IR 05000461/1999007

Insp Rept 50-461/99-07 on 990301-05.No Violations Noted. Major Areas Inspected:Review of Alarm Stations,Protected Area Detection & Assessment Aids

ML20205H747
Person / Time
Site:	Clinton
Issue date:	04/01/1999
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML19002A247	List: IR 05000461/1999007
References
50-461-99-07, 50-461-99-7, NUDOCS 9904090060
Download: ML20205H747 (12)

Text

rc a

e U.S. NUCLEAR REGULATORY COMMISSION REGION lli )

' -

Docket No: 50-461 i License No: NPF-62 -

Report No: 50461/99007(DRS)

Licensee: lilinois Power Company -

Facility: Clinton Power Station l

Location: Route 54 West Clinton, IL 61727

'

Dates: March 1-5,1999 '

inspector: James L. Belanger, Senior Physical Security inspector Approved by: James R. Creed, Safeguards Team Leader Division of Reactor Safety l

l

.

i

[.

9904090060 990401 Apocn osooo461 i

Pon l' O PoR _;

.

'

.

,

EXECUTIVE SUMMARY Clinton Nuclear Power Station

. NRC Inspection Report 50-461/99007 This inspection included a review of alarm stations, protected area detection and assessment aids, compensatory measures, security event logs, and quality assurance in security and safeguards activities. The inspection also included a review of follow-up issues related to

. previous issues identified and reviewed by the licensee. This was an announced inspection conducted by one regional inspecto =

The inspector identified that derogatory information relating to fitness-for-duty and access authorization reporting requirements regarding a contract employee was not provided to the appropriate staff for evaluation and resolution. In addition, the

' inspector identified that the licensee had not established any guidance or policy that required the information to be forwarded to the Fitness-for-Duty and Access Authorization staff for evaluation relative to continued unescorted protected area access. :Two Non-Cited Violations were identified regarding the reporting requirements. (Section S1.1)

Protected area assessment and detection aids were functional and effective based on observations of field testing. These systems provided the security organization with the ability to identify an extemal design basis threat attack on the facility. (Section S2.1)

-

The licensee appropriately analyzed, tracked and resolved security events. For example, the licensee identified a trend of computer related problems that

. reduced protection measures and was in the process of resolving the issu (Section S3.1)

.

Tactical response table top drills were an effective training tool, provided a good mechanism for the evaluation of individual performance, and demonstrated an effective contingency response capability. (Section S4.1)

-

' The security organization was effective in identifying, analyzing, and correcting problems through a combination of audits, self-assessments, and tracking and trending programs. (Section S7.1)

-

l

.

,

Report Details IV. Plant Support S1 Conduct of Security and Safeguards Activities S1.1 Failure to Report Use of Medication and Arrest Inspection Scope (81700 and 81502)

The licensee conducted an investigation in March 1998 to review a fitness-for-duty (FFD)

concem. The inspector reviewed the results of this investigation which revealed that an individual had not coraplied with licensee FFD procedural requirements relating to reporting the use of a medication and reporting an arrest for driving under the influenc Observations and Findinas The licensee's " Employee Concems Program" office, through an independent investigator, reviewed the following concern:

. In September 1997, a named contractor was in an automobile accident and was on medication that prevented him from working twelve hour shifts. The local union steward and general foreman decided that the individual was to work the twelve hour shifts. The licensee's FFD procedures were not followed in evaluating the fitness of an employee who was on medicatio The independent investigator determined that the foreman evaluated the individual's fitness by both visual observation and verbal discussion throughout the shifts and deemed him fit for duty. Additionally, the investigator determined that the foreman took a '

conservative safety approach by re-assigning the individual as part of a crew to work outside of the radiological control area doing non-safety related activities. The

'

investigator concluded that the foreman's action complied with the licensee's FFD program requirements, as contained in Corporate Nuclear Procedure 4.12, " Fitness For Duty," which requires, in part, that supervisors observe and evaluate personnel for behavior indicative of an impaired abilit The investigator also identified that the employee did not report the use of medication to

.

medical services for evaluation and did not report that he was arrested for driving under l

the influence (DUI) following the automobile accident.10 CFR Part 26.20 requires that j the licensee establish and implement policios and procedures designed to meet the performance objectives of the FFD rule. One of the general performance objectives is <

that FFD programs must assure that personnel are not under the influence of any substance, legal or illegal, or mentally or physically impaired from any cause, which in any way affects their ability to safely and competently perform their duties. The failure to report the use of medication was considered a violation of Section 2.1 of Nuclear Training and Support Department Procedure 1.16," Fitness For Duty," which required all individuals to report to Medical Programs personnel the use of prescription or

.

l non-prescription medication which may adversely affect their ability to safely perform

