ML17229A154
| ML17229A154 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 11/15/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17229A153 | List: |
| References | |
| 50-335-96-19, 50-389-96-19, NUDOCS 9612090002 | |
| Download: ML17229A154 (12) | |
See also: IR 05000335/1996019
Text
U. S. NUCLEAR REGULATORY COMINISSION
REGION II
Docket Nos:
License Nos:
Report Nos:
Licensee:
Facility:
Location:
Dates:
Inspector:
Approved by:
50-335, 50-389
50-335/96-19, 50-389/96-19
Florida Power and Light Company
St.,Lucie Nuclear Plant Units
1 and 2
9250 West Flagler Street
Miami, FL 33102
October 21 - October 25, 1996
L. Stratton, Safeguards
Inspector
Paul E. Fredrickson, Chief
Special Inspection Branch
Division of Reactor Projects
ENCLOSURE
1
96i2090002 96iii5
ADQCK 05000335
8
EXECUTIVESUMMARY
St. Lucie Nuclear Plant Units 1 and 2
NRC Inspection Report 50-335/96-1 9, 50-389/96-1 9
This routine announced
inspection was conducted in the area of plant support by a regional
safeguards
specialist.
The specific area evaluated was the Physical Security Program for
Power Reactors.
~
Portions of the licensee's Fitness for Duty program with respect to adulterated
samples and the appeal process were reviewed and found to be in accordance
with
requirements
(10 CFR 26 (S1.3)).
~
The licensee's failure to prevent unauthorized unescorted
access
into the protected
area and potential access
into vital areas
is an apparent violation of regulatory
requirements.
(S2.1)
The licensee's failure to log in the Safeguard Event Logs or make a one hour report
within the required time with respect to the access control events described
in
Paragraph
S2.1b is an apparent violation of regulatory requirements.
(S4.1)
The Training and Qualification Plan was reviewed with respect to conducting physical
fitness tests of security personnel and found to meet the requirements.
(S5.1)
Through document review and interview of licensee representatives,
the inspector
determined that the portion of the audit program evaluated was adequate.
REPORT DETAILS
Conduct of Security and Safeguards Activities
Fitness for Dut
Ins ection Sco
e 81502
In accordance
with 10 CFR 26.10(a), the licensee must provide reasonable
assurance
that nuclear power plant personnel will perform their tasks in a reliable and trustworthy
manner and are not under the influence of any substance,
legal or illegal, or mentally
or physically impaired from any cause, which in any way could adversely affect their
ability to safely and competently perform their duties.
Observations and.Findin
s
On October 21, 1996, at the Florida Power and Light (FP8L) Company corporate
offices, the inspector reviewed ten randomly selected records to verify compliance
with 10 CFR 26. The inspector noted that one record documented that an individual
was given a chemical test on January 4, 1996; however, the test result was
documented
as a "refusal." Upon further discussion with licensee representatives,
the
inspector learned that a confirmed adulterated sample was documented
as a refusal
by the licensee.
On January 5, 1996, the licensee's contract laboratory's report
documented that the sample appeared
to have a "soapy" presence.
Upon request
from the licensee's Medical Review Officer (MRO), the contract laboratory sent the
possible adulterated sample to another independent laboratory for review. That
laboratory confirmed the presence of an anionic surfactant.
The licensee determined
this was a failure to cooperate with the testing requirements,
therefore deemed the
test results as a refusal.
The individual was again tested by observation on January
5, 1996, with the results being negative.
10 CFR 26 requires that when an individual's test results are confirmed positive, the
licensee must offer an appeal process to that individual. Since the results of the
individual's test discussed
above was categorized
as a refusal, the licensee did not
offer an appeal under 10 CFR 26.
However, the inspector noted that on June 24,
1995, the individual was given an appeal based on 10 CFR 73.56, access
authorization requirements.
The licensee informed the inspector that since the
sample was confirmed adulterated, the individual's trustworthiness and reliability were
in question.
Therefore the suspension
of his unescorted
access was appealed,
rather
than the adulterated sample results.
The appeal board suggested
reversing the denial of unescorted
access
based on the
individual's willingness to cooperate; the fact that FP&L's policy did not adequately
address
adulteration; and the individual's second negative sample.
The licensee is
currently evaluating the case.
Conclusions
Through document review and discussion with licensee representatives,
the inspector
concluded that the portions of 10 CFR 26 that were reviewed met regulatory
requirements.
There were no violations of regulatory requirements
noted.
S2
Status of Security Facilities and Equipment
S2.1
Protected and Vital Area Access Control
Ins ection Sco
e 81700
10 CFR 73.55(d)('7) requires that licensee's shall establish an access
authorization
system to limit unescorted
access
to vital areas during non-emergency
conditions to
individuals who require access
in order to perform their duties.
The licensee's
Physical Security Plan (PSP), Revision 48, dated 2/23/96 states, "Only
those individuals with identified need for access
and having appropriate authorization,
shall be granted unescorted Vital Area access."
