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Insp Repts 50-245/97-03,50-336/97-03 & 50-423/97-03 on 970203-07.No Violations Noted.Major Ares Inspected: Audits,Security Training,Equipment Testing & Management Support
	ML20140C042
Person / Time
Site:	Millstone
Issue date:	03/26/1997
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20140B899	List: ML20140B896; ML20140C042;
References
	50-245-97-03, 50-245-97-3, 50-336-97-03, 50-336-97-3, 50-425-97-03, 50-425-97-3, NUDOCS 9704020039
	Download: ML20140C042 (10)
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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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Docket Nos.

50-245; 50-336; 50-423

License Nos.

DPR-21; DPR-65; NPF-49

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Report Nos.

97-03

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Licensee:

Northeast Nuclear Energy Company

Facility:

Millstone Nuclear Generating Station, Units 1,2, and 3

Location:

Waterford, Connecticut

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Dates:

February 3-7,1997

inspectors:

G.C. Smith, Senior Security Specialist

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E.B. King, Physical Security inspector

P.R. Frechette, Physical Security inspector

Approved by:

R.R.Keimig, Chief, Emergency Preparedness and

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Safeguards Branch, Division of Reactor Safety

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9704020039 970326

PDR

ADOCK 05000245

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EXECUTIVE SUMMARY

The licensee was maintain!ng an adequate program. However, management controls for

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identifying, resolving, and preventing programmatic problems appeared to be ineffective.

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This determination was based on fincings which consisted of three apparent violations of

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NRC requirements, two of which had been cited previously. The violations involved the

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licensee's failure to control vehicles in the protected area properly, failure to control

safeguards information properly, and the failure to perform personnel searches properly

prior to granting protected area access. Notwithstanding, audits were thorough and

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indepth, the alarm station operators were knowledgeable of their duties and responsibilities

and were not engaged in activities that would interfere with their response functions.

Security training was being performed in accordance with the NRC-approved training and

qualification plan and protected area detection equipment was consistent with the NRC-

approved Physical Security Plan (the Plan). Equipment testing was being performed as

required and maintenance of equipment was being conducted in a timely manner, as

evidenced by minimal compensatory posting associated with equipment repairs.

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Management support was evident by the procurement of three new security patrol

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vehicles, the procurement of two X-ray machines for personnel / package processing, and

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the replacement of the protected area barrier along the east side of the station. Security

force members possessed the requisite knowledge to carry out their assigned duties and

the training program was, in general, effective. Section 6.5 of the Plan, titled " Vehicle

Access" was reviewed as an inspection initiative. The review determined that since

February 1995, there were 37 incidents where vehicles were not adequately controlled

while in the Protected Area.

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REPORT DETAILS

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S1

Conduct of Security and Safeguards Activities

a.

Inspection Scope

The inspectors reviewed the security program during the period of

February 3-7,1997. Areas inspected included: effectiveness of management

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control; management support and audits; protected area detection equipment; alarm

stations and communication; testing, maintenance and compensatory measures;

training and qualification, vehicle access, and previously identified items. The

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purpose of this inspection was to determine whether the licensee's security

program, as implemented, met the licensee's commitments in the NRC-approved

security plan (the Plan) and NRC regulatory requirerlents.

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b.

Observations and Findinos

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Management support was evident by the procurement of three new security patrol

vehicles, the procurement of two X-ray machines for personnel / package processing,

and the replacement of the protected area barrier along the east side of the station.

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However, controls for identifying, resolving, and preventing programmatic problems

appeared to be ineffective based on inspection findings which consisted of three

apparent violations of NRC requirements, two of which had been cited previously.

The previously cited violations, identified by the licensee's security force, involved

the failure to control vehicles in the protected area properly, and to control

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safeguards information properly. The third violation, identified by the inspectors, is

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the failure to perform personnel searches properly prior to granting protected area

access. Audits were thorough and indepth and alarm station operators were

knowledgeable of their duti.5. and responsibilities and security training was bcing

performed in accordance with the NRC-approved training and qualification (T&Q)

plan. Protected Area (PA) detection equipment satisfied the NRC-approved physical

security plan (the Plan) commitments and security equipment testing was being

performed as required by the Plan. Maintenance of security equipment was being

performed in a timely manner as evidenced by minimal compensatory posting

associated with non-functioning equipment.

c.

Conclusions

The inspectors concluded that the licensee was generally conducting its security

and safeguards activities in a manner that protected public health and safety.

However, the licensee's corrective actions implemented to resolve previously

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identified violations appeared to be ineffective as evident by the frequent recurrence

of the violations. The inspectors concluded that the violations associated with the

control of vehicles and safeguards information are a result of plant employees failing

to adhere to station policy and management's failure to implement effective

corrective actions.

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S2

Status of Security Facilities and Equipment

S2.1 Protected Area Detection Aids

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a.

