ML20044C259

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Advises That Both Allegations RI-91-A-070-2 & RI-91-094-2 Document Same Issue Re Failure to Comply W/Natl Electric Code & Have 36-inch Working Space in Front of Same Two Panels Located in Unit 2 Maint Shop.W/Listed Attachments
ML20044C259
Person / Time
Site: Millstone Dominion icon.png
Issue date: 11/27/1991
From: Shedlosky T
NRC
To:
NRC
Shared Package
ML16266A160 List:
References
FOIA-92-162 NUDOCS 9303190352
Download: ML20044C259 (16)
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Text

{{#Wiki_filter:q 26 , ~ 1 $ 0 -3 3 b ~ MEMORANDUM TO: FILE November 27, 1991 FROM: TOM SHEDLOSKY

SUBJECT:

ALLEGATIONS INVOLVING NON-RADIOLOGICAL OSHA SAFETY ISSUES ON ELECTRIC PANEL CLEARANCES Both allegations RI-91-A-070-2 and RI-91-094-2 document the same issue, failure to comply with the National Electric Code and have a thirty-six inch working space in front of the same two panels (Panels No. 3& 4) located in the Millstone Unit-2 Maintenance ~ Shop. A representative of the U. S. Department of Labor (DOL) Occupational Safety and Health Administration (OSHA) Hartford Area Office conducted an on-site inspection (Number 100976687) of the panel installation on July 11, 1991 in response to an employee allegation (Complaint No. 073850059). A letter from the Area Office, dated October 31, 1991, identified a violation of the Occupational Safety and Health Act of 1970 and 29 CFR 1910.303(g)(1)(i); there was no civil penalty. The Millstone Station Director responded to the Citation by letter dated November 25, 1991. The letter informed the OSHA Area Office that the violation was abated during the week following the July 11, 1991 inspection. I think, it would be redundant to refer this to issue OSHA again as these allegations were received on April 15, 1991 and May 7,

1991, respectively.

I reccmmend that we inform tne alleger that an OSHA on-site inspection was made on July 11, 1991; e citation issued; and corrective actions taken. And that, we plan no additional actions. I also recommend that we do not transmit the attached correspondence to the alleger. Attachments:

1) OSHA Complaint No. 073850059
2) U.

S. DOL OSHA Hartfc.d Area Office letter to Northeast Nuclear Energy Company, dated October 31, 1991

3) OSHA Citation for violation of 29 CFR 1910.303(g)(1)(i)
4) NNECO letter to OSHA, dated November 25, 1991
5) Copy of 29 CFR 1910.303(g)(1)(1)

Allegation File RI-91-A-070-2 cc: Allegation File RI-91-A-094-2 E. Kelly, PPS No. 4A, DPS R. Barkley, PSB No. 4, DRP E. Conner, TSS, DPP 9303190352 921217 f, j PDR FOIA v HUBBARD92-162 PDR l

.A, i conmi Ome... seie.n street, seriin. Connecticut. NORTHEAST UTILITIES 1 P.O. box 270 1 rsw -um-HARTFORD. CONNECTICUT o6141-0270 [ (203) 665-5000 Z,CU7.,, L L J r I John J. Stanton. Jr. U. S. Department of Labor Federal Office Building - Room 508 J 450 Main Street Hanford, CT 06103 Re: Citation Resulting From Inspection 100976687, July 11,1991

Dear Mr. Stanton:

I inspection This letter is in response to a violation noted during the recentThe specific 2 maintenance shop. referenced above of the Millstone Unit violation was the failure to maintain a working space of more than 36 inches - in front of two (2) electric panels. The The violation was abated during the week following the inspection. was abated by removing an interior insulation retaining plywood violationAs a result, adequate work space clearances in excess of the minimum panel. Table S 1 were ' established. required by 10 CFR 1910.303 (g) (1) (i) Please contact me if you have any funher questions on this matter. Sincerely, j]N / W l Stephen E. Scace i Director, Millstone Station b bec J. F. Opeka i W. D. Romberg D. E. Welch J. F. Follett R. Voigt List D i j j

Occupational Safety and Health Administration U.S. Department of Labor r*-

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.= j i ~ U.S. Department of Labor Occupational Safety and Health Administration .,,, m s e Reply to the Attention of: If you escice to recuest an informal conference, please ccmplete tr,a attacheo nt.ticE et the Dottom cf th1s letter anc pcst it r,ast to tn citations as socn as tr.e time,

date, ans placs cf tne informai c:nferents have bsen cetermirred.

E= sure te bring te the ccnference witr,you eny unc all supporting occumentation cf ex1 sting conditions as well as of any aratament stets taken thus far. If conditions warrar.t. we can Enter inte an informal settlement agreement which amicacly rescives th1s mattar without liti;at1or,or contest, Eincerely, Am d. ^ 3: J. Etar, ten, Jr. Gre D1 rector Enc 1 Cst.1res .--.-.4:-.-.----.----~.-_._-_-.-___-- l i U.S. D:partment of Labor g Occupatonal Safety and Health Administration MY~D

3. Issuance Date
4. Ins: seton Numba l

Citation and Notification of Penalty 10/31/91 100976687 l l U.S. Department of Labor

5. Reporting ID
6. CSHO ID l

l Federal Office Building - Roon 508 0112000 Y4553 l + p,,,,,,, 450 Main Street The violaton(s) desenbed in this 7.optenal Report No. 8.Pcge No. l Are Due Within 15 Hartferd, CT 06103 C):ation are aneged to have oc. curred on or about the day the 604 g og } l ot e e ind cate wrthin he to. Inspection Date(s): Of Diis M# E desenption gfven below. Nattacadon 7/11/91 - 7/11/91 unless Contested Other 01

11. Inspecten Site:

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nca, Mll.LSTONE NUCLEAR POWER Pt.AMT

) Bmm) t To. WATERFORD, CT 06385 l l The Sec.on . NORTHEAST NUCLEAR DERGY CDMPANY y,3y 5, l De:ac*ed cnd its successors P.O. BOX 128 B'D, p, WATERFORD, CT 06385 Thel THE L.AW REQUIRES that a copy of this Citaten be posted immediately in a p t This Cr.aton describes vio'ations of the Occupatonal Safety and Health Act of 1970. The penafry(es) hsted b Is longw. d absta the violations referred to in this Citation by the dates listed below and pay the penaftes proposed, unless w and Federal holidays) from your rece:pt of this Citatron and penalty you mail a notco of contest to the U.S. Depar shown E.bove. (See the enclosed booklet which outhnes your nghts and resoons ft e pt d t be revewed by any this Citation and the preposed penattes will become a final orcer of the Occupatonal Safety and Health Review Commesseon d court or agency. Issuance of this Cita!cn does not constitute a finoing that a violaton of the Act has occurred u g ter in the Act or, if contested, unless the Citation is affirmed by the Revew Commission.