Observations
and Findin s
The licensee documented
on August 19, 1996, in Condition Report (CR) 96-2041 that
an individual was presented
a FP8L severance
package on July 17 and upon
returning to St. Lucie on August 14, learned his badge was never deactivated.
In
response
to the CR, the licensee determined an administrative error had occurred and
this error was an isolated event.
On September
19, 1996, the licensee's access coordinator determined that three
other former FP8L employees who were favorably terminated
in July continued to
have active badges to the St. Lucie facility. The access coordinator immediately
removed the individuals'ccess
from the security computer.
On October 9, 1996, the licensee discovered that one of the individuals determined
not to need access
on September
19, had entered into the protected area on five
different occasions on August 7, August 9, and August 15, 1996.
The individual did
not enter vital areas on these dates.
Upon interview, the licensee learned the
individual had returned to the site for a job interview and to "generally talk to some
people."
In response
to the discovery, the licensee initiated an audit on October 21, 1996, for
the period of January
1, 1996 to the present of individuals who had been terminated.
The audit, which was completed October 31, 1996, encompassed
checking 594
individuals'ames/social
security numbers against active badges
in the security
computer.
Through this corrective action, the licensee discovered six additional
individuals; two with access
to St. Lucie; three with access
to Turkey Point, and one
ENCLOSURE
1
with access to both facilities. All six individuals subsequently
identified had not
accessed
the protected or vital areas after the date of their termination.
Upon
discovery, the licensee deactivated those individuals'adges.
The inspector reviewed Administrative Procedure
(AP) 10509, "Personnel and Material
Control," Revision 18, dated September 30, 1996.
The procedure clearly states the
responsibility to notify security that an individual is terminated rests with (1) the
individual to turn in his security badge; (2) department head and supervisors to notify
security when unescorted
access
is no longer required; and (3) the Plant Resource
Control Supervisor or Human Resources
to notify security of personnel changes.
However, all three avenues of the procedure failed to be implemented.
The inspector
did note that although the procedure clearly states responsibility, a termination of
access form/checklist was not provided, which could possibly ensure hardcopy
documentation
in the event security was not notiTied.
Conclusions
The licensee's failure to prevent unauthorized unescorted
access
into the protected
area and potential access
into vital areas
is noted as an apparent violation of
regulatory requirements
(10 CFR 73.55 (d)(7) and EEI 50-335, 50-389/96-19-01).
S4
S4.1
Security and Safeguards Staff Knowledge and Performance
Records and Re orts
Ins ection Sco
e 81038
10 CFR 73.71, states that an actual entry of an unauthorized person into a protected
area or vital area be reported within one hour of discovery.
10 CFR 73.71, states that any failure, degradation, or discovered vulnerability in a
safeguards
system that could have allowed unauthorized or undetected
access to a
protected area or a vital area had compensatory
measures
not been established,
be
recorded within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of discovery in the safeguards
event log.
Observations
and Findin s
Upon review of the access
control event detailed in Paragraph
S2.1b, the inspector
reviewed Security Procedure
(SP) 6125, "Reporting of Safeguards
Events,"
Revision 10, dated October 9, 1996.
The procedure accurately outlines the provisions
specified in 10 CFR 73.71, Appendix G.
However, on September
19, 1996, the
licensee failed to document in the Safeguards
Event Log (SEL) the possibility of three
individuals having unescorted
access
to protected and vital areas.
In addition, on
October 9, 1996, the licensee failed to make a one hour report when they discovered
that one of the individuals who maintained unescorted
access after termination,
actually entered the protected area on five occasions.
Upon further review, the
ENCLOSURE
1
licensee determined that a one hour report was warranted.
On October 16, 1996, the
licensee made a one hour report to the NRC under the provisions of 10 CFR 73.71.
c.
Conclusions
The licensee's failure to log in the SEL or make a one hour report within the required
time with respect to the access control events described
in Paragraph
S2.1b is an
apparent violation of regulatory requirements
(EEI 50-335, 50-389/96-19-02).
S5
Security Safeguards Staff Training and Qualification
S5.1
Securit
Trainin
and Qualification
a.
Ins ection Sco
e 81700
The inspector reviewed the security training and qualification (T&Q) program to
ensure that the criteria specified in the licensee's T&Q plan were being met in the
area of conducting physical fitness tests for security personnel.
b.
Observations
and Findin s
The inspector reviewed T&Q Plan Implementing Instruction, Revision 2, dated
September
9, 1996, to verify the licensee was conducting the physical fitness test for
security personnel
in accordance
with the requirements of the T&Q Plan.
The
inspector noted that Attachment 3 had been added to the procedure, which is a
detailed instruction on conducting the physical fitness test.
Prior to this revision, the
procedure only documented what the test entailed and the time period required to
perform the test.
Attachment 3 denotes specific material required and detailed
guidelines to ensure
all physical fitness tests are performed consistently.
The inspector noted the procedure specifies that if an individual fails to pass the
required physical fitness test within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> a second attempt may be made.
However, on one occasion, an individual did fail both attempts to pass the physical
fitness test by not meeting the required time allowance, yet was allowed to make a
third attempt.
