IR 05000277/1989080

Physical Security Insp Repts 50-277/89-80 & 50-278/89-80 on 890105-27.Major Areas Inspected:Security Program Mgt & Effectiveness,Personnel Experience & Qualifications,Testing & Maint & Licensee self-assessments & Audits

ML20236B863
Person / Time
Site:	Peach Bottom
Issue date:	03/16/1989
From:	Bellamy R, Cameron D, Keimig R, Skelton R, Galen Smith, Sylvester E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236B850	List: IR 05000277/1989080 ML20236B846
References
50-277-89-80, 50-278-89-80, NUDOCS 8903210336
Download: ML20236B863 (18)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report No /89-80 50-278/89-80 l

50-277 DPR-44 Docket No License No DPR-56

Licensee: Philadelphia Electric Company '

2301 Market Street Philadelphia, Pennsylvania 19101 Facility Name: Peach Bottom Atomic Power Station, Units 2 and 3 Inspection At: Delta, Pennsylvania Inspection Conducted: January 5-6 and 23-27, 1989 j Type of Inspection: Special, Physical Security Team Inspection Inspectors: W &

R. R. Keimig, Team Leader, Region I 3/lle

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, w/ S shy D. F. Cameron, R6gion I date hrp 3 k6'/P1 R. F. Skelton,' Nuclear' Reactor Regulation date OR IS S T G. C. Smith, Re~gion I date h e 7 E. D. Sylvester, Region I

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Approved by: Q h. M Ro'nald R. Bellamy, Chief, $ cilities r4M date ibl9d i

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Radiological Safety and Safeguards Branch Inspection Summary: Special, Announced Physical Security Inspection on January 5-6 and 23-27, 1989 (Combined Report Nos. 50-277/89-80 and 50-278/89-80)

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Areas Inspected: Security program management and effectiveness. 'ersonnel experience and qualifications, plans and procedures; testing anu maintenance; review of licensee self-assessments and audits; review of licensee actions on previously identified violations and Regulatory Effectiveness Review corrective action Results: The licensee has established a significantly improved and effective security organization, and is implementing a performance-oriented and more effective security program than has existed in the past.

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DETAILS l Key Persons Contacted Philadelphia Electric Company (PECo)

• Bird, Nuclear Security Specialist M. Bruecks, Shift Security Specialist

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-i J. Carolan, I&C Supervisor q G. Cary, Shift Security Assistant l J. Chipp,.0perations Sh.ift Manager

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• J. Devlin, Nuclear Security Consultan *J. Franz, Plant Manager

• D.-Meyers, Manager, Support Division

• J. Pratt, Manager,_ Quality Assurance J. Slaymaker, Shift Security Assistant

• D. Smith, Vice-President, PBAPS R. Thomas, Shift Security Assistant

• R. Weindorfer, Director, Nuclear Plant Security Corporate Support ^

A. Wyatt, Shift Security Assistant M. Utz, Shift Security Assistant Protection Technology Inc. (PTI)

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• Brockman, Security Force Supervisor

• King, Training Coordinator

• Nagle, Regional Training Manager

• Pelligrini, President

• Shires, Operations Lieutenant

• V Vitale, Regional Vice-President Other

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• H. Abendroth, Senior Engineer, Atlantic Electric Company

• Phillips,. Senior Engineer, Public Service Gas and Electric Company U. S. Nuclear Regulatory Commission j

• Bellamy, Chief, Facilities Radiological Safety and Safeguards Branch

• T. Johnson, Senior Resident Inspector

• L. Myers, Resident Inspector

• R. Urban, Resident Inspector i

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• present at exit meeting on January 27, 1989

Other PECo and PTI personnel, incluaing members of the security force, ]

were interviewed during the inspectio j i

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. Background j Identified deficiencies in the Peach Bottom Atomic Power Station (PBAPS)

