IR 05000277/1993023

Insp Repts 50-277/93-23 & 50-278/93-23 on 930913-17.No Violations Noted.Major Areas Inspected:Security Audits, Detection & Assessment Aids,Access Control of Personnel, Packages & Vehicles,Vital Key Area Control & Alarm Stations

ML20058Q331
Person / Time
Site:	Peach Bottom
Issue date:	10/13/1993
From:	Albert R, Mccabe E, Ratta A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20058Q295	List: IR 05000277/1993023 ML20058Q294
References
50-277-93-23, 50-278-93-23, NUDOCS 9310260148
Download: ML20058Q331 (8)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION I

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' Report Nos.:'- 50-277/93-23

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'50-278/93-23

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Docket Nos.: 50-277

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-r 50-278 i

License Nos.:DPR-44

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DPR-56 Licensee:

Philadelohia Electric Comnany

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2301 Market Street

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Philadelphia. Pennsylvania 19101-Facility Name:

Peach Bottom Atomic Power Station. Units 2 and 3 i

Inspection At:

' Delta. Pennsylvania Inspection Conducted:

September 13-17. 1993 Inspectors:

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- A. Della Ratta, Physical Security Inspector Date nMbY

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R. 3. Albert, Pf ysical Security Inspector Date Approved By:

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/E, C. Medab6 Off f, eguards Section Date Division of Ra a on./ ety and Safeguards

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Areas Insnected: Management Support, Security Program Plans, and FFD and Security Audits; Protected and Vital Area Physical Barriers; Detection and Assessment Aids; Protected and Vital

' Area Access Control of Personnel, Packages and Vehicles; Vital Area Key Control; Alarm Stations and Communications; Power Supply; and Security Training and Qualification.

Results:. The licensee's FFD and' security programs 'were found to be directed toward public health and safety and in compliance with NRC requirements in the areas inspected. However,

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a weakness was identified during a review of FFD records.

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1-9310260148 931018

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S DETAILS

1.0 ~

Key Personnel Contacted 1.1

Licensee and Contractor Personnel

• G. Edwards, Plant Manager

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• G. Gellrich, Senior Manager Operations - Peach Bottom Atomic Power Station

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• G. Bird, Director - Nuclear Security

• R. Smith, Regulatcry Engineer

• R. Alexander, Assessor, Nuclear Quality Assurance

• T. Wasong, Manager, Experience Assessment

• D. Meyers, Director, Site Support Services R. Bonner, Director, Occupational Health and Safety W.' Syska, Physician Assistant W. Trump, Analyst

M. Utz, Chief Security Coordinator

• J. Slaymaker, Supervisor, Personnel Processing H. Owrutsky, Nuclear Security - Technical Engineer

• J. Robinson, Security Force Supervisor - Protection Technology Inc. (PTI)

R. Shrake, Technician, PTI K. Hamilton, Technician, FI'I A. Black, Technician, PTI D. Sarley, FFD Program Manager 1.2 U.S. Nuclear Regulatory Commissign

• R. Lorson, Resident Inspector

• Indicates those present at the exit interview.

2.0 Mananement Snooort. Security Pronram Plans and Audits 2.1 Mananement Sunoort Management support for the licensee's physical security program was determined to be consistent with program needs. This determination was based upon the inspectors' review of various aspects of the licensee's program during this inspection, as documented in this report.

i Security program enhancements made since the last physical security inspection in March 1993 (50-277/93-07 and 50-278/93-07) were as follows:

upgraded the security computers to enhance performance; e

installed new intrusion detection equipment for a perimeter zone; e

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installed a new sally port to enhance vehicle processing.

e The following observations were made by the inspectors:

The site security force totalled 89 (plus 12 additional temporary officers e

for outage support) on September 17, 1993; e

The attrition rate in 1993, through September 17, was less than 5 percent; and The security program continued to be actively supported by other plant e

groups, and effective communication channels existed among the security group (both licensee and contractor) and other plant groups.

Based upon review of the security program and the efforts undertaken to upgrade

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and enhance it, the inspectors determined that the program continued to receive appropriate management attention and support.

2.2 Security Procram Plans i

The inspectors verified that changes to the licensee's Security and Training and Qualification Plans, as implemented, did not decrease the effectiveness of the j

respective plans, and had been submitted in accordance with NRC requirements.

2.3 Andits.

The inspectors reviewed the annual security program audit report and verified that the audit had been conducted by the licensee's nuclear quality assurance (NQA)

group in accordance with the NRC-approved physical security plan (the Plan).

