IR 05000309/1985011

Physical Security Insp Rept 50-309/85-11 on 850428-0502.No Noncompliance Noted.Major Areas Inspected:Security Plan & Implementing Procedures & Security Organization.Details Withheld (Ref 10CFR73.21 & 2.790)

ML20133C716
Person / Time
Site:	Maine Yankee
Issue date:	07/11/1985
From:	Bailey R, Keimig R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133C681	List: IR 05000309/1985011 ML20133C679
References
50-309-85-11, NUDOCS 8508070118
Download: ML20133C716 (9)

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U. S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No. 50-309/85-11 Docket N License No. DPR-36 Licensee: Maine Yankee Atomic Power Company 83 Edison Drive Augusta, Maine 04336 Facility Name: Maine Yankee Atomic Power Station Inspection At: Wisscaset, Maine Inspection Conducted: April 28 - May 2, 1985 Date of Last Physical Security Inspection: August 27-31, 1984 Type of Inspection: Routine, Unannounced Physical Security Inspector: M Ejf- [ '

7. //- M R. Y Bailey, P[ysica'Inspecorgity e date Approved by: Mc Keimif, Ch c afeguards

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Inspection Summary: _ Routine, Unannounced Physical Security Inspection on

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April 28 - May 2,1985 (Inspection Report No. 50-309/85-11)

Areas Inspected: Security Plan and Implementing Procedures; Security Organization; Management Effectiveness; Security Program Audits; Records and Reports; Testing and Maintenance; Physical Barriers (Protected Area); Physical Barriers (Vital Areas); Training and Qualification Records; and, follow-up cn previously identified violations, inspector follow-up and unresolved item The inspection involved 34 man-hours onsite by one region-based inspector and began during a Sunday, day shift. Five hours were spent during off-shift period Results: The licensee was found to be in compliance with NRC requirements within the nine areas examine PDR ADOCK 05000309 0 PDR

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DETAILS Key Persons Contacted J. Garrity - Plant Manager B. Marshal - Director of Security H. Tolberg - Site Security Supervisor

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R. Crosby - Quality Assurance S.~Nichols - Licensing Department The inspector also interviewed other licensee employees and members of the Hall contract security organizatio ; MC 30703 - Exit Interview The inspector met with the licensee representatives listed in paragraph I at the conclusion of the inspection on May 2, 1985. At that time, the purpose, scope and results of the inspection were reviewed. At no time during this inspection was written material provided to the licensee by I the inspector. The inspector stated that he had observed test grading-disparities in the security training and requalification program. In response, the licensee had regraded all examinations using a more stringent grading criteri As a result, two individuals, who had previ-ously requalified, scored below the acceptance standard in one portion of a four part examination. Each individual was retested and the tests were graded using the revised criteria. Both passed the examinatio The licensee committed to take the following corrective actions by May 17, 1985 as a result of their review of this matter: Security qualification and requalification tests will be reviewed and revised, Security qualification and requalification test anse r keys will be reviewed and revised to preclude answers that are broadly subjective and, therefore, can lead to grading disparitie Security training lesson plans will be reviewed and revised where necessary, to conform to existing security procedure The security supervisor will review all test material, procedures and training documentation on a quarterly basis and record the results of his revie The inspector requested that these actions be documented in a letter to NRC Region I by the close of business on May 2, 1985. The licensee agreed and complied with the request. (See also paragraph 13 of this report.)

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3 MC 92701 - Follow-up on Inspector Identified and Unresolved Items The following Inspector Identified (IFI) and Unresolved Item (s) (UI) which contain SGI or COF1, were closed during this inspection: IFl 83-09-04; IFI 83-09-06; IFI 83-09-08; IFI 83-09-09; IFI 84-20-04; and VI 84-20-0 THIS PAGE CONTAINS SAFEGUAROf INFORMATiON AND IS NOTFOR PUBLIC CIEi.0SURE, ITIS INTENiiDEnf LEFT BLAN .

