ML17264A745
| ML17264A745 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 11/26/1996 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17264A744 | List: |
| References | |
| 50-244-96-10, NUDOCS 9612030176 | |
| Download: ML17264A745 (12) | |
See also: IR 05000244/1996010
Text
U. S. NUCLEAR REGULATORY COMMISSION
REGION
I
Docket No:
License No:
50-244
Report No:
50-244/96-10
Licensee:
Rochester
Gas and Electric Corporation
Facility:
R. E. Ginna Nuclear Power Plant
Location:
Ontario, New York
Dates:
October 7-11, 1996
Inspector:
Gregory C. Smith, Senior Security Specialist
Approved by:
Richard R. Keimig, Chief
and Safeguards
Branch
Division of Reactor Safety
'P6i2030i76 96ii26
ADQCK 05000244
8
EXECUTIVE SUMMARY
R. E. Ginna Nuclear Power Plant
NRC Inspection Report No. 50-244/96-10
On April 25, 1991, the Commission published the Personnel Access Authorization
Requirements
for nuclear power plants, 10 CFR 73.56 (the rule), requiring power
reactor licensees to implement an Access Authorization Program (AAP) by
April 27, 1992, and to incorporate the AAP into the licensee's physical security plan.
The objective of the rule is to provide high assurance
that individuals granted
unescorted
access
are trustworthy and reliable, and do not constitute an unreasonable
risk to the health and safety of the public, including a potential to commit radiological
sabotage.
The licensee's
Access Authorization Program was inspected during the period
October 7-11, 1996.
It was found to meet the above stated objective.
However, two
violations were identified in the area of Fitness-for-Duty involving the failure to retrain
supervisors,
nominally every 12 months, in their fitness-for-duty and continual
behavior observation duties and the failure to fitness-for-duty test an available
employee selected for random fitness-for-duty testing on the day he was selected.
Re ort Details
P8
Miscellaneous Security and Safeguards
Issues
P8.1
General
On April 25, 1991, the Commission published the Personnel Access
Authorization Requirements for nuclear power plants, 10 CFR 73.56 (the rule),
requiring power reactor licensees to implement an Access Authorization
Program (AAP) by April 27, 1992, and to incorporate the AAP into the
licensee's
physical security plan.
The objective of the rule is to provide high
assurance
that individuals granted unescorted
access
are trustworthy and
reliable, and do not constitute an unreasonable
risk to the health and safety of
the public, including a potential to commit radiological sabotage.
An April 20, 1992, letter from the licensee,to the NRC forwarded Revision F to
its physical security plan, which stated,
in part, that all elements of Regulatory
Guide 5.66, "Access Authorization Program for Nuclear Power Plants," have
been implemented to satisfy the requirements of 10 " R Part 73. An NRC
May 6, 1992, letter to the licensee stated that the changes
submitted had been
reviewed and were determined to be consistent with the provisions of 10 CFR
50.54(p) and acceptable for inclusion in the NRC-approved security plan.
at
Ins ection Sco
e Tl 2515 127
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 AAP to
determine if it was commensurate
with regulatory requirements
and the
licensee's
physical security plan.
P8.2
Access Authorization Pro ram and Administration Or anization
a 0
Ins ection Sco
e
The inspector reviewed applicable procedures
and conducted interviews to
assess
the licensee's
access
authorization program and administrative
organization.
b.
Observations
and Findin s
The Rochester
Gas and Electric Corporation (RGSE) AAP requirements
are
contained
in two documents.
The Site Unescorted Access Authorization
Program Procedure,
Revision 9, dated October 1, 1996, defines the overall
requirements for the program.
The fitness-for-duty and behavior observation
portions of the AAP are contained
in the fitness-for-Duty (FFD) Program
Manual, Sections FFD-8, Revision 6, dated March 4, 1996 and FFD-12,
Revision 1, dated February
1, 1992.
The responsibility for implementation of the AAP screening
program is vested in
the Access Authorization Administrator who reports to the Supervisor,
Nuclear
Safety.
The FFD portion of the AAP is administered
by the Corporate Human
Resources
Department.
All access authorization functions are performed in the
training building during outages.
During non-outage
periods, the FFD portion of
the AAP is done at'corporate
headquarters
or a local hospital.
