ML15118A335

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Insp Repts 50-269/98-04,50-270/98-04 & 50-287/98-04 on 980302-05.Violations Noted.Major Areas Inspected:Plant Support,Including Review of Random Samples of Security Procedures
ML15118A335
Person / Time
Site: Oconee  
Issue date: 03/25/1998
From:
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML15118A333 List:
References
50-269-98-04, 50-269-98-4, 50-270-98-04, 50-270-98-4, 50-287-98-04, 50-287-98-4, NUDOCS 9804020386
Download: ML15118A335 (11)


See also: IR 05000269/1998004

Text

U.S. NUCLEAR REGULATORY COMMISSION

REGION II

Docket Nos:

50-269, 50-270, 50-287

License Nos:

DPR-38, DPR-47, DPR-55

Report Nos:

50-269/98-04, 50-270/98-04, 50-287/98-04

Licensee:

Duke Energy Corporation

Facility:

Oconee Nuclear Station, Units 1, 2, and 3

Location:

7812B Rochester Highway

Seneca, SC 29672

Dates:

March 2-5, 1998

Inspector:

W. Stansberry, Safeguards Inspector

Approved by:

G. Belisle, Chief,

Special Inspection Branch.

Division of Reactor Safety

ENCLOSURE 2

9804020386 980325

PDR

ADOCK 05000269

G

PDR

EXECUTIVE SUMMARY

Oconee Nuclear Station. Units 1, 2, and 3

NRC Inspection Report 50-269/98-04.

50-270/98-04, and 50-287/98-04

This inspection included aspects of the licensee's plant support program. The

report covers a one-week period of an announced inspection by a regional

inspector.

Plant Support

The inspector's evaluation of the Fitness For Duty Program determined

that there were no changes to the licensee's Fitness For Duty Program

and that the program was adequate and met the licensees' commitments and

NRC requirements (Section S1.3).

A repeat violation was identified for failure to secure unattended

safeguards information. The unattended safeguards information was not

disclosed -or compromised (Section S1.4).

The inspector's review of plan changes verified that the changes did not

decrease the effectiveness of the Security and Contingency Plan and the

Training and Qualification Plan (Section S3.1).

The inspector's review of random samples of the Security Procedures

verified that the procedures adequately met the Security and Contingency

Plan commitments and practices (Section S3.2).

The inspector concluded through observation and interviews of security

force personnel, that the security force was being trained effectively

and according to the Training and Qualification Plan and regulatory

requirements (Section 5.1).

The inspector's review found that the security force training records

met the Training and Qualification Plan and regulatory requirements

(Section .5.2)..

The inspector verified that the total number of trained security

officers and armed personnel immediately available to fulfill response

requirements met the number specified in the Security and Contingency

Plan. One full-time member of the security organization who had the

authority to direct security activities did not have duties that

conflicted with the assignment to direct all activities during an

incident (Section 6.3).

ENCLOSURE 2

REPORT DETAILS

IV. PLANT SUPPORT

S1

Conduct of Security and Safeguards Activities

S1.3 Fitness For Duty Program

a. Inspection Scope (81502)

The inspector evaluated the Fitness For Duty Program to determine

whether changes to the licensee's Fitness For Duty Program met the

licensees' commitments and NRC requirements as stated in 10 CFR Part 26.

b. Observations and Findings

Through discussions with Fitness For Duty personnel and review of

Fitness For Duty records, no significant or major changes were found to

the licensee's Fitness For Duty and Chemical Testing programs.

Personnel interviewed understood their responsibilities and authorities

and were qualified to perform assigned duties as indicated in Corporate

Policy and Procedure. "Fitness For Duty Program." Revision 10.

The

licensee's audit reports for the Fitness For Duty Program were found to

meet NRC requirements and licensee commitments. The corrective actions

to resolve identified nonregulatory issues were technically adequate and

implemented in a timely manner.

The inspector specifically reviewed procedures for the sampling process

from the collection of a donor's specimen to the final storage process.

