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Partially Deleted Physical Security Insp Repts 50-245/87-22, 50-336/87-20 & 50-423/87-18 on 870831-0904 (Ref 10CFR2.790 & 73.21).Violations Noted.Major Areas Inspected:Plan & Implementing Procedure,Program Audits & Physical Barriers
	ML20235Z504
Person / Time
Site:	Millstone
Issue date:	09/29/1987
From:	Bailey R, Keimig R, Lancaster W, Madden T; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:	;
Shared Package
ML20235Z495	List: ML20235Z491; ML20235Z504;
References
	50-245-87-22, 50-336-87-20, 50-423-87-18, NUDOCS 8710210177
	Download: ML20235Z504 (13)
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. DESIG unTE0 ~

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ORIG itJ A L

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U. 8. NUCLEAR REGULATORY COMMISSION I

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REGION I ]

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Report Nos. 50-245/87-22 License Nos. DPR-21 Docket Nos. 50-245

50-336/87-20 DPR-65 50-336 1

50-423/87-18 NPF-49 50-423 l

Licensee: Northeast Nuclear Enercy Company

P. O. Box 270 l

j Hartford. Connecticut 06141-0270 ,

Facility Name: Millstone Nuclear Power Station. Units 1. 2. and 3

Inspection At: Waterford, Connecticut

Inspection Conducted: Aucust 31 - Seotember 4, 1987

Date of Last Physical Security Inspection: February 23-27, 1987

Type of Inspection: Routine Unannounced Physical Security Inspection

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Inspectors: -

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R. iley, cal rity Inspector date'

se ^:'-! -- - E9 /

T. Madden, Phy cal Seegrity Inspector datie

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Lancaster, Physical Security Inspector

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date

Approved By: M~ ~ 9

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R. R. Ifeimlg, Chit. , pfifeguards Section date

Inspection Summary: Routine unannounced Physical Security Inspection on

Aucust 33, 1987 (Combined Report Nos. 50-245/87-22; 50-336/87-20;

And 50-423/87-18)

Areas Inspected: Plan and Implementing Procedures; Organization; Program

Audits; Records and Reports; Testing and Maintenanc';e Physical Barriers

(Protected Area); Physical Barriers (Vital Areas); Lighting; Assessment

Aids (Protected Area); Access Control (Personnel); Access Control j

(Packages); Detection Aids (Protected Area); Alarm Stations; and Training {

and Qualifications. I

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EpstQtn: The licensee was not in compliance with the 14RL-approved Fhysical l

Security Plan or NRC Regulations in the following areas: Security

organization; Lighting; Testing and Maintenance; Assessment Aids

(Protected Area); Physical Barriers (Protected Area); Access Control 1

(Personnel); Physical Barriers (Vital Areas); and Detection Aids (Protected )

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8710210177 G71002

PDR ADOCK 0S000245

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DETAILS

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1. Kev Persons Contacted I

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a. Licensee and Contractor Personnel: ]

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'* S. Scace - Millstone Station Superintendent 1

H, Haynes - Millstone Station Service Superintendent .i

G. Hallberg - Corporate Nuclear Security Manager j

P. Weekly - Security Supervisor i

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R. Ayala - Station Services Engineer Supervisor

J.' Provencal - Station Services Engineer f

S. Roth - Chief of Security, Burns International l

t Security Services, Inc. j

L. Brown - Security Coordinator j

S. Horn - Security Captain, Burns International j

Security Services, Inc. {

b. U.S. Nuclear Reaulatory Commission Personnel:

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W. Raymond - NRC Senior Resident Inspector j

S. Barber - NRC Resident Inspector i

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Attended EXIT interview. l

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The inspectors also interviewed other licensee and contractor l'

security personnel.

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2. Manacement Effectiveness- !

