's l

' approved Security Plan, the proposed screening program for personnel to be granted

' unescorted access to the site, and compliance with the proposed schedule for completion of acceptance testing for security equipment. The concerns and findings do not represent noncompliance but represent items which must be completed and/or resolved prior to fuel loa ~

. Q3/k[Ohb

-

" (Details - UNCLASSIFIED SAFECUARDS INFORMATION) ~

-

. (IU" n- Contains FJORMAT10M

' ~

hj;[ :;,r ...lL.cn This. 4 3 rc,p 13 Lecontrolle'd

_

.

Wl An " ll ~

.

(1) A complete technical and administrative review of the licensee's Security Plan was required. Some commitments in the Security Plan exceed system design capability. Such commitments included required closed circuit television coverage of the entire. isolation zone and tamper alarms for intrusion detection security equipment panels, boxes, and enclosure If relief for these requirements is not obtained, the CCTV system and existing equipment tamper alarms will not meet Security Plan criteria. Administrative changes pertaining to personnel screening requirements for licensee (UE)

employees and routine testing of breakwire alarm systems were also {

necessary. Additionally, there were indications that drawings in i the Security Plan which depict CCTV coverage, main access facility and secondary access facility equipment layout, and the location of all alarm equipped doors may not be accurate. Therefore, the simplified drawings in the Security Plan required verification for accurac s (2) Personnel screening requirements for unescorted access to the plant needed to be clarified and initiate Screening requirements identified in the Security Plan for licensee employees were more stringent than the requirements contained in the security procedur )

The proposed screening program included the less stringent procedural j screening requirements. As of the close of the inspection i (October 27, 1983), contractors whose screening programs were to I be accepted had not been formally identified, licensee screening requirements had not been identified to contractors, and contractor (s)

who may perform screening for the licensee's Security Section had not J

been formally selected. Discussions with,the Security staff indicated i that in excesa of 1,000 persons may require screening for unescorted access to the plant upon receipt of an operating licens I The inspector emphasized that the screening process is normally time consuming and contractor screening programs would require )

review before approval. In addition to the screening requirements, training stipulated in the Security Plan had to be completed before granting unescorted access to protected and vital areas of the plant (refer to Paragraph 11 for further information).

l (3) Adherence to the Nuclear Operations Planning and Scheduling Depart-ment Project Schedule (Data Date 14 October 83) appears mandatory  ;

if the projected March 1,1984 Security Plan implementation date  ;

is to be achieved. The inspector noted that the schedule was very -

demanding based upon the amount of security equipment involved. The inspector emphasized that the capability of the security computerized ,

access control and alar'n monitoring system could only be accurately '

determined by subjecting the system to day-to-day demands. Delays in acceptance testing, personnel screening, security training and/or

.

!

CAS/SAS operator training could adversely impact on when the security computer system could be considered as capabic of meeting Security Plan criteri (Refer to Paragraphs 5, 6, 8 and 11 for further information.)

.

t. ', ,...-. 1 =

4 ,

• I) .

• * 8'*

.. . . _ _ . - -

7,

-

_ _ __ __

_ _ _ _ _ _ _ _ _ ,

_

i r -m

-

f

,

.

completio The Assistant Superintendent of Security' position and responsibilities also need to be included in a revision to the security-pla (483/83-24-02) s

!

The inspector noted that the Superintendent of Security does not " report i directly to the Plant Superintendent...." as described in Section 1.2.1.5 -

of the Security Plan. He reports directly to the Assistant Manager for Support Services who reports to the Plant Manager. Additionally, Section 1.2.1.1 of the Security Plan states that "the Assistant Plant Superin- j tendent and Superintendent Security...are the designated alternates for l the Plant Superintendent." A review of the Plant Organizational Structure dated September 14, 1983 indicated that there are'two Assistant Managers who report'to the Plant Manager.,. Sections 1.2.1.1 and 1.2.1.5 and Figure 1.2-1 of the Security Plan need to be revised to depict the correct lines of authority in reference to designated security l responsibilitie b, The organizational structure for the contract security force exceeds positions shown in Figure 1.2-2 of the Security Plan. However, the positions involve primarily security force overhead positions that may change upon issuance of an operating license. The overhead contract security force positions at the time of the inspection included: (Refer to Paragraph 6 for shift security personnel figures.)

