ML19353B197

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Partially Withheld Physical Security Insp Repts 50-289/89-22 & 50-320/89-10 on 891010-13 (Ref 10CFR73.21 & 2.790(d)).Violation Noted.Major Areas Inspected:Mgt Support, Security Program Plans & Audits & Security Training
ML19353B197
Person / Time
Site: Crane  
Issue date: 11/22/1989
From: Dexter T, Keimig R, Galen Smith
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19353B195 List:
References
50-289-89-22, 50-320-89-10, NUDOCS 8912120163
Download: ML19353B197 (7)


See also: IR 05000289/1989022

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U.S. NUCLEAR REGULATORY COMMISSION

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REGION I

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50-289/89-22

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Report Nos.

50-320/89-10

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50-289

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Docket Nos.

50-320

DPR-50

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License Nos. OPR-73

Licensee: GPU Nuclear

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100 Interpace Parkway

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Parsippany, New York 07054

Facility Name: Three Mile Island Units 1 and 2

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' Inspection At: Middletown, Pennsylvania

Inspection Conducted:

October 10-13, 1989

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Inspectors: [

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G. C. Smith, Senior Physical Security

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Inspector

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T. Dexter, Physical Sec tity Inspector

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Approved by:

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R. R. Keimig, Chi (f, Safeguards Section,

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Facilities Radiological Safety and Safeguards

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Branch

Inspection Summary:

Routine Unannounced Physical Security Inspection on

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October 10-13, 1989 (Combined Inspection Nos. 50-289/89-22 and 50-320/89-10)

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Areas Inspected: Management Support, Security Progrtm Plans, and Audits;

Protected and Vital Area Physical Barriers, Detection and Assessment Aids;

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Protected and Vital Area Access Control of Personnel, Packages and Vehicles;

Alare Stations and Communications; Emergency Power Supply; T'esting,

Maintenance and Compensatory Measures; and Security Training and

Qualifications.

Results: The licensee was found to be in compliance with NRC requirements

in the areas inspected with the following exception:

an armed guard failed to

meet the minimum physical qualifications for visual acuity.

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Details

1.

Key persons Contacted

H. Hukill, Vice President and Director TMI-1

R. Shaw, Radeon Director TMI-1

J. Stacey, Security Manager

J. Fornicola, Manager, TMI Quality Assurance

M. Wills, Media Relations Manager

S. Mervine, Protection Training Supervisor

J. Enders, Security Lieutenant

D. Hassler, Senior Licensing Engineer

J. Flowers, Security Analyst

D. Barry, Engineer

J. Herman, QA Auditor

C. Comerford, Security Staf f

The inspectors also interviewed other licensee security, maintenance and

training personnel.

All of the personnel identified above were present at the exit interview.

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2.

Management Support, Security Program Plans, and Audits

a,

Management Support - Management support for the licensee's physical

security program was determined to be adequate by the inspectors.

This determination was based upon the inspectors' review of various

aspects of the licensee's program during this inspection, as

documented in this report,

b.

Security Program Plans - The inspectors verified that changes to the

licensee's Security, Contingency, and Security Officer Training and

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Qualification Plan, as implemented, did not decrease the

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effectiveness of the respective plans, and had been submitted in

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accordance with NRC requirements. The inspectors' review of

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Safeguards Plans and implementing procedures disclosed that the

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number of rounds of ammunition carried by armed personnel for

revolvers was not specified.

The licensee agreed to document in a

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procedure that armed personnel carry 17 rounds of ammunition for

their revolvers and that, for safety reasons, the chamber under the

hammer of the revolver is empty,

c.

Audits - The inspectors reviewed the Annual Quality Assurance (QA)

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Audit of the Security Program conducted September 14 through

October 9, 1980.

There were no adverse findings identified during

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the audit and the recommendations made by the auditors, were for

minor, non-regulatory issues.

The audit was conducted by individuals

with a thorough understanding of nuclear plant security and

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independent of the security program.

The audit was comprehensive in

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scope and depth, however, one deficiency in the audit was identified

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by the inspectors.

During the audit, the QA auditors requested, but

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were denied, access to source medical documentation for members of

the security organization. The auditors stated that medical

department personnel maintained custody of the medical records and

orally responded to the auditors' questions relative to whether

personnel had met the physical qualifications required by the

NRC-approved Training and Qualification Plan and the NRC Regulations.

