ML20216F908

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Insp Rept 50-271/98-05 on 980316-19.Violations Noted.Major Areas Inspected:Selective Exam of Procedures & Representative Records,Interviews W/Personnel,Performance Tests of Security Equipment & Observations by Inspectors
ML20216F908
Person / Time
Site: Vermont Yankee File:NorthStar Vermont Yankee icon.png
Issue date: 04/13/1998
From: Modes M
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20216F843 List:
References
50-271-98-05, 50-271-98-5, NUDOCS 9804170275
Download: ML20216F908 (10)


See also: IR 05000271/1998005

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Docket No:

50-271

License No:

DPR-28

Report No:

50-271/98-05

Licensee:

Vermont Yankee Nuclear Power Corporation

Facility:

Vermont Yankee Nuclear Power Station

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Location:

Vernon, Vermont

Dates:

March 16-19,1998

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Inspectors:

Paul R. Frechette, Physical Security inspector

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Edward B. King, Physical Security inspector

David N. Orrik, Security Specialist, NRR

Ronald J. Albert, Security Specialist, NRR

Approved by:

Michael M. Modes, Chief

Emergency Preparedness and Safeguards Branch

Division of Reactor Safety

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EXECUTIVE SUMMARY

Vermont Yankee Nuclear Power Station

NRC inspection Report 50-271/98-05

in general, the licensee maintained a satisfactory program. Management support is

ongoing as evidenced by adequate manning levels to permit effective program

implementation and some recent security equipment enhancements. Audits were thorough

and in-depth, event logs are being trended and analyzed quarterly, and security equipment,

with the exception of the intrusion detection system (IDS), was being tested and

maintained in accordance with the NRC-approved physical security plan (the Plan).

Performance testing of the IDS, by the regional assist team, resulted in the assist team

successfully gaining undetected access into the protected area (PA) by climbing over the

protected area barrier (PAB) without generating an alarm in six of ten zones. This resulted

in a violation of NRC requirements associated with the protected area intrusion detection

system.

During performance testing of the personnel and package search equipment, a second

violation of NRC requirements associated with access controls of personnel and packages

was identified. Specifically, a test device (concealed in a backpack) was introduced into

the search train by the regional assist team with the licensees knowledge, and was not

detected by the security force member that performed a physical search of the backpack.

As an enhancement to the inspection, Section 6.1 of the Plan, titled "lllumination," was

reviewed. The inspectors determined, by observing the performance of a lighting survey

by security personnel using a calibrated light meter, that the licensee was implementing its

lighting program as required in the Plan.

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Report Details

S1

Conduct of Security and Safeguards Activities

a.

Inspection Scope (81700)

Determine whether the conduct of security and safeguards activities met the

licensee's commitments in the NRC-approved security plan (the Plan) and NRC

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regulatory requirements. The security program was inspected during the period of

March 16-19,1998. Areas inspected included: access authorization program;

alarm stations; and protected area access control of personnel and packages.

b.

Observations and Findinas

Access Authorization Proaram. The inspectors reviewed implementation of the

Access Authorization (AA) program to verify implementation was in accordance

with applicable regulatory requirements and Plan commitments. The review

included an evaluation of the effectiveness of the AA procedures, as implemented,

and an examination of AA records. Records reviewed included both persons who

had been granted and had been denied access. The AA program, as implemented,

provided assurance that persons granted unescorted access did not constitute an

unreasonable risk to the health and safety of the public. Additionally, the inspectors

verified by reviewing access denial records and applicable procedures, that

appropriate actions were taken when individuals were denied access or had their

access terminated which included a formalized process that allowed the individuals

the right to appeal the licensee's decision.

Alarm Stations. The inspectors observed operations in both the Central Alarm

Station (CAS), and the Secondary Alarm Station (SAS). This observation included

alarm response, and interviews with the, alarm station operators. The alarm stations

were equipped with appropriate alarms, surveillance and communications

capabilities and were continuously manned by knowledgeable operators. No single

act could remove the plants capability for detecting a threat and calling for

assistance because the alarm stations were sufficiently diverse and independent.

The CAS did not contain any operational activities that could interfere with the

execution of the detection, assessment and response functions.

Protected Area (PA) Access Control of Personnel and Hand-Carried Packaaes. On

March 18,1998, the regional assist team conducted testing of the metal detectors

and x-ray machines located at the protected area access building. These tests were

conducted using a licensee test device. These performance tests indicated that

licensee search equipment was performing in accordance with Plan commitments.

In addition, the test device, with the consent of licensee security representatives,

was placed in a backpack containing other articles, and placed on the x-ray

machine. The x-ray machine detected an object in the backpack that could not be

identified and the backpack was physically searched by a security force member

(SFM). However, the test device was not discovered during the physical search.

The licensee's failure to detect the test device is a violation of NRC requirements

(VIO 50-271/98-05-01). With the exception of the above noted violation, positive

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controls were in place to ensure only authorized individuals were granted access to

the PA. All personnel and hand carried items entering the PA were properly

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searched and the last SFM controlling access to the PA was in a position to perform

this function effectively.

c.