Physical Security Program as a result of NRC inspections, licensee assessments, and allegations resulted in a management meeting being held with PEco in February 1988 (50-277/88-02, 50-278/88-02). Despite- 1 corrective actions committed to by PECo, violations with multiple examples l were reported in July-August 1988, and resulted in the NRC issuing Notices i of Violation and Proposed Imposition of Civil Penalties in November 1988 l (50-277/88-26, 50-278/88-26; 50-277/88-31, 50-278/88-31). PECo acknow-ledged the enncerns, paid the civil penalty, and implemented corrective actions. These corrective actions had been initiated by PECo starting in the summer of 1988 as a result of the NRC inspections and PEco self-assessmen PECo reported to the NRC in December 1988 that they believed '

sufficient improvements had been realized for the NRC to reinspect the physical security program at PBAPS. This special inspection was conducted by a team of five specialists to assess the improvements in the PBAPS security progra . Purpose The purpose of this inspection was to assess the following aspects of the .

PBAPS security program with particular emphasis on management support, l management effectiveness, and qualifications of personnel: I Security organization, both proprietary (licensee) and contractor, and licensee management support to that organization; i Security plans and procedures, to include the security plan, the training and qualification plan, and the contingency plan; The testing and maintenance program for security-related systems and equipment; i Actions taken to improve weaknesses identified by licensee self-assessments and by the NRC; Actions taken on previously identified violations; and, Actions taken on findings from the NRC's Regulatory Effectiveness Review (RER). Scope of the Inspection The inspection focused primarily on changes to the security program made in calendar year 1988, in an attempt to determine whether the root causes of the NRC and licensee-identified weaknesses had been, or were being, adequately addressed and corrected. In addition to a review of revised policies, plans and procedures, the inspection team observed security-related systems, activities in progress, and conducted interviews of personnel in, and responsible for, the security organization, as well i

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as other plant personnel who interface, on a regular basis, with members of the security organizatio . Inspection Findings ,

The following represent the basis for and the conclusions of the inspection team (See Paragraph No. 6.) as a result of this inspectio Security Organization f Prior to April 1988, the licensee's site security organization reported directly to the Director of Nuclear Plant Security located in the company's corporate offices. At that time, the Director of Nuclear Plant Security had responsibility for the security program at both the PBAPS and the Limerick Generating Station (LGS). On April 1, 1988, the overall responsibility for the PBAPS security program was tranferred to the Vice President-PBAPS on sit (1) On-Site Proprietary Organizational Structure The licensee's proprietary site security organization is headed by the Nuclear Security Specialist (NSS) who reports directly to the Support Division Manager, under the Vice-President, PBAP The Support Division Manager is responsible for PBAPS security, fire protection, industrial safety, and administratio Reporting to the NSS are a Security Consultant (until

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March 31, 1989), a Technical Assistant, a Chief Security Coordinator, and six Shift Security Assistants (SSAs). Due to company personnel policy considerations, two of these positions are currently filled by personnel in an acting capacit The six SSAs, who report through the Chief Security Coordinator, are responsible for overseeing the performance of the contract security force around-the-clock, and act as the senior security representative on-site in the absenco of other licensee security supervision. In that capacity, they have the authority to direct the activities of the security organizatio While the current proprietary site organization does not represent an appreciable increase in number of personnel over s that which existed early in 1988, a much stronger and more effective organization was evident during this inspection. This is apparently due to a more structured organization, some personnel changes, and better and more comprehensive training of personnel, along with obvious management support of the progra (2) Management Initiatives The focus of the security program has been clearly defined by licensee management, responsibilities are assigned, and l

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performance standards were developed, against which the effectiveness of the overall program implementation can be measure In addition, specific performance indicators are being tracked and data are being compiled in a monthly report that is issued to appropriate levels of licensee management where changes can be effected, if adverse trends are note Additionally, at a minimum frequency of once per month, l management meetings are being conducted to discuss potential i problem areas and other security-related matters. These meetings are attended by the PBAPS-NSS, the LGS-NSS, the Director, Nuclear Plant Security (Corporate Support), and the security force contractor's Regional Vice-President (same contractor for PBAPS and LGS), at a minimum. These meetings have been successful in introducing common program improvements to the licensee's two nuclear stations, and reducing the number of problems between the licensee and its new security contractor (since late August 1988) at the PBAP As a new initiative, the PBAPS-NSS has instituted monthly i meetings between the plant operations staff and the security staf The purposes of these meetings are to resolve any interface problems between the two groups and to exchange information in an effort to reduce both perceived and real problems. During this inspection, members of the inspection team attended one such meeting. That meeting was well-attended by members of each group and was very professionally conducte The meeting included a review of old business, a discussion of new business from an earlier issued agenda, and the recording of minutes. The substantive nature of the agenda items, and the attention given to resolution of common problems indicate that the security program is receiving increased management suppor f Similar meetings are expected to be initiated in the near future !

