IR 05000341/1996008

Insp Rept 50-341/96-08 on 960812-16.No Violations Noted. Major Areas Inspected:Security Organization & Administration

ML20128K595
Person / Time
Site:	Fermi
Issue date:	10/02/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20128K557	List: IR 05000341/1996008 ML20128K552
References
50-341-96-08, 50-341-96-8, NUDOCS 9610110113
Download: ML20128K595 (10)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Docket No: 50-341 License No: NPF-43 Report No: 50-341/96008 Licensee: Detroit Edison Company (Deco)

Facility: Enrico Fermi, Unit 2 Location: 6400 N. Dixie Hwy.

Newport, MI 48166 l Dates: August 12-16, 1996

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Inspector: G. Pirtle, Physical Security Inspector 4 Approved by: James R. Creed, Chief Plant Support Branch 1

9610110113 961002 PDR ADOCK 05000341 G PDR

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EXECUTIVE SUMMARY i l

Enrico Fermi, Unit 2 NRC Inspection Report 50-341/96008 i i

This inspection included a review of the physical security program. It was an announced inspection conducted by a regional physical security specialist.

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i Four inspection followup items were noted pertaining to: (1) the security plan not describing the type of firearm actually used by the security response force (Section S3); (2) a revision to the security section of the Updated Final Safety Analysis Report (Section S8.7); (3) excessive loggable security events caused by security force personnel errors (Section S4); and (4) failure to complete a required evaluation for a security instructor (Section SS).

Five of six open inspection findings were closed (Section SS).

Appropriate utilization of the Deviation Event Report program by the security organization appeared evident (Section S7); and transition to a contract security force appeared to be progressing well (Section S6). The Quality ,

Assurance audit of the security program was considered a program strength 1 (Section S7). The security staff responded appropriately to a positive for-cause fitness-for-duty test involving a security supervisor (Section S8.8).

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Report Details S2 Status of Security Facilities and Eauioment

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a. Inspection Scope (81700)

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

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included, but was not limited to, search equipment, intrusion alarm equipment, and equipment within the alarm stations. Operation of the closed circuit television system was also evaluated.

b. Observation and Findinas Most security components required only limited compensatory measures and had a very high inservice time. When required, adequate compensatory measures were implemented for inoperable security equipment. The inservice time for the Closed Circuit Television (CCTV) system had improved significantly since the previous inspection (refer to Section S8.2 for details),

c. Conclusions Observed security facilities were well maintained and security equipment functioned as designed.

S3 Security and Safeauards Procedures and Documentation i

a. Inspection Scope (81700)

The inspector reviewed selected security procedures pertaining to the '

areas inspected and also reviewed appropriate logs, records and other documents pertaining to the activities inspected.

j b. Observation and Findinas During the Operational Safeguards Readiness Evaluation (0SRE) conducted in March 1996, the security department demonstrated their ability to effectively counter the security design basis threat. A specific weapon was used by the security force during the OSRE inspection as the primary weapon for the response force members but the weapon is not identified in the security plan as required. The security staff agreed to submit the appropriate security plan change to identify the weapons that will be used by the response force. This is an inspection followup item (50-341/96008-01).

c. Conclusions Procedures reviewed were of good quality and correctly described the tasks to be performed. Personnel observed and interviewed on post were familiar with procedure requirements applicable to their responsibili-ties. Other documents and logs reviewed were accurate. A security plan

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l change will be submitted pertaining to weapons used by response force members.

S4 Security and Safeauards Staff Knowledce and Performance a. Inspection Scope (81700)

l The inspector toured various security posts and observed performance of I duties. Interviews with security officers were conducted to determine ;

if the officers were knowledgeable of post requirements. Security event logs and other records pertaining to security force performance were also reviewed.

b. Observation and Findinas During review of Security Event logs and Security Department trending data, a recent significant increase was noted in the number of loggable i security events caused by security force errors. For the entire year of l 1995, 27 loggable security events were caused by security force errors.

