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Partially Deleted Insp Repts 50-498/87-25 & 50-499/87-25 Details.No Violations or Deviations Noted.Major Areas Inspected:Security Plan & Procedures,Audits,Records & Repts, Mgt Effectiveness,Security Organization & Locking Sys
	ML20206E680
Person / Time
Site:	South Texas
Issue date:	06/03/1987
From:	; NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV)
To:	;
Shared Package
ML20206E665	List: ML20206E661; ML20206E680;
References
	FOIA-87-590, FOIA-87-A-92 50-498-87-25-01, 50-498-87-25-1, 50-499-87-25, NUDOCS 8811180161
	Download: ML20206E680 (11)
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1. Parsons Contacted

Lictnsee

R. E. Carethers, Senior Engineer

A. O. Hill, Manager, Nuclear Security

W. G. Isereau, Supervisor, Operations Quality Assurance

C..L. Kern, Manager, Safeguards Services

D. R. Lamb, Supervisor, Security Operations

H. S. Monteith, Senior Specialist, Quality Assurance

D. E. Moore, Supervisor, Investigations / Assessments

"J. R. Moore, General Supervisor, Nuclear Security

M. A. McBurnett, Manager, Support Licensing

"J. J. McGrath, Foreman, Computar Support

"J. B. Neal, Supervisor, Nuclear Security

L. J. Ryley, Manager, Protective Services

W. H. Smith, Supervisor, Nuclear Security Training

E. L. Stansel, Supervisor, Computer Suoport Services

D. L. Sheesley, Security Coordinator

J. T. Westermeier, Project Manager

A. W. Woods, Supervisor, Outage / Modifications Support

"A. S. Worth, Coordinator, Nuclear Security

Others

D. Carpenter, NRC Senior Resident Inspector

R. G. Kattner, Be' * )1, Lead Architect

J. J. LaMontague, Bechtel, Construction Manager

R. M. Manek, Bechtel, Architect

Denotes attendance at the exit interview.

The NRC inspectors also interviewed several other licensee employees and

members of the contractors' staff.

2. Inspectors Observations

The NRC inspectors discussed the following observation:, with the licensee

during the exit interview. These observations are neither violations nor

unresolved items. They were identified for licensee consideration for

program improvement, but they have no specific regulatory requirement.

The licensee indicated that these items would be considered.

Access Control Personnel - 81070-02.04 Identification and

Authorizatioi - FBI Criminal History Rule - The licensee plans to

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load fuel durTng the period when the Comission may waive certain

requirements on i terporary basis. (see 10 CfR 73.57,

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8811100161 001028

PDR FOIA

D AUltAN O7-A-92 PDR

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Section(b)(2)(v)). The licensee intends to prepare an interim

procedure which will describe those personnel who are effected and

describe their status as it relates to this rule. The procedure,

which is identified as "Plant and Safeguards Information Temporary

Access Procedure," 0T0P02 25 0001, is intended to comply with the

Physical Security Plan anj f t's accompanying procedures, as written

and at the same time meet the intent of the new rule. All personnel

requiring unescorted access and or access to safeguards information

will be considered temporary employees r tingent upon favorable

results from the FBI fingerprint check. This procedure expires

7 80 days after the issuance of the Unit perating license.

' The elements of that procedure are:

'a. All personnel requiring unescorted access must satisfactorily

complete all elements of Section 6.2 of Intercepartmental

Procedure (!P) 7.2Q, Revision 2 or Section 6.5 of that IP before

unescorted access may be authorized.

b. Personnel will be allowed only one temporary clearance for a

period not to exceed 180 days,

c. Fingerprints shall be submitted to the NRC within 10 days from

the date of grar. ting the temporary clearance,

d. Personnel requiring access to safeguards information must g

satisfactorily complete all elements of IP 7.2Q, Revision 2 or

this procedure (OTOP02 25-0001) before access may be authorized.j

Locks, Keys, and Combinations Vital Keys 8104602.05-TheNRC

inspector expressed concern about the current procedure intended to

, control access to vital equipment.

