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Insp Rept 50-382/99-08 on 990405-07.One Apparent Violation Noted & Being Considered for Escalated Eas.Major Areas Inspected:Plant Support Including Licensee Access Authorization Program
	ML20206F480
Person / Time
Site:	Waterford
Issue date:	05/03/1999
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20206F473	List: ML20206F470; ML20206F480;
References
	50-382-99-08, 50-382-99-8, NUDOCS 9905060144
	Download: ML20206F480 (8)
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ENCLOSURE

U.S. NUCLEAR REGULATORY COMMISSION

REGION IV

Docket No.: 50-382

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License No.: NPF-38

Report No.: 50-382/99-08

Licensee: Entergy Operations, Inc.

Facility: Waterford Steam Electric Station, Unit 3

- Location: Hwy.18

Killona, Louisiana

Dates: April 5-7,1999

Inspector (s): A. Bruce Earnest, Physical Security Specialist,

Plant Support Branch

Approved By: Gail M. Good, Chief, Plant Support Branch

Division of Reactor Safety

Attachment : Supplemental Information

9905060144 990503

PDR ADOCK 05000382

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EXECUTIVE SUMMARY

Waterford Steam Electric Station, Unit 3

NRC Inspection Report No. 50-382/99-08

A reactive, announced inspection of the licensee's access authorization program was

conducted.

Plant Sucoort

An apparent violation was identified involving the licensee's failure to review and ,

consider derogatory information during a background investigation as required by

Paragraph 2.3.1 of the physical security plan and Paragraph 6.8.1 of Entergy Corporate

Security Departmental Procedure CS-DP-104, Revision 0. The licensee's failure to

review and consider the information allowed temporary unescorted access to an

individual who would not have been granted unescorted access (Section S1.1). i

' A violation was identified for failure to notify the NRC within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of discovery of a

significant access authorization event as required by 10 CFR Part 73.71 (b)(1) and

Attachment 7.1 to Security Procedure PS-010-104, " Security Reporting Requirements,"

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Revision 13. This issue was entered into the licensee's corrective action system as part

of Condition Report CR-WF-3-1999-0420. This Severity Level IV violation is being

treated as a non-cited violation in accordance with Appendix C of the NRC Enforcement

Policy (Section S3.1).

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Report Details

IV. Plant Suncort

S1' Conduct of Security and Safeguards Activities

- S1.1 Access Authorization

a. Inspection Scope (81700)

The access authorization program was inspected to determine compliance with the

requirements of 10 CFR 73.56, the physical security plan, and Regulatory Guide 5.66.

The inspector reviewed 25 background investigation files. The reviewed files included:

five files for reinstatement, five files for full background investigations, three files of

personnel who were grandfathered into the program, two files for updates, and ten files

that resulted in denial of access. The inspector reviewed information involving the

licensee's verification of identity, employment history, educational history, credit histoty, a

criminal history, military service, and the character and reputation of the applicants

before granting individuals' unescorted access to protected and vital areas.

b. Observations and Findinos

The files were generally thorough with one significant exception. On March 23,1999,

the licensee notified the NRC that a contractor employee had been erroneously granted

temporary unescorted access. The licensee's report confirmed that the access

authorization staff had completed an inadequate evaluation of the available background

investigation information.

Paragraph 2.3.1 of the licensee's physical security plan required that the licensee

comply with all elements of Regulatory Guide 5.66, " Access Authorization Program for

Nuclear Power Plants."

Paragraph 7.1 of the Appendix to Regulatory Guide 5.66 dated June 1991 (NUMARC

89-01) required that in its decision to grant unescorted access, the licensee shall review

and consider ali information obtained during a background investigation in making a

determination of trustworthiness and reliability. Paragraph 7.1a required the licensee to

review and consider willful omission or falsification of material information submitted in

support of employment or request for unescorted access authorization. Paragraph 7.1b

required the licensee to review and consider illegal use or possession of a controlled

substance or abuse of alcohol without adequate evidence of rehabilitation.

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Paragraph 6.8.1 of Entergy Corporate Security Departmental Procedure CS-DP-104, !