In only the first six months of 1996, 22 loggable events were attributed to security force errors. Of the 22 events,13 occurred between April '

and June of 1996. There appeared to be no pattern or common thread among the events noted in 1996, except that they were personnel errors.

Therefore, it is not clear at this point if the recent significant increases are isolated occurrences or if the error rate is a precursor to a significant adverse performance trend. Monitoring the number and type of loggable security events caused by security force errors will be an inspection followup item (50-341/96008-02).

No performance deficiencies were noted during visits to the security posts. Personnel interviewed and observed were aware of post responsibilities and procedures.

S5 Security and Safeauards Staff Trainina and Qualification a. Inspection Scope (81700)

The inspector reviewed randomly selected training and qualification records for newly hired security force personnel. The procedure pertaining to initial training and qualification requirements was also reviewed. Additionally, the inspector attended two security training classes.

b. Observation and Findinas Section 5.15.3 of Security Procedure SEP-SEl-04, " Initial Training, Requalification, and Firearms Policy" Revision 8, dated May 31, 1996, requires all individuals assigned instructional responsibilities to be evaluated annually and the results of the evaluation to be documented.

Inspector interviews showed that one of the six security department l instructors did not receive an annual evaluation. The evaluation was t not completed primarily because of lack of an effective method to i'

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monitor such evaluations. It should be noted that the Security Force Training and Qualification Plan, which is approved by the Commission, does not address evaluations of security instructors. The Director, Nuclear Security will assure that the required evaluation will be completed within 30 days after receipt of this inspection report and the evaluation results will be documented. Completion of the evaluation will be an inspection followup item (50-341/96008-03).

No deficiencies were noted during the review of randomly selected initial training and qualification records for newly hired security force personnel. The inspector confirmed that the personnel were qualified in the appropriate job related critical tasks prior to being formally assigned to shift assignment positions. Personnel fulfilling job positions requiring physical examination, physical fitness testing, and use of firearms had completed the necessary requirements prior to assignment to these positions.

The inspector also attended two classes conducted for newly hired security force personnel . Lesson plans were available and the presentations were conducted in accordance with the lesson plans.

c. Conclusions Training records reviewed for newly hired security personnel were complete and accurate and personnel were critical task certified prior to assuming shift job positions in a non-training status. One Security Department instructor had not received an annual evaluation. Observed training classes were completed in a professional manner.

S6 Security Oraanization and Administration a. Inspection Scope (81700)

The inspector reviewed the progress of transition from a licensee security force to a contractor security force.

b. Observation and Findinas Transition from the current proprietary security force to a contractor security force appears to be progressing in accordance with the licensee's plans. A contractor site manager position has recently been filled and authorization for four contractor shift security supervisor positions has been approved. Approximately 40 of the 55 security contractor personnel have been hired ard trained since the beginning of 1996. No deficiencies were noted during review of selected training records. The major concern at this point is the limited experience level of the vast majority of the contract security force personnel.

This limited experience level may contribute to the potential for further personnel errors and subsequent Deviation Event Reports and loggable security events.

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I l l c. Conclusions i

! The transition to a contractor security force was progressing satisfactorily.

S7 OualitY Assurance in Security and Safeauards Activities a. Inspection Scope (81700)

The inspector reviewed the most recent annual audit of the security program and other programs used by the Security Department for problem identification and correction.

b. Observation and Findinas The recent Nuclear Quality Assurance (NQA) audit of several elements of the security program was considered a strength. The audit (Report No.

96-0120) was conducted between May 28, and June 14, 1996, and involved about 340 person hours. The audit results were well documented. The status of security-related Deviation Event Reports (DERs) initiated by NQA and the status of NRC and NQA open items were also well documented.

The audit was effective in identifying weaknesses, particularly in the training department.