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THIS PARAGRAPH CONTAINS SAFEGUARDS INFORMAT!0M 3D IS NOT FOR PUBLIC DISCLOSURE,liISINTENil0NALLY -

LEFT BLAN (Closed) Inspector Follow-up (50-309/84-20-02): Review of security procedures pertaining to locks used on security containers that protect safeguards information. The inspector verified that the licensee published a written security procedure, No. 15-15, Revision 2, dated April 18, 1985 which, in paragraph 10, outlines the audit and combination change requirements for all account holders maintaining safeguards informatio (Closed) Inspector Follow-up (50-309/84-20-01): Review the scope of irdependent security program audit. The licensee was advised by the inspector to include other aspects of the security program that were not specifically identified to be audited in the Physical Security Plan; for example, Training and Qualification Plan, Security Contingency Plan, security event reporting and the protection of safeguards informatio The inspector reviewed the independent quality assurance audit MY-85-4, dated February 11-15, 1985 and observed that the licensee hcd included the protection of safeguards information. The licensee stated that other aspects of the program would be included in subsequent audit . MC 92702 - Follow-up on Violations The following violations, which contain SGI or C0FI, were closed during this inspection: 81-02-01; 83-09-01; 83-09-05; and 83-09-0 .

THlS PARAGV'" CONTAINS SAFEGUARDS INFORMAT'0F 'I'0 IS NOT FOR PUBLIC

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THIS PAGE CONTAINS SAFEGUAROS INFORMAT10M AND IS NOT FOR PUBLIC 015JLDSURE, Itis INTENTi0 natty LEFT BLAN .

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THIS PAUGPAPH CONTAINS SAFEGUA995 INFORM Aif v tND IS NOT FOR PUBLIC DISCl0 Sire. d 15 INTEN110NAllY LEFT Bt AN (Closed) Violation (50-309/84-12-02): Improper access control. An NRC inspector had observed an individual who failed to folicw proper access control procedures when entering the plant. The inspector verified on April 29, 1985, that the actions enumerated in the licensee's reply to the violation had been taken, and observed that Security Officers were implementing proper access control procedure (Closed) Violation (50-309/84-20-05): Failure to qualify all armed security officers in accordance with the physical security pla The licensee's reply to this violation stated that all officers previously qualified incorrectly were requalified in accordance with the security plan by September 4, 1984 and that future fitness demonstrations would be accomplished accordingly. The inspector verified that this had been accomplished by a records review and personal interview . MC 81018 - Security Plan and Implementing Procedures The inspector audited portions of the licensee's security program and found that they conformed to the security plan and implementing procedures. Plant safety was not observed to be adversely affected by security programs, procedures, or equipmen . MC 81020 - Management Effectiveness The licensee's security management staff and contractor management and superviscry staff appeared effective in discharging their responsibilities with respect to the security program. Additionally, in response to several discrepancies identified by the inspector in the qualification and requalification training program, the licensee's security management and security contractor management responded promptly with a technically sound and thorough approach to analyzing and resolving the problem. (See paragraph 13 of this report.) MC 81022 - Sacurity Org.anization The licensee's security management structure and chain of command were in conformance ith the approved physical security plan, contingency plcn, procedures, and applicable regulatory requirements, and were adequate and appropriata for their intended function In addition, the licensee has a management system to provide for the developmant, revision, implemon-tation and enforcement of physical protection procedure .