15. Date by Whch l
16. Penatry Votaten Must
12. ttirn Number Be Abated l
14. Desenpton
13. St:ndard. Regulaten or 4

Secton of the Act Volated 0.00 11/19/91 I 1 The dimension of the working space in the 29 CFR 1910.303(g)(1)(i): direction of access to liva parts operating at 600 volts or less and I likely to require examination, adjustment, servicing, or maintenance I while alive was less than indicated in Table S-1: l I THE WORKING SPACE I NCRTHEAST CORfER OF THE UNIT E MAINTENANCE SHOP: IN FRONT OF THE TWO (2) ELECTIRC PANELS WAS LESS THAN 36 INCHES 1 I I I i i l i I i 1 l i l I i i I 0.0< John J. Stanton, Jr. ( %,) hg I ~ * * * * l Total i NOTICE To EMPLOYEES - The law gives an empNyee el EMPLOYER DISCRIMINAT10J4 gag,' his trpresentative the opportunity to object to any abate-filing a complaint or for exercising any nghts under th:s Act.1g g,, i ment date set for a violation if he believes the date to be An employee who believes that he has been discrimmated against may file a complaint no later than 30 days after the - unro sonable. The contest must be mailed to the U.S. , o.a. discrimination with the U.S. Department of Labor Area Of- [ g J* i Department of Labor Area Office at the address shown above within 15 working days (excluding weekends and fice at the address shown above. l i Fed;ral holidays) of the receipt by the employer of this Cita-tion and penalty. richts and responsibilities and l mA e i.-.... - iw.~imar

_,J Occupational Safety and Health Administration U.S. Department of Labor f. c e 'c ,/ Reply to the Attention ot 9211;E 10 Et!L91EEi k CE,A tc ciscuss t r.s cita-An inf cr..a1 cor.ference Pas teen sche:uled *:th

ice.s izsace cc. 10/31/91. The c:nfarance will te held at the 05HA cifics located at Federsl Office h:ilding - Room 5OE, Hartford.

CT 0::103 o r. v _ a. I ( l i I l i i = l l 1 l i 1 e 1

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~ U.S. DEPARTMENT OF LABOR 9 OCCUPATIONAL SAFETY & HEALTH ADMINISTRATION GUIDELINES FOR PREPARING AN ADEOUATE ABA TEMENT LETTER e Abatement letters must specify action taken to correct citation items and the date stated corrections were completed. Please use the following guidelines forassistance in completing an abatement letter. IN ADDITION, if NO SETTLEMENT A GREEMENT IS REACHED AND YOU DO NOT CONTEST, PENALTIES ARE DUE IS WORKING i DAYS AFTER RECEIPT OF CITATIONS, AFTER WHICH THEY ARE CONSIDERED DELINOUENT AND YOU MA Y BE SUBJECT-TO INTEREST AND ADMINISTRA TIVE FEES. State the Citation Number, the item Number (s) and the instance letter. Enter date of completion and the specific corrective action taken, including any applicable dimen-sions, phohtographs, materials, specifications, personalprotective equipment, engin - -.-- cering controls, measurements or readings. If overexposure to an air contaminant or noise has been cited, sampling results need to be reported to verify compliance and document effectiveness of controls. Example: Citation 11, Item K1, Instance (a)- Date: 00/00/00 A guard was installed on the Black and Decker table saw. We cannot close your file if the abatement letter does not give abatement date and 5 specific corrective action taken. If an informalconferenceis scheduled, you may wish to bring the abatement letter to the meeting. Thank you. .:.Z. ~. l ) i

U.S. Departm qt,of WEor - Nobce C1 Auegeo da'ety or riea,ttl tiam o=s:e:ra savy ae Q Asweate ~

1. Compact Nam:c >073850059

~ 'u00 Dre 17- // - 9/

2. Empeyer ha~e CONN. LIGHT & POWER CO.

~ CT 06385 z sue tuum peet cm s:ee. zia WATERFORD MILLSTONE NUCLEAR POWER PLANT

i. u:ang Ameess of eew) peet ce s:a:e. zin tubeN-*fasmw/-1791 20 E uavgeme1 OMoa' ROBERT A. AYALA
7. Type d Bascess POWER GENERATION
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~ ~]'~ ? '~ s i a g $n M,. + c y l yv w l 6., ( a p:p? y' I L Q2 ~ ~.~~? ~ .lW Admin., Labt '3.

q-ational Safety and Health r.atio.

P QN table only if beid mgs shall be provid-I1910. % ! CFR Ck y N E M 4s. gobpart shall be kccep e or ment ; _.....eed giving voltage, current, wattag, The mark-r participa-. , - - ~ and Eramination, instcIlatiott, Examination. other ratings as necessary. s% ved. .O$rgd,y bihty to ing shall be of sufficient dura rided prior i volved. s, s-Q% e jof ecuspment-(l) shall be free LSsignmeni y withstand the environment nof disconnecting er' 5%' Q*y %.g[* '.ms @=eg% recognitedcause death or serious physi-equipment that are har.ards cal Identtrication nnect-fler. means cnd circuits. Each disco M-- t for 2 shall be of (D er, g"; g ewgy to employees. Safety. ing means required by this subparand appl l h the em-9' r% *"' Wp.QM tarm tohall be determined usmg y . The em. W4gg ier.s marked to indicate its purpose, un W m'd t Opment s and 1 employ. '** mm gg%.@llo ing considerationsinstallation motors se is %*2 [Q % w gg Suttabinty ior,th the provisions located and arranged so the purpo w and g.

feeder, yin conformity w:subpart. Suitability of equip-pe m M evident.

m Each sernte, its disconnecting athophyl. WW,_ % y *v s%- or overeurtent device, shall be at hu=%. Q P

circuit, j*6*a-. phis nMMpor labehng for branch arpr<se,

'n m legibly marked to indicate its punless l yvenced by listing means the tremo e identified purpose.gth and darabil. markincs ,olite in Nery electric Utilcation 5.1972. and ere' f"30f[9 Mechanical strenincluding, for parts designed t purpose is evident. These to equipment i D durabihty I util-of sufficient i olved. manner af ter March 15, ggg pe and protect other eqquacy of the protection darch withstand the environment nv% nomnd, or kne tinohte thus pro. shall be a ssegtog modificatlon' pg U nme ditat W M cbout electrseand wctking

  • rations electric' utm.,

dfd' ion. mons 1972 cad mi) Electricalinsulat Worktng space

art rch 15, Ws' cf.%}use. eaWg eMeets under cond Sufficient accessshall be provided and main equipmtat
  • to as.

2 or H ment uipment to

  • or ac.

