IR 05000266/1986012
| ML20216J143 | |
| Person / Time | |
|---|---|
| Site: | Point Beach  |
| Issue date: | 08/22/1986 |
| From: | Axelson W, Creed J, Pirtle G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20216J035 | List: |
| References | |
| FOIA-87-166 50-266-86-12-01, 50-266-86-12-1, 50-301-86-01, 50-301-86-1, 50-301-86-11, NUDOCS 8707020176 | |
| Download: ML20216J143 (11) | |
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U S. NUCLEAR REGULATORY COMMISSION
REGION III
l Reperts No. 50-266/86012(DRSS); 50-301/86011(DRSS)
Docket Nos. 50-266; 50-301 Licenses No. DPR-24; DPR-27 Safeguards Group.IV Licensee: Wisconsin Electric Power Company l
231 West Michigan Milwaukee, WI 53201
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Facility Name:
Point Beach Nuclear Plant, Units 1 and 2 I
Ir.spection Conducted: July 18, 1986 onsite August 6-7, 1986 at Region III office i
Enforcement Conference Conducted:
August 13, 1986 at Region III office Date of Previous Physical Security Inspection:
April 2-20, 1986 Type of Inspection: Announced Special Physical Security Inspection
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l Inspector: 3b-f^
h G. L. Pirtlec
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Physical Security Inspector
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Reviewed By:
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. R. Creed, Chief Date Safeg rds/ection
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Approved By:
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W/ L. Ax61 son, Chief Date ~
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l Nuclear Materials Safety and
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l Safeguards Branch
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i Inspection Summary
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Inspection on July 18 through August 7,1986 (Reports No. 50-266/86012(DRSS);
No. 50-301/86011(0RSS))
s i i l Areas Inspected: Included a review of the circumstances surrounding the degradations of vital area barriers and security event reporting requirements t
identified in 10 CFR 73.71(c). The inspection was conducted by one NRC
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G inspector and was initiated during the dayshift.
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Results,:
The licensee was found to be in compliance with NRC requirements
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v except t's noted below:
I a.
Physical Barriers - Vital Areas:
On three occasions between January 21, 1985 an'd July 13, 1986, a vital area barrier was degraded without proper compensatory measures being implemented.
b.
Records and Reports:
Between January 2} and 27,1985, two security
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eventis involving a loss of physical security effectiveness were not
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reported to the NRC as required by 10 CFR 73.71(c).
Additionally, a weakness was noted in the alarm station operator initial
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performance evaluation program.
(Details:
UNCLASSIFIED )
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DETAILS i
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1.
Key Persons Contacted 4'
a.
During Onsite Inspection
- C. Fay, Vice President, Np11 ear Power Department, Wisconsin Electric Power Company (WEPC)
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- J. Zach, Plant Manager (WEPC)
'J. Knorr, Regulatory Engineer (WEPC)
- D. Ivey, System Security Officer (WEPC)
- R. Krukowski, Security Supervisor (WEPC)
- D. Marcelle, Security Specialist (WEPC)
- R. Hedberg, Owner, Guardian Protective Services (GPS)
- R. Nelson, Manager (GPS)
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- B. Kopetsky, Site Commander (GPS)
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- E. Krueger, Project Coordinator, Fox Valley Technical Institute li (FVTI)
'J. Antoon, Project Coordinator (FVTI)
T. Wasmund, Sergeant (GPS)
J. Smith, Sergeant (GPS)
R. Leemon, Resident Inspector, U.S. NRC Region III
- Denotes personnel briefed on the inspection findings on July 18, 1986.
O b.
