ML20138J569
| ML20138J569 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/31/1997 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20138J566 | List: |
| References | |
| 50-302-96-18, NUDOCS 9702070359 | |
| Download: ML20138J569 (23) | |
See also: IR 05000302/1996018
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U. S. NUCLEAR REGULATORY COMMISSION
REGION 11
Docket No:
50-302
License No:
Report No:
50-302/96-18
Licensee:
Florida Pcuer Corporation
Facility:
Crystal River Nuclear Station Unit 3
Location:
15760 West Power Line Street
Crystal River, FL 34428-6708
Dates:
December 2-6 and December 16-19,1996
Inspector-
L. Stratton, Safeguards Inspector
D. Thompson, Safeguards Inspector
W. Stansberry, Safeguards inspector
Approved by:
Paul E. Fredrickson, Chief
Special Inspection Branch
Division of Reactor Projects
97020/0359 970131
ADOCK 05000302
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EXECUTIVE SUMMARY
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Crystal River Unit 3
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NRC Inspection Report 50-302/96-18
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This special, announced inspection was conducted in the area of plant support by three
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regional safeguards specialists. The specific area evaluated was the Physical Security
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Program for Power Reactors.
The licensee was operating from a temporary Central Alarm Station and Secondary
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Alarm Station; therefore, an adequate evaluation of the alarm stations could not be
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conducted. However, as part of the limited review of operations the inspector
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determined that there was an apparent violation of regulatory requirements for failure
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to have a procedure for the (in use) temporary Central and Secondary Alarm Station
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operational requirements (eel 50-302/96-18-01). Also, an apparent violation was
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identified in that the licensee failed to respond to a protected area alarm, thereby
causing the Perimeter Intrusion Detection System to be vulnerable for approximately
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two hours and 22 minutes (eel 50-302/96-18-02). Licensee Event Report 96-S03-00
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is closed. Additionally, an apparent violation of regulatory requirements was identified
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for the licensee's failure to employ adequate equipment to immediately assess more
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that one protected area alarm (eel 50-302/96-18-03). (Paragraph S2.2)
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The licensee maintained radio and telephone communications in accordance with the
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required Physical Security Plan and implementing procedures. (Paragraph S2.2.1)
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One apparent violation of regulatory requirements was identified in the area of
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protected area barriers (eel 50-302/96-18-04). Licensee Event Report 96-S02-00 is
closed. (Paragraph S2.6)
The licensee had a proactive lighting surveillance program in place which should
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prevent areas within the protected from being illuminated less than 0.2 footcandle,
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which is the required minimum level specified in the Physical Security Plan. Violation
96-02-02 is closed. (Paragraph S2.7).
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One apparent violation of regulatory requirements was identified in that openings in
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the ceiling of the armory caused security weapons to be accessible to the plant
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personnel (eel 50-302/96-18-05). (Paragraph S2.8).
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Significant work was required on the upgrade project and attention to requirements of
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10 CFR 73.55, and the approved PSP commitments had been lacking during the
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upgrade project development and implementation.
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One Unresolved item was identified in that a Physical Security Plan licensing submittal
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decreased the effectiveness of the security plan (URI 50-301/96-18-06).
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(Paragraph S3.1)
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There were three examples involving the failure to submit and maintain plan changes
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(eel 50-302/96-18-07) (Paragraph S3.1).
A review of applicable procedures revealed two examples of inadequate procedures
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which resulted in an additional example of apparent violation eel 50-302/96-18-01.
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(Paragraph S3.2).
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A review of randomly selected records and reports revealed that the documents were
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complete, available for review, and contained sufficient information to support and
ensure functionality. (Paragraph S4.1).
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The licensee's corrective action with respect f a controlling Safeguards Information was
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continuing and the control of Safeguard Info.mation had improved. Violation 96-07-01
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remains open. (Paragraph S4.3).
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The provisions set forth in the licensee's Training and Qualification Plan were being
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met. (Paragraph SS.1).
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Many of the problems documented in this inspection report, especially those with the
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security upgrade project, are demonstrative of significant weaknesses in management
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oversight. The inspector concluded that the licensee's new security management
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team was beginning to establish a security organization capable of supporting
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licensing requirements.
The security organization was established to meet the regulatory requirements. The
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licensee demonstrated during an observed drill they were capable of interposing
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themselves between vital areas and the established design basis threat.
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(Paragraph S6.3).
The licensee was conducting security audits in accordance with the regulatory
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requirements spcified in the Physical Security Plan. Although the auditors were
qualified to conduct security audits, numerous deficiencies with Physical Security Plan
change submittals were not documented during the 1995 audit. The auditors did note
during the 1996 audit that the security plan and procedures needed to be updated.
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An Inspector Followup item was opened to determine the adequacy of the licensee's
corrective actions (50-302/96-18-09). (Paragraph S7.1).
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REPORT DETAILS
S2
Status of Security Facilities and Eaulpment
S2.2 Alarm Stations
a.
Inspection Scope (81084)
The inspector ascertained that the licensee had established and maintained a central
alarm station (CAS) and a secondary alarm station (SAS) that was in conformance
with the Physical Security Plan (PSP) and rege'atory requirements, and that such
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stations were adequate and appropriate for their intended functions.
b.
Observations and Findinas
The inspector reviewed the alarm stations which were presently being upgraded and
were operating temporally outside regulatory requirements, although the
compensation for them was adequate. The current CAS was a temporary function
located in the Control Room. The CAS was manned by a single individual with the
capability to receive only visually the protected and vital area intrusion alarms.
Additionally, the CAS did not have video monitors to receive video alarms; therefore,
the CAS was unable to assess alarms. The CAS operator was responsible for
ensuring that the SAS took proper actions in respr.ase to all alarms. To compensate
for the CAS deficiencies, the licensee had established the SAS as the primary
response facility (located at the access control facility) to receive, acknowledk
assess, dispatch officers and clear all protected and vital area alarms. Two pemons
were always present within the SAS.
While reviewing the current CAS operations, the inspector identified that the CAS/SAS
analysts were operating under Security Procedure 205," Alarm Station Operations,"
Revision 13, dated January 14,1994, which detailed the CAS/SAS operations using
the old equipment which had been removed as part of the upgrade initiative. Part 1 of
the licensee's PSP " Introduction," states that written procedures are implemented and
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maintained to the detailed requirements necessary to implement the Secunty Plan for
plant operations. In addition, Par + l of the PSP also states "This Plan states FPC's
policy and commitmev. to meet the requirements of 10 CFR 73.55." This failure is
identified as the first example of apparent violation EEi 50-302/96-18-01.