with other plant groups, e.g., maintenance and health physic l These meetings should serve to integrate the security )

organization with other plant groups and increase each group's understanding of the others' roles and responsibilitie Additionally, a corporate support group, under the Director, Nuclear Plant Security, has been established to assist the licensee's on-site security organizations at both the PBAPS and the LGS. Some of the responsibilities of the grcup are: to effect commonality between the stations; to conduct assessments and evaluations of the programs; to provide liaison with the NRC ]

and law enforcement agencies on generic matters; to oversee the access clearance programs for the plants; to prepare drafts and conduct reviews of program plan changes, modifications and program enhancements; and to conduct investigations, as necessary. The group may also take on responsibilities in other areas, such as fire protection and industrial safety, in the futur _ _ _ _ _ _ _ _ . __ __

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At the time of the inspection, the group was not fully staffed but the inspectors found that the staff that existed had nuclear security experience at both the PBAPS and the. LG '

(3) Proprietary Staffing and Training-The licensee has established and defined the duties and responsibilities of its proprietary- staff-in written policy, procedures and position descriptions. The position descriptions were found to be comprehensive and covered basic functions, requisite qualifications, general and specific duties, relation-ships and interfaces, and notably, performance measurement criteri '

During interviews with the proprietary staff, the inspectors found that the staff members clearly understood their responsi-bilities and authorit The staff was motivated and ,

appeared to be working as a team toward the common goal of implementing an effective security program. This was parti-cularly apparent with the staff's individual and combined efforts in reviewing and upgrading program plans and procedure A brief summary of the experience and qualifications of several proprietary staff members, selected for review by the inspector, follows, a

The PBAPS Nuclear Security Specialist has held various

, security and engineering positions with PECo, including Senior Security Auditor with the Nuclear Quality Assurance Department; assignments in the PBAPS Maintenance Department; and Plant Operator at a fossil statio He has taken numerous engineering and security-related course He is a member of several technical societies, such as the American Nuclear Society and the American Society of Quality Contro He has been in this position since about mid-December 1988 and was extensively involved in the security program improvements since April 1988,

One of the proprietary Shift Security Assistants had thirteen years of experience with a Pennsylvania township police d^partment where he held the position of Shift Supervisor. He has taken numerous courses in police science and criminology at the FBI Academy and at various state and local institution He is certified in the use of many types of police equipment, including weapons, a Another of the proprietary Shift Security Assistants has twenty-eight years of experience with the Pennsylvania State Police where he held the position of Sergeant. He has taken numerous college-level courses in Criminal Justice,

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-* Another of the proprietary Shift Security Assistants has

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several years security experience with a large retail  ;

establishment where he was the Security Manager. He holds a Bachelor of Science Degree in Sociology / Criminology,

• Another of the proprietary Shift Security Assistants has ,

nine years of experience with a Pennsylvania police '

department where he held the rank of Sergeant. Before that (

he served as'a Sergeant in the United States Air Force '

Military Police. He holds a Bachelor of Science Degree in Criminal Justic All proprietary staff members were found to meet the qualifi-cation requirements for their position The inspectors reviewed the formal training program that had been developed for the SSAs, and was.in the process of being -

implemented. The program consists of four phases comprised of i about 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> of lectures and testing. The four phases  !

include training in: security program oversight responsibili- l ties; specific Training and Qualification (T&Q) tasks, as is i required for members of the contract security force; Central and  :