Enforcement Conference Attendees (August 13. 1986)
Licensee Attendees C. Fay, Vice President, Nuclear Power
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T. Zach, Plant Manager, Point Beach Nuclear Plant D. Ivey, Corporate System Security Officer
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R. Krukowski, Security Supervisor (PBNP)
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NRC Attendees 1'
I J. Keppler, Regional Administrator
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J. Hind, Director, Division of Radiation Safet,y
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and Safeguards
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B. Berson, Region III counsel B. Stampleton, Enforcement Coordinator W. Axelson, Chief, Nuclear Materials Safety i
and Safeguards Branch I
D. Kosloff, Acting Chief, Reactor Projects Section 28 j
G. Pirtle, Physical Security Inspector R. Leemon, Resident Inspector, USNRC Region III I
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2.
Entrance and Exit Meeting At the beginning of the inspection, the Plant Manager was informed of the scope of the inspection and the purpose of the visit. The inspector met with the licensee representatives denoted in paragraph I at the conclusion of the onsite inspection on July 18, 1986.
A brief description of the scope of the inspection and the tentative inspection findings were discussed.
No written material pertaining to the inspection wss left with the licensee or contractor representatives.
Listed below is a
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synopsis of the subjects discussed and the licensee's comments pertaining to the subjects:
a.
The circumstances pertaining to the July 13, 1986 security event pertaining to an unalarmed, unlocked, and unguarded vital area door was discussed.
The licensee representatives stated that the facts presented by the inspector were correct based upon available information at the time.
The immediate corrective actions pertaining to the security event were discussed and considered adequate.
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inspector noted that two other events similar to the July 13, 1986 event had occurred in early January 1985 and corrective actions for those security events did not appear adequate to prevent recurrence.
(Refer to Paragraphs 4.a and b for related information.)
i b.
The inspector also advised personnel present that the NRC Region III
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followup inspection of the July 13, 1986 security event showed that
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the two similar events which occurred in January 1985 were not reported to NRC, HQ as required by 10 CFR 73.71(c).
The licensee d
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representatives stated that the failure to report the events was because of their misunderstanding of the reporting requirements.
They noted that their Point Beach Security Procedure pertaining to reporting of security events had recently been revised to correct the error.
(Refer to Paragraph 3 for related information.)
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The licensee representatives were advised that the inspection findings would be reviewed by NRC Region III management and the final inspection report would contain the formal perspective for the inspection results.
They were also advised that items a and b noted above may warrant consideration for escalated enforcement actions. The security management representatives were requested to advise NRC kegion III of any additional
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information they became aware of pertaining to the three issues noted above. Subsequent to the onsite inspection, the licensee management was advised that an Enforcement Conference would be held at the NRC Region III office on August 13, 1986 to discuss the inspection findings.
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3.
Records and Reports (IP 81038):
One apparent violation was noted as a result of the inspection.
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10 CFR 73.71(c) requires licensees under a specific or general a.
license to notify the NRC Operations Center of a major loss of security effectiveness within one hour of discovery by any member of the security organization or any other employee of the licensee, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after discovery of a moderate loss of physical security effectiveness.
Footnote 2 of the Reporting of Physical Security Events Table in 10 CFR 73.7)(c) defines a major loss of physical security effective-ness to include, among other incidents, security features breakdown without compensation allowing unauthorized or undetected access to a vital area.
Footnote 5 of the same table defines moderate loss of physical security effectiveness as a breakdown in security features protecting vital areas which leaves these areas under the protectiort of only one security system.
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Contrary to the above, on January 2'/,1985, a major loss of physical security effectiveness involv an unloc
, unalarmed, and uncompensated vital area doo ecurred and the licensee failed to report the security event to t e NRC Operations Center.
Additionally, on January 21, 1985, a moderate loss of physical security effect s inv ving an unalarmed and uncompensated vital area doo ccurred and the licensee failed to report the secu event o the NRC Operations Center.
In both I
cases cited above, required licensee internal reports were prepared (206/86012-01; 301/86011-01).
b.
Because of the length of time since the security events occurred, specific detailed information about the two security events (January 21 and 27,1985) could not be remembered by the personnel interviewed by the inspector.