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7 MT. 81034 - Security Program Audit The licensee properly audited the security program with qualified persons who were incependent of both security management and supervision. Tne most recent audit of the program (MY-85-4) was conducted on Feb rua ry 11 - 15, 1935. Reports of audits conducted over the past five years were noted by the inspector to be in the files and were readily accessibl . MC 81038 - Records and Reports The insoector reviewed security logs and records for accuracy, comple-teness, abnormal conditions, significant changes and trends, required entries, and proper reporting. The following records and logs were reviewed: Training records, training test material, door alarn records, dr.d weekly functional alarm check sheet . MC 81042 - Testing and Maintenance THIS PARAGRAPN CONTAINS SAFESUFIDS INFORMATl0N ANDIS NOTFOR PgalN DISCl0SURE,ITISINTENTIONALLY LEFT BLANN, 11. MC 81052 - Physical Barriers (Protected Area)

The inspector observed that the licensee maintained the physical barriers around the protected areas in conformance with the security pla During a review of Figure 3.1.1.1 of the approved Physical Security Plan, the inspector observed that a particular exit door is not depicted as part of the protected area barrier but was considered as such. The licensee was advised to correct this in the next revision to the security pla (Inspector Follow-up Item 50-309/85-11-01.)

1 M^ 81054 - Physical Barriers (Vital Areas)

,The inspector observed that the licensee maintained the physical barriers surrounding the vital areas in conformance with the security pla . MC 81501 - Training and Qualification (T&Q) Plan During a review on April 30, 1985, of security training qualification and requalification records maintained by the security force contractor,

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the inspector observed that qualification tests previously graded by the security force training officer contained apparent discrepancies. The inspector, using the authorized test answer key determined, with the aid of the site security supervisor, that the scores on several tests graded by the training officer were several percentage points higher than those graded by the inspector. The training officer stated that since many questions on the tests were poorly worded, ambiguous or outdated,

~he accepted some answers which were different than those on the answer key and, in some cases, assigned partial credit for incomplete or partial answer However, even given that explanation, the inspector and site security supervisor found it difficult to assess the answers and apply the same the grades as the training officer did. The inspector stated i that, because of the highly judgmental nature of the grading process, he [

could not accept the scores as being valid. Additionally, the inspector '

could not find prescribed controls for the administration of qualification /

requalification testing in the Training and Qualification (T&Q) Plan or in the written security procedure In'the absence of such administrative control, and because of the judgement used in grading the tests used to qualify the security force, the inspector stated ~that a more definitive method of scoring the training test results would be necessary in order to determine whether the security force was qualified in accordance with the T&Q Plan. When the licensee was apprised of the inspector's findings, six individuals were selected to comprise a team under the Director of Security to regrade all tests that had been administered to qualify the current security force members. After the licensee developed consistent and accurate answers and grading criteria for each of the four examinations, the examinations were regraded. The regrading process resulted in grades being reduced on an average of 5.6 point The regrading process established that all security force members were qualified to perform security duties with the exception of two individuals who scored below the 70*J acceptance criteria in one of the four test ^ One individual was retested on May 1 and the other on May 2, 1985; both passed the tes The licensee committed to implement the following actions by May 17, 1985, to correct the problem: review and revise the security qualification /requalification tests; review and revise the test answer keys;and, ensure that there is compatibility between the lesson plans, security procedures and tests. The inspector requested the licensee to document these commitments in a letter to Region I by the close of business on May 2, 1985; the licensee complied. In addition to the actions mentioned above, the licensee committed to requiring the security supervisor to review all test material, procedures and training documen-v tation on a quarterly basis and formally record the results of that revie The licensee advised the inspector by telephone on May 8, 1985 that all security qualification /requalification test and test answer keys had been reviewed and revised, as necessary, and they are currently being c

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used for annual requalificatio During this telephone conversation the inspector reminded the licensee of the commitment made during the exit interview concerning the review and revision of lesson plans. This commitment was not incluoed in the licensee's May 2 letter to Region The licensee representative stated that all phases of the contractor's training program would be closely monitored by the site security superviso In a telephone conversation on May 13, 1985, the licensee advised the inspector that a procedure to control the integrity of tests, answer keys and test material was being develope The licensee was advised during the May 8 and 13 telephone conversations that the commitments made at the exit interview and in writing to Region I will be reviewed along with the effectiveness of the actions at a future inspection of their security program. (Inspector Follow-up Item 50-309/85-11-02.)

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