ML20236G943

Insp Rept 50-346/98-08 on 980526-0617.Violations Noted.Major Areas Inspected:Licensee Performance Re Physical Security

ML20236G943
Person / Time
Site:	Davis Besse
Issue date:	06/30/1998
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20236G927	List: ML20236G924 ML20236G936 ML20236G943
References
50-346-98-08, 50-346-98-8, NUDOCS 9807070026
Download: ML20236G943 (12)

See also: IR 05000346/1998008

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U. S. NUCLEAR REGULATORY COMMISSION

REGION lil

Docket No: 50-346

License No: NPF-3 i

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Report No: 50-346/98008(DRS)  !

Licensee: - Centerior Service Company

Facility: Davis-Besse Nuclear Power Station  ;

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Location: 5503 N. State Route 2

Oak Harbor, OH 43449

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Dates: May 26-29,1998 onsite

June 9,11,15, and 17,1998 in Region 111 Office

Inspector. G. Pirtle, Physical Security inspector  ;

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Approved by: James R. Creed, Chief, Plant Support Branch 1

Division of Reactor Safety

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9807070026 990630  ?

PDR ADOCK 05000346

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EXECUTIVE SUMMARY

Davis-Besse Nuclear Power Station

NRC Inspection Report 50-346/98008

This routine, announced inspection evaluated several aspects of licensee performance relating

to physical security for the facility. The inspection also addressed several previously identified

findings. Some elements of inspection focus included access authorization, security

equipment, protected area entry procedures, and self-assessment.

• A violation was identified for not disclosing specific information required for unescorted

access authorization background investigations. Inspection followup items were noted

for inaccurate or incomplete information in some background investigation case files,

and some materials, not identified in the security plan, being exempt from search prior to

entering the protected area. Protected area entry conicols for personnel, vehicles, and

material were effective (Section S1).

• An inspection followup item was identified in reference to actions required to increase

the protection for an active barrier within the Vehicle Barrier System (VBS). Security

equipment observed during the inspection was operable and functioned as designed

(Section S2).

• Security officers and supervisors were very knowledgeable of duty responsibilities and

no deficiencies were noted during post visits and interviews. Security force performance

was very good and consistent (Section S4).

e The self-assessment efforts were varied and effective in identifying problems and

performance trends, except for the background investigation related violation and issues

addressed in Section S1. Finding results were effectively monitored, tracked, and

resolved (Section S7).

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Report Details

S1 Conduct of Security and Safeguards Activities

a. Insoection Scoce (81700)

The inspector reviewed the unescorted accesc authorization background investigation

case files for two newly hired security officers. r)rotected area access of personnel,

vehicles, packages, and material was also reviewed (Refer to the Partial Listing of ,

Documents Reviewed Section of this report for additional information) . l

b. Observations and Findings

Two issues were identified while reviewing the background investigation case files for

two recently hired security officers. One pcrtained to required information not being

provided to authorized personnel conducting background investigations required by 10

CFR 73.56. The second pertained to inaccurate information contained in background

investigation case files. Another issue was identified pertaining to certain material being

exempted from search upon entering the protected area and not being identified in the

security plan, j

1. Review of background investigation case files showed that the contractor

performing the investigations for the licensee documented that it was against

company policy to release some information pertaining to the individual's

employment history. The company would provide information about the job title

and release from employment date, but no other employment history information

required by NRC rules and the licensee's procedures would be released.

Specifically, the case files reviewed stated that " policy prohibits the release of

information" in reference to employment history questions about disciplinary

history, criminal history, or any information that would adversely reflect upon the i

reliability and trustworthiness of the individual. Section 1.3.1 of the security plan

requires the licensee to meet the requirements of USNRC Regulatory Guide

5.66. Such information is required by NUMARC document 89-01, (Appendix to  ;

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USNRC Regulatory Guide 5.66, "Agcess Authorization Program For Nuclear

Power Plants", June 1991), and the licensee's unescorted access authorization

procedure, to be requested and evaluated prior to granting unescorted access

authorization to the protected area.

