IR 05000255/1987026

Forwards Responses to Violations & Concerns Noted in Insp Rept 50-255/87-26.Violations Involved Inadequate Escorting & Displaying of Badges.Concerns Addressed Requirements Re Fitness for Duty Failures.Encl Withheld (Ref 10CFR73.21)

ML18052B424
Person / Time
Site:	Palisades
Issue date:	12/18/1987
From:	Berry K CONSUMERS ENERGY CO. (FORMERLY CONSUMERS POWER CO.)
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
NUDOCS 8712220153
Download: ML18052B424 (8)

Text

• ATTACHMENT CONTAINS SAFEGUARDS INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE General Offices: 1945 West Parriall Road, Jackson, Ml 49201 * (517) 788-1636 December 18, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -RESPONSE TO INSPECTION REPORT 87-026 Kenneth W Berry Director Nuclear Licensing NRC inspection report 87-026 transmitted two items of violation and two items of concern. The violations involved inadequate escorting and improper ing of badges. The concerns addressed contractors procedural requirements upon fitness for duty test failures and adequacy of vehicle searche Consumers Power Company's respons to these violations and concerns are attached to this letter. Consumers Power Company requests that the attachment to -this letter be withheld from disclosu.re since it contains information which is exempt from disclosure in accordance with 10CFR73.21(c).

Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector-Palisades Attachment WHEN SEPARATED FROM ENCLOSURE HANDLE THIS DOCUMENT AS DECONTROLLED 8712220153 871218 ADOCK 05000255 PDR OC1287-0255-NL04

• ATTACHMENT CONTAINS SAFEGUARDS INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE consumers Power l'OWERINli llllClllliAN'S PROliRESS General Offices: 1946 West Parnell Road, Jackson. Ml 49201 * (617) 788:1636 December 18, 1987 Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 DOCKET 50-255 -LICENSE DPR-20 -PALISADES PLANT -RESPONSE TO INSPECTION REPORT 87-026 Kenneth W Barry Director Nuclear Licensing NRC inspection report 87-026 transmitted two items of violation and two items of concern. The violations involved inadequate escorting and improper ing of badges. The concerns addressed contractors procedural requirements upon fitness for duty test failures and adequacy of vehicle searche *Consumers Power Company's responses to these violations and concerns are attached to this letter. Consumers Power Company requests that .the attachment to this letter be withheld from public disclosure since it* contains information which is exempt from disclosure in accordance with 10CFR73.21(c).

Kenneth W Berry* (Signed) Kenneth W Berry Director, Nuclear Licensing CC Administrator, Region III, NRC NRC Resident Inspector-Palisades Attachment OC1287-0255-NL04 WHEN SEPARATED FROM ENCLOSURE HANDLE THIS DOCUMENT AS DECONTROLLED

• * OC1287-0255-NL04 ATTACHMENT CONTAINS SAFEGUARDS INFORMATION WITHHOLD FROM PUBLIC DISCLOSURE UNAUTHORIZED DISCLOSURE IS SUBJECT TO CIVIL AND CRIMINAL SANCTIONS ATTACHMENT Consumers Power Company Palisades Plant Docket 50-255 RESPONSE TO INSPECTION REPORT 87-026 December 18, 1987 5 Pages WHEN SEPARATED FROM ENCLOSURE HANDLE THIS DOCUMENT AS DECONTROLLED

• Response:

Safeguards Information Withhold From Public Disclosure RESPONSE TO REPORT 87-026 1 IE Inspection No. 50-255/87026 (DRSS) dated November 18, 1987 reported the results of a routine safeguards inspection conducted on October 19-23, 1987. Addressed in the report were two (2) violations and two items of concern to which responses are require The items of violation/concern and responses are provided below: Violation No. 1: Section 4.5.2 of the approved Palisades Security Plan requires that all personnel authorized protected and vital area access with escort shall be escorted by an individual who is authorized nonescorted access to those protected and vital areas. Contrary to the above, on July 20 and October 22, 1987 an individual who was authorized protected and vital area access with escort was found in the protected area without the required escort. Corrective Actions Taken And Results Achieved The individuals involved in the incidents were counseled regarding proper escort responsibilitie Plant employees were addressed by letter from the Plant Manager on November 2, 1987 about escort and other security errors at Palisade The letter advised plant employees that the unfavorable trend in security violations can and will be reverse It also warned that appropriate disciplinary action will be considered if individual attention does not eliminate the problem. In addition, the corrective actions taken in response to IE Inspection report Number 87-009, July 10, 1987 will continue to be emphasize Corrective Actions To Be Taken To Avoid Further Noncompliance Current plans are to implement the following additional actions: Each employee with unescorted access is currently authorized to escort visitor We will reduce the number of personnel authorized to escort and will periodically evaluate escort authorit Procedures will be established to waive these reductions in the event of emergenc The escort ratio is currently 5 to 1 for vital areas and 10 to 1 for protected areas. The escort ratio for vital and protected areas will be reduced to 3 to 1 through at least calendar year 1988. An evaluation will be made at the end of that period as to whether a permanent reduction is necessar Changes or temporary waivers of the 3 to 1 escort ratio may be granted by the Plant Manager, Planning and Administrative Manager, or Property Protection Supervisor or designat RESPONSE/AN03 Safeguards Information Withhold From Public Disclosure Safeguards Information Withhold From Public Disclosure 2 A program will be implemented to improve management accountability for security errors committed by their employee Disciplinary action will be considered if errors occur. In addition to the normal security responsibilities, increased monitoring of visitors for proper escorting will be conducte The results of the monitoring will be recorded, provided to department heads, and used for trending department performance in the security compliance area. Develop a security awareness video presentation that will cover proper escorting and other security subject It will be used to heighten security awareness in company educational program Date When Full Compliance Will Be Achieved The actions identified above have been approved for implementation by February 15, 1988 except the video presentation, for which we are planning a July 30, 1988 completio Full compliance is expected to be achieved by that date. Violation No. 2: Section 3.2.1. of the approved security plan requires that badges be displayed while inside the protected area on outer clothin Contrary to the above, on October 19, 1987 five personnel were observed in the protected area with their badges improperly displayed, beneath their outer garment Corrective Actions Taken And Results Achieved Plant employees were advised by Plant Manager letter on November 2, 1987 about the wearing of badges on outer garments and management concern about security errors at Palisades in general. The letter advised plant employees that the unfavorable trend in security violations can and will be reverse It also warned that appropriate disciplinary action will be considered if individual attention doesn't eliminate the problem. Numerous daily bulletin notices were run and the security force directed to make this an item of special interes Corrective Actions To Be Taken To Avoid Further Noncompliance Current plans are to implement the following additional actions: A program will be implemented to improve management accountability for security errors committed by their employee Disciplinary action will be considered if errors occur. RESPONSE/AN03 Safeguards Information Withhold From Public Disclosure Safeguards Information Withhold From Public Disclosure 3 In addition to the normal security responsibilities, increased monitor-ing of employees for the proper display of badges will be conducte The results of the monitoring will be recorded, provided to department heads, and used for trending department performance in the security compliance area. Develop a security awareness video presentation that will cover proper wear of badges and other security issues. It will be used to heighten security awareness in company educational program Date When Full Compliance Will Be Achieved The actions identified above have been approved for implementation by February 15, 1988, except the video presentation, for which we are planning a July 30, 1988 completio Full compliance is expected to be achieved by that date. Concern No. 1: During the inspection we were informed that two contractor personnel refused to participate in unannounced Fitness For Duty (FFD) testing. The contractor management immediately notified the Security Badge Issue Office that the two contractor's unescorted access be terminate We also determined through discussions with representatives from Security and Human Resources Department that there was no mechanism for the formal notification of the Security or Human Resources Department when a contractor employee is terminated for failing to participate in FFD testing. In this particular case the contractor management had prior FFD testing experience and took appropriate action by requesting termination of the individuals'

access. The possibility exists that contractor management unfamiliar with FFD testing may not request immediate termination of an individual's access, resulting in an employee, who knows his termination is imminent, retaining unescorted access to vital equipment for several days. Licensee staff representatives agreed with our assessment of the potential significance of the absence of plant policy and procedures to immediately revoke unescorted access when employees refuse to participate in FFD testing. The licensee expanded the scope of the issue and recognized the need to develop plant policy and procedures to immediately revoke unescorted access when any individual is terminated for cause. At the exit meeting the A/PM stated that efforts would begin immediately to develop appropriate plant policy and procedures to assure the immediate revocation of unescorted access for individuals terminated for cause. We informed the A/PM at the exit meeting that a resp.onse detailing licensee actions on this issue would be requested in this report. We therefore request the necessary information be provided to this office within 30 days of receipt of this report. (255/87-26-03)

