IR 05000483/1983029

IE Safeguards Insp Rept 50-483/83-29 on 831128-1202.No Noncompliance Noted.Major Areas Inspected:Status of Implementation,Installation & Operability of Security Program.Safeguards Info Deleted (Ref 10CFR73.21)

ML20244C801
Person / Time
Site:	Callaway
Issue date:	12/27/1983
From:	Creed J, Pirtle G, Bern Stapleton NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20083H322	List: IR 05000483/1983029
References
50-483-83-29, NUDOCS 8401040480
Download: ML20244C801 (7)

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. U. S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/83-29(DRMSP) License No. CPPR-139

Docket No. 50-483 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, M0 Inspection Conducted: November 28-December 2, 1983 Type of Inspection: Pre-Operational Physical Protection Inspection Date of Previous Physic.al Protection Inspection: October 24-31, 1983 Inspectors: b.S.h[dtc D ee .2% 1985 -

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G. L. Pirtle Date Physical Protection Specialist b.$. hb bee . art (,963

[B.W.Stapleton , Date Physical Protection Specialist; k.f. h[.M 0 b 21.t.9B's ApprovedBy:fJ.R. Creed, Chief

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Date Safeguards Section Inspection Summary Inspection on November 28-December 2, 1983 (Report No. 50-483/83-29(DRMSP))

Areas Inspected: Included a review of the status of implementation, installa-tion, and operability of the security program and pre-operational testing pro- '

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gram for security-related equipment. Specifically, the inspection addressed Security Plan and luplementing Proecures; Security Organization-Management;

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i Testing and Maintenance; Access Control-Personnel; Detection Aids-Protected j Area; Physical Barriers-Protected and Vital Areas; Communications; General Requirements-Training and Qualification Plan; and Safeguards Contingency Pla The inspection involved 76 inspector-hours onsite by two NRC inspector Eighteen of the 76 inspector-hours were conducted during off-shift period Eesults: 1he three areas of concern identified in paragraph 2 of Inspection j Report No. 90-453/83-24(DRMSP) remain open. Significant progress in the reviev j of the Secut ity Plan was noted and some progress pertaining to the personnel .

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,, screening program was noted. Five additional findings were identified during the inspection. The concerns and findings do not represent noncompliance but are items which must be corrected and/or resolved prior to fuel loa l (Details . UNCLASSIFIED )

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- . The inspectors reviewed the licensee's progress in addressing the three areas of concern identified in Paragraph 2b of Inspection  ;

Report No. 50-483/83-24(DRMSP). The inspectors noted that: '

(1) Since the last inspection,.significant progress was made in I addressing issues in the Security Plan which exceeded current'

system design capabilitie It was evident that an extensive  !

effort was expended to complete a technical and administrative review of the plan. Extensive discussion was held with licensee staff members pertaining to proposed Security Plan change The inspectors emphasized that the discussions did not represent formal positions and plan submittal should be initiated as l

I early as practicable for the required formal review and approval process to be completed by NRC, HQ Licensing personne (Refer to Paragraph 3 for further information.) 1 t

(2) Some progress had been made toward implementation of the Per- l sonnel Screening Program. However, a major effort is necess- 1

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ary to complete screening requirements before the Security j

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Plan implementation date of March 1, 1984. (Refer to Paragraph i

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8 for further information.)

(3) Progress in implementing the Nuclear Operations Project Schedule (Data Base October 14, 1983) had been delayed in several area These areas included security equipment acceptance testing, radio equipment installation, advising contractors of screening requirements, and security alarm station operator trainin It was noted that the projected dates of February 15, 1984 for the Security System to be operational and March 1, 1984 for implementation of the Security Plan had not been changed (refer to Paragraph 4 for further information). Based upon these delays, a new schedule was in the process of being develope The inspectors requested that a copy of the new schedule be sent to NRC Region III. (Refer to Paragraphs 4, 5, 8, and 10 for further information.)

The inspectors again expressed a concern about the licensee l having sufficient time to correct significant deficiencies noted during acceptance testing of security equipment. This concern was primarily in reference to factors in which the licensee had limited control over, such as availability of vendor represen-tatives, delivery dates for new components that may be needed, -

and weather conditions for outside equipment modification The licensee anticipated that the position of Assistant Superintendent of Security would be manned during December 198 The licensee representatives were advised that the following obser-vations must be corrected or resolved prior to issuance of an operating license. Although each finding was not discussed at the formal exit meeting, they were discussed with the Superintendent of Security or identified by the licensee's staff during the course of the inspectio ,, n , u.- in , n u . - '-

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Contingencies in the Contingency Plan. Some requirements in critical task certification wou1d eliminate set-up of some type of equipment since this function is primarily performed by Instrumentation and {