As a result of some of the findings during this inspection, the I

inspectors questioned the licensee's disposition and

consideration of previously issued NRC-security related

Bulletins, Circulars, and Information Notices that were forwarded '

to all licensees operating nuclear power plants. Since the i

licensee did not have a listing of those documents, one is being

provided as Attachment # 1 to this report. The licensee's method '

of addressing the information contained in those documents will

be reviewed during future inspections of the security program.

J. Security Plan and Imolementina Procedures

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The inspectors met with licensee representatives and discussed l

the NRC-approved Physical Security Plan (the Plan). As a result i

of these discussions, inspection, and a review of the Plan, it l

was determined that:

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(a) no changes have been submitted to the NRC since the last

physical security inspection;

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, (b) changes, to incorporate the revisions required by the !

miscellaneous amendments codified by the NRC on August 4, .

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1986, were submitted as required and are currently under-

review by NRR; and

(c) only one controlled copy of the Plan reviewed by the

inspectors on-site was current; e.g., the most recent change

to the Plan had not been incorporated into the Security

Supervisor's copy and the copy assigned to the Security 1

Shift Supervisors had not been updated for several years and

was no longer considered a. viable document by the

inspectors.

All security personnel interviewed, both licensee and security

contractor, demonstrated familiarity with security Plan

Implementing Procedures, however, only the Security Supervisor is

fully conversant with NRC-performance objectives.

4. Security Organization

The inspectors reviewed the Plan to determine if the licensee was

in compliance with Chapter 3 (Security organization). In

addition, the inspectors reviewed the official Millstone Station

Organizational Charts, dated July 7, 1987, and interviewed the l

Security Supervisor, Corporate Nuclear Security Manager, and I

various security-contractor personnel.

In January, 1986, Millstone Station submitted Figure 3.2 to the l

NRC as a 10 CFR 50.54(p) change to the Plan. Upon accepting this j

change, the NRC fully expected the security organization to be )

structured as depicted on Figure 3.2. Figure 3.2 shows three j

positions reporting directly to the Security Supervisor, i.e., j

the Contractor Security Chief, the Security Administrative l

Assistant and the Security Operations Assistant. The existing l

organization has sixteen positions reporting directly to the

Security Supervisor, in addition to the contract security force,

and does not have a Security operations Assistant position.

Additionally, while there is an individual functioning as a

Security Administrative Assistant, that position is not i

recognized nor are its duties and responsibilities defined.

Failure of the organizational structure to be as depicted in the

Plan is an apparent violation of NRC requirements. (50-245/87-

22-01; 50-336/87-20-01; 50-423/87-18-01)

The inspectors questioned the span of control .ssigned to the

Security Supervisor under the present structure. The licensee

acknowledged the inspectors question and stated that the matter

would be evaluated and corrected.

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5. Security Procram Audit

The inspectors reviewed security program audit reports and

verified that the audits had been conducted in accordance with

the Plan and that the reports were being retained on file for a

period of five years. The review included the response of the

security organization to the audit findings and the corrective

action taken to remedy any adverse findings. The documented

corrective actions appeared appropriate for the findings.

6. Records and Reports

The inspectors reviewed testing and maintenance records and

records of security events.

a. Testina and Maintenance Records:

The testing and maintenance records committed to in the Plan

were on file and readily available for inspection.

b. Security Event ReDorts:

The inspectors reviewed, and discussed with the licensee,

eleven security events that had been reported to the NRC in

accordance with 10 CFR 73.71(c) since January 1, 1987.

Of the eleven events reviewed:

(1) four involved malfunctions of the security computer due

to hardware and software related problems;

(2) four involved the degradation of vital area barriers;

(3) two events involved attempts to introduce contraband

into the plant; and

(4) one event involved a potential threat to the plant.

No discrepancies were identified relative to reporting the events

or the actions taken.

7. Testina and Maintenance

The inspectors reviewed testing and maintenance records for l

security systems and equipment.

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TlilS PARAGR/,Pil CONTE WS SAFEGUMDS l

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INFORWT!02 tm is No t FOR PU3UC

IllSCl0SURE, !T is m!ENT!ONMlY

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" THIS PARAGRAPil CONTAINS SAFEGUAUS {

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'IllFORMATION AND IS tiOT FOR PUBLIC-

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- DISCLOSURE,IT IS INTEL 4TIONAllY

LEfT BLANK.