. An appropriate procedure

' sho# d be developed to eddress this' issue. NUREG 0992, concerned

witr the security and safety interface issues, thould be reviewed and

the significant agrss points must be identified and the instructions

forpostingissuel

Hanggement Ef fectiveness - Establishment of Policy 81020 02.02 The

ERC inspector reviewed the firearns training program in view of

concerns that wtre raised about teaching techniques at the firing

range. Records were reviewed and interviews were conducted and the

NRC inspector concluded that the range program was operated in a

fashion similar to a military or police firearns training program,

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This is appropriate for the regulatory program set out for the

Ilcensee. It was, however, also observed that a pattern appeared to

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be developing concerning those that failed the firing qualifications.

It appeared that some mechanical adjustments, such as interchangeable

grips, and personal considerations could have improved the learning

situation. The licensee was i.iformed that these matters m1y be of a

regalatory nature since they effect competence and were of concern to

the NRC inspector. The licensee was requested to evaluate these

concerns and provide some explanation of program efforts to correct

this potential problem.

3. Program Areas Inspected

The following program areas were inspected. Unless otherwise noted, the

inspection was completed and revealed nc violations, deviations,

deficiencies, unresolved items, or open items. The inspection included

interviews with cognizant individuals, observation of activities,

independest 4asurements, and record reviews. The depth and scope of

these .v. Nities were consistent with past findings and with the current

stat'. O' the facility. Notations af ter a specific inspection item are

used to identify the following: I = item not inspected or only partially

, inspected; V = violation; O = deviation; U = unresolved ites; and 0 = open

item.

81018 Security Plan and Procede es - (see paragraph 4)

02.01 Review of Plan Changes

02.02 Management of Security Procedure Development (!)

02.03 Administration of Procedures (1)

02.04 Evaluation of Procedures Effectiveness (1)

02.05 Method for Changing Procedures (!)

81020 Management Ef fectiveness - Securit f_regras

02.01 Effective 3ess in Auministe. ing Security Program (1)

02.02 Management Awareness / Attitude (!)

a. Establi.Wnt of Policy (see paragraph 6)

b. Delegation

c. Review and followup

d. Schedule Maintenance

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e. Decisinn Making

81022 Security Organization

02.01 3ecurity Organization (!)

02.02 Contract Guard Force (1)

02.0) On Site Security Direction (!)

02.04 1.iaison with tocal Law Enforcement Agencies

02.05 Nurter of Responders (I)

02.06 Responses (!)

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81034 Security Program Audit

02.01 Frequency of Audit (I)

02.02 Audit Personnel (I)

02.03 Comprehensiveness of Audits (I)

02.04 Audit Report (I)

02.05 Quality of Audits (I)

02.06 Audit Report Findings (I)

02.07 Response to Audit Remarks (I)

02.08 Audit of Contracts (I)

81038 Records and Reports

02.01 Reports of Theft and Sabotage (I)

02.02 Reporting Security Events (I)

02.03 Security Personnel Training and Qualifications Records (I)

02.04 Access Control Program Records (1)

02.05 Testing and Haintenance Records (I)

02.06 Service Notification Records (I)

02.07 Routine Activity Records (I)

02.08 Retention of Records / Reports (I)

02.09 Quality of Records and Reports (I)

81042 Testing and Maintenance

02.01 Adequacy of Testing / Maintenance (I)

02.02 Security Equipment Reliability Program (I)

02.03 Testing and Maintenance of Security Equipment (I)

02.04 Performance Testing of Alarms (I)

02.05 Performance Testing of Communications (I)

02.06 Tests During Construction and Installation (I)

02.07 Preoperational and Initial Acceptance Tests (I)

02.08 Service Notifications

81046 Locks, Keys, and Combinations

02.01 Lock ar.d Key Control System (I)

02.02 Changes to Control Access (I)

02 03 Penetration Resistance (I)

02.04 Protection of Key Controller (I)

02.05 Protection of Override Features (I)

81052 BysicalBarriers-ProtectedArea_(PA)

02.01 Adequacy of PA Barriers (I) (see paragraph 5)

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02.32 PA Barrier (I)