'

their assigned dutie Section 1.4.1.1 of the Clinton Security Plan states that the licensee has implemented an access authorization program in accordance with the guidelines of Regulatory Guide 5.66 and that all elements of this Regulatory Guide have been implemented to satisfy the requirements of 10 CFR 73.56. Regulatory Guide 5.66 endorsed industry standard, NUMARC 89-01 dated August 1989. Paragraph 9 of NUMARC 89-01 requires the I reporting'of arrests that may impact upon an individual's trustworthiness. The failure to report the DUI arrest was considered a violation of Section 5.5 of Nuclear Training and Support Department Procedure 1.19, " Security Screening," which required all individuals granted unescorted access to notify Security Screening personnel of any arrest that may impact upon their trustworthines Based on a review of the named employee's access authorization file, the NRC inspector noted that the employee was trained in these reporting requirements. There was no indication in the licensee's investigation that the employee willfully violated these reporting requirement When the inspector questioned the Personnel Processing Supervisor (PPS) regarding the actions taken to evaluate this derogatory information for potential safety consequences, the inspector determined thet the PPS was not aware of the FFD program violations. The Employee Concerns Coordinator had not recognized that these issues were FFD Access Authorization (AA) related and consequently, the information was not communicated to the PPS for evaluation. Further, there were no procedural requirements in the Employee Concems Program to ensure these type of issues were communicated to the FFD/AA staff for evaluatio The licensee initiated corrective action consisting of reviewing and updating the employee's information in the Personnel Access Data System (PADS). The licensee updated the PADS entry on the individual to reflect that Illinois Power had additional information should the employee request unescorted access at another nuclear facilit According to the licensee, the PADS system showed that the former employee had not had access at any nuclear power plant since leaving Clinton Power Station. The licensee also stated that the PPS planned to enter the failures to appropriately evaluate derogatory information into its corrective action program. Nse Severity Level IV violations are being treated as Non-Cited Violations, consit tent with Appendix C of the

'

NRC Enforcement Policy (NCV 50-461/99007-01 and 50-401/99007-02). The licensee l placed these violations in their corrective action program as Condition Report No.1-99-03-08 l l

c. Conclusions j l

l The inspector identified that derogatory informatio i relating to fitness-for-duty and !

l access authorization reporting requirements regarding a contract employee was not l

'

provided to the appropriate staff for evaluation and resolution. In addition, the inspector l identified that the licensee had not established any guidance or policy that required the j

!

4  !

l l

1 A

i

.

.

j information to be forwarded to the Fitness-for-Duty and Access Authorization staff for evaluation relative to continued unescorted protected area access. Two Non-Cited i Violations were identified regarding the reporting requirement S2 Status of Security Facilities and Equipment 4 S2.1 Effectiveness of Protected Area intrusion Detection System and Assessment Aids Inspection Scoce (81700)

The inspector observed tests of the protected area intrusion alarm system and evaluated assessment capabilitie Observations and Findinas The inspector requested that the licensee demonstrate the effectiver.ess of the protected area intrusion alarm system through the conduct of the Monthly Detection Probability Test on a sample of protected area intrusion alarm zones randomly selected by the inspector, The sample was approximately twenty percent of the total number of alarm zones. The testing procedure required ten challenge tests per zone to include running, crawling and rolling. The testing was performed by two members of the security forc In the five zones tested, all ten tests per zone generated an alar The inspector examined the assessment system for the protected area perimeter J

intrusion alarm system and determined that the coverage and overlap provided adequate i means for alarm station operators to assess alarms. Picture quality was observed to be very goo Conclusions Protected area assessment and detection aids were functional and effective based on ;

observations of field testing. These systems provided the security organization with the I ability to identify an extemal design basb threat attack on the facilit S3 Security and Safeguards Procedures and Documentation S3.1 Review of Licensee Security Loaaabte Events Inspection Scope (81700)

The inspector reviewed the licensee's event log to verify that safeguards events were appropriately analyzed, tracked and resolve Observations and Findinos The licensee properly classified each safeguards event in accordance with its established Reportability Matrix and initiated condition reports when appropriate. Issues l

.

.

requiring the initiation of a condition report included several security plan violations involving mis-bsued vital area keycard badges, a failure to initiate proper compensatory measures for certain perimeter zones which had exceeded the false alarm rate criteria, improper control of a non-designated vehicle, and a failure to verify an alarm point had returned to normal status prior to removing compensatory measures. The inspector determined through a review of the applicable condition report that the licensee had taken appropriate and effective corrective actions to address these problem The licensee identified an ongoing problem with security door strikes that were computer related. The specific details are safeguards information. Based on discussions Nith the Security Supervisor, the inspector concluded that the security organization was receiving good technical support to resolve the problom. This is an inspection Follow Up Item (IFI)