Security Information Report (SIR) 10551, dated September 27,1997, "JC 6000 Al arm
Response," an addendum to Site Security Procedure 205," Alarm Station Operations,"
Revision 13, dated January 14,1994, was in place at the time of this inspection.
SIR 10551 was generated to convey specific guidance on alarm response. This
procedure stated that the general rule for all alarm station operators was to respond
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to all alarms. On November 20,1996, maintenance activities in the SAS resulted in a
deactivation of an intelligent multiplexer (IMUX), which controlled the perimeter
intrusion detection system (PIDS). Although an alarm was received in both the CAS
and SAS as MUX-4 Trouble Unavailable," the alarm station analysts misinterpreted
the information and acknowledged and cleared the alarm without initiating a response.
At the time of this alarm, another IMUX (2) was being serviced in the SAS. Through
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interviews, the inspector leamed that the CAS/SAS analysts made an assumption that
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IMUX 2 was the one that had caused the alarm. IMUX 2 was not online with the new
security computer system at the time of this event. Approximately two hours and
22 minutes later, the alarm stations failed to obtain an alarm on the PIDS during
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routine traffic departing the protected area. A Security Emergency was declared and
- appropriate compensatory measures were established. Approximately 15 minutes
later, after investigation by the licensee, the IMUX failure was corrected, and the PIDS
was retumed to operation.
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Section 6.1.1.1. of the licensee's PSP requires that in the event of a partial alarm
system failure the following compensatory measures will be taken:
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provide continuous surveillance utilizing a dedicated observer monitoring the
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closed circuit television monitor and increase Protected Area patrols through
use of an additional officer, or station a member of the security force at the
inoperable alarm location.
The inspector concluded that as a result of the alarm stations analysts' failure to
respond to the protected area alarm, the PIDS was not compensated for
approximately two hours and 22 minutes. This failure is identified as an apparent
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violation of regulatory requirements (eel 50-302/96-18-02).
The inspector reviewed documentation of a Root Cause Analysis (RCA) performed by
the licensee. Although the RCA determined that inadequate training and a lack of
knowledge of IMUX placement was the primary cause of the event, the inspector
determined that although the CAS/SAS procedure was inadequate, SIR 10555 clearly
delineated response expectations. Upgrade information is now clearly discussed each
shift to facilitate the accommodation with maintenance activities. LER 96-2003-00 is
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closed.
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The inspector also identified that the assessment equipmer t that had been installed
as part of the security upgrade did not have the capability to view more than one
perimeter alarm without manual call-up. Therefore, the licensee was not capable of
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immediately assessing more than one perimeter alarm at any given time. Section 6.4.
of the licensee's PSP states, in part, that monitors located in the CAS/SAS will
automatically switch to the appropriate camera during a perimeter alarm to
immediately display the area in alarm. In response, the licensee corrected this
deficiency when a software change was implemented on December 12,1996. The
inspector verified the 1icensee's corrective actions by observing the testing of three
zones during the same time period. All zones alarmed appropriately and called-up
automatically within one second as required.
The inspector determined that for approximately one month, the licensee had failed to
have a system that would automatically switch to the appropriate camera to display
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the areas in alarm when two or more perimeter alarms were generated. This failure is
identified as an apparent violation of regulatory requirements (eel 50-302/96-18-03).
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c.
Conclusion
The licensee is operating from a temporary CAS/SAS; therefore, an adequate
evaluation of the alarm stations could not be conducted. However, as part of the
limited review of operations, the inspector determined that there was an apparent
violation of regulatory requirements for failure to have a procedure for the temporary
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CAS/SAS operational requirements. Also, an apparent violation was identified in that
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the licensee failed to respond to a protected area alarm, thereby causing the PIDS to
be vulnerable for approximately two hours and 22 minutes. Additionally, an apparent
violation of regulatory requirements was identified for the licensee's failure to employ
adequate equipment to immediately assess more that one protected area alarm.
S.2.1 Communications
a.
Inspection Scope (81088)
The inspector evaluated whether the licensee had established and maintained the
required internal and extemal communication links in conformance with the approved
PSP.
b.
Observations and Findinos
The inspector verified that the CAS and SAS could establish communications with
local law enforcement via hardwired or radio communications. The licensee
demonstrated on December 3,1996, the capability to contact local law enforcement
via telephone and radio.
The inspector also verified that each officer could maintain continuous communication
with the individuals in the CAS and SAS.
c.
Conclusion
The licensee maintained radio and telephone communications in accordance with the
required PSP and procedures.
S2.6 Protected Area Barriers
a.
Inspection Scope (81052)
On November 1,1996, the licensee discovered a penetration path into the protected
area via a breach in the Circulating Water System (CWS). The inspector reviewed the
circumstances surrounding that event.
b.
Observations and Findinos
LER 96-S02-00 was submitted to the NRC to report the discovered breach in the
CWS. A security officer on a routine patrol discovered the breach and immediately
posted himself as a compensatory measure. Upon further investigation, the licensee
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determined that the protected area breech could have existed for approximately
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12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> and 35 minutes.
Maintenance activity on the system began at 8:35 a.m. on November 1. However,
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prior to starting work, Security was not notified. Through interview of licensee
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representatives, the inspector leamed that root cause analysis performed by the
licensee determined that although procedures were adequate to include security in the
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pre-planning of maintenance activity on the CWS, the work package failed to include
the procedural requirement. In addition, the label on the portal cover informing
employees to notify security was obscured when the portal cover was opened, prior to
removing the screens. Section 3.1 of the licensee's PSP, Revision 6-11, states that
the Protected Area is located within the Owner-Controlled Area and is enclosed by
physical barriers. The discovered protected area breach via the CWS is identified as
an apparent violation of regulatory requirements (eel 50-302/96-18-04).
Corrective actions initiated by the licensee included placing labels on the waterboxes
in obvious locations, using plastic ty-wraps to control the opening of the waterbox
equipment, and revising the work order form to include a security notification
provision.
c.
Conclusion
Through review of documentation and interview of licensee representatives, the
inspector determined one apparent violation of regulatory requirements had been
identified by the licensee. LER 96-S02-00 is closed.
S2.7
Liahtina
a.
Inspection Scope (81062)
The inspector reviewed lighting documentation to determine if the licensee was
meeting lighting requirements outlined in the PSP.
b.
Observations and Findinas
Prior inspections revealed lighting deficiencies within the protected area. However,
the licensee had corrected a number of those deficiencies identified. An aggressive
lighting surveillance program was in place at the time of this inspection to prevent
further lighting inadequacies from developing. Several work orders to install or repair
lights were still pending. Light meter surveys were being conducted on a periodic
basis. The licensee marked areas within the protected area to take surveys, so that
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results may be tracked more efficiently. The licensee informed the inspector they
planned to train all security officers on the use of the light meters. Corrective actions
initiated by the licensee were ongoing.