Conclusions

The licensee was conducting its security and safeguards activities in a manner that

protected public health and safety and that this portion of the program, as

implemented, with the exception of the noted violation, met both the licensee's

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commitments and NRC requirements.

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Status of Security Facilities and Equipment .

a.

Insoection Scope (81700)

' Areas inspected were: Testing, maintenance and compensatory measures; PA

detection aids and PA assessment aids.

b.

Obse vations and Findinas

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Testina. Maintenance and Compensatorv Measures. The inspectors reviewed

testing and maintenance records for security-related equipment and found that

. documentation was on file to demonstrate that the licensee was maintaining, and

with the exception of the protected area intrusion detection system, testing

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 within

the same day a work request necessitating compensatory measures was generated.

The inspectors reviewed security event logs and maintenance work requests

generated over the last year. These records indicated that the need for

compensatory measures was extremely minimal. When necessary, the licensee

implemented compensatory measures that did not reduce the effectiveness of the

security system as it existed prior to the need for the compensatory measure.

PA Detection Aids. On March 17,1998, the inspectors observed performance

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testing of the perimeter intrusion detection system (PlDS) at the protected area

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barrier (PAB). The testing, performed by the regional assist team, resulted in the

assist team successfully gaining undetected PA access I.y climbing over the PAB

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without generating an alarm in six of ten zones. The PIDS failure to detect climbing

as a means of gaining undetected access into the PA is a violation of the NRC-

aproved security plan (VIO 50-271/98-05-02). The licensee implemented

compensatory measures for.the identified failures.

Assessment Aids. On March 17,1998, the inspectors evaluated the effectiveness

of the assessment aids, by observing on closed circuit television (CCTV), a

walkdown of the PA by members of the regional assist team. This walkdown was

accomplished by individuals on both the inside and outside of the PAB. The

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walkdown was observed under both daylight and lowlight conditions. The camera

view, overlap and picture quality were very good. Additionally, to ensure Plan

commitments are satisfied, the licensee has procedures in place requiring the

implementation of compensatory measures in the event the alarm station operator is

unable to properly assess the cause of an alarm.

c.

Conclusions

The licensee's security facilities and equipment were determined to be well

maintained and reliable, with the exception of the noted violation, and were able to

meet the licensee's commitments and NRC requirements.

S3

Security and Safeguards Procedures and Documentation

a.

Insoection Scone (81700)

Areas inspected were: implementing procedures and security event logs.

b.

Observations and Findinas

Security Proaram Procedures. The inspectors verified that the procedures were

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consistent with the Plan commitments, and were properly implemented. The

verification was accomplished by reviewing selected implementing procedures

associated with PA access control of personnel and testing and maintenance of

personnel search equipment. However, it was determined that the procedure

associated with testing of the PIDS was inconsistent with Plan commitments,in

that the Plan indicates that the PIDS was designed to detect climbing, cutting and -

crawling. The testing procedure contained no criteria associated with climbing as a

means for detecting an intrusion.

Security Event Loos. The inspectors reviewed the Security Event Log for the

previous 12 months. Based on this review, and discussion with security

management, it was determined that the licensee appropriately analyzed, tracked,

resolved and documented safeguards events.

c.

Conclusions

' Security and safeguards procedures and documentation, with the exception of the

IDS testing element noted above, were being properly implemented. Event Logs

were being properly maintained, and effectively used to analyze, track, and resolve

safeguards events.

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Security and Safeguards Staff Knowledge and Performance

a.

Inspection Scooe (81700j

Areas inspected were security staff requisite knowledge and response capabilities.

b.

Observations and Findinas

Security Force Reauisite Knowledae. The inspectors observed a number of SFMs in

the performance of their routine duties. These observations included alarm station

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operations, personnel and package searches, and visitor processing. Additionally,

the inspectors interviewed SFMs and security management. Based on all of the

above activities, it was determined that the SFMs were knowledgeable of their

responsibilities and duties, and could effectively carry out their assignments.

F.esponse Caoabitities. On March 18,1998,the regional assist team conducted

three table-top time line drills, with security supervision. The drills were developed

by using the target sets developed and refined by the licensee since the 1994'

. Operational Safeguards Response Evaluation (OSRE). The benchmark for the drills

was the NRC design basis threat. The criteria used by the regional assist team to

determine response capability were; can the licensee: (1) provide a sufficient

number of responders, (2) appropriately armed, (3) in protected fighting positions,

and (4) in time to interdict armed intruders. ' The licensee's protective strategy was

based on the minimum requirements as noted in the Plan. The inspectors

determined by observation and discussions with the regional assist team and

- security supervision, that the licensee's ability to defend against the design basis

threat is adequate.

c.

. Conclusions

The SFMs adequately demonstr' ated that they have the requisite knowledge

necessary to effectively implement the duties and responsibilities associated with

their position.

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Security Organization and Administration

a.