J befo e ation and tained about all electric eq space MO l With '3) Arcing etfects.avi) Classification by type, sir.e. vo t-F0.302 t6ough 1910.308.m n permit ready and safe opermaintenanc ts and nt, fic use. tk de. swt p. current capacity, speci leem-which contribute N atx m I Wor reMacemeg i (O Working clecrances. here in this Other f actors f e:n-or rehabin:4uag. & piDr the practical safeguarding oMes unng or WW to working ! Im ple-quired or permitted elsewsubpart, the d .ntho-5. ,10 that invojvg m ex. DgUt.anewetenovatea 7 - 3h ply to set with the equipm nt* e or less and space in the direction M l Opro. parts operating at 600 vo ts

  1. ' used or in-djust-The folloutg provis! U8 likely to require examination, ame rad equipment shall beCed in accordance with r ny instruc-hile
e utilhation systems

/ label-equipment installed after Aprf) d ated in ' gy,tr.s included in the listtng or alive may not be less than in ic N dimen-l And Table S-1. In addition to the 81: shall be k pace ! xpg siens shown in Table S-1. wor s Conductors t%,ne am et ~,n s -d4hheed or joined with splicing devicesor by brazing. wide in [ Splicca e % ' t (c) may not be less than 30 inchesfron Dis-l n of mM tt 'W-with a fusible NNw [* [l[ **"o ***=4 Mitable for the use 1 c re. d splices shall

  • AM c%.,,,,0*,,8 g**$ telding, or soldermg tances shall be measured froparts from the ion-t cm,,
    • m.

tetal er alloy. Solderest be so spliced-or joined as to be

  • "" **ms "wie.

in-re J:echanically and electrically secuoldered. All enclosure front orenclosed Mso%A M7, '7' W und-dn- _Tithout solder and then sChees and joints and the free ends of parts arewalls are considered to be gro ~ *"S *r= dewed ~*A man uired in Tj'. ;mnductors shall be covered with an in-ed. Working space is not req "W me d front py tile t@ f the con-back of assemblies such as dea - ralation equivalent t.o that owith an insulating devicel centers Ts 3M switchboards or motor controable er ad-Af-w 3g ' G*owcmmnvn' 'umm ' shere there are no renew ~ hetors or switch-the purpose. of electric anacu _. Q *m

  1. Q f

justable parts such as fuses or e c s a c6 s ; graitable orArcing parfs. Partsordinary oper-a, s[7 e, ll connec-es on the back and where afrom locations = (d) h in s or . 6t'iuipment whici hion produce arcs, sparks flame, he 2M _._ uQ*ums*N5 8"%y accessible a. Aolten metal shall be enclosed or sep'd frorn all combusti-tions are y ',$g "C p

s. Jan.16. 2923; 46 PR 40185,-q,.. l1 rated and tsolateno. Electrical egalpment g

5 fac-ay not be used unless the manu Ne g jp3g h de-General requirements. VI.t $tarer's name, trademark, or ot er king by which the organi-E303 MMtel The conductof%"and Dment required or perm!tted ty / scriptive mar 659 } ,_f J,5 y O .g l '.Mk . -",k 4 ~ ry.g I h ',.b v l $M. k ~ GSm ~.,

--m-- r r e cp [ ational Sciety and Health Admin., Lobc i f. u 29 CFR Ch. XVII (71,gg

  • ^p I

.%d-on of a quahfied person at SU are + i [ 1910.303 is nt JnstcIlctions cceesttble to quali-such I (A) By location in a roo% ' ! 3 Tastr S.1 WoutoCLEmots - similar enclosure that is trol j j only to quahfied persons-4 ed yrsons only. Dect.rical instana-5 having exposed live parts shall new: .} wmm y spsu (B) B) suitable permanent, QA i I tia partitions or screens 50 arragI essible to quahfied persons only fuse ~ w,u m.,mramo [m i g shall comply with the apphcable un i t whe y quahfied persons st! % i 1 o ons of paragraph th)(3) of this fron 3 j t 3 $P hi et f f Nd f h* 3 e ar' y p m i JnstcRctions cceestible to un-tions or screens shan be 50 aised tag 1 hed persons. Dectrical instana-encl m t t u.- e, , w,,, = u. m.,

r. :

C",ed persons are not Uketyp. .1 g contact with thet,. that are open to unqualified per-4 "* E.,sna %. T N. N m s m to wrao*e a ra m opa.*or ~ hve parts or to bring conduct!Qg M g shall be made with metal-e m.o it sh pc e! 9 equipment or rhaU be enclosed g M.,m m % m. S, a.,%,,".i ".:.*#5 $'."om",. p e-O,** Jects mio contact with them-tilfhp "a vault or in an tres, access to 7^8' l j N .w.wo tuw a (C) By location on a sultele balced J ny. gauery, or platform so eleettad{ dich is controned by a icet. If metal. g".,j,*L*gg'; *,L'Zon","o;c**,L=ee; g f 1I ai N m .L a ar.ged as to exclude unqualised y helosed equipment is h.iaaned so that o' = o.g, m tu, a.,ago o as pe==a e co'= 4 * - Mi..J. ge bottom of the enclosure is less m t l J (D) By elevation of B feet og a@ gn 3 feet above the floor, the door - (11) Clear spceet Werking space re. above the floor or other working Meg-t ever shan be kept locked. Metal-4 may not be , *%Mk d switchgear, unit substations. i quired by this subpart used for storage. When normany en. (ii> 1n locations where electric egelpy, scloseg.,.:sformers. pull boxes, conne l D face. 'I l /A closed live parts are exposed for in. ment would be exposed to Dhfukah gses, and other similar associated sm t 2W i damage, Mosures or guards &Wb ydpment shall be marked with ap-or servicing, the working

  • l space if in a passageway or general so arranged and of such s* gas to A ppriate caution signs. If equipment j

M spection w A.4 YE uxposed to physical damage from ve-i j N open space, shan be suitably guarded. prevent such damage, Entrances to rooms and c"Lheep ffic. suitable guards shan be 3 N (iii) Access and entrance to teorking i 3 space. At least one entrance of suffj. guarded locations contai*r evnnedk. Mar traWed to pre (iii) cient area shan be provided to give live parts shan be marked with em'n W or simuar opengs M ml-b access to the working space about elec. spicuous warning sW.s forbW D oclosed equipment d tric equipment. quahfied persons to enter.. e wir5 a'i that foreign objects inserted l om ; amp hough these openings will be deflect-gl (iv) front toorking space. Where k te merM pads. there are live parts normally exposed used on circuits exceeding 600.'veBCg @ (* ! r on the front of switchboards or motor (1) Workspcce about equipment Suf-hl .ww control centers, the working ; pace in jy g,3 6 " andM, taintained about electric equipment gg p,. y front of such equipment may not be g p s i tion [ ! .ichrM. b permit ready and sa e opera 11ntenance of sj l O 8 0 8 less than 3 feet. (v) Illuminction.. Illumination shan d 2: f ment or modify those requ6M ( ! energized pans a.re exposed. (I spaces The provisions of paragraphalhK32/g gmum clear workspace may not tic, h be provided for all working about service equipment, switch-(hK3), and (hh4) of this sectiond8W g21ess than 6 feet 6 inches high sp. f fl { boards, panelboards, and motor con-apply to equ:pment on the s'd8ggg ured vertically from the floor or ng ; trol centers instaued indoors. 4 M' F Yml. or less than 3 feet wide th ; j j (vi) Hecdroom. The minimum head' d tM urvice conductors. $1s red parauel to the equipment). room of working spaces about service (2) Enclosure for clectriccl f m: j 4 switthboards, panel-tions. Dectr2 cal installationa'tJf g[pth shall be as required in wg j j 2.The workspace shall be ade-ot j boards. or motor control centers shall vault, room, closet or in an EUR equipment, } rounded by a wall screen..e to pertnit at least a 90-degree i ~ l be 6 feet 3 inches. access to, which is controHed of doors or hinged panels. "I f I Non-As used m this section a motor con. and key or other approved m A WorW sm M hm ar : j d' trol center is an assembly of one or more en-considered to be accessible n.ar n%,e m w a u. 'C I closed sf rtions havmg a comrr.on power bus pment such as switchboards, con. s contamms motor control-persons only. A wall. ser d panels, seg et hg 5 less than B feet in height F l and principally unna. ered to prevent access rubr controuers, relays, and simuar W' ment may not be less than speci- %+d In Table M uh WW (2) Gucrding oflity parts. (i) Except other features that provl gg el J as required or permitted elsewhere in isolation et;uivalent to T J this subpart, live parts of electric The entrances to all bu ed b h em Dmm at 50 volts or or enclosures containing be measured from the live parts i = equipment operating more shall be guarded agamst acciden. parts or exposed conda tbe7 tre exposed, or from the enclo-i tal contact by approved cabinets or at over 600 volts, n tront or opening if the live parts t i l 1 other forms of approved enclosures, or kept locked or shau 661 I l by any of the fonowing means: 660 a i J i' l i [ ji 1 i l i f i i l n ? W:h. --w _ .,e \\