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c.
Conclusion
The licensee had a proactive lighting surveillance program in place, which should
further prevent areas within the protected from being illuminated less than
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0.2 footcandle,'which is the minimum level specified in the PSP. Violation 96-02-01 is
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closed.
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S2.8 Security Eauipment Storaae
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a.
Inspection Scope
The inspector toured the armed repository to determine if security equipment was -
controlled in accordance with the provisions specified in the PSP.
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b.
Observations and Findinas
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On December 18,1996, while touring the plant, the inspector noted that the armed
repository, located in the TSC, was easily accessible. At the time of the inspection,
duct work replacement in the TSC was in progress, which revealed large openings in
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the ceiling of the armory. The armory door was locked with a security controlled lock.
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Upon further review, the inspector determined that the licensee storect security
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weapons, ammunition, and associated security equipment in open containers in the
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armory. Section 2.4.5. of the licensee's PSP states, in part, that security equipment is
stored in a locked repository within the Protected Area. Upon further evaluation, the
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inspector reviewed the SGI podion of Audit 93-06-ISEC. The physical layout,
architectural and structural details of the armory were identified as a concem. The
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audit report also stated, "The Nuclear Security Superintendent informed the Audit
Team Leader (ATL) that this issue had been considered prior to establishing the
armory at its current location and was determined to be an acceptable risk." The
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armory had been in its present configuration since 1989. This failure is identified as
an apparent violation of regulatory requirements (eel 50-302/96-18-05).
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In response to this finding, the licensee immediately posted an armed officer.
Subsequently, weapons, clips, and ammunition have been secured in a locked
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container and bolted to the armory floor. Additionally, locks on the armory door have
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been changed. A security key is now needed to either open or close the door to the
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armory.
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Conclusion
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Through observation, document review, and interview of licensee representatives, the
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inspector confirmed that the armory was locked; however, the openings in the ceiling
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caused security weapons to be accessible to the plant personnel, which is identified
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as an apparent violation of regulatory requirements.
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S2.9 Security Uoarade Project
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a.
Inspection Scope
ihe inspector reviewed the licensee's security upgrade program to ascertain if the
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upgrade met the PSP and regulatory requirements.
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b.
Observations and Findinas
The inspector determined that on December 23,1988, the licensee had submitted a
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letter to the NRC which described planned improvements in the security equipment,
management and operation of the security program, and planned replacement of the
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vital area access computer. By letter dated November 10,1989, the licensee had
informed the NRC that additional security improvements were planned. These
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improvements included:
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an upgraded access control system to include both personnel and vehicle
entry;
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an upgrade to the protected area barriers, and the addition of an inner
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nuisance fence;
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a reconfiguration of the closed circuit television (CCTV) cameras to provide
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total assessment and eliminate sun glare;
a replacement of the two remaining E-Fields; and
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after completion of the CCTV upgrade, an addition of lighting to provide a
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more uniform illumination.
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The licensee planned to complete the upgrade in 1992.
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On January 20,1992, the licensee met with the NRC and revised their security
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upgrade completion date to reflect completion to be at the end of 1993,
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On September 11,1992, the licensee informed the NRC by letter that a major portion
of the security upgrade project was being put on hold. The NRC responded to the
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licensee's letter on October 5,1992, and approved the deferral. On April 20,1993,
the licensee met with the NRC Office of Nuclear Reactor Regulation to discuss the
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new proposed security upgrades. The NRC responded to the proposal by letter dated
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May 18,1993, which informed the licensee that any SAS related changes would
require submittal under the provisions of 10 CFR 50.90 or an exemption request if the
licensee decided to pursue them. (See Paragraph S3.1 for further information on this
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issue.
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During review of the current security upgrade, the inspector identified that the
assessment capabilities did not meet regulatory requirements. (See Paragraph S2.2
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for further information on this issue.) Additionally, the protected area barrier at the
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new access portal, which was not yet is use, was not alarmed nor had assessment
capabilities been provided. Additionally, the position of where the final lock down
officer would be located in the new access portal appeared inadequate in that he/she
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would be unable to determine if a person was being forced to allow access while
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under duress. The inspector also noted that the licensee did not plan to install the
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capability for the CAS or SAS to alert someone in the event that they are placed
under duress. At the time of this inspection, the licensee was addressing these
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issues.'
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c.
Conclusion
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The inspector concluded that significant work was required on the upgrade project and
that attention to requirements of 10 CFR 73.55 and the approved PSP commitments
had been lacking during the upgrade project development and implementation.
S3
Security and Safeguards Procedures and Documentation
S3.1
Security Proaram Plans
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a.
Inspection Scope (81401)
This evaluation was to verify that those changes made in the licensee's PSP, Security
Contingency Plan (SCP), and security Training and Qualification Plan (T&QP) without
prior NRC approval under 10 CFR 50.54(p)(1) did not decrease the effectiveness of
the respective plans. Also, this review was to assure that changes have been
reported in accordance with the requirements of 10 CFR 50.54(p)(2). The
effectiveness of submittals for 10 CFR 50.90 changes which applied for an
amendment to the license were also reviewed.
b.
Observations and Findinos
This inspection effort included an onsite evaluation of the following changes made to
the security plans:
PSP Revision 6-1, dated November 16,1992, through Revision 6-13, dated
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June 20,1996.
SCP Revision 4, dated October 26,1989.
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T&QP Revision 6, dated July 29,1991, through Revision 7.1, dated March 1,
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1996.
These plans were reviewed for adequacy and consistency with the provisions outlined
in 10 CFR 50.54(p)(1), which states that a licensee shall make no change which
would decrease the effectiveness of the security plan or guard training and
qualification plan without prior NRC approval. The inspector evaluated the license for
any related conditions of the license and approved changes. Revisions reviewed
reflected the licensee's determination that the changes did not decrease the
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safeguards effectiveness of the plan. A problem involving a licensee plan change was
identified in PSP Revision 6-13. Revision 6-13, Appendix D, page 4 provided for
reducing the plan commitment of compensatory measures for unsecured vital area
doors by using a roving vital patrol instead of posting a security officer.
As a result of the review of Revision 6-13, the inspector noted that on August 12,
1996, the licensee initiated the following pre-planned compensatory posts for five
degraded vital area doors in the Control Complex Area during a transition phase of
the ongoing security upgrade:
One armed officer posted at door C-301 and one armed officer posted at
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C-508. A roving vital area patrol to compensate for degraded vital area doors
C-701, C-405, and C-101.