The inspector's revi of Securi Violation Report
. 85-01 showed that vital area doo was put into the "
ss" mode at 024 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> on January 21, 1 o allow the pas brou h the door and ure e door an The hen exited th roug anot door. " Access
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the vital How r, th ompensate or the uter controlled inactivat resulted in d ing locked by but ttempts roug e door, or the door was not compensated for by the se ty force.
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degraded barrier alarm was not discovered by the security force until 2352 hours0.0272 days <br />0.653 hours <br />0.00389 weeks <br />8.94936e-4 months <br /> on January 21, 1985. Therefore, the degraded barrier alarm condition existed without compensatory measures being implemented for about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />.
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The inspector's w of Security Violation Report No. 85-02 showed t
that vital doo as erroneously accessed for on hour and 16 f
minutes during the idnight shif t on January 27,19 6 The specific
time the door was accessed was not indicated on the security violation report and personnel interviewed could not recall the specific time the security event occurred.
Howeve e security violation repo indicate hat vi area doo as in the
" accessed" mod or one hour nd 16 minutes.
Interview resu ts showed that compensa y measures were not implemented for the period of time that the door was in the " access" mode and the lack of compensatory measures was the cause for the security violation report being written.
l The licensee expressed significant concern about the alarm station operators' poor duty performance in a memorandum, dated January 29, 1985, from the licensee's Security Specialist to the manager of the contract security organization.
Both of the security events cited above were identified as-examples of inadequate performance by alarm station operators, c.
Interviews with licensee security managers disclosed that the security events reporting procedure in effect at the time of the January 1985 events erroneously identified security event reporting requirements. At that time, Point Beach Security Procedure (PBSP)
1.10, titled " Reporting of Physical Security Events," defined major ss of ical securit ef ess as, a other exa s,
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Secur ty events required by the PBSP to be repor with 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> included " properly compensated ccess control to vital areas when all securit features breakdown Uncompensated access control failure was not identified as a reportable event. The procedure also identified the wrong NRC office to be notified of physical security events and the required time of implementation of
compensatory measures for reporting purposes was also erroneous.
In response to a late event reporting violation cited during an
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i April 2-10, 1986 inspection, the licensee stated in writing that the
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procedure had been modified to address the inspector's concerns (Refer to Inspection Report Nc. 50-266/86005 and 50-301/86005 for relatedinformation.)
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Access Control - Personnel QP 81070): One apparent violation was noted as a result of the inspection, a.
Section 11.1.1.2 of the Poi Nuclear P1 nt Plan i
re uires all access portal i
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l Section 11.1.2.1 of the Point Beach Nuclear P1 n
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recuires the detection system to immediate1
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l Section 5.3.1.3 o he Point Beach Nuc1 Plant Securit Plan l
requires internal Figure 5.1 oint ch Nuclear Plant Security Plan identifie 5 vital area doors under various
plant operating cor.dition.
Contrary to the above, on January 27, vital are as improperly placed in the " ace
m e for about an hour and minutes without compensatory measures ing implemented. Additionally, on July 13, 1986, the same vital area door was accessed for about 29 minutes without compensatory measures being implemented. During above time ess to the vital areas could be gained Both security events occurre during a weekend or extended 1.ito a backshif t period and both reactor units were operational during the time the securit events occurre Additionally, on ary 21, 1985, the for vital area door as inactivated f.or
.:pproximately 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> without compensatory measures being implemented (266/86012-02; 301/86011-02).
I The inspector's review of the above cited security events showed that alarm station operators error was responsible for the vital area doors being erroneously accessed.
Interviews and record reviews showed that in the January 27, 1985 and July 31, 1986 instan
, the central alarm 5 ion (CAS) operator had intended to access ut entered an incorrect The error consiste f
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rather the which i
a vital area oor un er the p ant ope *ating conditions t at existed at the time of occurren-ea door During accessing of security related the second station (SAS)
erator is re utred to
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t In both cases, the SAS ope f
o t the incor ommand and concurred wit As of abo
February 1985, af ter
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device was accessed.