02.03 Separation of Barriers (I)

02.04 Ir11ation Zones (I)

02.05 Pi king Areas (I)

02.06 Construction of PA Barrier (I)

02.07 Barrier Maintenance (I)

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81054 ,

Physical Barriers - Vital Areas (VA)

02.01 Location of Vital Equipment in VA (I)

02.02 VA Within the Protected Area (I)

02.03 Separation of Barriers (I)

02.04 Penetration Resistance (I)

02.05 Barrier Bullet Resistance (I)

02.06 Channeling to Entry Control Points (I)

81058 Security Syster Power Supp )

02.01 Adequacy Emergency Power Supply (I)

02.02 Uninterruptible Puwer Systems (I)

02.03 Independent Power for Non-Port M e Comrunications

Equipment (I)

l 02.04 Switchover (I)

81062 Lighting - (see paragraph 6)

02.01 Adequacy of Lighting (I)

02.02 Heasurement of Lighting (I)

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02.03 Illumination for Monitoring and Observation (I)

02.04 Illumination of Access Portals (I)

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02.05 Illumination of Ready Rooms (I)

02.06 Illumination of Alarm Stations (I)

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02.07 Illumination of Vital Equipment (I)

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81064 Compensatory Heasures

02.01 Development of Compensatory Measures (I)

02.02 Employment of Compensatory Heasures (I)

l' 02.03 Effectiveness of Compensatory Measures (I)

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81066 Assessment Aid; - (see paragraph 7)

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02.01 Provision of Assessment Aids (I)

l 02.02 Adequacy of Assessment Aids (I)

02.03 Protected Area Assessment Aids (I)

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1 02.04 Alarm Station Monitoring (I)

02.05 System Security (I)

02.06 Eye Augmentation Equipment (I)

02.07 Vital Equipment / Fuel Assessment (I)

02.08 Special Observation Posts (I)

81070 Access control - Personnel - (see paragraph 8)

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02.01 General System Observation (I)

03.02 Pr)tected Area Access Control (I)

02.03 Vital Area Access Control (I)

02.04 Control of Activities Internally (I)

' 02.0E Identification and Authorintion (I)

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02.06 Badging (I)

02.07 Searching and Search Equipment (I)

02.08 Escorting (I)

02.09 Access Control Facilities and Equipment (I)

81072 Access Control - Packages

02.01 Control of Package and Material Access Points (I)

02.02 Package and Material Search (I)

02.03 Package Authorization (I)

02.04 Off Loading Packages from' W hicles (I)

02.05 Protection of Admittance Control (I)

02.06 Control of Materials Entering Containment (I)

02.07 Control of Materials on Site (I)

81074 Access Control - Vehicles

02.01 Control of Vehicle Access (I)

02.02 Searching of Vehicles (I)

02.03 Protection of Admittance Control (I)

02.04 Control of Vehicles on Site (I)

02.05 Control of Designated Vehicles (I)

81078 Detection Aids - M tected Areas - (see paragraph 9)

02.01 Detection Systems Capability (I)

02.02 Zoning of Alaim System (I)

02.03 Alarming of Emergency Exits (I)

02.04 Detection Systems Security (I)

02.05 Maintenance of Detection Zones (I)

81080 Detection Aids - Vital Areas

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02.01 Detection System Capability (7)

02.02 Alarming of Emergency Exits (I)

02.03 Detection Systems Security (I)

81084 Alarm Stations

02.01 General Performance Requirements and capabilities (I)

02.02 Redundancy and Diversity (I)

02.03 Protection of Alarm Stations and Systems Security (I)

02.04 Alarm Annunciation (I)

81088 Comunications

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02.01 Continuous Comunication (I)

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02.02 Hard-wired Comunications Systems (I)

l 02.03 Radio Comunications Systems (I)

02.04 Duress Alarms (I)

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81501 Personnel Training and Qualification - (see paragraph 10)

02.01 Develop an Appropriate Sample (I)

02.02 Training and Qualifications Program (I)

02.03 General Training (I)

02.04 Demonstration of Abilities (I)

02.05 Documentation (I)

02.06 Employment Suitability and Qualification Criteria (I)

02.07 Physical Fitness Qualifications (I)

02.08 Security Knowledge, Skills, and Abilities (I)

02.09 (N/A to STP)