Section 10.2.1 of the licensee's Physical Security Plan states that security personnel
will be posted to compensate for reductions in the effectiveness of barriers, detection,
or surveillance. However, the licensee failed to establish adequate compensatory
measures by utilizing roving patrols rather than posted armed officers. The five vital
area doors were located on three different levels; therefore, the roving patrol was not
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constantly in visual view of the degraded doors.
This provision of Revision 6-13 decreased the effectiveness of the security plan
without prior approval from the Commission. A licensee proposing to make such a
change must submit an application for an amendment to the license pursuant to
10 CFR 50.90. This item is identified as an Unresolved item (URI 50-302/96-18-06)
pending further NRC review for the regulatory process of this issue.
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The regulation,10 CFR 50.54 (p)(2) require licensees to submit a report containing a
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description of each change within two months after the change is made. It also
requires the licensee to maintain records of changes to the plans made without prior
Commission approval for a period of three years from the date of the change. The
following circumstances were revealed during this evaluation:
The licensee failed to submit a report of changes of Revision 6-10 of the PSP
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within two months after the changes were made. Revision 6-10 of the PSP
had an effective date of February 16,1996; however, the date of the report
submitting the changes to the NRC was May 17,1996. This exceeded the
required two month timeframe specified in 10 CFR 50.54(p)(2).
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As of the inspection, the licensee had failed to submit a report of a PSP
change that deleted the commitment of E-Field perimeter intrusion detection
equipment made in Revision 6-2, page 48 and 49 of the PSP. Revision 6-2 of
the PSP had an effective date of September 17,1993; however, E-field was
removed in July 1995. As of December 19,1996, the licensee had not
submitted a plan change. This has exceeded the required two month
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timeframe specified in 10 CFR 50.54(p)(2).
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The licensee failed to maintain a record of changes to the T&QP, Revision 7.1,
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dated March 1,1996.
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. As a result of these failures, the inspector identified an apparent violation of regulatory
requirements (eel 50-302/96-18-07).
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Upon further review, the inspector noted that the licensee did not have a formal
process in place to determine if changes made to the PSP, SCP, or T&QP would
decrease the effectiveness of those plans. Administrative Instruction (Al) 800,
" Conduct of Plant Security," Revision 28, dated June 18,1996, required, in
Section 4.3.2. to ensure that all changes or revisions to the PSP, SCP, or T&QP are
, submitted in accordance ~with 10 CFR 50.54(p) and reviewed in accordance with
Nuclear Operations Directive (NOD) 11, " Maintenance of the Current Licensing Basis,"
Revision 6, dated March 21,1996. NOD 11 documented a licensing review process;
however, the process was based on circumstances surrounding a 10 CFR 50.59
review process. The licensee intends to develop a 10 CFR 50.54(p) and
10 CFR 50.90 review process and is tracking progression with Problem Report
(PR)96-0356. The licensee informed the inspector they will adhere to the provisions
outlined in Gt:neric Letter 95-08, "10 CFR 50.54(p) Process for Changes to Security
Plans Without Prior NRC Approval," dated October 31,1995.
c.
Conclusion
The inspector concluded that the plan changes identified above did decrease the
effectiveness of the security plans. This is identified as an Unresolved item. An
apparent violation of regulatory requirements was identified as described above.
S3.2 Procedures
a.
Inspection Scope (81401)
Part 1 of the licensee's PSP, " Introduction," states that written procedures are
implemented and maintained to the detailed requirements necessary to implement the
Security Plan for plant operations. In addition, Part I of the PSP also states "This
Plan states FPC's policy and commitment to meet the requirements of
10 CFR 73.55." The inspector evaluated licensee procedures to verify adherence to
the PSP.
b.
Observations and Findinas
- The inspector reviewed the licensee's applicable procedures to verify they were
implemented and maintained to the detailed requirements necessary to implement the
Security Plan for plant operations. Also, the inspector verified that the procedures met
the requirements of 10 CFR 73.55. Problems with two procedures were noted:
a
_ . _ _ .
. . _ _ _ . . .
_ _ _ _ _
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Site Security (SS) Procedure SS-205, " Alarm Station Operators," Revision 13,
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dated January 14,1994, was inadequate in that it failed to reflect current
j
equipment and operational instructions for the newly installed security
'
computer system for CAS/SAS operators. This configuration has been in
i
operation since November 5,1996. The licensee did have in place Security
Information Report 10551, "JC 6000 Alarm Response," dated September 27,'
1996, which generally outlined response requirements. This procedure
l
problem was identified as the first example of apparent violation
,
eel 50-302/96-18-01 in Paragraph S2.2.
SS Procedure 303," Compensatory Measures for Pre-Planned Maintenance,"
-
Revision 2,- dated July 28,1995, failed to estab%h the requirements that in the
event of a vital area door degradation, compensatory measures will not be
reduced in effectiveness as defined in 10 CFR 73.55(g)(1). The licensee
allowed the option to utilize a roving patrol, rather than the posting of an armed
i
security officer for pre-planned maintenance of vital area doors. This
procedural discrepancy is related to the URI identified in S3.1. The licensee's
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failure to have a written procedure that was implemented and maintained to
the detailed requirements necessary to implement the PSP is identified as a
second example of apparent violation eel 50-302/96-18-01,
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c.
Conclusion
A review of applicable procedures revealed two examples of inadequate procedures
as identified above.
S4.1
Records and Reports
a.
Insoection Scope (81038) -
This evaluation was to verify that the licensee maintained the records required by
regulations and by the PSP; maintained the required records available for inspection
for the time required; and to determine if records were adequate and appropriate for
the intended function.
b.
Observations and Findinas
The inspector reviewed Chapter 12 of the PSP and four security procedures to select
sample records and reports for this evaluation. Eight samples were selected. Four
dates, starting with December 4,1993, through February 29,1996, were randomly
chosen to ensure that the samples were maintained as required.
The licensee was aware of record and report regulatory requirements and the
commitments of the PSP and appropriate security procedures. The representative
sample of records selected involved access control; testing and maintenance; alarms
and response; and security patrols, tours and inspections.
a
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c.
Conclusion
s
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All sample records and reports reviewed were complete, available for review, and
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contained sufficient information to support and ensure functionality.
,
S4.3 Control of Safeauards information
3
a.
Inspection Scope (81810)
l
. The inspector ascertained if the provisions specified in 10 CFR 73.21, " Requirements
for the Protection of Safeguards Information," were being met by the licensee.
>
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b.
