IR 05000289/1987015

Partially Withheld Safeguards Insp Repts 50-289/87-15 & 50-320/87-11 on 870810-14 (Ref 10CFR73.21 & 2.790(a)).No Noncompliance Noted.Major Areas Inspected:Security Plan & Implementing Procedures & Security Organization & Audits

ML20236K166
Person / Time
Site:	Three Mile Island
Issue date:	10/19/1987
From:	Keimig R, Lancaster W, Madden T, Galen Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20236K160	List: IR 05000289/1987015 ML20236K158
References
50-289-87-15, 50-320-87-11, NUDOCS 8711090131
Download: ML20236K166 (7)

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U.S. NUCLEAR REGULATORY COMMISSXON REGION I ,_;;.t a y, ~

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Report No /87-15 50-320/87-11 R.Ke/m)

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DPR-50 License Nos. DPR-73 Licensee: GPU Nuclear Corporation 100 Interpace Parkway Parsippany, New Jersey Facility Name: Three Mile Island Nuclear Station, Units 1 and 2 Inspection At: Middletown, Pennsylvania Inspection Conducted: August 10-14, 1987 Type of Inspe tio - Soutine Unannounced Physical Security Inspectors: / Mu

'G. C. Smlth, Safeguards Specialist (O / 7!f 7

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W. K ucu n 10 / 14 / 8 7 W. Lancaster, Phy al Security Inspector date '

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T). Madden, Physical Security Inspector lC /? I

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Approved by: .

/# /9' Y f.R.KeElg, Chief feguards Section date Nuclear Materials ety and Safeguards Branch Inspection Summary: Routine Unannounced Physical Security Inspection on August 10-14,1987 (Report No. 50-289/87-15, 50-320/87-11)

Areas Inspected: Security Plan and Implementing Procedures; Security Organi-zation; Security Audits; Records and Reports; Testing and Maintenance; Locks, Keys and Combinations; Physical Barriers (Protected and Vital Areas); Emergency Power Supply; Lighting; Assessment Aids; Access Control (Personnel, Packages and Vehicles); Detection Aids (Protected and Vital Areas); Alarm Stations; Communications; Personnel Training and Qualifications; and Protection of Safeguards Informatio Results: The licensee was found to be in compliance with NRC requirements in the areas examine PDR ADOCK 05000289

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DETAILS Key Personnel Contacted

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i H. Hukill, Vice President and Director of TMI-1 l J. Knubel, Director of Security {

D. Laudermilch, Support Training Manager J. Stacey, Security Manager, Unit 1 ]

R. Stintzcum, Security Manager, Unit 2 ]

C. Incorvati, Audit Manager C. Smyth, Licensing Manager i 0. Shalikashvili, Plant Training Manager l

R. Conte, USNRC Senior Resident Inspector The inspectors also interviewed other GPUN employees during the inspectio . Followup on Regulatory Effectiveness Review Findings On June 9-13, 1986, the NRC conducted a Regulatory Effectiveness Review !

(RER) at Three Mile Island Nuclear Station, Unit 1. The report of the {

RER findings was issued by NRC on January 5,1987. On May 6, 1987, GPUN j responded to the RER findings with corrective actions to be taken, where i appropriate. GPUN's response to the RER findings is currently being !

evaluated by NRC-NRR. Af ter that evaluation, the proposed corrective actions will be reviewe . Security Plan and Implementing Procedures The inspectors confirmed, by a review of the NRC-approved physical [

security plan (security plan) and implementing procedures, that the licensee's security program was being carried out in accordance with i the commitments contained in the security program plan . Security Organization The inspectors confirmed that the security force was manned a'.i committed to in the security pla . Security Program Audits  :

The inspectors verified that an annual audit of the security program, as committed to in the security plan, was conducted by GPUN Quality Assurance Division, which is organizationally. independent from securit The audit ,

results were addressed to the GPUN Corporate Vice-President for Adminis- !

tration, organizational 1y one level higher than that having responsibility

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for day-to-day plant security, and copies were provided to other respon-

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sible management personnel. The inspectors verified that audit results are retained for a period of five (5) years, as committed to in the security plan.

