ML20154J926

Insp Rept 70-0371/88-03 on 880314-18.Violations Noted.Major Areas Inspected:Plan Implementing Procedures,Mgt Effectiveness,Organization.Program Audit,Records & Repts, Testing & Maint & Security Sys Power Supply

ML20154J926
Person / Time
Site:	07000371
Issue date:	05/17/1988
From:	Keimig R, Madden T, Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20154J906	List: ML20154J902 ML20154J916 ML20154J926
References
79-0371-88-03, 79-371-88-3, NUDOCS 8805270184
Download: ML20154J926 (8)

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U.S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 70-371/88-03 Docket No.70-371 License No. SNM-368 Licensee: UNC Incorporated UNC Naval Products 67 Sandy Desert Road Uncasville, Connecticut 06382 Facility Name: UNC Naval Products Inspection At: Uncasville, Connecticut Inspection Co ducted: March 14-18, 1988 Type of Inspec to : ' Routine Physical Security Inspectors: / A 17 Gh S. C. Smith, Sa g rds 4 e alist I dat/e T. P. Madden, Phy

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1 Security Inspector S//

1. da"te 88 Approved by: __e%cE*,$f 8 /3- M R. R. Ke1 M Tef Safeguards Section, date Division of Rad ion Safety and Safeguards Inspection Summary: Unannounced Physical Security Inspection on March 14-18, 1988 (Report No. 70-371/88-03)

Areas Inspected: Plan and Implementing Procedures; Management Effectiveness; Organization; Program Audit; Records and Reports; Testing and Maintenance; Locks, Keys and Combinations; Physical Barriers - Protected Areas; Physical Barriers - Material Access Areas; Security System Power Supply, t.ighting; Compensatory Measures; Assessment Aids; Access Control (Persor w., Packages and Vehicles); Detection Aids (Protected and Material Access Areas); Alarm Stations; Communications; Personnel Training and Qualifications; Safeguards '

Contingency Plan Implementation; Authorization for Access to National Security Information (NSI) and Restricted Data (RD); and Physical Protection and Safeguarding of NSI and RD.

Results: The licensee was in compliance with NRC requirements in the areas inspected with the following exception: failure to properly requalify members of the security organization in accordance with the requirements of the NRC-approved Training and Qualification Plan.

8805270184 880518 PDR ADOCK 07000371 C DCD

Details

1. Key Persons Contacted UNC

• R. Gregg, Director, Technical Services

• R. Gigliotti,. Director of Security R. Jason, Security Training Officer W. Ormeno, Security Operations Supervisor K. Nurmi, Security Shift Supervisor B. Gibson, Security Shift Supervisor M. Youngquist, Security Shift Supervisor E. Ezzel, Security Shift Supervisor C. Bowler, Security Shift Supervisor B. Taft, Security Shift Supervisor USNRC-NMSS W. Floyd, Security Specialist C. Gaskin, Project Manager R..Galloyos, Security Specialist The inspectors also interviewed employees of the licensee's contract security organization.

• present at exit interview 2 Security Plan and Implementing Procedures The inspectors reviewed the licensee's NRC-approved security plan (the Plan) and implementing procedures and confirmed that the procedures were

. consistent with the Plan'and were adequate to meet applicable regulatory requirements.

3. Management Effectiveness The inspectors observed that licensee management is involved in the security program and continues to be supportive of program requirements.

l The licensee has six proprietary Security Shift Supervisors that provide i around - the-clock oversight of the contract Security Force. The average l experience of the Security Shift Supervisors is in excessive of nine years.

The Security Shift Supervisors appear to provide effective oversight of the contract security force and interface between the security organization L

and the plant operations staff.

4. Security Organization l The inspectors reviewed the security force manning and determined there is

! a shortage that is resulting in a signifi ant amount of overtime being worked ~ in order to meet the manning comraitments contained in the Plan and 1

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3 to support major on-site construction activities. The shortage is apparently due to the extremely long time period to obtain U. S.

Department of Energy (DOE) clearances for new members of the security organization. The licensee and the NRC Office of Nuclear Material Safety and Safeguards (NMSS), in conjunction with 00E, are attempting to resolve this problem. The significant overtime has resulted in some morale problems in the security force; however, perfor..ance was determined to be at an acceptable level. The use of overtime and its effect on performance will continue to be monitored during future inspections.

5. Security Program Audi' The inspectors reviewed the security program audit reports for the past five years. The inspectors found that the scope of the audits were not always fully documented in the report, making it difficult, during a management review of the audit report, to determine the extent of the audit or whether all areas of interest were addressed. Additionally, the licensee's personnel who conducted these audits had little, if any, expertise in the area of security. The inspectors advised the licensee that even with a comprehensive audit plan, prepared by someone with expertise in the area being audited, the effectiveness of an audit is limited if the audit team lacks expertise, since only the areas specifically listed in the audit plan are reviewed and other potentially weak areas go unnoticed. The inspecto s also noted that when the management quality steering committee, which reviews the audit findings, does not accept (or fully accept) an audit response, disposition of the difference (s) is not tracked to final resolution, leaving the acceptability of the corrective action (s) unclear. While the foregoing weaknesses in the licensee's security audit program are not specifically contrary to licensee's cor.mitment in the Plan, the inspectors advised the licensee to consider remedial actions in order to strengthen the-effectiveness of the audit program.