The Security Department uses the Deviation Event Report (DER) program as an element of their methodology for problem identification and correction. Based upon interviews with several security force members and review of DER related documents and reports, the DER program seems to be generally understood and supported by the security force. During a joint security /NQA assessment in late 1995, NQA noted that some security incident reports should have been documented and evaluated via the DER process. Additionally, an Ombudsman evaluation dated May 3, 1996, identified that there were indications that DERs were viewed by some security personnel as a drastic, almost hostile step to take to get action completed. The security staff is addressing both observations and encouraging full participation in the DER program. The inspector's interviews indicated that the security personnel appreciated the purpose for the DER program, and expressed a willingness to submit DERs when they felt they were warranted. However, it was also noted that some contractor security personnel were uncertain if they could submit DERs.

It was further noted that there appeared to only be informal training given about the DER system. The number of security related DERs has increased for the first six months of 1996 when compared with the last six months of 1995, which identified a tendency or willingness to use the program. The status of security-related DERs was effectively monitored and tracked by the security staff.

The security staff continues to conduct self-evaluations. However, it was noted that three evaluations for the first six months of 1996 covered security shift operations. Security self-evaluations which have ,

been conducted are well documented and findings adequately evaluated and resolved.

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The inspector noted that the security department did not complete a self-identified commitment to review causes for security force errors.

A determination was made by the licensee that the security department and NQA department would conduct a joint evaluation of the causes for security related DERs caused by personnel errors. The joint assessment plan approved by the Directors of Security and NQA identified five activities for the security department to complete and three activities for NQA to complete. All of the activities identified in the joint assessment plan were to be completed in the fourth quarter of 1995. One of the five compliance evaluations tasked to the security department was not completed. The compliance evaluation which was not completed pertained to alarm station operations. The joint analysis results were somewhat weakened and incomplete by not having the benefit of the alarm station operations evaluation results as agreed to in the joint evaluation plan.

c. Conclusions Self-assessment efforts for the security program were varied and included NQA audits, department self assessments, DER program, and other elements. With the exception of the NQA audit, the overall self-assessment effort does not appear to be as strong as has been noted during past inspections when the self assessment efforts were considered a program strength. The limited number of security shift operations self assessments for 1996 and failure to complete a self-identified evaluation for alarm station operations is the basis for this conclusion.

S8 Miscellaneous Security and Safeauards Issues S8.1 (Closed) Inspection Followup Item 50-341/95006-03: Security contingency training had decreased because of delays in such training caused by the long turbine related outage and demands on the security force during the outage. Additional training was completed for the Operational Safeguards Readiness Evaluation inspection which was successfully completed in March 1996. This item is closed.

S8.2 (Closed) Inspection Followuo Item 50-341/95011-03: Closed circuit television (CCTV) cameras were out-of-service excessively. During 1995, four cameras accounted for about 30% (4000 hours0.0463 days <br />1.111 hours <br />0.00661 weeks <br />0.00152 months <br />) of the total out-of-service time for all security equipment. For the first six months of 1996, the CCTV camera system has had an out-of-service time of about 400 hours0.00463 days <br />0.111 hours <br />6.613757e-4 weeks <br />1.522e-4 months <br />. Considerable maintenance effort has been expended to resolve this concern. This item is closed.

S8.3 (Closed) Insoection Followup Item 50-341/95012-09: Two examples of incorrect compensatory measures were implemented during September 1995.

Corrective actions for this item have resulted in no similar type of compensatory measure failures since September 1995. This item is closed.

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S8.4 (Closed) Inspection Followuo Item 50-341/96002-14: Inadequate procedure guidance for the control, handling, and administration of psychological evaluation tests, and the control of initial diagnosis documentation was identified. The appropriate procedure has been revised to address these areas. This item is closed.

S8.5 (00en) Unresolved item 50-341/96002-15: This issue addressed the licensee's contractor's current practice of only releasing documents relating to psychological evaluations to other psychiatrists or psychologists. This practice essentially required individuals to retain a psychologist or psychiatrist for the sole purpose of receiving and l possibly evaluating the conclusions for access denial for psychological

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purposes. This practice appears contrary to published NRC Guidance.

This issue is still being reviewed and therefore will remain open.