No discrepancies in the medical qualification records were identified

during the QA audit, however, the lack of independent verification of

source medical documentation is considered to be a weakness in the

audit program. QA department personnel recognized this weakness at

the time of the audit and, at the time of the inspection, were

attempting to resolve the issue.

Further details relative to concerns over medical documentation are

contained in paragraph 8 of this report.

3.

Protected and Vital Area Physical Barriers. Detection

and Assessment Aids,

a.

Protected Area Barriers - The inspectors conducted a physical

inspection of the Protected Area (PA) barrier on October 10, 1989.

The inspectors determined by observation, that the barriers were

installed and maintaired as described in the Plan. No deficiencies

were noted.

b.

Protected Area Detection Aids - The inspectors observed the PA

perimeter detection aids on October 11, 1989 and determined that

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they were installed, maintained and operated as committed to in the

plan,

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The inspectors requested the licensee to test the detection aids at

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numerous locations. All detection aids performed as required except

for one that failed to alarm during the tests. The licensee took

immediate and appropriate compensatory measures and initiated action

to correct the deficiency.

c.

Isolation Zones - The inspectors verified by observation that

isolation zones were adequately maintained to permit observation of

activities on both sides of the PA barrier.

No deficiencies were

noted.

d.

Protected Area and Isolation Zone Lighting

The inspectors conducted a lighting survey of the PA and isolation

zones on October 11, 1989. The inspectors determined by

observation, that lighting in the PA and isolation zones was

adequate. No deficiencies were noted,

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Assessment Aids - The inspectors observed the PA perimeter assessment

aids during the daylight and the hours of darkness, and determined

that they were installed, maintained, and operated as committed to in

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the Plan.

The inspectors confinned that a blind spot in the

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assessment capability in the area of the Unit 2 Processing Center,

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identified during a previous inspection, had been corrected and that

assessment capability was adequate in this area.

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Vital Area Barriers - The inspectors conducted a physical inspection

of several vital area (VA) barriers during the period of the

inspection.

The inspectors determined, by observation, that the VA

barriers were installed and maintained as described in the Plan.

No

deficiencies were noted.

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Vital Area Detection Aidt, - The inspectors observed the VA detection

aids and requested the licensee to demonstrate, at several

locations, that the balance magnetic switch alarms and the tamper

switch alaras were installed properly and generated an audible and

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visual alarm at the security alarm stations. No deficiencies were

noted.

4.

Protected and Vital Area Access Control of Personnel.

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Packages, and Vehicles

a.

The inspectors determined that the licensee was exercising positive

control over personnel access to,the PA. This determination was

based on the following:

1)

The inspectors verified that personnel were properly identified

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and authorization was checked prior to issuance of badges and key

cards.

No deficiencies were noted.

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2)

The inspectors verified that the licensee was implementing a

search program for firearms, explosives, incendiary devices and

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other unauthorized materials as committed to in the Plan.

The

inspectors observed both plant and visitor personnel access

processing during peak and off peak traffic periods. The

inspectors also interviewed members of the security force and

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licensee's security staff about personnel access procedures.

No deficiencies were identified.

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The inspectors verified the VA access list was' reval'riated at

least' once every 31 days as committed in the Plan. . However, the

inspectors noted that all of the approximately 900 personnel

badged for unescor.ted access into the PA, were also granted

unescorted access to all VAs in the plant. This included

secretaries, maintenance workers and vendors.

Apparently, the

licensee considered that a clearance for unescorted access to the

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protected area was acceptable to permit unescorted access to'all

VAs.

The absolute need for access to a VA was not a considera-

t;on.

The licensee- agreed to review this portion of their

at cess program and determine what changes are necessary. This

will be reviewed during a subsequent inspection (Inspection

Follow item 50-289/89-22-01; 50-320/89-10-01).

4)

The inspectors determined, by observation, that individuals in

the PA and V4 displayed their access badges as required. ho

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deficiencies were noted.

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5)

The inspectors verified that the licensee had, and was

implementing, escort procedures for visitors to the PA and VAs.

No deficiencies were noted.

6)

The inspectors verified that the licensee had provisions for

expediting prompt access to vital equ'pment during emergencies

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and that the provisions were adequate for that purpose.

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b.