Observations and Findinas
,
a
l
In response to Violation 96-07-01, the licensee continued to evaluate the Safeguards
Information (SGI) program. At the time of this inspection, the licensee had SGI stored
in approximately 20 locations, inside and outside the protected area. The inspector
verified that all SGI stored in these locations were in approved locked storage
j
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containers. In an effort to have better control of SGI, the licensee had begun to
centralize SGI into fewer locations. Also, a declassification of SGI had been initiated.
Computer Based Training (CBT) of all badged individuals on the protection of SGI, as
,
directed by the Site Vice President, began October 10,1996, and was scheduled to
'
be completed by December 31,1996. The inspector reviewed multiple site
procedures with respect to the control of SGI and leamed from the licensee that
Compliance Procedure 130," Protection of Safeguards information," Revision 8, dated
'
June 18,1992, would encompass all prior procedures in an effort to standardize the
!
licensee's expectations with respect to the control of SGl. The inspector reviewed the
l
procedure and found that it met the requirements specified in 10 CFR 72.21. The
inspector also interviewed several individuals responsible for the protection of SGI and
found them knowledgeable of their duties. To track and trend SGI information, on
October 15,1996, the licensee established a Safeguards Action Committee (SAC).
The following circumstances were identified by the licensee during the course of their
i
corrective action plan as outlined in Problem Report (PR) 96-0394:
'
f
On August 21,1996, four SGI cabinets were relocated from the Nuclear
a.
Administration Building (NAB), which is outside the protected area, to the
Temporary Badging Trailer, which is inside the protected area. The licensee
determined that the area within the NAB possibly did not meet the design
!
criteria for a controlled access area. On August 22,1996, two of the four
relocated cabinets were moved to the TSC due to fire protection requirements
'
of plant drawings.
,
i
b.
On September 20,1996, a contractor noted an SGI aperture card left
i -
unattended in Document Control, which is located in the NAD. The card was
immediately secured. Upon completion of the licensee's investigation, it was
determined that an FPC employee was working on the same security drawings
.
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approximately 30 minutes earlier. The aperture card had inadvertently been
.
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left in the copier return tray The licensee determined the SGI left unattended
could not significantly assist an individual in an act of sabotage.
c
On September 27,1996, the licensee determined that SGI located at the
Nuclear Operations Training Center (EOF), which is located in downtown
Crystal River, was improperly stored in that the cabinet was not a GSA
approved safe. The cabinet contained SGI microfilm and had been in its
present configuration for several months. The cabinet was locked with a
combination lock and locking bar at the time of discovery. The licensee
immediately relocated the SGI to an approved cabinet.
d.
_ On September 28,1996, a security officer inadvertently left SGI unattended in
the security breakroom, which is located in the Nuclear Security Operations
Center, outside the protected area. The documents contained CAS/SAS SGI'
for response and vital area door checks. The SGI was left unattended for
approximately 17 minutes. The licensee determined the SGI left unattended
could not significantly assist an individualin an act of sabotage.
Beginning July 1,1996, the licensee began documenting all loggable events, such as
those described above, on precursor cards to better track and trend these events.
c.
Conclusion
Through document review and observations, the inspector concluded that the
licensee's corrective action was continuing and the control of SGI had improved.
Violation 96-07-01 remains open.
G5
Security Safeauards Staff Trainina and Qualification
S5.1
Trainina and Qualification
,
a.
Inspection Scope (81501)
This review was to validate that the licensee was training the security force to meet
the provisions specified in their NRC approved T&QP, Revision 7.1, dated March 1,
1996.
b.
t bservations and Findinas
,
The inspector reviewed ten randomly selected training records for armed security
officers, response team members, and CAS/SAS analysts to ascertain if the
requirements of the T&QP were being met. Records reviewed revealed task and
qualification scores were being achieved and documented accordingly. Also, medical
and fitness requirements were in accordance with 10 CFR 73, Appendix B.
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The inspector noted that weapon qualification scores had dropped from recent years.
Upon further discussion with licensee representatives, the inspector was informed that
,
'
only four hours of classroom training for the year 1996 was conducted, and a test was
given to all members of the security force. No firearms training was conducted.
The licensee informed the inspector that eight hours of training would be conducted
per week on a rotating basis for rrmmbers of the security force in addition to the
annual weapons requalification.
c.
Conclusion
Through document review and licensee interview, the inspector concluded that the
provisions set forth in the licensee's T&QP were being met.
S6
Security Oraanization and Administration
S6.2 Effectiveness o1 Manaoement Control
a.
Inspection Scope (81020)
The inspector ensured that licensee management was effective and adequately
discharged their responsibility conceming the security program.
b.
Observations and Findinas
During most of 1996, there has been a continuous involvement in the major ongoing
security upgrade. The security force has been operating in temporary structures and
with a prolonged, extensive over-time schedie. Equipment was minimally functional
and failure to comply with regulatory requirements were identified frequently. Until
recently, there appeared to be a lack of communications from management down to
the officer level regarding regulatory requirements, implementing procedures, and
progress of the security upgrade. Based on the inspector's observation, the new
security manager was beginning to establish policy, along with setting organizational
goals and objectives, in an attempt to move the organization into regtiatory
compliance. Also, in an effort to establish communications with the day-tn-day
security force, the security manager had implemented a telephone hotline which was
updated daily to ketp the security force abreast of the latest issues, including security
upgrade information.
c.
Conclusion
Many of the problems documented in this inspection report, especially those with the
security upgrade project, are demonstrative of significant weaknesses in management
oversight. The inspector concluded that the licensee's new security management
team was beginning to establish a security organization capable of supporting
licensing requirements.
i
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14
S6.3 Security Oraanization
a.
Inspection Scope (81022)
The inspector evaluated whether the licensee's security management structure and
l
chain of command were in conformance with the approved PSP, SCP, licensee
procedures, and applicable regulatory requirements, and were adequate and
appropriate for their intended function. In addition, the inspector evaluated whether
the licensee's planned response to security threats, incidents, or other contingencies
were adequate to meet the general performance requirements.
b.
Observations and Findinas
,
The inspector determined that the licensee has established and maintained an onsite
physical protection system and security organization, including officers, whose
objective was to provide assurance that the site could be protected from radiological
sabotage.
The licensee utilized a contract security force for site security. The ccntractor was
required to abide by NRC regulations and the licensee's PSP. The contractor was
also responsible for meeting the requirements of the licensee's TO&P and SCP.
The inspector determined that at least one full time member of the security
organization who had the authority to direct the physical protection activities was on
site at all times. Also, the licensee had established a chain of succession for the
security organization.