Insoection Scope

Conduct a physical inspection of the PA intrusion detection systems (IDSs) to verify

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that the systems were functional, effective, and met licensee commitments.

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b.

Observations and Findinas

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On February 4,1997, the inspectors determined by observation and selected testing

that the IDSs were functional and effective, and were installed and maintained as

described in the Plan.

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Conclusion

The PA IDS met the licensee's Plan commitments.

S2.2 Alarm Stations and Communications

a.

Insoection Scoce

Conduct a review to determine whether the Central Alarm Station (CAS) and

Secondary Alarm Station (SAS) are: (1) equipped with appropriate alarm,

surveillance and communication capability, (2) continuously manned by operators,

and that (3) the systems are independent and diverse so that no single act can

remove the capability of detecting a threat and calling for assistance, or otherwise

responding to the threat, as required by NRC regulations.

b.

Observations and Findinos

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Observations of CAS and SAS operations verified that the alarm stations were

equipped with the appropriate alarm, surveillance, and communication capabilities.

Interviews with CAS and SAS operators found them knowledgeable of their duties

and responsibilities. The inspectors also verified through observations and

interviews that the CAS and SAS operators were not required to engage in activities

that woulu interfere with the assessment and response functions, and that the

licensee had exercised communications methods with the locallaw enforcement

agencies as committed to in the Plan.

c.

Conclusion

The alarm stations and communications met the licensee's Plan commitments and

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NRC requirements.

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S2.3 Testina, Maintenance and Compensatorv Measures

a.

Insoection Scope

Conduct a review to determine whether programs are implemented that will ensure

the reliability of security related equipment, including proper installation, testing and

maintenance to replace defective or marginally effective equipment. Additionally,

determine if when security related equipment fails, the compensatory measures put

in place are comparable to the effectiveness of the security system that existed

prior to the f ailure.

b.

Observations and Findinas

Review of testing and maintenance records for security-related equipment confirmed

that documentation was on file that demonstrated the licensee was testing and

maintaining systems and equipment as committed to in the Plan. A priority status

was being assigned to each work request and repairs were normally being

completed in a timely manner for all work, necessitating compensatory measures.

c.

Conclusions

Security equipment repairs were timely and the use of compensatory measures was

found to be appropriate and minimal.

S5

Security and Safeguards Staff Training and Qualification

a.

Insoection Scope

Conduct a review to determine whether members of the security organization are

trained and qualified to perform each assigned security related job task or duty in

accordance with the NRC-approved T&Q plan.

b.

Observations and Findinas

The inspectors randomly selected and reviewed T&Q records for twenty-five SFMs.

Requalification records were reviewed for armed and unarmed SFMs and security

supervisors. The inspectors found that the training had been conducted in

accordance with the T&Q Plan and was properly documented.

However, on February 3,1997, the inspectors observed a SFM improperly

performing personnel searches at the South Access Point. Specifically, while using

the hand held metal detector, after an employee was unable to successfully pass

through the metal detector, the SFM failed to identify the cause of the alarm yet

granted protected area access. The SFM believed, but did not confirm, that alarms

received while using the hand held metal detector on the wrist area were caused by

the employee's watch and that alarms received in the area of the feet were caused

by steel toe shoes. Based on the employee's responses to the SFM's questioning,

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the SFM did not physically search the areas in question. The inspectors

immediately informed a supervisor in the area who stopped the employee's entry

and informed licensee management of their observation. On February 4,1997, the

inspectors observed personnel searches at both of the access points and determined

that, although the searches had improved as a result of the problem identified on

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the previous day, the SFMs were not consistent in their performance of personnel

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searches when using the hand held metal detectors. The licensee addressed the

inspectors' concerns by retraining the security force on personnel search techniques

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and expectations. The retraining was conducted during shift briefings and included

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a training film, developed by the training staff, on personnel search, and a question

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and answer session. By the end of the inspection, the inspectors determined, by

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observation, that personnel searches were being performed properly and

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consistently.

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c.

Conclusions

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The SFM's failure to identify the cause of an alarm positively, after an employee

was unable to successfully pass through the metal detector is an apparent violation

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of NRC requirements. (eel-50-245/97-03-01, 50-336/97-03-01 and 50-423/97-03-

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S6

Security Organization and Administration

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a.

Insoection Scope

Review the level of management support for the licensee's physical security

program.

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b.

Observations and Findinas

The inspectors reviewed various program enhancements made since the last

program inspection, which was conducted in May 1996. These enhancements

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included the procurement of three new security patrol vehicles, the procurement of

two X-ray machines for personnel / package processing, and the replacement of the

protected area barrier along the east side of the station.

c.

Conclusions

Management support for the physical security program was determined to be

adequate, except as indicated in Section S7, below.