(50-461/99007-03). The inspector will review the effectiveness of the licensee's actions to resolve the proble j Conclusions ,

k The licensee appropriately analyzed, tracked and resolved security events. For exrmple, the licensee identified a trend of computer-related problems that reduced ;

protective measures and was in the process of resolving the issu ]

l S4 Security and Safeguards Staff Knowledge and Performance S4.1 Table Too Drills Demonstrated Effective Continaency Response Caoability l l Inspection Scoce (81700)

The inspector observed two hours of scheduled tactical response table top drills involving security force supervisory personnel who could act as licensee contingency .

response team leaders. These drills simulated external assault l Observations and Findinas On March 1,1999, the inspector observed tactical response table top drills which were part of the licensee's ongoing training program. A training instructor and the Security Force Manager identified adversary characteristics, an entry point into the protected area, and movement of adversary personnel toward safety equipment. Both the training instructor and response team leader estimated the response time required for adversaries to proceed to the target area and judged the outcome of engagements between adversaries and responders. The inspector observed that in each scenario, the response team leader considered how the responding officers would be deployed. The officers involved in the table top drills were knowledgeable and confident in their ability to implement the defensive pla ,

. Conclusions Tactical response table top drills were an effective training tool, provided a good mechanism for the evaluation of individual performance, and demonstrated effective .

contingency response capabilit S7 Quality Assurance in Security and Safeguards Activities S The identification. Analysis. and Resolution of Problems in the Security Area Was Effective Insoection Scope (81 '00)

The inspector evaluated the licensee's programs for the identification, analysis, and resolution of security issues. Specifically, the inspector reviewed the quality assurance audit and formal security self-assessmer!s conducted since the last NRC security inspection, the informal self-assessments which were part of the Watch Tour Program, the independent self-assessment performed in October 1998 by an outside contractor at the request of the security organization, the tracking and trending of security performance indicators detailed !n the quarterly " Security Performance Reports," and the tracking of security issue Observations and Findinos

- Quality Assurance (QA) Audits and Formal Self-Assessments The inspector reviewed Quality Assurance Audit Report Q38-98-13 issued on August 10,1998, which addressed the implementation of the approved security plan and the access authorization' program, as well as the control of safeguards information. The audit was performance-based with field verifications of security ]

equipment and interviews with the security organization member '

The QA auditors concluded that the plans and programs associated with sll of the areas reviewed were effectively implemented. The auditors identified several l deficiencies including the fact that the security organization had not implemented the requirements of the licensee's formal self-assessment program defined in CPS 1005.16,"Self Assessment." However, the audit report stated that the informal self-assessments described in the Plant Security Organization (PSO)

Security Self Assessment Program, met the intent of the self-assessment requirements prescribed in CPS 1005.16. The inspector noted that the security organization subsequently implemented a self-assessment program satisfying the program requirements delineated in CPS 1005.1 One formal assessment, conducted from January 22,1999 to February 17,1999, by security managers, involved ar. evaluation of declining morale and an increase in human performance errors. The managers conducting the assessment interviewed and/or observed over 90 percent of the security force. No conditior s

_ _ _ _ _ _ _ _ _ _ _ _ _

, , . .

- _ _ _ _ _ _ _ _ _ _ _ _ _ ,

<

)

were identified which warranted the initiation of a condition report, but several recommendations were made to enhance communications and task assignment I

consistency. The inspector noted that these recommendations were tracked by security management for action. Three other formal assessments were scheduled for calendar year 19p9 including reviews of security screening and badging, the fitness for duty program, and the PADS progra .

Informal Self: Assessments The security organization established a comprehensive self-assessment program to evaluate the effectiveness of the Clinton Station's security program. Security Shift Leaders and training department members performed ongoing assessments (watch tours) to evaluate individual security force members' knowledge of job related duties. The watch tours were an integral part of the security program and were effective in identifying deficiencies in security procedures and practice The inspector noted that conditions identif;sd through the watch tour program requiring formal corrective action were documented and tracke . Indeoendent Self-Assessment by Security Contractor The inspector reviewed the results of an independent self-assessment of selected aspects of the Clinton Power Station (CPS) Security and Personnel Processing programs that was conducted bv an outside security professional at the request of the site security organization. '.e report documenting the results of this assessment was dated November 8,199d, and the assessment covered a two week period in October 1998. The scope of the audit included specific areas of interest requested by the licensee, such as: the Personnel Processing organization's effectiveness in identifying deficiencies and corrective actions, observation of FFD testing, and the implementation of the random fitness for duty selection program. No significant programmatic deficiencies were identified, but the report included a number of recommendations to enhance the progra . ?>ecurity Performance Reports The inspector reviewed the quarterly Security Performance Reports for 199 These reports provided management with a comprehensive tracking and trending tool in the evaluation of program performance. The licensee established goals and evaluated staff and management performance based on these goal Identified negative trends were tracked and the need for program improvements flagged. The inspectors noted that the performance report for the third quarter of 1998 indicated that the number of contraband drills and observations conducted to assess how well selected personnel were performing their required duties, had decreased and, although there was improvement in the first quarter of 1999, attention was still needed in this are _ _ _ _ _ _ _

.