Positions \

Quantity Site Security Supervisor 1 Key Control Supervisor 1 Locksmith / Armorer 1 Administrative Assistant to the 1 Site Security Supervisor Security Training Supervisor 1 Administrative Assistant to Security 1 Training Supervisor Security Training Instructor 2 Security Administrative Supervisor 1'

Administrative Assistant N the Security 1 Administrative Superd sor Security Operatione Coordinator 1 Total 11

.

The contract Security Force overhead positions appeared adequate to complete training requirements in preparation for issuance of an operating license and to support security operations upon implementa-tion of the Security Plan, The inspector and Superintendent of Security held in-depth discussions pertaining to planned implementation of required security function The Superintendent of Security stated that he was using the Nuclear Operations Planning and Scheduling Department (NOP&S) project schedule as his management document to determine projected completion dates

_t ,

b j-[h

~

7 =

"

@

__ _ _ _ -

,

,

,

On -.

-

ni, .- .n , , , , . . ,. im -

a ..

nn m uv u i y M n .J u

-

.

for key security functions. The NOP&S project schedule (Data date October 14, 1983) showed the following projected. completion dates for remaining crit.ical security functions:

-

Proj ected j Proj ect Completion Period or Date Receipt of security equipment October 5 - December 23, 1983 spare parts ,

Notification of Initiation of November 1, 1983 )

Screening Program  ;

Revision 3 to Security Plan December 15, 1983 j sent to NRC Security Equipment Acceptance {

November 17 - December 23, 1983 i

'

Test  !

Radio Equipment Installed November 30, 1983 -  !

All Security Officers Hired December 9, 1983 i and Initially Trained

!

BadgingsEquipment Operational December 30, 1983 l Complete Procedures for Operability December 30, 1983 i Tests for Intrusion Alarm System '

and Special Detection Equipment CAS/SAS Operators Certified December 15, 1983 -

January 25, 1984 All Security Officers Certified Prior to February 15, 1984 Security System Operational February 15, 1584' i Site Personnel Badged for Access December 30, 1983 -

February 28, 1984 Implement Security Plan March 1, 1984

.

The schedule appears demanding but necessary to meet the projected program implementation date of March 1, 1984. The Superintendent of Security was confident that the schedule could be complied wit Future inspections will monitor adherence to projected completion dates for the security program elements cited abov Close coordination appeared to exist between the Superintendent of Security and the contract Security Supervisor. Both persons appeared knowledgeable of the present status of the security program and the significant milestones for continued security system implementatio . Security Organization - Personnel (MC 81126B): * Interviews with the Superintendnet of Security and the contract Security Supervisor indicated that the current authorized strength for the security force was 108 personnel. During the inspection, 106 security force members were assigned. The following security shift positions were authorized: (483/83-24-03)

i I !S

{ ,$s ~ c ;, : :c, . ?. v . *f

,, xw n uo . . r t r cy; n ! An: ,

e

_-

!

, , , , , , -n i uru 1:

, - > ' " u

_yi  !

.

-

?

no such committee was planned fer the future. The Superintendent of '

Security was aware that Chapter 14 of the Security Plan required revi-sion to accurately depict security program audit responsibilities and the scope of such audit (483/83-24-04) The inspector confirmed that audits / surveillance of the security program was being performed by the Quality Assurance Department. The inspector -

reviewed the following audit / surveillance reports:  !

Report N Audit / Surveillance Period OQR 0579 September - October 1982 I 830305 March 21-25,:1983 AD5A830 September 19-23, 1983

The above audit / surveillance reports addressed:

(1) Review of Security Department Interim Procedures (2) Compliance of the Interim Security Plan with the NRC's five supplemental condition (3) Corrective actions for NRC Inspection Report 70-2945/82-01 (4) Identification and trackinE of Fuel Building problems related to security of special Nuclear Materials (5) Protection of Safeguards Information (6) Security Organization (7) Security Force and Local Law Enforcement Agency Training  ;

(8) Security Force Qualifications and Screening '

(9) Access Control (and Safeguards Information)