S8.6 (Closed) Inspection Followup Item 50-341/96002-11: Records for access authorization stored off site had an identified retention period less than required by the licensee's procedure or the NRC rule. Record

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l retention and disposition documents reviewed during this inspection l

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identified a retention period greater than the period required by the rule. This item is closed.

S8.7 A recent discovery of a licensee operating their facility in a manner l contrary to the Updated Final Safety Analysis Report (UFSAR) description l highlighted the need for a special focused review that compares plant practices, procedures and/or parameters to the UFSAR descriptions.

While performing the inspections discussed in this report, the inspector reviewed the applicable porth.ns of the UFSAR that related to the areas

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inspected. The inspector verified that the UFSAR wording was consistent j with the observed plant practices, procedures and/or parameters.

, The security section of the UFSAR had some instances of unclear and

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currently incorrect terminology. The review of the security section of the UFSAR was completed by the licensee's security staff in July 1996.

The inspector conducted an independent review of the UFSAR and the security staff's review results. An inspection followup item will be assigned to monitor completion of the needed changes to the security j section of the UFSAR (50-341/96008-04).

S8.8 On August 15, 1996, the licensee's security staff briefed the inspector i on the positive Fitness-For-Duty (FFD) test for a security supervisor.

The positive test results were for alcohol and the testing was conducted under the criteria of the licensee's for-cause testing aspects of the FF0 program. Additional FFD testing was completed for possible drug abuse and those test results were negative. The supervisor's unescorted access authorization was terminated on August 15, 1996, pending further

evaluation and analysis. The supervisor was referred to the licensee's Employee Assistance Program for evaluation and assistance. The incident was reported to the NRC as required by 10 CFR 26.73.

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XI Exit Meetina Summary The inspector presented the inspection results to n: embers of licensee management at the conclusion of the inspection on August 16, 1996. The licersee acknowledged the findings presented. Actions agreed to by the security staff to address the inspection findings were discussed during the exit meeting.

The inspector asked the licensee whether any materials examined or inspection findings discussed during the exit meeting should be considered as proprietary or safeguards information. No proprietary or safeguards information was identified.

PARTIAL LIST OF PERSONS CONTACTED Licensee:

P. Fessler, Plant Manager L. Goodman, Director, Nuclear Licensing B. O'Connor, Manager, Nuclear Assessment J. Korte, Director, Nuclear Security E. Kokosky, Superintendent, Radiation Protection T. Stack, Supervisor, Security Operations Support N. Peterson, Supervisor Compliance J. Louwers, QA Specialist J. Pendergast, Licensing Engineer J. Milton, Acting General Supervisor for Security Operations C.

Deardoff,

Site Manager, Stanley Smith Security A. Hickman, Ombudsman i

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INSPECTION PROCEDURE USED

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IP 81700 Physical Security Program for Power Reactors l

ITEMS OPENED, CLOSED, AND DISCUSSED l

Opened i 50-341/96008-01 IFI Security Plan Revision to Identify Primary Weapons for ;

Response Force Members 50-341/96008-02 IFI Recent Increase in Loggabe Security Incidents Caused by Security Force Errors 50-341/96008-03 IFI A Required Annual Evaluation of a Security Instructor Was Not Conducted and Documented 50-341/96008-04 IFI Revision to the Security Section of the UFSAR l is Needed for Clarification and Correct Terminology 1

Closed 50-341/95006-03 IFI Need For Increased Security Contingency Training l 50-341/95011-03 IFI Excessive Out-of-Service Time for Closed Circuit l Television l 50-341/95012-09 IFI Incorrect Compensatory Measures Were Implemented 50-341/96002-14 IFI Inadequate Procedure Guidance for Psychological Tests and Diagnosis Documents 50-341/96002-16 IFI Access Authorization Record Retention

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Discussed 50-341/96002-15 URI Retaining a Psychologist or Psychiatrist to Receive Copies of Psychological Evaluation Results.

LIST OF ACRONYMS USED DER Deviation Event Report FFD Fitness for Duty IFI Inspection Followap Item URI Unresolved Item OSRE Operational Safeguards Readiness Evaluation NQA Nuclear Quality Assurance

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