Interviews with the AS o erator on dut on Jul 13 1986 confirmed that he f iled to The inspector could confirm if the same fai ure to n the occurred on Jar.Jary 27, 1985.
The licensee's corrective actions, as indica d in rit lation Report No. 85-02, after the January 27, 1985 rror consisted of disciplinary action for the alarm station opera rs involved, and counselli of other alarm station
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more aware of t There were indica ns from r dr that the alarm statio erators were also This restr on was terminated in early bruary 1985 by memoran um.
Inspector interviews wi contractor security mana ers could not confirm if th
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prompted by the anuary
, 1985 security event or for anot r reason.
The licensee's corrective actions as a result of the January 27, 1985 security event was not effective in preventing recurrence as evidenced by the identical type of event occurring on July 13, 1986.
Immediate corrective actions, after initial response, for the j
July 13,1986 security event included:
i ina etion for J
the alarm station operators involved; j
(3) reinstruct on on proper proce ures (4) briefing of the security force to increase awareness; and (5) initiation of an analysis by the licensee's M are cha could be made to rovide closer The licensee's immediate corrective actions addressed the inspect 5 initial concerns.
b.
During the inspector's followup on the January 27, 1985 and July 13, 1986 security events, the inspector noted that another incident occurred on January 21, 1985 whereby a vital area door was left in an accessed mode for about 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br /> without compensatory measures being implemented. This wa less significant the vital area involved was secured by an wever, e door did lack the require f
or the entire period it was in the access mo e (13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />) and arm station operator error was the primary cause for the barrier degradation. (Refer to Paragraphs 3.a and 3.b for related information pertaining to the January 21 and 27,1985 security events).
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5.
Training and Qualification Requirements (IP 81501)
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The inspector reviewed alarm station operators initial training and t
qualification to determine if a training deficiency may have contributed to the problems noted during the inspection (barrier degradation, failure
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to implement compensatory measures, and security event reporting i
i deficiencies). The inspector was unable to determine the adequacy of the initial training and evaluation given to alarm station operators because of a lack of documentation involving training topics and initial evaluation of performance criteria.
Section 10.0 of the licensee's Security Force Training and Qualification Plan requires alarm station operators to demonstrate to the satisfaction of the licensee Security Supervisor that they can meet all site procedure requirements, in support of the security and contingency plan.
Interviews with the licensee Security Supervisor showed that he observes and evaluates alarm station operators prior to the rformin un rvised duties (other than on-the-b trainin status I
J This issue is cons ered a programmatic weakness in the alarm station operator training program (266/86012-03; 301/86011-03)
6.
Enforcement Conference g
An enforcement conference was held in the NRC Region III office on August 13, 1986 as a result of the preliminary inspection findings which identified apparent violations of NRC requirements.
The attendees for the enforcement conference are noted in Paragraph 1.b of this report.
The purpose of the conference was to:
(1) discuss the apparent violations, their significance and causes, and the licensee's corrective actions; (2) determine whether there were any aggravating or mitigating circumstances; and (3) obtain other information which would help determine the appropriate enforcement action.
During the enforcement conference, Mr. J. Keppler, Regional Administrator, j
described the purpose and scope of the meeting as well as the NRC enforcement policy in reference to concerns raised as a result of the July 18 through August 7,1986 inspection findings.
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The licensee's presentation included a description of the security deficiencies noted in Sections 3 and 4 of this report, corrective actions implemented and proposed for future implementation, and their perspective j
of the significance of the events. Although the licensee representatives ogreed the discussed security deficiencies were significant, they noted l
that no threat or damage to the plant or public occurred and the Commission decision on enforcement action should consider these factors along with the adverse affect a civil penalty could have on morale, plant
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operations, and relations with the adjacent community.
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I The NRC staff expressed significant concern about the licensee's security
'ii staff failure to recognize the seriousness of the potential violations, I
the ineffectiveness of initial corrective actions, and subsequent failure to fulfill security event reporting requirements.
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