.i f, P NNECO personnel revised the radwaste check off lists to include a specific instruction to review licenses for limitations in type, form and quantity of byproduct materials to be shipped. The inspector reviewed Revision 5 of the Radioactive Shipment Checklist to verify the change had been made and noted this action would be appropriate to preclude a recurrence of the error. This matter was reviewed with Region I personnel, including members of the Division of Radiation Safety and Safeguards. The inspector noted that the shipment of the control rod shearer containing 114 millicuries of Co-60 to Duane Arnold on January 17.1990 was a violation of the requirements of 10 CFR 30.41 and the Duane Arnold facility license. The matter has low safety significance. The implementation of NNECO's corrective actions will be reviewed further during a subsequent routine inspection of NNECO's radwaste program by NRC Region I personnel. The inspector verified that the criteria of 10 CFR 2. Appendix C, Section V.G.1 were met, and no violation will be issued (245/90-25-01,50-336/90-28-01. and 50-423/90-27-03). 5.0 EMERGENCY PREPAREDNESS On December 5,1990, NNECO conducted a partial participation exercise at Millstone 2. The exercise scenario simulated a leak from a steam generator nozz]e dam during refueling operations, that resulted in a loss of water in the spent fuel pool and created the potential for core uncovery. The exercise began with an Alert declaration due to radiation lesels in excess of 1000 times normal for 5 minutes and escalated to a Site Area Emergency due to a fire that affected safety systems. A General Emergency was declared based on a blackout of Millstone 2 with the potential for lasting more than 2 hours. Nine state government agencies, ten towns and two private organizations participated in offsite activities. Since this was a partial participation exercise, the offsite activities were not evaluated by the NRC. NNECO's conduct of the exercise was evaluated by an NRC review team, which included two resident inspectors. The full summary of NRC findings is provided in NRC combined inspection report 50-245/90-84,50-336/90-83 and 50-423/90-84 6.0 SECURITY Selected aspects of site security were verified to be proper during inspection tours, including site access controls, personnel searches, personnel monitoring, placement of physical barriers. compensatory measures, guard staffing, and response to alarms and degraded conditions. The inspector also reviewed a personnel matter that had implications in NNECO's fitness for duty program, as described below. Site security controls were effectively implemented. NNECO management notified the inspector on December 13 of a personnel matter on December 12 that had potential fitness for duty implications. A guard was relieved from V f 4 W

I 17 duty by a guard supervisor occause of behavior that was considered disruptive to shift acuvities. The guard was sent home at 5:00 p.m. The guard supervisor evaluated the incident as a personnel matter due to known personal and family problems being experienced by the guard. The guard supervisor specifically evaluated the guard's behavior and had no reason to believe the guard was unfit for duty. When the incident was reported to NNECO station security supervision, NNECO concluded that the guard's behavior could have been considered as " aberrant", and, as a conservative action, the guard should have been subjected to a for-cause drug test in accordance with the NNECO iltness for duty program. The guard was contacted at home at about 6:00 p.m. on December 12 and initially agreed to come back to the site that evening for a test. When contacted again at about 6:30 p.m. to arrange for transport back to the site, the guard refused to come in and submit to the test. The guard was suspended and protected area access was restricted pending resolution of the matter. NNECO efforts to arrange for a test continued uniil the guard submitted to a test on December 18. The results were negadve. The guard had also tested negative for random drug screenings in October and November,1990. The guard was referred to an employee assistance program. The suspension remained in effect pending completion of the EAP and re-evaluation by the medical review officer for approval to resume duty. The inspector reviewed the issue for reponability and no epons were necessary in acco: dance with the requirements of 10 CFR Pan 26.73. The inspector also reviewed NNECO's action in this matter in regard to "for-catise" testing requirements per 10 CFR 26.24(a)(3). NNECO actions were conservative and appropriate. 7.0 MAINTENANCE / SURVEILLANCE 7.1 OBSERVATION OF MAINTENANCE ACTIVITIES The inspector observed and reviewed selected portions of preventive and corrective maintenance to verify compliance with regulations, use of administrative and maintenance procedures, compliance with codes and standards, proper QA/QC involvement, use of bypass jumpers and safety tags, personnel protection, and equipment alignment and retest. The following activities were included: Millstone 1 M1-90-10636, "l A" LPCI Pump Motor,12/4/90 M1-90-10638, "l A" LPCI Motor Overhaul,12/5/90 M1-90-10991, Test LPCI Motor for Suitability, 12/19/90

APPENDIX 4.0 SAMPLE RECORD OF ALLEGATION PANEL DEC1510NS SITE: bih hN I 1,3 PANEL ATTENDEES: ALLEGATION NO.: k\\ A-A0 7 / Chairman - /3 f.oc,n s d[1/ (Mtg.[I)2345) / Branch Chief - IA <c r g c o DATE: Section Chief (AOC) - kF b 9 PRIORITY: High Mediumhfw-Others - 2dMI SAFETY SIGNIFICANCE: Yes([] Unknern [Mcd,[hl[/rWnb. CONCURRENCE TO CLOSEOUT: DD BC SC / f< O.w n, " h D S 1 CONFIDENTIALITY GRANTED: Yes (See Allegation Receipt Report),fo IS THEIR A DOL FINDING: Yes No 15CHILLINGEFFECTLETTER'hRRANTED: Yes No HAS CHILLING EFFECT LETTER BEEN SENT: Yes No HAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER: Yes No ACTION: 1) bety rnd de a //- co [ h],yl e c )' / ib b c Ca',~ t l(4lf, h / / f 41?te,/_) I 'c ~ ((hlinv*#s // / 2) i]In, c{c car?l. Oi-9f,4-co k [ / 3) 4) 5) NOTES: r A4-1 i 'l

sr & *,...us*s 'L UNITED STATES f,,i, * ' i i, ,-~. NUCLEAR REGULATORY COMMISSION i l '% W [' - f FR. REGNDN1 s 0 f 475 ALLENDALE ROAD 'g ~~s KING OF PRUS$lA. PENNSYLVANIA 19406 !ER 2 ; ny Docket hos. 50-245

2 u.