Section 6.5.1.d oflicensee procedure IS-AC-00516," Unescorted Access

Requirements", Revision 9, approved January 30,1998, and Section 6.2.1 of

NUMARC document 89-01, " Industry Guidelines for Nuclear Power Plant Access

Authorization Programs", August 1989, (Appendix to USNRC Regulatory Guide

5.66), requires employment history to be obtained by contacting employers for

the past five years to verify the following information fcr all claimed periods of

employment of 30 days or more: Position held by the individual; disciplinary

history; reasons for termination and eligibility for re-hire; and any other

information that would adversely reflect upon the reliability and trustworthiness of

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information that would adversely reflect upon the reliability and trustworthiness of

the individual as it relates to being granted unescorted access.

Additionally,10 CFR 73.56(f)(2) requires licensees, contractors, and vendors to

make personal information from background investigations required by 10 CFR

73.56 available to another licensee, contractor, or vendor provided that the

request is accompanied by a signed release from the individual. j

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Conflicting and incorrect procedure guidance contributed to this violation. l

Licensee procedure HR-405, Corporate Reference Manual-Human Resources, )

" Employment Verification", revised September 30,1997, allows, with ap opriate )

written releases, most employment history information to be released by the l'

Employee Services Call Center, Human Resources Department. However, the

procedure allows some employment history information to be released without a

i signed release with the individual's signature, and prohibits release of

information about the employee's eligibility for rehire. Both provisions violate

licensee procedure IS-AC-00516," Unescorted Access Requirements."

The Manager, Security stated during a teleA a conference call on June 15,  !

1998, that the practice had been implememK a long period of time. j

Subsequent inspection effort disclosed that the personnel tasked with )

responding to background information requests for information were not awarc of

the scope of disclosure allowed or required by the licensee's procedures. The l

failure to provide required information for background investigation purposes

constitutes a violation of 10 CFR 73.56(f)(2) and several sections of the

licensee's security plan (50-346/98008-01)(See Notice of Violation for further

detai!s).

2. Two deficiencies were noted during review of the newly hired security officers  ;

background investigation case files. The contractor conducting the bacxground  ;

investigations for the licensee annotated on the background investigation case i

files that " policy prohibits the release of information" in reference to suitable

inquiry questions required to be asked and evaluated (10 CFR 26.27(a)(1) and

(2)). Also,10 CFR 26.27(a)(3) requires suitable inquiry information to be made

available in response to a licensee's, contractor's, or vendors's inquiry supported

by a signed release from the individual.

During a telephone interview with the Supervisor, Access Authorization , after

completion of the onsite inspection, it was discovered that the contractor's

annotations on the case files were not completely accurate. The contractor

pertooning the b.ackground investigations for the licensee had been advised by

memorandum (dated February 23,1996) from the licensee, that the contractor

no longer needed to complete written or verbal suitable inguiries for the Centerior

Service Company, because the site Access Control Unit would completo the

suitable inquiries. Therefore, although the requested information was not bcing

provided to the contractor conducting the background investigation, it was being

provided to the on site Access Control Unit (nuclear) personnel. Therefore,

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release of the information was not prohibited by company policy as indicated on l

the background investigation case files.

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Review of the site Access Control Unit documentation of the suitable inquiry

results showed that such documentation was part of a worksheet with a section

for suitable inquiry and a column for "S" (satisfactory) and "U" (unsatisfactory).

Such documentation methodology does not indicate what portion (s) of the -

suitable inquiry constituted an unsatisfactory evaluation. The need to require

more accurate documentation by the contractor in reference to suitable inquiries,

and strengthen the documentation method used for suitable inquiries completed  !

by the Access Control Unit will be monitored as an inspection followup item (50- j

346/98008-02).