Revision 0, stated that the licensee's decision to grant unescorted access authorization

shall be based upon a review of allinformation developed during the completion of a

background investigation and psychological evaluation. Further, Paragraph 6.8.1 stated

that when derogatory information is developed, it must be compared against the

individual's prescreening documents for possible omissions and falsifications, in

addition, Paragraph 6.8.3 stated that the licensee must consider illegal use or

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possession of a controlled substance or abuse of alcohol without adequate evidence of

rehabilitation.

During the processing of the contractor's request for unescorted access on February 18,

1999, the access authorization technician did not review the temporary unescorted

access background investigation. The background investigation report contained

information indicating that the contractor employee had tested positive for a controlled

substance when applying for employment at a nonnuclear company on October 27,

1998. The personnel history questionnaire submitted by the contractor employee did

not list this information in the section that asked, "Have you ever tested positive for

drugs or alcohol?"

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Prior to reviewing the background investigation, a licensee access authorization

technician noticed that the licensee's fitness-for-duty test results had not been included

in the access authorization file. The technician placed the paper work into a suspense

file pending receipt of the fitness-for-duty test. Prior to determining that the - !

fitness-for-duty test result was missing, the technician dated and initialed that the i

individual was eligible for temporary unescorted access. The technician failed to

remove this certification when the file was placed into the suspense file. The

fitness-for-duty test result was received on February 23,1999. That same date, a

second access authorization technician reviewed the drug' screen results without

completing a review of the background investigation. The second technician assumed

that the first technician had reviewed the information, since that block on the access

authorization request form was dated and initialed. The access authorization file was

then forwarded to the Deputy Director of Corporate Security (who was on site to assist

with access authorization during the outage) for approval to grant unescorted access.

The Deputy Director made the same assumption and did not review the background

investigation that contained the derogatory information. Three access authorization

personnel failed to review information that would have resulted in a denial of access

authorization. The contractor employee was granted temporary unescorted access on

February 23,1999.

The licensee received the last piece of the background information (military records)

required for a permanent unescorted access authorization on March 22,1999. At this

time, a third access authorization technician reviewed the file for permanent unescorted

. access and identified the derogatory fitness-for-duty information. The licensee

immediately revoked the contract employee's access and conducted an investigation.

When questioned, the contractor employee admitted that the failed fitness-for-duty test

information was omitted. The failure to perform an adequate review of available

background information such that a contractor employee was erroneously granted

unescorted access is an apparent violation of Paragraph 2.3.1 of the physical security

. plan and Paragraphs 6.8.1,6.8.2 and 6.8.3 of Licensee Procedure CS-DP-104

(50-382/9908-01).

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The licensee's corrective actions included immediate retraining and counseling of the

access authorization personnel who were involved in the failure to review and consider

the information, in addition, all licensee access authorization personnel were retrained

prior to the completion of the inspection. The licensee also planned to brief and train all

Entergy access authorization personnel on the incident during annual training. Prior to

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the end of the inspection, the licensee initiated a revision to Entergy Corporate Security

Departmental Procedure CS-DP-104, Revision 0, to strengthen the requirements

involving the review of all background information. Finally, the access authorization staff

reviewed approximately 800 access authorization files. There were no further examples

of the failure described above.

c. Conclusions

An apparent violation was identified involving the licensee's failure to review and

consider derogatory information during a background investigation as required by

Paragraph 2.3.1 of the physical security plan and Paragraph 6.8.1 of Entergy Corporate

Security Departmental Procedure CS-DP-104, Revision 0. The licensee's failure to

review and consider the information allowed temporary unescorted access to an

individual who would not have been granted unescorted access.

S3 Security and Safeguards Procedures and Documentation

'S.3.1 Safeauards Event Reoortability

a. Insoection Scope (81700)

The inspector reviewed the first quarter 1999 safeguards event logs and the records

associated with a 1-hour notification call made to the NRC on March 23,1999,

b. Observations and Findinas

Attachment 7.1 to Security Procedure PS-010-104, " Security Reporting Requirements,"

Revision 13, stated in Item 30 that a .1-hour report will be made to the NRC for an

access authorization event which reflects a program failure (such as a failure to evaluate i

available information which results in a clearly unjustifiable granting of unescorted -

access).