,
The inspector determined that the licensee had established liaison with the local law
enforcement authorities and that the local law enforcement was capable of responding
in a timely manner.
On December 4,1996, the inspector observed the licensee conduct a contingency
response drill and verified that the responding officers were adequately armed,
'
tactically trained, able to maintain excellent communications, and capable of
interposing themselves between vital areas and the adversary attempting to gain entry
for the purpose of radiological sabotage.
c.
O .uusion
The inspector concluded that the security organization was established to meet the
regulatory requirements. Also, the licensee demonstrated during an observed drill
they were capable of interposing themselves between vital areas and the established
design basis threat.
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,
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15
S7
Quality Assurance in Security and Safeauards Activities
S7.1
Security Proaram Audit
a.
Inspection Scope (81034)
The inspector ascertained whether the licensee had properly and adequately audited
the security program to assure its continued effectiveness. Also, the inspector
reviewed whether the licensee had implemented the recommendations for
improvements contained in the annual security audit report.
b.
Observations and Findinas
The licensee had committed to an annual security audit in Chapter 13 of the
licensee's PSP. The audit was conducted by persons who are independent of both
security management and security supervision. However, the inspector noted that
the licensee employed the previous security manager to conduct an audit of the
security program in August 1996. The use of this individual was questionable, since
1
it is difficult for a person to conduct an unbiased audit of a program that the person
developed and managed. Although, the areas audited appeared to have been
adequately reviewed, the auditor's principle finding was the licensee's failure to
implement security upgrade items, which are not required by regulations. Additionally,
i
while reviewing the security upgrade project, the inspector determined that portions
failed to meet regulatory requirements, although the audit did not find this.
j
The inspector reviewed Nuclear Security Audit Report 95-06, which was conducted
June 12 through June 30,1995, and noted that the audit scope was to evaluate the
following areas:
- security procedures and practices
- effectiveness of the physical protection system
- physical protection system testing and maintenance
- commitments for response by local law enforcement authorities
- emergency contingency plans
- training and qualification of security officers
- transfer of access authorization program responsibilities
- the security key control program
- protection of safeguards information
l
The auditors had no findings, but several weaknesses in administrative controls. The
inspector noted that the auditors had determined that the Security Plans and their
implementing procedures that had occurred since the last audit did not decrease the
effectiveness of physical security protection. However, during the current inspection,
,
l
the inspector determined that PSP change submittal Revision 6-13, Appendix D, had
l
decreased the effectiveness of the security program. (See Paragraph S3.1 for
detailed information.) The inspector also reviewed annual Audit Report 96-05,
l
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conducted May 28 through June 14,1996 and noted that the audit included nuclear
security, access authorization / control, and fitness for duty. The auditors identified
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16
eight deficiencies and several strengths.
The inspector evaluated a security audit conducted from July 9 through s'atober 25,
1996, which identified numerous findings in the security area; however, Sie latest audit
report had not been forwarded to security for review and corrective actions at the time
of the inspection. The inspector was unable to review the corrective actions. This
was identified as an inspector Follow-up Item (IFl 50-302/96-18-08),
c.
Conclusion
The inspector determined that the licensee was conducting security audits in
accordance with the regulatory requirements specified in the PSP. Although the
auditors appeared to be qualified to conduct security audits, numerous deficiencies
with PSP change submittals were not documented during the June 12 through
June 30,1995 audit. The auditor did note during the July 9 through October 25,
1996, audit that the security plan and procedures needed to be updated. An IFl was
opened to determine the adequacy of the licensee's corrective actions.
S8
Miscellaneous Security and Safeouards issues
S8.1
Action on Previous inspection Findinos (92904)
(CLOSED) LER 96-S03-00 is closed (further discussed in S2.2).
(CLOSED) LER 96-S02-00 is closed (further discussed in S2.6).
(CLOSED) VIO 96-02-01. The licensee's corrective action to maintain 0.2 footcandle
in the protected area has resulted in prioritized work orders for deficient lights and
lighting surveillances at regular intervals (further discussed in S2.7).
(DISCUSSED) VIO 96-07-01. This violation with respect to the control of SGI
remains open pending the licensee's completion of corrective action (further discussed
in S4.3).
I
)
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.
.
17
Manaaement Meetinas
X1
Exit Meeting Summary
The inspector presented the inspection results onsite on December 6 and
December 19, and subsequently via telecon on January 10,1997, to licensee
management. The licensee acknowledged the findings presented. The inspector
discussed the ongoing security upgrade and the need for the licensee to ensure
compliance with regulatory requirements of each upgraded system. Although
reviewed during this inspection, proprietary information is not contained in this report.
Dissenting comments were not received by the licensee.
i
I
PARTIAL LIST OF PERSONS CONTACTED
Licensee
B. Bumgardner, System Engineer, Florida Power Corporation (FPC)
J. Baumstark, Director, Quality Programs, FPC
B. Hickle, Director, Nuclear Plant Operations, FPC
L. Kelley, Director, Nuclear Operations Site Support, FPC
B. McLaughlin, Sr. Nuclear Regulatory Specialist, FPC
D. Watson, Manager, Nuclear Security, FPC
i
R. Yost, Manager, Nuclear Quality Assurance, FPC
2
NRC
S. Cahill, Senior Resident inspector
T. Cooper, Resident inspector
K. Landis, Chief, Reactor Projects
INSPECTION PROCEDURES USED
IP 81020: Management Effectiveness - Security Program
IP 81022: Security Organization
,
IP 81034: Security Program Audit
IP 81038: Records and Reports
IP 81052: Physical Barriers - Protected Areas
IP 81062: Lighting
IP 81084: Alarm Stations
IP 81088: Communications
IP 81401: Plans, Procedures, and Reviews
IP 81501: Personnel Training and Qualifications - General Requirements
IP 81810: Protection of Safeguards information
IP 92904: Action on Previous inspection Findings
i
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18
)
ITEMS OPENED, CLOSED, AND DISCUSSED
l
.
Opened
50-302/96-18-01
eel
Failure to have adequate procedures
50-302/96-18-02
Eil
Failure to respond to a protected area alarm
)
'
50-302/96-18-03
eel
Failure to assess more than one protected area alarm
l
50-302/96-18-04
eel
Failure to maintain protected area barriers
50-302/96-18-05
eel
Inadequate arms repository
'
50-302/96-18-06
Failure to adhere to 10 CFR 50.54(p)(1)
50-302/96-18-07
eel
Failure to adhere to 10 CFR 50.54(p)(2)
50-302/96-18-08
IFl
Adequacy of licensee's corrective actions for audit findings
Closed
50-302/96-02-02
Failure to maintain protected area lighting
50-302/96-S02-00
LER
Failure to maintain protected area barrier
)
50-302/96-S03-00
LER
Failure to respond to a protected area alarm
.