The inspectors' determined that the reason for the disparity was

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that the licensee' erroneously allowed.a tolerance of one

additional day'in the testing' procedure. .The_ application of a ,

tolerance to surveillance testing requirements is permitted by. 'j

the.NRC in some cases, however,2 security related testing is not 1

' included. The. inspectors found that in no case reviewed was the

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period'in excess of one day.and.that all; equipment tests.were { '

current.. The inspectors' determined that there'was no degradation-

to.the security program'as a result of this practice. The.

licensee was advised that a tolerance could not be applied to {

specific. testing commitments made in the Plan. The licensee took

immediate corrective action to remove the tolerance provision

~from'the testing procedure'.

8. Physical' Barriers - (Protected Areal

The inspectors conducted a physical inspection of the protected area '

barrier.'

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' THIS PARAGRAPH C0!iTAlHS SAFEGU ARDS !

, INFORMATION AHO IS NOT F0il PUBLIC

DISCLOSURE,IT IS INTENIl0NALLY

LETIDLANX.

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Tills PARAGRAPH CONTAINS SAFECUARD5

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INFORMAT!0N AND 15 NOT FOR PUBLIC

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LEfI BLANK.

Failure of the' protected area barrier to conform to paragraph

4.2.1 of the Plan is an apparent violation of NRC requirements.

(50-245/87-22-02; 50-336/87-20-02; 50-423/87-18-02)

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DISCLOSURE,IT IS INTEllT!0NALLY

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lillS PAR AGRAPH CONTA!NS SAFEGUARDS

INFORMAI:0N AND IS NOT FOR PUBllc

DISCLOSURE,lilS INTEliT!0NALLY

LEFT BLANK.

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!! - 9. Physical' Barriers - (Vital Areas)

The' inspectors conducted observations of a sampling of the vital.

area.. barriers for Units 1,.2, and'3 and found the following:

a. Unit #'1:

(1)

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TlilS PARAGRAPfl CONTAINS SAFEGUARDS i

INFORMATION AND IS NOT FOR PUBUC

DISCLUSURE,IIIS INTEllIl0HALLY

1. EFT BLANK. ,

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The improperly secured opening in the vital area barrier is an

apparent violation of paragraph 5.3.1 of the Plan and NRC

requirements. (50-245/87-22-03; 50-336/87-20-03; 50-423/87-18-03)

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, (2) Tills PARAGRAPH CONTAINS SAFEGUARDS

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INFORMAT!ON Afl0 !S NOT FOR PUBLIC

DISCLOSURE,li15 INTENTIONALLY

LEFIDLAHX.

(3)

Tills PAPAGRAni CONTAIIIS SAFEGUARDS

INF0TtMATiDN AflD 15 NOT FOR PUBlic

DISCLOSURE,IT IS INTEllT!0NALLY

LEFTBLANK.

The non-conforming opening in the vital area barrier is an

apparent violation of paragraph 5.3.1 of the Plan and NRC

requirements. (50-245/87-22-04; 50-336/87-20-04; 50-423/87-18-04)

(4) Tills PAR AGR AFi! CONTAINS SAFEGUARDS

INFORMA!:0ll AND 15 NOT FOR PUBL[g

DISCLDSURE,IT IS liiTEHil0NALLY

LEFT BLANK.

The non-conforming opening in the vital area barrier is an

dpparent Violation of paragraph 5.3.1 of the Plan and NRC

requirements. (50-245/87-22-05; 50-336/87-20-05; 50-423/87-18-05)

(5)

Tills PARAct"R! CONTAINS S ATEGUARDS

!NTORMAT.'Oi! t,f:D IS NOT FOR puntgr.