Thinos To Do List Based on discussions with the Security Supervisor, the inspectors determined that the security staff met weekly to discuss the status of security action items on n " Things To Do List." This comprehensive listing of action items povided managemern with an effective means to track organizational performance and the status of commitment Condition Reoort Proaram Based on a review of condition reports generated by the security department during 1998, the !nspectors concluded that security issues were adequately documented and investigated, and that appropriate corrective actions were taken. The condition report packages reviewed were of high quality. The security organization was an active participant in the licensee's formal corrective adion progra Conclusions The security organization was effective in identifying, analyzing, and correcting problems through a combination of audits, self-assessments, and tracking and trending program S8 Miscellaneous Security and Safeguards issues S (Closed) IFl 50-461/95008-02: Occasional security force performance issues caused by ,

a lack of attention to detail. Based on their review of security self-assessments and l security loggable events, the inspectors determined that the licensee's security staff was I not experiencing events due to inattention to detail. In addition, the inspectors concluded that the security watch tour program was effective in identifying and correcting performance related issues. This issue is close S8.2 (Closed) IFl 50-461/97024-02: A security vulnerability was identified regarding the '

untimely closing of an active vehicle barrier gate. The barrier was normally left in the open position after vehicle traffic passed through the barrier. Barrier effectiveness was reduced when the barrier was left in the open position. The inspector observed that the '

licensee's procedures were changed to require the immediate closing of the barrier following the transit of a vehicle though the barrier. This issue is close V. Manaaement Meetinos X1 Exit Meeting Summary i

The inspector presented the inspection results to licensee r'anagement at the conclusion of the i onsite inspection on March 5,1999. The licensee acknowledged the findings presented. The inspector asked the licensee whether any materials examined during the inspection should be considered as proprietary. No proprietary information was identifie !

9 l l

.

.

PARTIAL LIST OF PERSONS CONTACTED Licensee G. Armstrong, Corrective Actions Manager G. Baker, Manager, Quality Assurance G. Birk, Security Administrator M. Hiter, Personnel Processing Supervisor K. Johnson, Manager, Nuclear Support M. McNamer, Burns Security Site Manager R. Phares, Manager, Nuclear Safety and Performance improvement J. Sipek, Director, Licensing D. Smith, Director, Secur!ty and Emergency Planning M. Stuckey, Licensing Representative C. Williamson, Security Supervisor NRC T. Pruett, Senior Resident inspector K. Stoedter, Resident inspector INSPECTION PROCEDURES USED IP 81700: Physical Secunty Program at Power Reactors IP 81502: Fitness For Duty Program ITEMS OPENED, CLOSED AND DISCUSSED Opened 50-461/99007-01 NCV Failure to report use of medication that could affect job performance 50-461/99007-02 NCV Failure to report arrest under access authorization program 50-461/99007-03 IFl Followup on corrective actions to address computer

.

'

problem that results in energized security locks without use of keycard l

Close_q 50-461/95008-02 IFl Attention to Detail Performance issues 50-461/97024-02 IFl Vehicle Barrier Vulnerability

l l

e-

. LIST OF ACRONYMS USED I

AA Access Authorization CFR Code of Federal Regulations CPS Clinton Power Station  !

CR Condition 7eport DRS Division of Reactor Safety ,

FFD Fitness For Duty  ;

IFl Inspection Followup item {

NCV Non Cited Violation i PADS Personnel Access Data System

~QA Quality Assurance l

,

n

.

!

f

.

l l

i u-

.

.

LIST OF DOCUMENTS REVIEWED PSO-007," Security Self Assessment Program," dated August 26,1998 Self-Assessment Report on Security Organizational Emerging Trends and Personnel Morale (SA #1999-017) dated February 17,1999 Quality Assurance Audit Report CPS Security, Audit Number Q38-98-13 Quality Assurance Assessment Report, Security Process, Report No. 1999-02-63-20, dated February 5,1999 Security Performance Reports 1999 S9curity Condition Reports 1999 Independent Self-Assessment Audit dated November 8,1998 Safeguards Events Report ability Matrix (CPS 1701.56F003) dated November 7,1996 Results of Self-Assessment of Apparent Cause Analyses for Level 3 Condition Reports Closed Since May 1,1998, dated October 16,1998 Results of informal Self-Assessment of 1998 Security Personnel Errors dated January 6,1999 Safeguards Event Log (August 1998 through January 1999)

l l

l l

,

]

!

,

J