The NQA audit team included two security specialists from another plant. The use of personnel with security expertise appeared to improve the scope and effectiveness of the audit. The audit report (No. A0730368), dated June 28, 1993, documented one deviation. The inspectors' review indicated that the audit was comprehensive in scope and the results were reported to the appropriate levels of management. A review of thelicensee's immediate response to the audit finding indicated that proposed corrective action was adequate and that the program was being properly administered.

To supplement the NRC-required annual program audit, the licensee was continuing to conduct a self-assessment program. The assessments were reviewed by the inspectors and were determined to be thorough and objective. Appropriate corrective actions were noted to have been recommended and implemented, as necessary.

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4 The inspectors also reviewed the licensee's annual FFD Audit Report (No.

A0745484), dated July 22,1993. The NQA Audit Team included a specialist with expertir in forensic technology and medical review officer activities. The audit repor, deumented four deviations and four recommendations, none of

.which we - indicative of programmatic weaknesses.

The audit was comprehensive in scope, and the results were reported to the appropriate level of management. A review of the licensee's response to the audit findings indicated that proposed corrective actions were adequate and that the program was being proper'; administered.

In addition to the review of the licensee's FFD audit report, the inspectors randomly selected and reviewed the FFD testing records of 10 individuals. Based on this review, the inspectors determined that, in accordance with licensee FFD procedures, one individual had been placed in a follow-up testing program as a result of being tested for-cause stemming from alleged aberrant behavior While the individual's for-cause test results were negative, licensee procedures required

- the follow-up testing program for a minimum of 3 months. However, this individual had been in the follow-up testing program for more than a year. When the inspectors questioned why this individual had been in the program for that

- period, the licensee stated that his retention in the program for greater than

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3 months was an error.

.Upon further review, the inspectors determined that the licensee's FFD procedures did not have a provision to terminate follow-up testing after the minimum requirements had been met nor did they have a provision for extending the minimum program requirements. The licensee committed to revise its FFD procedures by October 1993 to incorporate the necessary provisions.

The inspectors also determined that this individual's case was not well documented.

When asked, the licensee indicated that all the pertinent documentation on the case was in the individual's medical file. However, that file contained only limited information. Documentation indicating the reason for the for-cause test, decisions made by the FFD program personnel affecting the case, etc. were not contained in that or any other file made available to the inspectors during the inspection. The licensee agreed that better documentation of FFD cases was necessary. The lack of proper documentation, as well as the procedural inadequacies, contributed to the individual being retained in the program for the extended period. The licensee promptly conducted a 100 percent audit of other similar cases; no deficiencies were identified.

The inspectors also found that, even though for-cause testing and the follow-up testing program were included in the FFD-training lesson plans and each

employee is provided a copy of the FFD policy (per the licensee), available documentation in this case indicated that some of the FFD program personnel and l

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the individual may not have known that a person tested for-cause would automatically be placed in a follow-up testing program for a minimum of 3 months. The licensee also agreed to review this and take action, if necessary.

No safety concerns or violations of. regulatory requirements were found during the inspectors'. review of this case. ' This is an Inspector Follow-up Item (IFI 50-277/93-23-01 and 50-278/93-23-01) and will be reviewed during a subsequent

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inspection.

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Protected and Vital Area Physical Barriers. Detection and Assessment Aids L

3.1 frotected Area (PA) Barrier

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The inspectors conducted a physical inspection of the PA barrier on September 13 and 14,1993. The inspectors determined by observation that the barrier was installed and maintained as described in the NRC-approved physical security plan (the Plan).

3.2 PA Intrusion Detection Aids The inspectors observed the licensee perform the weekly surveillance test (ST) of the perimeter intrusion detection aids on September 14,1993, and determined that they were installed, maintained and operated as committed to in the Plan.

3.3 PA and Isolation Zone Linhtimr The inspectors conducted a lighting survey in the PA a:A isolation zones on September 15, 1993, from approximately 8:00 p.m. to 10:00 p.m. to determine if lighting levels met the minimum requirements of 0.2 fetcandles.

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inspectors were accompanied by the licensee's Chief Security Coordinator and the contractor's Security Force Supervisor. The inspectors determined by observation and use of the licensee's calibrated light meter that the station's lighting system met or exceeded the minimum requirements. The inspectors also found that the isolation zones were maintained clear and sufficiently illuminated to permit observation of activities on both sides of the PA barrier.

3.4 Assessment Aids The inspectors observed the PA perimeter assessment aids during day and night

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periods and determined that they were installed, maintained and operated as committed to in the Plan.