The inspectors determined that the licensee was exercising positive

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control over packages and materials that were brought into the PA.

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The inspectors reviewed the package and material control procedures

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and found they were consistent with the commitment _s in the Plan.

No

deficiencies were noted.

c.

The inspectors determined that the 1 wensee properly controlled

vehicle access to and within the PA.

Tne inspectors verified that

vehicles were properly processed prior to entering the PA. This-

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determination was made by inspection of vehicle logs, checking

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vehicles in the PA, and by interviewing membert of the security

force about vehicle processing.

No deficiencies were noted.

5.

Alarm Station and Commun M iom

The inspectors observed the operation of the Central Alarm Station (CAS)

and Secondary Alarm Station (SAS) and determined they were operated as

committed to in the Plan. CAS ud SAS operators were interviewed by the

inspectors and found to be knowledgeable of their duties and responsibi-

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11 ties. The inspectors verified that the CAS and SAS did not contain any

operational activities that would interfere with the assessment and

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response funr:tions. No deficiencies were nottd.

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Emergency Power Supply

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The : inspectors verified that the security systems emergency power was

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supplied by a dedicated diesel generator and batteries. The emergency

systems were reviewed and found to be consistent with the Plan. The

batteries, battery chargers, diesel generator, and transfer switches are

located in=a VA.

No deficiencies were noted.

7.

Testing, Maintenance and Compensatory Measures

The inspectors reviewed testing and maintenance records and confirmed that

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the records committed to in the Plan were on file and readily available

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for NRC review. The review of maintenance records indicated that repair

or replacement of inoperable equipment was accomplished in a timely.

manner.

The inspectors reviewed the licensee's use of compensatory measures and

determined them to be as committed to in the Plan. No deficiencies were

noted.

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8.

Security Training and Qualification

The inspectors randomly selected the training and qualification records

of 12 security' officers for audit.

The documentation required by the

Training and Qualification Plan (T&QP) was reviewed. .That documentation

consisted of physical qualifications and classroom, practical and firearms

training. -The inspectors determined that the required training had been

conducted in accordance with the T&QP and that it was properly documented.

However, the inspectors' review of physical qualification,

i.e., medical

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documenta. tion required by the T&QP, disclosed a discrepancy. The

inspectors found that during a physical, on May 26, 1989, an armed

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security officer's distance visual acuity was testM by the Medical

Department and determined to be 20/50 in the weak eye, corrected. The

NRC-approved.T&QP and 10 CFR 73.55, Appendix 8 states that the minimum

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visual requirement for the weak eye is 20/40, corrected, for armed

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security officers. The Medical Department did not disqualify.the officer

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for armed duty or provide the results of the eye test to security

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maagement cr to the offict . Therefore, the armed officer remained on

duty. Once this concern was identifiad to the licensee by the inspector,

this guard wcs removed from armed 6.'ty.

The failure to disqualify the officer for armed duty when he did not meet

the minimum physical requirements of the NRC-approved T&QP is a

violation (50-289/89-22-02; 50-320/89-10-02).

After the above violation wa: identified, the inspectors' requested

licensee management to conduct a review of the eye test portien of the

medical records for all security officers to determine compliac- with tne

prescribed vision standards identified in the NRC-approved T&QP. At

management's direction, the QA auditors reviewed the eye test source

medical documentation. The review was completed before the end of the

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inspection and it identified one additional armed security officer who

f ailed to meet the minimum visual acuity requirements. That of*icer had

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been tested by. the Medical Department in February 1989 and remained oc

armed duty .until this problem was identified.

As a result of the discrepancies identified with the eye test medical

documentation for security personnel, the licensee made a commitment to

perform a QA audit of the remaining portions of the security medical

records and the medical records of other licensee personnel who must meet

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NRC required physical qualifications.

Further, management stated that QA

personnel performing audits would have access to source medical

documentation in the future in order to provide an independent review of

the documentation. The QA audits performed'on the medical documentation

for security o.'i1cers and other licensee personnel will be revieved during

a subsequent inspection (Inspector Follor item 50-289/89-22-03;

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50-320/69-10-03)

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9.

Exit Interview

-The inspectors met with the licensee representatives identified in

paragraph 1 at the conclusion of the inspection on October 13, 1989. At

that time, the purpose and scope of the inspection were reviewed and the

findings were presented.

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