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. 3 The audits were found to be thorough and complete and addressed all' facets of the security program. Inspection of backup documentation confirmed that the last audit was comprehensive in both scope and dept . Record and Reports The inspectors determined that the licensee was maintaining records and reports as required by the security plan. This determination was based on a review of: protected area and vital area patrol logs; security -

equipment surveillance logs; 10 CFR 73.71 event reports; security force incident reports; alarm response records; access authorization records; security force training records; and security systems maintenance record .

l Testing and Maintenance j

The inspectors determined that the licensee was meeting the commitments of the security plan concerning testing and maintenance of security systems. This determination was based on: interviews with Instru-mentation and Control (I&C) technicians and security force personnel; observation of security force personnel conducting functional tests of search equipment; observation of I&C technicians performing maintenance on search equipment; and a review of records documenting I&C maintenance and security force functional test . Locks, Keys, and Combinations The inspectors determined by observation that the locks, keys, and combinations used to control access to protected areas, vital areas, and Safeguards Information are appropriately protected and controlled j to prevent compromis . Physical Barriers - Protected and Vital Areas The inspectors determined that protected and vital area barriers were installed and maintained in accordance with the security plan and that they were adequate for their intended purpos . Security System Power Supply The inspectors reviewed the systems that provide backup power for the I security systems and the accompanying test and maintenance procedure J This review indicated that the systems and test procedures were consist-ent with those committed to in the. security plan. The inspectors l j

verified through record review and interviews with licensee maintenance personnel that the backup power system is automatically activated upon loss of primary power and that the power transfer is accomplished without degrading the security systems. The security system backup power supply

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. 4 is loaded to 83% capacity when powering the security related system This was determined by the' inspectors through a review of load-test -

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1 Lidhting

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The inspectors determined that the' lighting in the isolation zones and within the_ protected areas was as committed to-in the security plan. .The:

lighting was determined, by observation, to be sufficient to monitor and

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observe persons and activities in the areas.

12. Assessment Aids The inspectors verified that the assessment aids were installed and operating in accordance with the security plan. Proper operation of the assessment aids was verified by the inspectors during both daylight an night hours.

13. Access Control - Personnel

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The inspectors determined that the security force was controlling access, of personnel as committed to in the security plan. This determination was i based on observation of personnel being processed into the' protected area - -

at the main and Unit 2 access points and a review of access authorization records for protected and vital areas.- I l

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Access Control - Packages

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1 The inspectors determined' that the licensee was search'ing packages;and hand-carried items entering the protected areas as committed to in th security plan. This was based'on review of procedures and observation'of both hand-carried and vehicle-delivered packages being processed into th j protected are j

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15. Access Control - Vehicles The inspectors determined that the security force was conducting vehicle searches and controlling vehicles in the protected area as committed to ;

in the security pla The inspectors made this determination based on '

observation of vehicles being processed into the protected area and a review of vehicles located within the protected area compared to the licensee's designated vehicle lis . Detection Aids - Protected Areas The inspectors deterained .through record reviews, inspector requested penetration tests, and interviews with I&C technicians that the perig.eter intrusion detection system (PIDS) was capable of detecting attempted pene-trations through the isolation zon During the course of this inspection, i the inspectors observed the ongoing installation of a new PIDS for Unit i The licensee had committed to the installation'by December 31, 1987. .The ,

inspectors were informed that installation would be complete and the system would be operational by August.19,~198 The inspectors'also reviewed the zone configuration and determined it to be adequate to ensure complete perimeter coverage as. committed to in the security pla . Detection Aids - VA

~ The inspectors verified that the licensee had intrusion detection systems capable of detecting attempts to gain unauthorized access to vital area The inspectors observed tests on a random sampling of vital area door ,

intrusion and tamper alarms. All alarms that were tested' performed.in r

accordance with the manufacturer's specification .. --

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DISCLOSME,IT 15 !MTEMT!0IMLLY LEFT BLAN This matter will be discussed with NRR Headquarter ~

1 Alarm Stations The inspectors observed the operation of both the CAS and SAS. Operation of the alarm annunciators, assessment aids, and communications equipment was consistent with the security plan. This equipment was adequate and appropriate for its intended purpos ,

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During the review of alarm station operations, the inspectors noted that there was no indication in either alarm station when the security system i was operating on backup power, however, this is not committed to in the security plan. This matter will be discussed with NRR Headquarter .