Secondary Alarm Station (CAS/SAS) optrations; and supervisory i techniques and NRC. requirement Lesson plans were developed for each module in each phase, and a review by the inspectors found the lesson plans to be very comprehensiv . Previously, training for the SSAs consisted of informal, or on-the-job sessions and self-study. While this informal training provided orientation for the SSAs, the NRC did not <

consider that it provided them with the requisite knowledge to carry out their duties and responsibilities as the licensee's site security representative. When completed, the formal training program should provide this knowledge. During inter-views and by observation, the inspectors found that the formal and other training received by the SSAs since July 1988 >had made them notably more effective in carrying out their responsibi-lities with regard to overseeing program implementation and ensuring contract security force performanc The licensee had scheduled the SSAs to complete this formal training program by August, 1989. However, through interviews of several SSAs during this inspection, the inspectors determined that certain portions of the formal training program  ;

should be completed more expeditiously. Those portions principally centered around the performance objectives of a nuclear plant security program, familiarization with the NRC's regulations, policies and practices, and contingency event 3 responses. The licensee committed to have all SSAs trained in those subjects by February 18, 198 _ _ _ - _ _ - _ _ _ _ _ _ - _ - - - _ _ __ -

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The inspectors also reviewed the results of testing, conducted l by the licensee in mid-January 1989, of the SSAs' knowledge of l the Training and Qualification (T&Q). Plan tasks. These T&Q' Plan tasks are the same tasks in which each member of the contract security force must show proficiency prior to being found ,

qualified to perform these tasks. The testing indicated that '

the SSAs had a sufficient overall knowledge of those tasks to carry out their duties, but that additional formal training, as opposed to on-the-job training, would enhance that knowledge, particularly with respect to-the details of the tasks. ' That type of training is included in the SSAs training program, as ;

described abov '

(4) Contract Security Force In mid-July 1988, the licensee awarded the security force contract to Protection Technology Inc. (PTI), the same con- ;

tractor that the~ licensee uses at LGS. PTI assumed management i

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of the PBAPS security force in late August 1988. Because many of the previously-identified security program weaknesses were ,

manifested through personnel performance-related problems, which i

.were traced to the previous contractor's lack of proper management, the inspectors also reviewed the new contractor's organization, management philosophy, and training progra ~The contractor's site organization (security force) is headed by the Security Force Supervisor (SFS) who reports directly to a

, Regional Vice-President (responsible for PBAPS and LGS only), )

under the President of PTI. Also reporting to the Regional l Vice-President are a Regional Training Manager ano a Regional

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Business Manager. The Regional Training Manager has a Training Coordinator and a four member full-time training staff, !

dedicated to PBAPS, reporting to him. A PBAPS dedicated Support I Services Manager reports to the Regional Business Manage Reporting directly to the SFS are an Administrative Assistant and an Operations Lieutenant. An Operations Sergeant,  ;

Surveillance Test Coordinator and staff, and a CAS/SAS !

Coordinator and attendants report to the Operations Lieutenan The shift force reports administrative 1y through the Operations _i Sergeant to the Operations Lieutenant during the day and to the SSAs during back shifts. The total contract security force, at i the time of the inspection, numbered 16 The inspectors reviewed the background and qualifications of the .

SFS and found that he had 5 years of management experience at l nuclear facilities, including a nuclear power plant and a Department of Energy facility. In addition, he served for twenty-one years in the U.S. Marine Corps where he gained the rank of Master Gunnery Sergeant. He holds an Associates degree in Business Administration and took numerous courses in security

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while in the U.S. Marine Corps. The inspection team found him j to be very knowledgeable of the PBAPS security program and a f highly effective supervisor, with excellent inter personal ;

skills. He was also found to be very motivated and appeared to i be an excellent leade !