On March 22,1999, the licensee discovered that an individual had erroneously gained

unescorted access to the protected and vital areas on February 23,1999. Due to a

communication problem, the access authorization supervisor and the plant security

superintendent failed to recognize that the incident was required to be reported within

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The event was initially placed into the safeguards event log on March 22,1999.

After additional information was received and reviewed on March 23,1999, the security

superintendent made the 1-hour report to the NRC. The security superintendent and

the access authorization supervisor implemented effective immediate correction actions

that included training of applicable personnel. The issue was entered into the licensee's

corrective action system as part of Condition Report CR-WF3-1999-0420. The

licensee's failure to report the incident to the NRC within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months was identified as a

violation of 10 CFR Part 73.71 (b)(1) and licensee Procedure PS-010-104. This Severity

Level IV violation is being treated as a non-cited violation consistent with Appendix C of

the NRC Enforcement Policy (50-382/9908-02).

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c. Conclusion

A violation was identified for failure to notify the NRC within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months of discovery of a

significant access authorization event as required by 10 CFR Part 73.71(b)(1) and

Attachment 7.1 to Security Procedure PS-010-104, " Security Reporting Requirements,"

Revision 13. This issue was entered into the licensee's corrective action system as part

of Condition Report CR-WF-3-1999-0420. This Severity Level IV violation is being

treated as a non-cited violation in accordance with Appendix C of the NRC Enforcement

Policy.-

V. Manaaement Meetinas

X1 Exit Meeting Summary

The inspector presented the inspection results to members of licensee management at

the conclusion of the inspection on April 7,1999. A followup discussion of the ,

inspection results was conducted with members of the licensee staff on April 22,1999.

The licensee acknowledged the findings presented.

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ATTACHMENT {

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SUPPLEMENTAL INFORMATION

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PARTIAL LIST OF PERSONS CONTACTED

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C. Dugger, Vice President, Operations

E. Aviles, Coordinator, Nuclear Security

E. Beckendorf, Superintendent, Plant Security

M. Brandon, Licensing Supervisor

E. Brauner, Systems Engineering Superintendent

R. Burski, Director, Site Support

G. Bourgeois, Quality Assurance Specialist j

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D. Childress, Supervisor, Security Access Authorization and Fitness-for-Duty

H. Cooper, Manager, Corporate Security

C. DeDeauz, Licensing Supervisor

D. Gallodoro, Engineering Supervisor ,

P. Gropp, Manager, Design Engineering l

A. Harris, Plant Engineering Manager i

G. Matharn, Design Engineering Supervisor !

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J. Meibaum, Systems Engineer

P. Melancon, Programs Engineering Supervisor

G. Pierce, Director, Quality ,

D. Pintado, Security Nuclear Coordinator !

R. Putnam, Design Engineering Supervisor

L. Rushing, Manager, Mechanical Design Engineering

G. Scott, Licensing Engineer

H. Williams, Plant Security Superintendent, Arkansas Nuclear One

R. Williams, Licensing Engineer

D. Young, Licensing Engineer

G. Zetsch, Security Senior Lead Coordinator

Contractor

K. Hayes, Project Manager, The Wackenhut Corporation

A. Smith, Project Supervisor, The Wackenhut Corporation

NRC

T. Farnholtz, Senior Resident inspector

J. Keeton, Resident inspector

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l INSPECTION PROCEDURES USED

IP 81700. _ Physical Security Program for Power Reactors

ITEMS OPENED. CLOSED, AND DISCUSSED

Opened

50-382/9908-01 eel Inadequate Access Authorization

50 382/9908-02 NCV Failure to Report an Event Within Required 1-Hour Time Frame a

Closed

50-382/9908-02 NCV Failure to Report an Event Within Required 1-Hour Time Frame

PARTIAL LIST OF LICENSEE DOCUMENTS REVIEWED

Waterford 3 Physical Security Plan, Revision 18

Entergy Departmental Procedure CS-DP-104, " Unescorted Access Authorization," Revision 0 ;

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Security Procedure PS-010-104, " Security Reporting Requirements," Revision 13 j

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Security Procedure OM-106, " Unescorted Access Authorization Program," Revision 3 I

First Quarter,1999 Safeguards Event Logs

Twenty-Five Access Authorization Files

ML20206F480

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