Further discussion with licensee representatives
revealed that those
two attempts at the physical fitness test were prior to the addition of Attachment 3 to
the T&Q Plan Implementing Instruction.
The licensee determined that those two tests
may not have been conducted consistently, therefore allowing an error in the actual
timekeeping.
However, since the test is now better standardized,
the timekeeping
margin of error has been eliminated.
The licensee considers this individual's second
attempt as a re-test rather than a second try.
ENCLOSURE
1
c.
Conclusions
Through interview of security personnel and procedural review, the inspector
determined that the licensee was meeting the provisions of the T8Q Plan with respect
to physical fitness testing.
S7
Quality Assurance in Security and Safeguards Activities
S7.1
Audits
a.
Ins ection Sco
e 81700
Chapter 14, of the licensee's
Physical Security Plan, Revision 48, dated February 23,
1996, denotes the security program shall be audited no less frequently than once
every 12 months..
b.
Observations and Findin s
The inspector reviewed a portion of the Security and Safeguards
Information-
Functional Area Audit QSL-OPS-96-03,
dated April 22, 1996 to verify that the required
elements of the security program were reviewed.
The audit was performed by the
Quality Assurance
Department, located at FP8L's corporate offices. The audit report
was furnished to site and corporate management
as appropriate.
Numerous strengths
were noted in the areas of security's self-assessment
program, tracking and trending
of personnel and hardware performance,
and unannounced
crucial tasking of security
officers. Two technical recommendations
were noted:
(1)
Land Utilization Procedure
LU-QI-11.0-20 be revised to include dimensional
verification (to ensure the 96 square
in limit is met) of selected panels during
safe-net inspections.
(2)
Substitute the simulated crawl test (conducted with a sled and aluminum ball)
with another method described
The inspector noted that the audit report covered AP-10509, "Personnel and Material
Control;" however, no findings by the auditors were documented.
Further evaluation
of the licensee's audit program for security will be reviewed in future inspections.
c.
Conclusions
Through document review and interview of licensee representatives,
the inspector
determined that the portion of the audit program evaluated was adequate.
ENCLOSURE
1
s
S8
Miscellaneous Security and Safeguards
Issues
S8.1
Action of Previous Ins ection Findin s 92904
(DISCUSSED)
IFI 96-010.
This IFI will remain open pending the completion and
future performance of the licensee's
FFD program.
S8.2
Followu
on Tam erin
Event
In response
to the recent tampering events that occurred at St. Lucie, the licensee
had initiated additional measures
as noted below:
At the time of this inspection, twelve boxes in remote locations in various vital
areas to house a camera and a VCR were in place.
The licensee plans to
.
have a total of 19 locations.
All locations will have a camera installed.
Two VCRs with a backup battery capacity of 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br />.
These two VCRs will
be rotated to two of the nineteen locations eve,",'4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, with one VCR per
unit. The licensee implemented these additional measures
beginning
October 4, 1996.
The evening Security Shift Supervisor will be responsible for selecting the
location and ensuring the VCR is installed.
AllVCR boxes are locked with security controlled keys.
The inspector noted that temporary extension cords were currently being used
to support the operation of the cameras
and VCRs. The licensee informed the
inspector they plan to run the cords through the existing cabling after an
engineering study has been performed sometime
in late November.
The two extra patrols the licensee had in place are no longer being utilized.
All nineteen locations have signs in the area warning personnel of the
possibility of being observed
by remote cameras.
The tapes will be maintained for approximately two weeks, according to the
implementing procedure.
The inspector and a security shift specialist performed
a walkdown of vital areas to
observe the boxes that were currently installed.
Additionally, the inspector reviewed
tapes of several locations to determine if the angle position of the cameras was
adequate.
All cameras
captured ingress and egress points of particular vital
equipment selected to be viewed.
ENCLOSURE
1
Mana ement Meetin s
X1
Exit Meeting Summary
The inspector presented
the inspection results to licensee management
at the conclusion of
the inspection on October 25, 1996.
The inspector noted and discussed
two apparent
violations with respect to access control and reportability requirements.
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
D. Bonthron, Access Program Supervisor, Florida Power and Light (FP8L)
A. Cummings, Fitness for Duty Coordinator, St. Lucie Nuclear (SLN)
S Plantz, Security Training. ~LN
J. Scarola, General Manager, SLN
E. Weinkam, Licensing Manager, SLN
W. White, Security Manager, SLN
M. Miller, Senior Resident Inspector
INSPECTION PROCEDURES USED
IP 81038:
IP 81502:
IP 81700:
IP 92904:
Reporting Requirements
Fitness for Duty Program
Physical Security Program for Power Reactors
Action on Previous Inspection Findings
~oened
ITEMS OPEN, CLOSED, AND DISCUSSED
50-335, 50-389/96-19-01
Failure to limit unescorted
access
to protected and vital
areas during non-emergency
conditions to individuals
who require access
in order to perform their duties.
50-335, 50-389/96-19-02
Failure to report an event under the criteria of 10 CFR 73.71
Discussed
50-335, 50-389/96-10
IFI
FFD Staff Reorganization
and Corrective Actions
ENCLOSURE
1
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