3. During review of vehicle antry practices into the protected area, it was identified

through interviews that on one occasion during the latest outage a vehicle was l

searched, sealed, and secured at the Perry Nuclear Plant. When the vehicle

arrived at the Davis Besse Plant, the contents of the vehicle were not searched  !

based upon the actions taken at the Perry plant (search, seal, and secure). I

Alti,ough this practice may provide an adequate level of protection, it constitutes

a category of material that is being exempted from search upon entering the

protected area that is not identified in the security plan or addressed in sufficient

detail in security procedures. The security staff has agreed to revise the security

plan to address this category of exempted material and the protection measures

used for such material. The adequacy of such measures will be evaluated when

the security plan revision is received (50-346/98008-03).

Protected area access control for personnel, vehicles, and materials were conducted in

accordance with procedure requirements.

c. Conclusions

A violation was identified for not disclosing specific information required for unescorted

access authorization background investigations. Inspection followup items were noted

for inaccurate or incomplete information in some background investigation case files,

and some materials, not identified in the security plan, being exempt from search prior to

entering the protected area. Protected area entry controls observed for personnel,

vehicles, and material were adequate.

S2 Status of Security Facilities and Equipment

a. Insoection Scoce (81700)

The inspector reviewed the condition of security equipment and facilities required by the

security plan. The equipment observed included, but was not limited to, personnel

search equipment and a portion of the Vehicle Barrier System (VBS),

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b. Observations and Findings

Section S1.1.b3(a) of Inspection Report No. 50-364/97010, dated October 11,1997,

l identified an unresolved item pertaining to a vehicle barrier system (VBS) gate located

outside of the protected area being designated as a " passive barrier." Protection

requirements are generally more stringent for " active" barriers than for passive barriers.

The unresolved item was if the gate barrier was a " passive" or " active" barrier. NRC

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review of the issue concluded that the barrier was an " active" barrier and the increased

l inspection frequency and protection criteria for active barriers applied to the vehicle

I gate. The VBS gate was routinely checked for operability on a weekly basis during

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perimeter alarm checks so the inspection frequency was not a significant issue.

However, the gate required an added level of protection because of its location within

the VBS. Because it was located outside of the protected area boundary and alarm  !

l system, an additional component was required to provide adequate protection for the

l gate (the nature of the required protection upgrade for the gate is considered

safeguards information and exempt from public disclosure until resolved).

The security staff completed a " Request for Assistance" form to mechanical and

structural engineering to evaluate all of the options applicable to the VBS gate.

Adequate interim measures (temporary barrier) were implemented pending final

resolution of the issue. Additionally, the security staff recognized that some procedures

will require revision to address frequency of inspection, and other criteria applicable to

active barriers. This issue will be monitored as an inspection followup item (50-

346/98008-04).

Maintenance support for security equipment was generally very good and compensatory

measures were seldom required for excessive periods of time. Equipment observed

functioned as designed.

c. Conclusions

An inspection followup item was identified in reference to actions required to increase

the protection for an active barrier within the VBS. Security equipment observed during i

the inspection functioned as designed.

S3 Security and Safeguards Procedures and Documentation

a. Insoection Scoce (81700)

The inspector reviewed selected procedures pertaining to the areas inspected and also

reviewed appropriate logs, records, and other documents.

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b. Observations and Findings

Procedures reviewed were well written and adequately described the tasks to be

performed. The procedures were routinely reviewed and were changed when new work

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practices were implemented. Security-related records, logs, and other documents

reviewed were accurate.

c. Conclusions

Security procedures and records reviewed were adequate.

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l S4 Security and Safeguards Staff Knowledge and Pedormance

a. Insoection Scooe (81700)

The inspector toured various security posts and observed performance of duties.

Security event logs and other records pertaining to security force performance were also

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I b. Observations and Findings

Review of security' event logs showed consistent good performance by the security force

since the beginning of the year (1998). All but one of the security performance goals

monitored by site licensee management (through the Windows Program) showed

L consistent or improved performance within the past six months. .

Security officers observed on post were very knowledgeable of procedure requirements

and performed their duties in accordance with the procedures. Security supervisors

observed and interviewed were aware of the status of ongoing security activities and

provided adequate oversight of security operations.

c. Conclusions

Security officers and supervisors were very knowledgeable of duty responsibilities and

no deficiencies were noted during post visits and interviews. Security force performance

was very good and consistent.