50-423 Nc";t e a st huc'. ear E*ergy Company AITN: "e. E. J. Mecc:ka Senier Vice Presice- - Nuclear Ergineer'ng anc 0;eratiens F. C. Ecx 273 Hartf erc, :c-nect ca: C6141-3273 Gentleren: luc]ect-

scett,cr Ncs. 50-245/9;-05, 50-336/91-07 and 50-423/91-06 This letter refers to ine routire safeguards inspection concutted by Messrs.

T W. Cexter anc E. E. King of this of fice on March 4-E,1991, at Waterforc, Conrecticut of activities authorizec by NRC License Nos. DFR-21, DPR-65, and NFF-49 anc 10 the discussions of cur findings held by Mr. Dexter with Mr. B. Fac cra, arc citer members of your staff at the contiusion of the ins;ecticn Areas exa-ire: curi*; this inspection are describec in the NRC Regien 1 Inscectice Re: Ort w" cn is eaclesec with this letter. Within these areas, the inscett,cn cersistec cf selettive examinations of procedures and representative rectrcs, intervie.s witt personnel, and observations by the inspectors. Easec c the r esu'is tf this inspection, it appears that three of your activit.es were rot ccrcuttec in full compliance with NRC recuirements, as set forth in ne Notice of Viciation, enciesed herewith as Appendix A. These viciatices nave teen categorizec by severity levels in accordance with the "Sereral Staterer c' Felicy anc Frececure for NRC Enforcement Actiers," 10 CFR Eart 2. A;ce-cir (Erforcerent Policy). You are recuire: to responc to this lette-anc ir preca- ; ycur response, you should f ollow the instructions in Ac; enc;> A. Adciticrally, two areas were identified that reauire attention: the effective-ness cf the annual security aucit, and the manner in which security training material is ceing na ntained. E0th are discussed in the inspection report. l Severai pregram ennancements were also noted by the inspectors, e.g., improved working areas for security support functions, staff additions for surveillance testing and security engineering and implementation of a new internal security communications system and coeputerized badging system. These enhancements are incicat ve of manage ent support for the security program. 1 3 ((. n-v /[/ l / 1 ~ u

4 AFR 2 4199; Nortbeast Nuc. lear 2 Energy Ccm;any Accencix A and certain paragraphs in the enclosed inspection report contain cetails of your security program that have been determined to be exempt from putlic disclosure in accordance with 10 CFR 73.21 (Safeguards Information). Therefore, they will not be placed in the NRC Public Occument Room and will receive limited cistribution. This letter and the remainder of the inspection report will be placed in the Public Document Room in accordance with 10 CFR 2.790(a). Your cooperation with us is appreciated. l Sincerely, l Y Hm James H. oyner, Chief Facilities Radiological Safety g7, and Safeguards Branch Division of Radiation Safety and Safeguards

Enclosures:

1. Appendix A - Notice of Violation (Contains Safeguards Information (SGI) 2. NRC Region I Combined Inspection Report Nos. 50-245/91-05, 50-336/91-07 and 50-423/91-CE (Contains Safeguarcs Information (SGI) in Paragraph No. 5) cc wienti (w/o SG:): W. D. Roccerg, Vice President, Nuclear Operations (w/SGI)

5. E. Scace, Nuclear Station Director H. F. Haynes, Nuclear Unit Director R. M. Kacich, Manager, Generation Facilities Licensing D. D. Norcouist, Manacer of Quality Assurance Gerald Garfield. Escuire A. Aoranam, PAC (30) SALP Reports anc (2) All Inspection Reports Puo'ic Docu ent Roc- (?DR)

Local Public Docu ent Room (LPDR) Naciear Safety Infor ation Center (NSIC) NRC Resicent Insoector (w/SGI) i State of Connecticut l i I h

APR ' }533 e Nortneast Nuclear 3 i Energy Company bcc w/enti (w/o SGI): Regien 1 Docket Room (with concurrences) Management Assistant, DRMA (w/o encl) J. Joyner, DR55 E. Kelly, DRP J. Shediosky, SRI, Haddam Neck r W. Raymord, SRI, Millstone K. Erockman, EDD D. Jaffe, PM, NRR M. Conner, SALP Reports Only R. Arrighi, DRP d d i i 4 i e i .i i i f a J j n i i t i i d l j l ll

-.a,.. , y ,_t' MLC-.<'exrw: A .<.a4 9_'.2v-g r . -+. APPENDIX A NOT:CE 0; VIOLATION Northeast Nuclear Energy Company Docket Nos. 50-245 Millstene t<uclear Powe-Station, Units 1, 2, and 3 50-336 50-423 License Nos. DPR-21 DPR-65 NPF-49 As a resuit of the ins ection conducted on March 4-8, 1991, and in accordance e in tre " General Statement cf Felicy anc Procecure for NRC Enforcement ct cns," 10 CFR Part 2. Appencix C (Enforcement Policy) (1990), tne following viciatiens we-e scentifiec: a cense Cencit,cn E to facility Coerating License Nos. DPR-21, DPR-65 and ~9, cate Cece cer 10, 1984, repuires that the licensee fully implement .anc maintain all ::rovisions of the NRC-approved Physical Security Plan. 1. The NRC - approvec Millstone Nuclear Power Station Physical Security Plan, Revisien 13, datec July 1990, Section 13.5, Security Personnel Ecui; ment, states, in part, that weapons are inspected upon issue caily anc tested every twelve (+/-) 2 months. Centrary to ine aDove, en March 7, 1991, twenty-five handguns and twenty-six snctguns were icentified for which there was no cccurentation to incicate that they were tested within the recuired f tir.e perloc. Tnis is a Severity Level V Violation (Supplement III). ,,,,, F,....,, -..,n.,.... c,,.Ec. k,,:.. u..a .:...c.s., a t~: :m..; m. a !. Z 'J ' :1 L l L NOI I0il P R IC D:5;iG:Z.i. li 15 rnTENil0NALLY-L ek. This is a Severity Level IV Violation (Supplement III) a f_1, ?[....p /Q-Qy~ k ~ s - Lff-

2 Appendix A l + 1 t 3. Appendix G, to 10 CFR 73, " Reportable Safeguard Events,"- Paragraph 1, " Events to be reported within one hour of ciscovery, followed by a written report within 30 days," l su paragraph (d) includes "the actual or attempted introduction of l contraband into a protected area, material access area, vital area, or transport." The Millstone Access Control Procedure, ACP i 7.05, Revision 44, Page 8, Section 6.7.1 states that all personnel are subject to search each time they enter the Prctected Area. Searches are conducted _for items of contraband such as alcohol, controlled drugs (prescribed), illegal drugs In addition, the Millstone Administrative Control etc. Procedure, ACP 7.13, Revision 1, Page 3, Section a.5.1 " Safeguards Events To Be Reported with One (1) Hour," Sudsection 4.5.1.1 states, in part, that certain significant safeguarcs events must be telephonically reported to the NRC within one hour of discovery of the event and a detailed written report (SER) must follow within 30 days. These one hour recortable safeguarcs events include actual or attempted introduction of centraband into a PA or VA. Centrary to the above, on August 10, 1990, the licensee investi-I gated the introduction of contraband (alcohol) into the Protected Area by a security officer on August 2, 1990. The licensee cetermined that tne security of ficer had unintentionally brought-a can of beer into the PA and failed to report it to his su;ervisor when he became aware of it. The licensee did not report the event to the NRC by telephone nor was a written report submitted within 30 days. Adcitionally, the event was j not documented in the security log that is required to be suomitted to the NRC each calendar quarter. Inis is a Severity Level IV Violation (Supplement III). Pursuant to the crovisiens of 10 CFR 2.201, Northeast Nuclear Energy Company is rerecy required to submit to this of fice wi';hin thirty days of the date of. l tre letter wnich transmitted this Notice, a written statement or explanation in reciy, inclucing: (1) the corrective steps which have been taken and the resuits acnievec; (2) corrective steps wnich will be taken to avoid further violations; ar.c (3) the date when full compliance will be achieved. Where good cause is snown, consiceration will be given to extending this response time. l 1 f r f r