Conclusion
The inspector's review of the AAP and the FFD manuals disclosed that both
manuals were comprehensive
and contained sufficient detail to provide
adequate
guidance to implement the AAP in accordance
with regulatory
requirements.
The consolidation of the access
screening,
under the direction of
the Access Authorization Administrator who has over 10 years experience
in
station access
processing,
and the FFD function in one location during outage
periods, has resulted in an effective method that allows processing
of personnel
in a proper and time!~,'anner.
However, as a'result of the AAP function and
the FFD functions being in separate
departments,
some weaknesses
in the FFD
program administration identified during this inspection and documented
in this
report adversely impacted on the AAP implementation.
Back round Investi ations
Bl Elements
Ins ection Sco
e
The inspector reviewed records and conducted
interviews to determine the
adequacy
of the program to verify the true identity of an applicant and to
develop information concerning employment history, educational history, credit
history, criminal history, military service, and character
and reputation of the
applicant prior to granting unescorted
access to protected
and vital areas.
Observations
Findin s and Conclusions
The inspector reviewed the results of 45 background
investigations
(Bls)
representing
a cross-section
of licensee and contractor employees.
The Bls are
performed by the licensee's
Site Access Specialists.
The scope and depth of
the Bls reviewed were found to meet the licensee's
program commitments and
provided adequate
information on which to base
a determination for access
authorization.
The 45 Bl reports also contained the information on which temporary access
was granted or denied.
The records of those abbreviated
scope and depth
investigations permitted by the rule contained information on which to base
a
determination regarding temporary access
pending completion of the full Bl, and
fulfilled the program requirements to which the licensee had committed.
The
inspector noted that any matter of questionable
or suspect information was
thoroughly evaluated
and documented
prior to granting or denying temporary
access.
In accordance
with 10 CFR 73.57, the licensee
is responsible for initiating
criminal history checks on individuals applying for unescorted
access
authorization,
and for considering
all information received from the U.S.
Attorney General.
Among the records reviewed by the inspector were those of
eight individuals whose fingerprint records had been returned with derogatory
information.
The irlspector determined that the information had been properly
evaluated
and appropriate action had been implemented
as a result of the
derogatory information.
P8.4
Ps cholo ical Evaluations
a.
Ins ection Sco
e
The inspector reviewed the licensee's psychological testing program procedures
and interviewed the individuals who administer and proctor the psychological
tests.
b.
Observations
and Findin s
The licensee has contracted with a licensed psychologist to provide oversight of
the psychological testing program and to perform the requisite evaluations.
All
individuals seeking unescorted
access to the site are required to complete the
psychological questionnaire
administered
by licensee personnel that have been
trained and qualified as examination proctors.
The answer sheets for the
psychological questionnaire
are forwarded to the psychologist for evaluation
and, if the need for a clinical interview is indicated, the psychologist conducts
the interview and recommends
either access
or denial to the licensee.
In all
cases reviewed, the licensee took the psychologist's
recommendation.
The inspector found that procedures
were clear and that the proctors
demonstrated
a sound knowledge of their duties.
c.
Conclusion
The inspector concluded that the licensee's
psychological evaluation program
was being effectively administered.
P8.5
Behavioral Observation
Pro ram
a.
Ins ection Sco
e
The inspector reviewed the Behavioral Observation
Program
(BOP) training
procedures
and lesson plans and conducted interviews to determine the
effectiveness of the licensee's
program.
b.
Observations
and Findin s
~
The BOP was reviewed to determine whether the licensee had a training and
retraining program to ensure that supervisors
have and maintain awareness
and
sensitivity to detect behavior changes
in employees that could adversely affect
their trustworthineds
and reliability, and to report such changes to appropriate
management
for further evaluation and action, if deemed
necessary.
The
program was instituted as part of, and is an element in common with, the
licensee's
Fitness-for-Duty (FFD) Program.
The inspector concluded that the
training program and lesson plans were adequate
to support the program.
Interviews conducted throughout the inspection with various individual
representatives
of a cross-section
of both supervisor and non-supervisory
employees
indicated
a knowledge of program requirements.
However, a review
of training records for supervisor BOP retraining disclosed that at least 10
supervisors
had not received the required retraining
nominally every 12
months.
The failure to provide BOP retraining to supervisors was noted in the
FFD Section of the licensee's Audit Report A1NT-1996-0009 TGT, dated
October 4, 1996.