-87 Quality Assurance in Security and Safeguards Activities

a. Insoection Scone (817001 l

The inspector reviewed the most recent audit report of the security program and other

documents and programs used by the security department for problem identification and

correction.'

b. Observations and Findings  !

The self assessment effort encompassed about six elements including Quality .

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Assurance (QA) audits, security self surveillance, supervisor tours, the site wide .  !

" windows" program elements, monthly trending and analysis of alarm system l

performance and maintenance supporf and the Potential Condition Adverse to Quality

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(PCAQ) program. Findings were being effectively tracked and monitored. None of these

self-assessment efforts were effective however in identifying the longstanding violation

pertaining to release of background investigation information and other issues

addressed in Section S1.

The inspector reviewed the most recent audit of the security program (No. AR-98-

SECUR-01), dated March 9,1998. The audit was conducted between January 21 and

February 6,1998. The QA audit identified the performance of self-assessments

(particularly the supervisor tours) as a strength. Two findings and three observations

were issued to security during the audit. Problems identified included, but were not

limited to: safeguards information protection; personnel search weakness; and fitness

for duty issue about post accident questionnaires. The QA audit was adequately

documented.

The licensee's " Windows Program" monitored, tracked, and trended performance in six

security-related areas. Examples of areas monitored include door alarms, equipment

malfunctions, external assessments, maintenance of security equipment, and reportable

security events. First quarter 1998 performance analysis showed consistent or (

improving performance in five of the six areas. A decrease was noted in maintenance of

security equipment because the average open time for maintenance logs increased by

two days. The security staff is closely monitoring maintenance support.

An excellent self-assessment plan and evaluation of the outage processing center

performance for outage 11RFO was completed. Self-assessment findings were

thorough, well documented, and supported by the narrative within the report.

The security staff also developed other methods to assess performance and identify

potential problems. The inspector reviewed five self-assessments, and 30 security

supervisor tour reports completed since the beginning of 1998. The self-assessments

and tour reports were adequately documented and tracked.

c. Conclusions

The self-assessment efforts were varied and effective in identifying problems and

performance trends, except for the background investigation violation and related issues

addressed in Section S1 Finding results were adequately monitored, tracked, and

resolved.

S8 Miscellaneous Security and Safeguard issues

S8.1 (Closed) Insoection Followuo item (Recort No. 50-346/97005-04): The number of

alarms for certain identified perimeter alarm zones appeared excessive. Review of

alarm records showed that the alarm rate for the perimeter alarm system has stabilized.

8.2 (Closed) Unresolved item (Recort No. 50-346/97010-01): A portion of the vehicle

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barrier system (VBS) was incorrectly designated as a passive barrier. NRC

Headquarters has reviewed this issue and has concluded that the barrier is an " active" o

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barrier and inspection frequencies have to be increased and actions have to be

completed to increase the protection for the barrier. The Manager, Security

implemented additional security measures for the barrier when advised of the resolution

of this issue. Long term actions are being evaluated. Although the unresolved item will

be closed, an inspection followup item will be opened to address actions that need to be

completed for the barrier (see Section S.2 for more information).

S8.3 (Closed) Insoection Followuo item (Recort No. 50-346/97010-02): Some VBS

procedure weaknesses were identified. The procedure weaknesses identified have

been corrected, with one exception. This item will be closed based upon a commitment

by the security staff to revise section 3.1.3.2a of the security plan to delete the provision

of delaying the implementation of compensatory measures for barrier deficiencies for up

to seven days. Compensatory measures for such barriers must be implemented within

two hours.

Management Meetings

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X1 Exit Meeting Summary

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

on May 29,1998. Personnel present were advised that followup inspection effort at the NRC

Region lll office would be completed in reference to an access authorization issue that was

identified late in the inspection process. Subsequently, several phone interviews were

conducted with licensee personnel to request necessary documents, clarify procedure i

requirements, and discuss the licensee staff position on the issues. Review of requested j

documents was also completed as part of the inspection process. On June 17,1998, the  !