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DISCLDSURE, n IS UdENTIDNALL1 '

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. Tills PARAGRAPil 00HTIINS SAFEGUARD ~C

INFORMATION AND 15 nolIDR PUBLIC.

DISCLOSURE,lTISlNTENil0NALLY

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'The non-conforming opening in the vital area barrier.is an

, apparent violation.of paragraph 5.3.1 of'the Plan and NRC

^ requirements. -(50-245/87-22-06; 50-336/87-20-06; 50-423/87-18-

06)

b Unit # 2:

(1)

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Tills PARAGRAPil CONTAINS SAFEGUARD $

INFORMATION AND IS NOT FOR PUBLJC

DISCLOSURE,II13 INTEllil0NALLY

LEFTBLANK,

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- The licensee agreed to provide evidence that the wall does meet ,

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' the criteria as committed to by paragraph 8.3.1 and Appendix A of

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. the Plan.and NRC requirements. This is an Unresolved Item. (50-

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245/87-22-07; 50-336/87-20-07; 50-423/87-18-07) 3

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Tills PARAGRAPH CONTAlHS S AFEGUARDS

INFORMATION AND IS NOT FOR PUBLIC

DISCLUSURE,IT 151NTENiiONALLY

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.The non-conforming opening in the vital area barrier is an i

apparent' violation of paragraph 5.3.1 of the-Plan and NRC' l

requirements. (50-245/87-22-08; 50-336/87-20-08;50-423/87.-18- l

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Tills PARAGRAPH CONTAINS SAFEGUADDS

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blSCLOSURE,II131NTENiiONALLY

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' Tills PARABRAPH CONTAlHS SAFE 00ARP#

INFORMATION AND IS NOT FOR PU8 tic 1

DlSCLOSURE,II15 INIENIl0NAU.Y

LEFTBLANK, j

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T!!!S PARACRAM: CGHTAINS SATE 0llM05

INFORMAT!DN AND IS NOT FOR PultLIC

DISCLOSURE,IT IS INTENil0NALLY

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The licensee agreed to demonstrate that the barriers discussed in

9.b.(4) and (5) above are suitable for the purposes intended as ,

committed to by paragraph 5.3.1 of the Plan and NRC requirements.

This is an Unresolved Item. (50-245/87-22-09; 50-336/87-20-09;

50-423/87-18-09),

c. All Units:

Tills PARAGRAPR CONTAlHS FATEttlAtlD;

INFORMAT!0N AND IS N01iM p{lbuh

DISCLOSURE,ITISlHHVil0N4ufy

LEFIBLANK.

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The inspectors conducted a lighting survey of the entire-

protected area.'during the hours of 8:00 p.m. to 10:00 p.m. on

September 2, 1987. The inspectors were each accompanied by a ,

licensee representative and had a calibrated light' meter l

available for direct measurement.of lighting levels. The ;

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inspection revealed six areas below the 0.2 foot-candle

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requirement. .'Three of these areas were lighted but the level was

less than 0.2' foot-candles; the other three areas lacked lighting

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entirely. . Some'of.the areas were deficient due to the placement

of dumpsters.and other obstructions that blocked installed

lighting.

The inspectors were informed by security that they were not )

advised when equipment was relocated. However, thr? ' ' n"Wtors j

questioned why observations of lighting were not'ro'.'tiw1) '

conducted during security patrols. Additionally, thw Sspectors

found that lighting deficiencies had been found in tNb of t.he .

last.three corporate security audits (1984 and 1985) at Millstone ,

and, therefore, should have continued to receive priority

attention.

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TlHS PARAGRAPH CONTAINS SAFEGUARDS

INFORMAT10N AND 15 NOT FOR PUBUC

DISCLOSURE,IIIS INTENTIONALLY

LEFT BLANK. l

Lighting within the protected' area less than 0.2 foot-candle is

an apparent violation of paragraph 7.3 of the Plan and NRC

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requirements. (50-245/87-22-10; 50-336/87-20-10; 50-423/87-Is-' '

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11. Assessment Aids

The inepectors observed the use of assessment aids and other ;

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security equipment in operation at both the CAS and SAS.