S7

Quality Assurance in Security and Safeguards Activities

S7.1 Effectiveness of Manaaement Controls

a.

Inspection Scope

Conduct a review to determine if the licensee had controls for identifying, resolving

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and preventing programmatic problems.

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b.

Observations and Findinas

The inspectors determined that the licensee had controls for identifying, resolving,

and preventing security program problems. These controls included the

performance of the required annual quality assurance (QA) audits, the licensee's

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formalized station self-assessment program, and the performance of root cause

analysis for each human performance error. The licensee also utilized industry data,

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such as violations of regulatory requirements identified by the NRC at other

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facilities, as criteria for self-assessment.

However, the inspectors found that the licensee's controls for identifying, resolving,

and preventing programmatic problems were not always effective. This finding is

based on three apparent violations of NRC requirements, two of which were cited

previously (see Sections X2 and X3 of this report). The inspectors found that

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although the repetitive violations associated with the control of vehicles and

safeguards information are associated with the security program and were identified

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by the security force, the violations appear to be the result of plant employees

failing to adhere to station policy and management's failure to implement effective

corrective actions. Additionally, the inspectors noted that three assessments were

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performed during 1996, and although trending of the safeguards event logs

identified weaknesses in the control of vehicles and safeguards information, none of

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the assessments addressed the known weaknesses.

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c.

Conclusions

A review of documentation applicable to the licensee controls, including results,

indicated that the controls were not being effectively implemented to resolve

potential weaknesses as evident by the recurrence of the noted violations and the

licensee's failure to address known weaknesses in a timely and effective manner.

S7.2 Audits

a.

Insoection Scope

Review the licensee's NRC-required audit of the security and fitness-for-duty (FFD)

programs to determine if t% licensee's commitments as contained in the Plan and

FFD rule are being satisficd.

b.

Observations and Findinas

The inspectors reviewed the 1996 QA audit of the security program, conducted on

September 5-17,1996, (Audit No. 96-A09-03), and the 1995 and 1996 audits of

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the FFD program. The 1995 FFD audit was conducted on October 12-27,1995,

(Audit No. A60597) and the 1996 audit was conducted on July 10-26,1996,

(Audit No. A60605). The audits were found to have been conducted in accordance

with the Plan and the FFD rule. To enhance the effectiveness of the audits, the

audit teams included independent technical specialists. The security audit report

identified one finding associated with protected area lighting deficiencies and two

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recommendations. The 1995 FFD audit report identified one finding associated with

an isolated failure to remove an intoximeter from service when, during daily

verification checks, it fell out of the acceptable range by 0.001, and one

recommendation. The 1996 FFD audit report identified one finding associated with

the potential for specimen adulteration within the collection facility and two

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recommendations. The inspectors determined that the audit findings were not

indicative of programmatic weaknesses and had been appropriately addressed. The

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audit results had been disseminated to the appropriate levels of management. The

inspectors determined, based on discussions with security management and a

review of the responses to the findings and observations, that the corrective actions

were effective.

c.

Conclusions

The inspectors concluded that the audits were comprehensive in scope and depth,

that the findings were appropriately addressed and distributed and that the audit

program was being properly administered.

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Exit Meeting Summary

The inspector met with the licens le representatives at the conclusion of the

inspection on February 7,1997. At that time, the purpose and scope of the

inspection were reviewed, and the preliminary findings were presented. The

licensee acknowledged the preliminary inspection findings.

X2

Review of Updated Final Safety Analysis Report (UFSAR)

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A recent discovery of a licensee operating its facility in a manner contrary to the

UFSAR description highlighted the need for a special focused review that compares

plant practices, procedures, and parameters to the UFSAR description. Since the

UFSAR does not specifically include security program requirements, the inspector

compared licensee activities to the NRC-approved physical security plan, which is

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the applicable document. While performing the inspection discussed in this report,

the inspectors reviewed Section 6.5 of the Plan, Revision 25, dated June 4,1996,

titled, " Vehicles Access." Based on discussions with security management,

reviews of procedures, and adverse condition reports and observations, the

inspectors determined that since February 1995 to the time of this inspection, there

have been 37 incidents where keys have been found in unattended vehicles in the

Protected Area. The Plan requires vehicles to be immobilized (ignition locked) when

not in use and the keys c.ontrolled. The failure to control vehicles in the Protected

Area was cited as a violation in Inspection Report 50-245/94-29, 50-336/94-25 and

50-423/94-27 conducted October 3-6,1994. This violation was closed in

Inspection 95-02, conducted January 1-February 7,1995. The 37 incidents of the

failure to control vehicles since the previous citation was closed is indicative of

ineffective corrective action. This is an apparent violation. (eel-50-245/97-03/02,

50-336/97-03-02 and 50-423/97-03-02)

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X3

Previously identified items

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(Open) VIO 96-06-01: Failure to Control Safeguards information. This violation

was identified during Inspection 96-05, conducted May 6-10,1996, and cited in

Inspection Report 96-06. Since inspection 96-05, there have been seven additional

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incidents where matter containing Safeguards Information has not been controlled.