Those supervisors were retrained shortly after the failure
was identified.
The inspector noted that the BOP training is included in and is
part of the supervisor
FFD requalification training.
However, the supervisors
who did not receive annual BOP retraining also did not receive the annual FFD
requalification training required by 10 CFR Part 26.21.
This was not identified
in the audit.
The failure to provide supervisors with requalification BOP and
FFD training resulted in the suspension
of access for 30 employees until their
supervisors were properly requalified in all training requirements.
c.
Conclusion
The failure to provide annual BOP and FFD requalification training to 10
supervisors
is a violation of 10 CFR 26. (VIO 50-244/96-10-01)
P8.6
Grandfatherin
Reinstatement
and Transfer of Access Authorization
a.
Ins ection Sco
e
The inspector reviewed a cross-section
of records to evaluate the licensee's
application of the provisions for Grandfathering,
Reinstatement
and Transfers of
Access Authorizations.
b.
Observations
and Findin s
~
"Grandfatherin
"
Included in the records selected at random by the inspector were records
of personnel who did not meet the criteria for "grandfathering," i.e.,
those who did not have uninterrupted,.unescorted
access
authorization
for at least 180 days on April 25, 1991, the date of publication of the
NRC's access
authorization rule.
Reinstatement
The licensee's
criteria for reinstatement
of access
authorization was
reviewed.
The criteria provided for reinstatement
of unescorted
access
authorization if one had been previously granted, that authorization was
terminated u'nder favorable conditions no more than 365 days prior to
the reinstatement
request,
and FFD program requirements
were met.
Transfer of Access Authorization
The licensee incorporated the provision for the transfer of access
authorization, both receipts in and transfers out, into its program.
The
records selected at random for review by the inspector included several
examples of each.
c.
Conclusion
The inspector concluded that the requirements for grandfathering,
reinstatement
and transfers of access
authorizations were being met and that these portions
of the AAP were being implemented satisfactorily.
No discrepancies
were
noted.
P8.7
Tem orar
Access Authorization
a.
Ins ection Sco
e
The inspector reviewed records that included the results of abbreviated
scope
investigations, which are used as the basis for granting temporary unescorted
access authorization,
as permitted by the rule.
b.
Observations
Findin
s and Conclusions
The records of the abbreviated
scope investigations were determined to contain
adequate
information (character and reputation from a developed
reference,
past year's employment history, and a credit check) on which to base
temporary access authorization.
The inspector noted that, in those records of
abbreviated
scope investigation, there were no instances
in which rescission of
access
authorization was necessitated
following receipt of the full 5-year
investigation.
P8.8
Denial Revocation of Unescorted
Access
a.
Ins ection Sco
e
The inspector reviewed the licensee's
provisions for the review of appeals of
denial or termination of access
authorization.
Observations
and Findin s
The inspector determined that an individual is informed of the basis for denial or
revocation of access authorization,
is provided the opportunity to provide
additional information for consideration
and can have the decision, and any
additional information, reviewed by the Plant Manager.
After that review, the
decision on the appeal is final.
C.
Conclusion
The inspector concluded that this aspect of the program was in accordance
with the rule and was being adequately
implemented.
P8.9
Audits
Ins ection Sco
e
The inspector reviewed the most recent combined nuclear quality assurance
audit of the security, access authorization and fitness-for-duty programs
conducted August 27 through October 2, 1996 tAudit No. A1NT-1996-0009-
TGT).
b.
Observations
and Findin s
The inspector's review of the AAP section of the licensee's audit report
disclosed that the audit identified one deficiency in the area of Access
Authorization involving the failure to notify candidates
on the Security Consent
Form of their right to review and correct any adverse information that they
believe is incorrect.
That right was being provided to them orally. The Security
Consent Form had been revised to correct this oversight and the inspector
could find no instance where this had been raised as a problem.
C.
Conclusion
The review concluded that the audit was comprehensive
in scope and depth,
that the findings were appropriately distributed and that the audit program was
being properly administered.
P8.10 Record Retention
a e
Ins ection Sco
e
The inspector reviewed the on-site record retention program for the AAP
records.
Observations
and Findin s
Records are stored in locked file cabinets, accessible
only to authorized
personnel.
The inspector noted that the records were very well organized
and
complete.
Conclusion
The inspector concluded. that the storage facilities provided adequate
security,
and that access to those records was adequately
controlled to protect personal
information from unauthorized
personnel.