'
Discussed
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50-302/96-07-01
Failure to control Safeguards information
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F:deral Regist:r / Vol. So, No.126 / Friday, June 30,1995 / N: tic s
34381
'
NUCLEAR REGULATORY
As reflected in the neverity levels, safety
(2) To encourage prompt
COMMISSION
significance includes actual safety
identification and prompt,
consequence, potential safety consequence,
comprehensive correction of violations.
Revision of the NRC Enforcement
and regulatory significance. The use of
aduated sanctions frora Notices of
Policy
(lolation to orders further reflects the
IV. Severity of Violations
,
AGENCY: Nuclear Regulatory
varying eeriou.sness of noncompliances.
Severity Level V violations have been
Commission.
- The enforcement conference is an
eliminated.The examples at that level
,
ACTION: Policy statement.
M,'jh g',$','nd 1:
i 8$
have been withdrawn from the
'
es
re
s
s
ca e
n cs a
SUMMARY:As a result of an assessment
[a
ecti s wi o o ly
a e fo
8
{
,
of the Nuclear Regulatory Commission s ,gran gor both the NRC and licensees, they
violations categorized at Severity Level
(NRC) enforcement program, the NRC
generally contribute to better decision.
I to IV to better focus the inspection and
has revised its General Statement of
making.
enforcement process on safety. To the
Policy and Procedure for Enforcement
- Enforcement actions deliver regulatory
extent that minor violations are
Actions (Enforcement Policy or Policy). messages properly focused on safety.These
described in en ins ection report, they
messa s emphasize the need for licensees to willbe labeled as on-Cited Violations
By a se arate action published today in
the Fe eral Register, the Commission is
nslvIto
C
'*
'
,,
,nd to be s
tial
(NCVs). When a licensee does not take
removing the Enforcement Policy from
o portunities to identify and prevent
corrective action or repeatedly or
the Code of Federal Regulations.
v oletions.
willfully commits a minor violation
DATES: This action is effective on June
e The use of discretion and judgment
such that a formal response would be
30,1995, while comments are being
throughout the deliberative process
needed, the violation should be
received. Submit comments on or before recognizes that enforcement of NRC
categorized at least at a Severity Level
,
August 14,1995. Additionally, the
requirements does not tend itself to
gy,
mechanistic treatment.
,
Commission intends to provide an
8
opportunit for public comments after
However,the Review Team found that
I
les in tha
this revise Enforcement Policy has
the existing enforcement program at
88**'I'Y I '***[e next 6 months.
s
been in effect for about 18 months.
times provided mixed re8ulatory
supplements over t
r
s mview ls to ensum
8 PjrPose o
wp , e)y g9e ,,e
ADDRESSES: Send written comments to:
messages to licensees, and room for
, mp),,
im rovement existed in the
The Secretary of the Commission, U.S.
Enyorcement Policy.The review
on safety significance including
Nuclear Regulatory Commission,
ggg
s
sted that the program s focus
consequence, potential safety
Washington, DC 20555. ATI'N:
s
d be clarifle to.
Docketing and Service Branch. Hand
consequence, and regulatory
deliver comments to: 11555 Rockville
- Emphasize the importance ofidentifying sigt.lficance.
Pike, Rockville, Maryland, between 7:45 problems before events occur, and of taking
am and 4:15 pm, Federal workdays.
Prompt, comprehensive corrective action
V. Predeciafonal Enforcement
Copies of comments received may be
when problems are identified:
Conferences
e Direct ency attention at licensees with
d at the
bli
""
t
dv
Enforcement conferences are being
Room. 2120 L St t
W, (Low
I.evel), Washington, DC.
- Focus okand
ho
ri
an8me Predecisional enforcement
current performance of
conferences. These conferences should
FOR FURTHER INFORMATION CONTACT:
licensees.
be held for the purpose of obtaining
James Lieberman, Director, Office of
In addition, the review team found
information to assist NRC in making
,
Enforcement, U.S. Nuclear Regulatory
that the process for assessing civil
enforcement decisions when the agency
Commission, Washington, DC 20555,
penaltles could be simplified to improve reasonably expects that escalated
(301) 415-2741.
the predictability of decision-making
enforcement actions will result. They
,
SUPPt.EMENTARY INFORMATION: On May
and obtain better consistency between
should also normally be held if
'
13,1994, the NRC's Executive Director
regions.
requested by a licensee. In addition they
for Operations established a review
As a result ofits review,the review
should normally be held before issuing
team to assess the NRC enforcement
team made several recommendations to an order or a civil penalty to an
program. In its report (NUREG-1525,8
revise the NRC Enforcement Policy to
unlicensed individual.
" Assessment of the NRC Enforcement
produce an enforcement program with
Program," April 5,1995), the review
clearer regulatory focus and more
In light of the changes to the
l
team concluded that the existing NRC
predictability.The Commission is
Enforcement Policy, the Commission
enforcement program, as implemented,
issuing this policy statement after
has decided to continue a trial program
is appropriately directed toward
considering those recommendations and of conducting approximately 25 percent
'
supporting the agency's overall safety
the bases for them in NUREG-1525.
of eligible conferences open to public
mission.This conclusion is reflected in
The more significant changes to the
observation pending further evaluation.
several aspects of the program:
current Enforcement Policy ar,
(See 57 FR 30762; July 10,1992, and 50
described below.
FR 36796: July 19,1994).The intent'of
. The Policy recognizes that violations
open conferences is not to maximize
have differing degrees of safety significance.
L Introduction and Purpose
public attendance,but is rather for
This section has been modified to
determining whether providing the
8 Copies of NUREG-ts2s may be purchased from emphasize that the purpose and
public with an opportunity to observe
the superintendent ot Documents. U.S. Covernment
Printing Office. Mail Stop SSOP. Washington. DC
objectives of the enforcement program
the regulatory process is compatible
20402-s32s. Coplas are also evallable from the
are focused on using enforcement
with the NRC's ability to exercise its
National Techancellnformation Servics. s28s Port
actions:
regulatory and safety responsibilities.
e {s
(1) As a deterrent to emphasize the
The provisions of the trial program have
(d
'
P
8
av let1
1ns
p
'
in the NRC Public Document Room. 2120 L Street,
importance of compliance with
been incorporated into the Enforcement
4
NW. (Lower t.evell, washington. DC 20sss-0001.
requirements; and
Policy.