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Tills PARACTMPR CONTAINS SATECUARDS ';

INFORMAI!DN 20 is Ng7 793 pgggg

DISCLOSURE, JT JS INTENit0NALLY l

LETY BLANK.

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DISCLOSURE,lTIS INTENTIONALLY.

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The. licensee acknowledged this and instituted immediate

compensatory measure while permanent corrective action was being

determined.

, Utilizing an assessment aid as a compensatory measure in an area j

that cannot be. fully assessed using the aid and that has an

inoperative intrusion detection system is an apparent violation-

of paragrapn'4;2.4.6 of the Plan and NRC requirements. (50- 3

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245/87-22-11;. 50-336/87-20-11; 50-423/87-18-11)

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12. Access Control - Personnel ,

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.The inspectors reviewed the perso'nnel access control procedures }

in use at-'the North and South Access Portals. .

Tills PARAGRAPH CONTAINS SAFECU ARD$

INF0HMA1!0N AND IS NOT FOR PUBLIC

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DISCLOSURE,IIIS INTE!!110NALLY

I. EFT BLANK.

Failure to conduct a " hands-on" search of non-regular employees

as committed to in paragraph 6.4.1.4 of the Plan, is an apparent

violation of NRC requirements. (50-245/87-22-12; 50-336/87-20-

12; 50-423/87-18-12)

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INFORMM!DN AND iS NOT FOR PUBLIC

DISCLOSURE,IT IS INTENT!0NALLY :

1. EFT BLANK.

13. Access Control - Packaces

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The inspectors observed the licensee's method of processing hand-

carried packages through the access portals and determined that

it was possible to introduce certain contraband into the

protected area without detection.

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INFORMATl0H ME IS NOT FOR PUBLIC '!

DISCLDSURE,IT IS INiENil0NALLY

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The licensee stated'that the matter would be reviewed in'an I

effort to preclude the vulnerability.- l

.14. ' Detection Aids - Protected Area !

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The inspectors reviewed the detection aids used around the

protected area barrier.

THIS PARAGRAPH CONTAINS SAFEGUARDS -

INFORMAI!DN At'D IS NOT FOR PUBUC

DISCLOSURE,IT IS INTENT!0NALLY

LEFT BLANK.

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Tills PARAGRAPH CONTAINS SAFEGUARDS

INFORMAT!DN 30 IS NOT FOR PUBUC

DISCl0SURE,lilSINTENT!0NALLY

LEFT BLANK.

THIS PARAGRAPH CONTAINS SAFEGUARDS

INFORMATf0N AND IS NOT FOR PUBLIC

DISCLOSURE,liIS INTENTIONALLY

LEFT BLANK,

The use of these switches is an apparent violation of paragraph

4.2.3'of the Plan and NRC requirements. (50-245/87-22-13; 50- l

336/87-20-13; 50-423/87-18-13) '!

The licensee acknowledged these findings and initiated immediate

compensatory or corrective action as appropriate.

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15 '. ' Alarm Stations

The inspectors observed the operation of both the CAS and SAS and !

found them to be operating in accordance with the Plan, with the !

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exception of those items previously identified in the report.

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,.- ' 16 . Trainina'and Qualification Ggneral Requirements

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.The inspectors reviewed training records.for 21 individuals.

These. records included armed guards, unarmed watch persons, and g,

supervisors. ,

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L illiS PARAGRAPil CONTAINS SAFEGUARDS

INFORMAT!0N /WD IS s0110?.NRLic '

DISCLOS'JRE IIISltHUd!941t7

Vr LEFI BLANL ,

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17. Exit iE;tprview

The inspectors met with the licensee representatives listed in

paragraph 1 at the conclusion of the inspection on September 4,

1987. At that time, the purpose)and scope of the inspection were

reviewed and the findings were presented.

At.no time.during this inspection was written material provided

to the licensee by the inspectors.

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ML20235Z504

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