The inspectors reviewed the training and qualification progra for the contract security forc The program was found to be professionally developed, very comprehensive and~ administered by )

an experienced coordinator, four full-time instructors and two j clerk / typists. Lessons plans were clear and detailed, and the I use of training aids was apparent. The inspectors observed, J however, that video equipment was not available to enable the 1 training staff to make its own training tapes. The inspectors i discussed the effectiveness of site specific video tapes as !

training aids with the licensee and the contractor. They agreed 1 with the inspectors and the licensee stated that a video camera

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would be procured for that purpose in the near futur )

During the inspection, the training facilities, which are :

on-site, were relocated to permit more space.and a quieter i environment. The new facility was found to be adequate and clean. The inspectors interviewed the Regional Training Manager, the Trad ning Coordinator and two members of the training staff. All were found to be very knowledgeable of the !

program and enthusiastic about their work. The inspectors also !

audited a portion of a firearms issuance training lectur The

, lecture was professionally delivered and class participation was stron The inspectors noted, however, that while.the instructor clearly stated the issuance requirements, the reasons for the requirements were not clearly presented. This was identified to the licensee and contractor early in the :

inspection and was corrected by modifying all lesson plans, '

prior to the end of the inspection, to incorporate into lectures the reasons behind the various requirement Since the new contractor took over the security force, all members have undergone retraining and requalification in the contractor's program, regardless of their previous experience and training. In order to assess the effectiveness'of the training program and the competence of the security force, the i contractor had recently conducted a statistical-based,  ;

performance testing program. The testing results, which were !

reviewed and confirmed by the inspectors, indicated that, at a -

95% confidence level, a minimum of 95% of the security force are acceptably knowledgeable of their assigned duties and responsi-bilitie This represents a significant improvement over both the licensee's and the NRC's assessments of the security force's performance capabilities during the previous year. The contractor indicated that similar performance testing would be conducted periodically to measure the effectiveness of the l

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.l, training program on a continuing basis. That type of testing was introduced by the contractor at the LGS about two years ago, and was shown to be very effective in improving the training program at that statio l

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The inspectors also interviewed ten randomly selected members of  !

the security force to determine their ability to carry out their l assigned tasks. The interviews indicated that they were very i knowledgeable of their duties. These interviews, and others conducted during this inspection, also indicated that members of the security force had a cositive attitude toward their jobs, were very professional, exhibited high morale, and were very satisfied with the. contractor's management .

(5) Observation of a Contingency Response Drill j At about 5:15 p.m. on January 25, 1989, the inspectors requested that the licensee initiate a contingency response drill at 5:45 p.m.,

during the shift change of the security force. The. drill scenario was provided by the inspectors and was designed to require the participation of the plant operations staff. Members of the NRC's security inspection team and the senior resident inspector observed the performance of the drill from pre-established post The inspection team noted that the response force was properly armed and equipped, dispatched with a minimum amount of delay or confusion, and was prompt and coordinated in the execution of its tasks. The

, attitude of all who participated in the drill was positive, serious, and very professional. All actions were consistent with the NRC-approved security plans and implementing procedures and the interactions between operations and security were sound and cooperative. While several deficiencies were noted during the drill, the inspection team's assessment was that personnel performance, in general, was excellen Subsequent to the conclusion of the drill, a frank and comprehensive critique was conducted. Most of the deficiencies noted by the inspection team were identified by members of the security forc Deficiencies were documented for training and discussion purpose Completion of some of the items referenced in Paragraph 5 f. of this I report should resolve most of the deficiencies identified during the  !

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. Security Program Plans and Procedures An audit of the security program plans and procedures was conducted to determine if recent program changes were being properly reflected i in these document ,

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-(1) Security Plan' 1

.The licensee revised the NRC-approved. security plan (the Plan).

in December 1988 to reflect recent changes-in the security a- '

organization and to incorporate new NRC generic security requirements (Miscellaneous Amendments). Additional revisions ,

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. to the Plan will be required to incorporate more.recent, and

. ongoing, changes to the security program, aquipment and system j The licensee has a program in place to accomplish this and has