6. Records and Reports The inspectors reviewed the following: Protected Area Visitor Access Control Register and Duty Logs for the wriod Dec2mber,1987 through March, 1988; Security Incident Reports; testing and maintenance records generated since the last inspection; and records of locks, keys and combination changes for 1987 and for 1988, to date. All records and reports were found to be well maintained and completed in accordance with the Plan and its implementing procedures.

7. Testing and Maintenance The inspectors reviewed the testing and maintenance records and procedures for the intrusion detection system, x-ray machines, metal detectors, explosives detectors, and assessment aids. No discrepancies were identified relative to either the records or procedures.

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8. Locks, Keys, and Combinations The inspectors reviewed the installation, storage, rotation, and associated records for all locks, keys, and combinations. No deficiencies were identified.

9. Physical Barriers - Protected Areas The inspectors observed all physical barriers that fcrm the protected area perimeter and found that the barriers were installed and maintained in conformance with the Plan.

10. Physical Barriers - Material Access Areas The inspectors observed the interior and exterior barrier features of the Material Access Areas and found that they were installed and maintained in accordance with the Plan.

11. Security System Pcwer Supply System The inspectors reviewed the uninterruptible power supply for security equipment and determined that the system functioned and was maintained as committed in the Plan. The inspectors found that the equipment was tested ,

under no-load cenditions weekly. However, annual load tests, were not formally documented, even though evidence was produced to indicate that the equipment had operated under load at least once a year. The licensee agreed to document future annual load tests in a more formal fashion. During the course of the inspection, the licensee demonstrated, by conducting a load test, that the equipment was capable of powering all security-related systems during a power failure.

12. Lighting The inspectors requested and observed the lighting within the protected l area from 6:30 p.m. to 7:30 p.m. on March 16, 1988. All areas selected were found to be lighted to a minimum of 0.2 foot-candle, using the ,

licensee's measuring equipment, except for six small areas within the l

isolation zone which, although below 0.2 foot-candle, were adequately lighted to assess activities in the areas, at the time of the inspection.

In one area where the lighting was below 0.2 foot-candle, the inspectors determined that the insufficient lighting was because a structure had been constructed in front of the light intended to illuminate the area, and effectively blocked the available light. All areas of insufficient lighting (less than 0.2 foot-candles) within the protected area were identified to the licensee by the inspectors. Since the licensee does not specifically commit to 0.2 foot-candle of illumination in the Plan and this is an NRC requirement, the matter is considered unresolved and will be forwarded to NRC's Office of Nuclear Material Safety and Safeguards (NMSS) for evaluation. (70-371/88-03/01) ,

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~13 . Compensattr, Meas'ures The inspectors observed the implementation of compensatory measures being utilized in conjunction with an on going major construction project inside the protected area. The measures were-found to be i.1 conformance with the Plan and the licensee'c implementing procedures.

14. Assessment Aids The inspectors observed the various methods of alarm assessment used by the licensee and confirmed that they were in conformance with the Plan.

15. Access Control-Personnel And Packages The inspectors reviewed the personnel and package access control procedures and determi ad them to be as committed to in the Plan. This determination was made by observing personnel access processing during shif t change, visitor access processing, and discussions with licensee i

and Security Personnel about package search procedures.

However, the inspectors noted a unique problem resulting from a conbination of facility configuration and Department of Energy (DOE) badging requirements. The facility is configured so that the personnel section is within the main administration building, which also houses the accesss control facilities and protected area portals, yet is outside of the protected area. DOE requires each individual who works within the administration building, both inside and outside of the protected area, to be badged. Badges are not issued until individuals have passed the random search generators which determine if an individual is required to be searched. As a result, employees who work in the personrel section complete normal-access processing at the beginning of each work period, receive their badges, then proceed to their offices, which are located outside of the protected area. In proceeding to their offices, employees of the personnel section have the opportunity to commingle with personnel who are entering the plaat and have not yet been processed for facility access. Also once they are badged, they are not required to undergo access controls (thereby avoiding random search) prior to re-entering the

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protected area, unless they physically leave the administration

-building. This is also true for plant employees who work within the protected area and have bus ness with employees in the personnel section, i.e., they leave the protected area to enter the personnel section offices and return to the protected area without undergoing access controls.

The inspectors noted that this practice appeared to increase the potential for the introduction of contraband on the site. The 1:censee '

committed to the inspectors that all personnel who leave the protected area will be subject to search upon re-entry, on a random basis, ia .

accordance with existing license requirements. *

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16. Access Control - Vehicles The inspectors reviewed the vehicle access control procedures and determined that they were as committed to in the Plan. This determination was made by observing vehicles being processed through the main and contractor access control points.