Each specimen was collected in one container. The temperature of the

sample was checked by a thermal strip attached the side of the container

and recorded in Step 2 of the Federal Drug Testing Custody and Control

Form (FDTCC) from SmithKline Beecham Clinical Laboratories. The

specimen was then split into two samples. Each sample was sealed with a

specimen bottle seal from the FDTCC form. Each seal was initialed by

the donor twice'verifying that the Social Security Account Number (SSAN)

and the date on the seal was correct. The sealed primary specimen

container (sample 1) was then sent to a laboratory for analysis. The

sealed split specimen container (sample 2) was stored in a locked

freezer at the site awaiting the outcome of the testing of the primary

specimen. If the primary specimen was found negative in containing

substances listed in the Fitness For Duty procedure, the sample was

destroyed. If the primary specimen was found positive, the testing

laboratory notified the corporate Medical Review Officer (MRO) of the

results. The MRO then called the site to have the split sample set

aside for possible retesting by another laboratory. The MRO also called

the donor to discuss any reason that the primary specimen was positive.

ENCLOSURE 2

2

The MRO asked the donor if they wanted to appeal the results and have

the split specimen sent to a second laboratory. If the donor wanted to

appeal the results and wanted the split specimen sent to a second

laboratory, the MRO notified the site to have the split specimen sent to

the second laboratory for retesting. If the donor did not want to

appeal the results and did not have the split specimen retested, the MRO

notified the site to send the split specimen to the corporate Fitness

For Duty office where it was archived in a locked freezer. If the split

specimen was negative, the site was notified of the negative split

specimen. If the split specimen was found positive, the MRO notified

the site and called the donor to discuss over the telephone or in person

the specific results. Any appeals of the process went to the Employees

Assistance Program. Fitness For Duty records at the site were stored in

a locked file cabinet in a locked room.. There were no master keys to

the room or file cabinet locks.

To verify the specimen process, the inspector selected four names to

track through the Fitness For Duty system. Two names had positive

primary specimen results. One individual's specimen was positive for

cocaine and the individual was advised of the positive test. The

individual had no explanations for the positive test and did not appeal

the results or ask for the split specimen to be sent to a second

laboratory for retesting. The second individual's specimen was positive

for d-methamphetamine. The MRO advised the individual of the positive

results. The individual denied use of that drug and requested that the

test results be reviewed by the Appeal Panel.

The Appeal Panel reviewed

and upheld the positive results. When the MRO advised the individual of

the positive results and the appeal process results, the individual did

not request that the split specimen be sent to a second laboratory for

retesting.

The inspector examined records and split specimens at the corporate

MRO's office. The FDTCC for the second individual indicated on copies 4

and 6, under Step 4, to be completed by the individual, the printed

name, signature, date of signature, a telephone number, and date of

birth. The two initials on the specimen bottle seal of.the split

specimen were similar to the handwriting of the individual signing the

FDTCC. The SSAN, specimen, and the requisition number were also the

same. At the site, the inspector reviewed the department location

organizational effectiveness contacts Fitness For Duty checklist,

Revised 3/1/96, (Checklist #1), and Program Administrator's Fitness For

Duty Event Checklist, Revised 3/1/96, (Checklist #2).

On line 24 of

Checklist #1,

the Organizational Effectiveness consultant indicated that

the second individual had been asked if they understood the Appeals

Process as explained by the MRO, and could appeal through the site

program administrator within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the time of notification.

ENCLOSURE 2

3

Line 25 indicated that the consultant informed the individual that the

request for unescorted access was being denied at all three Duke Energy

Corporation nuclear sites and that the positive screen would be released

to other utilities should they request such information. The inspector

found that the documentation of Checklist #2 was completed.

c. Conclusion

The inspector's evaluation of the Fitness For Duty Program determined

that there were no changes to the licensee's Fitness For Duty Program

and that the program was adequate and met the licensees' commitments and

NRC requirements.

S1.4 Control of Safeguards Information

a.

Inspection Scope (81810)

The inspector reviewed Problem Investigation Process (PIP) 4-098-1025

concerning an electrical systems engineer's (ESE) safeguards container

that had not been properly secured. This review was to determine

whether Safeguards Information (SGI), as defined in 10 CFR 73.21,

Nuclear Systems Directive 206, "Safeguards and Information Controls."

Revision 5, and Security Guideline - 18. "Safeguards Workplace

Procedures," had been disclosed or compromised.

b.