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committed to complete the submittal of all Plan changes necessitated by program changes and upgrades by' June 30, 1989, in accordance with 10 CFR 50.54(p). No. deficiencies were noted )

in the current Plan or in the program to maintain the Plan a curren (2) Plant Protection Procedures Plant protection procedores are used to implement the program described in the Plan. The licensee is in the process of revising all existing procedures, and is instituting new procedures, to reflect Plan changes and to clarify the purpose and content of the procedures. The. inspectors found that the procedure revision program was generally in step with the security program changes and upgrades. The licensee expects the-procedure revision program to be completed by June 30, 198 About 20% of the procedures had been revised at the time of this inspectio *

The inspectors reviewed a sampling of the revised procedures and found that, in general, they were clear and well writte However, one weakness was noted. The assignment of responsi-bility for carrying out various supervisory actions was not 2 sufficiently specific to preclude confusion. This weakness was shown to result in some minor confusion during the contingency response drill that was observed by the inspectors. The

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weakness was acknowledged by the licensee and will be corrected L in future revisiov of the procedure In the interim, the licensee committed to ensure that supervisory roles and responsibilities are stressed during training and drill (3) Administrative Instructions Plant protection procedures are augmented by administrative instructions developed by the security force contractor to provide guidance to the security force members for administrative activities. These instructions cover such topics as " Screening of Applicants for Employment as Security Force

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Members", " Performance of Security Surveillance Testing", and

" Preparation and Control of Post Orders". A review of these documents indicated that they are consistent with the

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i requirements of.the Plan,-and are, in general, detailed, logical, and clea (4) Post Orders and Special Orders A sample of post orders and special orders were reviewed, and found to be consistent with the Plan,-plant protection proce-dures and administrative instructions that they implemented.

l Post orders provide instructions to security force members assigned to speci_fic permanent posts. Special orders provide instructions for short-term or temporary posts, and supplement permanent post orders until a revision can be effected. A program is in place for the development, revision and distri-bution ofLpost and special orders, as necessary. New post orders, and changes to existing orders, are discussed at each guard mount, and are subsequently incorporated into the training pla (5) Contingency Plan The January 1989 revision of the PBAPS Contingency Plan was reviewed and found to be consistent with the Plan requirement This latest revision incorporates a contingency matrix which provides a clear outline of the actions and responsibilities of the security force members. A review was also conducted of recent contingency drill records that are maintained by the security force contracto In recent months, the licensee and contractor have conducted a large number of full-response and

. limited-response drills. The contractor uses a computerized tracking system to ensure that all shift members are involved in the monthly series of drills. After the contingency drill conducted during the inspection, licensee'and contractor i personnel carried out a comprehensive oral critique of the exercise,.which was attended by members of the inspection tea This practice was found to be standard after each dril However, the inspectors identified a weakness in that the driil 4 critiques are not always well documented to provide an effective )

mechanism for feedback into contingency response training. The l licensee acknowledged this finding and stated that minimum ]

documentation criteria would be establishe I a Testing and Maintenance The inspectors reviewed the status of the licensee's surveillance testing and maintenance programs for security-related systems and equipment due to previously identified weaknesses. Those weaknesses resulted in the need for a large number of compensatory measures for inoperable equipment, which, in turn, required an excessive use of

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I security manpower, on an overtime basis. The excessive overtime resulted in performance-related problems for members of the security force and, hence, a degradation of the progra l

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(1) Surveillance Testing Program

'The inspectors reviewed the. licensee's new surveillance testing (ST) program for adequacy and consistency with the Plan requirements. That review disclosed, in general, that the licensee has developed and is implementing an effective ST program for security systems and equipment. However, a review of the ST procedures found that they lacked sufficient detail

, and specificity to ensure that the STs would be performed in a

' uniform and consistent manner. When this weakness was brought to the licensee's attention, the licensee. stated that the weakness had been previously identified and that the STs were in j

