IR 05000461/1989019

Partially Withheld Safeguards Insp Rept 50-461/89-19 on 890206 & 0522-0607 (Ref 10CFR73.21).Violations Noted.Major Areas Inspected:Mgt Support,Protected & Vital Area Barriers, Access Control - Personnel,Packages & Vehicles & Testing

ML20245H473
Person / Time
Site:	Clinton
Issue date:	06/23/1989
From:	Pirtle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20245H443	List: IR 05000461/1989019 ML20245H441 ML20245H458
References
50-461-89-19, NUDOCS 8906290496
Download: ML20245H473 (4)

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, .U.S. NUCLEAR REGULATORY COMMISSION REGION.II Report No. 50-461/89019(DRSS)

Docket No. 50-461 License No. NPF-62 Licensee: Illinois Power Company 1 500 South 27th Street Decatur, IL- 62525 Facility-Name: iClintion Power Station, Clinton, Illinois Inspection At': Clinton Power Station Inspection Conducted: February 6, 1989 onsite May 22 - June 2, 1989 onsite June 7, 1989 in NRC Region III Office Type of Inspection: Unannounced Physical Security Inspection Date of Previous Security Inspection: ~ July 25-29, 1988 Inspectors: ~ 13.hb O23 /99 Date'

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G. L. Pirtle Ph 1 al y Inspector J. L. tieIanger

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6/25/ A9 Physical Security Inspector Date Approved By: / ' d' 23 [7 '

/J. R. Creed, Chief g/g Date Safeguards Section Inspection Summary Inspection Between February 6 and June 7, 1989 (Report No. 50-461/89019(DRSS)

Areas Inspected: Included Management Support; Protected end Vital Area Barriers; Access Control - Personnel, Packages, and Vehicles; Alarm Stations and Communications; Testing, Maintenance and Compensatory Measures; Training

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and Qualification; Licensee's Planning and Implementation of Strike Plans; Licensee's Actions for Previous Inspection Findings; am, noview of Licensee's Actions Pertaining to an Allegatio Results: The licensee was in compliance with NRC requirements in the areas inspected, except as noted below:

• Training and Qualification: Six newly hired security officers did not receive all of the training required by the Security Force Training and Qualification Plan prior to being assigned security shift duties in  ;

February 198 Enclosure Contains

~ 8906290496 890623 Upon Separation This

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.One of two previous inspection findings were closed. The remaining inspection finding was being adequately addressed by the licensee and it pertained to a modification for permanent heating, ventilation, and air conditioning I' capability for the security computer room. The need for revised compensatory l- measures to cope with a multiple security component f ailure contingency was identified. One segment of an alarm system experiences excessive out-of-service time. The interior alarm point false alarm rate requires further reduction. Strike contingency security operations appeared effective and well managed. Several additional positive observations were noted pertaining to j security force facilities, generally excellent procedural guidence, and conservative approach in implementation of compensatory measures and logging of security event (Details - UNCLASSIFIED )

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ATTACHMENT - ALLEGATION REVIEW-(Closed) Allegation RIII-89-A-0037 (IP 99014): 'This Allegation was sent to

-Illinois Power Company on March 30, 1989,. for investigation and resolutio The allegation consisted of_three parts and pertained to: (1) some newly

. hired security force members.at the time of the security force strike did not. receive all training required by the Security Force Training and

. Qualification Plan (SFT & QP); (2) non-task related training subjects were not completed by the newly hired personnel as required by the SFT & QP; and

.(3) requalification task. certification was being performed on-the-job and not within'a classroom environment as required by the SFT & QP. The above training deficiencies were allegedly caused by licensee management's decision to use the r.ewly hired security officers as soon as possible as contingency

. members.to cope with the. security force strik NRC Review: The licensee's investigation results and conclusions were provided

.to NRC Region:III by letter dated May 1, 1989. The licensee concluded, and the NRC Region III staff agreed, that non-task related training subjects were not specifically required by the SFT & QP to be completed prior to assignment to security shift dutie The NRC Region III staff review also agreed with'the licensee's conclusion that the -SFT & QP allowed requalification task certifi-cation to be. completed on-the-job as well as in the classroo As a result of an inspection conducted between May 22 - June 7, 1989, the NRC Region III staff did not agree with the licensee's conclusion that the newly hired personnel received all of the training required by the SFT & Q Section 2.2.3 of the SFT & QP requires all security force personnel assigned to security-related duties to successfully demonstrate the capability to perform all crucial security tasks under the conditions and to the standards specified on the applicable Job Analysis Worksheets prior to assignment to the specific shift involve Section 2.2.4 of the SFT & QP requires that prior to fulfilling a security force position, an individual will be qualified and certified in that positio The Individual Responsibility Matrix and the Position Description within the SFT & QP for Unarmed Security Force Members identifies 35 crucial . tasks that such personnel must be trained for and/or demonstrate the capability to perfor Contrary.to the above, six security force members assigned to security shift duties in February 1989 were not trained or had not demonstrated the capability to perform 18 of the 35 crucial tasks identified in the SFT & QP for unarmed personnel. Specifically, tasks pertaining to security contingency events and alarm assessment were not evaluated to confirm demonstrated capabilities for these tasks (461/89010-04).

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h Of the six personnel, four were no longer performing security duties as of May 22, 1989-(start of onsite-inspection). The two remaining personnel were i

trained and certified as qualified in the Armed Security Force Member position-in May 1989. . This certification process required training and evaluation on the 18' crucial tasks which were not evaluated when the personnel were'

initially assigned to security shift duties.

, A major. contributing factor to the violation was that the SFT & QP does not-address in specific detail variations in training and qualification certifica-tion for security officers hired or deployed to. function as contingency force members. The licensee agreed to revise the SFT & QP to. identify specifically what training, qualification, certification, and. documentation requirements will apply.for security contingency force personnel. The revised SFT & QP change would be completed within two months after receipt of this inspection report as required by 10 CFR 50.54(p) and will be reviewed by NRC Region III (461/89019-05).

Another contributing factor was the security staff's incorrect understanding that personnel required training only in tasks assigned or performed. The SFT & QP identifies training required'by " position" regardless of the tasks the person may or may not perform. Additionally, some of the six officers were used for compensatory posts that would require knowledge of some of the crucial tasks they.had not been evaluated or certified as proficient to perfor Conclusion:

The allegation that some newly hired security officers were not trained in all crucial tasks required by the SFT & QP was substantiated. The other two allegations were not substantiated. The causes of the training deficiency were lack of couplete understanding of SFT & QP requirements by security force managers, and lack of specific guidance in the SFT & QP pertaining to contingency force training, certification, qualification, and documentation requirement The licensee's agreement to revise the SFT & QP and submit the revision for NRC Region III review should resolve the issue and prevent recurrenc Therefore, a written response to the violation will not be requeste SAFEG *ntains UP on S S"

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