Observations and Findings

The licensee's investigation revealed the following:

0

Between the hours of 5:09 p.m. and 5:29 p.m., on March 3, 1998,

the second drawer of ESE safeguards container, ID#739, was left

unsecured in the engineering safeguards work area (ESWA).

o

The magnetic "OPEN/CLOSED" sign on the front of the container was

showing "OPEN."

o

The "CONTAINER ACCESS LOG" indicated that the container was closed

at 5:00 p.m.

o

The safeguard's container was within the protected area.

o

The ESWA was monitored by an alarm system with an interior motion

detector and door alarm switches at the doors to the area. The

alarm system annunciated in the badging area of the Protected Area

Access Portal.

The main entrance door was controlled by an

electrical keypad lock. The second door was locked from inside.

ENCLOSURE 2

4

Review of the annunciator records/logs showed that no entries into

the ESWA during the above time were made.

o

All documents within the container were accounted for based upon a

review of container contents against the container inventory

listing. The other safeguards containers in the area were found

secured.

o

Individuals involved were trained in safeguards practices and were

authorized access to the information within the unsecured

container.

0

No evidence of tampering or attempted forced entry into the

unsecured container or the doors to the ESWA.

The immediate corrective action was the securing of the container and

it's content. The inspector verified that the supervisor of the ESWA

was knowlegable of the requirements to secure SGI. The inspector

verified that the intrusion system was intact and the corrective actions

to the previous violation were still implemented. Intermediate and long

term corrective actions were not developed as of the end of the

inspection. The failure to secure Safeguards Information was a repeat

violation of a violation (NCV 50-269, 270, and 287/97-12-06) cited in

Inspection Report No. 97-12, dated October 6, 1997, and is identified as

violation 50-269. 270, 287/98-04-01.

c.

Conclusions

A repeat violation was identified for failure to secure unattended

safeguards information. The unattended safeguards information was not

disclosed or compromised.

S3

Security and Safeguards Procedures and Documentation

S3.1 Security Program Plans

a. Inspection Scope (81700)

The inspector reviewed appropriate chapters of the Duke Energy

Corporation Nuclear Security and Contingency Plan (S/CP). Revisions 02,

03, 04. and 06, and the Nuclear Security Training and Qualification Plan

(T&QP), Revisions 02. 03, and 04.

ENCLOSURE 2

5

b. Observations and Findings

The inspector's review of the changes to the S/CP and T&QP reported or

submitted for approval verified their compliance to the requirements of

10 CFR 50.54(p) or 50.90. Most of the changes were for clarity,

editorial, grammatical, and organizational/position/title changes.

Necessary coordination was made for merging the changes into the

consolidated S/CP and T&QP for each of the three Duke nuclear power

plants. Revision 5 will be implemented when the new personnel access

program with new badges and hand biometrics is installed and

operational.

c.

Conclusions

The inspector's review of plan changes verified that the changes did not

decrease the effectiveness of the S/CP and T&QP.

S3.2 Security Procedures

a.

Inspection Scope (81700)

The inspector reviewed a sample of the licensee's Security Plan

Implementing Procedures (SPIP) to verify that the procedures were

consistent with S/CP commitments and practices.

b.

Observations and Findings

The inspector reviewed seven SPIPs involving communications and access

controls. Procedures implementing plan changes that the licensee had

determined not to decrease the effectiveness of the S/CP were reviewed

and discussed with appropriate licensee management to verify the

validity of the determination. Also, the impact of the changes as

implemented on the plan and overall program was evaluated.

The S/CP was revised and reviewed in accordance with approved licensee

procedures before changes were implemented. Changes were incorporated,

as appropriate, into the implementing procedures. No changes reviewed

decreased the effectiveness of the respective plans.

ENCLOSURE 2

6

c.

Conclusion

The inspectors" review of random samples of the SPIPs -verified that the

procedures adequately met the S/CP requirements.