Control personne ' The inspectors emphasized that the discussions did not represent formal NRC positions and licensee management should not consider any discussion items as binding on their final management decisions in reference to the security plans revision. The inspectors did re-commend that the revisions to the plans be submitted to HQ, NRC as early as practicable for the required formal review and approval process if revised plans were desirable before issuance of an oper-ating licens The Superintendent of Security indicated that.the proposed Revision 3 of.the Security Plans would be submitted to NRC, HQ by December 22, 1983, rather than December 15, 1983, as indicated in the Nuclear Operations and Scheduling Department's project schedul l

. 'i e. ! The licensee had published Administrative Procedure APA-ZZ-00121, l " Personnel Access Requirements" and Security Department Procedure

! SDP-ZZ-PP004, " Security Screening Program for Unescorted Access"

[ since the previous inspection. Copies of these procedures were

{ provided to the inspectors for review at the Regional Offic Para-graph 4.b. of Inspection Report No. 50-483/83-24(DRMSP) noted that security procedures for safeguards contingency events 1 through 9 had not been provided to the inspectors for review purposes. Dis-cussions with the Superintendent of Security and the contract Security Supervisor showed that procedures to address these events were being prepared. Several of the events may be included in one i security procedure since the events pertain primarily to loss or I degradation of security systems. Progress has been noted in prepara- I tion of required security procedures. If the revised Security Plan 1 is approved by HQ, NRC, some procedures identified in Revision 2 of  !

the security plan will be eliminate Several procedures identified in Faragraph 4.a. of the previous inspection report (50-483/83-24 IDRMSP}) still need to be completed. The inspectors' review of the ,

security procedure status worksheet maintained by the Security Department showed that the time-frame from completion of a draft procedure to issue date ranged from two to five months. Administra-tive delays for procedure preparation and approval will have to be eliminated if required security procedures are to be in effect by the proposed Security Plan implementation date of March 1, 198 .

4. Security Organization-Management (MC 81122B) (483/83-24-02) Paragraph 5.a. of Inspection Report 50-483/83-24(DRMSP) noted that the present licensee (UE) manning within the Security Department appeared inadequate to fulfill the extensive responsibilities assigned to the Superintendent of Security in preparation for fuel load and efficient oversight of the security force upon issuance of an operating licens The licensee's actions in regard to this concern have been adequat A candidate for the Assistant Super >atendent of Security pcsition has been identified and was completing pre-employment screening activities

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during this inspection. The licensee anticipated th'at the final hiring decision would be made during December 198 This area of concern will be closed when the hiring decision is fi-nally determine Discussions with the Superintendent of Security indicated that the Assistant Superintendent of Security position and responsibilities would be included in the revised Security Plan. Necessary changes pertaining to depicting the correct lines of authority in reference to designated security responsibilities are also to be included in the revised Security Plan. These changes pertained to Sections 1.2.1.1 and 1.2.1.5 and Figure 1.2-1 of the Security Pla Several projected completion dates identified in the Nuclear Opera-tions Planning and Scheduling Department (NOP&S) project schedule (Data Date October 14, 1983) had not been met. Security equipment acceptance testing had changed from the November-December 1983 time-frame to early January-mid February time-frame. Radio equipment installation had changed from November 30, 1983 to the end of January 1984 for the Security Alarm Stations and late February 1984

! for the Callaway County Sheriff Department. Notification of.Per-

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sonnel Screening requirements to all affected contractors had

[changedfromNovember1,1983toearlyDecember1983. Completion of CAS/SAS operator training had changed from January 25, 1984 to February 15, 1984. The new project completion dates cited above were estimates provided by the Superintendent of Security. The new sched-ule, which was being prepared during the inspection, will formally identify the new completion date The inspectors noted that two of the key milestones pertaining to program implementation had not been identified as having to be

_ changed. The Security system operational date of February 15, 1984 and the Security Plan implementation date of March 1, 1984 are still t considered as valid. Hiring and initial training of security offi-cers was completed ahead of the projected date of December 9, 198 Four or five additional personnel need to be hired to fill the desired 108 person manning level identified by the Superintendent of Security. However, these positions will not prevent program imple-mentation as identified in the licensee's Security Pla The licenree has taken several actions to help reduce future imple-mentation delays in security equipment acceptance testing. On -

November 15, 1983, a Security System Task Force was formed. The Superintendent of Security was assigned as the head of the task forc Representatives frog licensing, systems engineering, nuclear engineering, construction, materials, and a Bechtel representative were identified as task force members. The task force meets at least once a week to discuss problems and solutions pertaining to implementation of the security program. The inspector attended two of the task force meetings. A broad area of expertise was evident and cooperation and coordination existed between task force member n _1. s i n i ; i o - 7,-- o , 1 l -