(10) Contingency Plans (11) Security Equipment and Systems l

The audit / surveillance findings indicated in-depth inspection of the l areas addressed. Emphasis on acceptance and operability tests, and procedures for maintenance and testing after acceptance, was included ,

in Audit Report AD5A8309A. This emphasis is appropriate and indicative of the auditor's understanding of the complexities of the security l system. All open licensee audit findings will be monitored by the inspector until they are close The inspector reviewed the proposed audit items for another audit scheduled in March 1984. The audit proposal included 25 areas plus direct observations of certain activities. The audit proposal appeared -

aggressive and appropriate based upon the licensee's proposed security ,

plan implementation date of March 1, 1984. During discussions with QA managers, they agreed to be responsive to recommendations pertaining to changes in audit items based upon preoperational inspection finding I During discussions of future audit activities with the Superintendent of Security and QA managers, audits of contractor screening programs were addresse The licensee tentatively plans to initiate such audits in the February / March 1984 time frame to assure that approved contractor i personnel granted unescorted access to the Protected and Vital Areas based upon contractor screening programs are screened in accordance with the licensee's criteri .

.

-

,e W

% p , . .. , ,, ,

. .. l

• _ _

3 i i I'

_M _

go, "'

1 Access Control - Personnel (MC 811705): Several major progras elements could adversely impact on an operational !

access control system before security plant implementation date. These I program elements include required security training for all contractor and licensee sonnel, requir personnel screening, acceptance testing

{

of quipment, fabrication of security '

completion o security orce training, and central and secon ary a are station operator training. In excess of 1.000 personnel may be subject to access centrol requirements. (483/83-24-08)

{

The Nuclear Operations Project Schedule (Data Date Octeber 14, 1983)

appears to have identified these program elements and completion dates have been projected (refer to Paragraph $ for details). The schedule 1 allows little deviation to meet the projected plan implementation date of March 1, 1984 DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques l DELETED - Not within the scope of this reques l

, DELETED - Not within the scope of this reques ,

t

, DELETED - Not within the scope of this reoues .

DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques .

DELETED - Mot within the scope of this reques DELETED - Not within the scope of this reques A conflict pertaining to licensee personnel (UE) screening requirements exist between Section 1.3.1.1 of the Security Plan and Section 4.1. Information in this record was deleted ,ffP/k-S4 ~779 in accordance with th freedom of information ( .-y

[ /M Act, exemptions N

' is -

[ . P'

F01 A #4 - 7 7 Sd'i t a o * ' ' '~'

-- - . .. .. _ .. . . .

___-

. ..

D t. 3 -

. ,r,

,7

'

-

1' '[ (

.

of Security Procedure SDP-ZZ-PP004. The Security Plan requires "all" UE employees allowed unescorted access at Callaway Plant to be screened in accordance with the requirements of ANSI 18.17-1983. Paragraph 4.3. (1)

of that standard requires an investigation to disclose adverse character trait Section 4.1.2.1 of Security Procedure SDP-ZZ-PP004 requ such an investigation for licensee employees (UE) "with less tha years of continuous services with Union Electric Company." The no e L stringent requirements of the Security Plan supersede procedural require-ments. This issue will be addressed by the licensee in their revision to the Security Plan in an ' to limit background investigations to UE employees with less then' years of continuous services with the compan Discussions with the Superintendent of Security indicated that screening results would be accepted from contractors who could meet UE screening requirements. As of the close of the inspection, no contractors had

'

been advised of the personnel screening requirements. However, a pamphlet, i

in draft format, had been prepared for distribution to contractors, The Superintendent of Security was aware that the contractor's personnel i

screening programs wou;d have to be reviewed to verify information i submitted in accordance with Section 1.3.1.4 of the Security Pla 'e y Contractor personnel who can not meet the licensee's screening require-

'; ments may have the screening conducted by the Security Departmen The Security Department plans to contract for such services with an outside agency. The ~ final determination of which agency would be ,

selected had not been made. Personnel screening requirements for licensee personnel is planned to be completed by the licensee Corporate Offic .imited psychological testing of personnel has been planned or initiate /duringfutureinspections. Screening procedures for each agency will be evaluated Personnel screening requirements for the security force sill be performed by the contract security agency. Interviews with the contract security force supervisor showed that Security Plan criteria identified in Section 1.4.2 is being used for their screening. All current security force personnel have been screened. Documentation for such screening vill be reviewed during subsequent inspection d.:

The Nuclear Operations project schedule requires security badging of personnel to occur between December 30, 1983 and February 28, 198 Equipment for badge fabrication had.not' arrived onsite as of this ,

inspection, but had been ordered. Approximately 2,000 card keys were

, availabit onsite for use,when the camera a6d fabrication meterial arrive DELETED - Not within the scope of this request.

DELETED - Not within the scope of this reques '

Information in this record was deleted f

in accordance with h Freedom of Information d'

& { "4, (

4\ Act, exemptions /'

/ f0lA M 9 9 6 y _- > ' ;( , A

. .

- -- =- -

_

_ - _ - _ _ _ _ _ _ _

.

"" i on n .

'.

,

n n

i s

u-1. i n u n. .

'i a

ui n .

s ..n..r W .

,

^

Enclosure Contains -

SAFEGUARD $ INT 0kMATIO!(

Upon Seperation This gg g Page is Decontrolled Docket No. 50-483 Union Electric Company ATTN: Mr. Donald F. Schnell Vice President - Nuclear Post Office Box 149 - Mail code 400 St. Louis, MO 63166 Gentlemen:

This refers to the pre-operational physical protection inspection conducted by Messrs. G. Pirtle and B. Stapleton of this office on November 28-December 2, 1983, of activities at the Callaway County Nuclear Station, Unit 1, authorized by NRC Construction Permit No. CPPR-139 and to the discussion of our findings with Mr. S. Miltenberger and other members of your staff at the conclusion of the inspectio The enclosed copy of our inspection report identifies areas examined during the inspectien. Within these areas, the inspection consisted of a selective examination of procedures and representative records, observations, and interviews with personne No items of noncompliance with NRC requirements were identified during the I course of this inspection. The enclosed report does contain certain findings  ;

which will be reviewed during future pre-operational inspections. No written 1 response is needed at this tim ,

We must eruphasize again that adherence to your security system implementation schedule is critical if program implementation is to be completed in time to allow reasonable time for evaluation by NRC Region III personne Areas examined during this inspection concern a subject matter which is exempt from disclosure according to Section 73.21(c)(2) of the NRC's " Rules of Practice," Part 73, Title 10, Code of Federal Regulations. This information must be handled and protected in accordance with the provisions of 10 CFR -

73.21. Consequently, our report of this inspection will not be placed in the Public Document Roo e

--

d

.24G/OYO'!fW pff

_ _ _ _ . .

pp-eM7o

., a sA -

-1 A < 15 -

< vA ui ,.e ' 2_ - 1

.

y

- - - -- --

,,,y in u-,i,>> q

.

--

...

,

i ,'1,, .in 1. i i n v i t e n s ivin '

-

, 1  !

~_

Enclosura centains SAFEGUARDS INFORMATl014 * j Union Electric Company 2 t!pon Separation This Jg t, ggntrolled f l

' 1 We vill gladly discuss any questions you have concerning this inspectio i

Sincerely,

W. L. Axelson, Chief  ;

Materials and Safeguards Branch Enclosure: Inspection Report No. 50-463/83-29(DRMSP)

(UNCLASSIFIED ) )

cc w/ encl:

W. H. Weber, Manager, Nuclear Construction S. E. Miltenberger, Plant Manager IE Files NMSS/SGPL NRR/DL/SSPB IE/DRP/ORPB ACRS cc v/ encl v/o UNCLASSIFIED :

DMB/ Document Control Desk (RIDS)

Resident Inspector, RIII -

Region IV K. Drey Ronald Fluegge, Utility Divison Missouri Public Service Commission

.

RIII RI RIII/

'

.RIII RIII diip # SEP A s e Pirtle/jp ftspleton p4 reed Kp Lin Axelson z /;g/83 on

.m o

n n n t - m , n i;, / 2.- _

i _y s . . n .,., --

%'

-- . , ,.

m', ,-