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the process of being revised by those responsible for doing.the I testing. This was confirmed by the inspectors. A major strength of the program is that ten individuals were designated, L i trained and qualified to perform the STs. A review of the lesson plans used to train and qualify these personnel, inter-views with them and observation of selected STs in progress by the inspectors disclosed that the testing being conducted exceeds that described in the ST program procedures due to the expertise of those conducting the ST The licensee committed to complete the revisions to the ST procedures on or before March 30, 198 (2) Preventive Maintenance Program The inspector's review of the maintenance program disclosed that a preventive maintenance (PM) program had been developed in December 1988, but that, when reviewed by management, it was-found to be unacceptable. Therefore, in January 1989, the licensee initiated action to develop a far more comprehensive program, modeled after the PM program at the LGS, and, one which will include applicable PECo testing and laboratory procedure At the time of the inspection, the licensee had approximate)y '

six PM procedures completed and scheduled for review by the Plant Operations Review Committee (PORC). Those procedures were found to be comprehensive and well-written. The remaining PM procedures are scheduled to be developed and PORC-approved by December 31, 1989. In the meantime, as system and equipment PMs become due, the vendor manual instructions and recommendations will be used if the equipment does not have an approved PM procedur The licensee also committed to have the PM program in a computerized tracking system by March 1,198 l l

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l (3) Corrective Maintenance Program A review of the corrective maintenance program by the inspectors disclosed that it is being performed in a timely manner and that <

the maintenance is generally effective, as evidenced by the lack of frequent repairs on the same equipment. There was one exception to this finding noted by the inspector Review of maintenance requests and history for assessment aids disclosed that repeated maintenance had been required for some of the same equipment to keep it operable. The licensee stated that the frequent maintenance associated with this equipment is due to the age of the equipment. The licensee committed to review this problem and to repair or replace the equipment by February 8, 1989. The licensee also plans to upgrade the protected area intrusion detection system equipment as part of the PBAPS Site Master Plan, starting in 199 Review of Licensee's Actions on Identified Weaknesses The inspectors reviewed the following licensee reports to determine, the adequacy of the licensee's actions and resolutions of previously identified program weaknesses and commitments made to the NR (1) PBAPS Security Corrective Action Follow-up, dated September 30, 1988. This report addressed commitments made to the NRC and PECo Nuclear Quality Assurance (NQA) as a result of NQA Audit AP 88-48 PL. The follow-up was conducted between

, June 27 and September 9, 1988. The report indicated that some commitments had been met but others were still in the process of being carried out. No additional adverse findings were identified during the follow-u (2) PBAPS Security Readiness Assessment, dated November 8, 198 This assessment was conducted between October 20-28, 1988, to determine the status of program improvements and changes made to address deficiencies identified in the licensee's Root Cause Analysis. The report indicated that program and performance improvements were continuing, but that some weaknesses still existe (3) Results of Security Readiness Review by Corporate Nuclear Plant i Security Section, dated November 10, 1988. This report concluded that overall program and performance had been improved, but identified several areas where additional training was necessary prior to NRC revie (4) Security Self-Assessment, dated December 9, 1988. This report, to the Vice-President, PBAPS, documented a meeting of the Security Assessment Committee to review the status of resolution i

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of the weaknesses identified in the reports (1), (2) and (3)

listed above. This report included an action plan and schedule to address the remaining open items and suggested that the PBApS security program would be ready for NRC review by mid-Decembe )

Based upon reviews of the above listed reports, licensee corre-rpondence to the NRC and NRC Inspection Reports, the inspectors determined that the licensee has corrected the identified program weaknesses and has met its commitments to the NRC, with only a few exceptions. At the Exit Meeting for this inspection, the licensee was requested to provide the NRC, in writing, with firm commitment ;

dates for completion of the remaining items. (See Paragraph No. 7 I of this report). Those dates were provided in a February 8, 1989 '

submittal, which is included in this report as Attachment Review of Licensee Actions On Previously Identified Violations The inspectors conducted a review of the licensee's corrective actions in response to the specific violations contained in the Notice of Violation and Proposed Imposition of Civil Penalties issued by the NRC in November 1988. The licensee's corrective actions were contained in a December 15, 1988, letter to the NRC. The results of the review are as follow ,

(1) (Closed) Violations (50-277/88-26-01 and 50-278/88-26-01; 50-277/88-26-03 and 50-278/88-26-03; 50-277/88-31-01 and 50-278/88-31-01): Failure to control access to vital area .