Inspection Scone (81700)

Areas inspected were management support, effectiveness and staffing levels.

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Observations and Findinas -

Manaaement Sucoort. The inspectors reviewed various program enhancements

made since the last program inspection to determine the level of management

support. These enhancements included the allocation of resources for the

procurement of two new x ray machines to enhance package search, ten new

radios to enhance communication capabilities and rolling mirrors to enhance vehicle

search capabilities.

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Manaaement Effectiveness. .The inspector reviewed the management organizational

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structure and reporting chain. ' The Security Manager's position in the organizational

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structure provides a means for making senior management aware of programmatic

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needs. Senior management's positive response to requests for equipment, training

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and resources in general have contributed to the effective administration of the

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security program.

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Staffina Levels. The inspectors verified that the total number of trained SFMs

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immediately available on shift met the requirements specified in the Plan.

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c.

Conclusions

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The level of management support was adequate to ensure effective implementation

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of the security program, and was evidenced by adequate staffing levels and the

allocation of resources to support programmatic needs.

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Quality Assurance in Security and Safeguards Activities

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a.

Insoection Scope (81700)

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Areas inspected were: audits, problem analyses, corrective actions and

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effectiveness of management controls.

b.

Observations and Findinas

Audits. The inspectors reviewed the 1997 QA audit of the security program,

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conducted October 20- 31,1997,(Audit No. 97-04). The audit was conducted at

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' the frequency specified in the Plan. To enhance the effectiveness of the audit, the

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audit team included an independent technical specialist.

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The audit report identified two event reports and five recommendations. The

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findings were associated with improper transfer of custodianship of Safeguards

repositories and controls for long term storage of security records. The inspectors

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determined that the findings were not indicative of programmatic weaknesses, and

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the findings would enhance program effectiveness. _ inspectors' discussions with

security management revealed that the responses to the findings were completed,

and the corrective actions were effective.

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Additionally, the inspectors reviewed the responses to the 1997 combined audit of

the fitness-for-duty (FFD) and access authorization (AA) programs, (Audit No. 97-

19). During the previous security inspection conducted in May 1997, the responses

to the audit were not finalized, and it was noted that the responses would be

reviewed during a subsequent inspection. The inspectors determined that the

responses to the findings were completed and the corrective actions effective.

Problem Analvses. The inspectors reviewed _ data derived from the security

department's self-assessment program. Potential weaknesses were being properly

identified, tracked, and trended.

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Corrective Actions. The inspectors reviewed corrective actions implemented by the

licensee in response to the QA audits and self-assessment programs. The

corrective actions were effective, as evidenced by a reduction in personnel

performance issues and loggable safeguards events.

Effectiveness of Manaaement Controls. The inspectors observed that the licensee

has a program in place which was effective in identifying, analyzing and resolving

problems. The corrective actions taken by the licensee, in response to audit

findings were adequate and should prevent recurring problems.

c.

Conclusions

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The review of the' licensee's audit program indicated that the audits were

comprehensive in scope and depth, that the audit findings were reported to the

appropriate level of management, and that the program was being properly

administered.

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Exit Meeting Summary

The inspectors met with licensee representatives at the conclusion of the inspection on

March 19,1998. 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.

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Review of Updated Final Safety Analysis Report (UFSAR)

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 inspectors compared licensee

activities to the NRC-approved physical security plan, which is the applicable document.

While performing the inspection discussed in this report, the inspectors reviewed the

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licensees Plan commitments in Section 6.1, titled "lliumination." The inspectors

determined, by observing the performance of a lighting survey by security personnel, using

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a calibrated light meter, that the licensee was implementing its lighting program in

accordance with the Plan.

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PARTIAL LIST OF PERSONS CONTACTED

LICENSEE PERSONNEL

Gregory Morgan

Security Manager

John Moriarity

Security Operations Specialist

Gary Sherer

Security Operations Supervisor

Ed Wright

Project Manager, TWC

John Jasinski

Security Training Supervisor, TWC

Frank Helin

Tech. Services Superintendent

U. S. NUCLEAR REGULATORY COMMISSION - REGION I

William Cook

Senior Resident inspector

Paul Frechette

Security inspector

Edward King

Security and EP specialist

U. S. NUCLEAR REGULATORY COMMISSION-HEADOUARTERS

David Orrik

NRR

Ronald Albert

NRR

John MacPhee

USNRC - Contractor

Marc Eckard.

USNRC - Contractor

Anthony Qualantone USNRC - Contractor

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INSPECTION PROCEDURES USED

IP 81700:

Physical Security Program for Power Reactors

LIST OF ACRONYMS USED

-AA

access authorization

CCTV

closed circuit television

FFD

fitness for duty -

SFM

security force members

QA

quality assurance

the Plan

NRC-approved physical security plan

PA

protected area

PAB

protected area barrier

PIDS

perimeter intrusion detection systems

CAS

central alarm system

SAS

secondary alarm system

OSRE

operational safeguards response evaluation

UFSAR

Updated Final Safety Analysis Report

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