. A 7 b r. .v Z . 6 'i...i- (.f.;fhpaui +HQ / p n t.- J U. S. NUCLEAR REGULATORY CCMMISSION REGICN I 50-245/91-05 50-336/91-07 l Report Nos: 50-423/91-06 5;-245 50-336 Docket.Nos: 50-423

:-21 CPR-65 License Nos:

NC -49 L4censee: Nortneast Nuclear Enercy Comcany F. O. Eox 270 Hartforc. Connecticut 06141-0270 Facilitj 'a e: Mi11stene Nucleae Power Station, Units 1, 2, and 3 Ins;ecti:n At: Waterferd, Connecticut Inspectica Concutted: Maren 4-E 1991 l / k Insce:::-s: MM[W / caye T. W. Dexter, Physical ~56turity Inspector ud

d. Ll../

4/n/ +1 E. E. King, Pnyste,rf\\5ecurity Inspector 'cate A::ecved by: [ d4 M MA

  1. //B/9/

h Civision of Ra::)Tation Safety and Safeguarcs R / R. seitig'; C (ief, Saf eguards Section cate Inspectica Surrary: Routine Unannounced Physical Security Inspection on Maren 4-5.19H (Recort Nos. 50-245/91-05, 50-336/91-07, 50-423/91-06). Areas Insce:tec: Onsite Folicw-Up of Previously Identified Items; Management Support, Security Program Plans and Audits; Protected Area _ Physical Barriers, Detection and Assessment Aids; Protected and Vital Area Access Control of Personnel and Packages; Alarm Stations and Communications; Testing, Maintenance, and Compensatory Measures; Records and Reports; Security Training and Qualifications; and Interviews of Security Personnel. ( Results: Three apparent violations were identified: failure to search hand carrie:: items; failure to document weapons testing; and failure to notify the NRC of a reportable event. g,, ;m=.o::m v r~ ', w. .a 3 I f i

1 CETAILS Key :ecs:rre' C:-tactec i Licersee an Centracter Personnel

5. 5: ace, Statice Director, Northeast Utilities i

E. r :::ca. Unit Services Cirector, hertheast Utilities a G. nalice ;, Manager, Nuclear Security, Nortneast Utilities l 0 Weekly. Station Security Manager E. Strom, Station Security I&C Supervisor

5. Glarc, Set;-ity Engineer V. Ot?'nas, Statter Security Suterviser - Administ-ation l

4 0

  • nait, Station Security Supeeviscr - Operations
6. 5: arts. N:et east E.egic-Vanager, Eurns International E. Sajorir, Sec.rity Cniet, Eurns International 15 '.. lear ;e;f at:ey Co missier (NRC)
. Hacipherst. ;esicer Inspector Al' Of the a 04e ircivi Jals were ;"esent at the exit interview.

j The inspectces als: irte vienec Otrer licensee and contractor personnel ed 7 **e ins ecti:n. t 2.: Crs':e :: -.: :# Previously Icertifie: Items 2.; (Close:) V:: 50-245/90-1E-01, 50-336/90-17-01, 50-a23/90-16-01: ine lice-see was ;ermitting emolcyees to broa -ster througn the metal cetectors : avc4d an alarm causea by the presence of metal in tneir steel ti; e: sr es. A: iti:nally, security f rte mem ers were j

latin: :ne3-nancs over tr.eir snields to avoic alarmine. the metal Cete:: rs as t*ey cassed tnrougn when reporting for work. During inis 3rstetti:*. the instect rs cetermined that personnel were J
sssi ;

.-:ugt tne metal cetectors corre:11y This determination l .as case: :

se<ving attess centrol during peak activity perieds,
  • eviea' ; -e ise; access control procecures, testing of=the access
: n t -: '. e:.ic ent, an: ciscussions with licensee management.

2.2 (Ope-) ::: 50-245/E9-22-C1; 50-336/59-21-01; and 50-423/89-22-01: l Ease: cr ::tential wea(nesses icentified during the three previous t ry si ca ' se:urity insrettions with the 'assessmee.t system, the inste:::*s rerformed a review of the system curing daylight-and night i concitions. In addition, the inspectors. reviewed the progress, to r date, en the corrective actions being taken by the licensee to-resolve this matter. The inspectors concluded that progress is being achieved, but that the work is not complete..The inspectors .cetermire: tnat approc-iate cemcensatory measures were still in place

  • ne-e recaire:.

Tnis item will remain open and will be reviewed ~ curirg s.csecuent inspections. ) a t 5 i

l' 3 t' 2.3 (Ocee) IFI 50-2c5/39-22-02; 50-226/89-21-02; and 50-423/89-22-02: Durire an inspection c:ncucted on September 11-15, 1989, the irsre ::rs verifiec that the cesign phase for upgracing previously icertifiec vital area carriers constructed of materials with marginal integrity hac been accomolisned and that installation would commence in 1990. An inspection of the icentified barriers was concutted by t e *,R: em August 29, 1990 and it was determined that, while a majori:3 cf tr.e tarriers hac teen upgraded, some work still remainec. t ar:n 6,1991, curing this inspection, the inspectors discussed On v ine status of the barrier upgraces witn the licensee and determined

  • at all accraces were net yet completed.