02.10 Requalifications (I)

02.11 Weapons Programs Qualifications /Requalifications (I)

02.12 Equipment for Security Officers (I)

02.13 Contract Personnel (I)

81601 Safeguards Contingency Plan Implementation

02.01 Review Contingency Plan Changes (I)

02.02 Availability of Capabilities (I)

02.03 Procedures Detailing Actions and Decisions (I)

02.04 Review and Program (I)

02.0L Evaluate Implementation of Safeguards Contingency Plan (I)

81810 Protection of Safeguards Information (SGI)

, 02.01 General (I)

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02.02 Access to SGI (I)

02.03 Disclosure (I)

02.04 Protection While In Use (I)

02.05 Storage (I)

02.06 Marking (I)

l 02.07 Reproduction (I)

l 02.08 Destruction (I)

02.09 Transmission of SGI (I)

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02.10 Use of ADP Systems (I)

02.11 Removal from SGI Category (I)

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4. Security Plans and Procedures

Tefinalreviewofthesecurityrelatedplansisbeingprocessedandit

is anticipated that the proposed license condition will hold with the

March 20, 1987, submittal of the physical security and security personnel

qualification and training plan and the March 29, 1985, submittal of the

, safeguards contingency plan. All the procedures and preoperational

l implementation will be inspected against those approved documents. The

finalization of related procedures is being handled under an HL&P punch

listnumberedA8Z-010. This list is related to the NRC Open

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Item 498/8637-01. ,

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5. Physical Barriers - Protected Area (PA) 81052

'3eNRCinspectorsobservedthelicensee'sphysicalbarriersintoe

protected area to determine compliance. The areas inspected included the

,fenceline, the interim fenceline between Units 1 and 2, and the

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'The inadequacies are (,idividually listed in HL&P memo A87-017. This item

will remain open until the licensee has corregted all inadequacies and is

being tracked under NRC Open Iten 498/8637-12.]

6. Lighting 8106?

The NRC inspectors attempted to review the status of lighting to determine

compliance and observed that the protected area is cluttered with

equipment and temporary buildings to the point that an adequate lighting

system can not be installed or tested. This item will remain open until

the area has been cleared and lighting tests conducted as set out in the

licensee's punch list A87-020. Open Item (453/8725-01)

7. Assessment Aids 81066

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Lin'a'd5acieY afe~individLillf TiuEh listed as A87-022, in a licensee

memorandum dated May 7, 1987. This item will remain open until the

licensee has corrected all inadequacies and the system is ready for

inspection. This is currently be ng tracked under NkC Open

t Items M H 37-18 and 498/8722-03.

8. Access Control Personnel - 81070-02.05 Authorization (Allegation 4-86-A-096)

! The NRC had received an allegation that the licensee had administered the

psychological screening test in an unfair manner which caused the alleger

to fail the test on two separate occasions.

The NRC inspectors examined the licensee's access authorization program to

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verify that it included a psychological testing program to satisfy the

Physical Security Plan and the industry standards to which the plan

commits. The purpose of the inspection was to verify that the licensee

has screened the personal histo-ies and personality characteristics of all

employees seeking unescorted access to the facility. This is done to

ascertain the reliability of those seeking access to this regulated area.

The plan commitments are a licensing condition. The related Nuclear Group

Policy for this matter is NGP-434. After lockdown, an individual's

processing is to be successfully completed prior to being allowed

unescorted access to the site. This will require that the licensee

establish, well before lockdown, a caref.11y designed program which

utilizes standard validated testing instruments, and that the scores of

these objective tests are reviewed by professionals who conduct clinical

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interviews to evaluate the results of those tests that score outside the

norm. A professional judgement is rendered to ensure that the objective

tast was not misused and that the tested person's personality

characteristics are in fact outside the norm in categories and degrees of

abnormality, sufficient tc present an unreasonable risk and prevent

unescorted access to tha facility.