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Access Control-Personnel (HC 81170B) (483/83-24-08)

a Implementation of the Personnel Screening Program, required by Section 1.3.1.1 of the licensee's Security Plan, con Tnues to be a major area of concern if the licensee's security prot:.em is to be fully implemented by March 1, 198 Some progress has been noted since the initial inspection (October 23-31, 1983). One contractor

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has responded to a bid to perform screening activities for the Security Department. Another contractor's response was expected by December 15, 198 Conversely, contractors who will do their own screening have not been advised yet of the licensee's screening requirements. The screening program for approved contractors will have to reviewed for adequacy. Tbc licensee's Corpcrate office has initiated personnel screening to a limited extent and the QA depart-ment is planning an audit of the corporate program in January 198 Equipment for security badge issue is expected to be delivered in December 1983. Security orientation training is planned to be initiated by January 4,.198 A review of the licensee's screening program for contract security t force members was conducted to determine whether the licensee is implementing the program in accordance with the security plan. The inspector determined the adequacy and completeness of the personnel

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selection process and administrative controls through a review of records and interviews with security force management personne The inspector reviewed ecurity guard force screening records for adequacy of documentation. This represents approximately 25% of the current guard forc These records included elements of employement e

c 7 suitability as well as qualificaitons criteria outlined in Appendix i

B (Personnel Training and Qualifications Plan). The licensee uses

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g5 4 information obtained in these records to determine if an individual EE is suitable for security placement and/or unescorted access to vial areas. Screening for security applicant.s is conducted by Burns *

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yg k International Security Services, Inc office 1,n Jefferson City, Missouri. ,orporated (B.I.S.S.I.) at the !

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5 g Strengths in the screening program identified by the inspector F5 included the proximity of the B.I.S.S.I. offsite office. The respons-

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t- ibility for assisting the Callaway office had been transferred to g N EN- Jefferson City, Missouri from its previous location in Lisle, Illinois. This should enhance communications and assist in reducing

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% administrative backlogs. Other strong points included a detailed j ,$ = .4Ey@~suamary sheet and a policy of including witness signatures on certain documents to aid in the validity of the documents. Most of these

, documents are not required by 10 CFR 73.55 (e.g., authority to release information statement).

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l During the. records review, several items were identified which could ;

impact on the overall reliability of the screening program. The most !

significant item identified was the. lack of a signatur,e by the Security ;

Super.intendent on the Administrative File Checklist. This signature is required by the Security Plan to ensure that a management repre- {

l sentative of the licensee reviews background information of all security officer !

Although interviews with security management j revealed records are indeed reviewed by management personnel, docu-mentation available did not support thfs required review. This find- <

ing was also identified during a licensee QA audit approximately seven weeks earlier. Other weaknesses in screening records included:

solated instance nvolving omission of the statement concerning in uste docu;aentat . pertaining to verifica-lon o an app '

d weaknesses in the way the licensee review All findings were discussed with appropriate management personne Corrective actions were discussed and B.T.S.S.I. personnel stated that all files would be reviewed for further errors and/or weaknesse .

DELETED - Not within the scope of ti.is reques DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques l l

DELETED - Not within the scope of this recues I DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques '

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q DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques DELETED - Not within the scope of this reques Information in this record was deleted .

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. TM I, M n LT U 1 L U N E FEB E 3 7331 '

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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 Mr. G. L. Pirtle of this office on January 30-February 3,1984, 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 j inspectio The enclosed copy of our inspection report identifies areas examined during l

the inspection. 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 ,

course of this inspection. The enclosed report does contain certain findings l

'which must be corrected and/or resolved prior to fuel load. These findings will be reviewed during future pre-operational inspections. Iio written response is needed at this tim Some progress in adherence to your security system implementation schedule was noted. However, this area and the Personnel Screening Program continue to warrant senior management review and oversight until total implementation of the Security Program has been complete 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 Regulation This information must be handled and protected in accordance with the provisions of 10 CFR 73.2 Consequently, our report of this . Inspection will not be placed in the Public Document Roo .

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Union Electric Company 2 FEB 22 T334 )

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We will gladly discuss any guestions you have concerning this inspeclio

Sincerely,

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W. el hief i Materials and Safeguards Branch Enclosure: Inspection Report j No. 50-483/84-05(DRMSP)

(UNCLASSIFIED )

cc w/ encl:

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

DMB/ Document Control Desk (RIDS)  !

Resident Inspector, RIII Region IV

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K. Drey Chris R. Rogers, Utility Divison, Missouri Public Service Commission

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