This item will remain wiii te revie-ec during subsequent inspections. 1 c:en ar 5 v a;e er: 5.::ce:. Security Propram Plan. and Audits 3.0 a 3.: vana:e er: Su ::r - Management Su; port for the licensee's physical security ;r gram was ceterminec to be adequate by the inspectors. i inis cetermination was based upon the inspectors' reviews of various cregra ennancements completed by the licensee since the last <rs;ect :- Trey incluce: r C:nstru: tion of a new South Access Point (SAP) which includes a at::mm::ations for venicle and visitor processing a cee u-:'s'in: of tre cic Sa? into offices anc work areas for iite-see, contract ano I& security personnel j C: 'ete refor-attinc of tne security training and personnel i fcice-s j ssi: rent c' two cecicated security tecnnicians to j ~

-:.:: se evaluate surveillance testing i

A:: ic cf ar. in-house security encineer i Irs allatice of a Target Vision Video Communications Systen to "r:rt.e internal communications within the Security Department s s

es allation et ten termanent perimeter defensive barriers

+ f:- tat:1:a1 response use i

stallation of a state-of-the-art, computer based badging j

sy stem 3.2 Security Procram Plans - The inspectors verified that changes to the licensee's Security, Contingency, and Guard Training and Qualification Plans, as implemented, did not decrease the effe:tiveress of the respective plans, and had been submitted in at:Or ance with NRC requirements. No discrepancies were noted. 9 t 1 l

r + 4 I l 3.3 Auc'ts - Tre inspectors reviewed the 1990 annual Management Security Aucit, A24019, concutted from October 12, 1990 - January 18, 1991. l ine inscectors verifiec inat the audit had been concacted in accorcance with the NRC - approved Physical Security Plan (the i [ Fian). t Feweve. the inspectors noted that some of the deficiencies icentified curing this inspection were in existence during the aucit perioc. Therefore, the inspectors questioned the depth and thoroughness of the audit, particularly in the training area as ciscussec in paragrapn 8 of this report. The licensee statec that tre matter would be reviewed and corrective actions taken where recessary. c.0 P-etectec Area Physical Barriers, Cetection and Assessment Aids I i 4.1 P-etected Area Barriers - The inspectors conducted a physical inspect;on of ne Protected Area (PA) barriers on Marcn 4, 1991. f Ine inscectors determined, by observation, that the barriers were l

nstallec anc maintained as described in the Plan.

4.2 Isolation Zones - The inspectors verified that isolation zones were aceouately maintained to permit observation of activities on both sices of the PA barrier. f 4.3 ;-etectec Area and Isolation Zene Lichtina - The inspectors conc;ctec a lignting survey of tne PA anc isolation zones on [ Maren 5, 1991. The inspectors determined, by observatien..that the station's lignting system was very effective. No discrepancies were [ r.c t e" 4.c Assessrer: Aics - The inspectors observed tne FA perimeter assessment a;cs anc determined that they were installed, maintained, arc oceratec as committed to in the Plan and that appropriate f cercensatory reasures were in plate, As indicated in Section 2.2., j

f ini s recort, it is evicent that the licensee is taking stecs to correct tne potential weaknesses associated with the assessrent system.

1 { inis ite will be reviewed during subsequent inspections.. i I 5.0 Prctectec anc Vital Area Access Control of Personnel, Packaces r anc Ven1cies t 5.1 Personnel Access Control The inspectors determined that the licensee was exercising positive controls over personnel access to the PA and vital areas (VAs). This cetermination was cased on the following: [ r i 6 6

l-5 5.1.1 The ins:ectors verified, by ocservation, that personnel are precerly icentified, anc authorization is checked prior to iss;ance cf tacges and key-carcs. No discrepancies were noted. 5.1.1 The inspectors verified that the licensee has a program to confirm the trustworthiness and reliability of employees and contractor personnel. No discrepancies were noted. 5.1.3 ine inspectors verified that the licensee takes precautions to ensure that an unauthori:ed name cannot be added to the access list by having a member of management review the list every 31 cays. No ciscrepancies were noted. t 5.1.4 The it.soectors verified that the licensee has a search program, as committed to in the Elan, for firearms, explosives, ircenciary cevices anc other unauthoel:ed material. The

nsoectors coserved plant personnel and visitor access processing several times during the inspection and interviewed mem:ers of the security force and the licensee's security staf f regarcing personnel access procedures.

One deficiency was icentifiec. r THIS P!AI.0F1.M 000AIKs SArttUA905 E::. J::::: c] 13 gg; reg pm;g GiO5!!,i, li IS IkTERIl0XALLY LEFTBLASE. I i I l l 1 l 3

i. 1 6 I t The inspectors determined that the licensee's failure to comply with the package search provisions in the NRC-approved Plan is an at arent violation of ARC requirements (VIO 50-245/91-05-01, 50-335/91-07-01, 50-423/91-06-01). 6.0 Alar-Station and Communications The inspectors observed the operation of the Central Alarm Station (CAS) anc Sectncary Alarm Station (SAS) and determined that they were maintained and c:eratec as committed to in the Plan. CAS and SAS operators were i te vie-ec cy the inspectors and found to be knowledgeable of their i

c. ties anc responsibilities. The inspectors verified that the CAS and SAS c,c not contain any operational activities that would interfere with the assess en ard response functions. No discrepancies were noted.

P Tne inscetters also discussed the testing protecures for all of f-site commun,cattors capabilities in the CAS with the cperators and determined l that tre operators were knowledgeable of their use and testing ree-,re ents. No discrepancies were noted. l 7.0 Testing, Mainte-ance and Com;ensatory Measures 4 The security organization is assigned dedicated instrumentation and cont-cis (I&C) technicians who maintain and test the security equipment ar.c systems. The inspectors toured the I&C work area and found that it ( .as well maintained and stocked. Based on tests of the security eouipment curir; inis ins ection, it was apparent that the technicians expended consideraDie time and effort to maintain the ecuipment in an acceptable marner anc that iney were very f amiliar with the equipment. l Corrensatory easures previously and presently being implemented were revie ec anc f cuna to be consistent with commitments in the Plan. No ceficiencies were noted. E.0 Decords anc 4e: orts Durirt this inspection, the inspectors discussed with the licensee an l l event involving the introduction of contraband (alcohol) into the PA by a i ~ security of ficer (50). It appears that on August 2, 1990, a can of beer was mistateniy placed in an 50's lunch box by the 50's-spouse instead of a i can of soda.. The lunchbox was allegedly searched using X-ray equipment, f but the can of beer was not cetected. When the 50 took his lurch break, te discoverec the can of beer and, instead of reporting the incident, he j discarced the can by throwing it outside of the protected area fence. l l On August 10,1990, the 50 was discussing the incident with another person and the discussion was overheard by another 50. The incident was reported to shift management who, in turn, reported the incident to licensee management. Licensee management's investigation of the incident resulted I in disciplinary action against the 50. However, the licensee failed to i i

k P 7 l t 5 report tre evert to tre NRC in accercance with the 10 CFR 73.71 and A;;e-cix G. T~e licensee statec that the failure to report er log the tericert was tes: Re ula: cry Guice 5.62 c:es not accress this easter as a prer;; repoe:a:le event. The inspectors stated that, while the Regulatory [ Gaice coes not specifically address the introduction of alcohol into the i PA, it coes accress centraband arc the licensee considers alcohol to be c:ntearand. The irstectors further advised the licensee that the regula::rj sigr.ificance of this event is that the FA access searcn system l failec, in :nis case, an: an 50 failed to discharge his security l rescensitility te report the incicent to management. t A::e cii 3. f :: :::. 73, " Reportable Safeguarc Events," Faragraph I, l Sut:aragra:- (c) states that the actual er attempted intre uction ef

nt-atan: '-:: a pectecte: area, is an event to be reported to the NRC aitnin cce :ur cf cistevery fc11c.ec by a written report witnin 3D cays.

e Mi'is:: e Access Centrol Prece ure, ACF 7.05, Revision 44, Page 8, y Section 7.7.1 states that all personnel are subject to search eacn time ney ente-ine Frotectec Area for items of contraband such as alcohol, c:nt-cile u;s (prescricec), illegal drugs etc. In adcition, the v'llstere A:-iristrative Control P-ecedure, ACP 7.13, Revision 1 Page 3, Sectict A.5.; "Safeguarcs Events To Se Reported witnin one (1) hour,"