17. Detection Aids - Protected Area The inspectors observed walk-through penetration tests of 100% of the licensee's intrusion detection system that were conducted on March 16, 1938.

Test results confirmed that operation of the system was in accordance with the Plan and the licensee's implementing procedures.

18. Detection Aids - Material Access Areas The inspectors observed the licensee conduct tests of several different alarmed portal barriers in the Material Access Areas on March 15 and 16, 1988. The alarms that were tested performed as intended, and were in conformance with the Plan and its implementing procedures.

19. Alarm Stations The inspectors confirmed that the Central Alarm Station (CAS) and Secondary Alarm Station (SAS) operators were performing their duties consistent with commitments in the Plan and its implementing procedures.

Effective command and control practices were evident in support of inspector requested response tests conducted during the inspection.

The inspectors also observed tests of all duress alarms and confirmed that they performed as intended.

20. Communications The inspectors monitored radic voice transmissions among the CAS operators, the SAS operators, and other members of the security organization and observed tests of equipment for offsite communications.

l The inspectors confirmed that equipment and alarm station operator l performance were in accordance with the Plan and the implementing proceoures.

I 21. Personnel Training and Qualifications I

The inspectors reviewed the licensee's Training and Qualification Plan (T&QP) and its implementation. The inspectors determined that training was conducted in accordance with the T&QP with the following exceptions.

The T&QP requires that all guards receive a physical fitness test within 30 days of a physical exam at least every 12 months. There is a provision in the T&QP that, if a guard is unable to take the fitness test because of a physical incapacitation, a wavier will be granted until the l

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7 guard is in condition to take the test. For initial employment only, if the physical fitness test is waived, the Security Training Officer and Corporate Security Director must concur that the inability to perform one or more portions of the fitness test would not interfere with the guard's ability to carry out his/her duties. Review of the guard force requalification records disclosed that the annual physical fitness test for one guard, who was not a new hire, had been waived for medical reasons.

While not a commitment in the NRC-approved T&QP, there was no documentation that an e ,oation had been performed to detarmine whether the medical incapacitation would impact upon the guard's ability to carry out his duties, that the Training Officer and the Security Director had concurred in the waiver or whether there were any restrictions on the duties to which the guard could be assigned. Further review disclosed tnat no restrictions had been placed on tasks which could be assigned and that

, the individual was assigned as a member of the armed response teau during the period he was deemed medically unable to perform the physical fitness test. The practice of waiving the regulatory required annual physical fitness test for an individual and then placing no restrictions on duties allowed to be performed is not adequately addressed in the-NRC-approved T&QP and is contrary to good security practice. This is an l unresolved item and is being referred'to NRC-NMSS for evaluation.

l (70-371/88-03-02)

The inspectors further determined that the T&QP requires that, at intervals not to exceed every 12 months, guards / watchmen will requalify I to insure they are capable of performing assigned tasks. A written requalification test is used and, based on the results of that test, individuals are reinstructed in areas shown deficient by the test.

One of the topics required by the training program is "Non-Lethal Weapons - Self Defense". The inspectors' review disclosed that this topic was not addressed on the requalification test. This topic and its subsets (Chemical Agents - Offense / Defense, Baton - Offense / Defense, Handcuffs, and Self Defense-Unarmmed) are generally considered to require a practical demonstration to determine proficiency and are not well l evaluated by a written test. The inspectors found that, in addition to I not being addressed on the raqualification test, there was no practical l requalification conducted on this topic within the 12 months proceeding this inspection. Failure of the licensee to meet commitments contained l

in the NRC-approved T&Q Plan is an apparent violation of NRC requirements. (70-371/88-03-03). .

22. Contingency Plan Implementation The inspectors reviewed the Security Contingency Plan and determined that its provisions were implemented as committed to in the Plan.

23. Authorization for Access to National Security Information (NSI) and Restricted Data (RD)

The inspectors examined the licensee's program for granting access to NSI d

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and RD. The program was determined to be in compliance with the requirements of 10 CFR 25. All access records were properly completed and terminations were handled as _specified by the regulation.

24. Physical Protection Facility Approved and Safeguarding of National Security Information (NSI) and Restricted Data (RD).

The inspectors reviewed the licensee's facility approval and determined-that it was documented in a letter from the NRC and was implemented by an_NRC-approved facility security plan. The inspectors determined that classified materials were being safeguarded as required by 10 CFR 95. No discrepancies were noted.

25. Unresolved Items An unresolved item is one about which more information is required in order to ascertain whether it is acceptable or a violation of NRC requirements. An unresolved item is identified in paragraphs 12 and 21.

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Exit Interview The inspectors met with licensee representatives indicated in paragraph 1 at the conclusion of the inspection on March 18, 1987, and summarized the scope and findings of the inspection. <

At no time during the inspection was written material provided to the licensee.

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