S5

Security and Safeguards Staff Training and Qualification

S5.1 Security Training and Qualification

a. Inspection Scope (81700)

The inspector reviewed the security training and qualification program

to ensure that the licensee was complying with the criteria in the

Nuclear Security Training and Qualification Plan (T&QP).

b. Observations and Findings

The inspector interviewed security non-supervisory personnel,

supervisors, and witnessed other security personnel during the

performance of their duties. Members of the security force were

knowledgeable of their responsibilities, plan commitments and

procedures. Documentation and equipment inspected was found as

committed to in the approved T&QP. The inspector found that armed

response personnel had been instructed in the use of deadly force as

required by 10 CFR Part 73. The inspector observed shotgun

requalification range firing and basic security officer training.

c. Conclusions

The inspector concluded through observation and interviews of security

force personnel, that the security force was being trained effectively

and according to the T&QP and regulatory requirements..

S5.2 Training Records

a. Inspection Scope (81700)

The inspectors interviewed security personnel and reviewed security

personnel training and qualification records to ensure that the criteria

in the Training and Qualification Plan were met.

b. Observations and Findings

The inspector interviewed security non-supervisory personnel and

supervisors about the quality and timeliness of the training provided.

Members of the security force were knowledgeable in their

ENCLOSURE 2

7

responsibilities, plan commitments and procedures. Twelve randomly

selected training records.covering the last three years were reviewed by

the inspectors concerning training, firearms, testing, job/task

performance and requalification.

The inspector found that armed response personnel had been instructed in

the use of deadly force as required by 10 CFR Part 73. Members of the

security organization were requalified at least every 12 months in the

performance of their assigned tasks, both normal and contingency. This

included the conduct of physical exercise requirements and the

completion of the firearms' course. Through the record's review and

interviews with security force personnel, the inspectors found that the

requirements of 10 CFR 73, Appendix B, Section 1.F. concerning

suitability, physical and mental qualification data, test results and

other proficiency requirements were met.

The interviews and training records reviewed revealed an effective

training program.

c. Conclusions

The inspector's review found that the security force training records

met the Training and Qualification Plan and regulatory requirements.

S6

Security Organization and Administration

S6.3 Staffing Level

a. Inspection Scope (81700)

The inspector was to verify the total number of trained security

officers and armed personnel immediately available at the facility to

fulfill response requirements met the number specified in Chapter 3 of

the S/CP. The inspector was also to verify that one full-time member of

the security organization who had the authority to direct security

activities did not have duties that conflicted with the assignment to

direct all activities during an incident.

b.

Observations and Findings

The licensee had an onsite physical protection system and security

organization. Their objective was to provide assurance against an

unreasonable risk to public health and safety. The security

organization and physical protection system were designed to protect

against the design basis threat of radiological sabotage as stated in

10 CFR 73.1(a). At least one full-time .manager of the security

ENCLOSURE 2

8

organization was always onsite and had no duties that conflicted with

the assignment to direct all activities during an incident. This

individual had the authority to direct the physical protection

activities of the organization. The four shifts had the number of

trained security officers and armed personnel immediatel-3 available to

fulfill response requirements and commitments of the S/CP.

c.

Conclusion.

The inspector verified that the total number of trained security

officers and armed personnel immediately available to fulfill response

requirements met the number specified in the Security and Contingency

Plan. One'full-time member of the security organization who had the

authority to direct security activities did not have duties that

conflicted with the assignment to direct all activities during an

incident.

V. Management Meeting

X1

Exit Meeting Summary

The inspector presented the inspection results to licensee management at

the conclusion of the inspection on March 5. 1998. The licensee

acknowledged the findings presented. Although reviewed during this

inspection, proprietary information is not contained in this report.

Dissenting comments were not received from the licensee.

PARTIAL LIST OF PERSONS CONTACTED

Licensee

E. Burchfield, Regulatory Compliance Manager

D. Durham, Security Specialist

P. Grobusky, Human Resource Manager

M. Nazar, Engineering Manager

M. Satterfield, Security Support Supervisor

NRC

M. Scott, Senior Resident Inspector

ENCLOSURE 2

9

INSPECTION PROCEDURES USED

IP 81502:

Fitness For Duty Program

IP 81700:

Physical Security Program For Power Reactors

IP 81810:

Protection of Safeguards Information

ITEMS OPENED, CLOSED, AND DISCUSSED

50-269. 270, 287/98-04-01

NOV

Licensees failed to secure unattended

safeguards information. (Section 1.4)

NONE

I

ENCLOSURE 2