The inspector noted that the records
were very well organized
and complete.
Exit Interview
The inspector presented
the inspection results to members of licensee
management
at the conclusion of the inspection on October 7, 1996. At that
time, the purpose
and scope of the inspection were reviewed and the
preliminary findings were presented.
The licensee acknowledged
the
preliminary inspection findings.
U dated Final Safet
Anal sis Re ort
UFSAR Review
A recent discovery of a licensee operating its facility in a manner contrary to
the UFSAR description highlighted the need for a special focused review that
compares plant practices, procedures
and/or parameters
to the UFSAR
description.
Security requirements
are not specifically included in the UFSAR;
they are in the licensee's
NRC-approved security plan.
While performing
inspections discussed
in this report, the inspector reviewed applicable portions
of regulatory requirements that related to the areas inspected.
In addition to
inspecting the licensee's AAP, the inspector also reviewed the licensee's
Fitness-for-Duty (FFD) random testing program.
The inspector noted that on
October 10, 1996, during random FFD testing being conducted
in the Training
Building, an employee that had been selected for random testing was excused
from testing and listed on the random testing roster as being off-site. The
inspector requested
the licensee to check the security computer transaction
records to validate that the employee was off-site. Those records indicated
that the employee, at the time of notification for testing, was, in fact, on-site.
Further review by the inspector disclosed that the same employee
had also
been randomly selected for FFD testing on October 2, 1996, but was listed on
the random testing roster as being excused from testing because
he was off-
site.
The inspector's review found that the employee was, in fact, on-site.
Review of other random selection
FFD rosters identified five more employees
who were not tested and listed as being off-site on September
10, 1996, when,
in fact, they were on-site.
Additional review by the inspector disclosed that the
employees selected for random FFD testing were not notified that they had
been selected.
In the case of the employee who was selected for testing on
October 2 and 10, 1996, the FFD contact person who was responsible to notify
the employee to report to the testing facility had provided information that the
employee was unavailable.
The FFD clerk conducting the random testing
accepted the excuse of unavailability and recorded the code for being off-site.
Discussions with licensee management
disclosed that the employee who had
been selected, was in a meeting on-site on both days at the time the FFD
contact person was notified. It was not clear why the FFD clerk assumed
he
was off-site on both days.
In the case of the five employees
selected for testing on September
10, 1996,
the inspector found that extenuating circumstances
existed which resulted in a
miscommunication between
a company vice president and the FFD clerk.
Those five employees
were also listed as being off-site although they were on-
site in a meeting.
Again, it was not clear why the FFD clerk recorded them as
being off-site. The licensee stated that the situations would be reviewed and
resolved.
The five employees
were placed on the "pick up" list (as was the
employee
in the later case) and were tested properly the next week in
accordance
with the licensee's
FFD Manual.
The licensee's
FFD Manual, FFD-8, Revision 6, dated March 4, 1996, states
that when an employee selected for testing is unavailable for a legitimate
reason (e.g., illness, vacation, jury duty), the supervisor will inform the FFD
clerk. The failure to test an employee selected for random FFD testing without
a legitimate reason
on October 2 and 10, 1996, and in accordance
with FFD
Manual, FFD-8, is a violation of 10 CFR 26.20 and 20.24(a)(2).
(VIO 50-244/96-1 0-02)
PARTIAL LIST OF PERSONS CONTACTED
Rochester
Gas and Electric Cor oration
R. Mccredy, Vice President,
Ginna Nuclear Production
J. Widay, Plant Manager
N. Hessler, Human Resources
Group Manager
S. Eckert, Access Authorization Administrator
R. Marchionda, Superintendent
Production
L. Hauck, FFD Coordinator
A. Plummer, Director, Medical Services
R. Teed, Supervisor,
Nuclear Security
N. Slocurn, Security Access Clerk
C. VerMeeisd, Security Access Clerk
D. Dunn, Computer Systems Clerk
J. Hutchkiss, Mechanical Maintenance
Manager
T. Porter, Security Systems Specialist
D. Kuhn, Security Operations Coordinator
B. Stanfield, QA Engineer
J. Smith, Maintenance Superintendent
M. Lilley, Manager, QA
U.S. Nuclear Re ulator
Commission
P. Drysdale, Senior Resident Inspector