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The seven incidents of uncontrolled Safeguards information since this violation was

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cited in May 1996 are indicative of ineffective corrective action. This is an

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apparent violation. (eel-50 245/97-03/03, 50-336/97-03-03 and 50-423/97-03-03)

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PARTIAL LIST OF PERSONS CONTACTED

LICENSEE PERSONNEL

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N. Carns, Senior Vice President, Millstone

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C. Clement, Manager, General Services

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F. Rothen, Vice President, Work Services

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T. Weekley, Security Manager

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P. Marchese, Senior Security Analyst

P. Anhalt, Security Supervisor-Operations

J. Gionet, NRC Coordinator, Licensing Department

J. McElwain, Recovery Officer, Unit 1

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STATE REPRESENTATIVE

M. Firsick, Radiation Control Physicist, State of Connecticut

Department of Environmental Protection (DEP)

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U.S. NUCLEAR REGULATORY COMMISSION - REGION I

T. Easlick, Senior Resident inspector

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denotes those present at exit meeting on February 7,1997

The inspectors also interviewed other licensee and contractor security personnel.

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March 26, 1997

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EA No.97-104

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Mr. Bruce D. Kenyon

President and Chief Executive Officer

Northeast Nuclear Energy Company

P. O. Box 128

Waterford, Connecticut 06385-0128

Dear Mr. Kenyon:

' SUBJECT:

NRC COMBINED INSPECTION REPORT 50-245/97-03;50-336/97-03:

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50-423/97-03; and NOTICE OF VIOLATION

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This letter refers to the routine safety inspection conducted by Messrs. G.C. Smith,

E.B. King and P.R. Frechette of this office on February 3-7,1997, of activities authorized

by NRC License Nos. DPR-21, DPR-65, and NPF-49 at the Millstone Site, Waterford,

Connecticut and to the discussion of our findings held by Mr. Smith with members of your

staff at the conclusion of the inspection. The security program was inspected during this

period. The inspection consisted of selective reviews of procedures and records, inspector

observations, and interviews with security personnel.

Based on the results of this inspection, three apparent violations of NRC requirements were

identified and are being considered for escalated enforcement action in accordance with

the " General Statement of Policy and Procedure for NRC Enforcement Actions"

(Enforcement Policy), NUREG-1600. No Notice of Violation is presently being issued for

these inspection findings, in addition, please be advised that the riumber and

characterization of apparent violations described in the enclosed inspection report may

change as a result of further NRC review. The violations involve the failure to control

vehicles in the protected area properly, the failure to control safeguards information, and

the failure to perform personnel searches properly prior to granting protected area access.

We are particularly concerned because the first two of these violations were cited in the

past and it appears that your corrective actions have not been effective.

A predecisional enforcement conference to discuss these apparent violations has been

scheduled for April 7,1997 at 1:00 p.m., in the Region I office. The decision to hold a

predecisional enforcement conference does not mean that the NRC has determined that a

violation has occurred or that enforcement action will be taken. This conference is being

held to obtain information to enable the NRC to make an enforcement decision, s

common understanding of the facts, root causes, missed opportunities to identify the

apparent violations sooner, corrective actions, significance of the issues and the need for /

lasting and effective corrective action. In addition, this is an opportunity for you to point

out any errors in our inspection report and for you to provide any information concerning

your perspectives on 1) the severity of the violations, 2) the application of the factors

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Mr. Bruce D. Kenyon

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that the NRC considers when it determines the amount of a civil penalty that may be

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assessed in accordance with Section VI.B.2 of the Enforcement Policy, and 3) any other

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application of the Enforcement Policy to this case, including the exercise of discretion in

accordance with Section Vll.

This conference will be closed to public observation. You will be advised by separate

correspondence of the results of our deliberations on this matter. You are not required to

respond to this letter at this time; however, any corrective actions that you deem

necessary should be implemented promptly.

In accordance with 10 CFR 2.790 of the NRC's " Rules of Practice," a copy of this letter

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and its enclosure will be placed in the NRC Public Document Roem.

The responses directed by this letter and the enclosed Notice are not subject to the

clearance procedures of the Office of Management and Budget as required by the

Paperwork Reduction Act of 1980, Pub. L. No. 96.511.

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Sincerely,

ORIGINAL SIGNED BY:

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Wayne D. Lanning

Deputy Director of Inspections

Special Projects Office, NRR

Docket Nos.

50-245

50-336

50-423

Enclosure:

NRC Combined Inspection Report 50-245/97-03; 50-336/97-03; and

50-423/97-03

ML20140C042

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