The inspectors determined that all corrective actions had been satisfactorily implemented, (2) (Closed) Violation (50-277/88-26-02 and 50-278/88-26-02):

Failure to follow the requirements for vital area key control and compensating measure The inspectors determined that all corrective actions had been satisfactorily implemented, (3) (Closed) Violation (50-277/88-26-04 and 50-278/88-26-04).

Failure to identify and implement compensatory measures for l protected area assessmer' aids that could not be used for their ;

intended function. The spectors determined that all except i one corrective action hat, eeen implemente The licensee stated )

in its reply to this violation that the Surveillance Test (ST) a procedures for assessment aids would be reviewed and revised by December 31, 198 The inspectors found that the procedures had been reviewed but were still in the process of being revised l along with other STs. (See Paragraph No. 5.c.(1) of this '

report). The inspectors determined, however, that the STs for assessment aids are now conducted in such a manner as to prevent recurrence of violations of this typ The revised ST pro-cedures that reflect the upgraded surveillance tests for the l assessment aids are scheduled for issuance, along with all other ST procedures, by March 30, 1989.

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I Review of Licensee's Response to Regulatory Effectiveness '

Review (RER) Findings From September 27 to October 2, 1987, the NRC conducted a RER at the PBAPS. The results of the review were communicated to the licensee by a NRC letter of November 2, 1987, which also requested the licensee to address thirteen potential security weaknesses that were identified during the RER. The licensee responded to that request in a January 8, 1988, letter to the NR During this inspection, the inspectors reviewed the licensee's actions to correct those weaknesses identified in the RER repor The inspector found that all items scheduled for correction by the date of the inspection had been completed. Several items were not completed but were on-schedule, and some additional enhancements

(identified by either the licensee or the NRC) were discussed with the licensee. These discussions lead to the commitments contained in the February 8,1989, submittal to the NRC (see Attachment 1). The RER findings that were considered closed by the inspectors are Itenis B, E, G, K, L and M of the RER repor Items A, C, D, F, H, I ind J of the RER report will be reviewed for closure when the commitatnts in the February 8, 1989, PECo letter are met. None of the ren aining work on these items adversely impacts upon the existing securitj program or constitutes a violation of NRC requirements. The come.itment dates, which were discussed with the licensee during the in'pection and are documented in the February 8, 1989 PECo ~etter, are considered acceptabl . Conclusion Based upon reviews, interviews, and observations conducted during this inspection, the NRC team concluded that the licensee's security program has undergone extensive modifications that have resulted in significant improvements. The efforts expended by licensee management to bring the program to its current status are noteworthy, and required a sincere and dedicated management commitment to an effective security progra The organizational and personnel changes made by the licensee, and the new security force contractor,,have also had a significant impact on upgrading the security program. Morale and professionalism in the entire security organization were found to be very high, in marked contrast to that which had previously existed. The licensee's Shift Security Assistants were also found to be notably more knowledgeable of their duties and responsi-

/ Cities snd exhibited more confidence in their abilities than previousl Proper licensee oversight of the program, and the performance of the contractor and the security force was apparen The licensee was found to be implementing an effective and performance-oriented, rather than merely a compliance-oriented program. All members of the security organization interviewed exhibited a better understanding

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of the objectives of a nuclear power plant security program and were working as a cohesive unit with a common goa There were no indications of a complacent attitude, either within the )

security organization or with licensee management. The licensee realized ;

that there was still more to be accomplished, and appeared to be on a path

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to make further improvements and program refinements. Planning and scheduling for the remaining work had been essentially developed and implementation was in progres The existing program is sound and comparable to effective security programs being implemented at operating nuclear station . Exit Meeting f i

The inspection team met with those licensee representatives and others indicated in Paragraph 1 on January 27, 1989, to summarize the scope and findings of the inspection. The licensee was requested to provide to the NRC, in writing, firm commitments dates for the completion of work on those remaining open items that were identified by the team members during the inspection (submitted on February 8,1989). The licensee was also requested to submit those commitments as an attachment to the current NRC-approved security plan. The licensee agreed to the request I

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