5. section 4.5.1.1 states, in part, inat certain significant safeguards i

events mus te telepnenically re:erted to the NRC within one hour of cis::very o' t e event anc a cetaile: written report (SER) must follow "t-in 3: cays. nese ene nour re:cetable safeguarcs events incluce actual ce atte ::e: intreev: tion of contraband into a FA or VA. ~ne insce:::-s ceteemine that the licensee's failure to comply with tne .I ee rting -e:Lirement of 10 C R 73, Appencix G., " Reportable Safeguarcs Events" an Mills cne crececures is an apparent violation of NRC l re:uirements. ( VIC 5:-2:5/91-35-02, 50-335/91-07-02, 50-423/91-05-02) l .C 5ecurity T-a'ri-ar Ouali'ication Procram T e insrect: s ra ::rly sele :e anc reviewec tne training and r

ualifica ::- <e::r:s f:r twelve security cf ficers (50s).

Physical

alificatiens ar
'irearms cualification recorcs were inspectec. These

-e:cres -ere 'er arre: guards, wat:tren and supervisory persennel. The inspecters ceterrired that tne required training had teen conducted in i art:rcance -;;r tre security program plans and that it was properly

curente:.

J The insrectors also -eviewe: the training lessen plans, descriptions of i i cructai tasks, anc cro:e=ures The inspectors found handwritten change notes in the margins of the instructors' lesson plan book and in the i department's master lesson plan book which were different and, in some j cases, entere: in ene out not the etter. Consecuently, the accuracy and consistency of tre material presentec to the 50s during training is j cuesticnacle. In addition, lessen plan books contained different i 1 i I i

"t. i 8 F revisions of tre sa e lesson plans and, in at least one case, an i . a;;r:ve revisi:n. For example, the master lesson plan book contained I Revision 2 c# a certain lesson plan wnile the instructors' lesson plan Occk centainec an unapproved, Revision 3 of that lesson plan. 4::itio-ally, while reviewing the descriptions of crucial tasks, the inspect:rs fcund that they were not being updated to reflect the changes i mace in tre lesson plans. Conseavently, the 50s could be qualifiec using

cate
cr.c ai tasks.

The inspectors reviewed the outdated crucial tasks arc ccr 'uced that the material would not have resulted in or.

  • teitate :: a viciation of NRC recuirements. The inspectors also founc i

t*at : ere was ne mettarism in place to track revisions made in the lesson i I

iars or crucial tasu,.

lr a Citict, tre inspectors 7 terviewed several 50s and training irst e:t rs. Ease: en inese interviews the inspectors determined that

ertain activit es 10 be concutte: by the 50s were provideo orally by l

s ervisers an: were not incorporatec in training procecures, lesson

lans, crucial tasks, or post orcers.

Even incugh the 50s were knowledge-aole o' treir :. ties anc responsibilities, the inspectors stated that all 4 cuties to be performec ey the 50s should be cocumentec in orcer to ensure i

nat tney are performed in a consistent manner.

t T-e ;' ensee c:r"4 tied to review these ratters and take corrective actions as recessary t sring a review cf firearm reccrds on the morning of March 7, 1991, at a:;reximately 9::: a.m., the inspectors found 25 handguns and 26 l steiguns ttat na tc c cumentation to indicate that they hac Oeen test-fire: witnin tre time frame committed to in tne Plan. rum:er :f t e 25 nar guns had been assignec to individual security l Officers anc tad cualified with them within the 12-month period that they l 5 :uid nave tee-tested, But the testing recorcs for those handguns were -:t sen: tate: : ircicate when they were used to qualify the security l cfficers, wni:r *cuic nave satisfied the testing requirement. Since a larce r. :e- :# etrer weacons hat documentatien to indicate that they had i teeE pre;eriy testet, the pr: Diem appeared to the inspectors to be record j i 6eepirg rathe* inan the aDsence of testing. j Tre ?,RC-ar:reve: Millstone Nuclear Power Station Physical Security Plan, l Revision 13, cate: July 1990, Secticn 13.5, Security Personnel Equipment, t states, in part, that weapons are inspected upon issue daily and tested every twelve (*/-) 2 months. t The inspectors determined that the licensee's failure to maintain cocumentary evicerte cf weapons testing is an apparent violation of the l a r.. (VIC 50-245/91-05-03., 50-336/91-07-03, 50-423/91-06-03). f t h a ? 5 t I i f

I' 9 f 10.0 Interviews of Security Personnel During the inspection, the inspectors interviewed 18 50s from all three shif ts to ceternine if there were any safety or security issues that the NRC should be aware of, or if any serious morale problems existed. The f discussions with security personnel included: their knowlecge of the Nucleae Safety Concern Program; treatment by or concerns about the l licensee anc contractor supervisors; their freedom to discuss issues with j the resident NRC inspectors; observations of adverse traits among security officers; and morale, in general. The interviews indicated that: they were very knowiecgeable of the Nuclear Safety Concern Program; they had no centerns with supervision; they did not feel their jobs would be i jeoparcizec if they discussed issues with the NRC inspectors; there were ne acverse behavioral cbservation issues on any security shift; and [ morale, in general, was good. Several minor concerns were discussed with the inspector. They incluced a desire for additional training, better communications with the contractor, and increases in wages and benefits, None were issues that could, or did, affect plant safety or security. An overview of the interview results were provided by the inspectors to the licensee's security management for feedback to the security contractor. 11.0 Exit Interview e The inspectors met with the licensee representatives identified in i Faragraph I at the conclusion of the inspection on March 8,1991. At that time, the purpose and scope of the inspection were reviewed, the fincings presente and commitments made by the licensee's representatives during the inspection were confirmed. i r i i i i

5 RECORD OF ALLEGATION PANEL DECISIONS SITE: /d/ 5 th 4 PANEL ATTENDEES: ALLEGATION NO.: dI-4 I-A- oo7I Chairman - "J.T t>Aa4 m r DATE: g A AY9 d (Mtg. 1 6 3 4 5) Branch Chief - f.C. Lu mq y e u PRIORITY: High low Section Chief (AOC) - SAFETY SIGNIFICANCE: Yes No Unknown others - C tu. GMi -e 7C S-lcuek-CONCURRENCE TO CLOSEOUT: DD h SC G.C. Li-d 2 l. A h b D 3. Nofo 2 C. iba CONFIDENTIALITY GRANTED: Yes No (See Allegatien Receipt Report) pf IS THEIR A 00L FINDING: Yes No IS CHILLING EFFECT LETTER WARRANTED: Yes No HAS CHILLING EFFECT LETTER EEEN SENT: Yes No HAS LICENSEE RESPONDED TO CHILLING EFFECT LETTER: Yes No ACTION: 1) e er O 07h 9 A3 J 35 eep On e. a e. 4 2) LeMee b a /f e a -e c n o dc Ma. n,a o 9 re h# cal -$o CI(r u o 3) i S) NOTES: i t / -}}

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