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'Yital Area (VA) Banners The inspectors conducted a physical inspection of selected VA barriers on September 15,1993. The inspectors determined by observation that the barriers were installed and maintained as described in the Plan.

3.6 YA Detection Aids The inspectors observed testing of selected VA detection aids on September 15, 1993, and determined that they were installed, maintained and operated as committed to in the Plan.

There were no deficiencies identified in these areas.

4.0 Protected and Vital Area Access Control of Pemnnel. Packages and Vehicles 4.1 Personnel Access Control The inspectors determined that the licensee was exercising positive control over personnel access' to the PA and VAs. This determination was based on the following: -

4.1.1 The inspectors verified by observations that personnel were properly identified and authorization was checked prior to issuance of badges and key cards.

4.1.2 The inspectors verified by observations that the licensee was implementing a search program for firearms, explosives, incendiary devices and other

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unauthorized materials as committed to in the Plan. The inspectors observed both plant'and visitor personnel access processing during peak and off-peak _ traffic periods on September 14 and 15,1993.

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inspectors' interviews with members of the security force and licensee security staff included questions to determine their understanding of personnel access procedures.

4.1.3 The inspectors determined by observations that individuals in the PA and VAs displayed their access badges as requirM.

4.1.4 The inspectors verified through a review that the licensee had escort procedures for visitors into the PA and VAs.

4.1.5 The inspectors verified through a review of procedures that the licensee i

had a mechanism for expediting access to vital area equipment during

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4.2 Package and Material Access Control n

The inspectors determined that the licensee was exercising positive control over packages and materials that were brought into the PA at the main access control portal. The inspectors reviewed the package and material control procedures and found that they were consistent with commitments in the Plan. The inspectors

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also' observed nc;kage and material processing and interviewed security force

members (SFMs) and the licensee security staff about package and material control proce( rs.

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4.3 Vehicle Access Control The inspectors determined that the licensee properly controls access to the PA.

The inspectors determined that the vehicles were properly authorized prior to being allowed to enter the PA, with identification being verified by an SFM. The

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inspectors also reviewed the vehicle search procedures and observul that at least two SFMs control vehicle access at the main vehicle access portal. These procedures were consistent with the commitments in the Plan. On September 14 and 15,1993, the inspectors also observed vehicle searches and interviewed SFMs and the licensee's security staff regarding vehicle search procedures.

There were no deficiencies identified in these areas.

5.0 VA Key Control On September 15, 1993, the inspectors reviewed the licensee's procedures for VA key control and also conducted an inventory of all VA keys. The VA key inventory included all VA keys issued to the Operations and Security Departments. All keys were accounted for during the inventory and the procedures were deemed adequate to ensure proper key control. No deficiencies were identified.

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6.0 Ala_rm Stntions and Communications The inspectors observed h operations of the Central Alarm Station (CAS) and the Secondary Alarm Station (SAS) and determined that they were operated as committed to in the Plan. CAS and SAS operators were interviewed by the inspectors and found to be knowledgeable of their duties and responsibilities. The inspectors verified that CAS and SAS operators do not perform any operational activities that would interfere with assessment and response functions.

The inspectors also verified that the licensee conducted communications checks with the local law enforcement agency as committed to in the Plan. No deficiencies were notel.

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7.0 Emercency Power Supply The inspectors verified that there are several systems (batteries, dedicated diesel generator within a VA, and plant on-site AC power) that provide backup power to the

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The inspectors reviewed the test and maintenance records and procedures for these systems and found that they were consistent with the Plan. No

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Security Traininn and Oualification

. The inspectors randomly selected and reviewed the training and qualification (including physical) records for 11 SFMs. The firearms requalifications records were also reviewed for armed SFMs and security supervisors in the sample. The inspectors determined that

.the training' and qualification had been conducted in accordance with the Security

. Training and Qualification (T&Q) Plan and that it was properly documented.

Several SFMs were interviewed to determine if they possessed the requisite knowledge and ability to carry out their assigned duties. The interview results indicated that they were professional and knowledgeable of the job requirements. No deficiencies were noted.

9.0 Exit Interview The inspector met with the licensee representatives indicated in Paragraph 1.0 at the conclusion of the inspection on September 17,1993. At that time, the purpose and scope of the inspection were reviewed and the findings were presented. The licensee's commitments regarding the FFD program, as documented in this report, were reviewed

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and confirmed with the licensee. The licensee acknowledged the inspection findings.

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