19. Communications The inspectors verified that both the CAS and SAS were equipped with appropriate hard wire and wireless communications capabilities. The ,

inspectors confirmed that both systems were operational and that both I locations were independently capable of maintaining continuous communi-cations with all required personnel. This was observed during the course of the inspection, when the primary hard-wire trunk. line was lost. The security force demonstrated its ability to maintain continuous communica-tion with on-site members of the security force and with law enforcement 4 agencies. The primary hard wire trunk line was restored prior to the '

conclusion of the inspection. All means of communications were found to- i be adequate and in accordance with the security plan commitment !

2 Personnel Training and Qualification - General Requirements The inspectors interviewed a number of security personnel to determine their knowledge of duties and responsibilities and their ability to '

perform tasks in accordance with the NRC-approved Training & Qualification (T&Q) Pla The personnel included a random sampling of armed and unarmed officers, shift corporals, shift sergeants, and CAS/SAS operators. In all cases the security personnel interviewed by the inspectors demonstrated appropriate knowledge and ability to perform their assigned tasks. The inspectors also attended an ongoing training session and confirmed, through document review and observation, that the instructors possessed appropriate qualifications, that the training was professionally conducted, and that the training facilities were appropriate to the training being conducte The inspectors randomly selected fif teen names of security force members in order to review their training records. Representatives of the licen-see stated that they could provide only computerized training " resumes" on each individual but could not readily provide the source documents to validate the data on the resumes. The inspectors then selected three names in order to audit the source documents to ensure that they were appropriately reviewed and signed by security management as stated in paragraph 2.2.4 of the licensee's NRC-approved T&Q Plan. The inspectors were informed that source training records were not filed-by discipline or by an individual's name, nor were they maintained in.a single locatio Personnel in the licensee's training department provided the inspectors with the locations of the requested documents for the 'three selected individuals. The inspectors determined that those documents were located in sixty seven different places in three physically separated locations:

the training center; the microfiche center; and the document / safeguards vault. It was estimated by licensee personnel that it would take up to 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> for the inspectors to retrieve and review the source training records for each individual selected. Licensee personnel stated that if

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the inspectors identified ten security personnel on Monday morning and asked to see the source training records that it would be difficult to produce the records by Friday of the same wee The inspectors expressed concern over the retrievability of the training records, the accuracy of the resumes, and the auditability, by licensee personnel, of these records. The licensee stated during the exit meeting that the security training record retrieval system would be reviewed in an effort to facilitate retrieval and auditing. Because the review of source training records was not possible during this inspection, this is considered to be an unresolved item (50-289/87-15-01; 50-320/87-11-01).

Security training records will be reviewed during a subsequent inspectio . Physical Protection of Safeguards Information The inspectors determined that the licensee protects " Safeguards Infor-mation" as required in 10 CFR 73.21. This was based on: review of corporate and site procedures; inspections of storage areas and cabinets used to store Safeguards Information; and, inspections of Safeguards Information in us A review of the licensee's corporate procedure no.1000-ADM-1510.0, titled

" Protection of Safeguards Information," revealed that (1) the procedure

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l did not address storage of Safeguards Information on diskettes used in word processors and (2) the procedure did not address storage of type-writer ribbons used for typing Safeguards Informatio The licensee agreed to revise the corporate procedure to include those I provision A review of the site procedures by the inspectors found that they contained the appropriate provision . Exit Interview The inspectors met with the licensee representatives listed in paragraph 1 at the conclusion of the inspection on August 14, 1987. At that time, the purpose and scope of the inspection were reviewed and the findings were presente At no time during this inspection was written material provided to the licensee by the inspectors.