RESPONSE/AN03 Safeguards Information Withhold From Public Disclosure

... f I I,.. Safeguards Information Withhold From Public Disclosure Corrective Actions Taken And Results Achieved 4 The plant has established a policy for contractor employees that provides for the immediate revocation of unescorted access when an individual is terminated for cause. Concern No. 2: Inspection results identified several areas of the licensee's vehicle search program that should be strengthened to assure that contraband material does not enter the protected area. During the inspection we requested and the licensee agreed to conduct unannounced vehicle *search drills. The details of the drills were fully discussed among the NRC inspectors, the Property Protection Supervisor*

and the Burns Security Training Coordinator, who conducted the drills. The scope of the drills encompassed the "planting" of a simulated weapon in various locations on different licensee vehicle Four different drills were conducte The simulated weapon was placed behind the drivers seat for two of the drills, and inside of the engine compartments of a licensee fork lift and station wagon. During each drill a different member of the security force was working the gate where the introduction of the simulated weapon would be attempte The security force was successful in two of the four drills in discovering the weapon. They were unable to locate the weapon inside of the engine compartment of the fork lift or behind the driver's seat. The cause for this failure was personnel error, in that search personnel failed to conduct an adequate search. It should be noted that because of the controlled circumstances surrounding the drill, no actual breach of security could have occurre The licensee stated that the results' 50% failure rate clearly identified a weakness in their vehicle search program. They agreed to take immediate and comprehensive action to assure the vehicle search program is being adequately implemente The following immediate actions were initiated by the licensee:

a. Both security officers who were unable to locate the weapon were critiqued and retrained on-the-spot in proper search technique b. A training class on vehicle searches was provided to all security officers and supervisors reemphasizing the importance of vehicle searches, and the proper techniques for the conduct of such searche The additional training was completed on October 30, 1987. At the exit meeting the Administrative and Planning Manager (A/PM) acknowledged the potential problem and agreed to initiate a comprehensive approach,to improve the effectiveness of vehicle searche The A/PM was informed that we would request a description of licensee long term actions on this issue 'in our final report. Therefore, the licensee is requested to furnish the Region III Office with the of corrective action taken within 30 days of receipt of this report. (255/87-26-04)

RESPONSE/AN03 Safeguards Information Withhold From Public Disclosure

' Ii&. ** I ;-... Safeguards Information Withhold From Public Disclosure Corrective Actions Taken And Results Achieved 5 Additional vehf°cle search training was completed on October 30, 1987 for all contract security officers and supervisor The importance of thorough vehicle searches was reemphasized along with the proper technique for the conduct of such searche A notice was published in the plant media advising plant employees that excessive amounts of trash must be removed from vehicles with designated status prior to entry into the protected area to assist security officers with their search responsibilit An additional supply of coveralls was made available for security officers to wear while assigned to vehicle search duties. Periodic unannounced vehicle search drills have been and will continue to be conducte Twelve unannounced vehicle search drills were conducted during the period October 30 -December 3, 1987. The scope of the drills encompassed the "planting" of a simulated weapon in various licensee and con.tractor vehicle The Plant Security Force was successful in all twelve of the drills. It should also pe noted that an undeclared handgun was discovered by security in a vehicle being searched for escorted protected area access on November 20, 1987 (see licensee event report number 87-038-00 dated November 20, 1987). Corrective Actions To Be Taken Current plans are to conduct periodic vehicle search training and continue unannounced vehicle search drills during calendar year 1988. RESPONSE/AN03 Safeguards Inf orrnation Withhold From Public Disclosure