Security Manager and other licensee staff members were briefed on the in-office inspection

effort pertaining to background investigations, which resulted in a vio!ation being identified. ,

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Additionally, an inspection followup item was identified for inaccurate and incomplete

documentation of some information in background investigation case files. j

The inspector asked the licensee personnel present if the inspection findings discussed during

the exit meetings should be considered as proprietary or safeguards information. No

safeguards or proprietary information was identified.

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PARTIAL LIST OF PERSONS CONTACTED

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! J. Wood, Vice President, Nuclear

M. Beier, Manager, Quality Assurance

C. DeTray, Auditor, Quality Assurance

B. Gessel, Manager, Human Resources (Nuclear)

C. Kramer, Licensing Engineer

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D. Lockwood, Supervisor, Regulatory Affairs

l R. Maier, Supervisor, Security Shift

D. Reese, Supervisor, Security

A. Schumaker, Supervisor, Security Support

G. Skeel, Manager, Security

l. W. Molpus, Manager, Nuclear Training

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S. Campbell, Senior Resident inspector

K. Zellers, Resident inspector

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INSPECTION PROCEDURES USED

IP 81700 Physical Security Program For Power Reactors

IP 92904 Followup - Plant Support

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ITEMS OPENED AND CLOSED

OPENED

50-346/98008-01 VIO Some Information Required For Background Investigations Was

Not Being Provided by The Licensee

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50-346/98008-02 IFl Some Documentation For Background Investigation Inquiries Was

Not Accurate or Was incomplete

50-346/98008-03 IFl increased Protection Requirements Were Necessary For a Part of

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l 50-346/98008-04 IFl Some Material Exempt From Search Was Not identified in The

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Security Plan

CLOSED

50-346/97005-04 IFl Excessive Alarms For Part of The Perimeter Alarm System

50-346/97010-01 URI Incorrect Designation of a Portion of The Vehicle Barrier System

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50-346/97010-02 IFl Deficiencies in Some Vehicle Barrier System Procedures

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LIST OF ACRONYMS USED

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l IFl Inspection Followup Item

I- QA Quality Assurance

URI Unresolved item

l VBS Vehicle Barrier System

l VIO Violation

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PARTIAL LISTING OF DOCUMENTS REVIEWED

Security Event Logs from October 1997 through May 25,1998

Procedure IS-AC-0004, "PA and VA Badge issuance and Control", Revision 7, January 20,

1998

Procedure IS-DP-0004, " Nuclear Security Self Assessment Program", Re"ision 3, October 2,

1997

Procedure IS-DP-00504, " Personnel Control for PA Areas", Revision 6, July 29,1996

Procedure IS-DP-00511. " Personnel Searches and Unauthorized Items", Revision 7, May 22,

1998

Procedure IS-DP-08512. " Vehicle Control Procedure", Revision 3, May 22,1998

Procedure IS-AC-00516, " Unescorted Access Requirements", Revision 9, January 30,1998

Procedure HR-405 Corporate Reference Manual-Human resources," Employment Verification",

approved September 30,1997

Report of Self Assessment of Outage Processing Center for 11RFO, dated May 15,1998

"W!NDOWS" Raport for the Security Department for the 4th Quarter of 1997 and First Quarter

of 1998

QA Audit of the Security Program (No. AR-98-SECUR-01), dated March 5,1998

Security Self Assessment 98-005," Controlled Softwate", dated April 16,1998

Security Self Assessment 98-004,"FFD Escort Information Available to the Supervisor-

Security Shift", dated January 21,1998  ;

Security Self-Assessment 98-003, " Procedure Control / Manual Updating", dated January 20,

1998

Security Self Assessment 98-002, " Drug /BAC Database Comparison", dated January 20,1998

Security Self Assessment 98-001, " Controlled Software", January 8,1998 i

Thirty Security Supervisor Tour Reports Conducted Between January 1.1998 and May 20, i

1998

Undated Backup System Failure Analysis (For Security Backup Computer)

Maintenance Log Sheet Report for January 1, through May 22,1998

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