3
. - - - - _ - - . - - . - - - . - . - - .- - - - - - . . - -
,
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Fsderal Register / Vol. 60, No.126 / Friday, June 30, 1995 / NoticIs
34381
i
NUCl. EAR REGut.ATORY
As reflected in the severity levels. safety
(2) To encours prompt
!
COMMISSION
significance includes actual safety
identification an prompt.
Co#*luence, potential sa
consequence,
comprehensive correction of violations.
'
l
Revision of the NRC Enforcement
and regulatory sign!Acance.
use of
usted sanctions imm Notices of
IV, Severity of Violations
1
Policy
t
lolation to orders further reflects the
i
AGENCY: Nuclear Regulatory
varying seriou.sness of noncompliances.
Severit LevelV violations have been
l
Commission.
- The enforcement conference is an
eliminate .The examples at that level
I", Q " ["l $ 'a'i8"
have been withdrawn from the
j
ACTION: Policy statement.
,
d 1ss
8uPplements. Formal enforcement
+
gn cent u fo m
decis
!
suuMARY:As a result of an assessment
actions will now on1 be taken for
33
ference
Mme
j
of the Nuclear Regulatory Commission's effort both the NRCand licensees,they
violations categorise at Severity Level
j
(NRC) enforcement pr
m, the NRC
generally contribute to better decision.
I to IV to better focus the inspection and
has revised its Genera
tement of
making.
enforcement process on safety. To the
Policy and Procedure for Enforcement
- Enforcement actions dellwr regulatory
extent that minor violations are
Actions (Enforcement Poli or Policy). messages psoperly focused on safety.The
described in anins
tion
rt, they
=
emphaelse the need forlicenme to willbelabeled as on Cited lolations
i
Bya
arate action publi d todayin
dent
viola
to ed
the
j
the F
al Register, the Commission is
_
,
. _ ,
v.
,
l
(NCVs). When a licensee does not take
i
removin the Enforcement Policy from
donations,portunities to identify and prevent
corrective action or repeatedt or
!
th~e Cod of Federal Regulations.
willfully commits a minor vio ation
DATES:This action is effective on June
. The use of discretion and judgment
such that a formal response would be
!
-
i
30,1995, while comments are bein
throughout the deliberatin process
needed,the violation should be
nian that enforcement of NRC
categorised at least at a Severity Level
received. Submit comments on or fore Quments does not lend itself to
gy,
August 14,1995. Additionally,the
"l
mchanistic tmatmot.
l
Commission intends to provide an
The NRC staff willbe reviewing the
opportunit for public comments after
However, the Review Team found that
lesin the
severity level examhe next 6 months.
i
this revi
Enforcement Poll;y has
the existi enforcement p ram at
supplements over t
l
been m effect for about 18 months.
times pro ed mixed regu tory
The purpose of this review is to ensure
i
A00RESSES: Send written comments to:
ruessages to licensees, and room for
the examples are appropriately focused
l
i
The Secreta of the Commission.U.S.
im rovement existed in the
En
ment Policy.The review
on safety significance, including
,
i
Nuclear Re letory Commission.
gg
g
su
ted that th program s focus
consequence, potential safety
I
i
Washington,DC 20555. A'!TN:
sh Id be clarifi to:
]
Docketing and Service Branch. Hand
consequence,and regulatory
deliver comments to: 11555 Rockville
e Emphaelse the importance ofidentifying significance *
'
~
Pike, Rockville, Ma land,between 7:45 problems before ownts occur, and of taking
l
am and 4:15 pm F eral workdays.
Prompt comprehensive corrective action
V,Fredecisionel Enforcement
when
lems are identined:
Conferences
Copies of comments received may be
,,igfpi,,,TMg",$,'i$7,,Tgj,*1f
Enforcement conferences are being
l
examined at the NRC Public Document
Room. 2120 L Street, NW. (Lower
short period: and
renamed "predecisional enforcement
1
<
1evel), Washington, DC.
. Focus on current performance of
conferences."These conferences should
FOR FURTHER INFORMATION CONTACT:
licensees.
bWbb
dM4
l
James Lieberman, Director, Office of
In addition, the review team found
information to ass t NRCin making
i
,
Enforcement, U.S. Nuclear Regulatory
that the process for assessin civil
enforconnent decisions when the agency
Commission, Washington, DC 20555,
nalties could be sim lift to improve reasonably expects that escalated
(301) 415-2741,
e redictability of d Ision-making
enforcement actions will result. They
SUPPL.EMENTARY INFORMATION:On May
and
sin better consistency between
should also normally be held if
i
13,1994, the NRC's Executive Director
regions.
uested by a licensee. In addition they
for Operations established a review
As a result ofits review, the review
sh uld normally be held before issuing
team to assess the NRC enforcement
team made several recommendations to an order or a civil nalty to an
program. In its report (NUREG-1525,t
revise the NRC Enforcement Policy to
unlicensedindivi unl.
" Assessment of the NRCEnforcement
produce an enforcement p ram with
Program," A til 5,1995), the review
clearer
ulato focus an more
in light of the chan a to the
team conclu ed that the existing NRC
redict lity.
Commission is
Enforcement Policy, e Commission
has decided to continue a trial program
enforcement
m, as implemented,
seuin this policy statement after
is appropriat y irected toward
consi rin those recommendations and of conducting pproximately 25 percent
supporti the age
's overall safety
the bases
them in NUREG-1525.
of eligible con erences o en to public
mission. is conc uslon is reflected in
The more significant changes to the
observation pending fu er evaluation.
neveral aspects of the program:
current Enforcement Policy are
(See 57 FR 30762; July 10.1991, and 59
described below.
FR 36796: July 19,1994).The intent of
. The Pol recogalass that violations
open conferences is not to maximize
have differing ogms of safety significence.
1. Introduction and Purpo"
public attendance,but is rather for
This section has been modified to
determining whether providing the
ihMaiendoN*'".ku's.
emphastre that the purpose and
public with an opportunity to observe
ne
at
Printins Omco. Matt stop ssor. washington. DC
objectives of the onforcement program
the
latory rocessiscompatible
204ca-esta. copies are etso evallable kan the
are focused on using enforcement
with e NRC' ability to exercise its
National Tschalml infomutton service, stes Port
actions:
regulatory and safety responsibilities.
!
yk^ba h
(1) As a deterrent to emphasize the
The provisions of the trial program have
P
in the NRC Public Document stoom. 2120 L suest,
importance of compliance with
, been incorporated into the Enforcement
w
e
m
,
Nw. (14wer Lewl), webington, DC 2ess5-oo01.
requirements; and
Policy.
~
3
.
-