In anticipation of licensing, HL&P designed a program to satisfy the

stated references and began program implementation in 1977.

A list of critical positions was established and the first group of

individuals to be evaluated were selected new hires in the Training and

Operations divisions and new hires in some supervisory positions.

Assessments began in 1978 for employees who were scheduled to visit other

nuclear power facilities that were already licensed and who required

certificatinn for unescorted access.

Other categories of personnel were phased in during the period 1982 to

present to include secuiity and all other positions located at the

South i'exas Project or at Houston if they require unescorted access. The

program was also introduced into the pre-employment process. As time went

by, the program was enhanced to the point of very high quality which is

exemplary within the nuclear industry.

The following references provide the basis fo" the use of the

i psychological evaluation as a screening tool as well as the guidelines for

I conducting these assessments:

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l * ANSI /N18.17 - 1973 (Industrial Security for Nuclear Power Plants)

ANSI /ANS-3.3 - 1982 (Security for Nuclear Power Plants)

NUREG/CR-2075 (Standards for Psychological Assessment of Nuclear

r acility Personnel)

NUREG/CR-2076 (Behavioral Reliability Program for the Nuclear

Industry)

STPEGS IP-7.2Q (Nuclear Plant Access Authorization System)

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HL&P management expressed by policy statement that all individuals

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requiring unescorted access to STPEGS would be required to successfully

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The applicant takes the following battery of tests:

I - Purdue Adaptability

- Vocational Preference Inventory (VPI)

- Gordon Survey of Personal Values

- Minor Sentence Corrpletion Scale

- Hinnesota Multi-phasic Personality Inventory (MHPI);

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This testing is supervised by a specially trained person. Clinical

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interview is conducted by a qualified psychologist.

A report to HL&P that recommends one of three actions regarding

certification for unescorted access: certification with special

monitoring under the HL&P Behavioral Observation Program, er denial

of certification.

Prior to rendering that opinion, questionable results are reviewed by

other professionals on the staff.

Prior to reporting to HL&P that they decline recommendation of unescorted

access, two additional checks are made. The MMPI test is computer scored

to rule out a grading error and a comprehensive review is made by an

outside clinical psychologist. These results are forwarded to HL&P for

final determination.

As an example of the process, in 1985, testing was conducted for some

individuals who were then current employees of STP. Of those tested, a

list of six individuals were identified who appeared to score outside the

estabitsbed norm. To support the clinical evaluation, additional data of

a personal nature was requested. Also, some individuals did not answer a

significant number of questions in the MMPI and the test was

readministered to them. The psychological consultants and HL&P management

personnel considered ways to deal with the matter of those six individuals

who could not be recommended for unescorted access, as a result of the

total process. Reportedly, it was decided that since the license

requirement was not yet in place, a 6-month waiting period would be

scheduled. After the period, five of the individuals were retested and

suspended with p)y pending an outcome of the latest test series and a

personnel decision. One of the original six had been terminated for

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This review concluded in recommending that two be certified for unescorted

access. The other three were denied certification and a variety of

personnel options were offered to them.

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The quality of the program observed by the NRC inspectors exceeds the

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commitments in the Physical Security Plan. The NRC inspectors concluded

f that the psychological screening program was administered in a

professional, fair manner.

l 9. Detection Aids - Protected Area 81078

The NRC inspectors reviewed the area bounda detection aids to

termine compliance.

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The inadequac'es were i

liste an te as lmicensee punch list A87-026. This item is

currently being tracked under NRC Open item 498/8637-19 and will rem

openuntilthesystem'sadequacycanbedeterminedthroughinspection@.

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10. Personnel Training and Qualification 81501

The NRC inspectors met with the security training supervisor to discuss

the progress being made toward preparing a lesson plan to match each of

the criticai elements listed for the security officers. This matter is

being carried as NRC Open Item 498/8714-09 and the licensee has

established punch list A87-030 for tracking that matter,

11. Exit Interview

The NRC inspectors met with Mr. A. O. Hill and other members of the

South Texas Project staff, on May 1,1987, to summarize the scope and

findings of the inspectior,.

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ML20206E680

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